NC0088366_Expansion&Regionalization_20090413

Beverly Eaves Perdue
Governor
MEMORANDUM
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
TO: Brian Sexton
Marziano & McGougan
THRU:
April 13, 2009
Dianne Reid, Supervisor
Basinwide Planning Unit and SEPA Program
FROM: Hannah Stallings, SEPA Coordinator
Basinwide Planning Unit and SEPA Program
SUBJECT: Harnett and Cumberland Counties
Expansion of South Harnett WWTP and Regionalization with Ft. Bragg and Spring Lake
DWQ#14096, DENR#1495
Dee Freeman
Secretary
The Division of Water Quality (DWQ) has reviewed the subject document and has the following comments which must
be resolved prior to a Finding of No Significant Impact (FNSI) being issued for this project:
1. Page 5 states that, since the Harnett County WWTP will be able to treat any industrial wastewater from Fort Bragg,
"no pretreatment program is required." This is not a complete assessment.
a. Harnett County already has a Pretreatment Program, which requires them to perform industrial waste survey
activities for all Users connected to its wastewater treatment systems to make SIU-(significant industrial user)
determinations and accordingly regulate any identified SIUs. This applies to Fort Bragg and all the other sewer
service areas proposed in the EA - see pagesl2 and 13.
b. Harnett County should submit an updated Industrial Waste Survey for all new service areas to PERCS prior to
connection.
2. Page 10 of the EA indicates that Fort Bragg includes land in 6 different counties. DWQ is concerned whether any of
the base's sewer system extends into Hoke, Moore, Richmond, or Scotland Counties. If anyland in any of these four
counties will be impacted by this project, we recommend that Harnett County obtains opinion from their attorneys as
to whether they need to obtain interjurisdictional agreements with any of these organizations.
3. The proposed expansion of the South Regional WWTP should result in an improvement to the effluent water quality.
However, regionalization requires extensive pressure sewers and new pumping facilities, which typically require more
off -site operations and maintenance. The EA document needs to address this issue and provide relevant cost data.
4. The proposed expansion replaces two treatment systems, Fort Bragg and Spring Lake, but keeps the existing
collection systems separate, with the ownership, operation, and maintenance of these collection systems remaining
independent with the local authorities. The EA states that both of these systems have a history of inflow and
infiltration (I&I) and blockage issues. .While collection systems issues were only briefly discussed in the EA, they
may affect the review of the NPDES permit application. Currently, the 20 year projection for treatment capacity
demand includes an annual 9.1 % portion for ongoing I&I. When Fort Bragg and Spring Lake wastewater flows are
diverted to the South Regional facility it is not clear what portion of I&I is acceptable and/or how the Regional facility
will manage control of I&I. Please amend the EA to address these issues.
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5. The September 26, 2008, Agreement between the US Government (Ft. Bragg) and Harnett County may require
revision or augmentation to allow proper Pretreatment Program administration.
a. The Agreement refers to Harnett County as the Contractor in the sense the Government is "contracting" Harnett
County to provide wastewater service. It goes on to say the Contractor will operate the Government's existing
WWTP until decommission, decommission the WWTP, and build the sewer lines necessary to connect the
Government's collection system to the South Central WWTP. These requirements seem invalid as the
Government no longer owns the Fort Bragg WWTP and collection system.
b. The Agreement does not stipulate that the Government will be subject to Harnett County's Sewer Use Ordinance, .•
nor does it address any particulars such as access to the Base.
c. The description for the existing pre-treatment of Fort Bragg vehicle maintenance and refueling waste sources only
mentions that oil/water separators are the only treatment available. Although this may be the least expensive
option, there are other commercially available treatment options available such as activated carbon filters. This
may be an issue in future NPDES permitting.
Please call me at [phone] if I can be of any further assistance on this project.
Thank you.
Cc: Belinda Henson — FRO