NCS000400_Email RE Jamestown MS4 Permit Public Comments_20240608

Georgoulias, Bethany
From: Tim Dickenson <[e-mail]>
Sent: Saturday, June 8, 2024 9:23 PM
To: Reed, Isaiah L
Cc: [e-mail]; [e-mail]; Biser, Elizabeth;
[e-mail]
Subject: [External] DEMLR Stormwater Program, Jamestown NC NPDES MS4 past-due permit
renewal NCS000400 - PUBLIC COMMENT
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Mr. Reed,
I am submitting this Public Comment for the above referenced item but first I must direct this to the EPA
reps who are cc'd here:
NOTE TO EPA - THE TOWN OF JAMESTOWN AND SOUTHERN GUILFORD COUNTY
NEED TO BE PUT ENTIRELY UNDER THE AUTHORITY OF THE ENVIRONMENTAL
PROTECTION AGENCY. ASAP. DO NOT RENEW THIS RIDICULOUS, DANGEROUS
PERMIT. REMOVE IT FROM THE "OVERSIGHT" OF THE NCDEQ WINSTON SALEM
REGIONAL OFFICE IMMEDIATELY!
Back to this weird permit - In Jamestown's town manager's Stormwater Management Plan
dated 3/4/2024, very little attention is given to Jamestown's GIANT polluting elephant: industrial
dischargers, landfills and hazardous sites.
The response to BMP#6 in TABLE 13 gives an extremely weak, vague, lazy, "pass the buck"
answer - Jamestown says it will "partner" with Stormwater Smart and the Piedmont Triad
Regional Council. This organization provides absolutely ZERO services and support to
Jamestown. We have documented examples of Jamestown residents writing PTRC for
information and answers about our water and stormwater practices, including within my own
household, and they've received NO response. NOTHING.
This is UNACCEPTABLE in a critical watershed such as Jamestown, where a network of water
supply streams converge for treatment at the un-permitted and overstressed Eastside
Wastewater Plant, before traveling south for five miles to our drinking water treatment plant and
reservoir, Randleman Lake, and then continuing south to the Cape Fear River.
The water supply streams that all meet up in Jamestown carry wastewater discharge, chemical
contaminants and VOCs from industrial facilities, chemical companies, manufacturers, landfills
and construction dumps in Greensboro, High Point, and northern Guilford County.
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I am a fisherman. I kayak-fished Randleman Lake (our drinking water supply) as soon as the
new reservoir opened for such activities in 2005. 1 was deeply disappointed to hear from the
onsite staff there (Randleman Lake/Southwest Park) that I should "never" eat any fish caught
from the lake due to the massive amounts of pollution and contamination. NOTHING has
changed, except that I stopped fishing Randleman Lake shortly after 2005.
How, in the name of God, can you allow this water to be served to us as drinking water with SO
LITTLE INFORMATION on the testing and DECADES of toxic contamination?
We all know that Piedmont Triad Regional Water Authority (PTRWA) - which owns and operates
Randleman Reservoir and the Kime treatment plant - has been "organized" such that it is
exempt from REPORTING AND WATER QUALITY MONITORING at the levels that North
Carolina PUBLIC water treatment facilities and reservoirs are required to do. SURELY you see
this as a health hazard to the residents of this community. WE all do. It's VERY hard to miss.
Since 2010, all of Jamestown's drinking water, and much of the surrounding areas here in
southern Guilford County and northern Randolph County, comes from PTRWA/Randleman
Lake. Nobody in local government ever felt it necessary to INFORM US OF THAT.
There is SO MUCH documentation showing that the state of North Carolina KNEW Randleman
Lake as a drinking water reservoir was a stupid idea - so stupid that they predicted the day
would come that PTRWA/Randleman Reservoir would come begging for money to fix its
contaminated drinking water problem -just as it has did at Jamestown Town Hall last fall.
In the first four rounds of the UCMR5 test sampling events, EIGHT PFAS were detected in
Jamestown's drinking water, some of them in double-digit parts per trillion. Our water would
NEVER have been tested for PFAS if the federal government hadn't mandated it. The town has
said NOTHING to residents or local communities about these findings. Private Jamestown
citizens found the results on the EPA UCMR data website and shared them with residents on a
citizens' website. Doing our OWN research as volunteers on our own free time is the ONLY way
we can inform ourselves about what is running through our backyard river and streams, under
our homes, shops and schools, and out of our faucets. Jamestown is part of a bigger Guilford
County plan to keep us in the dark. See https://themamestowner9.com/water-quality-mamestown-
n c/pfas-test-res u Its-round-4/
Jamestown's history with 1,4 Dioxane goes back more than thirty years with the creation of an
experimental "Dioxane phytoremediation tree forest" that was supposed to help remove some of
the 1,4 Dioxane from the abandoned/bankrupt/unremediated Seaboard Chemical Dump
superfund site in Jamestown, on Deep River. 1,4 Dioxane is also in the Pretreated Wastewater
of in-town chemical/plastics manufacturer Alberdingk Boley, and a number of hosiery,
automobile parts and chemical manufacturers in High Point that discharge to Richland
Creek/Deep River. We are expected to drink it after it's "treated" at the rundown Eastside plant
and the treatment plant at Randleman. See https://themamestowner9.com/water-quality-
0amestown-nc/1-4-dioxane-i22-years/AND https://themamestowner9.com/contaminant-sources-
hazardous-sites/alberdingk-boles-spills/eastside-wwtp-omitted-spill-info/
WHICH IS WHY the idea that this town would propose this as a "MEASURABLE GOAL" (for
Public Outreach and Education): "MAINTAIN LEGAL AGREEMENT WITH PIEDMONT TRIAD
REGIONAL COUNCIL FOR PUBLIC OUTREACH AND VOLUNTEER OPPORTUNITIES" is an
insult.
TABLE 13 of the draft SWMP dated 3/4/2024 references "APPENDIX A" for some kind of
memorandum of understanding between the town of Jamestown and the Piedmont Triad
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Regional Council/Stormwater Smart regarding the number of public information items
distributed.
APPENDIX A IS NOT ATTACHED TO ' HE SWMP IN ' HE PUBLIC FILE. This is a major
component of the EPA NPDES MS4 Public Education and Outreach requirement, yet it has
been completely left out of the SWMP that is currently posted for review.
Further, despite declarations by the town manager, there are very few residents, including my
household, that have ever seen ANY kind of stormwater education booth at a public town event
like "Music in the Park" as implied in Table 13 of the SWMP titled "Town Sponsored Events."
In fact, last month (May 2024) when private residents representing a 501(c) nonprofit attempted
to hand out copies of NCDEQ Secretary Elizabeth Biser's recent press release concerning the
28-page 1,4-Dioxane Health Study, the town manager embarrassed the residents of this town
by aggressively approaching the residents and threatening to have "the sheriffs remove" them.
See https://themamestowner9.com/local-government/mamestowns-matthew-mohnson/
As for BMP #8 in the March 2024 SWMP - The stormwater education link on the Town of
Jamestown's site ONLY addresses private residents - a ridiculous 3rd-grade primer on how not
to stop up sinks, drains and Jamestown's pipes.
There is not a single mention of the REAL problem - the ENORMOUS INDUSTRIAL
DISCHARGE FLOW that has been destroying DEEP RIVER for decades.
Jamestown residents have uncovered numerous engineering and surveys and groundwater
assessments/studies that make it very clear that much of the dumping and abandoned
hazardous sites in Jamestown and its extraterritorial jurisdiction along Riverdale Road continue
to exist because local government, for nearly 100 years, designated Deep River as the
designated water dump for High Point and Greensboro's furniture, textiles and chemical
manufacturing industries because Deep River was "NEVER GOING TO BE A DRINKING
WATER SUPPLY" source due to its massive contamination problem.
(See https://themamestowner9.com/water-quality-mamestown-nc/ncdeg-knew-it-was-a-bad-idea/)
Number 9 in the SWMP "Public Education and Outreach" section discusses a "stormwater
hotline." No such thing exists. Two years ago, when my wife and I had a simple question about
floodplains and flooding in our Jamestown neighborhood, the public utilities director was not
allowed to simply type up a response to our email. The town manager wrote us and said we
would need to meet personally with him at Town Hall to have our question answered.
We have since encountered MANY residents who have had the same thing happen. Ask a
simple question or call Town Hall with a water concern, and you have to play the town
manager's ridiculous game of setting aside an hour to meet with him and whomever else he
pulls off the job, at Town Hall.
This is a TREMENDOUS waste of taxpayer money, and in the case of my wife's and my
question, it resolved NOTHING. It was obvious the town manager is in WAY over his head and
doesn't have a clue about what it takes to run a small public water system let alone a small
town.
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In addition, Jamestown does NOT have the resources - personnel and knowledge - to manage
a system such as this. It's a major threat to the Upper Cape Fear River and, ultimately, our
downstream neighbors.
I have lived in my home since 2018. A WOTUS stream flows through my and several neighbors'
yards. It empties into Bull Run Water Supply Stream behind a neighbor's house that is
separated from mine by three houses.
Not ONCE has anyone from the town of Jamestown spoken to us or contacted us to ensure we
are maintaining our WOTUS stream properly, that we are not dumping into it, that the banks are
sound and not eroding, that we haven't planted invasive plants along the banks. There is
absolutely no care nor concern on the part of the town about water levels, the condition of the
existing culverts (two of which support the driveways of two neighboring homes because the
stream runs through their FRONT yards), and what is flowing out of the old abandoned gold
mines that dot the property upstream from and adjacent to ours.
When the January 2024 storm blew through Jamestown, culverts in my Jamestown
neighborhood were clogged with tree limbs and debris that washed down from unmonitored
points upstream. My wife almost went in to remove the limbs until she realized how strong the
gushing current was. In an emergency situation such as this we know there is NO ONE in
Jamestown to call for help.
These clogged culverts caused extensive flooding on my property, and caused the partial
collapse of a neighbor's driveway due to the clogged culvert underneath it. Once Town Hall's
office hours had opened the next day, the neighbor called for help. I was there when two
Jamestown utilities employees arrived on the scene, stood around and said nothing, did
nothing, then said, "well, we can't do anything until Paul sees it." They were speaking of Paul
Blanchard, Jamestown's utilities director.
My neighbor then said, "well, tell Paul to come see it. Take a picture or something!" The
employees responded, "he's in a meeting." As they got into their white Jamestown truck, she
turned to me and my neighbors and said "they're children. CHILDREN."
Read it again. The DAY AFTER the most water-intensive storm to hit Jamestown in at least two
decades, "Paul was in a meeting" and UNAVAILABLE TO RESPOND TO RESIDENTS'
URGENT STORMWATER concerns.
Contact me personally if you want to see my photos and video of the flooding in my
neighborhood. The worst was Bull Run Stream - it overflowed its banks and reached almost to
the back door of my neighbor's house where four children live and play all day, every day.
We now know that Alberdingk Boley discharges and spills into Bull Run - a chemical company
that has ridiculous amounts of 1,4 dioxane in its wastewater yet has a "Stormwater Permit" for
FOOD WAREHOUSING??!! Are you kidding me? Why is this allowed - isn't this EXACTLY what
the Clean Water Act was set up to PREVENT?
AND - the local office of the NC DEQ Dept of Water Resources (WINSTON) completely
IGNORES our concerns about Alberdingk Boley. I was told that the husband of the assistant
supervisor of that office (WSRO) works for a chemical company that has product affiliations with
Alberdingk Boley. And that she lives in Jamestown.
These same concerns apply to TABLE 14 - about the town's useless storm water education
website link (I bet you can't find it on the Town's website) in the March 4, 2024 SWMP - the
MEASURABLE GOALS are a JOKE: "review for broken links... train staff to answer the phone
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... add phone number to stationery..." Those are t MEASURABLE GOALS. They're minimum
wage job descriptions. Disgusting.
Did anyone at the North Carolina Department of Environmental Quality even READ Matthew
Johnson's SWMP?? HOW COULD you accept this garbage? NO wonder our water is the most
polluted system in the entire United States of America.
James Dickenson
Jamestown NC 27282
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