19970722 Ver 1_More Info Received_19980227

RECE(VED Randleman Briefing Notes
F a 2 -7 ? 19?? N.C. Division of Water Quality
Et?VIF", .9„IENCES 2/11/98
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Numerous environmental documents were reviewed by DWQ staff late in 1997, including the DEIS for the
Randleman Reservoir 404 Permit with the Corps (and 401 Certification from DWQ), an EA for the High
Point Eastside WWTP Expansion, and EAs for the Randleman Water Treatment Plant and Water Lines.
Staff has had considerable concerns with the content of the reports and the high likelihood of water quality
problems if the Randleman Dam is built. Concern over eutrophication of the lake and potentially high
concentrations of metals and pesticide contaminates appear to be warranted based on all the information
available to be reviewed. However, recognizing that an effort was needed to move the various processes
forward, several actions were taken by DWQ on each project, as summarized below.
#l. High Point WWTP Expansion: Due to the inter-relatedness of this proposed High Point Eastside
Wastewater Treatment Plant expansion and the proposed Randleman Reservoir, the Division remains
concerned about the water quality in the future Randleman Lake, and the effect of the expanded High Point
Discharge to this situation. Preliminary modeling of the watershed by Hazen and Sawyer and Tetra-Tech
indicate that the predicted water quality concerns in the future system would be phosphorous driven
(predominantly from the Eastside Plant) and that chlorophyll a standards may not be met throughout the
various segments of the lake, due to eutrophication that could occur from predicted phosphorous
concentrations.
Given the potential that the Randleman dam will be built and the likelihood of eutrophicadon of the lake,
High Point will need to reduce the discharge levels of phosphorous from the Eastside Plant as much as
possible, since it's contribution to the reservoir's phosphorous load is estimated to be 81 % of the total
phosphorous load. As discussed at the October 31, 1997 meeting with the City of High Point and their
consultant, and as detailed in the December 19, 1997 memo to Bobby Blowe (CG&L), the High Point
Eastside Wastewater Treatment Plant is being required to meet the following limits -
0.5 mg/l Phosphorous - monthly average, year round
6.0 mg/l Nitrogen - monthly average during summer months
(April - Oct.)
Other agencies commented on the EA as follows -
Winston-Salem Regional Office - concerned with operational problems at the WWTP (leaking sidewalls),
I/I problems in the collection system, and encouraged High Point to go beyond minimum water supply
guidelines to address problems.
Wildlife Resources Commission - concerned that proposed emergency power is insufficient to prevent
spill during power outages, nutrient exceedences may lead to increased frequency of fish kills and loss of
recreational opportunities, and that High Point currently does not have watershed protection ordinances in
place (but should).
#2. Water Treatment Plant EA: Request that as updated analysis/modeling of the predicted toxicant levels
be performed to address all sources of concern (i.e. contaminants associated with Seaboard, the landfill
and abandoned goldmines). Elevated concentrations of lead, mercury, nickel, lindane, dieldrin, as well as
possible other unknown contaminants may be of concern in the reservoir. Further, based on experience
with other eutrophic water supply sources, the treatability of the water for drinking water purposes is of
concern. The EA should document what methods of treatment are going to be used to address the
treatability concerns associated with the eutrophication and the predicted levels of other contaminants.
Additionally, if the water treatment will result in the need to dispose of backwash wastewaters, the method
of disposal and environmental impacts must be addressed. Characterization of the future backwash or
other wastewaters must be provided and the method of mitigation of the impact addressed. Need to also
discuss the need for reclassification of the waters prior to use as a water supply source.
s:
#3. 401 Certification: Move forward with conditional issuance of the 401 Certification contingent on the
following items occurring:
• Provision of 1:1 mitigation for 120 acres of wetlands impacted by the proposed reservoir
• DWQ has committed to issuing a 401 Water Quality Certification on the reservoir project, subject to the
condition that Piedmont Triad Regional Water Authority (PTRWA) develop a Nutrient Reduction
Strategy and Special Watershed Management Plan (under 15A NCAC 2B .0227) for the Randleman
Lake Watershed.
As discussed with PTRWA on 10/24/97 and the City of High Point on 10/31/97, this Plan will need to
determine the level of nutrient reductions required in the watershed to assure compliance with water
quality standards and protection of public health, aquatic life, and recreational uses in the future
Randleman Reservoir. The modeling being performed for this Plan will be required to establish the
maximum load of nutrients the reservoir can receive from all sources (point and non-point).
To develop the necessary tools to design the management plan, current documentation of land uses for
the watershed will be needed and the model updated to reflect the existing and reductions required in
the total phosphorus and nitrogen loads to the proposed reservoir. The management plan will need to
address all point and nonpoint sources from existing as well as future land uses. The Plan will also
need to define the specific management strategies necessary to achieve the nutrient reductions required,
and demonstrate how these reductions will be accomplished and sustained into the future for the
watershed. Some of the tools projected to be a needed component of such a management plan to
control phosphorus and nitrogen would include:
a. Riparian Buffers
b. Land Use Controls - including use of water supply watershed requirements more protective
than the WSIV regulations (i.e. implementing WSIII requirements where feasible on some of
the tributaries to the reservoir)
c. Best Management Practices for Stormwater Control - for both urban and agricultural land uses
d. Wetlands Restoration and Creation
e. Water Conservation and Wastewater Reuse
The City of High Point (along with all other local governments with planning jurisdiction in the
Randleman Watershed) will be required to address nutrient contributions from existing and future land
use changes and develop measures to reduce nutrient loadings. This will more than likely require the
implementation of specific non-point source mitigation measures and land use controls to reduce these
loads.
This Plan has been developed and submitted to DWQ for review (Feb. 9, 1998).
A recent Internal Draft Water Quality Monitoring Data report by the Environmental Sciences Branch
(dated January 1998) states that "eutrophication concern for potentially impounded waters" in the
Upper Deep River area is still warranted due to "elevated concentrations of nitrogen and phosphorous"
(see attached Executive Summary). PTRWA's own consultants, Tetra Tech, indicated in their October
1997 modeling studies that chlorophyll a standards may not be met for the entire reservoir, even with
best available technology for the High Point Eastside WWTP and with implementing significant non-
point source best management technologies throughout the watershed. To proceed with the Plan under
these circumstances may require preparation of a Site-Specific Standard for Chlorophyll a for this
reservoir.
This Management Plan will have to be adopted into rules by the Environmental Management
Commission. It is anticipated that the Management Plan, Reclassification (to Water Supply) and
adoption of a Site-Specific Chlorophyll a Standard (if necessary) for Randleman Reservoir will
proceed through the rule-making process concurrently. Staff is currently working on a draft schedule
of this process that would allow (given several very optimistic assumptions) the Rules to go before the
General Assembly in the 1999 session and become effective by April 1, 1999.
#4. DEIS for Corps 404 Permit for Dam. Specific comments on the adequacy of the DEIS were provided
in DWQ's October 3, 1997 memo to DENR, including concerns over eutrophication, cost analysis of
alternatives, toxic substances from Seaboard and the High Point Landfill, and watershed protection. DWQ
recommended that the "potential toxicant impacts to the water quality of Randleman Lake should be
reevaluated" (in an amended EIS) "upon receipt of the February, 1998 Remedial Investigation Report."
DWQ has not yet seen this report or an amended EIS.
In reference to the DEIS, DWQ has received a copy of a letter from EPA (Region 4) to the Corps on the
DEIS that states, "In conclusion, EPA has a number of misgivings over the feasibility and suitability of the
proposed project to provide a safe water supply that will meet the needs and maintain the health of future
generations. We recommend that the COE issue its Section 404 Permit on condition that the NC DEHNR
guarantee that the water quality in the proposed Randleman Lake will be suitable for its intended purpose,
that is for a public drinking water supply."
#5. Randleman Water Mains. DWQ commented to DEH on the EA for the Randleman Water Lines
(October 13, 1997) referring to the same water quality issues as, discussed in items 1-4 above.