19970722 Ver 1_More Info Received_19980219

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1 0, State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
1 ? •
NC ENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 19, 1998
MEMO
TO: Boyd DeVane
Pf
FROM: John Dorne
q) TI,
RE: Review of Draft report on Nutrient Management Strategy and
Implementation Plan - Randleman Lake
I have reviewed the draft nutrient management plan for Randleman Lake
dated February 1998. My comments are listed below:
1. Nonpoint source phosphorus goal. The nonpoint source portion of
the plan needs major work and (in my opinion) should not be accepted
by DWQ until revised. The point source portion of the plan has a goal
- namely, "to reduce P concentrations to the limits of technology and
as environmentally and economically feasible" (pg ES-3). In stark
contrast, the nonpoint source portion of the plan has no goal other than
comply with existing regulations. There needs to be a numeric goal for
the nonpoint sources of nutrients into the lake similar to the point
source goal. I would suggest that a logical goal would be "There shall
be no increase in non-point source contributions of phosphorus to the
lake based on February 1998 loadings prepared by Tetra Tech Inc. for
the Piedmont Triad Water Authority". This goal (along with the point
source measures outlined in the report) would be a serious
commitment by the Authority to protect the water quality of the
reservoir. It would basically set up a nutrient trading process in the
watershed and probably force more stringent water supply protection
measures. It would allow additional growth in the watershed but
ensure that the development would be nutrient-neutral.
2. Wetland Restoration Program discussions (page ES-5, and 3-15).
This statement needs to be clarified and agreed upon by Ron Ferrell.
My understanding is that he is not willing to find wetland mitigation
sites for the Authority. However he may be willing to conduct
mitigation for them on sites that they acquire. Please contact Ron for
clarification.
Environmental Sciences Branch 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
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3. Wetland mitigation sites (page 3-15). Pete Colwell has visited five of
these sites and they appear to be reasonable places to attempt
wetland. However at the Reddicks Creek and Buttke Dairy sites, it
may prove difficult to obtain the estimated wetland acreage of the lack
of hydric soils and the need for extensive grading and excavation. We
have not visited the Kersey Valley site and it is not shown on Figure 9.
Finally we have urged the Authority to locate and attempt more than
121 acres of restoration. This would provide some margin of error for
the Authority if the selected mitigation sites are not successful. The
Authority has apparently chosen to only locate 121.6 acres of
restoration areas. We repeat our suggestion to locate an additional
site to assure that the Authority meets the 121 acre goal. There is no
mention of the monitoring that will be required to assure mitigation
success.
4. EPA review. If EPA has not reviewed this report, they should. Their
staff will probably have useful comments concerning water quality
measures taken elsewhere in Region IV or the U.S. in similar
situations.
Cc: Ron Linville, Winston-Salem DWQ Regional Office
Dennis Ramsey
Pete Colwell
Randleman.pln