DEQ-CFW_00001232

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i
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Michael F. Easley, Governor William G. Ross Jr., Secretary
John Morris, Director
February 22, 2008
Melba McGee
Environmental Coordinator
North Carolina Department of Environment and Natural Resources
Office of Legislative & Intergovernmental Affairs
1611 Mail Service Center
Raleigh, NC 27699-1611
RE: Bladen Bluffs Regional Surface Water System
The Division of Water Resources (DWR) has reviewed the Environmental Assessment (EA) for
the Design, Construction and Operation of the Bladen Bluffs Regional Surface Water System
submitted in December 2007. The service area of the project as described in the EA includes
Bladen, Robeson, Sampson, and Columbus Counties which span six different river basins.
Therefore, there is the potential that operation of the proposed project, at some point in the
future, would require interbasin transfer certification. However, we have concluded that
operation of the project, specifically under Phase I as described in the December 7, 2008
draft of the EA, and through discussions with the Lower Cape Fear Water and Sewer
Authority and its consultants, will not likely cause an interbasin transfer (IBT) that would
require certification. This conclusion is based on a number of assumptions and interpretations
of IBT law which require clear explanation.
For the purposes of estimating the interbasin transfer amount caused by the Lower Cape Fear
Water and Sewer Authority (LCFWSA), it is necessary to consider all of its current and proposed
operations as a whole. The LCFWSA currently has a water withdrawal intake on the Cape Fear
River at King's Bluff. This intake is used to withdraw raw water which is sold to the City of
Wilmington and Brunswick County. Both Wilmington and Brunswick County treat the raw
water and provide treated water to areas both in and out of the source Cape Fear river basin,
resulting in interbasin transfer. The LCFWSA is currently planning to expand the capacity of
the King's Bluff intake which would increase the potential for IBT from the intake. It is
important to note that both Wilmington and Brunswick County own the pipelines at the
ridgelines between river basins where any interbasin transfers occur.
The proposed regional surface water system at Bladen Bluffs would include an intake upstream
of the King's Bluff intake, also on the Cape Fear River, with a withdrawal capacity of up to 30
million gallons per day (mgd). Phase I of the project includes a water treatment plant with a
capacity to treat up to 6 mgd.
1611 Mail Service Center, Raleigh, North Carolina 27699-1611
Phone: [phone] k FAX: [phone] Internet: www.ncwater.org
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Wirally
DEQ-CFW 00001232

,W .
Hobbs, Upchurch & Associates, P.A.
14U Consulting Engineers
14878 US Hwy 17 • P.O. Box 1400 • Hampstead, NC 28443
February 25, 2008
North Carolina Department of Environment and Natural Resources
DWQ Planning Section,
1617 Mail Service Center, Raleigh, NC 27699-1617
Hannah Stallings, SEPA Coordinator
Ref. Lower Cape Fear Water & Sewer Authority/ Bladen Bluffs EA (#1388)
Dear Ms. Stallings:
To address your comments in your Memorandum dated January 312008 please find
enclosed the final version of the EA and the following responses:
1. The December 19, 2007 response to comments states that this project will
not require an Interbasin Transfer (IBT). Phil Fragapane with the
Division of Water Resources said that he has not received paperwork
regarding the need for an IBT. Once DWQ receives notification
regarding the decision for need of an IBT, the Division will withdraw its
concerns on this issue.
Please refer to enclosed letter dated February 22, 2008 from the Division of
Water Resources. That letter summarizes the DWR conclusions regarding
the IBT paperwork for this project.
For Phase I (described on page 1 of the EA), the DWR concluded that the
"operation of the project, specifically under Phase I as described in the
December 7, 2008 draft of the EA, and through discussions with the Lower
Cape Fear Water and Sewer Authority and its consultants, will not likely
cause an interbasin transfer (IBT) that would require certification".
Mr. Fragapane also indicated that the IBT grandfathered capacity
worksheets and water balance tables that he had requested are no longer
necessary as part of the environmental review. However, they should be
submitted by the LCWASA as part 4 of its local water supply plan.
Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
DEQ-CFW 00001233

.4W ,
Stallings - FINAL- Bladen Bluffs DENR#1388, DWQ#13820.doc FEB 25 2008
The first beneficiaries of the regional surface water system (Tar Heel,
Elizabethtown, Dublin, and Smithfield Packing Company) are located in
Bladen County with their treated discharges into the Cape Fear Basin. This
statement is substantiated with the following excerpt from the Cape Fear
River Basin Water Supply Plan, March 2002, Second Draft for Discussion -
page 61:
"Eight public water systems in Bladen County are included in this analysis:
Elizabethtown, White Lake, Dublin, Tarheel, and four Bladen County water
districts (701 North, West Bladen, East Arcadia, and White Lake). All of
these systems rely on wells for water supply and have service areas at least
partly within the Cape Fear River Basin. There are two wastewater discharges to
the basin in Bladen County. Eli.Zabethtown treats wastewater from its own service
area and that of the Town of Dublin, and discharges treated wastewater to the
Cape Fear River. Wbite Lake discharges treated wastewater to Colly Creek, which
flows into the Cape Fear River".
2. There seems to be a typographical error in the December 19, 2007
response regarding expansions of the wastewater system in the Lumber
River Basin. The response states "that there are no plans in the next ten
years (-2012) for the expansions of the wastewater systems in the Lumber
River Basin are covered by this project." We are assuming that you meant
2022.
No. There is not a typographical error in our December response. HUA
consulted the DWR web -site Local Water Supply Plans of the systems that
could be served by the Bladen Bluffs Regional Surface Water System within
the Lumber River Basin, and found that the most recent published
information is from 2002. These systems indicated in the Water Supply
Plans for the year 2002, that they had no intentions to make any wastewater
expansions in the next 10 years (related to 2002, would be in 2012).
We attempted to gather the most recent information and telephoned each
of the potential water systems in the Lumber Basin to be served by the
LCFWASA. We found that they are currently updating their water supply
plans in accordance with DWR's call for the year 2007 Water Supply Plans,
which are due July 1, 2008. Often these plans are submitted by some users
much later.
2
Hampstead, NC • Telephone [phone] • Fax [phone] •
NJ email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
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Stallings - FINAL- Bladen Bluffs DENR#1388, DWQ#13820.doc FEB 25 2008
3. The December 19, 2007 response to comments states that standards for
class C waters and WS-IV waters are the same. This is incorrect. WS-IV
waters have additional criteria for protection of the raw water supply.
Please refer to 15A NCAC 2B .0216 (3)(h).
Noted.
4. Under the Federal Clean Water Act, surface water quality standards
cannot consider treatability. North Carolina's water quality standards are
based on what the affects are to aquatic life and human health per EPA's
Water Quality Criteria, which are explained in Section 304(a)(1) of the
Federal Clean Water Act. Please visit EPA's webpage for information on
these standards: http://www.epa.gov/waterscience/criteria/.
Noted.
5. We are pleased to see that the Bladen Bluffs Regional Surface Water
System will have a Water Emergency Plan/Conservation Plan. DWQ will
be recommending that LCFWASA's commitment to water conservation
be placed into DEH's FNSI.
The Bladen Bluffs Regional Surface Water System will have a Water
Emergency Plan/Conservation Plan and LCFWASA will insure that the
plan is placed within the Department of Health in accordance with the
reference to such a plan in the EA.
With the responses above, we believe that the concerns from DWQ have been
addressed and the FONSI is forthcoming. As you know, DEH is the lead agency
for this project and one of its requirements to prepare the FONSI is to obtain
written agreements from each commenting agency indicating their approval of the
applicant's responses or mitigation measures recommended (transmittal dated May
8, 2007, enclosed). We appreciate that DWQ submits that written agreement to our
office and copy McRight for the EA records. Thank you for your efforts reviewing
this project.
3
NJ Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
DEQ-CFW 00001235

Stallings - FINAL- Bladen Bluffs DENR#1388, DWQ#13820.doc FEB 25 2008
Respectfully submitted,
Hobbs, Upchurch & Associates, P.A.
Morella Sanchez -King, Ph.D., P.E.
Division Manager Hampstead Office
cc. Jim Mc Right, Public Water Supply Section, N.C. Division of Environmental
Health (w/o EA)
Melba McGee, NC DENR- Environmental Review Coordinator (w/o EA)
Dianne Reid, DWQ BPU and SEPA Program, Supervisor (w/o EA)
Nora Deamer, DWQ BPU and SEPA Program (w/o EA)
Connie Brower, DWQ Classification and Standard Unit (w/o EA)
Elizabeth Kountis, DWQ Classification and Standard Unit (w/o EA)
Phil Fragapane, P.E. NC Division of Water Resources (w/o EA)
Don Betz, Lower Cape Fear Water and Sewer Authority (with all enclosures)
Enclosures:
1) Environmental Assessment for the Design, Construction, and Operation of the
Bladen Bluffs Regional Surface Water System, Bladen County, NC. Final.
February 22, 2008
2) Letter from the NC Division of Water Resources dated February 22, 2008.
3) Transmittal dated May 8, 2007 from DENR, Division of Environmental
Health; Mr. James Mc Right.
NJ Hampstead, NC • Telephone [phone] . Fax [phone] •
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
DEQ-CFW 00001236

Through discussions with Don Betz of the LCFWSA and Morelia Sanchez King of Hobbs,
Upchurch and Associates, DWR understands the following:
1) LCFWSA has an agreement with Smithfield Packing Company (SPC) to provide up to 4
mgd of treated water from the Bladen Bluffs water treatment plant (WTP) to be used entirely
within the source basin, and
2) LCFWSA will also provide water from the Bladen Bluffs WTP to a number of other
water users which may use a portion of the water outside the source basin, resulting in an IBT..
With regards to LCFWSA's interbasin transfer, the Division of Water Resources has concluded
the following:
I. LCFWSA currently does not transfer any water out of the Cape Fear Basin, and has
no grandfathered capacity to transfer water.
Both of LCFWSA's raw water customers, the City of Wilmington and Brunswick
County, own the pipelines at the ridgelines between the source and receiving
basins. Therefore, Wilmington and Brunswick County are considered to transfer
the water out of the basin. Since LCFWSA owned no infrastructure for
transferring water out of the source basin on July 1, 1993, they are considered to
have no grandfathered capacity.
H. LCFWSA would be required to obtain an IBT certificate before it may transfer 2
mgd or more out of the Cape Fear River Basin on any day.
M. When the trausfer amount on any day reaches 1.6 mgd, which is 80% of 2 mgd,
LCFWSA must begin. reporting IBT amount estimates to DWR on an annual basis. At this
time, LCFWSA must also consider carefully whether IBT certification will be necessary for
future plans to operate the system, and if so, begin the certification process.
In a previous letter, I requested grandfathered capacity worksheets and water balance tables from
LCFWSA as part of the environmental review of the Bladen Bluffs project. Though this
documentation is no longer necessary as part of the environmental review, it should still be
submitted as part 4 of LCFWSA's 2007 local water supply plan, and should be prepared taking
into account all of LCFWSA's facilities and operations, both current and proposed.
Pleape
Au-
Philconttact me with questions at [phone] or [e-mail].
Fragapane, PE
River Basin Management Section
NC Division of Water Resources
cc: Linwood Peele, and Woodrow Yonts, NCDWR
Don Betz, Lower Cape Fear Water and Sewer Authority
Morella Sanchez -King, Hobbs, Upchurch, and Associates
1611 Mail Service Center, Raleigh, North Carolina 27699-1611 No ehCarolina
Phone: [phone] FAX: [phone]Internet: www.ncwater,org itttlrlt!!lJ
An Equal Opportunity ( Affirmative Action Employer - 50 % Recyded Y 10 % Post Consumer Paper
DEQ-CFW 00001237

MAY-08-2007 15:36
Div. of Environtnental Health
DENR
1634 Mail Service Center
Raleigh, NC 27099.1634
[phone]
FAX # [phone]
NC DEW PUBLIC WATER SUPP
T R A N
To:
Fax:
From:
Date:
919 715 4374
P.01
S
M
I T T
A L
Morelia Sanchez King, Ph.D., P.E.
910-270-5548
James McRight (919-715-0006)
May 8, 2007
Pages: 16 pages including cover sheet
Re: Environmental Assessment for, Bladen Bluffs
Regional Water System, Bladen County, NC
DENR 01388
I have received the following review comments for this
project. Please provide a response to each of the items
and secure a written agreement from each commenting
agency that the response or mitigation proposed is
appropriate for that agency to agree to a FONSI for this
project. When you have all agreements, please prepare a
final EA and include the agreements in the appendix of the
newly revised "final" EA. Please Include a cover letter
itemizing each commenting agency's item(s) and the agreed
final mitigation or response for ease of final review. Then
send me 10 copies of the final environmental assessment
for me to use with a final FONSI for the State Clearinghouse
review (which I will develop). Please note that I can not
secure a FOSNI on Federally funded projects until after the
public meeting and i have a copy of the Affidavit of
Publication showing a minimum of 30 days notice of the
meeting and that there were no significant comments at that
meeting.
Thanks
Jim McRight
DEQ-CFW 00001238