Daniel Holliman - United States Environmental Protection Agency

Wainwright, David
From: Holliman, Daniel <Holliman.Daniel @epa.gov>
Sent: Monday, April 07, 2014 4:03 PM
To: Bashaw, Justin P SAW
Cc: Gordon, Lisa Perras; Bowers, Todd; Mueller, Heinz
Subject: [EXTERNAL] EPA Review of EA for A Demonstration Project Showing the Impact of
Floating In -Lake Long- Distance Circulators in B.E. Jordan Lake
Mr. Bashaw,
We have completed our review of the above referenced EA and would like to offer the following comments below. It is
our understanding that "[t]his Environmental Assessment (EA) addresses a request for a proposed demonstration
project which would place a total of 36 floating in -lake long- distance circulators within Jordan Lake. Twenty -four
circulators would be deployed in the Morgan Creek Arm of Jordan Lake and 12 would be placed in the Haw River Arm of
Jordan Lake for a 24 month period. The circulators would upwell water from near the bottom of the hypolimnion to the
surface (epilimnion) of the lake. According to the State, the circulators are expected to improve water quality by
suppressing phytoplankton activity such that chlorophyll a, pH, and turbidity measurements would meet State water
quality standards within the project areas. Water quality would be monitored within the project areas and compared
with data collected outside of the project area as well as historically collected data. Such comparisons would allow the
NCDWR to verify if this project is having the intended results of reducing chlorophyll a." (p. 2 of EA)
The EA provides an analysis of four alternatives:
1. No Action
2. Solar Powered In -Lake Long- Distance Circulators
3. AC Powered In -Lake Long- Distance Circulators
4. Wind Powered In -Lake Long- Distance Circulators
The preferred alternative identified in the EA is Alternative 2 - Solar Powered In -Lake Long- Distance Circulators
EPA Comments:
1) State WQS — EPA notes that the proposed demonstration project is being implemented to address elevated Chl
a levels in Jordan Lake, however, we would expect other parameters to be impacted such as Dissolved Oxygen
and Temp. EPA recommends that all other WQ parameters be closely monitored to ensure that the proposed
demonstration project does not cause or contribute to violations of State water quality standards.
2) Phosphorus and Nitrogen Loadings — Chl a is a biological response to elevations in nutrients (phosphorus and
nitrogen) in the Lake. If the project is not addressing nutrient loading from the watershed, the underlying cause
of biological activity (elevated Chl a) is not being addressed. Since the proposed project is not removing
nutrients from the system, once the Solar Powered In -Lake Long- Distance Circulators are removed, it is
anticipated that the elevated Chl a levels would return.
3) "Jordan Lake Rules" Implementation - As stated in the EA, Jordan Lake is impaired for Chl a and low DO. Per the
Jordan Lake Phase I Nutrient TMDL "Elevated nutrient concentrations in Jordan Reservoir result from a
combination of point and nonpoint source loads. The point source loads include three major wastewater
treatment plants at the headwaters of the New Hope arm and seven major wastewater treatment plants
upstream on the Haw River. There are also several smaller dischargers. Nonpoint loading includes runoff from
urban areas in Durham, Chapel Hill, Cary, Burlington, Greensboro, and several other small municipalities, as well
as a variety of rural sources." Steps have been taken to address non -point pollution issues in the watershed

through the development and implementation of a nutrient management strategy (see
http: // portal .ncdenr.org /web /jordanlake). EPA supports these efforts to reduce nutrient loading in the
watershed and to Jordan Lake and we see these management strategies as long term solutions to Jordan Lake
WQ issues. EPA also notes that several modifications to the 2009 Jordan Lake Rules law have been enacted that
impact the implementation timeline of the nutrient strategy (as noted in 5.1.6 — water quality section of the
EA). EPA recommends that the Jordan Lake nutrient management strategy and the recent changes be more
comprehensively discussed under the "no action" alternative — Section 3.1.
4) Recreation and boater safety — With Jordan Lake being a major regional recreation attraction it is expected that
boater traffic is significant in the summer months. Recreation is also an authorized use of Jordan Lake. EPA
notes that figure 25 shows an actual deployment of the proposed solar circulators. EPA notes that these
circulators sit very low in the water and may be difficult to see by boaters; however we note that navigational
markings and strobes are being proposed. EPA remains concerned that the proposed circulators may pose a
significant impact to boater traffic in both the Haw River and Morgan Creek Arms of the Lake.
5) Impacts to Fish — It is stated in the EA that "There is a possibility that hypoxic or anoxic conditions may
periodically exist; however, any decrease in dissolved oxygen levels at the surface are expected to be relatively
short lived, lasting no more than a few days." (p. 25 of EA) Is there data that supports these conclusions? If so,
it should be provided in the EA. EPA is concerned that the impact of hypoxic conditions mentioned on p.25 on
fish species has not been fully explored in the EA. In addition, EPA notes that section 5.3.2.3 — Fisheries Section
— does not include the above referenced (potential hypoxic condition) as a potential impact on fisheries.
6) Uncertainty of In -Lake Long- Distance Circulators — With the understanding that this is a "demonstration
project ", EPA notes that there is uncertainty relating to the effectiveness and overall performance of the
proposed system. The EA does not disclose how many times the proposed system and has been deployed, what
types of lakes the system has been deployed in, and how they have performed in other deployments. EPA
believes this type of information is critical when making an informed decision relating to the proposed
action.
We appreciate the District's efforts to coordinate with Region 4 on this project. If you have any questions please give me
a call.
Dan Holliman
USEPA Region 4 I IN EPA Program Office
61 Forsyth Street SW I Atlanta, GA 30303
tel[phone] I holliman.daniel @epa.gov
Region 4 NEPA: http : / /www.epa.gov /region4 /opm /nepa /index.html