19970722 Ver 1_More Info Received_19980224 (2)

Winston-Salem Regional Office
TO:
FAX
FROM:
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North Carolina Department of
Environment, Health, and Natural
Resources
Division of Water Quality
Colleen Sullins
# of pages 6
FAX #

Larry D. Goble, Regional Supervisor
NOTE: Attached are the Regional comments on the Randleman Lake
Nutrient Reduction Strategy. This was a rush job and staff did not
have a chance to do an in-depth review, but we felt something was
better than nothing. In general we do not feel the plan is strong
enough to have any effect on protection of the proposed lake. It
appears to cover only the very minimum that is required under
current water supply regulations. It is suggested that the Plan be
returned to PTRWA for additional' Consideration.
585 Wavghtown Street, Winston-Salr..m, NC 27107 • 910-71174600 • FAX 910-7 '71 4 r,12
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FOR DWQ INTERNAL REVIEW ONLY
To: Larry Coble 5;? ?_
Steve Mauney
From: Ron Linville
Subject: Review of Randleman Lake Nutrient Reduction
Strategy and Implementation Plan Draft
Date: 980220
A very quick and extremely cursory review of the NRSIP for
Randleman Lake raises the following concerns and comments which are
presented here by page reference:
E$-3: NPS objectives are not specific. Current watershed
protection rules will not likely be sufficient to alleviate
degradation and water standard violations.
ES-4: In order to be effective, the nonpoint source reduction
strategy should exceed local watershed protection regulations by
protecting butters for all intermittent as well as perennial
streams. Currently, the Division has concerns about the full
implementation for the adequate protection of perennial stream
buffers in this area generally.
ES-5: Consideration of the new created wetlands for inclusion
in reduction measures should be carefully considered as these
restored or created sites will simply replace those which have been
lost. These may be at best a neutral scenario and at worst a
negative loss of reduction benefits.
ES-8: Concentrations of Chlorophyll a in some upper tributaries
should again emphasize the need to provide for additional
safeguards in as many other areas as possible (such as protecting
intermittent streams and avoiding small stream and wetland losses) .
1-1: Suggest that the document indicate that the PTRWA is
developing this strategy "for presentation to the DWQ" and not "in
cooperation with" EMC, DENR and DWQ.
1-5: What restrictions will be placed on the utilization of
chemicals and fertilizers within the watershed?
2-4: The document indicates that the Chlorophyll a
concentration, nuisance algal conditions and unaesthetic conditions
will occur. Specifically, what measures' can be taken in these
upper tributaries?
2-5: In the analysis of existing conditions relative to High
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Point's Eastside WWTP, are existing accumulations in the basin
given consideration due to the long term impact of the WWTP. Also,
are the figures utilized accurate? The Eastside WWTP has a history
of very significant bypasses of partially or little treated
effluent especially during storm events. Instantaneous flows have
been documented in excess -of 70-M MGs. During these events,
evidence exist which continues to point to possible combined sewers
and inflow of stormwater (normally considered nonpoint source) .
DMRs provided by the High Point lab continuously and routinely
suggests that the City of High Point has no confidence in much of
the data reported.
2-8: Have the four regional stormwater ponds shown actual
reductions? If so, the specific data'should be included in the
study.
2-9: A violation of the standard is a violation of the
standard. Unless the PTRWA seeks to go beyond the minimal
protection measures to try to offset these predicted violations and
request a variance based on these stringent development guidelines
and WWTP improvements, it is unlikely that the DWQ could support
reclassification to WS.
2-11: Elevated rates of discharge and withdrawal from the lake
are likely to exasperate predicted conditions and may contribute to
standard violations closer to the intake. Again, every effort
should be placed on maximizing protective measures by WWTP
improvements, stringent stream and wetland buffering as well as
minimizing development impacts to waters and wetlands for the long
haul. Prevention is worth a pound of cure.
2-12: Watershed protection measures in all jurisdictions should
be equally stringent and enforced. In this manner, losses in one
area might be offset by thorough protection measures around the
proposed lake.
2-14: Despite the increased flow rates due to increased
impervious surface, will biomass accumulations sustain conditions
which will cause more Chlorophyll a concerns?
3-15: It is unlikely that the "NCWREP" should participate in
this effort as payment into a wetland bank cannot contribute to
enhanced water quality in this proposed lake.
3-17: It is highly probable that stormwater is collected and
moved via drainages in many of these areas so it is likely that the
diffuse drainage statement may be somewhat incorrect.
3.19: All commercial and large scale developments in each
jurisdiction should be required to provide for maintaining the
hydrogragh in order to prevent streambank erosion and sediment
deposition into the proposed lake. Water quantity as well as
quality is an issue.
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3-23: The statement that the NC Sedimentation and Pollution
Control Act of 1973 prohibits visible sediment from washing oft
construction sites is misleading and does not indicate the reality
of soil losses directly caused by site development and indirectly
caused from streambank erosion due to hydrograph surges and
increases.
3-26-27: Education is fine but it will not suffice alone.
Enforceable application limits will need to be prescribed and
compliance will need to be mandatory through injunctive procedures
if necessary.
4-4: 'Coordination with DWQ" should be removed from the
l document. As written, the DWQ would appear to be partially
responsible for the success or failure of the Randleman Lake's
nutrient reduction strategy.
4-6: The PRTWA should not only update the strategy and
implementation, it should also be empowered to mandate programs
over all contributory watershed jurisdictions.
Please keep in mind that this has been a very quick review and
a full Grasp of details has not been accomplished. These comments
are provided for INTERNAL CONSIDERATION ONLY due to a lack of time
to fully and completely study the issues.
Cc: Central files
WSRO
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a .
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
WINSTON-SALT-M REGIONAL OFFICE
DIVISION OF WATER QUALITY
M E M O R A N D U M
TO: Larry Coble
Regional Supervisor - WSRO
FROM: Corey Basinge
Environmental Engineer - WSRO .
THROUGH: Steve Mauney
WQ Supervisor WS 0
DATE: 17 February 1998
SUBJECT: Comments - Randleman Lake
Nutrient Reduction Strategy &
Implementation Plan 2/98 DRAFT
The following are comments and/or questions regarding
the "RANDLEMAN LAKE - Nutrient Reduction Strategy and
Implementation Plan 2/98 DRAFT" document.
S
I Table on page ES-2 has several calculation errors that
are also repeated in the text on same page.
Specifically, the calculations relating to total
phosphorous reduction for low and high flow years.
2) Text on Page E9-3 reflects the idea that connecting
several minor facilities to the major municipals will
aid in nutrient reduction. Although a valid concept,
several question arise:
a) How many minor facilities?
b) Is it economically and/or environmentally feasible?
c) Who funds the connections?
d) Will it be suggested or required?
3) Paragraph 2, page ES-6 states that "( t?ere are only
three animal operations within the wa rshed..'"I. In
Randolph County there are three (3) animal waste
facilities that remain on the certification list. There
' are, however, a couple of zegistered farms that have
been removed from the certified list but remain in
business (numbers below threshold).
666 WAVGHTOWN STREET, WINDT014-3A69M. NORTH CARDLINA 87107
PHONE [phone] FAX[phone]
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MEMO - Larry Cable
17 February 1998
Page #2
4) Text on page 2-10 discusses nutrient loading in the
Muddy Creek 1 segment. 'Melbille Heights Subdivision
(Rayco) is mentioned as a "domestic-type wastewater
discharge" that will be connected to the municipal sewer
by PTRWA. No mention is made of Penman Heights
Subdivision (Rayco) located less than 3 miles away and
discharging to an unnamed tributary to Muddy Creek.
Also, the text does not state what municipal they should
be connected to, although it is assumed I.P. Eastside.
5) Text on page 2-12 states "It is assumed that no new
domestic-type wastewater discharges will be permitted by
the State within the Randleman Lake watershed. It is
also assumed that permitted flow will not be increased
on existing permits." Is this an official Division
position? Or, is it just an assumption on the part of
PTRWA?
6) TQV.4 on page 3-1 states t;;Rt High
neke r
currently covered under SOC? If MIT., LIIULL?!ft't they, be?
7) Text on page 3-2 again discusses connection of minor
"domestic-type" permitted wastewater discharges to
municipal sewer systems. The report again excluded
Penman Heights Subdivision and neglected to state which
municipal facility will receive the wastewater.
8) Table on page A-1-2 lists the domestic-type dischargers
in the Randleman Lake watershed. Included on this list
is Penman Heights Subdivision which had been excluded
throughout the text with regards to connection to
municipal sewer.
9) The report does not state a date or time frame for the
actual construction of the Randleman Lake Dam. Is this
information available? Can the Division obtain it?
This information would be extremely useful to several
animal facility owners to aid them in their decision to
spend thousands of dollars to maintain compliance with
.0200 regulations or sell out while the funds are being
offered.

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