19970722 Ver 1_More Info Received_19980707 (2)

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Division of Water Quality
April 10, 1997
MEMORANDUM
To: Randleman Reservoir File
Through: John Dorne and Jimm' Ov ton
From: Pete Colwell e_--
Subject: Mitigation Sites
On March 5, 1997 I met Ron Linville, John Kvne, Ed Powell, and Eddie Mcaldowny in Greensboro to
look at potential compensatory wetland mitigation sites for the proposed Randleman Reservoir project.
According to Powell, his firm (Davis, Martin, and Powell) will do the delineation and design for the
proposed wetland mitigation sites.
The first site was on Hickory Creek just above Viewmont Drive and just below the old demolition landfill
sites along Viewmont Drive. This site was suggested by Ron in order to remove pollutants leaching into
the stream from the landfills. There are 5-7 acres of non-wetland floodplain where a side stream merges
with Hickory Creek. The area has with mature trees on it and there are some signs of overbank flooding.
It may be possible to do some creation here, but it would be difficult and you would lose the mature
forest. A better site may be in the pasture adjacent to Hickory Creek just downstream of Viewmont
Drive.
The second site was identified as their Site #5. It is on Reddicks Creek off SR 1140 at the upper reaches
of the proposed lake elevation. The area is a relatively flat floodplain area with a golf course on one side
of the creek and young forest of river birch, ironwood, dogwood, and sycamore on the other. The
proposed lake level (682 elevation) would come to the existing ground level of the forest. Soils on the
forest side are mostly sandy deposits from the creek. Kime proposes to put a dam downstream (within
the waters of the lake) and flood the flat areas of the forest and golf course to create 5-10 acres of
wetlands. The dam would be designed to fluctuate the water levels in the created wetland. The area has
some potential as a mitigation site, but the design and elevations will have to be looked at closely.
Environmental Sciences Brunch Water Quality Section

The third site was identified as their Site #6. It is located along an unnamed tributary east of SR 1137,
again at the upper reaches of the proposed lake level within their 200 foot buffer. The site consist of a
steep valley with a narrow floodplain with wetlands along the creek. Much of the floodplain would be
inundated with several feet of water at normal pool level of the lake. Kime proposes to put a dam in the
creek and flood above normal pool and create a fringe wetland around the edge of the new pond. We
told them no on this site. The wetland fringe would be very narrow and serve little in the way of water
quality improvements.
The fourth site, their Site #7, was much the same as the one above. Place a dam in the unnamed tributary
off SR 1938 and create a new fringe wetland around the edges of the new pond. They chose the location
to filter run off from a large dairy operation upstream. We told them no for the same reasons as above.
The fifth site, their Site #9, is located on an unnamed tributary at SR 1936. Two streams with relatively
flat floodplains merge at the road crossings. Soils are red clay with evidence of hydric conditions just
below 12 inches. The vegetation consists of a disturbed forest of red maple and tulip poplar with an
understory dominated by privette. With a small dam at the road and some minor grading work between
the two streams, you could create up to 5 acres of wetlands that would filter water coming from
pasturelands up stream. This site has potential.
The sixth site, their Site #4, is located on Taylor Branch where it enters Muddy Creek just north of SR
1922. In this are Muddy Creek and Taylor Branch are deeply incised and the proposed lake level would
flood the channels to bank full. There are existing wetlands within the floodplain that have formed along
seeps where the water is backed up by the old spoil piles along Muddy Creek. Much of the forest is
mature sycamore, river birch, poplar, and ironwood. There may be the potential for several acres of
enhancement and restoration in this area.
Overall, Kime is looking at trying to create wetlands within their 200 foot buffer zone by damming up
ponds just above the proposed normal pool elevation. None of the sites we found were as good as the
Muddy Creek site above SR 1917 or the site near High Point's water treatment plant.
Randmit. memo
Environmental Sciences Branch
Water Quality Section
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890 Ile_
May 9, 1997 /
IN REPLY REFER TO V
Regulatory Branch
Action ID: 199102669
Mr. John F. Kime, Executive Director
Piedmont Triad Regional Water Authority
Koger Center, Wilmington Building, Suite 201
2216 West Meadowview Road
Greensboro, North Carolina 27407-3480

1%,41-,VF?
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NpF?

Dear Mr. Kime:
This letter is in response to your letter dated
the acceptability of the mitigation plan that yo
impacts associated with the proposed Randy
l 25, 1997 requesting the Corps' position on
submitted to compensate for the wetland
Lake water supply project.
The proposed mitigation plan involy two components: 1) the creation of 120 acres of
wetlands on the upper tributaries Ua4 proposed lake on Richland, Reddick's, Hickory, and
Muddy Creeks at approximate) four sOes recommended by the N.C. Division of Water Quality
(NCDWQ); and 2) the preservation by fee simple purchase of approximately 700 acres of
wetlands known as the Cone's Folly site located downstream in the Cape Fear basin. The
proposal indicated that the present owner would retain hunting rights to the property. The
proposal also indicated that the final disposition of the property was yet undecided and that the
Authority was considering several options including retaining ownership of the property or
granting title to a public trust agency, such as the N.C. Wildlife Resources Commission
(NCWRC) or the Nature Conservancy.
It is our opinion based on our visit on October 22, 1996 to the Cone Folly site that, although
the property is somev
natural value that its t
We believe that this c
Service, the NCWRC
the preservation of th
tributaries of the pro
requirements for this
iat distant from the Randleman Lake impact area, it is of such significant
;e? s partial mitigation for the Randleman Lake impacts is acceptable.
ion is shared by the agency personnel of the U. S. Fish and Wildlife
and the NCDWQ who were also present. Accordingly, we believe that
Cone Folly site and the proposed creation of 120 acres of wetlands on the
Ised lake should satisfy the wetlands compensatory mitigation

-2-
Based on the nature of the preservation tract and the existing interest retained by the Nature
Conservancy in adjacent properties, we believe it would be appropriate and recommend that the
Cone Folly tract be conveyed to that organization. In regard to the proposed wetland creation
sites, a detailed plan describing the goals, materials, methods, timing, and success criteria will
need to be developed. This plan should be available for inclusion in the Final Environmental
Impact Statement.
If you have questions, contact Mr. David Franklin at telephone [phone].
r•
Sincerely,
G. Wayne Wright
Chief, Regulatory Branch
Copy furnished:
Mr. Newt Colston
545 North Pleasantburg Drive
Suite 101
Greenville, South Carolina 29607
Mr. Don Cordell
Hazen and Sawyer
4011 Westchase Boulevard, Suite 500
Raleigh, North Carolina 27607
Mr. John Hefner
U.S. Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, North Carolina 27636-3726
Mr. Lee Pelej
U. S. Environmental Protection Agency
Atlanta Federal Center
100 Alabama Street, SW
Atlanta, Georgia

-3-
Mr. Frank McBride, Program Manager
N.C. Wildlife Resources Commission
1142 I-85 Service Road
Creedmoor, North Carolina 27522
Mr. John Dorney
N.C. Department of Environment,
Health, and Natural Resources
Division of Water Quality
4401 Reedy Creek Road
Raleigh; North Carolina 27607
State of North Carolina
Department of Environment,
Health and Natural Resources / • •
Division of Water Quality
James B. Hunt, Jr., G ove mor
Jonathan B. Howesy Secretary C) E H N R
A. Preston Howard, Jr., P.E., Director
May 19, 1997
Mr. John F. Kime
Piedmont Triad Regional Water Authority
Koger Center, Wimington Building, Suite 201
2216 West Meadowview Road
Greensboro, NC 27407-3480
Re: Proposed Randleman Reservoir Mitigation Sites
Dear Mr. Kime:
Y?
This letter will serve to summarize our May 7, 1997 meeting ttake a second look at your
proposed mitigation sites for the Randleman Reservoir project. Also at that meeting were Andrea
Spangler with your office, Ed Powell and two associates with Davis-Martin-Powell, Inc.(DMP),
and Ron Linville from the Division's Winston-Salem Regional Office. We discussed five potential
mitigation sites and visited three of those sites. Our comments on each site are listed below.
Site No. 1. Richland Creek. This site lies just west of High Point's Eastside wastewater
treatment plant. It is an excellent site for the restoration/creation of wetlands that have a lot of
potential for improving the water quality of Richland Creek before it enters the proposed
reservoir. DMP has estimated approximately 47 acres in the mitigation area that would be
occasionally flooded by the two dams. From our site inspection, much of this area is already
jurisdictional wetlands. An accurate delineation of the wetlands will be needed. Modification of
the existing wetland areas will not count toward your mitigation credits and care should be taken
in your design to avoid impacts to these areas.
Most of the western half of the site consists of relatively mature bottomland hardwood forest
(sycamore, box elder, red maple, green ash) on hydric soils. Extremely high flows from Richland
Creek occasionally flow through the forest, but water does not appear to saturate the soils long
enough to make all of the forest jurisdictional wetlands. We would recommend restoring the
hydrology to these forest areas, but we would not support clearing and regrading the forest.
The field area has the greatest potential for restoration! The crown of the field will need to
graded down, meandering channels put back through it to restore the hydrology, and wetland tree
species planted. Your present mitigation design shows two dams that will hold stormwater back
and flood the site. This design may have to modified to adjust for the existing wetlands on the
site and for the actual elevations. r.1 t ' 1 , ' ,
Environmental Sciences Branch • 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
An Equal Opportunity Alfinnative Adon Employer 500/6 recycled/10% post consumer paper

the Water Authority property. We have identified a potential site on Hickory Creek between
Viewmont Road and Bishop Road as well as one along Taylors Branch which enters Muddy
Creek above Muddy Creek Road.
The mitigation plans for each site should contain an existing site plan showing wetlands,
fields, forested areas, streams, and elevations:. They should also have the proposed design plan
showing any grading, channels, structures, and planting scheme. There should also be a
monitoring plan and success criteria (see attached materials). The Division looks forward to
reviewing your mitigation plans and assisting you further with their development. Should you
have any questions please feel free to contact Ron Linville or myself.
Sincerely,
P & V, J&
Peter B. Colwell
Environmental Specialist
cc: Ed Powell, DMP
Ron Linville, DWQ Winston-Salem Regional Office
David Franklin, US Army Corps of Engineers
John Dorney, DWQ Central Office
Ron Ferral, Wetland Restoration Program
GLEN SIMPSON--SOIL EVALUATIONS
P.O. BOX 7767
HIGH POINT, NC 27264
August 7, 1997
Mr. Eddie MacEldowney
Davis-Martin-Powell
218 Gatewood Ave.
High Point, NC 27262
Re: Soil Evaluations of Proposed Wetland Sites
Randleman Dam Project
Dear Mr. MacEldowney,
FECDVED
u! Ir 9 1997,
ENVIR()PJN" N 1 AL SCIENCES
At the request of Davis-Martin-Powell, (DMP), an evaluation was conducted of the
soils on five previously selected sites associated with the Randleman Dam Project.
The purpose of the evaluation included the following:
1. To assess the accuracy of the soil maps prepared by the Soil Conservation
Service (SCS) at each site;
2. To correct if necessary, the soils information on topographic maps provided by
DMP; and,
3. To identify any soil factor which could limit or restrict the use of the sites for
wetlands.
The soils identified by the SCS on the sites can be separated into two distinct groups:
1. the upland soils which have formed in residual parent material- Enon, Wilkes, and
Mecklenburg, and 2. the floodplain soils which have formed in alluvial sediments-
Congaree and Chewacla.
The upland residual soils due to a combination of factors such as clayey subsoils,
shallow depth to rock, and steep slopes, were considered unsuitable for use as
wetlands and not given further consideration in the evaluation.
The Congaree and Chewacla soils are similar soils having formed in loamy alluvial
sediments, but differ with respect to internal drainage. The Congaree is considered
well-drained and the Chewacla- somewhat poorly drained, which means the
Chewacla is inherently a wetter soil. The Chewacla soil should contain more naturally
occurring wetland areas than the Congaree soil, and could be modified for wetland
usage. The Congaree soil could also be used for wetlands, but is a naturally drier soil.
,
The Chewacla soil is typically found in broad, flat floodplain areas, and the Congaree
is typically found in long narrow floodplains. Although both soils have formed in
loamy sediments , the Chewacla soil tends to contain more clay in the subsoil with clay
loam and silt loam textures being common, while the Congaree soil tends to have
coarser subsoils with sandy loam and loamy sand textures common. The location of
the Congaree and Chewacla soils are highlighted in yellow on the site maps.
With the exception of the Buttke Dairy site, naturally occurring sand levees were
identified on the banks adjacent to the creeks at the other sites. The height and width
of the levee varied with the size of the creek, from 6 to 18 inches in height above the
adjacent floodplain elevation and up to 15 feet in width along the bank. The levees
consist of coarse textured sediments to depths of 60 inches. The levees are a source
of sediment during flooding because the sandy creek banks are easily eroded, and the
levees receive sediment during flooding when the creeks over flow their banks and
deposit sandy material.
Depth to rock in both soils is typically greater than 60 inches, and rock at depths of less
than 36 inches was not considered a limitation at any of the sites.
The preparation of a soil map is a two step process-identification of a soil type and
delineation of the soil from adjacent different soils. Although different soils on a soil
map are separated by a line suggesting a distinct boundary, the boundaries between
different soils are usually diffuse with broad transition zones. Typically, any soil area
delineated on a soil map will contain small inclusions of different soils. Due to the
variability and topography of a floodplain, small areas of Chewacla are expected to be
found with the Congaree soil, and vice versa.
The level of detail in any soil map is controlled by the scale of the base map. Small or
narrow soil areas can not be shown on soil maps due the limitations imposed by the
map scale, and attempts to transfer soils information betwen maps with different scales
may lead to incorrect interpretations. The Guilford County sites were mapped by the
SCS at a scale of 1 ":1650', and the Randolph County sires were mapped at a scale
of 1":2000'. Topographic maps of the sites used for the soil evaluations, were prepared
by DMP at scales of 1 ":100' and 1 ":200'.
1. Muddy Creek Site: The field evaluation confirmed that the Chewacla soil is the
predominant floodplain soil on the site as identified by the SCS. The site consists of
large, broad areas (150-200') of Chewacla soil on both sides of Muddy Creek. In a
couple of places, there is no floodplain where the creek channel and upland residual
soil are adjacent to each other. Sand levees, approximately 15 feet wide and 12-15"
high were observed along the creek banks. Depth to rock was not considered to be a
limitation to the use of this site for wetlands. Small depressions which were slightly
wetter than the surrounding areas were observed in the Chewacla floodplain.
r ,
2. Hickory Creek Site: The field evaluation of this site confirmed the presence of a
broad, flat area of Chewacla soil, and a long thin strip of Congaree soil adjacent to
Hickory Creek, as shown on the SCS soil map. The area of Chewacla soil was 300-
400 feet in width, while the Congaree soil areas were 100-150 feet in width. Small
sand levees adjacent to the creek were observed and depth to rock was not
considered a limitation to the use of this site. Small depressions in the Congaree soil
areas were considered to be inclusions of the slightly wetter Chewacla soil.
3. Reddick's Creek Site: This site consists of long, thin strips of the well-drained
Congaree soil adjacent to Reddick's Creek. Inclusions of Chewacla soil were
identified from soil borings with free water encountered in the these soils at 40" below
the surface. Small sand levees were observed adjacent to the creek, and in spite of
the rocky appearance of the site, bedrock was not encountered within 42 inches of the
surface in 24 soil borings throughout the floodplain area. The clay content in the
subsoil gradually increased from a sandy loam near the creek to a sandy clay loam
away from the creek. Three small alluvial terraces were identified with loamy
sediments over residual sandy clay at depths of 30 to 40".
4. Buttke Dairy Site: Most of this site based on the project boundaries was determined
to be residual, upland soil- Mecklenburg. Very little alluvial soil was identified in a thin
strip, 50-75 feet wide above Old Walker Mill Road, and a small area of Chewacla soil
was identified below the road where the floodplain widened along the creek. This site
was not considered as well suited for wetland modifications as some of the other sites.
5. Richland Creek Site: This site consists of large, broad, flat areas of Chewacla soil
on either side of Richland Creek as identified by the SCS. Due to the size of Richland
Creek, the sand levees along the creek banks were fairly large. Bedrock was not
encountered in soil borings to 45 inches in depth and was not considered to be a
limitation in the use of this site. Small, slightly wetter depressional areas were
observed in the floodplain. Due the size and extent of the Chewacla soil on the
floodplain, this site should be well suited for wetland modification.
Respectfully submitted,
Glen Simpson
Soil Scientist
Reddick's Creek Soil Boring Descriptions
BORING DEPTH DESCRIPTION
1 No rock w/i 48". ~50' from creek-
Layered sandy loam; loamy sand
sediments to 48 inches.
2 Rock @ 38" . -100' from creek-
Sandy loam topsoil to orange
sandy clay loam at 24 inches
with gradual clay increase.
3 No rock w/i 48". 150 ' from creek-
Terrace landscape position with
sandy loam and sandy clay loam
to 30" with residual orange/gray
sandy clay below 30" .
4 No rock w/i 48". -50' from creek-
Similar to soil Boring #1 except
for a gradual clay increase to
orange sandy clay loam at 42
inches.
5 Rock @ 42". -100' from creek-
yellowish-tan sandy loam to 24"
with orange sandy clay loam
from 24 to 42 inches.
6 No rock wA 45". - 50' from creek-
Similar to Borings #1 and 4 with
loamy sand and sandy loam to
42 inches. Slight clay increase
with depth.
7 No rock w/i 45". ~30' from creek-
Coarse-textured soil with layers
of loamy sand and sand to 45
inches.
8 No rock w! 48". - 100' from creek-
Low terrace landscape position
with tan loamy sand - sandy
loam to orange sandy clay loam
at 42 inches. Similar to Boring #3
and #5.
9&10
11
12
13
14
15
16
17
18
No rock w/i 45". Poorly drained area with
brown, sandy loam topsoil
over gray soil subsoil. Free
water encountered at 40
inches.
No rock wA 42" . 100' from creek-
Coarse- textured soil w/ layers of
loamy sand and sand to 42" .
Water encountered @ 40 inches.
No rock w/i 42". 150' from creek-
Gray silt clay loam to 30" with
gray silty clay loam from 30 to
42".
No rock w/i 45". 100' from creek-
Sandy loam topsoil underlain by
silty clay loam from 24 to 45".
Water encountered @ 36 inches.
No rock w/i 42". ~50' from creek-
Tan sandy loam over grayish
brown sandy clay loam from
30 to 42".
No rock w/i 42". -100' from creek-
Loamy sand-sandy loam over
brownish gray sandy clay loam
from 24 to 42". Similar to #14.
No rock w/i 42". ~50 ' from creek-
Similar to #14 & #15 w/ tan
sandy loam over brownish sandy
clay loam at 40".
Residual
No rock wA 42". -200' from creek-
Tan loamy sand-sandy loam
over tan sandy clay loam at 36".
19
20
21
22
23
24
No rock w/i 42" 150' from creek Terrace
landscape position with 36" of
sandy loam over residual orange
- gray sandy clay from 36 to 42".
No rock w/i 42". Gray sandy loam to 42".
No rock w/i 42". Gray sandy loam and sandy clay
loam to residual orange/gray
sandy clay at 36".
No rock w/i 42". 100' from creek residual soil
with residual clay at 10".
No rock w/i 42". -100 from creek sandy loam
over sandy clay loam at 30
inches. Water encountered C
40".
No rock w/i 42". 150 from creek tan sandy loam
over orange sandy clay loam
from 30 to 42".
i
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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
Ja mes R Hunt, Jr., G ove mor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
June 5, 1996
Drs. Doug Frederick and Russ Lea
Triangle Wetland Consultants
Post Office Box 33604
Raleigh, NC 27636
Dear Drs. Fredrick and Lea:
AAM Oft
?EHNF1
Thank you for providing a copy of the Wetland and Habitat Mitigation Plan (March
27, 1996) for Randleman Lake. This plan provides an informative and succinct description
of the wetland issues associated with the development of reservoir and is well written, well
organized and includes many citations to the scientific literature. My review of the plan
focused primarily on assessing whether lost wetland functions will be replaced but I have
provided comments on many related issues.
Overall the plan focuses on the replacement of lost wetland area and provides a
good discussion of the uses of wetlands by wildlife. However, the initial water quality
conditions of this reservoir are expected to promote primary productivity resulting in high
concentrations of chlorophyll a, particularly in the upper arms of the lake. This is clearly a
concern that needs to be addressed before a Section 401 water quality certification can be
issued. Landscape level approaches to address and solve water quality problems are now
beginning to be developed and examples exist in the scientific literature. The statement
"environmental issues yet to be identified will have to be resolved through the extended
review process and thus will be addressed by later versions of this mitigation plan" (page
2) indicates the importance of the plan and the need to go beyond the traditional 'this for
that' philosophy and wildlife concerns associated with compensatory mitigation.
The Division of Environmental Management (DEM) has serious concerns about the
water quality of the reservoir particularly the projected chlorophyll a concentrations in the
upper arms of the lake. These projected concentrations will exceed the water quality
standard of 40 µg/1 for chlorophyll a. Section 401 water quality certifications are issued
only when an applicant of a project can show (or the DEM can determine) that the effects of
the project will not violate water quality standards resulting in a significant loss of use.
These concerns have been conveyed to the applicant at several meetings. In addition, the
opportunities that compensatory mitigation can provide to address water quality concerns
also were conveyed at those meetings. The present mitigation plan does not target water
quality concerns regarding stormwater runoff and chlorophyll a.
One possible approach to the water quality and wetland mitigation issues could
involve the restoration, creation and enhancement of wetlands along tributaries to the
proposed reservoir throughout the watershed. This idea was proposed to the Piedmont
Triad Regional Water Authority by Mr. John Domey (DEM) during the December 6, 1995
meeting. A similar approach is being undertaken by the City of High Point in the
watershed for Oak Hollow Lake.
•onmental Sciences Branch • 4401 Reedy Creek Road Raleigh, North Carolina 27607
,one 919-733-9960 FAX # [phone]
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page 3
Groundwater recharge/discharge Groundwater discharge and recharge are often cited as
functions of a wetland and are alluded to in the mitigation plan. Although these are
important processes, they are more a function of landscape position than a specific type of
habitat (i.e. wetlands). I mention this primarily to focus attention on the landscape instead
of smaller ecosystems contained within the landscape.
Exceptional Habitat Areas (p. 10) This section mentions the existence of seasonal ponds
and states that "excellent seasonal pond creation opportunities exist in open fields at the
upstream limits of the proposed reservoir." The discussion of these exceptional habitat
areas and seasonal ponds focuses primarily on mature forests and the benefits of seasonal
ponds for amphibians. However, if excellent wetland creation opportunities exist in the
upstream limits of the proposed reservoir, these also should be explored to address water
quality concerns.
Management Criteria for Buffer Area (,p. 15) A management plan for the buffer area should
be developed and address a variety of concerns. Water quality issues that can be addressed
include wetlands, stormwater and control of erosion and sedimentation.
Proposed Pool Level Management (F. 16) Ensuring proper hydrological conditions for the
growth and establishment of the proposed created wetlands will be necessary. However,
these conditions may not be appropriate for the long term maintenance of the communities
and reproduction of specific tree species. That is, hydrological conditions that promote
seed germination are not the same as those conditions for the maintenance of a forest
community. A description of how the proposed management of the pool level may affect
wetland functioning would be beneficial.
Ac ear gg The draft wetland mitigation plan (July 10, 1995) states that 107 acres of
jurisdictional wetlands will be created between the 683 and 685 ft MSL elevations.
However this plan (March 27, 1996) states that 380 acres of wetlands will be created
between the 680 and 682 ft MSL elevations. This discrepancy should be clarified. Please
state what the normal pool level will be.
Table 2 (U. 18) This table presents a list of species recommended for planting. Note that
sweetgum (j iauidambar sWAdflua will become established naturally and thus should not
be planted. In addition, alder (fig serrulata) is a nonleguminous nitrogen fixing species.
Since eutrophic conditions are expected to develop within the proposed reservoir,
additional nutrient sources may need to be discouraged. We have discussed nitrogen
fixation in alder briefly and agree that, under certain conditions, it can be a desirable species
to plant. Since nitrogen is unlikely to be a limiting nutrient in this reservoir the use of alder
will not be discouraged.
Cleared Areas (p. 18) The mitigation plan mentions that there are many undesirable
creation sites. These include areas with eroded A-horizons and steep slopes. Although
these may be inappropriate sites for wetland creation, these sites probably need stabilization
and vegetative cover. Permitting these sites to regenerate naturally may slow the
stabilization processes. Clearly, these are areas in need of management.
Site Preparation (p. 19) Site preparation activities will include clearing, ripping,
fertilization and herbicide application. Many, if not all, of these activities are necessary for
successful wetland creation, however they may initially conflict with water quality goals of
the reservoir. That is, additional nutrient sources resulting from fertilization could
exacerbate primary productivity in the reservoir. In addition, the application of herbicides
will have to be timed to prevent entry into surface waters. These precautions are necessary
presuming filling of the reservoir may coincide with wetland creation activities.
page 5
Literature cited:
Megonigal, J.P., W.H. Conner, S. Kroeger and R.R. Sharitz. 1996? Aboveground
production in southeastern floodplain forests: A test of the subsidy-stress hypothesis.
Accepted to Ecology, under revision).
Mitch, W.J. and . Rust. 1984. Tree growth responses to flooding in a bottomland forest
in northeastern Illinois. Forest Science 30:499-501
October 15, 1996
MEMO
TO: John Kime, Piedmont Triad Water Authority
John Hefner, U.S. Fish and Wildlife Service
Frank McBride, NC Wildlife Resources Commission
David Franklin, U.S. Army Corps of Engineers
FROM: John Dorne
RE: Meeting to discu s Randleman Reservoir mitigation needs
Davidson County
As you are aware, David Franklin has scheduled a meeting at
the proposed Cone's Folly mitigtation site for the Randleman
Reservoir on 22 October 1996. In a letter sent to the Piedmont
Triad Water Authority on 21 July 1996 (attached), we suggested
that a meeting be held with the applicant and the agencies to
determine a mitigation approach for the reservoir. Mr. Kime has
agreed that such a meeting would be useful. Since we will be
meeting with regard to this project on 22 October, I suggest that
we meet to discuss the larger mitigation matter after the field
visit to the Cone's Folly site. David agrees with this approach.
Please call me at 919-733-1786 if you have any questions or
concerns about this proposed meeting.
ran.mit
cc: Steve Tedder
--------Ron- Linville, Winston-Salem DWQ Regional Office
Central Files
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
Ja mes B. Hunt, Jr., G ovemor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
July 21, 1996
Mr. John Kime
Piedmont Triad Regional Water Authority
Wilmington Building
Suite 100
2216 West Meadowview Road
Greensboro, N.C. 27407-3480
Dear Mr. Kime:
RE: Wetland mitigation plan
Proposed Randleman Reservoir
Randolph County
&k?41 e
ID FE F1
Thank you for the copy of the letter you sent to the U.S. Army
Corps of Engineers dated 24 June 1996 concerning changes in your
proposed wetland mitigation approach for the Randleman Reservoir.
John Dorney of my staff has discussed the matter with David Franklin
of the Corps and we believe that a meeting of your agency, the EPA,
the Corps of Engineers, Wildlife Resources Commission, U.S. Fish and
Wildlife Service and Division of Water Quality would be useful before
your revised mitigation plans proceed further. We are concerned that
wetland mitigation for this project should be coordinated with all
relevant agencies so you can be certain that the type and amount of
mitigation proposed will be approvable by these agencies. As you are
aware we have had ongoing concerns with the water quality of the
reservoir and continue to believe that significant wetland mitigation
should partially be directed at protecting the water quality of the
reservoir. The work proposed by the City of High Point for treating
urban runoff for Oak Hollow Reservoir may well serve as a prototype
for the Randleman Reservoir as well.
Please call Mr. John Dorney or Jimmie Overton of my staff-at 919-
733-1786 to schedule a meeting. We will be glad to host a meeting at
our Water Quality Laboratory if you prefer. We look forward to
developing a wetland mitigation plan which will both satisfy the
wetland permitting requirements and protect the water quality of the
reservoir.
S'ncerely,
Steve W. Tedder, Chief
randlke.mem
cc: David Franklin, Corps of Engineers
Lee Pelej, U.S. EPA
Newt Colston, Black and Veatch
Environmental Sciences Branch • 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
An Equal Opportunity AMffna&e Action Employer 509E recycl MOI/. post cormumw paper
October 15, 1996
MEMO
_TO:..-.. __--John Kime, Piedmont Triad Water Authority
John Hefner, U.S. Fish and Wildlife Service
Frank McBride, NC Wildlife Resources Commission
David Franklin, U.S. Ar y Corps of Engineers
FROM: John Dorn
RE: Meeting to discu s Randleman Reservoir mitigation needs
Davidson County
As-you are aware, David Franklin has scheduled a meeting at
the proposed Cone's Folly mitigtation site for the Randleman
Reservoir on 22 October 1996. In a letter sent to the Piedmont
Triad Water Authority on 21 July 1996 (attached), we suggested
that a meeting be held with the applicant and the agencies to
determine a mitigation approach for the reservoir. Mr. Kime has
agreed that such a meeting would be useful. Since we will be
meeting with regard to this project on 22 October, I suggest that
we meet to discuss the larger mitigation matter after the field
visit to the Cone's Folly site. David agrees with this approach.
Please call me at 919-733-1786 if you have any questions or
concerns about this proposed meeting.
ran.mit
cc: Steve Tedder
- r r--_..._.Ron ..L?pville, Winston-Salem DWQ Regional Office
Central Files
October 15, 1996
MEMO
_._TQ:_..... ...-...-.John Kime, Piedmont Triad Water Authority
John Hefner, U.S. Fish and Wildlife Service
Frank McBride, NC Wildlife Resources Commission
David Franklin, U.S. Ar y Corps of Engineers
FROM: John Dorne IDA
RE: Meeting to discu s Randleman Reservoir mitigation needs
Davidson County
- - .-As:-you are aware, David Franklin has scheduled a meeting at
the proposed Cone's Folly mitigtation site for the Randleman
Reservoir on 22 October 1996. In a letter sent to the Piedmont
Triad Water Authority on 21 July 1996 (attached), we suggested
that a meeting be held with the applicant and the agencies to
determine a mitigation approach for the reservoir. Mr. Kime has
agreed that such a meeting would be useful. Since we will be
meeting with regard to this project on 22 October, I suggest that
we meet to discuss the larger mitigation matter after the field
visit to the Cone's Folly site. David agrees with this approach.
Please call me at 919-733-1786 if you have any questions or
concerns about this proposed meeting.
ran.mit
cc: Steve Tedder
- Ran_-l,uille, Winston-Salem DWQ Regional Office
Central Files
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., G ovemor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
July 21, 1996
Mr. John Kime
Piedmont Triad Regional Water Authority
Wilmington Building
Suite 100
2216 West Meadowview Road
Greensboro, N.C. 27407-3480
Dear Mr. Kime:
RE: Wetland mitigation plan
Proposed Randleman Reservoir
Randolph County
LT.W?FA 1
40
A&141 0
?EHNF1
Thank you for the copy of the letter you sent to the U.S. Army
Corps of Engineers dated 24 June 1996 concerning changes in your
proposed wetland mitigation approach for the Randleman Reservoir.
John Dorney of my staff has discussed the matter with David Franklin
of the Corps and we believe that a meeting of your agency, the EPA,
the Corps of Engineers, Wildlife Resources Commission, U.S. Fish and
Wildlife Service and Division of Water Quality would be useful before
your revised mitigation plans proceed further. We are concerned that
wetland mitigation for this project should be coordinated with all
relevant agencies so you can be certain that the type and amount of
mitigation proposed will be approvable by these agencies. As you are
aware we have had ongoing concerns with the water quality of the
reservoir and continue to believe that significant wetland mitigation
should partially be directed at protecting the water quality of the
reservoir. The work proposed by the City of High Point for treating
urban runoff for Oak Hollow Reservoir may well serve as a prototype
for the Randleman Reservoir as well.
Please call Mr. John Dorney or Jimmie Overton of my staff:at 919-
733-1786 to schedule a meeting. We will be glad to host a meeting at
our Water Quality Laboratory if you prefer. We look forward to
developing a wetland mitigation plan which will both satisfy the
wetland permitting requirements and protect the water cruality of the
reservoir.
S'ncerely,
Steve W. Tedder, Chief
randlke.mem
cc: David Franklin, Corps of Engineers
Lee Pelej, U.S. EPA
Newt Colston, Black and Veatch
Environmental Sciences Branch • 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
An Equal Opportunity Affinnadve Action Enpbyer 5096 nxyeWN109'6 post cwrAr er pager
RECEIVED
JON 2 6 1996
ENVIRONMENTAL SCIENCES
PIEDMONT
TRIAD REGIONAL
W A T/E R
?J
AUTHORITY
June 24, 1996
41V-
0111-
Mr. David Franklin
US Army Engineering District /?
P. O Box 1890
Wilmington, NC 28492-1890
Dear David:
Please disregard the draft mitigation plan dated March 27, 1996 and forwarded to
your office for review.
Due to other project considerations, the Water Authority is currently developing
another mitigation proposal under the direction of Dr. Newt Colston, Black & Veatch,
Inc.
If you have questions, please feel free to call.
erely,
o-QQ
John F. Kime n
Executive Director Q? cC
FK:hs -
J U
?Q
cc: Mr. John Dorney, DEM
Mr. Lee Pelej, EPA
Mr. Frank McBride, NCWRC p
Mr. John Ellis, USFWS 5
Mr. Charlie Hollis, Regulatory Consultant ??
Dr. Newt Colston, Black & Veatch, Inc. r'
LIS/ 0A5• -,7
G
? P?? _ ,? ASS ? ? ?? ??
Wilmington Building, Suite 100 • 2216 West Meadowview Road • Greensboro, North Carolina 27407-3480 • [phone]
9

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PIEDMONT TRIAD REGIONAL WATER AUTHORITY
Preliminary Design Guidelines and Information
for Constructed/Enhanced Wetlands
DAVIS-MARTIN-POWELL & ASSOCIATES, INC.
Engineering - Land Planning - Surveying
High Point, NC
e
SCOPE
¦ Develop a hydrologic model of the watershed by analyzing watershed conditions
¦ Evaluate runoff volumes and discharges from various storm events using the model
¦ Develop conceptual design for creating wetlands ( dam, dike, etc.)
¦ Route various flood events through site and determine water levels and drawdown
times for these flood events
Extended Detention (ED) Wetlands
In extended detention wetlands, extra runoff is created above the shallow marsh by
temporary detention of runoff. The ED feature enables the wetland to consume less
space, as temporary vertical storage is partially substituted for shallow marsh storage.
A new growing zone is created along the gentle side-slopes of ED wetlands that extends
from the normal pool elevation to the maximum ED water surface elevation.
The water level within an ED wetland can increase by as much as three feet after a storm
event, and then return to normal levels within 24 hours. As much as 50% of the total
treatment volume can be provided as ED storage, which helps to protect downstream
channels from erosion, and reduce the wetland's space requirement.
The design of extended detention wetlands involves unique sizing rules. In general, the
design standards for the ED wetland are as follows:
• the volume of extended detention (Edv) will be no more than 50% of the total
treatment volume (Vt)
• the target ED detention time for this volume will be 12 to 24 hours
• the use of V-shaped or proportional wiers is encouraged to assure a constant
detention time for all storm events
• the maximum ED water surface elevation should not be greater than three feet
above the normal pool of the wetland. Higher ranges in ED water surface
elevations are routinely used in conventional ED ponds, however, these cannot
be used in wetland applications. The large and frequent changes in water level
are not conducive to the growth of dense or diverse stands of emergent
wetland plants.
B4 ? _ "I
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Sizing of Stormwater Wetlands
Treatment volume is necessary but not a sufficient condition for achieving reliable levels of
pollutant removal. For this reason, the designer must design a stormwater wetland to
meet seven basic sizing criteria:
1. contain a treatment volume (Vt) that is capable of capturing the runoff
generated by 90% of the runoff-producing storms in the region on an annual
basis.
2. have a minimum surface area in relation to the contributing watershed area.
3. allocate the surface area of the wetland to meet targets for certain depth zones.
4. allocate the treatment volume of the wetland to meet targets for the depth
components of the wetland.
5. meet a minimum standard for the internal flow path through the wetland.
6. demonstrate that the water supply to the wetland is greater than the expected
loss rate (so that water elevations can be maintained).
7. provide for extended detention for smaller storms (ED wetlands only).
Sizing Criteria
Runoff Treatment Volume (Vt)
Wetland to Watershed Area Ratio
Allocation of Surface Area (%)
Allocation of Treatment Volume (%)
Flow Path
a. length to width ratio
b. dry weather path
Water Balance
Extended Detention
ED Wetland
min Vt of 0.25 watershed-inches
0.01
20 - deep
35 - to marsh
45 - hi marsh
20 - pool
30 - marsh
50-ED
1:1
2:1
inflow rate > 0.002 cfs/acre
Edv = 50% of Vt
12 to 24 hours
ED range <= 3 ft.
A 1.0% wetland to watershed area ratio is recommended as a target. However, this
criteria may not always be feasible at some sites, and may be waived.
TARGET ED
ALLOCATIONS WETLANDS
Percent of
Surface Area:
Forebay 5
Micropool 5
Deepwater 0
"Lo Marsh" 40
"Hi Marsh" 40
"Semi-Wet" 10
Percent of
Treatment Volume:
Forebay 10
Micropool 10
Deepwater --
"Lo Marsh" 20
"Hi Marsh' 10
"Semi-Wet" 50
Deepwater - one to six feet below normal pool (includes forebays, miropools, pool and
channel)
Lo Marsh - six to 18 inches below normal pool
Hi Marsh - zero to six inches below normal pool
Semi-Wet - zero to 2 feet above normal pool ( includes ED )
The allocation targets are only general guidelines and will vary according to design and
site constraints.
Sediment Forebav
A separate-cell sediment forebay is a required design element for the ED wetland system.
A sediment forebay serves several useful purposes in wetland design, as it acts to:
• Reduce the incoming runoff velocities to the wetland
• Trap coarse sediments before they enter the wetland, thereby preserving its
capacity and microtopography.
• Spread runoff evenly over the marsh to create sheetflow conditions.
• Extend the flow path and prevent short-circuiting.
The forebay should comprise at least ten percent of the entire treatment volume, Vt, and
should be 4 to 6 feet deep. The forebay should be a separate cell, which can be formed by
gabions or an earthen berm.
Micropool
The purpose of the micropool is to create sufficient depth near the outlet to allow for a
reverse sloped pipe to extend into the normal pool. Typically, the release from the pond is
situated no more than one foot below the permanent pool. The reverse sloped pipe has
been demonstrated in the field to be highly resistant to clogging, which can be a major
concern given the vegetation within wetlands. Organic rich sediments are trapped below
the orifice, and debris and plant wrack float above it.
The minimum dimensions for a micropool are that it comprise ten percent of the total
treatment volume(Vt) and that it be four to six feet in depth. The micropool should be
equipped with a drain capable of de-watering the wetland within 24 hours. Typically, the
pond drain is controlled by a lockable and adjustable gate valve within the riser. The drain
should have an upward facing inverted elbow, so that it extends above the bottom
sediments of the micropool.
The pond drain is an integral feature of the stormwater wetland as it allows the operator to
manipulate water levels within the wetland (e.g., to drawdown for the planting of
emergent wetlands or to cleanout sediments from the forebay).
** Taken from "Design of Stormwater Wetland Systems: guidelines for creating diverse
and effective stormwater wetlands in the mid-Atlantic Region" , Metropolitan
Washington Council of Governments
• Outlet sized to carry base flow of 7.03 cfs and maintain 18" water depth above top of
channel.
• Riser perforated to allow storm flows to be drawn down over a period of time. Allow
saturation in "semi-wet" areas and create hydric conditions.
• Emergency spillway provided to by-pass large storm flows and prevent dam
overtopping. Allow large flows to follow channel more closely.
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Randleman Lake
Overview of 401 Certification Issues
March 3, 1995
The proposed Randleman Lake project will need an Individual 404 Permit and 401
Certification since about 130 acres of wetlands will be impacted. This impact will require
compensatory mitigation probably through creation of wetlands. To date, no 404 Permit
application has been received by DEM. DEM staff have had preliminary meetings with
consultants from the Piedmont Triad Regional Water Authority concerning a possible
mitigation approach which would combine wetland creation with watershed protection via
regional stormwater ponds. It is likely that obtaining the 404 Permit will take up to several
years unless numerous, thorough preapplication meetings are held by the Authority with DEM
and the Corps of Engineers (COE). To date, these meetings have not been held nor are they
scheduled. The Corps of Engineers will probably have to develop, circulate and eventually
approve an EIS for this project. This document can use the existing reports done of the
authority. DEM and the COE will not be able to conclude their regulatory responsibilities
until the document is finalized. This will also add to delays in the project. The conceptual
mitigation plan will have to be a part of the EIS. The EPA, COE and DEM will review the
project to determine whether there are any practicable alternatives to the dam and then (if
there are none) whether the wetland loss (from flooding) has been adequately replaced
through mitigation.
In addition, DEM's decision will be based on the compliance of the lake with water
quality standards. Based on modeling to date, the water quality standard of concern will most
likely be chlorophyll a. The state water quality standard is 40 ug/1. The consultant's model
shows that average levels in the uppermost arm of Randleman Lake will be about 90 ug/l
without extensive WWTP improvements, 81 ug/l with an effluent concentration of 1.0 mg/1 P
from the WWTP, 75 ug/1 with an effluent concentration of 0.5 ug/l P from the WWTP, and
53 ug/l without the WWTP. All these are well in excess of the relevant water quality
standard. In other portions of the lake predicted chlorophyll a levels appear to be generally
less than the water quality standard. DEM believes that a 401 Certification can probably be
issued for this project if strong measures are taken to control or manage nutrient inputs
(especially P) into the upper arm of the lake. It is very possible to combine these measures
with the wetland mitigation that will be required for this project. One possible approach
would be to design a large portion of the upper arm(s) of the lake to create freshwater
marshes and bottomland hardwood forests. These areas would 1) remove excessive nutrients
before they reach the lake and 2) satisfy the mitigation requirements for the 404 Permit and
401 Certification. Control of future (and perhaps existing) urban development in the
watershed will also be essential to ensure adequate water quality in the reservior. DEM looks
forward to working with the Authority to develop a watershed management plan which will
allow the timely issuance of a 401 Certification and will provide an acceptable source of
water for the region. We suggest that the model for the watershed be revisited to identify
specific nutrient sources, potential load reductions based on specific controls and to determine
the likely algal response to the controls.
randlemn.ltr

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Ms. Andrea Spangler
Piedmont Triad Water Authority
Wilmington Bldg., Suite 217
2216 W. Meadowview Rd.
Greensboro, NC 27407
I A 'T X?FA
I D FE F1
June 23, 1997
RE: Watershed protection for proposed Randleman reservoir
Dear Ms. Spangler,
The purpose of this letter is to inform you of the status and scope of the individual water
supply watershed protection ordinances for the various local governments having land use
jurisdiction in the proposed Randleman reservoir watershed. These local governments
include Guilford and Randolph Counties, the Town of Jamestown, and the Cities of
Archdale, Greensboro, High Point, and Randleman. Local water supply watershed
protection ordinances for each of these municipalities have now been reviewed by Division
of Water Quality (DWQ) staff; several are pending revision prior to final review and
approval by the Environmental Management Commission (EMC) in acco dance with the
Water Supply Watershed Protection Act (NCGS 143-214.5).
In summary, the two counties and the City of Greensboro are protecti g the proposed
reservoir as if it were currently classified for water supply; the other local overnments are
not. A summary chart comparing the different watershed management strategies for each
of the local governments is attached. Randolph County, in particular, deserves special
mention for taking extraordinary measures to protect this potential future water supply
watershed area.
Since the reservoir does not exist and there is no current classification, DWQ can not
require local governments to enforce water supply watershed protection ordinances for this
particular land area. However, DWQ staff feels that, in light of the proposed future
reclassification for the Randleman reservoir, and to address concerns over potential
upstream pollution and/or contamination, these municipalities would be wise to go above
and beyond state minimum standards and adopt measures to protect the water quality in this
area. Staff would ask that you encourage the municipalities not currently protecting their
land area within the proposed Randleman reservoir watershed to seriously consider
amending their local ordinances to do so, should they desire reclassification for water
supply in the future.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50%a recycled/ 10% post-consumer paper
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Ms. Andrea Spangler
Piedmont Triad Water Authority
June 23, 1997
Page Two
If you have any questions regarding the staffs review and analysis or regarding the
Water Supply Watershed Protection Program in general, please contact me at (919) 733-
5083, extension 508 at your convenience. Thank you in advance for your cooperation and
support of the Water Supply Watershed Protection Program.
Sincerely,
%?4 c -A?
Brent C. McDonald
Community Planner
cc: John Dorney, DWQ -- WQ Lab
Ron Linville, DWQ -- WSRO
Warren Simmons -- Guilford County
Hal Johnson -- Randolph County
J. Martin Myers -- City of Archdale
C. Thomas Martin -- City of Greensboro
James Boyer -- City of High Point
John J. Frezell -- Town of Jamestown
Rick Hardin -- City of Randleman
David Long, DCA -- WSRO
DWQ -- Central Files
t?A O
? cFti
?Fs
-State of North Carolina
f Department of Environment,
Health and Natural Resources
Division of Water Quality rr
sholdw
James B. Hunt, Jr., Governor 1
Wayne McDevitt, Secretary C) E y N
A. Preston Howard, Jr., P.E., Director
September 30, 1997
MEMORANDUM
TO, Melba McGee _
FROM: Michelle Suverkrubbe
THROUGH: A. Preston Howard, Jr., P.E.
RE: Comments on SCH # 98-0029; DWQ#11686
Piedmont Triad Regional Water Authority (PTRWA)
Randleman Lake DEIS
Randolph and Guilford Counties
The proposed project consists of a Draft Environmental Impact Statement (DEIS)
on the Section 404 Permit prepared by the Army Corps of Engineers for the Randleman
Lake project for Piedmont Triad Regional Water Authority (PTRWA). The DEIS will also
be used by the Division of Water Quality (DWQ) in issuing a Section 401 Water Quality
Certification for the project.
The project entails discharging dredged or fill materials into waters of the US and
their contiguous wetlands. The proposed water supply reservoir will inundate 28 miles of
free-flowing streams, impact approximately 121 acres of Section 404 jurisdictional
wetlands, and inundate 3,000 acres of forest, agricultural and residential land.
The Division has reviewed the DEIS. As you will note, the Division is very
concerned about the future water quality in the proposed reservoir. The Division,
however, is prepared to issue a 401 Water Quality Certification on this project, subject to
the condition that PTRWA develop (with DWQ's assistance) a Nutrient Reduction Strategy
and Watershed Management Plan for the Randleman Lake Watershed.
This Strategy and Plan will need to determine the level of nutrient reduction
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
Strategy and Plan will also need to define the specific management strategies necessary to
achieve the nutrient reductions, and demonstrate how these necessary reductions will be
accomplished and sustained into the future for the watershed. This Management Plan and
Nutrient Strategy will need to be.approved and put in place (i.e. local government
ordinances adopted and effective, if necessary) pnor to the reclassification of the
Randleman Watershed for Water Supply purposes.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 2
Regional / Program Management Coordination Branch Comments on DEIS
The DEIS states that Randleman Lake would be expected to violate the state water
quality standard for chlorophyll a (40 mg/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 Eastside
WWTP discharging effluent of total phosphorous of 0.5 mg/l, nuisance algal
blooms are still predicted to occur 70-80 % of the time in the upper Deep River arm,
and violations of the water quality standard for chlorophyll a are still anticipated to
occur throughout the proposed lake, due to point and non-point sources of nutrients
in the watershed.
In response to this prediction of eutrophication in the future reservoir, the DEIS
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
-- fi.iished water would meet all drinking water standards." This approach ignores
state in-stream and in-lake water quality standards (ser 15A NCAC 2B .0211) that
require consideration of other potential uses of the reservoir, including aquatic life
propagation and survival, fishing, wildlife, secondary recreation (wading and
boating), and agriculture.
The Division has found that the Deep River currently exhibits consistent problems
associated with elevated nutrient loading such as nuisance algal blooms and low
dissolved oxygen (DO). The Division is seriously concerned that impoundment of
the river will tend to exacerbate these existing eutrophic conditions, potentially
leading to extensive algal blooms, low dissolved oxygen, common occurrence of
fish kills, reduction of fish stocks, decrease in the diversity of fisheries, taste and
odor problems in the drinking water (even after treatment), and reduced
opportunities for human recreation on the lake.
2. An explanation should be provided in the EIS addressing specifically which
alternatives under review in this DEIS differ from the alternatives discussed for the
prior EIS (dated 1991, prepared by the NC Division of Water Resources). Also,
the EIS should discuss why the selection of alternatives for the project has changed.
3. Alternative A, the Upper Deep River Lake, is proposed to flood parts of the
Seaboard Chemical Company, High Point Landfill and High Point Eastside WWTP
sites. Therefore, due to the potential environmental impacts of hazardous waste
leaching from these buried sites into the reservoir and the cost to relocate the
existing Eastside Plant, this alternative was deemed unacceptable in the EIS. The
EIS should either consider a redesign of this alternative so that flooding of these
sites would not occur, or discuss why this alternative cannot be redesigned to avoid
flooding these sites. Obviously, if this alternative was not designed to flood these
sites, the acceptability of that alternative may be substantially greater, both in terms
of reduced costs (especially the $64 million to relocate the High Point Eastside
WWTP) and fewer potential environmental/ health (toxicant) impacts.
4. On pages 1-5 and 1-6 of the document, the reasons that the Randleman Dam
proposal is considered the preferred alternative are discussed. One of the
mentioned items was cost. The conclusion that the Randleman alternative is least
costly does not take into consideration the issue mentioned in item 2. If the
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 3
replacement of the High Point Eastside WWTP was removed from Alternative A
(Upper Deep River Lake), its costs would be reduced by $64 million to
$108,912,624, making it the cheapest alternative discussed in this EIS, cheaper
than the Randleman alternative by $14 million.
The costs listed for the Randleman alternative presented in Table 13 do not appear
to be complete. The document should indicate how the $200,000 listed for cleaning
up the Old Randleman Dump was derived. The Randleman alternative should
include estimated costs to remediate and clean up the groundwater from the High
Point Landfill and the Seaboard Chemical sites to protect aquatic and human health
water quality standards in the proposed reservoir (that are necessary due to the
proposed reservoir, and would not be necessary if the reservoir was not proposed).
The Randleman alternative should also indicate the potential costs to build a water
treatment plant with the advanced technology necessary to treat the water quality
expected in this lake, e.g. GAC (activated carbon), membrane filters, auxiliary
treatment lagoons, etc. Such an advanced plant would not necessarily be required
for the other alternatives. A true and complete representation of costs presented is
necessary before it can be stated that Randleman Lake is "estimated to be the least
costly alternative by a substantial margin."
5. Pages 3-4 of the DEIS, it is stated that, "Contamination of groundwater in the
vicinity of the proposed reservoir has created some concern regarding potential
impacts on water quality of the lake. Toxic substances from the abandoned
Seaboard Chemical Company and the Closed High Point Landfill, both of which
are located along the Upper Deep River adjacent to the proposed reservoir, have
contaminated the groundwater at each site. However, modeling studies have
predicted that contaminated groundwater from these sites `should not have any
significant impacts on the water quality of Randleman Lake'." This statement was
taken from earlier modeling results of several Black & Veatch studies dating back to
1991.
DWQ has reviewed comments made by Bill Meyer with the Division of Waste
Management (dated 8126/97) on this DEIS. DWM states that they believe "the
contaminant loading to the Deep River is substantially higher" (yet un-quan tified),
than that modeled by Black and Veatch.
The Special Order for cleanup of these sites (which was recently published in the
NC Register) indicates known releases of hazardous substances on the sites. Soils
tests have revealed the presence of volatile and semi-volatile organic compounds,
including but not limited to acetone, 1,2-dichlorobenzene, 1,1-dichloroethene, 1,2-
dichloroethene (total), methylene chloride, 1,1,1-trichloroethane, phenol,
naphtahlene, bis-2 ethyl hexyl phthalate, and 1,2,4 trichlorobenzene.
Groundwater sampling (separate from the current testing being performed for the
Remediation Investigation), revealed the presence of volatile and semi-volatile
organic compounds, including but not limited to acetone, benzene, 1,1-
dichloroethane, 1,2- dichloroethane, 1,1-dichloroethene, 1,2- dichloroethene
(total), methylene chloride, 1,1,1-trichloroethane, phenol, and naphtahlene.
The DWM letter on the current DEIS indicates that the results of the Remedial
Investigation will not be available until February, 1998. The potential toxicant
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 4
impacts to the water quality of Randleman Lake should be reevaluated upon receipt
of the February Remedial Investigation Report.
6. On page 3-28, the DEIS states that, for Randleman Lake "watershed protection
measures have been in place for more than eight years." Also, on page 3-29 it is
stated that "... other alternatives involve Rockingham and Alamance Counties,
which do not have watershed protection ordinances." Both of these statements are
misleading.
The Division manages the Water Supply Watershed Program for the state and our
records indicate the correct statements should be:
(Page 3-28) - "For the Randleman Lake watershed, 86% of the watershed is
currently protected under water supply watershed protection programs by local
governments - Randolph County (which comprises 37% of the watershed),
Guilford County (4717o), and Greensboro (290). The municipalities of Archdale,
which makes up 690 of the watershed, and High Point (8%), Jamestown (1%), and
Randleman (1 %) are not currently implementing any water supply watershed
protection programs for the Randleman Lake watershed, although they may have
watershed protection ordinances that require protection of other watersheds in their
jurisdictions."
(Page 3-29) - "Rockingham and Alamance Counties both have adopted watershed
protection ordinances which protect approved water supply watersheds in their
jurisdictions; however, neither have yet adopted protections for any of the
alternatives discussed in this EIS, including the Randleman alternative."
(Pages 5-24 and 25) - It is accurately stated that Guilford and Randolph Counties
have enacted watershed protection ordinances, but they fail to mention the fact that
Greensboro also currently protects the Randleman watershed.
In addition to amending these above sections, the EIS should provide an .
explanation for why the municipalities listed have not chosen to enforce watershed
protection provisions in the Randleman Watershed.
7. Table 10, page 3-16 discusses surface water evaluation criteria for each alternative.
This table should include a criteria for whether or not each alternative would meet
state water quality standards (including protecting aquatic life, recreational, and
water supply uses).
8. The Corps should refer back to DWQ's letter to PTRWA on January 24, 1997 for
specific comments on the wetlands aspects of this project and mitigation proposed
by PTRWA.
mis:1980029 Randleman EIS
cc: DWQ staff
DEH - Public Water Supply
MRWA - Mr. John Kime
FROM 9197153605 SOLID WASTE DIV
Staia o North C line
Dep#rt ent of irohment,
Health and Nat&i Resources
Division of Wiste anagement
James . Hunt, Jr, Governor
We?ne cDevitt, cretary
William ?. Meyer, rector
MEMO UM
To; Melba
From; Bill M
Divisil
RE; June 1
and RI
The Division of Wass
08.26.1997 15:23
P. 1
i
EDF=HNF;Z
August 26,1997
cGee
or, Direoforz?? ,
of Waste Management
Post•It" brand fax transmittal memo 7871 IN of P0966
rom
o. o.
apt. on•
.Y r
7 D'ra`t Environmental Impact Statement for Randleman Lake, Guilford
lolph Counties, North Carolina (EIS)
(DAM has five continents on the EIS.
The DWM do rot believe the modeling inputs (both volumes of contaminated water,
number of con 'nants, and contaminant concentrations) assigned to the Seaboard
Chemical Site .d the City of High Point Landfill by Black and Veatch are representative
of-the actual si . DWM believes the contaminant loading to the Deep River is
substantially her. Once the Remedial Investigation for the Seaboard Chemical Site
and the City o \
High Point Landfill are completed (sometime in 1998), the DWM will be
a to provide oro r epresentative values, Once those values are available, Black and
?atch should
7 a able to determine if there will be an impact on the Deep
River/Randle Lake from the Seaboard Chemical Site and the City of High Point
L I dfill.
T e DWM is ently finalizing an Administrative Order on Consent which authorizes
thi Seaboard up II and the City of High Point to undertake a feasibility study. The
fe sibility stud will examine remediation alternatives for the site,
•
?i
2. 0 page 5.11, ?I
Section 5.3.5,4, the EIS states that "... This analysis was reviewed and
ap roved by tl N.C. Division of Solid & Hazardous Waste (NCDSHW) and the .
N EMC..." T the best of my knowledge, the DIAM did not approve any analysis
performed on t modeling performed by Black and Veatch.
3. 0 page 5.12 ' Section 53,5,4, the EIS states that with the Randleman Lake, the 100 '
ye? flood wo reach approximately to elevation 691.5 feet mean sea level. Table 8 on
pa a 3-3 Indic s that 705.3 mean> sea level is the probable maximum flood pool
el vation, Thi levation is important because the amount of municipal waste that would
be under water luring a 100 year flood would be significantly different and the area
available for installation of a remediation system will be substantially less.
P.o. Box 29603. Rafe , North carolln& 27611.8603 Yolophone 019.733.499e FAX [phone]
I An E04 11 OPPOrtunhv Artumi110 Action EmPloyer E0% nicyt110 110% Port•Coniuma Piper
FROM 9197153605 SOLID WASTE DIV 08.26.1997 15124

" Memo - s. Me' lba Gee
August 2 6, 1997
Page 2 o 2
4. I the second Ill paragraph on page 5.12, the EIS states that "...The leachate is now
b ing colleete and transported by truck to the Eastside WWTP for treatment and
discharge ..." WM is eoncemed that this paragraph, including this sentence, implies
t lat all of the aehate generated at the landfill is being collected and treated. In fact, the
e?isting leach a collection system only intercepts leachate generated from a small
portion of the nditll.
section 5.3.
5. In 4 on page 5-13, there is a discussion of the Randleman Town Dump and
?
th potential a ironmental impacts on the proposed Randleman Lake. At the conclusion
olj, this section he EIS states that the Randleman Dump will be removed.
I
T e DWM rec
l i
emends that the removal be conducted i confornance wit;1 ?he attached
dance,
If there are any questi i s please contact either Bob Glaser at 733-2178 extension 215 or me.
clwp RI s4uAki?<am6, •p>
P. 2 j
I
I
i
I
i
. 11 I . 1 . . ..
***END***

COMMENTS RECEIVED FROM STAFF REVIEW
2/25/98
MODELING
• "Regardless of the modeling scenario utilized, it is highly
likely that chlorophyll a levels in violation of water quality
standards will be predicted to persist in this area (Deep
River I) of the reservoir for the majority of the growing
season."
• "Model predicts that loading in Deep River I must be reduced
to 1,800 kg/yr in order to prevent predicted chlorophyl a
levels from exceeding 40 ug/l more than 5% of the time."
Even without the discharge in that arm of lake, current
loading from that portion is estimated to be near 28,000
kg/yr. "a more substantial effort to reduce nutrients should
be required" Modeling could be improved but "it is unlikely
that any such adjustments would alter the fundamental
conclusions of the modeling effort."
• They should "revisit the economic alternatives analysis for
the discharge bypass option at this time."
• Groundwater contamination from superfund site should be
given more attention.
• "In short, the plan offers no measures to address NPS
loading to the reservoir other than those already required
by existing programs or permits."
PLANNING
• "The management strategy did not include any cost-
3
r1
effective analysis, although one of the objectives of this
strategy was to identify the most cost effective ways of
reducing nutrient loading."
• "Consider
categories
most cost
to interm
buffer . .
nutrient management for most
since nutrient management is
effective bmp's" "Extend the
ittent streams, require 10 feet
. and a minimum setback of 30
of land use
considered on the
buffer requirement
of undisturbed
Feet."
• "Increase wetland acreage (restored) in the watershed"
• Document potential phosphorus loading reductions through
illegal discharge removal and repair of leaking sewer lines"
• Certify all animal facilities.
• Plan only addresses nutrients, ignores toxicants.
• No indication of growth management controls to be applied.
• Should consider moving discharge and using other sources.
FIELD OFFICE
• Require buffers on all intermittent streams
• Will need a variance to get a reclassification. Will EMC
support.
• All jurisdictions in watershed should have equally stringent)
watershed protection measures.
• All developments should be made to "provide for
maintaining the hydrograph in order to prevent
streambank erosion and sediment deposition into the
4

proposed lake.".
• "PRTW should be empowered to mandate programs over all
jurisdictions".
• Concerns over what small facilities will be connected to
larger ones. Also missed two facilities.
POINT SOURCE PERMITTING
• Should be pointed out that WS requirements are not
designed for nutrient control.
• "They need to look at urban components of the Neuse Rules"
- buffers, illicit discharges
• Load reduction estimates are not clear. What efficiencies
were used" where did numbers come from? Percentages
from existing conditions???
Wetlands Restoration
• Can't guarantee they can use the program. Sites must meet
their requirements.
Wetlands - Dorney
• Nonpoint source program has no goals. Should be rejected.
Suggest "There shall be no increase in nonpoint so urce j
contributions of phosphorus to the lake based on February
1998 loadings ". It would basically set up a nutrie nt trading
process in the watershed and probably force more
stringent protect ion measures." Growth would be allowed
but would be " nutrient neutral",
• They have urged the Authority to select more sites to
provide for some margin of error.
• There is no mention of monitoring for wetland success.
5
•
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CLASSIFICATION ISSUES
QUESTION WILL "C" USES BE ATTAINED IN LAKE?
ANSWER
WE DECIDED THAT "C" USES WILL NOT BE ATTAINED IN UPPER
ARMS OF LAKE.
QUESTION
IF THE CHLOROPHYL A STANDARD WERE ONLY VIOLATED
24% OF THE TIME AND BY EPA GUIDANCE, THE USES WOULD
BE SUPPORTED, COULD WE SAY THE STANDARDS ARE MET?
OR, WOULD ALL CRITERIA NEED TO BE MET? COULD ASK EPA
QUESTION FOR THE AUTHORITY TO ANSWER
WE KNOW THAT STANDARDS WILL BE VIOLATED AND A 401
CANNOT BE ISSUED THEREFORE THE AUTHORITY WILL NEED
TO DECIDE WHICH REGULATORY PATHWAY THEY CHOOSE TO
FOLLOW TO ALLOW
• NSW CLASSIFICATION
• VARIANCE
• REVISION TO STANDARD
• ESTABLISH A SITE-SPECIFIC STANDARD WHEN
RECLASSIFYING WATER BODY
HAVE SOMETHING LIKE A 50-60 UG/L FOR A PERCENTAGE
OF THE TIME AS LONG AS MANAGEMENT ACTIONS ARE
TAKEN.
A • .

IF WE WERE NOT TRYING TO FORCE A GOOD PLAN, WE BELIEVE THE
CORPS AND EPA WOULD BE PUSHING TO DENY THE 404
APPROVAL.

y

9197153605 SOLID WRSTE DIV

LEOENOt
Dr-4

02.25.1998 10,18

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D 100 200 400 FIGURE
ERM-Southeast, Inc. SEABOARD AND RIVERDALE DR. LANDFILL BITES
CRARLOTTZ, NORM CAROUNA Mr.H POINT, NORTE CAROLINA 1
ERM
P. 2
FROM 9197153605 SOLID WASTE DIV
02.25.1998 10118
Table 1
SEABOARD CHEMICAL CORP. & RIVERDALE DRIVE LANDFILL
REMEDIAL INVESTIGATION REPORT
DEEP RIVER P-11ZOMETER ANALYTICAL DATA
p . ft
m m I' p 11
DAM
07118187
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07/16/87
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FROM 9197153605 SOLID WASTE DIV 02.25.1998 10119
Table 1 (Continued)
SEABOARD CHEMICAL CORP. & RIVERDALE DRIVE LANDFILL
REMEDIAL INVEaTI0ATION REPORT
ORge RIVER PIEZON19TER eNALY11CAi QAJA
P. 4
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L " , irk
Table 1 (Continuodl
SEABOARD CHEMICAL CORP. & RIVERDALE DRIVE LANDFILL
REMEDIAL INVESTIGATION REPORT
DEEP RIVER 21120MITER ANALYTICAL DATA
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From: John_D
Sent: Monday, March 02, 1998 4:48 PM
To: 'preston_howard @ h2o.enr.state. nc. us'
Cc: 'coleen_sullins@ h2o.enr.state. nc.us'; 'greg_thorpe@ h2o.enr.state.nc.us';
'[e-mail]'; 10_0 '[e-mail]';
'don [e-mail]. nc.us';'[e-mail]'; John_D
Subject: Randleman Reservoir meeting - Summary
I apologize in advance for the length of this email but this is a complex issue. Instead of copying all 12 DWQ staff
members at the meeting, I have cc'ed the Branch Heads so they can send it on as needed.
As you know, DWQ staff met with staff from the Piedmont Triad Regional Water Authority (PTRWA) this morning to
review the draft Nutrient Reduction Strategy and Implementation Plan developed to address DWQ's concerns regarding
eutrophication in the reservoir.
PTRWA staff reviewed the background and purpose of the nutrient management plan and modeling efforts to predict
eutrophication status of the lake. Their modeling indicates that under current conditions, the Deep River arm of the lake
will greatly exceed the water quality standard for chlorophyll a while the Muddy Creek arm will slightly exceed the
standard. The nutrient management plan will address this issue by 1) reducing point sources of phosphorus to the
maximum extent practical and 2) by handling nonpoint sources of phosphorus as required by the watershed protection act
and resulting rules.
Overall these strategies will still result in chlorophyll a exceedances in the Deep River arm when the lake is built and also
in the Muddy Creek arm as the watershed gets developed.
DWO staff discussed five major issues. DWQ staff believe that these issues will need to be answered for the
Environmental Management Commission before they agree to proceed to rule making. Also, DWQ will provide a summary
of the technical review comments to the Authority within one week
1. Schedule - It is possible to complete all the necessary rule making by the end of December 1998 in order to
have it ready for review by the January 1999 General Assembly. However the schedule is very tight and optimistic. Any
slippage for any reason would push the effective date for the reclassification and nutrient management plan back to the
year 2000.
2. Toxicants - Newly analyzed ambient data from DWQ and newly available data on the Seaboard Chemical
landfill from the Division of Waste Management point out relatively high, existing levels of several organic chemicals in
water of the Deep River. The PTRWA will need to model these chemicals to ensure that drinking water standards will be
met in the lake.
3. Point source of nutrients - The Authority was asked to readdress the option of relocating the High Point
discharge to below the lake. The Authority stated that relocation was mostly an economic issue (aproximately a $15
million dollar cost) rather than one which affects the safe yield of the reservoir. They will do additional analyses as well as
examine options for treatment of effluent from several mobile home parks and animal operations.
4. Nonpoint sources of nutrients - PTRWA staff will need to develop and thoroughly analyze various nonpoint
source control options for the reservoir. It is clear that the nonpoint source measures required by the watershed
protection act are not sufficient to protect water quality standards for Randleman Reservoir and that the Authority will
need to go above and beyond the minimal requirements of the watershed act. The Authority was given two weeks to
develop cost/benefit analyses of various options to manage these nutrient sources. Possibilities to examine include
buffers along intermittent streams, wider buffers on premanent streams, additional wetland creation, additional land use
controls, management of nutrients from already developed areas and other measures. The Authority was told to address
a mix of management measures and then to address how those measures could be implemented. An example of the
need for more stringent nonpoint source controls is in the Muddy Creek arm of the lake where modeling predicts that
eutrophication will not be a major problem when the lake is built but that without additional nonpoint source controls,
eutrophication will be a severe problem in the future.
5. Site-specific or revised water quality standards - Even with a thorough nutrient management plan, it is likely
that the chlorophyll a standard will be exceeded in the Deep River arm of the lake. EPA has expressed strong concerns
in this regard in their recent correspondence to the Corps of Engineers for the Environmental Impact Statement. DWQ
staff will investigate various regulatory options to address this generic problem. Any necessary action could be done
simultaneously with the reclassification and nutrient management plan for the lake.
In general, the PTRWA was told to develop a nutrient management plan which maximizes point source and nonpoint
source measures in order to protect the water quality of the lake.
The Authority expressed concern as to the willingness of the local governments to take those measures but will attempt to
meet DWQ's deadline of a revised plan within two weeks so we can continue to get the management plan adopted for
review by the 1999 General Assembly. .
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charges of first-degree murder and attempted
armed robbery. Prosecutors wilPst-k t5ie death
penalty against Lyons if he is convicted.
Lyons was charged after Stephen W. Stafford,
an owner of Sam's Curb Market in Ogburn Sta-
tion, was shot to death last September. A second
defendant, Derrick Hall, has pleaded guilty to
second-degree murder and attempted armed
vi. Idle ave wiu oe questioned again. If prosecu-
tors excuse that juror, the lawyers will need to
settle on eight more and two alternates.
Prosecutors have used six of the 14 peremp-
tory challenges allowed by law, and defense
attorneys have used four of their 14.
Judge William H. Freeman of Forsyth Superi-
or Court excused other jurors yesterday, some
because they said they could not vote for the
bouts of manic happiness and du
Freeman granted permission
Rob Lang to requestion one ju
vealed new information about Y .i
son. The juror said lie was a ford
leader and had seen how chi]6
from abusive or neglected back&
come juvenile delinquents. Lang i
questioning today.
Water authority to seek Legislators
$12.6 million for new dam state needs
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¦ Agency, responding to
demand rise, to ask local
governments for money
By Tenp Naft
JOURNAL RALEIGH BUREAU
GREENSBORO
Wearied by legislative wrangling and
pressed by rising water demands, the
Piedmont Regional Water Authority de-
cided yesterday to raise $12.6 million in
the next two years from its six local
governments for the proposed $68 million
Randleman Dam.
The group won't press the 1994
General Assembly to appropriate any of
the $6.6 million the authority expects
the state to kick in for the project.
Authority members praised a new
engineering study that, suggests that the
3,046-acre lake they seek can be im-
pounded on the Deep River near Randle-
man to provide safe drinking supplies.
Critics have opposed the dam on the
beep River because High Point dumps
treated sewage into the river not far
from the proposed dam site. And some
have raised questions about chemicals
leaking into the river from an old industri-
al site.
"We don't plan to come down to the
legislature ... until we get our permit and
get some of the broader issues taken
care of," said Tom Phillips, an authority
member. "And if we're going to have
this thing completed by the year 2000,
we're going to have to spend more of
the money now."
Current projections show that the
demand for water in Greensboro and
High Point will outstrip the current
supplies by the year 2000.
State legislators from across the Tri-
ad wrangled right up to the final day of
the 1993 session to secure $600,000
for the Randleman project, against con-
siderable opposition from other re-
gions. Altogether the legislature has ap-
propriated about $2 million of what
the authority hopes will be the state's
$7.6 million share of the project.
Now the authority proposes to spend
$12.6 million over the next two years by
raising the money from Greensboro
and its five partners in the regional water
system: High Point, Jamestown, Arch-
dale, Randolph County and Randleman.
The six governments propose to
share 48 million gallons of water a day
from the Randleman Reservoir, which
has been proposed in various forms since
1967.
Newt Colson, an environmental con-
sultant for the project, said that updated
ground-water testing shows that none
of 12 chemicals that is apparently leaking
from the former Seaboard Chemical
Corp. plant would exceed the state's
drinking-water standards in the reser-
voir's water.
But state regulators in agencies gov-
erning water quality and hazardous waste
say they are awaiting the results of
their reports before sharing in that con-
clusion.
And the Deep River Citizens Coali-
tion, which is fighting the project, is
awaiting a ruling by Judge Dexter
Brooks of Wake Superior Court that the
group hopes will stop or delay the
project for failure to adequately answer
environmental concerns.
John Forbis, an authority member
and former mayor of Greensboro, told the
authority yesterday that "this project is
enormously important to the Piedmont
Triad. We're literally going to be dead
in the water without it."
Alan Horton, a Sierra Club member
active in the opponents' efforts, was un-
moved. "There are going to be more
than dead fish in that water if they go
through with that project because their
own studies show that, during drought
conditions, sewage and industrial dis-
charges from High Point will make up 97
percent of the flow from the Deep Riv-
er," he said after the meeting.
Arnold Koonce, the chairman of the
authority, said that the lake will be built,
regardless, and the water will be safe.
"There isn't a member on the au-
thority who would be on a board that pro-
duces a cesspool," he said.
from univers
¦ Problems need UNC's
Spangler, system presider
THE ASSOMTED PRESS
North Carolina needs more help from
system if it is going to solve the state's ed
economic-development problems, legisla
Spangler, the president of the UNC syste
Spangler appeared before the Comm
Status of Education at the University of
na, a commission created by the legislate
look at a number of issues involving Ui
"Basically, there are two groups of pi
out of public schools," Spangler said.
tremendous education and they come tt
"And the other group somehow misses
offered there. We don't overlook the goi
do in public schools. We can only work wi
they send us."
But some legislators pointed out that I
tem trains many of the teachers who we
schools, affecting the quality of the ed
students get.
Other legislators questioned the univer
to extend its programs outside the imme
the 16 university campuses, its work *
tional students and limiting course reqt
that students can complete their degrees i
Rep. Martin Nesbitt, D-Buncombe, the
of the commission, also asked if the cor
leges and universities could agree on tour
so that community-college students don't
college credits that they can't transfer.
SPANGLER SAID THAT the legislatur
begin setting standards for specific tour
there is little central control among the 6E
colleges.
"I agree with you, but you must re(
someone somewhere must make that dec
Martin Nesbitt, D-Buncombe, said. "The w
to figure out some way to set standards
community colleges can fix the problem,
problem."
Nesbitt said that students taking college
community colleges should be able to I
credits will transfer to which four-year c
1 ? I You are invited to meet N.C. author,
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Pete C
From: James Ronald (Ron) Linville [[e-mail]. nc.us]
Sent: Tuesday, July 14, 1998 1:24 AM
To: Pete Colwell; Cyndi Bell
Cc: John Dorney
Subject: DOT Meeting this Friday at your location (10:00 AM)
Some Issues: 1. Phenol compounds and WS-IV reclassification, ie. WO
standard concerns. 2. DOT stream and wetland mitigation. Possible
landfill and stormwater scenarios (methods/buffers) for some needed
mitigation credits, if possible (not likely to occur if they can't
get benefit on their mitigation reqmts). 3. DOT and PTRWA
cooperative strategies.
Beth Morton is meeting with Bradley Bennet today in Raleigh. She is
going to suggest that Bradley may want to attend DOT meeting this
Friday to offer his stormwater insights for our consideration.
Would be helpful if we have as much Randleman Lake information
available (generic sites anyway) so DOT can see what PTRWA is
trying to do in vicinity.
I will bring file on leacheate from demolition landfills on upper
Hickory Creek below water park.
Phillip Todd is to bring aerial photo of same area.
Pete, I also looked at EcoScience Inc document. Suggest we keep in
mind minimal release and fish migration in their design criteria.
They indicated that creeks could dry up between fixtures during
low flow. Not good for protecting existing uses. Also we
should consider preservation of some alternate sites as insurance in
the event they are unsuccessful in some of their efforts. We need a
larger more detailed map showing all areas they have reviewed.
The narative in this last document did not appear to discuss Hickory
Creek considerations.
See you Friday. You guys must be extremely busy. Have called
several times and nobody is available.
EcoSciece Corporation Inc. (ESC) has been contracted by the Piedmont Triad Regional Water
Authority (Authority) to conduct an investigation of 15 sites which may provide compensatory
mitigation for unavoidable jurisdictional impacts to bottomland hardwood wetlands resulting from
construction of the Randleman Reservoir in Randolph and Guilford Counties. Compensatory
mitigation is typically conducted to restore/create similar wetland types and functions as those
impacted. Potential mitigation sites investigated are located within the vicinity of the proposed
Randleman Reservoir (Figure 1). Site investigations were conducted by ESC personnel on the days
of July 12, 17, 29, and 30 1998 and consisted of field reconnaissance of each site to determine
mitigation potential. Resources utilized in support of the field effort include U.S. Geological Survey
(USGS) topographic mapping, U.S. Fish and Wildlife Service National Wetlands Inventory (NWl)
mapping (Pleasant Garden, Glenola, High Point East, and Randleman 7.5 minute quadrangles),
Natural Resources Conservation Service (formerly Soil Conservation Service) soils information on
Randolph and Guilford Counties, and electronic files provided by the Authority. Sites were
investigated for: stream restoration potential; non-incised streams where control structures could be
positioned to re-hydrate floodplains; relatively flat sites with streams of low to moderate valley and
cross-floodplain slope; and sites which have floodplains that do not currently support jurisdictional
wetlands. Descriptions of each site and its mitigation potential are listed below.
Site I (Sophia Site) is located west of SR 1941 approximately 1 mile east of the Town of Sophia on
an unnamed tributary to Muddy Creek. The Sophia Site encompasses approximately 2,000 linear
feet (ft) of stream channel supporting a floodplain approximately 50 to 250 feet (ft) in width in non-
forested pasture. Within the floodplain, an approximately 5 ft wide, 3 ft deep stream channel is fed
by a smaller tributary and a farm pond. The main stream channel contains 6 inches of water and
supports relatively moderate velocity flows. Pasture land includes areas which support hydrophytic
vegetation; however, soils do not exhibit hydric characteristics. The Sophia Site may offer up to 3
acres for wetland restoration/creation though damming of stream channels and tributaries.
Site 2, 3, and 4 (Bob Branch Site) are located in the southeastern quadrant at the intersection of SR
1944 and SR 1931 on Bob Branch. Bob Branch encompasses approximately 3,500 linear ft of
stream channel within a floodplain that varies in width up to 300 ft. The floodplain supports a mix
of hardwood forest and agricultural fields. The Bob Branch stream channel is approximately 4 ft
deep, 20 ft in width, and contains 6 inches of water with moderate flow velocities. A man-made
irrigation pond has been constructed on Bob Branch adjacent to SR 1944 which has increased the
duration floodwaters remaining on the eastern portion of the site and reduced the mitigation potential
for this area. Wetlands are present within the floodplain behind the man-made pond, and in sloughs
and pockets along the length of the floodplain; however, existing wetland acreage is minimal.
Approximately 5 acres of floodplain may be available at the Bob Branch site through damming of
stream channels.
Site 5 (Holly Ridge Site) is located south of SR 1932, on an unnamed tributary to Muddy Creek,
approximately 1.5 miles east of the Town of Glenola. The Holly Ridge Site encompasses
approximately 1,000 linear ft of stream channel supporting a floodplain 50 to 250 ft in width within
agricultural pasture. The floodplain supports a stream channel approximately 25 ft in width, 7 ft in
depth, with 6 inches to 1 ft of slow moving water. Small pockets of wetland are in the floodplain
P.
in areas where cows have created ruts or small pools; however, the acreage of jurisdictional areas
is minimal. The Holly Ridge site may contain approximately 3-4 acres of floodplain suitable for
wetland restoration/creation through impoundment of stream channels.
Site 6 (Robbins site) is located west of SR 1927, north of SR 1928, on an unnamed tributary to
Muddy Creek, approximately 1.5 mile east of the Town of Glenola. The Robbins Site contains a
floodplain approximately 200 ft in width, with wet slopes in fallow fields. The floodplain is
traversed by a 1 to 3 ft wide, 2 ft deep stream channel which originates at a man made pond and has
1 to 3 in of water with slow flow. Most of this site is currently wetland which makes this site
unattractive for mitigation use.
+Site 7 is located north of SR 1928, west of SR 1922, on Muddy Creek approximately 1 mile
northeast of the Town of Glenola. Site 7 consists of a tributary to Muddy Creek with a floodplain
approximately 150 ft in width; in addition, the mainstem of Muddy Creek is characterize by a
floodplain approximately 150 ft in width triangulated with its adjacent tributary. The tributary
stream channel is roughly 5 ft wide, 3 ft deep, and contains 1 to 3 inches of water with moderate
flow. Most of the tributary floodplain currently supports wetlands in toe-slope areas and in sloughs
across the flat hardwood bottom. Valley slope is moderate to steep in this area, which reduces
mitigation potential. The Muddy Creek channel is approximately 40 ft wide, 7 ft deep, with 1 to 3
ft of slow moving water. Most of the Muddy Creek floodplain consists of elevated stream-side
levees that exhibit little mitigation potential. Due to the presence of existing wetlands, narrow
floodplains, and steep valley slope, mitigation potential is limited at this site.
Site 8 is located adjacent to SR 1919 on Muddy Creek approximately 1 mile north of the Town of
Glenola. Site 8 consists of a tributary to Muddy Creek and a portion of Muddy Creek which has a
disturbed hardwood floodplain approximately 350 to 400 ft in width. The Muddy Creek channel is
approximately 25 ft wide, 5 ft deep, with 1 to 2 ft of slow moving water. The tributary to Muddy
Creek is a linear depression with no defined bed or bank and is contained within a wet flat. Much
of the usable floodplain currently supports wetlands in toe-slope areas, relict oxbows, wet flats, and
sloughs which drain from the tributary. Site 8 exhibits little mitigation potential due to the presence
of jurisdictional wetlands within the floodplain.
--Site 9 is located northeast of the intersection of SR 1517 and Interstate 85, approximately 1.5 miles
southeast of the Town of Archdale. Site 9 consists of a portion of Muddy Creek which supports a
hardwood floodplain approximately 200 ft in width. The Muddy Creek stream channel is
approximately 20 to 25 ft wide, 6 ft deep and has 6 inches to 1 ft of slow moving water. Utility lines
parallel Muddy Creek in the southern floodplain and have create a damming effect of hydrological
inputs to the floodplain. This dam effect has increased residence time of water on up hill side of the
utility lines and increased the wetland acreage in this area. Conversely the down hill side of the
utility line does not receive surface waters and hydrology from small tributaries which could
potentially be use in the restoration/creation of wetlands for the Muddy Creek floodplain.
Construction of Interstate 85 has disturbed the northern floodplain to Muddy Creek. A tributary
crosses under I-85 and enters Muddy Creek from the north; however, culverts and construction from
I-85 have made use of this tributary difficult due to encroachment of the highway into the floodplain.
Use of this tributary for mitigation could subject I-85 to flooding if structures are placed within the
tributary channel for restoration/creation purposes. Adjacent wetlands are present in small pockets
and sloughs across the floodplain as well as in utility line construction depressions; however,
wetland extent is fragmented and consists of very limited acreage. Opportunities for mitigation at
Site 9 are poor due to the utility line to the south and I-85 directly north of the site.
Site 10 is located southwest of the intersection of SR 1608 and 1717 on Muddy Creek in the Town
of Archdale. Site 10 includes a segment of Muddy Creek and a contributing unnamed tributary
located between SR 1603 and SR 1608. The floodplain of Site 10 is approximately 300 ft in width
and supports hardwood forest. The Muddy Creek channel is approximately 15 to 20 ft wide and 5
ft deep containing 6 in to 1 ft of water with moderate flow. The unnamed tributary channel is
approximately 5 ft deep, 3 ft wide, with 3 to 6 in of water. The unnamed tributary channel is rip-rap
lined and directly adjacent to maintained yards. A utility line runs along the south side of Muddy
Creek and impounds water which would normally sheet flow into the floodplain. This dam effect
reduces the potential for mitigation in the Muddy Creek floodplain due to the disruption of
hydrological inputs impounded by the utility line. Mitigation potential is poor on Site 10 due to
residential dwellings immediately adjacent to the tributary and utility line disturbances in the
floodplain adjacent to Muddy Creek.
Site 11 (Archdale Site) is located between SR 1912 and SR 1915 approximately 1-mile east of the
Town of Archdale on an unnamed tributary to Muddy Creek. The Archdale Site encompasses
approximately 2,500 linear ft of stream channel supporting floodplains which vary in width from
approximately 50 to 250 ft. The floodplain is forested in the upper portion of the site with
agricultural fields located in the southern portion. The main tributary to Muddy Creek is 20 to 30
ft wide, 6 ft deep with 6 inches of water exhibiting moderate flow. Several smaller tributaries
provide hydrological inputs to the main creek from surrounding upland slopes. Wetlands are
currently on this site in areas where livestock have compacted the soils, and in areas where
groundwater is expressed at the surface as springs in depressed areas; however, these areas are of
minimal size and should not inhibit mitigation efforts. The northern portion of the Archdale Site is
less than 1000 ft downstream from SR 1912 which could be subject to flooding if water is impounded
on downstream floodplain areas. Approximately 3 to 5 acres of floodplain are potentially available
for wetland mitigation through impoundment of streams on site.
Site 12 "Hockett Dairy Site" is located approximately 1 mile upstream from SRI 938 on an unnamed
tributary to the Deep River. The Hockett Dairy Site encompasses approximately 1,000 linear ft of
stream channel within a 150 ft wide floodplain supporting agricultural fields. The unnamed tributary
channel is approximately 20 ft wide, 4 ft deep and has 6 inches of water with moderate flow. The
unnamed tributary is fed by several smaller tributaries which originate from farm ponds in
agricultural fields south of the main stream. No wetlands are adjacent to the unnamed tributary;
however, the smaller tributaries do not have defined channels and may support narrow adjacent
wetlands which cross the floodplain. Valley slope in the floodplain on the southern side of the
unnamed tributary is moderate and may limit mitigation potential in this portion of the floodplain.
Approximately 2 acres of floodplain on the north side of the unnamed tributary are available as
potential mitigation though damming of streams, and creative use of the smaller tributaries on the
southern side of the unnamed tributary may increase the acreage of useable floodplain to 3-4 acres.
/i
ite 13 is located on an unnamed tributary to Deep Creek due west of US 220 at the Guilford and
Randolph County Line. Site 13 consists of a hardwood bottomland floodplain approximately 100
to 150 ft in width surrounded by wetland seepage slopes. The tributary channel is approximately 20
to 25 ft wide, 6 ft deep, and supports 6 in of water with moderate flow. The tributary floodplain
contains oxbows and slews which receive hydrology from wetland seepage slopes and overbank
flooding. Most of the usable floodplain currently supports jurisdictional wetlands, therefore
mitigation potential is limited.
-?-Site 14 "Reddicks Creek Site" is located southeast of the intersection of SR 1140 and SR 1113 on
Reddicks Creek approximately 1 mile southwest of Kirkman Crossroad. The Reddicks Creek Site
consist of a hardwood floodplain approximately 400 ft in width situated approximately 5,00 ft
downstream from SR 1113. The stream channel of Reddicks Creek is 25 ft wide, 7 ft deep and
supports 1 ft of water with moderate flow. The Reddicks Creek floodplain supports jurisdictional
wetlands across much of the site in pockets and sloughs. Residential dwellings are situated
immediately adjacent to the potential mitigation area with maintained lawns extending into the
floodplain. The Reddicks Creek Site is unattractive for mitigation use due to the presence of
jurisdictional areas within the site, proximity to a state maintained road upstream of the site, and
presence of residential structures within the floodplain.
Site 15 "Lower Commonwealth Site" is located north of the intersection of SR 1990 and SR 1951
approximately 2 miles east of the Town of New Market on an unnamed tributary to The Deep River.
Site 15 is located approximately 5,00 ft downstream from SR 1990. Site 15 encompasses
approximately 2,000 linear ft of stream channel within a floodplain which widens to approximately
180 ft and supports a mixture of hardwood forest and fallow agricultural pasture. Within the
floodplain the unnamed tributary channel is 10 to 15 ft wide, 5 ft deep, with roughly 6 inches of slow
flowing water. A linear depression enters the unnamed tributary from the south and supports
jurisdictional wetlands along its length. Mitigation potential is limited with this site due to
jurisdictional areas present in this depression and the proximity of the site to SR 1990 which could
be subject to flooding if water is impounded on downstream floodplain areas. However, should all
other alternatives be exhausted, Site15 may contain 1-2 acres of usable floodplain for wetland
mitigation.
Of the 15 sites investigated for additional mitigation consideration, 7 sites exhibit opportunities for
obtaining mitigation credit. The Sophia Site, Bob Branch Site (include 3 sites), Holly Ridge Site,
Archdale Site, and Hockett Dairy Site potentially offer up to 18 acres of floodplain which may be
suitable for mitigation through impoundment of streams. Additionally, Site 15 "Lower
Commonwealth Site" may contain 1-2 acres of usable floodplain should all other alternatives be
exhausted. Site 15 "Lower Commonwealth Site" may have some difficulties for use as a potential
mitigation site due to its proximity to a state maintained road and existing wetlands; however, some
usable floodplain may exist. This investigation determined that 7 sites should be discounted due to
difficulties associated with steep valley slope, narrow floodplains, existing jurisdictional wetlands,
and proximity of adjacent roads, utility lines, or other structures.
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Pete C
From: James Ronald (Pon) Linville [e-mail]]
Sent: Thursday, Octot r 01, 1998 4:40 AM
To: Pete Colwell
Cc: TS19W400MR. 4; N 1 ED706 @ N ROAR04
Subject: PTRWA Mitigation plan
Just started looking at their mitigation document. Whoever did the
work for them appears to be familiar with Rosgen's work and
methodology. So, restoration via bioengineering and geomorphology
can likely be discussed with some clarity and understanding.
RECOMMEND THAT WHEN THEY DO DESIGNS THAT WHERE
POSSIBLE STREAM ELEVATIONS BE RAISED VIA RESTORATION
OF STREAMS TO NATURAL GRADES, CONTOURS AND CONDITIONS INSTEAD
OF DEPENDING ON WEIR STRUCTURES ENTIRELY. THIS WILL
PROVIDE WETTER WETLANDS OVER A LONGER PERIOD OF TIME
AND IMPROVE WETNESS DURATION THROUGHOUT THE RESTORED
WETLANDS AREAS. THERE WILL BE LESS BANK DEPTH TO
"DRAWDOWN" SUBSURFACE WATERS. LET'S TALK ABOUT THIS WITH THEM WHEN
WE HAVE OUR MEETING. THAT ASSUMES WE WILL SIT DOWN AND TALK TO
THEM ABOUT THE SUBMITTAL. IT WILL BE MUCH BETTER THAN JUST WEIRS
WHICH WILL ALLOW FASTER DRYING DURING DRY PERIODS OF THE YEAR. IT
MAY ALSO ALIEVE SOME OF THE ENTRENCHMENT DEPTH PROBLEMS ASSOCIATED
WITH THE PROPOSED WETLAND RESTORATION.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
August 13, 1997
TO: Interested DWQ Staff -
AdMINE911111111111MOM AN
ED EHNR
Larry Coble Ron Linnville
Coleen Sullins Larry Ausley
Jay Sauber Kurt Trumbower
Alan Clark Steve Zoufaly
Lisa Martin Jason Doll
FROM: Michelle Suverkrubbe
SUBJECT: Draft Randleman History
Attached for your information is a Draft History of the Randleman Lake Project as it
relates to water quality. As you recall, this task was given to me by Greg Thorpe at the
conclusion of our meeting on July 7 that dealt with the High Point WWTP Expansion EA.
The goal was to chronicle all the pertinent conclusions made on water quality for this
project since it was first conceived of by the federal government in 1968.
I hope you find it useful in your review of the Randleman EIS and the Eastside
WWTP EA. Due to length, I have not included the Appendices referenced in the
document. If you need the appendices, please let me know and I will make you copies (of
all or just the pertinent ones you need).
As you use this report, please let me know of any corrections or additions needed.
As it stands now, DWQ has not yet developed an opinion on these projects or how to
proceed. I will send you copies of all our comments once they are finalized. Since
comments on the Randleman EIS are due August 29, I am sure we will be coming up with
something very soon.
My number is [phone], ext. 567 if you have any questions.
Enclosed Randleman Lake Project - Water Quality History
cc: Owen Anderson, NC WRC
Lee Spencer, DEH - Public Water
Wayne Munden, DEH - Water Supply
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
DRAF T
Randleman Water Quality History
Table of Contents
PaEe
1. Preimpoundment Studies - Randleman Project ...............................................1
Water Quality Characteristics, UNC Wastewater Research
Center, School of Public Health, Chapel Hill; February, 1973
2. USEPA Letter to US Army Corn of Engineers .............................................3
Wi min on Office. on Water Quality in Randleman Lake
USEPA, Region IV, Jack Ravan, February 13, 1975
3. Assessment of the Social- Economic. and Environmental ..................................3
Effects of the Randleman Lake Projecttc , Research Triangle Institute
June, 1975.
4. Draft Env ron_mental Statement. Randleman Lake ............................................4
US Army Corps of Engineers, Wilmington District, October, 1976
5. Final Environmental Statement Randleman Lake ............................................5
US Army Corps of Engineers, Wilmington District, September, 1980
6. e 162A-7 & 153A-285 Review Document and ..........................................6
Environmental Impact Statement. Randleman Lake
Piedmont Triad Regional Water Authority (PTRWA),
Division of Water Resources, January, 1990
7. Memorandum from Trevor Clements to Melba McGee ......................................9
on Draft Randleman EIS, October, 1990
8. G 162A-7 & 153A-285 Review Document and ..........................................9
Final Environmental Impact Statement Randleman Lake
Division of Water Resources, October, 1991
Appendix C of FEIS - Water Quality and Quantity Studies s ............................... 10
to Support Randleman Lake Environmental Impact Statement
Black and Veatch, 12/1/90
Appendix D of FEIS - Final PTRWA Water Supply Alternatives ........................ 11
Assessment 9/91
9. Record of Decision - Final Environmental Impact Statement ............................ 12
for Randleman Lake, DWR & DEHNR, Approved by EMC 12/12/91
10.
............................ 13
Signed on 2/22/92
Document DRAFT Page
11. Letter to Army CoWs of Engineers from US EPA on .................................... 13
Randleman Lake FEIS by Heinz Mueller, May 22, 1992.
12. Letter to DWR from DEM on Low DO Study of Carbonton Dam ....................... 13
October 16, 1992
13.
14.
September,
................................. 14
l 1y au.1J ui ulV vvwa aiw? au.v. •...... ...........
Environmental Sciences Branch, DEM
.14
15. Brief of the Respondents - Appellants - NC Court of_A e s :.......................... 14
Deep River Citizens Coalition v DEHNR EMC and PTRWA
AG's Office (Dan Oakley), Nov. 14, 1994
16. Memo to Monica Swihart on Effect of Proposed Randleman Dam ...................... 15
on Reservoir Water Quality, Betsy Johnson, TSB, January 25, 1995
17. Memo to Linda Rimer on Randleman Darn Water Quality Issues ........................ 15
Preston Howard and Steve Tedder, Feb. 3, 1995
18. Water Quality and Predictive Modeling Studies on the Proposed ........................ 15
Randleman Reservoir. High Point. North Carolina,
Patrick L. Brezonik, University of Minnesota, Minneapolis hired by
PTRWA, March 1995
19
Judge Greene, June 6, 1995
.................. 16
20. Cape Fear River Basinwide Water Quality Management Plan, DWQ .................... 16
Approved by EMC on October 12, 1995
21. Memo to Mr. Kime (PTRWA) on 401 Certification for Randleman ..................... 16
DWQ, January 24, 1997
22. Low Flow Characteristics and Profiles for the Deep River Basin ........................ 16
in h =.N Fear River Basin. North Carolina, by Curtis Weaver,
US Geological Survey (in cooperation with DWQ and DWR), May, 1997
23. Watershed Protection Information for Randleman Lake Watershed ..................... 17
Lisa Martin, DWQ, July 22, 1997.
Judge Dexter Brooks, May 12, 1994
Randleman WQ History
Page 1
Overview
rrent Randleman Lake EIS (by
u
This study was completed to assist Division staff in re viewinDRAFT
the Corps for the 404 Permit) and the High Point Eastside WWTP Expansion EA. This History
should assist staff in understanding the numerous reports and memorandums regarding existing
and future projected water quality that have been completed to date on the proposed Randleman
Lake Project. No comments on these two current projects are included in this History.
Specifically, this summary and analysis provides an historical account of all previously approved
water quality studies, reports, conclusions, hearings, findings, and letters found relating to the
proposed project in DWQ and DEHNR's files to date. Every effort was made to find known
documents, however, some other historical reports may exist that are unknown to the author.
This study attempts to go beyond a mere repeating of reports; it attempts to summarize each
document in a historical context, with special emphasis provided on those issues DWQ is
especially concerned with today - eutrophication, toxics, aquatic resources and discussion of
immediate and long-tern point and non-point source water quality impacts. The importance of
each document is listed, and when necessary, copies of specific pages of text are provided in
Appendices. Some studies are very technical and lengthy, and for these reports only the main
summaries are provided here. Each document listed has information on where it can be found
(with call numbers for all library documents) to assist staff in locating it for further review.
This study is compiled in a chronological order, with the oldest documents of record listed first,
and the most recent items listed last. Every attempt was made to locate all known documents. This
chronology may be amended, however, if additional items are found to exist.
Document Listing
1. Ti - "Preimpoundment Studies - Randleman Project,
Water Quality Characteristics"
Authors - Charles M. Weiss, Donald E. Francisco and David R. Lenat
Agency - Department of Environmental Sciences and Engineering, UNC Wastewater Research
Center, School of Public Health, Chapel Hill
Data - February, 1973
Prepared under contract with - Corps of Engineers, Wilmington District
Location of Document - DEHNR Library, 7th Floor, Archdale Bldg., (call # G36.9, 403:327,
880701)
Purpose of Document - To perform detailed water quality analysis (during high flow (spring) and
low flow (summer) conditions) of the proposed Randleman Lake impoundment and reservoir site
for use by the Corps in the first EIS on this project. Specifically, this study evaluated 9 sampling
sites along the Deep River and several streams draining to the Deep (to capture point sources and
characterize subbasins). This study sampled physical, chemical and biological (macroinvertibrate
benthos) water quality parameters in the proposed lake area, and also included analysis and
interpretation of the results.
Importance of Document - First detailed water quality sampling / study done for this project.
Prepared almost 25 years ago. First conclusions made in the record regarding potential water
quality in the proposed lake. Forms basis of WQ section of the first EIS on the project (by the
Corps), which is incorporated by reference in the DWR DEIS document prepared for project.
Project Area - The proposed Lake and earthen dam for the project were proposed as: surface area
of 2,400 acres, reservoir length of 13 miles, dam located on the Deep River 2 miles upstream of
the Town of Randleman, and the northern reach on the Deep River extending approximately 1 mile
north of I-85.
DRAFT Randleman WQ History
Page 2
Phu poses of Project - 1) flood control, 2) recreation, 3) future water supply
a. The High Point Sewage Treatment Plant accounted for 25-35% of BOD in Spring
sampling, but rose to 50-85% during late summer.
b. BOD from "other sources and general runoff established that a naturally high level of
oxygen-consuming materials are introduced regularly into the drainage and waters of the
Upper Deep River. Although the oxygen resources of the stream were sufficient to meet
the spring BOD demand, those of the summer were insufficient."
C. "Control of both identifiable and nonidentifiable BOD discharges may be a prime
consideration in developing a control strategy for maintaining water quality at the highest
level in the proposed impoundment."
d. Total nitrogen had its major source the High Point Treatment Plant on Richland Creek.
"Non-controllable runoff, however, appeared to also contribute significant amounts of
nitrogen to the system." However, "nitrogen cannot be a limiting nutrient for growth of
algae in the reservoir."
e. "Me introduction of phosphorus seems to be principally the contribution of the HP
Treatment Plant." If 90% of phosphorus was removed from HP's plant, the instream
concentration would be about 0.3 mg/1. "This is a compatible concentration for impounded
waters, since sedimentation processes in the standing water of the lake would also
contribute to removal and reduction of residual phosphorus concentrations to a point
environmentally acceptable."
f. Except for just below the point of waste treatment effluent discharge from HP's plant,
microbial indicators of recent fecal coliform contamination do not persist south of Hwy.
62. Variability in quality due to fecal coliform was found on the Deep River, above the
confluence with Richland Creek, possibly due to "intermittent discharge from nearby
industries or storm water runoff."
g. All metals for high and low flow conditions were within acceptable limits (for the time) for
both drinking water and aquatic health. One exception was lead, which, from the pattern of
distribution centered on the HP plant and runoff from the I-85 overpass.
h. Along major river segments, all major aquatic benthic groups were present, but were
limited to species capable of handling low DO. The station below High Point Lake showed
low oxygen demanding materials present but showed a benthic population indicative of low
DO, presumably due to the discharge of low DO water from the hypolimnion of the Lake.
The benthic populations at SR 1113 (above Richland Creek) were limited by organic
enrichment and toxics (from undisclosed sources). Most of the natural recovery and
purifying of the water quality in the river occurs between SR 1939 and US 220. "These
purifying elements would, of course, be eliminated on impounding the river."
i. Muddy Creek and Hickory Creek have a high diversity of organisms, indicative of high
water quality. A higher proportion of filter feeders was found on these creeks, indicating a
greater amount of runoff, probably from agricultural drainage.
j. "Existing contributions of pollutional materials from both point and non-point sources and
general surface drainage into the tributary streams of Deep River and the main stream itself
indicate a body of water currently heavily polluted by established standards. It exhibits,
however, rapid recovery in its downstream flow through the capacity for self-purification
characteristic of running waters. By increasing levels of effective sewage treatment at the
High Point plant on Richland Creek and curbing other point sources of discharge along the
upper Deep River between High Point Dam and Interstate 95, a good improvement in water
quality could be expected with quality levels well within limits set for acceptable water
supply. Complete bypassing of the High Point plant discharge around the proposed lake,
plus improved treatment to prevent further downstream effects, would result in a highly
acceptable body of water for all proposed uses. There are no indicated economically
DRAFT Randleman WQ History
Page 3
unresolvable pollution control problems as currently determined within the Randleman
impoundment project area."
k. The study further admits that "prediction of qualities that will be found in any specific
impoundment can only be estimated to a limited degree of accuracy" and "no attempt will be
made to arrive at a precise statement as to what might be expected in the nature of the
impounded water, except where the introduction of existing substances both of a
conservative and nonconservative nature might give rise to quality characteristics that
would be undesirable for the ultimate uses of the impoundment."
2. - "USEPA Letter to US Army Corps of Engineers, Wilmington Office,
on Water Quality in Randleman Lake"
Author - USEPA, Region IV, Jack Ravan
D= - February 13, 1975
Location of Document - DWQ Files [copied from appendices of ACOE DEIS (item #4)]
Summary of Conclusions - EPA examined the level of treatment necessary to "maintain water
quality for each of the proposed alternatives" (in the DEIS). The report was prepared in order to
determine the necessary levels of treatment (effluent limitations) required for each discharger
draining to the lake to determine allowable pollutant loadings to the proposed Randleman Lake. "It
is our conclusion that the Randleman Lake project could be constructed provided that the effluents
from the communities of Jamestown and High Point are either by-passed around the reservoir or
given land treatment." "'T'hese conclusions are based primarily on the nutrient contributions and
potential eutrophication in the lake." Copy of full study is attached as Appendix A.
3. 1& - "Assessment of the Social, Economic, and Environmental Effects of
the Randleman Lake Project, Final Report 43U-998, Volumes I-III"
Author - Research Triangle Institute, RTP
Dom, - June, 1975.
Prepared under contract with - Corps of Engineers, Wilmington District.
Location of Document - DEHNR Library, 7th Floor, Archdale Bldg., (call # D, 103.2:A7, v. 1-3)
impose of Document - The basic study objectives of the study were to: a) determine existing
social, economic and environmental conditions of the project area and the areas that will be affected
by the proposed lake; b) determine the most probable future of these areas without any federal
water resource development; c) assess the social, economic and environmental impacts of the
alternate water resource development plans on the most probable future conditions in the planning
area; and d) identify the significant effects of all alternatives and recommend mitigation or
elimination of the adverse effects. Nine construction alternatives were investigated. Another
proposed lake at Howard's Mill was also investigated in this study. It is not clear why this study
exists, except in reference to the Flood Control Act of 1968 (Public Law 90-483) which authorized
both Randleman and Howard's Mill for construction using federal funds. This study was written
to comply with the River and Harbor Flood Control Act of 1970 and the National Environmental
Policy Act of 1969. Volume I is the main text, Vol. II is the supporting data (including some water
quality information) and Vol. III is a household survey conducted to measure popular opinions on
the proposed lake. This document appears to be a data gathering tool f6r the Corps.
Importance of Document - Forms basis of Corps DEIS on project; is an appendix to the DEIS from
the Corps (see item #4).
Project Area - The nine alternatives discussed in the document addressed both Randleman and
Howard's Mill projects. For Randleman Lake, the nine alternatives consisted of the no project
alternative and eight others that included a conservation pool that ranged from 603 to 3,424 acres
and associated flood control and recreation lands that totaled between 3,606 and 7,784 acres.
Pu rposes of Project - 1) flood control, 2) recreation, 3) future water supply
Randleman WQ History
Page 4
Su_mmarv of Conclusions - DRAFT
a. The construction of a multi-purpose project at Randleman only (not at Howard's Mill)
would be "the most acceptable alternative. However, it will be necessary to bypass the
effluents from the High Point Eastside and Jamestown Water Pollution Control Plants to a
point on the Deep River downstream from the damsite. Stringent effluent limitations by the
State of North Carolina will insure that the bypassed effluent does not degrade downstream
water quality. With the bypass, the quality of Randleman Lake will be acceptable for water
supply, water quality, and recreational standpoints."
b. Summary impacts of the project: "Nutrient loading in the impoundment is likely to promote
eutrophication unless an effluent bypass is constructed."
C. See copies of pertinent sections of the report in Appendix B of this study.
4. Zk - "Draft Environmental Statement, Randleman Lake, Deep River,
North Carolina"
Author - US Army Corps of Engineers, Wilmington District
D= - October, 1976
Location of Document - State Archives; Clearinghouse Item #109-76.
P g ose of Document - To comply with NEPA as an EIS on the federal funding of dam
construction, relocation of population, and acquiring properties for flooding and associated
recreation activities.
Importance of Document - Two volumes to Draft - Main Text (DEIS) and three bound parts that
make up the Appendices to the DEIS (referred to as the "General Design Memorandum"). Portions
(mostly conclusions) of items #1 and 2 are included in the General Design Memorandum (appendix
to the DEIS).
Project Description - The proposed project is the construction and operation of a 3,045 acre
conservation pool reservoir with 105,000 acre-feet of gross storage and acquisition of 7,075 acres
of recreation/ buffer area surrounding the reservoir (total project area is 10,400 acres). The
proposed lake would have a 169 square mile drainage area. Proposed 50,000 acre-feet of water
supply storage with a yield of 48 mgd. Minimum release from proposed dam alone was 7 cfs.
Combined with discharge from High Point and Jamestown (with a 36" line) below the dam,
combined release below dam was estimated at 20 cfs. The project would entail construction of an
earthen dam, spillway and multi-level outlet structure, and relocation of roads, utilities, residents,
farms and homes.
Poses of Project - 1) flood control, 2) recreation, 3) future water supply; Benefits of project
included water supply, recreational lands and fisheries.
Summary of Conclusions -
a. The proposed lake is "so located that, without control, treated wastes from the City of High
Point would be discharged into an upper arm of the reservoir. The US EPA and RTI have
advised that consideration should be given to measures for safeguarding the quality of
water in the reservoir..." "The controlling factor for reservoir water quality will be the
nutrient loading from the High Point and Jamestown treatment plants that, if it were
allowed to discharge into the lake, would increase the rate of eutrophication of the lake to
the point where water quality could be below standards for intended uses" (i.e. water
supply and fisheries). DEIS considered three methods to prevent nutrient loading - 1)
advanced treatment at HP and Jamestown plants, 2) land treatment, and 3) bypass. Initial
30 mgd bypass was chosen due to least cost and most feasible method for safeguarding
water quality in proposed lake. It was stated that if state of the art treatment processes were
developed, the bypass may not be needed in the future.
DRAFT Randleman WQ History
Page 5
Nutrient loading in the impoundment is likely to promote eutrophication unless an effluent
bypass is constructed.
b. "Project would entail loss of 39 miles of stream ecosystems."
C. "Basin soils and urban runoff will influence the reservoir's water quality."
d. "After a few years, nutrient input from the Deep River and tributaries will dominate
reservoir energy sources."
e. "Nutrients from basin soils and from tributaries of the Deep River will probably produce a
moderately eutrophic reservoir."
f. "The degree of eutrophy will probably change as one progresses from the upstream
shallow areas of the reservoir to the deeper water near the damsite and be more oligotrophic
near the damsite."
g. "Nutrients, particulate matter, and plankton biomass will be passed downstream from the
lake and tend to lower the eutrophic conditions of the reservoir."
h. "Tbe potential high rate of eutrophication will be decreased to a great extent by the
installation of the planned sewer by-pass system."
i. "The state of eutrophy predicted for Randleman Lake will not interfere with any proposed
project purposes."
j. See copies of pertinent sections of the report in Appendix C of this study.
5. 1& - "Final Environmental Statement, Randleman Lake, Deep River,
North Carolina"
Author - US Army Corps of Engineers, Wilmington District
D= - September, 1980.
Location of Document - DEHNR Library, 7th Floor, Archdale Bldg., (call # D, 103.62:R3)
Dose of Document - Final EIS (Draft EIS is item #4).
Importance of Document - This is the document referred to in the DWR EIS (see #6) as having
adequately addressed many environmental impacts of the Lake project, including water quality.
This final EIS contains comments made and responses to the Draft (see #4). This Final does not
include the appendices (General Design Memorandum) from the Draft.
Project Area - see Draft EIS (#4)
Purposes of Project - see Draft EIS (#4)
Summary of Conclusions -
a. Same as for DEIS (see #4)
b. Comments and responses to DEIS by agencies -
Both High Point and DEM were concerned with the cost of the sewer by-pass not
being included in the DEIS, but it was added in the FEIS as part of the cost of the
project. The FEIS states that the purpose of the by-pass is to prevent adverse water
quality impacts of the project, but the Corps alludes to future state of the art sewage
treatment technologies that would "allow effluent directly or indirectly into the lake,
doubling the water supply yield from the lake with no increase in water supply
cost."
OMM6
DRAF, T Randleman WQ History
Page 6
* NC DOA had submitted comments (including DEM's) to the Corps on the DEIS.
DOS memo indicated that the state "had no objections to the project". DEM's
primary concerns and the Corps responses were -
1) DEM- other alternative water supplies could have been discussed; Corps -other
alternatives probably do exist, but only ones deemed most likely to occur were
discussed.
2) DEM- some small point sources were not discussed in the DEIS; Corps - those
small discharges make up less than 3% of effluent discharged into lake, therefore,
allowing them to remain (and not be re-routed through the bypass) was OK.
3) DEM- a portion of drainage basin for lake is experiencing high urban
development, and unless development is controlled, new growth will generate more
wastewater within a shorter time period than anticipated; Corps - agree that I-85
construction will foster growth and additional wastewaters. "Development ....in the
Randleman Lake drainage area and generation of wastewaters is to be controlled by
the State of North Carolina...".
4) DEM- urban stormwater runoff from the projected growth in the area would
"create significant problems for the proposed lake"; Corps - agrees that "increasing
urban stormwater runoff due to growth in the lake drainage area could create water
quality degradation in the lake. With the advent of 208 planning (?) in the area
though, we anticipate that, where feasible, measures to control urban stormwater
runoff will be implemented. It should be noted that measures to control urban
stormwater runoff to prevent surface water quality degradation would have to be
implemented regardless of whether Randleman Lake is built."
5) DEM - "Although the future water quality of no reservoir is guaranteed, the
location of the Randleman reservoir in an urban area increases the chances of future
water quality problems. The chances of maintaining a satisfactory water quality in
the lake are increased with the installation of the sewer bypass. Although not fully
covered in the text, we believe the danger from surface runoff has been adequately
discussed in previous reports and that the likelihood of widespread intense
eutrophication is minimal." Corps - noted.
C. See copies of pertinent sections of the report in Appendix D of this study.
6. Tl>Z? - "G.S. 162A-7 & 153A-285 Review Document and Environmental
Impact Statement, Randleman Lake" (DWR's DEIS)
Author - Piedmont Triad Regional Water Authority (PTRWA)
Agency - Division of Water Resources
D= - January, 1990
Location of Document - DWQ's Randleman Lake files
Purpose of Document - PTRWA has taken over project from ACOE (ACOE withdrew from
project in 1987 because changes in federal funding made the project ineligible for federal funding).
This EIS was prepared as part of PTRWA petition to EMC for an eminent domain certificate (for
the acquisition of land and water rights) and also for an interbasin transfer certificate.
Importance of Document - This "DWR EIS" incorporated the previous Corps EIS into the
document. However, this DEIS was completely rewritten before becoming Final, and in the final
references to these previous documents is very limited (see #8).
project - The towns of Jamestown and Randleman, and the cities of Archdale, High Point and
Greensboro and the county of Randolph (which make up PTRWA) have jointly agreed to construct
a raw water intake, pumping station and new water treatment plant on the west side of Randleman
Lake on Muddy Creek, approximately 1.5 miles above the proposed dam location. PTRWA, in
addition to Greensboro and Guilford County, would be supplied with treated water from the
V=hk
URAFT Randleman WQ History
Page 7
project. The proposed project is the construction and operation of a 6,000 acre water supply
reservoir with a maximum safe yield of 48 mgd using the same dam location and same
conservation pool area (of 3,045 acres), and elevation of 682' MSL as the Corps' project. Total
project elevation has been lowered from 694 feet to 682 feet, which shortens the length of the
reservoir substantially from the Corps' proposal. The 7,075 acres of recreation/ buffer area
surrounding the proposed Corps' reservoir has been reduced to 3,000 acres (i.e. a 200-foot buffer
strip). The proposed lake would have the same 169 square mile drainage area as the Corps project.
Total project area for the PTRWA reservoir is therefore 6,000 acres.
The project would entail construction of an earthen fill dam, concrete spillway, clearing and
grubbing of vegetation in the conservation pool, relocation of roads, utilities, households and
people, and construction of a water treatment plant and distribution lines to serve member
governments. The flood control and recreational aspects of the Corps' project were eliminated.
PTRWA proposed staged release from dam (at 30 cfs initially). Would be dropped to 20 cfs when
reservoir drops below 60°x6, and 10 cfs when below 30%. This was to be confirmed by DWR
modeling to determine the effect on the 48 mgd.
Four alternatives for handling High Point WWTP's 16 mgd average daily flow of effluent were
evaluated by their costs (but not their environmental impacts) - 3 bypass alignments and one
proposal to upgrade the WWTP for "advanced treatment that includes phosphorus removal".
Because the upgrade of High Point's WWTP ranked substantially lower than the other three
options in total worth cost, it was chosen for this project as the preferred alternative. See
attachment D for a copy of this analysis.
Pose of Project - water supply mainly, flood control under certain conditions and potential for
recreation
Summary of Conclusions -
a. Project impacts included -
1) permanent inundation of 3,045 acres of terrestrial environment
2) inundation of 23 miles of stream and 16 miles of tributary ecosystem
3) positive impact on the Deep River water quality and will cause positive low flow
augmentation effects to occur downstream of the reservoir.
b. "PTRWA proposes the upgrade of the HP Eastside WWTP as the preferred alternative in
conjunction with the location of the intake structure on the Muddy Creek arm of the lake.
This water plant location removes any potential problems associated with the I-85 crossing
of the Deep River arm, the greater potential risk due to spills, and is not located on the more
urbanized section of the lake which would tend to have greater sources of non-point
pollution. Precedent in this approach is found in the location of the intake structure for the
Cary-Apex water plant on Lake Jordan. Similar modeling studies predict the movement of
water in the two arms of the lake will be performed before the actual treatment plant site is
selected."
C. "Both Randolph and Guilford Counties have taken measures to protect the water quality of
the future Randleman Lake by adopting watershed ordinances..." "...PTRWA will also be
purchasing approximately 2,075 acres of protective (200-foot) buffer in Randolph
County". "With the limited and rural state of development in the county, these measures
should protect the lake to the highest extent possible. They also illustrate the local
commitment to the quality of water in the proposed lake."
d. The High Point Landfill is adjacent to the Deep River at the headwaters to the Lake and has
raised concerns about the potential contamination of the lake due to leachate. Three
L 9L
10 U
ijRAFT Randleman WQ History
Page 8
groundwater wells maintained by HP and surface water samples from the landfill "indicate
that no significant leaching is occurring from the municipal landfill." At a normal
conservation pool, no surface inundation will occur. Even though probability of surface
inundation is small, structural measures "will be considered" to alleviate or minimize
inundation.
e. From an original list of 40 water supply alternatives, nine alternatives were chosen for
detailed study (in an attached Water Supply Alternatives Assessment, dated 1985). This
study stated that "the Randleman Lake alternative proposed by the Corps of Engineers (see
#5) is the most appropriate water supply alternative."
A final evaluation of water supply and water quality alternatives was produced as part of
the Final EIS in December, 1990 and September, 1991 (see #7)
f. The proposed release from the Randleman Lake "will improve stream flows during low
flow augmentation periods, as well as provide from improved water quality due to dilution
effect on the High Point discharge and therefore should not have a detrimental affect on the
Gulf/Goldston (?) operation. The proposed multi-level outlet structure will allow for the
monitoring of temperature, DO content, and chemical composition of the water at various
levels within the lake. When leaving the dam, water from these various levels is mixed to
produce a discharge best suited to downstream needs. The benefit of this regulated
discharge of 20 or 30 cfs becomes more apparent in times of drought when stream flows as
low as 1 cfs have been recorded."
"Preliminary analysis by DWR indicates that the reservoir will affect... hydropower
operations (on the Deep River) because the duration of flows within the operating ranges
will be reduced. These reductions vary from 5 to 14 percent for a 20 cfs minimum flow
release and from 5 to 13 percent for a 30 cfs minimum flow release."
g. "The impact of Randleman Lake on high flows in the Deep River is unknown at this time,
because the design and operating policies of the lake have not been finalized."
h. "Fishing below the dam also will be enhanced by the increased flow during low flow
periods brought about by the release from the dam, as well as the improved water quality
brought about by the dilution of the HP Eastside discharge."
"Indications are that water quality in the Deep River has shown continued improvement
since the upgrade of the High Point Plant and the elimination of the Jamestown discharge."
"Point and Non-Point source pollutants would be diluted by the lake waters and would tend
to settle out in the upper reaches of the lake." See appendix E for copies of the WQ
discussion from the DEIS. This section of the DEIS references a DEM study entitled
"Chemical and Biological Monitoring of the Deep River 1983-1987". The Executive
Summary of this study can be found in appendix E.
"From the beginning of the project, it has been anticipated that the likelihood of widespread
intense eutrophication would be minimal according to the previous State review of the
federal project, which is outlined in the August 18, 1976 memo from W. E. Knight..."
"Since that time, the Clean Water Act has been reauthorized and the resulting regulatory
activity on behalf of the state should adequately protect the proposed lake. The elimination
of the bypass by the PTRWA anticipates that nutrient removal will be required. Measured
concentrations of phosphorus probably have little impact on a free-flowing system, but
would have some impact on impounded waters. The discharge from the High Point
Eastside wastewater treatment plant would be subject to the nitrogen and phosphorous
MEOW
Do aAFT Randleman WQ History
Page 9
limits set by DEM. It is anticipated that the limit for phosphorous will be 0.1 to 0.5 mg/1
and the limit for nitrogen to be 1-6 mg/l."
k. The DEIS indicates that the existing watershed protection ordinances in Guilford and
Randolph Counties will control stormwater from impervious surfaces and minimize NPS
pollution. "Additionally, the local governments in the more urbanized headwaters of the
watershed (Greensboro, High Point, Guilford County) have adopted more stringent
sedimentation control ordinances which limit development in the area." Also, the proposed
200 foot buffer around the lake perimeter will "prevent large loads of sediments and
nutrients from further degrading the Deep River."
k. Comments made by Trevor Clements (DEM) on the DEIS are contained in Appendix E of
this study. These concerns were serious and touched on many of the same issues we have
today with the project. This letter (and therefore responses to it) are not included in the
FEIS, but are referenced in Appendix C to the FEIS.
1. A list of further actions required by the project applicant are contained in Appendix E of this
study.
7. Tlt - "Memorandum from Trevor Clements to Melba McGee on Draft
Randleman EIS"
12= - October, 1990.
Location of Document - DWQ's Randleman File
Purpose of Document - Follow-up to previous comments on DEIS. He must have been reviewing
a draft of the Water Quality Study referenced in #8.
Comments - 1) WQ Model results in Black and Veatch's study for Randleman Lake only describe
potential impacts in the location of the proposed intake. It should summarize impacts predicted
elsewhere in the lake. 2) The table comparing Randleman with other piedmont reservoirs should
provide source of this information and criteria on which these data are based. 3) Flow duration
curves not consistent with graphs in the document. "I do not understand how substantial losses
below the dam caused by creation of the lake can be made up downstream such that flows with the
project will exceed flows without the project at Ramseur and Carbonton ... It appears that the post
project profile should begin at 10 cfs rather than 34 cfs to reflect minimum release... As currently
written, therefore, I do not believe the conclusions drawn from the graphs at Ramseur and
Carbonton." "The statements about 'Randleman providing low flow augmentation' and
'increasing flows in the Deep River during low flow periods' are misleading and should be
stricken from the report... These issues should be brought to the attention of the EMC prior to
making final ruling on the project." As mentioned previously, DEM has concerns regarding water
quality impacts, particularly for dissolved oxygen standard violations and corresponding
implications on assimilative capacity for downstream users such as Ramseur, Robbins, Sanford
and Golden Poultry." See full letter in Appendix F.
8. Tltltti - "G.S. 162A-7 & 153A-285 Review Document and Final
Environmental Impact Statement, Randleman Lake" (DWR's FEIS)
Author - Division of Water Resources
D= - October, 1991
Locations of DocumenIS - FEIS - DEHNR's Randleman Lake files, SCH# 92-0276; Appendices
C & D - DEHNR Library (Call # NC, 23:R36/A)
Pumose of Document - Final EIS
Importance of Document - This Final EIS was completely rewritten by DWR from what had been
done for the DEIS. This Final document addresses 3 other reservoir alternatives that were not
Randleman WQ History
Page 10
discussed in detail in the DEI M"a ' ake, naja e/ Polecat Creek Lake, and Upper
Deep River Lake)
Project Description- See #6
Phu -pose of Project - See #6
Summary of Conclusions - Most of the conclusions made during the DEIS remain unchanged.
a. "Besides being the most cost-effective way of handling the wastewater (from HP WWTP),
the direct discharge (to the upper end of the lake) is not expected to significantly increase
the level of eutrophication in Randleman Lake."
b. Altamahaw Lake and Benaja Lake/ Polecat Creek Lake alternatives were deemed unfeasible
due to a state law that requires Rockingham County Commissioner's approval on a
reservoir in their county (which was determined unlikely, since Rockingham would receive
no benefit from this reservoir). And, the Upper Deep River Lake alternative would require
flooding of the High Point Eastside WWTP, HP Landfill and Seaboard Chemical Site.
C. Modeling studies were completed by Black and Veatch to predict water quality in the Lake.
The studies concluded that "the raw water will meet all toxics standards for finished
drinking water if normal losses of pollution from sedimentation are included. The model
also predicted that nutrient inflow to the lake will cause summer algae blooms on the part of
the Deep River arm that will exceed State standards. This condition is not predicted to
interfere with the suitability of the lake for fishing, boating and swimming."
d. The Lake, with a multi-level outlet structure, should "improve the quality of water in the
Deep River downstream of the project. Pollutant concentrations will decrease, as natural
chemical and physical processes, such as partitioning with sediment, hydrolysis, and
volatilization, occur in the lake."
Author - Black and Veatch
Importance - These appendices are PTRWA's attempt to address (through the consulting firm of
Black and Veatch) the comments made by Trevor Clements (DEM) on the DEIS. This is the first
time this analysis was presented (it was not in the DEIS). These appendices form the basis for
determining no significant WQ effects from the project.
Apigndix C - "Water Quality and Quantity Studies to Support Randleman Lake
Environmental Impact Statement"
D= - 12/1/90
Poses of Study - analyze downstream flows, study anticipated lake trophic levels, and study
toxic substances in lake.
Importance - This appendix finally provides water quality modeling for the proposed lake project.
The eutrophication model used (called BATHTUB) was developed by W. W. Walker and uses
loading estimates from point (based on monitoring data and permit requirements) and non-point
(based on distribution of land use, nutrient export coefficients and runoff data) sources to calculate
total phosphorous and chlorophyll a concentrations within the pool. No water quality sampling
was performed (it was based on existing information). The future land uses in the current
unincorporated (but future municipal) areas of both counties were assumed to be limited by the
watershed protection ordinances of Randolph and Guilford Counties.
Randleman WQ History
Page 11
Conclusions - Do AFT 1) During low flow periods the lake will provide higher flows in the Deep River downstream of
the reservoir compared to flows in the river without the reservoir. This is due to the three-
tiered minimum release requirement from the reservoir and wastewater return flow associated
with the lake yield supplements flow in the river.
2) On an average annual basis, flows in the Deep River with the lake are less than flows in the
river without the reservoir. The difference is approximately equal to the lake yield.
3) The proposed location for the water intake is in the area of the reservoir that would have the
best water quality.
4) Given the future land use assumptions of the study, estimates of phosphorus and nitrogen
loadings in the watershed would increase by 101 and 73 percent, respectively. For both
existing and future land use conditions, the reservoir is not predicted to be highly eutrophic.
5) The water in Randleman Lake will be safe to drink
6) Groundwater contamination from the Seaboard Chemical Company and the High Point Landfill
sites should not have a significant adverse impact on water quality in the lake.
7) Discharging effluent from the High Point Eastside WWTP to the reservoir is a feasible
alternative; toxic substances discharged from the plant directly into the reservoir should not
create a problem with the proposed water plant for the lake meeting Safe Drinking Water Act
requirements.
8) Concentrations of organic and inorganic pollutants at the proposed water intake should be less
than the concentrations predicted with the model. This is because most of the pollutants would
enter the reservoir at the upper end of the Deep River area, and the water intake would be
located approximately 10 miles downstream at the lower end of the reservoir. It is expected
that significant quantities of organic and inorganic pollutants would be removed by
sedimentation as the water is routed through the reservoir to the intake location.
9) The reservoir will cause no significant adverse impacts on the quantity or quality of the Deep
River water downstream from the project.
Summary Findings and Conclusions, maps, and pertinent text and tables from this appendix are
included in Appendix G.
Annendix DD - "Final PTRWA Water Supply Alternatives Assessment"
D= - 9/91
Poses of Study - update PTRWA water use projections to include 1990 water use data and
conservation measures, present potential secondary impacts of project, compare potential
environmental impacts of three other reservoir and one ground water supply alternatives, and
develop a reservoir filling plan.
Importance - Evaluation of alternatives is extensive and at first seems valid, until realize that all
choices other than Randleman are not considered "feasible" due to fatal flaws in their conception.
The reservoir alternatives considered originated in prior Corps' evaluations; interestingly, though,
the Howard's Mill alternative (from earlier Corps' evaluations) was not discussed. Under SEPA,
all reasonable (feasible) alternatives to the project must be discussed. A true comparison of
feasible alternatives is not provided in the study. The study only provides comparisons to
Randleman of those options that are prevented from happening due to flawed design (flooding the
Highpoint WWTP with the Upper Deep River Lake alternative, for example) or political realities
(current state law that prohibits construction of the alternative reservoir in Rockingham County).
Unanswered questions - Do other feasible alternatives to Randleman exist? How do the impacts
from all feasible alternatives rank against Randleman in terns of water quality?
Randleman WQ History
Page 12
Conclusions - RAFT
1) "The existing watershed management program for Randleman Lake should minimize future
development of point and non-point source pollution within the watershed." (The details of this
"program" were not defined in the report, but supposedly cover Oak Hollow Lake (High Point)
and City Lake (Guilford County) watersheds.) "Once the reservoir is filled, water quality
would be monitored. In addition, wetland areas that may emerge along the reservoir would
contribute to nutrient uptake, reducing nutrient levels and algae growth in the reservoir pool."
2) "A fatal flaw has been identified for each alternative except Randleman Lake." Randleman is
therefore considered the most implementable option available.
3) The Randleman Lake alternative includes upgrading the High Point Eastside WWTP to provide
phosphorous and additional nitrogen removal capabilities. These upgrades would improve
water quality in the reach of the Deep River that would be inundated by the proposed reservoir.
Modeling studies predict that effluent discharges from the Eastside WWTP will not impair the
ability of treated raw water to meet Safe Drinking Water Act Requirements.
4) "Toxic substances from the Seaboard Chemical Company and the High Point landfill, both of
which are located adjacent to the proposed reservoir ... have contaminated groundwater."
Modeling studies predict that contaminated groundwater from these sites will have no
significant impacts on water quality of the lake.
5) "The project would have minimal effect on regional growth, but it would increase the rate of
localized population growth and economic development of communities near the proposed
reservoir. Growth within the critical area around the impoundment will be restricted, however,
by the watershed protection ordinances of Guilford and Randolph Counties. Indirectly, the
presence of additional water supply in the Piedmont Triad area could stimulate development
and encourage in-migration from nearby cities. This could create avenues for commerce that
could stimulate economic activity."
9. T1Il? - "Record of Decision - Final Environmental Impact Statement for
Randleman Lake"
Author - DWR, DEHNR
D= - Project and FEIS approved by the EMC on December 12, 1991.
umma[y of Conclusions - "Based on a very conservative model, the untreated water in the lake is
projected to meet all standards for finished drinking water except aluminum, copper and iron.
These metals will either settle out in the lake or be removed in the water treatment plant and will not
be a problem in the finished drinking water supply. The water quality study also predicted the
level of nutrient enrichment (eutrophication) in Randleman Lake. While some over-enrichment is
projected in the Upper Deep River area near High Point's Eastside WWTP, the lake as a whole is
predicted to be less eutrophic than many other water supply impoundments in the Piedmont area of
NC."
Mitigation Measures -
The EMC added 12 specific conditions to the project to minimize environmental impacts, several of
which involve surface and ground water quality or quantity concerns. Specific to water quality: 1)
the City of High Point was required to complete a water quality assessment of its old landfill and
develop a closure plan that mitigates whatever water quality problems might exist (also, NC Solid
Waste Division will test the Old Randleman Town Dump and require whatever clean-up is
necessary); 2) the ten largest contributors of hazardous waste to the Seaboard site will "take
whatever actions are necessary to correct the groundwater problems associated with the site"; 3)
DEM was required to investigate the causes of the DO deficit below Carbonton Dam on the Deep
River. "Its engineers will recommend ways to solve the problems"; and, 4) the PTRWA will
construct a multi-level outlet device at the dam to ensure that it can release high quality water. Also,
PTRWA will study the DO content in the Deep River below Randleman Dam and will install and
operate appropriate oxygenation equipment at the dam if significant improvement in DO
t
Randleman WQ History
Page 13
concentrations below Carbonton Dam will occur. See Appendix H for the full text of conditions
for the project.
10.-L& - "Corrected Certificate Authorizing the PTRWA Authority for Eminent
Domain and Interbasin Transfer by the EMC"
Author - EMC
D= - Signed by EMC on 2/22/92
Summaries of Conclusions - Many of the same conclusions from the ROD are repeated here.
Items of note -
1) Randleman Lake will release a minimum flow of 30 cfs under normal conditions, thereby
providing an augmented flow downstream during dry periods. The quality of the discharge
will also be better than the present flow in the Deep River because of the dilution and natural
sedimentation and assimilation of pollutants in the reservoir. There will therefore be a slightly
positive effect on downstream communities who use the Deep River for water supply and
wastewater assimilation."
2) Because Randleman Lake will supplement base flows during dry periods and improves the
quality of water flowing downstream; it should help improve the quality of water in the lower
Deep River at Carbonton Dam.
3) PTRWA is required to determine the relationship between the DO concentration of water
released from Randleman Lake and the DO concentration downstream in the Deep River to the
confluence with the Haw River.
See Appendix I for the full text.
11. T3>l? - "Letter to Army Corps of Engineers from US EPA on Randleman Lake
FEIS" by Heinz Mueller
D= - May 22, 1992.
Location of Document - DWQ's Randleman file
Importance of Document - recommends holding project in abeyance until a comprehensive
investigation of the High Point Landfill and Seaboard Chemical site can be performed. Concerned
about potential for leaching toxics into the reservoir from the Landfill, Old Randleman Town Dump
and Seaboard Site. Also concerned that full remediation of any of these sites was not considered in
the cost estimation for the project. See full text in Appendix J.
12. Tltl? - "Letter to DWR from DEM on Low DO Study of Carbonton Dam" by
Steve Tedder
D - October 16, 1992
importance of Document - Study was performed as a condition of the Randleman Lake ROD and
EMC Decision.
Results of Sq& - Water quality above and below the Carbonton Dam-is highly variable depending
on flow and season. It is expected that low dissolved oxygen concentrations will occur below the
dam when the hypolimnion is at a higher level then the release structure. Observations above the
dam indicate that hypereutrophic conditions that occur there will need to be addressed through a
comprehensive management strategy. It was the intent of DEM to evolve these management
strategies through the basin management plan for the Cape Fear Basin.
See full text in Appendix K.
U tiFT Randleman WQ History
Page 14
13. T11 - "Record of Proceedings - Wake County Superior Court: Deep River
Citizens Coalition v. DEHNR, EMC and PTRWA"
Air - Judge Dexter Brooks
1ktr,-- May 12, 1994
Location of Document - DWQ's files
Importance of Document - Judge deemed the FEIS inadequate because it did not fully show and
analyze all of the impacts of the proposed project nor did it address all of the reasonable alternatives
to the proposed action.
Conclusions - 1) It was arbitrary and capricious for the EMC to approve a water supply project that
cannot guarantee that the water it supplies is drinkable and protective of public health and safety, 2)
The EMC erred in approving the Randleman Dam application absent sufficient assurances of
adequate water quality, 3) The EMC erred in basing its decision contingent upon unfinished studies
and future hypothetical actions, and, 4) The EMC erred by relying on an EIS which failed to
consider all of the reasonable alternatives to the proposed action. The petitioner's request for relief
was granted and the decision by the EMC was reversed and vacated.
14. T k - "Water Quality Monitoring Data for Waters in the Upper Deep River
Area, July 28, 1992 - October 7, 1993"
Author - Environmental Sciences Branch, WQ Section
Agency - DEM / DEHNR
D_= - September, 1994.
Location of Document - DWQ's Randleman file
Importance of Document - Detailed water quality monitoring study of existing conditions in the
Upper Deep River area. Executive Summary is included in Appendix L. This report does not
attempt to predict or evaluate water quality conditions which may occur as a result of
hydromodifrcations from the dam or lake. This report was presented to the EMC WQ Committee
by Ken Eagleson on March 8, 1995. Notes from that WQC meeting indicated that DWQ was
primarily concerned with nutrients (no controls presently in drainage area). DEM was also waiting
for an organics characterization study to be completed by DEH to address water quality issues on
the potential WS reclassification. DWQ's files do not contain this study.
15. T - "Brief of the Respondents - Appellants - NC Court of Appeals: Deep
River Citizens Coalition v. DEHNR, EMC and PTRWA"
Autho - DEHNR / EMC (Dan Oakley)
D= - Nov. 14, 1994
Location of Document - DWQ's files
Importance of Document - Brief from AG's office, supporting the appeal of the Superior Court's
Decision. Argued that the FMC's decisions regarding Randleman Lake's water quality are
supported by substantial evidence in the record and in the FEIS. Further,
"The existenceeof nearby waste sites would not adversely affect water quality and the
public health and safety... the FEIS contains a thorough and conservative water
quality analysis which includes large projected increases in future pollutant loadings
to the lake from point and non-point sources... this analysis makes further
conservative assumption that all of these pollution inputs will remain suspended in
the water column, even though in reality they are substantially reduced by the natural
processes of chemical breakdown, sedimentation and volatilization. Despite this
conservative approach, the analysis shows that the untreated raw water ... will meet
drinking water supply standards with the exception of iron, copper and aluminum.
Standard drinking water treatment processes will remove these elements....
verification with 100% certainty of the water quality of the reservoir is a clearly
Randleman WQ History im i Page 15
impossible task. The record demonstrates that even after using very conservative
estimates, drinking water standards will be met in Randleman Lake."
16. TIYI? - "Memo to Monica Swihart on Effect of Proposed Randleman Dam on
Reservoir Water Quality"
Amt - Betsy Johnson, TSB
D= - January 25, 1995
Location of Document - DWQ's files
impose of Document - To assist Monica in briefing Linda Rimer on the Lake project, future
permits that are needed and associated water issues.
Importance of Document - Showed DWQ's continued concern with WQ in the lake.
Findings - Agreed with the EIS in that water quality in Randleman Reservoir will be within the
range of values measured in other NC lakes. However, the comparable lakes are all eutrophic.
From the model results, it is highly likely that Randleman Lake will be eutrophic as well. See
Appendix M for full report and attached studies from DEM on the Deep River. These attached
studies make interesting findings, including one report which states that to reduce existing algae
growth and improve dissolved oxygen concentrations in the Deep River, either the natural riverine
conditions can be restored (by removing existing impoundments) or nutrient concentrations should
be reduced.
17. Ilk - "Memo to Linda Rimer on Randleman Dam Water Quality Issues"
Author - Monica Swihart (signed by Preston and Steve T.)
D= - Feb. 3, 1995
Location of Document - DWQ's files
Purpose of Document - To brief Linda Rimer on the Lake project.
Importance of Document - Showed DWQ's continued concern with WQ in the lake.
Findings - 1) water quality in Randleman Reservoir will likely be eutrophic; 2) the dam and
interbasin transfer will decrease average annual flow in Deep River, which could lengthen
detention times behind the many dams downstream, thereby contributing to DO and chlorophyll-a
standards violations. DEM has serious concerns regarding potential chlorophyll-a and DO
violations in the reservoir (which might affect the 401 certification for the project); 3) water supply
reclassification for the reservoir will have to wait until the dam is constructed, due to potential
stream ecology and water quality changes after impoundment; 4) DEM is also concerned with
potential toxic compounds from the landfills and hazardous waste sites in the area. Modeling had
indicated aluminum and copper would exceed state and federal standards. DEM is also concerned
with mercury traces from old gold mines found tributary to the upper,arm of the proposed
reservoir; 5) as of that date, although no 404/401 application had been received, a conceptual
wetland mitigation plan was being discussed; and, 6) even with the HP Eastside WWTP
discharging effluent of total phosphorous of 0.5 mg/l, nuisance algal blooms are still predicted to
occur 70-80 % of the time in the upper Deep River arm due to point and non-point sources.
Appendix N for full report.
18. T1>l? - "Water Quality and Predictive Modeling Studies on the Proposed
Randleman Reservoir, High Point, North Carolina"
Autho - Patrick L. Brezonik, University of Minnesota, Minneapolis
Agency - PTRWA
]= - March 1995
Location of Document - DWQ's files
Importance of Document - An independent review of previous studies on water quality issues of
the lake, particularly its trophic state and potential contamination by organic chemicals from a
landfill and abandoned chemical plant. This document claims to be a careful analysis and
Randleman WQ History
DRAFT story
Page 16
evaluation of previous studies (a good summary of reports produced to date is included on page 2)
in terms of their completeness, adequacy of methodology and technical accuracy. This summary
analysis contains references to documents that are not found in DWQ's files. See Appendix O for
a complete copy of the report.
19. - "Record of Proceedings - NC Court of Appeals (from Wake County):
Deep River Citizens Coalition v. DEHNR, EMC and PTRWA"
AuthoI - Judge Greene
D= - June 6, 1995
Location of Document - DWQ's files
Importance of Document - Decision to overturn Superior Court's decision.
Findings - Because the petitioners did not first have the contested case hearing to which they were
entitled, the superior court was without jurisdiction to conduct a judicial review. The order of the
superior court reversing and vacating the decision of the EMC is vacated. The office of
administrative hearings was ordered to hold a contested case hearing and the EMC issue a decision
based on the new record. The result - the original EMC decision still stands (the certificates are still
good and the FEIS was considered approved).
Subsequent Actions - Communications with John Sutherland (DWR) and Frank Crowley (EMC
Atty.) indicate the Deep River Citizens Coalition dropped the case after they lost this appeal due to
lack of legal funds.
20. lik - "Cape Fear River Basinwide Water Quality Management Plan"
Author - DWQ
D_, - Approved by EMC on October 12, 1995
Location of Document - DWQ's files
Importance of Document - Copy of Executive Summary and Future Initiatives Sections are
included in Appendix P. Contains good up-to-date summary of existing water quality conditions
in the project area and proposes specific initiatives to correct toxics and nutrient issues in the
proposed Randleman watershed.
21. Lk - "Memo to Mr. Kime (PTRWA) on 401 Certification for Randleman"
Author - DWQ (Tedder signed, written by John Domey)
I2= - January 24, 1997
Location of Document - DWQ's files
Importance of Document - Addressed wetland mitigation and watershed management requirements
necessary for issuance of a 401 Certification. Recommended comprehensive management plan to
address chlorophyll-a nutrient problem and the wetland mitigation issue (necessary as a result of
wetland losses from the reservoir) as part of the 401 Certification process. "We believe that a
comprehensive wetland mitigation and watershed management plan along the lines outlined above
will allow a 401 Certification to be issued for this project." See Appendix Q for full letter.
22. Ti11? - "Low Flow Characteristics and Profiles for the Deep River Basin in
the Cape Fear River Basin, North Carolina"
Author - J. Curtis Weaver, US Geological Survey (in cooperation with DWQ and DWR)
D= - May, 1997.
Location of Document - DWQ's files
impose of Document - To prepare a low-flow discharge profile for the Deep River Basin.
Importarice of Document - Only measures existing conditions (as of 1995) and does = address
projected conditions from the Randleman Lake
Summary of Conclusions - See attached Appendix R for summary information from the study.
r-%. Ai F?T Randleman WQ History
Page 17
23. L& - "Watershed Protection Information for Randleman Lake Watershed"
Author - Lisa Martin, DWQ Water Supply Watershed Protection Program
D= - July 22, 1997.
Location of Document - DWQ's files
impose of Document - To determine amount of Randleman Watershed currently protected by local
government regulations and amount still remaining to be protected (and which local governments
would be affected).
Results -
a) 86 % of watershed currently protected
b) Local governments currently implementing water supply watershed regulations -
Randolph County 37% of watershed 24,318 acres
Guilford County 47% of watershed 30,837 acres
Greensboro 2% of watershed 1,285 acres
c) Local governments not implementing water supply watershed regulations -
Archdale 6% of watershed 3,764 acres
High Point 8% of watershed 5,069 acres
Jamestown 1% of watershed 466 acres
Randleman 1% of watershed 260 acres
mis: \ Randleman Project History
I -.
?j
State of North Carolina
Department of Environment,
Health and Natural Resources IA&4 • •
Division of Soil and Water Conservation
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
C. Dewey Botts, Director
MEMORANDUM August 19, 1997
TO: Melba McGee
o
FROM: David Harrisr???ri
SUBJECT: PTRWA Water Transmission Mains and Associated Facilities. Randolph County,
NC
The proposed project involves 26,000 linear feet of 48-inch water main, 25,000 linear feet
of 24-inch water main, 20,500 linear feet of 16-inch water main, 250,000 gallon elevated steel
storage tank, 2 million gallon (MG) prestressed concrete gound storage tank, and 2,220 gallon
per minute (gpm) packaged booster pumping station. Most improvements will be located on
existing highway right-of-ways. Land requirements for the storage tanks and the pumping
station was not indicated.
The Environmental Assessment should include information on the amount and location of
Prime or Important Farmland that will be impacted. Alternatives that reduce impacts to Prime or
Important Farmland soils are preferred. A listing of these soils in North Carolina is available
through the MLRA Team Leader, North Carolina State Office, Natural Resources Conservation
Service, USDA, 4405 Bland Road, Suite 205, Raleigh, N.C. 27609, [phone].
The Prime Farmland designation is not limited to land currently being cultivated. It is
intended to identify the best soils that can be used as farmland without regard to the present
vegetative cover. Only areas that are already built-up or within city limits are exempted from
consideration.
DH/tl
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
- - . - . .. ._ ? _a:__ r.__.._. cna ,....,..te?/ I rM. rv?ct?nna imar nnnar
I -.
State of North Carolina IT
Department of Environment,
Health and Natural Resources 1 • •
Division of Forest Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary [DEEHNFZ
Stanford M. Adams, Director
Griffiths Forestry Center
2411 Old US 70 West
Clayton, North Carolina 27520
August 18, 1997
MEMORANDUM
TO: Melba McGee, Office of Legislative Affairs
FROM: Don H. Robbins, Staff Forester DOW
SUBJECT: EA Scoping for PTRWA Water Transmission Mains and Associated Facilities in
Conjunction with Randleman Lake Project in Randolph County
PROJECT # 98-0134
DUE DATE: 9-27-97
We have reviewed the above subject scoping document of 8-6-97 and have the following comments
concerning potential impacts to woodland:
Type of Information that we would like to see in this Environmental Document to Address Impacts to
Woodland - The following should be addressed for each alternative or project.
The total forest land acreage by types and merchantability aspects that would be taken out of forest
production or removed as a result of new right-of-way purchases, easements and all construction
activities. Emphasis needs to be directed towards reducing impacts, whenever possible to the following
types of woodland in the following order of priority -
a. High site index productive land that is currently under active forest management.
b. Productive forested wetlands.
c. Lower site index productive land that is currently under active forest management.
d. Unique or unusual forest ecosystems.
e. Unmanaged, fully stocked woodland.
f. Unmanaged, cutover rural woodland.
g. Urban woodland.
2. The productivity of the forest soils as indicated by the soil series that'would be involved within the
proposed project.
3. The impact upon existing greenways within the area of the proposed project.
??y? An Equal Opportunity Affirmative Action Employer
P. O. Box 29581, Raleigh, North Carolina 27626-0581 N?? C
%I-!- nice 79Q_71A) C A Y 010_715-A45r1 50% recvcled/l0% post-consumer paper
Normawa.ocess
Time
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PERMITS SPECIAL APPLICATION PROCEDURES or REQUIREMENTS limit)

?
Permit to drill exploratory oil or gas well File surety bond of 55,000 with EHNR running to State of N.C.
conditional that any well opened by drill operator snail, upon
abandonment, be plugged according to EHNR rules and regulations. 10 days
(NIA)

Q Geophysical Exploration Permit Application filed with EHNR at least 10 days prior to issue of permit
Application by letter. No standard application form. 10 days
(NIA)

? State Lakes Construction Permit Application fee based on structure size is charged. Must include
descriptions a drawings of structure a proof of ownership
of riparian property. 15.20 days
(NIA)
60 days
401 Water Oualily Certification NIA (130 days)
55 da
s
y
? CAMA Permit for MAJOR development S250.00 fee must accompany application (150 days)
22 days
? CAMA Permit for MINOR development 550.00 fee must accompany application (25 tlays)
? Several geodetic monuments are located in or near the project area. If any monuments need to be moved or destroyed. please notify:
N.C. Geodetic Survey. Box 27687, Raleigh, N.C. 27611
Dandonment of any wells. if required, must be in accordance with Title 15A, Subchapter 2C.0100.
otification of the proper regional office is requested it -orphan'' underground storage tanks (LISTS) are discovered during any excavation operation.
45 nays
E] Compliance with 15A NCAC 2H.1000 (Coastal Stormwater Rules) is required. (NIA)
* Other comments (attach additional pages as necessary. being certain to cite comment authority):
A 6/A S/9 7
ANY CONSTRUCTION ACTIVITIES INCLUDING CLEARING, GRADING, AND
EXCAVATION ACTIVITIES RESULTING IN THE DISTURBANCE OF FIVE (5) OR MORE
ACRES OF TOTAL LAND ARE REQUIRED TO OBTAIN A NPDES STORMWATER PERMIT
PRIOR TO BEGINNING THESE ACTIVITIES. e_v ?
REGIONAL OFFICES
Questions regarding these permits should be addressed to the Regional Office marked below.
l Office
i
ill
R
? ? Fayetteville Regional Office
ona
eg
Ashev
e
59 Woodfin Place Suite 714 Wachovia Building
Asheville, NC 28801 Fayetteville, NC 28301
(704) 2516208 [phone]
? Mooresville Regional Office ? Raleigh Regional Office
Suite 101
3800 Barrett Drive
919 North Main Street, P.O. Box 950
Mooresville, NC 28115 ,
Raleigh, NC 27609
[phone] [phone]
? Washington Regional Office
1424 Carolina Avenue
Washington, NC 27889
[phone]
? Winston-Salem Regional Office
8025 North Point Blvd.
Suite 100
Winston-Salem, NC 27106
rn,e, flOA7nm
? Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
[phone]
\\ ARCHDALE '
1POP. 5,726 4x
f?UIUORD .CO. 179
' o
\ le
L ?
Presumed Location of Project
2100 2101 `IG•?
Lev.l' SO
Cross `
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IJL 1.9 J
24
I
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Edgar Branch a
'1': I p 311 - t 1 16
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ar et UNE• Town DUMP
/ Johnson Field
NCO 966 97 374.
NORTHWESTERN f ?- w'?` I 3
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( ?11O NCO 003 226 515
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/ 1 I ?\ 311 Q? t
I
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1310 Flint Hill 1 E 1 o Satellite
13L .? y of
a \ .? i> 1 371_ `, I Rand;emon
` ` 1701.2 •3 i lsll m
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39
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5FIEPHEltD MTN. , 0.r,?1? 1319 .3 Hsheboro
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111 :4 D v NCO 000822 064
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9 ?• 2 1 1 ?.j? ?
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POP. 15,25-,::,,
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. 10,000 FOOT GRID BASED ON NORTH CAROLINA PLANE COORDINATE SYSTEM
1 1 POLYCONIC PROJECTION 42
?T_ isle 17iY v -
1327 (UNINC.) 1 > /•• qtr 2 Z
•1365 ,6 POP. A91
1317 - /1 1326 13,19 2\
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
p ? NR
TO: Division Secretary, Waste Mgt. Division AU
? ?61 ?T
FROM: Joseph H. Deakins, Waste Mgt?Specialist Hazardous Waste Section /?/}
J
DATE: August 21, 1997
SUBJECT: (PTRWA) Water transmission mains and associated facilities to
be constructed in conjunction with the Randleman Lake Project.
The Hazardous Waste Section has reviewed the noted project and-
offers the following comments:
Trinity Foam, Glenola, on Highway 311, is currently in litigation with
the State over groundwater contamination and air permit questions. Tritech
Environmental may want to look at the situation at Trinity Form.
I see no problems at other locations on the map. If a site call
encountered during the project that involves hazardous waste, please
x;919) ?33-2179.
CC: Keith Masters
Guilford County File
P.o. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
A. r,.....i n,1l1 5-h inity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
I
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
MEMORANDUM
. UAK?hFA
1DEHN
September 11, 1997
TO: Michael Kelly, Deputy Director
Division of Solid Waste Management
FROM: Philip J. Prete, Head
Field Operations Branch
Subject: Piedmont Triad Regional Water Authority (PTRWA)
Water Transmission Mains and Associated Facilities
Environmental Impact Study
The Solid Waste Section has reviewed the attached project proposal and has seen no
adverse impact on the surrounding community and likewise knows of no situations in the
community which would affect the project.
The PTRWA should make every feasible effort to minimize the generation of waste, to
recycle materials for which viable markets exist, and to use recycled products and materials in the
development of this project where suitable. All waste generated by this project must be disposed
of at a solid waste management facility permitted by the Division. The nearest facility permitted
to receive land clearing and inert debris is located on Pine Hill Road in Asheboro, Randolph
County. Please contact the site operator, Don Pritchard, at [phone] for more information.
Additional questions regarding soild waste management may be directed to Mr. Hugh
Jernigan, Waste Management Specialist, Solid Waste Section, at [phone] extension 206.
PJPAcf
cc: Hugh Jernigan
FAX [phone]
P.O. Box 27687, W4
C
Raleigh, North Carolina 27611-7687 N va An Equal Opportunity Affirmative Action EmE
_ - - .,k 91-ft ra,^vnlari/IrP/- nnc+s-nnci imar nrinP
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management -
James B. Hunt, Jr., Governor EH N FZ
Wayne McDevitt, Secretary
William L. Meyer, Director
September 12, 1997
TO: Melba McGee
Office of Legislativ Intergovernmental Affairs
FROM: Michael A. Kelly
Deputy Director
SUBJECT: Project Number: 98-0134
Randolph County
..The Waste Management Division has reviewed and commented on
the above-referenced project. Please find enclosed separate
comments from the Hazardous Waste Section, Solid Waste Section
and Superfund Section.
Should you have additional questions, please feel free to
contact our office.
MK:sh
Enclosures

P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal opportunity Affirmative Action Employer 50% Recycled / 10% Post-Consumer Paper
NCWRC,HCP,FRLLS LAKE TEL:[phone] Oct 10'97 10:56 No.002 P
PTRWA Water Transmission System 3 October 10, 1997
Guilford/Randolph Counties
(c) Include specific measures that will be implemented to promote water conservation
and wastewater reuse.
(d) Tnclude a discussion of any other local ordinances or programs (e.g., industrial
pretreatment, infiltration and inflow management and recycling) that will mitigate the
impacts of development.
9. Include a list of document preparers that shows each individual's professional background
and qualifications.
Measures to avoid or minimize impacts to sensitive resources, including wetlands, should
be implemented during construction. Where impacts to wetlands are unavoidable, we will
recommend mitigation of the losses. In addition to providing wildlife habitat, wetland areas
perform important functions of flood control and water quality protection.
To avoid or minimize wetland impacts, we offer several generalized recommendations.
Utility lines should be placed in or adjacent to upland areas. It is recommended that a minimum
100-foot buffer of natural vegetation be left between construction corridors and the banks of
perennial streams. These buffers will help minimize impacts to water quality, stabilize stream
banks and provide travel corridors for wildlife. Trees and shrubs should be retained or
established in the buffers. Buffers should also be left along intermittent drains or streams.
Construction corridors should be no wider than absolutely necessary. The 401.
certification for Nationwide Permit 12 stipulates that wetland construction corridors arc not to
exceed 40 feet and permanent maintained corridors are not to exceed 10 feet except at access
points. Plant communities should be re-established that will result in wetland plant community
succession into habitat of equal or greater value than the habitat that was destroyed. Disturbed
wetland areas should he returned to original soils and contours. Temporarily disturbed wetlands
should be reseeded with annual small grains appropriate for the season (e.g. oats, millet, rye,
wheat, annual lespcdeza or rye grass) and be allowed to revert to natural wetland vegetation.
Crossings of wetlands and streams should be minimized, located at narrow areas, and made
perpendicular to the stream.
't'hank you for the opportunity to provide input in the early planning stages for this
project. If we can he of further assistance, please contact our office at [phone].
OFA/ofa
cc: Kevin Moody, Biologist, USFWS
Michelle Suverkrubbe, Division of Water Quality
NCWRC,HCP,FRLLS LRKE TEL:[phone] Oct 10'97 10:55 N0.002 P.03
PTRWA Water Transmission System 2 October 10, 1997
Guilford/Randolph Counties
should facilitate preparation of fish and wildlife impact assessments. This information will be
very useful if it becomes necessary to prepare an environmental document.
In addition to addressing the concerns discussed above, the environmental document
should include a detailed assessment of existing natural resources within these areas of potential
development and should discuss the potential of mitigating development impacts to wetlands,
waters and high quality upland habitat. Additionally, to provide a meaningful review of
proposed project impacts on fish and wildlife resources, we request that consultants, project
sponsors or permit applicants provide the following information in the environmental document:
1. Include descriptions of fish and wildlife resources within the project area, and a listing of Whcn federally or state designated threatened, endangered or special concern should be
n? idea
practicable, potential borrow areas to be used for project construction
in the inventories. A listing of designated species can be developed through consultation
with: The Natural Heritage Program, NC Division of Parks and Recreation, P. O. Box
27687, Raleigh NC 27611, PH: [phone].
2. Include descriptions of any streams or wetlands affected by the project.
3. Include project mars identifying wetland areas. Identification of wetlands (y be If
accomplished through coordination with the U.S. Army Corp Engineers the COE is not consulted, the person delineating wetlands should be identified and
criteria listed.
4. Provide a description of project activities that will occur within wetlands, such as fill or
channel alteration. Acreage of wetlands impacted by alternative project designs should
be listed.
5. Provide a description and a cover type map showing acreage of upland wildlife habitat
impacted by the project.
6. Discuss the extent to which the project will result in loss, degradation or fragmentation of
wildlife habitat (wetlands and uplands).
7. Discuss any measures proposed to avoid or reduce impacts of the project or to mitigate
unavoidable habitat losses.
8. Discuss the cumulative impacts of secondary development facilitated by the proposed
project. Such discussions ould weigh the economic benefits of such growth against the
costs of associates] environmental degradation.
(a) Include specific measures that will be used to address stormwater at the source.
Include specific requirements for both residential and industrial developments and
BMPs that will be required. It is our understanding that High Point, Jamestowm and
Archdale do not currently have stormwater regulations in place. It is recommended
that these communities and Randolph County implement stonnwater regulations and
management to help address the severe water quality problems in area streams and
mitigate some of the impacts that will be caused by development of this water supply.
It is further recommended that these conununities make a commitment to protecting
area streams with riparian buffers through purchase or conservation easement.
(b) include specific measures that will be used to protect stream corridors, riparian
habitat and a minimum of a 100-year floodplain.
NCWRC,HCP,FALLS LAKE

TEL:[phone] Oct 10'97 10:54 No.002 P
51
North Carolina Wildlife Resources Commission it
512 N. Salisbury Street, Raleigh, North Carolina 27604.1188, 919-733.3391
Charles R. Fuffwood, Executive Director
MEMORANDUM
TO: Melba McGee
Office of Legislati[ve?and In overnme Affairs
FROM: Owen F. Anderson de nt Region Coordinator
Habitat Conservation Program
DATE: October 10, 1997
SUBJECT: Scoping for Environmental Assessment for Piedmont Triad Regional Water
Authority, Transmission Mains, Guilford and Randolph Counties, North Carolina,
98-0134
Biologists with the North Carolina Wildlife Resources Commission have reviewed the
subject document. Our comments are provided in accordance with provisions of the Fish and
Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.) and the North
Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; 1 NCAC 25).
The Piedmont Triad Regional Water Authority (PTRWA) proposes to construct water
transmission lines to convey water from the proposed new water treatment plant for Randleman
Lake to members of the PTRWA (i.e., Randolph County, Randleman, Greensboro, Archdale, and
High Point).
Most of the water lines appear to follow highway ri&hts of way; therefore, we would not
anticipate significant direct impacts to fish and wildlife habitat. However, even road rights of
way can provide important habitat, including habitat for endangered species (e.g., Schwenitz's
sunflower).
Our major concerns from projects such as this are the secondary and cumulative impacts
from development. Dish and wildlife have been impacted already in the sprawling urbanized
Triad area. The water supply and transmission lines will cause additional adverse impacts to fish
and wildlife populations. Water quality in area streams is already of such poor quality that the
proposed Randleman Reservoir is questionable for water supply and recreation. Also, interbasin
transfers that will result from these projects will result in further degradation of water quality and
recreational opportunities in the Haw River and Jordan Reservoir.
The information provided is not sufficient for our staff to make definitive
reeommcndations or conclusions concerning this project. Due to staff limitations, this
standardized response was developed for projects such as this. Although some of the
infonration, requests and comments may not be applicable to certain projects, these guidelines
ANTI -SEEP COLLAR
. I_ 18 I
I inches . i Utility Line
I .4_0"1 [Diameter Varies)
f ?
1 foot I I-?--- Class B Concrete
I or Compacted Clay
L I
6 inches Trench Width 6 inches
Not to exceed 40 feet
SECTION
r Class B Concrete
Id A or Compacted Clay
I
12
inches
6 inchesi. W-4- ,_l.,6 inches
PLAN
until a FONS1 or ROD is issued by the State Clearinghouse;
14. Stormwater management shall not be required for this Certification;
15. Compensatory mitigation (i.e., restoration, creation or preservation) for
wetland losses will not be required for this Certification;
16. This Certification does not relieve the applicant of the responsibility to
obtain all other required or local approval.
Non-compliance with or violation of the conditions herein set forth by a specific
fill project shall result in revocation of this Certification for the project.
The Director of the North Carolina Division of Environmental Management may
require submission of a formal application for individual certification for any project in
this category of activity, if it is determined that the project is likely to have a significant
adverse effect upon water quality or dEcrade the waters so that Existing uses of the
wetland or downstream waters are precluded.
Public hearincs may be held for specific applications or croup of applications
prior to a certification decaon if deer-ned in the publics best interest by the Director of
the North Carolina Divisi--n of EnvironmE'Ital Management.
This is the Z day of September, 1995
DIVISION OF ENVIRONMENTAL 1':1r-.Nr.GEMEN T
i ,
Ey ?
A. Freston Howa.
- Director
nwl2b.cer
wQC r 3022
7. The construction corridor (including access roads and stockpiling of
materials) is limited to 40 feet (12.2 meters) in width and must be
minimized to the maximum extent practicable.
a. Measures shall be taken to prevent live or fresh concrete from coming
into contact with waters of the state until the concrete has hardened;
o. Permanent, maintained access corridors shall be restricted to the
minimum width practicable and shall not exceed 10 feet (3 meters) in
width except at manhole locations. A 10 feet (3 meters) by 10 feet (3
..meters) perpendicular vehicle turnaround must be spaced at least 500
feet (152.4 meters) part.
10. An anti -seep collar shall be placed at the downstream (utility line
gradient) wetland boundary and every 150 feet (45.7 meters) up the
gradient until the utility exits the wetland for buried utility lines. Anti-seep
collars may be constructed with class 6 concrete or compacted clay.
Perpendicular wetland crossings less than 150 feet (45.7 meters) Iona do
not require anti-seep collars.
The compacted clay shall have a specific discharge of 1 X 10'5 cm/sec or
less. A section and plan view diagram is attached for compacted clay
and concrete anti-seep collars.
The following specifications slIa!I apply to class 6 concrete:
a) &iininum genera content, sacks
per cLbic yard with rounded
course a^_aregate 5.0
b) tilinimun cement content, sacks
per cubic yard with angular
course aggregate
c) Maximum water-cement ratio
aallons per sack 6.8
d) Stump range 2` to 4"
e) Minimum strength - 28 day psi 2,500
11. Placement of rip rap is restricted to stream bottom and banks directly
impacted by the placement of the utility line. The.stream berm must be
restored to the original contour after construction;
12. This general certification does not authorize any permanent changes in
preconstruction elevation contours in waters or wetlands. The permittee
will have a specific plan for restoring wetland contours. Any excess
material will be removed to a high ground disposal area;
13. If an environmental document is required, this Certification is not valid
GENERAL, CERTIFICATIONS FOR PROJECTS ELIGIELE
FOR CORPS OF ENGINEERS NATIONWIDE PERMIT NUMBER 12 OR
REGIONAL PERMIT 049 (UTILITY LINE F-AM-=-ILL AND EEDDING)
This General Certification is issued in conformity with the requirements of
Section 401,. Public Laws 92-500 and 95-217 of the United States and subject to the
North Carolina Division of Environmental Management Regulations in 15A NCAC 2!
Section .0500 and 15A NCAC 2B .0109 AND .0201 for the discharge of fill material to
waters and wetland areas as described in 33 CFR 330 Appendix A (6) (12) and
General Permit No. 198100049 of the Corps of Engineers regulations (i.e., include any
fiil activity for utility line backfill and bedding. This certification replaces Water Quality
Certification Number 2664 issued on January 21, 1992 and is rescinded when the
Carps of Engineers reauthorize Nationwide 12 or Regional Fermit 049.
The Slate ci North Carolina certifies that the specified category of activity will
not violate Sections 301, 302, 303, 306 and 307 of the Public Laws 92-500 and S5-
217 if conducted in accordance with the conditions here!na;ier set forth.
Conditions of Certification:
1. Activities covered by this Genera! Certification do not reculfe WrlttEn
concurrence from the Division of Environmental Management (DEM) as
lone as they comply with all conditions of this General Certification and
the conditions of Nationwide 12 or Regional Permit 049;
2. Written concurrence from DEM is required if the utility line is installed
para!!E! to and c!Cser than 10 fEEt (3 me ers) to a stream or if the utility
line c.csSES 2 stream channe! c less than 75 decreES or more than 105
CE?fe=s (i.e., riot perpendicular S,rc--=m c.csszina) of the strcci7 bank;
3. Const-uction corridors para!le! to streams sell be placed M.
the furthest
dis, ice from the stream to the maximum extent practicable;
4. That eStablished sediment and erosion control practices are utilized to
prevent violations of the 2pprconate turbidity water quallty standard (50
N T Us in streams and rivers not desionated as trout watcrr by DEM; 25
N T US in all salt water classes, and all lakes and reservoirs; and 10 NTUs
in treat Wc- ). All sediment and erosion control measures placed in
wetlands shall be removed and the natural grade restored after the
Division of Land Resources has released the project;
5. Annul:' species suitable for wet locations shall be planted within
juris%dicticna! v?et12nds for soil 2nd erosion c--ntrcl. Perennials such as
fC-scue are prohibited,
6. No fertilizer shall be applied within 10 feet (3 meters) of streams;
1 State of North Carolina
Department of Environment,
Health and Natural Resources 4 •
Division of Environmental Management
James E. Hunt, Jr., Governor AMM
Jonathan E E. . HOWES. Secretary C
A. Preston Howard. Jr., P.E., Director
October 6, 1995
MEMO
To: Wetland consultants and municipalides
From: John Dome
I
Re: Modification to Certification for Nationwide Permit 12 - Utility lines
The Division of Environmental Management (DE.'Yi) has reissued the Gene z-t Cerdficatien
(GC) for Nationwide Pe^mit 12 and Regional Permit 049. The new GC will expedite the per,, ittina
process and clan-l" for the acchc ant conditions necessary for a cerdnable proje = The simufic-urt
cha*t(Zes are:
1) No fertilizer applied within 10 feet of streams:
2) Anti-seep collars every 150 feet in wetlands:
3) Restore to original contours after consuacion. A specific plan is needed.
4) Rip rap is restricted to strea..n bottom and banks directly impacted by the
utility line: -
5) The consmac.ion corridor (including accrss roads and stockpiling of mate::als)
is limited to 40 feet in width
6) Construction corridors parallel to s-atarns shall be placed at the furthest
distance from the stream to the maximum extent practicable; and
7) Althoush you still need to act)ly to the U.S. Ar„ v Corns of Engineers for
these oe=its. written concur-ence from DENT is no longer needed provided
that all conditions of the General Certification are followed. Written
concn?:, .-.c;: is requi-zd if Me j"Ir? Line is installed paraEei and closer than 10
feet to a stream or if the line crosses a stream channel at less than 75 degrees
or more than 105 degrees (i.e., not perpendicalar stream crossing).
A copy of the revised GC is enclosed for your information. DF-M will be making compliance
site inspections. Should the utility line be installed such that a condition is violated. remedial actions
inc!udinL, utility lire relocation or installation of anti-seep collars fines may be imposed.
1786.
Should you have any questions, please contact Eric Gala*nb or John Domey at (919) 733-
nwl2.mun RECEIVED
OCT 16 1995
ENVIRCNMENTAL SCZNC ES
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 4
impacts to the water quality of Randleman Lake should be reevaluated upon receipt
of the February Remedial Investigation Report
6. On page 3-28, the DEIS states that, for Randleman Lake "Watershed protection
measures have been in place for more than eight years." Also, on page 3-29 it is
stated that "... other alternatives involve Rockingham and Alamance Counties,
which do not have watershed protection ordinances." Both of these statements are
misleading.
The Division manages the Water Supply Watershed Program for the state and our
records indicate the correct statements should be:
(Page 3-28) - "For the Randleman Lake watershed, 86% of the watershed is
currently protected under water supply watershed protection programs by local
governments - Randolph County (which comprises 37% of the watershed),
Guilford County (4790), and Greensboro (2%). The municipalities of Archdale,
which makes up 6% of the watershed, and High Point (8%), Jamestown (M), and
Randleman (1%) are phi currently implementing any water supply watershed
protection programs for the Randleman Lake watershed, although they may have
watershed protection ordinances that require protection of other watersheds in their
jurisdictions."
(Page 3-29) - "Rockingham and Alamance Counties both have adopted watershed
protection ordinances which protect approved water supply watersheds in their
jurisdictions; however, neither have yet adopted protections for any of the
alternatives discussed in this EIS, including the Randleman alternative."
(Pages 5-24 and 25) - It is accurately stated that Guilford and Randolph Counties
have enacted watershed protection ordinances, but they fail to mention the fact that
Greensboro also currently protects the Randleman watershed.
In addition to amending these above sections, the EIS should provide an
explanation for why the municipalities listed have not chosen to enforce watershed
protection provisions in the Randleman Watershed.
7. Table 10, page 3-16 discusses surface water evaluation criteria for each alternative.
This table should include a criteria for whether or not each alternative would meet
state water quality standards (including protecting aquatic life, recreational, and
water supply uses).
8. The Corps should refer back to DWQ's letter to PTRWA on January 24, 1997 for
specific comments on the wetlands aspects of this project and mitigation proposed
by PTRWA.
m1s:1980029 Randleman EIS
,?
cc: DWQ staff
DE-H - Public Water Supply
PTRWA - Mr. John Kime
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 3
replacement of the High Point Eastside WW'IP was removed from Alternative A
(Upper Deep River Lake), its costs would be reduced by $64 million to
$108,912,624, making it the cheapest alternative discussed in this EIS, cheaper
than the Randleman alternative by $14 million.
The costs listed for the Randleman alternative presented in Table 13 do not appear
to be complete. The document should indicate how the $200,000 listed for clearing
up the Old Randleman Dump was derived. The Randleman alternative should
include estimated costs to remediate and clean up the groundwater from the High
Point Landfill and the Seaboard Chemical sites to protect aquatic and human health
water quality standards in the proposed reservoir (that are necessary due to the
proposed reservoir, and would not be necessary if the reservoir was not proposed).
The Randleman alternative should also indicate the potential costs to build a water
treatment plant with the advanced technology necessary to treat the water quality
expected in this lake, e.g. GAC (activated carbon), membrane filters, auxiliary
treatment lagoons, etc. Such an advanced plant would not necessarily be required
for the other alternatives. A true and complete representation of costs presented is
necessary before it can be stated that Randleman Lake is "estimated to be the least
costly alternative by a substandal margin."
5. Pages 3-4 of the DEIS. it is stated that, "Contamination of groundwater in the
vicinity of the proposed reservoir has created some concern regarding potential .
imparts on water quality of the lake. Toxic substances from the abandoned
Seaboard Chemical Company and the Closed High Point Landfill, both of which
are located along the tipper Deep River adjacent to the proposed reservoir, have
contaairated the groundwater at each site. However, modeling studies have
prndic•.ed that contaminated grroundwater from these sites `should not have any
siQ*uficant impacts on the water quality of Randleman Lake'." This statement was
K2:, from e: *lier modr:in_ results of several Black & Veatch studies dating back: to
1991.
DWQ hz reviewed comments made by BillMeyer vith the Division of Waste
'1ana2:-nent (dated 8/26197) on this DEIS. DR.k4 states that they believe "the
cohta .ina_*;t loading to the Deep River is substantially higher" (yet un-quantified),
t?:z^. t,'-.at mod--ied by Black and Veatch.
The Special Order for c?eanup of these sites (which was recently published in the
NC Re?ster) indicates knov-a releases of hazardous substances on the sites. Soils
tes-z h.2a;e revealed the presence of volatile and semi-volatile organic compounds,
incIL`+''.'in2 but not limited to acetone, 1,2-dichlorobeazene, 1,1-dichloroethene, 1,2-
dichloroe•.hene (total), methylene chloride, 1,1,1-trichloroethane, phenol,
naphLahtene, bis-2 ethyl hexyl phthalate, and 1?," trchlorobenzene.
G.-oundwater ;F---pas! (separate from the current testing being performed for the
R--mediation Investigation), revealed the presenm of volatile and semi-volatile
or?a-:ic compounds, inc:uding but not limited to =tone, benzene, 1,1-
dic :Ior,,-_thane, 1,2- dic:.loroethane, 1,1-dichloroethene, 1,2- dichloroethene
chloride, 1,1,1-t6chloroethane, phenol, and naphtahlene.
T e ie on tree c nrent DEIS indicates that the results of the Remedial
L? :e?-,:a:r.iGn will not be available until February, 1998. The potential toxicant
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 2
Regional / Program Management Coordination Branch Comments on DEIS
1. The DEIS states that Randleman Lake would be expected to violate the state water
quality standard for chlorophyll a (40 mg/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 Eastside
WWTP discharging effluent of total phosphorous of 0.5 mg/l, nuisance algal
blooms are still predicted to occur 70-80 % of the time in the upper Deep River arm,
and violations of the water quality standard for chlorophylla are still anticipated to
occur throughout the proposed lake, due to point and non-point sources of nutrients
in the watershed.
In response to this prediction of eutrophication in the future reservoir, the DEIS
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
state in-stream and in-lake water quality standards (see 15A NCAC 2B .0211) that
require consideration of other potential uses of the reservoir, including aquatic life
propagation and survival, fishing, wildlife, secondary recreation (wading and
boating), and agriculture.
The Division has found that the Deep River currently exhibits consistent problerris
associated with elevated nutrient loading such as nuisance algal blooms and low
dissolved oxygen (DO). The Division is seriously concerned that impoundment of
the river will tend to exacerbate these existing eutrophic conditions, potentially
leading to extensive algal blooms, low dissolved oxygen, common occurrence of
fish kills, reduction of fish stocks, decrease in the diversity of fisheries, taste and
odor problems in the drinking water (even after treatment), and reduced
opportunities for human recreation on the lake.
2. An explanation should be provided in the EIS addressing specifically which
alternatives under review in this DEIS differ from the alternatives discussed for the
prior EIS (dated 1991, prepared by the NC Division of Water Resources). Also,
the EIS should discuss why the selection of alternatives for the project has changed.
3. Alternative A, the Upper Deep River Lake, is proposed to flood parts of the
Seaboard Chemical Company, High Point Landfill and High Point Eastside WWTP
sites. Therefore, due to the potential environmental impacts of hazardous waste
leaching from these buried sites into the reservoir and the cost to relocate the
existing Eastside Plant, this alternative was deemed unacceptable in the EIS. The
EIS should either consider a redesign of this alternative so that flooding of these
sites would not occur, or discuss why this alternative cannot be redesigned to avoid
flooding these sites. Obviously, if this alternative was not designed to flood these
sites, the acceptability of that alternative may be substantially greater, both in tetras
of reduced costs (especially the $64 million to relocate the High Point Eastside
WWTP) and fewer potential environmental/ health (toxicant) impacts.
4. On pages 1-5 and 1-6 of the document, the reasons that the Randleman Dam
proposal is considered the preferred alternative are discussed. One of the
mentioned items was cost The conclusion that the Randleman alternative is least
costly does not take into consideration the issue mentioned in item 2. If the
State of North Carolina .
Department of Environment,
Health and Natu al Resources 4 0 •
Division of Water Quality
James B. Hunt, Jr., Governor C3 E H N F=?
Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director
September 30, 1997
M MORANDLT1
TO, Melba McGee
FROM: Michelle S uverkrubbe -
THROUGH: A. Preston Howard, Jr., P.E.
RE: Comments on SCH # 98-0029; DWQ#11686
Piedmont Triad Regional Water Authority (P'IRWA)
Randleman Lake DEIS
Randolph and Guilford Counties
The proposed project consists of a Draft Environmental Impact Statement (DEIS)
on the Section 404 Permit prepared by the Army Corps of Engineers for the DRaandlem also
Lake project for Piedmont Triad Regional Water ui u issuing aSection 401 Water Quality
be used by the Division of Water Quality (D Q) g
Certification for the project.
The project entails discharging dredged or fill materials into waters of the US and
their contiguous wetlands. The proposed water supply reservoir will inundate 28 miles of
free-flowing streams, impact approximately 121 acres of Section 404 jurisdictional
wetlands, and inundate 3,000 acres of forest, agricultural and residential land.
The Division has reviewed the DEIS. As you will note, the Division is very
concerned about the future water quality in the proposed reservoir. The Division,
however, is prepared to issue a 401 Water Quality Certification on this project, subject to
the condition that PTRWA develop (with DWQ's assistance) a Nutrient Reduction Strategy
and Watershed Management Plan for the Randleman Lake Watershed.
This Strategy and Plan will need to determine the level of nutrient reduction
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
Strategy and Plan will also need to define the specific management strategies necessary to
achieve the nutrient reductions, and demonstrate how these necessary reductions will be
accomplished and sustained into the future for the watershed. This Management Plan and
Nutrient Strategy will nerd to be approved and put
rior tothe (reclassification i.e. local government
ordinances adopted and effective, if necessary) Randleman `Watershed for Water Supply purposes. 919 P.C. Ecx 295-5, Raleigh, North Carolina 27626-0535 Telephone 19-733 post-cons
umer paper-715-5637
An ?? ai Cppcrunity Affirmative Action Employer 50% Y
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 3, 1997
&4 10 ;e
ID E-= F=1
MEMORANDUM
TO. Melba McGee FILE COPY
FROM: Michelle Suverkrubbe
RE: Clarification on Comments on SCH # 98-0029; DWQ#11686
Piedmont Triad Regional Water Authority (PTRWA)
Randleman Lake DEIS
Randolph and Guilford Counties
. The original memorandum from DWQ on this project (dated 9/30/97) contained a
statement that needs to be clarified. Item number 4 on page 3 (second paragraph) contained
the following statement:
"The Randleman alternative should include estimated costs to remediate and clean
up the groundwater from the High Point Landfill and the Seaboard Chemical sites
to protect aquatic and human health water quality standards in the proposed
reservoir (that are necessary due to the proposed reservoir, and would not be
necessary if the reservoir was not proposed)."
The Division meant that for the Randleman alternative, the DEIS should explain the
difference between what it would cost to remediate the Landfill and Seaboard sites with,
and without, the proposed reservoir, given the different levels of groundwater clean-up that
may be necessary under each scenario to meet applicable water quality standards. The
DEIS should provide a discussion of the differences (both economically and
environmentally) between the level of groundwater clean-up that would be required if the
reservoir was not built (it remained in a riverine setting, and no water reservoirs or intakes
were planned adjacent to the sites) and what specific additional clean-up measures would be
necessary under the Randleman Lake public water supply reservoir scenario.
I hope this provides adequate clarification. Please pass this on to the
Clearinghouse and the project applicant. I can be reached at [phone], ext. 567 if
they should have any questions.
Thank you.
mis:1980029 Randleman Clarification
cc: DWQ staff
DEH - Public Water Supply
PTRWA - Mr. John Kime
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
State of North Carolina
Department of Environment,
Health and Natural Resources ` • •
Division of Water Quality ON
James B. Hunt, Jr., Governor ?•? H
E
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
October 13, 1997
MEMORANDUM
TO: Melba McGee
FROM: Michelle Suverkrubbe/L`-S
THROUGH: Coleen Sullins
RE: Comments on SCH # 98-0134; DWQ #11742
PTRWA - Randleman Water Mains and Facilities - EA Scoping
Randolph and Guilford Counties
The above EA scoping request applies to a proposed water line project associated with the
Randleman Lake Reservoir project. The project will include construction of 13.5 miles of 16 to 48-
inch diameter water mains, a 250,000 gallon elevated storage tank, a 2 million gallon ground
storage tank, and a 2,220 gallon per minute package booster pumping station. The protect will
supply treated water from the proposed Randleman Lake Water Treatment Plant to various areas in
Randolph County and the municipalities of Randleman, Archdale, Greensboro and High Point.
The Division is very concerned about the future water quality in the proposed Randleman
Reservoir (see attached comments), especially increases in nutrients from point and non-point
sources as a result of the urbanization to be served by this proposed water line. The Nutrient
Reduction Strategy and Watershed Management Plan PTRWA will be developing as a condition of
its 401 Certification should contain adequate measures to resolve these issues. However, because
this proposed water line project could be dramatically affected by the final design of the proposed
ne project
reservoir and the location and design of the proposed water treatment plant, this water li
should not be allowed to move forward without those other aspects of the project being finalized.
The Division therefore
an Lake Water areatme Treatment Plants EA/FONSII and the Randleman Lake Reservoir
both the Randleman
FEIS/ROD are approved by the Clearinghouse.
Regarding the content of the EA for the water line project, the applicant should be made
aware of the necessity to follow the requirements for the general certification for Nationwide
Permit 12 - Utility Lines by the Army Corps of Engineers when disturbing wetlands for water or
sewer utility line construction activities. Deviations from the General Certification will require a
formal application for a Section 401 Water Quality Certification from our Division. See attached
401 handout for more information. If the applicant should have any questions on wetland impacts
or the 401 Certification process, please direct them to John Dorney, Ecological Assessment Group,
at 919-733-1786.
I can be reached at 919-733-5083, ext. 567 if there are any questions.
misA 980134 Randleman Water Lines
cc: DWQ staff
attached: Randleman DEIS memos
401 handout
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
State of North Carolina
Department of Environment
and Natural Resources
Legislative & Intergovernmental Affairs
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Richard E. Rogers, Jr., Director
MEMORANDUM
TO: Chrys Baggett
State Clearinghouse
FROM: Melba McGee
Environmental Review Coordinator
RECEIVE
CCI 2 2
EMITA
RE: 98-0134 Scoping Piedmont Triad Regional Water Authority,
Transmission Mains, Guilford and Randolph Counties
DATE: October 15, 1997
The Department of Environment and Natural Resources has completed its
review of the proposed project. The attached comments identify information that
our review agencies would like for the applicant to consider and address if this
project is to proceed.
The proposed water transmission mains are intended to deliver water from the
proposed Randleman Reservoir and the proposed water treatment plant, which is
presently being reviewed under DENR's internal review process. Generally
speaking, these projects cannot function without the approval of the Randlemar.
Reservoir. In our Randleman Reservoir project comments dated October 2, 1997,
major emphasis was placed on the future water quality of the reservoir. Our
agencies also identified a number of other deficiencies with the DEIS and askec
that the Corps of Engineers not approve the project until additional efforts
could be made in resolving agency concerns.
Since the two referenced projects seem to center around the Randleman Reservoix
proposal being approved, the department believes that its too premature tc
specifically respond to this proposal. Therefore, it is recommended that the
Peidment Triad Authority not move forward too quickly in developing further
environmental documentation without final approval of the Randleman Reservoir
project. Final concurrence with this project would not be warranted until our
concerns were satisfactorily addressed and appropriate conditions were
implemented in the proposed Randleman Reservoir project. Again, our primary
interest at this time is to continue to communicate and work closely with the
Corps of Engineers and the Piedmont Triad Regional Water Authority staff sc
issues can be resolved in an efficient manner.
Thank you for the opportunity to respond.
attachments

PO Box 27687, Raleigh, North Carolina 27611-7687 - Telephone: [phone]
[DENR
If no woodland is to be impacted, then the document needs a clear statement that aQ woodland will be
impacted as a result of the entire project.
Efforts should be made to address the above items and to reduce impacts to woodland. We would hope that
the improvements would have the least impact to forest and related resources in that area.
pc: Mike Thompson, Warren Boyette - CO
Ken Jeffries - R2
Vic Owen - D10
Steve Pearce - Randolph County
File
DIVISION OF WATER QUALITY
August 26, 1997
MEMORANDUM
TO: Michelle Suverkrubbe
THROUGH: Ruth Swanek (2"
Coleen Sullins
FROM: Jason Doll
SUBJECT: Draft Environmental Impact Statement
Proposed Randleman Reservoir
U. S. Army Corps of Engineers (June, 1997)
The Technical Support Branch (TSB) has reviewed the Draft Environmental Impact
Statement (DEIS), prepared by the U.S. Army Corps of Engineers, in support of the
application by the Piedmont Triad Regional Water Authority for a permit pursuant to
Section 404 of the Clean Water Act. Throughout the history of the Randleman Reservoir
proposal, the TSB has maintained and regularly expressed concern with the predicted
eutrophic state of the impoundment and the resultant violations of water quality
standards. The current DEIS proposes little in the way of mitigative measures to address
eutrophication problems and fails to adequately support issuance of the necessary 401
water quality certification that must precede issuance of a Section 404 permit.
A Section 401 water quality certification should not be issued for the project until an
extensive watershed management plan is developed to mitigate the predicted eutrophic
state of the proposed impoundment. The current DEIS presents a shallow overview of
proposed watershed management measures aimed at reducing non-point source nutrient
loading from future development, but these measures will only reduce the increase in
loading caused by new development in the watershed. In light of the predicted eutrophic
state for Randleman under existing conditions, a detailed watershed management strategy
to reduce point and non-point source nutrient loading below existing levels is absolutely
necessary. The detailed strategy should be based on predicted estimates of the nutrient
load reductions, necessary to protect the daily maximum chlorophyl a standard of 40 ug/l,
as derived from an updated version of the Walker model or another water quality model
approved by the Division of Water Quality (DWQ). In its current state of development,
the Walker model is not adequate to stand alone as a decision making tool to support the
development of a comprehensive watershed management plan.
Once a comprehensive watershed management strategy is developed, the true cost of
the Randleman Reservoir should be re-evaluated including the costs of developing and
implementing the strategy. When considered in a more complete fashion, the revised cost
estimate for the project may directly affect the selection of a preferred alternative.
In its current state, the Walker model has predicted that with phosphorus
concentrations in the High Point - Eastside WWTP reduced to 1.0 mg/1, the resulting
mean chlorophyl a concentrations in the Deep River arm of the reservoir would be 75-85
ug/l, and concentrations would achieve nuisance levels over 80% of the time during the
growing season. The support document does not stipulate what is determined to be a
"nuisance level" for chlorophyl a, or how the stated frequencies were calculated. In real
world terms, these predictions represent a significant potential for regular and ongoing
occurrences of noxious algal bloom conditions in the reservoir. Algal blooms of the
severity suggested by the modeling are likely to cause substantial diurnal dissolved
oxygen fluctuations, which could result in periods of anoxia and fish kills. Problems of
this nature could seriously impair the uses of the reservoir beyond the intended water
supply purpose and would certainly constitute an outward public nuisance. In recent
incidents, North Carolina public heath officials have warned citizens to avoid swimming
or otherwise coming into contact with waters in the immediate area of a fish kill due to
potential health risks.
It should be noted that in order to predict the eutrophic conditions for the future
scenario, the model was run assuming a wastewater discharge of 20 MGD. The current
Environmental Assessment document for the expansion of the Eastside WWTP calls for
an expansion to 26 MGD, which may alter the outcome of the model. If Randleman is
constructed, the expanded water supply will likely promote further growth in the High
Point area and necessitate further expansions of the WWTP. The planning period utilized
to determine the expansion to 26 MGD for the WWTP is 20 years, but the planning
period for the reservoir is 50 years. A true simulation of future conditions should also
include expanded WWTP discharges representative of the longer planning period for the
reservoir.
The modeling report is not clear as to the time period from which the land use data
for the model is derived, and given that the model was developed prior to 1990, it is
likely that some of the inputs and assumptions are out of date. The report does concede
that, at the time of model development, for many areas the most recent data were already
several years old. The report also does not clearly explain what assumptions or
alterations were made in order to simulate the "future land use conditions" for which
model results are presented. The methods and assumptions utilized in developing the
various land use scenarios should be clearly presented in the report. Since initial model
development occurred some time ago, urban growth has likely caused significant land use
changes within the watershed that may render the assumptions and scenarios represented
in the model invalid. The validity of these assumptions should be re-evaluated, and the
model should be rerun with more up-to-date land use scenarios, as appropriate.
Confidence in the models input scenarios and output predictions would be greatly
enhanced if a working copy of the updated model were submitted to the DWQ with the
report.
Thank you again for the opportunity to comment on Draft Environmental Impact
Statement. Please let me know if I can be of any further assistance in this matter.
cc: Preston Howard
Steve Tedder
Don Safrit
Jimmy Overton
John Dorney
Larry Ausley
Steve Mauney
Judy Garrett
DECEIVED
SEP 0 5 1997
ENVIRONMENTAL SCIENCES
DIVISION OF WATER QUALITY
Winston-Salem Regional Office
MEMORANDUM
TO: Michelle Suverkrubbe
THROUGH: Steve Mauney
FROM: Ron Linville /
SUBJECT: Comments on Randleman Lake Draft EIS
DATE: 970818
RECEIVE[:
AUG 2 1 1997
FNVIRONMFN7/4LaGIENCES
The WSRO has reviewed the USACOE Draft EIS and provides the following comments
for your consideration.
The WSRO concurs with Jimmie Overton's comments as they are quite appropriate.
Specifically, the WSRO would like to emphasize that chlorphyll a is a concern of some
importance in potential eutrophication of the lake. The Water Authority should be advised of
this concern. As previously indicated in the Eastside WWTP expansion EA, the WSRO
continues to be concerned over secondary impacts from both projects which will occur from
increased higher density development due to the creation of the lake and expanded sewer
services to the lake area. As previously indicated in the High Point WWTP Expansion EA, all
the municipalities involved with planning associated with this lake should be required to go
above and beyond typical watershed protection by requiring developers to maintain preexisting
hydro graphic flows and by requiring stream and wetland buffers for all developments. No
additional streams or wetlands should be unnecessarily degraded, piped, filled or flooded in any
manner (intentional or unintentional sediment) around this lake. This may reduce the ultimate
density of development for various projects, but should provide for more open space zoning and
greater protection of surface waters. Local planning agencies should take the lead role in
minimizing wetland and stream impacts. No unnecessary 404/401s should be issued in this
watershed basin if the lake is built. All treated wastewaters, whenever possible, should be
returned to their basin of origin in order to support downstream flow regimes. Minimum
releases must have precedence over water utilization during drought conditions. Water
conservation measures must be implemented, especially in Greensboro.
The EIS indicates increased recreational opportunities but does not include hunting
specifically. Due to nuisance goose populations and the inability of the current animal damage
control measures to reduce populations, the authority should include legal hunting to avoid
exasperating conditions later from erosion and sanitation problems associated with non-migrating
geese. Mississippi has refused to relocate any more of these geese as they are now causing
problems in that state.
Page 2
Randleman EIS
The WSRO does not support the proposed option to build Benaja or Altamahaw Lakes
due to the unique character and functions of the floodplains and wetlands associated with those
areas. Mitigation for that area would likely be impossible. As Greensboro and High Point have
previously contributed significantly to conditions now found in the Deep River, it is appropriate
that they directly address current and future concerns for this watershed. It is very likely that
they will redouble their efforts to provide better wastewater treatment and water quality
preventive measures to protect the watershed from which they will withdraw their own drinking
water. The DWQ should emphasize that the state's watershed protection guidelines are
minimums and not optimum guidelines. Again, the WSRO would encourage optimal protection
measures instead of the state minimum due to the magnitude of current concerns and the
opportunity to avoid preventable future secondary impacts (please see High Point EA comments
previously submitted).
cc: WSRO
Central Files
Jimmie Overton
John Dorney

DIVISION OF WATER QUALITY
Winston-Salem Regional Office
MEMORANDUM
TO: Michelle Suverkrubbe
THROUGH: Steve Mauney
FROM: Ron Linville /
SUBJECT: Comments on Randleman Lake Draft EIS
DATE: 970818
The WSRO has reviewed the USACOE Draft EIS and provides the following comments
for your consideration.
The WSRO concurs with Jimmie Overton's comments as they are quite appropriate.
Specifically, the WSRO would like to emphasize that chlorphyll a is a concern of some
importance in potential eutrophication of the lake. The Water Authority should be advised of
this concern. As previously indicated in the Eastside WWTP expansion EA, the WSRO
continues to be concerned over secondary impacts from both projects which will occur from
increased higher density development due to the creation of the lake and expanded sewer
services to the lake area. As previously indicated in the High Point WWTP Expansion EA, all
the municipalities involved with planning associated with this lake should be required to go
above and beyond typical watershed protection by requiring developers to maintain preexisting
hydrographic flows and by requiring stream and* wetland buffers for all developments. No
additional streams or wetlands should be unnecessarily degraded, piped, filled or flooded in any
manner (intentional or unintentional sediment) around this lake. This may reduce the ultimate
density of development for various projects, but should provide for more open space zoning and
greater protection of surface waters. Local planning agencies should take the lead role in
minimizing wetland and stream impacts. No unnecessary 404/401s should be issued in this
watershed basin if the lake is built. All treated wastewaters, whenever possible, should be
returned to their basin of origin in order to support downstream flow regimes. Minimum
releases must have precedence over water utilization during drought conditions. Water
conservation measures must be implemented, especially in Greensboro.
The EIS indicates increased recreational opportunities but does not include hunting
specifically. Due to nuisance goose populations and the inability of the current animal damage
control measures to reduce populations, the authority should include legal hunting to avoid
exasperating conditions later from erosion and sanitation problems associated with non-migrating
geese. Mississippi has refused to relocate any more of these geese as they are now causing
problems in that state.

Page 2
Randleman EIS
The WSRO does not support the proposed option to build Benaja or Altamahaw Lakes
due to the unique character and functions of the floodplains and wetlands associated with those
areas. Mitigation for that area would likely be impossible. As Greensboro and High Point have
previously contributed significantly to conditions now found in the Deep River, it is appropriate
that they directly address current and future concerns for this watershed. It is very likely that
they will redouble their efforts to provide better wastewater treatment and water quality
preventive measures to protect the watershed from which they will withdraw their own drinking
water. The DWQ should emphasize that the state's watershed protection guidelines are
minimums and not optimum guidelines. Again, the WSRO would encourage optimal protection
measures instead of the state minimum due to the magnitude of current concerns and the
opportunity to avoid preventable future secondary impacts (please see High Point EA comments
previously submitted).
cc: WSRO
Central Files
Jimmie Overton
John Dorney

State of North Carolina
Department of Environment,
Health and Natural Resources • •
Division of Water Quality A&14
AR
James Hunt, Governor ED E
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
August 20, 1997
Mr. John Kime
Piedmont Triad Water Authority
Wilmington Building
2216 West Meadowview Road
Suite 217
Greensboro, NC 27407-3480
Dear Mr. Kime:
Re: 401 Water Quality Certification
Randleman Reservoir
Guilford and Randolph Counties
DWQ #970022, COE #199102669
On 11 July 1997 we were notified of your request for 401 Water Quality Certification
for your project to flood about 120 acres of wetlands for construction of the Randleman
Reservoir at Deep River near the town of Randleman in Guilford and Randolph Counties.
We believe that this project is currently under review by the State Clearinghouse. DWQ
cannot issue the 401 Certification until the project has received a Finding of No Significant
Impact (FONSI) or Record of Decision (ROD) from the State Clearinghouse in accordance
with NCAC 15A: 01C .0402. Therefore, I must hereby place this project on indefinite
hold until the State Clearinghouse has issued the FONSI or ROD. However we will
continue to review the project and make you aware of any concerns. You should notify us
that the NEPA process is complete so we can reactivate the project. In addition, by copy of
this letter, I am also notifying the U.S. Army Corps of Engineers that this project should be
placed on hold.
If you believe that this decision is in error, please call me at 919-733-1786 to discuss
the matter.
Sincerely,
I J hn R. Donne
ater Quality fication Program
cc: Winston-Salem DWQ Regional Office
U.S. Army Corps of Engineers Wilmington District Office
Michelle Suverkruebbe; DWQ Planning
Central Files 970022.nocert
Division of Water Quality - Environmental Sciences Branch
4401 Reedy Creek Rd., Raleigh, NC 27626-0535 - Telephone [phone] - FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper

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State of North Carolina
Department of Environment,
Flealth and Natural Resources `
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary p E H N
A. Preston Howard, Jr., P.E., Director
September 30, 1997
MEMORANDUM RECEI VEG
TO: Melba McGee fit' L' ,? 199,
FROM: Michelle Suverkrubbe -,NVI R0N%Nr4L8C1ftFs
THROUGH: A. Preston Howard, Jr., P.E.
RE: Comments on SCH # 98-0029; DWQ#11686
Piedmont Triad Regional Water Authority (PTRWA)
Randleman Lake DEIS
Randolph and Guilford Counties
The proposed project consists of a Draft Environmental Impact Statement (DEIS)
on the Section 404 Permit prepared by the Army Corps of Engineers for the Randleman
Lake project for Piedmont Triad Regional Water Authority (PTRWA). The DEIS will also
be used by the Division of Water Quality (DWQ) in issuing a Section 401 Water Quality
Certification for the project.
The project entails discharging dredged or fill materials into waters of the US and
their contiguous wetlands. The proposed water supply reservoir will inundate 28 miles of
free-flowing streams, impact approximately 121 acres of Section 404 jurisdictional
wetlands, and inundate 3,000 acres of forest, agricultural and residential land.
The Division has reviewed the DEIS. As you will note, the Division is very
concerned about the future water quality in the proposed reservoir. The Division,
however, is prepared to issue a 401 Water Quality Certification on this project, subject to
the condition that PTRWA develop (with DWQ's assistance) a Nutrient Reduction Strategy
and Watershed Management Plan for the Randleman Lake Watershed.
This Strategy and Plan will need to determine the level of nutrient reduction
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
Strategy and Plan will also need to define the specific management strategies necessary to
achieve the nutrient reductions, and demonstrate how these necessary reductions will be
accomplished and sustained into the future for the watershed. This Management Plan and
Nutrient Strategy will need to be approved and put in place (i.e. local government
ordinances adopted and effective, if necessary) prior to the reclassification of the
Randleman Watershed for Water Supply purposes.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 106% post-consumer paper
NP. #98-029
Ileman DEIS
? Comments
2
The DEIS states that Randleman Lake would be expected to violate the state water
quality standard for chlorophyll a (40 mg/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
I% of the time near the drinking water intake. Even with the High Point Eastside
WWTP discharging effluent of total phosphorous of 0.5 mg/l, nuisance algal g
blooms are still predicted to occur 70-80 % of the time in the upper Deep River arm,
and violations of the water quality standard for chlorophyll a are still anticipated to
occur throughout the proposed lake, due to point and non-point sources of nutrients 1
in the watershed.
In response to this prediction of eutrophication in the future reservoir, the DEIS
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
state in-stream and in-lake water quality standards (see 15A NCAC 2B .0211) that
require consideration of other potential uses of the reservoir, including aquatic life
propagation and survival, fishing, wildlife, secondary recreation (wading and
boating), and agriculture.
The Division has found that the Deep River currently exhibits consistent problems
associated with elevated nutrient loading such as nuisance algal blooms and low
dissolved oxygen (DO). The Division is seriously concerned that impoundment of
the river will tend to exacerbate these existing eutrophic conditions, potentially
leading to extensive algal blooms, low dissolved oxygen, common occurrence of
fish kills, reduction of fish stocks, decrease in the diversity of fisheries, taste and
odor problems in the drinking water (even after treatment), and reduced s
opportunities for human recreation on the lake. to
i
An explanation should be provided in the EIS addressing specifically which
alternatives under review to this DEIS differ from the alternatives discussed for the
prior EIS (dated 1991, prepared by the NC Division of Water Resources). Also,
the EIS should discuss why the selection of alternatives for the project has changed.
Alternative A, the Upper Deep River Lake, is proposed to flood parts of the
Seaboard Chemical Company, High Point Landfill and High Point Eastside WWTP
sites. Therefore, due to the potential environmental impacts of hazardous waste is
leaching from these buried sites into the reservoir and the cost to relocate the
existing Eastside Plant, this alternative was deemed unacceptable in the EIS. The 2-
EIS should either consider a redesign of this alternative so that flooding of these
sites would not occur, or discuss why this alternative cannot be redesigned to avoid
flooding these sites. Obviously, if this alternative was not designed to flood these
sites, the acceptability of that alternative may be substantially greater, both in terms
of reduced costs (especially the $64 million to relocate the High Point Eastside
WWTP) and fewer potential environmental/ health (toxicant) impacts.
On pages 1-5 and 1-6 of the document, the reasons that the Randleman Dam
proposal is considered the preferred alternative are discussed. One of the
mentioned items was cost. The conclusion that the Randleman alternative is least
costly does not take into consideration the issue mentioned in item 2. If the
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 4
impacts to the water quality of Randleman Lake should be reevaluated upon receipt
of the February Remedial Investigation Report.
6. On page 3-28, the DEIS states that, for Randleman Lake "watershed protection
measures have been in place for more than eight years." Also, on page 3-29 it is
stated that "... other alternatives involve Rockingham and Alamance Counties,
which do not have watershed protection ordinances." Both of these statements are
misleading.
The Division manages the Water Supply Watershed Program for the state and our
records indicate the correct statements should be:
(Page 3-28) - "For the Randleman Lake watershed, 86% of the watershed is
currently protected under water supply watershed protection programs by local
governments - Randolph County (which comprises 37% of the watershed),
Guilford County (47%), and Greensboro (2%). The municipalities of Archdale,
which makes up 6% of the watershed, and High Point (8%), Jamestown (M), and
Randleman (I %) are = currently implementing any water supply watershed
protection programs for the Randleman Lake watershed, although they may have
watershed protection ordinances that require protection of other watersheds in their
jurisdictions."
(Page 3-29) - "Rockingham and Alamance Counties both have adopted watershed
protection ordinances which protect approved water supply watersheds in their
jurisdictions; however, neither have yet adopted protections for any of the
alternatives discussed in this EIS, including the Randleman alternative."
(Pages 5-24 and 25) - It is accurately stated that Guilford and Randolph Counties
have enacted watershed protection ordinances, but they fail to mention the fact that
Greensboro also currently protects the Randleman watershed.
In addition to amending these above sections, the EIS should provide an
explanation for why the municipalities listed have not chosen to enforce watershed
protection provisions in the Randleman Watershed.
7. Table 10, page 3-16 discusses surface water evaluation criteria for each alternative.
This table should include a criteria for whether or not each alternative would meet
state water quality standards (including protecting aquatic life, recreational, and
water supply uses). -
8. The Corps should refer back to DWQ's letter to PTRWA on January 24, 1997 for
specific comments on the wetlands aspects of this project and mitigation proposed
by PTRWA.
mis:\980029 Randleman EIS
7arachaw-M
cc: DWQ staff
DEH - Public Water Supply
PTRWA - Mr. John Kime
Randleman Lake DEIS
Guilford/Randolph Counties
October 1, 1997
be located." The aquatic and fisheries resources will be present throughout the reservoir
proper. High bacterial and nutrient levels can increase the incidence of disease epidemics
and localized fish kills. High metal and chemical concentrations could bioaccumulate
and lead to fish consumption advisories. The DEIS primarily addresses the potential poor
water quality in the reservoir from a drinking water perspective, however, it does not
address the adverse impacts of the poor water quality, hazardous waste and heavy metals
on fisheries and recreation. A thorough discussion on the potential impacts on fish and
recreation should be provided. Include in this discussion the expected bioaccumulation
of chlorinated hydrocarbons, heavy metals and other hazardous wastes in predatory fish,
such as largemouth pass, crappie and catfish, and if the fish would be expected to be safe
for human consumption.
2. In a previous memo dated June 5, 1996 (Owen F. Anderson; Wetland and Habitat
Mitigation Plan for Randleman Lake), we questioned the statement, However, most fish
in the area are adaptable to the lake environment and overall species composition should
not change drastically." (Section 5.3. 10) Many of the species collected in the surveys are
characteristic of stream habitats and will be extirpated from the areas inundated by the
reservoir. Of the 34 species listed in Table 19 (pg 4-17), only one-half will be able to
readily adapt to a reservoir environment. This adverse impact should be clarified.
3. To help mitigate the loss of stream habitat for those species within this reach of the Deep
River, it is essential that free flowing reaches up and downstream of this reservoir be
maintained in a high quality state. Forested stream buffers and wetland mitigation will
help protect water quality in upstream reaches; however, water quantity could be a
limiting factor, especially during low flow periods. Therefore, to help mitigate the loss of
habitat for riverine species, it is requested that a minimum release be established for Oak
Hollow and High Point lakes according to the Division of Water Resources procedures to
protect and enhance aquatic habitat. A significant minimum release may also provide
enough water quality improvement to prevent or reduce fish kills in the upper arm of
Randleman Lake during severe environmental conditions.
4. Section 4.3. 10 states that the existing Deep River fishery is "not unique or particularly
diverse. "Although the Deep River fishery is typical of a Piedmont stream, it should be
noted that the newly created reservoir fishery would certainly not be considered "unique
or particularly diverse" either. Actually 34 species within the project streams represents
relatively high diversity, especially when compared with a Piedmont reservoir.
Additionally, in the Greensboro/High Point area alone, reservoir fisheries can be found in
Oak Hollow, High Point, Higgins, Brandt and Townsend lakes. Therefore, the Deep
River could be considered relatively diverse and unique. We request that this reasoning
for destroying stream habitat for a reservoir because it is "not unique or diverse" be
deleted or reworded so that it is not misleading to the public.
Section 4.3. 10 also states that "the degraded, and in places depauperate, fishery currently
existing at the project site is not a resource of significant value." We believe the
degraded fishery is mostly due to poor water quality, not poor aquatic habitat. The
Division of Water Quality (DWQ) rated the streams of the area only fair to good-fair in
1993 for benthic invertebrates and fish Community Structure in Muddy Creek rated only
fair-good in 1994. DWQ attributed decreased fish abundance to urban stormwater runoff.
The Deep River between High Point City Lake to approximately the Guilford County line
is designated as only partially supporting its uses. Lower reaches are designated support
threatened. We believe upstream discharges from point and non-point sources have
degraded the water quality in this section of the river, which has affected the quality of
the fishery. Improvements in water quality would likely result in a greater diversity and
abundance of fish. Destroying stream habitat because the water quality is poor should not

Randleman Lake DEIS 4 October 1, 1997
Guilford/Randolph Counties
be used to downplay the adverse impacts of the reservoir; therefore, we request that this
section also be reworded.
6. Section 5.3. 10 states "Relative to the present degraded fishery of the project area, the
future fishery of the lake is expected to be a substantial improvement." We question the
validity of this statement. As stated above, the DEIS does not address what impact high
levels of bacteria, chlorophyll a, heavy metals and hazardous chemicals will have on the
reservoir fishery, particularly in the upper lake sections. The projected water quality in
this reservoir may lead to fish lesions and periodic fish kills in the upper arms of the lake
and make management of the fishery difficult. This section should be reworded to reflect
the potential for a poor fishery.
7. Section 5.3.5.8, regarding interbasin transfers, states: "These transfers, which would
occur in the form of treated wastewater, could affect the dependability of water quality
and water supply storage of Jordan Lake through adverse impacts on nutrient and
dissolved oxygen levels in the lake." Sedimentation directly destroys aquatic habitat and
is one of the largest problems facing reservoirs. Development facilitated by this
interbasin transfer, is likely to lead to increased sediment loading in the Haw River..
Provide clarification on the impacts of sedimentation on B.E. Jordan Reservoir.
8. The DEIS does not address what measures, if any, have been planned to minimize a
WWTP bypass, overflow or spill. Untreated wastewater has a high biological oxygen
demand and can result in a fish kill due to decreased dissolved oxygen levels. Since
power failures at wastewater treatment plants from catastrophic events (e.g., hurricanes)
would cause a catastrophic impact in the lakes, it is requested that any wastewater
treatment facilities that discharge into Randleman Lake or the Haw River be equipped
with emergency generators (fit dual feed power) to maintain the wastewater treatment
works during power outages.
9. In Section 4.3.9, Wildlife Resources, the habitat values appear to be downplayed. While
the habitat has been degraded primarily as a result of the proposed reservoir, the
remaining habitat and the forest habitat that would develop could have significant
wildlife value. There are a number of birds and mammals that would be expected to use
the mosaic of habitats. Information should be included on the numbers and species of
birds and mammals that are known or expected to inhabit the project area. A number of
neotropical birds might breed in the area or use the area during migration and are of
special interest.
10. We concur with leaving forested buffers along streams in the reservoir pool until just
before dam closure. This measure should reduce impacts from erosion and
sedimentation. Provide the width of forested buffers to be left along the streams within
the reservoir pool.
11. According to the document a significant amount of clear-cutting has occurred in response
to the proposed project and wildlife habitat values have been diminished. The project
sponsors propose to allow the clear-cuts and pastures to undergo natural succession. To
mitigate for the loss of forested habitat caused by the reservoir and the clear-cutting that
has occurred in response to the reservoir, it is recommended that open agricultural lands
and clear-cut areas be planted with high quality hardwoods that are beneficial to wildlife.
Oaks, hickories, black gum, dogwood and other mast producing trees are examples of
species that should be planted.
12. Provide clarification on how water quality problems in B.E. Jordan Reservoir will be
mitigated by operation and management of Jordan Dam. Low flow and drought periods,
Randleman Lake DEIS
Guilford/Randolph Counties
October 1, 1997
when a significant amount of the water in the Haw River will be effluent, are of special
concern. Include a discussion of expected adverse impacts on fish and recreation within
Jordan Reservoir.
13. In section 4.3.5.2, it is stated that at a permitted flow of 16 mgd, the High Point Eastside
WWTP will comprise 70 percent of the flow in the Deep River. At what river flow will
effluent make up 70 percent of the flow and what percentage of the flow will be effluent
when the High Point Eastside WWTP reaches the proposed expansion capacity of 26
mgd?
14. Clarify the wording in section 5.8.3, concerning stocking of fish by NCWRC, to reflect
the problematic management and recreational opportunities and potential public health
advisories that may result from the poor water quality as it relates to the lake's fishery.
15. It is our understanding that High Point, Jamestown and Archdale do not currently have
stormwater regulations in place. It is recommended that these communities by required
to implement water supply stormwater regulations to help address the severe water
quality problems. It is further recommended that these communities make a commitment
to protecting area streams with riparian buffers through purchase or conservation
easement.
16. Include the number of river miles that will be protected by the Cone Folly preservation
site.
In summary, our main concern is poor water quality and its impact on the reservoir
fishery. The DEIS does not adequately address water quality problems from a fisheries and
recreation perspective, especially in the upper reaches of the reservoir. It has come to our
attention that the High Point water supply reservoirs (High Point and Oak Hollow) do not have a
minimum release. Developing a minimum release schedule for these reservoirs could potentially
improve water quality in the upper reaches of Lake Randleman and provide additional fisheries
habitat in the Deep River between High Point City Lake and Randleman Reservoir by
augmenting flows. Additionally, we believe there are opportunities for the sponsors to provide
mitigation in the way of protecting riparian areas both in the Deep and Haw River basins that
would help address water quality problems related to this project.
Thank you for the opportunity to review this DEIS. If we can provide further assistance
or clarification of these comments, please contact our office at [phone].
SB/OFA/ofa
cc: Kevin Moody, Biologist, USFWS
Coleen Sullins, Division of Water Quality
4 hn Dorney, Division of Water Quality
Michelle Suverkrubbe, Division of Water Quality
Jim Mead, Division of Water Resources
Steve Hall, Natural Heritage Program
Bill Meyer, Division of Solid Waste

0z North Carolina Wildlife Resources Commission 0
512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733-3391
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: Melba McGee,
Office of Legislative t rgo rnmental Affairs
FROM: Owen F. Anderson, Piedmont Region Coordinator
Habitat Conservation Program
THROUGH: Franklin T. McBride, Program Manager
Habitat Conservation Program 1
%J1
e4 7
Ppy??l9! I99J
DATE: October 1, 1997
SUBJECT: Draft Environmental Impact Statement (DEIS) for Randleman Lake, Guilford and
Randolph Counties, North Carolina, 98-0029
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) have
reviewed the subject document. Our comments are provided in accordance with provisions of
the National Environmental Policy Act (42 U.S.C 4332(2)(c)), the Clean Water Act of 1977 (33
U.S.C. 466 et seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661 et seq.).
The Piedmont Triad Regional Water Authority proposes to construct Randleman Dam
and Reservoir on the Deep River approximately two miles upstream of the Town of Randleman
in Randolph County. The reservoir will destroy 2,100 acres of forest habitat and 868 acres of
open field/agricultural habitat, 28 miles of free flowing stream and 121 acres of wetlands. Long
term direct and indirect impacts to fish and wildlife habitat will be significant.
Our staff have been involved with this project for greater than 20 years. Over this period
of time we have expressed concerns about the significant adverse impacts to fish and wildlife
resources and their respective habitats.
In 1991, NCWRC found the State Environmental Impact Statement to be inadequate and
did not concur with the content of the document. The inadequacies, such as surveys for fish and
wildlife resources, were to be included in the Federal Environmental Impact Statement.
Most of the controversy revolves around the current poor water quality of the stream to
be impounded that is expected to produce a reservoir with poor water quality and a degraded fish
community. Additionally, an interbasin transfer is proposed, which has the potential to
exacerbate problems with water quality and fish communities in the Haw River and Jordan
Reservoir.

Randleman Lake DEIS 2 October 1, 1997
Guilford/Randolph Counties
Considering the controversy surrounding the poor water quality, the DEIS does a
relatively good job of addressing the adverse impacts. Some additional surveys were completed
for fish and reptiles. However, considering the rather serious adverse environmental impacts that
could result from this project, we believe there are a number of items that still need to be
addressed. The DEIS does not do a good job of addressing impacts on fish and recreation.
Additionally, there is little discussion of secondary and cumulative impacts from this project.
According to the Division of Waste Management (Memo, Bill Meyer to Melba McGee
August 1997), there are a number of unresolved issues concerning the Seaboard Chemical site
and landfills in or at the edge of the reservoir pool. The toxic mixtures at the Seaboard site are
apparently more complex than indicated by previous studies. A remediation study is due to be
completed during 1998. Also, there are potential problems with leachate containing toxic
substances from the High Point landfill that would flow into the proposed reservoir.
We also are very concerned about the potential adverse impacts from additional effluent
that will be discharged to the Haw River as a result of this project. The additional effluent has
the potential to exacerbate declining water quality within Jordan Reservoir. The DEIS states that
the potential effects of interbasin transfer from Randleman Lake cannot be estimated until the
State completes its pending water reallocation modeling studies, which are scheduled to be
finished sometime in 1998.
Given the high probability of poor water quality conditions and the fact that several
important studies have not been completed, we believe the submission of this DEIS is premature.
We cannot complete review and concur with a project prior to the completion of these studies
and inclusion of the results in the revised DEIS.
We concur with the wetland mitigation that has been proposed; however, we believe it
still is somewhat minimal regarding the mitigation of losses of free flowing streams.
Establishing minimum releases from High Point City Lake and protecting additional stream
reaches in the area with forested buffers by purchase or conservation easement are recommended.
Streams flowing to the Haw River also should be considered, since water quality in this basin
will be adversely impacted as a result of this project.
Our comments focus primarily on fish and wildlife resources and mitigation of adverse
impacts. We request that the following items be addressed in the revised DEIS.
Water quality in the! reservoir is of concern because of effluent from the Eastside
Wastewater Treatment Plant(WWTP), leachate from the abandoned Seaboard Chemical
facility, the High Point landfill and Randleman dump and stormwater runoff from an
urbanized landscape. The North Carolina Division of Environmental Management
conducted studies in 1992-93 to measure existing water quality in the Deep River
(Section 4.3.5.2). "These studies identified a number of concerns, including high
bacterial levels; metals concentration higher than action levels for copper, zinc, and iron;
a few dissolved oxygen concentrations below the water quality standard of 4.0 mg/l;
violations of the water quality standard for lindane and dieldrin; and elevated nutrient
levels." Section 5.3.5.5 states "During the growing season, chlorophyll a concentrations
were predicted to exceed the 40 ppb standard about 12 percent of the time for the
reservoir as a whole, over 80 percent of the time in the Deep River I sub-basin, and about
1 percent of the time near the proposed water intake location (Black and Veatch, 1990)."
Section 1.5 states "Substances from any of these sources could enter the upper end of the
lake... Concentrations of pollutants would be greatly reduced during the time required
for water to travel to the downstream end of the lake where the water supply intake would
N N o
State of North Carolina
Department of Environment,
Health and Natural Resources A?jO2
Division of Water Quality
James B. Hunt, Jr., Governor AdMftMd0WWWK
Wayne McDevitt, Secretary ID E H N
A. Preston Howard, Jr., P.E., Director
October 3, 1997
TO: Melba McGee
FROM: Michelle Suverkrubbe
RE: Clarification on Comments on SCH # 98-0029; DWQ#11686
Piedmont Triad Regional Water Authority (PTRWA)
Randleman Lake DEIS
Randolph and Guilford Counties
The original memorandum from DWQ on this project (dated 9/30/97) contained a
statement that needs to be clarified. Item number 4 on page 3 (second paragraph) contained
the following statement:
"The Randleman alternative should include estimated costs to remediate and clean
up the groundwater from the High Point Landfill and the Seaboard Chemical sites
to protect aquatic and human health water quality standards in the proposed
reservoir (that are necessary due to the proposed reservoir, and would not be
necessary if the reservoir was not proposed)."
The Division meant that for the Randleman alternative, the DEIS should explain the
difference between what it would cost to remediate the Landfill and Seaboard sites with,
and without, the proposed reservoir, given the different levels of groundwater clean-up that
may be necessary under each scenario to meet applicable water quality standards. The
DEIS should provide a discussion of the differences (both economically and
environmentally) between the level of groundwater clean-up that would be required if the
reservoir was not built (it remained in a riverine setting, and no water reservoirs or intakes
were planned adjacent to the sites) and what specific additional clean-up measures would be
necessary under the Randleman Lake public water supply reservoir scenario.
I hope this provides adequate clarification. Please pass this on to the
Clearinghouse and the project applicant. I can be reached at [phone], ext. 567 if
they should have any questions.
Thank you.
mis:\980029 Randleman Clarification
cc: DWQ staff
DEH - Public Water Supply
PTRWA - Mr. John Kime
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
I{FA R4 ORC
9.0 ST'gip
FO
.40 r?
4EAD/OEA
ID=404-562-9598 OCT 08'97 10: 02 Pic
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RgQnN 4
ATLANTA FEDERAL CENTER
100 ALABAMA STREET, S.W.
ATLANTA, GEORGIA 30303-3104
Dal 0 6 1121
Colonel Terry R. Youngblutlt
WihWtigton District, Corps of Engineers
P.O. Box 1890
Wilrnington, NC 28402-1890
Attn: Mr. David Franklin

ULT 1 ? 149
ENV1Pn?,l,r-NrAC,C?IVCEr;
RE: Draft Environmental hnpact. Statement on Randleman Lake, Oilford and Randolph
Counties, North Carolina; June 1997
Dear Colonel Youngblut.h:
The U. S. Environmental Protc ction Agency (EPA) has mvicwccl tlic rcfe,renccel document
in accordarice. with EPA's responsibilities under Section 105) of the Clean Av Act and Section 102
(2)(C) of the National Environmontal Policy Act (NEIIA). The 1>rnft. Envir•oamontal Impact
Statement (Draft FIS) is an asseSsrnow of impacts of constructing a dcnn and reservoir situated
approximately two miles upstream from the town of Randlen-iitn in Randolph County, North
Carolina. The proposed damnung of the Dexp River would flood some 3,000 acres including 12,
acres of Section 404 jurisdictional wetlands and 29 miles of free-flowuig stream-,.
Our letter from William L. Cox, Chief of 1?l'A's Wetlands S,.ction elated September 12.
1997, related to matters pursuant to wetland mitigation issues. This 1;.tte.T referenced additional
comments that would be prepared by EPA; these. are. provided below.
The Draft EIS did not provide sufficient documentation to reach the conclusion that
groundwater coritarninat?ion would not have a significant adverse impactt, on tic, proposed
Randleman Lake water quality. DNA's principal concern is that area residenLS be provided a safe
drinking water supply. Other concerns include increased algal and microbial growth from
increased nutrients, and the bioaccumulation of toxic; materials in higher food-chain anu»al
species. If fishing and recreational use of the lake. were to occur, theft risks from these paths of
exPoSUre would need to be evaluated. Our concenis stem from contaminated groundwater
migrating into the proposed reservoir water from the Seaboard (:hemical Plant and the High Point
landfill sites. Thcse sites arc situated along the Deep ]fiver pTaxinratc to thtr proposed reservoir.
Particularly noteworthy arc tic concentrations and chemical nature of the organic solvents
etttanating frorn these. sites which Caro scheduled for remcdiat.ion as sot forth in the Seaboard
Group 11 and the City of Mph Point RCITICdiid lnvest.igtttion Work flan dated A me 1995.
ReeycledMacyelable * Pftad wills Vnfletanie Oil liane(I Ink, nu 100% Socycled Papar (40%Peetor,muntiii)
EPA, R4 ORC ID :z04-562-95'92 UI- U ? ' _ 1'? • I i - .. - -
Although the Draft EIS stated that these remMiation sites were sinial.ed entirely abovt
the normal pool of the proposed reservoir, there was no supporting evidence (such as topographji
maps) to support this contention. Changes in surface and groundwater levels will affect not oniv
those areas that are inundated, but can be expected to saturate soils that are periphtxal to the
reservoir boundaries. Elevation of the water table would most likely increase contaminant
mobility, thereby posing additional potential risks from these sources.
Descriptions of known chemical contaminants were insufficient and tlic sources of both
chemical and non-point source inputs to the watershed were not adequately characterized. Tli_
five organic. compounds that were identified in Section 5.3.5.4 Toxic Substarim Evatuntiu,
appeal' to represent only a small subset of organic constituents present in the groundwater. R'.
would offer that a typical EPA site investigation includes over 150 chemical parameters. Lacking
were discussions of the organic contaminants that were identified (the chlorinated hydrocarbons)
as beuig primarily dense non-aqueous phase liquids (DNAPLs) which may degrade to more toxic
chemical species such as vinyl chloride. Additional chemical issue concerns are described it more
detail (see Attachment).
The Draft EIS identified 42 permitted existing, discharges in the Randleman watersb&l.
yet. the text discussed only three, i.e., the Egli Point landfill, Seaboard Chemical site and the High
Point Eastside wastewater treatment plant (WW7'P). Although the other discharges may yield an
insignificant amount of clen&al loading; to the watershed, there was insufficient data for the
reader to come to this conclusion, The Final HJS should clarify and expand the cumulative
impacts of These additional discharges.
The direct discharge of treated sewage effluent from the High Point Eastside' WTP into
the upper reach of the lake would raise the levels of phosphorus and nitrogen and contribute to
the cutrophication of the proposed lake, it water body Ib it is predicted to be, cutrophic without t1c.
High Point Eastside, WW'1'? discharge. This increased organic loading would further degrade the
lake as a drinking water source, and although it is technologically feasible to remove high organic
loads, costs attendant to inecting drinking water standards would b:. expensive. Because the
prRioct will necessitate state-of-the-art equipment to treat both drinking water and wastewater,
we reconunend tine increased costs of operation and maintenance bcs included in the Final EIS.
Because project costs were one criteria for selecting, the Randleman Luke alternative, a
more dctruled exposition of costs would assist readers, unfamiliar with project costing. It was
unclear how some alternative cost elements in Table 1 were, derived. To accommodate the raised
surface waters and buffer areas, twenty-one road and highway relocation and abandonment
actions would be required in Gilford and Randolph Counties. We,: could not clctcrmine if liigh%x-ay
relocation costs (Table 21) were included in the Proposed ProjmL analysis. For Alternative A
(Upper Deep River Lake), were there no alternative configurations possible that would have
eliminated the, WWT? relocation costs of $64 million? For Alternative F (Combination of Beriliia
Lake, and Groundwater Wells), it was not clear if tile. purchase of 73 square miles (48,000 acres)
of watershed wero included in Alternative F Reservoir Dove] opment Costs (Table 13). The l'iat'll
3
EIS should include a more thorough explanation of alternative cost. elements.
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 North Carolina Department of Environment, l iealth, & Natural Resources (NCDEHNR) ?-
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. EPA further recommends that any ongoing
remedial investigation evaluation(s) be completed prior to proposed construction activity so that
the nature and amounts of contaminants at the Seaboard and the High Point landfill sites may be
more thoroughly defined. We also suggest that the applicant. revisit the project alternative costs
to ensure that the preferred alternative is cost-cffcctivc for the long term when the expenses of
treating both wastewater and potable water t.o high lcvcls of purity urc considcrod. -
Based upon review of the rafc.renml document by our technical staff, we have rated thc.
Draft. EIS "EO-2", that is, EPA hug environinent:al. objections to the Randleman Lake project and
has identified significant environmental impacts that must be avoided in order to provide adequate
protection for the environment and public, health. The Draft CIS did not contain sufficient
infomiation to assess environmental impacts and health concerns; EIIA has identified additional
information and analyses that should be included in the Final EIS.
We appreciate die opportunity to review this document. If more information is require,.
do not hesitate to call nie or Heinz Mucller at [phone].
Sincerely,
CL
Phylli Iarris, Regional Counsel and Director,
F.nviroruncntal Accountability Division
Enclosurc
cc: Dr. Lynda Realer, NCDI-lINR
EFR R4 ORC
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ID:404-5b2-yDy6 ut-I tjQ .71
?-r. r erC?? ?? eND !OMAN DEIS
Colonel Terry R Younlbluth
t7.S.Army Corps of Engineers
Wilmington, North Carolina
1. This area of the Piedmont Crescent in North Carolina is among the fastest-growing in
the country. The Randleman source may only be sufficient. for the projected need for the new 40
years (to 2035, maybe to 2050 if strict conservation requiremetits are irnpose4l). Does the
construction of the Randleman Lake foreclose any options for water supply 40 years hence'l
2. The, EIS notes that the SY50 (50-year safe yield) yields for all of the existing sources
serving Water Authority members total 60.6 MOD. Most of these arc sulall lakes which have
been in existence for some time. Has it been ascertained that these sources will still produce this
yield in 20507
3. The existing High Rock lake on the Yadkin River is approximately 30 mules from the
region. It is larger than the proposed Randleman Lake, and hus limited development at this time.
Has there beeti any consideration of this source as a water supply?
1. We are concerned that the contaminant concentrations and volumes of eontamineted
water that were used for modeling inputs may not represent field conditions at the Seaboard
Chemical site and the High Paint landfill sites. These sites are presently undergoing remedial
investigations which should be completed in early 1998. When on-site values are available,
modelers should be better able to determine impacts on the Deep River and Randleman Lake from
the Seaboard Chemical and Highpoint landfill sites.
2. The draft HIS did not adequately address how much of the High Point Landfill will be
underwater at both normal pool elevation and flood pool elevation. The EIS indicated (Page 5-
12) that the 100-year flood pool would reach approximately to elevation 091.5 mean sea level
(msl), whereas Table R (page 3-3) lnciicat d that 705.3 msl is the probable maximum flood pool
elevation. We would like to know tlic probable maximum pool, as the amount of buffer area
that. would be saturated inc:reasGS dramatically as the pcx)l elevation increases.
pl jBLIC' 1 BAL.TH AND TOXICITY
The proposed lake development regUrds its use. as a drinking water source to,be subjected
to conventional treatment before caMuittption. From the cliemical characterixati011 data
EF'F R4 ORC I D :404-562-9596 u?- 1 11e 7
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presented, it is possible that state-of-the-art water treatment would produce a safe drinking mater
from Lake Randleman; however, the EIS does not specify what is meant by the generic term
"conventional treatment" in regard to filtration medium (activated carbon, sand, etc.),
sedimentation/flocculation procedures or disinfection process that would be used, Such treatment
details would need to be known before the actual drinking water quality and health risk could be
determined. An aesthetic water quality concern (taste and odor problems) may also need to be
addressed with the treaunent pruccss if nutrients added to the lake encourage algal and other
microbial growth. EPA has concerns about pathways of exposure that are not discussed. IS
fishing and recreational use of the lake is to occur, then risks from these pathways of exposure.
would need to be evaluated.
It is unclear that sufficient toxic substances will or will not enter the proposed Randleman
Lake, from identified sources in sufficient. quantities to pose hcalt.h concerns. Howevef from this
agency's perspective the EIS Appendices fall short of providing strongly convincing
documentation of no impacts on human health, '17,is evaluntion is inadequate in providing a
sufficient documentation such that a concerned person would independently reach the three
conclusions stated on page D-4 of the 1.]S Appendices. DetaiN of concerns nre discussed below:
1. The RIS states that 42 pcrmittt;d discharges exist in the Randleman watershed, Figure.
V-2 appears to show the location of seven of the 42 and the text discusses only three soiIrces, i.e.
High Point Landfill, Seaboard Chemical site and High Point Fastside. WWP. Are these
wastewater or storm water? The other discharges may yield insignificant chemical loading to th;:
watershed as indicated in the RIS. il'owever, insufficient data and information is presenters in the
document for the reader to coin to this conclusion.
2. Only 14 chemical pollutants were identified as having toxicity concerns. The
environmental chemical analysis for a typical 1?l'A site investigation includes over 150 chemicals.
It is not clear what chemicals were included in the analysis of environmental tnedia at the tluec
primary sites or the many NPDES discharges. We do not. get the sense that chemical sourc: s to
the watershed have bcun adequately chmacterized.
3. The draft. RIS stated (page 5-13) that the High Point Hastside W'WTP was evaluated
and found not to be a significant source of mganic pollutants. Infonnation Should be included in
the E18 which states how this evaluation was done including a definition of "significant" source.
A priority pollutant scan may hove. b=n conduotui during NPDES permit issuance or reissuance
which would provide an indication of the pollutants detected in Ow High Point WWTF e llucnt.
Tf so, that information should be sneluded in the EIS, otherwise a priority pollutant scan is
recottvtnendeti in order to detertnine other potential contwiiinant.s to the reservoir. A rcvicw of
this infonnation for other discharges to the proposed lake woalcl also be useful.
4. The Trinity Fotun site located in (Aenola will he approximately'/z mile from the edge of
the proposed lake. With the rising of groundwater levels associated with the eonstrtu;tion of the
lake, contamination from the Trinity Foam site may extend to additional wells located in tle area.
ERR R4 ORC ID:4U4-bb1-3ny6 U?, - --
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This impact should be described in the EN.
5. 'l'he Seaboard Chetr?ical site ig clearly associatul with a groundwater VOC plume.
From the discussion, we would anticipate that a DNAPL exist that would be a source of dissolved
VOCs to the aquifer. Such a DNAPL would likely be located below the deep fractured-bedrock
aquifer. The influence of soil hydration from the lake, on the VOC plume and possible DNAPLs
relative to future; and continual lake contamination should receive additional discussion and
perhaps study.
6. The three; primary sources of lake contamination will be located in the upper reaches of
the lake some 10 miles upstream of the drinking water intake. The assumption made from the
modeling exercise is that adecluatc rniXing and dilution will result in contaminant levels at. the
water intake well below concern levels. It is not clear that the modeling has consider factor such
as channeling that would hindor cornl?)ctc and unifunn mixing in the lake. Further discussion of
the modeling in this regard is appropriate.
7.. An important issue is whether or not the diichaq.,,e from High Point Eastsido WWTP
should enter the lake or be routed below the lake. It would seem that further discussion of the
treatment process, e.g. combined sewer overflow/by-pass issues, fail-safe overflow provisions,
b,eatinent redundancy for protection against microbial kill-off, would be appropriate.
8. The discussion of the High Point East. WWTI' (page 5-13) estirnat.M in-strenin metals
concentrations on a mean annual basis. This evaluation should also lie conducted for the low flew.
(that is, 7Q10 or other appropriate flow as defined in State Water Quality Standards) condition.
NUTRIENTS
1. The expectation that the lake will be highly eutrophic was also not adequately
addressed. The EIS stated that the proposed Randleman Lake will be highly eutrophic due to the
nutrient inputs even without the High Point W WTP discharge. 'T'hus the lake is likely to
experience frequent if not continuous algae problems that will impair its value as a public water
supply and as a recreational resource. High organic loading from algae would require a water
ti-cnuncnt plant that will have to incorporate more sophisticated and expensive processes including
activatzd carbon to remove natural and chlorinated organic contaminants. The DEIS should
include long-ttertn operating expenses in tho costing scenarios.
2. The W WTP was considered to be relocated (or its dischargc) around the lake, but
apparently relocation would not leave enough water for adequate. drinking water withdrawal and
sufficient relcaw. from the lake itself. That forces the W WTP to a very expensive high efficiency
nutrient removal system and fail-safe redundancy - since the WWTP is upstretun of the, drinlcvig
water withdrawal point. In the event the plant were to forced to bypass or experience a power
outage, the. water treatment plant could be subjected to increased virus, ccrypto sporidium, ginrdia,
EF' R4 ORC ID:L04-562-9598 UCH uz?-yr 1kj• ---
4
etc. None of these issues were adequately addressed in tht: EIS and all the secondary costs
associated with the; lake were not. accounted for - the extra costs for WWTP itnd drinking wat,.?r
plant and their respective additional O&M costs. A treatment plant could be designed to achieve
a consistently low phosphonis level - 0.3 mg/l or so, however, the fail-safe redundancy for
disinfection and treatment would be costly. Even 0.3 mg/1 would contribute approx. 24,000
Ax/year of phosphorus at 26 MGD, which is the proposed permit flow.
3. The Walker 13ATI ITUB model predictions indicate that the North Carolina water
quality criteria for chlorophyll "a" of 40 ito wlll not be achirved in the Deep River sub-basin of
Xandlcman Labe. An argument is made that the. overall average lake chlorophyll "a" will meet the
state criteria; however, those, criwria must bo met at any col] I1t.111 the lake. In addition, the state
chlorophyll "a" criteria is a daily maximum critcritt while lute EIS analysis estimated in stream
chlorophyll "a" cor centrations only on an annual and growing sruson basis. It is re asromtble to
expect that same daily chdoro h ll "a" conce.nu•ations will exceed average concentrations. W
evaluation of the ullowablc maximum nutncnt dings to
rccornuncnd that the MS include an
provide for maintenance of the State chlorophyll "a" criteria in the Deep River 1 sub-basin. Basud
att a review of the modeling results in Appendix A, it appears that even with removal of the High
Point discharge, the state chlorophyll "a" criteria will be exceeded and that non-point source
controls would be needed. Both the NC DEM Cape Fear Basin-wide WRter Quality Mtmngement
Plan (page 6-50) and the draft IiTS state that it is "highly likely" that. Randleman Lake will be
eutrophic.
4. The HIS (page 4-10) stated; that the proposed Randleman Lake would inundate two
segments of Deep River which are inoludml in the State's 303(d) list of impaired waters. The
segments are impaired due to elevated levels of fecal colifortn and ntrbidity, One segment is
additionally itpaired by elevated levels of metals including copper and mercury. Waters included
on the 303(d) list are those requiring development of TMDLs (Total Maxinumt Daily Loads).
The TMDL analysis determines (1) the causes and sources of 11m use impairments and (2) the
needed pollutant load reductions for tliuse sources to restore the beneficial uses of the water
body. Absent a TMDL for the listed waters, the EIS must provide documentation that the
proposed project. will not cause or contribute to use impairments and violations of state water
quality standards. A thorough analysis of the impacts of lake construction and operation on water
quality with respect to focal coliform and turbidity should be included in the E1S. This is
especially important sinuo the draft. EIS subecsts (page 5-9) that short tens increases In turbidity
would occur duo to construction of the clam.
5. Nutrient loading analyses were based on effluent flows from the l ligh Point East.
NVWTP tip to 20 MGD. This flow was apparently determined in the, reservoir yield tma.lysis. Wt:.
understand that the High Point Mast facility has a pennitt.ed effluent flow of 26 MGD. It. seems
that the appropriate now for calculating maximurn nut6ent loading fi-om the High Point. facility
would be the permitted flow of 26 MUD. The EM should provide more discussion to justify the
use of a flow less than the. maximum permiu.ed flow especially for estimating future lyadings.
EPA R4 ORC
ID:404-562-9598 utr U6 yr llj•?. ---
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6. Base flow quality for phosphorus and nitrogen input. assutnption% were made in
determining nutrient loadings The IH1S Appendix should provide an explanation for how these
assumptions were made (e.g., field dtita, other sunilar areas, NRCS retmornmendations) for both
tale existing condition,: and future loadings scenarios. Consideration should be given to
conducting a sensitivity analysis for these inputs to determine the relative importance on model
predictions.
1. page 5-9 of the draft document states that. "...minor changes in the groundwater level
will occur..." and "...overall, groundwater effects on the water duality of Randleman Lake are
predicted to be insignificant..." These; conclusions are not apparent from inforniat.i.oti and data
provided in the document and appendices.
2.. With respect to the groundwater level, the. report should include an appropriately
scaled topographic map and potentiometric rnap. Since changes to the potentiornetric surface will
vary within the watershed, cross-sections should be generated which represent the changing
potentiontetrie slopes within the watershed. Supporting inforination should be, accompanied by
land use snaps and descriptive text. This effort will require more detailed analysis of ground water
contribution with respect to reservoir yield analysis and toxic substances evaluation.
3. Changes to the potentiorndtric slope will affect ground water inflow[baseflow
estimates. Page 1V-] R of the appendix (tropic level evaluation) acknowledges that basetlow
should decrease, but that tine current values were used as a cumurvative. estimate. While this is
cotiect with respect to loading it may not be conservative with respect to yield and mass balance
calculations. This should be considered in the Draft EIS.
4. Changes in the surfucc water and ground water levels will affect not. only what is
inunduted but what is fiaturated. ror this reason additional assessmetnt is required to assured there.
toe not adverse offects from toxic ur hazardous sources. The two existing sources identified in
the Toxic Substances Evaluation on pale V- l of the appendix are the Seaboard Chemical
company and the High I?oint landfill. Page 5-11 of the draft report indicate that "...both are
located entirely above the; normal pool elevation of the reservoir..," These locations should be
identified on a topographic map which should he used to support this conclusion; however,
cursory review indicates this may not be correct.. Review indicatat that normal pool may inunclaw
a. portion of the landfill and a 100-year flood may inundate a portion of the Seaboard chemical
Company.
5. More important than surface inundation, however, tna.y be the effect. of the change in
elevation of the water table such that buried waste and contaminated soil may become saturated.
increasing the potential risk of these, sources, We would include a discussion of the Randleman
Town Dttmp (pgs 5-12-13). Indicate whether depth of burnt] is know (and ]low). Indicate its
EPH R4 ORC
ID :404-562-9598 U'_ VQ y -
location on topographic and pot.entiotrx:tric maps. Discuss the number, location, and results of
samples irtcluding'1'CLP analysis. Address the time frame for removal and reference it to the
proposed time frame of the project. Do removal costs include verification sampling and industrial
landfill disposal? What information is available regarding the concentrations and extent of groamd
water contamination? Is treatment proposed? What is the regulatory authority? Where and at
what concentrations will ground water contamination impact the reservoir?
6. Data and information are dispersed through Ule text and appendix, however, nutncru::?
Issues stand out. For both the Scrtbottrd and landflll sites, the full list of constituents and the
distribution and extent of contanutlation have not been identified. This assessment is mandator%
to evttlua.te potential risk from ground water contamination.
7. Cursory review suggests that information in the draft report was incomplct6 with
respect to sampling and monitoring data, hydraulic conductivity data, and aquifer test data which
may have been available at the time of the report.
K. The five. organic compounds identified in the draft report and Uppendix appear to
represent only a subset. of organic constituents identified in the ground water. The
characterization of die chemical compounds is inadequate in that it fails to recognize that these
idtntified (and unidentified) chemicals are primarily DNAPLs, dense non-aqueous phase liquidi,
and that they degrade to a murc toxic compound, vinyl chloricle (which has apparently been
identified in the ground water at concentrations orders of magnitude greater than the drinking
water standard).
9. While the draft report and appendix correctly identifies ground water flow in the
direction of (lie, river, it assumes that contamnadon will he in the direction of ground water flow.
With DNAPUs this is not necessarily the case A DNAI'L plume will move by gravity along, the
bedrock plane. This, has not been identified nor was the potential of fracture flow considered.
Bout possibilities must be considered to adequately address the potential risk of both the
Seaboard site and the landfill.
10. Data appear to exist which supports an increase of contaminant concentrations with
depth, fracture flow, and changes in direction of vcrucal hydruulic gradient. This information is
extremely significant. In the evaluation of potential risk, yct appears not to have been usM. Page
4-19 of the draft. (Endangered, Thmalcncd, and Rare Species) identifies upland seeps, suggesting
that this information was known and that a more thorough assessment of the ground water flow
regime should have been developed.
11. The distribution and extent of huried waste and the chwige ut ground water elevation
must be better understood. The organic compound idcntifietl as originating from the Seaboard
site have the capacity to dissolve other constituents. Of particular concern are the constituents
which alight likely be found in the landfill (such as metals, herhicides, and pesticides)- It is
essential to know the extent and depth of burial and the change in elevation of tttc potentiotnetric:
-
ERA R4 ORC 1 v:L0L-j'2-Uk- I Vv ?;
7
surface to adequately assess the possibility of saturation and the potential of ground water
impairment. Capping of the landfill may not be satisfactory and remcdiation or removal at the
Seaboard site may not be feasible given a rise in the water table.
12. The 20 foot thickness used in the appendix to calculate Darcy flow should be
supported by datit. A bedrock surface snap should be provided. Identification of fractures and
water-bearing zones in the bedrock is necessary. Fracture flow should be assessed.
13..Additionalpotential sources of ground water contamination, including dumps; RCRA
generators and TSD (trmtment, storage, and disposal) facUitics, CERCLA sites, Toni,,; Rele-se
Inventory TR1 sites, and should be iricntificd and assessed.
Additional potential sources of surface water contatination should be identified and assessed.
't'hese include the hundreds of ac-,res of agricultural land which would be inundate] and eould still
act as a contaminant source. Livestock, crop areas, and pote-n-lal chemicaLs of concern (nutrients,
ammotua, fecal coliform, pesticides and herbicides) .zhoulcl be identified and assessed.
14. All potential sources should be evaluated at the point of the sources impact with the
proposed lake. Quantified estimates (such as the estimated ground water concentrations nt the
point of discharge or dissolved nutrients ab:)ve a buried dair}' farrlr acreage) should be compared
to drinking water standards, recreational, and ecological standards. While these concentration
may represent a worst case, dilution should not be considered for these comparisons. (Altho.igh
dilution trod/or treatment may provide an adcyuate, drinking water supply, this may not protect
plants and animals.
1. Pg. 1-l. The summary states that the proposal was developed for a period of
approximately 50 years. Explain why is this different from projwtions later in the text (40 gars,
100 years/pg. 111-2).
2. Pg. 3-1. The proposal 1968 cunstruction would have discharged effluent from the
High Point l:ttstside WLNTP downstream of the dam. t?xplairr tlie changes resulting in this
modification.
3. Pg. 3-3, pgs. 111-2-4. These data sngge,.t that the height between the stream bccl inc
the lake floor on either side of tic proposed dam will be 24 feet. What is the current change in
elevation between these two proposed loeations7 Provide a cross-section. What is the elevation
of the outfall strictures? Consider the effects of scouring and changes to fluvial geomorphology.
Provide greater explanation of the Soil Conservation methods. "Tabulate the data including:
reservoir capacity, volume increment, capacity inflow ratio, % sediment trappul % sediment
trapped per volume increment, acre-ft sediment trapped annually , and lie number of_ycars
required to till the volume increment. Explain why sediment accumulation was projec'tcd for 100
ERM R4 ORC
I D :404-562-9598 at-1 Ua 7 f 1V- I--
8
years. What is the sedirnmt accumulation in 50 years?
4. Ng. 3-4. The effects of the interbasin transfers to the fluvial geomorphology and the
endangered species habitat must be considered.
5. Pgs. 3-9-10. Cireater detail should be provided for Alternatives E and F, using ground
water wells.
6. Pg, 3-14-1$. Ltclude the tttili s of roadways and rtlilways. Effects to down, trcFitn (pg.
5-],reduced annual flow) geomorphology, wetlands, and endangcrcd and threatened spcctes must
be noted (Section 4). Effects on geomorphology, wetlands, and to endangered and thrcatcned
species in basins receiving interbasin transfers must also bcs noted (Section 4). Given the
expectation of lake eutrophication and the possibility of toxic effects to aquatic lifo,*tiiv
recreational use of the proposed lake should lxs reconsidertmi ( also pgs. 3-24, 5-1, 5-16-17,5-21).
7. 11g. 3-23. A wetlands inventory for alternatives is advised.
8. Pg. 4-3. Identify the types and locations of mining (.)pe.rations exist in Guilford Count.
9. Pg. 4-8. Delineation of prime familand is recommended.
10. Pg. 4-10. Discuss what monitoring and treatment would exist for pesticides and
herbicides. Identify the concentrations of lindane. and choldrin which exceeded the water duality
standards and note the standards.
11. Pgs. 4-20-21, pits. 5-17-1S. Discuss the effect on endangered and threatened species,
especially the Capc Fear shiner and Carolina darter, downstream of the project and in the basins
recciving interbasin transfers,
12. Pgs. 5-1-2. Provide a land use map. Identify the operating dairies.
13. Pg. 5-3, pgs. 5-17-18. 1Ji,cus5 estimates of the e:cononuc losses to hydroelectric
projects along the Deep.River and in basins affected by interbasin transfers. Have thcsc costs
been included in the Projmt Cost Estimates.?
14. Pgs. 5-6-7, Pgs. 5-16-17, 5-21-22, Find Section 4. 'fables 23 and 24 identify a 17%.
reduction in average, flow during filling and a 6% reduction in average flow at the High Falls
location. Provide the range and durations of flows at this locution and at the Gulf and Moncure
stations further downstream and discuss the impact to the Cape, Fear Shiner Critical I labit.ats
located oil the Deep River in Randolph and Moore Counties (upstreair of the High balls station)
and in Chatham and Lee Counties (upstream of the Moncurc station). Relate projected flows to
current flows for uverag;e, high, and low flow conditions. Disizuss where ttew st:ottri!)g may
occur, the cwrent health of the streams, nod modeling supporting; ;t redaction in I301') and
LF'H K4 UKl
increased DO.
15. Pg 5-11-12. Discuss what is n=nt by the czPression "rncan annual c on:;entrations":
what well(s), location, frequency, and number. Discuss the cm-. ent staves of the Seaboard
Chemical Company and the High Point Landfill. ldentify Me regulatory althonties.
16. Section 5. Gencratc the cumularive concentrations of the all sources.
1.7. Pgs 5-17-18. Discuss changes in stream geonnorphology and ecosystems resulting
from increased flows in dio Haw River Pasin and Yadkin )Zivcr Basin.
18. Pgs. 5.21-22. Provide the locations or rare plants which will be located in the buffer
zone on a potentiorne;tric map and discuss tho c-fecN of ground water saturation if appropriate.
19. Pgs. 17-1, pg. 5-7. Provide additional discussion and cla:ifi; ation on the flow and
yield analysis. Page ll-1 states that die average annual floe in the Daep River with Randleman
Lake is less than the flow without the reservoir. 'fable 24 idcnti:tas the average annual flow as
163 cfs (105.4 mgd). Pg. 11-1 identifics the }ield of Randleman Lake as 54 mgd (77.95 cfs) and
states that tic difference between the current and projected floe in the Deep River is
approximately equal to the Randleman Lakc yield. 1his suggests that the lake yield is
approximately half of the current flew and the projected flow will be al proximately equal to the
lake yield and approximately half of tote current flow. 17tis is inconsistent with tie 29`ic reducticn
in average flow at the Randleman dam site indicated on Table 24. This discrepancy calls into
question the flow reductions projectcl fur ttadons further downstream on the Deep River. Sinc-C
this Includes flow in Critical Habitat for the Cape Pear shiner, clarification of this apparent
discrepancy is imperative.
20. Pg. U-1. The text states that -Up to 26 mid of the Randleman Lake yield, would
return to the Ducp River watershed as wastt: amr..." and "...0 mgd could be discharged
downstream of the roservoir to the Decp ]over." Whcrc and how would this discharge occur?
What cost would he incurred? This discharge rcprescnts approximatcly 1 U ;'o or the projected
flow downstream on the dam. What effect does this have? Nas the downstream flow been
modeled for dissolved cgxygen? Provide the results.
21. Pg. 11-3. Cumulative concentrations from all sources should he estimated for water
quality evaluations; sources eliminates should be identified with iustification. Water classification
and standards should be identified. 'i'he estitnated concentrations should he compared co drinl:inu
water, surface water, and ecological standards. The project. must h evaluated with respect to
compliance with the Clean Wetter Act including generation of '1'MI)J..s where appropriate.
Pgs. V-12-13. After a thorough assessment of ground water contamination, meats concentration
should be developed for all constituents including organic COmpounds not currently identifies
(including such compounds as vinyl chloride). ToWe V-5 indicates there is no standard for
Methylene Chloride:. This is incorroo. A Maximum Contaminant I evul MC.L of 5 micrograms
LFH K4 uKC 1ll:404-562-9598 OCT 08'97 10:10 Nc.01"`
10
per liter for Dichloromethane (Methylene Chloride.) was promulgated in July 1992. The mean
annual concentration idcntifiui in Table V-S, without the WWT11, is 4.9 micrograms per liter just
under the STDWA MCL criteria, but exceeding the MC:L during; maximum projection of 17
micrograms per liter In Table V-6 on pxgc V-14.
22. Pg. HA The text states that "It is expected that significant.quantitles of organic anel
inorganic pollutants would be removed by sedimentation as the water is routcd through the
reservoir to the intake locution." Discuss the projected siltation rates and the possibility of the
sediment acting its a pollut.nnt source. Discuss the effects on bottom dwelling aquatic life.
23. Pg. IV-18. Provide a justification for the baseflow concentration

RECEIVED
State of North Carolina
Department of Environment
and Natural Resources
Legislative & Intergovernmental Affairs
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Richard E. Rogers, Jr., Director
MEMORANDUM
OC)' 2 1997
ENVIRON?VTq?SG1ENC,?3
ID N FZ
TO: Chrys Baggett
State Clearinghouse
FROM: Melba McGee
Environmental Review Coordinator
RE: 98-0134 Scoping Piedmont Triad Regional Water Authority,
Transmission Mains, Guilford and Randolph Counties
DATE: October 15, 1997
The Department of Environment and Natural Resources has completed its
review of the proposed project. The attached comments identify information that
our review agencies would like for the applicant to consider and address if this
project is to proceed.
The proposed water transmission mains are intended to deliver water from the
proposed Randleman Reservoir and the proposed water treatment plant, which is
presently being reviewed under DENR's internal review process. Generally
speaking, these projects cannot function without the approval of the Randleman
Reservoir. In our Randleman Reservoir project comments dated October 2, 1997,
major emphasis was placed on the future water quality of the reservoir. Our
agencies also identified a number of other deficiencies with the DEIS and asked
that the Corps of Engineers not approve the project until additional efforts
could be made in resolving agency concerns.
Since the two referenced projects seem to center around the Randleman Reservoir
proposal being approved, the department believes that its too premature to
specifically respond to this proposal. Therefore, it is recommended that the
Peidment Triad Authority not move forward too quickly in developing further
environmental documentation without final approval of the Randleman Reservoir
project. Final concurrence with this project would not be warranted until our
concerns were satisfactorily addressed and appropriate conditions were
implemented in the proposed Randleman Reservoir project. Again, our primary
interest at this time is to continue to communicate and work closely with the
Corps of Engineers and the Piedmont Triad Regional Water Authority staff so
issues can be resolved in an efficient manner.
Thank you for the opportunity to respond.
attachments
PO Box 27687, Raleigh, North Carolina 27611-7687 • Telephone: [phone]
An Equal Opportunity / Affirmative Action Employer . 50% Recycled 10% Post-Consumer Paper
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
?EHNR
October 13, 1997
MEMORANDUM
TO: Melba McGee
FROM: Michelle Suverkrrubbe/;-,S
THROUGH: Coleen Sullins(/ w .
RE: Comments on SCH # 98-0134; DWQ #11742
PTRWA - Randleman Water Mains and Facilities - EA Scoping
Randolph and Guilford Counties
The above EA Scoping request applies to a proposed water line project associated with the
Randleman Lake Reservoir project. The project will include construction of 13.5 miles of 16 to 48-
inch diameter water mains, a 250,000 gallon elevated storage tank, a 2 million gallon ground
storage tank, and a 2,220 gallon per minute package booster pumping station. The project will
supply treated water from the proposed Randleman Lake Water Treatment Plant to various areas in
Randolph County and the municipalities of Randleman, Archdale, Greensboro and High Point.
The Division is very concerned about the future water quality in the proposed Randleman
Reservoir (see attached comments), especially increases in nutrients from point and non-point
sources as a result of the urbanization to be served by this proposed water line. The Nutrient
Reduction Strategy and Watershed Management Plan PTRWA will be developing as a condition of
its 401 Certification should contain adequate measures to resolve these issues. However, because
this proposed water line project could be dramatically affected by the final design of the proposed
reservoir and the location and design of the proposed water treatment plant, this water line project
should not be allowed to move forward without those other aspects of the project being finalized.
The Division therefore requests that DEH not approve the Randleman Water Line EA/FONSI until
both the Randleman Lake Water Treatment Plant EA/FONSI and the Randleman Lake Reservoir
FEIS/ROD are approved by the Clearinghouse.
Regarding the content of the EA for the water line project, the applicant should be made
aware of the necessity to follow the requirements for the general certification for Nationwide
Permit 12 - Utility Lines by the Army Corps of Engineers when disturbing wetlands for water or
sewer utility line construction activities. Deviations from the General Certification will require a
formal application for a Section 401 Water Quality Certification from our Division. See attached
401 handout for more information. If the applicant should have any questions on wetland impacts
or the 401 Certification process, please direct them to John Dorney, Ecological Assessment Group,
at 919-733-1786.
I can be reached at 919-733-5083, ext. 567 if there are any questions.
m(s:\ 980134 Randleman Water Lines
cc: DWQ staff
attached: Randleman DEIS memos
401 handout
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
State of North Carolina
Department of Environment,
Health and Natural Resources N:.WVTA
Division of Water Quality
James B. Hunt, Jr., Governor AdftMM
Wayne McDevitt, Secretary C) F= H N F=1
A. Preston Howard, Jr., P.E., Director
October 3, 1997
MEMORANDUM
TO. Melba McGee FILE COPY
FROM: Michelle Suverkrubbe
RE: Clarification on Comments on SCH # 98-0029; DWQ#11686
Piedmont Triad Regional Water Authority (PTRWA)
Randleman Lake DEIS
Randolph and Guilford Counties
The original memorandum from DWQ on this project (dated 9/30/97) contained a
statement that needs to be clarified. Item number 4 on page 3 (second paragraph) contained
the following statement:
"The Randleman alternative should include estimated costs to remediate and clean
up the groundwater from the High Point Landfill and the Seaboard Chemical sites
to protect aquatic and human health water quality standards in the proposed
reservoir (that are necessary due to the proposed reservoir, and would not be
necessary if the reservoir was not proposed)."
The Division meant that for the Randleman alternative, the DEIS should explain the
difference between what it would cost to remediate the Landfill and Seaboard sites with,
and without, the proposed reservoir, given the different levels of groundwater clean-up that
may be necessary under each scenario to meet applicable water quality standards. The
DEIS should provide a discussion of the differences (both economically and
environmentally) between the level of groundwater clean-up that would be required if the
reservoir was not built (it remained in a riverine setting, and no water reservoirs or intakes
were planned adjacent to the sites) and what specific additional clean-up measures would be
necessary under the Randleman Lake public water supply reservoir scenario.
I hope this provides adequate clarification. Please pass this on to the
Clearinghouse and the project applicant. I can be reached at [phone], ext. 567 if
they should have any questions.
Thank you.
mis:1980029 Randleman Clarification
cc: DWQ staff
DEH - Public Water Supply
PTRWA -Mr. Jobn Kime
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Ecual Ocportunity Altirmative Action Employer 500.1. recycled/ 10% post-consumer paper
State of North Carolina .
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary p E ?---? N F=1
A. Preston Howard, Jr., P.E., Director
September 30, 1997
MEMORANDUM
TO: Melba McGee
FROM: Michelle Suverkrubbe
THROUGH: A. Preston Howard, Jr., P.E.
RE: Comments on SCH # 98-0029; DWQ#11686
Piedmont Triad Regional Water Authority (PTRWA)
Randleman Lake DEIS
Randolph and Guilford Counties
The proposed project consists of a Draft Environmental Impact Statement (DEIS)
on the Section 404 Permit prepared by the Army Corps of Engineers for the Randleman. Lake project for Piedmont Triad Regional Water Authority (PTRWA). The DEIS will also
be used by the Division of Water Quality (DWQ) in issuing a Section 401 Water Quality
Certification for the project.
The project entails discharging dredged or fill materials into waters of the US and
their contiguous wetlands. The proposed water supply reservoir will inundate 28 miles of
we,Ja dsland streams, ,000 acres of forestlagricultural and resid ntial land. oval
.•*1an ,
The Division has reviewed the DEIS. As you will note, the Division is very
concerned about the future water quality in the proposed reservoir. The Division,
however, is prepared to issue a 401 Water Quality Certification on this project, subject to
the condition that PTRWA develop (with DWQ's assistance) a Nutrient Reduction Strategy
and Watershed Management Plan for the Randleman Lake Watershed.
This Strategy and Plan will need to determine the level of nutrient reduction
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
Strategy and Plan will also need to define the specific management strategies necessary to
achieve the nutrient reductions, and demonstrate how these necessary reductions will be
accomplished and sustained into the future for the watershed. This Management Plan and
Nutrient Strategy will need to be approved and put in place (i.e. local government
ordinances adopted and effective, if necessary) pnor to the reclassification of the
Randleman Watershed for Water Supply purposes.
P.C. Ecx 29535, Raleiah, North Carolina 27626-0535 50 elepholedl9 0°/733-5 83 F post-consumer
An C?'J2i Opportunity Affirmative Action Employe
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 2
Regions / Program Management Coordination Branch Comments on DEIS
1. The DEIS states that Randleman Lake would be expected to violate the state water
quality standard for chlorophyll a (40 mg/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 Eastside
W V P discharging effluent of total phosphorous of 0.5 mg/l, nuisance algal
blooms are still predicted to occur 70-80 % of the time in the upper Deep River arm,
and violations of the water quality standard for chlorophyll a are still anticipated to
occur throughout the proposed lake, due to point and non-point sources of nutrients
in the watershed.
In response to this prediction of eutrophication in the future reservoir, the DEIS
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
state in-stream and in-lake water quality standards (see 15A NCAC 2B .0211) that
require consideration of other potential uses of the reservoir, including aquatic life
propagation and survival, fishing, wildlife, secondary recreation (wading and
boating), and agriculture.
The Division has found that the Deep River currently exhibits consistent problems
associated with elevated nutrient loading such as nuisance algal blooms and low
dissolved oxygen (DO). The Division is seriously concerned that impoundment of
the river will tend to exacerbate these existing eutrophic conditions, potentially
leading to extensive algal blooms, low dissolved oxygen, common occurrence of
fish kills, reduction of fish stocks, decrease in the diversity of fisheries, taste and
odor problems in the drinking water (even after treatment), and reduced
opportunities for human recreation on the lake.
2. An explanation should be provided in the EIS addressing specifically which
alternatives under review in this DEIS differ from the alternatives discussed for the
prior EIS (dated 1991, prepared by the NC Division of Water Resources). Also,
the EIS should discuss why the selection of alternatives for the project has changed.
3. Alternative A, the Upper Deep River Lake, is proposed to flood parts of the
Seaboard Chemical Company, High Point Landfill and High Point Eastside WWTP
sites. Therefore, due to the potential environmental impacts of hazardous waste
leaching from these buried sites into the reservoir and the cost to relocate the
existing Eastside Plant, this alternative was deemed unacceptable in the EIS. The
EIS should either consider a redesign of this alternative so that flooding of these
sites would not occur, or discuss why this alter-native cannot be redesigned to avoid
flooding these sites. Obviously, if this alternative was not designed to flood these
sites, the acceptability of that alternative may be substantially greater, both in terms
of reduced costs (especially the $64 million to relocate the High Point Eastside
WWIP) and fewer potential environmental/ health (toxicant)- impacts.
4. On pages 1-5 and 1-6 of the document, the reasons that the Randleman Dam
proposal is considered the preferred alternative are discussed. One of the
mentioned items was cost. The conclusion that the Randleman alternative is least
costly does not take into consideration the issue mentioned in item 2. If the
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 3
replacement of the High Point Eastside W VV`TP was removed from Alternative A
(Upper Deep River Lake), its costs would be reduced by $64 million to
$108,912,624, making it the cheapest alternative discussed in this EIS, cheaper
than the Randleman alternative by $14 million.
The costs listed for the Randleman alternative presented in Table 13 do not appear
to be complete. The document should indicate how the $200,000 listed for cleating
up the Old Randleman Dump was derived. The Randleman alternative should
include estimated costs to remediate and clean up the groundwater from the High
Point Landfill and the Seaboard Chemical sites to protect aquatic and human health
water quality standards in the proposed reservoir (that are necessary due to the
proposed reservoir, and would not be necessary if the reservoir was not proposed).
The Randleman alternative should also indicate the potential costs to build a water
treatment plant with the advanced technology necessary to treat the water quality
expected in this lake, e.g. GAC (activated carbon), membrane filters, auxiliary
treatment lagoons, etc. Such an advanced plant would not necessarily be required
for the other alternatives. A true and complete representation of costs presented is
necessary before it can be stated that Randleman Lake is "estimated to be the least
costly alternative by a substantial margin."
5. Paces 3-4 of the DEIS, it is stated that, "Contamination of groundwater in the
vicinity of the proposed reservoir has created some concern regarding potential
impacts on water quality of the lake. Toxic substances from the abandoned
Seaboard Chemical Company and the Closed High Point Landfill, both of which
are loc-ted along, the Upper De--p River adjacent to the proposed reservoir, have
contaminated the groundwater at each site. However, modeling studies have
pr°dict_-d that contaminated groundwater from these sites 'should not have any
sig,ni.ticant impacts on the water quality of Randleman Lake'." This statement was
taxzn fmm earlier modeling results of several Black & Veatch studies dating back to
1991.
DWQ has re,,iewed comments made by Bill Meyer with the Division of Waste
:?ianag,e cent (dated 8/26/97) on this DEIS. DN. I states that they believe "the
conta.:; inant loading to the De--p River is substantially higher" (yet un-quantified),
than the- modeled by Black and Veatch.
The Special Order for cleanup of these sites (which was recently published in the
NC Register) indicates Imown releases of hazardous substances on the sites. Soils
tests have revealed the presence of volatile and semi-volatile organic compounds,
i:ciudLn2 but not limited to ac--tone, 1,2-dichlorobenzene, 1,1-dichloroethene, 1,2-
diciuoroethene (total), methylene chloride, 1,1,1-trichlorcethane, phenol,
raphLa _iene, bis-2 ethyl hexyl phthalate, and 1?,4 trichlorobenzene.
Gr; ? .d ?.afe: samplina (separate from the current tesfinQ being performed for the
Re: •w':;.ation Investigation), revealed the presence of volatile and semi-volatile
ora27-ic compounds, inc:udine but not limited to atone, benzene, 1,1-
d1c,or"ethane, 1,2- dic'Joroethane, 1,1-dichloroethene, 1,2- dichloroethene
(u,ta2).:,,?? yle:.e chloride, 1,1,1-trichloroethane, phenol, and naphtahlene.
T -z D',le =r on the cu:-Tent DEIS indicates that the results of the Remedial
Lf,;°s?zsLOn .•ul not be available until February, 1998. The potential toxicant
DEHNR #98-0029
Randleman DEIS
DWQ Comments
page 4
impacts to the water quality of Randleman Lake should be reevaluated upon receipt
of the February Remedial Investigation Report.
6. On page 3-28, the DEIS states that, for Randleman Lake "watershed protection
measures have been in place for more than eight years" Also, on page 3-29 it is
stated that "... other alternatives involve Rockingham and Alamance Counties,
which do not have watershed protection ordinances." Both of these statements are
misleading.
The Division manages the Water Supply Watershed Program for the state and our
records indicate the correct statements should be:
(Page 3-28) - "For the Randleman Lake watershed, 86% of the watershed is
currently protected under water supply watershed protection programs by local
governments - Randolph County (which comprises 37% of the watershed),
Guilford County (47%), and Greensboro (2%). The municipalities of Archdale,
which makes up 6% of the watershed, and High Point (8%), Jamestown (1%), and
Randleman (1%) are not currently implementing any water supply watershed
protection programs for the Randleman Lake watershed, although they may have
watershed protection ordinances that require protection of other watersheds in their
jurisdictions."
(Page 3-29) - "Rockingham and Alamance Counties both have adopted watershed
protection ordinances which protect approved water supply watersheds in their
jurisdictions; however, neither have yet adopted protections for any of the
alternatives discussed in this EIS, including the Randleman alternative."
(Pages 5-24 and 25) - It is accurately stated that Guilford and Randolph Counties
have enacted watershed protection ordinances, but they fail to mention the fact that
Greensboro also currently protects the Randleman watershed.
In addition to amending these above sections, the EIS should provide an
explanation for why the municipalities listed have not chosen to enforce watershed
protection provisions in the Randleman Watershed.
7. Table 10, page 3-16 discusses surface water evaluation criteria for each alternative.
This table should include a criteria for whether or not each alternative would meet
state water quality standards (including protecting aquatic life, recreational, and
water supply uses).
8. The Corps should refer back to DWQ's letter to PTRWA on January 24, 1997 for
specific comments on the wetlands aspects of this project and mitigation proposed
by PTRWA.
misA980029 Randleman EIS
?tff-
cc: DWQ staff
DEN - Public Water Supply
PIRWA - Mr. John Kime
State of North Carolina
Department of Environment,
Health and Natural Resources 4 • ;
Division of Environmental Management
James B. Hunt, Jr., Secreta ID FE H N PI
Jonathan B. Howes. . Secretary
A. Preston Howard, Jr., P.E., Director
October 6, 1995
ME-'CIO
To: Wetland consultants and municipalities
A
From: John Dom&
Re: Modification to Certification for Nationwide Permit 12 - Utilitv lines
The Division of Environmental Management (DE-M) has reissued the Gene -t Certification
(GC) for Nationwide Permit 12 and Regional Pe:rnit 049. The new GC will expedite the pe.-mitung
process and clarify for the applicant conditions necessary for a certifiable project The significant
changes are:
1) No fertilizer applied within 10 feet of sueams;
2) Anti-se-cp collars every 150 feet in wetlands;
3) Restore to original contour after construction. A specific plan is needed;
4) Rip rp is restricted to stream bosom and banks directly impacted by the
utility line;
5) The construction corridor (including acczss roads and stock=iling of materials)
is limited to 40 feet in width;
6) Construction corridors parallel to streams shall be placed at the furthest
distance from the stream to the maximum extent practicable; and
7) Although you still need to aDOly to the U.S. Armv Corns of Engineers for
these oe:-mits. written concurrence from DENT is no longer needed orovided
that all conditions of the General Certification are followed. Written
is rcquired it' zu'le iiuiiry Use i5 instau'led parallel and closer than 10
feet to a stream or if the line crosses a stream channel at less than 75 degrees
or more than 105 degrees (i.e., not perpendicular stream crossing). y
A copy of the revised GC is enclosed for your information. DE-M will be making compliance
site inspections. Should the utility line be installed such that a condition is violated, remedial actions
includinz utility line relocation or installation of anti-seep collars fines may be imposed.
1786.
Should you have any questions, please contact Eric Galamb or John Domey at (919) 733-
nwl2.mun
RECEIVED
OCT 16 1995
F14VIRCNMENTAL MENCES
F.O. Box 29535. Rdeiah. Norlh Carolina 27626-0525 Teaechone 919-733-7015 FAX [phone]
GENERAL, CERTIFICATIONS FOR PROJECTS ELIGIBLE
FOR CORPS OF ENGINEERS NATIONWIDE PERMIT NDM:ER 12 OR
REGIONAL PERMIT 049 (UTILITY LINE EACKFILL AND EEDDING)
This General Certification is issued in conformity with the requirements of
Section 401,. Public Laws 92-500 and 95-217 of the United States and subject to the
Nonh Carolina Division of Environmental Management Regulations in 15A NCAC 2H,
Section .0500 and 15A NCAC 2B .0109 AND .0201 for the discharae of fill material to
waters and wetland are-as as described in 33 CFR 330 Appendix A (6) (12) and
General Permit No. 198100049 of the Corps of Engineers regulations (i.e., include any
fill activity for utility line backfill and bedding. This certification replaces Water Quality
Certification Number 2664 issued on January 21, 1992 and is rescinded when the
Corps of Engineers reauthorize Nationwide 12 or Regional Permit 049.
The State cf North Carolina certifies that the specified category of activity will
not violate Sections 301, 302, 303, 306 and 307 of the Public Laws 92-500 and 95-
217 if conducted in accordance with the conditions hereinafter set fonh.
Conditions of Certification:
Activities covered by this Genera! Certification do not require written
concurrence from the Division of Environmental Manaaernent (DEM) as
Iona as they comply with all conditions of this General Certification and
the conditions of Nationwide 12 or Regicnal.Permit 049;
2. Written concurrence from DEM is required if the utility line is installed
paralie! to and closer than 10 feet (3 meters) to a stream or if the utility
line crosses a Stream channe! at less than 75 degrees or more than 105
cecrees (i.e., not perpendicular sire-=m arcs-zing) of the stream bank;
3. Construction corridors para!le! to streams shall be placed at the furthest
distance from the stream to the maximum extent practicaiDie;
4. That established sediment and erosion control practices UE UtiIiZed to
prevent violations of the 21Dprooriate turbidity water qu2lity standard (50
N T Us in stre2mS and rivers not desicnated'as trout Waters by DEM; 25
N T Us in a!I salt water classes, and all lakes and reservoirs; and 10 NTUs
in trout waters). All sediment and erosion control me2sures placed in
wet12nds shall be removed and the natural crade restored after the
Division of Lend Resources has re!eased the prciect;
5. Annul'. Species suitable for wet locations S l2!l be planted within
jurisdicticn2l wetlands for soil and erosion ccntrcl. Perennials such as
fescue are prohibited;
6. Nc fertilicer sha!I be applied within 10 feet (3 meters) of streams;
7. The construction corridor (including access roads and stockpiling of
materials) is limited to 40 feet (12.2 meters) in width and must be
minimized to the maximum extent practicable.
8. Measures shall be taken to prevent live or fresh concrete from coming
into contact with waters of the state until the concrete has hardened;
9. Permanent, maintained access corridors shall be restricted to the
minimum width practicable and shall not exceed 10 feet (3 meters) in
width except at manhole locations. A 10 feet (3 meters) by 10 feet (3
meters) perpendicular vehicle turnaround must be spaced at least 500
feet (152.4 meters) apart.
10. An anti-seep collar shall be placed at the downstream (utility line
gradient) wetland boundary and every 150 feet (45.7 meters) up the
Gradient until the utility exits the wetland for buried utility lines. Anti-seep
collars may be constructed with class 6 concrete or compacted clay.
Perpendicular wetland crossings less than 150 feet (45.7 meters) Iona do
not require anti-seep collars.
The compacted clay shall have a specific discharge of 1 X 10'5 cm/sec or
less. A section and plan view diagram is attached for compacted clay
and concrete anti-seep collars.
The following specifications shall apply to class 6 concrete:
a) Minimum cement content, sacks
per cubic yard with rounded
course aggregate 5.0
b) Minimum cement content, sacks
per cubic yard with angular
course aggregate 5.5
c) klaximum water-cement ratio
gallons per sack 6.8
d) Siump range 2" to 4"
e) Minimum strength - 28 day psi 2,500
11. Placement of rip rap is restricted to stream bottom and banks directly
impacted by the placement of the utility line. The.stream berm must be
restored to the original contour after construction;
12. This general certification does not authorize any permanent changes in
preconstruction elevation contours in waters or wetlands. The permittee
will have a specific plan for restoring wetland contours. Any excess
material will be removed to a hich ground disposal area;
13. If an environmental document is required, this Certification is not valid
until a FONSI or ROD is issued by the State Clearinghouse;
14. Stormwater management shall not be required for this Certification;
15. Compensatory mitigation (i.e., restoration, creation or preservation) for
wetland losses will not be required for this Certification;
16. This Certification does not relieve the applicant of the responsibility to
obtain all other required or local approval.
Non-compliance with or violation of the conditions herein set forth by a specific
fill project shall result in revocation of this Ce ?ification for the project.
The Director of the North Carolina Division of Environmental Manacement may
require submission of a formal application for individual certification for any project in
this category of activity, if it is determined that the project is like!y to have a significant
adverse effect upon water quality or decrade the waters so that e!CIS Ing uses of the
wetland or dcwnstre?m waters are precluded.
Public hearincs may be held for specific applications or croup of applications
prior to a certification decision if deemed in the public's best interest by the Director of
the North Carolina Division of Environmental Manaae.ment.
This is the C day of September, 1995
DIVISION OF ENVIRONMEJVTA.L P:1r.NAGEMENT
f ?
Ey l
A. Freston Howa.7
- Director
nwt 2b.cer
WOC r 3022
ANTI -SEEP COLLAR
I. 18 I
I inches . I Utility Line
I (Diameter Varies)
I I
1 foot I Class B Concrete
L - or Compacted Clay
vL-I
6 inches Bench Width 6 inches
Not to exceed 40 feat
SECTION
Class B Concrete
or Compacted Clay
I
t_1 2
inches
6 inche? W+ -*-P .6 finches
PLAN
N(-h1RC.HC'P,FALLS LAKE TEL:[phone] Oct 10'97 10:54 No.002 P.02
i
North Carolina Wildlife Resources Commission t
512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733.3391
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: Melba McGee
Office of Legislati(vee and In overnme 1 Affairs
FROM: Owen F. Anderson, Pie nt Region Coordinator
Habitat Conservation Program
DATE: October 10, 1997
SUBJECT: Scoping for Environmental Assessment for Piedmont Triad Regional Water
Authority, Transmission Mains, Guilford and Randolph Counties, North Carolina,
98-0134
Biologists with the North Carolina Wildlife Resources Commission have reviewed the
subject document. Our comments are provided in accordance with provisions of the Fish and
Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.) and the North
Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; 1 NCAC 25).
The Piedmont Triad Regional Water Authority (PTRWA) proposes to construct water
transmission lines to convey water from the proposed new water treatment plant for Randleman
Lake to members of the PTRWA (i.e., Randolph County, Randleman, Greensboro, Archdale, and
High Point).
Most of the water lines appear to follow highway rights of way; therefore, we would not
anticipate significant direct impacts to fish and wildlife habitat. However, even read rights of
way can provide important habitat, including habitat for endangered species (e.g., Schwenitz's
sunflower).
Our major concerns from projects such as this are the sewndary and curnulative impacts
from development. Fish and wildlife have been impacted already in the sprawling urbanized
Triad area. The water supply and transmission lines will cause additional adverse impacts to fish
and wildlife populations, Water quality in area streams is already of such poor quality that the
proposed Randleman Reservoir is questionable for water supply and recreation. Also, interbasin
transfers that will result from these projects will result in further degradation of water quality and
recreational opportunities in the Haw River and Jordan Reservoir.
The information provided is not sufficient for our staff to make definitive
recommendations or conclusions concerning this project. Due to staff limitations, this
su mdardized response was developed for projects such as this. Although some of the
infrmnation, requests and comments may not be applicable to certain projects, these guidelines
NCWRC,HCP,FRLL5 LRKE TEL:[phone] Oct. 10'97 10:55 IVo.002 P.03
PTRWA Water Transmission System 2 October 10, 1997
Guilford/Randolph Counties
should facilitate preparation of fish and wildlife impact assessments. This information will be
very useful if it becomes necessary to prepare an environmental document.
In addition to addressing the concerns discussed above, the environmental document
should include a detailed assessment of existing natural resources within these areas of potential
development and should discuss the potential of mitigating development impacts to wetlands,
waters and high quality upland habitat. Additionally, to provide a meaningful review of
proposed project impacts on fish and wildlife resources, we request that consultants, project
sponsors or permit applicants provide the following information in the environmental document:
Include descriptions of fish and wildlife resources within the project area, and it listing of
federally or state designated threatened, endangered or special concern species. When
practicable, potential borrow areas to be used for project construction should be included
in the inventories. A listing of designated species can be developed through consultation
with: The Natural Heritage Program, NC Division of Parks and Recreation, P. O. Box
27687, Raleigh NC 27611, PH: [phone].
2. Include descriptions of any streams or wetlands affected by the prniect.
3. Include project maps identifying wetland areas. Identification of wetlands may be
accomplished through coordination with the U.S. Army Corps of Engineers (C(AE). If
the COO is not consulted, the person delineating wetlands should be identified rind
criteria listed.
4. Provide a description of project activities that will occur within wetlands, such as fill or
channel alteration. Acreage of wetlands impacted by alternative prcliec:t designs should
be listed.
5. Provide a description and a cover type map showing acreage of upland wildlife habitat
impacted by the project.
6. Discuss the extent to which the project will result in loss, degradation or fragmentation of
wildlife habitat (wetlands and uplands).
7. Discuss any measures proposed to avoid or reduce impacts of the project or to mitigate
unavoidable habitat losses.
8, Discuss the cumulative impacts of secondary development facilitated by the proposed
project. Such discussion should weigh the economic benefits of such growth against the
costs of associates] environmental degradation.
(a) Include specific measures that will be used to address stormwater at the source.
Include specific requirements for both residential and industrial developments and
BMPs that will be required. It is our understanding that High Point, Jamestown and
Archdale do not currently have stormwater regulations in place. It is recommended
that these communities and Randolph County implement stonmwater regulations wid
management to help address the severe water quality problems in area streams and
mitigate some of the impacts that will be caused by development of this water supply.
It is further recommended that these conununities make a commitment to protecting;
area streams with riparian buffers through purchase or conservation easement.
(b) Include specific measures that will be used to protect stream corridors, riparian
habitat and a minimum of a 100-year floodplain.
L
NCWRC,HCP,FRLLS LAKE TEL:[phone]
PTRWA Water Transmission System 3
Guilford/Randolph Counties
Oct 10'97 10:56 No.002 P.04
October 10, 1997
(c) Include specific measures that will be implemented to promote water conservation
and wastewater reuse.
(d) Include a discussion of any other local ordinances or programs (e.g., industrial
pretreatment, infiltration and inflow management and recycling) that will mitigate the
impacts of development.
9. Include a list of document preparers that shows each individual's professional background
and qualifications.
Measures to avoid or minimize impacts to sensitive resources, including wetlands, should
be implemented during construction. Where impacts to wetlands are unavoidable, we will
recommend mitigation of the losses. In addition to providing wildlife habitat, wetland areas
perfor,n important functions of flood control and water quality protection.
To avoid or minimize wetland impacts, we offer several generalized recommendations.
Utility lines should be placed in or adjacent to upland areas. It is recommended that a minimum
100-foot buffer of natural vegetation be left between construction corridors and the banks of
perennial streams. These buffers will help minimize impacts to water quality, stabilize stream
banks and provide travel corridors for wildlife. Trees and shrubs should be retained or
established in the buffers. Buffers should also be left, along intermittent drains or streams.
Construction corridors should be no wider than absolutely necessary. The 401.
certification for Nationwide Permit 12 stipulates that wetland construction corridors are not to
exceed 40 feet and permanent maintained corridors are not to exceed 10 feet except at access
points. Plant communities should be re-established that will result in wetland plant community
succession into habitat of equal or greater value than the habitat that was destroyed. Disturbed
wetland areas should he returned to original soils and contours. Temporarily disturbed wetlands
should be reseeded with annual small grains appropriate for the season (e.g. oats, millet, rye,
wheat, annual lespedeza grass) s shouand be ld be min mized, located at narrow areas, vegetation.
Crossings of wetletlands and strre
perpendicular to the stream.
Thank you for the opportunity to provide input in the early plaruiing stages for this
project. If we can he of further assistance, please contact our office at [phone].
OFA/ofa
cc: Kevin Moody, Biologist, USFWS
Michelle Suverkrubbe, Division of Water Quality
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor C) FE"FR
Wayne McDevitt, Secretary
William L. Meyer, Director
September 12, 1997
TO: Melba McGee
Office of Legislativ Intergovernmental Affairs
FROM: Michael A. Kelly
Deputy Director
SUBJECT: Project Number: 98-0134
Randolph County
..The Waste Management Division has reviewed and commented on
the above-referenced project. Please find enclosed separate
comments from the Hazardous Waste Section, Solid Waste Section
and Superfund Section.
Should you have additional questions, please feel free to
contact our office.
MK:sh
Enclosures

P.O. Box 29603, Raleigh, North Carolina 27611-9603 Telephone [phone]
An Equal opportunity Affirmative Action Employer 50% Recycled / 10% Post-Consumer Paper
I
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
e??
[DEHN
September 11, 1997
MEMORANDUM
TO: Michael Kelly, Deputy Director
Division of Solid Waste Management
FROM: Philip J. Prete, Head
Field Operations Branch
Subject: Piedmont Triad Regional Water Authority (PTRWA)
Water Transmission Mains and Associated Facilities
Environmental Impact Study
The Solid Waste Section has reviewed the attached project proposal and has seen no
adverse impact on the surrounding community and likewise knows of no situations in the
community which would affect the project.
The PTRWA should make every feasible effort to minimize the generation of waste, to
recycle materials for which viable markets exist, and to use recycled products and materials in the
development of this project where suitable. All waste generated by this project must be disposed
of at a solid waste management facility permitted by the Division. The nearest facility permitted
to receive land clearing and inert debris is located on Pine Hill Road in Asheboro, Randolph
County. Please contact the site operator, Don Pritchard, at [phone] for more information.
Additional questions regarding soild waste management may be directed to Mr. Hugh
Jernigan, Waste Management Specialist, Solid Waste Section, at [phone] extension 206.
PJPAcf
cc: Hugh Jernigan
P.O. Box 27687, W ;6 FAX [phone]
V? C An Equal Opportunity Affirmative Action Employer
N A*
Raleigh, North Carolina 27611-7687
Voice 919-733-4996 500% recycled/ 100% post-consumer paper
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Solid Waste Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
William L. Meyer, Director
A4
± 111110?lk
,E? EHNR
TO: Division Secretary, Waste Mgt. Division
FROM: Joseph H. Deakins, Waste M t. Specialist
Hazardous Waste Section / '
DATE: August 21, 1997
SUBJECT: (PTRWA) Water transmission mains and associated facilities to
be constructed in conjunction with the Randleman Lake Project.
The Hazardous Waste Section has reviewed the noted project and-
offers the following comments:
Trinity Foam, Glenola, on Highway 311, is currently in litigation with
the State over groundwater contamination and air permit questions. Tritech
Environmental may want to look at the situation at Trinity Form.
I see no problems at other locations on the map. If a site is
encountered during the project that involves hazardous waste, please call
[phone].
CC: Keith Masters
Guilford County File
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Waste Management
James B. Hunt, Jr., Governor p E ?---? N R
Wayne McDevitt, Secretary
William L. Meyer, Director
MEMORANDUM
August 20, 1997
TO: Mike Kelly, Deputy Director
Division of Solid Waste Management
THROUGH: Bruce Nicholson, Head, Special Remediation Branch 6id
Superfund Section
FROM: S. Franch, Environmental Chemist, ,?,
Superfund Section ?`
SUBJECT: Piedmont Triad Regional Water Authority (PTRWA) Water Transmission
Mains and Associated Facilities Project (Randolph County)
I have completed the review of the attached information on the subject project for the
proximity to CERCLIS or inactive hazardous waste sites. The subject project involves the
construction of about 72,000 linear feet of water main, a ground storage tank, an elevated storage
tank, and a booster pumping station. These water mains (denoted on the attached map) and
facilities will be installed in northern Randolph County along Highway 311, Highway 220
Bypass, and SR 1936. Four sites were found within a four-mile radius of these proposed water
mains. These sites are described below and are denoted on the attached map.
Both the Union Carbide Corp. Site (NCD 000 822 957) and the Burlington Industries
Asheboro Warehouse 1190 (NCD 000 822 064) are located about three and four miles south,
respectively, of the Highway 311 water main. The Old Randleman Town Dump Site (NCD 986
197 374) and the JP Stevens Co. Site (NCD 003 226 560) are located about 1.2 miles and 2.2
miles, respectively, southeast of the Highway 220 water main.
After reviewing the file infonnation, I believe it is unlikely that the project will affect the
sites or vice versa. If you have any questions, please call me at ext. 314.
cc: Bruce Nicholson
P.O. Box 29603, Raleigh, North Carolina 2761 1-9603 Telephone [phone]
An Equal Opportunity Affirmative Action Employer 50% Recycled / 10% Post-Consumer Paper
H
Q N t © 71 O:
r
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V 1? C by ??A
'--/\ f^ Cron ` Q
ARCHDALE Cross -
POP. 5.326 t;. 31 ] U_A
U1LFORD,CO6139 \? `• yf 2797
>r C eo ??\ Ills 1.9
or, r VIA t
t::.:.
t: :;; ftG 71,E
•• DY. Glenda ? ` ,` Y ?\\\
J~ 1961 a
U
.3
7113
`Presumed Location of Project.
1 $ .reed
711 1
P
Edgar Branch
the
C:1
J11
^2]22T9' 2113 7116 .
EXT,- liew Old Randleman
Johnson Field orket LANE' TOWn Dump
% -
.
NORTHWESTERN NCO 9136 197374
tr' em cl ( 2?1?
FfillrvilM, ?'
Co
/ J f Sophia .?T `' t fps POP. 1.1 $teVOllSr JP St
111 NCO 003 226 560'
O ti .? t 70 4f' t:
P , 1
,?, L`Tw`'•S
177
•t
2
Worthville
to 1.6
1540-' Flint Hill •a' 1527 IN • Satellite
,r
1524 i
,o 13]1 of
o I Randle- n.
m
1701,2 •J i 1 1311
131 , 1317 712e
.o ?? / lees jQ0A -•^ ? 2 712
o B ;14A' .7
1
I579 X1507 \ 2 2712
.7 \? T 171 .D. 4 t'
Union Carbide Corp ° 7261
NCD 000 622 957 .._f 1 LINE i
111 3119 t___ I W v - .i f
A-. &ntrol
'? ? a ? FoIIY. /
171 1?, Burlin ton Ind 1767
SHEPHERD MTN. -? r? S 9
7 Rr r ti ti 1519 .3 Asheboro
SEepherd cJ"LA ,7i ? '9 Whse 1190
4'• 1412 NCO 000 622 064
,. a
1 'N is o', 1520 b r.< ..;X /• :? 2715
477 t? .J. Is18 ?:7 .>r ( :i.;
Ins 1 O .J 71 ,, . O. IQ4d t;. A \rID v? .J
17 ° SCALE - / r 2217
%.A 19 \7, 271.6
6, .7 0 1 2 3 4 MILES „t,• :? ?'J
1411
176 0 0.5 1 MILE
]]a o?G.6 SCALE FOR ENLARGEMENTS i
o :.I f I
1]]D. , ygSHEB.aR I ; 311:
3
POP. 15,25• Z,
\ 770E
10,000 FOOT GRID 4AS4ED ON NORTH CAROLINA PLANE COORDINATE SYSTEM T'•^
13]1 POLYCONIC PROJECTION 42
1710 177Y v V n??,........_ - - \ .,
9 11377 f ' (UNHNC.) Z •?
1377 1363 .6 1326 4 F POP. All
b •'j i ?_ ?..
11 1p
/ P ?' ?0G 1220 ry1359 .. \ ..L` 7
State of North Carolina Reviewing Office:
Department of Environment, Health, and Natural Resources (_0 '5 V_A_J
Project Number: Due ate:
INTERGOVERNMENTAL REVIEW - PROJECT COMMENTS _ O1 3 l} (_ a
After review of this project it has been determined that the EHNR permit(s) andfor approvals indicated may need to be obtained in
order for this project to comply with North Carolina Law.
Questions regarding these permits should be addressed to the Regional Office indicated on the reverse of the form.
All applications. information and guidelines relative to these plans and permits are available from the same Normal Process
Time
Regional Office. (statutory time
SPECIAL APPLICATION PROCEDURES or REQUIREMENTS limit)
PERMITS

t Application 90 days before begin construction or award of 30 days
construct d operate wastewater treatmen
? Permit t
6 sewer
m extensions
t construction contracts On-site inspection. Post-application
(90 days)
.
e
sewer sys
facilities. technical conference usual
ayslems not discharging into state surface waters
systems
NPDES - permit to discharge into surface water and/or Application 180 days before begin activity. On-site inspection.
Additionally. obtain permit to
nference usual
i 907120 days
? permit to operate and construct wastewater facilities
tate surface waters
i .
on co
Pre-appl cat
construct wastewater treatment facility-granted after NPDES Reply (N'A)
nto s
discharging s after receipt of plans or issue of NPDES
30 d
ay
time.
permit-whichever is later.
days
Pre appl cation technical conference usually necessary =
? Water Use Permit
7 days
Complete application must be received and permit issued (15 days)
Well Construction Permit prior to the installation of a well.
Application copy must be served on each adjacent riparian property 55 days
On-site inspection. Pre-application conference usual. Filling
owner
redge and Fill Permit .
may require Easement to Fill from N.C. Department of 190 days),
Administration and Federal Dredge and Fill Permit.
'
Permit to construct 8 operate Air Pollution Abatement N/A
facilities and/or Emission Sources as per 15A NCAC
Of0
Any open burning associated with subject proposal
? must be in compliance with 15A NCAC 2D.0520
Demolition or renovations of structures containing

n compliance with 15A
asbestos material must be i

NCAC 2D0525 which requires notif cation and removal NIA
prior to demolitionContact Asbestos Control Group
919 733 0820
? omplex Source Permit required under 15?, NCAC 2D.0800.
The Sedimentation Pollution Control Act of 1973 must be properly addressed for any land disturbino activity. An erosion 8 sedimentatio
er Regional Ollice (Land Quality Sect.) at least 30
ro
ith
fil
d
20 days
control plan will be required if one or more acres to be dist
e of S30 for the first acr
A f p
w
p
e
urbed. Plan
e and S2000 for each add uonal acre or Dan must accompanv the Ian y
s
e
days before be innino activity
n Pollution Control Act of 1973 must be addressed with respect to the referrenced Local Ordinance:
ti y5,
(30 da
o
? The Sedimenta
On site inspection usual Surety bond filed with EHNR. Bond amount
varies with type mine and number of acres of affected land Any area 30 days
? Mining Permit mined greater than one acre must be permited The appropriate bond 160 days
must be received before the permit can be issued
On site inspection by N.C. Division Forest Resources if permit ddaa
? Norin Carolina Burning permit exceeds 4 days I
Special Ground Clearance Burning Permit 22 On site inspection by N.D. Division Forest Resources required "if more
tions
I 1 day
(NIA)
? counties in coastal N C with Organic sods nspec
than five acres of ground clearing activities are involved.
uested at least ten days before actual burn is planned "
re
h
ld b
q
ou
e
S
90 t20 ca•s

? NIA (NIA}
Oil Refining Facilities
It permit required. application 60 days before begin construction.
30 days
Applicant must hire N C. qualified engineer to: prepare plans.
inspect construction. certify construction is according to EHNR approv
? Dam Salety Permit ed plans May also require permit under mosquito control program. And
60 days
a 404 permit from Corps of Engineers. An inspection of site is neces
sary to verify Hazard Classification. A minimum fee of 5200.00 must ac
company the application. An additional processing fee based on a
percentage or the total project cost will be required upon completion
Continued on reverse
NormaVkocess
Time - l

(statutory time
PERMITS SPECIAL APPLICATION PROCEDURES or REQUIREMENTS limit)
File surety bond of 55,000 with EHNR running to State of N.C. 10 days
Permit to drill exploratory oil or gas well conditional that any well opened by drill operator shall, upon
l
i (NIA)
at
ons.
abandonment, be plugged according to EHNR rules and regu
Q Geophysical Exploration Permit Application filed with EHNR at least 10 days prior to issue of permit
ation form
li
d
d
N 10 days
(N/A)
.
ar
c
o stan
app
Application by letter.
State Lakes Construction Permit Application fee based on structure size is charged. Must include 15.20 days
Q descriptions 6 drawings of structure i3 proof of ownership (NIA)
of riparian properly.
60 days
401 Water Ouatity Certification NIA (130 days)
55 days
? CAMA Permit for MAJOR development $250.00 fee must accompany application (150 days)
22 days
? CAMA Permit for MINOR development 550.00 fee must accompany application (25 days)
Several geodetic monuments are located in or near the project area. If any monuments need to be moved or destroyed. please notify:
? N.C. Geodetic Survey, Box 27687, Raleigh, N.C. 27611
bandonment of any wells. if required, must be in accordance with Title 15A, Subchapter 2C.0100.
otification of the proper regional office is requested if *'orphan" underground storage tanks (USTS) are discovered during any excavation operation.
45 days
E) Compliance with 15A NCAC 2H.1000 (Coastal Stormwater Rules) is required. (NIA)
Other comments (attach additional pages as necessary. being certain to cite comment authority):
?fl??K P IZ1 I01?
A- 6/iZS19?
ANY CONSTRUCTION ACTIVITIES INCLUDING CLEARING, GRADING, AND
EXCAVATION ACTIVITIES RESULTING IN THE DISTURBANCE OF FIVE (5) OR MORE
ACRES OF TOTAL LAND ARE REQUIRED TO OBTAIN A NPDES STORMWATER PERMIT
PRIOR TO BEGINNING THESE ACTIVITIES. ?, G-e,•(? ?- Z ?_5 7
REGIONAL OFFICES
Questions regarding these permits should be addressed to the Regional Office marked below.
? Asheville Regional Office ? Fayetteville Regional Office
59 Woodfin Place Suite 714 Wachovia Building
Asheville, NC 28801 Fayetteville, NC 28301
[phone] [phone]
? Mooresville Regional Office
919 North Main Street, P.O. Box 950
Mooresville, INC 28115
[phone]
? Washington Regional Office
1424 Carolina Avenue
Washington, NC 27889
[phone]
? Raleigh Regional Office
3800 Barrett Drive, Suite 101
Raleigh, INC 27609
[phone]
? Wilmington Regional Office
127 Cardinal Drive Exlcnsion
Wilmington, NC 28405
[phone]
? Winston-Salem Regional Office
8025 North Point Blvd.
Suite 100
Winston-Salem, NC 27106
[phone]
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Land Resources
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Charles H. Gardner, P.G., P.E.
Director and State Geologist
A VK -Xig
YT-?'?T
[D F= F1
PROJECT REVIEW COMMENTS
Project Number: _9S_013+ County: 4ggnQlO1ah
I
Project Name: Ped&?oW TY?G?tAle Cq%OrA4/ la v Igor; ??+?-?-r- ,??e.s
NC Office of State Planning - Geodetic Survey
This project will impact *)o geodetic survey markers. N.C.
Geodetic Survey should be contacted prior to construction at P.O.
Box 27687, Raleigh, N.C. 27611 [phone]. Intentional
destruction of a geodetic monument is a violation of N.C. General
Statute 102-4.
This project will have no impact on geodetic survey markers.
Other (comments attached)
For more information contact the N.C. Office of State
Planning, Geod tic Survey office at 919/733-3836.
W ?J li - 9 7
Reviewe Date
Erosion and Sedimentation Control
No comment
This project will require approval of an erosion and sedimentation
control plan prior to beginning any land-disturbing activity if
more than one (1) acre will be disturbed.
If an environmental document is required to satisfy Environmental
Policy Act (SEPA) requirements, the document must be submitted as
part of the erosion and sedimentation control plan.
If any portion of the project is located within a High Quality
Water Zone (HQW), as classified by the Division of Environmental
Management, increased design standards for sediment and erosion
control will apply.
The erosion and sedimentation control plan required for this
project should be prepared by the Department of Transportation
under the erosion control program delegation to the Division of
Highways from the North Carolina Sedimentation Control Commission.
Other (comments attached)
For more information contact the Land Quality Section at 919/733-4574.
?4u?cY mac-a?? 9// 8?9 7
R v ewer Date
Geological Survey Sec ior} Land Quality Section Geodetic Survey Section
[phone] [phone] [phone]
FAX: [phone] FAX: [phone] FAX: [phone]
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
State of North Carolina
Department of Environment, Y"WAA
Health and Natural Resources 1 • Ae
Division of Soil and Water Conservation
James B. Hunt, Jr., Governor H N
Jonathan B. Howes, Secretary C. Dewey Botts, Director E-3 FE F=1
MEMORANDUM August 19, 1997
TO: Melba McGee
FRO : David Harriso i
SUBJECT: PTRWA Water Transmission Mains and Associated Facilities. Randolph County,
NC
The proposed project involves 26,000 linear feet of 48-inch water main, 25,000 linear feet
of 24-inch water main, 20,500 linear feet of 16-inch water main, 250,000 gallon elevated steel
storage tank, 2 million gallon (MG) prestressed concrete gound storage tank, and 2,220 gallon
per minute (gpm) packaged booster pumping station. Most improvements will be located on
existing highway right-of-ways. Land requirements for the storage tanks and the pumping
station was not indicated.
The Environmental Assessment should include information on the amount and location of
Prime or Important Farmland that will be impacted. Alternatives that reduce impacts to Prime or
Important Farmland soils are preferred. A listing of these soils in North Carolina is available
through the MLRA Team Leader, North Carolina State Office, Natural Resources Conservation
Service, USDA, 4405 Bland Road, Suite 205, Raleigh, N.C. 27609, [phone].
The Prime Farmland designation is not limited to land currently being cultivated. It is
intended to identify the best soils that can be used as fannland without regard to the present
vegetative cover. Only areas that are already built-up or within city limits are exempted from
consideration.
DH/tl
P.o. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 096 post-consumer paper
State of North Carolina IT I _W RAF
Department of Environment,
Health and Natural Resources 1 • •
Division of Forest Resources
i.r
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary pENN R
Stanford M. Adams, Director
Griffiths Forestry Center
2411 Old US 70 West
Clayton, North Carolina 27520
August 18, 1997
MEMORANDUM
TO: Melba McGee, Office of Legislative Affairs
FROM: Don H. Robbins, Staff Forester ( oWe
SUBJECT: EA Scoping for PTRWA Water Transmission Mains and Associated Facilities in
Conjunction with Randleman Lake Project in Randolph County
PROJECT # 98-0134
DUE DATE: 9-27-97
We have reviewed the above subject Scoping document of 8-6-97 and have the following comments
concerning potential impacts to woodland:
Type of Information that we would like to see in this Environmental Document to Address Imaacts to
Woodland - Tile following should be addressed for each alternative or project.
The total forest land acreage by types and merchantability aspects that would be taken out of forest
production or removed as a result of new right-of-way purchases, easements and all construction
activities. Emphasis needs to be directed towards reducing impacts, whenever possible to the following
types of woodland in the following order of priority -
a. High site index productive land that is currently under active forest management.
b. Productive forested wetlands.
c. Lower site index productive land that is currently under active forest management.
d. Unique or unusual forest ecosystems.
e. Unmanaged, fully stocked woodland.
f. Unmanaged, cutover rural woodland.
g. Urban woodland.
2. The productivity of the forest soils as indicated by the soil series that would be involved within the
proposed project.
The impact upon existing greenways within the area of the proposed project.
IW_ 4 Affirmative Action Employer
P. O. Box 29581, Raleigh, North Carolina 27626-0581 N16 M C An Equal Opportunity
Voice 919-733-2162 FAX [phone] KRIMIZEM2ZIMM 50% recycled/ 10°% post-consumer paper
4. The provisions that the contractor will take to sell any merchantable timber or woody material that is to
be removed. Emphasis should be on selling all wood products first, including energy chips. If wood
products cannot be sold, then efforts should be made to haul the material off or run through a tub grinder
and turned into mulch. This practice is encouraged to accomplish the following -
a. Minimize the need for piling and burning debris during construction.
b. To reduce the danger of escaped fires and smoke on nearby highways.
c. Reduce smoke management problems to the traveling public, towns and cities.
5. Woodland Land Clearing and Open Burnine - If any open burning is needed, the contractor should
comply with all laws and regulations pertaining to debris burning. The regulation of open fires are
covered under G.S. 113-60.21 thru 113-60.31 all inclusive. Land clearing contractors should make
particular note of G.S. 113-60.23 High Hazard Counties requiring a special permit from our local county
rangers and 113-60.24 for Open Burning in Non-High Hazard Counties requiring a regular burning
permit from our local burning permit agents.
Randolph County is a non-high hazard county and G.S. 113-60.24 would apply. Certain conditions may
exist at the time that would prevent the issuance of this permit. Also there may be other local
requirements such "as most cities do not now allow any burning and some counties now have a burning
ordnance that would take precedence.
6. The provisions that the contractor will take during the construction phase to prevent erosion,
sedimentation and construction damage to forest land outside the right-of-way and construction limits.
Trees outside the construction limits should be protected from construction activities to avoid:
a. Skinning of tree trunks by machinery.
b. Soil compaction and root exposure or injury by heavy equipment.
c. Adding layers of fill dirt over the root systems of trees, a practice that impairs root aeration.
d. Accidental spilling of petroleum products or other damaging substances over the root systems of
trees.
Water and sewer lines and treatment plants -
a. Normally new water distribution lines do not impact much woodland because they are generally
placed within existing rights-of-ways. We think this is a good idea.
b. New sewer lines do impact woodland and productive woodland because they normally run adjacent
to creeks and streams of water.
c. WWTP are normally larger facilities and can have higher impacts to woodland.
d. Water plants can impact woodland if they are constructed next to rivers and/or streams.
e. We would mainly be concerned if any master plans proposed new construction of facilities that in
turn would have the potential to impact any woodland, if any construction. was proposed for any.
existing woodland acres. Therefore, the Master Plans should take the following into consideration:
I . Avoid woodland if at all possible.
2. If woodland cannot be avoided, then address all impacts to this woodland.
Any cumulative impacts to woodland as a result of the expansion to the water and sewer or other
improvements in the service area. Of particular concern would be a good estimate of future loss of
woodland acres from future development coming into the service area as a result of increased water
capacity from these improvements.

If no woodland is to be impacted, then the document needs a clear statement that n2 woodland will be
impacted as a result of the entire project.
Efforts should be made to address the above items and to reduce impacts to woodland. We would hope that
the improvements would have the least impact to forest and related resources in that area.
pc: Mike Thompson, Warren Boyette - CO
Ken Jeffries - R2
Vic Owen - D10
Steve Pearce - Randolph County
File
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Note for Pete Colwell
From: John Dorney
Date: Fri, Nov 15, 1996 1:08 PM
Subject: FW: Randleman reclass.
To: Jimmie Overton; Pete Colwell
fyi
From: Brent McDonald on Fri, Nov 15, 1996 1:00 PM
Subject: Randleman reclass.
To: Lisa Martin
Cc: John Dorney
Talked with Steve Zoufaly about some of these issues. He said that DWQ policy was to wait
on reclassification until after reservoirs have been constructed and water quality sampling had
occurred; this was the procedure for Falls Lake and Jordan Lake anyway.
I am presuming that Greensboro wants the Randleman project to move forward, create the
reservoir, and build the intake/treatment at which point they will have expended substantial
resources such that not granting the reclassification would be unthinkable politically.......
4
,f
Pete C
From: John _D
Sent: Tuesday, June 30, 1998 7:22 PM
To: '[e-mail]. nc.us'
Cc: Pete_C; 'dennis'
Subject: Comments on Randleman Riparian Area Protection rules
Following are comments on the draft Randleman rules. They reflect the information we have learned from the Neuse River buffer
rules as well as the 401 Certification program.
1. Have the Authority contract with a consultant to map all locations (survey and/or GPS) where streams begin. DWQ can
check them as needed. This map will then provide a definitive location from which buffers can be drawn for future
development.
2. Allow one year (rather than six months) for the Authority to develop the stream map.
3. Add in-stream ponds and utilities to those activities allowed in the buffer if there is no practical alternative [(e)(I)]. This is
crucial - many of the problems we have had with the Neuse buffer rules stem from this omission. If anyone wants to (again)
argue with me about this, pick up the phone.
4. Delete (e)(ii). See above comment.
5. Where did the underlined language ion (2)(a) come from and what does it mean?
6. (2)(g) Modify to read: Stream and wetland restoration projects,...
7. Modify (5) to read "Where application of this Rule would prevent all reasonable uses of a lot, a variance may be granted by
the ..."
Based on our recent fieldwork, the topo maps are about 40% accurate in the piedmont in their stream depiction. Therefore
any attempt to limit the buffers to only those streams shown on USGS topo maps should be resisted at all cost.
Please call if you have any questions.

DIVISION OF WATER QUALITY
June 18, 1998
MEMORANDUM
To: Coleen Sullins
Greg Thorpe
Jimmie Overton
Beth McGee
Boyd DeVane
Ruth Swanek
Bradley Barnett
Steve Zoufaly
Annette Lucas
Liz Kovasckitz
Jill Hickey
Jason Doll
Jim Blose
Rich Gannon
Linda Hargrove
Jeanette Powell
Jay Sauber
John Domey
Matt Matthews
Larry Coble
Steve Mauney
Mike Mickey
Ron Linville
From: Lin Xu
'.VQ/ .I l 1 ? ?`C
\ ?y
Subject: Wastewater discharge, Stormwater And Riparian Area Protection Rules For Randleman Lake
I have attached a copy of the draft wastewater discharge, stormwater and riparian area rules for the proposed Randleman Lake
water supply watershed. We will need any comments by early next week (Tuesday, June 23) since it is a fast track project.
Please call me at 733-5083 x 357 if you have any questions.
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