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HomeMy WebLinkAboutNC0049778_Raw Water Storage Reservoir_20080114Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director Division of Water Quality January 14, 2008 MEMORANDUM TO: Melba McGee, Environmental Projects Officer DENR THRU: Dianne Reid, Supervisor Basinwide Planning Unit and SEPA Program FROM: Hannah Stallings, SEPA Coordinator Basinwide Planning Unit and SEPA Program SUBJECT: Moore County Southern Pines Raw Water Storage Reservoir DENR#1419, DWQ#13918 The Division of Water Quality has reviewed the subject project and has the following concerns and comments: 1. A reclassification of this unnamed tributary to include CA (critical area) may be required for it to continue to be used for drinking water purposes once the emergency has passed. Several places in the EA (pages 142, 158, and the May 1, 2007, letter in Appendix B) state that DEH will be contacted in regards to reclassification. While DEH makes a determination of whether a water body can be used for raw drinking water, DWQ is responsible for reclassifying the water body such that its use as a water supply is protected. This process can take up to 2 years if there is no controversy and the waters meet the surface water quality standards for water supply classification. 2. Southern Pines should have water restriction/conservation measures in place prior to utilizing this emergency water resource. - 3. Please note that Appendix C — Wetlands Permitting Correspondence for Project contains a letter from the Department of Cultural Resources that is not pertinent to this Appendix. 4. Figure 17 is not contained in Appendix A. Please include this figure so that there is a mapping of local. wetland features. 5. While page 8 states there will be 52.43 acres flooded for this project, the July 17, 2006, letter to the U.S. Army Corps of Engineers contained in Appendix C states that only 31 acres will be flooded. Please clarify. 6. Page 24 describes the project as a water system expansion and an upgrade. Please clarify that this project will not increase the capacity of the Southern Pines Water Treatment Plant (WTP) nor will it increase the distribution system. 7. Please remove the third paragraph from page 58 as it is repetitive, yet somewhat contradictory to the information on page 57. North Carolina Division of Water Quality 1617 Mail Service Cent Internet: www.ncwaterqualitv.org Location: 512 N. Salisbi NoorthCarolina Naturally 919) 733-7015 Customer Service 19) 733-2496 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Melba McGee 1/14/2008 2 8. While section 5.4.1 states that best management practices (BMPs) will prevent sediment from entering waterways, sections 5.4.2 and 5.10.2.1 state that sediment will enter streams. Please clarify. 9. The first two paragraphs on page 110 are conflicting, in that one says there will not be cumulative impacts to wetlands from the project and the other states that these impacts will occur. Please clarify. 10. Since the last paragraph on section 5.10.1.1 discusses indirect impacts, please move this text to section 5.10.1.2. 11. While section 5.10.1.1 says that new homes would likely be connected to central water and sewer systems, text in section 5.10.1.2 suggests that new homes in the area will use septic systems for treatment and disposal of wastewater. Please clarify. 12. Section 5.10.2: a. The unnamed tributary flows into Horse Creek which is classified as WS-II, HQW. High Quality Waters (HQW) is a subset of waters with higher quality than the standards require and need protection against future degradation to retain this high quality. A minimum release flow over the dam should be required in order to maintain this area as a HQW habitat for the aquatic biota. The biological standard for HQW is an excellent or good benthic macroinvertebrate bioclassification. Hydromodification of this stream, resulting from the dam and the possible groundwater disconnection (due to the lining of the reservoir) will likely reduce the habitat. This will ultimately lead to a reduction of the aquatic bioclassification below good or excellent, therefore not meeting the HQW standard. The flows directly below the dam would need to remain comparable to the normal average yearly flow in order to reduce biological impacts from the dam. The biological rating at both Horse Creek and Drowning Creek are currently Excellent based on latest assessment by DWQ in July 2006. (Macroinvertebrate sampling sheets are attached.) b. There is a lack of information on the direct impacts on the aquatic macroinvertebrates below the proposed Dam. DWQ has 54 total samples from Lumber Subbasin 50. Of this total, 32 of the 54 samples (59%) received excellent bioclassifications. Moreover, several nearby unnamed tributaries to Drowning Creek have had EPT species richness values equivalent to Excellent bioclassifications. These data suggest that it is possible that this unnamed tributary has the very real potential to qualify as HQW or ORW. Reduced flows would adversely affect the invertebrate community. Therefore, a benthological survey (as per DWQ collection methods - http://h2o.enr.state.nc.us/esb/BAUwww/benthossop.pdf) should be performed. c. When were the flows estimated for the stream? If this was done since the latter half of 2006, they would not represent an accurate assessment of the average annual daily flow (currently listed as less than 3 cfs in the EA). d. This EA does not address the possible impacts to the stream below the dam if they have to release water over the dam due to flooding in the area. It is important that this be done in a manor that would not cause excessive habitat destruction due to excessive flow volume that wouldn't normally occur at this location. Excessive erosive flows can lead to habitat degradation, erosion of streambanks and streambed, and can result in increased sedimentation. 13. Indirect and Cumulative Impacts: a. Since the project will not create an increase in capacity at the WTP (page 120), it does not seem that this project would result in indirect or cumulative impacts from increased development. Please clarify the following passages: • Page 108 states "The indirect impacts of this project to land use in the area are contingent upon many factors that may be amplified or suppressed with the expanded water capacity." ■ Page 119 states, "the construction of this project will increase the potential for development .. . thereby increasing the possibility of indirect impacts on the environment ..." • Page 120 states, "The cumulative impacts that could result after the construction of the proposed project [are] ... associated with newly developed lands within the existing water service areas." Melba McGee 1/14/2008 3 ■ Page 141 states, "The location of the proposed raw water storage reservoir project upon and surrounding the existing, prior -converted, pool site will limit any indirect and cumulative impacts from further development in the immediate vicinity." b. If it is determined that this project will result in indirect impacts from increased development, please state exactly what these specific impacts will be. c. Page 142: Any positive cumulative impacts on wetlands should be discussed in section 5.4. 14. While the discussion of need for this project on page 21 states "it is a measure to ensure raw water supply" for Southern Pines, page 142 states that the "primary goal of the proposed project is to expand" the existing raw water supply during times of drought. Please list the other goals of this project. Please contact me at 733-5083, ext. 555, if I can be of any additional help. Thank you. Cc: Belinda Henson — FRO Eric Fleek — ESS Elizabeth Kountis — CSU Nora Deamer — BPU Benthic Macroinvertebrate Sample Waterbody Location Date Bioclassification HORSE CR SR 1102 07/10/06 Excellent County Subbasin 8 digit HUC Index Number Latitude Longitude MOORE 50 03040203 14-2-10 350512 793100 Level IV Ecoregion Stream Classification Drainage Area (mil) Stream Width (m) Stream Depth (m) Sand Hills WS-II, HQW 40.6 7 0.3 Visible Landuse (%) Forested/Wetland Urban Agriculture Other (describe) 100 0 0 0 Upstream NPDES Dischargers (>1MGD or <1MGD and within 1 mile) NPDES Number Volume (MGD) none Water Quality Parameters Temperature (°C) Dissolved Oxygen (mg/L) Specific Conductance (pS/cm) pH (s.u.) Water Clarity 21.3 8.1 17 5 tannin stained Habitat Assessment Scores (max) Channel Modification (15) Instream Habitat (20) Bottom Substrate (15) Pool Variety (10) Left Bank Stability (10) Right Bank Stability (10) Light Penetration (10) Left Riparian Score (5) Right Riparian Score (5) Total Habitat Score (100) Sample Date 15 18 13 4 10 10 10 5 5 90 Sam le ID Substrate ST Site Photograph 80% sand, 20% silt EPT BI EPT BI Bioclassi 07/10/06 9974 n/a 26 n/a 2.4 Excellent 07/09/01 8435 n/a 20 n/a 2.8 Good 07/08/96 7063 n/a 28 n/a 2.8 Excellent 09/09/91 5712 n/a 26 n/a 2.3 Excellent Taxonomic Analysis Numbers of EPT taxa were in similar to the 1991 and 1996 collections. However, in 2006 only three mayfly taxa were collected, the lowest number seen when compared to the five, seven and eight taxa in previous collections. Baetid mayflies collected previously (e.g. Acerpenna pygmaea, Pseudocloeon ephippiatum, P. frondale, Baefis intercalris) were not seen in 2006. Stenonema exiguum (rare) was collected for the first time in 2006. The stonefly Pteronarcys dorsata abundant in 1991 and common in in 1996 has been absent since. The highest numbers of caddisflies were recorded in 2006 with a number of new taxa for this site (e.g. Agarodes, common). Data Analysis Horse Creek rated Excellent in 2006, an inprovement from the Good biolcassification in 2001. High water levels in 2001 made sampling difficult causing a decrease in taxa collected. In that year the Biotic Index remained similar to previous years supporting the conclusion that water quality did not decline. The absence of the shredder Pteronarcys dorsata could mean that less CPOM is retained in the stream. The absence of baetid mayflies remains a mystery, though could be related to low pH values. Benthic Macroinvertebrate Sample Waterbody Location Date Bioclassification DROWNING US 15-501 07/17/06 Excellent County Subbasin 8 digit HUC Index Number Latitude Longitude HOKE 50 3040203 14-2-(10.5) 350122 792636 Level IV Ecoregion Sand Hills Stream Classification C, Sw, HQW Drainage Area (mil) Stream Width (m) Stream Depth (m) 242 10 0.8 Visible Landuse (%) Forested/Wetland Urban Agriculture Other (describe) 100 0 0 0 Upstream NPDES Dischargers (>1MGD or <1MGD and within 1 mile) Moore County Public Utilites NPDES Number NC 0037508 Volume (MGD) 6.7 Water Quality Parameters Temperature (°C) Dissolved Oxygen (mg/L) Specific Conductance (pS/cm) pH (s.u.) Water Clarity 25 6.7 53 6.5 tannin stained Habitat Assessment Scores (max) Channel Modification (15) Instream Habitat (20) Bottom Substrate (15) Pool Variety (10) Left Bank Stability (10) Right Bank Stability (10) Light Penetration (10) Left Riparian Score (5) Right Riparian Score (5) Total Habitat Score (100) Sample Date 15 20 13 10 9 9 10 5 5 96 Sample ID Substrate ST Site Photograph gravel 10%, sand 70%, silt 20% EPT BI EPT BI Bioclassification 07/17/06 9969 78 26 4.81699 3.64222 Excellent Taxonomic Analysis A very simliar benthic community resides in Drowning Creek at US 15/501 as at SR 1004, approx. 10 miles upstream. Total taxa and Biotic Index values were similar and suggests that the pollution intolerant community found in the upper portions of the Lumber River Basin (Jackson Creek, Naked Creek, Horse Creek) continue downstream through this reach. Taxa found here that were not collected at other Lumber River basin sites in 2006 include the chironomid Trissopelpia and freshwater mussels (both common). Data Analysis Drowning Creek at US 15/501 was proposed as a new basinwide site as it was downstream of the Moore County Public Utilities discharge on Aberdeen Creek (approx. 3.5 miles upstream of US 15/501). The Excellent rating here suggests that any concerns about that facility should be looked at on Aberdeen Creek itself, where in 1987 a DWQ study found little difference between upstream and downstream collections associated with that discharger. Benthic Macroinvertebrate Sample Waterbody Location Date Bioclassification DROWNING SR 1004 07/10/06 Excellent County Subbasin 8 digit HUC Index Number Latitude Longitude RICHMOND 50 03040203 14-2-(6.5) 350357 793300 Level IV Ecoregion Stream Classification Drainage Area (mi2) Stream Width (m) Stream Depth (m) Sand Hills WS-II, Sw, HQW 125.5 10 0.5 Visible Landuse (%) Forested/Wetland Urban Agriculture Other (describe) 100 0 0 0 Upstream NPDES Dischargers (>1MGD or <1MGD and within 1 mile) NPDES Number Volume (MGD) none Water Quality Parameters Temperature (°C) Dissolved Oxygen (mg/L) Specific Conductance (pS/cm) pH (s.u.) Water Clarity 21 7.3 26 5.6 tannin stained Habitat Assessment Scores (max) Channel Modification (15) lnstream Habitat (20) Bottom Substrate (15) Pool Variety (10) Left Bank Stability (10) Right Bank Stability (10) Light Penetration (10) Left Riparian Score (5) Right Riparian Score (5) Total Habitat Score (100) Sample Date 15 20 15 4 9 9 10 5 5 92 Sample ID Substrate ST Site Photograph gravel 50%, sand 40%, silt 10% EPT BI EPT BI Bioclassification 07/10/06 9967 81 29 4.4 2.8 Excellent 07/13/01 8437 81 31 4.5 2.8 Excellent 07/08/96 7064 74 34 4.5 3.2 Excellent 09/09/91 5711 90 39 4.5 2.8 Excellent 02/16/89 4829 40. 40 n/a 2.6 Excellent Taxonomic Analysis Pollution intolerant taxa such as the mayfly Paraleptophlebia , the stonefly Neoperla , and the caddisflies Brachycentrus numerosus, Helicopsyche borealis, Oecetis morsei and Psilotreta frontalis have been collected here consistently since sampling first began in 1985. Unique taxa only collected here in 2006 within the Lumber River basin include the caddifly Paranyctiophylax celta, the beetle Sperchopsis tessellatus, and the chironomid Stelechomyia perpulchra Data Analysis The lowest Biotic Index in the Lumber River Basin in 2006 was recorded here (among Full Scale and Swamp samples). Drowning Creek has rated Excellent since 1985, when it was first sampled. All seven samples collected here since then indicate that water quality has not declined in this reference stream. No changes between 2001 and 2006 in the Natural conditions were noted at Gum, Little Raft (above the Town of Red Springs), Little Marsh, and at Big Marsh swamps. Bioclassifications declined from Natural to Moderate at Bear and Hog swamps. Declines noted at Bear Swamp may have been due to sampling under high flow conditions in 2006 rather than a true decline in water quality conditions; reasons for the decline at Hog Swamp were not known. No true changes were noted at Ashpole Swamp or a Gapway Swamp; both streams continued to be rated as Moderate. Table 1. Waterbodies monitored in Lumber River HUC 03040203 in the Lumber River basin for basinwide assessment, 2001 and 2006. Map #' Waterbody County Location 2001 2006 B-1 Lumber R Scotland SR 1404 Excellent Excellent B-2 Lumber R Robeson SR 1003 Excellent Excellent B-3 Lumber R Robeson NC 41/72 Excellent Excellent B-4 Lumber R Robeson NC 72 Good -Fair Good -Fair B-5 Lumber R Robeson US 74 Excellent Good B-6 Drowning Cr Richmond SR 1004 Excellent Excellent B-7 Drowning Cr Hoke US 15/501 Excellent B-8 Jackson Cr Moore . SR 1122 Good Good B-9 Naked Cr Richmond SR 1003 Excellent Excellent B-10 Horse Cr Moore SR 1102 Good Excellent B-11 Gum Swp Robeson SR 1312 Natural Natural B-12 Back Swp Robeson SR 1003 Not Rated Natural B-13 Bear Swp Robeson SR 1339 Natural Moderate B-14 Little Raft Swp Robeson SR 1323 -- Natural B-15 Little Raft Swp Robeson SR 1505 Moderate Severe B-16 Raft Swp Robeson SR 1505 Moderate Natural B-17 Raft Swp Robeson SR 1527 --- Moderate B-18 Little Marsh Swp Robeson SR 1907 Natural Natural B-19 Big Marsh Swp Robeson SR 1924 Natural Natural B-20 Porter Swp Columbus SR 1503 Moderate Severe B-21 Ashpole Swamp Robeson NC 41 Natural Moderate B-22 Hog Swamp Robeson SR 2262 Natural Moderate B-23 Gapway Swp Columbus SR 1356 Moderate . Moderate F-1 Drowning Cr Moore NC 73 Not Rated Not Rated F-2 Jackson Cr Moore SR 1122 Not Rated Not Rated F-3 Naked Cr Richmond SR 1003 Not Rated Not Rated F-4 Horse Cr Moore SR 1112 --- Not Rated F-5 Deep Cr Moore SR 1113 Not Rated Not Rated F-6 Aberdeen Cr Moore SR 1105 Not Rated Not Rated F-7 Quewhiftle Cr Hoke SR 1225 Not Rated Not Rated F-8 Mountain Cr Hoke SR 1215 Not Rated Not Rated B = benthic macroinvertebrate monitoring sites; F = fish community monitoring sites. River and Stream Assessment Specific site summaries of the 21 benthic macroinvertebrate and fish community samples may be found at this link: 0M0203. Special Studies Benthic Macroinvertebrate Monitoring of the Bear Swamp and Mill Branch Watersheds (Robeson County) Bear Swamp at NC 710, Watering Hole Swamp at Joseph H. Road, Moss Neck Swamp at SR 1570, and Mill Branch at NC 710 all in Robeson County were assessed in 2004 as part of an Ecosystem Enhancement Program study. There was no indications of severely degraded water quality in Bear Swamp (Good -Fair), Moss Neck (Good -Fair), or Mill Branch (Fair). Watering Hole Swamp was classified as "Not Rated" because it has an extremely small drainage area (0.8 square miles) and likely dries -up during the summer. As expected, the drying up of the stream also depresses the benthic community. However, this watershed also includes runoff from the Town of Pembroke, which may also be affecting the benthic community (Biological Assessment Unit Memorandum B-040524). NCDENR, Division of Water Quality Basinwide Assessment Report - Lumber River Basin - April 2006 11 Benthic Macroinvertebrate Monitoring of Ashpole Swamp at NC 130 and at SR 2258, Robeson County The Fayetteville Regional Office and the Planning Section requested additional sampling during the 2006 swamp season in Ashpole Swamp. Sites were chosen to fill in areas without data coverage. Ashpole Swamp at NC 130 is located approximately six miles upstream of a basin site (NC 41) and approximately 10 miles upstream of SR 2258, the other special study location in this part of the Lumber Basin. The site at SR 2258 integrates most of the entire Ashpole Swamp watershed (minus Indian Swamp) prior to its confluence with the Lumber River. Though both sites have very different watershed sizes they contain many of the same benthic fauna. Both the NC 130 and SR 2258 special study sites rated Moderate, with a fairly diverse but relatively tolerant (biotic index 7.1 and 7.2 respectively) benthos community. Crustacean and mollusk taxa were diverse at both sites (Biological Assessment Unit Memorandum B- 070227). NCDENR, Division of Water Quality Basinwide Assessment Report - Lumber River Basin - April 2006 12