19970722 Ver 1_Report_19981201

•
Draft
Summary of DEIS Comments and Responses
Randleman Lake
Guilford and Randolph Counties
North Carolina
•
December 1998
HAZENAND SAV~JYER
Environmental Engineers & Scientists
•

• • •
RANDLEMAN EIS
LIST OF AGENCIES AND INDIVIDUALS COMMENTING ON THE DRAFT EIS 12/01/98
EPA U.S. Environmental Protection Agency (10/8/97)
EPAW U.S. Environmental Protection Agency, Wetlands Section (9!12/97)
SC Sierra Club, Haw River Group (9/17/97)
DOT N.C. Department of Transportation (10/6/97)
LC Lee County Environmental Affairs Board (9/23197)
LIA N.C. DENR Legislative and Intergovernmental Affairs (10/2/97)
DWQ1 N.C. DENR Division of Water Quality (9/30!97)
DWQ2 N.C. DENR Division of Water Quality (10/3/97)
DWQ3 N.C. DENR Division of Water Quality (1/24/97)
WRC N.C. Wildlife Resources Commission (10/1/97)
DEH N.C. Division of Environmental Health, Public Water Supply Section, Winston-Salem Regional Office (8/11/97)
DWR N.C. Division of Water Resources (9/18/97)
DPR N.C. Division of Parks and Recreation (7/9/97)
DFR N.C. Division of Forest Resources (8/7/97)
DWM N.C. Division of Waste' Management (8/26/97)
GC Guilford County Advisory Board for Environmental Quality (9/12/97)
DOI U.S. Department of the Interior (8/15/97)
NOAA National Oceanic and Atmospheric Administration (8/4/97)
HRA Haw River Assembly (8/25/97)
NAS National Audubon Society, New Hope Chapter (8/26/97)
WPPDC West Piedmont Planning District Commission (9/5/97)
DRPA1 Deep River Park Association (to Mr. John Meshaw) (8/30/97)
DRPA2 Deep River Park Association (to Mr. David Franklin) (8/30/97)
CCNC Conservation Council of North Carolina (8/5/97)
DHHS U.S. Department of Health and Human Services (8/25/97)
RRA1 Rock Rest Adventures (8/18/97)
RRA2 Rock Rest Adventures (10/8197)
RDF Rainy Day Farm (8/15/97)
C-AH1 Alan Horton (to Mr. John Hankinson) (9/15/97)
C-AH2 Alan Horton (to Mr. David Franklin) (9/15/97)
C-AH3 Alan Horton (comments on scoping)
Page 1

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RANDLEMAN EIS
• •
LIST OF AGENCIES AND INDIVIDUALS COMMENTING ON THE DRAFT EIS 12/01/98
C-AH4 Alan Horton (5/12/97)
C-AH5 Alan Horton (6/30/97) .
C-AH6 Alan Horton (8/15/97)
C-TA Thelma Adams (Including attached letter from Leon D. Owen) (8/12/97)
C-AS Alice Smith (no date)
C-SG Susan S. Graham (9/10/97)
C-CH Caleb Harrison (8/29/97)
C-VW Vernon Wilson (8125/97)
C-WF W.S. Farabow (8/25/97)
C-KS Kenneth R. Sawyer (8/13/97)
C-NP Nancy Priddy (7/31197)
C-MSE Michael Semonsky (8/19/97)
C-EC Edith S. Coltrane (8/16/97)
C-NC Neal E. Coltrane (8/16/97)
C-DC David Craft (8/16/97)
C-RP Robert H. Pickard (8/10/97)
C-HP Hilda H. Pickard (8/8/97)
C-MSM Marsh Smith (8/5/97)
Page 2

• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
1. NEED
1.1 Provide updated estimates of existing SC
and projected water consumption. C-AH2
Annual average daily water use for PTRWA members for the years
1991 through 1997 is included in Table 3 of the FEIS. Projected
water demands presented in the FEIS for the years 2000, 2010 and
2020 (Table 6) were obtained from the 1992 Water Supply Plans
prepared by the PTRWA members and submitted to the N.C. Division
of Water Resources (NCDWR). The projected water demand in the
design year 2050 of 108.6 mgd was based on a linear extrapolation
of the projected demands from the Water Supply Plans for the years
2010 to 2020, minus a projected reduction for water conservation.
The projected design year water demand of 108.6 mgd is equivalent
to an average annual increase of approximately 1.5 percent compared
to the 1997 water use of 48.07 mgd. This is considered a reasonable
growth rate for the Piedmont Triad region of North Carolina. For
comparison, the historical population for the PTRWA members (not
including Guilford County} increased at an average annual rate of 0.9
percent from 1970 to 1980 and 1.5 percent from 1980 to 1990.
Section 2.4 of the FEIS (Table 3) includes additional information on
historical water use for PTRWA members through 1997, which is also
shown on Figure 3.
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• • •
Table 3 (cantinued),=
Annual Average Daily Water Use (MGD)
Water Sources 1991 1992 1993 1994 1995 1996 1997
Greensboro
Lake Townsend WTP cs> 16.90 15.64 15.43 15.82 18.26 21.44 20.70
N.L. Mitchell WTP cs> 14.80 15.38 15.95 17.28 16.20 12.67 13.20
High Point
Kearns WTP ~'~ NA NA NA NA NA NA NA
Frank L. Ward WTP ~'~ 10.61 10.89 10.92 12.30 12.21 12.73 12.80
Jamestown
Oakdale Cotton Mill c8~ 0.20 0.15 NA NA NA NA NA
Archdale
Davidson Water, Inc. c9> - - - 0.20 0.18 0.22. 0.14'
Randleman
Randleman WTP ~10~ 1.031 0.954 0.958 1.054 0.995 1.097 1.150
Asheboro ~10~ 0.021 0.025 0.035 0.049 0.040 0.046 0.076
TOTAL ANNUAL 43.56 43.04 43.29 46.70 47.89 48.20 48.07
AVERAGE
(6) Williams, January 1998.
(7) Kairis, January 1998.
(8) Frezell, January 1998; water received from Greensboro and High Point included in Greensboro and High Point quantities,
respectively.
(9) Ogburn, January 1998; water received from High Point included in High Point quantities.
(10) Hardin, January 1998.
NA Not Applicable
" Number is low due to malfunction of meter.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
1.2 Rewrite water conservation section to C-AH2
provide an accurate evaluation of
what real conservation measures
could achieve.
Potential reductions in water demand from water conservation are
discussed in Appendix A, pages 12 through 19, and in Section 2.5 of
the FEIS. The projected reduction in total demand of 12.5 percent
over the 50-year design period is considered the maximum amount
practicable since the cities of Greensboro and High Point have
already implemented water conservation measures, which will make
additional water demand reductions more difficult to achieve (see
response to Comment 2.32). The projected 12.5 percent reduction
over a 50-year period is equivalent to a water demand reduction of
approximately 32 mgd in the design year 2050, or a 22 percent
reduction compared to the projected water demand without water
conservation. This reduction in water demand is considered
reasonable for the purpose of long-term water supply planning. No
revisions to the EIS are necessary.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
1.3 Discuss whether the existing water EPA The existing surface water supply sources for the PTRWA members
supply sources will still produce a consist of Lake Townsend, Lake Brandt and Lake Higgins for
yield of 60.6 mgd in 2050. Greensboro; High Point City Lake and Oak Hollow Lake for High
Point; and Randleman City Lake for Randleman. PTRWA members
also obtain water from other water systems, including the City of
Asheboro and Davidson Water, tnc. Table 2 in the FEIS shows an
estimated 50-year safe yield (SY~) for the existing surface water
sources of 61.6 mgd. Based on previous safe yield evaluations
(Hazen and Sawyer, 1988), storage volume losses due to
sedimentation for the Greensboro surface water supply sources will
reduce the SY~ at the end of the 50-year planning period to
approximately 35.2 mgd, or a reduction of approximately 2 percent.
Assuming similar reductions for the other surface water supply
sources, the total SY~ in the year 2050 for all surface water sources
is estimated at approximately 58.7 mgd. The current total contract
amount for purchase of water from other water systems is 1.5 mgd.
Assuming no change in existing contract amounts, the total SY~ in
the year 2050, including surface water supplies and water from other
water systems, would be approximately 60.2 mgd. This would equate
to a water supply shortfall of 0.4 mgd in the design year 2050. This
is not considered significant based on the length of the planning
period and the uncertainties involved in projecting future water
demands. Table 2 and Table 6 in the FEIS include revised
information on the projected SY~ for the existing water supply
sources.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
1.4 Clarify the number of years for the EPA The number of years for the planning period for the proposed project
planning period for the proposed is 50 years. The FEIS is consistent in referencing the correct number
project (p. 1-1 and III-2). of years for the planning period. Reports in the Appendix may not
reflect the correct planning period duration because they were
prepared previously. They are included in the FEIS for reference only,
where applicable, and as supporting documentation. The FEIS
includes a note indicating that statements included in reports provided
as appendices to the FEIS are not necessarily consistent with
statements in the FEIS, and that those in the FEIS take precedence.
The proposed reservoir design for a sediment storage pool with a
capacity for storage of 100 years of sediment is not inconsistent with
the 50-year planning period for the reservoir.
1.5 Projected growth and water demand CCNC See response to Comment 1.1.
are overestimated.
2. ALTERNATIVES
2.1 Consider the alternative of SC The altemative of withdrawing water from Jordan Lake was evaluated
withdrawing water from Jordan Lake. NAS in the 1985 CH2M Hill report on water supply alternatives for the
Evaluate in a supplemental EIS. C-AH2 Upper Cape Fear River Basin. This altemative was eliminated from
C-AH5 consideration for the following reasons:
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
2.1 (Continued)
COMMENTOR RESPONSE
(1) It would be more than 70 miles from the community water
systems to be served and would be vulnerable to
interruptions in supply because of the long transmission
pipeline.
(2) Pumping head would be in excess of 1000 feet, which would
make operating costs high. This would make the Jordan
Lake altemative more sensitive to escalation in energy prices
and inflation than the other altematives.
(3) Allowable yield was lower than projected water requirement.
Jordan Lake is estimated to have a total safe yield for water supply
purposes of 100 mgd. Currently, a total water supply of 33 mgd is
allocated to other water systems, leaving 67 mgd for allocations for
new water systems and for expansions of allocations for existing
water systems. It is unlikely that the PTRWA could obtain an
allocation approaching 48 mgd from Jordan Lake. Therefore, this
alternative would not meet the projected water supply need for the
proposed project and is not a feasible altemative.
Section 3.1 and Table 7a of the FEIS include additional information on
the alternatives recommended in the CH2M Hill report and the
reasons for rejecting the other altematives which were considered.
Of the 40 alternatives considered, four alternatives were
recommended as alternative water supply sources. Of the 36
alternatives which were not recommended, 20 were rejected for
inadequate safe yield, three were rejected because of excessive cost,
two were determined to be feasible as interim alternatives only, four
would require the development of additional future water supply
sources, and seven consisted of treatment options only for one of the
evaluated water supply sources (see Table 7a).
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• • •
Table 7a
Summary of Water Supply Alternatives from 1985 CH2M Hitl Study
Alternative Description 50-year Safe
Yield (mgd) Recommended
Alternative Reason for Eliminating from Consideration
1.1, 1.2 Multipurpose 48 Yes -
Randleman Lake (USAGE)
2.1, 2.2 Single Purpose 48 No More expensive than non-Federal water supply portion of cost for
Randleman Lake Alternatives 1.1 and 1.2.
3.1, 3.2 Upper Deep River Lakes 46 No More expensive than recommended alternatives.
4 Upper Deep River Lakes 40 Yes -
Lower Pool Only
5.1, 5.2 Altamahaw Lake 48 Yes -
6.1, 6.2 Benaja Lake 26 No Inadequate safe yield.
7 Upper Haw River Lake 11.6 No Inadequate safe yield.
8.1, 8.2 Polecat Creek Lake 14.3 No Inadequate safe yield.
9 Benaja Lake and 40.3 Yes -
Polecat Creek Lake
10 Benaja Lake, Polecat Creek 80.3 No More expensive than recommended altematives. Would require
Lake and Upper Deep River construction of three separate reservoirs. .
Lake -Lower Pool Only
11 Purchase from NA No Inadequate safe yield. Would require return of an equal volume
Winston-Salem of wastewater to Yadkin River Basin; such return is not feasible
for PTRWA members.
12.1, 12.2 Purchase from Jordan Lake 25 No Inadequate safe yield. Long transmission pipeline would make it
vulnerable to water supply interruptions. High pumping head
would make it more sensitive to escalation in energy prices and
inflation.
13 Purchase from Lake Reese 1.2 No Inadequate safe yield.
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• • •
Table 7a (continued)
Summary of Water Supply Alternatives from 1985 CH2M Hill Study
Alternative Description 50-year Safe
Yield (mgd) Recommended
Alternative Reason for Eliminating from Consideration
14 Purchase from Lake 13.6 No Inadequate safe yield.
Mackintosh
15 Purchase from Reidsville 13.3 No Inadequate safe yield.
Reservoir
16 High Point to Greensboro NA No Short-term solution only.
Temporary Exchange
17 High Point -High Rock NA No Inadequate safe yield. Would require return of wastewater to
Reservoir Exchange Yadkin River Basin to overcome legal problems with interbasin
transfer; such return is not feasible for PTRWA members. Other
economic considerations.
18 Yadkin River to 11 No Inadequate safe yield. Would not meet long-term water demand.
Reedy Fork Creek
19 Yadkin River to 5 No Inadequate safe yield. Would not meet long-term water demand.
Upper Deep River
20 Dan River to 11 No Inadequate safe yield. Would not meet long-term water demand.
Reedy Fork Creek
21 Dan River to Reedy Fork 11 No Inadequate safe yield. Would not meet long-term water demand.
Creek via Belews Lake
22 Mayo River to 11 No Inadequate safe yield. Would not meet long-term water demand.
Reedy Fork Creek
23 Yadkin River to 27 No Inadequate safe yield. Would involve interbasin transfer. Long
Cape Fear River Basin transmission pipeline would increase energy/inflation sensitivity
and vulnerability to interruptions from line breakage.
24 Haw River Diversion 11 No Inadequate safe yield. Would not meet long-term water demand.
25 Deep River Diversion 5 No Inadequate safe yield. Would not meet long-term water demand.
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• • •
Table 7a (continued)
Summary of Water Supply Alternatives from 1985 CH2M Hill Study
Alternative Description 50-year Safe
Yield (mgd) Recommended
Alternative Reason for Eliminating from Consideration
26 Groundwater NA No Feasible as an interim supply only. Not viable as a long-term
supply.
27 High Point and Greensboro NA No Inadequate safe yield. Would not meet long-term water demand.
Effluent Recycle
28 Irrigation Reuse NA No Inadequate safe yield. Would not meet long-term water demand.
29 Industrial Water Supply NA No Minimal potential reduction in potable water use; cannot eliminate
the need for further water supply sources.
30 Structural Conservation NA No Not considered as complete alternatives; cannot eliminate the
need for further water supply sources.
31 Economic Conservation NA No Not considered as complete alternatives; cannot eliminate the
need for further water supply sources.
32 Ordinances Conservation NA No Not considered as complete alternatives; cannot eliminate the
need for further water supply sources.
33 Risk Management NA No Not considered as complete alternatives; cannot eliminate the
need for further water supply sources.
NA Not a significant source of supply for meeting long-term water demands.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.2 Discuss the yield capacity of both SC The 1992 Water Supply Plan for the City of Burlington lists two water
Lake Cammack and Lake Mackintosh NAS supply sources for the City: Lake Mackintosh, with a 20-year safe
for the alternative of buying water C-AH2 yield (SYZo) of 36 mgd, and Stony Creek Reservoir, with a SYZO of 12
from Burlington. Evaluate yield C-AH5 mgd. Lake Cammack is upstream of and drains into the Stony Creek
capacity and cost of purchasing C-AS Reservoir. The total SYZO for the two sources is assumed to be 48
water from Burlington. mgd. Both water supply sources are used to meet the water
demands of the City of Burlington. The projected year 2020 water use
for the City of Burlington from the City's 1992 Water Supply Plan is
14.2 mgd. The 1992 Water Supply Plan also indicated that the total
contract amount for purchase of water from the Burlington system by
other jurisdictions was 4.27 mgd. The sum of the 2020 water demand
for the City of Burlington and the current total contract amount for
water supplied to other jurisdictions is approximately 18.5 mgd.
Allowing for increases in the water demand for the City of Burlington
from 2020 to 2050, it is estimated that less than 20 mgd would be
available in 2050 for sale to other water systems. Therefore, the
altemative of purchasing water from the City of Burlington would not
meet the projected water demand for the PTRWA members for the
50-year planning period and is not a feasible altemative. In addition,
the City of Burlington has expressed a willingness to sell water to
Greensboro in an emergency or on a short-term basis only. Section
3.2.5 of the FEIS includes the above information for the alternative of
purchasing water from other municipalities (Altemative D).
2.3 Evaluate the lower pool option for the SC The Upper Deep River Lake alternative in the EIS (Altemative A) is
Upper Deep River Lake alternative. NAS the same as the lower pool option presented in the 1985 CH2M Hill
C-AH2 report. Therefore, this alternative has already been evaluated. No
C-AH5 revisions to the EIS are necessary. Also, see response to Comment
2.8 below.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.4 More thoroughly evaluate the "No SC The "No Action" alternative would have severe implications for the
Action" alternative. C-AH1 health, safety and economic conditions of the PTRWA member
C-AH2 governments. Most environmental effects would be eliminated.
However, water quality downstream of existing water supply
reservoirs would be negatively impacted by the reduction in flows
during drought periods. The "No Action" alternative would not meet
the purpose and need of the PTRWA members and is not a feasible
alternative. No revisions to the EIS are necessary.
2.5 Consider recycling/reuse of SC The use of reclaimed water is discussed in Appendix A, page 14 of
wastewater as an alternative to the DEH the EIS. The proposed project involves the recycling of wastewater
proposed project. HRA in that the wastewater effluent from the High Point Eastside WWTP
would be discharged to the proposed Randleman Lake and would be
used for water supply for the PTRWA members. Use of reclaimed
water, especially for irrigation of golf courses, parks or large
landscaped areas, is likely to .increase over the 50-year planning
period and could contribute to reductions in water demands for the
PTRWA members. Reductions of significant magnitude to eliminate
the need for the proposed project are unlikely. Therefore, this is not
considered a feasible alternative. No revisions to the EIS are
necessary.
2.6 Evaluate all primary and secondary SC All feasible alternatives to the proposed project were considered and
alternatives. C-AH2 are discussed in the FEIS. Previous reports on water supply
alternatives for the Upper Cape Fear River Basin (CH2M Hill, 1995;
Black and Veatch, 1991; NCDEHNR, 1991) evaluated other
alternatives. Alternatives determined to be infeasible based on
previous reports were not evaluated in the EIS. A summary of the
alternatives evaluated in the CH2M Hill report is included in Section
3.1 of the FEIS (see response to Comment 2.1).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.7 Discuss the differences between the DWQ1 The alternatives in the EIS are the same as those in the 1991
alternatives in the 1991 DWR EIS NCDWR EIS except for the addition of Alternatives D, E, F, and G,
and the DEIS. Discuss why the which were added during review by the U.S. Army Corps of
selection of alternatives has Engineers. These alternatives were added to meet the Federal
changed. requirement for NEPA documents that a suitable array of alternatives
be considered. No revisions to the EIS are necessary.
2.8 Consider a redesigned Alternative A DWQ1 The Upper Deep River Lake alternative (Alternative A) in the EIS is
(Upper Deep River Lake) that would C-AH2 the same as the Upper Deep River Lake -Lower Pool altemative in
not flood the Seaboard Chemical C-AH5 the 1985 CH2M Hill report. Alternative A would flood the High Point
Corporation, High Point Landfill, or EPA Eastside WWTP despite the fact that the cost of relocating the plant
High Point Eastside WWTP sites. was not included in the costs for this altemative in the 1985 CH2M Hill
Include CH2M Hill (1985) comments report.
on this alternative.
A redesigned Alternative A to eliminate flooding of the Eastside
WWTP was not considered in the 1985 CH2M Hill report. It would
require the normal pool for the Upper Deep River Lake to be reduced
from the proposed 715 feet m.s.l. to around 682 feet m.s.l., or the
same as the normal pool elevation for the proposed Randleman Lake.
It is estimated that this would reduce the 50-year safe yield for the
Upper Deep River Lake to less than 20 mgd. This revised altemative
would not meet the purpose and need of the PTRWA members and
is therefore not a feasible alternative. No revisions to the EIS are
necessary. .
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.9 Include the increased cost for
remediation of the Seaboard
Chemical Corporation and High Point
Landfill sites in the cost of the
proposed project. Discuss the
impacts (both economical and
environmental) associated with the
level of groundwater clean-up that
would be required with and without
the proposed project. Discuss
additional clean-up measures
required for the proposed project.
2.10 For the recommended alternative,
discuss the potential cost to build a
water treatment plant with the
advanced technology necessary to
treat the water quality expected in the
proposed lake, e.g., activated
carbon, membrane filters, or auxiliary
treatment lagoons.
DWQ1 Remedial investigation studies are in progress. Results of these
DWQ2 studies are not yet available (see response to Comment 5.1).
However, recent evaluations have been conducted by Tetra Tech,
Inc. (Hazen and Sawyer, 1998) for ten organic solvent priority
pollutants which have been detected in groundwater at the site.
Based on these evaluations, no violations of water quality standards
associated with groundwater loading from the Seaboard Chemical
Corporation or High Point Landfill sites are expected (see response
to Comment 5.1). Therefore, no additional costs are anticipated for
remediation measures at these sites as a result of the construction of
the proposed lake. No revisions to the EIS are necessary.
DWQ1 No additional water treatment costs are required as a function of the
EPA expected water quality in the proposed lake. Ozone is proposed to be
used for disinfection and will provide state-of-the-art disinfection
performance for removal of Giarrlia and Cryptosporidium and for taste
and odor control. Two of the plant's four filters are proposed to be
biological activated carbon (BAC) filters for taste and odor control.
However, the proposed level of technology is the same as that which
would be used for any surface water supply reservoir in the Piedmont
of North Carolina in order to meet expected drinking water standards.
No revisions to the EIS are necessary.
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•
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.11 Revise Table 10 on Page 3-16 to DWQ1
include whether or not each
alternative would meet State water
quality standards.
Table 10 of the FEIS includes information on the capability of meeting
applicable State water quality standards for each alternative. Based
on water quality modeling conducted for the proposed Randleman
Lake, it is predicted that the chlorophyll a standard would be
exceeded in portions of the lake during the growing season. For the
Upper Deep River Lake, the capability of meeting the standards has
not been determined and would depend on the location of the effluent
discharge for the High Point Eastside WWTP, which would need to be
relocated for this altemative. The expected water quality for the
Altamahaw Lake alternative has also not been determined; its water
quality would be affected by the fact that it would receive the effluent
from the Reidsville WWTP. For the alternatives involving Benaja
Lake and/or Polecat Creek Lake, the water quality would be expected
to be good because these lakes would be located in less developed
watersheds compared to the other reservoir alternatives.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.12 Consider alternative of withdrawal
from the Dan, Mayo or Yadkin Rivers
DEH Water supply altematives involving withdrawal of water from the
C-AH2 Yadkin, Mayo and Dan Rivers were considered in the 1985 CH2M Hill
water supply altematives study. Detailed costs were prepared for the
alternative involving transfer of water from the Yadkin River to the
Cape Fear River Basin. While this altemative was considered
desirable from a reliability standpoint, it required an off-stream
emergency storage reservoir to provide a source of supplemental
water during drought periods. This altemative provided a safe yield
of only 18.8 mgd and its costs per mgd of supply were significantly
higher than those for the Randleman Lake altemative. In general,
long transmission pipelines would be required for all of these
altematives, resulting in increased pumping costs, and consequently
greater sensitivity to increasing energy costs and inflation. Because
of the long pipelines, these sources would also be subject to
interruptions from line breakage. These alternatives would involve
interbasin transfers and would require serious legal and political
issues to be resolved before they can be implemented.
Because these alternatives were evaluated in the 1985 CH2M Hill
report and determined not to be feasible compared to the proposed
Randleman Lake project and the other alternatives evaluated in the
EIS, they are not evaluated in detail in the FEIS. Additional
information is provided in Section 3.1 and Table 7a of the FEIS on
these and other alternatives evaluated in the 1985 CH2M Hill report
(see response to Comment 2.1 above).
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i • •
SUMMARY OF DEIS COMMENTS
COMMENT
2.13 Discuss reasons for eliminating DEH
Alternative D, Purchase of Water HRA
from Burlington andlor Winston- C-CH
Salem, from detailed evaluation. CCNC
Discuss serious deficiencies that
make this alternative unacceptable.
COMMENTOR RESPONSE
Purchasing water from Burlington was eliminated from detailed
evaluation because the City of Burlington has expressed a willingness
to sell water to Greensboro in an emergency or on a short-term basis
only. In addition, limited safe yield prevents this alternative from being
considered a long-term water supply source for the PTRWA
members. This alternative would also not serve as a regional water
supply source since it would only address the water supply needs of
one of the PTRWA members (i.e., the City of Greensboro). See
response to Comment 2.2 above.
The alternative of purchasing water from Winston-Salem was
evaluated in the 1985 CH2M Hill report and was eliminated from
further consideration because Winston-Salem would have required
the purchaser to return an equal volume of water to the Yadkin River
Basin and because there are no significant discharges to the Yadkin
River Basin by the PTRWA members. This alternative would also not
meet the long-term water supply needs of the PTRWA members
because of limitations in available treatment plant capacity. Section
3.1 and Table 7a in the EIS include additional information on this
alternative and other alternatives evaluated in the 1985 CH2M Hill
report.
2.14 Consider water conservation
alternative.
HRA
C-CH
CCNC
C-NC
See response to Comment 1.2 above.
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.15 Consider the dollar value of free- RRA1 Section 5.3.5.2 of the EIS indicates that 28 miles of free-flowing
flowing streams in the evaluation of streams would be lost through inundation by the proposed project.
alternatives. This is an adverse impact of the project. However, the proposed
project would also have the effect of moderating high flow conditions
and augmenting low flow conditions downstream in the Deep River.
There is no established basis for determining the dollar value of free-
flowing streams. The different amounts of free-flowing streams
inundated are considered in the qualitative evaluation of the
environmental effects of the feasible altematives. No revisions to the
EIS are necessary.
2.16 Discuss all feasible alternatives. C-AH1 See response to Comment 2.6 above.
2.17 Explain why costs for some C-AH2
alternatives increased more than
others compared to the costs
presented in the 1991 EIS (p. 3-12
and Appendix A, p. 80).
Tables 12c through 12f in the FEIS present revised reservoir
development cost estimates for the alternative reservoir projects.
These costs were developed based on the following sources for each
alternative: (1) estimates of road relocation costs based on the
number of roadways to be abandoned, the roadway miles for
roadways for which the structure would be replaced and the roadway
raised, and unit costs estimated from average unit costs for the
proposed Randleman Lake road relocations and abandonments
(NCDOT 1995), (2) estimated RCC dam costs based on a ratio of
dam cross-sectional area at normal pool level for each altemative vs.
the cross-sectional area for the proposed Randleman Lake dam, and
(3) estimated costs for land purchase, land clearing and land for
wetlands mitigation based on estimated lake area, buffer area, and
land area required for mitigation and unit costs for the proposed
Randleman Lake alternative (Table 12). Costs in the 1991 EIS were
based on updated costs from the 1985 CH2M Hill report. No data is
available on the methodology used to determine the costs in the
CH2M Hill report. Therefore, it is not possible to determine the
reasons for relative cost differences between the FEIS and the 1991
EIS.
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.18 Include increased pretreatment costs C-AH2
for industries discharging to the High
Point Eastside WWTP in the costs
for the Randleman and Upper Deep
River alternatives.
Based on the speculative limits for the Eastside WWTP received from
NCDWQ on September 19, 1995, only two parameters would have
more stringent NPDES permit effluent limits if Randleman Lake is
constructed. These are: (1) phenols, for which a limit of 1.0 ug/L will
be applied if Randleman Lake is constructed and no limit will be
applied without Randleman Lake, and (2) nickel, for which the limit will
be reduced from 88 ug/L to 25 ug/L if Randleman Lake is constructed.
No additional pretreatment measures are expected to be required for
industrial dischargers to allow the Eastside WWTP to meet the more
stringent limits. The more stringent nickel limit has already been
included in the Eastside WWTP's headworks analysis, which is used
for allocating pollutant loadings to the existing industrial dischargers.
No problems are anticipated in meeting the tighter nickel limit for
existing and projected future residential, commercial and industrial
flows. Based on discussions with City of High Point staff, the City
does not agree with the proposed phenols limit and intends to contest
the imposing of this limit when a draft permit for the proposed
expansion of the Eastside Plant is issued by NCDWQ. The City
believes that the total phenols test is less accurate than the chemical-
specific tests the City currently runs quarterly as a part of its Annual
Pollutant Analysis Monitoring (APAM) requirement. These tests are
run using gas chromatograph/mass spectrometer (GC/MS)
techniques. No concentrations above quantitation limits were
observed for any phenolic compounds in the APAM testing over the
period from January 1996 through January 1998. Additional
information on phenolic compounds is included in the analysis of
potential water quality impacts from toxic organic chemicals in the
Nutrient Reduction Strategy and Implementation Plan for the
proposed lake (Hazen and Sawyer, 1998). No revisions to the EIS
are necessary.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.19 Include the cost of the C-AH2
comprehensive management plan
required to address nutrient problems
and the wetlands mitigation issues in
the alternatives evaluation.
2.20 Include the costs of implementing C-AH2
watershed land use restrictions for
the alternatives involving new water
supply sources. Include the
additional costs for implementing
water quality controls.
2.21 Include the Lake Mackintosh C-AH5
alternative on the map following Page
1-4.
2.22 Clarify the safe yield of the proposed C-AH5
Randleman Lake, including
consideration of wastewater
discharges to the lake.
It is assumed that wetlands mitigation issues and/or nutrient problems
would need to be addressed for all altematives which involve water
supply reservoirs. Therefore, similar costs would be required for
development of management plans for nutrient loadings and/or
development of wetlands mitigation plans. In addition, these costs
are difficult to predict and are not expected to be significant compared
to the total projected costs for the alternatives. For these reasons, it
is not considered necessary to include these costs in the altematives
evaluation. No revisions to the EIS are necessary.
See response to Comment 2.19 above.
Lake Mackintosh is not included on the map because it is not a water
supply alternative being evaluated in the EIS. Alternative D consists
of the purchase of water from Burlington and is not dependent on the
specific source of the water supply. No revisions to the EIS are
necessary.
Based on a safe yield analysis conducted by Black ~ Veatch (1990)
(DEIS, Appendix A), the safe yield of the proposed Randleman Lake
would be approximately 54 mgd. This is based on a wastewater
discharge from the Eastside WWTP of 12 mgd. This value is based
on a return ratio of 0.68 and a combined safe yield of 18 mgd from the
City's existing water supply reservoirs, Oak Hollow Lake and High
Point Lake. Assuming the same return ratio is applied to the City of
High Point's allocation of water from the proposed Randleman Lake
(10.08 mgd), the additional wastewater discharge to the proposed
lake would be approximately 7 mgd. This would increase the
expected safe yield from the proposed lake to approximately 61 mgd.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.23 Provide greater detail for Alternatives EPA
E and F on the use of groundwater C-CH
for water supply (pp. 3-9, 3-10). CCNC
The use of groundwater to meet the water supply needs of the
PTRWA members (Alternative F) is not feasible because of excessive
costs for a large groundwater system and the limited yield of
groundwater resources in the Deep River Basin. According to the
1992 Water Supply Plans, only one municipal or county water system
in the Deep River Basin, the Lee County-Tramway System, currently
uses groundwater wells for water supply. The Lee County-Tramway
System reported an average daily water use in 1992 of 0.146 mgd
from one groundwater well. The Plan indicated that the well depth
was 400 feet and its safe yield was 0.382 mgd. The combined 12-
houryield of all wells in the system was listed as 0.393 mgd. Based
on the above information, the capability of developing a groundwater
well system with a safe yield of 48 mgd, or even 22 mgd, at a
reasonable cost is considered unlikely. Use of groundwater to meet
a portion of the total water supply need of the PTRWA members
(Alternative F) is considered a feasible alternative and is evaluated in
the FEIS in Section 3.3. However, because of excessive costs,
excessive wetland impacts of the reservoir component of this
alternative, limited well yields, and the difficulty of implementing a
large-scale groundwater well system in the Piedmont Triad region,
Alternative F is not recommended. No revisions to the EIS are
necessary.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.24 Indicate how the $200,000 cost for DWQ1
cleaning up the old Randleman Dump
was derived.
The cost estimate for cleaning up the old Randleman Dump was
based on an estimated volume of material for removal and disposal
of approximately 32,270 cubic yards (based on a depth of materials
of 10 feet and an area of 2 acres). The estimated costs for cleanup
are listed as follows:
Loading $ 50,475
Hauling 107,640
Disposal 67.275
Total $225, 390
Section 5.3.5.4 of the FEIS includes the above cost breakdown. The
summary of costs for the project alternatives in Table 13 includes the
estimated cost for the proposed cleanup.
2.25 Include in the alternatives evaluation EPA No additional capital or operation and maintenance costs are
the increased capital and operation anticipated for the High Point Eastside WWTP and the Randleman
and maintenance costs at the WTP as a result of the discharge of treated wastewater to the
Eastside WWTP and the proposed proposed lake. No additional treatment processes are required at the
Randleman WTP associated with High Point Eastside WWTP since only two parameters will have more
discharge of treated effluent to the stringent effluent limits as a result of discharge to a proposed water
proposed lake, the eutrophic supply reservoir. Effluent concentrations for these parameters are
conditions in the lake, and the use of expected to be controlled by process modifications and/or other
the fake for water supply purposes. measures for industrial dischargers to the Eastside WWTP (see
response to Comment 2.18). No additional treatment costs are
anticipated at the Randleman WTP (see response to Comment 2.10).
No revisions to the EIS are necessary.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.26 More thoroughly explain project costs EPA
for the alternatives, including those
for the proposed project, Alternative
A and Alternative F (Table 1, Table
13).
2.27 Discuss whether the proposed
project forecloses any options for
water supply in 40 years.
2.28 Consider High Rock Lake on the
Yadkin River as a source of water
supply.
More detailed project costs are presented in the FEIS for the
proposed project and Alternatives A, B, C and F (see response to
Comment 2.17). For the proposed project, estimated road relocation
costs and reservoir development costs are presented in Tables 12a
and 12b, respectively. Costs are presented in Tables 12c through 12f
for the reservoirs for Alternatives A, B and C, including the reservoir
for Alternative F. Road relocation and reservoir development costs
for the alternative reservoir projects were estimated based on a
comparison with the more detailed costs prepared for the proposed
Randleman Lake project. Other cost items were estimated using the
unit costs included in the notes in Table 13.
EPA The proposed project does not foreclose any options for water supply
at the end of the 50-year planning period. Benaja Lake, Polecat
Creek Lake and Altamahaw Lake would still be able to be developed
for water supply purposes in the future assuming development does
not occur which would preclude this use. It may also be possible to
increase the water level of the proposed Randleman Lake to increase
its safe yield subject to the same considerations about development
which may occur around the proposed lake. No revisions to the EIS
are necessary.
EPA The alternative of withdrawing water from High Rock Lake in the
Yadkin River Basin was considered in the 1985 CH2M Hill study. This
altemative was eliminated from further consideration because of the
need to return wastewater effluent to the Yadkin River Basin to
overcome some of the legal problems associated with interbasin
transfer, and because it was not regarded as a viable water source
due to low lake levels in early 1985, at the time the report was written.
Economic considerations also made this alternative less attractive
compared to the other alternatives. Based on the above factors, this
alternative is not considered feasible and it is not evaluated in detail
in the EIS (also see response to Comment 2.12). Section 3.1 and
Table 7a include additional information on this altemative (see
response to Comment 2.1).
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•
• •
Table 12b
Randleman Lake Dam Conceptual Design
Estimated Construction Cost, RCC Dam - 500-Foot Wide Spillway on Dam
Item Estimated Quantity Unit Unit Price Estimated Amount
Mobilization 1 JOB L.S. $650,000
Clear and Grub 65 AC $2,000.00 $130,000
Strip and Stockpile 30,000 CY $3.50 $105,000
Dewatering Excavations 1 JOB L.S. $500,000
Found. and Stlbsn. Exc. Com. 123,500 CY $6.00 $741,000
Rock Excavation 40,000 CY $30.00 $1,200,000
Dental Excavation 1,000 CY $10.00 $10,000
Dntl./Lvl. Conc. and Grt. Cap 3,000 CY $100.00 $300,000
Found. Grouting 1 JOB L.S. $1,200,000
RCC Dam 149,700 CY $45.00 $6,736,500
Formed Conc. & Steel 1,700 CY $515.00 $875,500
Conc.Sp. Crest 1,120 CY $200.00 $224,000
Facing Concrete 6,370 CY $200.00 $1,274,000
River Diversion 1 JOB L.S. $500,000
Earth Embank. 98,800 CY $4.00 $395,200
Earth Embank. Drain 20,000 CY $35.00 $700,000
RCC Drain (Dam and Found.) 1 JOB L.S. $250,000
Toe Drain 620 LF $10.00 $6,200
Riprap 4,300 CY $40.00 $172,000
Riprap Bedding 1,075 CY $40.00 $43,000
Spread Topsoil and Seeding 1 JOB L.S. $20,000
Drainage Gallery 1 JOB L.S. $150,000
Ventilation System 1 JOB L.S. $20,000
Gates 1 JOB L.S. $200,000
Hydraulic Controls 1 JOB L.S. $50,000
Stoplogs 1 JOB L.S. $100,000
Elect. Systems 1 JOB L.S. $100,000
Subtotal x16,652,400
Contingency ~ 20% x3,330,480
TOTAL x 19,982,880
Source: Phase I Hydrologic and Hydraulic Analyses and Conceptual Design Alternatives for the Proposed Randleman Lake Dam, GEI Consultants,
April 25, 1995.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.29 Include miles of roadways and EPA
railways impacted in the alternatives
evaluation (pp. 3-14 to 3-18). Include
effects on downstream
geomorphology, wetlands and
endangered and threatened species
(Section 4). Include effects on
basins receiving interbasin transfers
(Section 4).
~ ~ ~~
17 ~~
l:
~'~
~~--
!`~ °
,~~".,
Table 10 of the FEIS includes reference to miles of roadways and
railways impacted for each alternative. Effects on downstream
geomorphology were not expected to be significant for the altemative
reservoirs considered. Each would moderate high flows by holding
back water during high flow events, thereby reducing scouring during
high flow conditions. The effects of these reductions in maximum
flows have not been determined; however, these effects are not
expected to significantly impact the evaluation of altematives in the
EIS. Effects on maximum flows in basins receiving interbasin
transfers are not expected to be significant because the volume of
flow transferred is small compared to maximum stream flows during
flood events. The amount of flow which would be transferred to the
Haw River Basin is 18.5 mgd (44.1 cfs). Based on USGS streamflow
data for the Haw River at Haw River, the maximum daily flows for
calendar year 1994 and water year 1995 (October 1994 through
September 1995) were 9,240 and 19,900 cfs, respectively.
Therefore, impacts on downstream geomorphology for basins
receiving interbasin transfers are also not expected to be significant
for the alternatives being considered in the EIS.
Attenuation of flood peaks can result in reductions in overbank
flooding and can have negative impacts on downstream wetlands.
The magnitude of these impacts has not been determined, although
it is expected to be small. The proposed project would also have
short-term effects on downstream wetlands from construction of the
proposed dam, including increased sediment and altered streamflows.
Effects on downstream wetlands for basins receiving interbasin
transfers are expected to be minimal because of limited impacts on
maximum streamflows. Section 3.3.2 (Table 10), Section 5.3.8 and
Section 5.3.5.8 of the FEIS include reference to expected impacts on
downstream wetlands.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.29 (Continued)
2.30 Provide a wetlands inventory for EPA
alternatives.
~-- , J~ ~l
C~
Effects on downstream endangered and threatened species are
discussed in Section 5.3.11 of the FEIS. The Cape Fear shiner is the
only endangered or threatened species located within the potential
realm of influence of the proposed project. Impacts on this species
are not expected to be significant. There are no known endangered
or threatened species in the Haw River upstream of Jordan Lake.
Therefore, no adverse impacts on endangered and threatened
species are expected from interbasin transfer to the Haw River Basin.
Section 5.3.5.8 of the FEIS includes the above information on impacts
on endangered and threatened species in basins receiving interbasin
transfers.
(' Wetlands have not been delineated for the altemative reservoir
projects. However, site visits have been made for the purpose of
;' gathering comparative information on the presence of jurisdictional
;' wetlands and general habitat conditions (Carter, 1995). Pertinent
~, aerial photography, topographic maps and soils maps were also
reviewed. Based on these evaluations, the amount of wetlands to be
impacted for the altematives involving Altamahaw Lake, Benaja Lake
' and Polecat Creek Lake would be significantly more than for the
proposed Randleman Lake altemative. Therefore, additional field
'~~ delineation of wetlands for these alternatives is not considered
`, justified.
i
Impacts on wetlands for the Upper Deep River Lake (Alternative A)
are expected to be similar to those for the proposed project.
However, the cost of this alternative is significantly higher, it has a
~ lower safe yield, and it would inundate more of the High Point Landfill
and the Seaboard Chemical Corporation site than the proposed
project. It would also require relocation of the High Point Eastside
WWTP, which is the main reason for its higher cost. It is also not
feasible to construct the Upper Deep River Lake at a lower pool
~ elevation to eliminate flooding of the Eastside WWTP because that
would reduce the reservoir safe yield to such a point that it would not
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
2.30 (Continued) meet the purpose and need for the proposed project (see response
~- to Comment 2.8). Therefore, field wetlands delineation is also not
- considered necessary for the Upper Deep River Lake altemative
because other factors make the Randleman Lake altemative the
preferred alternative. No revisions to the EIS are necessary.
2.31 Consider smaller impoundment. CCNC A smaller impoundment would not fully satisfy the PTRWA's purpose
and need for a regional water supply source that would meet the
needs of the PTRWA members to the year 2050. A smaller
impoundment would not significantly reduce the environmental
impacts of the proposed project and would require the PTRWA
members to develop additional water supply sources to meet future
needs sooner than the end of the 50-year planning period. This would
increase costs for the PTRWA members and their customers and
would likely result in increased environmental impacts compared to
the proposed project. No revisions to the EIS are necessary.
2.32 Evaluate water conservation C-MSM Water conservation measures implemented by the ,cities of
alternative. Address techniques and Greensboro and High Point include the adoption of plumbing code
strategies outlined in two attached requirements for water-saving devices, leakage and water loss control
papers. programs, industrial water conservation programs, and meter
replacement programs. Public education programs and rate structure
changes are also expected to provide reductions in water demand
over the planning period (see Section 2.5 of the FEIS).
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• • s
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
2.32 (Continued) The Greensboro Utilities Department opened its Water Conservation
Office in October 1994, and it currently includes a staff of one person
and a budget of $140,000. The Office primarily targets residential
water users and offers public education, technical assistance and
water-saving hardware. The City's public education effort, which
includes demonstration projects, news releases, print advertising,
radio talk shows, and television commercials, captured the U.S. EPA
Region IV 1st Place "Public Education" award for 1997. High levels
of customer participation in the City's hardware distribution programs
have resulted in 12,000 toilets and 7,000 shower stalls being
upgraded to water-saving status. The City's hardware effort captured
the U.S. EPA Region IV 1st Place "Case Study" award for 1996.
Under the City's technical assistance program, commercial properties
are offered free hardware in exchange for the City's right to publicize
"before" and "after" findings. Three apartment demonstration projects
participating in the program cut water use by amounts ranging from
25 to 40 percent. Plans are underway for the expansion of
Greensboro's water conservation effort.
Another water conservation technique which can be considered is
discounts on per-unit hookup fees for new construction which
incorporates reduced turf area. Giveaway programs for high-
efficiency shower heads and faucets and rebate programs for use of
ultra-low-flush toilets, like those implemented by the City of
Greensboro, can also be considered. Installation of water saving
devices and landscapes at public buildings can also allow such
hardware and landscapes to become familiar and acceptable to the
people who use them and can speed up adoption by the general
public. These additional measures are discussed in Section 2.5 of
the FEIS. Also see response to Comment 1.2 above.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
;'
3. WETLANDS IMPACTS /MITIGATION
3.1 No objections to the project from a
wetlands perspective.
3.2 Indicate the number of river miles
that will be protected by the Cone's
Folly preservation site.
3.3 Provide details on the wetlands
mitigation plan.
COMMENTOR RESPONSE
EPAW
WRC
NAS
;~ ~ /~
~r
i
~"
' ~ `~ti~
v' ~ U~
~f~~ti
C/"
~~~~
The PTRWA agrees with this comment. No revisions to the EIS are
necessary.
Section 5.8.3 of the FEIS includes a statement that 8.5 river miles will
be protected at the Cone's Folly preservation site.
J c ~ ~~~
~w
Section 5.8.3 of the FEIS includes additional information on the
wetlands restoration and/or creation sites. All of the proposed sites
exhibit the potential for wetland restoration with appropriate
modifications to hydrological regimes. A summary of estimated
acreages for the proposed mitigation sites is presented in Table 35.
The sites, which comprise 31,900 linear feet of stream channel and
174 acres of floodplain/terrace, are expected to provide 122 acres of
compensatory mitigation for the proposed Randleman Reservoir. The
two mitigation methods proposed, in-stream structures (Option 1) and
green tree impoundments (Option 2), are expected to restore wetland
hydroperiods and functions while maintaining existing forests or
supporting the growth of shrub emergenUforested wetlands.
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• • •
Table 35
Estimated Acreage of Mitigation Design Units
Mitigation Design Unit
In-Stream Habitat
Length of Average Width of and Upland Stream-
Stream Valley Floodplain Total Area Side Levees Existing Wetlands Wetland Restoration
Mitigation Site (feet) (feet) (acres) (acres) (acres) (acres)
In-Stream Structures
Archdale 3,200 150 10 4 1' S
Hickory Creek 3,500 310 25 7 3 15
Mile Branch 1,100 200 5 1 1' 3
Muddy Creek 2,200 260 13 5 1 7
Kersey Valley 4,100 150 142 4 1' 4
Richland Creek 3,300 660 50 8 7 35
Subtotal 69
Green Tree Impoundments
Bob Branch 1,800 190 8 ----- 1' 7
Edgar (Upper Muddy) 6,600 150 23 -- 2' 21
Reddicks Creek 3,900 210 19 --- 0 19
Sophia 2,200 150 7 -- 1' 6
Subtotal 53
TOTAL 31,900 -- 174 29 18 122
Notes:
' The acreage of existing wetlands has been estimated by assuming an average of 10% of low-order, Piedmont floodplains support
jurisdictional wetlands.
2 The approximately 14-acre acquisition boundary includes areas near secondary roads that may not provide restorable wetlands. The
potential for hydraulic impacts to adjacent properties and structures must be determined at all potential mitigation corridors.
3 Floodplain widths and acreages have been estimated based on available topographic mapping and limited field reconnaissance.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
3.3 (Continued) Option 1 includes stream modifications which will reduce the rate of
groundwater discharge and restore wetland hydroperiods within
adjacent floodplains. This mitigation option is proposed for the
Archdale, Hickory Creek, Mile Branch, Muddy Creek, Kersey Valley,
and Richland Creek sites. Decreases in cross-sectional area are
often achieved in a cost effective manner through placement of in-
stream structures. Structures should be placed along existing
nickpoints within the stream corridor. Nickpoints represent natural
% grade control features in the channel which limit entrenchment in the
upstream direction. At Randleman, these nickpoints are frequently
bedrock outcrops occurring at various intervals along the channel. To
minimize stream adaptions, nickpoints can be elevated by the use of
,~" constructed riffles (rip-rap aprons), gabions, weirs, or natural
materials (coarse woody debris). Rip-rap aprons can be placed along
the riffle for an average 15 feet of stream length and at a target
thickness designed to reduce the effective depth of the channel to
approximately 1 foot below the adjacent floodplain. The apron can be
designed with river or quarry rock sized to limit entrainment and to
f direct high energy flows away from the channel banks. Based on
1 preliminary field surveys, the constructed riffles will occur, on average,
at 200-foot intervals within the stream corridor (17,400 linear feet of
r channel, 87 constructed riffles). However, final structural elevations
,~ will be determined based upon detailed field surveys and actual
elevations within site interiors. If nickpoints are not available within a
200-foot reach of channel, structures may be considered which mimic
the stream dynamics along natural outcrops in the upstream and
downstream direction. Invariably, constructed riffles will be placed
immediately below in-stream pools identified at each site. This design
for in-stream structures may reduce stream migration and promote
passive meander formation or stream braiding over a relativel~C longer
period of time.
Page 32

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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
3.3 (Continued) ~ Vegetation plantings should include characteristic tree species of
~~ value to wildlife which are capable of survival in floodplain wetland
conditions. Tree species may include willow oak, overcup oak,
swamp chestnut oak, green ash, river birch, American sycamore,
cherrybark oak (Quercus pagoda), and/or swamp cottonwood
(Popu/us heterophylla). Planting of shrub species such as tag alder
(A/nus serru/ata), buttonbush (Cephalanthus occidentalis), elderberry
(Sambucus canadensis), Viburnums (Viburnum spp.), and willows
(Salix spp.) will also assist in stream bank stabilization and cover, if
needed.
Construction of green tree impoundments (Option 2) was considered
for sites where in-stream structures failed to restore wetland
hydroperiods in adjacent flood plain areas. Sites supporting pasture
lands, Congaree soils, and/or heavily degraded streams (relatively
high floodplain slopes (>0,007 rise/run}) were not projected to support
wetlands within adjacent stream terraces. This green tree
impoundment option is proposed for the Bob Branch, Edgar (Upper
Muddy), Reddicks Creek, and Sophia sites.
Green tree impoundments comprise a series of floodplain levees and
i" controllable outlet structures which are raised during winter months
/ and lowered in early spring. Levee systems should be constructed to
/ provide for less than 2 to 3 feet of inundation during winter months.
Impoundments would be placed at each 2 to 4-foot rise in the valley
floor, estimated at an average 430-foot spacing along approximately
14,300 feet of channel (25-50 impoundments). Green tree
impoundments are projected to benefit the overall water quality of the
proposed reservoir with respect to sediment loading. Additionally,
nutrient recycling benefits are also expected, as long as wetland
vegetation dominates. However, strict monitoring and management
will be required to ensure the stability and survival of these systems.
Page 33

• ~ •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
3.3 (Continued) Approximately 122 acres of wetlands can be achieved at 10 sites
located within the proposed Randleman Reservoir watershed as
mitigation for wetland losses associated with reservoir construction.
Additional detailed studies will be necessary to refine mitigation
strategies and clarify wetland restoration potential.
The restored wetlands will also control stormwater runoff to reduce
the force of the flowing water and reduce the concentrations of
pollutants carried by the runoff. This will result in an improvement in
the quality of water entering the proposed Randleman Lake.
3.4 Evaluate impacts of wetlands C-N~ Approximately 121 acres of wetlands will be lost to inundation as a
alteration. ~~~ ~ result of the proposed project. Some impacts on downstream
wetlands will also occur. These impacts are discussed in Se
ction
~~ "' _
5.3.8 of the FEIS. See response to Comment 2.29 above.
4. INTERBASIN TRANSFER ,
4.1 To transfer water from the Deep DRPA1 Section 5.3.5.8 of the FEIS addresses the effects of the interbasin
River to the Haw River would be a RRA1 transfers associated with the proposed project. These interbasin
mistake. C-CH transfers have been approved by the N.C. Environmental
Management Commission (Appendix B). Section 5.3.5.8 of the FEIS
includes additional information on the environmental effects of
interbasin transfers (see response to Comment 2.29).
4.2 The EIS should be delayed until the HRA The alternative of withdrawing water from Jordan Lake is discussed
State completes its pending water RRA1 in Section 3.1 of the FEIS. Allocations from Jordan Lake are not
reallocation modeling studies for C-MSE expected to provide adequate safe yield to meet the purpose and
Jordan Lake. WRC need of the PTRWA members to the year 2050. Therefore, this
alternative is not considered a feasible alternative to the proposed
project (see response to Comment 2.1). Therefore, it is not
considered necessary to delay the EIS until the State completes its
pending water reallocation modeling studies. No revisions to the EIS
are necessary.
Page 34

• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
4.3 Evaluate environmental effects of RRA1
interbasin transfer for the proposed C-AH6
project. CCNC
C-NC
4.4 Consider effects of interbasin transfer EPA
to the Haw and Yadkin River Basins
on fluvial geomorphology and
endangered species habitat (pp. 3-4,
5-17, 5-18).
5.
WATER QUALITY
5.1 Include workplan, studies, or SC
Remedial Investigation report DWQ1
conclusions for existing groundwater DWM
contamination from Seaboard C-AH5
Chemical Corporation and High Point WRC
Landfill sites. EPA
See response to Comment 2.29.
See response to Comment 2.29.
Remedial investigation studies for the Seaboard Chemical
Corporation and High Point Landfill sites are in progress. Results and
conclusions of these studies are not yet available. Quantitative
estimates of loading rates of contaminants and firm estimates of rates
of groundwater flow from these sites to the river are also not
available. Since these data are not available, a screening approach
was taken to assess whether the maximum reasonable loading rate
from these sites would potentially result in violations of water quality
standards in the proposed reservoir (Hazen and Sawyer, 1998). This
approach was applied to the ten organic solvent priority pollutants
which have been detected in groundwater at the site and is expected
to greatly overestimate the likely concentrations which will occur in the
lake. However, if these very conservative screening estimates can be
shown to still be below relevant water quality standards, it can be
concluded that contaminated groundwater from the sites will not result
in excursions of water quality standards in the proposed lake. The
analysis was based on a groundwater flow rate of 5,000 gpd and the
maximum contaminant concentrations detected in the groundwater
monitoring conducted by NCDWQ. The results of this analysis are
summarized below:
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.1 (Continued)
Screening of Toxicants from the
Seaboard Chemical Corporation and Riverdale Drive Landfill Sites
Maximum Screening Concentration
(n9~)

Compound Deep River 1
(Below Source) Deep River 3B
(Water Intake) Standard or
Criterion (ng/L)
Chlorobenzene 382 0.70 488,000
1,2-Dichlorethane 0.65 0.013 380
1,1-Dichloroethylene 2.8 0.052 57
Vinyl Chloride 4.9 0.084 2,000
Benzene 0.016 0.0002 1,190
2-Chlorophenol 1.6 0.036 120,000
Methylene Chloride 7.3 0.13 4,700
1,1,2,2-Tetrachloroethane 6.1 0.13 172
1,1,2-Trichlorethane 2.5 0.054 600
Toluene 17.4 0.29 11,000
Based on the screening analysis, no excursions of water quality
standards associated with groundwater loading from the Seaboard
Chemical Corporation and High Point Landfill sites are expected. The
above information is included in Sections 5.3.5.4 and 5.3.5.6 of the
FEIS.
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•
• ~
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.2 Provide modeling for the 26 mgd SC Modeling has been conducted for the nutrient loading associated with
discharge from the High Point C-AH6 the proposed 26 mgd discharge from the High Point Eastside WWTP,
Eastside WWTP to the proposed as well as the nutrient loadings from other point and nonpoint sources
lake. in the proposed Randleman Lake watershed. Estimates of chlorophyll
a concentrations in the lake were also prepared. A review of this
modeling is presented in the Nutrient Reduction Strategy and
Implementation Plan prepared by Hazen and Sawyer and Tetra Tech,
Inc. (Hazen and Sawyer, 1998). The report also includes responses
to NCDWQ comments on the Draft Nutrient Reduction Strategy and
Implementation Plan submitted to NCDWQ in February 1998. Based
on the Nutrient Reduction Strategy, projected reductions in effluent
phosphorus concentrations from the Eastside WWTP will provide a
reduction in total phosphorus of 50,880 kg/yr from the existing load of
58,070 kg/yr. This is equivalent to a reduction in total phosphorus
loading of 88 percent. Projected reductions in effluent nitrogen
concentrations will provide a reduction in total nitrogen of 74,660 kg/yr
from the existing load of 290,350 kg/yr, or a reduction in total nitrogen
loading of 26 percent. Nonpoint nutrient loads are expected to
increase relative to existing conditions because of increased
development. However, this impact will be mitigated by the proposed
nutrient reduction measures of the Nutrient Reduction Strategy. In an
average flow year, the proposed Nutrient Reduction Strategy is
expected to result in a reduction in total phosphorus loading from
nonpoint sources of 8,000 kg/yr compared to future loadings without
the Nutrient Reduction Strategy.. This is equivalent to a reduction of
20 percent. A reduction in total nitrogen loading from nonpoint
sources of 49,240 kg/yr (13%) is expected compared to future
conditions without the Nutrient Reduction Strategy.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.2 (Continued) The modeling included chlorophyll a predictions for future conditions
with the Nutrient Reduction Strategy in place. During average and
high flow years, the Nutrient Reduction Strategy would result in a
small decrease in predicted chlorophyll a concentrations in all
segments of the proposed lake. The predicted average chlorophyll a
in the lake in low flow years was 20 ug/L, and in average and high
flow years was 19 ug/L. During average flow years, the predicted
chlorophyll a concentration in the Deep River 1 segment, the segment
with the highest chlorophyll a concentration, declines from 95 ug/L
under existing loadings to 67 ug/L for future conditions with the
Nutrient Reduction Strategy. The predicted chlorophyll a
concentrations in Deep River 1 for future conditions with the Nutrient
Reduction Strategy during high and low flow years are 61 and 81
ug/L, respectively. These values can be compared to the existing
water quality standard for chlorophyll a of 40 ug/L. Further reductions
in nutrient loads are not feasible at this time because of technological,
economic and environmental constraints on reducing phosphorus to
achieve very low phosphorus concentrations (0.008 to 0.025 mg/L) at
the Eastside WWTP. The remaining segments of the lake are
predicted to be below 40 ug/L during all flow conditions.
Sections 5.3.5.5 and 5.3.5.6 of the FEIS include a discussion of the
results of the additional modeling conducted for the 26 mgd discharge
from the High Point Eastside WWTP.
5.3 Include a recent toxic substances SC Additional toxic substances evaluations have been conducted for the
evaluation. Seaboard Chemical Co. site and the High Point Landfill (see response
to Comment 5.1). Results of a toxic substances evaluation conducted
in March 1995 by Dr. Patrick Brezonik are also referenced in the FEIS
in Section 5.3.5.6. The. report on the evaluation by Dr. Brezonik is
included in Appendix ' of the FEIS.
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• •
•
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.3 (Continued) Additional toxic substances analyses were conducted on the water
quality in the proposed lake to evaluate impacts of lindane, phenolics
and unidentified organic chemicals detected in NCDWQ monitoring in
the Deep River drainage basin (Hazen and Sawyer, 1998). Lindane
is listed by EPA as a priority pollutant. NCDWQ has adopted a water
quality standard for lindane of 10 nanograms per liter (ng/L) for the
protection of aquatic life. NCDWQ monitoring in 1992 and 1993
detected concentrations of lindane exceeding the water quality
standard. Monitoring conducted by NCDWQ in 1997 found no
reportable concentrations of lindane. The monitoring in 1992-93
found relatively high concentrations of lindane downstream of the
High Point Eastside WWTP. For this reason, the model used for the
toxic substances analyses used the upper bound estimate of mass
loading of lindane (5 ug/s) observed at the monitoring location just
downstream of the High Point Eastside WWTP to provide an upper
bound estimate of in-lake concentrations. Based on the modeling,
estimated upper bound concentrations for lindane during the growing
season were determined as follows:
Deep River 1
(Below Point of Maximum Deep River3B
Lindane Concentrations) (At Water Intake)
Estimated Range, Estimated Range,
Flow Regime Value, nglL ng/L Value, ng/L ng/L
Dry Year (1967) 5.07 3.52-5.86 0.010 0.007-0.24
Wet Year (1975) 2.82 2.44-2.92 0.25 0.043-0.37
In all cases, both the best estimate and the maximum predicted
lindane concentrations at either location are below the State water
quality standard, despite conservative assumptions about loading
rates. Therefore, existing lindane sources do not appear to present
any risk of excursions of water quality standards in the proposed lake.
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• •

SUMMARY OF DEIS COMMENTS
COMMENT
5.3 (Continued)
COMMENTOR RESPONSE
In 1997, NCDWQ sampled the Deep River at various locations for
total recoverable phenolics (phenols). There is currently a State
standard for phenols of 1.0 ug/L for water supply waters. For the
1997 sampling, 36 of 45 samples were greater than 1.0 ug/L, with a
maximum of 52 ug/L. Relatively high concentrations of phenols were
found in the Deep River downstream of the High Point Landfill and the
Seaboard Chemical Corporation site, in Richland Creek upstream and
downstream of the High Point Eastside WWTP, as well as further
downstream in the Deep River. A conservative analysis was
performed to determine the range of concentrations of phenols
expected in the proposed reservoir. The range of predicted phenols
concentrations for various segments of the proposed lake are shown
as follows:
Predicted Phenols Concentration. ug/L
Segment Minimum Maximum
Deep River 1 0.31 4.4
Deep River 2 0.006 0.45
Deep River 3A . 0.00002 0.13
Deep River 3B 0.68 9.0
Muddy Creek 2 2.3 x 10~ 0.10
Near Dam 7.8 x 10-'Z 0.005
These results suggest the possibility of exceeding the State water
quality standard for phenols in the Deep River 1 and Deep River 36
segments. However, once the lake is impounded, residence times
will increase and will lead to increased opportunity for removal of
phenols by biodegradation. Thus, concentrations are expected to
decline rapidly with distance away from any source of loading. In
general, unidentified phenolic compounds are not expected to present
a water quality problem. However, further investigation may be
needed to determine the source of phenols in the proposed
Randleman Lake watershed.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.3 (Continued)
COMMENTOR RESPONSE
Water quality monitoring for organic substances was conducted by
NCDWQ in 1992-93 and 1997 in the Upper Deep River. In reporting
these data, NCDWQ noted the presence of many "unidentified peaks"
in the organics analyses. The unidentified peaks were detected using
EPA-approved gas chromatographic (GC) methods used to monitor
water quality for chlorinated pesticides and PCBs, acid herbicides,
organophosphate pesticides, semivolatile organics and volatile
organics. Unidentified peaks are routinely followed up with additional
analysis using mass spectrometry (MS) methods when the peaks
occur above a threshold activity level (indicating relatively high
concentration). The activity level threshold for proceeding to MS
analysis is equivalent to a concentration in water for most compounds
of approximately 5 ug/L. None of the unidentified peaks on the
chlorinated pesticide, acid herbicide or organophosphate pesticide GC
scans in the Deep River samples were present at sufficient
concentrations to merit further identification by MS methods. This is
an indication that the unidentified compounds were present at low
concentrations. On the semivolatile GC scan, many of the
unidentified peaks are assumed to represent phenolic compounds, as
discussed above. In general, the unidentified peaks likely include a
mixture of naturally-occurring compounds, synthetic compounds
contained in nonpoint stormwater runoff and compounds associated
with the High Point Eastside WWTP. However, the unidentified peaks
are present at concentration below the threshold required to pursue
identification by MS methods and are unlikely to involve a significant
human health risk or adversely affect water quality in the proposed
lake.
Sections 5.3.5.4 and 5.3.5.6 of the FEIS address the toxic substances
evaluations conducted for the proposed project.
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.4 Evaluate the Greensboro "tank farm" SC
along I-40 as a possible source of
existing contamination of the Deep
River. Consider other possible
sources.
The Greensboro "tank farm" (bulk petroleum storage facility along
I-40) is tributary to the East Fork of the Deep River upstream of High
Point Lake, one of the City of High Point's two water supply
reservoirs. Water quality in the Deep River, including the East Fork,
was evaluated in the N.C. Division of Water Quality (NCDWQ) Cape
Fear River Basinwide Water Quality Management Plan (NCDEHNR, .
1996a). According to this report, macroinvertebrate sampling by the
N.C. Department of Environment and Natural Resources during 1993
showed that the water quality in the East Fork was Fair, and indicated
that the stream is adversely affected by nonpoint source runoff, small
dischargers and low summer flows. The report also indicated that the
East Fork was rated as "partially supporting" its designated uses, with
potential sources of pollution being minor, nonmunicipal wastewater
discharges and agricultural runoff. The Greensboro "tank farm" was
not identified as a possible source of existing contamination of the
Deep River in this report. The report also indicated that the NCDWQ
is considering the development of a general NPDES permit for bulk
petroleum storage facilities. According to the report, if tank farm
facilities maintain proper treatment systems and on-site management
practices, the risk posed to surface water quality by their minimal
discharges is negligible. The NCDWQ also recommended that local
emergency management agencies develop extensive contingency
plans to protect water supplies in the event of spills, substantial leaks,
or any other incidental petroleum product releases.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.4 (Continued)
One of the City of High Point's regional stormwater detention ponds,
Piedmont Lake, is located downstream of the tank farm. Due to the
potential for spills from the tank farm, Piedmont Lake has spill
containment capabilities.
The Cape Fear River Basinwide Water Quality Management Plan also
indicated that effluents from municipal wastewater treatment plants
make up the majority of the flow in the Deep River during low flow
periods, resulting in severe water quality problems throughout the
upper portions of the Deep River. Elevated nutrient levels were
measured throughout the Upper Deep River study area during
sampling conducted in 1992 and 1993, as well as violations of water
quality standards for fecal coliforms, dissolved oxygen, lindane and
dieldrin. Metals concentrations higher than action levels were
observed for copper, zinc and iron. These issues are discussed in
Section 4.3.5.2 of the FEIS, which also references planned upgrades
of the High Point Eastside WWTP, which will result in reduced
nutrient loadings to the Deep River. Section 5.3.5.4 addresses
potential sources of discharge of toxic substances to the Deep River,
including the abandoned Seaboard Chemical Corporation site, the
closed High Point Landfill, the Randleman town dump and the
Eastside WWTP. The possible sources of existing contamination of
the Deep River are adequately addressed in the FEIS. Section
4.3.5.2 of the FEIS includes additional information on possible
sources of existing contamination of the Deep River.
COMMENTOR RESPONSE
5.5 The proposed project will result in a SC
violation of the CWA; refer the project
to the CEQ.
The uses of the proposed lake for fish propagation and water supply
are predicted to be supported. Therefore, the proposed project is not
anticipated to result in any known violations of the Clean Water Act.
Modeling conducted for the proposed lake indicates that the State
water quality standard for chlorophyll a is likely to be exceeded in one
segment of the lake (see response to Comment 5.2). For a
discussion of the impacts of the expected chlorophyll a violations, see
the response to Comment 5.10 below. No revisions to the EIS are
necessary.
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~ • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.6 The High Point Eastside WWTP will LC
discharge a large amount of nutrients
to the lake. Chlorophyll a content will
lead to algal blooms and further
enhance eutrophication in the lake.
5.7 Inundation of the Seaboard Chemical LC
Corporation site will add additional
chlorinated solvents to the lake.
5.8 Contaminant loading from the LIA
Seaboard Chemical Corporation and DWQ1
High Point Landfill sites is DWM
significantly higher than that stated in WRC
the DEIS and will contribute to water
quality degradation.
5.9 Develop a Nutrient Reduction DWQ1
Strategy for the Randleman Lake DWQ3
watershed.
See response to Comment 5.2.
The proposed lake will not inundate the Seaboard Chemical
Corporation site. Impacts of the Seaboard Chemical Corporation site
on the water quality of the proposed lake are discussed in Sections
5.3.5.4 and 5.3.5.6 of the FEIS (see response to Comments 5.1 and
5.20).
See response to Comment 5.1.
A nutrient reduction strategy for the Randleman Lake watershed has
been developed and is discussed in Sections 5.3.5.5 and 5.3.5.6 of
the FEIS (see response to Comment 5.2).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.10 Consider impacts of predicted DWQ1 Water quality modeling has predicted that the uppermost portion of
eutrophication of the lake on State WRC Randleman Lake will likely experience eutrophic conditions. Although
instream and in-lake water quality GC water quality modeling may be used to estimate with some confidence
standards, as well as impacts on the concentrations of nutrients and chlorophyll-g in different segments
aquatic life, fishing, wildlife, of a proposed reservoir, and even the expected frequency of nuisance
secondary recreation and agriculture. algal conditions, other effects of eutrophication are more difficult to
Evaluate the potential for extensive predict with any degree of confidence, such as the degree to which
algal blooms, low dissolved oxygen, oxygen will be depleted by decay of algae, frequency of fish kills, and
common occurrence of fish kills, effects of eutrophication on fisheries diversity. For this reason,
decrease in fisheries diversity, taste impacts of eutrophication on Randleman Lake were evaluated by
and odor problems in drinking water, reviewing water quality data and other information from the upper
and reduced opportunities for segments of two existing North Carolina Piedmont reservoirs: Jordan
recreation. and Falls Lakes. These two lakes are similar in morphometry
(although larger in size), physiographic setting, and climate regime to
the proposed reservoir.
Like the proposed lake, Jordan and Falls Lakes have one or more
wastewater treatment plants (WWTPs) discharging into streams that
feed the upper portions of the lakes. Falls Lake has two WWTPs:
the North Durham Water Reclamation Facility (WRF), which
discharges into Ellerbe Creek just upstream of the lake, and the
Butner WWTP, which discharges to Knap of Reeds Creek. Jordan
Lake has two WWTPs just upstream of the New Hope Creek arm of
the lake: the South Durham WRF on New Hope Creek and the
OWASA Mason Farm WWTP on Morgan Creek. Durham County's
Triangle WWTP discharges to Northeast Creek, also draining to the
New Hope Creek arm of Jordan Lake. The treatment plants with the
greatest effluent flow and the most potential impact-North Durham,
South Durham, and OWASA-are operating with state-of-the-art
tertiary treatment, and are under strict effluent limitations similar to the
limits proposed for the expanding High Point Eastside Plant, as
shown in the following table:
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.10 (Continued)
Table 1
Comparison of Effluent Limitations (April-0ctober) at WWTPs on
Jordan Lake, Falls Lake, and the Proposed Randleman Lake
Effluent Limitations
OWASA Proposed
North South Mason Limits for High
Durham Durham Farm Point Eastside
Parameter WRF WRF WWTP WWTP
Design Flow (mgd) 20.0 20.0 9.0 26.0
Ammonia Nitrogen (mg/L) 1.0 1.0 2.0 2.0
Total Phosphorus (mg/L) 0.5 0.5 0.6 0.2'
' The High Point Eastside Plant is expected to have an NPDES permit
limit of 0.5 mg/L total phosphorus, but will aim to meet a monthly
average of 0.2 mglL. Economic incentives are expected to be provided
by the PTRWA to encourage achieving the lower concentration.
Various data and information from the upper portions of Falls and
Jordan Lakes were reviewed. Emphasis was placed on records
since 1990, as the phosphate detergent ban and plant upgrades
have resulted in significant reductions in phosphorus loads since
the early 1990's. Information reviewed included:
• Water quality data collected by the N.C. Division of Water Quality
(NCDWQ) (1990-97)
• In-lake self-monitoring data collected in the lakes by the North
Durham WRF and the OWASA Mason Farm WWTP (monthly or
twice monthly, 1994-1997)
• Records kept by NCDWQ of investigated fish kills (1985-present)
• NCDWQ records of algal bloom investigations (1990-present)
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.10 (Continued) Information gathered in conversations with U.S. Army Corps of
Engineers staff, and with N.C. Parks and Recreation staff
stationed at the two takes, regarding impacts of eutrophication
on recreational use of the lakes
• Information gathered in conversations with N.C. Wildlife
Resources Commission (NCWRC) regional fisheries biologists
regarding the health of fisheries in the two lakes.
In-lake monitoring data from NCDWQ and the WWTPs show
somewhat elevated levels of nutrients in the upper arms of both
Jordan and Falls Lakes: total phosphorus in the upper reaches of both
lakes averages about 0.1 mg/L. Depth-averaged dissolved oxygen
(DO) levels in the upper portions of both lakes average greater than
5.0 mg/L, and surface DO meets the water quality standard in 90-95%
of samples. However, there are relatively frequent violations of the
DO water quality standard in deeper water (1-2 m below the surface),
where decay of settling organic matter consumes oxygen. Between
a third and a half of depth profiles performed during the March-
October growing season showed DO below 5 mg/L at some depth
(Table 2). While DO may naturally be low in the hypolimnion of a
stratified lake, depth profiles taken by NCDWQ and by the OWASA
plant indicate no stratification of Jordan or Falls Lake at these sample
sites (i.e., temperature of the water is nearly the same throughout the
water column).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.10 (Continued)
Table 2
Summary of Dissolved Oxygen Observations in Upper Portions of
Falls and Jordan Lakes, March-0ctober, NCDWQ Data (1990-1997)
and WWTP Self-Monitoring Data (1994-1997)
Number of
Number Sampling
of Average Dates with Frequency of
Sampling DO a DO Exceedance
Station Dates (mg/L) Exceedance (%)
Falls Lake Above I-85 19 5.03 6 31.6
(NEU010)
Falls Lake at I-85 60 5.46 28 46.7
(NEU013)
Jordan Lake, Mouth of 56 6.57 22 39.3
Morgan Creek
(CPF086C)
Jordan Lake, Mouth of 20 6.59 12 60.0
New Hope Creek
(CPF081 Al C)
Chlorophyll a concentrations in the upper portions of Jordan and Falls
Lakes tend to exceed the state water quality standard of 40 ppb
(ug/L), as shown in Table 3.
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.10 (Continued)
Table 3
Summary of Chlorophyll a Observations in Upper Portions of Falls
and Jordan Lakes, March-0ctober, NCDWQ Data (1990-1997) and
WWTP Self-Monitoring Data (1994-1997)
Average Number of
Number Chl a Sampling
of Concen- Dates with Frequency of
Sampling tration a Chl a Exceedance
Station Dates (ug/L) Exceedance (%)
Falls Lake Above I-85 19 26.6 6 31.6
(NEU010)
Falls Lake at I-85 66 59.3 37 56.1
(NEU013)
Jordan Lake, Mouth of 53 48.7 36 67.9
Morgan Creek
{CPF086C)
Jordan Lake, Mouth of 19 45.9 8 42.1
New Hope Creek
(CPF081 Al C)
Reported significant algal blooms do occur but are relatively
infrequent in Jordan and Falls Lakes. Since 1990, NCDWQ has
investigated 11 reported algal blooms in Jordan Lake and 4 in Falls
Lake.
Fish kills are even less frequent. Since 1986, there have been four
known fish kills in Falls Lake and one in Jordan Lake. In Falls Lake,
all four fish kills occurred in the upper lake, and three have been
attributed to algal blooms (the fourth to Hurricane Fran). In Jordan
Lake, the single fish kill occurred in the Haw River arm, and has been
attributed to an algal bloom.
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• • ~
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.10 (Continued) Fisheries in Jordan and Falls Lakes seem to be quite healthy, and
include many species, including largemouth bass, crappie, striped
bass, catfish, chad, bluegill, carp, sunfish, bullheads, and others.
NCWRC does not have strong data that demonstrates impacts on
fisheries as a result of eutrophication, but fisheries biologists with
NCWRC say there appear to be higher incidences of "red sore"
disease in fish in the upper portions of both lakes, which would
indicate that fish in these areas are under some stress. However,
both Jordan and Falls Lakes are heavily used by the public for fishing.
Beaches at Jordan and Falls Lakes are managed by N.C. Parks and
Recreation staff stationed on the lakes. These staff receive
occasional complaints from the public regarding conditions
detrimental to the use of the lakes for swimming and other
recreational purposes. In Jordan and Falls Lakes, they have not had
algal blooms that have directly affected swimming or recreational
areas. Under certain conditions in Jordan Lake, however, a thin algal
film can be found on the water surface, which can make park visitors
uncomfortable. In Falls Lake during hot weather, gelatinous masses
of algae, several inches to a foot in diameter, are sometimes found
floating below the water surface. These jelly-like masses can be
disconcerting to some swimmers, and have resulted in complaints
from the public on an annual basis at Falls Lake.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.10 (Continued)
COMMENTOR RESPONSE
5.11 Discuss planned measures to WRC
minimize WWTP bypasses,
overflows or spills to the proposed
Randleman Lake or the Haw River.
Based on the above experience with Jordan and Falls Lakes,
relatively frequent violations of the DO water quality standard are
expected in the deeper waters in the Upper Deep River arm of the
proposed Randleman Lake. Significant algal blooms are expected to
occur but on a relatively infrequent basis. The incidence of fish kills
as a result of algal blooms is expected to be even less frequent.
Overall fisheries quality is expected to be good, although indications
of stress are expected to occur periodically for some fish species in
certain areas of the proposed lake. Based on experience with Jordan
and Falls Lakes, recreational use of the proposed lake is not expected
to be significantly affected by eutrophication of the lake. Section
5.3.5.5 of the FEIS includes additional information on the potential
impacts of predicted eutrophication in the proposed lake.
The City of High Point has an infiltration/inflow (Ill) reduction program
which will enable the Eastside WWTP to operate within the hydraulic
design capacity of the expanded plant. The expanded plant will have
the capability to treat a peak flow of 3.0 times the design capacity of
26 mgd, or a peak wet weather flow of 78 mgd. I/I improvements
include a major pumping station and force main, which will eliminate
an interceptor segment with a significant amount of I/I flows.
Approximately $9.3 million was authorized in 1993 for interceptor
pipeline rehabilitations and replacements. The continuing I/I reduction
program will reduce the peak wet weather flows that must be
processed by the plant and will minimize the potential for overflows
from the wastewater collection system and treatment plant.
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SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.11 (Continued) The design of the treatment plant expansion facilities will also include
measures to minimize the potential for treatment system failures. The
plant expansion facilities will include redundant equipment, parallel
treatment trains, and alarm systems to alert operators of failure of
crucial equipment. Redundant electrical power supplies will also be
provided for the expanded plant. The dual power feed will be from
two electrical substations, the Jackson Lake Substation and the Filter
Plant Substation. Both substations are main delivery points for power
from Duke Power Company. The proposed dual power feed system
meets cun'ent regulatory requirements for treatment system reliability.
Electrical provisions are also being made to allow standby generators
to be added in the future if needed for additional power system
reliability. Operation of the expanded plant will also include
preventive maintenance procedures to ensure that equipment is
maintained in proper working order throughout its full service life and
that equipment is replaced as needed.
Continued monitoring and enforcement under the City's Industrial
Pretreatment Program will minimize the potential for toxic substances
and heavy metals in the plant influent, which could lead to upsets of
the treatment process or result in pollutants passing through to the
treatment plant effluent. The Industrial Pretreatment Program
headworks analysis will be updated periodically and the industrial
allocations for specific parameters adjusted as necessary to ensure
compliance with the NPDES permit effluent limits for the expanded
plant.
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• •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.11 (Continued) For the WWTP discharges to the Haw River Basin, the City of
Greensboro also has an on-going program to reduce I/I in the
wastewater collection system and regulates its industrial users under
an industrial pretreatment program. Redundant equipment, parallel
treatment trains and redundant power supplies are also provided at
the Greensboro T.Z. Osborne and North Buffalo VWVfPs. Most of the
increased flow associated with the additional water supply will be
treated at the T.Z. Osborne VW1/TP. Environmental assessments for
the expansions of the T.Z. Osborne W1N"fP to 30 mgd and 40 mgd
have been submitted and approved by the NCDWQ. Facilities to
expand the T.Z. Osborne WWTP to 30 mgd are currently under
construction and include capacity to treat a peak flow of 2.5 times the
design average flow without overflows or bypasses.
Sections 5.3.5.2 and 5.3.5.8 of the FEIS include this additional
information on the planned measures to minimize WWTP bypasses,
spills and overflows to the proposed Randleman Lake and the Haw
River.
5.12 Indicate the Deep River flow at which WRC According to the Cape Fear River Basinwide Water Quality
a discharge of 16 mgd from the High Management Plan (NCDEHNR, 1996a), an effluent discharge of 16
Point Eastside WWTP will make up mgd for the High Point Eastside WWTP makes up 73 percent of the
70 percent of the flow. Indicate the flow in the Deep River at Freeman Mill, just downstream of the
percentage of flow that will be confluence of Richland Creek and the Deep River, during 7Q10 (7-
effluent at the proposed expanded day, 10-year low flow) conditions. During 7Q10 conditions, a
capacity of 26 mgd. discharge of 26 mgd will make up approximately 82 percent of the
flow in the Deep River at Freeman Mill. Section 4.3.5.2 of the FEIS
includes this additional information on the percentages of the 7Q10
flow that is effluent for the current and expanded capacities of the
High Point Eastside WWTP.
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SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.13 Discuss the following areas of DEH Section 1.5 of the FEIS includes additional discussion of the potential
controversy in Section 1.5: (1) high nutrient loadings from dairy farms, urban runoff, and the High
potential high nutrient loadings from Point Eastside WWTP. The implementation of the nutrient reduction
dairy farms, urban runoff, and the strategy for the Randleman Lake watershed will minimize impacts to
High Point Eastside WWTP, (2) water quality associated with these loadings (see response to
infiltration/inflow in the High Point Comment 5.2). Section 1.5 also includes a discussion of
collection system which will cause infiltration/inflow in the High Point wastewater collection system and
wastewater bypasses at the Eastside planned measures to minimize the potential for overflows and
WWTP, and (3) the detrimental and bypasses at the Eastside WWTP (see response to Comment 5.11).
positive effects of the long retention
time in the proposed lake. Positive effects of the long retention time in the proposed lake
include:
• Opportunity to remove phenols by biodegradation
• Opportunity for losses of lindane due to volatilization,
sedimentation, and degradation
• Removal of organic chemicals from the High Point Landfill and
Seaboard Chemical Corporation sites through volatilization,
hydrolysis, and photolysis
• Protection of downstream water quality through removal of
• sediment and other pollutants.
Detrimental effects of the long retention time include:
• Moderation of high flows downstream in the Deep River and the
resulting potential adverse effects on downstream wetlands
• Opportunity for increased photosynthesis and increased growth of
algae and rooted aquatic plants.
The detrimental and positive effects of the long retention time in the
proposed lake are discussed in Section 5.3.5.5 of the FEIS.
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.14 Discuss in Section 1.6 the fact that DEH Section 4.3.5.2 of the FEIS includes additional information from recent
water quality standards and action C-AH1 NCDWQ reports on existing problems with water quality in the Deep
levels are not currently met in the River (NCDEHNR, 1994a, 1994b, 1996a) (see response to Comment
Deep River. More fully address the 5.4).
"continuing problems" with water
quality on Page 4-10.
5.15 Address all identified sources of DEH A list of NPDES dischargers in Subbasin 03-06-08 of the Deep River
pollution, including both point and watershed is included in Table 15a. Urban areas in the Deep River
nonpoint sources. watershed tributary to the proposed lake include Kemersville,
Jamestown, and High Point. Agricultural areas also contribute runoff
to the proposed Randleman Lake watershed. These include six
operating dairies which are located in the watershed (see response
to Comment 16.22). Additional potential sources of groundwater
contamination are discussed in the response to Comment 5.59.
Section 4.3.5.2 of the FEIS includes additional information on the
existing sources of pollution in the proposed Randleman Lake
watershed.
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• • •
Table 15a
NPDES Dischargers in the Randleman Lake Watershed
Dischar er
g NPDES Permit
Number
Discharge Location Permitted
Flow, mgd"
Type of Discharge
Amerada Hess Corp. NC0069256 UT East Fork Deep River NL Stormwater**
Ashland Petroleum Co. NC0065803 UT East Fork Deep River NL Stormwater**
Carolina Steel Corp. NC0084492 UT West Fork Deep River 0.0144 Groundwater Remediation
Colonial Pipeline Co. NC0031046 UT East Fork Deep River NL Stormwater**
Crown MHP NC0055255 UT Hickory Creek 0.042 Domestic
NCDOC -Sandy Ridge Corr. Ctr. NC0027758 UT West Fork Deep River 0.0175 Domestic
E~ocon Co. NC0000795 UT East Fork Deep River NL Stormwater**
E~ocon Co., USA NC0084522 UT Jenny Branch 0.0216 Groundwater Remediation
S. Guilford H.S. NC0038229 UT Hickory Creek 0.012 Domestic
Southern Elem. NC0038091 UT Hickory Creek 0.0075 Domestic
Sumner Elem. NC0037117 UT Hickory Creek 0.009 Domestic
Hidden Forest Est. MHP NC0065358 UT Deep River 0.027 Domestic
High Point Ward WTP NC0081256 UT Richland Creek 10 Municipal WTP Solids Handling
High Point Eastside WWTP NC0024210 Richland Creek 16 Municipal WWTP
HRS Terminals, Inc.
(GNC Energy Corp.) NC0074241 UT East Fork Deep River NL Stormwater**
Hickory Run MHP
(Huntington Properties, LLC) NC0041505 UT Bull Run Creek 0.035 Domestic
Louis Dreyfus Energy Corp. NC0026247 UT East Fork Deep River NL Stormwater**
National Pipe and Plastics, Inc.
(LCP National Plastics, Inc.) NC0036366 UT West Fork Deep River NL Cooling Water, Cooling Tower Slowdown
Plantation Pipeline Co. NC0051161 UT East Fork Deep River NL Stormwater**
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• •
•
Table 15a (continued)
NPDES Dischargers in the Randleman Lake Watershed
Discharger NPDES Permit
Number Discharge Location Permitted
Flow, mgd* Type of Discharge
Plaza MHP N00041483 UT Hickory Creek 0.003 Domestic
Rayco Utilities, Melbille Heights N00050792 Muddy Creek 0.0315 Domestic
Rayco Utilities, Penman Heights N00055191 UT Muddy Creek 0.025 Domestic
Star Enterprise N00022209 UT Long Branch NL Stormwater'*
Triad Terminal Co. N00042501 UT East Fork Deep River NL Stormwater"
William Energy Ventures
(Conoco, Inc.) N00074578 UT Long Branch NL Stormwater"
Tota I 26.245
Total, Excluding High Point Ward WTP and Eastside WWTP 0.245
* NL = no flow limit; UT =unnamed tributary
Located at the "tank farm" along I-40.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.16 Verify the statement on Page 5-15 DEH
that the water quality of Randleman
Lake is expected to be within the
range of values measured at other
eutrophic lakes in North Carolina.
Discuss how this was determined.
A comparison of projected water quality in the proposed Randleman
Lake was made in the FEIS prepared by the N.C. Department of
Environment, Health and Natural Resources, Division of Water
Resources (NCDEHNR, 1991). Predicted model values were
compared with other regional reservoirs and lakes in this report.
Table 25 in the FEIS presents Secchi depth, total phosphorus,
chlorophyll a and size data for eight regional lakes, along with
corresponding values for Randleman Lake. The Randleman Lake
values were based on the assumption that the effluent total
phosphorus for the High Point Eastside WWTP was reduced to 0.5
mg/L. Secchi depth, total phosphorus, and chlorophyll a values
predicted for Randleman Lake were within the range of values
measured in the other lakes. Updated values from the modeling
conducted in 1998 for the expanded High Point Eastside WWTP are
consistent with the values shown in Table 25. The predicted values
from this modeling are also within the range of values for other
regional lakes. Section 5.3.5.5 of the FEIS includes this additional
information on the comparison with other lakes in North Carolina.
5.17 Discuss the mass loadings of N and GC Mass loadings of N and P are discussed in the Nutrient Reduction
P for the High Point Eastside WWTP, Strategy report (see response to Comment 5.9). Loadings from other
including current and future loadings NPDES dischargers are also discussed in that report. According to
after the proposed upgrade and the report, nutrient loadings from these other dischargers are not
expansion. Discuss future loadings significant compared to the nutrient loadings from the High Point
from other NPDES dischargers. Eastside WWTP. Existing phosphorus and nitrogen loadings for the
Eastside WWTP are 58,070 kg/yr and 290,350 kg/yr, respectively.
Projected loadings for phosphorus and nitrogen after the proposed
upgrade and expansion are 7,190 kg/yr and 215,690 kg/yr,
respectively. The projected phosphorus and nitrogen reductions for
the Eastside WWTP are 88 and 26 percent, respectively. Reference
to the Nutrient Reduction Strategy report and mass loading data for
the High Point Eastside WWTP are provided in Section 5.3.5.5 of the
FEIS.
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•
• •
Table 25
Comparison of Lake Water Quality

Lake
Secchi Depth (m) Total Phosphorus
(TP)
(mg/L) Chlorophyll a

(Ng~L) Area

(acres)
Badin Lake 1.1 (1.4) 0.03 (0.025) 23.5 (17) 5,350
Belews Lake 3.95 (3.2) 0.015 (0.01) 1 (1) 4,030
Jordan Lake 0.5 (0.4) 0.08 (0.09) 26 (40) 14,300
Falls Lake 0.6 (0.5) 0.08 (0.07) 56 (32) 12,490
Harris Lake 1.8 (2.0) 0.03 (0.03) 24 (9) 4,150
Lake Hickory 1.55 (1.15) 0.035 (0.03) 22.5 (5) 4,100
Lake Rhodhiss 1.0 (1.1) 0.1 (0.06) 22 (3) 3,515
Lake Tom-A-Lex 0.8 (0.9) 0.045 (0.045) 26 (32) 650
Randleman Lake` 1.2 0.07 19.4 3,123
Assuming High Point Eastside WWTP effluent TP concentration is 0.5 mg/L.
Source: Final Environmental Impact Statement for Randleman Lake, NCDEHNR, 1991. Values derived from "1988 North
Carolina Lakes Monitoring Report," NCDEM Report No. 89-04, 1988 (values from "North Carolina Lake Assessment
Report," NCDEM Report No. 92-02 in parentheses).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.18 Provide advanced treatment at the GC Advanced treatment for nitrogen and phosphorus will be provided at
Eastside WWTP to reduce nitrogen C-AH1 the High Point Eastside WWTP. The Eastside WWTP will be
and phosphorus concentrations. C-AH5 designed to reduce the effluent phosphorus concentration to 0.5 mg/L
Consider routing the discharge C-AH6 or lower and the effluent total nitrogen concentration to 3 to 6 mg/L
around the lake (p. 3-1). EPA year-round. Projected reductions in effluent phosphorus and nitrogen
C-DC loadings compared to existing conditions are 88 and 26 percent,
C-HP respectively (see response to Comment 5.17). The option of routing
the discharge around the proposed lake is not feasible because it
would significantly reduce the safe yield of the proposed reservoir.
Based on the reservoir yield analysis conducted by Black & Veatch
((1990) DEIS, Appendix A), the safe yield of the proposed Randleman
Lake would be 42 mgd (54 mgd minus an Eastside VWVfP discharge
of 12 mgd) if the Eastside VWVTP discharge is routed around the lake.
This would adversely affect the long-term water supply from the
proposed lake. It would also cause greater adverse effects on water
quality and water and wastewater facilities downstream of the
proposed lake than discharge to the proposed lake. In addition,
discharge downstream of the lake would result in greater impacts on
the water supplies of downstream water users. This may make the
option of discharging downstream of the proposed lake politically
unacceptable. For these reasons, discharge of the Eastside WWTP
effluent to Randleman Lake is the recommended option. Section
5.3.5.5 of the FEIS discusses the advanced treatment level to be
provided at the High Point Eastside 1IVW'fP.
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•
~ •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.19 Address the potential for spills of DOI
hazardous waste from I-85 and other
highways which would cross the
reservoir.
5.20 Discuss the effect on inundation of DOI
the Seaboard Chemical Corporation
waste site of a 200 to 500-year flood
or a flood c-oser to the maximum
pool elevation.
The proposed reservoir would be vulnerable to spills of hazardous
waste from I-85 and other highways which would cross the reservoir.
To help minimize the impacts of spills, bridges which are modified for
the proposed reservoir will include measures to allow containment of
hazardous materials which are spilled on the roadway, in accordance
with DOT "Guidelines for the Location and Design of Hazardous Spill
Basins". Section 311 of the Clean Water Act has also been amended
by the Oil Pollution Act of 1990 to require immediate notice in the
event of spills of oil or hazardous substances. A report must be made
to the National Response Center in Washington D.C. 24-hour toll-free
telephone number: [phone]; the predesignated Federal on-
scene commander (OSC); the nearest EPA office; or the nearest
Coast Guard office. When a spill is reported, the OSC will investigate
whether appropriate cleanup action is being taken by the discharger
and by State, local and regional governments. The OSC will assume
control of response activities if appropriate containment or cleanup
action is not being taken. In the event of a spill affecting the proposed
Randleman Lake, the other water supply reservoirs of the PTRWA
members would provide an alternative source of supply for short
periods. Section 5.3.5.4 of the FEIS addresses the potential for and
response to spills of hazardous materials.
The Seaboard Chemical Corporation site covers approximately.13
acres; operations took place on approximately 5 acres. The 5-acre
area where operations took place is located entirely above elevation
730 ft. m.s.l. (Geraghty & Miller, 1995). The Probable Maximum
Flood (PMF) pool elevation for the proposed Randleman Lake is
705.32 ft. m.s.l. Therefore, the Seaboard Chemical Corporation site
will not be flooded by the proposed lake. Section 5.3.5.4 of the FEIS
includes additional information on the potential for flooding of the
Seaboard Chemical Corporation site. (Also see response to
Comments 5.1 and 5.7).
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SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.21 Discuss the percentage removal of HRA An analysis of potential water quality impacts from toxic organic
pollutants between the upper end of chemicals from the Seaboard Chemical Corporation and High Point
the proposed reservoir and the water Landfill sites and other point and nonpoint source discharges in the
intake (p. 5-13). Discuss the model proposed Randleman Lake watershed was conducted as a part of the
used to predict the removal nutrient reduction strategy for the proposed lake (Hazen and Sawyer,
percentage. 1998). In addition to the toxic organic chemicals found at the
Seaboard Chemical Corporation and High Point Landfill sites,
projected concentrations of lindane and phenols were evaluated.
Lindane has been found in Richland Creek downstream of the High
Point Eastside WWTP. Lindane has also been identified in the
Eastside WWTP effluent, but the presence of lindane is intermittent
and concentrations are highly variable. Assuming that the Eastside
WWTP is the source of lindane concentrations in the proposed lake,
modeling conducted on estimated upper bound lindane
concentrations indicated that the reduction in lindane concentration
from the source to the proposed water intake ranged from 71 percent
based on dry year annual flows to 99.8 percent for dry year conditions
during the growing season. Upper bound estimates for lindane
concentration in the proposed lake were determined using estimates
of both annual and summer growing season segment-to-segment flow
rates from the eutrophication model, BATHTUB. In all cases, both the
best estimate and the maximum predicted concentrations of lindane
at the source and at the water intake are well below the State water
quality standard of 10 ng/L and the drinking water standard of 200
ng/L, despite conservative assumptions regarding mass loading rates.
Based on the screening of toxic chemicals from the Seaboard
Chemical Corporation and High Point Landfill sites, the reduction in
maximum screening concentrations from the source to the proposed
water intake ranged from 98 to 99 percent. For both locations, the
maximum screening concentration was well below the applicable
standard or criterion for each pollutant. The pollutant concentration
at the water intake was determined using a simple steady-state model
of transport through the lake, with the underlying hydraulics provided
by the application of the BATHTUB eutrophication model.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.21 (Continued)
Predicted removal of phenols within the proposed lake range from 97
to greater than 99.99 percent. Ranges of predicted phenols
concentrations were determined based on varying assumptions for
the rate of biodegradation of the phenolic compounds, the solids
concentration and settling velocity, and the resuspension velocity.
The results suggest that there is a possibility of exceeding the State
water quality standard for total phenols at the upper end of the
proposed lake and at the proposed water intake. This is based on the
assumption that the projected load of phenols enters directly into
these segments. However, it is unlikely that the unidentified phenols
that have been observed in the Deep River are the problematic
chlorinated phenols covered by the State standard. In addition,
concentrations are expected to decline rapidly with distance away
from any source of loading. In general, unidentified phenolic
compounds are not expected to present a water quality problem since
chlorinated phenols are not likely to be present at significant levels.
However, further investigation may be needed to determine the
source of phenols present in the lower portion of the proposed lake.
Section 5.3.5.4 of the FEIS includes additional information on removal
of toxic substances in the proposed lake.
COMMENTOR RESPONSE
5.22 Discuss the model used to determine HRA
that flooding of Randleman Lake will
cause only minor effects on the
Seaboard Chemical Co. and High
Point Landfill sites (p. 5-11).
5.23 Describe methods to remove excess HRA
metals from groundwater at the
Randleman dump (p. 5-13).
See response to Comment 5.1.
There are no plans to remove metals from groundwater at the
Randleman Dump site (see response to Comment 5.55). Materials
at the site will be removed and properly disposed of (see response to
Comment 5.28). No revisions to the EIS are necessary.
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• • ~
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.24 Discuss whether water users will be HRA
required to install expensive extra
treatment to remove high levels of
pollutants (p. 5-13).
5.25 In Section 5.3.5.4, verify whether the DWM
N.C. Division of Waste Management C-AH5
approved the analysis performed on C-AH6
the modeling by Black & Veatch
(p. 5-11).
5.26 Discuss the difference between the DWM
100-year flood and the probable EPA
maximum flood in Table 8 and
Section 5.3.5.4 (pp. 3-3 and 5-12).
5.27 Clarify that the leachate system for DWM
the High Point Landfill only intercepts
leachate generated from a small
portion of the landfill (p. 5-12).
Water users will not be required to install expensive extra treatment
facilities to remove high levels of pollutants. Conventional treatment
methods are expected to be employed (see response to Comment
2.10). No revisions to the EIS are necessary.
The reference to the approval of the analysis performed by Black &
Veatch by the N.C. Division of Waste Management has been deleted
from the FEIS.
The Probable Maximum Flood (PMF) is the upper limit of flooding
produced by the greatest amount of precipitation for a given duration
that is physically possible, as determined by the National Weather
Service. The return frequency of the Probable Maximum Precipitation
(PMP) is estimated to be once in 10,000 years. Consequently, the
PMF is significantly higher than the 100-year flood and is not likely to
occur during the life of the reservoir. Table 8 in the FEIS includes
information comparing the 100-year flood to the PMF. Section 5.3.5.4
also includes a reference to the probable maximum storm event.
The location of the leachate collection system at the High Point
Landfill is shown on Figure 3 in the report on the groundwater and
surface water investigation conducted by Environmental
Investigations, Inc. (Environmental Investigations, 1992). The
leachate collection system consists of collection lines draining to six
collection tanks. The tanks are pumped out periodically and the
leachate is then transported by truck to the High Point Eastside
WWTP. The leachate collection system collects leachate from the
central portion of the landfill next to the Deep River and from part of
the eastern portion of the landfill. The depth of the drain lines is not
known. Therefore, it is not known how much of the leachate from the
landfill is being collected. Section 5.3.5.4 of the FEIS includes
additional information on the leachate collection system for the High
Point Landfill.
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~ • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.28 Removal of the Randleman Dump DWM Section 5.3.5.4 of the FEIS addresses the requirement that the
should be conducted in conformance cleanup of the Randleman Dump be conducted in conformance with
with DWM Guidelines for DWM Guidelines for Assessment and Cleanup under the Inactive
Assessment and Cleanup under the Hazardous Waste Sites Program (July 1997).
Inactive Hazardous Sites Program
(July 1997).
5.29 VOCs from the groundwater C-AH1 See response to Comment 5.1.
contamination at the Seaboard
Chemical Co. and High Point Landfill
sites have made the proposed
project environmentally
unacceptable.
5.30 Discuss measures to ensure that the C-AH2 Modeling has been conducted by the N.C. Division of Water Quality
Deep and/or Haw Rivers can accept (NCDWQ) to set NPDES permit effluent limits for the expanded High
the increased wastewater discharges Point Eastside WWTP discharge to the Deep River Basin and the
from the new water source. Conduct Greensboro T.Z. Osborne WWTP discharge to the Haw River Basin.
modeling to set pollution limits An environmental assessment addressing the impacts of the High
considering the current safe yields of Point Eastside WWTP expansion to 26 mgd is currently being
all current water supplies and their reviewed by the N.C. Department of Environment and Natural
potential discharge locations. Resources (NCDENR). Environmental assessments have been
approved for expansion of the T.Z. Osborne WWTP to a first-phase
capacity of 30 mgd and to 40 mgd in the future. These increased
capacities are for the additional wastewater to be generated from the
increased water supply from the proposed reservoir. Wastewater
from Jamestown and Archdale is also treated at the High Point
Eastside WWTP. Additional wastewater flows for other PTRWA
members will be addressed by additional modeling conducted by the
NCDWQ in response to NPDES permit applications for treatment
plant expansions or as part of the Cape Fear Basinwide Water Quality
Management Plan review conducted every five years by the NCDWQ.
No revisions to the EIS are necessary.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.31 Discuss the current plans to expand C-AH5
the Eastside WWTP to 26 mgd.
Describe the trophic conditions in the
proposed lake during drought
conditions at the expanded plant
capacity.
5.32 Discuss whether a 32 mgd discharge C-AH6
from the High Point Eastside WWTP
is a planned part of the project.
5.33 Update water quality modeling based C-AH6
on the revised lake hydraulic
retention time and current water
quality data.
See response to Comments 5.2 and 5.9.
A discharge of 32 mgd from the High Point Eastside WWTP is not a
planned part of the proposed project. The proposed plant expansion
to 26 mgd is projected to meet wastewater treatment needs of the
City of High Point and surrounding communities to approximately the
year 2020. No revisions to the EIS are necessary.
See responses to Comment 5.2.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.34 Compare the instream waste C-AH6 The total permitted wastewater flow for the major NPDES dischargers
concentration of the proposed (permitted capacity >1.0 mgd) to the Haw River arm of Jordan Lake
Randleman Lake at low flow is 73.75 mgd. Dischargers include the wastewater treatment plants
conditions to the instream waste for the cities of Reidsville, Burlington, Greensboro, Graham and
concentration for Jordan Lake. Mebane and the discharges for Cone Mills in Greensboro and the
Greensboro Lake Townsend Water Treatment Plant. Allowing for the
proposed expansion of the Greensboro T.Z. Osborne WWTP to 40
mgd, the total permitted flow would increase to 93.75 mgd (not
inGuding increases for other municipal dischargers). The 7Q10 flow
for the Haw River at the Bynum WWTP is estimated to be 37.5 mgd.
This would result in an instream waste concentration for. the Haw
River arm of Jordan Lake of approximately 71 percent. The 7Q10
flow for the Deep River at Freeman Mill is estimated to be
approximately 5.9 mgd. The High Point Eastside WWTP and the
High Point Ward Water Treatment Plant are the only major NPDES
dischargers to the Deep River Basin upstream of the proposed
Randleman Lake. Based on the expanded wastewater flow capacity
for the Eastside WWTP of 26 mgd, the instream wastewater
concentration for Randleman Lake would be approximately 82
percent. Predicted impacts of the wastewater discharge on the water
quality in Randleman Lake are discussed in Sections 5.3.5.2 and
5.3.5.5 of the FEIS. (Also see response to Comments 5.2 and 5.10).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.35 Discuss the impact of the proposed C-AH6
project on the number and duration of CCNC
downstream water quality violations
at low flow conditions.
5.36 Discuss how fish and humans will be C-WF
protected from areas of the proposed
lake with high pollutant
concentrations.
The proposed project will result in increased flows in the Deep River
downstream of the proposed lake during low flow conditions as a
result of the planned minimum flow release of 30 cfs. The minimum
flow release would be reduced during drought conditions to a
minimum of 10 cfs when the reservoir volume is reduced to 30
percent full or less. This is still higher than the existing 7Q10 flow of
7.7 cfs at the Randleman gage on the Deep River (see Section
5.3.5.3 of the FEIS). The normal minimal flow release of 30 cfs is
expected to reduce the number and duration of downstream water
quality violations by providing greater assimilative capacity for
wastewater discharges to the Deep River. Gates will also be provided
to enable releasing water from the proposed lake at various levels to
ensure that the dissolved oxygen concentration of the released water
is high enough that water quality is not affected immediately below the
dam (GEI, 1995). Section 5.3.5.7 of the FEIS discusses the impact
of the proposed project on downstream water quality.
The water quality in the proposed lake is expected to meet all
applicable water quality standards for freshwater and for waters
classified as water supplies except for chlorophyll a. No areas of the
proposed lake are expected to have high pollutant concentrations that
would adversely affect fish or humans (see responses to Comments
5.10 and 6.1). Sections 5.3.5.4 and 5.3.5.5. of the FEIS discuss the
reservoir toxic substances and trophic level evaluations relating to the
water quality of the proposed lake.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.37 Provide test borings at the Jackson C-KS
Lake Road dump site to determine if C-NP
hazardous chemicals are present and
potential impacts on the proposed
project. Discuss in EIS.
The Jackson Lake Road Landfill has been closed since the 1950's
and has not been identified as a potential source of hazardous
chemicals in previous reports on water quality in the Randleman Lake
watershed. The Jackson Lake Road Landfill site is outside the critical
area for the proposed lake, which would also reduce the potential
impacts of the landfill on water quality in the lake. According to
communication with City of High Point staff, the landfill site is located
on privately-owned land and was a private landfill during the period of
its operation. For this reason, the PTRWA is not likely to be able to
obtain access to the site to perform test borings. Therefore, in order
to further evaluate the potential for release of hazardous chemicals
from the site, a review of existing water quality monitoring data was
conducted. The landfill site is tributary to Richland Creek just
upstream of SR 1154. Extensive monitoring was conducted at this
location in 1992-93 and 1997 by the NCDWQ. The results of this
monitoring are summarized in Table 27. Violations of water quality
standards for fecal coliforrns and cadmium were noted for this site, as
well as concentrations above action levels for copper, iron and zinc.
The high iron concentrations are believed to be due to naturally
occurring iron in the clay soils of the area. Phenols were also
observed at this location at levels above the water quality standard for
phenols of 1.0 ug/L, which was established to protect water supplies
from taste and odor problems from chlorinated phenols. Based on
existing water quality monitoring, phenols concentrations above 1.0
ug/L occur at several locations in the Upper Deep River and are not
limited to this monitoring site. Based on the review of water quality
monitoring conducted in Richland Creek immediately downstream of
the landfill, there is no indication that hazardous chemicals from the
landfill are being released into Richland Creek. Section 5.3.5.4 of the
FEIS discusses the Jackson Lake Road Landfill and its potential to
have adverse impacts on the proposed project.
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• • •
Table 27
Water Quality Data for Richland Creek Downstream of Closed Jackson Lake Landfill
1992-93 Data' 1997 DataZ Water Quality

Avg.
Max.
Min.
Avg.
Max.
Min. Standard or
Action Level (AL)
Dissolved Oxygen, mg/L 9.7 13.0 7.2 7.5 9.4 6.0 5
Temperature, °C 14.4 24.5 5 20 23 13 -
pH, units 7.3 7.8 6.6 7.3 7.4 7.2 6.0-9.0
Conductivity, Nmhos/cm 170 199 132 126 179 71 -
Fecal Coliform, No./100 mL 158` 420 <10 711* 5,000 150 200"
Total Coliform, No./100 mL 2,039' 8,200 270 4,139` 35,000 2,500 -
Cadmium, ug/L <2.1 2.7 <2 <2 <2 <2 2
Chromium, ug/L <25 <25 <25 <25 <25 <25 50
Copper, ug/L <3.0 6.3 <2.0 4.6 7.2 3.4 7 (AL)
Nickel, ug/L <10 <10 <10 <10 <10 <10 25
Lead,ug/L <10 <10 <10 <10 <10 <10 25
Zinc, ug/L <10 <10 <10 41 77 12 50 (AL)
Iron, ug/L 440 1,100 110 800 1,200 380 1,000 (AL)
Aluminum, ug/L <260 1,100 <50 510 1,000 120 -
Manganese, ug/L 85 140 26 110 130 75 200
Beryllium, ug/L <10 <10 <10 <10 <10 <10 0.0068
Barium, ug/L <26 39 <10 36 41 30 1,000
Arsenic, ug/L <10 <10 <10 <10 <10 <10 50
Mercury, ug/L <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 0.012
NH3, mg/L 0.14 0.28 0.03 0.21 0.29 0.1 -
TKN, mg/L 0.4 0.7 0.2 0.5 0.6 0.4 -
NOZ+NO3, mg/L 0.56 0.92 0.19 0.68 0.8 0.56 -
Total Phosphorus, mg/L <0.3 0.07 <0.01 0.04 0.06 0.02 -
Orthophosphate, mg/L <0.01 0.02 <0.01 <0.01 0.01 <0.01 -
\WAZEN01101\WPDOCSIPRIVATEIWPFILESIMISCIRANDEISIDEISTABL RAN Page 70

•
• •
Table 27 (continued)
Water Quality Data for Richland Creek Downstream of Closed Jackson Lake Landfill
1992-93 Data' 1997 DataZ Water Quality

Avg.
Max.
Min.
Avg.
Max.
Min. Standard or
Action Level (AL)
Chlorophyll a, Ng/L - - - <7 30 <1 40
Total Residue, mg/L 130 150 100 136 150 130 -
Suspended Residue, mg/L <3 9 <1 12 23 6 -
Turbidity, NTU - - - 13 17 3.9 50
Alkalinity, mg/L 44 60 6.7 41 51 31 -
Chloride, mg/L 12 14 7 9 14 8 230
Hardness, mg/L 65 95 39 55 69 42 100
Phenols, Ng/L <3 12 <2 <14 52 <1 1.0
Sulfate, mg/L 14 16 9 8 9 7 250
Pesticides/Organics***
Pentachlorophenol, Ng/L - - - 0.03 0.05 0.02 -
2, 4-D, Ng/L - - - 0.18 0.18 0.18 100
Bioclassificafion Fair (1988) - -
* Geometric mean for 30-day period (five samples).
*` Also, not more than 20 percent of samples greater than 400 organisms/100 mL (also exceeded for 1997 data).
*** Numerous unidentified pesticide and herbicide peaks were also reported. These peaks are indications of organic compounds, but chemical-
specific confirmation and identification was not possible. Chloroform was also detected (tentatively identified for 1992-93 data) below
quantitation limit.
NCDEHNR, 1994b.
Water quality monitoring data from NCDWQ (Draft).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.38 Provide additional documentation EPA See response to Comment 5.1.
that groundwater contamination
would not have a significant adverse
effect on the proposed Randleman
Lake water quality.
5.39 Provide supporting evidence EPA A topographic map for the High Point Landfill and Seaboard Chemical
(topographic maps) to show that the Corporation site is shown on Figure 7a. The normal pool of the
Seaboard Chemical Co. and High proposed lake is at Elevation 682.0 feet m.s.l. and the 100-year flood
Point Landfill sites are situated pool is at Elevation 688.21 feet m.s.l. A hydraulic analysis of the
entirely above the normal pool of the Deep River at the landfill site was also conducted (GEI, 1995). For
proposed lake (p. 5-11). Discuss this analysis, cross sections were evaluated at various locations along
how much of the High Point Landfill the landfill. Based on the hydraulic analysis, the water surface
will be under water at both normal elevation at the landfill during the 100-year flood is approximately one
pool elevation and flood pool foot higher with the project than without the project. The 100-year
elevation. flood is generally contained on the river side of the dike which forms
a road along the toe of the landfill and separates the landfill from the
Deep River. However, there is one 200-foot-long area along the river
where the water surface elevation during the 100-year flood is slightly
above the toe of the landfill. The maximum computed water surface
elevations at the upstream end of the landfill for the full range of
floods analyzed, with and without the proposed project, are
summarized in Table 26. Water surface elevations determined by
FEMA are also shown. Based on the elevations shown in this table,
the maximum water surface elevation at the landfill during the 100-
year flood is 692.83 feet m.s.l. Section 5.3.5.4 of the FEIS includes
additional information on the degree of inundation of the High Point
Landfill and the Seaboard Chemical Co. site at the proposed normal
pool elevation and during flood conditions.
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i
~ •
Table 26
Maximum Water Surface Elevations at Riverdale Road Landfill
Randleman Lake Dam
Randolph County, North Carolina
FEMA Computed Computed
Recurrence Interval Water Surface Elevations Water Surface Elevations Water Surface Elevations
Without Project' Without Project With Project2
(ft. NGVD) (ft. NGVD) (ft. NGVD)
10 686.50 687.38 688.76
25 Not Available 688.91 690.13
50 690.50 690.26 691.42
100 692.80 691.76 692.83
Notes:
As determined by the Federal Emergency Management Agency (FEMA) and included in the Flood Insurance Study for the
Unincorporated areas of Guilford County, NC.
2. For 500-foot-wide ogee spillway.
Source: Phase I Hydrologic and Hydraulic Analyses and Conceptual Design Alternatives for the Proposed Randleman Lake Dam,
Volume I, GEI Consultants, Inc., 1995.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.40 More fully describe known chemical EPA Results of previous groundwater sampling conducted in 1994 by the
contaminants. Identify the full list of NCDEHNR and by Environmental Investigations, Inc. for the High
constituents and the distribution and Point Landfill and the Seaboard Chemical Co. site are summarized in
extent of contamination. More Tables 3-2 and 3-4 (Geraghty & Miller, 1995). Additional testing has
adequately characterize the sources been conducted by ERM-Southeast, Inc. for the Remedial
of both chemical and nonpoint source Investigation for cleanup of these sites (see response to Comment
inputs to the watershed. 5.1). A map showing existing monitoring well locations is shown on
Figure 3-1 (Geraghty & Miller, 1995). Section 5.3.5.4 of the FEIS
includes additional information from these sources on known chemical
contaminants from these sites.
Additional information on sources of point and nonpoint source
discharges to the proposed Randleman Lake watershed is provided
in Section 4.3.5.2 of the FEIS (see response to Comments 5.15 and
5.41). The High Point Eastside WWTP is the most significant point
source discharger. Impacts of discharges of toxic substances and
nutrients from the Eastside WWTP are addressed in Sections 5.3.5.4
and 5.3.5.5 of the FEIS (see response to Comments 5.2, 5.10, 5.41
and 5.42).
5.41 Clarify and expand the discussion of EPA Section 4.3.5.2 of the FEIS includes additional information on the
the cumulative impacts of the permitted dischargers in the Randleman Lake watershed (see
chemical loadings of the additional response to Comment 5.15). Most of these dischargers are small
permitted existing dischargers not domestic-type dischargers. The total permitted flow for the small
discussed in the DEIS. Clarify NPDES dischargers (not including the High Point Eastside WWTP
whether they are wastewater or and the High Point Ward WTP) is approximately 0.23 mgd. The effect
stormwater. of these small dischargers on the water quality in the proposed
Randleman Lake is insignificant compared to the effect of the High
Point Eastside WWTP. NPDES stormwater dischargers located at
the "tank farm" along I-40 are also addressed in the response to
Comment 5.4.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.42 Discuss how the Eastside WWTP EPA Seven priority pollutants scans for the effluent from the High Point
was determined to be not a Eastside VWVfP for the two-year period from February 1996 through
"significant" source of organic January 1998 were reviewed. Based on the results of the pollutant
pollutants (p. 5-13). Define a scans, the State water quality action level for copper of 7 ug/L was
"significant" source. A priority exceeded for six samples, the action level for silver of 0.06 ug/L was
pollutant scan is recommended. exceeded for two samples, the cyanide water quality standard of 5
Provide a review of this information ug/L was exceeded for three samples, and the toluene water quality
for this and other discharges to the standard of 11 ug/L was exceeded for one sample. Substances for
proposed lake. which action levels are set are defined as those which are generally
not bioaccumulative and have variable toxicity to aquatic life because
of chemical form, stream characteristics or associated waste
characteristics. If the action levels for any of these substances are
determined by a waste load allocation to be exceeded in the receiving
water by a wastewater discharge under the specified low flow criterion
for toxic substances, the discharger will be required to monitor the
chemical or biological effects of the discharge. The substances for
which action levels are established will be limited as appropriate in a
dischargers NPDES permit if sufficient information exists to indicate
that any of the substances may be a significant causative factor
resulting in toxicity of the effluent. The current NPDES permit for the
Eastside VVVVfP includes an effluent limit of 5 ug/L for cyanide. The
effluent is required to be monitored only for silver and copper.
Section 5.3.5.4 of the FEIS discusses the results of recent priority
pollutant scans for the High Point Eastside WWTP. The other
dischargers to the proposed Randleman Lake watershed are primarily
either domestic-type dischargers or stormwater--only dischargers and
would not be expected to have significant amounts of organic
pollutants, i.e., amounts that would result in violations of water quality
standards in the proposed lake.
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• •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.43 Discuss the potential impact on the EPA The Trinity Foam site is located approximately one mile from the edge
Trinity Foam site and contamination of the proposed lake. It is also located outside of the Randleman
of nearby groundwater wells. Lake watershed, and drains to Caraway Creek in the Yadkin-Pee Dee
River Basin. The ground elevation at the Trinity Foam site is
approximately 795 feet m.s.l. Because of the site evaluation,
drainage and distance from the proposed lake, the proposed project
is not expected to affect the extent of groundwater contamination from
the Trinity Foam site. No revisions to the EIS are necessary.
5.44 Provide further discussion and EPA
perhaps study of the influence of soil
hydration from the proposed lake on
the VOC plume from the Seaboard
Chemical Corporation site and
possible DNAPLs relative to future
and continual lake contamination.
Consider the potential of fracture flow
and the movement of a DNAPL
plume by gravity along the bedrock
plane for both the Seaboard and High
Point Landfill sites.
5.45 Provide additional discussion of the EPA
lake modeling regarding potential
channeling that would hinder
complete and uniform mixing in the
lake and reduction of contaminant
levels at the water intake.
See response to Comment 5.1.
Consideration of the morphometry of the proposed lake indicates that
complete lateral mixing should occur welt upstream of the water
intake. The upstream segment on the Deep River, where the three
primary sources of lake contamination are located, is long and narrow,
with an average width of 258.3 feet and a length of 4.4 miles. This
section of the lake is expected to exhibit advective characteristics with
a short residence time, driven by inflows from the Deep River, but the
length-to-width ratio is sufficiently large to allow ample time for mixing.
No physical structures exist to prevent lateral mixing. Further, the
shallow character of this segment (average depth 13.65 feet),
advective flow, and susceptibility to wind-induced mixing are both
expected and predicted to prevent the formation of significant thermal
stratification in this segment.
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• s

SUMMARY OF DEIS COMMENTS
COMMENT
5.45 (Continued)
COMMENTOR RESPONSE
This segment can be treated as aslow-moving river segment for
purposes of obtaining an upper bound estimate of the distance to
complete mixing. A conservative approach assumes that a pollutant
load enters as a bank discharge, with minimal initial mixing. The
standard engineering formula for obtaining an order-of-magnitude
estimate of distance to complete lateral mixing for a bank discharge
is (Thomann and Mueller, 1987, pp. 50-51)
2
L~ - 2.6 U B
H
where:
Lm = length to complete mixing (feet),
U = average velocity (fps),
B = average width (feet), and
H = average depth (feet).
Water quality modeling for the upper Deep River segment (upper 4.4
miles of the lake) using the BATHTUB lake model suggests that
average velocities within this segment will range from 0.021 to 0.14
fps, depending on seasonal hydrologic conditions, with an average
velocity under average meteorologic conditions of 0.094 fps. Using
the formula above, the estimated length to complete lateral mixing
ranges from 270 to 1,780 feet. Thus, complete lateral mixing is
expected to occur well upstream of the water intake.
Section 5.3.5.4 of the FEIS includes additional information on the lake
modeling and on mixing in the proposed lake.
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• •

SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.46 Provide further discussion of EPA See response to Comment 5.11.
treatment processes at the High
Point Eastside WWTP in relation to
water quality, e.g., sewer
overtlow/bypass issues, fail-safe
overflow provisions, and treatment
redundancy for protection against
microbial kill-off.
5.47 Estimate instream metals EPA The DEIS text on which this comment is based refers to metals
concentrations from the High Point concentrations within the proposed Randleman Lake (not "instream").
Eastside WWTP for the low flow The State is expected to ensure that the High Point Eastside WWTP
condition. effluent continues to meet all water quality standards within the
receiving stream as part of the NPDES permit process.
Concentrations resulting from this effluent within the lake will be less
than concentrations in the receiving stream; thus, compliance with
appropriate NPDES permit limitations will also ensure meeting water
quality standards for metals within the lake. It is, however, relevant
to consider the range of possible metals concentrations expected in
the lake, and not just the annual average concentration.
Maximum metals concentrations within the lake will occur under
conditions of minimum dilution. North Carolina typically evaluates
effluent limitations for compliance with water quality standards by
using a minimum dilution flow, specified as the minimum average
flow, for a period of seven consecutive days that has an average
recurrence of once in ten years (7Q10 flow) (15A NCAC
26.0206(x)(1)). The regulations recognize, however, that use of the
7Q10 flow is not always appropriate (15A NCAC 28.0206(x)):
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.47 (Continued)
COMMENTOR RESPONSE
Water quality-based effluent limitations are developed to allow
appropriate frequency and duration of deviations from water
quality standards so that designated uses of receiving waters are
protected... A flow design criterion is used in the development of
water quality-based effluent limitations as a simplified means of
estimating the acceptable frequency and duration of deviations.
More complex modeling techniques can also be used to set
effluent limitations directly based on frequency and duration
criteria published by the U. S. Environmenfal Profection Agency...
For a lake, a 7Q10 flow is not directly defined. Maximum
concentrations of metals from the Eastside WV1rfP are expected in
the part of the proposed Randleman Lake nearest the outfall, in the
upper Deep River arm. As noted in the response to Comment 5.45,
this segment is long and narrow, and is expected to exhibit persistent
advective flow even under drought conditions, due primarily to the
presence of flow from the WW'fP. The current average flow from the
VWVfP is 10.5 mgd, or about 16 cfs. Under such conditions, USEPA
guidance (USEPA, 1991) states that critical design conditions within
the reservoir can be approximated as those appropriate to a regulated
river, using appropriate minimum (7Q10) inflows and minimum in-lake
mixing.
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• ~ •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.47 (Continued) Flows in the Deep River at the head of the proposed Randleman Lake
have not been gaged. However, a USGS gage has been in operation
on the Deep River near Randleman (USGS gage 02099500) since
1929. This gage is near the Guilford-Randolph County line and
several miles downstream of the Eastside WW'fP. Flow at this gage
was altered in 1971 by the completion of Oak Hollow Lake upstream.
An analysis of low flows at this gage since 1971, using a Log Pearson
III analysis, yields an estimated 7Q10 flow of 12 cfs. This is less than
the current average flow from the Eastside VWVfP. It is therefore
appropriate to evaluate minimum dilution flow into the headwaters of
the lake as equal to flow from the VWVTP. The fact that Richland
Creek, the receiving water for the High Point Eastside effluent, and
the Deep River downstream of Richland Creek are effluent-dominated
are reflected in the fact that permit limits for the Eastside VWVfP are
set equal to ambient water quality standards.
Given that the system is effluent-dominated during low flow, the upper
bound on potential concentrations within the upstream end of the lake
is determined by the concentrations in the effluent. Due to longer
residence time and mixing, however, the lake will not reflect
instantaneous concentrations in the effluent, but rather concentrations
averaged over time. A scoping analysis of potential maximum metals
concentrations in the lake can be obtained by examining effluent
monitoring data. Monthly average metals concentrations are
presented in Table 4 for 1997, the last year with complete monitoring.
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•
• •
Table 4
High Point Eastside VWNTP Effluent Metals Concentrations, Monthly Averages for 1997 (Ng/L)
Month Cadmium Chromium
(Total) Copper Lead Mercury Nickel Silver Zinc
1/97 <1.0 <5.0 14.8 <5.0 - <10.0 <5.0 66.6
2/97 2.2 <5.0 13.1 <5.0 - <10.0 <5.0 56.0
3/97 <1.0 <5.0 9.5 <5.0 - <10.0 <5.0 72.0
4/97 <1.0 <5.0 9.4 <5.0 <0.2 <10.0 <5.0 58.0
5/97 <1.0 <5.0 9.3 <5.0 - <10.0 <5.0 66.0
6/97 <1.0 <5.0 8.4 <5.0 - <10.0 <5.0 74.0
7/97 <1.0 <5.0 9.6 <5.0 <0.2 <10.0 8.3 60.0
8/97 <1.0 <5.0 12.4 <5.0 - <10.0 <5.0 18.0
9/97 <1.0 <5.0 12.7 <5.0 - <10.0 <5.0 43.0
10/97 <1.0 <5.0 16.6 <5.0 <0.2 <10.0 <5.0 54.0
11/97 <1.0 <5.0 18.3 5.9 - <10.0 <5.0 62.0
12/97 <1.0 <5.0 10.3 <5.0 - <10.0 <5.0 62.0
Average* 0.6 ND 12.0 2.8 ND ND 3.0 58.0
NPDES limit 2.0 50 - 25.0** 0.012 25.0 - -
State
Standard 2.0 50 7.0
(AL) 25.0 0.012 25.0 0.06
(AL) 50.0
(AL)
* Average calculated with below detection limit (less than) values set to one-half the detection limit for all compounds
detected at least once.
** Effluent limit with proposed Randleman Lake.
AL: State-specified Action Level requiring monitoring and evaluation of potential toxicity.
ND: Never detected.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.47 (Continued)
COMMENTOR RESPONSE
The existing NPDES permit specifies effluent limitations equal to the
State water quality standard for cadmium, total chromium, lead,
mercury, and nickel. Chromium, mercury, and nickel were never
detected above quantitation limits, either in 1997 or in 1998
monitoring to date. Lead concentrations have remained well below
the standard. For cadmium, the annual average concentration is well
below the standard; however, a single observation in February 1997
of 2.2 Ng/L was slightly above the permit limit and state standard of
2 Ng/L. This one observation is believed to be an anomaly and
cadmium has not been detected above the quantitation limit in
subsequent monitoring. In any event, operation of the VWUfP in
compliance with the existing NPDES permit will result in
concentrations of metals in the lake which are well below applicable
standards for cadmium, total chromium, lead, mercury, and nickel.
Silver, copper, and zinc are monitored by High Point, but do not
currently have NPDES permit limits. For these three metals, the State
specifies an Action Level, rather than a water quality standard. Action
levels allow flexible application in the determination of effluent
limitations, but are also applicable as ambient water quality standards
(15A NCAC 28.0211(4)):
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.47 (Continued)
COMMENTOR RESPONSE
Action Levels for Toxic Substances: if the Action Levels for any
of the substances listed in this Subparagraph... are determined
by the waste load allocation fo be exceeded in a receiving water
by a discharge under the specified low Now criterion for toxic
substances... the discharger will be required to monitor fhe
chemical or biological effects of the discharge... Those
substances for which Action Levels are listed... will be limited as
appropriate in the NPDES permit based on the Action Levels...if
sufficient information (to be determined for metals by
measurements of that portion of the dissolved insfream
concentration of the Action Level parameter atfributab/e to a
specific NPDES permitted discharge) exists to indicate that any
of those substances may be a significant factor resulting in
Toxicity of the effluent,•
For purposes other than consideration of NPDES permitting of
point source discharges as described in this Subparagraph, the
Action Levels in this Rule, as measured by an appropriate
analytical technique, will be considered as numerical ambient
water quality standards.
Silver has been detected once in effluent monitoring, at a
concentration well above the Action Limit. This anomalous
observation is likely due to an industrial process discharge and is not
reflective of average loadings. NCDWQ has not monitored for silver
within the Deep River during their intensive surveys. Further, the
quantitation limit used in the analyses of the effluent is nearly 100
times greater than the Action Level. As a result, there are no data on
which to base a quantitative analysis of silver concentrations in the
lake resulting from the WWTP discharge. It is suspected, however,
that average silver concentrations in the WWTP effluent will be low,
and that any occasional peak loads will be rapidly diluted upon
entering the lake.
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.47 (Continued) For copper and zinc, individual monthly average concentrations in the
effluent, as well as the annual average concentration, are above the
State Action Levels. For these constituents, an analysis of expected
ambient concentrations within the proposed Randleman Lake is
appropriate.
F~cpected concentrations in the lake segment below the discharge can
be calculated through use of a mass balance model. Assuming that
a chemical is completely mixed throughout the volume, V;, of a lake
segment, i, and that exchange with the next downstream segment
occurs only by advection, a mass balance of the total chemical mass
contained in the water column of the lake segment may be written as:
~r
Yt dt ~ Wr-Q;~ci-vy•Ar'Q~ ~2~
where c is concentration (M/L3), f is time (T), Q is flow (L3/T), W is
mass loading rate (M/T1, v, is net reaction and exchange loss rate per
unit area basis (UT), and A is segment surface area (LZ).
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.47 (Continued) At steady state, do/dt = 0 and (2) may be solved for c:
~' - ~t
Q~ . va Ar ~3)
or, dividing the top and bottom of (3) by A;,
c~ - Wj A~q~ ' va) (4)
where qs = Q/A is segment overflow rate (L/T'). This is the classic
solution for toxicant concentration in a mixed lake of Thomann and Di
Toro (1983) and is similar to the lake mass balance equation for total
phosphorus presented by Vollenweider (1969). If W is expressed in
Ng/yr, A in mz, and qs and vt in units of m/yr, Equation (4) yields c in
Ng/m3, equivalent to nanograms per liter (ng/L).
For metals, the only loss mechanism considered is due to sorption
and settling (interaction with the sediment). Following Chapra (1991),
the sediment interaction can be expressed in terms of a recycle ratio,
Fr:
v~ - ~1-Fr ~•(vsfpl . vd fdl) (5)
where fd, is the dissolved fraction in the water column, equal to
1/(1+Kdm); vs is the settling velocity, (L/T); fp, is the particulate
fraction in the water column, equal to 1 - fd~; vd is a diffusion mass
transfer coefficient (UT); Kd is a partition coefficient (L3/M); and m is
the suspended solids concentration (M/L3).
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~ • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.47 (Continued)
COMMENTOR RESPONSE
The recycle ratio, Fr, contains factors governing sediment interaction,
and represents the ratio of the rate of sediment feedback of
contaminant (i. e. , resuspension and diffusion) to the total rate at
which the sediment purges itself of contaminants (i. e., resuspension,
diffusion, and burial). An additional simplifying assumption can be
made. If it is assumed that the partition coefficients in the water and
sediment layer are equal, Chapra (1991) shows that diffusive
sediment-water transfer will either be negligible or result in a loss from
the water to the sediments. Therefore, ignoring the diffusion
coefficients will either have negligible effect on the solution or result
in an upper-bound (conservative) prediction. The general expression
for loss rates can then be written as:
v~ - (1 - Fr ~ vs ~t (s~
Water body parameters for application of the model are summarized
in Table 5.
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• • •
Table 5
Parameter Values for Metals Fate and Transport Model: Water Body Characteristics
Parameter Values Source
z,A Segment depth, area variable BATHTUB model specification for Randleman Lake (Hazen and Sawyer,
1998).
qs Segment overFlow rate (m/yr) variable BATHTUB model results, future land use conditions across range of
flows.
m Solids concentration in water 10 Conservative estimate appropriate to region

column (mg/L) .
Fr' Resuspension ratio 20% Assumption that less than 20% of sedimenting solids within the lake will
be subject to resuspension into the water column.
vs Settling velocity (m/yr) 1000 Settling velocity depends on both turbulence and particle size. Thomann
and Mueller (1987) suggest a range of 900 to 1800 m/yr for Great Lakes.
Using Stokes Law, settling velocity for fine particles (clay with 20 Nm
clumps) is about 900 m/yr. Most likely value is placed in the low end of
the range to account for probable effects of turbulence in this narrow
impoundment.
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.47 (Continued) Application of the modeling approach also requires calculation of a
partition coefficient to particulate matter, Kd. For metals, the partition
coefficient is generally found to vary as a function of solids
concentration. USEPA (1984, p. I-46) provides estimates of partition
coefficients for metals in the form:
Kd - Kpp•SS
where Kd is in units of L/kg, SS is suspended solids concentration in
mg/L, and K~ and a are parameters. The coefficients given for
copper and zinc are as follows:
Copper: K~ = 2.85 x 106 a = -0.900
Zinc: K~ = 3.34 x 106 a = -0.678
Calculation of concentrations in the lake also requires assumptions
about concentrations in the upstream flow. Intensive monitoring by
NCDWQ in 1992-1993 and in 1997 provides information on
background concentrations in the Randleman Lake area from
observations in the Deep River (Station RL2) and Richland Creek
(RL3), both upstream of the Eastside WWTP. Average copper
concentrations in both monitoring periods at both stations were less
than 5 Ng/L; so 5 Ng/L has been assumed as the background copper
concentration for this analysis (the Draft EIS assumed 4 Ng/L).
NCDWQ generally reported zinc as not detected at a detection limit
of 10 Ng/L in 1992-93; however, 1997 sampling shows an average
concentration of 29 Ng/L upstream in Richland Creek and 41 Ng/L in
the Deep River above the WWTP. A background zinc concentration
of 42 Ng/L was assumed for this scoping exercise (the Draft EIS
assumed 10 Ng/L).
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•
• •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.47 (Continued) The Eastside VWVfP was assumed to discharge at 10.5 mgd, the
average flow over recent years, with metals concentrations at the
average values presented in Table 4. Use of average, rather than
maximum values is justified because of the mixing and dilution effect
of the lake, particularly at low flow conditions when residence times
in the upper segment are long. The analysis is presented for the
upper Deep River arm lake segment, the segment nearest the WWTP
outfall, as described for the lake eutrophication model in the Draft EIS.
Predictions were made over a variety of flow conditions, selected from
the Black ~ Veatch analysis of reservoir inflows based on 1930-1988
meteorological conditions, ranging from minimum dilution conditions
(summer conditions during extreme drought year of 1967) to high flow
conditions (annual flow balance for high flow year of 1975). The
ranges of predicted metals concentrations in this segment are shown
in Table 6. For both copper and zinc, the upper bound on the
predicted concentration is well below the State Action Level, due to
a combination of losses to sedimentation and dilution.
Table 6
Range of Estimated Metals Concentrations (ug/L) in
Upstream Deep River Arm of Proposed Randleman Lake
Estimated Concentration

Parameter
Minimum
Maximum State Action
Level
Copper 0.5 1.9 7.0
Zinc 2.4 14.1 50.0
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.47 (Continued)
The combined effect of sedimentation and dilution will also result in
rapid diminution of concentrations within downstream segments of the
lake, with the result that concentrations at the water intake should
approach background levels.
Finally, at projected design flows from the WWTP of 26 mgd,
discharge at the same metals concentrations are expected to result
in maximum copper concentrations less than 2.3 Ng/L and maximum
zinc concentrations less than 17.0 Ng/L within the upstream Deep
River Arm of the lake, still well below State Action Levels.
Section 5.3.5.4 of the FEIS includes additional information on
expected metals concentrations in the proposed lake.
COMMENTOR RESPONSE
5.48 Include an evaluation of the allowable EPA
maximum nutrient loadings to provide
for maintenance of the State
chlorophyll a criteria in the proposed
lake.
Allowable maximum nutrient loadings are discussed in the Nutrient
Reduction Strategy for the proposed Randleman Lake watershed (see
response to Comment 5.9). According to the Nutrient Reduction
Strategy, the allowable total phosphorus loading for the upper
segment of the Deep River arm of Randleman Lake is 2,880 kg during
a high flow year, 1,800 kg during an average flow year, and 600 kg
during a low flow year based on the water quality modeling analyses.
For the upper segment of the Muddy Creek arm of Randleman Lake,
the allowable total phosphorus loading is estimated to be 2,290 kg
during a high flow year, 1,700 kg during an average flow year, and
780 kg during a low flow year. The allowable phosphorus loading is
based on the loading required not to exceed • a chlorophyll a
concentration of 40 ug/L for more than 5 percent of the growing
season. Because it is not reasonable to predict that the 40 ug/L water
quality standard be predicted to be met 100 percent of the time, a
model-predicted frequency of less than 5 percent of days during an
annual growing season (May to October) with chlorophyll a
concentration greater than 40 ug/L is a reasonable indicator and
appropriate target for assessing nutrient assimilative capacity.
Sections 5.3.5.5 and 5.3.5.6 of the FEIS includes additional
discussion of the Nutrient Reduction Strategy.
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• •

SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.49 Relative to proposed inundation of EPA
two segments of the Deep River
which are included in the State's
303(d) list of impaired waters (p. 4-
10), provide documentation that the
proposed project wilt not cause or
contribute to use impairments and
violations of State water quality
standards. Provide a thorough
analysis of the impacts of lake ,
construction and operation on water
quality with respect to fecal coliform
and turbidity.
The proposed project will not result in violations of any State water
quality standards except for chlorophyll a (see response to Comment
5.10).
An analysis of projected fecal coliform concentrations in the proposed
lake was also conducted (Hazen and Sawyer, 1998). The analysis
included estimates of the potential upper bound fecal coliform bacteria
concentrations in each segment of the proposed lake. The predicted
range of the 80th percentile of fecal coliform concentrations is as
follows:
Estimated Range of 80th Percentile
Concentration of Fecal coliform Bacteria
During Low Flow Conditions
Segment (organisms/100 mL)
Deep River 1 104-223
Deep River 2 10-23
Deep River 3A 5-11
Deep River 3B 18-39
Muddy Creek 1 32-144
Muddy Creek 2 59-130
Near Dam 35-76
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.49 (Continued)
COMMENTOR RESPONSE
In all cases, the predicted range is less than the 400 organisms per
100 mL water quality standard for the 80th percentile. The
conservative predictions are also less than the geometric mean water
quality standard of 200 organisms per 100 mL in all segments except
Deep River 1, reflecting the fact that die-off is substantially increased
in a lake compared to existing free-flowing stream conditions.
Reductions in fecal coliform concentrations in the proposed lake
would be primarily due to the increased residence time and dilution
volume. Predicted concentrations are highest in the Deep River 1
segment because the dilution volume is small and the residence time
is short. The screening analysis predictions are segment-wide
averages. Therefore, excursions of the standard for fecal coliforms
may still occur in the locality of any concentrated sources, such as
operating dairies. Since there are no dairies in the Deep River 1
segment of the lake, high fecal coliform concentrations in this
segment appear to be associated with urfian development, particularly
in areas tributary to Richland Creek and the portion of the Deep River
immediately below the confluence with Richland Creek. A wetlands
mitigation site is planned to be constructed on Richland Creek
upstream of the Eastside WWTP and would provide interception of
urban runoff from High Point and would also provide additional
opportunity for inactivation of bacterial loads before they reach the
proposed lake. The PTRWA also intends to work with local
jurisdictions to ensure that enforcement of all ordinances regarding
on-site disposal of domestic wastewater, including septic tanks,
receives high priority.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.49 (Continued) The proposed project would be expected to result in short-term
increases in turbidity in the Deep River downstream of the proposed
dam site. These effects would be minimized by implementation of
effective erosion control measures in accordance with an approved
sedimentation and erosion control plan. On a long-term basis, the
proposed reservoir would be expected to reduce the turbidity
downstream of the proposed project by trapping sediment within the
proposed lake. The proposed watershed protection measures
adopted in accordance with the Nutrient Reduction Strategy and
Implementation Plan (see response to Comment 5.9) would also
result in reduced levels of sediment discharged to the proposed lake
through nonpoint source controls on new development in the
watershed.
Section 5.3.5.2 of the FEIS includes additional information on the
projected impacts of lake construction and operation on fecal colifomt
concentrations and turbidity.
5.50 Provide more discussion to justify the EPA The permitted flow of 26 mgd has been used in the recent nutrient
use of an effluent flow of 20 mgd for loading analyses referenced in Sections 5.3.5.5 and 5.3.5.6 of the
the High Point Eastside WWTP in the FEIS (Hazen and Sawyer, 1998).
nutrient loading analyses instead of
the proposed permitted flow of 26
mgd.
5.51 Provide an explanation in the EIS EPA The nutrient loading analysis presented in the EIS Appendix has been
Appendix of how base flow quality superseded by the recent nutrient loading analysis referenced in
assumptions were made in Sections 5.3.5.5 and 5.3.5.6 of the FEIS (Hazen and Sawyer, 1998).
determining nutrient loadings for both
existing and future loading scenarios.
Consider providing a sensitivity
analysis for these inputs to determine
the relative importance for model
predictions.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.52 Provide more information to support EPA Significant increases in groundwater levels will occur within and
the conclusions that "minor changes around the perimeter of the proposed reservoir. In general, when the
in the groundwater level will occur" reservoir is filled, the hydraulic gradient will rise to reach a new
and "overall, groundwater effects on equilibrium level. During periods when the reservoir level is high,
the water quality of Randleman Lake bank storage will tend to feed the groundwater. During periods when
are predicted to be insignificant" (p. the reservoir level is falling, the groundwater will discharge to the
5-9)• reservoir as it does to other surface waters.
Groundwater wells were installed in rock at the dam site during
geology testing for the proposed dam (GEI Consultants, 1996b). The
readings at the wells indicate that groundwater in the valley section
within 100 feet of the Deep River is very close to the elevation of the
water in the Deep River. Groundwater elevations in wells installed on
the sloping abutments of the dam indicate that groundwater
elevations rise approximately 40 feet above the surface of the Deep
River at a distance of approximately 600 feet from the river.
Based on the groundwater elevations and the distances between the
observation wells, a gradient for groundwater flow was estimated
downslope and along the axis of the dam toward the river. The
gradients in the abutment rock are indicative of low permeability in the
underlying rock. Areas of higher permeability were also encountered.
Any potential problems associated with seepage loss beneath the
reservoir closure at the dam because of fractured rock will be
addressed with blanket and curtain grouting beneath the dam axis.
A discussion of groundwater effects on water quality in the proposed
lake is included in the response to Comment 5.1 above. Section
5.3.5.1 of the FEIS includes additional information on the effects of
the proposed project on groundwater levels and the effects of
groundwater on the water quality in the proposed lake.
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• ~ •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.53 Provide an appropriately-scaled EPA Topographic and potentiometric maps showing groundwater levels in
topographic map and potentiometric the watershed for the proposed Randleman Lake are not available.
map for groundwater levels. Development of such maps is not considered necessary; they are not
Generate cross-sections which relevant to the NEPA process since they are not expected to affect
represent the changing the reservoir yield analysis or the toxic substances evaluation.
potentiometric slopes within the Groundwater levels and potential impacts of contaminated
watershed. Provide land use maps groundwater at the High Point Landfill and the Seaboard Chemical
and descriptive text with supporting Co. site are relevant to the NEPA process and are discussed in detail
information. in the FEIS (see response to Comment 5.1). A geologic map,
hydrogeologic cross-section maps, and topographic maps showing
groundwater levels at these sites have also been prepared (ERM-
Southeast, 1997). A discussion of this information is provided in
Section 5.3.5.1 of the FEIS.
5.54 Consider changes to the EPA The reservoir trophic level evaluation in Appendix A has been
potentiometric slope and their effect superseded by recent modeling conducted in response to comments
on groundwater inflow/baseflow on the DEIS (see response to Comment 5.2). The results of this
estimates (Appendix, p. IV-18). Use modeling are discussed in Sections 5.3.5.5 and 5.3.5.6 of the FEIS.
of current values may not be
conservative with respect to yield and
mass balance calculations. Provide
a justification for the baseflow
concentration.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.55 Discuss potential impacts from EPA See response to Comment 5.1 for the Seaboard Chemical Co. site
saturation of buried waste and and the High Point Landfill. For the Randleman Dump site, all buried
contaminated soils for the Seaboard waste and surface material will be removed and disposed of off-site
Chemical Co., High Point Landfill and prior to completion of the proposed project. Eight representative
Randleman dump sites. Indicate samples were taken of soils on the site and analyzed for pesticides,
extent and depth of burial, if known. PCBs, and TCLP RCRA metals. The soils on the sites were found to
Show locations on topographic and contain very low concentrations of pesticides, PCBs and metals, with
potentiometric maps. Discuss the values not exceeding applicable regulatory limits or guidelines.
number, location and results of Groundwater samples were also taken from the site at four locations,
samples, including TCLP analysis. one uphill of the dump area and one downhill of the dump area
Address the time frame for removal (Trigon, 1993). Samples were analyzed for volatile organic
or remediation and reference to the compounds, semi-volatile organic compounds, PCBs, total RCRA
time frame for the proposed project. metals, nitrate/nitrite, BOD and COD. Test results indicated that
Discuss whether removal costs unfiltered groundwater samples from two of the sites exhibited
include verification sampling and concentrations of total RCRA metals slightly above North Carolina
industrial landfill disposal. Discuss groundwater quality standards. No other chemicals were found at
the concentrations and extent of concentrations exceeding State standards. A representative of the
groundwater contamination. Discuss Superfund Section of the N.C. Department of Environment and
treatment proposed and regulatory Natural Resources, Division of Waste Management indicated that,
authority. Discuss where and at what based on these results, no additional groundwater analysis is
concentrations groundwater warranted (GEI Consultants, 1996a).
contamination will impact the
proposed lake. The planned cleanup of the Randleman Dump site will be conducted
in conformance with DWM guidelines (see response to Comment
5.28). The location of the Randleman Dump site is shown on Figure
7b in the FEIS. Additional information on the evaluation of the
Randleman Dump site is provided in the report entitled Former Dump
Area, J.L. Coble Property, Randleman, North Carolina (GEI
Consultants, 1996a).
5.56 Provide more complete information EPA See response to Comment 5.1.
with respect to groundwater sampling
and monitoring data, hydraulic
conductivity data and aquifer test
data.
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• •
•
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.57 Develop a more thorough EPA
assessment of the groundwater flow
regime and its impact on contaminant
concentrations.
5.58 Provide data to support the 20-foot EPA
thickness used in the Appendix to
calculate Darcy flow of the
groundwater (p. V-7). Provide a
bedrock surface map. Identify
fractures and water-bearing zones in
the bedrock. Assess fracture flow.
5.59 Identify and assess additional EPA
potential sources of groundwater
contamination, including dumps,
RCRA generators and TSD facilities,
CERCLA sites, and TRI sites.
See response to Comment 5.1.
See response to Comment 5.1.
Additional potential sources of groundwater contamination were
evaluated, including landfills, CERCLA sites, TRI sites, RCRA
generators and TSD facilities. A list of existing open and closed
landfills in the proposed Randleman Lake watershed is presented in
Table 28. Several active and closed land clearing inert debris (LCID)
landfills are located south of the City of Greensboro in Guilford
County. Inspection of these landfills has been delegated to the
Guilford County Department of Public Health. Based on
conversations with Guilford County staff, one of these landfills, the
Groome and Strickland Landfill has had problems with leachate in the
past. These problems have resulted in the release of leachate to
Hickory Creek (Evans, 1998). NCDENR monitoring of this site
indicated the presence of phenols and other parameters in the
leachate and in downstream surface waters. According to Guilford
County staff, the leachate problems at this site have now been
corrected and no further leachate has been observed. No leachate
problems have been identified at the other LCID landfills inspected by
Guilford County. These landfills primarily receive inert materials
which are not expected to cause contamination of groundwater in the
vicinity of the landfill sites.
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• • •
Table 28
Landfills in the Proposed
Randleman Lake Watershed
No. Name Type* Location Status
1. D.H. Griffin CD Wiley Davis Drive open
2. D.H. Griffin LCID Wiley Davis Drive open
3. Grandover LCID Grandover Parkway closed
4. Joyce LCID Commercial Road closed
5. Thomas Kelly LCID Winford Road closed
6. A-1 Sand Rock LCID Bishop Road open
7. A-1 Sand Rock -Phase 1 LCID Bishop Road closed
8. Viewmont Sand Rock LCID Viewmont Road open .
9. Doggett LCID Viewmont Road closed
10. B&B LCID Viewmont Road In process of closing
11. Groome and Strickland LCID Viewmont Road closed
12. Fred Groome LCID Viewmont Road closed
13. Thompson Arthur LCID Longacre Road closed
14. Doggett LCID Bishop Road open
15. Kersey Valley Road Landfill MSW Kersey Valley Road open
16. Jackson Lake Road Landfill SW Jackson Lake Road closed
17. Old Riverdale Drive Landfill MSW Riverdale Drive closed
CD = Construction and demolition
LCID = Land clearing inert debris
MSW = Municipal Solid Waste
SW = Solid Waste
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.59 (Continued)
COMMENTOR RESPONSE
One construction and demolition landfill, the D.H. Griffin Landfill on
Wiley Davis Dr., has been identified in the Randleman Lake
watershed. This landfill is inspected by the N.C. Division of Waste
Management, Winston-Salem Regional Office. No water quality
problems have been identified for this landfill.
Other landfills in the Randleman Lake watershed include the
operating High Point Kersey Valley solid waste landfill and the closed
Jackson Lake and Riverdale Drive Landfills. The Kersey Valley landfill
has a finer and its operation is not expected to result in any discharge
of leachate to groundwater. Potential groundwater contamination
from the Jackson Lake and Riverdale Drive Landfills are addressed
in the responses to other DEIS comments (See responses to
Comments 5.1, 5.3, 5.37, 5.40 and 5.55).
A Resource Conservation and Recovery Act (RCRA) Notifiers List for
Guilford and Randolph Counties from the State of North Carolina
Database was reviewed to identify the RCRA generators and TSD
facilities in the proposed Randleman Lake watershed. RCRA
generators include all facilities which handle hazardous materials
regardless of size, and include numerous small quantity generators,
such as cleaners and laundries, automobile repair shops, service
stations, photo finishers, etc. For the purpose of determining potential
sources of groundwater contamination in the Randleman Lake
watershed, large quantity generators, those that handle more than
1,000 kilograms per month, were evaluated. A list of large quantity
generators in the proposed Randleman Lake watershed is presented
in Table 29. The RCRA Notifiers List also includes TSD facilities,
which are those facilities that treat, store or dispose of hazardous
materials. A list of TSD facilities in the Randleman Lake watershed
is presented in Table 30. Of the 23 large quantity generators, 13 are
upstream of one of High Point's existing water supply lakes. These
sites are not expected to adversely affect the quality of the water
supply from the proposed Randleman Lake because they are not
considered to be adversely impacting High Point's water supply and
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• • •
Table 29
Large Quantity Generators" on RCRA Notifiers List
In the Proposed Randleman Lake Watershed
No. Name ID No. Address Remarks
1. Amerada Hess Corp. NCD000792770 69078 West Market Street Upstream of High Point Lake
Greensboro, NC 27419
2. AMP, Inc. NCD000202549 8420 Triad Drive Upstream of High Point Lake
Greensboro, NC 27235
3. AMP, Inc. NCD981014996 8300 Triad Drive Upstream of High Point Lake
Greensboro, NC 27409
4. AMP, Inc. NC0000202523 719 Pegg Road Upstream of High Point Lake
Greensboro, NC 27409
5. Colonial Pipeline Co. NCD057038168 411 Gallimore Dairy Road Upstream of High Point Lake
Greensboro, NC 27419
6. Concept Plastics, Inc. NCD981865462 2631 E. Green Street --
Hi h Point, NC 27261
7. Exxon Terminal #4187 NCD000825547 6907 W. Market Street Upstream of High Point Lake
Greensboro, NC 27409
8. AMF Hatteras Yachts NCD061793253 2100 Kivett Drive Also Superfund site (requires no further
Hi h Point, NC 27261 action ; is movin out of watershed
9. Lilly Industries, Inc. NCD053491221 2147 Brevard Road Also Superfund site (requires no further
Guardsman Chemicals, Inc. Hi h Point, NC 27263 action ;also TRI site see Table 34
10. Mannington Wood Floors NCD982090383 1327 Lincoln Drive --
Hi h Point, NC 27260
11. Marsh Furniture Co., Inc. NCD003233111 1001 S. Centennial Street Also TRI site (see Table 34)
Hi h Point, NC 27261
12. Mast Tank Cleaning NCR000005298 208 S. Chimney Rock Road Upstream of High Point Lake
Greensboro Greensboro, NC 27409
13. Miller Desk, Inc. NCD003215621 1212 Lincoln Drive Also Superfund site (requires on further
Hi h Point, NC 27261 action
14. Myrtle-Mueller Operations NCD003233137 801 Millis Street --
High Point, NC 27260
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• • •
Table 29
(continued)
Large Quantity Generators* on RCRA Notifiers List
in the Proposed Randleman Lake Watershed
No. Name ID No. Address Remarks
15. Novartis Crop Protection, Inc. NCD061801361 410 Swing Road Also TSD facility (See Table 30); also
(Ciba-Geigy) Greensboro, NC 27419 Superfund site (RCRA permitted)**;
u stream of Hi h Point Lake
16. Prochem Chemicals, Inc. NCD986190213 510 W. Grimes Avenue Also TRI site (See Table 34)
Hi h Point, NC 27260
17. Proctor & Gamble Mfg. NCD003237963 100 Swing Road Upstream of High Point Lake; on ridge line of
Greensboro, NC 27420 watershed
18. RF Micro Devices, tnc. NCR000007187 7914 Piedmont Triad Parkway Upstream of High Point water supply lakes
Greensboro, NC 27409
19. Sequa Chemicals, Inc. NCD096158696 6008 High Point Road Also Superfund site
Sedgefield (Burlington Ind. Greensboro, NC 27407
Chem. Div. 0675
20. Southeast Terminals NCD000609974 6801 W. Market Street Upstream of High Point Lake
Greensboro, NC 27409
21. Star Enterprise NCD096165121 101 S. Chimney Rock Road Also Superfund site; upstream of High Point
Texaco, Inc. Greensboro, NC 27409 Lake
22. Summit Molded Products NCR000006452 7901 Industrial Village Road Upstream of High Point Lake
Greensboro, NC 27409
23. Thomas Built Buses, Inc. NCD003233970 1408 Courtesy Road On ridge line of watershed
High Point, NC 27261
RCRA =Resource Conservation and Recovery Act
* More than 1000 kg/month.
** Facilities that have or are in the process of applying for a RCRA permit to treat, store or dispose of hazardous waste.
J:PRIVATE\WPFILESVv11SCUiANDE1SITABLES24 DOC Page 101

• • •
Table 30
TSD Facilities on RCRA Notifiers List
In Proposed Randleman Lake Watershed
No. Name ID No. Address Remarks
1. Brestl Solution, Inc. NCR000001909 211 Fraley Road --
High Point, NC 27263
2. Novartis Crop Protection, Inc. NCD061801361 410 Swing Road Also large quantity generator* on RCRA
(Ciba-Geigy) Greensboro, NC 27419 notifiers list; also Superfund site (RCRA
ermitted **; u stream of Hi h Point Lake
3. Seaboard Chemical Corporation NCD071574164 5899 Riverdale Drive Also Superfund site (RCRA permitted)**
Jamestown, NC 27282
RCRA =Resource Conservation and Recovery Act
TSD =Treat, store or disposal facility
* More than 1000 kg/month.
** Facilities that have or are in the process of applying for a RCRA permit to treat, store or dispose of hazardous waste
1WAZEN01\Ot\WPDOCS\PRIVATEIWPFILESUAISC\RANDEISITABLES24 DOC Page 102

• • s
SUMMARY OF DEIS COMMENTS
COMMENT
5.59 (Continued)
COMMENTOR RESPONSE
are a significant distance upstream of the proposed reservoir. Three
of the RCRA large quantity generators are also CERCLA (Supertund)
sites which require no further action, in that they pose no
unacceptable risk to human health or the environment. Except for the
RCRA sites that are identified CERCLA sites, no information is
available to indicate that the existing large quantity RCRA generators
and TSD facilities are adversely affecting groundwater quality or
would adversely impact the water quality of the proposed lake.
Existing Federal and State regulatory controls should be enforced to
ensure that there are no releases of hazardous materials to the
environment from these facilities.
Information on the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) sites in the proposed
Randleman Lake watershed was obtained from the N.C. Division of
Waste Management, Supertund Section in their Inactive Hazardous
Sites Program, Annual Report fo the North Carolina Genera/
Assembly (NCDEHNR, 1997). Site maps in the Supertund Section
Fite Room were also consulted to determine site locations for
CERCLA (Supertund) sites in the proposed Randleman Lake
watershed. The N.C. Division of Waste Management, Supertund
Section has established several categories of Supertund sites. These
include sites on the Sites Priority List (SPL), which include inventory
sites with confirmed contamination or known disposal of hazardous
substances that have been ranked using the Prioritization System
rules (15A NCAC 13C.0200). A list of the CERCLA sites in the
proposed Randleman Lake watershed which are on the SPL is
provided in Table 31. Seven sites are listed in Table 31, along with
their ranking on the SPL.
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~ • •
Table 31
CERCLA Sites on NC Sites Priority List
In the Proposed Randleman Lake Watershed
Known Media Quantity
Site Name Rank ID No. Address Contaminants Contaminated tons Remarks
Burlington Industries
Chemical Division 0675 192 NCD096158696 6008 High Point Road
Greensboro, NC 27407 Organics Soil <1
--
Custom Processing and
Manufacturing 19 NCD982117590 1110 Surrett Drive
High Point, NC 27261 Metals, Organics Groundwater, soil Unknown
--

Duke Refining Corp.
76
NCD003230836 2020 Jarrell Street
High Point, NC
Organics Groundwater, soil,
surface water or
Unknown
--
sediment
Hi h Point Coal
g
G
s Pl
t
111
NCD986188837 Centennial Street Organics
(coal tars, coal oils
Surface water or
Unknown
Awaiting signed agreement
a
an High Point, NC ,
ferrocyanide wastes) sediment for remedial action
Monarch Furniture/
Thaden Metals, Inc. 46 NCD990883001 300 Scientific Street
Jamestown, NC Metals Groundwater, soil 175 (est.)
Texaco, Inc. 161 NCD096165121 101 S. Chimney Rock Road
Greensboro
NC 27409 Organics Groundwater, soil Unknown Upstream of
, High Point Lake
Union Oil Co./
SE Terminal
185
NCD000609974 6801 W. Market Street
Greensboro
NC 27409
Organics
Groundwater, soil
Unknown Upstream of
, High Point Lake
J:IPRIVATEIWPFILESIMISCIRANDEISTABLES24.OOC PagQ ~ n

• •

SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.59 (Continued) Another category of CERCLA sites includes those sites with
evaluations pending. This category includes those sites that require
evaluation before the priority of the site can be determined.
According to the Annual Report, very limited resources are available
for the task of ranking sites. A list of CERCLA sites in the proposed
Randleman Lake watershed with evaluations pending is presented in
Table 32. Five sites are listed, including the closed High Point City
Landfill on Riverdale Drive and the Old Randleman Town Dump.
Issues related to the High Point City Landfill are discussed in
responses to other DEIS comments (see above). The Randleman
Town Dump is planned to be removed prior to construction of the
proposed reservoir. Two of the sites listed in Table 32 are also
located in the watershed of High Point Lake, one of the City of High
Point's water supply reservoirs.
A third category of CERCLA sites are those which are RCRA
permitted or are interim status facilities. These are facilities that have
or are in the process of applying for a RCRA permit to treat, store or
dispose of hazardous waste. These sites are exempt from CERCLA
requirements pursuant to G.S. 130A-310(3). There are two sites in
this category in the proposed Randleman Lake watershed and these
are listed in Table 33. They are the Ciba-Geigy Corporation in
Greensboro and the Seaboard Chemical Corporation site on
Riverdale Drive. The Ciba-Geigy site is also upstream of High Point
Lake.
The CERCLA sites listed in the above tables have the potential to
cause groundwater contamination in the proposed Randleman Lake
watershed. It is not known to what extent groundwater contamination
has occurred for the majority of the above sites or what impact
existing contamination would have on water quality in the proposed
Randleman Lake. Based on experience with CERCLA sites upstream
of the existing High Point water supply reservoirs, these impacts are
likely to be minor or nondetectable. Of the identified CERCLA sites,
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• •
Table 32
CERCLA Sites with Evaluation Pending
In the Proposed Randleman Lake Watershed
•
No. Site Name ID No. Address Remarks
1. American Petrofina Marketing/Greensboro NCD096160262 7115 W. Market Street
Greensboro, NC 27409 Upstream of High Point Lake
2. Ashland Petroleum Co. NCD000828814 6311 Bumt Poplar Road
Greensboro, NC Upstream of High Point Lake
3. High Point City Landfill NCD980557565 Riverdale Road __
High Point, NC
4. Union Camp Corporation NCD003216959 Ragsdale Road __
Jamestown, NC

5.
Old Randleman Town Dump
NCD986197374 Walker Mill Road
(SR 1961)
To be removed prior to construction
Randleman, NC of proposed reservoir
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• • •
Table 33
CERCLA Sites Which are RCRA Permitted or Interim Status Facilities
In the Proposed Randleman Lake Watershed
No. Site Name ID No. Address Remarks
1. Ciba-Geigy Corp. NCD061801361 410 Swing Road Upstream of
Greensboro, NC 27419 Hi h Point Lake
2. Seaboard Chemical Corp. NCD071574164 5899 Riverdale Road
Jamestown, NC 27282
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
5.59 (Continued) three are in the critical area of the proposed reservoir, i.e., the High
Point City landfill, the Randleman Town Dump and the Seaboard
Chemical Corporation site. Potential contamination from these sites
is addressed in the FEIS. Remedial action is pending for a fourth site,
the High Point Coal Gas Plant. Remedial action for other sites is
expected to be conducted in order of their ranking on the N.C. Sites
Priority List and as funds are available.
A list of Toxic Release Inventory sites in the proposed Randleman
Lake watershed is provided in Table 34. Toxic Release Inventory
sites are sites which have released one or more of 600 designated
toxic chemicals to the environment. Manufacturers are required to
report these releases by the Emergency Planning and Community
Right-to-Know Act (EPCRA) of 1986. Three TRI sites are located in
the proposed Randleman Lake watershed. Two of the sites are also
RCRA sites and the third, Lilly Industries, Inc. (Guardsman
Chemicals, Inc.), is also a CERCLA (Superfund) site. According to
the 1997 Annual Report on Superfund sites, the Lilly Industries site
requires no further action under the Superfund program. Therefore,
this site is not anticipated to be a potential source of groundwater
contamination or to cause adverse impacts on the water quality of the
proposed reservoir.
The toxic releases for the other two TRI sites, Marsh Furniture Co.
and Prochem Chemicals, Inc., occurred between 1987 and 1993. All
of the releases were either to land or groundwater. The total release
of approximately 10 pounds of diethanolamine and diethyl sulfate to
groundwater occurred in 1990. Neither of the two TRI sites is located
in the critical area for the proposed reservoir. Both sites are tributary
to Richland Creek upstream of SR 1154. Extensive monitoring has
been conducted by NCDWQ at this location (see response to
Comment 5.37). The sampling conducted by NCDWQ suggests that
groundwater from these sites is not resulting in excursions of water
quality standards in Richland Creek. After the proposed lake is
Page 108

• •
Table 34
TRI Sites
In the Proposed Randleman Lake Watershed
•
Quantity
No. Site Name ID No. Address Year Media Ibs Chemicals Remarks
Acetone, glycol ethers,
Lilly Ind., Inc. 2147 Brevard Road methanol, methyl ethyl Also Supertund
1' (Guardsman Chemicals, Inc.) NCD053491221 High Point, NC 27263 1987 Land 2,000 ketone, methyl isobutyl site; requires no
ketone, n-butyl alcohol, further action
toluene, lene
1001 S. Centennial

2.
Marsh Furniture Co.
NCD003233111
Street
1987
Land
500
Toluene, xylene Also RCRA site

High Point, NC 27261 (See Table 29)

3.
Prochem Chemicals, Inc.
NCD986190213 510 W. Grimes Avenue
1993
Land
500 Diethanolamine, ethylene Also RCRA site
High Point, NC 27260 glycol (See Table 29)
1990 Land 40 Diethanolamine, diethyl
sulfate
1990 Groundwater 10 Diethanolamine, diethyl
sulfate
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.59 (Continued)
completed, it is expected that any residual chemicals from these sites
will be further reduced by volatilization, biodegradation, hydrolysis and
photolysis due to the large dilution volume and the long residence
time in the proposed lake. Therefore, these TRI sites are not
expected to have a significant adverse effect on water quality in the
proposed reservoir.
Section 5.3.5.4 of the FEIS includes additional information on the
potential sources of groundwater contamination in the proposed
Randleman Lake watershed.
5.60 Identify and assess additional EPA
potential sources of surface water
contamination, including agricultural
land which is inundated, livestock
areas, crop areas and potential
chemicals of concern.
Potential sources of surface water contamination include agricultural
areas which are inundated by the proposed lake, estimated to cover
approximately 870 acres; agricultural areas tributary to the proposed
lake, estimated to cover approximately 21,810 acres, or approximately
20 percent of the proposed Randleman Lake watershed; livestock
areas in the watershed, incuding six operating dairies; urban or other
developed areas; and point source dischargers to surface waters
tributary to the proposed lake (see response to Comment 5.15).
Potential chemicals of concern include nutrients, oxygen-demanding
materials, heavy metals, pesticides and herbicides, and other organic
and inorganic chemicals. Control of pollutants from these sources will
be in accordance with water quality regulations for point source,
nonpoint source and stormwater pollution in Class WS-IV watersheds
(15A NCAC 28.0216). Measures to control nonpoint source and
stormwater pollution will also include those provided under the N.C.
Sedimentation Pollution Control Act for construction activities.
Agricultural areas to be inundated will be cleared and structures
associated with agricultural operations will be demolished and hauled
away for disposal. All materials that could result in surface water
contamination will also be removed to suitable sites for disposal.
Section 5.3.5.2 of the FEIS addresses these potential sources of
surface water contamination and measures taken to minimize impacts
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
5.60 (Continued)
COMMENTOR RESPONSE
5.61 Evaluate all potential contamination EPA
sources at the point of the sources
impact with the proposed lake.
Compare quantified estimates to
drinking water, recreational and
ecological standards.
5.62 Discuss proposed monitoring and EPA
treatment for pesticides and
herbicides (p. 4-10). Identify the
concentrations of lindane and dieldrin
which exceeded the water quality
standard and note the standards.
of these sources on the water quality of the proposed Randleman
Lake. Measures to control nutrient discharges are addressed in the
Nutrient Reduction Strategy for the proposed Randleman Lake
watershed (see response to Comment 5.9).
See responses to Comments 5.1, 5.42, and 5.47.
The N.C. water quality standards for lindane and dieldrin for all
freshwater are 0.01 and 0.002 ug/L, respectively. The applicable
standard for dieldrin for WS waters is 0.000135 ug/L. Samples were
analyzed in 1992 and 1993 for pesticides and organic chemicals at
seven stations in the area of the proposed Randleman Lake
(NCDEHNR, 1994b). Of these samples, the State standard for
dieldrin was exceeded in one sample, with a dieldrin concentration of
0.003 ug/L. Numerous violations of the State standard for lindane
were detected, and the lindane concentrations ranged from 0.005
ug/L (estimated) to 0.05 ug/L. Sampling for lindane and dieldrin was
also conducted by NCDWQ in 1997 and found no reportable
concentrations. See response to Comment 5.21 for additional
information on modeling conducted to estimate lindane concentrations
in the proposed lake.
No specific monitoring and/or treatment for pesticides or herbicides
is planned. Monitoring conducted by the NCDWQ as a part of the
Basinwide Water Quality Management Plan process includes benthic
macroinvertebrate monitoring, fisheries monitoring, lake assessment
program, aquatic toxicity monitoring, chemical physical
characterizations, sediment oxygen demand monitoring, and Ambient
Monitoring System monitoring. Monitoring at upstream and
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.62 (Continued) downstream points in receiving streams is also conducted by NPDES
dischargers. Nonpoint source control programs under the N.C.
Pesticide Law of 1971 are also managed by the N.C. Department of
Agriculture (NCDOA), and inGude regulations for the use, application,
sale, disposal and registration of pesticides for the protection of the
health, safety and welfare of the people and for the promotion of a
healthy and safe environment. The NCDOA also administers a
Pesticide Disposal Program to provide an available, affordable and
environmentally acceptable mechanism by which any homeowner,
farmer or institution can dispose of unwanted or unusable pesticides.
Section 4.3.5.2 discusses the measured concentrations and
standards for lindane and dieldrin and existing monitoring and control
programs for pesticides and herbicides in North Carolina.
5.63 Define "mean annual concentration" EPA The mean annual concentration is defined in Appendix A, p. V-12.
(pp. 5-11, 5-12). Discuss well Sources of groundwater monitoring well data are discussed in
locations, and frequency and Appendix A, p. V-1. For additional information on the High Point
numbers of samples. Discuss the Landfill and the Seaboard Chemical Corporation site, see response
current status of the Seaboard to Comment 5.1.
Chemical Corporation and High Point
Landfill. Identify the regulatory
agencies.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.64 Determine cumulative contaminant
concentration for all sources (p. II-3,
Section 5). Identify water
classifications and standards.
Compare estimated concentrations to
drinking water, surface water and
ecological standards. Evaluate with
respect to the Clean Water Act,
including generation of TMDLs,
where appropriate (pp. V-12, V-13).
Develop mean concentration for all
constituents, including organic
compounds not currently identified.
Correct Table V-5.to identify the MCL
for dichloromethane (methylene
chloride) of 5 ug/L (also see Table
V-6).
5.65 Discuss the nature and location of
the projected 6 mgd portion of the
reservoir yield that would be
discharged to the Deep River
downstream of the proposed lake (p.
II-1). Discuss the effect of this
discharge. Discuss whether
modeling has been conducted for
dissolved oxygen and the results.
EPA See responses to Comments 5.15, 5.40, 5.41, 5.59, 5.60, and 5.61.
Also see response to Comment 5.1 regarding impacts of the
Seaboard Chemical Corporation site and the High Point Landfill.
EPA Wastewater flows associated with the Randleman and Randolph
County portions of the Randleman Lake yield (totalling 7.01 mgd) are
assumed to be discharged downstream of Randleman Lake. A
portion of the flow is expected to be treated in individual septic tanks.
The remainder will be treated in wastewater treatment facilities and
discharged to surface waters in the Deep River Basin. The
Randleman WWTP currently has a permitted capacity of 1.745 mgd.
Randolph County does not currently have a wastewater collection and
treatment system. The location of potential future wastewater
treatment facilities for Randolph County has not been determined.
The County established a Water Task Force, whose mission was to
examine a broad range of water-related issues and their impact on
the quality of life and long-range development of Randolph County.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.65 (Continued)
The Water Task Force Report, issued in January 1995, set the
following goal: to ensure quality, economically feasible wastewater
treatment systems within Randolph County which provide protection
of groundwater and surface water resources. One strategy under this
goal was to determine areas within the County in need of wastewater
treatment facilities and to explore feasible alternatives. There are no
specific plans to provide additional wastewater treatment plants to
serve Randolph County. Any new treatment facilities will be
evaluated and modeled by the NCDWQ in accordance with basinwide
modeling conducted for the Cape Fear River Basin after an NPDES
permit application is submitted for the proposed discharge. An
environmental assessment will also be prepared for any new NPDES
discharges to ensure that the most cost-effective alternative has been
selected and that environmental impacts have been fully evaluated.
Section 5.3.5.2 of the FEIS addresses the potential for additional
wastewater discharges to the Deep River Basin downstream of the
proposed Randleman Lake.
5.66 Discuss the projected siltation rates EPA
and their effect on removal of organic
and inorganic pollutants (p. II-4).
Discuss the possibility of sediment
acting as a pollutant source.
The projected siltation rate for the proposed reservoir is 0.461 acre-
feet per square mile per year, or an accumulation of 7,880 acre-feet
in 100 years (see Appendix A, p. III-4). A portion of the organic and
inorganic pollutants entering the reservoir will be removed by
incorporation in the sediment. The level of pollutants in the sediment
is not expected to be significantly different than that for other
reservoirs in the Upper Cape Fear River Basin.
Water quality in the proposed Randleman Lake and its suitability for
its intended uses for aquatic life support, recreational use and drinking
water supply will also be monitored under the North Carolina Lakes
Assessment Program. The Lakes Assessment Program is
administered by the NCDWQ and includes assessment of lakes to
determine the trophic state of each lake, a measure of the lake's
nutrient enrichment and productivity, and whether the designated
uses of the lake have been threatened or impaired by pollution.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
5.66
(Continued)
Section 5.3.5.2 of the FEIS includes additional information on
sediment loading to the proposed lake and its potential effects on
bottom dwelling aquatic life.
6. RECREATION
6.1 Evaluate effects of proposed project
on recreational activities, including
fishing and canoeing. Consider
impacts of reduced flows in the Deep
River and increased wastewater
discharges to the Haw River.
LC Water quality in the proposed lake is expected to meet all applicable
WRC water quality standards for protection of aquatic life, human health
RRA1 and water supplies, except for the chlorophyll a standard of 40 ug/L
C-SG (see response to Comments 5.61 and 5.64). Bacterial and nutrient
C-CH levels are not expected to result in an increased incidence of disease
epidemics or localized fish kills (see response to Comment 5.10).
Metals and toxic chemical concentrations are also not expected to
occur at levels which could lead to fish consumption advisories from
bioaccumulation.
The proposed project will result in a reduction in flows downstream in
the Deep River at average flow conditions. This reduction in flows will
be greatest at the end of the 50-year planning period and will range
from around 27 percent at Randleman to 3 percent at Moncure,
approximately 88 miles below the dam. The proposed project will
result in an increase in minimum flows because of the proposed
minimum flow releases from the dam. The minimum flow releases
would range from 30 cfs at normal conditions to 10 cfs when the
reservoir is reduced to 30 percent full or lower. The current 7Q10 low
flow is 7.7 cfs. The reduction in average flows and the corresponding
reduction in water levels may have an adverse impact on canoeing,
especially near the end of the planning period. However, the
proposed increase in minimum flows will have a beneficial effect on
fish species and may increase opportunities for canoeing during the
summer months. Impacts of the proposed project on fishing and
canoeing are discussed in the FEIS in Sections 5.3.10 and 5.3.13,
respectively. The impacts of increased wastewater discharges to the
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
6.1 (Continued)
6.2 Clarify the wording in Section 5.8.3 WRC
concerning stocking of fish by the
NCWRC to reflect the potential
impacts on the fishery that may result
from poor water quality.
6.3 Clarify whether recreation C-WF
opportunities will be provided for the
proposed project (p. 3-1).
Haw River were evaluated in the environmental assessments for the
expansion of the Greensboro T.Z. Osborne WWTP to 30 mgd and
40 mgd. The increased wastewater discharge from the T.Z. Osborne
WWTP is not expected to have a significant effect on recreational
activities, including canoeing, in the Haw River. NPDES permit
effluent limits for the T.Z. Osborne Plant will be set by the NCDWQ at
levels which will ensure that water quality in the Haw River will not
adversely impact human health or aquatic life as a result of the
increased discharge. Also see response to Comment 8.4.
See response to Comment 6.1.
The PTRWA has no specific plans to develop recreational facilities.
However, the PTRWA will cooperate with Guilford and Randolph
Counties in their plans to develop recreational facilities adjacent to the
buffer area around the proposed lake. The recreational facilities will
be limited to boat access and day visitor picnic facilities. Recreational
activities will include boating, fishing and picnicking, as well as nature
study and bird watching. No hunting will be permitted in the buffer
area. Section 5.3.13 of the FEIS discusses the proposed recreational
facilities to be provided. Section 3.2.1 includes a clarification of the
types of recreational facilities to be provided.
6.4 Address the impact of expected EPA Algae growth is not expected to significantly impact the use of the
algae problems on the use of the C-DC proposed lake as a recreational resource. No significant impacts on
proposed lake as a recreational fish species are expected, and the amount of algae growth is not
resource. expected to be significantly different from other North Carolina
reservoirs (see responses to Comments 5.16 and 6.1).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
6.5 Reconsider recreational use of the EPA
proposed lake given the expectation
of eutrophication and the possibility
of toxic effects on aquatic life (p. 3-
24, 5-1, 5-16, 5-17, 5-21).
6.6 Collect more information to better RRA2
assess the impact of the proposed
project on recreation.
7. WATERSHED PROTECTION
See responses to Comments 6.1 and 6.4
(To be added later.)
7.1 Clarify statements on existing DWQ1 Approximately 87 percent of the Randleman Lake watershed is
watershed protection measures. currently protected under water supply watershed protection programs
Explain why some municipalities by the following local governments: Guilford County (which comprises
have not enacted watershed 47 percent of the watershed), Randolph County (37 percent),
protection measures in the Greensboro (2 percent) and Randleman (1 percent). The
Randleman Lake watershed (pp. 3- municipalities of High Point (which makes up 8 percent of the
28, 3-29, 5-24 and 5-25). watershed), Archdale (6 percent) and Jamestown (1 percent) are not
currently implementing any water supply watershed protection
programs for the Randleman Lake watershed, although they may
have watershed protection ordinances that require protection of other
watersheds in their jurisdictions. Rockingham and Alamance
Counties have both adopted watershed protection ordinances which
protect approved water supply watersheds in their jurisdictions;
however, neither have adopted protections for any of the alternatives
discussed in the FEIS, including the Randleman Lake alternative.
Section 3.3.6 of the FEIS has been revised to include the above
information.
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
7.1 (Continued)
7.2 High Point, Jamestown and Archdale WRC
should be required to implement DEH
water supply stormwater regulations. DWQ3
7.3 High Point, Jamestown and Archdale WRC
should make a commitment to
protect area streams with riparian
buffers.
Section 5.4.2 of the FEIS has been revised to indicate that
Greensboro has also enacted watershed protection ordinances for the
Randleman Lake watershed. Section 5.4.2 also indicates that High
Point has agreed to adopt Guilford County's watershed protection
ordinances for the Randleman Lake watershed. Guilford County's
ordinances are more stringent than the State minimum for WS-IV
waters. These more stringent ordinances will also be applicable in
the existing Oakdale watershed overlay district. Jamestown and
Archdale have not yet adopted watershed overlay districts for the
proposed Randleman Lake watershed. However, these jurisdictions
have existing WS-IV water supply protection ordinances for other
watersheds, and it is assumed that similar ordinances will be adopted
for Randleman Lake. Detailed information on existing and proposed
watershed protection measures is presented in the Nutrient Reduction
Strategy and Implementation Plan (Hazen and Sawyer, 1998).
See response to Comment 7.1.
Based on existing ordinances for other water supply watersheds, High
Point, Jamestown and Archdale are expected to require the state
minimum requirements for vegetative buffers for perennial streams of
30 feet for low density development and 100 feet for high density
development. High Point and Jamestown are also expected to
require protected buffers around some intermittent streams (open
drainage channels). Buffer width for these streams varies from
10 feet (15 feet for Jamestown) to the 100-year flood plain contour,
depending on the area of the drainage basin. Section 5.4.2 includes
additional information on proposed stream buffers for watershed
protection. Detailed information on stream buffer requirements is
presented in the Nutrient Reduction Strategy and Implementation Plan
(Hazen and Sawyer, 1998).
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• • •
SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
7.4 Discuss how the Randleman Lake DEH Table 1 in the FEIS has been revised to indicate that the proposed
watershed was determined to be Randleman Lake watershed is moderately developed. It includes
"primarily undeveloped" (Table 1). portions of the municipalities of Greensboro, High Point, Jamestown
and Archdale. Currently, approximately 54.5 percent of the watershed
is forested land or open space. The watershed for the Upper Deep
River Lake alternative is also shown as moderately developed in this
table.
7.5 Develop a Watershed Management DWQ1 A watershed management plan is included in the proposed nutrient
Plan for the Randleman Lake DWQ3 reduction strategy for the Randleman Lake watershed (see response
watershed. DHHS to Comment 5.9).
8. AQUATIC LIFE
8.1 Address the adverse impacts of the WRC See response to Comment 6.1.
potential poor water quality, C-CH
hazardous wastes and heavy metals
on fisheries and recreation in the
proposed lake. Discuss the expected
bioaccumulation of chlorinated
hydrocarbons, heavy metals, and
other hazardous wastes in predatory
fish, such as largemouth bass,
crappie and catfish, and if the fish
would be expected to be safe for
human consumption.
8.2 Clarify adverse impacts on fish WRC
species due to the change from a
stream habitat to a lake environment
(Section 5.3.10).
Section 5.3.10 of the FEIS has been revised to indicate that many of
the species collected in fish surveys conducted in 1992 and 1993 are
characteristic of stream habitats and will be eliminated from the areas
inundated by the reservoir. Of the 34 species listed in Table 19,
approximately one-half will be able to readily adapt to a lake
environment.
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
8.3 Revise wording that says that the
existing Deep River fishery is "not
unique or particularly diverse"
(Section 4.3.10). Revise wording
that states that the existing fishery is
"not a resource of significant value".
Revise Section 5.3.10 to reflect the
potential for a poor fishery in the
proposed reservoir.
8.4 Discuss expected adverse impacts
on fish and recreation in Jordan
Lake.
WRC The sentences that indicate that the existing Deep River fishery is not
unique or particularly diverse and that the existing fishery is not a
resource of significant value have been deleted from Section 4.3.10
of the FEIS. However, the fishery in the proposed reservoir is not
expected to be significantly affected by the water quality in the
reservoir since all water quality standards except chlorophyll a are
expected to be met (see response to Comment 6.1). The chlorophyll
a standard is expected to be exceeded in the upstream portions of the
reservoir only and may result in some adverse impacts on fishery
resources in these areas.
WRC Some adverse impacts on fish and recreation in Jordan Lake are
expected as a result of the proposed project due to the increased
discharge of nutrients to the Haw River Basin from wastewater
discharges and from urban runoff associated with increased
development in the Greensboro service area. Point source loadings
for phosphorus will be controlled by maintaining the effluent
phosphorus from the Greensboro T.Z. Osborne WWTP at or below
the current, effluent limit of 2 mg/L on a quarterly average basis. The
impacts associated with urban runoff will be minimized by
enforcement of watershed protection and erosion and sediment
control measures of the City of Greensboro and Guilford County.
Drainage and stormwater management requirements for development
projects contained in the City of Greensboro stormwater and
subdivision regulations will also minimize adverse impacts of new
development. Section 5.3.5.8 includes additional information on
potential adverse effects of .the proposed project on fish and
recreation in Jordan Lake.
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
8.5 Further clarify impacts to downstream DPR The downstream habitat for the Cape Fear shiner will not be
habitat occupied by the Cape Fear adversely affected by the proposed project. Adequate flows will be
shiner (Notropis mekistocholas) (p. 5- maintained during reservoir filling and during operation of the
22). Discuss potential impacts during proposed reservoir by maintaining a minimum 30 cfs release rate
reservoir filling and precautions taken during reservoir filling (see Section 5.2.6.1) and athree-tiered
to maintain adequate flows. Consult minimum release rate of 30, 20 and 10 cfs during reservoir operation.
with the U.S. Fish and Wildlife Section 5.3.11 of the FEIS indicates that a minimum release rate of
Service with regard to measures to 30 cfs would be maintained during reservoir filling to minimize
be taken. adverse impacts on the Cape Fear shiner.
8.6 Discuss the effect on threatened and EPA Effects of the proposed project on the Cape Fear shiner habitat
endangered species, especially the downstream of the proposed lake are addressed in Section 5.3.11 of
Cape Fear shiner and Carolina the FEIS (see response to Comment 8.5). None of the known
darter, downstream of the project and populations of the Cape Fear shiner is located in the Haw River
in the basins receiving interbasin downstream of the Greensboro T.Z. Osborne WWTP discharge or in
transfers (pp. 4-20, 4-21, 5-17, and the Yadkin River Basin. Therefore, no adverse impacts on the Cape
5-18). Fear shiner are expected as a result of the interbasin transfers
associated with the proposed project. The Carolina darter has also
not been identified in the Haw River Basin downstream of the
Greensboro T.Z. Osborne WWTP discharge. No adverse impacts on
this species are expected as a result of the proposed project. Section
5.3.5.8 indicates that interbasin transfers associated with the
proposed project are not expected to result in adverse impacts on the
Cape Fear shiner or the Carolina darter.
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SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
8.7 Provide the range and duration of EPA Flow duration curves for locations on the Deep River at Ramseur and
flows at High Falls, Gulf and Moncure Carbonton are presented in Appendix A of the FEIS. Ramseur is
and discuss the impact to the Cape approximately 21 miles upstream of the point where the critical habitat
Fear shiner critical habitats on the begins for the Randolph and Moore County population of the Cape
Deep River in Randolph, Moore, Fear shiner. The critical habitat extends for 4.1 miles along the Deep
Chatham and Lee Counties (pp. 5-6, River below this point. High Falls is approximately 4 miles
5-7, 5-16, 5-17, 5-21, 5-22, and downstream of the end of the critical habitat for this population.
Section 4). Relate projected flows to Carbonton is approximately 21.5 miles upstream of the point where
current flows for average, high and the critical habitat begins for the Chatham and Lee County population
low flow conditions. Discuss where of the Cape Fear shiner. The critical habitat for this population
new scouring may occur, the current extends for 2.6 miles along the Deep River. Gulf is located
health of the streams, and modeling approximately 6 miles below Carbonton and Moncure is located
supporting a reduction in BOD and approximately 2 miles downstream of the end of the critical habitat for
an increase in DO. this population.
Based on a review of U.S.G.S. streamflow data for the 10-year period
from 1984 to 1993, current flows for selected gaging stations along
the Deep River are as follows:
Lowest Highest
Daily Mean Average Daily Mean
Location Flow, cfs Flow. cfs Flow. cfs
Near Randleman 3.6-16 127 865-6,560
At Ramseur 18-45 356 2,180-15,100
At Moncure 25-70 1,445 7,160-26,800
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SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
8.7 (Continued) Minimum releases from the proposed reservoir will be based on
reservoir level and will range from 10 to 30 cfs. The minimum release
will be 30 cfs under normal conditions and will decrease to 20 cfs and
then 10 cfs during drought conditions. Estimated periods of time for
each flow release are as follows:
Minimum Release cfs Percent of Time
10 0.3
20 8.0
30 91.7
Based on the above data, a minimum release of 30 cfs would
increase the daily mean low flow at Randleman for all the years
evaluated, and would increase the daily mean low flows at Ramseur
and Moncure by the same amount.
Based on the September average flow duration curve for Ramseur,
the flow value that would be exceed 95 percent of the time without the
effects of the proposed reservoir would be approximately 34 cfs. With
the proposed reservoir, this flow would increase to approximately 42
cfs, or an increase of approximately 24 percent. Corresponding
September average flow values for Carbonton are approximately 55
cfs without the proposed reservoir and 71 cfs with the proposed
reservoir, or an increase of approximately 29 percent.
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SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
8.7 (Continued) High flows would be reduced as a result of the proposed project.
Based on the monthly average flow duration curve for Ramseur, the
flow value that would be exceeded 5 percent of the time without the
effects of the proposed reservoir would be approximately 970 cfs.
With the proposed reservoir, this flow would decrease to
approximately 870 cfs, or a decrease of approximately 10 percent.
Corresponding monthly average flow values for Carbonton are
approximately 3,150 cfs without the proposed reservoir and 2,850 cfs
with the proposed reservoir, or a decrease of approximately 9.5
percent.
In general, the proposed project will increase downstream low flows
due to the proposed minimum releases from the reservoir and will
decrease downstream high flows due to storage and attenuation of
peak flows in the reservoir. The reduction in peak flows will tend to
reduce scouring downstream in the Deep River. No new scouring is
expected as a result of the proposed project.
Cun'ently, the water quality in the lower Deep River downstream of the
proposed project is severely impacted by nutrient loading from
upstream sources (NCDEHNR, 1996a). Water quality issues are
further complicated by a series of dams which reduce velocity by
pooling water upstream of each dam, especially during low flow
conditions when instream waste concentrations are at the highest
percentage and warm temperatures contribute to biological
productivity. Approximately 13 dams are located in the Deep River
between the proposed Randleman Dam and the confluence with the
Haw River. The increased retention time provided by these dams
allows utilization of nutrients by aquatic plants, resulting in excessive
chlorophyll a concentrations and major changes in dissolved oxygen
(DO). Frequently occurring low DO values have been reported in the
Deep River at SR 1400 near Cumnock, the upstream monitoring
station for the Sanford Big Buffalo Creek WWTP.
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SUMMARY OF DEIS COMMENTS
COMMENT
8.7 (Continued)
COMMENTOR RESPONSE
Upstream in the Deep River at Ramseur, benthos data have shown
improvement from Fair in 1983 and 1985 to Good-Fair in 1993.
Benthos data from a downstream location in Moore County have
consistently indicated an Excellent bioclassification. At High Falls and
Carbonton, action levels for copper and iron have been exceeded for
the following percentages of samples:
of Samples
Exceeding Action
Location Levels
Copper Iron
High Falls 33 29
Carbonton 38 56
Fecal coliform counts also exceeded State standards for 38 percent
of the samples from the Carbonton site.
No specific modeling has been conducted to support a reduction in
BOD and an increase in DO for the water discharged from the
proposed reservoir. The proposed reservoir would have amulti-level
outlet structure to allow selective water withdrawals from different
depths to provide releases with the maximum DO content. Control of
the depth of the release water, as well as a reduction in nutrient
loadings from point and nonpoint source discharges to the proposed
lake, would minimize the adverse impacts of the proposed project on
the downstream water quality in the Deep River.
Sections 4.3.5.2, 5.3.5.2 and 5.3.11 of the FEIS include additional
information on existing water quality and potential impacts of the
proposed project on downstream flows and water quality and on the
critical habitat areas for the Cape Fear shiner.
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SUMMARY OF DEIS COMMENTS
COMMENT
8.8 Discuss the effects on bottom
dwelling aquatic life of sediment
containing organic and inorganic
pollutants (p. II-4).
COMMENTOR RESPONSE
EPA Water quality in the proposed reservoir is expected to meet all
applicable water quality standards except for chlorophyll a (see
response to Comment 6.1). No adverse affects on bottom dwelling
aquatic life from sediment containing organic and inorganic pollutants
are anticipated (see response to Comment 5.66). No revisions to the
EIS are necessary.
8.9 Discuss the impacts on biota from CCNC
lack of flow compounded by potential
pollutant overloading resulting from
interbasin transfer from the Deep
River to the Haw River.
8.10 Evaluate the effects of the proposed C-MSM
project on the downstream viability of
the Deep River's aquatic habitat as a
result of toxins which seep into the
water from landfills which the lake
floods.
Minimum flows in the Deep River downstream of the proposed
reservoir will increase compared to current low flow conditions (see
response to Comment 8.7). This should improve water quality and
would have a beneficial impact on aquatic life in the Deep River. The
nutrient reduction strategy for the proposed project would also result
in improved water quality downstream in the Deep River, and would
also improve conditions for aquatic life (see responses to Comments
5.9 and 8.7). Projected reductions in average flow ranging from 27
percent at Randleman to 3 percent at Moncure as a result of
interbasin transfers are not expected to adversely affect downstream
aquatic life. No revisions to the EIS are necessary.
See responses to Comments 5.1, 5.37 and 6.1.
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SUMMARY OF DEIS COMMENTS
COMMENT
9. HUMAN HEALTH
COMMENTOR RESPONSE
9.1 Discuss the potential for residual GC Chlorination will not be used for disinfection at the proposed
byproducts of algae during Randleman Water Treatment Plant. Ozonation will be used in order
chlorination, including THMs. to provide state of the art disinfection performance. No residual
byproducts are expected to form from disinfection by ozone. A small
amount of chlorine as sodium hypochlorite will be added after the
filters, as recommended for disinfection of organisms that slough off
the biological activated filters. Production of THMs from this chlorine
addition is not expected to be significant because of the removal of
most of the organic materials prior to the chlorine addition. No
revisions to the EIS are necessary.
9.2 Evaluate the potential human health NAS See responses to Comments 5.1 and 6.1.
impacts of the Seaboard Chemical C-TA
Co. and High Point Landfill C-CH
hazardous waste sites. C-RP
9.3 Discuss whether any sampling has DEH
been conducted for Cryptosporidium
or Giardia.
No sampling has been conducted for Giardia and Crytosporidium.
The proposed use of ozonation for disinfection would provide the
most effective disinfection performance for Giarrlia and
Crytosporidium compared to other types of disinfection. No revisions
to the EIS are necessary.
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
9.4 Discuss measures to ensure that a DHHS Measures to ensure that a safe raw water supply is maintained are
safe raw water supply is maintained, discussed in the responses to Comments 5.11, 5.18 and 7.5. Erosion
i.e., wastewater treatment facilities and sediment control ordinances and erosion control plans are
improvements, watershed protection discussed in the nutrient reduction strategy report (see response to
plans, erosion control plans, and Comment 5.9). Greensboro, Guilford County, Jamestown and High
monitoring plans (Section 5.8). Point have their own sedimentation control ordinances and provide
the administration and enforcement for these ordinances. Erosion
and sedimentation control measures for Archdale, Randleman and
Randolph County are regulated by the regional offices of the
NCDENR. Raw water quality monitoring will be conducted by the
PTRWA in accordance with applicable state regulations for public
water supplies. Effluent and instream monitoring for wastewater
treatment plants discharging into Randleman Lake will be in
accordance with NCDENR requirements contained in each treatment
facility's NPDES permit. Section 5.8 of the FEIS includes additional
information on the above measures.
9.5 Evaluate the risks associated with EPA
fishing and recreational use of the
proposed lake from increased algal
and microbial growth from increased
nutrients and the bioaccumulation of
toxic materials in higher food-chain
animal species.
9.6 The Section 404 Permit should be
issued on condition that NCDEHNR
guarantee that water quality in the
proposed lake will be suitable for its
intended use as a public drinking
water supply.
See response to Comment 6.1.
EPA NCDENR cannot provide a water quality guarantee. However,
NCDENR has indicated that the uses of the proposed lake for water
supply are predicted to be supported ( ' ).
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
9.7 Describe proposed treatment of EPA Conventional flocculation and sedimentation processes will be used
water from the proposed lake, prior to filters. The filters will consist of two anthracite filters and two
including filtration media, biological activated carbon filters (see response to Comment 2.10).
sedimentation/flocculation Ozone will be added prior to the filters for disinfection and chlorine will
procedures, and disinfection process be added after the filters and prior to the clearwell for additional
to be used.' Discuss processes to be disinfection. Ammonia will be added before the finished water is
used to address potential taste and pumped to the water distribution system to convert the chlorine
odor problems associated with algal residual to chloramine. Ozonation and biological activated carbon
and other microbial growth. filters are effective for taste and odor control.
9.8 Evaluate the human health impacts C-NC See responses to Comments 5.1, 5.37 and 6.1. All potential sources
of numerous recorded waste dumps of toxic substances were identified and evaluated and the proposed
and possible unrecorded pollution. reservoir will meet atl applicable drinking water standards for
protection of human health.
9.9 Discuss the human health impacts of C-HP Control of toxic chemicals discharged from the High Point Eastside
toxic chemicals from the High Point WWTP will be by (1) control measures of the City's Industrial
Eastside WWTP. Pretreatment Program for toxic substances which may be introduced
to the treatment plant, and (2) monitoring and enforcement
procedures contained in the plant's NPDES discharge permit. The
NPDES permit controls toxic substances by requiring effluent toxicity
testing and priority pollutant scans quarterly and by prescribing
specific effluent limits for toxic substances, such as heavy metals and
other pollutants, for which water quality standards apply. Section
5.3.5.4 discusses the potential human health impacts of toxic
substances from the Eastside WWTP.
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SUMMARY OF DEIS COMMENTS
COMMENT
10. OTHER MITIGATION
COMMENTOR RESPONSE
10.1 Establish minimum releases from WRC The PTRWA has no legal means to require minimum releases from
High Point Lake and Oak Hollow DPR High Point Lake and Oak Hollow Lake. Current Dam Safety
Lake, and protect additional stream regulations of the N.C. Administrative Code (15A NCAC 2K.0502)
reaches in the area with forested include a requirement for minimum flow releases from water supply
buffers by purchase or conservation reservoirs. However, the regulations do not require a minimum flow
easement. Consider similar release for existing reservoirs unless there is evidence of (1) water
protection for streams flowing to the quality standards not being met, (2) water quality classifications
Haw River. which are only partially supported or not being supported, or (3)
aquatic habitat not being maintained. Where required, the minimum
flow releases are a function of the quality of the downstream aquatic
habitat and are equal to the 7Q10 flow in the stream as a minimum.
Higher values are required for streams with moderate or good aquatic
habitat. Currently, no minimum flow releases are required for High
Point Lake. and Oak Hollow Lake.
State water supply regulations (15A NCAC 26.0211(f)(3)(B)(VI))
require the maintenance of a vegetative buffer between all new
development activities and perennial streams draining to WS-IV
waters. The minimum buffer width is 30 feet for low-density
development and 100 feet for development under the high-density
option. No buffer is required for intermittent streams. All of the local
jurisdictions in the proposed Randleman Lake watershed have
ordinances which meet or exceed these minimum requirements. In
addition, High Point and Jamestown require buffers around some
intermittent waters (open drainage channels) ranging from 10 feet to
the 100-year flood plain contour, depending on the drainage basin
area. Randolph County, Randleman and Archdale all require a 50-
foot buffer in the Randleman Lake watershed. All buffers are to
remain vegetated and undeveloped, with some exceptions allowed for
road and greenway crossings and water-dependent structures.
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SUMMARY OF DEIS COMMENTS
COMMENT
10.1 (Continued)
Stream buffer requirements for streams flowing to the Haw River are
contained in the Guilford County Soil Erosion and Sedimentation
Control Ordinance. This ordinance includes the following provisions:
• Requires an approved erosion control plan before initiation of any
land-disturbing activity which uncovers one acre or more;
• Establishes mandatory standards for land-disturbing activities,
including standards for buffer zones, graded slopes and fills,
ground cover, and prior plan approval; and
• Requires permanent downstream protection measures for stream
banks and channels to protect them from increased degradation by
accelerated erosion caused by increased velocity of runoff from the
land-disturbing activity.
The City of Greensboro also has aCity-wide stormwater permit, which
requires stormwater controls to reduce the discharge of pollutants to
the maximum extent practicable. Additional information on existing
City and County ordinances may be obtained from the City and
County Planning Departments. Section 5.8.3 of the FEIS contains
additional information on minimum releases from the High Point lakes
and on stream buffer requirements.
COMMENTOR RESPONSE
10.2 Plant open agricultural lands and WRC
clear-cut areas around the proposed DFR
lake with high quality hardwoods that
are beneficial to wildlife.
(To be added later.)
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
10.3 Clarify planned measures for WRC
operation and management of Jordan
Lake Dam to mitigate water quality
problems in Jordan Lake.
NCDWR is planning to conduct a water reallocation modeling study
for Jordan Lake and the Cape Fear River down to U.S. Lock and Dam
No. 1 beginning sometime in July or August 1998 (Fransen, 1998).
Twelve months will be allowed for this study, which will develop a
hydrologic simulation model for the lake. The model will be a simple
water balance model and will not address water quality in Jordan
Lake, although it will have some outputs which can be used as inputs
to other water quality models. There will be a provision in the model
for evaluating impacts of the proposed Randleman Lake, primarily
looking at conditions with and without Randleman Lake and the
impacts on downstream flows and the uses of the lake. Because the
proposed water reallocation modeling study is not expected to
address water quality in Jordan Lake, it is not expected to address
measures for operation and management of Jordan Lake Dam to
mitigate water quality problems in Jordan Lake.
Water quality problems in Jordan Lake are discussed in the NCDWQ
Cape Fear River Basinwide Management Plan (NCDEHNR, 1996a).
Issues raised in the plan include excessive loadings of oxygen-
demanding materials and nutrients from both point. and nonpoint
source discharges. It is expected that water quality problems in
Jordan Lake will be addressed by additional controls applied to point
and nonpoint source discharges under the basinwide management
planning process to reduce excess pollutant loadings to the Jordan
Lake watershed.
Section 5.3.5.8 of the FEIS includes the above information on
measures to address water quality problems in Jordan Lake.
10.4 Discuss mitigation measures to DHHS
reduce the adverse effects of
residential and business
displacements/relocations (Section
5.8).
The PTRWA is expected to provide assistance to affected persons in
relocating within the community or to another area. Section 5.2.7 of
the FEIS addresses this issue.
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
10.5 Discuss improved treatment for RRA1
wastewater treatment plants
discharging to the proposed
Randleman Lake or to the Haw River
as a mitigation measure.
10.6 Focus mitigation efforts on the local RRA1
area where there is a need to
improve water quality.
11. SEDIMENTATION CONTROL
The proposed expansion of the High Point Eastside WWTP includes
improved treatment for nutrients, as well as measures to improve
treatment system reliability. (See responses to Comments 5.9, 5.11,
5.13 and 5.18.) Section 5.8.3 of the FEIS discusses the nutrient
reduction strategy for the proposed project, one element of which
includes improved nutrient removal performance at the Eastside
WWTP.
See response to Comment 10.1.
11.1 Clarify the impacts of sedimentation WRC An increase in sediment loading to the Haw River Basin will result
on Jordan Lake (Section 5.3.5.8). from construction activities associated with new development in the
Greensboro service area that occurs as an indirect result of the
proposed project. Control of erosion and sediment will be by the
existing Guilford County Soil Erosion and Sedimentation Control
Ordinance and City of Greensboro stormwater regulations (see
response to Comment 10.1). Section 5.3.5.8 of the FEIS addresses
the increased sedimentation associated with the proposed interbasin
transfer to the Haw River Basin.
11.2 Discuss the width of forested buffers WRC A buffer width of 50 feet will be maintained along the Deep River and
to be left until just before dam closure Muddy Creek during construction. Section 5.8.2 of the FEIS includes
along the streams within the reservoir a reference to this buffer width.
pool.
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SUMMARY OF DEIS COMMENTS
COMMENT
12. WILDLIFE HABITAT
COMMENTOR RESPONSE
12.1 Include information on the numbers WRC
of birds and mammals that are
known or expected to inhabit the
project area (Section 4.3.9).
12.2 Discuss effects on black vulture C-VW
nesting area.
13. LOW-FLOW AUGMENTATION
13.1 Discuss reduction in water supply DWR
withdrawals which must coincide with
reductions in minimum releases at
low reservoir levels, as required by
15A NCAC 2K.0502(c)(6).
Guidance from review agencies during the scoping process for the
EIS indicated that there was no need to compile new information on
birds and mammals in the Randleman Lake area. The bird and
mammal species of this part of North Carolina are well known, and no
species of concern are known from this area. However, biologists
conducting field surveys for the proposed project noted the birds and
mammals they encountered (Carter and Heiman, 1993). During the
surveys, two unusual birds were recorded, as discussed in Section
4.3.9. Bald eagles and peregrine falcons could occur occasionally
along the Deep River and in adjacent open habitats, but none were
seen during the field surveys. No revisions to the EIS are necessary.
(To be added later.)
According to the Dam Safety rules (15A NCAC 2K.0502(c)(6)), when
the usable water supply storage has been reduced to the level which
triggers the first reduction in the minimum flow release, the average
daily water withdrawal must be reduced by at least 10 percent
compared to the average daily withdrawal for the 60-day period
immediately prior to the first reduction in minimum flow. The water
supply operator must accomplish this reduction in withdrawal within
two weeks of the reduction in the minimum flow release. When the
usable water supply storage has been reduced to the level which
triggers the second reduction in the minimum flow release, the
average daily withdrawal must be reduced by at least 20 percent.
Section 5.3.5.3 of the FEIS discusses the required reductions in water
withdrawals associated with the reductions in minimum flow release.
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SUMMARY OF DEIS COMMENTS
COMMENT
14. FORESTRY
COMMENTOR RESPONSE
14.1 Discuss use by the PTRWA of best DFR
management practices in the
planning, care, and harvest of forests
in the 3,000-acre buffer area.
Discuss PTRWA measures to
encourage its contractor(s) to
salvage as much timber as possible
from the lands inundated by the
reservoir and to protect standing
trees outside construction limits from
heavy equipment.
The PTRWA will take appropriate measures during construction to
ensure that trees located outside of construction limits will be
protected from the following kinds of damage:
Skinning of tree trunks by construction equipment.
2. Soil compaction or root exposure or injury by construction
equipment.
3. Adding layers of soil over the root systems of trees.
4. Accidental spilling of petroleum products or other substances
over the root systems of trees.
14.2 Clarify whether forest management DFR
and recommended timber harvesting
will be allowed in the 3,000-acre
buffer zone (pp. 3-20, 3-21 and 5-30;
Appendix C, p. 45).
This will be accomplished by identifying appropriate protection
measures and including those measures as contract requirements for
construction of the proposed reservoir.
It is expected that much of the marketable timber within the proposed
normal reservoir pool area would be cut and sold during the
construction phase of the project. Other brush in the normal pool
area would be cleared and burned.
The above measures are discussed in Section 5.3.7 of the FEIS.
Section 5.3.7 has also been revised to indicate that the PTRWA will
use Best Management Practices in the planning and care of forest
land in the reservoir buffer area (see response to Comment 14.2).
No timber harvesting within the buffer area is allowed under the
mitigation requirements for the proposed project. No revisions to the
EIS are necessary.
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SUMMARY OF DEIS COMMENTS
COMMENT
COMMENTOR RESPONSE
14.3 Clarify impacts of logging using water DFR
quality BMPs (pp. 5-19 and 5-20;
Appendix C, pp. 15 and 16).
15. PUBLIC HEARING
15.1 Have a public hearing.
16. MISCELLANEOUS
Section 5.3.7 of the FEIS has been revised to indicate that logging
accomplished using forestry Best Management Practices (BMPs)
(NCDEHNR, 1989) minimizes erosion and prevents or controls water
pollution from forestry operations. tf properly applied, these BMPs will
protect the quality of waters that might be affected by these
operations. Section 5.3.7 of the FEIS includes a reference to the use
of forestry BMPs to protect water quality.
NAS Extensive public and agency review and input on the proposed project
C-AH3 have occurred since 1988. Section 6.0 of the FEIS discusses the
public involvement for the proposed project. No additional public
hearing is required for the FEIS.
16.1 The PTRWA and the Corps have not SC
followed proper procedures in the
timing of the scoping, notice of intent,
and the preparation of the DEIS.
Proper public comment and debate
have not been allowed.
The Corps of Engineers (USAGE) believes that proper procedures
have been followed in the EIS process for the proposed project.
Public comment and debate on the proposed project have taken place
since 1988, when the PTRWA first met with the USAGE to request
approval for construction of the proposed lake. A public hearing was
held at the Randleman High School in Randleman, NC on February
6, 1991. Public comment was also received during the review of the
N.C. EIS completed in 1991. Public comment was solicited on the
USAGE DEIS published in June 1997. On the basis of the above
opportunities for public comment and input, the USAGE believes that
proper public comment and debate have been allowed on the
proposed project. No revisions to the EIS are necessary.
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SUMMARY OF DEIS COMMENTS
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16.2 The Corps cannot be objective and SC
unbiased enough to remain as the C-AH1
responsible lead agency because of
time and finances expended.
16.3 The PTRWA and the Corps have SC
made financial commitments to the
project and the EIS will only be a
smokescreen with no validity.
16.4 A Notice of Intent (NOI) was not SC
prepared before the DEIS was
. started, in violation of NEPA
regulations.
16.5 No scoping was held after publication SC
of the NOI, in violation of NEPA
regulations. Not enough scoping and
public input was allowed.
16.6 An EIS should have been prepared SC
when the PTRWA proposed the
project to the Corps in 1988.
16.7 Include an evaluation of the DOT
environmental impacts of the
roadway improvements required for
the proposed project.
The USACE believes that it is objective and unbiased in its role as
lead agency for the proposed project. No revisions to the EIS are
necessary.
The USACE and the PTRWA believe that previous financial
commitments to the project do not affect the validity of the EIS. No
revisions to the EIS are necessary.
See response to Comment 16.1.
See response to Comment 16.1.
See response to Comment 16.1.
Environmental impacts of the proposed roadway improvements are
discussed as follows:
• The proposed improvements will involve the removal and
abandonment of seven bridges and the replacement of two bridges
at new locations. Bridges to be relocated inGude SR 1921 over the
Deep River near Coltranes Mill and SR 1140 at Registor's
(Reddicks) Creek. These improvements will involve changes in
land use for the abandoned and new bridge sites. The remaining
modifications of twelve roadways will consist of raising the roadway
at the existing location and will involve minor changes in land use
associated with the increased roadway elevation.
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SUMMARY OF DEIS COMMENTS
COMMENT COMMENTOR RESPONSE
16.7 (Continued) The proposed roadway improvements could impact
approximately 2.5 acres of wetlands. The actual amount will
depend on the final design of the roadway improvements. Table
21 shows the amount of wetlands that are estimated to be
impacted for each roadway project. The acres to be impacted
are based on the delineated wetlands located within 200 feet on
either side of the roadway where it crosses the entire project
area, including the proposed lake and the buffer area. The
wetlands within the proposed lake area are already included in
the total acres of wetlands to be impacted by the proposed
project.
• Prime farmland soils would be impacted by the proposed relocation
of SR 1921 near Coltranes Mill. Approximately 0.5 to 1.0 acres of
prime farmland soils would be lost as a result of the proposed
roadway modifications at this site.
• No public land or scenic or recreational areas would be affected by
the proposed roadway improvements.
Of the twenty-one proposed roadway improvements, four are
located near archaeological sites which may be eligible for the
National Register of Historic Places. These include SR 1129 over
the Deep River, NC 62 over the Deep River, SR 1938 over Sam's
Creek, and SR 1936 over Sam's Creek. These archaeological sites
are expected to undergo further investigation to determine their
eligibility for the National Register before construction of the
proposed project. The proposed roadway improvements are not
expected to impact any additional archaeological sites that are not
already affected by the proposed reservoir.
• The proposed roadway improvements would result in temporary
adverse effects on air quality from airborne dust and construction
equipment exhaust. These impacts would be localized and of
relatively short duration. Noise levels would also increase as a
result of construction activities.
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SUMMARY OF DEIS COMMENTS
COMMENT
16.7 (Continued)
COMMENTOR RESPONSE
• The proposed roadway improvements are not expected to have
any significant impacts on groundwater quality.
No significant impacts on surface water quality, water supplies,
or eutrophication of surtace waters are expected as a result of
the proposed roadway improvements. Some erosion and
sedimentation will occur as a result of construction activities and
will cause short-term increases in turbidity in downstream
surface waters. These effects would be minimized by
sedimentation and erosion control measures installed in
accordance with an approved sedimentation and erosion control
plan for each project. The proposed roadway improvements are
not expected to have any significant effects on downstream
water supplies, the nearest of which is the Gulf-Goldston water
supply, approximately 70 miles downstream of the proposed
Randleman Lake.
The proposed roadway improvements are not expected to have
any significant effects on shellfish, fish, or wildlife and their
habitats. One endangered species, the Cape Fear shiner, has
been identified in the Deep River at Coleridge, approximately 22
miles downstream of the proposed dam site. One of the
designated critical habitats for this species is located in the Deep
River approximately 33 miles below the dam site. Increased
turbidity associated with erosion and sedimentation during
construction may result in short-term adverse impacts on this
species. These adverse impacts would be minimized by
maintenance of effective erosion and sedimentation control
measures for each construction project.
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SUMMARY OF DEIS COMMENTS
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16.7 (Continued)
No significant introduction of toxic substances is expected as a
result of the proposed roadway improvements. The proposed
bridges are expected to be designed with hazardous spill basins
to collect any hazardous spills that occur on the roadways over
the reservoir. No significant amounts of toxic substances are
expected to be released to the environment as a result of
construction activities.
Section 5.2.5 of the FEIS discusses the environmental impacts of the
roadway improvements for the proposed project.
16.8 Discuss burning permits required for DFR
land clearing activities in Section
5.4.4.
16.9 Verify sulfate concentrations in DOI
inflows to the proposed lake in Table
V-4. Verify units for sulfate and
nitrate concentrations in Table V-5.
Check units in Tables V-6 and V-7.
16.10 The issuance of a Federal Section WPPDC
404 permit is acceptable.
16.11 Based on known water quality C-AH2
concerns, it appears that Part 325,
Appendix B NEPA Regulations 8.a
have not been implemented.
Section 5.4.4 of the FEIS references the need to obtain burning
permits for land clearing activities.
Data is not available to verify the sulfate concentration in Table V-4.
However, even if the sulfate concentration were 3 orders of
magnitude higher, it would still not approach the water quality
standard of 250 mg/L. Units for concentrations for sulfate, nitrate and
aluminum should be mg/L in Tables V-5, V-6 and V-7. Appendix A
has been revised to show the correct units in these tables.
The PTRWA agrees with this comment. No revisions to the EIS are
necessary.
The DEIS was provided to the appropriate Federal agencies for their
review and comment. The U.S. EPA has been aware of this project
and provided comments on the NCDEHNR EIS on May 22, 1992. At
that time, the EPA raised concerns about the potential water quality
in the proposed lake. Comments were also received on the DEIS
from the EPA and responses to those comments are included in the
FEIS. The EIS has been revised in accordance with the responses
to the EPA comments.
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SUMMARY OF DEIS COMMENTS
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COMMENTOR RESPONSE
16.12 Land acquisition for the proposed C-AH3
project by the PTRWA violates
Section 1501.6 of NEPA.
16.13 Describe the scoping that took place C-AH3
on the proposed project from
September 11, 1996 (NOI published)
until the scoping ended.
16.14 Discuss the Superior Court ruling of C-AH4
May 12, 1994 on the EMC decision to
grant an interbasin transfer permit for
the proposed project.
16.15 Discuss the effect of retention ponds C-VW
on the flow in the Deep River. C-WF
Discuss the effects of retention
ponds at dairy, hog and chicken
farms.
Section 1501.6 of NEPA addresses agency cooperation in the NEPA
process. This section has no relevance to PTRWA purchase of land
for the proposed project. The Corps of Engineers is not aware of any
regulations that prohibit purchase of land by the PTRWA. No
revisions to the EIS are necessary.
No formal scoping for the proposed project was held after
September 11, 1996. Public and agency review and input for the
proposed project have been ongoing since 1988. The Corps of
Engineers believes that no additional scoping is necessary. Public
and agency comments on the DEIS have been considered and
responses to these comments are included in the FEIS. The FEIS
has been revised in accordance with the responses to the comments.
The Superior Court ruling of May 12, 1994 is discussed in Section 6.1
of the DEIS. No revisions to the EIS are necessary.
Stormwater retention ponds required by City or County codes are
designed to reduce nonpoint source loadings from existing and new
development. The ponds also provide retention and containment
capabilities for any potential hazardous material spills. The ponds
have limited surface area and do not have a significant effect on
downstream flow in the Deep River. No revisions to the EIS are
necessary.
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SUMMARY OF DEIS COMMENTS
COMMENT
16.15 (Continued)
COMMENTOR RESPONSE
16.16 Footnote 1 on Table 16 should apply C-VW
to other charts as well.
16.17 Verify the number of residents and C-VW
businesses affected by the proposed
project (Table 1). Tax records show
higher numbers; many dairy and
poultry farms also affected.
16.18 Provide more discussion of WRC
secondary and cumulative impacts. C-MSM
Pollutants from retention ponds at the operating dairies in the
proposed Randleman Lake watershed are controlled by provisions of
the individual waste management plans for these dairies, which are
required under North Carolina regulations (15A NCAC 2H.0217(a)(1)).
Dairies with over 100 head of cattle are required to have an approved
animal waste management plan. This includes five dairies in the
Randolph County portion of the watershed. Control of pollutants from
these dairies is further addressed in the Nutrient Reduction Strategy
and Implementation Plan for the proposed Randleman Lake
watershed, which is discussed in Sections 5.3.5.5 and 5.3.5.6 of the
FEIS (see response to Comment 5.9).
Footnotes are included in all of the tables in the FEIS for which there
are discrepancies for the acres of the proposed lake and buffer area.
The number of residences and businesses affected have been
verified using tax maps. Section .5.2.2 of the FEIS indicates that
portions of 16 farms, including four operating dairies, would be
inundated. No poultry farms would be shut down as a result of the
proposed project. One small dairy is expected to be shut down as a
result of the proposed project. Section 5.2.2 of the FEIS discusses
the effect of the proposed project on dairy and poultry farms.
Indirect and cumulative impacts of the proposed project on land use
are expected to include the conversion of other lands in the region
from their current use to industrial, commercial, or residential uses.
This would be a result of economic growth made possible by the
increase in available water supplies. Future development in the
Piedmont Triad region would be directed in accordance with land
development plans and ordinances of the PTRWA member
governments. Section 5.2.2 of the FEIS includes additional
information on indirect and cumulative impacts of the proposed
project on land use.
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SUMMARY OF DEIS COMMENTS
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16.18 (Continued) Indirect and cumulative effects of the proposed project on municipal
and county services would result from new industries or residents
attracted to the area because of the additional water supplies.
Services that are likely to be impacted include solid waste facilities,
schools, police and fire protection services, and medical services.
Indirect and cumulative effects of the proposed project on local
transportation systems would result from new industries and
population attracted to the area by the increased water supplies.
Increases in traffic volumes would occur in areas of new industrial,
commercial, and residential construction. Sections 5.2.4 and 5.2.5 of
the FEIS discuss the indirect and cumulative effects of the proposed
project on municipal and county services and transportation systems.
Section 5.2.6 of the FEIS discusses the indirect and cumulative
effects of the proposed project on energy resources. These would
consist of additional energy requirements for new industrial and
economic growth resulting from the increased water supplies. The
FEIS indicates that ample electrical power is available for future
growth needs.
Indirect and cumulative impacts on the proposed project on historical
and archaeological resources include potential adverse impacts from
development projects that may be facilitated by the proposed
reservoir project. If such projects occur, they would be subject to
State and local review and permit programs. Development may also
result in the discovery of additional archaeological resources which
may provide information on the area's prehistory. Some historic sites
may be preserved or protected through renovation for other uses.
Section 5.2.8 of the FEIS includes additional information on indirect
and cumulative effects of the proposed project on cultural resources.
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SUMMARY OF DEIS COMMENTS
COMMENT
16.18 (Continued)
COMMENTOR RESPONSE
Construction and operation of the proposed project would have
indirect and cumulative impacts on the topography of the region
outside the project area. These impacts would result from
construction due to industrial, commercial, and residential growth
attracted by the increased water supplies. The location of these
impacts would be subject to existing and future zoning controls of the
PTRWA member governments, with industrial growth likely to be
concentrated along major transportation corridors. Section 5.3.2 of
the FEIS discusses the indirect and cumulative effects of the
proposed project on topography in the Piedmont Triad area.
Section 5.3.3 of the FEIS indicates that indirect and cumulative
impacts of the proposed project on geological resources are not
expected to be significant.
Indirect and cumulative impacts on soils would occur in areas of new
industrial and residential development related to the increased water
supplies from the proposed project. Wind erosion and sedimentation
would occur with this new construction. New areas served by water
distribution systems are generally provided with central wastewater
facilities at the same time. Consequently, the project is not expected
to have significant adverse impacts on soils related to development
of on-site wastewater disposal systems for residential and commercial
developments. Indirect and cumulative effects on prime farmland
would occur as existing agricultural land is converted to residential,
commercial and industrial uses as a result of the development that
occurs as an indirect result of the increased water supplies. Section
5.3.4 of the FEIS discusses the indirect and cumulative effects of the
proposed project on soils.
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SUMMARY OF DEIS COMMENTS
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16.18 (Continued) The proposed project is not expected to have significant indirect or
cumulative effects on groundwater resources. New residential
housing areas are generally connected to central water and
wastewater service at the same time. Therefore, the proposed
project is not expected to have significant adverse effects on
groundwater through increased wastewater disposal through
individual on-site septic systems. Section 5.3.5.1 of the FEIS
discusses the indirect and cumulative effects of the proposed project
on groundwater.
The FEIS addresses indirect and cumulative effects of the proposed
project on surface water, both within and downstream of the proposed
reservoir. Cumulative effects of existing and projected future point
source discharges, including the High Point Eastside WWTP;
nonpoint source discharges from existing and projected new
development; point source loadings from the Seaboard Chemical
Corporation and High Point Landfill sites; and potential point source
loadings from other hazardous waste sites are evaluated (see
responses to Comments 5.1, 5.2, 5.3, 5.4, 5.9, 5.15, 5.37, 5.40, 5.41,
5.42, 5.43, 5.49, 5.55, 5.59, and 5.60).
The proposed project would have some indirect and cumulative
impacts on vegetation resources outside the immediate project area.
The increased water supply is expected to allow additional industrial
growth and residential development, primarily in areas that are in and
adjacent to the existing urban areas in the Piedmont Triad region.
Some plant communities would be cleared to accommodate new
and/or expanded facilities. Section 5.3.7 of the FEIS discusses
indirect and cumulative effects of the proposed project on vegetation
resources.
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SUMMARY OF DEIS COMMENTS
COMMENT
16.18 (Continued)
l
COMMENTOR RESPONSE
wildlife resources will result from urbanization in newly-served areas
and will consist of increased fragmentation of existing wildlife habitats.
Native vegetation will be replaced with urban species, and wildlife will
withdraw from the expanding urban area due to increased human
disturbances and loss of suitable habitat. Increases in urban runoff
will occur. During seasonal low flows, urban runoff, where it occurs,
will have a more pronounced effect on aquatic habitat quality because
of the low dilution capacity of the receiving streams. Control
measures adopted pursuant to statewide watershed protection and
urban stormwater management regulations will reduce the impact of
increased urbanization in the Piedmont Triad area. Section 5.3.9 of
the FEIS discusses indirect and cumulative effects of the proposed
project on wildlife resources.
ndirect and cumulative effects of the proposed project on wetlands
o ro ec area wou not a si ni scan . e an areas are
ge ra y avoided for residential and industrial development when
suitable upland sites exist. This is due to the presence of high
groundwater levels and the fact that hydric soils may also have high
shrink-swell potentials. Such conditions lead to soil movement, which
is detrimental to building foundations. Use of wetlands would also
require a permit from the U.S. Army Corps of Engineers. Section
5.3.8 of the FEIS includes additional information on indirect and
cumulative effects of the proposed project on wetlands.
Indirect and cumulative effects of the proposed project on terrestrial
The proposed project is not expected to have significant indirect and
cumulative effects on fishery resources.
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SUMMARY OF DEIS COMMENTS
COMMENT
16.18 (Continued)
COMMENTOR RESPONSE
16.19 Discuss whether the data from a GC
1989 (Black and Veatch) study is still
adequate for use in the EIS.
The proposed project is not expected to have significant indirect and
cumulative effects on endangered, threatened or rare species.
Effects of the proposed project on critical habitat of the endangered
Cape Fear shiner downstream of the project are discussed in Section
5.3.11 of the FEIS. Effects on downstream flow and water quality and
the potential impacts on the Cape Fear shiner include the direct
effects of the construction of the proposed lake, as well as indirect
and cumulative effects that could occur in combination with the
proposed project (see responses to Comments 8.5, 8.6, and 8.7).
Results of Black ~ Veatch studies conducted in 1988, 1990 and 1991
have been updated in subsequent studies by Black & Veatch and
others. Data reported in the EIS are considered accurate for
evaluating alternatives and impacts for the proposed project. No
revisions to the EIS are necessary.
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16.20 Provide the change in elevation EPA The stream bed and the lake floor are at the same elevation, which is
between the stream bed and lake approximately 604.0 feet m.s.l. A plan and a cross section of the
floor on either side of the proposed proposed dam are shown in the FEIS on Figures 5a and 5b,
dam (pp. 3-3, III-2-4). Provide a respectively. The outlet structure would consist of a riser which
cross-section. Provide the elevation discharges into an outlet conduit. The riser would be attached to the
of the outfall structures. Consider the vertical upstream face of the dam at the right (south) abutment. The
effects of scouring and changes to outlet conduit would be 120 feet long and would be placed in a rock
fluvial geomorphology. Provide more cut at the base of the abutment. The outlet conduit would discharge
explanation of soil conservation into the stilling basin for the emergency spillway on the downstream
methods. Tabulate data on reservoir side of the dam. Gates installed in the sides of the riser at various
capacity, volume increment, capacity levels would be used for controlling downstream releases. One or
inflow ratio, percent sediment more large gates at the base of the riser would be used for draining
trapped, percent sediment trapped the reservoir. For effects of scouring and changes to fluvial
per volume increment, acre-feet of geomorphology, see responses to Comments 2.29 and 8.7.
sediment trapped annually, and the
number of years required to fill the Soil erosion and sediment control measures to be used during
volume increment. Explain why construction of the proposed dam will be determined during
sediment accumulation was preparation of the sediment and erosion control plan. The plan will be
projected for 100 years. Discuss developed in accordance with the guidelines of the North Carolina
sediment accumulation in 50 years. Division of Land Resources, Land Quality Section and submitted to
the Land Quality Section for approval.
Reservoir capacity, streamflow data, sediment data and volume
increments for water supply and sediment storage are included in
Table 8 in the FEIS. Sediment accumulation was projected for 100
years because that is the projected design life for the proposed
reservoir. This means that the proposed reservoir would provide a
minimum safe yield of 48 mgd throughout its design life. Sediment
accumulation in 50 years would be one-half of the 100-year sediment
accumulation, or 4,000 acre-feet.
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16.21 Identify the types and locations of EPA Existing mining operations in Guilford County consist of open sand,
existing mining operations in Guilford rock and gravel pits located southwest of the City of Greensboro.
County (p. 4-3). Cun'ently, two mining operations are permitted. Information on these
two operations is summarized as follows:
Permit Permitted
Name Location Exaltation Date Area. acres
Groome Sandrock 4608 Groometown Rd. May 2004 35
Pit Greensboro, NC 27407
A-1 Sandrock Pit 2132 Bishop Rd. October 2001 60
Greensboro, NC 27408
These two operations drain to tributaries of the Deep River within the
Randleman Lake watershed. Neither operation is in the critical area
for the proposed lake. Section 4.2.3 of the FEIS discusses existing
mining operations in the Guilford County portion of the Randleman
Lake watershed.
16.22 Provide a land use map; identify the EPA No land use map is available. Based on land use information from
operating dairies (pp. 5-1, 5-2). Carter and Heiman (1993), approximately 70 to 72 percent of the land
area in the proposed reservoir normal pool and buffer areas is
forested land. Approximately 27 to 28 percent of the land area in the
normal pool and buffer areas is open pasture or fields. The remaining
1 to 2 percent comprises other land uses, including residential, acidic
cliff, low elevation seeps, other agricultural, developed, industrial,
ponds and powerline rights-of-way. Additional data on acreages of
community types in the proposed reservoir project area is presented
in Appendix C of the DEIS.
There are currently five operating dairies in the proposed Randleman
Lake watershed that are required to submit a registration form to
NCDWQ and to have an approved animal waste management plan
under NCDENR regulations (15A NCAC 2H.0217(a)(1)). The five
dairies are all located in Randolph County, and three are within the
critical area for the proposed reservoir. The locations of the five
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16.22 (Continued) dairies are shown on Figure 5c. Additional information on these
dairies is provided in the Responses to NCDWQ Comments on the
Draft Nutrient Reduction Strategy for Randleman Lake (March 19,
1998), which are contained in the Nutrient Reduction Strategy and
Implementation Plan (Hazen and Sawyer, 1998). Information on
these dairies is summarized as follows:
Map _ Average No. of Acres for Land
No. Name Milking Cattle A_ palication of Waste
1 Green Valley Farms 250 Approx. 600
2 Cashatt Dairy 150-200 350
3 Buttke Dairy 1,200 800
5 Loftin Dairy 300 170
4 W.R. Farlow & Sons 175 300
A sixth dairy, Robbins Dairy, is located in the watershed but is not
required to submit a registration form or have an approved animal
waste management plan. Sections 4.2.2, 4.3.5.2, 5.2.2 and 5.3.5.2
of the FEIS address the operating dairies in the proposed Randleman
Lake watershed and their expected impacts on the proposed project.
16.23 Discuss estimates of economic EPA Economic losses to hydroelectric facilities in the later years of the
losses to hydroelectric projects along planning period for the proposed project have been estimated at 5 to
the Deep River and in basins affected 15 percent. These losses are proposed to be offset by optimizing flow
by interbasin transfers (pp. 5-3, 5-17, releases from the reservoir during the early years of the project. For
5-18). Include costs in project cost this reason, projected economic losses are not included in project
estimates, as appropriate. cost estimates (see Section 5.2.6 of the FEIS). No economic losses
to hydroelectric facilities are expected for basins receiving interbasin
transfers because there will be no reductions in streamflows. No
revisions to the EIS are necessary.
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16.24 Provide the locations of rare plants in EPA
the buffer zone on a potentiometric
map and discuss the effects of
groundwater saturation, if appropriate
16.25 Provide additional discussion of the EPA
projected Deep River flow and
reservoir yield analysis (pp. II-1, 5-7).
16.26 Consider the potential for
overdevelopment in the area
surrounding the proposed lake.
The dissected toothwort (Carrfamine dissects), a significantly rare
plant in North Carolina, has been identified at three locations.
Portions of two locations would be within the buffer area for the
proposed reservoir. One consists of a population along Richland
Creek just east of SR 1154 (Kersey Valley Road). The other is along
Hickory Creek between SR 1140 and the Deep River. Since this
species is neither endangered or threatened, no further evaluation of
the impacts to this species is necessary. No revisions to the EIS are
necessary.
The 29 percent reduction in average flow in the Deep River at the
proposed Randleman Lake dam site shown in Table 24 is based on
a reservoir yield of approximately 48 mgd minus the portion of the
reservoir yield that is returned to the Deep River. In other words, the
reduction in downstream flow is approximately equal to the interbasin
transfer amounts for the proposed project, as discussed in Section
5.3.5.3 of the FEIS. These flow reductions reflect the amount of
water withdrawals from the lake; therefore, they will be low initially but
will increase over time as the water demands increase for the
PTRWA members. The projected reductions in average flow
downstream in the Deep River are believed to accurately reflect
conditions at the end of the planning period for the proposed project
and are not expected to result in any impacts on the critical habitat of
the Cape Fear shiner. No revisions to the EIS are necessary.
C-NC Development around the proposed lake will be controlled in
accordance with watershed protection ordinances of the seven
jurisdictions which have areas within the proposed Randleman Lake
watershed. Development will be controlled to minimize the impacts
of new development on the water quality of the reservoir (see
responses to Comments 5.9 and 7.5). Proposed ownership by the
PTRWA of a 200-foot buffer area around the reservoir will also reduce
the impacts of development around the reservoir. No revisions to the
EIS are necessary.
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16.27 Discuss the water levels in the Deep C-RP
River downstream of the dam while
the proposed lake is filling and after.
16.28 Discuss effects on scenic natural cliff C-VW
along the Deep River.
17. CULTURAL RESOURCES
17.1 The proposed project will have C-CH
adverse effects on archaeological,
historical and architectural resources.
See responses to Comments 6.1 and 6.6.
(To be added later.)
Archaeological surveys have been conducted to identify
archaeological resources in the project area and, where possible, to
determine if these resources are potentially eligible for inclusion in the
National Register of Historic Places. During the most recent survey,
which was completed in 1997, 80 archaeological sites were recorded,
and four previously recorded sites were revisited (Coastal Carolina
Research, 1997). Of the 84 sites, 26 were recommended for
additional investigations to determine if they are eligible for the
National Register. One additional previously recorded site was also
recommended for testing to determine its eligibility. After completion
of the recommended additional investigations, the PTRWA, in
consultation with the North Carolina State Historic Preservation
Officer (SHPO), will formulate and implement an appropriate
preservation or mitigation plan for all sites which the PTRWA and
SHPO agree are eligible for inclusion in the National Register. The
PTRWA will also undertake an architectural survey of all unassessed
architectural properties in the project area. Appropriate preservation
or mitigation plans will also be implemented for these sites in
consultant with the SHPO. The architectural survey must be
conducted prior to any undertaking which may affect these properties.
Sections 4.2.8 and 5.2.8 of the FEIS discuss the results of the
archaeological and architectural surveys.
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SUMMARY OF DEIS COMMENTS
COMMENT
17.2 Provide locations of historic and
prehistoric sites.
18. FARMLAND
COMMENTOR RESPONSE
C-VW Site descriptions and a map of historic and prehistoric sites are
presented in the report on the most recent survey of archaeological
sites in the proposed Randleman Lake watershed (see response to
Comment 17.1). A copy of this report is available for review at the
offices of the Piedmont Triad Regional Water Authority in Greensboro,
North Carolina.
18.1 In Section 5.0, discuss conversion of C-VW
farmland in the project area to
residential uses.
An indirect effect of the proposed project will be new development
which occurs as a result of the economic growth made possible by
the increased water supply from the proposed reservoir. It is likely
that this development will occur within and around the urban services
areas of the PTRWA members. Development that occurs will result
in conversion of existing pasture and farmland, open space, and
forested land to residential, commercial, or industrial uses. Future
development would be directed in accordance with the land use plans
and development and watershed protection ordinances of the local
governments within the Randleman Lake watershed. Section 5.2.2
of the FEIS discusses the indirect impact of the proposed project on
development in the Randleman Lake watershed.
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SUMMARY OF DEIS COMMENTS
COMMENT
18.2 Delineate prime farmland
19. NGS MONUMENTS
COMMENTOR RESPONSE
EPA Prime farmland soils affected by the proposed project have been
estimated based on county soils maps and information on prime
farmland soil classifications from U.S. Department of Agriculture
Natural Resources Conservation Service representatives. Based on
this information, prime farmland soils that will be inundated by the
proposed lake are estimated to comprise approximately 26 acres in
Guilford County and 270 acres in Randolph County. Additional areas
that will be inundated are classified as prime farmland if they are
drained and are protected from flooding or not frequently flooded
during the growing season. Locations of these soil types were
compared to flood plain areas identified on Federal Emergency
Management Agency (FEMA) Flood Insurance Rate Maps. Additional
prime farmland soils that are not located in flood plains are estimated
at approximately one acre in Guilford County and 40 acres in
Randolph County. Prime farmland soils in the buffer area for the
proposed reservoir were also evaluated and are estimated at
approximately 18 acres in Guilford County and 285 acres in Randolph
County. Section 5.3.4 of the FEIS includes additional information on
the effects of the proposed project on prime farmland.
19.1 Identify any NGS monuments that NOAA
would be impacted and notify NOAA.
No NGS monuments would be affected by the proposed project.
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