19970722 Ver 1_More Info Received_19980223

)'
February 23, 1998
M. Greg Thorpe
FROM: Steve Zoufaly
THROUGH: Boyd DeVane
SUBJECT: Comments on Proposed Randleman Reservoir Water Quality
Management Plan
The following are my comments regarding the document entitled Randleman Lake -
Nutrient Reduction Strategy and Implementation Plan (February 1998):
The plan only addresses nutrients and does not address other potential water
quality problems from the Seaboard Chemical waste site, landfill and former
gold mining operations. All of these may have an effect on water quality.
The plan should either clearly address that these potential sources of
contamination of the drinking water are not a problem or remedial action
should be addressed.
The most recent water quality analyses continue to indicate that existing and
future nutrient levels are of sufficient quantity to cause eutrophication
concerns. Other parameters, such as metals, fecal coliform and phenols (the
latter based on water supply standards not currently in place), were also
documented as being above water quality standards. Over 610 unidentified
peaks were also documented in this last water quality analysis of the Deep
River. This poses the question of whether the water quality will improve
after the reservoir is constructed or if water quality violations can be
continued to be expected Dilution may minimize the effect of many of the
contaminants, but modeling analysis for nutrients seems to suggest that
violations for at least nutrients will continue to occur.
Can a reclassification occur if water quality standards are expected to be
violated? An advisory memorandum from the Attorney General's office
(May 22, 1997) states "If the Division's data on the water body and
contributing sources indicate that the uses associated with the proposed
classification cannot be attained, it would be improper for the Commission to
reclassify to the higher classification." The higher classification in this case
would be a reclassification from Class C (current classification) to Class WS-
IV (water supply).
- Should the reservoir be built, monitoring should be required of the Piedmont
Triad Regional Water Authority to address the possible contamination from
the landfill, Seaboard Chemical waste site and the former gold mines.

The draft management plan emphasizes the reduction that may be obtained
from the largest contributor of nutrients to the water body, the High Point
Eastside Wastewater Treatment Plant, but it wasn't clear whether additional
growth controls within the watershed would be applied in an effort to reduce
all sources of nutrients to the maximum extent practicable. Rather than
applying WS-IV density controls as the minimum, more restrictive controls
should be examined which might achieve the desired nutrient levels in the
lake. The report seemed to imply that growth will continue along established
patterns based on development pressures. Those patterns should be
examined and changed if necessary to reduce pollutant impacts. Perhaps,
more open space is necessary than existing local ordinances call for.
The draft management plan states on page 3-4 (first paragraph) that the WS-V
classification is intended for future water supplies. This is incorrect. There
is a separate supplemental classification, FWS (Future Water Supply), that is
designed to be applied to a primary WS classification to recognize those
waters that are intended for future water supply use. WS-V waters are in
general those waters that are former water supplies or are used by an industry
to supply their employees with a potable water supply source.
- Was water quality modeling completed to determine the effect of applying
more restrictive land use controls on water quality? If not, an analyses of the
benefits expected from proposed controls and what benefits could be
achieved if more controls were in place would be useful.
- How do costs of applying controls (i.e., consolidating wastewater treatment
facilities, tightening nutrient reduction at the High Point Eastside Wastewater
Treatment Plant, applying more stringent density controls) compare to other
alternatives such as obtaining water from other sources such as Jordan Lake?
The assumption has been made that to have adequate flow for practical use of
the reservoir that High Point Eastside Wastewater Treatment Plant needs to
discharge to the reservoir. This should be reexamined. Moving the
discharge below the reservoir would help reduce the nutrient loading to the
reservoir. However, if this occurs, this should not negate planned controls
on the non-point sources of pollutants to the water body or the consolidation
of the other point sources currently discharging upstream of the planned
reservoir.
Attachment