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HomeMy WebLinkAbout19970722 Ver 1_Complete File_19950918particulate organic material (floodplain detritus) to phytoplankton, as open water replaces existing vascular plant material sites. The fishery resources of the site will be impacted by the proposed reservoir. Fish species composition within the river systems in the vicinity of the proposed reservoir is composed of over 30 species of fish (Carter 1993), with a composition generally of bluegill (Leptomis macrochirus), warmouth (Lepomis gulosus), redear sunfish (Lepomis microlophus), red breast sunfish (Lepomis auritus), blue head chub (Noncoms letocephalus) and catfish (Ameiurus sp.). This lotic fishery resource will be replaced by a typically lentic, flat water fishery. Typical fish species of the proposed reservoir system may include bluegill, largemouth bass (Micropterus salmoides), channel catfish (Ictalurus punctatus), yellow perch (Perca flavecens) and black crappie (Pomoxis nigramaculatus). 4.0 MITIGATION The Section 404 (b)(1) guidelines of the Clean Water Act (16 USC 1344), as described in 40 CFR Part 230, state that unavoidable wetland losses resulting from projects which have completed the sequencing process may be offset by effective mitigation actions. According to the National Environmental Policy Act (NEPA) of 1969, mitigation actions should include avoidance, minimization, restoration, enhancement and compensation for unavoidable impacts. After all practical attempts to avoid and minimize wetland losses have- been accomplished, compensatory mitigation in the form of restoration, enhancement, creation, preservation and acquisition should be developed. As identified in the Memorandum of Agreement between the USACE and USEPA (15 November 1989), wetland restoration is the most desirable form of compensatory mitigation. Creation is the second most desirable form of mitigation and is generally deemed more desirable than enhancement. Acquisition of existing wetlands, while potentially significant for corridor protection and as a hedge against future development, ranks least desirable for wetland mitigation. Ideally, compensatory mitigation should be in-kind and on-site. Wetland areas at or adjacent to the project site may be restored, created or enhanced to compensate for wetland functions and values of the wetland areas impacted. However, in areas with significant topographic relief, in-kind and on-site mitigation for reservoir projects may be limited in both quantity and quality of wetlands that can be successfully restored and/or created around the periphery of the reservoir. The second priority of compensatory mitigation should be in-kind, off-site mitigation which compensates for the function and value of the 13 wetlands lost in an area as close to the project area as possible. The mitigation proposal for Randleman Lake reservoir is a comprehensive plan that includes: • on-site creation of littoral zone bottomland hardwood wetlands (107 ac) established on fields and pastures between the 683-685 ft MSL contour; • on-site creation of wet flat woodlands (132 ac) on fields and pastures between the 685-690 ft MSL contour; • on-site re-establishment of upland hardwood forest (545 ac) above the 690 ft MSL contour to the property boundary; • enlargement of the reservoir buffer zone from 50 ft to 200 ft. 4.1 Avoidance and Minimization of Impacts Impacts associated with the construction of the proposed dam and reservoir were initially avoided and minimized to the extent practicable and are described in the 404 application. Measures to minimize impacts are generally considered during the siting process and evaluation of alternative sites. During the construction of the dam and reservoir, best management practices (B1\/LPs) will be employed to minimize impacts to adjacent wetlands and aquatic systems. Specific measures to reduce erosion, and to control sediment movement will be employed to protect the water quality of the Deep River downstream from construction areas. Specific practices will include the use of upland siltation barriers and sediment traps, stream channel basins, and runoff diversion dikes, where applicable. Details for these sediment retention and erosion control measures are typically outlined in the engineering drawings for this project. Such features/structures will be inspected regularly and maintained throughout the construction period and additions or repairs will be made as necessary. Additionally, an uncleared buffer strip will be maintained adjacent to the Deep River and Muddy Creek within the confines of the cleared reservoir basin to reduce impacts to water quality and stream biota during construction. Vehicular access routes needed during construction will be minimized and restricted to specific routes to minimize disturbance to adjacent and surrounding wildlife and habitats. Construction roads as well as the sediment control features will be located on the site as required by the site's physical constraints and construction schedule. 4.2 On-Site Mitigation The compensatory on-site mitigation actions proposed for the immediate reservoir area include wetland forest creation, upland forest restoration, buffer zone management and 14 preservation, and the creation of natural littoral zone emergent wetlands which will evolve naturally. 4.2.1 Wetlands Creation and Habitat Restoration The majority of the wetlands impacted by the proposed reservoir are temporarily and seasonally flooded forested wetlands and scrub-shrub wetlands. Accordingly, wetland creation will focus on these types of wetlands. There is opportunity to mitigate for these wetland types around the periphery of the proposed reservoir in the purchased land adjacent to the proposed normal pool (683 ft MSL) that are tilled agricultural fields or pastures. These fields are expected to provide part of the onsite wetland mitigation requirements for wetland impacts resulting from the construction of Randleman Lake. During March through May 1995 reconnaissance of all mapped fields and pastures within the proposed buffer for Randleman Lake was conducted. Site visits yielded data on the existing condition of each field, approximate verification of field boundaries, inconsistencies in the existing mapping, and general information on soil suitability. All of these data were used to determine specific prescriptions for reforestation of each field. In addition, the condition of many fields was photo-documented. Some of these color photographs are included in Appendix C. Where possible, the size and boundaries of each field/pasture were verified using 1984 aerial mapping. However, many areas within the projects boundaries have changed substantially since 1984. Field and pasture areas reported in this document are based on revised boundaries resulting from this study and depicted on the revised onsite wetland mitigation area mapping (revisions dated 6/1/95). 4.2.1.1 Existing Fields and Pastures The existing fields and pastures within the proposed 200 foot buffer zone can be grouped into the following general categories: tilled field, grazed pasture, hayfield, abandoned field, and mid-successional abandoned field. Tilled fields include those areas currently cultivated and planted with row crops, and areas that were cultivated within the last year (Photo #1, Appendix C). Grazed pasture includes those areas that are fenced and show evidence of grazing by cattle. Grazed pasture may be entirely open or may have scattered trees (Photos #2 and #3, Appendix C). Hayfields are open grasslands periodically mowed for hay production (Photo #4, Appendix Q. This grouping may also include mowed residential areas. Abandoned fields are open areas that have not been tilled, mowed, or grazed for 15 approximately two to five years. These areas are generally characterized by invasion of several common early successional old field species such as broomsedge (Andropogon virginicus), goldenrods (Solidago spp.), multiflora rose (Rosa multij7ora), blackberry (Rubrts spp.), scattered eastern redcedar (Juniperus virginiana), and scattered loblolly pine (Pinnrs taeda) (Photo #5, Appendix C). Mid-successional abandoned fields include former fields and pastures that have been abandoned for over five years. These areas are characterized by the early successional old field species, sapling sized eastern redcedar and loblolly pine, and various hardwood species including sweetgum (Liquidambar styraciflua), yellow poplar (Liriodendron tulipifera), and green ash (Fraxinus pennsylvanica) (Photo #6, Appendix Q. 4.2.1.2 Littoral Bottomland Hardwood Wetlands Between the normal pool (683 ft MSL) and the saturated soil zone (685 ft MSL) zone there is an area of approximately 107 acres available for creation of forested wetlands from fields and pastures (See Table 2 in Section 4.2.1.5). Wetland creation in these areas will focus on a mixture of facultative wetland, and facultative species. Although this area will be above the normal pool of the reservoir, there will be an alteration of the soils resulting in. an increase in soil saturation from the concomitant rise of the water table adjacent to the reservoir:. The lower topographic areas within the 683-685 saturated soil zone are excellent candidates for creation of obligate to facultative wet forest wetland dominated communities. Their present condition as open lands means that they will likely evolve naturally to wetland forest, but we can actively control species composition and community diversity. Without active intervention, natural regeneration of open uplands to wetlands involves domination of opportunistic tree species such as red maple, river birch, boxelder, and black willow into monotypic "weedy" forests. Mitigation on these areas will involve the blockage of any drainage ditches, and site preparation for planting using a combination of disking, chisel plowing (see Site Preparation Prescriptions Section 4.2.1.4). Each site will be stratified by soils, topography and proximity to naturally shallow littoral wetlands. Based on an inventory of preflooded bottomlands, a planting prescription of canopy trees and understory shrubs will be developed (Table 3). Trees and shrubs will be planted at 6 x 10 foot spacing (726 plants/acre = 600 trees/acre plus 126 shrubs/acre). Planting will be mixtures of tree and shrub bare root seedlings and matched to specific hydrological strata within each site to correspond to native species mixtures in adjacent obligate and facultative wet habitats. Planting will be done following contour lines to simulate natural stem distribution and stratification. 16 Table 3: Tree and Shrub Species Recommended for Mitigation Planting in the Bottomland Hardwood (BLH), Wet Flat Woodland (WFW), and Upland Zone (U) at Randleman Reservoir. Species Status Zone Canopy Trees BLH WFW U Onercus michauxii swamp chestnut FACW x x - oak Quercus pagodifolia cherrybark oak FACW x x - Ortercus nigra water oak FACW x x - Ouercus phellos willow oak FACW x x x Quercus lyrata overcup oak FACW x x - Ottercus rubra red oak UPL - _ x Ouercus alba white oak UPL - - x Ottercus coccinea chestnut oak UPL - - x Carya spp. hickory UPL - _ x Nyssa sylvatica var swamp blackgum FACW x - - bif7ora Taxodium distichum cypress OBL x - - Fraxinus pennsylvanica green ash FACW x x - -41ttrtanus occidentalis sycamore FAC x x - rurrus serotina black cherry FACU x Celtis occidentalis . sugarberry FACW x x - r bus virginiana Virginia pine UPL - - x echinata shortleaf pine UPL - - x Understory Shrubs Alnus serrulata hazel alder OBL x x - Ilex cassine Dahoon holly OBL x x - Lindra benzoin spice bush FACW x x - Cercis canadensis redbud UPL - - x Corpus f orida dogwood UPL - x x Vaccinnium corymbosum blueberry UPL x x - OC 17 4.2.1.3 Wet Flat Woodlands Between the saturated soil zone of 685 ft MSL and 690 ft MSL there is an area of approximately 132 acres of open land in fields and pastures (Table 2). Wet flat woodland creation in this area will involve planting a mixture of facultative wetland, and facultative tree and shrub species. Although much of this area will be above the jurisdictional wetland boundary, hydric conditions will be prevalent. There will be a gradual wetting of this area from the general regional rise of the water table immediately adjacent to the reservoir and some portion of this area will become jurisdictional wetlands. It will take several years for the 7 enact nature of the wetlands to evolve, and hence these creations will not be included with the wetland t The melding of this zone with the adjacent created wetlands, however, will ensure that a true transitional forest community type will develop from obligate to facultative species at the same location. This transition forest type will also provide benefits for water quality protection and habitat corridor development around the entire reservoir margin. Mitigation will involve much of the same procedures for planting and site preparation as stated for the littoral bottomland hardwood wetlands. Table 3 lists the commercially available species that will be established. 4.2.1.4 Upland Hardwood Forest Restoration Between the 690 ft MSL and the project boundary there are 545 acres of open fields and pastures that will be restored to upland forest habitat (Table 2). Although not considered to be important in terms of "no net loss" of jurisdictional wetlands, such upland restoration is high priority for habitat protection and water quality concerns. Planting techniques and densities will be similar to those previously outlined. Species listed in Table 3 will be established to produce a facultative to facultative upland community composition. An objective of upland hardwood forest establishment is to ensure that ample hard and soft mast species are provided for wildlife in addition to reservoir water quality protection. 4.2.1.5 Site Preparation Prescriptions The site preparation for each field type will vary somewhat, but in general the planting area needs to be cleared of herbaceous and grass competition by initial mowing and herbicide application. In addition, many of the existing soils are compacted from cattle and machine 18 traffic so the fields will be deep ripped to alleviate compaction and to facilitate planting. Deep ripping of these fields will also provide the row marking for planting crews. Mowing will be accomplished using a standard "bush-hog" mower, except in certain mid-successional abandoned fields where specialized equipment may be necessary in order to clear sapling sized pines. The specialized equipment and additional time necessary for clearing rows in these mid-successional fields may substantially increase the costs of site preparation in these areas. PTRWA will consider the costs versus benefits of this additional restoration acreage prior to implementing site preparation. Herbicide applications will follow deep ripping and row marking and will consist of an early spring application of Glyphosate (Roundup) at 1 ounce active ingredient per acre combined with Sulfometuron Methyl (Oust) at 2 ounces active ingredient per acre. The herbicide mixture will be applied prior to planting in 24 inch bands centered over the planting rows. Deep ripping will be implemented using a tractor and ripping bar(s) attached to the 3-point hitch. The soil will be ripped to a depth of 12 to 24 inches to facilitate planting and mark the planting rows. Planting rows should follow the natural field contours as much as possible. Fields will be marked prior to ripping to ensure row spacing (10 feet) is maintained. A tool bar with one or more ripping bars and a 10 foot extension on either side can be set up. The 10 foot extensions serve as a template to maintain the proper row spacings. Planting will follow site preparation in the spring, generally from late-February to mid-April. Since these sites will not be irrigated, planting should be scheduled as early as possible to ensure maximum success. Nutrient analysis of soils will be performed prior to planting to facilitate fertilizer prescriptions to optimize seedling growth. Fertilizers will be banded at the time of ripping to ensure proper incorporation into the soil and to reduce any effects of fertilizer movement downslope. 19 4.2.1.6 Reforestation areas Table 2 summarizes the restorable condition of the field, and provides specific for each field, categ 1z s :s where appropriate. the existing Table 2: Summary of rable Fields and Pastures in 200 foot r" BM-e? ne at Randleman Lake Field ID Exist. Cove Area f,2 Area 2 Area 2 Soil Comments & r ( ) (ft ) (ft ) T e Regeneration T e to 685) (685-690 (690+ 1-1 A 16120 200 29140 I\ B sovbean field 1-2 E 41540 164921 36581 MhB C redcedar, V.pine bioomsed e 1-3' B/E 28520 32860 233742 WkC/Ch rose, blackberry & some sweet um 2-IA" B 11160 2480 28520 Ch/WkC scattered V. pine & redcedar 2-1B" B 97341 98580 249862 EnB/Chi scattered V.pine WkC/Mh$ .' & redcedar 2-2* 4/C 17980 24800 1860 WkD/Ch, boxelder along Z? I" roadwav 3-4 D 0 8680 70680 V*E fallow field 3-3* A 31000 47120 11 160 Cli / tilled field 3-2* C 115321 70680 71301 Ch mowed ass 3-1 C/D 19840 26040 11780 W part mowed field w/boxedler & blackberry 4-1 A/D 8680 7440 47120 WkE most) tilled 4-2* C/D 39060 11160 163061 WkE mowed grass w/ house & scattered ine/cedar/hdwds 4-3" C 4960 2480 12090 EnC disturbed area 5-1 C 26040 33480 75021 Co/WkD mowed ass 5-2* B 57660 80600 196543 MhC2/ scattered large WkE shtlf & loblolly 5-3* C/D 0 5580 379133 WkE/EnC broomsedge, rose, & blackberry 5-4* D 0 4960 15035 WkE pond/bldg. w/ scattered trees 5-5 A 37200 47120 148182 EnC fallow w/b(d . 5-6* A 5580 7440 22940 EnC fallow com 6-1 C 739047 251721 161823 EnD/WkE golf course /Co w/scattered trees 6-2 B/D 58280 37820 48051 EnD/Co scattered trees & blackberTy 7-1* C/E 73160 70060 268463 MliB2/Co bldgs & fencerows dense loblolly in 50% of area 7-2 D 6820 4960 16740 WkE/Co fallow field w/ some hdwd. re en 7-3• B 70042 68800 110400 WkD scattered trees/ remove road 7-4 E 5742 8145 114144 WkD slitlf/lob pine. sweetgum, maple, poplar, boxelder, some oaks 7-5* E 0 0 79050 WkC loblolly+hdwds. w/ broomsedge & blackberry 7-6 B 38440 26040 284583 EnC fencerow bisects 7-7 B 6200 11160 235292 EnD terraced Field 7-8' B 10312 22000 254000 1leC/VaB move fencelines 20 7-9* B 11261 14000 168000 HcC/VaB WkE Ig. trees. move fence/bld s. 7-10* B 13501 11200 127200 WkE remove bldg. 7-11 E 16401 12000 83200 WkC/WkE saplings of lob pine, swectgum + blackberry, rose 7-12* D 1260 7600 48800 EnD abandoned field 8-1 B/D 32492 49200 202000 50B grazed pasture / some fallow 8-2 B 98425 229600 249200 55132/ 55C2 open pasture heavily grazed 8-3' B 17690 12000 56800 55B2 new area 8-4 B/D 2590 10000 33600 63E highly eroded w/ junk cars, trash & bld . 9-1' B 24331 24400 132000 55B2/ 55C2 powerline ROW. trailer w/ some redeedar 9-2* B/C 1890 7200 83600 55C2 residential bldgs w/ asture+woods 9-3 B/C 32603 48800 247200 5013/63C remove hse+bams 9-4 C 6520 11200 35600 5013/63C remove new house 9-5 D 1750 12800 55200 63C fallow/herbaceous 9-6* A 19812 20400 161600 50B/ 50C2 cult. field 9-7* D 11590 20000 45600 50C2 scattered trees 9-8 A 7421 9600 120000 55B2 cult. field 9-9* A/C 2970 16000 70000 63C residential w/ scattered trees 9-100 C 880 2580 23200 63E havfield 9-11* C 63682 34000 140400 55B2 residential w/ several houses + owerline ROW 9-12 A 12441 20000 130000 50C2 cultivated 9-13* B/D 10000 32800 198000 55132, 55C2 adj, to powerline art overgrown 10-1 A 63145 122000 340000 55B2 powerline ROW on edge of field 10-20 A 10800 18000 60000 55B2 new trailer lot + owerline ROW 10-30 XB I 41263 56400 270000 50B/50C powerline ROW + forested swales 1040 A 19410 18000 52800 55C2 powerline ROW bisects 10-5 A 22483 36400 278400 5013i63C winter wheat 10-6 A/C 97057 78400 560800 55B2 remove house. sheds, pool 10-7 A 16802 26000 192800 63B lencerow bisects 10-8* VC 33114 24800 376400 55B2 residential & cultivated 10-9* D 0 0 62000 55132 owerline ROW 10-10 A 16731 22000 67600 55B2 winter wheat 10-11 owerline ROW 10-12* D 0 0 62310 55B2 fallow field 11-1 A/B/D 25888 60000 629600 55B2/ 55C2 winter wheat + fallow field w/ ponds. barns II-IA* B 11941 27600 64000 55B2 gazed pasture ll-iB0 A 12870 15200 26800 55B2 winter wheat 11-2* A/C 89098 118000 580000 55B2 winter wheat + residential area 11-3 A 73172 96800 86400 55132 tilled 11-4 A 26424 24400 390000 55132/ 50C/50B tilled 11-5 A 107422 171200 436400 63B/63E tilled/mowed 11-6 C 0 0 103541 55B2 hayfield near new houses 21 12-1 D 14880 21700 304423 50B2 broomsedge. blackberry, sonic hdwds. 12-2 A 65722 58900 205841 5582/ winter wheat 55C2 12-3 B/C 25420 19840 42160 55B2/ behind davis 55C2 farmhouse 12-4 B/C 43712 39060 205220 55B2/ hay/grazed 55C2 124A B/C 21200 6800 64000 5582 havfeld 12-5 A 8680 42160 24800 50B2 com stubble 12-6 A 41543 79980 176080 50B/ com stubble 50C2 12-7 A 1240 31000 37200 50B com stubble 12-8 A 3410 6820 36580 50C2 com stubble 12-9* A 5580 3720 98581 50C2 com stubble 12-10 A 37976 40300 217622 5082 mostly tilled 13-1 B/C 9491 20800 74800 20B2 grazed areas + residential 13-2 C 16612 29200 156000 2082 hayfield 13-3 A 19581 12800 97200 50B2 corn stubble 13-3A A 1860 16740 9920 50B2 corn stubble 13-4 A 24617 58400 131200 50B2 corn stubble 13-5 B/C 47285 158800 364000 16D pasture, woods, residential areas 13-6• B/C 54254 71200 325600 2082/ pasture, pond, 20C2 residential area 13-7 AID 51063 108800 226400 20B2 fallow field 13-8 C 118147 122000 452400 20B2/ hayfield, 20C2 remove road? 13-9• C 2760 6800 51200 16C residential w/ scattered trees 13-10• C 60215 54400 139600 16C/16B hayfield w/ owerline ROW 13-11 A/C 5200 15200 66400 45B2/ tilled field w/ 45D houses/farm 13-12' D 4581 15600 78400 2082 fallow field w/ broomsed e 14-1 B 28241 34000 69200 20B2 grazed pasture w/ redcedar, rose, & some hdwds. 14-1A B 13200 5600 2800 20B2 pasture 14-2 D 24952 4000 202000 50B abun. sweetgum + some poplar 14-3 D 35430 1200 48000 20B broomsedge + blackber v 14-4 D 8454 800 116400 20B broomsedge + blackberry 14-5 C 13350 25200 56000 20C mowed grass, tower ROW? 14-5A' C 7440 5580 22010 20C ass 14-6 C 10820 8400 62000 20D mowed grass tower ROW? 14-7• B/C 34119 36000 200000 20B2 farm w/ house, barns, pasture, scattered trees 14-8 E 11031 400 135200 20B2/ dense redcedar& 20C loblolly regen 8.10' tall 14-9 E 36942 25600 134000 20C gas line ROW pole-sized swtgum & pine w/ herbs 14-10 A 16395 400 544000 20B2 ag field w/ powerline ROW & residential areas l4- A 0 0 436174 20B2 ag field l0A' 22 14-11 B/C 3200 4800 152000 20C2/ SOB pasture w/ residential 14-12* B 68161 24000 12000 20132 pasture near hse 15-1 B Entire field is downstream from proposed dam location restorable area = 161201 45B/74D open pasture bisected by werline ROW 15-2 B Entire field is downstream from proposed dam location restorable area = 564205 45B/74D pasture bisected by pipeline ROW 15-3* C Entire field is downstream from proposed dam location restorable area = 159341 45B hayfield 16-1 D 25420 23560 196852 20C2 fallow a field 16-2 B/C 24180 44020 172982 45C hayfield/pasture w/some trees 17-1 C 4240 64000 88000 55B2 hayfields + residential bld s 17-2 C 37168 119200 623600 5OC2 hayfields w/ misc. bld s. 17-3 B/D 4621 10000 172000 50132/ 50C2 overgrown pasture w/ rose, cedar, & hdwds. 17-4 B 93656 88000 412000 50132 pasture w/ trees 17-5 B 1250 18000 78400 50132 pasture 17-6 B 8881 16800 138000 50132 pasture 17-7* B 28233 48000 244000 50B2/ 63E pasture w/ mature trees & shrubs 17-8* BX 61624 68000 336000 5082 field w/ scattered pines & redcedar 17-9 C 17391 144800 8000 55132 hayfield 17-9A* C 0 0 22630 55132 hayfield 17-10 E 9920 5600 44000 55C2 dense hdwd. & redcedar re en. 17- I0A* E 0 0 72540 55C2 aban field 17-11 B 32983 24000 240000 63E pasture w/ scattered trees 17-12 A 62482 24000 164000 55132 corn stubble 17-13 B 4000 16000 64000 50B2 pasture 17-14* B/C 3121 18000 88000 50B2 residential & other bld s 17-15 B 20000 56000 104000 50C2 pasture 17-16 B 4491 32000 112000 20B2 pasture 17-17* D 7800 200 194000 20B2 fallow field 18-1* B/C 24800 22320 139811 55B2 asture/havfid 19-1* A 35960 68200 144152 55B winter wheat 19-2* A 52080 117181 213902 55B winter wheat + fencerow 19-3* B 32240 44020 109431 50C pasture w/ woods 19-3A* B 1240 2480 252032 50C Pasture 194* B/C 29760 50840 266913 55C2/ 56B2 pasture w/ scattered trees 19-5* B/C 34720 58900 175152 56132 hay/pasture 19-6 E 9920 8060 64480 56B2 sapling re en 19-7A* B 52080 76260 371385 55C2 pasture w/ scattered trees 19-7B* B 50840 79360 358985 55C2 pasture w/trees 19-7C* B 44640 62000 251103 55C2 pasture w/trees 19-8 A 48360 65720 252033 50132/ 50C scraped field, eroding w/ dumping activity 19-9 A 16740 13020 72541 55B2 winter wheat 19-10* A 19840 27280 8990 5582 tilled field 20-1* C 2480 3720 14260 63C hayfield 23 20-2' D 10000 10000 20000 63E aban field .v/ herbaceous 20-3' D 35000 15000 10000 63C/63E overgrown field 204• D 5580 6820 58590 5013/63C rcdcedar+ inc re en. 20-5' B 37200 59520 261333 63C pasture w/ wet 20-6• A 7440 23560 101681 63C winter wheat 20-7' A 1860 5580 73160 63C tilled field ?0.8' D 0 13020 70060 5513/63C fallow field TOTALS (area) 4661375 (107ac) 5746868 (132ac) 23731484 545ac) ' indicates a revision of field boundaries based on 1995 field reconnaissance 1 Cover classes are as follows: A = tilled agricultural field B = grazed pasture C = hayfield or mowed area D = abandoned field (2-5yrs) E = abandoned field (5-10yrs) 2 Soil types are as follows: Guilford Co. Ch - Chewacla sandy loam (Fluvaquentic Dystrochrepts) Co - Congaree loam (Typic Udilluvents) EnB,EnC,EnD - Enon fine sandy loam (Ultic Hapludalfs) HeC - Helena sandy loam (Aquic Hapludults) MhB2.MhC2 - Mecklenburg sandy clay loam (Ultic Hapludalfs) VaB - Vance sandy loam (Typic Hapludults) WkC.WkD,WkE - Wilkes sandy loam (Typic Hapludalfs) Randolph Co. 50B.50C,50C2 - Zion variant-Enon complex 55B2.55C2 - Mecklenburg clay loam 55C - Mecklenburg loam 63B,63C,63E - Wilkes-Poindexter-Zion variant complex 20B2.20C2 - Georgeville silty clay 20B.20C,20D - Georgeville silt loam 45C - Badin-Tatum complex 24 4.2.2 Buffer Area Preservation One of the most notable aspects of this project's commitment to water quality is the excessive measures taken by the PTRWA to ensure that the immediate buffer area around the impoundment will be protected through condemnation and purchase, rather than use of easements, right-of -ways, etc. Nominally, North Carolina statutes only require that "...a margin of at least 50 feet around the impoundment shall be owned or controlled by the water supplier (15A NCAC 18C.0403)." Whereas the PTRWA has taken deliberate actions to significantly expand the purchase of the reservoir buffer to 200 ft horizontally above the normal pool level. This commitment by PTRWA will result in fee simple ownership of 6,184 acres of buffer area that will provide untold benefits for habitat improvement, future impact reduction (such as erosion), and protection from additional water/wetlands impacts. Since the acreage within the required 50 foot buffer was calculated to be 4,354 acres, it can thus be concluded that the PTRWA has purchased or will purchase approximately 1,830 acres more than normally required for such reservoirs. Given the aforementioned measures to revegetate frequently disturbed areas (fieldsO? and pastures) within this buffer area by wetlands creation and upland restoration, the mitigating effects to reservoir water quality can be assumed to be significant. Vegetation provides the primary production, and protection of the catchment ecosystems. The restoration of the plant communities greatly influences the runoff-rate, water-loss through evapotranspiration, and soil erosion (Petts, 1984). Well protected and vegetated buffer areas are known to improve the percolation of rainfall and to divert this water into the reservoir as subsurface stormflow versus surface stormflow (Horton, 1945). For developed watersheds that may drain stormwater into the reservoir through feeder streams, there will be an additional remediation or mitigation of stormflow through this greatly expanded buffer area. Vegetated riparian buffer areas are well known for their functions in mitigating stormflow, inorganic nutrient retention and transformation, and sediment trapping. Without a stable buffer area, it is well documented that a reservoir's storage capacity can be seriously compromised in less than 20 years (Dorst, 1970; Walling, 1981). It is the opinion of the PTRWA that the additional buffer area will provide some valuable temperature modulation in riparian areas by shading effects, and allowing some temperature sensitive species to exist within the reservoir by seeking safe havens in the vegetated buffer areas (Minshall, 1978; Hawkins and Sedell, 1981). Additionally, an expanded buffer area will provide a stable location for fish populations to feed on an intact invertebrate communities common in feeders streams (Culp and Davies, 1982). For some fish species, their presence in 25 the reservoir will be wholly dependent upon the interaction of the reservoir and the invertebrate community in the adjacent riparian areas. Therefore it is important to recognize the need to consider conservation measures that will achieve efficient protection of reservoir functions and species diversity. 4.2.3 Wildlife Habitat Enhancement The proposed impoundment will result in the significant loss of wildlife habitat. However, construction of the reservoir will also facilitate the development of new wildlife habitat. Randleman reservoir is expected to attract a wide variety of waterfowl and other migratory bird species by providing improved feeding and resting habitat. Species potentially attracted to the open water and shallow littoral zone habitats associated with the proposed reservoir include the mallard duck (Arras plathrhynchos), American widgeon (Arras americana), American black duck (Anas rubripes), Canada geese (Branta canadensis), wood duck (Aix sponsa), teal (Arras spp.) and horned grebe (Podiceps auritus). The proposed reservoir is extensive and should attract raptors such as osprey (Pandion haliaetus). The loss of riverine and bottom-land hardwood habitat, and the associated loss of wood duck nesting habitat will be mitigated by the installation of at least 60 nest boxes located in shallow coves and around the periphery of the reservoir. Wood duck nest boxes, when properly constructed, can be extremely effective in increasing the production of wood.ducks. The juxtaposition of the reservoir and adjacent mitigation areas will provide attractive sites for wood duck nest boxes. The artificial nesting structures in conjunction with buffer zone management should increase the population of resident wood ducks around the reservoir. 4.2.4 Fisheries Resource Enhancement The construction of the proposed dam and reservoir on the Deep River will significantly alter the existing aquatic community. Species associated with the existing lotic systems will be gradually replaced by those species favoring a lentic system; such as bluegill, largemouth bass, yellow perch, channel catfish and black crappie. To improve the fishery resources, habitat value and to increase public use of the proposed reservoir, fishery enhancement measures will be applied. Specific measures include retention of dead trees for fish attractors, and potential fish stocking. Fish attractors are designed for two principal purposes: to create habitat features that will promote fish production and survival, and to facilitate congregations of desirable species for improved angling. The fish attractors proposed in this plan will consist of residual trees 26 that will be left to die from inundation in selected coves within the impoundment. Coves will be selected that are conducive from a structural and water depth perspective to provide additional feeding and spawning areas in the deeper, more secluded areas of the reservoir. After a period of several years the standing dead snags will fall and be partially submerged in place to further structural components. These structures are known to successfully congregate fish and improve the angling potential of a reservoir. This strategy has been successfully utilized on other recreational impoundments and has the added benefit of providing perches and nesting sites for fishing raptors. The actual location of such standing timber will be determined in consultation with N.C. and U.S. fisheries biologists. Fish stocking when correctly utilized is one of the oldest methods of fish population manipulation. Stocking is employed to establish fish species composition, enhance fisheries production, and to improve angling opportunities. The proposed reservoir should be stocked with appropriate recreational fish in consultation with the NC Wildlife Resources Commission and under the direction of the Piedmont Triad Regional Water Authority. Sufficient public access will be provided to optimize recreational opportunities. 4.3 Management Criteria for Buffer Area The management and protection strategies for the buffer areas will be extremely important for the long term protection of the reservoir. This vegetation zone is situated directly adjacent to the reservoir and is the final protection zone. Clearly, the buffer area must provide maximum protection from sedimentation and water-born pollutants from upstream and surface water from uplands. Both point and non-point sources of pollution originate in the Deep River watershed. Likely contaminants include pesticides, animal waste, wastewater effluent, petroleum products and sediment. Measures must be taken to minimize the quantity of these pollutants and the negative impacts to water quality and the useful life of the reservoir. A Management and Protection Plan for the watershed including the buffer area should be developed. The first requirement for implementation of a this Plan is a complete inventory of the natural resources and an accompanying survey of land uses within the watershed. The resulting data bases and descriptions will characterize forest canopy, mid and understory vegetation, soil type and quality, hydrology including feeder streams, reservoir margins and associated wetlands, and prominent species of wildlife. Data bases should be generated through GIS systems compatible with those used by Piedmont Triad Water Authority. Results should include descriptions and quantities of land use on surrounding properties, and discussion of observed or potential impacts of such uses on the reservoir. 27 Where amelioration or mitigation is needed and alternative management approaches should also be presented leading to recommended courses of action. Implementation of the management plan would include but would not necessarily be limited to: 1. Installation of erosion and sedimentation control structures and/or vegetation. 2. Implementation of a sampling plan to assess the amount of sediment delivered to the reservoir annually. 3. Thinning of established forest stands to enhance value. 4. Advising the Piedmont Triad Water Authority on working with neighboring landowners on practices to minimize adverse impacts of certain land uses. 5.0 MONITORING A monitoring plan has been formulated to evaluate the success of on-site wetland creation (littoral zone bottomland hardwoods) and off-site wetland creation. The plan is designed to document changes in the seasonal ground water table level and planted and natural species composition over time in the wetland creation areas. A yearly monitoring report will be prepared and submitted to the USACE and USEPA for review and distribution to interested commenting agencies. The monitoring program will be conducted for five years and will follow USACE Guidlines (12/8/93). At the completion of this period, the success of the mitigation plan will be evaluated by the USACE in consultation with the USEPA to determine if the mitigation plan will require modification and/or additional years of monitoring. The monitoring plan will consider soil hydrology and vegetation. Matching the ecological setting of the project areas to natural wetlands is a fundamental aspect of the proposed mitigation approach. Monitoring, in the development of mitigation applications, provides an accounting of ecosystem processes to ensure that functioning forested wetlands are established. The performance of the mitigation will be assessed by comparing monitored data from the mitigation sites relative to undisturbed, adjacent, reference forested wetland habitats. Since the intensity of post-construction monitoring varies with the environmental significance of the project (White, 1991) and the probability of successfully achieving targeted wetland functions, our monitoring regime will measure and evaluate both structural and functional indices. There will be both graphic and written components to generate baseline conditions of each mitigation area. Maps will be generated to record wetland mitigation area, shape, the 28 patterns of vegetation and open water adjacency. A written narrative will augment the graphics and will serve as a record of what specifically was done during the construction phase regarding soil amendments, site preparation, and plant establishment. This assessment will be filed with the appropriate regulatory agencies within six months following project implementation. Once the as-built assessment is complete, differences between what was proposed and what was built will be evaluated by the permitting agency or overseeing agency. If modifications to the project are necessary, the as-built assessment will need to be updated to reflect these changes. When the evaluation is final, the as-built assessment will become the permanent record to enable comparison with all future project assessments. Routine assessments are project examinations which will record wetland development toward mitigation. This information is used to: 1) identify problems that require correction; 2) provide a record of progress; and 3) determine when project performance warrants releasing the Contractor from further responsibility. Data collected during routine assessments should reflect project objectives (Kentula et al., 1992), and will include the following: 5.1 Ground Water Water depth will be measured both as a function of inundation above ground (staff gauge), and depth below ground using shallow monitoring wells consisting of slotted PVC pipe 2.5 inches in diameter to a 30 inch depth. Indirect indicators will also be recorded according to the U. S. Army Corps of Engineers, (1987) Federal Manual for Identifying and Delineating Jurisdictional Wetlands (WTI, 1981). During the first year, measurements will be taken monthly during the dormant season and weekly during the growing season. Measurements will be made to the nearest 0.1 inch and will be plotted to show changes over time. This monitoring schedule will be followed until regulatory release. 5.2 Soils Soil depth will be determined using a soil auger or by excavation of a pit to depth of compacted soil or rock. Munsell color will be determined for chroma and hue for both matrix and mottles (WTI, 1987) for each soil horizon to a depth of 40 inches. Soil texture will be determined for each soil horizon using textural triangle and based upon feel. All soil amendments such as fertilizer or lime will be documented and activity monitored by soil analysis for the first two years. Soil analysis will also include measuring organic matter. 29 The degree of anaerobiosis of surface souls will be measured using iron rebar inserted to a 30 inch depth established at each well location and recorded on the well measurement schedule. The iron rod technique is based upon the principle that an iron rod placed in poorly drained soils will rust rapidly in the aerated zone of the soil, but not in the saturated zone where biological oxygen demand creates reducing conditions. This method has been shown to be a reliable indicator of the average soil water table levels on poorly drained heavier soils, and is one of the several methods used to determine the presence of reducing soil conditions in jurisdictional wetland determination (McKee, 1978 and Hook et al., 1987). 5.3 Vegetation Planting locations will be mapped and planting methods will be filed in the first year status report. Survival, number of plants per acre, and tree height and diameter (when appropriate) will be measured at the end of each growing season just prior to leaf fall. A survival rate for all planted woody species of 400 stems/acre will be required after 5 years. At least one sampling station will be established for every two acres of uniform terrain to ensure adequate representation of site conditions. Permanent vegetation 0.05 acre circular plots will be monumented in the field and on maps to facilitate repeated measurements. Species composition, wetland indicator status, and dominance will be measured within each plot. Trees and shrubs will be assessed separately and will be evaluated for number and coverage. The number and species of volunteer woody stems will also be recorded in each sample plot and compared with planted species. 5.4 Observation The project areas will be photographed from permanent photo stations and changes in any of the above variables will be recorded and included in each annual report. A series of sampling stations will also be established randomly in areas that currently support lentic bottomland hardwood areas. If necessary, other impoundments will be visited that have been created several decades ago to assess the degree of parameter overlap of naturally regenerating bottom-lands with those created with this project. Impoundments, such as Hyco Lake near Roxboro, N.C., that are created on similar Piedmont soils and geology might prove useful for establishing reference bottomland wetland communities. 30 6.0 REGULATORY RELEASE A report will be compiled annually to summarize the current year's assessments and will be submitted to the appropriate agencies in December. The report will indicate if corrections are required or if more comprehensive monitoring is needed to interpret wetland conditions since the last routine assessment was performed. The annual assessment will be filed with the permanent project records so that it is available for future reference. Following review of the Annual Reports or interim review and recommendations by the regulatory agencies, modifications may be implemented. The success of the wetland creation and upland restoration will be determined at the end of the five-year monitoring period based on review of the monitoring results. Evaluative criteria for the littoral bottomland hardwood creation will follow the "Mandatory Technical Criteria for Wetland Identification" described in the 1987 USACE field manual. Monitoring efforts will continue if the following standards are not attained: 1. A mean density of 400 trees per acre are growing at wetland sites consisting of preferred canopy species which average 6 feet tall based on one permanent sampling station established for every 5 acres. 2. At least 50% survival of planted understory species will be present, or 63 plants per acre based on row plot samples. 3. Soils will be considered acceptable for restoration when the physical and chemical properties for successful re-establishment of the wetland forest vegetation are present. At a minimum the soil will be saturated within 12 inches of the surface for seven consecutive days during the growing season (April through October, inclusive). 4. Hydrological conditions, as determined by visual observation and monitoring wells, will meet 80% overlap with 1987 Mandatory Technical Criteria. 6.1 Contingency Plan If the presented wetland mitigation plan is partially successful, i.e., wetlands have been created, but less than the total acres projected, additional wetlands will be created within the riparian watershed or in adjacent watersheds on wet agricultural lands. All criteria, excluding the degree of soil saturation, will be required for the wet flat woodlands and the upland restoration. Any additional mitigation efforts will only be in an amount necessary to make up the balance of acres required for jurisdictional wetlands. If wetland creation adjacent to the 31 proposed reservoir is initially unsuccessful, appropriate adjustments in elevation and/or species planting will first be attempted. If adjustments do not produce successful wetland creation, additional acreage will be sought. It is implicit that the mitigation plan and contingency actions proposed herein are complete and will require no further actions once executed. 32 7.0 References Brinson, M.M., F.R. Hauer, L.C. Lee, W.L. Nutter, R.D. Smith, and D. Whigham, 1994. DRAFT Guidebook for Application of Hydrogeomorphic Assessments to Riverine Wetlands, U.S. Army Corps of Engineers, Waterways Experiment Station, Technical Report (in preparation), Vicksburg, MS, 202 pp. Brinson, M.M. 1993. A Hydrogeomorphic Classification for Wetlands. U.S. Army Corps of Engineers, Waterways Experiment Station, Wetlands Research Program Technical Report WRP-DE-4, Vicksburg, MS, 79 pp. Brinson, M.M., H.D. Bradshaw, and E.S. Kane. 1984. Nutrient Assimilative Capacity of an Alluvial Floodplain Swamp. J. Appl. Ecol. 21:1041-1057. Brinson, M.M., A.E. Lugo, and S. Brown. 1981. Primary Productivity, Decomposition, and Consumer Activity in Freshwater Wetlands. Ann. Rev. Ecol. Syst. 12:123- 161. Carter, J.H. 1993. Biological assessment for Randleman Lake, Randolph and Guilford Counties, North Carolina. A report submitted to the Piedmont Triad Regional Water Authority, 70 pp. Conner, W.H. and J.W. Day. 1976. Productivity and Composition of a Baldcypress-Water Tupelo Site and a Bottomland Hardwood Site in a Louisiana Swamp. Amer. J.. Bot. 63(10):1354-1364. Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States, U.S. Fish and Wildlife Service, Biological Report FWS/OBS-79/31, Washington, DC, 103 pp. Cuffney, T.F. 1988. Input, Movement and Exchange of Organic Matter within a Subtropical Coastal Blackwater River-Floodplain System. Freshwater Biology 19:305-320. Culp, J.M. and R.W. Davies. 1982. Analysis of longitudinal zonation and the river continuum concept. Canadian Journal of Fisheries and Aquatic Sciences. 39:1258- 1266. Dopyera, C. 1995. Amphibians on the Brink. Wildlife in North Carolina (February, 1995):10-15. Dorst.J. 1970. Before Nature Dies. Collins, London. 352 pp. 33 Dunson, W.A., R.L. Wyman, and E.S. Corbett. 1992. A Symposium on Amphibian Declines and Habitat Acidification. J. Herpet. 26(4):349-352. Elder, J.F. 1987. Factors Affecting Wetland Retention of Nutrients, Metals, and Organic Materials. Pp. 178-184 in J.A. Kusler and G. Brooks (eds.) Proceedings of the National Symposium: Wetland Hydrology, Association of State Wetland Managers Technical Report 6, Berne, NY. Forester, D.C. 1992. The Importance of Saturated Forested Wetlands to the Perpetuation of Amphibian Populations. Pp. 16-23 in Proceedings of a Workshop on Saturated Forested Wetlands in the Mid-Atlantic Region: The State of the Science. Fitzell, A.A. 1988. Ecology of Wetlands. pp. 213-226 In D.D. Hook (ed.) The Ecology and Management of Wetlands, Vol. 1 Timber Press, Portland, OR. Gambrell, R.P. 1994. Trace and Toxic Metals in Wetlands - A Review. J. Envir. Qual. 23:883-891. Gilliam, J.W. 1994. Riparian Wetlands and Water Quality. J. Envir. Qual. 23:896-900. Gosselik, J.G., B.A. Touchet, J. VanBeek, and D. Hamilton. 1990. Bottomland Hardwood Forest Hydrology and the Influence of Human Activities: The Report of the Hydrology Workgroup, Pp. 347-387 in Ecological Processes and Cumulative Impacts Illustrated by Bottomland Hardwood Wetland Ecosystems. Lewis Publishers, Chelsea, MI. Hawkins, C. A., and J. R. Sedell. 1981. Longitudinal and seasonal changes in functional organizations of macroinvertebrate communities in four Oregon streams. Ecology. 62:387-397. Hook, D.D., M.D. Murry, D.S. DeBell, and B.C. Wilson. 1987. Variation in growth of red alder families in relation to shallow water level. Forest Science. 33(1): 224-229. Horton, R.E. 1945. Erosional development of streams and their drainage basins: hydrophysical approach to quantitative morphology. Bull. Geol. Soc, of Amer., 263:303-312. Kentula, M.E., R.P. Brooks, S.E. Gwin, C.C. Holland, A.D. Sherman, and J.C. Sifneos. 1992. And approach to improving decision making in wetland restoration and creation. Edited by A.J. Hairston, U.S. Environmental Protection Agency, Environmental Research Laboratory, Corvallis OR. 151 pp. 34 Kuenzler, E.J. 1988. Value of Forested Wetlands as Filters for Sediments and Nutrients. Pp. 85-96 in D.D. Hook and R. Lea (eds.) The Forested Wetlands of the Southern United States, U.S. Forest Service, Southeastern Forest Experiment Station, Asheville, NC. Lowrance, R. 1992. Groundwater Nitrate and Denitrification in a Coastal Plain Riparian Forest. J. Envir. Qual. 21:401-405. McKee, W.H. Jr. 1978. Rust on iron rods indicated depth of soil moisture. Site productivity symposium, U. S. Dept. of Agric, Atlanta, GA 286-291 pp. Minshall, G.W. 1978. Autotrophy in stream ecosyustems. Bioscience. 28:767-771. Mullohand, P.J. and E.J. Kuenzler. 1979. Organic Carbon Export from Upland and Forested Wetland Watersheds. Limnol. Oceanogr. 24(5):960-966. Petts, G.E. 1984. Impounded Rivers. Perspectives for ecological management. J.Wiley & Sons, Ltd. London. 326 pp. Poteat, J.A. 1993. Jurisdictional wetland delineation maps of Randleman Lake. Submitted to the Piedmont Triad Regional Water Authority. PTRWA, 1990. G.S. 162A-7 and 153A-285 Review Document and Environmental Impact Statement for Randleman Lake. prepared by Piedmont Triad Regional Water Authority 132 pp. PTRWA, 1994. Environmental Impact statement for Randleman Lake. Piedmont Triad Regional Water Authority. Reddy, R.R. and W.H. Patrick. 1975. Effect of Alternate Aerobic and Anaerobic Conditions on Redox Potential, Organic Matter Decomposition, and Nitrogen Loss in a Flooded Soil. Soil Biol. Biochem. 7:87-94. Sather, H.J. and R.D. Smith. 1984. An overview of major wetland functions and values. USFWS, FWS/OBS - 84/18 67 pp. Schafale, M.P. and A.S. Weakley. 1990. Classification of the Natural Communities of North Carolina, Third Approximation. North Carolina Natural Heritage Program, Raleigh, NC. 325 pp. Taylor, J.R., M.A. Cardamone, and W.J. Mitsch. 1990. Bottomland Hardwood Forests: Their Functions and Values, Pp. 13-86 in Ecological Processes and Cumulative Impacts Illustrated by Bottomland Hardwood Wetland Ecosystems. Lewis Publishers, Chelsea, MI. 35 Walling, D.E. 198 1. Yellow River which never runs clear. The Geographical magazine. 53:568-576. Wetland Training Institute, Inc. 1991. Field Guide For Wetland Delineation: 1987 Corps of Engineers Manual. WTI 91-2. 133 pp. Wharton, C.H., W.M. Kitchens E.C. Pendleton and T.W. Sipe. 1982. The ecology of bottomland hardwood swamps of the southeast: A community profile. FWS/OBS -81- 37. 133 pp. White, T.A., J.A. Allen, S.F. Mader, D.L. Mengel, D.M. Perison and D.T. Tew (eds.). 1991. MiST: A methodology to classify pre-project mitigation sites and develop performance standards for construction and restoration of forested wetlands. Results of an EPA-sponsored workshop. Region IV Wetlands Planning Unit. U.S. Environmental Protection Agency. 85 pp. Wilkinson, D.L., K. Schneller-McDonald, R.W. Olsen, and G.T. Auble. 1987. Synopsis of Wetland Functions and Values: Bottomland Hardwoods with Special Emphasis on Eastern Texas and Oklahoma. U.S. Fish and Wildlife Service, Biological Report 87(12), Washington, DC, 132 pp. WRP, 1993. Installing and monitoring wells/piexometers in wetlands. WRP Tech. Note HY-IA-3.1. 14 pp. 36 A endix A. Summa of Wetland T es and Areasl F ID d Wetland Area (a c) Wetland Ty e2 HGM Type3 Comments 2-1 0.02 PFO 1 A fringe 2 2 - 0.02 PFO 1 A fringe 3 1 - 1.29 PFO 1 AB * backswam hard mast 1.50 PFO 1 A/C* backswamp vernal pond hoto 91 1.77 A/C* backswam vernal and k 1.08 ffPFO frin e 0.26 frin e 0.03 PFOIA frin e 4 - 0.19 PFO 1 fringe 4 7 - 0.04 PFO 1 A fringe 4 8 - n _0 0.38 n nA PFO 1 backswam - 4 10 v•VT rrv1H trrnge - 0.05 PFO 1 A fringe 4-11 0.11 PFO1/EMl fringe/seep 4 12 - 0.58 PFO 1 /EM 1 fringe/seep 4-13 0.09 PFO 1 /EM 1 backswam 4-14 0.01 PFO 1 backswam 4-15 0.77 PFO 1 backswam 4-16 0.17 PFO1/EMl backswam 4 17 - 0.06 PFO 1 backswam 4-18 0.05 PFO 1 backswam 4 19 - 0.84 PFO 1 backswamn 5 1 - 0.56 PFOIA/E* backswam photo 92 5-2 4.50 PFOIA/B* backswam --- 5 3 - 0.43 PFO 1 kswam 5 4 - 0.29 PFO 1 kswam f 5 5 - 04 PFO 1 a kswam 5 6 - E 46 t PFO 1 backswam 5 7 - 28 PFOI fringe 5 8 - 5 9 07 PFO 1 /EM 1 backswam razed - 0.03 PFO1 fringe 5 10 - 0.06 PFO1 fringe 5 11 - 0.10 PFOI fringe 5 12 - 0.02 PFOI fringe 5 13 - 0.57 PFO l A fringe 38 5-14 0.15 PFO 1 A fringe 5-15 0.11 PFO 1 A fringe 5-16 0.53 PFOIA fringe 5-17 0.39 PFOIA fringe 5-18 0.04 PFO 1 A - fringe 5-19 0.11 PFOIA fringe 5-20 0.07 PFO 1 A fringe 5-21 0.07 PFO 1 A fringe 5-22 0.13 PFOIA fringe 5-23 0.04 PFO 1 A fringe 5-24 0.08 PFO 1 A fringe 5-25 0.04 PFOIA fringe 5-26 0.01 PFO 1 backswam 5-27 <0.01 PFO 1 backswam 5-28 0.01 PFO I backswam 5-29 <0.01 PFO 1 backswam 5-30 0.03 PFOIA fringe 5-31 0.05 PFO 1 A fringe 6-1 0.77 PFO1C backswam vernal and 6-2 0.27 PFO 1 A backswam 6-3 <0.01 PFO 1 A backswam 6-4 0.07 PFO 1 A backswam 6-5 0.01 PFO 1 A backswam 6-6 0.01 PFO 1 A backswam 6-7 0.01 PFO 1 A backswam 6-8 0.06 PFO 1 A backswam 6-9 <0.01 PFO 1 A backswam 6-10 <0.01 PFO 1 A backswam 6-11 0.14 PFO 1 A backswam 6-12 0.13 PFO 1 A backswam 6-13 0.03 PFO 1 A backswam 6-14 0.02 PFO I A backswam 7-1 1.77 PFOIA fringe old sand it 7-2 3.57 PFOI/SSIAB fringe old and 7-3 0.27 PFO I A fringe 7-4 0.45 PFO 1 C fringe 7-5 0.02 PFOI fringe 7-6 0.01 PFO1 fringe 7-7 0.04 PFO 1 fringe 7-8 0.12 PF01 fringe 7-9 0.10 PFO 1 backswamp 39 7-10 0.26 PFO I backswam 7-11 0.01 PFO 1 fringe 7-12 0.06 PFO 1 _ frin 7-13 1.28 PFO 1 /EM 1 e frin 7-14 0.32 PFO 1 ge backswam 7-15 0.54 PEM 1 frin e/see 7-16 0.23 PEM 1 B/E 7-17 0.57 PFO 1 see backswam 7-18 0.23 PFO 1 B frin e/see 7-19 0.07 PFOI frin 7-20 0.07 PFO 1 e frin 7.21 0.01 PFO 1 e fringe 7-22 0.08 PEM 1 B/E 7.23 0.08 PFO 1 A see frin 7-24 0.10 PFO 1 A e frin 7.25 0.13 PFO 1 A e frin 8-1 1.20 PFO 1 A/B e backswamp 8-2 1.11 PFO 1 frin e 8-3 0.34 PFO I backswam 8-4 3.60 PFOI/EM1A/B frin e 8-5 0.16 PFO 1 A frin 8-6 1.42 PFO 1 A e fringe 8-7 8 0.32 PFO 1 A backswamp -8 0.06 PFO I A frin 8-9 0.33 PFO 1 e backswam 8-10 0.52 PFO 1 backswam 9-1 3.21 PFO 1 A backswam 9-2 5.53 PFO 1 A/B backswam y_3 2.44 PFO 1 A/B backswam 9-4 <0.01 PFO 1 frin 9-5 <0.01 PFO 1 e frin 9-6 0.01 PFO1 e frin 9-7 0.27 PFO 1 e backswam 9-8 0.17 PFO 1 backswam 9-9 0.48 PFO 1 backswam 9-10 0.43 PFO 1 backswam 9-11 0.07 PFO 1 backswam 9-12 0.52 PFO 1 backswam 9-13 0.01 PFO 1 backswam 9-14 0.22 PFO 1 backswarnp below grazed / photo #3 40 9-15 4 86 9-16 . 0.74 PFO 1 backswam 9-17 0 21 PFO 1 A frin e 9.18 . 0.47 PFO1 backswam 9-19 0.16 PFO 1 backswam 9.20 5 54 PFO1 frin e 9-2 1 . 0.14 PFO1/EM1 AB frin e/bksw 9-22 0 42 PFO1 frin e 9-23 . 0 02 PFO 1 frin e 10-1 . <0 01 PFO 1 A frinoe 10-2 . 0 05 PFO 1 A frin e 10-3 . 0 02 PFO1A frin e 10-4 . <0 01 PFO I A frin e 10-5 . 0 01 PFOIA frin e 10-6 . 0 72 PEM1A frin oe 10-7 . 0 17 PFO 1 A frin e 10-8 . 0.42 PFO 1 backswam ] 0-9 0 14 PFO 1 A frin e 10-10 . 0 02 PFO 1 fringe 10-11 . 0 08 PFO IA frinoe 10-12 . 0 03 PFO I A frin e 10-13 . 0 01 PFOI A frin e 10-14 . 0 02 PFOIA fringe 10-15 . 0 04 PFO 1 A frin e 10- 16 . 0 01 PFO I A fringe 10-17 . 1 62 PFO 1 A f rin oe 11-1 . 0.73 PFO 1 fringe 11-2 <0 01 PFO I frin e 11-3 . 0 02 PFOIA fringe 11-4 . 0 01 1 PFO I fringe I1-5 . 0 25 PEMI frin e 11-6 . 0 04 PFO I /EM 1 frin ge 11-7 . 0 44 PFO 1 frin e 12.1 . 0 11 PFO I A fri n e 12-2 . 0 08 PFO 1 A frin e 12_3 . <0 01 PFO 1 A frin e 12-4 . <0 01 PFOIA frin e 12-5 . <0 01 PFO 1 A r fin e 12-6 . <0 01 PFO I A fringe 12.7 . 0 11 PFO 1 A fir in e 12-8 . <0 p 1 PFO I A frin e . PFO 1 A f i r nge owerline 41 12-9 12-10 13-1 13-2 13-3 13-4 13-5 13-6 13-7 13-8 14-1 r914-8 14-10 14-11 14-12 14-13 14-14 14-15 14-16 14-17 15-1 15-2 15-3 15-4 15-5 15-6 15-7 15-8 15-9 15-10 15-11 15-12 15-13 0.04 0.15 3.51 0.04 0.34 0.53 0.04 0.08 <0.01 <0. 01 13.60 0.21 0.25 1.93 1.03 0.28 <0.01 0.27 0.83 <0.01 0.02 4.23 0.27 0.42 0.15 0.02 0.04 0.03 0.04 0.05 <0.01 0.01 0.08 0.03 0.01 0.07 1.77 0.02 0.01 0.14 PFOIA PFOIA LEE i1 /SS 1 B PFOIA PFOIA PEM I B PFOIA PFOIA PFOIA PFOIA PEM2E PFO 1 E PFOIE PF01 PFO1 PFO1 PFOI PFO1 PFO1 4;F OIA PFOIA PEM 1 E PEM 1 E PFO1 PFOIA PFOIA PFOIA PFOIA PFOIA PFOIA PFOIA PFOIA PFOIA PFOIA PFOIA PFOIA PFO1 PFOIA PFOIA PFOI 42 frin e fringe fringe/see hoto #4 frin e fringe see fringe fringe frin e fringe backswamp grazed / hoto #5 backs iam backswam backswamp backswam backswamp backswam backswam fringe fringe fringe see /bksw grazed fringe fry fringe fringe fringe fringe fringe fringe fringe frinae fringe fringe fringe/b frinae rrin e I backswamp 15-14 <0.01 PFO IA 15-15 0.01 PFO1 A frin e 15-16 0 01 fringe 15-17 . <0 01 PFO 1 A frin e 15-18 . <0 01 PFO l A frin e 15-19 . <0 01 PFO 1 A frin e 15-20 . 0 03 PFO 1 A frin e 15-21 . 0 05 PFO 1 A frin e 15-22 . <0 01 PFO 1 A frin e 15"23 . 0 04 PFO 1 A frin e 15-24 . 0 06 PFO 1 A frin e 16-1 . 3 28 PFO 1 A fringe 16-2 , 0 23 PFO 1 /SS 1 B/C backswam 16-3 . 0 01 PFO 1 backswam 16-4 . 0 21 PFO 1 A frin e 16-5 . 0 07 PFO 1 backswam 17-1 .. 0.89 PFO I backswam? 17-2 0,01 PEM1B see /fringe 17-3 0 23 PFOI frin e 17-4 . 0 01 PFO 1 backswam 17-5 . 1 23 PFO 1 backswam 17-6 . 0 05 PFO 1 frin e 17-7 . 0 03 PFOI frin e 17-8 . 0 01 PFO 1 frin e 17-9 . 0 05 PFO I A frin e 17-10 . 0 46 PFO1 A fringe 17-11 . 17 0 PFO 1 A frin e 17-12 . <0 01 PFOl A fringe 17-13 . <0 01 PFO1A frin e 17-14 . 0 01 PFO1A frin e 17-15 . 0 01 PFO 1 A fringe 17-16 . 0 03 PFO1 A fringe 17-17 . <0 0 1 PFO 1 A frin e 17-18 . 0 10 PFO1A fringe 17-19 . 0 03 PFO I backswam 17-20 . <0 01 PFO1A fringe 17-21 . <0 O 1 PFO 1 A frin e 17-22 . 0 20 PFO 1 A frin e 17-23 . 0 04 PFO 1 backswarn 17-24 . 0 04 PFO 1 A frin e 17-25 . 0 13 PFO 1 A frin e . PFO 1 A fringe old-field 43 18-1 0.01 18-2 0.01 PFOIA Erin e 18-3 0.03 PFO I A fringe 19-1 1.69 PFO 1 A fri __._ PFO1/EM1B n e seep/fringe 19-2 <p. O 1 19-3 0.15 PFO I A fringe 19-4 PFO 1 1.35 PFOI see /frin e 19-5 <0.01 see /frin PFOIA e 19-6 0,07 PFO 1 A frin e 19-7 0.01 fringe 19-8 <0. 0 1 PFO1 A fringe 19-9 0.04 PFO1A frin e 19-10 0.04 PFO 1 A PFO1 frin e 19-11 0.05 backswam 20-1 0.07 PFO I backswarri 20-2 0.01 PrO1A frin e 20-3 PFO 1 A <0.01 PFO 1 A frin e 20-4 <0.01 frin e 20-5 0.01 PFO 1 A fringe 20-6 PFO I A 20-7 0.24 PFO1 A fringe 20-8 0.24 PFO I A fir-in e 20-9 0.13 PFO 1 A backswam 20-10. 0.04 PFO I A frin e 0.13 fringe 20-11 1.00 PFO 1 A PFO 1 E frin e 20-12 0.12 see /fringe 20-13 0.11 PFO I frin e 20-14 0.03 PFO 1 fringe 20-15 0.07 PFO 1 A PF01 A frin e 20-16 0.01 frin e 20-17 PFO 1 A 0.10 PTO 1 A fringe 20-18 0,02 frin e 20-19 0 23 PFOIA fringe 20_20 PFO 1 backswam 20-21 0.13 PFO 1 20-22 0.62 PFO 1 backswam 0.21 PFO 1 backswam MuDeeddy River 12710 R2UB backswam 1 Creek 19.86 R3 BI n/a n/a ATV use / photo #6 44 Richlands • Creek 11.90 R3 UB 1 Registers Creek 1.02 n/a Hickory R3 UB I Creek 9.37 n/a 1 st & 2n R3 UB I n/ order 2S? 60 a a tribut ries R4SB3 n/a TOTAL AREA 194.35 acres Riverine TOTAL AREA 119.11 acres Palusirine I Based on 7/92 2 wetland Wetlands ma type based pp?ng from J. 9 and ams Compan 3 HG1lgan e erial Photo n eolWre din et al. 0 97R. McAd P s based anon determined by Brinson (1993) y ground-truthing 45 Txuvvd&w?. LaL- 04- A4t ewe n)fs ? e?s ?54 02? cig Vvt aa- rl, co? sCPM?cfid5 ceo ?a J7. tj uelml? v/a 2D, s ?rrie v??? ? mss. -?vu ?o te"Tl 14t -- a4 lq6? car" -116 ALI\A 6il A? ? rur ?ti wrakle DAVIS - MARTIN - POWELL & ASSOCIATES, INC. ENGINEERING LAND PLANNING • SURVEYING 218 GATEWOOD AVENUE • SUITE 102 - HIGH POINT, NC 27262 PHONE (910) 886-4821 • FAX (910) 886-4458 August 19, 1996 Re: City of High Point, NC Eastside WWTP Expansion Environmental Assessment Job No. E-1971 (BF) Mr. Alan R. Clark Basinwide Planning Group DEHNR PO Box 29535 Raleigh, NC 27626-0535 Dear Mr. Clark: We are enclosing three (3) copies of the Environmental Assessment. (EA) in regards to the referenced project which has been revised in, accordance with your review comments. Additional exhibits depicting the service area, the Randleman Lake, and downstream Deep River waters are included. More detailed existing Deep River water quality information is included in Section 2.04. Additional mitigative measures have been added to and expanded upon in Section 8. Pretreatment program information has been added as Section 3.05. The September 18, 1995 speculative limits DEHNR letter has been added to Appendix A. These items, as well as others mentioned in your review comments, are included in the revised EA. If the revised EA meets with your approval, please let us know and we will send additional copies to you for review by various agencies. Thank you for your cooperation in these regards. Very truly yours, DA MARTI POWELL & A CIATES a ;L. cNeill P.E. RLM/res c: Mr. Perry Rairis Mr. Robert DiFiore File State of North Carolina Department of Environment, 170 Health and Natural Resources Division of Environmental Management / a 0 James B. Hunt, Jr., Governor 00 Jonathan B. Howes, Secretary E WIMN IL A. Preston Howard, Jr., P.E., Director H June 6, 1996 Mr. Randy McNeil E Copy Davis-Martin-Powell & Associates, Inc. 218 Gatewood Avenue, Suite 102 High Point, NC 27262 Dear Mr. McNeil RE: EA for High Point's Eastside Wastewater Treatment Plant Expansion and Upgrade My apologies for not having provided comments on the subject environmental assessment (EA) to you earlier. I have had a chance to review the EA and have included comments from our Division's Technical Support Branch. The EA does a reasonably good job of touching on many key issues and at least mentioning the possible primary and secondary impacts of the proposed expansion. It appears that most, although not all, of the comments from reviewers at the scoping stage had been addressed. For example, item 6 in the letter from the Division of Forest Resources was not included (acres of forest impacted) and a couple of items listed in the letter from DEM's regional office also need to be expanded upon (Section 7.02, below). Where the EA falls down is in the following areas: 1) not adequately defining the affected area, 2) inadequately describing the existing water quality of the Deep River and Richland Creek, 3) not quantifying some of the secondary impacts of development, and 4) failing to describe how, in Chapter 8, water quality and other environmental impacts associated with the enlarged discharge and increase in stormwater runoff from land use changes will be mitigated in Richland Creek and Deep River. Each of these is discussed in more detail, below: 1) Project Area Maps:, First, the EA needs a map (or maps) that show the boundaries of both the existing and proposed service areas in addition to the WWTP facility location maps. These mapped lines represent the area in which development and land use changes will be taking place as a consequence of enlarging the plant. It is understood that the boundaries of the proposed service area may need to be estimated; however, this should not preclude making an effort to depict the extent of the future service area. As a minimum, the map should include municipal boundaries, major roads, major streams and lakes, major interceptors and the WWTP facility. Second, the EA should include a map of the waters downstream of the facility that are affected by the discharge. This should include a map of Richland Creek and the Deep River downstream from the plant to at least Carbonton Dam. Use support ratings of Richland Creek and the Deep River should be indicated on the map (color use support map attached). Third, a map also needs to be included of entire the proposed Randleman Reservoir. This should include the extent of the normal and flood pools as well as the WWTP discharge location. P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer Mr. Randy McNeil • June 6, 1996 Page 2 2) Water Quality: Biological and ambient water quality data collected by DEM indicate that water quality in Deep River below the plant is impaired. The discussion of surface waters in Section 2.04 needs to expanded. Information is available from the Randleman Reservoir EIS and DEM's Cape Fear Basinwide Water Quality Management Plan. 3) Secondary affects: In addition to showing the service area, the EA should quantify the land area (acres or square miles) within the existing and proposed service areas and estimate before and after population. It should also include acres of land cover by major types within the existing and proposed service areas (can use types already mapped at city of county level), and to then quantify, to the extent possible, how these numbers will change by the time the plant is at full capacity. Of particular interest is the change in impervious surface area that will occur. This can be used to gain some understanding of the changes in stormwater runoff, expected changes in nutrient loadings and potential stream impacts from increased runoff rates and scouring. 4) Section 8 - Mitigative Measures: This project entails significantly increasing the size of a major wastewater treatment plant discharge just upstream of a controversial proposed water supply reservoir on a river whose water quality is considered impaired. The plant will facilitate increased development in the watershed draining to the reservoir which could have adverse affects on water quality in the reservoir and in other urban streams. The potential primary and secondary impacts of this project on the environment are significant. And yet the only mitigating measures listed in Chapter 8 address onsite erosion control, onsite construction limits and treatment system failure. Without adequate mitigation of the potential adverse impacts of this project a Finding of No Significant Impact (FONSI) could not be justified for this EA. To be fair, there are many potentially effective mitigating measures presented in chapter 7, not the least of which are some of the proposed improvements to the waste treatment plant and the ongoing improvements to the collection system to address significant inflow and infiltration problems. The mitigating measures presented in Section 7 need to be added to Section 8. They can either be repeated in Section 8, or preferably, a brief reference to mitigating measures can be included in various subsections of Section 7 with the more complete presentation of the mitigating measures placed in Section 8. This would help avoid repetition and use the available space in the EA most efficiently. (In regard to space and length, it is noted that the text is double-spaced. Making a single-spaced document should provide ample room to add the additional material requested while still meeting the 30-page limit.) While the above recommendation for beefing up Section 8 by moving mitigative measures from Section 7 will be helpful, a number of the mitigative measures need to be expanded upon. More specifically, a number of subsections in Section 7 make reference to impacts being mitigated by various local programs. However, it is unclear what these programs are, who the responsible governing agency is and how the programs will mitigate impacts. Each of the following programs needs to be described in sufficient detail to explain how the impacts will be mitigated and by whom. - Section 7.01 (Changes in Land Use) states that "adverse impacts from future development will be minimized by enforcement of local Planning and Zoning Ordinances." What are these adverse impacts and how will they be mitigated? In Section 7.05, how will conducting development "consistent with local zoning regulations" mitigate the loss of agricultural lands due to growth that is facilitated by this project? Section 7.08 needs to acknowledge that the increased development accommodated by this project will increase automobile usage which in turn can increase air emissions. In Section 7.10, what are the provisions of the "local watershed restrictions and zoning ordinances" that will mitigate the indirect effects of future residential and industrial development in the watershed area? Mr. Randy McNeil June 6, 1996 Page 3 In Section 7.11, what are the "proper runoff control measures and proper stormwater management " measures that will be used to minimize impacts of new development in the service area on shellfish or fish and their habitats. In Section 7.12, how will impacts to wildlife and their habitats be minimized by "local planning and Industrial Pretreatment Ordinances, as well as by local Stormwater Management Programs". Who are the responsible governing agencies for each of these programs and what are the provisions that will minimize impacts. To what extent will impacts be minimized, if at all? In regard to Section 7.02, Table 1 on page 29 needs to be expanded (or a new table added) to show the actual loadings in lbs/day of each of the listed parameters for existing limits at 16 MGD and the proposed limits at 26 MGD. For those parameters with summer and winter limits, corresponding summer and winter loadings should be presented. Also, Section 7.02 needs to be revised to address the comments contained in the attached May 1, 1996 memorandum from Farrell Keough to Alan Clark In addition to more explicitly discussing the potential algal blooms in the proposed reservoir, what is being done to address those concerns listed at the bottom or the attached memorandum regarding cyanide, foaming and color in the effluent, and pretreatment opportunities. Please contact me if you have any questions. Sincerely, ?,t, t Z?(-, Alan R Clark Supervisor Basinwide Planning Group Attachment (May 1 memorandum) cc: Ruth Swanek Coleen Sullins Farrell Keough Boyd DeVane North Carolina Division of Environmental Management Water Duality Section / Rapid Assessment Group May 1, 1996 To: From: Through: Alan Clark Farrell Keo ?}(?/ Carla Sanderson 0 Ruth Sw Don Safi Subject: High Point - Eas&ide Waste Water Treatment Plant NCO024210 Guilford County Environmental Assessment I have reviewed the Environmental Assessment for the High Point - Eastside VWVTP referenced as Job No. E-1971. We request the following be addressed : Section 7.02 Surface Water Ouality I reviewed instream data, (attached) from the NCDEM Water Quality Ambient Monitoring Network. Data from two stations; 02.0994.8400 on Richland Creek at SR 1145 near High Point and 02.0995.0000 on Deep River at SR 1921 near Randleman was reviewed for nutrients. The Deep River Watershed has shown problems with the assimilative capacity of nutrients, therefore nutrient limits have been recommended for this proposed expansion. As indicated by this data, nutrients in these waterbodies are at levels which have a strong potential for algal blooms. This is especially acute at the Richland Creek site during the more critical summer months. This document should review this issue, especially as it relates to Randleman Lake and the increased residence time that could precipitate excessive algal growth. The instream monitoring taken by the facility should also be thoroughly reviewed in this document, with special attention to the issue of nutrient loading. The ambient monitoring stations also showed elevated levels of copper, lead, nickel, and zinc. Aluminum and sulfates were also detected. The levels for nickel would not meet the standard if the proposed Randleman Lake water supply reclassification is approved. Sulfates would also need to be reviewed if this proposed reclassification is approved. This situation needs to be thoroughly addressed in this document. Instream monitoring for lead and nickel are required in the current permit, therefore review of this data should be included in this document as well as discussion of the data for its potential impact on the proposed water supply reclassification. Appendix A should contain the letter of speculative limits, dated September 18, 1995 sent to the Director of Utilities for the Town of High Point for verification that all recommended limits are being addressed. Appendix A contains a letter from the Winston-Salem Regional Office dated June 26, 1995 and outlines numerous issues which need attention in this report. We concur with the requests made in this letter and note that the following need attention in this document: a. Cyanide concerns in effluent. c. Foaming and color in effluent (previous and future complaints). L Pretreatment opportunities and potential improvements [noted in the next comment section is a review of instream data which has metals well above detection levels] Thank you for this opportunity to review and comment. cc: Coleen Sullins Permit File NORTH CAROLINA DEPARTMENT OF ENVIRONMENT HEALTH AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT April 23, 1996 M E M O R A N D U M TO: Monica Swihart THROUGH: Steve Mauney FROM: Ron Linville I/ SUBJECT: Environmental Assessment for City of High Point Eastside POTW Expansion Guilford County The following comments are provided for you consideration and review. They are enumerated by the EA page numbers for your convenience. These comments are intentionally brief due to time constraints. 1. Additional treatment capacity is also necessary at this facility due to significant inflow which may cause this plant to provide only primary treatment during severe or long-term inclement weather. It is probable that inflow and flow throughs could contribute to current stream conditions below the POTW. This expansion appears to be somewhat belated due to recent sewer extensions and concerns about inflow into the collection system. 2. It is possible that wetlands may be located near the discharge trough of the existing POTW. The Corps of Engineers should determine if any impacts could occur instead of depending on a soils distribution "surrounding the site" (contact John Thomas w/ COE @ 919/876-8441x25). 6. Average daily flows of 16 MGD and peak hydraulic flows of 32 MGD are indicated in the document. Periods when routine flows of around 12.5 MGD have been exacerbated by instantaneous flows in excess of 3-4 times the daily permitted flow of 16.0 MGD are not unusual. 9. Consideration may need to be given to insuring that the abandoned outfall running through the landfill is not and does not provide an opportunity for pollutants to leach out through a french drain effect. 10. The 201 study included only High Point and Jamestown. The Region is concerned that inflow concerns may be more pronounced for Sedgefield and Archdale (both tributary to Eastside) as well as High Point. Jamestown may be in better shape. Inflow investigation and flow coordination by all parties tributary to the City of High Point's WWTP should be helpful. 13. Data which correlates high instantaneous flows with inflow and treatability during inclement weather events should be provided. This would further understanding of how these events could (even after expansion) negatively affect the Randleman Dam Watershed if it is built. 19. The EA's focus on the expansion allowing for future extensions of sewer into newly developed areas should also address the issue of repair and replacement of portions of the collection system currently contributing to significant inflow. Without such considerations, is it likely that point source nutrients could be discharged during inclement weather by flow throughs providing only partial treatment? Are there combined sewers that provide for the transport of urban runoff from the downtown area? 25. It is likely that the Eastside expansion "will result in a reduction in nutrients discharged to the receiving waters in the Deep River Basin". It is also likely that an enhanced I&I Program could also provide for further reductions. 26. The POTW (if the Randleman Lake is built) should insure that inclement weather events do not reduce the capacity of the WWTP to provide continual removal of nutrient loads during and after those events. 27. What type of redundant power supplies are proposed (on-site automatic generator or dual power sources). Previous known failures are believed to have been intrinsic to the POTW. These comments are based on a general understanding of conditions relative to this WWTP and are expressed for the benefit and consideration of the City of High Point and the proposed Randleman Dam project which is also discussed in the EA. a:\hipt.eam Prepared for the CITY OF HIGH POINT, NC State Review Agency NC Department of Environment, Health & Natural Resources Contact Person: Mr. Alan R. Clark (919) 733-5083 HAZEN AND SAWYER, P.C. DAVIS-MARTIN-POWELL & ASSOCIATES, INC. 4011 Westchase Blvd. 218 Gatewood Avenue, Suite 102 Raleigh, North Carolina High Point, North Carolina JOB NO. E-1971 Prepared Jointly Bv: TABLE OF CONTENTS Section Section 1 - Purpose Page ...........................................1 Section 2 - Existing Environment .................................... 2 2.01 Topography ..................................... 2 2.02 Land Use ....................................... 2 2.03 Soils .......................................... 2 2.04 Surface Waters . ............. . ........ ...... . ..... 3 2.05 Water Supply .................................... 4 2.06 Groundwater ..................................... 6 Section 3 - Existing Wastewater Facilities ............................... 7 3.01 General ........................................ 7 3.02 Plant Description .................................. 7 3.03 Existing NPDES Permit .............................. 10 3.04 Collection System .................................. 10 3.05 Industrial Pretreatment Program ......................... 12 Section 4 - Need for Proposed Facilities and Action ........................ 15 Section 5 - Analysis of Alternatives .................................. 18 5.01 No Action Alternative ............................... 18 5.02 Relocated Wastewater Treatment Plant Alternative .............. 18 5.03 Non-Discharge Alternatives ............................ 19 5.04 Wastewater Plant Expansion Alternative .................... 19 Section 6 - Proposed Facilities and Actions, Funding Sources ................... 20 Section 7 - Environmental Consequences ...... ........................ 22 7.01 Changes in Land Use ................................ 22 7.02 Surface Water Quality ............................... 22 7.03 Groundwater Quality ................................ 24 7.04 Wetlands and Flood Plains ............................ 24 7.05 Prime or Unique Agricultural Lands ...................... 25 7.06 Public Lands, Scenic, and Recreational Areas ................. 25 7.07 Archaeological and Historic Sites ........................ 25 7.08 Air Quality ...................................... 26 7.09 Noise Levels ..................................... 26 7.10 Water Supplies ................................... 26 7.11 Shellfish or Fish and Their Habitats ....................... 27 '7able of Contents (Continued) Section Page 7.12 Wildlife and Their Habitats ............................ 27 7.13 Introduction of Toxic Substances ......................... 28 7.14 Eutrophication of Receiving Waters ....................... 28 Section 8 - Mitigative Measures ..................................... 30 8.01 Changes in Land Use ................................ 30 8.02 Water Quality .................................... 31 8.03 Groundwater Quality ................................ 34 8.04 Infiltration/Inflow Reduction Program ........ ........... 34 8.05 Erosion Control ................................... 35 8.06 Construction Limits ................................. 35 8.07 Treatment System Failure ............................. 36 Table 1 Existing and Future NPDES Permit Limits .................. 37 References ................................................. 38 Exhibit 1 Site Location Map Exhibit 2 Normal Pool and 100 Year Flood Levels for Randleman Lake Exhibit 3 Proposed Facilities Expansion to 26 MGD Exhibit 4 Randleman Lake Exhibit 5 Eastside WWTP Service Areas & Randleman Lake Exhibit 6 Cape Fear River Basin #1 Appendix A - Project Comment Letters from Federal and State Agencies SECTION 1 PURPOSE The purpose of this Environmental Assessment for the City of High Point's Eastside Wastewater Treatment Plant (WWTP) is to discuss environmental impacts that expanding and upgrading the WWTP may have on the surrounding areas and communities that will be served by the expanded WWTP. See Exhibit 1 for the vicinity map that indicates the location of the Eastside WWTP. The proposed project will expand and upgrade the existing Eastside WWTP from a capacity of 16 million gallons per day (MGD) to 26 MGD. This increase in treatment capacity will allow the facility to adequately process anticipated wastewater flows as well as enhance existing treatment processes. The upgraded plant will be designed to achieve greater levels of treatment and higher quality effluent, which will be required to minimize adverse impacts on water quality in the proposed Randleman Lake. See Exhibits 4 and 5 for the location of the proposed Randleman Lake. The additional treatment capacity is necessary to accommodate anticipated growth and development in the existing and expanding service area which has and will lead to extensions of the wastewater collection and transmission system into newly developed areas. This report discusses the effects of this upgrade on the surrounding environment. Environmental Assessment for the City of High Point, Job No. E-1971 - 1 - SECTION 2 EXISTING ENVIRONMENT 2.01 ToRggraphy The proposed project is located in the Jamestown Township east of High Point, North Carolina. More specifically, the project is located at the site of the existing Eastside WWTP, along Richland Creek near the Riverdale Road crossing of Interstate 85. (See Exhibits 1 and 5). The existing plant site varies in elevation from 680 feet to 800 feet above mean sea level. The area to be disturbed is limited predominantly to the existing plant site in areas that were cleared and graded during construction of the existing treatment plant process units. 2.02 Land Use The project site is bounded on the south and east by Interstate 85 and Richland Creek. The area downstream of the project site, across Interstate 85, is primarily undeveloped woodland. The area to the west of the project site is mixed agricultural and woodlands. North of the project site, across Riverdale Road, is the City of High Point Landfill and the closed Seaboard Chemical Corporation site. 2.03 Soils The soils at the plant site have generally been cut or filled to accommodate the existing WWTP components. As a result of this cutting and filling, the natural distribution of soil series and types have been altered. The soils on land surrounding the site are typically well- drained Enon and Wilkes series soils. Environmental Assessment for the City of High Point, Job No. E-1971 -2- L.04 Surface Waters The existing Eastside WWTP site borders Richland Creek. No other surface waters are contiguous to the site. The existing treatment facility discharges effluent to Richland Creek, a small urban stream with a 7Q10 flow of 1.0 CFS. Richland Creek is designated as a Class C stream under the North Carolina Surface Water Classifications and Water Quality Standards. The discharge into Richland Creek is located just upstream of Richland Creek's confluence with the Deep River in the Cape Fear River Basin. Other major point source discharges in the Deep River Basin segment of the Cape Fear River Basin include the Randleman WWTP, Asheboro WWTP, Robbins WWTP, and Sanford WWTP. Nonpoint source discharges into the Deep River service area are predominantly from urban surface water runoff or farmland runoff. Point source discharges to the Deep River are of concern because of their impact on downstream dissolved oxygen. In addition, the Eastside WWTP is a very significant contributor of point source nutrients to the Deep River. These nutrients can cause algal blooms, which also reduce the amount of dissolved oxygen in the waters. This reduction of dissolved oxygen and excessive nutrients can affect normal growth of wildlife species and can lead to a eutrophic state for downstream surface waters. Biological and ambient water quality data collected by the Division of Environmental Management (DEM) indicates the water quality in the Deep River, below the Eastside Plant, is impaired. (See Exhibit 6). Surface waters like the Deep River are rated as either fully supporting, support- threatened, partially supporting, or non-supporting. The terms refer to how the classified Environmental Assessment for the City of High Point, Job No. E-1971 -3 - ' ' ' ' uses of the water are being supported. The term "impaired" refers to surface waters that are rated either partially supporting or not supporting of their specific classified uses. The Deep River sub-basin from High Point to its confluence with the Haw River contains 16 small dams. These dams slow the river's velocity and limits the system's assimilative capacity. These 16 impoundments, which affects stream velocity, point source nutrient loading such as WWTP discharges, and non-point source loadings, play a significant role in the eutrophication of stream. The river's inability to adequately assimilate the nutrients in the stream is directly related to the impaired ratings for the river. Although non- point source and an array of other NPDES point-source discharges contribute to nutrient loading in the Deep River, sampling data implicates that Richland Creek, receiving waters for the High Point Eastside WWTP, as a significant contributor of point-source nutrients to the Deep River. Randleman Lake, a proposed regional supplemental drinking water supply for the Cities of High Point, Greensboro, and Archdale and the Town of Jamestown, as well as surrounding areas within Randolph and Guilford Counties, will be constructed on the Deep River downstream of the Eastside WWTP and will back up water into the effluent channel of the existing WWTP. (See Exhibits 2 and 5). 2.05 Water Supply The existing City of High Point water supply treatment and transmission facilities consist of two; two raw water pumping stations and associated raw water transmission mains; two water filtration plants with associated clearwells and high service pumping facilities; distribution mains; two elevated storage tanks, and a ground storage repump facility. Environmental Assessment for the City of High Point, Job No. E-1971 -4- The two reservoirs, High Point City Lake and Oak Hollow Lake, are the sources of water supply for the City of High Point. City Lake was constructed in 1928 and has served as the primary water source since its construction. In 1971, Oak Hollow Lake was constructed to supplement the City Lake supply. After Oak Hollow Lake was completed, stored water could be released through the intake structure to allow waters to flow downstream to City Lake. Previous engineering reports indicate that the average dependable daily yield of City Lake and Oak Hollow Lake combined is 22 MGD. Each reservoir currently has a raw water pumping station and transmission system capable of delivering raw water to either of the two existing water filtration plants. The primary raw water pumping station located downstream of City Lake includes four pumps with capacities ranging from 8 MGD to 20 MGD each. The Oak Hollow Raw Water Pump Station located just behind Oak Hollow Dam includes three pumps with capacities ranging from 8 MGD to 12 MGD each. Raw water is transmitted through a system of mains to either of the two existing water filtration facilities. The primary water filtration plant, Ward Plant, has an existing water production capacity of 16 MGD. The secondary water filtration plant, Kearns Plant, is an extremely old facility and has an emergency backup water production capacity of 8 MGD. Plans are being completed for the expansion of the Ward Plant from 16 to 32 MGD capacity. The existing 22 MGD combined safe yield for the High Point Reservoirs and the planned 32 MGD water treatment capacity should provide the City with adequate water supply until 2010, after which time an additional water supply source will be needed. Construction of Randleman Lake is proposed to supplement the capacities of High Point's and Greensboro's raw water supplies to meet long-term water needs for the area. Randleman Environmental Assessment for the City of High Point, Job No. E-1971 - 5 - '' ' ' Lake is planned to provide an additional safe yield of 48 MGD, of which 10 MGD is allocated to the City of High Point. 2.06 Groundwater Groundwater is utilized for individual residencies in rural areas of Guilford County. No major potential groundwater aquifers are located in the area. Most wells produce less than 25 gallons per minute. Groundwater quality is normally good, except for high iron levels in some areas. No water supply wells are located in the vicinity of the Eastside Wastewater Treatment Plant site. Environmental Assessment for the City of High Point, Job No. E-1971 -6- SECTION 3 EXISTING WASTEWATER FACILITIES 3.01 General The City of High Point is located in the northern Piedmont of North Carolina in southwestern Guilford County. The wastewater service area includes High Point, Archdale, Jamestown, and the Sedgefield Sanitary District, as well as surrounding areas located adjacent to the High Point corporate limits. The existing City of High Point sewer system includes approximately 500 miles of sewers, 25 wastewater pumping stations, and two wastewater treatment plants. A major ridge line through the City separates two distinct watersheds: the Cape Fear River Basin to the east and the Yadkin River Basin to the west. Gravity sewers to the east of the ridge flow to the Eastside WWTP, and those to the west flow to the Westside WWTP. The Eastside Plant provides service to the northern, eastern, and southern areas within and surrounding the City, while the Westside Plant provides service to western areas only. The Eastside Plant also receives flows from the City of Archdale, the Town of Jamestown, and the Sedgefield Sanitary District. 3.02 Plant Description The Eastside Plant was originally constructed as a trickling filter process and was subsequently modified during the early 1960's to a trickling filter/activated sludge process. During the early 1980's, the Eastside Plant was expanded to provide treatment for an average daily flow of up to 16 MGD and a peak hydraulic flow of 32 MGD. Flow is transported to Environmental Assessment for the City of High Point, Job No. E-1971 -7- ' the plant site by two major outfalls: the Perry Outfall and the Richland Creek Outfall. Preliminary treatment includes bar screens, flow measuring, and grit removal. Parallel bar screens are provided for the removal of large solids and stringy materials. The influent flow rate is then measured by a 3' - 0" wide Parshall flume which discharges to parallel aerated grit chambers. Flow is then split and distributed to four primary clarifiers. The preliminary treatment units and the primary clarifiers are designed to accommodate all influent flows up to the 32 MGD peak rate. The flow is then split equally between two independent secondary treatment trains. One-half of the plant flow is routed through the trickling filter/activated sludge train. Primary effluent is received by the trickling filter influent pumping station, where it is lifted by vertical diffusion vane pumps to the trickling filters. Within this train, the trickling filters are followed by aeration basins and secondary clarifiers. Effluent from the secondary clarifiers is lifted by screw pumps and combined with effluent from the second train. The second, parallel process train consists of aeration basins and secondary clarifiers. No intermediate pumping is required for this train. Flow is routed by gravity through this train to a junction box and is combined with the first train's secondary effluent before tertiary treatment by conventional gravity filtration. Following filtration of the combined flows, the tertiary effluent is disinfected by chlorination and discharged over a cascade aeration system to an effluent channel and downstream plant outfall pipes. Flow is then discharged by gravity into Richland Creek. In 1990, a four-million gallon influent flow equalization tank was constructed to reduce peak influent flow rates to levels that could be passed through the plant while maintaining adequate treatment levels. Environmental Assessment for the City of High Point, Job No. E-1971 - R - The solids handling facilities constructed in a previous expansion of the Eastside Facility included dissolved air flotation (DAF) thickeners, anaerobic digesters, a liquid storage lagoon, and belt filter presses. The digesters have recently been converted to lime stabilization tanks and the belt filter presses are currently not in service. The City of High Point currently disposes of lime stabilized sludge by land application in the liquid state. Primary sludge is transferred directly from the primary clarifiers to the lime stabilization/mixing tank. Secondary sludge wasted from the activated sludge processes is pumped to the dissolved air flotation thickening tanks. Thickened secondary sludge is transferred to the lime stabilization/mixing tank where it is mixed with the primary sludge. The lime stabilization/mixing system includes two tanks operating in series. The first tank includes a lime feed system and mixing facilities. The second tank is currently being utilized to store stabilized sludge only at this time. Plans have been completed and construction has begun to add mixing equipment to the second tank, as well as to replace the transfer pumps between the two tanks. Two other construction contracts are in progress to allow abandonment of the sludge land application program. The existing belt filter presses are being replaced with high solids centrifuges to dewater the liquid sludge. An incineration facility is also being added to further reduce waste sludge volumes and stabilize the sludge. Incinerator ash will be disposed of in a landfill. Environmental Assessment for the City of High Point, Job No. E-1971 -9- 3.03 Existing NPDES Permit The existing NPDES permit limitations for the Eastside Plant are as follows: Parameter Monthly Average Flow 16.0 MGD BOD Summer 8.0 mg/l BOD Winter 16.0 mg/l TSS 30.0 mg/l NH3-N Summer 3.0 mg/1 NH3-N Winter 6.0 mg/l DO 6.0 mg/l Fecal Coliform 200/100 ml The existing Eastside NPDES permit was issued on February 1, 1993 and expires on March 31, 1996. The State Department of Environment, Health & Natural Resources has just issued the NPDES permit for continued operation at the 16 MGD capacity. The NPDES limits are identical to the previous permit and will remain active until March 31, 2001 or until the plant is expanded. 3.04 Collection System Flow is transported to the Eastside Plant by two major outfalls: the Perry Outfall and the Richland Creek Outfall. The Richland Creek Outfall was originally constructed in the early 1900's to provide sewer service to the southeastern area of High Point. In order to provide additional capacity for the growing southeastern area, as well as additional capacity to accommodate wastewater from the Archdale area, a portion of the Richland Creek Outfall was replaced in 1972. The Perry Outfall was constructed in the late 1950's to serve the northeastern areas of High Point. A municipal solid waste landfill has been constructed over a portion of this outfall. The landfilling operation has progressed to a point that portions of the outfall are being covered by up to 70 feet of fill. The over 35-year old concrete pipeline Environmental Assessment for the City of High Point, Job No. E-1971 - 10- shows signs of concrete deterioration. A pump station and force main is being constructed to allow abandonment of the portion of the outfall located under the landfill. See Exhibit 5 for location of major outfalls which contribute to the Eastside WWTP. Flow is transported to the Westside Plant by three outfalls: the Rich Fork Creek Outfall, the Kool Pool Outfall, and the Ensley Creek Outfall. These outfalls were originally constructed prior to 1950 utilizing 3-foot lengths of clay pipe material with grouted joints. Segments of each outfall have been rehabilitated or replaced during the past 20 years. A sewer system infiltration/inflow (I/I) analysis was included in the original 201 Facilities Plan that was prepared by Black & Veatch during 1975 and a comprehensive High Point sewer system report was prepared by Hazen & Sawyer during 1988. The I/I study in the original 201 included a cost effective analysis that indicated that the collection systems of High Point and Jamestown did not experience excessive I/I. Therefore, it was determined that it would be cost effective to transport and treat these I/I flows. At that time, the City of Archdale had not constructed a central sewer collection system. The purpose of the 1988 study was to identify future needs within the sewer collection and treatment system. The 1988 study indicated that a number of the major outfalls were approaching capacity and future plans should include replacing the near-capacity pipelines to accommodate long-term future growth. The 1993 City Bond Issue included funds for outfall pipeline rehabilitations and replacements. Plans are currently being prepared to address I/I-related sewer main pipeline rehabilitations on the most deteriorated pipeline segments within the collection system. Approximately $9.15 million was included in the 1993 Bond Issue for sewer system renovations and I/I reduction. $4.5 million is being utilized to install gravity sewer, the Riverdale Road Pump Station, and a force main to allow abandonment of the deteriorated I/I-laden concrete outfall Environmental Assessment for the City of High Point, Job No. E-1971 - 11 - . ' located under the existing landfill. $1.6 million is being utilized to reduce I/I in the most deteriorated segments of the Kool Pool, Kindergarden, and Colbert Outfalls. $2.9 million has been identified to reduce I/I in the most deteriorated sections of the Perry, Deep River, and Mechanicsville Outfalls. The City's five-year plan for 1997-2002 includes an additional financial commitment for further sewer system rehabilitation and the 2002-2007 long-range plan includes ongoing sewer system rehabilitation financial support. In addition, the City of High Point is devoting a crew to ongoing I/I evaluations and sewer system repairs. 3.05 Industrial Pretreatment Program Major industries that contribute wastewater to the Eastside Plant include furniture and textile manufacturing facilities, as well as other industries that provide products that are utilized by these manufacturers. The principal industrial wastewater generators include furniture manufacturers, textile manufacturers, textile chemicals processors, coatings - manufacturers, electroplaters, steel drum cleaners, and dairies. The wastewaters discharged by the significant industries are regulated by the City of High Point Industrial Pretreatment Program. The Industrial Pretreatment Program allows a systematic approach to regulate industrial wastewater discharges in order to minimize disruptions of the City's treatment plant processes. The Industrial Pretreatment Program sets forth uniform requirements for direct and indirect contributors to the wastewater collection system and treatment plants to enable the City of High Point to comply with State and Federal requirements of the Clean Water Act and General Pretreatment Regulations included in EPA 40CFR - Part 403. The objectives of the Industrial Pretreatment Program are as follows: Environmental Assessment for the City of High Point, Job No. E-1971 - 12- • To prevent the introduction of pollutants into the municipal wastewater system which will interfere with the operation of the system or contaminate the resulting solids; • To prevent the introduction of pollutants into the municipal wastewater system which will pass through the system, inadequately treated, into any waters of the State or otherwise be incompatible with the system; • To improve the opportunity to recycle and reclaim wastewaters and solids from the system; • To protect both municipal personnel who may come in contact with wastewater solids and effluent in the course of their employment, as well as the general public; To provide for equitable distribution of the cost of operation, maintenance, and improvement of the municipal wastewater system; and • To ensure the municipality complies with its NPDES or Nondischarge Permit conditions, solids use and disposal requirements, and any Federal and State laws to which the municipal wastewater system is subject. The Industrial Pretreatment Program provides for regulating industrial discharges by issuance of Discharge Permits for significant industrial customers. Specific industrial pollutant discharge limitations are determined by a headworks loading analysis of the wastewater treatment influent flows and any applicable Federal categorical regulations. The Industrial Pretreatment Program includes provisions for surcharges of certain pollutants for industrial customers that discharge high strength (nondomestic) wastewater. The specific pretreatment discharge limit for each pollutant is based upon historical discharge Environmental Assessment for the City of High Point, Job No. E-1971 - 13 - records of existing or similar industries, the continuously-updated treatment plant influent headworks analysis, and Federal categorical regulations. More stringent industrial user effluent limitations may be necessary to control concentrations of specific concerns such as cyanide, color, surfactants, etc. The continued emphasis on and the enforcement of the Industrial Pretreatment Program is the most economical means of controlling toxicity and heavy metals in the plant effluent. Environmental Assessment for the City of High Point, Job No. E-1971 -14- SECTION 4 NEED FOR PROPOSED FACILITIES AND ACTION Population projections for the City of High Point service area provide the basis for planning of necessary wastewater treatment facilities improvements to accommodate the associated wastewater system flows. For the purpose of this project, the projections are presented through the year 2015. Projections are provided for both existing and future service areas. The existing service areas include High Point, Jamestown, Archdale, and the Sedgefield Sanitary District. Future service areas include areas where major interceptors have or are being constructed to provide service to growing areas. The U.S. Census Bureau estimated the 1992 population for the City of High Point at 69,424. Census population projections for Guilford County were utilized to project future populations for the City of High Point as follows: Guilford County High Point Year Population % Increase Population 1992 355,335 69,424 (Census) 1995 364,252 2.5 71,160 2000 375,107 3.0 73,295 2005 382,908 2.1 74,835 2010 391,817 2.1 76,405 2015 410,485 4.9 80,150 Environmental Assessment for the City of High Point, Job No. E-1971 - 15 - An analysis of historical water consumption records for the 12-month period from June 1994 to June 1995 indicates approximately 67 percent of water sold is returned to the Eastside WWTP and 33 percent is returned to the Westside Plant. High Point flow projections for the Eastside Plant are as follows: Year Projected High Point Flow to Eastside WWTP (MGD) 1995 11.7* 2000 12.2 2005 12.4 2010 12.7 2015 13.3 * Based on Eastside Plant flow data for 1995. To project future flows expected at the Eastside WWTP, existing and future service area flow projections were combined, as follows: Projected Wastewater Flow (MGD) Year City of High Other Future Eastside Eastside WWTP Point Municipalities Service Areas WWTP ADF Peak Month 1995 11.7 1.9 0.0 13.6* 15.9* 2000 12.2 2.0 2.3 16.5 20.6 2005 12.4 2.0 4.5 18.9 23.6 2010 12.7 2.0 6.8 21.5 26.9 2015 13.3 2.1- 9.1 24.5 30.6 * Based on Eastside Plant flow data for 1995. The projected peak month flow included above is based upon a ratio of the highest recorded monthly average flow during the past years divided by the ADF for the same period, or approximately a peak month to ADF factor of 1.25. Environmental Assessment for the City of High Point, Job No. E-1971 -16- The preceding projections indicate that the expected 2015 ADF for the Eastside Plant will be 24.5 MGD, with a corresponding peak month average daily flow of 30.6 MGD. Along with continued growth in population, it is anticipated that more stringent NPDES permit effluent limits will be imposed. This comes from the observance of significant nutrient problems in the downstream areas of the Deep River. The Eastside WWTP effluent contributes over 70% of the Deep River flow at its permitted flow of 16 MGD. Phosphorus and nitrogen concentrations are of concern in terms of their effect on Randleman Lake and downstream waters. The Eastside Plant is estimated to reach its current permitted capacity of 16 MGD before the year 2000, and the 20 year flow projections indicate an expected flow increase to 26 MGD by 2015. Based upon this information, speculative future effluent limits for a capacity of 26 MGD has been established. See Table One on Page 37 for a comparison between the existing 16 MGD NPDES limits and the proposed 26 MGD limits. As shown in the Table, more stringent limits for BOD, NH3-N, and nickel are proposed and new limits are proposed for phosphorus, nitrogen, residual chlorine, fluoride, phenols, and mercury. Environmental Assessment for the City of High Point, Job No. E-1971 - 17- SECTION 5 ANALYSIS OF ALTERNATIVES 5.01 No Action Alternative In the last few years, the Eastside WWTP has received flows approaching and, in 1995, nearly reaching its permitted capacity of 16 MGD. Current regulations require that the plant be expanded to adequately treat expected wastewater flows or that development be curtailed to produce wastewater flows within the capacity of the existing treatment plant. Therefore, no action would mean a moratorium on development generating new wastewater collection system connections or would require any future development in the service area to be served by privately-owned treatment systems, septic tanks, or other subsurface disposal systems. Historical records indicate that most soils in the service area are not suitable for subsurface disposal systems. Also, privately-operated package wastewater treatment facilities have typically resulted in inadequately treated effluent being discharged to surface waters. For these reasons, the no action alternative is not considered a feasible alternative. 5.02 Relocated Wastewater Treatment Plant Alternative Relocation of the Eastside WWTP to an alternate location is not cost-effective. The existing service area topographic features and the existing major outfalls that terminate at the existing Eastside headworks facilities restrict relocation options. Since a majority of the existing treatment facilities are of recent construction and their operation is reliable, excessive, unnecessary cost would be required to replace the existing processes at an alternate location. In addition, the existing plant site has adequate space for Environmental Assessment for the City of High Point, Job No. E-1971 - 18- the proposed expansion. If an alternate site was available, additional social, environmental, and political issues would make implementation of the proposed project much more difficult. An alternative site located downstream could possibly increase the overall service area but is not considered feasible because of the proximity of the proposed Randleman Lake. Expansion of the existing WWTP at its current location is more cost-effective than construction of a new facility at an alternate location. Therefore, construction of a relocated treatment facility is not a feasible option. 5.03 Non-Discharge Alternatives Land application is not considered a feasible option for the proposed treatment plant expansion. The area required for land application of the proposed 10 MGD addition flow would be more than 3,000 acres. It is highly unlikely that a parcel or parcels of land that size could be found within close proximity to the plant. Even if suitable land is available, the cost to purchase the land and the cost to transport the effluent would be very high and would make this alternative not cost effective compared to the proposed plant expansion. 5.04 Wastewater Plant Expansion Alternative The proposed treatment plant expansion will increase the existing plant capacity from 16 MGD to 26 MGD. Expansion of the existing facilities would occur on the existing plant site. Expansion and upgrade of the existing plant will allow further development in the service area and allow the facility to produce a higher quality effluent. The proposed plant expansion is the most cost-effective alternative. A Preliminary Engineering Study has been prepared that analyzes various processes that can achieve nitrogen and phosphorus nutrient effluent limits included in the state issued speculative NPDES limits for a plant capacity of 26 MGD. Environmental Assessment for the City of High Point, Job No. E-1971 - 19- SECTION 6 PROPOSED FACILITIES AND ACTIONS, FUNDING SOURCES The proposed Eastside Treatment Plant expansion will increase the existing plant capacity from 16 MGD to 26 MGD. The layout of the plant improvements proposed for construction is shown on Exhibit No. 3. The proposed upgrade and expansion will include new barscreens, new grit removal system, two additional primary clarifiers, new blower and administration building, activated sludge facilities for biological phosphorus and nitrogen removal, additional final clarifiers, additional effluent filters, and new ultraviolet disinfection facilities. The project will also include the replacement of outdated pumps; valves, valve operators, and miscellaneous equipment, as well as the conversion of existing structures into additional flow equalization and sludge storage tanks. The current ongoing construction project at the Eastside Plant to expand the waste solids handling facilities is part of the phased construction for plant expansion to 26 MGD capacity. Liquid sludge blending/storage renovations, sludge concentration by new dry solids centrifuges, and the installation of a fluid bed incineration unit are being constructed to accommodate existing and future waste sludge capacity needs. The Eastside Plant is estimated to reach its current permitted capacity of 16 MGD before the year 2000. Based upon the estimated flow projections, the following schedule for plant upgrade and expansion is as follows: • Preparation of plans and Specifications August 96 - August 97 • Construction of Upgrade and Expansion October 97 - December 99 Environmental Assessment for the City of High Point, Job No. E-1971 -20- The estimated construction cost for the upgrade and expansion of the Eastside Treatment Plant from 16 MGD to 26 MGD capacity is $35,000,000. It is anticipated that a local Sewer Bond Issue will be developed to finance the construction of the proposed improvement. The City of High Point may also apply for SRF-State Revolving Fund Loan monies to help finance the cost of the proposed improvements. Environmental Assessment for the City of High Point, Job No. E-1971 -21- SECTION 7 ENVIRONMENTAL CONSEQUENCES 7.01 Changes in Land Use The proposed Eastside WWTP expansion will be limited to the existing plant site property boundaries. The proposed plant expansion is not expected to cause any changes in land use in the immediate area. A secondary indirect impact on land use will result from the continued expansion of the service area and continued development of surrounding, currently undeveloped lands. The increase in wastewater treatment capacity will allow future expansions of the wastewater collection system to serve newly developed areas. Exhibit 5 indicates the existing system service area which includes approximately 29 square miles and two growth areas which are expected to develop during the next twenty years. One area located northwest of the existing service area includes 6 square miles and a similar area located east of the existing service area includes 51fa square miles. 7.02 Surface Water Quality The Eastside WWTP discharges its effluent into Richland Creek, a small urban tributary of the Deep River in the Cape Fear River Basin. Other major point source discharges in the Deep River Basin segment of the Cape Fear River Basin include the Randleman WWTP, Asheboro WWTP, Robbins WWTP, and Sanford WWTP. Nonpoint source discharges into the Deep River service area are predominantly from urban surface water runoff or farmland runoff. Environmental Assessment for the City of High Point, Job No. E-1971 -22- Point source discharges to the Deep River are of concern because of their impact on downstream dissolved oxygen. In addition, the Eastside WWTP is a very significant contributor of point source nutrients to the Deep River. These nutrients can cause algal blooms, which also reduce the amount of dissolved oxygen in the waters. This reduction of dissolved oxygen and excessive nutrients can affect normal growth of wildlife species and can lead to a eutrophic state for downstream surface waters. Speculative future effluent limits for the Eastside WWTP expanded to 26 MGD have been established and are shown in Table 1 on Page 37, along with a comparison to the limits for the existing 16 MGD plant. The future speculative limits were provided in a letter from Mr. Steve W. Tedder to Mr. Linwood E. O'Neal dated September 15, 1995. As shown in the table, the limits for nickel will be reduced and a new limit for phenols will be added upon construction of Randleman Lake. Several other effluent limits will be reduced as a result of the Eastside WWTP expansion. The BODS limit (in mg/1) will be reduced from 8 to 5 during the summer months and from 16 to 10 during the winter months, or a reduction of 38 percent. The NH3-N limit (in mg/1) will be reduced from 3 to 2 during the summer months and from 6 to 4 during the winter months, or a reduction of 33 percent. New limits for fluoride, mercury, residual chlorine, phosphorus, and total nitrogen are included in the speculative limits. The nutrient limits will help to minimize the algal blooms and dissolved oxygen reduction in downstream waters. Therefore, the additional treatment processes for nutrient reduction will enhance the quality of plant effluent. Nonpoint source discharges to the Deep River are primarily from roadways and farmland. As the areas are developed, there will be more roadway runoff and less farmland Environmental Assessment for the City of High Point, Job No. E-1971 -23- runoff. Nutrient loadings from nonpoint sources are expected to increase slightly with the proposed project because of the conversion of undeveloped land to land developed for urban uses. 7.03 Groundwater Ouality The proposed project will be confined to the existing plant site which is well drained. No water supply wells will be affected by the construction of the proposed improvements. Secondary benefits will result from continued service area expansion, which will allow reduced dependency on septic tanks and other subsurface disposal systems and allow the elimination of existing failing subsurface disposal systems in the expanding service area. Elimination of the failing systems will improve groundwater quality. 7.04 Wetlands and Flood Plains The existing plant and the proposed expansion facilities are confined to an area where there is no evidence of wetland vegetation and the soils are well drained. Based on Flood Insurance Rate Maps from the National Flood Insurance Program, the 100-year flood elevation for Richland Creek is approximately 688.8 feet. The proposed Randleman Lake will have a normal pool elevation of 682 feet. At this elevation, the lake will be just below the bottom step of the plant effluent cascade aeration structure. The previously proposed Corps of Engineers lake would have had a 100-year flood elevation of 694.5 feet. The Corps lake design is larger than the currently proposed Randleman Lake. Based on preliminary design information, the 100-year flood for the currently proposed Randleman Lake will be between 689.0 and 690.0 feet. See Exhibit 2 for various flood elevations expected adjacent to the existing plant site. Environmental Assessment for the City of High Point, Job No. E-1971 -24- . With the proposed Randleman Lake, the existing cascade aeration system will be slightly impacted. During a flooding event, aeration of the effluent will be reduced, possibly requiring additional means of aeration. (See Exhibit 2 for expected flood elevation and plant effluent elevations). 7.05 Prime or Unique Agricultural Lands The proposed project is expected to have no effect on the existing agricultural land to the west of the plant. No other agricultural lands are located near the site. Secondary impacts may be a future reduction of agricultural lands due to continuing growth and development of the service area allowed by the increase in treatment capacity. 7.06 Public Lands. Scenic, and Recreational Areas The proposed project site is located across Riverdale Road from the existing High Point Solid Waste Landfill and the closed Seaboard Chemical Corporation site and is bounded on the south and east by Interstate 85 and Richland Creek. There are no public lands, parks, scenic, or recreational areas that will be affected by the proposed construction at the existing treatment plant site. The North Carolina Division of Parks and Recreation, National Heritage Program is not aware of any parks or recreational areas or wild or scenic rivers that would be adversely affected by the proposed project. 7.07 Archaeological and Historic Sites There are no archaeological or historic sites that will be affected by the proposed project due to its location on the existing plant site. Based on a file data search, North Carolina Department of Cultural Resources staff indicated that they are not aware of any structures of historic or archaeological importance within the boundaries of the proposed construction. Environmental Assessment for the City of High Point, Job No. E-1971 -25- 17.08 Air Quality The overall effect of the project on air quality will be negligible. Short-term effects on air quality will include windblown dust and exhaust emissions generated during construction. Long-term effects on air quality are expected to be negligible since the proposed expanded plant will utilize treatment processes similar to the existing plant. Measures to control odors from existing and proposed process units will be included in the proposed expansion project. Burning of trees and brush resulting from minor clearing of the site may be permitted by air pollution regulations under the jurisdiction of the Guilford County Health Department. If burning is not permitted, the waste materials will be properly disposed of in a landfill or recycled. The expanding service area will ultimately lead to an increase in population and automotive usage which will, in turn, increase air emissions. 7.09 Noise Levels Long-term noise levels are not expected to increase significantly due to construction of the proposed project. Short-term increases in noise levels associated with construction activity can be expected. The facility's remote location and its proximity to Interstate 85 further support the belief that noise levels should not be a significant problem. 7.10 Water S ies The proposed Eastside WWTP expansion will not have any effect on the existing water supplies that serve the City of High Point. These supplies, High Point City Lake and Oak Hollow Lake, provide an average dependable combined daily yield of 22 MGD. It has been estimated that this water supply will be adequate for the City until 2010. The proposed Randleman Lake (See Exhibit 4), upon completion, will supply the surrounding communities Environmental Assessment for the City of High Point, Job No. E-1971 -26- with a planned safe yield of 48 MGD. The more stringent effluent limitations to be imposed upon the expanded Eastside Plant will control the quantity of nutrients released into the Randleman Lake. Indirect effects on the water supply will result from future residential and industrial development in the watershed area due to the increased capacity of the treatment plant. 7.11 Shellfish or Fish and Their Habitats The proposed plant expansion will not adversely affect shellfish, fish, or their habitats. Direct impacts due to siltation during construction will be mitigated by erosion control measures implemented in accordance with North Carolina and Guilford County erosion control regulations. An Erosion Control Plan that has been approved by the NC Division of Environment, Health and Natural Resources, Division of Land Resources will be included in the project design plans. The expanded plant will also include enhanced treatment to reduce nutrient concentrations and to reduce the potential for chronic toxicity by discontinuing the use of chlorine for disinfection. Indirect impacts from the proposed project will result from new development in the service area. Increasing urban runoff will occur due to new development. 7.12 Wildlife and Their Habitats The existing plant site is cleared and planted in grass which is mowed and offers limited habitat for wildlife. Since the plant expansion will be confined to the existing site, no adverse impacts to wildlife or their habitat are expected. Approximately one acre of plant site wooded area will be cleared to facilitate construction. Birds and small animals that feed on the grassy areas of the plant site may temporarily leave because of construction activities, but should return during and after construction is Environmental Assessment for the City of High Point, Job No. E-1971 -27- completed. Traffic and noise from construction activities may cause wildlife inhabiting adjacent forest habitats to temporarily move further into the forested areas. Some species will adjust to the disturbances and return to the site during construction while others will return to the vicinity after construction is completed. Indirect impacts from the proposed project will result from new development in the service area. Some natural wooded areas along with their wildlife habitat will be replaced by housing or industry, thus impacting wildlife species in the developed areas. 7.13 Introduction of Toxic Substances The expansion of the Eastside Plant should have no significant adverse impacts relating to toxic substances. The existing NPDES permit requires effluent chronic toxicity testing on a quarterly basis. The plant consistently passes the effluent toxicity test. The proposed plant expansion will include ultraviolet disinfection, thereby eliminating the potential for chlorine- related effluent toxicity. The City's aggressive Industrial Pretreatment Program continuously monitors and controls toxic organic and inorganic chemicals discharged to the sewer system. The program includes a headworks analysis to allocate selected pollutants from industries. The analysis is periodically submitted to NCDEM and was last approved during May 1994. 7.14 Eutrophication of Receiving Waters The proposed upgrade and expansion of the Eastside WWTP will result in reduction in nutrients discharged to receiving waters in the Deep River Basin. There is no effluent limit for total nitrogen in the current NPDES permit for the Eastside Plant. Future limits projected by NCDEM include a monthly average effluent limits for total nitrogen of 6 mg/1 during the months of April through October. As for nitrogen, there is presently no effluent limits for Environmental Assessment for the City of High Point, Job No. E-1971 -28- phosphorus in the current NPDES permit. NCDEM projects a future limit for phosphorus of 1 mg/l as a monthly average. Since the expanded wastewater treatment plant will discharge into the proposed Randleman Lake, the effluent from the plant will be treated to more advanced treatment levels. The expanded plant will be designed to meet nutrient limits which will preclude or minimize the potential for eutrophication in Randleman Lake and other downstream receiving waters. Environmental Assessment for the City of High Point, Job No. E-1971 -29- ' ' SECTION 8 MITIGATIVE MEASURES Various measures are planned to minimize adverse environmental impacts during construction and operation of the proposed expanded Eastside WWTP. These measures will address short and long-term impacts of the proposed project. 8.01 Changes in Land Use The proposed Eastside WWTP expansion will be limited to the existing plant site property boundaries. The proposed plant expansion is not expected to cause any changes in land use in the immediate area. A secondary indirect impact on land use will result from the continued expansion of the service area as indicated on Exhibit 5 and continued development of surrounding, currently undeveloped lands. The increase in wastewater treatment capacity will allow future expansions of the wastewater collection system to serve newly developed areas. The growth pattern will, however, be controlled and orderly in accordance with the City of High Point Development Ordinance. The purposes of the Development Ordinance include the following: • Prevent overcrowding of land. • Facilitate the adequate and economic provision of transportation, water, sewage, schools, parks, and other public services. • Protect water quality within the Watershed Critical Areas and the General Watershed Areas of designated water supply watersheds. Environmental Assessment for the City of High Point, Job No. E-1971 - 30 - • Require appropriate setbacks for buildings and other structures to facilitate the safe movement of vehicular and pedestrian traffic, provide adequate fire lanes, and ensure adequate distance from dust, noise, and fumes created by vehicular traffic. • Encourage development in areas which have major streets and utility lines in place but are experiencing little or no development. • Protect water quality, preserve wildlife habitats, and protect natural features such as streams, lakes, wetlands, and trees. • Reduce the amount of grading necessary for site preparation. • Create a better quality of life for the community by encouraging preservation of existing trees and vegetation. • Provide the separation necessary to permit certain land uses to co-exist harmoniously which might not do so otherwise. By enforcing the Development Ordinance as the wastewater system expands, adverse impacts as a result of expanding system will be mitigated. 8.02 Water Quality The expanded capacity NPDES point discharge into Richland Creek, tributary to the Deep River in the Cape Fear River Basin, will include effluent limitation as established by the Division of Environmental Management (see Table 1 on Page 37 for comparison of existing 16 MGD and speculative 26 MGD limitations). The speculative limit provided by DEM takes into account all upstream and downstream water quality issues including the proposed Randleman Lake and are based upon the findings of the Cape Fear River Basinwide Water Quality Management Plan. Environmental Assessment for the City of High Point, Job No. E-1971 - 31 - As indicated in the table, effluent limitations have been established for several non- previously regulated parameters and other effluent limitations will become more stringent. Nutrient limits for phosphorus and nitrogen will be imposed to minimize downstream nutrient related impacts. Effluent limitations will also be established for fluoride, mercury, and chlorine. The proposed plant expansion will utilize ultraviolet light as the disinfectant, eliminating chlorine residuals and the potential for developing casonigenic chlorine compounds downstream. More stringent limits for nickel and new limits for phenols will be added upon construction of Randleman Lake. Several other effluent limitations will be reduced as a result of the Eastside WWTP expansion. The BOD5 limit will be reduced approximately 38 percent based upon concentration and only a mass (lbs/day) increase of less than 2 percent. The NH3-N limit will be reduced 33 percent based upon concentration and only a mass increase of 8 percent. The proposed plant expansion will be designed with flexibility to exceed the proposed effluent limitations. The design expansion to 26 MGD average daily flow will include provisions for treatment of peak flows up to 3 times design flow or 78 MGD. Activated sludge facilities for biological and nitrogen removal will be included. The potential changes in water quality caused by the increase in service area will be minimized by the City of High Point Development Ordinance which includes Watershed Management and protection features. The purposes of these watershed use regulations to control non-point discharges are as follows: Environmental Assessment for the City of High Point, Job No. E-1971 -32- , , . .• Protect those portions of designated water supply watersheds which lie closest to existing and proposed water supply reservoirs from activities which could degrade water quality in the reservoirs. • Reduce the volume of nutrients and other chemicals which could enter the water supply by reducing the rate of runoff which any given development will generate. • Minimize land disturbance to reduce the amount of sediment washing into streams and lakes and to enhance the infiltration of runoff into soils, thus alleviating the sedimentation of water supply lakes which reduces their storage capacity, shortens their useful life, and makes them less able to withstand drought. • Reduce the probability of the release of harmful chemicals into water supply reservoirs, either through natural catastrophe or human error. • Provide for natural and engineered methods for managing the stormwater which flushes contaminants off of built-upon areas in the water supply watersheds and which may reach water supply reservoirs unless controlled. • Minimize pollution entering municipal reservoirs to assure the public health and the public provision of a continued supply of safe drinking water thereby protecting the water quality of these water supply reservoirs and promoting public safety. • Encourage a low intensity of land development in the most sensitive portions of the water supply watersheds (Watershed Critical Areas) thereby reducing the risks to water quality posed by higher density residential and non-residential uses. The construction of an expanded WWTP plant, which complies with DEM NPDES point discharge effluent limitations and the enforcement of the non-point discharge watershed Environmental Assessment for the City of High Point, Job No. E-1971 -33- management and protection features of the City's Development Ordinance, will minimize adverse impacts to water quality. 8.03 Groundwater Ouality The proposed project will be confined to the existing plant site which is well drained. No water supply wells will be affected by the construction of the proposed improvements. Secondary benefits will result from continued service area expansion, which will allow reduced dependency on septic tanks and other subsurface disposal systems and allow the elimination of existing failing subsurface disposal systems in the expanding service area. Elimination of the failing systems will improve groundwater quality. 8.04 Infiltration/Inflow Reduction Program The City of High Point's commitment to infiltration/inflow (I/I) reduction will allow the Eastside Plant to operate within hydraulic design parameters. A major pumping station and force main are under construction that will eliminate an I/I laden outfall segment which is also routed under an existing solid waste landfill. Approximately $9.3 million was authorized in 1993 for outfall pipeline rehabilitations and replacements. Plans are currently being prepared to address I/I related sewer main pipeline rehabilitations on the most deteriorated pipeline segments within the collection system. The continuing I/I reduction program will reduce the peak wet weather peak flows which must be processed through the plant, and coupled with the expanded peak design capacity of 3.0 times the projected 20 year average daily flow, design capacity of 26 MGD will allow the plant to adequately treat peak flows and eliminate the existing reduction in treatment efficiencies caused by high I/I laden flow events. Environmental Assessment for the City of High Point, Job No. E-1971 -34- . , 8.05 • Erosion Control The construction of the proposed project will be performed in accordance with an approved Erosion Control Plan. The Erosion Control Plan will include measures to control erosion during all phases of project construction. These measures will be used to prevent excess sediment runoff from the construction areas. Potential secondary erosion control impacts related with the development of the expanding service area will be minimized by the City of High Point Erosion and Sediment Control Ordinance. The purpose of the Ordinance is as follows: • Regulate certain land-disturbing activity to control accelerated erosion and sedimentation to prevent the pollution of water and other damage to lakes, watercourses, and other public and private property by sedimentation. • Establish procedures through which the purposes of soil erosion and sedimentation control can be fulfilled. The enforcement of the Ordinance will mitigate future erosion control concerns associated with ongoing development. 8.06 Construction Limits Construction limits will be clearly defined before construction commences to prevent the disturbance of areas outside the limits of the proposed project improvements. The purpose for setting construction limits is to prevent excess destruction of natural woodlands and grasslands in the surrounding areas. By setting these construction limits, surrounding wildlife will be minimally disturbed. Environmental Assessment for the City of High Point, Job No. E-1971 -35- 8.07 . Treatment Svstem Failure The design of the proposed expansion facilities will incorporate measures designed to minimize the likelihood of treatment system failure. The proposed expansion will include redundant equipment, parallel treatment processes, and alarm systems to alert operators of failure of crucial equipment. Redundant electrical power supplies will also be provided as part of the project improvements. The main and backup power supplies will each be sized to provide adequate power to operate critical plant components until full electrical power service is restored. Operation of the expanded plant will include preventive maintenance schedules designed to keep equipment in proper working order throughout its full service life and to replace equipment as needed. Environmental Assessment for the City of High Point, Job No. E-1971 -36- . TABLE 1 EASTSIDE WWTP EXISTING AND ESTIMATED FUTURE NPDES PERMIT LIMITS ** Parameter Existing Future * Summer (Winter) Summer (Winter) Flow 16 MGD 26 MGD BODS, Summer 8 mg/l, 1,068 lbs/day 5 mg/1, 1,084 lbs/day BODS, Winter 16 mg/l, 2,136 lbs/day 10 mg/l, 2,168 lbs/day NH3-N Summer 3 mg/l, 400 lbs/day 2 mg/l, 434 lbs/day NH3-N Winter 6 mg/1, 800 lbs/day 4 mg/1, 868 lbs/day Dissolved Oxygen 6 mg/l, 800 lbs/day 6 mg/1, 1,301 lbs/day Total Phosphorus No Limit 1 mg/l, 216 lbs/day Total Suspended Solids 30 mg/1, 4,003 lbs/day 30 mg/1, 6,505 lbs/day Total Nitrogen No Limit 6 mg/l, 1,301 lbs/day tt Fecal Coliforms 200/100 ml 200/100 ml Residual Chlorine No Limit 17 µg/l, 3.69 lbs/day pH 6-9 SU 6-9 SU Cadmium 2 µg/1, 0.27 lbs/day 2 ,ug/1, 0.43 lbs/day Chromium 50 µg/1, 6.67 lbs/day 50 µg/1, 10.84 lbs/day Nickel 88 µg/1, 11.74 lbs/day 88 µg/1, 19.08 lbs/day Nickel t -- 25 µg/1, 5.42 lbs/day Lead 25 µg/1, 3.34 lbs/day 25 µg/1, 5.42 lbs/day Cyanide 5 µg/1, 0.67 lbs/day 5µg/1, 1.08 lbs/day Fluoride No Limit 1.8 mg/l, 390 lbs/day Mercury No Limit 0.012 µg/1, 0.004 lbs/day Phenols t No Limit 1.0 µg/1, 0.22 lbs/day t Monitoring is also required for chronic toxicity (quarterly) and priority pollutants (annually). * Future limits as given in a letter to Mr. Linwood E. O'Neal from Mr. Steve W. Tedder dated September 18, 1995 - See Appendix. * * Winter limits are shown in parentheses where applicable. Limits are monthly averages except for DO which is a daily average and cyanide, fluoride, phenols, and metals which are daily maximums. Limit to be applied if Randleman Lake is constructed. i i Limit for Total Nitrogen required during months of April through October. Environmental Assessment for the City of High Point, Job No. E-1971 -37- References: 1) Hazen and Sawyer, P.C., "High Point Sewer System Report - Comprehensive Plan", March 1988. 2) Davis-Martin-Powell & Associates, Inc., "City of High Point - 201 Facilities Plan Amendment - Eastside & Westside Wastewater Treatment Plants", July 1994. 3) Davis-Martin-Powell & Associates, Inc., "City of High Point - Proposed Water Production Facilities Improvements", April 1994. 4) Camp Dresser & McKee, "City of High Point Eastside Wastewater Treatment Plant Evaluation", January 1995. 5) N.C. Division of Environmental Management Water Quality Section, "Draft Cape Fear River Basinwide Water Quality Management Plan", May 1995. 6) Malcolm Pirnie, Inc., "High Point, North Carolina Water Supply System Safe Yield Analysis", March 1995. 7) Hazen and Sawyer, P.C., "Draft Eastside Wastewater Treatment Plant Expansion and Upgrade", January 1996. 8) NC Division of Environmental Management, Water Quality Section, "Water Quality Monitoring Data for Waters in the Upper Deep River and Review of Deep River/Carbonton Water Quality Investigations", 1992/1993. 9) Black & Veach, "Final Environmental Impact Statement for Randleman Lake", October, 1991. Environmental Assessment for the City of High Point, Job No. E-1971 -38- ' r r, H 1• 1?° "??r r?l ?? G' p -C o° F- U- cu •'tt? r-. ??' • ?? ?i // H En p W Q I ?;; ?\\ ?\ X _..I H ?` ?` N c w Q a? \ ., ,I % ? .? ?,? J ? _ ? 7 ? ,? iii ? /?/??l I w ???_, • g . , ? ? ? I ? ?5??? / ' ? X00- 11 \\ \, ?? G?uf' ?• ?? ?? 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RANDOLPH & GUILFORD COUNTIES NORTH CAROLINA L zooo OS zooo Aooo WOO C4LE IN FEE- all is ,• - ? 9 ? a _ _ D `VIDSON COQ Z WWI a all r w W y = L EG EN? r-- EXIST. SERVICE AREA BOUNDARY a• FUTURE SERVICE AREA BOUNDA s .? ! J P m '° EXIST. SEWER OUTFALL FUTURE SEWER OUTFALL EXIST. FORCEMAIN EXIST. FUTURE FORCEMAIN PUMP W _ Y b V >/ % iii H AqEa ?- r-s - _ - ` > W LIJ Lo -i ?4\ n ?? ? r • lLY ? r y. X 0 z cc w 133 U) cn n ? si j - I ti b _ U) W t Lt, - w w a N eo CD m co m LL m CL U o r a a e yk c tq E a o° ° ; V w !cc i Co 6 r'n 0 C L ('n N a. as ? a M z co m cc m LL 0. cc m = X w W o? oz S ? C1 IN s` U z $ a O 3 a 8 S: f F ii EE !E :f z s a Appendix A Project Comment Letters from Federal and State Agencies Department of Environment, V _T Health and Natural Resources • • Division of Forest Resources om I James B. Hunt, Jr., Governor M Jonathan B. Howes, Secretacrets ry E H N F= Griffiths Forestry Center 2411 Old US 70 West Clayton, North Carolina 27520 June 7, 1995 Mr. Randy L. McNeill, P.E. Davis-Martin-Powell & Assoc. inc. 218 Gatewood Avenue, Suite 102 High Point, North Carolina 27262 Re: City of High Point Eastside Wastewater Treatment Plant Expansion Preliminary Engineering Report & Environmental Assessment DMP Job No. #-1971 (BF) Dear Mr. McNeill: Reference your scoping letter to me dated June 5, 1995, concerning the above proposed expansion. To better determine the impact to forestry in this urban setting, the Environmental Assessment should contain the following information concerning the proposed project: 1. The total forest land acreage by types that would be taken out of forest production as a result of all construction activities. 2. The productivity of the forest soils as indicated by the soil series, that would be involved within the proposed project. 3. The impact upon existing greenways within the area of the proposed project. 4. The provisions that the contractor will take to sell any merchantable timber that is to be removed. This practice is encouraged to minimise the need for piling and burning during construction. If any burning is needed, the contractor should comply with all laws and regulations pertaining to debris burning. 5. The provisions that the contractor will take during the construction phase to prevent erosion, sedimentation and construction damage to forest land outside of construction limits. Trees outside the construction limits should be protected from construction activities to avoid: a. Skinning of tree trunks by machinery. b. Soil compaction and root exposure or injury by heavy equipment. C. Adding layers of fill dirt over the root systems of trees, a practice that impairs root aeration. d. Accidental spilling of petroleum products or other damaging substances over the root systems of trees. 6. Any cumulative impacts to woodland as a result of the expansion to the water and sewer in the service area. Of particular concern would be a good estimate of future loss of woodland acres from future development coming into the service area as a result of increased waste capacity ability. We would hope that the project would have the least impact to forest and related resources in that area. Sincerely, ? 19? ins, Staff Forester onH. Robb - pc: Melba McGee -Office of Legislative Affairs Vic Owen - D-10 Warren Boyette - CO File J P.O. Box 27687, Rdeigh, North Carolina 27611-7687 Telephone 919-733-2162 FAX 919-733-0138 An Equal Opportunity Affirmative Action Employer 50% recycled/ t o% post-consumer paper N.G. DIVISION OF MARINE FISHERIES STAnSUMS & INFOW4AMONIA 69 G, EM ENT SECnON 3441 Arendell Morehead City, NC 28557-0769 (919) 726-7021 FAX (919) 726 7222 FAX COVER. SHEET DATE: TIME: 4- 7 tar e -q TO: . AG _ FAX #: FROM. NUMBER OF PAGES, INCLUDING COVER: / MESSAGE: yt e :`? ar.f , Gds; r=0' yam--_ , 1i?rt?C r/1 JIUIC VI Ivor ?? ?.urvur iu DT-V 1V epartment of Environment, Health and Natural Resources / • • Division of Parks & Recreation James B. Hunt, Jr., Governor E H N F1 Jonathan B. Howes, Secretary Dr. Philip K. McKnelly, Director June 19, 1995 Nickie D. Mills Davis-Martin-Powell and Associates, Inc. 218 Gatewood Avenue, Suite 102 High Point, NC 27262 Subject: Eastside Wastewater Treatment Plant Hxpansicn, City of High Point The Division does not know of any parks or recreational areas in the vicinity of the proposed wastewater plant expansion that might be adversely affected by the project, nor are there any Wild and Scenic Rivers located in this part of the state. According to the Natural Heritage Program database, no federal or state-listed:species of plants or animals have been recorded within a five mile radius of the project site. Thank you for the opportunity to comment on this project. If you need any further information, please feel free to contact us. Sincerely, S ?L" P, b ?Stephen P. Hall, Environmental Review Specialist North Carolina Natural Heritage Program P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4181 FAX 919-715-3085 An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper M ?Or ?• North Carolina Department of Cultural Resources James B. Hunt, Jr„ Governor Betty Ray McCain. Secretary June 22, 1995 Nickie D. Mills Davis-Martin-Powell & Associates, Inc. 218 Gatewood Avenue, Suite 102 High Point, NC 27262 Re: High Point Eastside Wastewater Treatment Plant expansion, preliminary engineering report and environmental assessment, DMP Job. No. E- 1971 (BF), Guilford County, ER 95-9148 Dear Mr. Mills: Division of Archives and History William S. Price, Jr.. Director Thank you for your letter of June 5, 1995, concerning the above project. We have conducted a search of our files and are aware of no structures of historical or architectural importance located within the planning area. However, since the 1975 architectural survey of Guilford County has not been updated, there may be structures of which we are unaware located within the planning area. We are concerned with the presence of historic structures in any area which is not currently part of the wastewater treatment plant. Please send us photographs of all structures over fifty years old in the proposed expansion area if the plant is to be expanded outside of the current boundaries. We understand the selection and review of an expansion site is not within the project scope of the preliminary engineering report. Please forward this information to us when it becomes available. Seven archaeological sites are located west of the existing High Point Eastside wastewater treatment plant. These sites vvere recorded in 1976 by Scil Systems, Inc., in connection with the Richland Creek outfall project. None of these sites are considered to be eligible for the National Register of Historic Places. We recommend that you forward a map showing the location of any expansion area outside of the existing wastewater treatment plant boundaries so we can evaluate potential effects to unrecorded archaeological resources. The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR Part 800. 109 East Jones Street - Raleigh, North Carolina 27601-2807 Thank you for your cooperation and consideration. If you have questions concerning the above comment, please contact Renee Gledhill-Earley, environmental review coordinator, at 919/733-4763. Si rely, f c? David Brook Deputy State Historic Preservation Officer DB:slw cc: Guilford County Joint Historic Preservation Commission Department of Environment, Health and Natural Resources Winston-Salem Regional Office James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary Leesha Fuller, Regional Manager Mr. Nickie D. Mills, EIT Davis-Martin-Powell & Assoc., Inc. 218 Gatewood Avenue, Suite 102 High Point, NC 27262 June 26, 1995 Subject: High Point's Eastside WWTP Expansion Preliminary EA Considerations DMP Job No. E-1971 (BF) Guilford County Dear Mr. Mills: 1•• E3aHNF;Z DIVISION OF ENVIRONMENTAL MANAGEMENT In response to your written request of June 5, 1995 concerning your preliminary engineering report and preliminary environmental assessment, the following items should be given consideration in your analysis: 1. Physical Plant: a. Flooding concerns at the plant b. Acquiring 404/401 Certifications for actual expansion c. I&I studies and associated collection system classification and necessary system improvements d. High flow treatability and short-circuiting (reduced treatment) associated with rainfall e. Flow measurement accuracy during and after significant rainfall events f. Alternate disinfection such as Ultraviolet or Ozonation g. Water reuse and recycling potentials 2. Chemical & Physical Processes: a. Cyanide concerns in wastestream and effluent b. Phosphorus removal by chemical processes as well as biological removal efficiency c. Foaming and color in effluent (previous and future complaints) d. Color removal and associated benefits to treatment efficiency e. TOC review and future loading considerations f. Pretreatment opportunities and potential improvements g. Land application or other disposal options (incineration, etc.) 585 Waughtown Street, Winton-Salem, North Carolina 27107-2241 Telephone 910-771-4600 FAX 910-771-4631 An Equal Opportunity Affirmative Action Employer 50% recycled/ 1076 Post-Consumer paper The EA or EIS should provide a thorough review of the potential impacts to downstream natural environments and potential requirements for this discharge if the Randleman Dam is built. Best available technologies (BATs) may become necessary and appropriate. If so, the reuse and recycling of water should be given ample consideration. Flow measurement at this facility during rain events is a concern. The plant is permitted for 16.0 MGD and flows up to 32 MGs are not uncommon. It is our understanding that flow measurements less than 35 Mgs may be somewhat accurate but that greater flow values are extremely suspect. Repair and replacement of portions of the collection system should be given expanded and integral consideration as the WWTP experiences significant high flows which reduce treatment during storm events (both short and long term events). Expanded equalization may provide some buffering; however, major I&I should be addressed at the source and in an ongoing manner. Failure to reduce I&I could jeopardize or negatively impact expansion of the plant and future municipal growth as well as precipitate flow allocation processes by this Division. Health concerns and third party suits will likely become more of a potential if insufficient treatment and pass throughs of high flows continue to be a concern should these waters become water supply waters. The Region recommends that you thoroughly review the Compliance Sampling Inspection letter sent to Mr. Linwood O'Neal on March 29, 1995 for additional concerns and considerations. The WSRO is aware that an "Eastside WWTP Evaluation Study" was completed in January by Camp, Dresser and McKee. The Region requested a copy of this document in order to gain additional insights concerning the WWTP and potential impacts to the proposed Randleman dam and associated water quality issues. The Region has requested a copy of this document and would defer making additional comments on any draft High Point Eastside EAs until after reviewing the study. This study could also provide insight useful in your EA. The Region is unaware of any considerations for the proposed EA to become an EIS; however, it may behoove DMP and the City of High Point to request a determination as to which is more appropriate (if not previously done). Comments provided herein are provided in order to offer additional insights and should not be considered as an official review or approval of this project. If you have any questions regarding this letter, please call Mr. Ron Linville, Mr. Jim Johnston or me at (910) 771-4600. Sincerely, Steven M ey Water Quality Supervisor cc: Ken Carter, Guilford County Environmental Health Division Director Michelle Suverkrubbe, Guilford County Planning Dept. WSRO Central Files \hipt-exp.eis Department of Environment, Health and Natural Resources / • • Division of Coastal Management James B. Hunt, Jr., Governor Jonathan B. Howes, , Secretary Roger N. Schecter, Director July 3, 1995 Nickie D, Mills Randy L. McNeill Davis Martin Powell, & Associates 218 Gatewood Avenue Suite 102 High Point, NC 27262 Dear Sirs: Thank you for your letter dated June 5, 1995 concerning the proposed expansion of the City of High Point's Wastewater Treatment Plant. As the proposed activity will not be located on a barrier island subject to the Coastal Barrier Resources Act of 1982, the act will not apply to the proposed activity. Similarly, since the proposed activity is not located within the North Carolina coastal area and the activity will not affect resources or uses of the coastal area, the Coastal Zone Management Act of 1972 is not applicable to the proposed activity. Thank you for your consideration of the North Carolina Coastal Management Program. Sincerely, tephen B. Benton Consistency Coordinator P.O. Box 27687, Rdeigh, North caroiina 27611-7687 Telephone 919-733-2293 FAX 919-733-1495 An Equal opportunity Affirmative Action Employer $0% recycled/ 10% post-consumer paper Department of Environment, Health and Natural Resources Division of Water Resources James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary John N. Morris, Director July 13, 1995 Mr. Nickie D. Mills, EIT Mr. Randy L. McNeill, P.E. Davis, Martin, Powell & Associates, Inc. 218 Gatewood Avenue, Suite 102 High Point, N.C. 27262 Dear Messrs. Mills & McNeill: 0 40 9' 4,14 AC4*1' [D FE F=1 I am responding to your June 5, 1995 letter requesting comments on the preparation of an Environmental Assessment for the expansion of High Point's East Side Wastewater Treatment Plant. I have the following questions and comments: 1. Will'the proposed expansion include an upgrade of existing facilities to remove phosphorus and possibly nitrogen so that downstream water quality can be improved? 2. How will you approach the Randleman Lake issue? 3. Will you outline secondary and indirect effects of the expansion? 4, You will want to make sure that the sewage flow projections for the City of High Point service area are tied to the City's water supply projections as found in its Local Water Supply Plan. Thank you for the opportunity to comment on this project. Sincerely yours, John D. Sutherland, Chief Water Resources Planning Section JDS\bb cc: Mr. Woody Yonts P.C. Box 27687, Raleigh, North Carolina 27611-7687 Telephone 919-733-4064 An Equol opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper ® North Carolina Wildlife Resources Commission 512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733-3391 Charles R. -Fullwood, Executive Director July 25, 1995 Mr. Nickie D. Mills, EIT Mr. Randy L. McNeill, PE Davis - Martin - Powell & Associates, Inc. 218 Gatewood Avenue SU 102 High Point NC 27262 Subject: Scoping for City of High Point Eastside Wastewater Treatment Plant Expansion, Guilford County, NC Gentlemen: This letter responds to your request regarding impacts on fish and wildlife resources resulting from the subject utility improvements. Our comments are provided in accordance with certain provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d), Section 201 of the Clean Water Act, and the North Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; 1 NCAC 25). The proposed project consists of expanding the Eastside Wastewater Treatment Plant (WWTP) from 16 mad to 24 mad or 26 mad. The improvements will be confined to the existing plant site and adjacent lands; therefore we would not expect that impacts to wildlife habitat would be significant. However, the information provided is not sufficient to make an assessment of the impacts to fish and wildlife or their respective habitats. Our major concern about this project is the direct impact on water quality in Richland Creek and downstream in the Deep River. Richland Creek and segments of the Deep River are currently listed as impaired by Department of Environmental Management. The Eastside WWTP is a significant point source that contributes to the degraded state of these streams. The EA should thoroughly discuss the impacts of this additional discharge on water quality and downstream aquatic habitats. A second concern is the secondary cumulative impact from development spurred by the increased capacity at the WWTP. We recommend that ultraviolet light be used for disinfection instead of chlorination where the clarity of effluent makes this feasible. If poor effluent quality precludes the use of ultraviolet disinfection, we request that wastewater treatment plants be equipped with backup dechlorination systems and emergency power supplies. Ultraviolet systems should also be supplied with emergency power. Due to staff limitations, this standardized response was developed for projects such as this. Although some of the information requests and comments may not be applicable to certain projects, these guidelines should facilitate preparation of fish and wildlife impact assessments. aubra A Vyur LdriJ LJrrrV •r .• a y r .. ?! --, -- ' - Scoping This information will be very useful if it becomes necessary to prepare an environmental document. The environmental document should include a detailed assessment of existing natural resources within these areas of potential development and should discuss the potential of mitigating development impacts to wetlands, waters, and high quality upland habitat. To provide a meaningful review of proposed project impacts on fish and wildlife resources, we request that consultants, project sponsors, or permit applicants provide the following information in the environmental document: 1. Include descriptions of fish and wildlife resources within the project area, and a listing of federally or state designated threatened, endangered, or special concern species. When practicable, potential borrow areas to be used for project construction should be included in the inventories. A listing of designated species can be developed through consultation with: The Natural Heritage Program, NC Division of Parks and Recreation, P. 0. Box 27687, Raleigh, N. C. 27611, (919) 733-7795 2. Include descriptions of any streams or wetlands affected by the project and their proximity to construction areas. 3. Include project maps identifying wetland areas. Identification of wetlands may be accomplished through coordination with the U.S. Army Corps of Engineers (COE). If the COE is not consulted, the person delineating wetlands should be identified and criteria listed. 4. Provide a description of project activities that will occur within wetlands, such as fill or channel alteration. Acreage of wetlands impacted by alternative project designs should be listed. 5. Provide a description and a cover type map showing acreage of upland wildlife habitat impacted by the project. 6. Discuss the extent to which the project will result in loss, degradation, or fragmentation of wildlife habitat (wetlands and uplands). 7. Discuss any measures proposed to avoid or reduce impacts of the project or to mitigate unavoidable habitat losses. 8. Discuss the cumulative impacts of secondary development facilitated by the proposed utilities improvements. Such discussion should weigh the economic benefits of such growth against the costs of associated environmental degradation. Include a discussion of any local ordinances or programs that mitigate these adverse impacts, such as: stormwater management, industrial pretreatment, infiltration and inflow management, water conservation programs, and stream corridor protection. 9. Include a list of document preparers which shows each individual's professional background and qualifications. Measures to avoid or minimise impacts to sensitive resources, including wetlands, should be implemented during construction. Where impacts to wetlands are unavoidable, we will recommend mitigation of the losses. In addition to providing wildlife habitat, wetland areas perform important functions of flood control and water quality protection. Scopmg To avoid or minimize wetland impacts, we offer several generalized recommendations. Utility lines should be placed in or adjacent to upland areas. It is recommended that a minimum 100-foot buffer of natural vegetation be left between construction corridors and perennial streams. These buffers will help minimize impacts to water quality, stabilize stream banks, and provide travel corridors for wildlife. Trees and shrubs should be retained or established in the buffers. Buffers should also be left along intermittent drains or streams. Construction corridors should be no wider than absolutely necessary. The 401 certification for Nationwide Permit 12 stipulates that wetland construction corridors are not to exceed 40 feet and permanent maintained corridors are not to exceed 10 feet except at access points. Plant communities should be re-established which would result in wetland plant community succession into habitat of equal or greater value than that which was destroyed. Disturbed wetland areas should be returned to original soils and contours. Temporarily disturbed wetlands should be reseeded with annual small grains appropriate for the season (e.g. oats, millet, rye, wheat, annual lespedeza or rye brass) and be allowed to revert to natural wetland vegetation. Crossings of wetlands and streams should be minimised, located at narrow areas, and made perpendicular to the stream. Thank you for the opportunity to provide input in the early planning stages for this project. If I can further assist your office, please contact me at (919) 528-9886. Sincerely, Owen F. Anderson Piedmont Region Coordinator cc: Melba McGee, Office of Legislative and Intergovernmental Affairs L.K. Gantt, Supervising Biologist, USFWS John Alderman, Nongame/Endangered Species Biologist Shari Bryant, District 5 Fisheries Biologist Larry Warlick, District 5 Wildlife Biologist Department of Environment, Health and Natural Resources Winston-Salem Regional Office James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary Leesha Fuller, Regional Manager Mr. Nickie D. Mills, EIT Davis-Martin-Powell & Assoc., Inc. 218 Gatewood Avenue, Suite 102 High Point, NC 27262 June 26, 1995 Subject: High Point's Eastside WWTP Expansion Preliminary EA Considerations DMP Job No. E-1971 (BF) Guilford County Dear Mr. Mills: 1•• oft [DaHNF;Z DIVISION OF ENVIRONMENTAL MANAGEMENT In response to your written request of June 5, 1995 concerning your preliminary engineering report and preliminary environmental assessment, the following items should be given consideration in your analysis: Physical Plant: a. Flooding concerns at the plant b. Acquiring 404/401 Certifications for actual expansion c. I&I studies and associated collection system classification and necessary system improvements d. High flow treatability and short-circuiting (reduced treatment) associated with rainfall e. Flow measurement accuracy during and after significant rainfall events f. Alternate disinfection such as Ultraviolet or Ozonation g. Water reuse and recycling potentials 2. Chemical & Physical Processes: a. Cyanide concerns in wastestream and effluent b. Phosphorus removal by chemical processes as well as biological removal efficiency c. Foaming and color in effluent (previous and future complaints) d. Color removal and associated benefits to treatment efficiency e. TOC review and future loading considerations f. Pretreatment opportunities and potential improvements g. Land application or other disposal options (incineration, etc.) 585 Waughtown Street. Winston-Salem. North Carolina 27107-2241 Telephone 910-771-4600 FAX 910-771-4631 An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper The EA or EIS should provide a thorough review of the potential impacts to downstream natural environments and potential requirements for this discharge if the Randleman Dam is built. Best available technologies (BATs) may become necessary and appropriate. If so, the reuse and recycling of water should be given ample consideration. Flow measurement at this facility during rain events is a concern. The plant is permitted for 16.0 MGD and flows up to 32 MGs are not uncommon. It is our understanding that flow measurements less than 35 Mgs may be somewhat accurate but that greater flow values are extremely suspect. Repair and replacement of portions of the collection system should be given expanded and integral consideration as the WWTP experiences significant high flows which reduce treatment during storm events (both short and long term events). Expanded equalization may provide some buffering; however, major I&I should be addressed at the source and in an ongoing manner. Failure to reduce I&I could jeopardize or negatively impact expansion of the plant and future municipal growth as well as precipitate flow allocation processes by this Division. Health concerns and third party suits will likely become more of a potential if insufficient treatment and pass throughs of high flows continue to be a concern should these waters become water supply waters. The Region recommends that you thoroughly review the Compliance Sampling Inspection letter sent to Mr. Linwood O'Neal on March 29, 1995 for additional concerns and considerations. The WSRO is aware that an "Eastside WWTP Evaluation Study" was completed in January by Camp, Dresser and McKee. The Region requested a copy of this document in order to gain additional insights concerning the WWTP and potential impacts to the proposed Randleman dam and associated water quality issues. The Region has requested a copy of this document and would defer making additional comments on any draft High Point Eastside EAs until after reviewing the study. This study could also provide insight useful in your EA. The Region is unaware of any considerations for the proposed EA to become an EIS; however, it may behoove DMP and the City of High Point to request a determination as to which is more appropriate (if not previously done). Comments provided herein are provided in order to offer additional insights and should not be considered as an official review or approval of this project. If you have any questions regarding this letter, please call Mr. Ron Linville, Mr. Jim Johnston or me at (910) 771-4600. Sincerely, ??. Steven M ney Water Quality Supervisor cc: Ken Carter, Guilford County Environmental Health Division Director Michelle Suverkrubbe, Guilford County Planning Dept. WSRO Central Files \hipt-exp.eis Department of Environment, Health and Natural Resources Division of Environmental Health b T Public Water Supply Section - tIA James B. Hunt, Jr., Governor Q a H N R Jonathan B. Howes, Secretary Linda C. Sewall, Director August 11, 1995 Mr. Randy L. McNeill, P.E. Davis-Martin-Powell & Associates, Inc. 218 Gatewood Avenue, Suite 102 High Point, North Carolina 27262 Re: City of High Point Eastside Wastewater Treatment Plant Expansion Dear Mr. McNeill: This letter response to your letter dated June 5, 1995 addressed to Linda Sewall requesting comments on the Preliminary Engineering Report and Environmental Assessment for the City of High Point Eastside Wastewater Treatment Plant Expansion. The comments are prepared by Lee Spencer, the Public Water Supply Section regional engineer in the Winston-Salem office. We apologize for not meeting the August 1, 1995 deadline. If you have any questions on the comments, please call Lee Spencer at (919) 771-4600. Sincerely, Paul B. Clark Environmental Engineer Public Water Supply Section PBC cc: Linda Sewall, Division of Environmental Health-Director Lee Spencer, Regional Engineer P.O. Box 29536, Raleigh, North Carolina 27626-0536 Telephone 919-733-2321 FAX 919-715-3242 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper Department of Environment, to Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director Q? ? ?EHNR September 18, 1995 Mr. Linwood E. ONeal, P.E. Director of Public Utilities P.O. Box 230 High Point, NC 27261-0230 Subject: Speculative Discharge Limits 14PDES Permit No. NC-0024210 City of High Point - Eastside WWTP Guilford County Dear Mr. ONeal: Reference is made to the requests submitted by James Cramer of Hazen and Sawyer and Nickie Mills and Randy McNeill of Davis - Martin - Powell & Associates for speculative limits for the potential expansion of the High Point - Eastside Wastewater Treatment Plant from 16 MGD to 24 or 26 MGD. The Division of Environmental Management (DEM) is hereby supplying limits that would presently be applied to the discharge at its current location in Richland Creek with and without consideration of the proposed Randleman Lake reservoir, as requested. At the point of High Point's discharge Richland Creek is a small urban stream with a 7Q10 flow of 1.0 cfs. At 24 MGD, the Eastside WWTP discharge would constitute an instream waste concentration of 97% during 7Q10 flow conditions (98% at 26 MGD). In addition, DEM ambient stream monitoring stations located below the outfall have detected summer occurrences of dissolved oxygen levels below the state standard of 5.0 mg/L The Division's modeling efforts have indicated that the discharge will have to meet advanced tertiary treatment limits in order to adequately protect the receiving stream. For wasteflows of 24 or 26 MGD, the Eastside WW'TP would be required to meet the following limits for conventional pollutants: aramet nit Limits (monthly avg.) BOD5 (Sum(Win) mg/l 5110 NH3N (Sum/Win) mg/l 2/4 DO (minimum) 1119/1 6.0 TS S mg/1 30 pH S U 6.0-9.0 Fecal Coliform /100 ml 200 Total Phosphorus mg/l 1.0 Total Nitrogen mg/1 6.0 P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 1o% post-consumer paper %.?Ly ui rugs roue - rasUIae w w 1r September 18, 1995 Page 3 application for a project requiring an EA until the document has been approved by the Department of Environment, Health and Natural Resources and a Finding of No Significant Impact (FONSI) has been sent to the state Clearinghouse for review and comment. The EA should contain a clear justification for the proposed facility and an analysis of potential alternatives which should include a thorough evaluation of non-discharge alternatives. In addition, an EA should show how water reuse, conservation and inflowrmfiltration reductions have been considered. Nondischarge alternatives, such as spray irrigation, water conservation or inflow and infiltration reduction, are considered to be environmentally preferable to an expanded surface water discharge. In accordance with the North Carolina General Statutes, the practicable waste treatment and disposal alternative with the least adverse impact on the environment is required to be implemented. If the EA demonstrates that the project may result in a significant adverse affect on the quality of the environment, an Environmental Impact Statement would be required. Monica Swihart of the Water Quality Planing B.-anch can provide further information regarding the requirements of the N.C. Environmental Policy Act. In light of the EA/EIS requirements, it should be noted that DEM staff at the Winston- Salem Regional Office have expressed concerns over the impact of inflow and infiltration (I&I) on the hydraulic capacity at the Eastside WW'I'P. DEM strongly urges the City to aggressively pursue efforts to identify and reduce areas of I&I at the source, rather than addressing potential peak flows through construction and operational activities at the treatment plant. Identification and replacement of delapidated sewer lines may prove to be significantly more advantageous, economically and environmentally, than large increases in the hydraulic capacity of the treatment plant proper. Any EA or EIS submitted in support of a flow increase should include an in depth study and review of this concern. Please also note that these are speculative limits and are not binding unless the limits are part of an issued NPDES permit. All information pertaining to this request has been sent to our Central Files for storage. When you are ready to request the increase, please submit a complete application package including fees appropriate for that point in time. If you have any questions please contact Jason Doll at (919) 733-5083 ext 507. Sincerely , -e IV! ?C.eve W. Tedder, Chief Water Quality Section ac: Randy L. McNeill, P.E. - Davis - Martin - Powell & Associates Nickie D. Mills, EIT - Davis - Martin - Powell & Associates James A. Cramer, P.E. - Hazen and Sawyer Don Safrit - Technical Support Branch David Goodrich - NPDES Permits Group Winston-Salem Regional Office Central Files