DEQ-CFW_00001290

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
November 19, 2007
MEMORANDUM
TO: Morella Sanchez -King, Ph.D., P.E.
Hobbs, Upchurch and Associates, P.A.
THRU: Dianne Reid, Supervisor
Basinwide Planning Unit and SEPA Program
FROM: Hannah Stallings, SEPA Coordinator �!%}
Planning Section
SUBJECT: Bladen County
Bladen Bluffs Regional Water System
DENR#1388, DWQ#13820
The Division of Water Quality has the following comments and concerns on the subject project:
1. The response to comment 1 from March 30, 2007, states that the revised EA will contain a "Regional Water
Supply Feasibility Study" for the area that presents plans for surface water distribution systems. The
proposed distribution routes and their impact corridors must be directly discussed in the main text of the
revised EA and not merely contained in an appendix.
2. The Authority maintains that the project will not impact the Lumber River Basin:
The proposed project will not alter the water resources in the Lumber River Basin. Instead, it
will provide a beneficial shift from using groundwater to the use of surface water. However,
the wastewater treatment plants will treat the same volume of water from the surface water source
as they now treat from the groundwater source. Therefore, no increase in wastewater will result.
However, the September 2007 response states that there are two possible impacts to the Lumber River::"(1)
increase in wastewater discharge, and (2) increase of runoff as the consequence of increased development."
Provision of municipal water service to areas in the `4-County Region' will impact water resources in the
Lumber River Basin. Please consider and acknowledge the following with discussion in a revised EA:
a. Please determine whether the project will or will not impact wastewater discharge flows.
b. As stated in the EA, the project will affect the groundwater resources in the basin as they are part of the
total water resource within a river basin.
c. This project will create an interbasin transfer of water from the Cape Fear River Basin. As stated on page
25, "raw water would be removed from the Cape Fear River in the central region of Bladen County, and
[only] a small amount of wastewater [effluent] generated by the wastewater [treatment] process would be
returned to the river via an NPDES permit." A large portion of the wastewater generated from this
project in the Lumber River Basin will not be discharged into the same basin. Also, wastewater not
processed at a WWTP will be discharged into the aquifers of the Lumber River Basin.
(See comment 15 from March 30, 2007, and comment 2 from April 16, 2007.)
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3. The August response states:
Increased wastewater production may occur as business enterprises increase. At present, septic
disposal of wastewater for households is common in rural areas. Industry on the other hand cannot
rely on septic disposal of wastewater and would require sewer main extensions or build their own
wastewater treatment systems.
It appears that this EA makes the case for an expanded and/or new WWTP(s) construction solely to serve
industrial customers, not local homeowners in the 4-County area. Since Smithfield Packing Company (SPC)
is the sole beneficiary of the initial phases of the project, with domestic uses "expected," but not guaranteed,
in the future, it seems that SPC is preordaining its own exclusive NPDES and/or nonpoint discharge increase
(page 5).
Please discuss.
4. The word "would" in the first sentence of the first paragraph on page 3 should be replaced with "may."
Sampling results for this reclassification have not been received yet and therefore it is not certain whether
they will address this concern. For the two portions of this part of the river that were "not rated" for aquatic
life, the 2002-2006 data show that one of these portions remains "not rated" but is newly impaired for
mercury based on water column as well as fish tissue results. This data also shows that the second portion,
which has been impaired only on the basis of mercury fish tissue results, is now also impaired for water
column lead, low pH, and water column mercury results. (Please note that one portion of this part of the river
has been, and continues to be, "not rated" for recreation, and there is also a new portion of this part of the
river that the data now shows as "not rated.")
Regarding the third and fourth sentences of the second paragraph on Page 3: It is not known at this time
whether additional PFOA data for the proposed intake and associated reclassification will be needed for the
reclassification to proceed. The Science Advisory Board (SAB) has been requested to recommend a reference
dose value for PFOA from which a water quality standard can be derived. The need for additional PFOA data
is dependent on (1) whether or not the SAB deems that existing toxicity data is sufficient enough for them to
make a recommendation, and (2) the SAB value recommended, and in turn, the corresponding derived water
quality standard.
6. Issues raised in comment 3 from March 2007 were not settled. Please directly address the following:
Page 5 states "SPC is the immediate beneficiary of the initial phase of the System, but expansion of the
System to provide water to the 4-County Region is expected." This sentence implies the possibility that
the 4-County Region may not ever receive potable water from this project. Please clarify.
a. Page 5 also states "The water line distribution system will serve SPC and eventually, the 4-
County Region."
i. The FNSI issued for this project will only be effective for 5 years. Will the 4-County
Region be served within this time frame?
ii. This EA is supposed to present a 20-year plan. Will all of the intended customers within
the 4-County Region receive service within a 20-year timeframe?
Page 85 states, "If the storage tanks are high enough, then the water may gravity flow to SPC without a
finished water pump station. The other finished water pump station would convey water to large users
other than SPC, so this finished water pump station will be added if and when there is enough regional
water demand to justify it." How long will it take for the potable water provided by this project to benefit
anyone beyond SPC?
7. As expressed in previous DWQ comments, it is suspect whether the 4-County Region will ever benefit from
this project. Responses to comments and contents of the previous EA do not provide clarity on this issue.
■ "The 30-MGD intake, SWTP and storage reservoir will be located on land that is currently owned by
[SPC] ... Arrangements will be made for long-term use of the site by the Authority once the project is
approved and prior to construction" (page 1, March 2007 EA).
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■ September responses state "The main goal of the proposed project is the preservation of the 4-County
Region groundwater resources by providing an alternative and reliable water source." The March 2007
EA contains "Resolutions for Support from the counties of Bladen, Columbus and Sampson, the City of
Clinton and the Towns of Elizabethtown, Chadbourn, St. Pauls, White Lake, Lake Waccamaw, and
Whiteville. [This support is given because of the expectation that] Treated water will be offered to these
municipalities through a water distribution system from the location of the SWTP," (page 3).
■ The September response to comments states the project has been downsized:
■ "The intake will operate up to 12-MGD capacity and the surface water treatment plant up to 6-
MGD capacity," with SPC's allocation being 4 MGD.
■ There are varying expected participation rates: up to "the 100% participation scenario" and
"down to a Bladen County only participation" scenario.
*The response states "Bladen County and its municipalities will be the first to benefit from this
project."
■ Alternatives in a revised EA will include options with different sizes of WTPs and associated
infrastructure for distribution and storage.
Based upon the September responses and the apparent reduction of scope, this project becomes progressively
more questionable. It increasingly appears that the sole planned benefactor of this SWTP will be SPC, with
the surrounding municipal areas all but forgotten.. Also, with SPC continuing its holding rights to the
property, it is questionable whether this project will ever reach its full potential or if future phases will be
severely impeded because it will deem future expansion not to be cost-effective (page 2 of September
responses).
If this is the case, then the project needs to be wholly scaled back and redesigned so that (at least) monies
allocated for and impacts from installation of water distribution mains through Sampson, Robeson, and
Columbus Counties are removed.
8. The September response makes the case for Bladen County receiving flows from the SWTP first because it
has LUPs and zoning ordinances in place. Since Sampson County and the City of Clinton also have LUPs in
affect, is there a guarantee that they will also have immediate access to the project?
9. When discussing the purpose and need for the project, the March EA states, "The 4-County Region will
benefit from the System. This infrastructure will establish a water source that will support industry
investments through 2030 thereby making a significant difference in the economic futures of the citizens of
the 4-County Region." Page 5 of the September responses cites the benefits of achieving an "economies of
scale [by] building a single SWTP sized large enough at the outset to serve all of the customers that would
possibly be attached."
The significant reduction in the volume of water that will be treated has altered the scheme under which the
original alternatives were analyzed since there cannot be as large of a potential benefit for those in the 4-
County Region other than SPC. In truth, the marked reduction in volume of the preferred alternative will
compare to the "no action" or "restricted growth" alternative (pages 23-24) in the March EA.
Since it now appears that the proposed SWTP will not connect to all of the originally anticipated areas,
economies of scale will not be achieved for this project.
Please respond.
Also, please reconsider the rationale for supporting the chosen alternative.
10. Page 87 of the March EA states, "Each municipality that is proposed to connect to the project plant at full
development is currently drawing water from wells and will no longer require that flow with the possible
exception of drought periods." (A similar statement is on page 90.)
Page 3 of the September response states this project provides the chance for participant municipalities "to
seize the current opportunity of establishing a cost effective regional water source that can significantly slow
the aquifer withdrawals, thereby protecting the quality of the groundwater for years to come while
empowering the economy of the area. But the alternative water source will have to exist before the towns can
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plan to attach to the distribution system. Without the surface water option there will be no planning for
attaching to that resource."
Page 4 of the response states "When the transmission lines are in place the municipalities will have the option
of 1) slowing or ceasing flow from the wells and attaching to the distributed water or 2) to continue pumping
water from their wells and treating/softening. As towns attach to the regional water supply they may reduce
their work force and equipment maintenance by greatly reducing or curtailing groundwater pumping. Total
connection to the system sill occur incrementally over the 20 year horizon."
a. If municipalities have choice whether to connect to the proposed SWTP, it would seem that they would
opt not to allocate money for this, especially considering that local "economies do not offer enough to
keep police officers on duty." If they choose not to connect, only SPC would benefit.
b. If the municipalities elect not to connect to the SWTP system, all possible total connection to the system
will not occur and the project will not fulfill its purpose and the potential economies of scale will not be
achieved.
c. If municipalities do connect to the SWTP, due to the reduction in scope, they will not be able to reap the
benefits as they were intended to have at the outset of this project. (See comment 6 above).
d. Sampson County has submitted an Environmental Assessment to develop seven (7) groundwater wells for
a potable water supply. The scope of this project challenges the need for the Bladen Bluffs project.
Please discuss with the County its intentions and modify the scope of this document as necessary.
Please respond.
11. Page 36 of the March 2007 EA states that Sampson County and Clinton do not have LUPs, the September
responses indicate that they adopted LUPs in 2002. Please review the text and determine that all
representations of policy adoption are accurate.
12. Page 7 of the responses states "Robeson County is currently outside of the Authority's service area." When
will be Authority's Mission as presented on page 2 be modified for Robeson County and what action(s) will
be necessary for this amendment?
13. Page 10 states both that there will be a predictable "increase in wastewater discharge" and there will be "no
increase in wastewater [discharges]." Please be consistent.
14. The qualitative mass balance calculation to determine the effect of the withdrawal on downstream dissolved
Oxygen levels used a very simplified approach under a 7Q10 flow in that it did not take into account the
affect of low DO inputs from the tributaries and the instream oxygen consuming processes. While DWQ
acknowledges the difficulty of accurately representing all causes of low dissolved oxygen levels in the river,
all possible sources should be identified and accounted for, at least qualitatively, in the analysis. Based on the
consultant's own calculations using its basic approach, the dissolved oxygen levels will be lowered by 1 to
3% because of the withdrawal.
Once the Cape Fear Estuary model and the TMDL development are completed, the requirements established
in the TMDL should be met by all parties. Therefore, any permit issued for this project should include a
reference to the TMDL being developed for the Cape Fear Estuary.
15. DWQ remains concerned about how this withdrawal will affect downstream users. If this withdrawal occurs,
are the downstream users still within 20% of the 7Q10?
16. Those served by the proposed SWTP should have conservation measures in place to use during time of
drought so that they can also reduce withdrawals when the river needs the water most. The river already
suffers from chlorophyll a issues and low dissolved oxygen problems, both of which will be exacerbated
when conditions are hot and dry and natural flows are slowing down.
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There has been a significant change in scope for the proposed project since its last submission. Due to this and
because of inconsistencies within the previous EA, within responses to comments, and between the EA and
responses received, DWQ requests that it be provided with copies of the draft EA prior to its final submittal for its
review and approval.
It is necessary for DWQ to have its concerns fully and clearly resolved because the Classification and Standards
Unit of DWQ must make the case for the reclassification for this section of the Cape Fear River to the EMC.
Also, please be sure to amend the discussion of project design and resulting environmental impacts so that they
align with the currently proposed plan.
Please contact me at 733-5083, ext. 555, if I can be of any assistance in resolving these issues.
Thank you.
Cc: Melba McGee — DENR
Jim McRight — DEH
Dianne Reid — BPU
Nora Deamer — BPU
Connie Brower — CSU
Rlizabeth=Kountisi— "CSU4*-
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