19970722 Ver 1_More Info Received_19970808

Division of Water Quality
August 8, 1997
Q ?
MEMORANDUM
To: Michelle Suverkrubbe
From: Jimmie Overton
Subject: Comments on the Ran eman Lake Draft Environmental Impact Statement
Enclosed are comments on the draft Environmental Impact Statement (EIS) for the proposed
impoundment of the Deep River to be known as Randleman Lake.
Concern over eutrophication predicted in this proposed drinking water supply reservoir is
warranted. Statements presented in the draft EIS indicate a strong likelihood that biological
response to eutrophication will be expected to violate water quality standards. The Deep River
consistently exhibits problems associated with elevated nutrient loading such as nuisance algal
blooms and low dissolved oxygen. The EIS states that Randleman Lake would be expected to
violate the state water quality standard for chlorophyll a (40 µg/L) 12% of the time for the
reservoir, as a whole, and 80% of the time in the upper Deep River portion of the reservoir and
1% of the time near the drinking water intake. Even with the High Point East WWTP operating at
greatly reduced levels of phosphorus (costs for nutrient removal do not appear to be included in
the EIS) the lake is expected to have violations of the water quality standard for chlorophyll a.
The report states that "the studies predicted that substances that are possible in raw water of the
lake would be sufficiently removed by conventional water treatment and that finished water
would meet all drinking water standards." This approach ignores other potential uses of the
reservoir as well as the in-stream and in-lake standards to protect these uses including
maintenance and propagation of aquatic life and secondary recreation such as wading and boating.
The prediction of routine water quality violations should be explicitly outlined during this EIS
process.
If you have any questions or need additional information, please call John Dorney (733-1786) or
Jay Sauber (733-6510) or me (733-9960).
cc Jay Sauber
John Dorney
Larry Ausley
Steve Tedder
Ron Linville
Steve Mauney
Judy Garrett
Environmental Sciences Branch Water Quality Section
Environmental Sciences Branch Comments
Draft EIS for Randleman Lake
August 8, 1997
GENERAL COMMENTS
1. Throughout the report, the NCDWQ is referred to as NCDEM
(example page 4-5)
2. Mercury - The Randleman Lake watershed has several abandoned
gold mine and at least one abandoned gold processing site
(McCullers (sp) Mill) where mercury was dumped into Copper Branch
after it was used to process the gold ore. Mercury is of concern
due to potential food chain bioaccumulation. The EIS should
describe a plan to assess mercury concerns in the basin and them
ameliorate them.
3. Additional nutrients to Jordan Lake - The interbasin transfer
described in the EIS will result in additional nutrient input into
Jordan Lake which is already experiencing eutrophication problems.
The EIS should address whether this addition of nutrients will
exacerbate the existing eutrophication problems in Jordan Lake.
4. NSW designation - If Randleman Lake is built, it is very
likely that the Environmental Management Commission will have to
reclassify streams in the watershed as Nutrient Sensitive Waters
due to the eutrophication potential. The EIS should address the
economic and development impacts of this designation.
5. Wetland Mitigation - As discussed in the Draft EIS, the
applicant has agreed to create/restore 120 acres of wooded
wetlands along the tributaries of Randleman Lake. This provision
will be a requirement of any 401 Water Quality Certification for
the lake. The water quality benefits of these wetlands in
removing nutrients could be quantified by the applicant in the
final EIS if desired.
6. Eutrophication - The report states that the chlorophyll a
water quality standard will be exceeded 12% of the time for the
entire reservoir and 80% of the time for the Deep River arm of
the reservoir based on modeling. The 401 Water Quality
Certification is a statement that water quality standards will not
be violated. The EIS should address how the state can legally
issue a 401 Water Quality Certification for this project in light
of the predicted violation of the chlorophyll a water quality
standard. In this respect, other alternatives such as the
Benaja/Polecat Creek Lake alternative would likely be easier to
certify due to their relatively undisturbed watersheds and lack of
wastewater discharge.
7. The headwaters of Randleman Lake are located in the High Point
- Jamestown - Archdale urban region. At present, these waters are
impacted by nutrient loading, metals and pesticides based on water
quality monitoring efforts by DWQ. During a water quality study
of the Deep River conducted by DWQ from July 1992 to October 1993,
phenol values above laboratory detection levels were found at all
sampling stations in the upper Deep River study area. Pesticides
were also found along with violations of water quality standards
for Lindane and Dieldrin. (NCDEM. September 1994. Water Quality
Monitoring Data for Waters in the Upper Deep River Area, July 28,
1992 - October 7, 1993. Water Quality Section, Environmental
Sciences Branch. Raleigh, NC.) What steps will be taken to
protect the future water supply from these toxic chemicals?
8. Wetland impacts of alternatives: The EIS correctly states that
detailed wetland evaluations were only made for the Randleman
alternative. Comparison between alternatives using hydric soils
is problematic due to inaccuracies of these maps. The Draft EIS
should compare the alternatives using National Wetland Inventory
maps. These maps are also problematic in terms of accuracy but
comparison of alternatives using the two data bases may be
revealing in terms of relative impacts on wetlands. When the NWI
map data are reported, they should be reported by hydrology class
since some hydrology classes are more accurate in the piedmont.
ADDITIONAL COMMENTS
Page 1-2 Section 1.4 paragraph 3
This paragraph suggests that the most environmentally acceptable
alternatives are Upper Deep River Lake and Randleman Lake due to
the fact that these alternatives change current land uses less
than the other alternatives. It should be noted that while this
condition may be true for wildlife habitat, it ignores water
quality issues.
Page 1-3 Section 1-4 (Table 1):
While the Randleman Lake Project would be less expensive to build,
impacts based on a review of Table 1 appear greater for the
construction of this project as compared with the alternatives.
Have costs related to acquisition of properties and relocation of
businesses and residences been factored into the overall cost of
the Randleman Lake Project?
Page 1-3: Table 1 lists each of the watersheds for all
alternatives as "primarily undeveloped". This is not the case for
Randleman Lake (at least in the relative sense). Quantification
of the existing level of development should be done using land
use/land cover data available from the Center for Geographic
Information and Analysis. Similarly listing the town of Pleasant
Garden as "an area of concentrated development" for the
Benaja/Polecat Creek Lakes alternative (as similar to High Point
and Jamestown for the Randleman Lake alternative) is unrealistic.
Page 1-5 first sentence (continued from page 1-2) states that "all
alternatives would reduce downstream average flows". Paragraph 3
states that "all alternatives would result in increased stream
flows downstream from the reservoir during low flows, which would
improve water quality within these stream reaches during summer
droughts." It is suggested that these statements be combined for
clarity. While all alternatives would reduce downstream average
flows, they would increase downstream flows under drought
conditions.
Page 1-6 Section 1.5 paragraph 2 states that several modeling
studies have concluded that the water of Randleman Lake at the
intake will be safe and that substances can be removed by
conventional water treatment. Other highly eutrophic water supply
lakes with conventional water treatment typically have taste and
odor complaints from water consumers. Some of these systems have
required substantial re-engineering to treat these nuisance
conditions. Has the cost of granular activated carbon (GAC)
treatment been included in the draft EIS? In addition, this
statement ignores other uses of surface waters and water quality
standards to protect those uses.
Page 1-6: Under areas of controversy, the "effect of runoff from
existing and new urban development" should be added. This is an
important threat to the water quality of Randleman Lake.
Page 3-3 to 3-5:
Potential impacts of treated wastewater discharge to the Haw
River, as well as impacts related to reduction of flow downstream
of the Randleman Lake Project, have not been well addressed. How
would increased wastewater discharge in the Haw River upstream of
Jordan Lake impact the lake which is currently eutrophic and
experiencing seasonal nuisance algal blooms due to nutrient
loading? How would reduced flow in the Deep River, which is
currently experiencing problems related to nutrient loading,
impact the river? How would increased wastewater discharge from
expected future growth in the region (which will be supported by
the new water supply) impact all of these systems? Secondary
growth impacts supported by the new water supply have not been
adequately addressed in this document.
Page 3-3 first sentence states that "the water impounded by
Randleman Lake is expected to be of moderate quality as a water
supply". What does "moderate" mean? DWQ data collected so far
points to many water quality concerns associated with these
waters.
Page 3-4 paragraph 4. This paragraph states that about 63 percent
of the lake's total yield will be diverted from the Deep River
basin to other river basins. This diversion of water into the Haw
River could also cause increased nutrient loading in Jordan Lake.
Page 3-7 second paragraph. The term "moderate water quality" is
used again. See above.
Page 3-22 second paragraph. A statement is made that removing
water from the Haw River basin would be more detrimental to Jordan
Lake than contributing additional wastewater to the Haw River
basin. This statement is unsupported and should be stricken
unless the statement can be supported as to their relative effect
on water quality. The opposite statement could be argued with
respect to the addition of nutrients of Jordan Lake.
Page 3-22: The statement that "the specific impacts of interbasin
transfer... have already been judged acceptable by the State of
North Carolina" needs to be substantiated and referenced. The
allusion to the EMC action needs to be backed up by the relevant
minutes of the EMC meeting if possible or this statement should be
removed.
Page 3-27 Section 3.3.4.2 states that all alternatives would
provide moderate to good water quality. This statement is a
contradiction of another statement in the report that states that
the chlorophyll a standard will be violated in the lake (12% of
the time for the reservoir as a whole, 80% of the time in the
upper Deep River portion and 1% of the time at the intake).
Page 4-10 Paragraph 3 - Second sentence. Need to define under
what flow conditions (in the Deep River) High Point Eastside WWTP
effluent comprises 70% of the flow of the Deep River and in which
portion of the river.
Page 4-10 last paragraph- second sentence-insert the words fecal
coliform between the words high and bacterial, i.e. high fecal
coliform bacterial.
Page 4-10 last paragraph-last sentence. There is no reference
listed in the references section in the back of the report for
NCDEHNR, 1995.
Page 4-20 Section 4.3:
A population of Cape Fear shiners (Federally
were found approximately 22 miles downstream
Randleman Lake project. The document should
structure will provide adequate oxygen in doi
epilimnetic or hypolimnetic release from the
downstream aquatic habitats and populations.
listed endangered)
of the proposed
clarify what release
wnstream areas (i.e.,
dam) to protect
Page 5-13 third paragraph discussion on copper from High Point
Eastside WWTP. The report states that the average copper
concentration in the reservoir due to the High Point Eastside WWTP
would be above the action level but the copper could be removed in
the water treatment process. An evaluation of copper toxicity
should be made to determine whether this would violate the water
quality standard for this metal.
Page 5-13 third paragraph There is no mention of Lindane or
Dieldrin in the effluent. These pesticides were found in levels
above state water quality standards during DWQ monitoring.
Page 5-14 Section 5.3.5.5
Randleman Lake, or at least portions of the lake, are likely to
become eutrophic with nuisance blooms of blue-green algae during
the growing season. Stormwater and water supply protection
ordinances should be addressed as means by which local governments
can take steps to protect the water quality of the lake from
impacts related to urbanization and development within the
watershed.
Page 5-14 fourth paragraph. The statement is made that the
chlorophyll a standards will be exceeded over 80% of the time in
the Deep River Subbasin 01, 1% of the time at the intake, and 12%
of the time for the reservoir as a whole. This is an
acknowledgment that water quality standards will be violated.
Page 5-15 fifth paragraph. A statement is made that "predicted
Secchi depth, total phosphorus, and chlorophyll a values are
expected to be comparable to those of other regional reservoirs
and lakes". Undoubtedly, Randleman Lake will be highly eutrophic
and these values will only be comparable to eutroohic regional
reservoirs and not "all other regional reservoirs and lakes" (see
comment for Appendix IV, page 36).
Page 5-18 first paragraph.
A statement is made that any water quality problems in Jordan Lake
caused by interbasin transfer from Randleman Lake could be
addressed by modifications in the operation and maintenance of
Jordan Lake by the Corps. Examples of possible future problems
would be increased algal blooms and associated fish kills in the
Haw River arm of Jordan due to increased nutrient levels from
WWTPs. An explanation is needed of how these potential problems
can be "fixed" by the Corp's lake operation and maintenance. It
also does not seem logical to allow discharge to one lake by
creating problems in another.
Appendix IV, page 36
The table which appears on page IV-36 of the Randleman Lake Draft
Environmental Impact Statement Draft Appendices presents a
comparison of three water quality parameters (Secchi depth, total
phosphorus and chlorophyll a) for eight regional lakes with the
modeled water quality data for Randleman Lake, (which assumes
wastewater treatment plant effluent concentrations are at 0.05
mg/L). The data for the eight regional lakes was from the 1988
North Carolina Lake Monitoring Report (NCDEM Report No. 89-04,
1988). This data was from a one time sampling trip to these
lakes, which is essentially a snapshot in time. Such data may not
be representative of the water quality of a lake. An unusually
dry spell prior to sampling or a rainfall event within the
watershed can result in data that is outside of the norm for the
lake.
The table below presents a comparison of similar data for
Randleman Lake with data collected by DWQ for 16 Piedmont lakes.
The lakes in this table were ranked according to lake mean
chlorophyll a concentrations. However, under present total
phosphorus loading, it is conceivable that the expected
chlorophyll a concentrations for Randleman Lake will be much
higher than 19 µg/l. The High Point Eastside WWTP, which was
incorporated into the Randleman Lake Model as exporting 0.05 mg/l
total phosphorus, currently operates under an NPDES permit
(NC0024210, April 1, 1996 through March 31, 2001) which does not
require the facility to incorporate total phosphorus restrictions
during any part of the year. As stated in the draft EIS, this
facility is currently releasing an estimated 4.0 mg/L total
phosphorus. This concentration is eight times greater than the
modeled concentration of 0.05 mg/L.
Mean Values FETENT?JN
LAKE DATES SECCHI DEPTH II ' TOTAL PHOSPHORUS I CHLA TIME Volume
I_.I-" u I-11% lel...1 Irtn••R --fil
Roanoke Rapids Res. August 1981 - August 1994 19 1.5 1 9 0.04 19 1 96.00
H co Lake July 1983 - August 1994 36 2.0 38 0.03 36 4 99 180.00
Belews Lake July 1981 - Au ust 1994 34 3.7 34 0.01 34 7 1500 228.00
Lake Norman August 1981 - August 1992 39 1.8 1 35 0.01 39 7 239 131.16
Fags Lake July 1981 - July 1994 15 1.2 12 0.03 12 8 177.00
Lake Gaston August 1981 • Au ust 1994 32 1.4 32 0.02 32 6 512.00
Lake Tillery Juty 1981 - July 1994 28 1.3 1 28 0.03 28 11 15 207.00
Lake Rhodhiss August 1981 • Sept. 1992 33 1.0 I 33 0107 33 12 21 36.70
Harris Lake August 1987 July 1996 18 1.8 18 0.03 18 15 840 10.08
Kadin Lake July 1981 . Ju 1994 35 1.2 35 0.03 35 16 28 344.00
Lake Wylie August 1981 Au Oust 1992 i 56 1.1 57 0.06 56 16 38 35.26
Randleman Lake -Model 1.2 0.07, . 19 .' 200 .
:-
i•s.70.48
Lake Hickory August 1981 . August 1992 32 1.2 32 0.04 32 22 33 16.58
Lake Thom-A•Lex July 1881 • July 1994 12 0.7 12 0.04 12 28 7.80
Page of the Nauss Aril 1983 - Jul 1996 559 0.6 558 0.10 558 29 83 176.70
B. Everette Jordan July 1982 -Sept. 1996 778 0.6 776 0.11 765 39 418 929.60
Tuckertown Res. July 1981 . Ju 1994 12 0.7 12 0.07 12 81 297.50
* N = Number of observations
Note: The Randleman Reservoir modeling data assumes a WWTP effluent total
phosphorus concentration of 0.05 mg/1.