DEQ-CFW_00001303

NJ
December 19, 2007
Hobbs, Upchurch & Associates, P.A.
Consulting Engineers
14878 US Hwy 17 • P.O. Box 1400 • Hampstead, NC 28443
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 November 19, 2007, on behalf
of the Lower Cape Fear Water and Sewer Authority (LCFWASA), please find enclosed
an updated version of the Environmental Assessment (Version 4: December 18, 2007),
a cover letter from the LCFWASA, a letter from CDM, designer of the Bladen Bluffs
Regional Surface Water System (BBRSWS), and the following responses:
Response to question 1. Ref: "Regional Water Supply Feasibility Study"
The proposed distribution routes and their impact corridors must be directly
discussed in the revised EA and not merely contained in an appendix.
Regrettably, the Regional Water Supply Feasibility Study will remain as an appendix
as it was authorized by the Lumber River Council of Governments and funded by
grant money and local matching money by the COG members. It'would be
unethical for the LCFWASA to include this body of work within the contracted
Environmental Assessment. It is considered a supplement to the project but not
included in Phase I, not was it envisioned by the scoping meeting of April 11, 2006
in which Mr. Jim McRight made it clear that the scope of the EA was limited to the
parameters of the current project (For the description of the BBRSWS See page 1
of the updated EA and response to question 7).
Furthermore, Mr. McRight indicated that if an expansion of the project would be
undertaken within five years, the EA contemplated for the project currently being
scoped could be "refreshed' to take into account such future expansions (mostly
transmission lines and a plant expansion) beyond the parameters of the current
project. The LCFWASA is following the steps as directed by Mr. McRight to
secure a FONSI.
Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
DEQ-CFW 00001303

Stallings - Submittal_ 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
The LCFWASA's Bladen Bluffs Regional Surface Water System provides for a
surface water alternative that will be available to the 4-County Region comprised of
Bladen, Columbus, Robeson and Sampson Counties over a 20-year period (See
Section A. 1, page 3).
As explained on page 8 of the updated Environmental Assessment, a network of 6,
8, 10, and 12 inch diameter water mains exists through the 4-County Region. This
existing distribution infrastructure is accessible to the proposed Phase II
transmission lines and positions the 4-County Region for access to the surface
water alternative system. This is in keeping with the intent of a Cooperative
Agreement executed by the North Carolina Environmental Commission, the
Division of Water Resources, and the Lumber River Council of Governments on
October 14, 2004 (enclosed), which states that alternative water sources for regional
water users, including shifting users to the surface water source be developed.
Response to question 2. Ref: Impacts to the Lumber River Basin
There is a misunderstanding as the expression will impact was not used in the
description. In retrospect, on our September 2007 response to question 15 (page
10, 5th. paragraph) we intended to explain that the Lumber River Basin would not
be affected for (1) increases in wastewater; (2) increases of runoff; and (3)
Interbasin Transfer. To provide a clearer description, we are rephrasing our
response as follows:
December 2007 version (page 112)
In the discussion for the Cape Fear River Basin factors such as the impact of the
intake and its withdrawal, water use projections and conservation plans, and low
dissolved oxygen in the estuary were addressed. For the Lumber River Basin, four
possible factors were evaluated: (a) increase in wastewater discharge, (b)
groundwater recovery; (c) interbasin transfer and (d) increase of runoff as the
consequence of increased development.
In response to the comment "whether the project will or will not impact wastewater
discharge flows" we now clearly state (See page 112, item 1):
Mi Hampstead, NC • Telephone [phone] • Fax [phone] •
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DEQ-CFW 00001304

Stallings - Submittal 4 Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
(a) No increases in wastewater are expected.
For Phase I, the LCFWASA anticipates that the wastewater treatment plants will
treat the same volume of water within the Lumber River Basin from the surface
water source as they now treat from the groundwater source. The most current
information from the DWR-Local Water Supply Plans (2002) indicates that there
are no plans in the next 10 years (-2012) for the expansion of the wastewater
systems in the Lumber River Basin area covered by this project (municipalities in
Robeson and Columbus counties), rural areas are mostly in septic systems, and it is
not expected that they would shift to wastewater plants. Therefore, no increase in
wastewater is expected in the immediate future, during the effective period of the
FONSI for this project.
Nevertheless, considering the 20-year timeframe that this EA covers, the
LCFWASA acknowledges that the regional build out of the alternative water supply
system may prompt the need for wastewater treatment and disposal within the
Lumber River Basin but not by the LCFWASA. To that end, Section A.1 explains
the actions that the Lumber River Council of Governments and the Lower Cape
Fear Council of Governments are taking to address wastewater disposal in the
future.
(b) The proposed surface water system will positively impact groundwater
withdrawals by reducing the rate of aquifer decline and prolonging the life of the
aquifer as a possible source of water for the region.
(c) Phase I of this project will not create an IBT from the Cape Fear to the Lumber
River Basin, as the 6 MGD water treatment plant will have not additional capacity
in Phase I to transfer 2 MGD to the Lumber River Basin, thus the system will not
activate the qualifying factor for an IBT.
l� Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
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DEQ-CFW 00001305

Stallings - Submittal 4 Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
(d) Increase of runoff as the consequence of increased development is not expected
to be significant in Phase I.
Local governments within the Lumber River Basin have established or are
establishing guidelines for controlled growth in an environmentally -friendly pattern;
see page 42, Section DA (Columbus and Robeson counties and their municipalities.
The guidance of growth from any form of stimulus is the function of planning
departments throughout the state. The more rural counties are lagging in the
development or updating of LUP and zoning ordinances but they are receiving help
from state agencies to develop those plans, which could be in place by 2010 when
the benefits of this project are realized. The existing and developing LUPs and
other smart growth guidelines may assure that the effect of the potential runoff
increase not negatively affect the Lumber River.
The land use plan for Bladen County seeks to guide and control development in all
of the county, including the Lumber River basin portion of the county, in such a
way as to minimize conditions.
A large portion of the water 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.
This is an unfounded observation as this is not included in the EA submissions.
There is no provision in the proposed project to collect wastewater from service
areas in the Lumber River Basin and direct it to wastewater treatment plants in the
Cape Fear River Basin. The LCWASA is not a wastewater service provider.
NJ Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
DEQ-CFW 00001306

Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Response to question 3. Ref: Increased wastewater production — Lumber
River specifics
The statement "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" was provided as a response to a previous question related to the specifics
of the Lumber River.
The statement has been misinterpreted and editorialized towards the construction
of wastewater treatment plants, which is totally unrelated to the BBRSWS.
Furthermore, the implication that SPC's wastewater discharge permit is somehow a
beneficiary of the BBRSWS is unfounded. For the record, SPC's NPDES permit
was renewed on July 15, 2007 and the permit is driven by the SPC's treatment
capacity to meet the discharge requirements of the permit, and not the BBRSWS.
As explained in Sections A, B, C, and in the document submitted to DWQ:
"Justification of a 30-MGD Intake in the Cape Fear River at Tar Heel, Bladen
County, NC" in November 2006, the intent of the system is to provide a surface
water alternative to customers within the 4-County Region to alleviate the
groundwater withdrawal and relieve consumption pressure on the underlying
aquifers, as provided for in the Cooperative Agreement. The BBRSWS is intended
to provide a treated surface water alternative to the region. SPC will not be the sole
beneficiary of the system. The LCFWASA has executed a project development
agreement to finance, design, construct and operate a 30-MGD intake, pumping
station, and a water treatment plant (in phases) to benefit the 4-County Region.
Phase I will utilize 6-MGD of the 30-MGD capacity of the intake, thus providing
future available capacity to the region from the intake (See page 3, paragraph 3,
updated EA).
m� Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
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DEQ-CFW 00001307

Stallings - Submittal 4 Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Response to question 4:
The word "would" in the first sentence of the first paragraph on page 3
(August 30) response should be replace with "may".
Noted.
Response to question 5:
For the protection of the public close to or downstream of the proposed intake,
comprised of recreational users and current drinking water users served by
Brunswick County and the City of Wilmington, the water quality concerns related
to the presence of metals, pH, PFOA, etc. should have already been resolved. The
public expects that DWQ takes action to collect any water quality data required to
rate the condition of the Cape Fear River.
We call your attention to the NC DENR- DWQ "Red Book" Surface Water and
Wetlands Standards, which establishes that the surface water quality standards for
surface water classified as "C" (current classification of the segment under request)
and surface waters classified as WS-IV (requested classification) are the same (Red
Book pages 21 and 32).
The LCFWASA acknowledges the creation of the Scientific Advisory Board (SAB)
and has had a representative present in effort to be informed of the progress
directed toward the need of additional PFOA data and any corresponding derived
water quality standard that may be adopted by the State of North Carolina. 15A
NCAC 02B.0104 d does give the state the right to consider information on
potential sources of pollution to determine that risks posed by all significant
pollutants are adequately considered, even if the pollutant is not otherwise regulated
by the Safe Drinking Water Act, US EPA, or other sources.
The concern should be the treatability of PFOA, not necessarily the level of PFOA
in the river; thus, the Reclassification Application and the Environmental
Assessment as submitted by the LCWASA should proceed accordingly. Please
refer to letter addressed to Mr. Alan Clark on November 27, 2007 by the
LCFWASA regarding the request for reclassification submitted to DWQ in
November 2006.
�� Hampstead, NC • Telephone [phone] . Fax [phone] •
email: [e-mail]
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DEQ-CFW 00001308

Stallings - Subm ttal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Response to question 6:
The statement that was interpreted as implying the "possibility that the 4-County
Region may not ever receive potable water from this project" is an invalid
conclusion based upon the construction of the BBRSWS which consists of a 30-
MGD intake, pumping station, and 6-MGD water treatment plant. SPC, as the
initial customer, has not contracted for all of the 6-MGD capacity. It is anticipated
that the balance of the capacity is immediately available to Bladen County which has
a distribution line in the ROW of NC 87, adjacent to the surface water treatment
plant.
i. "The FONSI issued for this project will only be effective for 5 years. Will
the 4-County Region be served within this timeframe?"
At the scoping meeting on April 11, 2006, the project was presented in phases with
SPC and Bladen County as the immediate beneficiaries of the system, upon
application for service. Phase I capacity of the surface water treatment plant is not
intended to serve all four counties during the effective period of this FONSI.
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?"
It is anticipated that within the 20-year timeframe service will be available to the
four counties. Service to all customers would be made available by a Treated Water
Application for service. SPC has executed its application. Bladen County is
anticipated to apply for treated water within five years. The town of Elizabethtown
and municipalities not served by the Bladen County system and parallel to NC 87
are anticipated to apply for service and be served by the BBRSWS within the 20-
year timeframe. Columbus County, a member of the service area, will be served
upon an application for treated water.
Sampson and Robeson counties currently are not within the LCFWASA service
area but can be served upon application for inclusion (Treated Water Supply
Agreement) in the service area. This process is applicable to any other customers
that would be interested in the service as an alternative to groundwater supplies
(See page 3, footnote).
The LCFWASA has been incorporated since 1970 and authorized to provide
service to a 5-County Region (New Hanover, Pender, Brunswick, Bladen and
Columbus counties) and as of 2007 has contracted water service agreements in
place with three of the five counties. Bladen and Columbus counties, members of
the LCFWASA are awaiting service.
B� Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
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DEQ-CFW 00001309

Stallings - Submittal 4 Bladen Bluffs DENR#1388, DWO#13820.doc DEC 19 2007
Response to question 7: The September response states the project has been
"downsized'
The reference made to a 12-MGD capacity is an operational consideration
of the pump station. The operation of the system intake, pump station,
reservoir and water treatment plant are business decisions of the LCFWASA
for an efficient and cost-effective operation of the facility, similar to many
municipal systems within the State of North Carolina that have a larger
capacity and often operate at a lower capacity.
We are enclosing a letter from the design engineering firm (CDM) to attest
to the components to be designed and constructed, as originally presented.
The project has not been downsized. The operation of the system is a
component of the constructed facility. We call your attention to comments
made by Mr. John Sutherland, DWR Water Projects Section Chief,
memorandum dated April 2004, 2007, on behalf of DWR: "we do not
object to the construction of an intake structure that will accommodate the
withdrawal of up to 30-MGD in the initial phase". Furthermore, he
supports that the initial phase of this project, the intake, equipped to
withdraw up to 12 MGD, and a water treatment plant sized to treat up to 6-
MGD capacity. This is the BBRSWS project and it has not been
downsized, its components are listed below and on page 1 of the updated
EA:
(a) A 30-MGD intake structure installed adjacent to the river to avoid
future river disturbances but operated at a withdrawal capacity of
12 MGD,
(b) Screens, pipe, and pump station installed for 30 MGD, but initially
operating up to 12-MGD capacity,
(c) A water treatment plant with a capacity of up to 6 MGD,
(d) A raw water impoundment with a capacity between 12 to 20 MG,
and
(e) Transmission line main, at the ROW of NC 87, will be available to
existing local water distribution systems (i.e Bladen County).
8
MI Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
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DEQ-CFW 00001310

Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Response to question 8:
As indicated above (response to question 6, item ii), any area within the 4-County
Region by means of an application for treated water supply agreement may have
access to the water within the 20-year planning period regardless of the status of
their LUPs or zoning ordinances.
Response to question 9:
Page 5 of the September response to question 6 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 be possibly
attached (paragraph 4).
This statement remains valid for the Phase I, 6-MGD water treatment plant. The
rationale used for the development of each alternative is still valid and the
economic of scales applicable. The 4-County Region has two possible sources of
water, surface water and groundwater. Aquifer levels have dropped dramatically
and further withdrawals will aggravate the conditions. Multiple water treatment
plants dispersed throughout the region are redundant and expensive to operate. A
single surface water plant (built in phases) supplying the region remains the most
cost effective solution to economies of scale.
Regrettably, in page 5, paragraph 5 of response to question 6 (September 14, 2007)
the statement "Since the scope of the project was narrowed to a 12-MGD system
and a 6-MGD surface water treatment plant" was misleading due to the use of the
words "reduced scope of the project was narrowed", which was not intended, and
may have led to a conclusion that the initial phase has been changed. However, the
6-MGD surface water treatment plant has been consistent throughout the process.
NJ Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
DEQ-CFW 00001311

Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Response to question 10:
Rationale
In North Carolina, reliance on groundwater as the principal source of drinking
water has resulted in declining water levels, salt water encroachment, dewatering,
and land subsidence in some areas of the coastal plain. The justification of the
BBRSWS project is to provide an alternative as opposed to the continued use of
groundwater resources in the Southern Coastal Plain (Reference Cooperative
Agreement, October 14, 2004)
In 2002, the North Carolina Division of Water Resources (DWR) distributed a
report entitled `Bladen County Preliminary Capacity Use Assessment." This
assessment encompassed Bladen, Robeson, northern Columbus, Sampson, and
Cumberland Counties. This geographic region is where the highest volume of
groundwater usage occurs in the Southern Coastal Plain. Five aquifers supply water
to this area: these include from deepest to shallowest, the Lower Cape Fear, Upper
Cape Fear, Black Creek, Peedee and Surficial aquifers. Of these five, the majority
of the total volume withdrawn is from the Upper Cape Fear and Black Creek
aquifers.
For the Southern Coastal Plain, the North Carolina Environmental Management
Commission (EMC) considered implementing new regulatory measures, and
directed the DWR to determine if a Capacity Use Area regulation (similar to the
Central Coastal Plain Rule) was warranted in Bladen and surrounding counties.
Although a Water Resources Plan (2004) prepared by the Lumber River Council of
Governments indicated that current groundwater conditions do not warrant a
Capacity Use Area regulation, the study did conclude that
"groundwater resources are limited, and that long-term viability of the aquifers (Black
Creek and Upper Cape Fear) appears to be threatened at certain cones of depression
associated with several majorpumping centers':
Therefore, similar to the Neuse Regional Water and Sewer Authority initiative,
whose purpose is to provide an alternative surface water resource as opposed to the
groundwater resources in the Central Coastal Plain, the Lower Cape Fear Water and
Sewer Authority proposes a regional approach for the Southern Coastal Plain
Counties to utilize surface water as an alternative water source to enhance the
sustainability of groundwater resources.
NJ Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
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10
DEQ-CFW 00001312

Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Respon e to specific concerns in question 10:
a. Municipalities have the choice...
County -wide distribution lines exist through the 4-County Region that is
currently served by groundwater. There is no comparison between the costs
associated to the extension of transmission lines along approved ROWs to
the cost of each municipality building their own intake, pump station, and
surface water treatment plant in addition to the transmission lines.
Furthermore, please consider the benefits to the environment by providing
the surface water alternative.
b. Economies of scale
Many municipal water and sewer systems are funded by the users of the
system (i.e. Enterprise Funds) rather than by property taxes of the
municipality. Property taxes are generally used to fund police officers.
As aquifers in the region fail to supply appropriate volumes of quality water
and the capacity of wells is restricted, surface water as an alternative,
provides for a balanced water supply management system within this region.
The Cape Fear River contains the largest volume of water in the southeast,
and therefore, the most capable surface water supply. If each municipality
were to be required to design, permit, and build their own intake, pump
station and SWTP, the cost of water could economically adversely affect
these already distressed counties. The BBRSWS designed, permitted and
constructed for the LCFWASA, with a 30-MGD intake from the river is
more economical for these distressed counties.
c. Reduction in scope
Previously, in responses to comments 7 and 9 above, we clarified that there
is no reduction in scope but rather a phasing associated only with the 6-
MGD surface water treatment plant component of the system.
d. Sampson County wells
Sampson is not within the LCFWASA service area at this time. It is
apparent, as with many counties within the State of North Carolina, that
Sampson County needs additional water to meet the demands of its citizens.
The request by Sampson County apparently is to increase the capacity of its
existing groundwater supply system. As directed by the Cooperative
Agreement; the BBRSWS will assist in shifting groundwater users both
present and future to a surface water supply. The system, once permitted,
will involve a lengthy construction period (similar to the Neuse Regional
Water and Sewer Authority) and not be available in time to meet the
immediate needs of Sampson County. The BBRSWS may help provide a
balanced Water Management Plan, consisting of treated surface water
system and groundwater systems within the region
11
r4j Hampstead, NC • Telephone [phone] • Fax [phone] •
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DEQ-CFW 00001313

Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Response to question 11:
We requested a copy of the Sampson County LUPs. The Sampson County LUP
was adopted June 18th- 2001. This correction was made to pages 40 and 42, of the
updated EA.
Response to question 12: Ref: Robeson County is outside the Authority's
service area.
When the BBRSWS is permitted and constructed, Robeson County, specifically, the
Town of Saint Pauls, upon submission of the Treated Water Supply Agreement can
be served by the additional capacity from the 6-MGD surface water treatment plant
a component, of the BBRSWS project.
Response to question 13: Wastewater Increase.
Previously, in response to comments 2, we had clarified the issue of wastewater.
Response to question 14: DO inputs from tributaries and the in stream
oxygen consumption processes
As explained in page 99 of the updated EA and in our response to Mr. Adugna
Kebede on August 21, 2007, the Cape Fear Estuary causes of dissolved oxygen
concentration are:
(1) Direct oxidation of BOD discharged to the estuary;
(2) Decaying phytoplankton biomass, and
(3) Natural sources of refractory organic matter from "blackwater" sources.
(4) Low DO input from the Black and Northeast Cape Fear and increases in
water temperature.
The analysis presented in the EA, pages 99-108, related to the effect of the
proposed water withdrawal at 7Q10 flows on downstream discharges and TMDLs,
is based on source point oxygen users (NPDES permitted dischargers: item 1,
above) available at the time of the submittal of this environmental assessment.
The analysis could not account for items 2-4 because that information is not
available since the modeling is under development. It is understood that DWQ is
working in conjunction with Dr. James Bowen at the University of North Carolina
at Charlotte in the modeling of the estuary. Dr. Bowen in the 2003 Cape Fear Basin
TMDL Conference in Raleigh listed the following challenges of modeling the
estuary:
N� -
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DEQ-CFW 00001314

Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
a. Three dimensional variability (longitudinal, lateral, vertical) in state variables,
b. Mixing regimes vary significantly from upstream (riverine) to mouth (energetic
tidal mixing),
c. Many significant sources of DO surface waters: algal productivity, surface
reparation, lateral inflows from ocean,
d. Many significant sinks of DO that affect surface waters: sediment oxygen
demand, low DO water input from Black and NE Cape Fear River, municipal
and industrial wastewater loads, BOD inputs from adjacent swamps and Black
and NE Cape Fear Rivers,
e. Widely varying decomposition rates of different organic matter sources;
decaying phytoplankton biomass, industrial/municipal BOD loads, refractory
matter form "blackwater" sources.
Nevertheless, in an effort to qualitatively include all possible sources of low DO in
the river and complement the analysis submitted in August 21, 2007, the following
information (Physical, Chemical, and Biological Characteristics of the Lower Cape
Fear River and Estuary) was added to Section E.10 — Surface Water- (a.5) as
"TMDL under Development", page 101.
Excerpt from (l) EnvironmentalAssessment of the Lower Cape Fear River Syrter� published by the
Center for Marine Science University of North Carolina Wilmington at Wilmington, N.C., 2005 1
"Dissolved oxygen (DO) problems are a major water quality concern in
the Cape Fear River and its estuary, and several of the tributary streams.
Concentrations in 2003-2004 ranged from 0.2 to 14.4 mg/L and station
annual means ranged from 3.8 to 9.5 mg/L Average annual DO levels at
the river channel stations for 2004 were very close to the average for
1996-2004.
Dissolved oxygen levels were lowest during the summer, often falling
below the state standard of 5.0 mg/L at several river and upper estuary
stations. Working synergistically to lower oxygen levels are two factors:
lower oxygen carrying capacity in warmer water and increased bacterial
respiration (or biochemical oxygen demand, BOD), due to higher
temperatures in summer. These hypoxic conditions could have negative
impacts on the biota in the Cape Fear River.
1 The study is entitled: Environmental Assessment of the Lower Cape Fear River System, updated 2005 by
Michael A. Mallin, Matthew R. McIver and James F. Merritt, September 2006 (CMS Report No. 06-02)
Center for Marine Science, University of North Carolina Wilmington, Wilmington, N.C. 28409. References
and tables were removed from the excerpt above, to read the entire document, pleased consult the following
web -site:
htt ://www uncwil edu/crosr/aquaticecology/lcfW/WO%20Rel2orts/LCFRP%202005%20rQort/LCFR%
2020050/620regort.12df , verified on December 17, 2007.
13
IM Hampstead, NC • Telephone [phone] • Fax [phone] •
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DEQ-CFW 00001315

Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
There is a dissolved oxygen sag in the main river channel that begins at
DPI below a paper mill discharge and persists into the mesohaline
portion of the estuary. Mean oxygen levels were highest at the upper
river stations NC11 and AC and in the muddle to lower estuary at station
M23. Lowest mainstem mean DO levels occurred in 2004 at the lower
river and upper estuary stations IC (7.3 mg/L) and M61 (7.2 mg/L).
Discharge of high BOD waste from the paper/pulp mill just above the
AC station, as well as inflow of blackwater from the Northeast Cape
Fear and Black Rivers, helps to diminish oxygen in the upper estuary. As
the water reaches the lower estuary higher algal productivity, mixing and
ocean dilution help alleviate oxygen problems.
The Northeast Cape Fear and Black Rivers generally have lower DO
levels than the main stem Cape Fear River (NCF117 2004 mean = 6.2,
B210 2004 mean = 6.9). These rivers are classified as blackwater systems
because of their tea colored water. As the water passes through swamps
en route to the river channel, tannins from decaying vegetation leach
into the water, resulting in the observed color. Decaying vegetation on
the swamp floor has an elevated biochemical oxygen demand and usurps
oxygen from the water, leading to naturally low dissolved oxygen levels.
Runoff from concentrated animal feeding operations (CAFOs) may also
contribute to chronic low dissolved oxygen levels in these blackwater
rivers. The Northeast Cape Fear River in general seems to be more
oxygen stressed than the Black River; from 2003-2004 NCF117 had DO
concentrations below 4.0 mg/L 33% of the time sampled, while during
that same period B210 had DO below 4.0 mg/L 13% of the occasions
sampled.
Several stream stations were severely stressed in terms of low dissolved
oxygen during the year January 2003-December 2004. ANC had DO
levels below 4.0 mg/L 46% of the occasions sampled, NC403 50%, GS
42%, BCRR 25% and SR 50%.
Some of this can be attributed to low water conditions and some
potentially to CAFO runoff; however point -source discharges also likely
contribute to low dissolved oxygen levels at NC403 and possibly SR,
especially via nutrient loading."
We acknowledge that the Cape Fear River Estuary model and the development of the
TMDL are works in progress, and when adopted, all parties should comply with the
loading allocations established. The permit for the BBRSWS can be amended to
include the adopted conditions when applicable.
1 DP, NC11, AC, M23, etc are Lower Cape Fear Monitoring Stations. Figure 28 of the updated, enclosed EA
shows the locations of those monitoring stations.
WJ 14
Hampstead, NC • Telephone [phone] • Fax [phone] •
email: [e-mail]
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Stallings - Submittal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
Response to question 15: LCFWASA withdrawal effect on downstream users
As a request from Mr. John Sutherland with DWR, the Cape Fear River Basin
model was used to describe the effects of the LCFWASA withdrawal at Tar Heel in
conjunction with other reasonable and foreseeable water users at least 20 years into
the future. The updated EA includes in Section E.10, the subsection (a.2) entitled:
"Water Use Projections Using the Cape Fear Basin Model" and in Exhibit H, the
entire analysis. A summary of the results follows:
I=act of the Proposed Withdrawal
Simulations of the Cape Fear River, with and without the proposed intake, were
conducted using the Cape Fear River Basin Model that is operated and maintained
by the NC DWR. Four scenarios were evaluated: base data, 2010 projections and
two 2030 projections.
The results of the simulations suggest that the intake in the river makes a very small
difference in the average flow of the river. For all scenarios, the average flow
decreased in the range of 4 to 5%. For extreme low flows or drought periods, the
impact of the intake in all scenarios ranged between 22 and 26% in all future
scenarios.
For more information related to the withdrawals and discharges from and to the
river, please consult the Exhibit H of the updated EA: Water Use Projections for
the Cape Fear River Using the OASIS Software (Cape Fear River Model).
Response to question 16: Conservation Measures
Municipal systems within the State of North Carolina have conservation policies or
water emergency plans associated with their water treatment plants.
In addition, conservation measures have been developed as part of the draft B. Everett
Jordan Lake Drought Management Plan, dated December 2002, prepared by the North
Carolina Division of Water Resources. These would apply to water users in times of
severe drought. Other conservation measures may be required by the Public Water
Supply Section.
The Bladen Bluffs Regional Surface Water System will have an adopted Water
Emergency Plan/Conservation Plan for the 6-MGD treated surface water plant, once
permitted and constructed, but not later than January 1, 2012 for all customers of the
system
W1 Hampstead, NC . Telephone [phone] • Fax [phone] •
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
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Stallings - Subn-ttal 4- Bladen Bluffs DENR#1388, DWQ#13820.doc DEC 19 2007
We believe that we have addressed your comments as thoroughly as possible to include
all available information to the best of our knowledge for each issue. We are enclosing
an updated version of the Environmental Assessment (dated December 2007) and
copies of this letter to be circulated among the reviewers listed below. We believe we
have followed the guidance of Mr. Jim McRight in securing a FONSI. We acknowledge
the input and guidance from Mr. John Sutherland, and most importantly, we believe we
have complied with the intent of the Cooperative Agreement between the
Environmental Management Commission, the Division of Water Resources, and the
Lumber River Council of Governments, dated October 14, 2004 (enclosed) by creating
the Bladen Bluffs Regional Surface Water System.
Respectfully submitted,
Hobbs, Upchlurch & Associates, P.A.
Morelia Sanchez -Ding, Ph.D., P.E.
Division Manager Hampstead Office
cc. Jim Mc Right, Public Water Supply Section, N.C. Division of Environmental
Health (with all enclosures)
Melba McGee, NC DENR- Environmental Review Coordinator (w/o EA)
John Sutherland, NC DENR DWR, Water Projects Section Chief (with all
enclosures)
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)
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. Version 4:
December 18, 2007
2) Cooperative Agreement between the Environmental Management Commission,
the Division of Water Resources, and the Lumber River Council of Governments.
3) Cover letter from the Lower Cape Fear Water and Sewer Authority, dated
December 17, 2007
4) Letter from CDM, designer of the BBRSWS summarizing the Design Capacities of
Proposed Water Treatment System dated December 17, 2007
NJ Hampstead, NC • Telephone [phone] • Fax [phone] . 16
email: [e-mail]
Southern Pines Nags Head Charlotte Beaufort
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