19970722 Ver 1_More Info Received_19971009

August 11, 1997
MEMORANDUM
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ENVIRnNMENTALSCIENCES
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TO: Melba McGee
Office of Legislative and Intergovernmental Affairs
FROM: Lee G. Spencer, Regional Engineer
Public Water Supply Section
Winston-Salem Regional Office
SUBJECT: Project No. 98-0029 - Proposed Randleman Lake
Randolph County
This office has a number of concerns about this draft
Environmental Impact Statement (EIS) and a number of concerns about
the proposed Randleman Lake itself. water supply and wastewater
disposal for this entire area (in Guilford and Randolph counties)
is a complex and controversial issue. It should be viewed from a
broad and long term perspective.
"Areas of Controversy" under Section 1.5 in the Summary of the
EIS did not include: (1) Potential extremely high nutrient loadings
into the proposed lake from dairy farms and urban runoff, in
addition to High Point's Eastside wastewater treatment plant
(WWTP); (2) Inflow/Infiltration in High Point's wastewater
collection system which will cause sewage to bypass the new
tertiary WWTP during larger storm events and be collected in the
proposed lake; (3) The detrimental effects, in addition to the
positive effects, of the long retention time in the proposed lake.
How can the EIS state under Section 1.6 in the Summary that
"There are no unresolved issues"? Water quality standards and
action levels are not currently met in this stream.
Other concerns include
protection, and water quality
issues are outlined below:
alternatives analysis, watershed
issues. Comments on each of these
I - Alternatives Analysis
If the Randleman Lake project goes through, as the EIS points
out, there will be a substantial interbasin transfer from the Deep
River basin to the Haw River Basin. Instream waste concentrations
of both Greensboro's and High Point's wastewater effluent flows
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Randleman Lake EIS Comments
August 11, 1997
Page 2
are very high. A significant portion of the flow into' the proposed
Randleman Lake Reservoir will be from High Point's wastewater
effluent flow. With this in mind, perhaps additional consideration
should be given to Greensboro conducting wastewater reuse/recycling
within their own basin. Indeed, this would provide incentive for
optimum wastewater treatment, and would perhaps be a model for our
part of the country. This alternative is not listed under Section
1.3 of the EIS.
Withdrawals from the Dan or Yadkin Rivers are not listed as
alternatives in the EIS. Interbasin transfers and water rights
issues would come into play, but water quality in each of these
streams is considered good. Also, these streams are already
classified and used for water supply.
Why was alternative D eliminated from detailed evaluation?
What "serious deficiencies" make purchasing at least some water
from Burlington and/or Winston-Salem unacceptable?
II - Watershed Protection
Continued urbanization of this already stressed watershed is
of concern (see water quality issues below). Why are local water
supply watershed ordinances in place for Guilford County, Randolph
County, and Greensboro, but not for High Point, Jamestown, and
Archdale?
How was "primarily undeveloped" determined for the Randleman
Lake Watershed in Table 1?
III - Water Quality Issues
A DEM memorandum dated March 2, 1993, revealed water quality
problems on this portion of the Deep River. This memorandum states
that "A review of the data reveals that quite a bit of data exceed
water quality standards both as presently classified as well as if
these waters were classified as a water supply." This memorandum
goes on to say that testing indicated that a lake situation
downstream has the potential for significant problems from algal
response to nutrients.
This office received on August 22, 1995, two reports on water
quality in the Deep River. Both documents were approved on
September 28, 1994, by Steve Tedder, Chief of the Water Quality
Section. One is entitled "Water Quality Monitoring Data For Waters
in the Upper Deep River Area, July 28, 1992 - October 7, 199311, and
the other is entitled "Review of Deep River/Carbonton Water Quality
Randleman Lake EIS Comments
August 11, 1997
Page 3
Investigations, 1992/1993". These reports were very informative
and obviously the result ofa great deal of work.
Both of these reports reference various water quality
violations and chemical detections in the Deep River. During the
sampling period, water quality violations were found for dissolved
oxygen, fecal coliform bacteria, Lindane, and Dieldrin. Action
level exceedences were found for copper, zinc, and iron. Detection
levels were found for phenols, and 1,376 unidentified organic
chemicals. Elevated nutrient levels were found throughout the
study area.
These reports all reveal water quality problems on the Deep
River. Two of the reports indicate that a lake situation in the
study area has the potential for significant problems from algal
response to nutrients. The EIS does discuss these studies on Page
4-10, but does not fully address the "continuing problems" with
water quality. 0
Have all identified sources of pollution, both point and non-
point, been addressed in light of the proposed Randleman Lake
Reservoir for a public water supply source on the Deep River?
Has there been any sampling for Crypto sporidium or Giardia
parasites in light of their resistance to many disinfection
techniques, and in light of the large dairy farms in the Muddy
Creek watershed of the proposed lake?
Is the statement accurate on Page 5-15, which says "The water
quality of Randleman Lake is expected to be within the range of
values measured at other eutrophic lakes in N.C.? If so, how was
this determined?
This office would like to see all the above issues addressed
in the Environmental Impact Statement.
cc: Jessica G. Miles, Section Chief, Public Water Supply
Faith Abbott, Public Water Supply, Raleigh
August 20, 1997
TO: Faith Abbott, Environmental Engineer
Public Water Supply Section
Raleigh Central Office
FROM: Lee G. Spencer, Regional Engineer
Public Water Supply Section
Winston-Salem Regional Office
SUBJECT: Piedmont Triad Regional Water Authority
Randleman Water Treatment Plant
Environmental Assessment - July 1997
Randolph County
This office has reviewed the above referenced Environmental
Assessment (EA). We have a number of concerns about the proposed
Randleman Lake for a public water supply source. As you know, I
sent a memorandum on the recent draft Environmental Impact
Statement (EIS) for Randleman Lake to Melba McGee on August 11,
1997. A number of the concerns about the EIS apply to this EA.
There is one primary concern about the EA for the Water
Treatment Plant. Is the proposed water supply suitable for use as
a public water supply source, and has the best available water
source in this area for a public water supply been chosen? North
Carolina General Statute (NCGS) 130A-316 charges us with
examination of waters, sources, and surroundings which are proposed
to be used as a public water supply. We are to determine whether
the waters and their sources are suitable for use as a public water
supply source. NCGS 130A-317 further charges us with advising all
persons of the most appropriate source of public water supply.
With the above in mind, this office would like to have some
issues adequately addressed. These include alternatives analysis,
watershed protection, and water quality issues. Comments on each
of these issues are outlined below:
I - Alternatives Analysis
This office is aware that a new public water supply source is
sorely needed in this area due to growth and economic prosperity.
However, we would like to make sure that all other alternatives to
Randleman WTP EA
August 20, 1997
Page 2
this project have been sufficiently explored and eliminated.
If the Randleman Lake project goes through, as the EIS points
out, there will be a substantial interbasin transfer from the Deep
River basin to the Haw River Basin. In stream waste concentrations
of both Greensboro's and High Point's wastewater effluent flows
are very high. A significant portion of the flow into the proposed
Randleman Lake Reservoir will be from High Point's wastewater
effluent flow. With this in mind, has consideration been given to
Greensboro (the largest user) conducting wastewater reuse/recycling
within their own basin? Indeed, this would provide incentive for
optimum wastewater treatment, and would perhaps be a model for our
part of the country. Why is this alternative not listed in the EA?
Why are withdrawals from the Dan or Yadkin Rivers not listed
as alternatives in the EA? Interbasin transfers and water rights
issues would come into play, but water quality in each of these
streams is considered good. Also, these streams are already
classified and used for public water supply.
Why is purchasing finished water from Burlington and/or
Winston-Salem not listed as an alternative in the EA?
II - Watershed Protection
Continued urbanization of this already stressed watershed is
of concern (see water quality issues below). Why are local water
supply watershed ordinances in place for Guilford County, Randolph
County, and Greensboro, but not for High Point, Jamestown,
Archdale, and Randleman? Will all the water supply watershed
ordinances, once in place, adequately address non-point source
pollution? Do the large animal operations on the Muddy Creek arm
of the proposed lake pose a pollution and health risk from runoff
and spills?
III - Water Quality Issues
A DEM memorandum dated March 2, 1993, revealed water quality
problems on this portion of the Deep River. This memorandum states
that "A review of the data reveals that quite a bit of data- exceed
water quality standards both as presently classified as well as if
these waters were classified as a water supply." This memorandum
goes on to say that testing indicated that a lake situation
downstream has the potential for significant problems from algal
response to nutrients.
This office received on August 22, 1995, two reports on water