19970722 Ver 1_Complete File_19970707

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Tohn Kime
Piedmont Triad Water Authority
Wilmington Bldg
Suite 1217
2216 West Meadowview Road
Greensboro, NC 27407-3480
Dear Mr. Kime:
1 ~ •
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Re: Certification Pursuant to Section 401 of the Federal Clean Water Act,
Proposed Randleman Reservoir
WQC Project # 970722 COE #199102669
Guilford and Randolph Counties
Attached hereto is a copy of Certification No. 3221 issued to the Piedmont Triad Regional
Water Authority.
If we can be of further assistance, do not hesitate to contact us.
Sincerely,
Attachments
A. Preston Howard, Jr. P.E.
970722.wgc
cc: Wilmington District Corps of Engineers
Corps of Engineers Raleigh Field Office
Winston-Salem DWQ Regional Office
Mr. John Dorney
Mr. John Parker, Division of Coastal Management
Central Files
Jerry McCrain; EcoScience, Inc.
Alan Horton; Deep River Citizens' Coalition
Kathy Matthews, US EPA
Boyd DeVane
Coleen Sullins
Dennis Ramsey
Division of Water Gluality Environmental Sciences Branch
Enviro. Sciences Branch, 4401 Reedy Creek Rd., Raleigh, NC 27607 Telephone [phone] FAX # [phone]
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NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS 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 Water Quality (DWQ) Regulations in 15A NCAC 2H, Section .0500. It is issued to Piedmont
Triad Regional Water Authority resulting in 121 acres of wetland impact in Guilford and
Randolph Counties pursuant to an application filed July 10, 1997 to construct the proposed
Randleman reservoir.
The application along with other environmental protection provisions outlined in this
document provides adequate assurance that the discharge of fill material into the waters of Deep
River and the proposed development will not result in a violation of applicable Water Quality
Standards and discharge guidelines. Therefore, the State of North Carolina certifies that this
activity will not violate the applicable portions of Sections 301, 302, 303, 306, 307 of PL 92-500
and PL 95-217 if conducted in accordance with the application and conditions hereinafter set
forth.
This approval is only valid for the purpose and design that you submitted in your
application, as described in the Public Notice. If you change your project, you must notify us
and send us a new application for a new certification. If the property is sold, the new owner must
be given a copy of the Certification and approval letter and is thereby responsible for complying
with all conditions. For this approval to be valid, you must follow the conditions listed below. In
addition, you must get any other federal, state or local permits before you go ahead with your
project including (but not limited to those required by) Sediment and Erosion control, Non-
discharge and Water Supply watershed regulations.
Condition(s) of Certification:
1. Appropriate sediment and erosion control practices which equal or exceed those
outlined in the most recent version of two manuals. Either the "North Carolina
Sediment and Erosion Control Planning and Design Manual" or the "North Carolina
Surface Mining Manual" (available from the Division of Land Resources in the DENR
Regional or Central Offices). The control practices shall be utilized to prevent
exceedances of the appropriate turbidity water quality standard (50 NTUs in all fresh
water streams and rivers not designated as trout waters; 25 NTUs in all lakes and
reservoirs, and all saltwater classes; and 10 NTUs in trout waters);
2. All sediment and erosion control measures placed in wetlands or waters shall be
removed and the natural grade restored after the Division of Land Resources or
delegated local agency has released the project;
3. Should waste or borrow sites be located in wetlands or streams, compensatory
mitigation will be required since it is a direct impact from road construction activities;
4. If any changes are made to 15A NCAC 2B. 0248, .0249, .0250 and .0251 adopted by
the Environmental Management Committee on November 12, 1998, that are not equal
or more protective than these rules, then this Certification is voided and new 401
Certification with public notice is required.
5. Compensatory mitigation shall be done to assure a 1:1 ratio of restoration or creation of
riparian wetlands in the watershed of the proposed reservoir. Sites should include those

discussed in DWQ's September 25, 1998 letter to the Authority. DWQ shall be copied
on a detailed mitigation and monitoring plan as well as the approved ratio, location, size
and method of mitigation (restoration, enhancement, creation, and preservation) within
90 days after the permit is issued and annual reports for the entire length of the
monitoring period. The final mitigation plan shall be sent to DWQ within three months
of issuance of the 404 Permit. Mitigation shall begin in conjunction with land clearing
for the reservoir.
Violations of any condition herein set forth shall result in revocation of this Certification
and may result in criminal and/or civil penalties. This Certification shall become null and void
unless the above conditions are made conditions of the Federal Permit. This Certification shall
expire upon expiration of the 404 permit.
If this Certification is unacceptable to you, you have the right to an adjudicatory hearing
upon written request within sixty (60) days following your receipt of this Certification. This
request must be in the form of a written petition conforming to Chapter 150B of the North
Carolina General Statutes and filed with the Office of Administrative Hearings, P.O. Box 27447,
Raleigh, N.C. 27611-7447. If modifications are made to an original Certification, you have the
right to an adjudicatory hearing on the modifications upon written request within sixty (60) days
following receipt of the Certification. Unless such demands are made, this Certification shall be
final and binding.
DIVISION OF WATER QUALITY
A. Preston Howard, Jr. P.E.
WQC # 970772

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Dr. G. Wayne Wright, Chief,
Regulatory Division
U. S. Army Corps of Engineers
Box 1890
Wilmington, North Carolina 28402
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SUBJ: Final Environmental Impact Statement on Randleman Lake, Guilford and Randolph
Counties, North Carolina, December, 2000
Dear Dr. Wright:
The U. S. Environmental Protection Agency (EPA) has reviewed the referenced
document in accordance with the EPA's responsibilities under Section 309 of the Clean Air Act
and Section 102 (2)(C) of the National Environmental Policy Act (NEPA). The Final
Environmental Impact Statement (Final EIS) assesses impacts attendant to constructing a dam
and reservoir on the Deep River situated upstream from the town of Randleman in North
Carolina. This impoundment is being proposed by the Piedmont Triad Regional Water Authority
(PTRWA) and is to be named Randleman Lake. It will be situated in Guilford and Randolph
Counties and is expected to satisfy water demands of the region for the next 50 years. Creating
Randleman Lake would flood approximately 3000 acres including 121 acres of jurisdictional
wetlands and approximately 28 miles of free-flowing streams.
EPA's letter October 6, 1997 to the U. S. Army Corps of Engineers (USAGE) raised
environmental concerns focusing on several public health issues. Because the proposed lake
would be situated downstream of a rapidly urbanizing area, existing and future sources of
pollution and nutrients could cause unacceptable levels of eutrophication and threaten the water
quality of the lake. Discharges from the City of High Point's Eastside Waste Water Treatment
Plant (WWTP) have been and will continue to be a major source of phosphorus and nitrogen.
Undesirable algal growth would pose difficulties in meeting the State of North Carolina's
chlorophyll a standards of 40 micrograms/L in the upper shallow-bottom reaches of the lake. A
second issue stemmed from two contaminated properties being contiguous with the proposed
lake property boundary. Both the former Seaboard Chemical Corporation plant property and the
City of High Point's landfill sites lie adjacent to the NW arm of the proposed lake, and are
sources of contaminated groundwater seeping into the proposed lake.
These concerns were shared with the North Carolina Department of Environment and
Natural Resources (NCDENR) Division of Water Quality (DWQ), who met with EPA in August,
1999. NCDENR staff members provided strategies to resolve pollutant and nutrient concerns.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 4
ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960 ,,,,
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FF8 5 2001
Internet Address (URL) • http://www.epa.gc~~
Recycled/Recyclable • r'rnted vdtlh Vegetable Oil 8:~~ed Inks on Recycled Paper (tviinimum 30°a Rosicon .firmer)

Additional technical studies, provided by the PTRWA ,offered site remediation options.
Following EPA's evaluation of the new material, EPA's October 19, 1999, letter to USACE
stated that the proposed strategies seemed reasonable and that the nutrient management rules
adopted by the North Carolina's Environmental Management Commission (EMC) should be
given the opportunity to demonstrate that the lake will support its designated uses. If
implemented, EPA believes the nutrient control strategies will be effective in controlling algal
growth and chlorophyll a in the proposed lake.
Potential Eutrophocation of Randleman Lake - A principal issue regarding attainment
of the 40 micrograms/Liter chlorophyll a standard was point- and non-point source loadings from
the Randleman Lake watershed. Point-source modeling studies indicated that moving the City of
High Point's Eastside WWTP discharge away from the shallow water to a deeper point near
Freeman Mill would result is significantly lower eutrophication in the upper arm of the Deep
River. To address non-point source loadings, NCDEM reclassified the proposed Randleman
Lake watershed as WS (Water Supply)-IV, Critical Water Supply Watershed. The EMC adopted
Nutrient Management Strategy Hiles and required all local governments to adopt watershed
protection ordinances stipulated under the rules, and both Randolph and Gilford Counties have
responded by adopting ordinances that establish water critical areas.
The efficacy of implementing Nutrient Management Strategy rules, however, need to be
demonstrated as protecting the quality of Randleman Lake water from excessive chlorophyll a.
While the Certification No. 3221 issued to the PTRWA pursuant to Section 401 of the Clean
Water Act (401 Certification) does identify changes in watershed protection ordinances adopted
by the EMC on November 12, 1998, no chlorophyll a monitoring appears in the 401
Certification. EPA believes that demonstrating efficacy of Nutrient Management Strategy Hiles
is essential and requests that USACE stipulate in their Record of Decision that PTRWA local
governments monitor Randleman Lake waters for chlorophyll a at intervals and locations
acceptable to NCDWQ and EPA.
Contaminated Groundwater -NCDWQ believes that contaminants found in the
groundwater that could potentially threaten lake water quality can be controlled using
groundwater diversion, interception, wellpoint pump-and-treat technology, air injection and
other means. EPA concurs with NCDWQ's position that it is technically feasible to achieve a
drastic reduction in organic chemical pollutants leaving the contaminated sites; however, the key
to determining the level of contamination removal is the implementation of a lake water
monitoring program. As with the nutrient issues above, the efficacy of the organic chemical
control strategies need to be demonstrated as protecting the quality of Randleman Lake water
from pollutant levels harmful to public health. No monitoring of organic chemicals appears in
the Randleman Lake 401 Certification. EPA requests that USACE stipulate in their Record of
Decision that PTRWA local governments monitor Randleman Lake waters for organic chemicals
at intervals and locations acceptable to NCDWQ and EPA.
Compensatory Wetland Mitigation -Following our review of the compensatory
wetland mitigation proposals in the FF,IS, EPA has the following requests/comments.

1
1. EPA requests that the USACE stipulate in their Record of decision that the Cone's Folly
site be transferred in fee to an appropriate state or federal agency or land conservancy
organization. EPA considers ownership in fee to be a much better protection than the
granting of conservation easements alone.
2. EPA is interested in the concept of using in-stream strictures to create or restore wetlands
in the historical floodplain. We caution the applicant that under no circumstances should
the structures be designed to provide treatment of storm water because the Clean Water
Act clearly prohibits the use of waters of the U.S. (including wetlands) for treatment of
wastewater (including storm water). EPA would prefer more natural stream restoration
practices as mitigation, where practicable (restoration of geomorphic dimension, pattern,
and profile through use of natural materials and grading practices). Although a simpler
and probably cheaper installation, the placement of man-made structures in a stream may
not produce the ecological dynamics of natural flow restrictions such as topography, and
may not produce a permanent restoration. EPA would appreciate being provided more
information on this proposal, and the rationale for the use of the structures rather than
employing more natural, geomorphic modification techniques.
3. EPA does not recommend the use of greentree impoundments as mitigation (greentree
impoundments are shallow habitats created for waterfowl).
In summary, EPA believes that the FEIS generally resolves most of our previous technical
and environmental concerns. We request that USAEC include in the Record of Decision the
following elements: a) that PTRWA local governments monitor Randleman Lake waters for
chlorophyll a and organic pollutants at intervals and locations acceptable to NCDWQ and EPA;
b) that the Cone's Folly site be transferred in fee to an appropriate state or federal agency or land
conservancy organization. Regarding wetland mitigation, EPA prefers more natural stream
restoration practices, where practicable; created wetlands may not provide treatment areas for
wastewater and stormwater; and EPA does not recommend the use of greentree impoundments as
mitigation.
We appreciate the opportunity to review this document. If more information is needed,
please call John Hamilton at 404.562.9617, or Kathy Matthews for wetlands/Section 404
considerations at 404.562.9373.
Sincerely,
~,
;~
Heinz Mueller, Chief
Office of Environmental Assessment
CC: John Dorney, NCDWQ

4 '`State of North Carolina
Department of Environment
and Natural Resources / • •
Division of Water Quality
James B. Hunt, Jr., Governor D C ^' p
Bill Holman, Secretary C I V f~l
Kerr T. Stevens, Director
Division of Water 6luality
Environmental Sciences Branch & Wetlands/401 Unit
Location: 4401 Reedy Creek Road
Raleigh, N.C. 27607
Mailing Address: 1621 Mail Service Center
Raleigh, N.C. 27699
FAX: [phone]
FAX TO: ~ ) Q,I) ilk -I~l~N1l~c..~ ~ ~n FAX NUMBER:
FROM: ~•~ a~. ~ ~~X
PHONE: ( J
NO. OF PAGES INCLUDING THIS SHEET:
If you receive this fax by mistake call; ESB [phone] or Wetlands [phone],

~' ~~.
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
/~•
NORTH CAROLINA (]EPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
September 25, 1998
Andrea M. Spangler
Environmental and Special Projects Manager
Piedmont Triad Regional Water Authority
Wilmington Building, Suite 207
2216 West Meadowview Road
Greensboro, NC 27407-3480
Dr. Gerald McCrain
EcoScience Corporation
612 Wade Avenue
Raleigh, NC 27604
Re: Randleman Lake Compensatory Mitigation Proposal
Dear Ms. Spangler and Dr. McCrain:
Pete Colwell and I have reviewed the July 1998 Preliminary Wetland Assessment
prepared by EcoScience for the wetland mitigation for the Randleman Lake project. The
proposal identifies 10 potential wetland mitigation sites, which are projected to yield 122
acres of wetland restoration, or creation, which will satisfy the 1:1 wetland mitigation
requirement for the project. At six of the sites a total of 69 acres of wetlands are
proposed to be restored or created by the use of in-stream structures to put water back
onto existing floodplains. The remaining 4 sites will create wetlands through "green tree
impoundments" along the associated stream.
As stated in our July 20, 1198 correspondence, the Division feels that the
proposed wetland mitigation sites are worthy of further examination. We also realize
that the Authority may acquire property through the power of eminent domain. However
this process may take a considerable amount of time. Prior to the issuance of the 401
WQC the Division will need to have a time frame for acquiring the proposed mitigation
properties. The items listed below from our July 201etter should be addressed in the
detailed mitigation plan, which should be submitted for written approval prior to any
construction activities in wetlands.
Environmental Sciences Branch 4.01 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
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1) Minimal release of water with the instream structures to maintain existing
uses in the streambed.
2) Design criteria that might allow for fish migration in the larger streams.
3) Maintenance and management of the water control structures, particularly
with the green tree impoundments.
4) Possible use of "forebays" to collect sediments and protect the wetland
mitigation sites downstream.
5) Planting schemes for each mitigation site.
6) Monitoring plan with success criteria.
We still encourage the Authority to identify some additional potential mitigation
sites should any of those proposed fail to produce the wetland acres estimated or are
simply not available for mitigation. It is our understanding the Environmental
Management Commission will review the Watershed Management Plan for the proposed
reservoir at their November meeting. We will consider the issuance of the 401 WQC
after the Management Plan is approved by the EMC. Should you have any questions or
wish to discuss additional mitigation sites please contact Pete Colwell or myself at 919-
733-1786.
S'ncerel
~~
Jo R Dorney
W tlands / 401 Grou
cc: Ed Powell, DMP
Ron Linville, DWQ Winston-Salem Regional Office
David Franklin, US Army Corps of Engineers
Pete Colwell, DWQ Central Office

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
~~~
~~
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary NORTH CAROLINA DEPARTMENT OF
A. Preston Howard, Jr., P.E., Director ENVIRONMENT AND NATURAL RESOURCES
September 25, 1998
Andrea M. Spangler
Environmental and Special Projects Manager
Piedmont Triad Regional Water Authority
Wilmington Building, Suite 207
2216 West Meadowview Road
Greensboro, NC 27407-3480
Dr. Gerald McCrain
EcoScience Corporation
612 Wade Avenue
Raleigh, NC 27604
Re: Randleman Lake Compensatory Mitigation Proposal
Dear Ms. Spangler and Dr. McCrain:
Pete Colwell and I have reviewed the July 1998 Preliminary Wetland Assessment
prepared by EcoScience for the wetland mitigation for the Randleman Lake project. The
proposal identifies 10 potential wetland mitigation sites, which are projected to yield 122
acres of wetland restoration, or creation, which will satisfy the 1:1 wetland mitigation
requirement for the project. At six of the sites a total of 69 acres of wetlands are
proposed to be restored or created by the use of in-stream structures to put water back
onto existing tloodplains. The remaining 4 sites will create wetlands through "green tree
' ts" along the associated stream.
ted in our July 20, 1198 correspondence, the Division feels that the
land mitigation sites are worthy of further examination. We also realize
~fv may acquire property through the power of eminent domain. However
~~ considerable amount of time. Prior to the issuance of the 401
;d to have a time frame for acquiring the proposed mitigation
~d below from our July 201etter should be addressed in the
which should be submitted for written approval prior to any
n wetlands.
,ranch 4401 Reedy Creek Road Raleigh, North Carolina 27C>07
Telephone [phone]Fi FAX # [phone]
,portunity Affirmative Action Employer 50% recycled/10% post consumer paper

1) Minimal release of water with the instream structures to maintain existing
uses in the streambed.
2) Design criteria that might allow for fish migration in the larger streams.
3) Maintenance and management of the water control structures, particularly
with the green tree impoundments.
4) Possible use of "forebays" to collect sediments and protect the wetland
mitigation sites downstream.
5) Planting schemes for each mitigation site.
6) Monitoring plan with success criteria.
We still encourage the Authority to identify some additional potential mitigation
sites should any of those proposed fail to produce the wetland acres estimated or are
simply not available for mitigation. It is our understanding the Environmental
Management Commission will review the Watershed Management Plan for the proposed
reservoir at their November meeting. We will consider the issuance of the 401 WQC
after the Management Plan is approved by the EMC. Should you have any questions or
wish to discuss additional mitigation sites please contact Pete Colwell or myself at 919-
733-1786.
S'ncere
~-
Jo n R. Dorney
W tlands / 401 Grou
cc: Ed Powell, DMP
Ron Linville, DWQ Winston-Salem Regional Office
David Franklin, US Army Corps of Engineers
Pete Colwell, DWQ Central Office

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402.1890
IN REPLY REFER TO November 14, 1997
Regulatory Division
Action ID: 199102669
Ms. Melba McGee
North Carolina Department of Environment
and Nat~iral Resources
Post Office Box 27687
Raleigh, North Carolina 27611
Dear Ms. McGee:
^~~~
We appreciate you, Ms. Linda Rimer, and Mr. Preston Howard meeting with us on
November 12, 1997 to discuss the water quality issues that have been raised regarding the
proposed Randleman Lake. All of the issues that have been raised with regard to water quality
should be dealt with before or during the development of the Final Environmental Impact
Statement, and we will look to you to assist us with that task. As agreed, we have enclosed a list
of the primary water quality issues that we believe need to be addressed. These issues were
raised in comments from the Divisions of Water Quality and Waste Management, the Wildlife
Resources Commission, and the U.S. Environmental Protection Agency (EPA).
We are interested in obtaining input and a definitive position from the State of North Carolina
as to whether the proposed Randleman Lake would be expected to meet State water quality
standards for drinking water and aquatic resources.
You have indicated to us that the successful development of a Nutrient Reduction Strategy
and Watershed Management Plan may serve to satisfactorily address most of the water quality
issues. You also indicated that the State should be able to provide a determination on the
suitability of the proposed reservoir as a source of drinking water upon the completion of that
plan. We would encourage you to address all water quality issues raised by the State and EPA,
including potential contaminants, as appropriate, during the development of the management
.plan. ..

~~
-2-
If you have questions, please contact me or Mr. David Franklin at telephone [phone].
Sincerely,
G. Wayne Wright '
Chief, Regulatory Division
Enclosure
Copies furnished w/enclosure:
Mr. Preston Howard
N. C. Department of Environment
and Natural Resources
Post Office Box 27687
Raleigh, North Carolina 27611
Mr. John F. Kime, Executive Director
Piedmont Triad Regional Water Authority
l~o~ ger Center, Wilmington Building, Suite 201
2216 West Meadowview Road
Greensboro, North Cazolina 27407-3480
Ms. Linda Rimer
N. C. Department of Environment
and Natural Resources
Post Office Box 27687
Raleigh, North Carolina 27611
Mr. Heinz Mueller
U.S. Environmental Protection Agency
Region 4
61 Forsyth Street
Atlanta, Georgia 30303-3104

s~
Water Ouality Issues
EPA letter dated October 6,1997:
1. Potential groundwater contamination from Seaboard Chemical Plant and the High s' 3 8
Point landfill sites. .
2. Potential increased algal and microbial growth from increased nutrients q, ~
3. Potential bioaccumulation oftoxic materials in higher food-chain animal species ~, J
including the consumption'of fish taken from the proposed lake.
4. Consideration of the results of the ongoing remedial investigation evaluation(s). s"~ ~
5. Consideration of additional organic constituents that may be present in the S-, ~{ o
groundwater.
6. Consideration of the more toxic forms that may result from the degradation of the S~, ~ o
compounds that do occur.
7. Consideration of the nature and contribution from the entire 42 permitted existing s; ~ ~
discharges in the Randleman watershed and consideration of the cumulative impacts
of these discharges.
8. Consideration of the increased cost of operation and maintenance required from 2 2S
potentially necessary state of the art equipment to treat both drinking water and
wastewater.
Attachment to EPA letter:
1. Entire section titled Public Health and Toxicity.
2. Entire section titled Nutrients.
3. Entire section titled Groundwater Resource Issues.
4. Section titled Additional Concerns, Item 21.

. .
- M .

~`"~ -2-
NC Division of Water Quality memorandum
Dated September 30,1997:
1. Page 1, paragraph 3: "..:the Division is very concerned about the future water quality
in the proposed reservoir."
2. Page 1, paragraph 4: A Nutrient Reduction Strategy and Watershed Management Plan 5~, g
needs to be developed, approved, and put in place prior to the reclassification for
Water Supply purposes.
3. Pages 2 through 4, Items 1, 3, 4, 5, and 7.
NC Division of Waste Management memorandum
Dated August 26,1997:
1. Item 1 which states that contaminant loading from the Seaboard Chemical and High
Point landfill sites used in water quality modeling may not be accurate.
2. Item 4. Is the State suggesting that more leachate needs to be removed?
3. Item 5. Will the State require the removal of the Randleman Dump and to what level
of conformance?
NC Wildlife Resources Commission memoradum
Dated October 1,1997:
1. Potential of exacerbated problems with water quality and fish communities in the Haw ~
~.~r
River and Jordan Lake from additional effluent discharged into this system due to ~~ ~
interbasin transfer.
2. Concerns with contanimants from the Seaboard Chemical and High Point landfill s-, g
sites.
3. Item 1.
4. Item 6.
5. Item 7.

6. Item 8.
7. Item 12.
8. Item 13.
9. Item 15.

EPA R4 ORC lll•µV4-JVL ~J~~ -
~; t e~t~ 1ZANI~LHR"AN DI~•
Colonel Terry R Younl;bluth
U.S.Arn~y Corps of Engineers
Wilmington, North Carolina
1. This area of the Piedmont. Crescent in North Carolina is arnortb the fastest-growing i»
the country. The Randleman source ratty only be sufficient. for the projeeaed need for the next ~!l
ye.~'trs (to 2035, maybe to 2050 if sr.rict. eanservatl.on rec}tt>lcrTtentsorc itrtpose~l). Dees the
corisiruction of the l~andleman Luke foreclose any options for water supply 40 years hence'(
2. The EIS notes that the; S'YSO (50-year safe yield) yields for all of the existing sources
serving Water Authority members rural GO.~ iV1C3D. Most ~f these ate snial lakes -.~~hiGh have
burn in existence for Samc time. Has it bce;n asccrtainrd that these suui~ccs will stil] procluc:e thi;
yield in 20507
3. The existing)-Tigh ]lock l.;tke on the Yadkin River is appruxirnately 3U miles from the
region. It is i;uger than the proposed Randleman Lake, and has limited devcioprr~ent at thin time.
Has there beet flay cottsidc:r'atinn of this source as a water supply'?
1~rrRTH>?R 1NVE~TIGATTO~?S~MC~NrrbizlNG
1. We arc concerned that the contaminant. coneontratic;ns and volumes of eorteamin4ted
water Qtat were used for modeling inputs ratty not. represent field conditions at. the Seaboard
Chct7tical site and the High Paint landfill sites. Tltesc sites are presently underg,oirts rcmeclia]
investigations v~~hich should be caupleted in early 1998. Wlrc;n on-site values ar'e available,
modelers should tx; better able to detea'mine impacts on the Uecp River and Randleman Lake from
the Seaboard Chcnvcal and l3ighpoint Landfill sites.
2. The draft ]~lS did not. adcquatrly address how mach of the High Point. l,andiill will he
undcrwattr at ht~th normal pool elevation and flood pool elevation. The EIS indicated (r'age S-
12) that the ]00-year flood pool would rct+ch approximately to eleavation 091.5 mean sea level
(tnsl), wlicrc;as 7'ahle $ (page 3-3) indicatccl that 7(15.3 msl is t.lte probable maximum flood pc7o1
ctcvat.ion. We would like to knew tlic probable maximum pool, as the amount of buffer art-.c+
that. would br. sat~rrltui incre;asrs dramatically as the pcx~l c;lcvttt.ion increases.
Pt ~;;, ~r~ u>; e~)3 ANU'1'OXICl'1'Y
'I`he proposed lake develapmurt regt+rds its use: as a drinking water source tp1~e sutijcctc.d
to cunvcntiunal treatment before eansuinption. }~rrnn the chemical characterization data

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Colonel Teary R. Youngblutll , p_„ ~L
WllI11IIlf~'1a11 Dist1'ict, C01'pS OC B11~1IIC.:(:I'S ~`~" ,~
P.O. Box 1KyU ~°
Wilmington, NC 28402-1~1U _
Attn: Mr. David 1--ranklin
~~
~~
RL: Daft. Cnvirotullenta111npact Statcrncnt on Kttntllc;ran Lake, Gifford and Randclplt
Coulltics, Nortll Catalina; Junc l 997
hear Colonel YounKblut.h:
The U. S. L'nvironlncntal Protc:Ction Alcncy lF'YA) has reviewed t11c r~ic~enc:~cl dcx:uan~n;
111 flCC•OrdA(1CC W11I1 EPA's rCSponsibiiitic, under Secainn ;(i~J of the Clean l1i: l1Ct and Section ) t.'~
(2)(C) of the Natiotlal Environments} I'oficy Act (NEl'A}. 't'he I-~rn;t )/uvirv:L-ncntaI Innact
Stat.en~ent (Drift AJS) is an Rssesslnr.nl ;.~C in;px~'ts of construcrin, a dam anc ro.5ervo r ti:tua>1.ci
approximately ilvo miles upstreal7t frolt~ the town of I~ancileman in 12at,dolpl; C;:>unty, ?`orth
C,'amlina. The Proposed datntning oC thr. C)r.cp River wc~ulcl =1r~nd SOnle :~,UOU a.•res inrludinb J ? 1
acres of Section 404 jurisdictional wetlands and 2k miles ~f free-`la:t~ing strea-n~.
C)ur letter' frotll hr'ilIiam L. C:ox, Chief of I;I'A's ~~'etlancl; Section dated Septetrlbcr l2.
I~y7, related to matters pursuant to wetland mitigation issues. This l;.tter. >::.ierencc;d adciinonal
comments that wrnlld he Prepared by LPA; thcsc ari; provided be.lo~v.
The Draft EIS did not provide sufficient dncumcnteticm to reach the cor,clusi~n that
graunclwatcr contalrlinatynn would not have a signifiatnt adverse impact on ttu: proposed
Randleman Lake water quality, 1?1'A's principal conccxn is that area residents b;: provided a safe.
clrinlc.ing water supply. Other concerns include increased all;al Ia~d microbial SI'owth fi'onl
increased nuuiunts, and the bioaccunlulatictn of taxis Inatcri,tls in higher food-chain anullal
spt;;t;ics. If fishing and recreational use of the Jake were to oc:cut', then risks frolTt these paths of
exposure would need to lle evaluated. Uur consents stem from cont~IminatEd grottndwate:r
migrating into the proposed reservoir water ti'om the Scallct~ird Chemical Plant and the Hi t~h Nctint
landfill sitrs. Thrsc sitr;ti ace s~Cuated slang the beep Diver prax.inlate to the proposed reservoir.
Particularly noteworthy r1.rC the canccntratiunti and chemical natucc of the orgtnlic solvents
ctnitnrltict~, frorn these sitcti which a.rr, schr.<lulcd for remedi:ll.irut .,s s'.•.t firth in Che Seaboard
Group II and the. City of ITiFh Point I~c:rrledial Investigation W~+rk I']an doted Junc 1945.

UNITED STATES ENVIRONME=NTAL PROTECTIOti AGENCY
REG1dN b
ATLANTA FEDcRAL CENTER
100 ALABAMA STREET, S.Y.
ATLANTA, GEORGIA 30303-3:Cr4
opt o l; 1941
~5
~•

f~eeydadlpecyClaUl~ • P111Hht1 Wllh ViKleiid)le Oil liasecl Inks Oh 1005E Ruryctad Paper (CO'/. f'osta,nsunret}

EPA ~:4 ORC ID •LVL-JFL-(=~J9r, ~~~ i G'c'~ S- 1= •`~- ,.- • - --
7.
Although the Draft EIS stated that these retneciation si°.es ~~ere situated entirely- ahoti•e
the normal pool of the proposed reservoir, there wtls no snppc,ning evidenx (such as t~~pograpi~i.
snaps) w support this contortion. Chanbcs in surface and ~~ro>~ndwater levels will affc;ct not on;y
those areas that are inundated, Uut can be expected to satura.e soils that are periph~7al w .he
reservoir bOlJndarleS. Elevauott of the watc.-r table would most likel}' increase contar:vna:-It
mobility, thereby posing additional potcrttial risks rrom these sources.
Descriptions of known chemical cc~nt2tnin~snt~ v<'a c inst:fficicnt and t}~c svarces ^f >?:;th
C11e1111C81 atrCl tlOir-pOlilL SOUYC;C inputs t0 the Wi1tCTS11Cd V/Crc no: adctluat~iy c;haractcrizcd. T}t_
five organic compounds drat were idcntifiui in Section 5.3.5.E T~~xic ~ubstnn c~ Fval i3ti~~p.
appear to rept~esent only a small subset of organic constitttcttts pr~srnt in th;, grottndw•ate;. «'~
would offer ~i5at a typical EPA site invesTigation includes over 15C~ chen,ic~] parametcr5. LaC:}~il k:
were discussions of the organic c:onta~»inants that were i:dentificd (the chlorinated hydroc~rho»s.?
as beut~ prirrtarily dense non-aqueous Phase liquids (DN/~PLc) ~~ hic:h may degrade to more to~:ic
chenvea] species such as vinyl chloride. Additia~al chctnical iaue concerns are d:^.sc,-rib°d ir, more.
detail (see AtLachmcnt).
The Draft EIS iclcntii=ted d2 Permitted existing dischar~.;~,~ in the Raudlcman watershed.
yet. the text discussu] only three, i..e., the Hipp Paint landfill, Seaboard Chemical site and tiu Hire
Point Easttizde wastewater treatment plant (WW'1`l'). Although the other aischarges may ~rield :~n
insibnificant amount. of chetttical loading tc~ the watershed, these was in;uf~;;ient data fc~r the
reader to come to this conclusion, The fiinaJ 1s1S should clarity and expand the cumulative
imptrcts oi' these additional discharges.
The direct. disclrargc ~f trcttteci sewage. effluent from the High Point Eastside 1~'-Vv"TP into
thr. upper reach of the lake would raise tae levels of phosph~rusand nitrogen and contribute tc•
dte ctttrophication of the proposed lxkc, a water body that is predicted to be cutr~ph_ i~ x~ltlu)1.ez-taco
t-tint. Pnin~ Facto.;~~w~ ~t;srharec. This increased org.attic lo;iding would further degradC •.h~
11kc as a drinking wtt.trr source, and although it lS Tec:llltolOgically feasible to remove tugh orga::ic'
loads, costs attendant to tnceting cirinl:ing wzl.cr standards ti•ould b:. expensive. IieeausC the
Pmjec%t will necessitnie state-af-the-art equipment to trct,t both dri.ctl:ing water an[l waste~t~ater,
we I'CCOtrunerrd 4u; incr~ttsed costs of operation ttnd tnaintenanee tr includctl in the Final E1S,
$eCSUSe Project. costs were cane criteria.l'or selectinl; the 12ttndlenrttn Lake altcrnativc, a
morn. dctailu] exposition of costs would assist t'eadci' unfamiliar with prajc;cst costing. It was
unclear how some alternative cost elcrnents in Table ]were deri~~ed. To accommodate the raised
sut~face wa.tcrs and buffer areas, twenty-one road and highway relocation and abandontrr~nt
actions wott]d be rcyuirec] in Gilford and Ittsndolph C'ountics. R%c: ccn~ld not dctcrrnine if high~'a~•
rcl~cdtion cnsrs (T~ble 2]) wtre included in t)rc Proposed Project analysis. Pot Alternative A
(Upper Ue~p River Lakc), were there no alternative configurations pnssi6lc that would have
clinrinated the WWTP relocation casts of $G4 million'? rot Alternative f (Cotnbinati_on of Br.n~sis
Lake, a.nC) Groundwater Wells), it was not clear if lh<: pure/lose of 73 sduare miles (48,001) acres~~
of watershed were includes] in Alterttativc F Reservoir I)evclc~pment t'osts (Table 13). The 1=i:tal

EFA R~ ORC

E1S should include a mart; thorough explanation of alt~rna:ive cost e_rrnents.
In conclusion, IPA has a number of misgivings over tlt~ fc;asibility and suitability of dte
proposed project. t.o provide a safe water supply that will rr~cct the ncrzi~ anJ maintain the health
of future generations. We recornme[td that the COE issue its Section 4;k Pe.mii on c[~:tditivn
that the North Carolina Department of I?nvironment, 1 Iealth, c~i. i~atura: Rcsourc;es (NCDEI~L~}'„
guarantee that the water quttiity in the proposed Randleman l~.kc will be sutabie for its intend ~<i
ptu-posc~, that is, for a public drinY,ing water supply. LPP. ~r•~iie: reco:r~rtends that any o:lboin~~
rcmetiiai investil;ation evaluation(s) be completed prior to p.owse:l c;:.rtsL-uction activi'}~ se thy:
tltc nature anti amounts of cemtaminani~~ at the 5eabotud and the High Point landfill sites rnt[y )-~
more thoroughly defincci. We also su~cst that flit applica:it r;,visit the project altenati~~e ces~
to t;ntiure that the preferred Alternative is cost-effective for th:; lur.` tern whet[ the expt.nticti c,f
treutini; both wustewttter And potAble water w iuFh 1cveL5 v p;triry arc c;onsiacrcd. -
Based upon review of the rcfcrene:ed document by our technical staff, we have rated thy.
Draft. EIS "EO-2", that is, EPA has environmenGtJ objections w the Randleman Lzl:e project arc:
has idc~itifiecl sigctific;ant environmental impacts that must be avoid_ci in order to provide adeciLSt~
protection Tor the environment snd Puhlic heo-tllh_ The Draft 1/IS dicJ r.vt contaui sufficient
info[Ynalic>n LCD assess environrnentttl impacts and health con;.:,r.is: E1'A na.: ]:lenUiieCl acJcitiv-::~.
information and analyses that should tx; inc;luci;,d in the 1=ina1 LIS.
We appreciate the opportunity to review this document. If morn; info;tnarion is rrquire_i,
da not hesitate to call me or Heinz Muealer at (404) Sul-~ul ] .
5inee['el}',
~~~ ~ ~ ~~
Phylli Iarr•is, Reb~onal C:ot:[uel and Director,
T:nviroturcntal Accountability Di«si~~n
Encl~surc
cc: I7r. Lynda Itcrner, NCDJ=I iNR

EPA. °~ ORC I LI . LQL-JrJG-riJr7~~ Or ; r.,; ' ~ - _ ~ • .. IBC . - - -

presented, it is possible that srat~of-the-art water treatment would produce a safe drirl.ini; water
from Lake Randleman; however, the ~ IS noes not specify vc'hat is meant b5° t:ce ecneric term
"c;onventional trettttnent' in rcbard to filtraricm medium (a::rivute<l carbon, sand, etc.j,
Sec}itnent.atiot~/floc:culation proce„lures nt disinfection process that would br us%;d. Su.•h :reatrr~et:e
details would need t0 be known be~'ore the actual drinking water quality onto: altit risk could l~
detetYnined. An aesthetic water quality concern (taste and odor problems) may also n~C co be
addressed with the u•cauticnt prucc;ss if nutrients added to the. Jake enco~•aee 21ba1 and ocher
microbial growth. EPA has concerns ahout pathways of exposure that ate act discussed. )f
flslling and recreational use of the lake: is to oc:c:ur, then risks irottt thGtc pad'}•ays of exposure.
would aced to be evaluated.
It is unclear that sufticirnt toxic substances will ur ~~-ill not ent:,r the proposed Mandl°mail
Lake; from identified sources in sufficient ~~uantities to pose hc~tlth concerns. However from this
u~ency'5 perspective the )/LS Appi:nlic:;s fail short of providing strongly convincing
documentation of no impacu on hr.r~an he;~ltn. 'this ever?untion is inadedu:~te in providing, a
sufficient. doctttnentatian such that a concerned person would independent'.}' reach the there
conclusions stated on page D-4 0` the 1:15 Appendices. Detail:; of concerns are discussed belo~~::
1. The r1S states t};at ~2 pcrrnitted discharges exist in the Randleman watershc.:i, l;igt:re
V_2 appears to show the location of seven of the 42 and ~Jte t'xt discusser only three sources, i.e.
High Point. Lttnr1fi11,Scaboard Chemical site and Hil;h }'Hint i?asisidc WtiVTY. Are these
Wastewater or storm water? The other disc}tcrf;cs ma} yield insignificant chen~ic<tl loadir;~ to tie.
Waters}tc;c1 as indicated in the TsIS. IIbti~•evcr, insufficient tiara oral information is presentee] in the
document fc~r the reader to come to this conclusion.
2. Only 14 chcrnical pollutants were identified ati having toxicity i;rncems. Ttlc
envu•otunental chemical analysis for a typical }a'A site investigation inc;luds over 1~0 ahem:c;aa.
lt. is trot clear what chemicals were includes] in the analysis of c.nvircmment.~1 meelia at the three.
primary sites or the many NYDLS clischar~tcs, Vt'e do not get the sense that chemical sours; s tc~
the wtttersltecl have be:u.n actecluatel}' cltarttcterizut.
3. '1`hc draft.T?lS stated (page 5-13) that the High Noint rastsidc V~'WTP rocs evaluated
and found not to be a significant aourc;e of organic pollutants. ].nfot~nation should be included in
tha E1S which states how this evaluation tisas done including a dciitiilion of "significant" source.
A priority pollut~~nl. scan may have l~:en cuiiductc;ci during NPD)/S permit issuance or reissttancc
which would pt•ovide an indication of the pollutants detect~.d in the; High Point WW"1'1' ci'llucnt.
Tf co, that information should be ittcludecl in the L'IS, othcrh~tie ti priority pollutant scan is
recommcndui in order to determine other potential cont;n~iinants to the reservoir. A review of
this information for other diseh<crbes to the proposed lake waulcl also he useful.
4. The; Trinity Fount site loeatul in (ileno}a will he approxllnatcly ~/z mile from the edge of
the proposal like. Wilt the rising of ~raundwater levels ttssoci,jted with the construt;ti~n of the.
lake, contamination .from the `Trinity rc»tn site may extend t~~ iidditional wells located in the area.

EPA R4 ORC I D ~ 404-562-9598 OCT 08' 97 lu ~ u~ ~'+u . ~.~~_~-
Ti,is impact should be dcsc~ibed in the L]S.
S. The Seal~Ottrd Chemical site iF; i;lcarly ~tssociatul with a groundwtiter VOC plume;.
From the discussion, we would anticipate that a DNnI'L c;xist that would Ue a source of dissolved
VOCs to the agttiSer. Stich a pNAPL would likely be located below the deep fractured-bedrOCl:
ac}ttifer. The influence of soil hydration from the lake on tl,e V UC~ plume and passible UNAPLs
rclativC to future anti cantinttal Jake contamination should i•cccivc additional discussion and
perhaps study.
b. Tltc t}trrc primary sources of lake contamination will be located in the upper reacher of
the lake some 10 miles upstream of the drinking water i.nt<~kc. The assumption made Pram the
modeling exercise is i.ltal. aduluatc; rnixin~; and dilutirn, will result. in contanunant levels at. the
water intakr. well below c.:c,ncern Jeveis. It is not. cle~'u' that the modeling has consider factor Such
as channeling, that would hinder complete and u„iforc,i,nixin}; in the lake. Further d}scussion of
the t„odclin~ in this regard is approFriau. --
7.. An important issue is whether or not. tl,c diSCht,rl;e from High Point Et7stsidc ~'JWTF'
should entc~.r the lake or be routed below the lake. 1t wen,ld seem that further disce~ssiot, of the
treatment process, e. g. combined sewer overflow/1iy-pass issues, fail-s;ife avezflow lsrovisic7ns,
ti~eat.ment recluttdancy for protee;tion against microbial kill-off, would be appropriate.
x. The discttssinn cif the 1-iigh Point East. WW'77' (page 5-13) estitnatu3 in-strewn metals
cottcentratians on a mean tu,nual basis. This evaluation tihnttld also be cottductecl for the tow 11c~v:
(that is, 7Q10 ar other appropriate flow as defined in State Water Quality Standards) condition.
I. The expec:tutian that the Iakc will be highly eutrophic was also nat.ldequately
fldclressed. The EIS stated that the propasecl ltandlet~tan Lake ~~ill be highly cutrophic due to the
nutrient. inputs even without. rite High Point WWTP discharge:. 'Thus the lake is likely to
expcricnu; frequent if not. continuous algae problems that will impair its value as a puUlic water
supply and as a rec:rPat.iOnal resoterce. Nigh organic loading from algae would require a water
G'c„unwn. plant. that will hove to incorporate more s01?histicatcd and exl?ensivc processes including;
activutr-d carbon 1o remove nrt.ttn'al and e}-lorinated organ}c contaminants. The U)/TS shott}d
inc:hzde long-t.ezYn c~pc'sttiting expenses in thr. costing sccnacios.
2. 't'he WWTP was considered io be relocated (or. its discharge) around tl,c ]r,kc, but
apparently relocation would not leavr. cnc,ugh water for adcqua.te dnnku,g wafer withdrawn} and
sufficient rcarase. from the 1al:~e itself. 'I'ha.t. forces the W W'1'}'to a very expiensive high Cfficicncy~
nut.t'ient removal system Anc} fail-safe redundancy -since the WWTT' is upstJ'etut, of'the dt'it,kit,g
watts withdrawal point. In the event. the plant were to fot'eecl u> bypass oz' cxpcriettc;e a power
Outage, the: water treaunent plant. could he subjected t.o increased vita,, crypto sporidium, giardis,

IU ~ 404-562-9598 OC i G2' ~ ~ i~.-~ ~ _,r •,... - _
EPA R4 ORC
4
~USIS
etc. NonC of these issues were adc~yuatcly addressed in the EIS and all the sewn arYt • ~ wat,7
associatul with the lake were not. accO7~~~ ~ustti. to trX tn~ nttplant t,ould be des gn°d to a:,•hie~. F
plant and their resspecttve addttlonal
a consistently low phosphon7s level cos 1117 E oeti 0.37m~ cl w~ulu camtribnte appaox. 24f Ct~~Xt
d7s7nfu:tion and treatment. would 1 e )
]bs/ycxr of ptt~sphorus at 26 MCiI~, wt7ich is the proposed permit flow.
~, The Walker 13ATJ ITUI3 ]t7oclel predictions indicate that the i\ortl~ Carolina water
quality criteria for cnloroph}'ll "fl" of 40 ttgll thel ovPrflll ~t e71':•tgellake cchD roPh 1J1 r' aS `v111~mc:::t the
]Zandleman Lake. An argument is oracle that
stx.tr. criteria; l7awcvcr, these criteria muU 7 b` ne in w1i11cliftc EIS •anal}~ s etitin7adted in strejma.e
chlorophyll) "a" criteria is a doily 7naxt
chorophyll "u" concentrations only on an annual and ~rvwinb season basis. It is reaavn-.tble to
expect that same dFtily chlorophyll "a" CUricCrltt'atipns will G?tiCCCd avcr2~C CbnCentri1l10:ts. Vvc
rccottunc;nd that the LJS include 3n evnluacion of the ull~wuUt~ n~nxunum nutrient loaaings to
prvvidc: for maintenance of tl7e State cliloroPiidix,A, it :~rp ars ~~ e~p with ramo at of the Hi€hl
nn a review of the modeling results m Ap}
Point discltat'ge, the state chlorophyl] "a" criteria will be cxcc:ed'd and chat non p,'~t~t~~ raEetnent
controls ~~~oultl fx• ncx;dui. )3oth the NC: I7T:M Cape Fear Bain-wide Water Q Y
Plan (pale 6-5(1) and the draft.l7S state tJ7at it is "hi>~hly likely" that I~andlcman Lake will b:-
cutropltic.
4. The l/lS (page 4-lU} statcfi that the proposed Rtuldletttan Lake weuld inundate two
segments of Feel? River which arc inC.lude•c1 in the State's 303(4) list of impaired waters. The
segments are isnpairerI due to elevated levels of fecal caliform and atrbidity. one segment is
additionally itnJ7aireti by elevated levels of metals including capper and mercury. Waters inclucleci
on th~ 303 (d) list are those requiring development of TMT~Ls (Total Maximum Daily Loads).
Tl7e. TMDL analysis cietermit7es (1) the causes and sources c+f tltc use impairtncnts and (2) t.hc
needed pollutant load reductions for tttusc: sources tc7 restore tltc be;nericial uses of the water
body. Ahsem a TMDL for the listed waters, the EIS must provide documentation that the
proposed project. will not cause or co»u'iUutc; uw use impairments and violations of state water
quality sttlndru•ds. A thorough analysis n1' the impacts of lake construction and operation on water
quality with respect to fGc:al colif°rtn and turbidity shvuld be included in [he LIS. This is
especially itnpoi'tant sine%c the draft. L'IS sub~csts (page S-`~) dint short tentt increases v1 turbidity
would occur due to contitntction of t.hc clam.
S. Nutrient. loaduig analyses were bused nn effluent. i7ows from the lligh Point ]:ast.
WVJTI:' t7p to 20 MUD. This flow was ;tppari:ntly determined in the reservoir' yield analysis. ~Vc
understand that. the 13igh Point );ast f:+oslity h:tc rs permitted :diluent flow of 26 MCl~, lt. scans
that the appmpria.t.e flow fe7r`cttleult7ung maxirnurn +lUtt'Jent lc~adinl;s fi-om the: High Point facilit)~
would he the pernlittcd flew of 2G MUl7. The }3IS should prcwicle more discussion to justify the
use of a flow less than the maximun7 pern7iucd flow especially fur estimating, future l•~adings•

EPA' P,4 ORC
ID:404-562-9598 OCT 08'97 ~'
6. Base flow quality for phosphorus and nitrogon input. assutnpitonti «~etc
detertiuning iuiuiettt loadings The 1's1S Appendix shou]d provide an explanation
assumptions were made (e.g., field data, other similar flreas, NRCS rccommenda~~
the existing cottditlons and future loadings scenarios. Consideration should be giv
conducting a sensitivity analysis for these inputs to determine the relative importar ~~
predictions.
`iSn~tT.inSa~e•r-nu ~ESOL7RCE lS,~~l_l5
1. Page 5-9 of the draft document. states that. "...minor chetn~es in the ~~. ~
will occur..." and "...ovcyrull, gmundwF~te~• effects urt the water quality of Randle;!.
predicted to be insigtuficant..-" There conclusions fire not apparent from infoiYt~.~~+~ `
provided in the document and appenc}ice~.
2.. With 1'espect to the l;roundwttter ]evel, the report should include an a
scaled topogt'apiiic snap and potc:ntic~metric trap. Since chan};e5 to the potentio:.
vary within the watershed, cross-sections should be l;enerated which represent the, ~ >~-~~~~
potetttiotttctric slopes within the watershed. Supporting infotYttatiott should ~jv
land use maps ttnd descriptive text. This effort will reduire more detailed ttntaty:~!
contribution with t'espect. w reservoir yieici analysis and toxic substances evalua+
3. Changes to the potentiomOtric slope will affect ground water inflow,
estimate:;. Page lv-1 K ot'the appendix (tropic level evaluation) acknowledges ti
s}iottlci dcc;rcase, but that the current. values were used as a cuttscrvative estima~
coti'ect with respect to lofldittg it ttiay iu~t be conservative with respect to yielc' ~~
calculations. This should be considerul in the nrafl. EIS.
4, C:hangcs in the surface wat.cr and ground water levels will affer:.t not
inundtsted but. what is saturtttcd. Por this rcasc~n uelditional asscs5ment is requ~%
cue not: adverse effects from toxic yr hazardous soarers. The twc~ existing sot
the Toxir. Substances Evaluation on pulse V-t of the appendix arc the Scahc~s, .
c:ompzny and thu High )?Dint Landfill, Pxg,u 5-11 of the draft report. indicate ups
located entirely aUove the normal pool clc.vation oti the t•escrvuir..." These log
identified on a topographic map which should he used to support chic concluss~
Cursory review itidical.es this may not be• correct. Review ictdicares that norm::`
a. portion of the landfill and a 1OO-year floi~d tttny inundate a portion of the Se~~..
Company.
5. More important than surface inundation, hawcve;r, may be the effe:r
elevation of the water table such that hurled waste and contttminatcd tioil tnn~; ~ -
incxrasinsthe potential risk of these sottrccs. We wrntld inclucli; a discussi~ ~ ;
Town Dump (pgs 5-12-i3). hulicxtc, whether depth of burial is know (and ~

EPH P.4 ORC
ID 404-562-9598 u~ i ~'u ~` 1" •"' '•~ • ~ --
6
location on topographic and Pot.entiotnctric maps. Discuss the nuinb:,r, location, and results of
samples irlcluding'l'GLP analysis. Address the tithe frame for removal and reference it to the
proposed time frame of the project. T}o removal costs include verification sampling and industrial
landfill disposal? What infc)rmdtion is available regat•ding the concentrations and extent of gra~.ut~
water cant~'tminatictn? Is treabnent Pt'opnsed`? Whttt. is the regulatory authority? Where and at
what. eanceiltrations will ground v~-xter contamination i,l,pact the reservoir'?
6. >?ata and infom~ation are dispersedindfill sltesetlic full lispc~f cvnstantei is andithe`r"u~
issues stand out. For bath the Setibottrd told
disti'ibutian and extent of cont:tmintit.ion have not becti identified. This ~ISSessment. is mandatory
to evfilunt.e potential risk Cl~om ground water cvntamin<ttian.
7. CurSOry rcvic;w suggests that information in the draft report wtis incoittplctc with
respect to sarnp]ing trod monitoring d1t1, hydraulic conductivity cluta, and ttgttifcr test data ~vhicl~
mF•• have brcn available at the time of the report. __
$. `1'lie five. organic oompc~uncls identified in the draft i•c~pc~rt and appendix appear to
repretient only a subset. of organic i;onstituents identified in the ground water, The
Chiirircteriztttion of the ClIC2111Cc'i1 eolllpounds is inadeclulte n1 that. it fails to recognize that t}i~se
identified (and unidentified) chemicals are primarily I7NAPLs, dense non-;ulueous phase ]iquid~,
and that they degrade lU ti more toxic compound, vinyl chloride (which has apparcntIy been
iclent.ified in rite ground water at concentrations orders of mai;nitude greater than the druiking
water standarci},
~). While the draft. report and appendix coircctly icicntifies ground water flo`v in the
direction of the river, it assumes that contatlunauon will he in the du~ection of ground water flc~~~•.
With 13NAPl~'s t11is is not necessarily the case. A hNAI'L Plume will move by grtivit.y along, t}tr
bedrock plane. '1'hrs 1115 i1Ut bCeIl identified 1101' WaS the pOtCritial of frFlCitlr'C fltlw cOTlSidel'ed.
Bott1 pc)ssibilities must. be eoiisidereci to <idetluately address the Potential risk of both the
Seaboard site and the landfill.
] 0. llata ripl~clr to exist. which supports at1 increase of cnntaizuilant c;clncenuations with
dcpt.ll, fritcture flow, and changes in dircct.ivn of vertical hydraulic gradient. This 1Jti'02`tllation is
extremely signiflcatlt. iii tllc Cvaluativn of potential risk, yet ~ippczrs nut tv have been used. Page
4-19 of the drn.ft. (Bndangerecl,'I'hrellcne~.1, and Rare Spcc;ics) iclcntifies upland scc.Ps, suggesting
that this information watt known and that a mare thorough asscssrncnt of the ground water i1o~v
regime should have been developed.
l 1. The ciistrihution and extu.nt of htirie-ci waste ariii the chiulge iii ground water elevation
must be bett.cr uiidcrstond. The org,anii: compound identifiui as originating from the Setiboard
site have the capacity to dissolve ~thcr cnnstitue.nts. Of particular concern are the constituents
which miglltlikc:ly he. found it1 the ]audfill (.such ac tllctals, herl,icides, and pestieidcs~ It is
csscr-tial to know thy: ext.c:nt and depth rtf burial trod the change ii1 clevatinn Cif the potent.iorncu•ic:

EPH R4 ORC
ID 404-562-9598 u~ ~ "~ 71 lv ~~" ~ -
7
surface to adequately assess the possiliilit.y of saturation and the potential of ground wut.er
impairment. Capping of the landfill may trot. be satisfactory artd t'emediation or removal at. the
Seaboard site may not be feasible given ~t rise in the water table.
12. The 20 feet thickness used in the appendix to calculate Darcy flow should be
supported by data. A bedrock surface tnap should be provided. Identification of fractures and
water'-hearing zones itt the bedroi;k is necessary. l~ractttre flow should ]x: assessed.
13. Additional potential sources oi' ground water cotttarninatiUn,lncluding dumps; 1tCx~+
gatcrators atul TSI7 (t.rentment, storage, and disposal) facilities, CE1ZCt.,A sites, Toxic: Release
lnvcnto~y TR]. silts, and should be identified tend asscssccl.
Additional potential sources of surface welter contAtnination should he identified and a5scscd.
'These include the hundreds of acres of agricultural land which would be inuttdatcr3 an(i could still
act as a contaminant source. Livestock, crop areas, and potential chemicals of concc;rn (nutrients.
ammonia, fiscal enliforcn, pesticides and herUicides) should he identified and assessed.
14. Al] potential sources should be cvaIu©ted tit. the point of t}te sources impact with the
proposed lake. Quantified estimates (sac:h as the estimated ground water crn~centrations art the
point of dischtugc (tr dissolved nuu•ients above a buried dairy farm acreage) should be ectmpaii~Pd
to drinking water standards, recreatianKl, and ccolo~~ical s~jndarcls. While these eottcentrations
mtt.y represent a worst case, (hltlt.l0ll S}tUllld nOt he ConSlderecl fU1' t11etiG Cot11p1r1SOt15. (nlthauitit
dilution ;tttd/vr treatment ratty provicTe art adeyuatc; ({sinking water supply, CMS tttay ttUt prOteCC
plants trod animals.
Bnni'r'1nNnL CONCLL~
1. 1'g. 1-1. The summary states that the propotial was developed for a period of
approximately 50 yea's. Explain why is this different froth projections utter in the text. (4(} years.
]()Q years/pg. lll-2).
2. Pg. 3-1. The proposed 1068 construction would have discharged effluent. from the:
High Pint l-:nst.sidc. W~iJ'I'P (iownstream of the citu~,. I?xl?lain the changes resulting in this
tttadification,
~ pg 3-3, Pgs. III-2-4. ']`here data suggest that the heig}tt betv~~een the stream Uccl ant?
the lake floor on either side of i]rc proposed darn will he 24 feet.. What is the current change in
elevation 1,etween these two proposed loc:atiuns`.> Prcwide a cross-secaion. What is the elevation
of the outfall smtctures'? Consider the effects of scouring. and changes to fluvial ~;eoutarphologl'.
1.'rovide l;reater explanati~n_ctf the Soil Conscavation methctcls. 'I'abuIate the dtita including
reservoir capacity, volume increment, capacity inflow ratio, °lc~ sediment trappui °k~ sediment
trapped per volwne incrcrnent, acre-ft sediment. trapped r?ti,u~ally .and rite number of.,ycxrs
required to till the volume incre~tnent. T:xplain why sedicttc:nt attar»ulation was ltrojex.tec] for 1 U(1

EPH R4 ORC ID ~ 404-562-9598 CJCT U~ "~ ! 1'= •'~ ~ "- • ' - -
years. What is t.lte sediment accutliulatiun in 50 ye~'trs'?
A. Ng. 3-4. The effects of the ittterbasin transfers tc> the fluvial geomorphology and the
etulan6erc;d species habitat muse be considered.
5. I'6s, 3-9-10. Cheater detail should Ue providccl for .alternatives L and F, usint ~;rotm~l
water wells.
(.,, Ug, 3-14-1$. lticlude the trifles cif rc~t~dways anti ritilwtl}'s. L'ffects to clownstrcatn t:p~•
,5-],reduced tinttaai flow) geomorphology, wetlands, and endt;tig,c:cd and threatened species niu..t
be noted (Section 4). Effeeas on geomorphology, wetlands, and to endangered and tltrc;atcn;;d
spu:ie4 in basins receiving interbasin transfers must a15c> E•x; noted (Section 4). Given the
cxpci;tation cif lake eutrophicatioti and tltc possibility of te~xic effects to aquatic lifo,~ti~t~
ru;re<ttionsl use of the proposed lake should Iu; rcc:~nsicleru9 (a]co pgs. 3-24, 5- ] , 5-1 t;-] 7, 5-211.
_._
7. I'~. 3-23, A wetlands inventory for ~tltcrnatives is advised.
g, p~,, 4.3, Identify the types and locations of mining operations exist in ~iuilfozd Cohn!> .
), P~,. 4-8. Delineation of pt•i-ne flrn~land is rcrommended.
1 Q. Pg. 4-10. Discuss what monitoring and treatmct~t wc7uld exist for pesticides and
ht:rhicides. ldentify the concentrations of ]indane and cliclclrin which exceeded the water quality
standards and note the standards.
l 1. I'gs, 4-20-Z1, pgs. 5-17-J ~. Discuss the effect can endanficred and tl]realened species,
especially the Cape Fear 5hinet' rind Carolina darter, cinwnstre;nn of the presje~;t. and i.n tfto vatiins
rcc:civing int.ctUasut transfers,
l2. pgs. S-].-2. Provide; a land use map. Identify thr, ciPer,tting dairies.
13, pg, 5-3, pgs. 5-17-1A, Discuss est.itnntcs c>f the e.cononuc losses to hydroclcctric
pr~jcu:ts along the Deep,River and in basins affcctcci by interbasin transfers. 1-lave tlic;sc cc>tits
heen included in the Proju:t Cost Lstimates'1
14. I'gs, S-G-7, pgs. _5-16-]7, 5-21-22, and Section ~1. 'fables 23 and 24 identii'y a 17%.
reduction in average flow during fil]inf; and a Gc9o reductitxt in average flow at the liigh Falls
i~cation, Provide; the range and durations of flows at. this lUC:ution and at the Gulf find Mortcurc
stations ftu•t.her downstream and discuss the impact. to the Capes Near Shiner' CYitical 1 iabit<~ts
incttted on t.ho.I7c;tp River in..Randolplt and Moore Counties (uptitreai» of t.Itc High 1'xlls station)
and in Chatham and Lee Counties (upstream of the Moncure station). Kelatc prctjec;ted flows to
current. (.'lows for average, high, and low flow condlt.ians. L~iti~-usti where new scottrit~ ttiay
occur, the etu•rent health of khe streams, ntiil -nodclin~; supporting ;t reduction in 1301 anti

E~FI R4 ORC
increased DU.
I D ~ 404-562-9598 u~ I u~ y r 1 ~-~ • ~ ~ ~~~ • ~-~~-~--
15. Pg 5-11-] 2. Discuss what. is JttCaut by the expression "iTleilt] alTtlual CQr1CP.llt['flti0I1S":
what well(s), location, freciuency, ;Tnd number. Discuss the current status of the Seaboard
ChetTilca] Company and the Iilgh Point Landfill. Identify the regulatory authorities.
I C. Section S. Generate thv cumulative concenu~ations t~f the all sources.
1.7. Pgs 5-17-18. Discuss changes in stream geomc~rPhc>logy and ecosystems resulting,
from increased slows in the I-Iaw diver I3flsitt ttnd Yadkin 1Ziver 13asin.
18. Pgs. 5-2I-22. Provide the loeatioJts or rare plant<~ which will be located iJt tl~c buffer
zone on a putcnliUmc:tric map and discuss the effects csf ground water saturation if al~propriace.
19. Pbs. Ij-1, pl;. S-7. Provide adtlitionnl discussion ;tnd clarification nn the flow and
yield analysis. Page IT-I strttes that. the avrsa(;c annual t7ow in the UeeP River with Randlem:ui
Lake is less than the flow without the reservoir. 'fable 24 identifies the average annual i'7ow as
lG3 cfs (1Q5.~ mgd), Pg. lI-1 identifies the yield of Randlcntan Laka as 54 ttTgd (77.95 cfs) and
states that. the difference between the current ttnd Proje;;tcd flow in the 17eep ~ivcr i5
approximately equal to the Randlc:rtrut Lttlc yield. 'Phis suggrsts that the lake yield is
approximately half Uf the current flow and 4TC projected flow tivill be approximately equal to the
lake yield and approximately half of the current flow. 'i'1Tis is inconsistent with the 29~7o rep-lttctii~rT
in average flow at the RandlemazT darn site indicated orT T;Jble 24. This dist;repance calls into
question the flow reductions projectul fur stations further downstream otr tlTC Uc;ep 1Ziver. Since
this includes flaw in Critical Habitat for the Cape Fear shiner, clarification of this Jtpparent.
discrepancy is imperative.
20. Pg. II-1. Thy text. stfues that "iJp to 26 mld of the Itandleman Lake yield, would
return t.o the Dccp hivcr watershed as wastewater..." and "...~~ ml;d could be discharged
dawnst.reartt of the reservoir to the Uecp )fiver." Wltcrc arui how would this discharge o:;cur?
What cost. wc~ulcl he incurrec]? This ciischargc represents aPproxitnatcly 1 U~ii, or the projected
flow downstream on the darn. Whnt. effect does this have:? 1-3as the downstream fJuw been
modeled for dissolved gxygen`1 Pravidc the results.
21. Yg. I I-;3. C1TmtTlative c;onccntralionc from all saurccs should be cstitr-ated for wntcr
gtTality evaluations; sout'ccs eliminates should be identified with justification. Water classiilcation
atTd standards should be identified. The estitTTatcd concentrations should tie coirtparecl to drinking
water, surface water, and ecological stmdards. The Project. ttntst hr rvaIuated with respect to
compliance Wlt.1T tl1C Clean Water Aea including leneratiun of `I'Ml~l..s where appropriate.
Pgs, V-I2-13. After a thorough assessment of ground water GonttliTTirtatign, 1TleatT Ct>nGt:nl]'BilUn
should be dc:velopeci fc~r all con"stitucnts includitg orfianic comPaunds not cttrrently identiiles
(including such compontTds as vinyl chloride), TalJle V-S indicates there is tta standard for
Methylene Chloride. `1h1S IS IJ1Cl>JTC(:1.. A Maximum C'ontuminant I,evrl MC'L of S tnicrohrams

t_i N t'•. ~{ t~Kt.. 1L •'-V'--JVL-- =JJV V'_ i •.~~: ~ - ~ - . ~ ~_ _
10
per liter for Dichloromethane (>\'led~ylcne Cltloridej •~~as pre~iiul~;atrri it; Jt:iy 1992. Tits mc;nn
nnnttal concentration idcntifit;d in Table V-~, without the WVJ'I'1', is 4.9 nucro~ans per litc7 just
under the SI~WA MCL criteria, but ezcestiinb the MCL during nuximum projection of 17
microgrAtnS per lit.et u1 TaU1C V-6 on pnbc V-14.
22. Pg. II-4, 'I'ltc text stales that "lt is CxpCC:t.ec1 thGt significant cuantities of organic ~in~1
inorganic pollutants would be z-emovcd by sedimentation as rite water is :autcd throu};h the
reservoir tc~ the into}:c locution." biscuss Tf:e proje~».:i siltation rates an c the possibility of the
Sediment nctinl; tts a pollut~~nt source. Ibis: uss the cLrc;cts ~:i iwttc:n d`r•clling aauaac life.
23. Pg;. IV-]&. Prcwicie a justificarion for tn~ oaseilow coneentrati~n

Division of Water Quality
January 4, 1999
TO: John Dorney ~
FROM: Boyd DeVane !~~
SUBJECT: Review of Randleman Document
When the Corps did the draft EIS for the Randleman Dam,
they received considerable comments from EPA about water quality
impacts. They also received many questions about water quality
impacts from DWQ (Michelle S.). David Franklin was a little
perturbed that DWQ would ask for the EIS to contain answers to
considerably more questions on water quality. He therefore met
with Preston and Linda Rimer and supposedly got them to agree to
address all the additional water quality issues for the EIS. He wrote
the Department a letter after the meeting and said that "as was
agreed, you will address all of the remaining water quality issues
and that they will probably be addressed in the management plan
for the reclassification" (not an exact quote but close to it.). Anyway,
the Regional Water Authority was aware of this and realized that the
management plan for the reclassification would not address many of
the detailed questions about water quality, especially those of EPA.
They accordingly hired a consultant to address those questions. I
have attached the consultant's report addressing those issues and
portions of some of the original letters on the EIS which they
address. Coleen suggested that you should review any portions of
the document relating to wetlands. I have placed a sticky note on
the pages which I thought you might be interested in. I would
appreciate you reviewing what is said and let me know if you can
live with it. If not, please indicate what it would take to make it
suitable. I intend to prepare a letter for Preston saying that this is
our response to the commitment we made to address the water
quality issues.
I would appreciate you looking at this as soon as possible.
They are pushing me hard to get the letter out this week. However,
if you could have those pages reviewed by Friday afternoon, that
would be great. Call if you have any questions or would like for me
to do anything to help.
cc: Dennis Ramsey

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C
From: John Dorney [john_dorney~h2o.enr.state.nc.us]
Sent: Wednesday, January 13, 1999 12:52 PM
To: Boyd DeVane
Cc: Dennis Ramsey; coleen_sullins~h2o.enr.state.nc.us; pate_colwell~h2o.enr.state.nc.us
Subject: Re: 401 Certfficate : Raneleman
i love being quoted when i did not say anything. I wouki definately remember
a conversation with Mr. Kime -there was none.
I did read the report last night and here are my thoughts:
1. Effects on downstream wetlands -they make a real weak case that there
will be no effect. Amore logical response would be that most piedmont
wetlands do not derive a significant portion of their water budget from
overbank flooding of the main stream (e.g. Deep River) but rather derive water
from smaller tributaries as they enter the larger floodplain. Therefore flow
attenuation from the dam should have little effect on downstream wetland
function.
2. Wetland mitigation -what they have proposed is fine. We will need
final, detailed mitigation plans for these sites within (say) 6 months of the
issuance of the 401.
3. Wetland impacts by alternatives -again their response is weak. As of
12/31/98 we now have a digital wetlands map of the state (piedmont and
mountains and outer coastal plain anyway) with known levels of accuracy. If
they so choose, they could use that map to approximate wetland acreages within
their other alternatives. Have them call me or Shannon Stewart ff they are
interested.
4. With respect to the larger issue of water quality standards, i would go
with the logic we briefly discussed yesterday. Say that DWG will require
relocation of the discharge to segment 2 and that the NPS buffers,etc. plan
will handle NPS problems and that the modeling shows an average chlorphylll a
level of 39 ug/I which is less than the standard of 40.
Finally i have a meeting with Preston this afternoon for a bunch of items.
The only issue I know of with respect to the 401 for Randleman is as follows.
The Management Plan (and relocation of discharge) are crucial to making a
statement in 401 that water quality standards will be met. The logic above is
fine with me but the Management Plan (and its corresponding rules) is not
final until the Legislature does not act (goofy law). What 'rf we issue 401
which relies on the rules and then the Legislature tosses out the rules?
need to discuss the dilemna/process with Preston/coleen. If you have any
thoughts, let me know.
Boyd DeVane wrote:
> The 401 letter is certainly not going out this week and I don't have any
> estimate about when lt will. John Dorney/Dennis Ramsey will be dealing
> with that. As far as the response to the Corps' November 14, 1997 letter,
> I am preparing that but still have not completed lt. I'm involving several
> staff in the review of the information and am waiting to get their input
> before I complete the memo. I don't see lt getting out until next week,
> at the earliest. I will send you a copy of our response as soon as it is
> approved. As for waiting until the Remedial Site investigation is out, I
> will have to look into that and get back to you.
> Alan Horton wrote:
> > The Greensboro News 8~ Record today reported ..."state environmental
> > administrators plan to send (401 Certificate) this week... that state

~f
ot:icials told him (John Kime) the letter had been held up by the
> holidays and other assignments."
>>
> > would you please email me what the status of the response to the Corps
> > of Engeneers letter of November 14, 1997 is, and what the status of the
> > 401 Certificate is.
> > I understand the Seaboard Chemical /High Point Landfill Remedial Site
> > Investigation is now due by the end of March 1999. Will the 401 be
> > issued before the Division of Solid and Hazardous Waste has the
> > opportunity to OK ?
> > Thank you,
> > alan horton
> > thank you,
> > alan horton
z

Alan M. Horton
1057 Pace Road
Burlington, N.C. 27217
November 15, 1997
John R. Dorney r=.-°-~
Wetlands Scientist b i ~', ~ ~ ~ ~ ~~-
Division of Environmental Management
4401 Reedy Creek Road ' `s NOV 19 I~~'~'
Raleigh, N.C. 27607 _
Re: Randleman Lake 401 Water Quality Certificate
Dear Mr. Dorney:
On behalf of the Deep River Citizens' Coalition I would like to request a public hearing
on the Piedmont Triad Regional Water Authority (PTRWA) 401 Water Quality
Certificate for the proposed Randleman Lake.
The October 3, 1997 "Press. Release" from Don Reuter NCDENR , "DWQ SETS
CONDITIONS FOR 40~'CERTIFICATIONG~ RANDLEMAN PROJECT ", states : "The
DEIS (1997 Draft Environmental Impact statement) will also be used by DWQ in
issuing a Section 401 Water Quality Certificate for the project."
In my letter to Boyd DeVane NCDWQ dated June 8, 1998 I requested that, "The
watershed management plan and nutrient reduction strategy proposed by the Division
of Water Quality should reflect the questions and concerns that were addressed as
written comments to the Corps of Engineers (COE) on the June 1997 Draft
Environmental Impact Statement for the proposed Randleman Lake." I feel a number
of questions and concerns were not addressed in the rules adopted by the
Environmental Management Commission in their reclassification action on Thursday,
November 12, 1998.
In my comments to the COE on the 1997 DEIS I stated a number of reasons a
Supplemental Draft EIS (SETS) should be required. One concern was the Randleman
Lake Watershed Management /Nutrient Reduction Plan had not been proposed or
adopted, and should be included in a SETS. I would hope a 401 Water Quality
Certificate would not be issued until a SETS was published. I feel the DEIS is
inadequate and a SEIS would allow the COE to address the questions and concerns
from the DEIS written comments.
The DEIS states on page 3-22 : "...the specific impacts of the interbasin transfer
associated with the proposed project have already been judged acceptable by the

I
State of North Carolina." I would like to point out the fact that North Carolina Superior
Court Judge Dexter Brooks, in his May 12, 1994 Order found : "The (1991 -PTRWA
Final) EIS for the proposed Randleman Lake is inadequate as 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 project. As such, the EIS does not provide a
suitable `tool for decision makers' and cannot be relied upon."
DWQ comments on the 1991 PTRWA FEIS stated Water Quality Section Asst. Chief
Trevor Clements concerns had not been addressed. Ina January 23, 1990 memo
from Mr. Clements to Melba McGee the following concerns were noted
" The influence of the impoundment on the present flow regime, and corresponding
water quality both in the project area and downstream are not discussed. "
"...no mention is made of how often minimum release events will occur. A 7Q10 event
reflects the lowest seven consecutive day average flow that is expected to occur only
once every ten years. Will this event under the proposed project occur more often? If
so, what are the implications of creating more frequent critical low flow periods thereby
placing greater stress on the downstream receiving waters? If 48 MGD (estimated safe
yield) is removed from the lake during low flow periods when inflow is less that 10
MGD, what will the effect be on both lake residence time and downstream releases
(i.e., expected duration of minimum release events) ?"
The October 1995 Cape Fear River Basinwide Water Quality Management Plan on
page 4-28 sates:
" Self-monitoring data ,provided by the Sanford wastewater treatment facility, has
indicated frequently occurring low D.O. values in the Deep River at their upstream
monitoring station, SR 1400 near Cumnock. The reported low D.O. levels are often
below the water quality standards established for instantaneous surtace readings for
class "C" surtace waters. "
" The water quality issues in the Deep River are further complicated by a series of
dams which reduce velocity by pooling water upstream from each dam, especially
during low flow conditions..." "The increased retention time provided by these dams
allow utilization of nutrients by aquatic plants (algae) resulting in excessive chlorophyll
a and major changes in D.O. There are approximately thirteen dams in the Deep River
downstream from Richland Creek [and the proposed Randleman Dam] prior to the
confluence with the Haw River. Time-of-travel (dye) studies conducted by DEM in the
mid 1980,s indicate that during low-flow (summer) conditions, time-of-travel for the
slow moving nutrient enriched waters to move from the upper Deep River (High Point
area) downstream to the Cape Fear would be measured in months."
What would be the ramifications of the proposed Randleman impoundment, on the
stressed waters of the lower Deep River? These questions, and their environmental
effects have not been addressed. The EPA 1997 DEIS comments states
"Has the downstream flow been modeled for dissolved oxygen? Provide the results."
NCDWQ Environmental Sciences Branch Comments on the 1997 DEIS states:
" The interbasin transfer described in the EIS will result in additional nutrient input into

' ~ ~
Jordan Lake which is already experiencing eutrophication problems. The EIS should
address whether this addition of nutrients will exacerbate the existing eutrophication
problems in Jordan Lake."
" A statement is made that any water quality problems in Jordan Lake caused by
interbasin transfer from Randleman Lake could be addressed by modifications in the
operation and maintenance of Jordan Lake by the Corps. Examples of possible future
problems would be increased algal blooms and associated fish kills in the Haw River
arm of Jordan Lake due to increased nutrient levels from WWTPs. "
"The report states that the average copper concentration in the reservoir due to the
High Point Eastside WWTP would be above the action level but the copper could be
removed in the water treatment process. An evaluation of copper toxicity should be
made to determine whether this would violate the water quality standard for this metal."
The model used by DWQ to predict chlorophyll a in the proposed lake should be
updated after the NPDES permit for the Eastside wastewater treatment plant
expansion is issued -using the estimated total phosphorus NPS loading associated
with the adopted rules and at low flow conditions and the new NPDES limits.
The published estimated chlorophyll a violations in the Deep River 1 segment on page
8 of the Report of Proceedings reflect the NPS concentrations for phosphorus from a
watershed management plan that was NOT adopted. These results also reflect
average flow conditions and should reflect low flow conditions.
Page A-20 of the Report of Proceedings also states : "...there is a possibility of
exceeding the state water quality standard for total phenols in the Deep River 1
segment ,and the Deep River 3B segment, if the undetermined load of phenols enters
directly into this segment."
What are these phenols, and what are the health effects to both human and aquatic
life? Why have the concentration of phenols in sampling at the Muddy Creek 8
location increased from an average of 4 ug/I to 30 ug/I ? Why has the detection of
phenols increased so greatly from the sample results published in September 1994
vs. the sample results published in March 1998 ?
The ramifications of issuing the required 401 Certificate are many. I feel it is in the best
interest of the people living in the Cape Fear Basin, that a public hearing be held on
such a vital issue.
Thank you,
Alan M. Horton

.r
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
January 18, 1999
MEMO
TO: Preston Howard
THROUGH: Coleen Sullins
Dennis Ramsey
FROM: John Dorn~p~
RE: Request for Public Hearing
Randleman Reservoir
1 •
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
3j
~~
~V 1
~ ~ ~ ~ suNV
As we discussed last week, attached is a letter from Mr. Alan Horton regarding a
request for a public hearing for the 401 Certification for Randleman Reservoir. My
recommendation is not to have a hearing since DWQ had a hearing for the management
plan late last year. I will also send a copy of the letter to Larry Coble, WSRO for his
opinion to you relative to a hearing.
Cc: Larry Coble, Winston-Salem Regional Office
~le~ ~~~,r`r,r~.
~,a,~n. , dp~~" ` C
Wetlands/401 Unit 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
An Equal Opportunity Affirmative Action Employer 50~ recycled/10% post consumer paper

~ ~.

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~~
Division of Water Quality
January 28, 1999 ; ;~. ~ ~ ~ ~ ~ _.,__~
;i J ,
~~
~ ~_ FEH 31999
TO: Larry Coble & Interested Staff
~~ ~ VtlETf.,tNDS GROI;~
FROM: Boyd DeVane~~~--v ~,. W%+~~ ^!lAlln S:~°
SUBJECT: Randleman Document
Attached is a letter and a document we sent to the Corps this
week. It is basically the PTRWA's consultant answering questions
and comments submitted earner about the Corps's Draft EIS. It was
prepared by their consultants and I reviewed it, with the help of
few folks here, to see if it would suffice for our promise- to the Corps
to address the outstanding water quality-related questions. I've Beni
it back twice with modifications. I decided to spare you folks the
dreadful task of revietiving it and making suggestions for
improvements. tiVe could have taken years to address all the issues
raised but we chose not to e:ctend this process for that. If the Corps
accepts the answers, they will continue their preparation of the Final
EIS which will be needed before the 404 can be given. I have . n o
idea what they will say about this submittal but I wanted to you
have a copy in case the issue comes up in the region. Of course, if
you see something that is wrong, please let me know and I can ge t
the correction, or improvement, to the Corps.

,,. ~ =tom "`" NORTH CAROLINA DEPARTMENT OF
~?:+•~Y ~- ~ - "~ ENVIRONMENT AND NATURAL RESOURCES
~~~ '.~;1 "': ~.~-,~~ DIVISION OF WATER QUALITY
.~.~~,~~
~~~ JAMES B. HUNT JR. ~ January 2~, 1999
GOVERNOR
Dr. G. `Vavne tiVriQht, Chief
- Regulatory Division
`D~'e~partmeat of the Army
WAYNE MCOEVIT~ YY llrnln~tonpDLStIICt, COlrs Of Ena1T1e0rS
SECRETARY ~ P_O_ BOX 1090
tiVilmington, Norh C:.roiilna 2802-1890
A. PRESTON HOWARD,
JR., PE.
DIRECTOP.

Dear Dr. Wright:
In our \ove^:ber 199 i meet:.nQ on tl~:e proposed Ran dleman Reservoir. •.L'e
agreed to provide your uQe^cv with additiona:rformation on the classification, ar:~
quality of the Deep River;vacers wiuca +.vouid form that lake. As I inforned you
then, our Commission would be conside.^:na rec:assifying those ;varers and reaui-~^?
a management strategy ~.v.ich would be useful to you in addressing the water au~,_ii_~
issues remaining in tine EIS. Tne Co~::...issicn h~ completed the rec?assificacon
process and adopted a management strategy anal I a-n now able to submit that
information to you for using in the :uiali~aacn of the EIS.
During this past year. we have devotee considerable resources to the
reclassirication process and to many or the issues associated with the EIS
ffnalization. Tne Environmental ylanaQe:nent Commission has addressed those
issues in several rnee:ings u s past ye:~r and .-jade decisions and took actions which,
we believe, will have a significant impact on u.e water quality of the lake. T:~.e maor
action taken was the at;proval by tare Commission to reclassify segments or tre Deeo
River as suitable for water sut,oly..`>rft~r a wet-attended public meeting and public
hearing, and re~riewin~ over 300 pages of written comments, the three Lnviror..Tae^ral
tilanagement COmmlS~ion he :ring officers :.,: Ommended that the various se? gents
of the proposed la:~ce be reclassified to a ;eater supply classification (WS-IV). Tre
Commission, voted on November 1?. 1998 to acprove the reclassification and ; Aso to
implement rules winch they referred to as the "~andleman Lake Watersi:ed
?„a*ragerrent Scrate`y." Tne rules c;,rtain a combination o: require cents wi,.ic1 we
believe will significantly reduce the nutrients and other pollutants to the lake and
provide adequate protection of the water quality standards. Those rules were adopted
by the Commission, approved in December by the Rules Review Commission and,
unless specirically addressed by action of the General Assembly, will come i:.to
effect on April 1, 1999. I have enclosed a copy of those rules as approved by the
Rules Review Commission.
In your letter doc~,unenting our November 1997 meeting, you requested that
we make a statement as to the suitability of the lake as a source of drinking water-
According to the Commission's rules (15A NCAC 2B .0216(2)), their classification
decision must be made on a finding that "The waters, following treatment required by
the Division of Environmental Health, shall meet the Maximum Contaminant I-'veI
concentrations considered safe for drinking, culinary, or food-procea'sing purposes
P.O. Box 29535, RALEIGH, NORTH CAROLINA 27626-0333
PNONE 91 9-733-3083 FAX [phone]
AN EQUAL OPPORTUNITY /AFFIRMATIVC ACTION EMPLOYER - 509'e RECYCLED/1 O uPOST-CONSUMER PAPER
.~ ~ _

~ ~
,, ..
Division of Water Quality
January 28, 1999 -- ?
~~ _
W 199
~'EB 3
TO: Larry Coble & Interested Staff r
WElE~1NDS GROUI'~~
WnTER ~_IAUTY ~FfT`
FROM: Boyd DeVan ~ --°~ ~ ~--~
SUBJECT: Randleman Document
Attached is a letter and a document we sent to the Corps this
week. It is basically the PTRWA's consultant answering questions
and comrr~ents submitted earlier about the Corps's Draft EIS. It was
prepared by their consultants and I reviewed it, with the help of ~:Y
few folks here, to see if it would suffice for our promise to the Corps
to address the outstanding water quality-related questions. I've Beni
it back twice with modifications. I decided to spare you folks the
dreadful task of reviewing it and making suggestions for
improvements. We could have taken years to address all the issues
raised but we chose not to extend this process for that. If the Corps
accepts the answers, they will continue their preparation of the Final
EIS which will be needed before the 404 can be given. I have n o
idea what they will say about this submittal but I wanted to you
have a copy in case the issue comes up in the region. Of course, if
you see something that is wrong, please let me know and I can get
the correction, or improvement, to the Corps.

'.:'^.S
"'-~. ~ ~
~,.r
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
P~~~ENR
~ January 2S, 1999
JAMES B. HUNTJR.
GOVERNOR
Dr. G. Wayne Wright, Chief
Regulatory Division
Department. of the Army
WAYT.E McoeviTT' ~ District, Corps of Engineers
Wilmington
SECRETARY ~ p
P,O. BOX 1090
Wilmington, North Carolina 28402-1890
Dear Dr. Wright:
..
A. PRESTON HOWARD,
'~•~ PE• In our November 1997 meeting on the proposed Randleman Reservoir, we
°IRecrOR agreed to provide your agency with additional information on the classification and
quality of the Deep River waters which would form that lake. As I informed you
then, our Commission would be considering reclassifying those waters and requiring
a management strategy which would be useful to you in addressing the water quality
issues remaining in the EIS. The Commission has completed the rec'assification
process and adopted a management strategy and I am now able to submit that
information to you for using in the fmalizauon or the EIS.
_~_;
- f ,. ~. ~I
- J _~~
_. .. ~~... _ .... r.__:_._~',,

During this past year, we have devoted considerable resources to the
reclassification process and to many of the issues associated with the EIS
finalization. The Environmental Management Commission has addressed those
issues in several meetings this past year and made decisions and took actions which,
we believe, will have a significant impact on the water quality of the lake. The major
action taken was the approval by the Commission to reclassify segments of the Deep
River as suitable for water supply. After awell-attended public meeting and public
hearing, and reviewing over 3!)0 pages of written comments, the three Environmental
Management Commission hearing officers recommended that the various segments
of the proposed lake be reclassitied to a water supply classification (WS-IV). The
Commission voted on November 12, 1998 to approve the reclassification and also to
implement rules which they referred to as the "Randleman Lake Watershed
1`~.anagerrent Strategy." The rules contain a combination of requirements which ~.ve
believe will significantly reduce the nutrients and other pollutants to the lake and
provide adequate protection of the water quality standards. Those rules were adopted
by the Commission, approved in December by the Rules Review Commission and,
unless specifically addressed by action of the General Assembly, will come into
effect on April 1, 1999. I have enclosed a copy of those rules as approved by the
Rules Review Commission.
V
In your letter documenting our November 1997 meeting, you requested that
we make a statement as to the suitability of the lake as a source of drinking water.
According to the Commission's rules (15A NCAC 2B .0216(2)), their classification
decision must be made on a finding that The waters, following treatment required by
the Division of Environmental Health, shall meet the Maximum Contaminant Level
concentrations considered safe for drinking, culinary, or food-processing purposes
P.O. BOX 29535, RALEIGH, NORTH CAROLINA 27626-0333
PHONE [phone] FAX [phone]
AN EgUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 50y6 RECYCLED/1 O e POST-CONSUM[R PAPER

1
,~.
f
which are specified in the national drinking water regulations and in the North Carolina Rules
Governing Public Water Supplies, 15A NCAC 18C .1500." In approving the reclassification, The
Environmental Management Commission has made that conclusion. Our decision to recommend
making the reclassification was based on extensive point and nonpoint source modelling efforts
and comparison of the predictions with other similar lakes in the Piedmont area of the state. Based
on our modelling efforts and associated predictions, we have concluded that implementation of the
management strategy to control point and nonpoint sources of pollutants will provide sufficient
protection to support the designated use of the Randleman Reservoir as a public water supply.
In addition to the.above-noted information, we have attached for your consideration a
"Summary of DEIS Comments and Responses." The responses were initially prepared by the
consulting firm of Hazen and Sawyer for the Piedmont Triad Regional Water Authority. We have
reviewed the document, directed that several modifications be made, and are submitting this as a
response to your earlier request that we address the primary water quality issues raised in
comments by the Environmental Protection Agency and the Wildlife Resources Commission. The
document also addresses concerns voiced by other organizations and citizens.
I hope this information addresses the needs of your a`;ency. If you have any specific
questions about the document, Boyd DeVane, of the Water Quality Section staff, will be glad to
provide assistance. He can be reached at (919) 733 - 5083 ext. »9.
Sincerely,
~ '~
A. Preston Howard Jr., P.E.
c: Coleen Sullins
John Kime

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Subject: [Fwd: [Fwd: 401 Certificate/Randleman Dam]] ~ ~`~~
Date: Mon, 25 Jan 1999 13:10:26 -0500
From: [e-mail] l-at.€~~°>!~A~l
Organization: N.C. Dept, of Environment and Natural Resources
To: Boss Holman <Bill_Holman_at_NRDCS01 [e-mail]> ,
Coleen Sullins <[e-mail]> ,
Boyd DeVane <[e-mail]> , ,1
dorney <[e-mail]> ,
Tommy Stcvcns <[e-mail]>
We will prepare a reply to Alan's request for hearing and attempt to
address all of the issues contained in his note. I have not made the
decision on hearing vs no hearing yet, but will keep you informed.
Subject: [Fwd: 401 Certificate/Randleman Dam]
Datc: Mon, 25 Jan 1'?~`9 ' 1:29:37 -0500
l.~r~En: 'l'rr•..:.:~; tl:........:~ ,;.I~.-...-.:, ~,.:,t~_...;;mh'v.enr.statc.nc, us~~
'~ -
To: [e-mail]
SnhjPCt: Re: 401 f'ert~ficatP/Rar_dleman Dam
.~;~ie: Fri, 2; „~,. i ', , ; , a' ~- _,_:~tt':
From: Bill_IIvL;~ai,_«<_ I~1IZDCSG~r@~~~ail.enr.state.nc.us (Bill liolma~~)
To: [e-mail] (Preston Howard),
tummy_stevcn~nh2o.enr.state,nc.us, [e-mail].~.~=
My response to Alan Horton is below. What is the status of the 401? We had a
good public process on reclassification/mgt plan so I don't feel a need for a
hearing on the 4f~1 but that's DWQ"s call. Could one of y'all contact Alan
directly?
_ _ g~rward Header
Subject: Re: 401 Certificate/Randleman Dam
a~:thor: Bill Holman at NRDCS0IP
Date: 1/22/99 5:39 PM
I'll ask the status of the 401. I'd like to know myself.
I haven't read you comments on the Corps EIS. I did review your comments
on EMC reclassification/mgt plan.
Reply Separator
Subject: 401 Certificate/Randleman Dam
Author: Alan Horton <[e-mail]> at Internet
Date: 1/21/99 8:13 AM
could you let me know about the status of the 401 Certificate for the
Randleman Dam?
still have a problem with using the term lake in the Randleman context
is it presumptuous to use Randleman "Lake"?
I of 2 1/25/99 1:33 PM

,~! - ~~,Ili:~[c;RtuiJlrin;in Ihuiill
I have written John Dorney asking for a Public Hearing on the 401
Would you find out if the 401 will be issued before the Seaboard
Chemical/High Point Landfill Remedial Site Investigation Report is
published.
I would also like to know if the 401 will be issued before the NPDES
Permit for the High Point Eastside Wastewater Treatment Plant is issued.
Can you tell me the status of the DENR response to the Corps letter of
Nov. 14, 1997. Was the EMC aware of the Corps letter before they voted
on the reclassification and watershed management plan - I wasn't aware
of the letter.
Have you read my comments on the Corps 1997 DEIS?
Have you read my comments on the EMC reclassifiction/management plan?
wVUil.1 a~,_,.~ .~ 4~.i should not be iSSUCU until.
1- The SCC/ High Point Landfill Remedial Site Investigation is published
and the water quality concerns from the site are addressed
2- '!'Y.~ 1Ja,~tsidA TnTTn7TA nipnES Permit is a_ppr"~,e~l
' -,;.:n.-„-rFi-rent plan ~ .> " i n - ' - -- „
4- The Corps i~~ues a rewrite, or Supplemental DEIS a::d the comments on
the revised DEIS made public
UO HEELS!!!
clan
2 cif Z 1/25/99 1:33 PM

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Fwd: Randleman 401]
Subject: [Fwd: Randleman 401]
Date: Thu, 04 Mar 1999 10:01:36 -0800
From: "John Dorney" <[e-mail]> l~~tcrnal
To: [e-mail]
CG Coleen Sullins <coleen [e-mail]>
jen- can you make this change in the 401?
Subject: Randleman 401
Date: Thu, 04 Mar 1999 07:50:15 -0500
From: "Coleen Sullins" <[e-mail]>
To: John Dorney <[e-mail]> ,
Dennis Ramsey <[e-mail]> ,
Boyd DeVane <[e-mail]> ,
Pam Whitley <[e-mail]>
John - I think the 401 needs to be modified to provide the date of the
Randleman rules that you are citing. I suggest that the condition be
revised to state: If any changes are made to 15A NCAC 2B .0248,..
adopted by the Enviromental Management Commission on December ??, 1998,
that are not equal or ...
If you will make that change and send the file electronically to Pam, we
will print it out and send it on up.
Boyd - are we ready to move forward with the letter of response to Mr.
Horton also? Coleen
I of 1 3/4/99 11:02 AM

Randleman
Subject: Randleman
Date: Morl, 1 ~ Mar 2000 10:4~:~7 -0500
From: Coleen Sullins <C~leen.Sullins~a).ncmail.net~
To: John Dorncy 'John.Dorneyl~ncmail.nct?
CC: Bovd Devane <_l3ovd.Devanelc~ncmail.net?
John - Uavid Franklin called me Friday about: t;he mitigation that is
hPi na proposPrl to a~3dr~.ss the Rand1 Pman clam _ Tle wanted 1-o knnw f w~
f>vF+r rt i_!1 ~n al~l>r~~~v'a l <3r>r~.lntir~r! I f~~r I, }?P iti~i t i <~~i l~ i ~~ri, 1+.=i ri i ,•nl ;~ r~l ~~ ~ }ip
upstream mitigation that is boir.; done. I feel ~^rtain that :ae have a
uv.:iiiu~ii~ ;lyriiiiJ ufi vii Llii: iiiltig~ttvll ~llc,lli~ livw~tivl~ '.~~ C1iC1 rivL li~iVi ~i
cv~y of it and wanted viie w Lirialize Clieir LiieS witli respect tv CliiS
pr~~ecC. Please let me know ii sucli a d~~urnenL exists aril fax him a
col?y at 910/ 251-402_x. He man also be reached aL 251-4952. I would
like to aet him somethina ASAP. Thanks C:oleen
loll.
i

+~.
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
~ ~ •
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 19, 1998
MEMO
TO: Boyd DeVane
FROM: John Dorne ~ ~
RE: Review of Draft report on Nutrient Management Strategy and
Implementation Plan -Randleman Lake
I have reviewed the draft nutrient management plan for Randleman Lake
dated February 1998. My comments are listed below:
1. Nonpoint source phosphorus goal. The nonpoint source portion of
the plan needs major work and (in my opinion) should not be accepted
by DWQ until revised. The point source portion of the plan has a goal
-namely, "to reduce P concentrations to the limits of technology and
as environmentally and economically feasible" (pg ES-3). In stark
contrast, the nonpoint source portion of the plan has no goal other than
comply with existing regulations. There needs to be a numeric goal for
the nonpoint sources of nutrients into the lake similar to the point
source goal. I would suggest that a logical goal would be `?here shall
be no increase in non-point source contributions of phosphorus to the
lake based on February 1998 loadings prepared by Tetra Tech Inc. for
the Piedmont Triad Water Authority". This goal (along with the point
source measures outlined in the report) would be a serious
commitment by the Authority to protect the water quality of the
reservoir. It would basically set up a nutrient trading process in the
watershed and probably force more stringent water supply protection
measures. It would allow additional growth in the watershed but
ensure that the development would be nutrient-neutral.
2. Wetland Restoration Program discussions (page ES-5, and 3-15).
This statement needs to be clarified and agreed upon by Ron Ferrell.
My understanding is that he is not willing to find wetland mitigation
sites for the Authority. However he may be willing to conduct
mitigation for them on sites that they acquire. Please contact Ron for
clarification.
Environmental Sciences Branch 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
An Equal Opportunity Aff rmative Action Employer SlK9a recycled/10% post consumer paper

3. Wetland mitigation sites (page 3-15). Pete Colwell has visited five of
these sites and they appear to be reasonable places to attempt
wetland. However at the Reddicks Creek and Buttke Dairy sites, it
may prove difficult to obtain the estimated wetland acreage of the lack
of hydric soils and the need for extensive grading and excavation. We
have not visited the Kersey Valley site and it is not shown on Figure 9.
Finally we have urged the Authority to locate and attempt more than
121 acres of restoration. This would provide some margin of error for
the Authority if the selected mitigation sites are not successful. The
Authority has apparently chosen to only locate 121.6 acres of
restoration areas. We repeat our suggestion to locate an additional
site to assure that the Authority meets the 121 acre goal. There is no
mention of the monitoring that will be required to assure mitigation
success.
4. EPA review. If EPA has not reviewed this report, they should. Their
staff will probably have useful comments concerning water quality
measures taken elsewhere in Region IV or the U.S. in similar
situations.
Cc: Ron Linville, Winston-Salem DWQ Regional Office
Dennis Ramsey
Pete Colwell
Randleman.pln

FOR DWQ INTERNAL REVIEW ONLY '. I``
~,:_ . -
To : Larry Coble ,'~, ~°
Steve Mauney `'
From: Ron Linville
Subject: Review of Randleman Lake Nutrient Reduction
Strategy and Implementation Plan.Draft
Date: 980220 ~~~R>ZP)
A very quick and extremely cursory review of the NRSIP for
Randleman Lake raises the following concerns and comments i are
presented here by page reference:
ES-3: NPS objectives are not specific. Current watershed
protection rules will not likely be sufficient to alleviate
degradation and water standard violations.
ES-4: In order to be effective, the nonpoint source reduction
strategy should exceed local watershed protection regulations by
protecting buffers for all intermittent as well as perennial
streams. Currently, the Division has concerns about the full
implementation for the adequate protection of perennial stream
buffers in this area generally.
ES-5: Consideration of the new created wetlands for inclusion
in reduction measures should be carefully considered as these
restored or created sites will simply replace those which have been
lost. These may be at best a neutral scenario and at worst a
negative loss of reduction benefits.
ES-8: Concentrations of Chlorophyll a in some upper tributaries
should again emphasize the need to provide for additional
safeguards in as many other areas as possible (such as protecting
intermittent streams and avoiding small stream and wetland losses) .
1-1: Suggest that the document indicate that the PTRWA is
developing this strategy "for presentation to the DWQ" and not "in
cooperation with" EMC, DENR and DWQ.
1-5: What restrictions will be placed on the utilization of
chemicals and fertilizers within the watershed?
2-4: The document indicates that the Chlorophyll a
concentration, nuisance algal conditions and unaesthetic conditions
will occur. Specifically, what measures can be taken in these
upper tributaries?
2-5: In the analysis of existing conditions relative to High

~ ~
` , ~'
Point's Eastside WWTP, are existing accumulations in the basin
given consideration due to the long term impact of the WWTP. Also,
are the figures utilized accurate? The Eastside WWTP has a history
of very significant bypasses of partially or little treated
effluent especially during storm events. Instantaneous flows have
been documented in excess of 70-90 MGs. During these events,
evidence exist which continues to point to possible combined sewers
and inflow of stormwater (normally considered nonpoint source).
DMRs provided by the High Point lab continuously and routinely
suggests that the City of High Point has no confidence in much of
the data reported.
2-8: Have the four regional stormwater ponds shown actual
reductions? If so, the specific data should be included in the
study.
2-9: A violation of the standard is a violation of the
standard. Unless the PTRWA seeks to go beyond the minimal
protection measures to try to offset these predicted violations and
request a variance based on these stringent development guidelines
and WWTP improvements, it is unlikely that the DWQ could support
reclassification to WS.
2-11: Elevated rates of discharge and. withdrawal from the lake
are likely to exasperate predicted conditions and may contribute to
standard violations closer to the intake. Again, every effort
should be placed on maximizing protective measures by WWTP
improvements, stringent stream and wetland buffering as well as
minimizing development impacts to waters and wetlands for the long
haul. Prevention is worth a pound of cure.
2-12: Watershed protection measures in all jurisdictions should
be equally stringent and enforced. In this manner, losses in one
area might be offset by thorough protection measures around the
proposed lake.
2-14: Despite the increased flow rates due to increased
impervious surface, will biomass accumulations sustain conditions
which will cause more Chlorophyll a concerns?
3-15: It is unlikely that the "NCWREP" should participate in
this effort as payment into a wetland bank cannot contribute to
enhanced water quality in this proposed lake.
3-17: It is highly probable that stormwater is collected and
moved via drainages in many of these areas so it is likely that the
diffuse drainage statement may be somewhat incorrect.
3-19: All commercial and large scale developments in each
jurisdiction should be required to provide for maintaining the
hydrogragh in order to prevent streambank erosion and sediment
deposition into the proposed lake. Water quantity as well as
quality is an issue.

~ ~~
3-23: The statement that the NC Sedimentation and Pollution
Control Act of 1973 prohibits visible sediment from washing off
construction sites is misleading and does not indicate the reality
of soil losses directly caused by site development and indirectly
caused from streambank erosion due to hydrograph surges and
increases.
3-26-27: Education is fine but it will not suffice alone.
Enforceable application limits will need to bey.prescribed and
compliance will need to be mandatory through injunctive procedures
if necessary.
4-4: "Coordination with DWQ" should be removed from the
document. As written, the DWQ would appear to be partially
responsible for the success or failure of the Randleman Lake's
nutrient reduction strategy.
4-6: The PRTWA should not only update the strategy and
implementation, it should also be empowered to mandate programs
over all contributory watershed jurisdictions.
Please keep in mind that this has been a very quick review and
a full grasp of details has not been accomplished. These comments
are provided for INTERNAL CONSIDERATION ONLY due to a lack of time
to fully and completely study the issues.
^~ cc: Central files
WSRO

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 H N ~
A. Preston Howard, Jr., P.E., Director
October 3, 1997
MEMORANDUM
TO: Melba McGee
FROM: Michelle Suverkrubbe
RE: Clamcation 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

NC-ADMIN-CODE ~ Page 1
15A NCAC 48.0024, DESIGN STANDARDS IN SENSITIVE WATERSHEDS
15A NCAC 4B.0024
NORTH CAROLINA ADMINISTRATIVE CODE
TITLE 15A. DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
CHAPTER 4. SIDIMIIQr!'ATION CONTROL
SUBCHAPTER 4B. EROSION AND SEDIMENT CONTROL
.0024 DESIGN STANDARDS IN SENSITIVE WATERSHEDS
(a) Uncovered areas in HQW zones shall be limited at any time to a
maximum total area within the boundaries of the tract of 20 acres. Only the
portion of the land-disturbing activity within a HQW zone shall be governed by
this Rule. Larger areas may be uncovered within the boundaries of the tract
with the written approval of the Director.
(b) Erosion and sedimentation control measures, structures, and devices
within HQW zones shall be so planned, designed and constructed to provide
protection from the runoff of the 25 year storm which produces the maximum
peak rate of runoff as calculated according to procedures in the United States
Department of Agricultural Soil Conservation Service's "National Engineering
Field Manual for Conservation Practices" or according to procedures adopted by
any other agency of this state or the United States or any generally
recognized organization or association.
(c) Sediment basins within HQW zones shall be designed and constructed
such that the basin will have a settling efficiency of at least 70 percent for
the 40 micron (0.04mm) size soil particle transported into the basin by the
runoff of that two-year storm which produces the maximum peak rate of runoff
as calculated according to procedures in the United States Department of
Agriculture Soil Conservation Services "National Engineering Field Manual for
Conservation Practices" or according to procedures adopted by any other agency
of this state or the United States or any generally recognized organization or
association.
(d) Newly constructed open channels in HQW zones shall be designed and
constructed with side slopes no steeper than two horizontal to one vertical if
a vegetative cover is used for stabilization unless soil conditions permit a
steeper slope or where the slopes are stabilized by using mechanical devices,
structural devices or other acceptable ditch liners. In any event, the angle
for side slopes shall be sufficient to restrain accelerated erosion.
(e) Pursuant to G.S. 113A-57(3) provisions for a ground cover sufficient
to restrain erosion must be provided for any portion of a land-disturbing
activity in a HQW zone within 15 working days or 60 calendar days following
completion of construction or development, whichever period is shorter.
*20319
History Note: Statutory Authority G.S. 113A-54(b); 113A-54(c)(1); Eff. May 1,
1990.
Editor's Note: Title 15, Department of Natural Resources and Community
Development, has been recodified as Title 15A, Department of Environment,
Health, and Natural Resources effective November 1, 1989. The recodification
was pursuant to G.S. 143B-279.1.
Copyright (c) West Publishing Co. 1996 No claim to original U.S. Govt. works.

DIVISION OF WATER QUALITY
Water Quality Section
September 12, 1997
M E M O R A N D U M
'It? Michelle Suverkrubbe
FROM: Steve Zoufaly-~~~,.e/
SUBJECT: Environmental Review Number 874 - Randleman Water
Treatment Plant EA - Guilford and Randolph Counties
Thank you for the opportunity to comment on the Environmental Assessment
for the proposed Randleman Reservoir Water Treatment Plant.
As you are aware, there is considerable discussion occurring presently
pertaining to the proposed Randleman Reservoir. Since the section of the
Deep River where the reservoir is proposed to be constructed is not currently
classified for use as a water supply source, a reclassification will be required.
Additional water quality evaluations are currently underway to assess the
suitability of reclassifying the Deep River (Randleman Reservoir) as a raw
water supply source. Prior to use as a raw water supply source, the
Environmental Management Commission must reclassify the Deep River
(Randleman Reservoir) for water supply use. Typically the Division of
Environmental Health Public, Water Supply Section, does not grant approval to
withdraw water for consumption until the water supply reclassification has
occurred. Even though there is a direct correlation between the reservoir and
the water supply intake, a separate analysis is being conducted for the
reservoir, therefore my comments will be limited to the assessment of the
proposed water treatment facility.
The water treatment plant construction will need to comply with the water
supply watershed development requirements by limiting the amount of
impervious surface area and using the appropriate buffer size. Due to the
close proximity of the water treatment plant to the intake, consideration
should be given to constructing the facility using more protective
development measures than the state's minimum criteria for water supply
watershed protection whenever possible. For example, minimizing impervious
surface area, incorporating a buffer that is larger than the minimum
requirements, making certain that any hazardous materials are properly
stored with adequate spill prevention/containment measures designed into the
facility including a spill remediation, and incorporating the requirements of
the Division of Land Resource's more stringent sedimentation and erosion
control requirements (15A NCAC 4B .0024) throughout the construction phase.
If you have any questions please give me a call at 733-5083, ext. 566.
Enclosure
cc: Coleen Sullins
Lisa Martin
ER/Randleman Res. WTP.mem

State of North Carolina
Department of Environment
and Natural Resources ` ~ ~
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary ~ E N
A. Preston Howard, Jr., P.E., Director
December 19, 1997
MEMORANDUM
TO: Melba McGee
FROM: A. Preston Howard, Jr., P.E. %''
RE: Comments on DENR# 874; DWQ#11763
Piedmont Triad Regional Water Authority (PTRWA)
Randleman Water Treatment Plant EA
Randolph County
The proposed project consists of an Environmental Assessment (EA) on a proposed
Water Treatment Plant and intake to be located at the future Randleman Lake water supply
reservoir in Randolph County. The project will entail construction and operation of a 12
million gallon per day (MGD) water treatment plant to supply treated water to several local
governments in the Triad area, including Randolph County and the municipalities of
Greensboro, High Point, Jamestown, Archdale and Randleman. These local governments
comprise the Piedmont Triad Regional Water Authority (PTRWA), which is the "applicant"
for the project. Eventual expansion of the WTP to 24 MGD is predicted to be needed to
meet the projected 50-year demand in the project service area, however, that withdrawal is
not considered part of the current EA.
The Division has reviewed the EA on the project and has the following comments:
1. The Division is very concerned about the future water quality in the proposed
Randleman Reservoir, especially increases in nutrients from point and non-point
sources as a result of the urbanization to be served by this proposed water treatment
plant (see attached comments). There is a strong likelihood that a biological
response to eutrophication in the future reservoir will result in high chlorophyll a
concentrations, requiring a higher degree of treatment.
The proposed Treatment Plant could be dramatically affected by the final design of
the reservoir, the Final EIS for the Randleman Reservoir, the Nutrient Reduction
Strategy and Watershed Management Plan (currently under development by
PTRWA as a condition of it's 401 Certification for the reservoir), and the not-yet-
completed water quality testing of the proposed impounded waters.
2. On page 5 under the heading of "Groundwater", the EA implies that there will be no
significant adverse impacts from the contaminated groundwater at the Seaboard
ChemicaU High Point landfill sites. As discussed in DWQ's comments on the
DEIS for the reservoir, DWQ will not be able to verify this statement until the 1998
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 #874
Randleman WTP
DWQ Comments
page 2
Remedial Investigation report on the sites is complete. Indications are that
contaminants may be at greater levels than previously reported.
In addition, DWQ has records that show several abandoned gold mines and at least
one abandoned gold processing site (McCullers Mill) are in the Randleman Lake
watershed. McCullers Mill is where mercury was dumped into the Copper Branch
of the Deep River after it was used to process the gold ore. Mercury is of concern
due to potential food chain bioaccumulation. This issue was not adequately
discussed in the Water Treatment Plant EA or the Randleman Lake EIS.
Water Quality studies of the Deep River conducted by DWQ from July 1992 to
October 1993 also found phenol values above laboratory detection levels at all
sampling stations in the Upper Deep River study~area. Pesticides were also found
along with violations of water quality standards for Lindane and Dieldrin.
The Division therefore requests that an updated analysis /modeling of the predicted
metal and toxicant levels in the surface waters of the future reservoir be performed
and the results provided in the Water Treatment Plant EA. Elevated concentrations
of lead, mercury, nickel, lindane, dieldrin, as well as possible other unknown
contaminants may be of concern in the reservoir and should be adequately assessed
in the EA. The EA should provide discussion of the steps that will be taken to
mitigate these concerns and protect the future water supply from the sources of
these toxic chemicals.
3. In combination with the issues discussed in item 2 above and the Division's
experience with other eutrophic water supplies, DWQ is concerned about the ability
of the future Randleman water to be adequately treated for public consumption. The
EA should provide a discussion of the method(s) of treatment that will be used to
address the treatability concerns associated with the eutrophication and the predicted
levels of other contaminants in the future reservoir water. This discussion of
various treatment methods should use the most recent water quality testing studies
available and address all environmental and human health impacts, as well as cost
comparisons among the methods proposed. The EA should distinguish all cost
estimates as to initial or recurring costs.
4. If water treatment will result in the need to dispose of backwash wastewaters, the
method of disposal and environmental impacts must be addressed. Characterization
of the future backwash or other wastewaters from the WTP (including toxicants)
must be provided and the method of mitigation of the impact addressed.
5. The assumption put forth in the EA that filter backwash and effluent from the WTP
(which will be discharged back into the reservoir) will not contain any nutrients
should be supported with data and concentration information from other similar
facilities. Other similar water treatment plants should be investigated, such as
Cary's WTP, where the water supply is eutrophic and has a high nutrient load.
6. Reclassification of the Randleman Watershed to a Water Supply (WS)
Classification will be required prior to use of the water for public consumption.
The Management Plan and Nutrient Strategy required as part of the 401
Certification for this project will need to be approved and adopted (and in effect) by

DEHNR #874
Randleman WTP
DWQ Comments
page 3
local governments either prior to or simultaneously with the reclassification of the
Randleman Watershed for Water Supply purposes. Additional discussion on the
reclassification process and required construction practices in water supply
watersheds is provided in the attached memo from Steve Zoufaly with DWQ's
Classifications and Standards Unit.
7. On page 8 of the EA a statement is made that the project will have no adverse effects
on other water supplies. Discussion should be provided as to the potential impacts
of the water withdrawal on downstream users. In addition, the proposed interbasin
transfer of water from the Deep River to the Haw River Basins will result in
additional nutrient inputs into Jordan Lake which is already experiencing
eutrophication problems. The EA should discuss whether this addition of nutrients
will exacerbate the existing eutrophic conditions lit Jordan Lake.
If the applicant should have any questions on these comments, I can be reached at
[phone].
mis:\874 Randleman WTP
attachments
cc: DWQ staff
DEH -Public Water Supply

State of North Carolina
Department of Environment,
Health and Natural Resources ~ • •
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary ~ E H N F~
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; DWt?#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 Quakry
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
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 ui 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
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 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 tei~ris
of reduced costs (especially the $64 million to relocate the High Point Eastside
WWTP) and fewer potential environmentaU 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 requu•ed
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 8/26/97) on this DEIS. DWM states that they believe "the
contaminant loading to the Deep River is substantially higher" (yet un-quantified),
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 perforrned 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

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AGENDA
NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
CALLED BUSINESS MEETING
512 N. Salisbury Street
Archdale Building -Ground Floor Hearing Room
Raleigh, North Cazolina
November 12, 1998
lzecutive ~rc~er No. 127 mandates tj:at tie air inquir+a as to w~iet~rer any
member knows of any ~¢nown con~ict of interest or appearance of con~ict with
respect to matters ~iefore t~e L'ommiseion. If any mem~ier ~enowe of a con~ict
of interest or appearance of conflict, pease so state aE Eltis time.
David H. Moreau, Chairman, Presiding
I. Preliminary Matters
1. Call to Order at 11:00 am
2. Approval of Minutes from the October 8, 1998 Commission Meeting
3. Summary of Approval Documents - No report
4. Revisions or Additions to the Agenda
Presentation on Air Quality Permitting Procedures for North Carolina Class I Areas
(This item requires no action)
II. Action Items Page 1
980060 (WQ)
Hearing Officers' Report on the Proposed Reclassification of a
Portion of the Deep River (Randleman Reservoir) and tributaries
to Classes WS (Water Supply)-N and WS-IV CA (Critical Area)
III. Status Reports
1. Status Report by EMC Committee Chairmen
a. NPDES Committee
b. Water Quality Committee
c. Groundwater Committee
d. Air Quality Commitee
e. Steering Committee
IV. Information Items - No information items for this meeting
V. Concluding Remazks
By Commission Members
By Directors
By Counsel
By Chairman
Adjournment

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~tt£D ST,~rF ~C G ~.IYL~( `U `~V,
aJ A .SU UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ~ t v~~k
/A Y
< ~~ Z REGION 4
i ~ < ATLANTA FEDERAL CENTER ~~~; ti.~~
;F ,o= 61 FORSYTH STREET
tir,~~ nAOt£°1 ATLANTA, GEORGIA 30303-8960 (\~y'~
GCT 1 5 1999 s ~`~`
-~, ~,
).
';~~ ~ .
~;~
~C'~~
Dr. G. Wayne Wright, Chief. ~~
Regulatory Division
Corps of Engineers
Box 1890
Wilmington, North Carolina 28402
SUBJ: Draft Environmental Impact Statement on Randleman Lake, Guilford and Randolph
Counties, North Carolina, June 1997
Dear Dr. Wright:
This letter is in response to your May 28, 1999 letter requesting the Environmental
Protection Agency's (EPA) review of supplemental material pursuant to water quality issues that
EPA expressed in comments on the subject draft Environmental Impact Statement (EIS).
'to summarize our understanding of the proposed action, the Piedmont Triad Regional
Water Authority (PTRWA) had proposed to build Randleman Lake as a water supply for the
Piedmont Triad Region. This impoundment, to be located in Guilford and Randolph Counties, is
expected to satisfy water demands of the region for the next 50 years. Because the proposed lake
would be situated downstream of a rapidly urbanizing area, existing and future sources of
pollution and nutrients could threaten the water quality of the lake. Technical studies conducted
over the past decade have predicted that although the majority of the lake is projected to meet
water quality standards, nutrients are predicted to cause undesirable algal growth and pose
difficulty in meeting the state's chlorophyll a standard in the upper shallow-bottom reaches of the
lake. A second issue stemmed from two contaminated properties being contiguous with the
proposed lake property boundary. Both the former Seaboard Chemical Corporation plant
property and the City of High Point Riverdale Landfill lie adjacent to the IVtiV arm of the proposed
lake, and are sources of contamination by seeping groundwater.
The Wilmington District Corps of Engineers (COE) issued t}~e subject draft EIS in June
1997, and in October 1997 EPA expressed concerns that the Draft EIS did not adequately address
>roundwater contamination and the excessive nutrients that were projected to be in the proposed
lake. Following EPA's concerns, North Carolina Department of Environment and Natural
Resources (NCDENR) Division of Water Quality (DWQ) provided additional information (Ref 1)
in early 1999 and the Wilmington COE requested that EPA evaluate the new material. In addition,
NCDENR met with EPA in August 1999, and provided more technical materials to EPA at that
time.
Internet Address (URLj • http:,~lwww epa.gov
RecVCled/Recyclable • Printed wAh VeyetabW. Oil BaseC Inks rn ;~ec~cle~! Paper ,.Minimum 25'o Postconsurner

Since the release of the Randleman Lake Draft EIS in 1997, a number of technical studies
have been made available to EPA and the public. Foremost of these was DWQ's water quality
modeling study which incorporated two previous modeling studies performed by Tetra Tech (Ref
2) and Research Triangle Institute (Ref 3), two private consulting organizations that specialize in
waste loading and contamination issues. The largest single source of nutrient loadings to the
proposed lake would be from the High Point-Eastside Wastewater Treatment Plant (WWTP).
Modeling studies by DWQ (Ref 4) indicated that moving the WWTP discharge away from
shallow water to a deeper point near Freeman Nlill (approximately 1 -1/2 miles below the present
outfall) would result in significantly lower eutrophication in the upper arms of the Deep River.
DWQ's studies concluded that this discharge relocation would substantially reduce the potential
for eutrophication in the Deep River arm because of the elimination of a major source of nutrients
that would support algal growth in that arm, and the ability of the lake waters to better assimilate
the nutrients at the downstream site.
Stringent basin-wide nutrient control measures have also been proposed by NCDENR.
Without a significant management initiative, historic monitoring data within the watershed
indicate that the proposed lake is likely to experience elevated trophic conditions. In early 1997,
DWQ staff informed the PTRWA of the need to implement a "Comprehensive Watershed
Nlanagement Plan" as part of the 401 state certification process. The Plan was to include
assurances that point and non-point controls on nutrients would be given which would provide
protection of the lake waters. Elements of this Plan are now specified in the NC Administrative
Rules adopted by the Environmental Management Commission (15A NCAC 2 B.0248, .0249,
.0250, and .0251). The major elements of the Plan include providing 50-ft buffers around all
perennial and intermittent streams, regulate tree cutting around those streams, control housing
density within afive-mile drainage area and more stringent controls within the first '/~ mile of the
lake, limiting the mass loading based on an effluent limitation of 0.5 mg/I of phosphorus at 26
MGD flow (in addition to relocating the discharge approximately 1 -'/~ miles downstream), and
other stormwater protection measures.
Nutrient levels in the proposed lake are predictions based on mathematical models and, as
such, are only estimates of conditions that might exist in the future. The models indicate that lake
water quality will be within state regulatory guidelines; however, post-impoundment water quality
may exceed expectations, or may be of diminished quality. These unknowns will be determined
by post-impoundment water quality monitoring surveys proposed by DWQ (Ref 5) to be
conducted by local governments. Should post-impoundment water quality require reduction of
nutrient flows into the system, then additional restrictions or alternative strategies would need to
be adopted as required. EPA believes that the nutrient control measures already proposed by
NCDENR and adopted by the North Carolina Environmental Management Commission constitute
measures that can reasonably be expected to improve the control of nutrients into the proposed
lake.

The contaminated soils and groundwater present in the Seaboard Chemical Corporation
site and the Riverdale landfill site are situated near the upper arm of the proposed lake, and
contaminants can seep into the lake via groundwater. Groundwater flow and transport model
studies are on-going (Ref 6) that measure the rates and direction of contaminant migration. A
companion study (Ref 7) examined remediation options that are available to the PTRWA.
Various remediation alternatives include natural attenuation (no action), hydraulic containment via
groundwater pumping, in-situ treatment via air sparging, expanded groundwater recovery and
treatment, and other options. Impacts of human health have likewise been examined (Ref 8).
NCDEtiR has released these studies for public comment, and the comment period is still open as
of this date. EPA believes that the NCDENR is examining contamination issues in a responsible
and thorough manner and is including the public in these deliberations. There is a suite of
technological options available to manage groundwater contamination, and EPA has confidence
that the programs NCDENR are considering are adequate to prevent significant amounts of
contaminants in the proposed lake water.
In conclusion, EPA believes that the nutrient control measures should be given an
opportunity to demonstrate efficacy in controlling algal Qrowth and chlorophyll a in the proposed
lake. ~~'e also concur with the North Carolina Environmental >/Ianagement Commission's
conclusion (Ref 4, Page 10) that "[the nutrient management plan] ...should result in a lake that
will support all designated uses assigned and that the reclassification action of the Commission
would be consistent with the requirements of the Federal Clean Water Act and the State's laws
and rules." Regarding the significant issue of whether the pollution from the toxic chemicals
found at the former Seaboard Chemical facility and the High Point Riverdale Landfill sites in
Guilford County pose a serious threat to the water quality of the reservoir, we accept the state's
conclusion that "...[I]t is technically feasible and economically viable to achieve a drastic reduction
in and pollutants leaving the site and accordingly minimize the potential of pollutants causing any
violations of water quality in the lake."(Ref 9) The NCDENR has indicated its confidence that,
even though the final approval process for the remediation plan is not complete, there is sufficient
evidence and "strong commitment" that "...[A]ll water quality standards and uses will be
protected in the lake."(Ref 9) Furthermore, we are encouraged by the information we've seen on
the various remediation alternatives and the public health risk assessments that have been
performed and are now under public review. Although the alternative to remediate the site has
not been specifically selected, we believe that the alternatives do offer options which will ensure
the protection of the lake and we have confidence in the commitment of the State agencies to see
that the selected option is implemented and the lake is protected. Finally, we would encourage
the Wilmington COE to include in the final EIS synopses of all relevant technical studies, perhaps
as a technical appendix to the document. With this information and the assurances offered by the
State of North Carolina, EPA considers its previous technical concerns resolved and concurs with
the En~~ironmental Ntanagement Commission conclusions.

4
EPA appreciates the opportunity to review the referenced draft EIS and the technical
materials that were provided by NCDENR and the PTRWA. If further information is needed,
please call me or John Hamilton at 404-562-9617.
Sincerely,
~Gt~v/~_
Ro F. McGhee, Director
Wa r Management Division
Enclosures: William L. Meyer Letter
cc: Ms. Coleen Sullins, NCDENR
Chief, Water Quality Section
Box 27687
Raleigh, North Carolina
Mr. Boyd DeVane, NCDENR
Division of Water Quality
Box 27687
Raleigh, North Carolina
Mr. John Kime, Executive Director
Piedmont Triad Regional Water Authority
Koger Center, Wilmington Bldg, Suite 201
216 West Meadowview Road
Greensboro, North Carolina 27407
Mr. Don Cordell
Hazen and Sawyer
4011 West Chase Blvd.
Raleigh, North Carolina 27607
References:
1. Hazen and Sawyer, 1998. "Draft Summary of DEIS Comments and Responses, Randleman
Lake, Guilford and Randolph Counties North Carolina, December 1998," Revised December 14,
1998, Revised January 20, 1999.

5
2. Piedmont Triad Regional Water Authority_ , 1998. This report by TetraTech is found in
"Support Documentation for Nutrient Load and Eutrophication, Nlodel, TetraTech, Inc., February
199S" that was included in Section 5 in the "Randleman Lake Nutrient Reduction Strategy and
Implementation Plan," issued by the Piedmont Triad Regional Water Authority. [Ed note: This
document in Draft form was not republished as Final, the Draft being determined by DEQ staff as
needing no substantive changes.]
3. Research Triangle Institute, 1998. "Eutrophication Modeling for the Randleman Lake Project,
Final Report" submitted to the North Carolina Department of Environment and Natural
Resources Division of Water Quality, September 30.
4. State of North Carolina Department of Environment and Natural Resources, 1998. "Report
of Proceedings, Proposed Reclassification of Segments of the Deep River (Proposed Randleman
Reservoir)." Public Hearing, September 1, 1998, Jamestown, NC.
5. State of North Carolina Department of Environment and Natural Resources, 1999. Draft
Study Plan, Water Quality Characterization of Post-Impoundment Randleman Reservoir Deep
River, September 1, 1999. Attachment to letter to Mr. Robert F. McGhee, Director, Water
Management Division, USEPA Region 4, Atlanta, Georgia 30365
6. Synesis Environmental, 1999. "Seaboard Chemical Corporation Facility and City of
Highpoint Former Riverdale Drive Landfill Groundwater Flow and Transport Model Report,"
April 1999. Prepared by Synesis Environmental Inc., Aiken, South Carolina 29803.
7. Environmental Resources Management, 1999. "Seaboard Group II arid the City of High Point
Feasibility Study (FS) for the Former Seaboard Chemical Corporation Facility and the City of
Highpoint Riverdale Drive Landfill, Jamestown, North Carolina," April 1999. Environmental
Resources Management, Exton, Pennsylvania 19341.
8. Environmental Resources Management, 1999. "Seaboard Chemical Company and City of
High Point Riverdale Drive Landfill, Jamestown, North Carolina, Human Health and Ecological
Risk Assessment," March 1999. Environmental Resources Management, Exton, Pennsylvania
19341.
9. State of North Carolina Department of Environment and Natural Resources, 1999. Letter
from William L. Meyer, Director, Division Waste Management, NCDENR to Robert F. McGhee,
Director, Water Management Division, Region 4 EPA, September 3, 1999.

_y<~:~
..,~•:M
NORYH CAROLIt~- [DEPARTMENT OF
~'.rtyt~.otvntierrr' AND NATURAL RESOURCES
DIVISION OF WASTC MANAGEMRNT
~`,,
Septe;nber 3,1999

Mz. Robert F. McGhee; Director
Water Management Division
US EPA Region N
Atlanta Federal Center
61 Forsyth Street
At?anle, Georgia 30303 3950
Subject: Additional Infortz~ation on Seaboardlliigh Point >~andf~115ite
Dear Mr. McGhee:
The North Carolina Division of Water Quality staffhas asked that I provide
you with updated information on the remedial invesli~dtion of the former
Sorsboard Chemical Corporation Facilit-i' and the High Povat Riverdale Drive
Landfill sins in Guilford CfUr Seabo~ Grow rI and the'C ~ f H ghPoint n)
BAs you know, Consultants
have recently prepared a Human Health and Ecclogical Risk Assessment" and
a "Feasibility Srldy'' for remedialiu>.>. of tho cxi3ti~ag Sources of cf ~rll ~ urination
al tLe Seaboard Chemieal/High Pent I.audfill site. These documents and
associated supporting data and evaluations are currently under review by the
Division of Waste Management and the public. The report provides detailed
information nn the nature and extent o° the contazrxinarion at the site amd
Compares the dative effectiveness of se~reral remediation technologies that
have potential application to address surPice euc) ~I•ounlwater pollutArit
concentrations found at the site.

In re~onse to a ~ucstion on tlxe acceptability of the docuxnrnts, until the
reviews z~c complete and agency anA rublie cotzunents are available, I can not
conclude that the documents will be approved as they now exist. 1:Iowever, I
can state that they do provide alternativra that caz~ achieve our goals for
protection of the environment at the site and in adjacent waters of the Deep
River or the Randleman Reservoir, if it is constructed. Based upon. sigaifican~
remediatiotl expciieucc with Superfiuid and RCRA Subtitles C, D, and I, the
DWM is confident that the proposed alternatives reflec~seo ~datonchni~ and
scientific merit. Based on information available to us,
that it is technic311y feasible and economically viable to achieve a drastic
redur.tinn in any vollutants leaving the site and accordingly minimize the
pntPntiAl ~f p~llut'duty tt~on7 this site csuxl.-~ ~,y violetinr~ of ~vaur qu.]lt} I11
the lake. FueQicnuare, as X have uuiica-~r1 in shn pa_SL` the ~ VYIrx hab a auvi.~
4V1 OYGRI ,w RbAO, SV1TE 1 S0, RALlIOMr NC 27605
p}IbNt 119-739•Aa~s FAX D10-7tS.3f05
AN EQUAL O~nbRTUN1T1' ~ AppIRMATI Y!! Ac'rwr !1[PLq Yl11 - SOli RLCYCLlp/LO~I. POST{gNlYMCR PAPCA

Mr. Robert F. McGhee
Scptcmber 3, 1999
Page 2 of 2
eoncumitment that the over-riding critenon for actions from our Divi~auu will Lc t1,at all water
quality Rr~ndarda and uoeC will be protected in the lake. This is Otlr $4a1 Bud we believe we
have the l~owledge, technology, aad financially responsible panics available to achieve this
goal.
Cinrerely
._ -
i 'am L. Mcye~, Directox
T7ivison of Waste Management
cc; To~xny Stevens
Coleen Sullins
c:lrvpfiletWtNvlglmeyers l.doc

OCT-19-99 15:05 FROM=WATER MGMNT REGION 4 ID:404 562 9343 PAGE 2/6
~~~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
_~' A ~ REGION 4
8 ~1~~ g ATLANTA FEDERAL CEM~ER
~ ~+1~/ 61 FORSYTH STREET
~c A7L4NTA, GEORGIA 3ai0C3-8960
OCT 1.9 199
4EAD/OEA ~~
Dr. G. Wayne Wright, Chief,
Re~.Ilatory Division
Corps of Engineers
Box 1890
Wilmington, North Carolina 28402
SLBJ: Draft Environmental Impact Statement on Randleman Lake, Guilford and Randolph
Counties, North Carolina, June 1997
Dear Dr. Wright:
This letter is in response to your May 28, 1999 letter requesting the Environmental
Protection Agency's (EPA) review of supplemental material pursuant to water quality issues that
EPA expressed an comments on the subject draft Environmental Impact Statement (EIS).
To summarize our understanding of the proposed action, the Piedmont Triad Regional
Water .Authority (PTRWA) had proposed to build Randleman Lake as a water supply for the
Piedmont Triad Region. This innpoundment, to be located in Guilford and Randolph Counties, is
expected to satisfy water demands of the region for the next 50 years. Because the proposed lake
would be situated downstream of a rapidly urbanizing area, existing and future sources of
poIlution and nutrients could threaten the water quality of the lake. Technical studies conducted
over the past decade have predicted that although the majority of the lake is projected to meet
water quality standards; nutrients are predicted to cause undesirable algal growth and pose
difficulty in meeting the state's chlorophyll a standard in the upper shallow-bottom reaches of the
Iake_ A second issue stemmed from two contaminated properties being contiguous with the
proposed lake property boundary. Both the former Seaboard Chemical Corporation plant
property and the City of Hach Point Riverdale Landfill lie adjacent to the NW arm of the proposed
lake, and are sources of contamination by seeping groundwater.
The Wilmington District Corps of Engineers (COE) issued the subject draft E1S in .tune
1997, and in October 1997 EPA expressed concerns that the Draft EIS did not adequately address
groundwater contamination and the excessive nutrients that were projected to be in the proposed
lake. Following EPA's concerns, North Carolina Department of Environment and Natural
Resources (NCDENR) Division of Water Quality (DWQ) provided additional information (Ref 1)
in early1999 and the W-iIminb on COE requested that EPA evaluate the new material. In addition,
NCDEIvR met u~th EPA in August 1999, and provided more technical materials to EPA at that
time.
Internet Address (URL) • htt~J/www_apa.gov
Recyded~Recydable •Prittsdwitll VefletaDic Oll Based Inl~ on Recytied Paper QJtinimlxn 25,G Postoonsmner)

OCT-19-99 15:05 FROM=WATER MGMNT REGION 4 ID=404 562 9343 PAGE 3/8
2
Since the release of the Randleman Lake Draft EIS in l 997, a number of technical studies
have been made available to EPA and the public, poremost of these was DWQ's water quality
modeling study which incorporated ttivo previous modeling studies performed by Tetra Tech (Ref
2) and Research Triangle Institute (Ref 3), two private consulting organizations that specialize in
waste loading and contamination issues- The largest single source of nutrient loadings to tl~e
proposed lake would be from the High Point-Eastside Wastewater Treatment Plant (WWTI~),
Modeling studies by DWQ (Ref 4) indicated that moving the WWTP discharge away from
shallow water to a deeper point near Freeman Mill (approximately 1 -1/2 miles below the present
outfall) would result in significantly lower eutrophication im the upper arms of the Deep River.
DWQ's studies concluded that this discharge relocation would substantially reduce the potential
for eutrophication in the Deep River arm because of the elimination of a major source of nutrients
that would support algal growth in that arm, and the ability of the lake waters to better assimilate
the nutrients at the downstream site.
Stringent basin-wide nutrient control measures have also been proposed by NCDENR.
Without a significant management initiative, historic monitoring data within the watershed
indicate that the proposed lake is likely to experience elevated trophic conditions. In early l 997,
DWQ staffinformed the PTRWA of the need to implement a "Comprehensive Watershed
Management Flan" as part of the 40I stn±e certification process. The Plan was to include
assurances that point and non-point controls on nutrients would be given which would provide
protection of the lake waters. Elements of this Plan are now specified in the NC Administrative
Rules adopted by the Environmental Management Commission (] SA NCAC 2 B.0248, .02•t9,
.0250, and .0251). The major elements of the Plan include providing 50-ft buffers around all
perennial and intermittent streams, regulate tree cutting around those streams, control housing
density within afive-mile drainage area and more stringent controls within the first'/Z mile ~~f the
lake, limiting the mass loading based on an effluent limitation of 0.5 mg/1 of phosphorus at '26
MGD flow (in addition to relocating the discharge approximately I -'/~ miles downstream). and
other stormwater protection measures.
Nutrient levels in the proposed lake are predictions based on mathematical models <<nd, as
such, are only estimates of conditions that might east in the future. The models indicate that fake
water quality will be within state regulatory guidelines; however, post-impoundment water quality
may exceed expectations, or may be of diminished quality. These unknowns will be determined
by post-impoundment water quality monitoring surveys proposed by DWQ (Ref 5) to be
conducted by local governments. Should post-impoundment water quality require reduetic~n of
nutrient flows into the system, then additional restrictions or alternative strategies would need to
be adopted as required- EPA believes that the nutrient control measures already proposed by
NCDENR and adopted by the North Carolma Environmental Management Commission constitute
measures that can reasonably be expected to improve the control of nutrients into the proposed
lake.

OCT-19-99 15:05 FROM=WATER MGMNT REGION 4 ID=404 562 9343 PAGE 4/B
3
The contaminated soils and ~oundwater present in the Seaboard Chemical Corporation
site and the Riverdale landfill site are situated near the upper arm of the proposed lake, and
contaminants can seep into the Iake via groundwater. Groundwater flow and transport model
studies are on-going (Ref 6) that measure the rates and direction of contaminant migration. A
companion study (Ref'7) examined remediation options that are available to the PTRWA.
Various remediation alternatives include natural attenuation (no action), hydraulic containment via
groundwater pumping, in-situ treatment via air sparging, expanded groundwater recovery and
treatment, and other options. Impacts of human health have likewise been examined (Ref 8).
NCDENR has released these studies for public comment, and the comment period is still open as
of this date. EPA believes that the NCDENR is examining contamination issues vn a responsible
and thorough manner and is including the public in these deliberations- There is a suite of
technological options available to manage groundwater contamination, and EPA has confidence
that the programs NCDENR are considering are adequate to prevent significant amounts oi'
contaminants in the proposed lake water.
In conclu~on, EPA believes that the nutrient control measures should be given an
opportunity to demonstrate efficacy in controlling algal growth and chlorophyll a in the proposed
lake. We also concur with the North Carolina Environmental Management Commission's
conclusion (Ref 4, Page 10} that "[the nutrient management plan] ...should result in a lake that
will support all designated uses assigned and that the reclassification action of the Commission
would be consistent with the requirements of the Federal Clean Water Act and the State's laws
and rules." Regarding the significant issue of whether the pollution from the toxic chemicals
found at the former Seabaard Chemical facility and the High Point Riverdale Landfill sites in
Guilford County pose a serious threat to the water quality of the reservoir, we accept the state's
conclusion that "... [T]t is technically feasible and economically viable to achieve a drastic reduction
in and pollutants leaving the site and accordingly mitrtimaze the potential of pollutants causir:g any
violations of water quality in the lake."(Ref 9) The NCDENR has indicated its confidence chat,
even though the final approval process for the remediation plan is not complete, there is su117cient
evidence and "strong commitment" that "... [A]lt water quality standards and uses will be
protected in the lake."(Ref 9) Furthermore, we are encouraged by the information we've tieen on
the various remediation alternatives and the public health risk assessments that have been
performed and~are now under public review. Although the alternative to remediate the site has
not been specifically selected, we believe that the alternatives do offer options which will ensure
the protection of the take and we have confidence in the commitment of the State agencies to see
that the selected option is implemented and the lake is protected. Finally, we would encou~ age
the Wilmington COE to include in the final EIS .rynopses of all relevant technical studies, perhaps
as a technics] appendix to the document. With this information and the assurances offered by the
State of North Carolina, EPA considers its previous technical concerns resolved and eoneu; s with
the Environmental Management Commission conclusions-

OCT-19-99 15:06 FROM=WATER MGMNT REGION 4 ID=404 562 9343 PAGE 5/6
4
EPA appreciates the opportunity to review the referenced draft EIS and the technic,~l
materials that were provided by NCDENR and the PTRVi,'A. If further information is needed,
please call me or John Hamilton at 404-562-9617.
Sincerely,
~Ro F. McGhee, Director
Wa Management Division
Enclosures: William L. Meyer Letter
cc: Ms. Coleen Sullins, NCDENR
Chief, Water Qualitty Section
Box 27687
Raleigh, I~Torth Carolina
Mr. Boyd De'Vane, NCDENR
Division of Water Quality
Box 27687
Raleigh, North Carolina
Mr. John Kime, Executive Director
Piedmont Triad Regional Water Authority
Koger Center, Wilmington Bldg, Suite 201
2I6 West Meadowview Road
Greensboro, North Carolina 27407
Mr. Don Cordell
Hazen and Sawyer
4011 West Chase Blvd.
Raleigh, North Carolina 27607
References:
1. Hazen and Sawyer, 1998. "Draft Summary of DEIS Comments and Responses, Randleman
Lake, Cnlilford and Randolph Counties North Carolina, December 1998," Revised December 14,
1998, Revised January 20, 1999.

OCT-19-99 15:06 FROM=WATER MGMNT REGION 4 ID:404 562 9343 PAGE i3/8
5
2. Piedmont Triad Regional Water Authority, 1998. This report by TetraTech is found in
"Support 17ocumentation for Nutrient Load and Eutrophication Model, TetraTech, Inc., Febnlary
1998" that was included in Section 5 in the "Randleman Lake Nutrient Reduction Strategy and
Implementation Plan," issued by the Piedmont Triad Regional Water Authority. [Ed note: 't'his
document in Draft form was not republished as Final, the Draft being determined by DEQ staff as
needing no substantive chanaes.l
3. Research Triangle Institute, 1998. "Eutrophication Modelzng for the Randleman Lake Froject,
Final Report" submitted to the North Carolina Department of Environment and Natural
Resources Division of Water Quality, September 30.
4. State of North Carolina Department ofEnvirorument and Natural Resources, 1998, "Rt:port
of Proceedings, Proposed Reclassification of Segments of the Deep River (Proposed Randleman
Reservoir)." Public Hearing, September 1, 1998, Jamestown, NC.
S. State of North Carolina Department of Environment and Natural Resources, 1999. Draft
Study Plan, Water Quality Characterization ofPost-Impoundment Randleman Reservoir Deep
River, September 1, 1999. Attachment to letter to Mr. Robert F. McGhee, Director, Water
Management Division, USEPA Region 4, Atlanta, Georgia 30365
6. Synesis Environmental, ] 999, "Seaboard Chemical Corporarion Facility and City of
Highpoint Fornner Riverdale Drive Landfill Groundwater FIovv and Transport Model Report,"
April 1999. Prepared by Synesis Environmental Inc., Aiken, South Carolina 29803.
7, Environmental Resources Management, 1999. "Seaboard Group II and the City of High Point
Feasibility Study (FS) for the Former Seaboard Chemical Corporation Facility and the City of
Highpoint Riverdale Drive Landfill, Jamestown, North Carolina," April 1999. Environmental
Resources Management, Exton, Pennsylvania 19341.
8. Environmental Resources Management, 1999. "Seaboard Chemical Company and City of
High Point Riverdale Drive Landfill, Jamestown, North Carolina, Human Health a~~td Ecolo~ca]
Risk Assessment," March 1999. Environmental Resources Management, Exton, Pennsylvania
19341.
9. State of North Carolina Department of Environment and Natural Resources, 1999. Letter
from William L. Meyer, Director, Division Waste Management, NCDENR to Robert F. McGhee,
Director, Water Management Division, Region 4 EPA, September 3, 1999.

OCT-19-99 15=07 FROM=WATER MGMNT REGION 4 ID=404 562 9343 PAGE 9/B
Mr. RoberE F. McChet
Scptcmber 3, 2994
Page 2 of 2
co~itmeut tbzt the over-~,ic~ing criLta~~ori for actions from o~ Divisaua w~Il i~c 1~ all ~r~
gaaliEy etJt~rclart~I nad aeAE will Y!e pxo~cted i~ thr. take. This i5 Orii $UaI 8md WC ~?C~leu'e we
have the i~owle~ge, teck~nology, aad 1-maacially r~pons~b~e pies avaal8ble to achieve this
~~-
SiacerelY j~
illiam I.. Ney ,Director
Divisors of Waste Management
cc: Tangy Stevens
Caicen Suhims
~twy~es~utt,Mg~my~sl.doe
~.

OCT-19-99 15=06 FROM:WATER MGMNT REGION 4 ID:404 562 9343 PAGE 7/8

Dmssori flF 1~YIr.'Tg 1rU-N+u~b~KT
Mx. Robeort F, McGhee; TTire-^Zoz
Rr~ M~getnent Division
US E3?A Region N
Atlanta Federal Center
51 Forsyth S
A~•~,e, Cioorgia 30303.8950
N4RTI"t G~~N'°' p~pAR'IMEi~t't' OF
'L~KYERONMCNT IWD [~[ATUR1lT_ RfiSOUftCES
September 3,1999
Subject: Additional jp{o~arion on Seab0atdlHi$h Point ~ site
Dear Ivlr. l4lcCsiiee:
The North Caroli~ Division of Gtt'ater QttzlitY sta~iias asked that I provide
you with. ~pd,ated ~~madon on the reme~~ investigation of the £oaaer
5cabosrd Chemieat Corp4rxtiol~ Facility ~ the High Point Rive~rd2le ~'e
);.anatfill sites im C~ford County E~~ as one "site" in the z~'estigatrou).
Consnttaats fvr Seabb~ ~~ ~ and the City of HighPoiut
BAs you know, "
have recently p~azed a "Hu-~aan F~e~altb. and Ecological Rusk Assessmem and
far re~led'~~ of tha ~ co~ce¢ of umlamrslarlo~l
a "Feasibility S`tudy' point Landfill sate. These do~m~ and
at dle Scaboazd Clam:~~ valuations ate cnrently uadex review by the
assoctabed y-avgartsng data awl e~ ~ ub~~.c. The report provides detailed
Division of Wsste Ddanag~~ P on ax the site and
iaferanation nn the nature ~ exert o` the C°n
ap~tpares tha relative e,veness of sevet2d. ~edaation techoaoiogfes that
have potential ~lication to address stare ~1 ~n-o~mclwatC'r pc~lluttmt
eoneeatratim~s . at the site.
~ respotlse to a question oa the acceptnbility of the docameuts, tincr~. the .
tevi~+a arc rosnpiCta and agency anti pt~lic CO~~~ are available, I can not
conclude that the ~sne~ats w"~ be appt'oved as they IIO~ exss~ $owovez', l
can State that they do pxo'Vide altexnativea that cam aehicve our goals foa
~ ~ anent waters of the Deep
pxotection of the enviranmeat at the site ~} d ~~ficant
River or the Randleman Reservs~ir, if it is wa~'~~- i~
Z~edr2xiOD. ~Fler~.C with 5ttperfuad z~ RCR A Sttbtrtles C. D, sod I, the
AWM is confident tha± the proposea alteznati~ es reflect sound texhnicaL~ad
scientific mexit Based on infornatioaz available m ns, wz rcmahl. coafid~
that it is Lac>~~Y £easi~ie ~d ecouonticaZly viable to achieve a drastic
~ ~ufia~ leav~g the site and accor'di-u~' ~~ the
redtirtinr ~ atL~ DQ ~riol~l+~*+-a a€ vw.ttQt qu~l ~ ~' ~
potpttl'iAi Q~ DS?11uli3ilL: tivm tl$S Elie cauai+-~ fsuy bss a ~uv
ule lake. F ~utiteruao~, a3 X have i~~"+'~ ~ tip P~ ~ u ~~ ~
soy oRe+v =~ QoAa, SulTS t sq tiv-aar•, N~ 2y~o5
PN~t 9i 9-73s.aY0~ ~A% ai ~7ti S.I~S
AM COWL prvoAT.iKI:Y f AFF+RFIAn~ Aczsw~ 6Kn,pvln - So'!ri R7[c'+'~a/t01i fp~rc°rsvwCR ~/~ix
r+-
~~

Department of Environment
and Natural Resources
' Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Tohn K1me
Piedmont Triad Water Authority
Wilmington Bld;
Suite 1217
2216 West Meadowview Road
Greensboro, NC 27407-3480
Dear Mr. Kime:
`••
NORTi-t C.IROLINA DEr~-ARTME.'JT OF
ENVIRONMENT AND NATURAL RESCURC~
Re: Certification Pursuant to Section 401 of the Federal Clean Water Act.
Proposed Randleman Reservoir
WQC Project n 970722 COE 199102669
Guilford and Randolph Counties
Attached hereto is a copy of Certification No. 3221 issued to the Piedmont Triad Regional
Water Authority.
If we can be of further assistance, do not hesitate to contact us.
Sincerely,
A. Preston Howard, Jr. P.E.
Attachments
°~ 970722.wgc
cc: Wilmington District Corps of Engineers
Corps of Engineers Raleigh Field Office
Winston-Salem DWQ Regional Office
Mr. John Dorney
Mr. John Parker, Division of Coastal Management
Central Files
Terry McCtain; EcoScience, Inc.
Alan Horton; Deep River Citizens' Coalition
Kathy Matthews, US EPA
Boyd DeVane
Coleen Sullins
Dennis Ramsey
Division of Water Cluality • Environmental 5c;ences Branch
Enviro. Sciences Branch, 4401 Reedy Creek Rd., Raleigh, NC 27607 Telephone 919-i33-1786 FAX # [phone]
An Equal opportunity Affirmative Action Employer • 50% recycied/10°'° post consumer paper

NORTH CAROLINA 401 WATER QUALITY CERTIFICATION
THIS 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 Water Quality (DWQ) Regulations in 15A NCAC 2H, Section .0500. It is issued to Piedmont
Triad Regional Water Authority resulting in 121 acres of wetland impact in Guilford and
Randolph Counties pursuant to an application filed July 10, 1997 to construct the proposed
Randleman reservoir.
The application along with other environmental protection provisions outlined in this
document provides adequate assurance that the discharge of fill material into the waters of Deep
River and the proposed development will not result in a violation of applicable Mater Quality
Standazds and discharge guidelines. Tnerefore, the State of Nonh Carolina certifies that this
activity will not violate the applicable portions of Sections 301, 302, 303, 306, 307 of PL 92-500
and PL 95-2I7 if conducted in accordance with the application and conditions hereinafter set
forth.
This approval is only valid for the purpose and design that you submitted in your
application, as described in the Public Notice. If you change your project, you must nodry us
and send us a new application for a ne :v certiricaaon. If the property is sold, the new owner must
be given a copy of the Certification and approval lever and is thereby responsible for complying
with all conditions. For this approval to be valid, you must follow the conditions listed below. In
addition, you must get any other federal, state or local permits before you go ahead with your
project including (but not limited to chose required by) Sediment and Erosion control, Non-
discharge and Water Supply watershed regulations.
Condition(s) of Certification:
1. Appropriate sediment and erosion control practices which equal or exceed those
outlined in the most recent version of two manuals. Either the 'Ttorth Carolina
Sediment and Erosion Control Planning and Design Manual" or the "North Carolina
Surface Mining Manual" (available from the Division of Land Resources in the DENR
Regional or Central Offices). The control practices shall be utilized to prevent
exceedances of the appropriate turbidity water quality standard (50 NTUs in all fresh
water streams and rivers not designated as trout waters; 25 NTUs in all lakes and
reservoirs, and till saltwater classes; and 10 NTUs in trout waters);
2. All sediment and erosion control measures placed in wetlands or waters shall be
removed and the natural grade restored after the Division of Land Resources or
delegated local agency has released the project;
3. Should waste or borrow sites be located in wetlands or streams, compensatory
mitigation will be required since it is a direct impact from road construction activities;
4. If any changes are made to 15A NCAC 2B. 0248, .0249, .0250 and .0251 adopted by
the Environmental Management Committee on November 12, 1998, that aze not equal
or more protective than these rules, then this Certification is voided and new 401
Certification with public notice is required.
5. Compensatory mitigation shall be done to assure a I: l ratio of restoration or creation of
riparian wetlands in the watershed of the proposed reservoir. Sites should include those

discussed in DWQ's September 25, 1998 letter to the Authority. DWQ shall be copied
on a detailed mitigation and monitoring plan as well as the approved ratio, location, size
and method of mitigation (restoration, enhancement, creation, and preservation) within
90 days after the permit is issued and annual reports for the entire length of the
monitoring period. The final mitigation plan shall be sent to DWQ within three months
of issuance of the 404 Permit. Mitigation shall begin in conjunction with land clearing
for the reservoir.
Violations of any condition herein set forth shall result in revocation of this Certification
and may result in criminal and/or civil penalties. This Certification shall become null and void
unless the above conditions are made conditions of the Federal Permit. Tnis Cenification shall
expire upon expiration of the 404 permit.
If this Certification is unacceptable to you, you have the right to an adjudicatory hearing
upon written request within sixty (60) days following your receipt of this Certification. This
request must be in the form of a written petition cor_forming to Chapter 1~OB of the North
Carolina General Statutes and filed with the Office of Administrative Hearings, P.O. Box 27=!=-'-7,
Raleigh, N.C. 27611-7447. If modifications are made to an original Certification, you have the
right to an adjudicatory hearing on the modifications upon written request within sixty (60) days
following receipt of the Certification. Unless such demands are made, this Certification shall be
final and binding.
DIVISION OF WATER QUALITY
A. Preston Howard, Jr. P.E.
WQC n 970772

State oflNorth Carolina
'Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
1 ~ •
NORTH CAROLINA DEPARTMENT CF
ENVIRONMENT AND NATURAL RESOURCES
September 25, 1998
Andrea M. Spangler
Environmental and Special Projects Manager
Piedmont Triad Regional Water Authority
Wilmington Building, Suite 207
2216 West l~ieadowview Road
Greensboro, NC 27407-3480
Dr. Gerald I~IeCrain
EcoScience Corporation
612 Wade Avenue
Raleigh, NC 27604
Re: Randleman Lake Compensatory Mitigation Proposal
Dear Ms. Spangler and Dr. McCrain:
Pete Colwell and I have reviewed the July 1998 Preliminary Wetland Assessment
prepared by EcoScience for the wetland mitigation for the Randleman Lake project. The
proposal identifies 10 potential wetland mitigation sites, which are projected to yield 122
acres of wetland restoration, or creation, which will satisfy the 1:1 wetland mitigation
requirement for the project. At six of the sites a total of 69 acres of wetlands are
proposed to be restored or created by the use of in-stream structures to put water back
onto existing floodplains. The remaining 4 sites will create wetlands through "green tree
impoundments" along the associated stream.
As stated in our July 20, 1198 correspondence, the Division feels that the
proposed wetland mitigation sites are worthy of further examination. We also realize
that the Authority may acquire property through the power of eminent domain. However
this process may take a considerable amount of time. Prior to the issuance of the 401
WQC the Division will need to have a time frame for acquiring the proposed mitigation
properties. The items listed below from our July 201etter should be addressed in the
detailed mitigation plan, which should be submitted for written approval prior to any
construction activities in wetlands.
Environmental Sciences Branch 4.01 Reedy Creek Road Raleigh. North Carolina ?7607
Telephone [phone] FAX # [phone]
An Equal Opportunity Affirtn~tive Action Employer 50% recycled/10% post consumer paper

1) Minimal release of water with the instream structures to maintain existing
uses in the streambed.
2) Design criteria that might allow for fish migration in the larger streams.
3) Maintenance and management of the water control structures, particularly
with the green tree impoundments.
4) Possible use of "forebays" to collect sediments and protect the wetland
mitigation sites downstream.
5) Planting schemes for each mitigation site.
6) Monitoring plan with success criteria.
We still encourage the Authority to identify some additional potential mitigation
sites should any of those proposed fail to produce the wetland acres estimated or are
simply not available for mitigation. It is our understanding the Environmental
Management Commission will review the Watershed Management Plan for the proposed
reservoir at their November meeting. We will consider the issuance of the 401 WQC
after the Management Plan is approved by the EMC. Should you have any questions or
wish to discuss additional mitigation sites please contact Pete Colwell or myself at 919-
733-1786.
S'ncerel
~' ~ ~
Jo R Dorney
W Hands / 401 Grou
cc: Ed Powell, DMP
Ron Linville, DWQ Winston-Salem Regional Office
David Franklin, US Army Corps of Engineers
Pete Colwell, DWQ Central Office

wetlands job
Subject: wetlands job
Date: Mon, 17 May 1999 15:58:22 GMT
From: "Liz Thomson" <thomson [e-mail]>
To: [e-mail]
Hi John - I am writing in regards the DWQ wetlands compliance position which
I interviewed for a couple of weeks ago. I don't know if my name was
forwarded as a candidate, but I wanted to let you know that I have since
accepted a position in the water quality program at Research Triangle
Institute. Thank you very much for taking the time to chat with me, I
enjoyed meeting both you and Erik and I'm sure we'll run into each other in
the future!
Thanks,
Liz Thomson
Get Free Email and Do More On The Web. Visit http://www.msn.com
i of 1 5/17/99 12:52 PM

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Hansel], R-Cabamts, have been appointed Co-
chairmen of the legislature's study on Property Is-
sues. The legislators will investigate takings, an-
nexation,and condemnation.
Three years in the making Durham County's
?0?0 Comprehensive Plan calls for 20% of new
housing and 45% of new jobs to be located in more
compact, transit-oriented deve]opments.
Sen. J.K. Sheron, D-Wake, will speak at the
January 13 meeting of Friends of State Parks at
Glen Eden Park in Raleigh at 11 am on Duraleigh
Road, Umstead Park and other issues.
N.C. Chapter of the American Planning As-
sociation has scheduled meetings to discuss tak-
ings legislation and other planning issues for 2/1 in
New Bern, 2/14 in Asheboro at the Zoo and 2J21 in
Morganton. Contact NCAPA Legislative Chairman
Tim Gauss at 910-727-2087 for details.
N.C. Wildlife Federation's annual meeting
and conservation awards banquet is February 16-17
at the Mamott Hotel in Research Triangle Park.
Discussions on the changing coast, piedmont and
mountains will be featured. Contact NCWF at 919-
833-1923 for details.
N.C. Coastal Federation and others are spon-
soring aHog Summit at the Sheraton Hotel in
New Bem on February 29-March 1. Sierra Club
may sponsor a forum for candidates for U.S. Sen-
ate the evening of February 29. Contact NCCF at
919-393-8185 or [e-mail] for details.
Defenders of Wildlife placed North Carolina
in its third-highest rank in a study of states facing
the greatest risks of losing unique natural areas.
Rapid, uncontrolled development, pollution and
logging threaten N.C.'s long leaf pine forests and
savannas, mountain spruce-fir forests, remaining
pockets of old growth forests, rivers and coastal
area ecosystems.
Transit 2001 forum
Governor Hunt's Transit 2001 Commission
will hold a forum on January 17, 1996 from 10-
430 at the Friday Center in Chapel Hill. Andres
Duany will speak on land use and transportation.
Urban transportation, high-speed rail, human ser-
vices transportation and rural transit will be dis-
cussed. Registration is S30. Contact Pam Cloer at
ITRE at 919-878-8080 or [e-mail]
for details.
Congressional votes
The national League of Conservation Voters
is distributing congressional votes on environmen-
tal legislation electronically. To subscribe to lcv-
update e-mail to: [e-mail] with "sub-
scribe" in the subject. Provide yotu name, e-mail
address. Information about whether you are an
LCV member, your organization, snail mail ad-
dress, phone, voter registration, and congressional
district is appre~;iated.
Carolina Conservationist (925760) is published monthly
by the Conservation Council of North Carolina, P.O. Box
61854, Durham 1C 27715. Subscription price is S20 per
year which includes membership in CC\C. Second Class
postage paid at Durham SC 27715.
POST'.17ASTER: Send address changes to Carolina
Conservationist, P.O. Boz 61854, Durham \C 27715.
CCNC Office: Renee Price, Director
P.O. Box 61854
~ Durham NC 27715-1854
(919)644997
President: John Runkle
ii P.O. Box 3793
Chapel Hill \C 27515
Newsletter Editor: Jo Ellen Perry
5529 Earle Rd.
Raleigh \C 27606
Carolina Consen ationist 2nd Class Postage Paid at
P.O. Box 61354 Durham NC 27715
Dtuham NC 27715
1196 Carolina Conservationist
Volume 24 Number 294 (published monthly)
LISPS No. 925760
January 1996 Carolina Conseruationist Volume 24 Number294
Faircloth moves to gut clean air act
N.C. Senator Lauch Faircloth, author of a
1995 bill that would define mast wetlands out of
existence, has taken aim at the Clean Air Act
Amendments of 1990.
At the request of industry lobbyists Sen. Fair-
cloth has proposed gutting key provisions of the
law. His draft bill would make Title V air pollution
permits with consistent nationwide provisions far
monitorine: public review and comment optional,
would allow industries to substantially increase
their pollution without having to amend their per-
mits, limit EPA's ability to enforce the Clean Air
Act and would remove incentives for EPA to de-
velop maximum available control technology
(b1ACT) to reduce toxic air pollutants. CCNC op-
poses the bill.
The Clean Air Act Amendments of 1990
were recommended by President George Bush and
passed with strong bipartisan support. Environmen-
talists struggled for thirteen years to strengthen the
law.
What Faircloth ought to be doing
CCNC believes that Sen. Faircloth should
start listening to his North Carolina constituents in-
stead of his cash constituents. He'd find that the
State of North Carolina is doing a good job imple-
mentinQTitle Vpermitting provisions of the Clean
Air Act.
Sen. Faircloth would also find support for
strengthening the Clean Air Act: I) to reduce ozone
and haze pollution that hide our beautiful 5outhem
Appalachian mountains and threaten the health of
mountain forests, 2) to establish a national odor
standard to protect the health and property of the
neighbors of factory hog operations, 3) to develop
more effective strategies to reduce ozone pollution
in urban areas, and 4) to reduce deposition of nitro-
gen from power plants and vehicles into N.C.'s al-
readystressed estuaries.
Important EMC votes in February
The Environmental Management Commis-
sion will probably vote on an interim Neuse River
clean up plan and compromise wetland regulations
at its February 8 meeting. CCNC is pushing for a
river clean up plan that goes beyond the voluntary
measures presented to the FMC's Water Quality
Committee in December.
CCNC supports requiring farmers to follow
best management practices, regulating industrial
hog and poultry industries as other industries, a
vegetated buffer along streams, rivers, lakes and es-
tuaries, stormwater controls for new development,
and a declining cap on nitrogen from wastewater
treatment plants.
CCNC is disappointed that the proposed wet-
land rules are waaker than the rules considered dur-

,titl ~ ~ l
ing public heari s early in 1995 and will allow
many Piedmont wetlands to be destroyed without
avoidance, minimization or mitigation. Most Pied-
montwetlands are less than an acre in size.
CCNC has asked Rep. John Nichols, R-
Craven, and Sen. Fountain Odom, D-Mecklenburg,
for an opportunity to speak to the legislature's En-
vironmental Review Commission on February 15
to make recommendations to the 1996 General As-
sembly on cleaning up the Neuse and other rivers.
EPAT
CCNC worked for ten years to reorganize and
consolidate environmental programs into one de-
partment. The 1989 General Assembly created the
Department of Environment, Health and Natural
Resotrces that included all major environmental
programs except for regulation of pesticides.
The Environmental Programs Action Team
(EPAT} has completed its report on options to reor-
ganize and consolidate agencies and functions of
the Department of Environment, Health and Natu-
ral Resources.
The report focused on seven areas: 1) frag-
mentation and overlap of water supply and waste-
water treatment programs, 2) management of many
non-point source water quality programs, 3) central
versus regional administration of programs, 4)
should DEHNR's many technical assistance be
consolidated. S) regulation of mixed hazardous and
radioactive waste, 6) creation of a separate Divi-
sion ofAir Quality (7S0 people now work on water
and air quality issues at Division of Environmental
Management), and 7} various non-structural recom-
mendations.
The Department may recommend reorganiza-
tlon and consolidation to the 1996 or 1997 General
Assembly. Contact Lisa Zywicki at 919-733-4984
for a copy.
Hunt speaks on sustainable
forestry and clean water
At the December sustainable forestry confer-
ence Governor Jim Hunt endorsed two kev recom-
mendations of the sustainable forestry task force's
report that are supported by conservationists. Hunt
called for expanding and broadening the member-
ship of the forest policy council and for limiting
~~
state forestry incentives to landowners who prac-
ticesustainable forestry.
Hunt also called for using vegetated buffers
along rivers and streams and restoring and enhanc-
ingwetlands to cl Neuse and other coast-
al rivels:~
l~andieman dam update
The U.S y Corps of Engineers has again
asked redmont Triad Water Authority if the
sed Randleman Dam project is too large. The
Corps points out that a smaller project would cost
less and reduce environmental and socioeconomic
impacts.
The Deep River Citizens Coalition and Wa-
tershed Protection Alliance withdrew their adminis-
trative appeal of the EMC's approval of the Ran-
dleman Dam project in December. Gary Kenton of
the Watershed Protection Alliance said that envi-
ronmentalists may challenge the 404 wetlands per-
mit if the Corps issues one for the project
Injunctions of the month
Attorney General Mike Easley continues his
aggressive enforcement of state environmental
laws. At the request of the attomey general judge
in Greene County shut down J&H Milling Compa-
ny's hog operation. A judge in Henderson County
ordered Sexton Dairy Farms to close until the state
approves a waste management plan.
Also in December the attomey general went
to court to shut down Bailey & Associates, Inc. of
Jacksonville and two wastewater utilities that it op-
erates. The utilities have violated their wastewater
discharge permits more than 450 times since 1993
and have failed to pay thousands of dollars in fines.
Environmental permitting
DEILNR's Permit Process Action Team
(PPAT) has made 20 recommendations to improve
environmental permitting in N.C. The recommen-
dations include: training permit applicants, training
DEI-LNR staff, standardizing applications and pro-
cesses,establishing apermitinformation center, in-
tegrating and coordinating programs, reducing indi-
vidual permit decisions with general permits,
permit-by-rule and exemptions, decentralizing per-
mitting, clarifying liability, improving information
management and standardizing outcome measures.
Contact DEHNR General Counsel Richard Whis-
nant at 919-733-4984 for a copy.
r~., Takings moves to Senate floor
The U.S. Senate Judiciary Committee ap-
proved Sen. Bob Dole's, R-KS, S. 605 takings bill
10-7 on December 21. Sen. Dole's bill is more ex-
Creme and far-rearhing than tha ta~S bill passed
by the House in 199. The U.S. Office of Manage-
; merit and Budget estimates that the House bill
' would cost taxpayers $28 billion over a seven year
\, period. Sen. Dole is pushing for a Senate vote on
takings in 1996. Voters in Washington state defeat-
- ed takings legislation 60% to 40% in November.
Repeal logging without laws
Rep. Elizabeth Furse, D-Oregon, has intro-
duced H.R. 2745 to repeal N.C. Rep. Charles `"Tim-
ber" Taylor's logging without laws rider that was
attached to the recissions budget bill earlier this
year. Rep. Taylor's provision exempts sales of so-
called salvage and associated timber from environ-
mental, public and judicial review.
Tank fees may increase
The Division of Environmental Management
reported to the legislature's Environmental Review
Commission in December that it was paying under-
ground petroleum storage tank claims out of the
underground tank insurance fund much quicker
than it was receiving tank fees and gasoline tax rev-
enues. Although DEM is shutting down clean ups
at sites that it claims don't threaten public health,
the 1996 General Assembly will probably have to
increase the fees that tank owners pay to maintain
the solvency of the fund.
Tree cut in front of billboard
A 2S foot tall weeping willow at the Shallotte
Congregation of Jehovah's Witnesses on U.S. 17
was illegally cut down in front of an Outdoor East
billboard in October. Trees are illegally cut down
in front of billboards about SO times per year.
Brunswick County may adopt new rules to require
billboards to be shorter, smaller and 3000 feet apart
on U.S. highways.
The Few, the proud,
the Marines and the Woodpeckers
U.S. Secretary of the Interior Bmce Babbitt
and the U.S. Marine Corps unveiled a poster of
Marines training at alongside red cockaded wood-
peckers at Camp Lejeune in December. The red
cockaded woodpecker is an endangered species.
Forty two pair of birds live at Camp Lejeune.
Quote of the month
"It could be as little as 10 days for public
comment. We're not required to have a public com-
mentperiod, so we're not obligated to give people
time," according to Dr. Emie Carl, Co-chairman of
the "blue ribbon" animal waste study commission
The study's preliminary recommendations will per-
haps be released in April shortly before the legisla-
ture convenes for its short session on May 13.
DEM wetlands workshops
The Division of Environmental Management
is holding "strategic planning work groups for wet-
lands protection in N.C." in January. The work
groups will be ljll at Asheville DEHNR office, 1/
17 at Washington DEHNR office,1J19 at Wilming-
ton DEHNR office, 1/22 at the Archdale Building
in Raleigh and 1J23 at Mooresville DEHNR office.
The sessions are from 8:30 am - 5:00 PM. Contact
Lisa Everett at 919-733-1786 for details and an in-
formation packet. The packet is useful for land-
owners and conservationists even if they can't at-
tend the work groups.
Announcements
Peter and Ginny Nicholas have given $?0
million to Duke University's School of [he Envi-
ronment.
Protection and acquisition of wetlands by
public and private agencies, the conservation provi-
sions of the Farm Bill and wetter weather have in-
creased the population of ducks in the Atlantic
Flvway by over 10% since 1994.
Cherish the Earth, a em~ironmental educa-
tion organization focusing its efforts on home
teachers is seeking facilitators across N.C. Contact
Helen O'Brien at [phone] far mare details.
Rep. Sam Ellis, R-Wake, and Sen. Fletcher

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Co~s~~
Water Quality and Predictive Modeling
Studies on the Proposed Randleman Reservoir,
High Point, North Carolina
Review by
Patrick L. Brezonik
Department of Civil Engineering
University of Minnesota
Minneapolis, MN
for the
Piedmont Triad Regional Water Autbority
Greensboro, Norih Carolina
March 1995

Introduction
Randleman Lake is a 3230 acre proposed water-supply reservoir on the Deep River
near High Point, North Carolina. If constructed, the reservoir would supply drinking water
to several cities served by the Piedmont Triad Regional Water Authority (PTRWA). Con-
cerns have been expressed about water quality conditions in the proposed reservoir, in
particular about its trophic state and about potential contamination by organic chemicals from
a landfill and abandoned chemical plant. A variety of studies have been undertaken to
evaluate the significance of these potential problems. Questions also have been raised about
the merit and adequacy of these studies. An independent review of the studies was commis-
sioned by the PTRWA, and this report is a summary evaluation of these prior studies.
Background Information
With a contributing drainage basin of about 171 square miles, and a total storage cap-
acity of 18.3 x 109 gallons (-- 54,000 acre-ft), Randleman Lake is designed primarily to ex-
pand the public (drinking) water supply for the Piedmont Triad Regional Water Authority,
which supplies water to the cities of High Point and Greensboro and several smaller, nearby
municipalities. Typical of riverine reservoirs in the Piedmont area of the mid-Atlantic states,
Randleman Lake would have an irregular, dendritic, and elongated shape. The length of the
reservoir along the Deep River stem would be approximately eight miles before entering the
main pool formed by Randleman Dam. A smaller, shorter stem from Muddy Creek would
join the main pool just to the west of the Deep River stem. The water supply intake would
be located near the downstream end of the reservoir in the Muddy Creek stem and off the
main channel of the Deep River.
Concerns have been expressed about water quality conditions in the proposed reser-
voir, and a series of studies have been undertaken since 1988 to address these concerns and
predict conditions that would occur in the reservoir if it were built. Principal concerns focus
on trophic state conditions and the potential occurrence of toxic organic compounds in the
raw water supply. The former concerns arise from the fact that sewage effluent from the
High Point wastewater treatment plant (WWTP) would enter the Deep River at approximately
the upper limit of the reservoir's Deep River stem. In addition, the large drainage area in-
cludes both urbanized areas and agricultural (row crop) lands, both of which have the poten-
tial for relatively high rates of nutrient export in stormwater runoff. The latter concerns arise
from the fact that the High Point municipal landfill and an abandoned chemical processing
plant are located adjacent to the Deep River in the vicinity of the High Point WWTP, i.e. in
the upper reach of the Deep River stem of the reservoir. The chemical plant, in particular, is
known to have caused local contamination of groundwater with a variety of organic solvents,
mostly chlorinated, low-molecular weight compounds such as methylene chloride and tri-
chloroethane, which have low drinking water standards exist because of their potential
toxicity to humans.
An environmental impact statement (EIS) was prepared for Randleman Lake in 1990
as part of the permitting process for the dam and reservoir. As part of the EIS, the engineer-
1

ing consulting firm Black & Veatch prepared a report on water quality and quantity studies
(Black & Veatch, 1990), and an assessment of alternatives for water supply for the region
also was prepared by this firm for the PTRWA (Black & Veatch, 1991). Additional ques-
tions were raised about the potential impacts of contaminated groundwater from the landfill
and abandoned chemical plant after the EIS was completed, and subsequent studies were
undertaken (environmental Investigations, 1992; Geraghty and Miller, 1993) to evaluate the
magnitude of contamination at the chemical plant/landfill site and the potential export of
organic contaminants from the site to the river. Subsequent to these studies, Black & Veatch
(1994) conducted additional modeling studies to determine the potential risk to the reservoir
posed by this contamination, and they updated their estimates of concentrations of organic
contaminants that could occur in the reservoir as a result of the movement of contaminated
groundwater. The North Carolina Division of Environmental Management has conducted
monitoring studies since the early 1980s on the Deep River in the region of proposed Randle-
man Lake and in downstream areas that potentially would be affected by the lake. A series
of data summary reports have been prepared (NCDEM, 1988, 1994ab).
The present analysis and evaluation of past studies related to Randleman Lake was
conducted by the author over the period November 1994 -March 1995. Documents re-
viewed for this report are described in the preceding paragraph and listed in Appendix 1.
The analysis and evaluation was conducted by careful reading of the above-mentioned reports
and review of their contents with regard to three issues:
(i) completeness: have the various studies addressed the significant questions in a
sufficiently comprehensive manner so that all important water quality issues have been
addressed and adequately answered?
(ii) adequacy of methodology: are the methods used essentially "state-of-the-art", or
were obsolete or out-of-date procedures used?
(iii) technical accuracy: regardless of the level of sophistication of the methods, was
the work performed using those methods done in a technically competent manner?
To clarify a few issues that arose from a review of the written documents, I also had
phone conversations with Beth Quindlan, the staff engineer from Black & Veatch, who was
responsible for the reports prepared by that firm. However, no independent modeling or cal-
culations were done as a part of this review, and I did not address potential issues regarding
the proposed reservoir that are not covered in the reports available for this review. The con-
clusions made below thus apply to the adequacy and sufficiency of studies conducted to eval-
uate the likely water quality of the proposed reservoir. No inferences are intended regarding
socio-economic factors or political issues, on which a decision to proceed with dam construc-
tion also may depend.
The review is divided into two main sections, each covering one of the principal water
quality issues that was studied: trophic conditions and organic contaminants.
Trophic State Analysis
Studies related to the prediction of water quality conditions in the proposed Randleman
2

Lake as a result of nutrient loading and trophic state conditions are covered mainly in the
document prepared by Black and Veatch (1990) for the Environmental Impact Statement. In
brief, studies conducted by Black & Veatch on this topic included: (i) the development of
water and nutrient loadings to the proposed lake; (ii) a detailed analysis of hydrologic condi-
tions based on a record of almost 60 years of hydrologic data that was synthesized from
existing flow and climatological records; (iii) nutrient loading-reservoir response modeling;
and (iv) an analysis of projected trophic conditions in the reservoir. The computer model
BATHTUB was used for the exercise, and for modeling purposes, the proposed lake was di-
vided into six segments. Two upstream reservoirs, High Point Lake and Oak Hollow Lake,
were included as additional (external) segments in the model. The Randleman segments
consisted of three sequential segments of the Deep River (DR 1-3), the main pool area near
Randleman Dam, and two segments of Muddy Creek (MC 1 and 2). Effluent from the High
Point wastewater treatment plant was an input to the most upstream Deep River segment (DR
1), and the intake for the proposed water treatment plant was assumed to be in MC 2.
Analysis of projected trophic conditions in the lake was done for each of the segments
fora 59-year period of synthesized flow and loading data and for two sets of land-use condi-
tions: existing values and a future situation in which 50% of the watershed was assumed to be
urbanized. Mean annual values of trophic state parameters predicted by the model include
phosphorus concentrations, chlorophyll a, and Secchi disk transparency. Algal nuisance fre-
quency also was estimated by the model from empirical relationships based on the percent of
time that chlorophyll levels exceed some set criterion.
The results of the modeling exercise indicated that trophic conditions vary consider-
ably among the reservoir segments, but only the uppermost Deep River segment (DR 1),
which receives the High Point WWTP effluent, was in a generally unacceptable category.
Total phosphorus (TP) concentrations in that segment were very high (540-1400 µg/L), and
predicted chlorophyll a levels were 85-95 µg/L, leading to nuisance conditions about 85-90~
of the time. Conditions in the next downstream segment (DR 2) were predicted to be much
better (TP of 240-300 µg/L; chlorophyll levels of 31-34 µg/L).
It is likely that the conditions predicted for segment DR 1 are worse than actually will
occur because of an artifact of the modeling procedure. In reality, Randleman Lake will not
behave as a system consisting of six separate segments, each of which is assumed to behave
in the model as a homogeneous reactor (continuous-flow, stirred tank reactor or CFSTR).
Instead, it will exhibit flow conditions intermediate between riverine plug flow and the
CFSTRs-in-series scenario implicit in BATHTUB. As modeled by Black & Veatch, segment
DR 1 had a relatively small distance along the river and a small total water volume. ~ Conse-
quently, input of all the High Point WWTP effluent into this .segment resulted in quite high
concentrations of phosphorus. In the real system, the effluent is likely to be diluted fairly
rapidly into a larger volume of the reservoir, as a result of longitudinal dispersion processes.
Of course, this implies that the model predicts better water quality conditions (i.e. lower TP
levels) for the downstream segments, especially DR 2 and perhaps to some extent DR 3,
than are likely to occur. In summary, actual trophic conditions in both segments DR 1 and 2
are likely to be intermediate between the predicted values for these segments
3

In the main pool area near the dam, TP was down to 47-62 µg/L and chlorophyll a
was predicted to be 14-16 µg/L. The best conditions were predicted to occur in MC 2 (TP
of 42-42 µg/L; chlorophyll a of 12-13 µg/L; algal nuisance frequency of ---1 `~ ); this is the
segment from which water will be withdrawn for public water supply purposes.
Overall, the studies performed by Black & Veatch to predict water quality and trophic
state conditions in Randleman Lake were thorough and competently done. The analysis was
conservative, and involved state-of-the-art methods. The model used by Black & Veatch
(BATHTUB) is widely used by consulting engineering firms and state water management
agencies, and I believe it was an appropriate model to use for this analysis. It is not the most
detailed nutrient loading-trophic response model that is available, but it is adequate for the
sort of analysis needed in the present situation. For example, it does not consider internal
nutrient recycling processes and calculates trophic conditions on an annual time-step rather
than short-term (weekly or monthly values). Consequently, the model is unable to predict
infra-annual (and infra-seasonal) variations in transparency and chlorophyll levels caused by
short-term algal blooms. Models that do make such predictions are more complicated and
require much larger data bases to run. Nonetheless, even these more complicated models
generally do a poor job of simulating the short-term behavior of nutrient and algal levels in
lakes. Typically, such models provide reasonable simulations of mean values and variances
about the mean, but they do a very poor job of simulating the timing of algal blooms. In
reality, there thus was little to be gained from the use of a more complicated model.
The use of a 59-year hydrologic data base to evaluate loading-response relationships
over a range of flow and climatic conditions at least partially compensates for the inability of
BATHTUB to model short-term events. That is, the variability in trophic responses over the
59-year period of varying flows and climate may simulate the short-term behavior of the lake
and the infra-annuallintra-seasonal variability in chlorophyll levels caused by short-term varia-
tions in flow and seasonal variations in temperature.
Black and Veatch did very nice work in assembling hydrologic data for along-term
analysis of the water budget of the proposed lake. They employed well-accepted procedures
to estimate nutrient loadings from nonpoint sources based on the use of nutrient export co-
efficients, and they showed resourcefulness in assembling the information and conducting the
analyses. The work appears to have been done with attention to detail, and the product is a
reasonably comprehensive analysis of trophic conditions in the proposed lake.
Organic Contaminants
The principal source of organic contaminants to proposed Randleman Lake, at least
contaminants that could cause concerns about use of the reservoir as a drinking water supply,
appears to be leachate from an abandoned chemical plant (a solvent reprocessing facility)
located adjacent to the Riverdale Road landfill of the City of High Point. This landfill is
located just west of the current channel of the Deep River and immediately north of the High
Point wastewater treatment plant. Although early studies (cited by Black & Veatch, 1990,
4

1994) were unable to distinguish the relative importance of the landfill and the abandoned
chemical plant as sources of organic contaminants, it now appears that the landfill itself is not_;
a significant source of contamination.
Water quality studies done by Black & Veatch for the environmental impact statement
included calculations on the potential loading of organic contaminants to the reservoir from
the landfill/chemical plant site and inorganic contaminants (principally heavy metals) from the
High Point WWTP. A simple mass balance model then was used to compute monthly aver-
age concentrations of contaminants in Randleman Lake. These calculations were based on
fairly limited data then available regarding concentrations of contaminants in groundwater at
the site. To be on the conservative side, Black & Veatch used concentrations of organic
contaminants from a monitoring well near the edge of the Seaboard property and just down-
gradient from the area suspected to have the highest contamination. This well is several
hundred feet from the river; concentration data were not then available for landfill wells
located closer to the river. Black & Veatch assumed (reasonably) that these likely would
have lower contaminant levels because of dispersion and loss processes as the groundwater
travelled east (through the landfill) from the origin of contamination. Five organic solvents
were modeled: methylene chloride, 1,1,2,2-tetrachloroethane, 1,1,1-trichloroethane, 1,1,2-
trichloroethane, and toluene. Each of these compounds had been detected in several moni-
toring wells on the Seaboard property.
In general, the calculated loadings of organic contaminants were quite small and re-
sulted in predicted in-lake concentrations far below existing water quality criteria -- and thus
below the level that would pose problems for use of the reservoir's water as a drinking sup-
ply. Heavy metal loadings also were fairly low, but the model results indicated that effluent
from the WWTP would increase levels of chromium, copper, lead, nickel and zinc in the
lake. , Of these metals, only copper was slightly higher than the State of North Carolina's
Class II water quality criterion (predicted value of 9.5 µglL versus a criterion of 7 µg/L). ' ,
Because copper has low toxicity to humans, both of these values are much lower than the ;
relevant drinking water standard (the U.S. EPA's maximum contaminant level [MCLJ for
copper in drinking water is 1300 µg/L).'
The toxic substances model used by Black & Veatch (1990) to compute in-lake con-
... ~~:.:.,
centrations from estimated loadings was highly conservative, and for a'grven loading it '::
produced in-lake values far higher than would likely occur. This is because the model did
not consider any in-lake processes for loss/degradation of organic contaminants or removal of
heavy metals by sorption/precipitation and sedimentation processes. There are strong reasons
to believe that internal loss processes would be significant for both orgatic and inorganic
contaminants. Most of the organic contaminants found in groundwater at the chemical plant/
landfill site are low molecular weight solvents that have substantial volatility. Some of the
compounds also are photoreactive and can be decomposed by photolysis. Others, such as
benzene and toluene, can be degraded by microbial activity. All the organic chemicals tend
to sorb onto solids and tend to be accumulated (to varying extents) in aquatic biota.
Therefore, it is highly conservative to treat the organic compounds in question as if
5

they are unreactive in water. There is a substantial body of information in the literature to
demonstrate their reactivity in aquatic environments, and a variety of fate-and-transport
computer models are available to predict their behavior. Black & Veatch (1990) chose nat to
use these models because there is some uncertainty about the kinetic coefficients for loss
processes of various compounds and because these models added a level of complexity to the
analysis that the Black & Veatch engineers considered unnecessary. According to their
reasoning, if the concentrations of organic contaminants predicted by the conservative mass
balance model were substantially lower than relevant water quality criteria or standards for
these compounds, then "safe conditions" would have been demonstrated without the need to
invoke in-lake removal mechanisms. Results from the simple mass balance model thus could
be regarded as a "worst case" situation (assuming that the contaminant loadings themselves
were accurate). Given the low concentrations of organic contaminants calculated for the .
reservoir from the available loading information, the decision to use the simple mass balance
model appears reasonable.
However, three uncertainties in the analysis of organic contaminant levels led to more
detailed investigations of the chemical plant/landfill site. First, questions were raised con-
cerning how representative the available groundwater concentration data were for the site as a
whole. Second, the shape and rate of spreading of any contaminant plume was not defined
by data then available. Third, the cross-sectional area across which groundwater could flow
from the landfill/hazardous waste site and into the river (and thus the total flow rate from this
source area) also was poorly defined. Because chemical fluxes in such situations are the pro-
duct of concentration times the areal water flow rate (i.e. the flow past a given cross section),
quantifying both the cross-sectional area for flow of contaminated water and the concentration
of contaminants in that flow are keys to accurate flux estimates.
Black & Veatch (1990) estimated that the groundwater flow to the river from the Sea-
board/landfill site was -- 450 gallons per day (gpd), based on a contaminant plume width of
350 feet, a plume depth of 20 feet, and available information on the hydraulic conductivity
and hydraulic gradient at the site. Subsequent estimates by hydrogeologists from the North
Carolina Division of Solid Waste suggested that the flow was about 11 times higher (~ 5000
gpd). Black & Veatch took this higher flow into account in the final Environmental Impact
Statement published in 1991. They used the same contaminant concentration values as in
their 1990 report and thus found loadings and reservoir concentrations 11 times higher than
the initial estimates. However, their basic conclusions did not change: predicted contaminant
levels in the reservoir were below existing water quality standards; the maximum concentra-
tion found was 0.33 µg/L (for 1,1,1-trichloroethane).
Extensive hydrogeologic investigations at the landfill site were conducted by Environ-
mental Investigations, Inc. in 1991 and 1992 (EII, 1992). Four deep and nine shallow moni-.
toying wells were installed on landfill property to complement six pre-existing wells at the
site. Shallow and deep wells were installed as nests at four locations in order to determine
vertical gradients and evaluate contamination in the deeper part of the aquifer. Wells were
sampled on a quarterly basis for basic water chemistry, heavy metals and volatile and semi-
volatile organic compounds. Tests were done on most wells to determine hydraulic conduc-
6

tivity, and well levels were measured quarterly to determine hydraulic gradients in the landfill
area. Finally, surface waters were sampled at seven locations on the site, and three leachate
collection tanks were sampled.
Results generally indicated that highest concentrations of total volatile organic carbon
[TVOC] (up to 600 ppm) occurred at a well adjacent to the eastern boundary of the Seaboard
chemical plant property; TVOC values at all other wells were one to four orders of magni-
tude lower. These results supported the conclusion that the source of volatile organic corn-
pounds in groundwater at the landfill originates from a site up-gradient of the landfill (i.e. the
abandoned Seaboard chemical plant). Although the number of wells installed at the site was
not sufficient to delineate the TVOC contaminant plume exactly, contour maps developed by
EII showed that the plume was much smaller in the shallow groundwater than in deeper
groundwater. At both depths the plume was limited primarily to "area A" of the landfill.
Area A is a relatively small zone in the middle of the landfill site, through which a small
stream flows. It should be noted that the interpolation method used by EII to draw the con-
tour maps from the well data was not given. Finally, quarterly monitoring of the Deep River
above and below the landfill showed no indication of VOCs in any of the up-gradient
samples, but the last quarterly sample collected from the river before it leaves the landfill
property contained chlorobenzene at 6µg/L.
Highly detailed investigations of groundwater and soils at the Seaboard chemical plant
site were conducted by the consulting hydrogeology firm Geraghty and Miller as a remedial
site inspection (RSI) in 1992 and 1993 (Geraghty and Miller, 1993). Numerous soil borings
were made throughout the chemical plant site, and water quality samples were obtained from
approximately 30 wells: A thorough review of other studies conducted at the site and the
neighboring landfill was presented in the Geraghty and Miller report. In particular, compar-
isons were made between the nature and levels of organic contaminants found by EII (1992)
at the landfill and contaminant data from the RSI for monitoring wells on the Seaboard
property. The general goal of this comparison was to determine whether VOCs found in
wells and surface waters at the landfill could be attributed to sources within the landfill itself
rather than to movement of contaminants from the Seaboard site.
In general, 1 did not find the arguments of Geraghty and Miller regarding the origin
of contaminants at sites off the Seaboard property very convincing. This is not to say that
the Seaboard plant is the sole source of all VOCs found in ground and surface waters of this
area. However, both the hydrogeology of the area and the transport transformation processes
of VOCs found in these studies are highly complicated. Moreover, the frequency of sample
collection in the investigations was low, and inferences concerning the provenance of organic
compounds in any single water sample must be taken with some skepticism. Nonetheless, it
is apparent that a large effort was expznded by Geraghty and Miller to characterize soil and
water contamination at the Seaboard site. Much of the work reported in the RSI is not di-
rectly relevant to the question of organic contamination of Randleman Lake, however, be-
cause wells located closer to the river (and down-gradient from the property) were not
sampled. The results of the RSI are more pertinent to issues of the need for and liability for
clean-up at the Seaboard site.
7

Finally, Black & Veatch (1994) reviewed and explained their earlier work for the
draft and final EIS reports and discussed relevant findings from the subsequent site investiga-
tions by EII and Geraghty and Miller. They presented specific details regarding the assump-
tions aild parameter values they used for contaminant modeling work in the draft and final
EIS reports. Based on the more recent data on contaminant levels in groundwater and the
more extensive information available in the hydrogeology of the chemical plant/landfill site,
Black & Veatch updated their Randleman Lake toxics model and presented predictions of
average and maximum concentrations of 12 organic contaminants in the reservoir. They used
contaminant concentrations measured in a well (W3) located at a landfill site close to the
Deep River and in the middle of the contaminant plume modeled by EII. Based on the EII
hydrogeological studies they divided the groundwater plume into an upper aquifer (20 ft
thick) and a lower aquifer 100 ft thick. Flows from the landfill into the river were calculated
by Darcy's law using hydraulic conductivity and hydraulic gradient information from the EII
study. This modeling exercise yielded contaminant concentrations that are many orders of
magnitude below relevant drinking water standards. The maximum concentration predicted
for any chemical is 0.01 µg/L for chlorobenzene; the next highest is 0.006 µg/L for 1,1,1-
tricbloroethane. In contrast the MCL for chlorobenzene is 100 µg/L, and the MCL for
1,1,1-trichloroethane is 200 µg/L.
How conservative are these estimates and how reliable are the predicted values? In
my opinion, for the assumed contaminant concentrations in the groundwater plume, the pre-
dicted values are highly conservative for two reasons. First, the model assumed no reaction
or loss of the organic contaminants within the reservoir except by outflow of water at the
dam or water intake. All of the modeled contaminants (indeed, all the contaminants found in
groundwater at the chemical plant or landfill) are reactive. The chlorinated alkanes (e.g
chloroethanes) are quite volatile and most are biodegradable. The chlorobenzenes are bio-
degradable, and some are photoreactive. Sorption onto suspended solids and subsequent sedi-
mentation would be a significant sink for most of the compounds. Precise estimates of loss
rates would differ among the contaminants and also vary with environmental conditions, but
loss rates of 909b or more are likely for typical conditions'in the reservoir.
Second, a large cross-sectional area was used by Black & Veatch to calculate water
flow from the plume area. of the landfill into the river. In my opinion, the actual cross-
sectional area that contributes groundwater flow into the river at this location is likely to be
smaller. Black & Veatch assumed that the total depth of the contributing aquifer is 120 feet.
The top 20 ft represents a "shallow" aquifer in soil, and the lower 100 ft is a granitic bedrock
aquifer. Detailed flow net analyses are not available for the area, but it seems unlikely to ~
this reviewer that water as deep as 100 ft below the bedrock surface would flow upward into
the river. Moreover, the vertical gradient in head is downward at wells near the river,
implying that this area is acting as a groundwater recharge zone rather than a groundwater
discharge zone. ;More detailed hydrogeological investigations and models would be needed to
accurately define the zone that flows into the river, but as a minimum it is reasonable to con-
clude that the depth selected by Black & Veatch is conservative (erring on the high side).
The contaminant concentrations used by Black & Veatch in their 1994 analysis are the
8

more reliable than the data available to them for their earlier analyses. The 1994 concen-
trations are from a well (W3) located close to the river and approximately in the middle of
the contaminant plume found in the EII study. In contrast, values used in the earlier work
were from wells much closer to the source of contamination (and much farther from the
river). Well 3 should provide a reasonable picture of the quality of groundwater flowing into
the river under current conditions.
The question may be asked: will the contaminant plume migrate intact down-gradient
so that the high concentrations now found near well 7 (on the eastern boundary of the Sea-
board property and the landfill) eventually move toward well 3, or do present conditions
represent essentially asteady-state? This question cannot be answered definitively from the
existing data and modeling studies, but there are reasons to conclude that the former situation
is unlikely. Contamination at the Seaboard site is not a very recent happening. Nonetheless,
high concentrations of VOCs are restricted to a small area under the property and near the
landfill/plant boundary. Based on the hydraulic conductivity and hydraulic gradient values
reported by Black & Veatch for the landfill, groundwater at the site moves on the order of
several tens of feet per year. Over the decade or more of contamination at the plant, the
plume should have moved down-gradient a substantial fraction of the distance toward the
river. That is has moved only slightly over this period suggests that substantial redardation
factors are involved. There is good reason to believe that this pattern will continue for the
indefinite future. Contaminant concentrations at well 3 thus will remain relatively low be-
cause dispersion is a significant component of the flow pattern. -Small amounts of contam-
inated water from the area of well 7 thus are mixed with large amounts of water that is low
in organic contaminants as it moves down-gradient toward well 3 and the river.
Conclusions
In my professional opinion, the conclusion that water quality in the reservoir will be
suitable for its primary intended purpose (raw water supply for municipalities) relative to
trophic state conditions is justified by the analysis. It is clear that trophic conditions and re-
lated water quality parameters will vary considerably from the top of the reservoir to the
main pool and the location of the intake pipe of the Piedmont Triad Regional Water Author-
ity. High nutrient concentrations can be expected in the upper reaches of the reservoir right
at the entry point of wastewater effluent from the High Point municipal wastewater treatment
plant, but dilution and in-reservoir settling processes will result in acceptable water quality in
most of the reservoir. From the perspective of trophic state-water quality issues, I do not ,~
believe that any additional studies are needed in order to make a decision to proceed with
construction of the reservoir.
Overall, the work done to analyze potential impacts of contaminated groundwater
from the High Point landfill and neighboring Seaboard hazardous waste site is based on sound
science and accepted engineering practice. The studies represent a thorough and competent
analysis. An impressive amount of hydrogeological work was accomplished at the landfill
and hazardous waste site, and the work is sufficient to characterize the general nature of the
contaminant plume. To be sure, not every possible question was answered in the study, but I
9

believe that the significant issues were addressed. The conclusions made by Black & Veatch
are supported by the analysis. In brief, the principal conclusion is that the hazardous waste
site and landfill will not contribute organic contaminants to Randleman Lake at a sufficient
loading rate to cause a problem with regard to using water from the reservoir for amunicipal -
(drinking) water supply. The analysis on which this conclusion was based was highly con- `
servative. ~ No attempt was made to account for in-reservoir losses of any organic compounds
entering the reservoir from the landfill and hazardous waste site. In-reservoir losses from
volatilization, sorption and settling, photolysis, and biodegradation can be assumed to be
considerable. Even without accounting for these losses, the concentrations of VOCs predicted
to occur at the water supply intake are far below relevant water quality standards.
Overall, I conclude that the studies performed to date provide a sufficient basis to
support the construction of Randleman Reservoir from a technical perspective regarding water
quality and hydrologic conditions.
Reports Reviewed for this Assessment
Black & Veatch. 1990. Water Quality and Quanrity Studies to Support Randleman Lake
Environmental Impact Statement. Rept. 168AEB, Kansas City, MO. Prepared for Piedmont
Regional Triad Water Authority and dated December 1, 1990.
Black & Veatch. 1991. Water Supply Alternatives Assessment. Project No. 18321, Kansas
City, MO. Prepared for Piedmont Regional Triad Water Authority and dated September,
1991.
Black & Veatch. 1994. Randleman Lake 1994 Update to the Environmental Impact Statement.
Project No. 25291, Kansas City, MO. Prepared for Piedmont Regional Triad Water
Authority and dated April 1994..
Environmental Investigations, Inc. 1992. Groundwater and Surface Water Investigation,
Riverdale Road Landfill, .High Point, North Carolina. Durham, N.C. Prepared for the City of
High Point, NC and dated October, 1992.
Geraghty and Miller, Inc. 1993. Final Report of the Remedial Site Inspection of the Seaboard
Chemical Site. Raleigh, N.C. Plus Addendum #1 to Work Plan, dated Nov. 25, 1992.
North Carolina Division of Environmental Management. 1988. Chemical and Biological
Monitoring of the Deep River 1983-1987. NCDEM, Water Quality Section, Dated Feb. 9,
1988 and identified on report as Appendix G of an unspecified report. Raleigh, NC.
North Carolina Division of Environmental Management. 1994a. Review of Deep River/
Carbonton Water Quality Investigations 1992/1993. NCDEM, Water Quality Section,
Environmental Sciences Branch, Dated September 28, 1994. Raleigh, NC.
10

North Carolina Division of Environmental Management. 1994b. Water Quality Monitoring
Data for Waters in the Upper Deep River Area. July 28, 1992 -October 7, 1993. NCDEM,
Water Quality Section, Environmental Sciences Branch, Dated September 28, 1994. Raleigh,
NC.
11

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Mate 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
24 January 1997
Mr. John Kime
Piedmont Triad Water Authority
Wilmington Building
Suite 100
2216 West Meadowview Road
Greensboro, NC 27407-3480
Dear Mr. Kime:
'_ Y
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~~~
~EHNFi
Re: Wetland mitigation and stormwater management plans
Proposed Randleman Reservoir
Randolph County
Based on the recent field visit to the Cone's Folly site along the Black River on 22
October 1996, you, Mr. McDuffy and John Dorney of my staff agreed that a letter from the
Division outlining mitigation and watershed management requirements for the 401 Water
Quality Certification would be useful. This letter summarizes the approach that we believe
the Authority should take in order to allow DWQ to issue the required Water Quality
Certification for the proposed Randleman Reservoir.
As you are aware, a 401 Certification is a statement that water quality standazds will
not be violated by a project. The primary standard of concern with the Randleman
Reservoir is the chlorophyll a standard of 40 ug/l. As you know, algal growth is in
response to nutrient input from both point and nonpoint sources. It is clear that intensive
point and nonpoint control measures will be needed in the watershed in order not to violate
the chlorophyll a water quality standard and tlLinimi~e problematic algal blooms. These
measures will have to address both existing and future nutrient sources to the lake.
By our wetland rules, mitigation for wetland losses within 150 feet of surface waters
(which will likely include all acres of wetlands flooded by the reservoir) could require as
much as 4:1 restoration and be higher still for creation, enhancement or preservation. The
rules require DWQ to defer to the mitigation requirements of the Corps of Engineers but
still require a minimum of 1:1 restoration/creation (15A NCAC 2H .0506(6)). Thus
DWQ's mitigation requirements would be 120 acres of restoration/creation of wooded
wetlands. Preservation efforts by the Authority such as those discussed at Cone's Folly
do not meet this criteria and aze of no value to water quality in the Reservoir since the site is
more than 100 miles downstream from the Reservoir. Similazly the proposed 200 foot
buffer adjacent to the reservoir will be of limited benefit to water quality since it filters only
about 2°l0 of the watershed and only that small portion of runoff that enters laterally into the
lake.
We believe that a carefully designed comprehensive management plan can address both
the chlorophyll a nutrient problem rl the wetland mitigation issue. We have discussed
this approach with the Authority several times over the recent years and believe that the time
is appropriate for the Authority to finalize this plan.
As you discussed with my staff on 22 October 1996, the centerpiece of the plan should
be the identification, acquisition and implementation of wetland restoration/creation efforts
Environmental Sciences Branch 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
An Equal Oppactunity Affinnadve Action Employer 5096 tecycled/1096 post consumer papa

to total 120 acres on the major tributaries to the lake (notably Richland Creek, Muddy
Creek and Hickory Creek). As discussed, we believe that the funds you had earlier
targeted to create wooded wetlands adjacent to the lake within the buffer would be better
spent on mitigation along the lake's inflowing streams as outlined below. The recent work
done by High Point on the East Fork of the Deep River is an excellent example of work to
both restore/create wetlands and handle storm water quality issues. As David Franklin
stated, if 404 pernuts aze needed for these measures (which is likely), these can be added to
the permit application for the Reservoir. Staff reported that the sites at Richland Creek neaz
the Eastside WWTP and on Muddy Creek at SR1917 would be excellent wetland
restoration sites with about 40 to 50 acres each of restoration of wooded wetlands. The site
on Hickory Creek would also be a good mitigation site although it is somewhat smaller.
The site at Muddy Creek on Muddy Creek Road is probably too small to be effective. At
any of the sites, the likely design would involve completely plugging the small tributaries in
order to divert the entire flow as well as placing an instream dam or concrete or stable rip
rap to divert the higher flows from these lazger creeks into the created wetlands in the
floodplains. Grading of these sites should not be necessary except in limited instances. As
was discussed, Ron Linville of our Winston-Salem Regional Office and Pete Colwell of
our Central Office will be glad to continue visiting and evaluating other potential mitigation
sites. In this context, a site visit to the wetlands which will be impacted by the reservoir
would be useful. Please contact Pete Colwell of our Central Office and/or Ron Linville of
our Winston-Salem Regional Office in this regard. Based on work we have seen
elsewhere, the total cost of mitigation should range from $600,000 to $1.8 million for the
mitigation . Since some of the acceptable sites we visited are already owned by the
Authority, this should keep costs in the lower end of this range.
While the restoration discussed above addresses the primary concerns regarding the
401 Certification associated with the 404 permit, please recognize that other issues will
need to be addressed with the Water Quality Division as you move forward with your
efforts to build and use a water supply reservoir. The most efficient means of addressing
these issues would be through development of a comprehensive watershed management
and protection plan. Such a plan should identify existing and future sources of nutrients,
identify measures (both structural and non structural) to control these sources and then
implement specific plans for these measures. This plan should be part of the 401
Certification approval process.
Measures that should be provided in this plan include floodplain preservation via
zoning or subdivision ordinances to manage new nonpoint sources of nutrients, wetland
restoration creation, stormwater requirements for new development, stream buffer
protection and repair, and stormwater detention ponds as well as other measures
throughout the watershed. The wetland restoration/creation would be an important
component of this plan in order to attempt to address water quality and wetland mitigation
efforts. Every jurisdiction in the lake's watershed will need to adopt and implement
appropriate watershed management plans in accordance with the classified uses. To begin
this process, we suggest that you collect all existing watershed management plans and
ordinances that are in effect in the Randleman Lake watershed so we can begin to work
with you to evaluate their effectiveness and begin to develop an appropriate watershed
management plan.
We will be glad to meet with you and your consultants to discuss this approach and all
issues relating to the water quality of Randleman Reservoir. If site visits would be helpful,
both our Central and Winston-Salem Regional Offices would be glad to arrange and assist
with these visits. We believe that a comprehensive wetland mitigation and comprehensive
watershed management plan along the lines outlined above will allow a 401 Certification to
be issued for this project. Finally, as you are awaze, the Environmental Management
Commission would have to reclassify the Reservoir in order to allow its use as a water
supply.
In summary, the primary issue that will need to be addressed in order for us to move
: forward on the Water Quality Certification is a wetland mitigation plan consistent with - - - .
Corps of Engineers' requirements and which includes at a minimum, a wetland
_: :restoration/creation plan to restorelcreate at least 120 acres of wetlands on the major

tributaries entering the lake. This effort should be focused on treating existing sources of
nonpoint pollutants.
This and other issues that need to be addressed will be most efficiently handled
through development of a comprehensive watershed management and protection plan to
assure that future development will not result in degraded water quality in the lake. This
plan might incorporate commitments from each municipality and county to implement
watershed ordinances which are protective of the water supply and reasonable in terms of
future development patterns, measures to address point sources of nutrients, and plans to
collect water quality data to address the eventual reclassification issue.
The staff of the 401 Water Quality Certification, Watershed Supply Protection,
Instream Assessment Unit, and Basinwide Planning Programs as well as the Winston-
Salem Regional Office remain available to provide help with individual components of the
comprehensive management plan. We would encourage the authority to adopt watershed
protection and wetland mitigation measures beyond the minimum requirements to further
enhance water quality in the proposed reservoir. Please call John Dorney or Jimmie
Overton of my staff at 919-733-1786 to continue efforts began in the field on 22 October
1996 in order to develop a plan which will protect the reservoir's water quality.
Sincerely,
~.~.~--_
Steve W. Tedder
Chief, Water Quality Section
cc:
Preston Howard
Jimmie Overton
Greg Thorpe
Don Safrit
Frank McBride, WRC
Kevin Hardy, US FWS
David Franklin, COE
Lee Pelej, US EPA
Central Files
Steve Mauney, Winston-Salem DWQ Regional Office
Lisa Martin, Water Supply Protection
Ruth Swanek
Steve Zoufaly

bcc: Charlie Hollis
Doug Frederick, Triangle Wetland Consultants

WATER QUALITY PLANNING Fax~919-715-5637
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• ~ ` ~ : : Environmenta~:~ eso~xces I~Eitrtagenfent, Inc. (ER)VI) ti~l be conducting aan
EcologicaT~'Char~cteriza~tiori;art~f Risk .Assessment in aecoxc~ance ~uvitb a
I ! :Remedial:Ir-vestgaticiri;uncler~the direction of the United Mates
I • ' ::. Erivirontnental;~'xotectlon Agency.,(U.S. EPA), of the fgrmti r Seaboard
• : Chemical facilit~~andthe'City:of bIigltpoint Riverdale pri,~e Landfill
.' (collecfii~ety:xef~ired ~o ~~s the':'site"). The site is located ~I Guilford
.: Cour~Cy,'Nortli. +•arol~iia, and can be found at 5894 Rivez~d~le Drive,
' , :: jaxriestawn, IBC (see enclosed~map): The site borders the Deep River.
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EitIvl is ctarrer~'tly coi>jducting ascree~ting-level evaluation ~to determine
eccl~gical:issues assecRtec~ with the potential action. 'Accordingly, the
puiposeof:tltis; let#er~ia:ta soI}cit information from the!Uc~ision of Water
j ~ ;:;•~ Quality.c~nce'rriing•t1~~classifcation of the river and its tributaries.
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Environmental
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Management, Ync.
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Exton, Pennsylvania 19341
(610)52-3500
[phone] (fax)
ERM.
A mrrnber of UE F.nvlronmCntel
ltescrurce5 Wlana~emun~ Group

WATER RLI~il` PLANNING Fax~919-715-5637 Feb 18 '97 15 11
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Donald P. Knorr '
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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
Water Supply Watershed Protection
~~/~
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M E M O R A N D U M
+53,.,
TO: Andrea Spangler ~'4~P ~~~~`1~~,
Piedmont Triad Water Authority `~'~ip ~'~
ti
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FROM: Brent C. McDonald q4s%~
~~~~~s
DATE: March 21, 1997
RE: Local governments' water supply watershed protection
ordinance revisions near proposed Randleman reservoir
Enclosed please find requests for ordinance changes for City of Greensboro
and City of High Point to meet minimum statewide water supply watershed
protection measures (a.k.a. "120-day letters"). As I mentioned on the
telephone this morning, both municipalities consider their watershed
protection programs to be more stringent than state minimum standards.
DWQ staff agrees that they are -- in certain ways (e.g. control of existing
development, tiered critical areas, etc.); however, in other respects, they are
actually less stringent (e.g. excessive density permitted in Tier 3 and 4 critical
areas, only 1/2 inch stormwater control required). Staff feels that in light of
the proposed future reclassification for the Randleman reservoir, these
upstream municipalities would be wise to go above and beyond state
minimum standards and take exceptional measures to protect the water
quality in this area. Staff would ask that you encourage these municipalities
to strongly consider amending their local ordinances to incorporate all of the
recommended changes detailed in the a ached letters.
.~ i
~~~ ; ~
c c : Lisa Martin ~~`'
John Dorney
Steve Zoufaly
Ron Linville, WSRO
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX 919-71

James Ronald (Ron) Linville,2/27/97 11:31 AM,Randleman _Lake/Landfill Miti~a 1
From: "James Ronald (Ron) Linville" <[e-mail]>
Organization: WSRO DEHNR
To: [e-mail]
Date: Thu, 27 Feb 1997 11:31:25 +0000
Subject: Randleman Lake/Landfill Mitigation???
Priority: normal
I talked to John D this AM and discussed the B6B landfill ideas that
I have been thinking about. He recommended that when we meet next Wed
that we let the consultant for Kime know that we want to look at the
upper ut to Hickory Creek below these landfills as a possible mitigation
location due to pollutant/leacheates from old landfill sites. John
indicated that a Randleman review and sampling should be
accomplished prior to getting DOT involved. According to Phillip
Todd it will be later in the spring before DOT delineates the I-85
impacts thru this area but that he knows of some wetland and stream
impacts near the landfills already. Please let me know for sure when
and where we are to meet and with whom on the 5th of March.
Any strategy on my part has not been formalized and will necessarily
be done at a later date when things jell or not jell. If DOT, etc. and
909/401 mitigation can be customized to fix a known problem (a
possible landfill reconfiguration and end capping integration w/ DSWs
concurrence) we should be able to say we improved water quality.
At the very least, we need to get all the interested parties together
to discuss options and possibilities.
Anyway, I feel that if I don't ask about these opportunities, nobody
else will. The county really wants to close these landfills but may
not push the issue on the older landfills as far as buffer
requirements relative to the stream which I believe are crucial.
And now the B6B landfill does not have a 909/901 per my conversation
with John Thomas yesterday. It will likely get more interesting....
Next Tuesday, WSRO will be gathering samples upstream and downstream
along this stretch of stream.
Ron Linville @ WSRO 910/771-9608 x 265
"One of the penalties of an ecological education is that one lives alone in a world of wounds. Much of
the damage inflicted on land is
quite invisible to laymen. An ecologist must either harden his shell and make b
elieve that the consequences of science are none of
his business, or he must be the doctor who sees the marks of death in a community that believes itself
well and does not want to be told
otherwise." from Round River by Aldo Leopold
-----------
Printed for [e-mail] (Pete Colwell)

James Ronald (Ron) Linville,2/20/97 11:06 AM,B&B (Moose Lode) & Associat 1
From: "James Ronald (Ron) Linville" <[e-mail]>
Organization: WSRO DEHNR
To: Phillip Todd <[e-mail]>
Date: Thu, 20 Feb 1997 11:06:23 +0000
Subject: B6B (Moose Lodge) b Associated Landfills
CC: "NROAR04/TS19W40"@wsro.ehnr.state.nc.us,
"NROAR04/N1NW359"@wsro.ehnr.state.nc.us,
"NROAR04/N1EA330"@wsro.ehnr.state.nc.us, [e-mail]
Priority: normal
We need to talk about concerns and potential opportunities at the
Moose Lodge site near Groometown on a tributary to Hickory Creek. If
the Randleman dam gets built, this could be important to resolve. If DOT builds
an 85 Bypass thru this area, there are some things that you guys need
to consider. There may be some potential (if County will cooperate
w/ 319 funds they have) to improve water quality or at least "digest"
some leacheate discharging from several "inert debris" landfills. Extent
of problem is not known at present but we have some concerns and have
collected some samples. This is all very preliminary and I'm not
sure where this will go or how it will go; but, my thinking is that
somehow the county, DWQ (including 9016 watershed protection), COE,
DOT, DSW, and Randleman Lake Commission should meet to at least discuss
the situation, cooperative options and/or mutually beneficial
opportunities.
See you Wed. on Hwy 16 project. Ron
Ron Linville @ WSRO 910/771-9608 x 265
"One of the penalties of an ecological education is that one lives alone in a world of wounds. Much of
the damage inflicted on land is
quite invisible to laymen. An ecologist must either harden his shell and make believe that the
consequences of science are none of
his business, or he must be the doctor who sees the marks- of death in a community that believes itself
well and does not want to be told
otherwise." from Round River by Aldo Leopold
Printed for [e-mail] (Pete Colwell) 1

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Department of Environment,
Health and Natural Resources
Winston-Salem Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
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RECEIVEC
MAY ~ 71997 1 ~ •
ENVIRONMENTAL SGiEN .
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C~EHNR
DIVISION OF WATER QUALITY
May 9, 1997
Mr. Randy L. McNeill, PE
Davis Martin Powell & Associates
218 Gatewood Ave. Suite 102
High Point, NC 27262
SUBJECT: City of High Point
Eastside Wastewater Treatment Plant
Expansion and Upgrade
Guilford County
Dear Mr. McNeill:
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This office has received your letter of April 28, 1997 in response to a memorandum
previously sent to Michelle Suverkrubbe.
Please be advised that the memo sent to Michelle sought to address concerns directly
discussed in the Eastside WWTP EA with some consideration for potential impacts that
development around the proposed Randleman Lake may cause. This office is aware that
High Point has recently exerted considerable efforts in I&I reduction due to concerns
previously expressed by this Division. We are also aware that planning ordinances are
intended to provide various buffers along perennial streams. Additionally, we are aware that
Eastside has redundant power potential. Firsthand observations have provided concern for
color in the Eastside discharge and color issues are likely to be addressed through permit
considerations.
The memo written to Michelle was based on the findings of the "Water Quality
Monitoring Data For Waters in the Upper Deep River Area July 28, 1992 -October 7,
1993". From conditions found in that study, a previous study of the Seaboard Chemical
Facility and general knowledge of downstream conditions, considerations should be given by
the City of High Point and Randleman Lake proponents to take steps which are designed to
improve existing conditions by providing very efficient and dependable wastewater treatment
and preserving areas of the watershed which may still be in good condition. Back up dower
generation on site as opposed to redundant systems provides additional assurance that a water
supply lake can be protected during future events like Hurricane Fran. An ongoing and
proactive I&I program is essential to prevent untreated wastewaters from being released into
the watershed. Optimal protection should be preferred in order to insure the best long term
water quality.
585 Waughtown Street, ~~y~ FAX [phone]
Winston-Salem, North Carolina 27107-2241 r~ An Equal Opportunity/Affirmative Action Employer
Voice 910-771-4600 50% recycled/10°h post-consumer paper

The EA indicated that construction of the proposed improvements at the Eastside plant
will provide a secondary benefit from continued service area expansion by reducing
dependency on subsurface disposal systems. This expected growth will likely be deleterious
to the lake should it be built since this growth, if not strictly controlled with proper best
management practices, will likely lead to more pollution and nutrient loading than now
occurs in the watershed. This would happen because of increased turf management, greater
impervious areas, more human activities, manmade stormwater conveyances and destroyed
headwater wetlands and tributaries filled by development activities or similar impacts.
Thus, since these waters are not in the best condition now, it would be appropriate to
provide additional measures to control development so as not to destroy functioning
waters/wetlands which are normally found above perennial waters. It is important to realize
that these headwater tributaries and wetlands currently assimilate to some extent urban runoff
and wastewaters. Hence, in the case of the Randleman Lake, these areas are very valuable.
Construction of wetlands to mitigate for lost wetlands which will be submerged by the
proposed lake will be undertaken by the Randleman Lake Authority. Hopefully, providing
these new wetlands and preserving existing wetlands and tributaries would protect the
proposed lake by preventing piecemeal losses to water quality as the area developes. Again,
due to the current Deep River conditions and the proposed water supply lake, we urge that
optimal (rather than minimal) proactive measures be utilized in the planning process.
Should you have questions, please contact me at [phone] extension 265.
Sincerely,
~~
,,,~/~ '
Ron Linville
Environmental Specialist II
enclosures: excerpts from Deep River Study
Seaboard Chemical Facility memo
cc: Central Files
John Dorney
John Kime
Jay Sauber
WSRO
Michelle Suverkrubbe
Chrys Baggett
John Thomas
a:\expnsion.HP

Executive Summary
Monitoring to measure improvements in water quality associated with
management efforts in the Deep River has been ongoing. A review of chemical and
biological information from 1983 to 1987 was included in the Chemical and
Biological Assessment of the Deep River 1983-1987 (report no. 88-01).
Improvements in biological integrity noted at that time have remained fairly stable.
Water quality of the upper Deep River area has become of particular interest to the
public since local governments formed the Piedmont Triad Regional Water
Authority (PTRWA) in 1986 with plans to construct Randleman Lake for a drinking
water supply. Because of the intense interest in this area, this study was undertaken
to measure existing water quality in the upper Deep River and its tributaries. This
report does not attempt to evaluate or project water quality conditions which may
occur as a result of hydromodifications from dam construction or lake formation.
The following summary provides a review of water quality and macro invertebrate
data collected at selected stations within the upper Deep River area. This
monitoring summary includes the most recent data from both mainstem and
tributary streams.
Fourteen monthly sampling events were conducted at nine different locations
from July, 1992 to October, 1993. Five coliform only sampling collections were
conducted at eleven locations during the month of June, 1993. Summary tables are
provided for all data that equal or exceed water quality standards as presently
classified. Attached in the appendices are all chemical data and a list of NPDES
dischargers in the watershed.
Individual fecal coliform concentrations exceeding 200./100 ml were found at all
stations during this evaluation. Five sampling runs for fecal coliform were
performed with in a 30 day period of time during June of 1993. The fecal coliform
water quality standard of 200/100m1 was violated at four of eleven locations, Muddy
Creek at SR 1936 (224/ 100 ml), the Deep River at Highway 220 Bypass (229/ 100 ml),
Muddy Creek at SR1922 (288/100 ml), and at Muddy Creek at SR 1941 (851/100 ml).
A suspected source of these high bacteria levels was a dairy located upstream on
Muddy Creek. However, additional sampling performed on Muddy Creek upstream
of the dairy at SR 1922 and at SR 1941 failed to confirm it as the primary cause of the
high bacteria levels.
Metals concentrations higher than action levels for Copper, Zinc, and Iron were
found in the Upper Deep River. The High Point Eastside WWTP appears to be a
contributing source of copper since all concentrations greater than 7 ug/1 except T
were found downstream of the High Point Eastside WWTP (31 observations of
Copper exceeded lug/1).
Three dissolved oxygen observations less. than or equal to the water quality
standard of 4.0 mg/1 were found in the data collected. Two of these low dissolved
oxygen values were found on the Deep River above the confluence of Richland
Creek at I 85 upstream from the potential influence of the High Point Eastside
WWTP.
Phenols values above laboratory detection levels were found at all stations in the
upper Deep River study area. Pesticides and organics were found in the data
collected from the Upper Deep River study area. Violations of the water quality
standard for Lindane and Dieldrin were found. The source of the Lindane appears
to be the High Point Eastside WWTP as most of the violations were found
immediately downstream. The City of High Point suspects the residential use of flea
1

dip and shampoo containing lindane as the source of these elevated lindane levels.
Numerous unidentified peaks suggested the presence of many organic chemicals.
Unidentified peaks are indications of organic compounds but chemical specific
confirmation and identification was not possible. During this entire study 87
samples were collected for pesticides and organics analyses. Laboratory analysis of
these samples indicated 1,376 unidentified peaks. Richland Creek below the
Highpoint WWTP discharge (14 samples) had 643 unidentified peaks. While
Richland Creek above the Highpoint WWTP discharge (14 samples) had 41
unidentified peaks.
Elevated nutrient levels were measured throughout the study area. The lowest
concentrations of nutrients were observed on Richland Creek upstream of the waste
water discharge from the High Point Eastside facility. The High Point Eastside
WWTP is a significant contributing source of the observed elevated nutrient levels
as all nutrient parameters were generally found in higher amounts at stations
downstream of the WWTP. Algal growth ,potential tests performed on ~ samples
collected in Muddy Creek and in the Deep River indicated that these waters have
the potential for significant problems from algal response to nutrients if sufficient
retention time and sunlight were available.
Benthic macroinvertebrate data from the upper Deep River have been collected
periodically since 1983. Historically, the most upstream site was severely impacted
by wastes from the Jamestown WWTP. The Jamestown WWTP plant went off-line
in October 1984, and an immediate change in bioclassification from Poor to Fair was
observed. Total taxa richness continued to increase for several years (until 1986).
Further recovery may be limited both by the urban character of the watershed and
the influence of the High Point Eastside WWTP. There has been only limited
improvement since that time, and the fauna is dominated by very tolerant species.
The most downstream site sampled for ~enthos is the Deep River at SR 1461 near
Jugtown in Moore County. This site has received an Excellent bioclassification from
1983 through 1993.
Discussion of Upper Deep River Data
Introduction
Local governments surrounding the proposed Randleman Lake formed
the Piedmont Triad Regional Water Authority (PTRWA) in 1986 to purchase
water supply storage. The PTRWA received permission from the
Environmental Management Commission to proceed with plans to construct
Randleman Lake for a drinking water supply. Existing concerns about the
present water quality in the Upper Deep River area warrant an investigation
of the Deep River and its tributaries.
This study was undertaken to measure current: conditions and characterize
water quality in the Deep River and its tributaries in this area. The following
discussion summarizes results of these data and details areas of concern
including frequency and location of water quality standards violations. Table
1 presents the frequency of parameters that exceed water quality standards as
presently classified. Table 2 presents the individual concentrations for water
quality observations that exceed standards as presently classified. Appendix A
contains a list and map of dischargers to the watershed.
2

~..,..,. _.., ,:...., .... _ ement
Division Of Environmental Manag
North CarolinSection / Environmental Sciences Branch
Water Quality Intensive Survey Group
8 January 1990
MEMORANDUM
Ken Eagleson
To: 1
Through: Jay SaubercJ
Jim Overt
Kurt Trum wer
From:
of the Deep River Adjacent to the
Subject: Sampling
Seaboard Chemical Facility
River
Results of the sampling performed in the Deep
and downstream of the ut running through the High
upstream and in the ut itself
As you are aware
Point LandfiCeived fromothe laboratoryof October 17, 1959,
have been re revious memorandum of DEHNR's Winston
from Taku Fujierformed by Michael Mickey onse to an
sampling was p 1989 in resp
Salem Regional Office on October 12, the Seaboard Chemical
inquiry from Kenneth Rudo concerning
Company. led once each for pesticides,
Four stations were samp anics and are shown on
organics, and purgeable org arameters
herbicides, map Sample results for these P ounds were
the accompaning Several comp Only
also are attached to this memorandum•an state standards
detected in all samples collreaterath at all stations.
were equal~to or g exist for many of the
2 values, running through
although state standards do not in the ut
ounds detec Ladd.fill and Seaboard Chemical) a Toluene
comp
the High Point This value is above the 11uagic
value of 47 ug/1 was found. rotection of aq
or
River downstream from the
state standard for all freshwaters an estimated
life. At station 67 (in the Deep River) , ual to
confluence of the ut and 1hWaDefound, This value is eq
Lindane value of 0.01 ug/ 1 for all freshwaterswhich were
the state standard of 0.01 ugSix values were found
protection of aquatic life. uality
above levels recommended in the EPA document "
~~ At station_64, the chlorofofr0.19
Criteria for Water 19861•was above the EPA Criteria
estion. At station 65, a
value found of 0.60 ug above the EPA
ug/1 for water and fish ing 1 was found,
chlorobenzene value of 170 ug/ 1 At this same
ne value of 5.4 ug/l, above the .EPA crp,lsolat
freshwater benzelc criteria of 50 ug ion was found;
station, a
of 0.66 ug/1 for water and fofh47ngg~l was found which is
station 65, a Toluene value 1 for water and fish
chloroform values above
above the EPA criteria of 14.3 ug/
At stations 66 a~dfor'water and fish ingestion
ingestion. 19 ug/
the EPA critrtia of 0.

were found. The value found at station 66 was 0.22 ug/1 W~nStOn-
while at station 67 the value for this parameter was 2.2 ~~~ a, Salem
ug/1. Since several compounds were found in the Deep Riv 10~ ~~flC@
above, as well as below the confluence of the ut, it is not
appropriate to suggest that all compounds found in the River
below the confluence are originating from the High Point
Landfill and/or Seaboard Chemical. Please call me if you
have any questions or require further information.
cc. Michael Mickey
Steve Mauney

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DATE STATION RESULTS
891012 64 1,1 DICHLOROETHANE - 2.1 UG/L
CHLOROFORM - 0.60 UG/L
CHLOROBENZENE - 2.2 UG/L
3 UNIDENTIFIED PEAKS DETECTED BY GC/ELCD.
NO VOLATILE ORGANICS DETECTED BY GC/PID.
NO BASE/NEUTRAL OR ACID ORGANIC EXTRACTABLE
COMPOUNDS DETECTED BY GC/MS.
NO PESTICIDES DETECTED BY GC/FPD.
NO PESTICIDES DETECTED BY GC/EC.
NO ACID HERBICIDES IDENTIFIED;
17 UNIDENTIFIED PEAKS DETECTED BY GC/EC
891012 65 1,2 DICHLOROETHANE - 0.30 UG/L
CHLOROBENZENE - 170 UG/L
3 UNIDENTIFIED PEAKS DETECTED BY GC/ELCD.
ACETONE - 1500 UG/L
METHYL ETHYL KETONE - 1000 UG/L
BENZENE - 5.4 UG/L
METHYL ISOBUTYL KETONE - 33 UG/L
TOLUENE - 47 UG/L
M,P-XYLENE - 0.99 UG/L
O-XYLENE - 1.7 UG/L
4 UNIDENTIFIED PEAKS DETECTED BY GC/PID
THE FOLLOWING COMPOUND WAS IDENTIFIED BY GC/MS
TARGET COMPOUND ANALYSIS. CONCENTRATION WAS
ESTIMATED AGAINST A KNOWN INTERNAL STANDARD.
4-METHYL PHENOL - 50 UG/L
THE FOLLOWING COMPOUND WAS TENTATIVELY IDENTIFIED
BY MATCHING TO LIBRARY MASS SPECTRA. IT WAS NOT
MATCHED TO A STANDARD. CONCENTRATION WAS ESTIMATED
AS A RATIO TO A KNOWN INTERNAL STANDARD.
3- METHYL PHENOL - 14 UG/L
15 UNIDENTIFIED PEAKS DETECTED BY GC/MS.
ESTIMATED CONCENTRATION - 1100 UG/L
NO ACID HERBICIDES~IDENTIFIED;9 UNIDENTIFIED
PEAKS DETECTED BY GC/EC.
NO PESTICIDES IDENTIFIED;11 UNIDENTIFIED PEAKS
DETECTED BY GC/EC.
NO PESTICIDES IDENTIFIED;10 UNIDENTIFIED PEAKS
DETECTED BY GC/FPD.
891012 66 CHLOROFORM - 0.22 UG/L .
NO VOLATILE ORGANICS DETECTED BY GC/PID.
NO BASE/NEUTRAL OR ACID ORGANIC EXTRACTABLE
COMPOUNDS DETECTED VIA GC/MS.
NO PESTICIDES DETECTED BY GC/EC.
NO PESTICIDES DETECTED BY GC/FPD.
NO ACID HERBICIDES IDENTIFIED;34 UNIDENTIFIED
PEAKS DETECTED BY GC/EC.
891012 67 CHLOROFORM - 2.2 UG/L
BROMODICHLOROMETHANE - 1.1 UG/L
CHLORODIBROMOMETHANE - 0.52 UG/L
NO VOLATILE ORGANIC COMPOUNDS DETECTED BY GC/PID.
NO BASE/NEUTRAL OR ACID EXTRACTABLE ORGANICS
DETECTED BY GC/MS.
NO PESTICIDES DETECTED BY GC/FPD.
LINDANE - 0.01 UG/L(ESTIMATED)
7 UNIDENTIFIED PEAKS DETECTED BY GC/EC.
NO ACID HERBICIDES IDENTIFIED; 40 UNIDENTIFIED PEAKS
is !`~

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