20061203 Ver 2_Western Wake Comment Summary 082307 PDT materials (9-27-07)_20070927

Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
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Leila Goodwin - Town of Cary
Wastewater Option 4: Purchase Under "Purchase Capacity from Durham County" the text states that the amount of
'
1 Management Capacity from Other wastewater included in the Town of Cary
s wastewater treatment contract with The text will be changed to reflect this revision.
Options Systems Durham County is 4 mgd. The amount was originally 4 mgd, but the contract was
amended to 5 mgd to add flow from a Morrisville pump station.
Henry Wicker - US Army Corps of Engineers
Preliminary
Identification of The information about sites approved for development or is developed (sites 21 41 51
Analytical
Additional information to justify dismissing sites that are now considered unavailable due
2
Potential Water 6, 9, and 27) is not adequate to justify their exclusion. We need site specific
Framework
to development will be available at PDT Meeting No. 5. Site 6 is not in this group.
Facility information to concur with this assessment.
Reclamation
Sites
The Partners' approach to the Harris Lake elevation issue was as follows: Progress Energy
has stated that the conservation pool elevation of the lake is going to be raised from
Elevation 220 to 240. We know that in addition the design will have to provide for flood
storage or surcharge. In addition to flood surcharge it is reasonable to assume that a buffer
around the lake will be kept for security/access reasons as well as water quality protection
purposes yet (we realize that water quality buffers are applicable to other water bodies at
other sites which will be included in their analysis). Because the design of the Harris Lake
a. Information from Progress Energy indicates that the potential expansion of the Expansion is not done, we suggested that 20 feet of elevation above 240 is reasonable and
Sharon Harris Power Plant will require Harris Lake elevation to be raised to 240', appropriate for analysis of impacts on candidate WRF sites and other infrastructure in the
not 260'. Although some distance for buffers etc. is reasonable 240' should still be area. As a point of reference, records on Jordan Lake show conservation pool at elevation
the baseline figure for reviewing potential Progress Energy sites for the WWP's 246.2 and flood storage at elevation 261.5 - 15 feet difference (not including any buffers).
facility. All of the Progress Energy sites should be reviewed again at 240' lake
" Available information for Harris Lake shows that the documented flood plain around Harris
elevation. The information in your Table
Site Impacts Resulting from Harris Lake
"
'
Lake for the current 220
foot conservation pool elevation ranges from Elevation 240 to 260.
Expansion
should reflect this change. After review of the sites at the 240 di
This is a 20 to 40 foot t difference from the conservation pool elevation. Applying the the
elevation, combining the remaining sites should be considered. minimum end of this range to the proposed new conservation pool elevation would
conservatively put the new 100 year flood plain elevation at approximately 260 feet. Since
3 Analytical Progress Energy's the WRF is critical public infrastructure, we would recommend that it be located to avoid
Framework Sites inundation during the Harris Lake spillway design event. That event should be at least the
IN probable maximum precipitation (PMP) storm and will result in a water surface elevation
above the 100 year flood plain. Using Elevation 260 to preliminarily assess impacts to WRF
Sites near Harris Lake as the first part of the analytical framework is conservative (in terms
of areas excluded from consideration) and reasonable.
As stated in the prior response, the Partners believe using Elevation 260 to preliminarily
assess impacts to WRF Sites near Harris Lake is conservative (in terms of areas excluded
from consideration) and reasonable. A preliminary WRF has been designed for one of the
b. Previously there has been some discussion about combining sites (20, 21, 22, sites. Its rough foot print covers approximately 57 acres and it has a perimeter distance of
and 23, or 20 and 24) to provide needed acreage since they are all adjacent to each approximately 7200 feet. Providing for a 200 foot perimeter buffer is estimated to be ((7,200
*
other. Sites 20/21 were grouped together in earlier analysis. We do not concur with ft
200 ft)/43,560 sf/acre) approximately 50 acres. Increasing the combined total area
their exclusion as separate sites. Sites should be grouped together for analysis if requirement (107 acres) by 50 /o to provide space for site specific design variances to
they cannot be used by themselves. avoid/minimize environmental impacts, results in a reasonable minimum site requirement of
160 acres.
Consideration will be given to combining adjacent sites when they are excluded based on
size.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
SEE SK
c. Site 25 was eliminated because the site was bisected by streams. This is not a
sufficient reason to eliminate the site. WWP's will need to explain in more detail Site 25 has been retained in the revised initial screening.
why this site should be eliminated. Site 25 may need to be to remain under
Analytical Progress Energy's consideration if there are no other reasons for eliminate the site.
3

(contd) Framework Sites
At this time it has not yet been definitively determined that procuring Progress Energy
(contd) (contd) d. Also, it is important that the WWP receive correspondence from Progress property for constructing the WRF or the influent and effluent conveyance facilities is
Energy stating that the procurement of their property is possible for constructing the possible either through purchase or condemnation. The Partners have not proposed using
facility. At the moment it is assumed that it is possible, but the WWP needs the fact that a parcel is owned by Progress Energy as reason to dismiss a particular site at
something in writing to address this issue. this first stage of the analytical framework.
Water Reclamation In TM05 Site 16 shows an area of 306.91 acres while the table on Page 4 shows an In TM05 site 16 and 17 or a portion thereof were combined into one. For the current
Analytical Facility Candidate area of 167.71 acres. Which is correct? If the former is correct both sites 16 and 17 analysis, Sites 16 (167.71 acres) and 17 (228.5 acres) as defined in PDT materials
4 Framework Sites that Remain should be considered separately. If the latter is correct then Site 17 should be distributed to date were considered separately first. Sites 16 and 17 are largely separated
for Screening considered separately and then together with Site 16. by a likely perennial stream, combining these sites does not offer another reasonable
alternative to the WRF site selection process.
As addressed in a previous response, a preliminary WRF has been designed for one of the
sites. Its rough foot print covers approximately 57 acres and it has a perimeter distance of
1) Physical Environment approximately 7200 feet. Providing for a 200 foot perimeter buffer is estimated to be ((7,200
a. What is the WWP proposed acreage limit that will be used to eliminate sites. ft * 200 ft)/43,560 sf/acre) approximately 50 acres. Increasing the combined total required
area (107 acres) by 50% to provide space for site specific design variances to
avoid/minimize environmental impacts, results in a minimum property size of 160 acres.
Habitat quality has been defined in the initial screening criteria as Significant Natural
Heritage Areas.
2) Biological Environment As the site selection process is narrowed down to the pool of sites to be analyzed in detail,
Water Reclamation a. Habitat Quality. The habitat evaluation procedure will need to be defined. site walkovers and rapid assessments such as terrestrial habitat assessments (including
Facility Candidate game species, threatened and endangered species, and species of concern), stream
Site Screening to assessments, and wetland functional assessments may be used to better define habitat
quality.
Analytical Determine Those 3) Socioeconomic
5 Framework Sites Considered as a. Site Proximity to Schools, Churches and other Sensitive Land Uses. Other Sensitive Land Uses are defined in the initial screening criteria as cemeteries, day care
Reasonable sensitive land uses need to be identified. facilities, retirement facilities, schools, hospitals, and churches.
Alternatives to the
Proposed Project 4) Water Reclamation Facility Development Factor
Site a. Site Acquisition and Availability. This criteria was used earlier. Do not need Concur.
for further analysis of sites.
5) Water Reclamation Facility Development Factors.
a. The "numerical scoring, weighting factors or other numerical techniques" Methodology is under consideration and will be defined.
need to be identified. The methodology used to eliminate sites needs to be further
defined.
6) Detailed Evaluation of Reasonable Alternative WRF Sites
Western Wake Partners (WWP) Goals and Objectives are not relevant to the EIS
section of an environmentally preferable alternative and should not be used as Project Purpose and Need will not be used as a criterion.
criteria. A more appropriate place to list the WWP goals and objectives is in the
section that discusses the history of the project.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
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Jennifer Haynie - NCDWQ Construction Grants and Loans
The way the memorandum is presented (e.g. headers and organization) makes it
Analytical difficult to follow and determine the process that was used to reduce the number of
6
Framework General sites under consideration from 30 to an intermediate number. Please see the Concur.
proposed outline at the end of the document for a possible way to organize this
framework.
Analytical Preliminary ID of The third paragraph of this section states that Sites 2, 4, 5, 6, 9, 10, and 27 have
7 Framework Potential WRF Sites been developed. Please provide documentation that shows that this development See response to Comment 2.
has either already occurred or is eminent.
1) Correspondence that addresses Progress Energy's long-term plans should be USACE and the Project Partners are currently working to obtain written correpondence
' included in the DEIS. Until then, it is not wise to eliminate sites based on this addressing Progress Energy's long-term plans

Progress Energy
s
reason. .
Sharon Harris
Power Plant Long- 2) Table - Site Impacts Resulting from Harris Lake Expansion: Information
Analytical Term Plans and provided in this table as well as Figure B shows that, while not sufficient by See response to Comment 3 b.
$ Framework Regulatory themselves, Sites 20 and 21, 22 and 23, or 20 and 24 could be combined to provide
Compliance Affects the needed acreage because they are adjacent to each other.
Consideration of
WRF Sites
3) At the top of Page 5, Site 25 is eliminated because of streams onsite. This may
not be a sufficient reason to eliminate this site. Instead, Site 25 should remain See response to Comment 3 c.
under consideration.
This section combines Sites 16 and 17. According to the 2/07 version of TMO5, Site
Analytical WRF Candidate 16 has an area of 306.91 acres while the table on Page 4 shows an area of 167.71
9 Framework Sites that Remain acres. Which acreage is right? If the former is correct, then both Sites 16 and 17 See response to Comment 4.
for Screening should be considered separately. If the latter is correct, then Site 17 should be
considered separately and then together with Site 16.
1) The title of this section makes an erroneous supposition that the proposed site is
the chosen site. The title should be revised so that it accurately reflects the Concur.
discussion. Please see the outline below for a possibility.
2) In the third paragraph after the second sentence, please clarify that readily
available data will be used at this stage while more detailed study of sites (e.g., field Concur.
investigations, ground-truthing) will occur for the final set of sites.
WRF Candidate 3) Physical Environment
Site Screening to a. Site Topography and Acreage Requirements
Determine Those i. It is unclear as to what would be the bright line that would eliminate sites due See response to Comment 5, part (1) a.
Analytical Sites Considered as to acreage.
10 Framework Reasonable ii. Site topography should be considered under a separate criterion since the
Alternatives to the topography in this area would not necessarily be a valid reason to completely Concur.
Proposed Project eliminate a site.
Site
b. Location of Site in Relation to Service Area Demand and Wastewater
Treatment Needs and Location of Site in Relation to Cape Fear River Discharge:
Please remove these categories from this level of screening because they were
previously used during the initial screening. Using them at this level would Concur.
constitute double-counting.
c. Floodplain Considerations and Wetland Impacts and Waters Considerations:
Rif- IAAH ho oliminnf-I in tho initial on-nine n-p- if romnval of flnnrlnlain aroa from tho
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
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0
oil=
No concrete number is provided for a bright line to eliminate sites based on
site results in inadequate area (defined as 160 acres) for the site.
floodplains.
4) Biological Environment
a. Habitat Quality:
It is unclear what is meant by "a reasonable habitat evaluation procedure." It
may be difficult to define the quality of habitat without detailed field study, which See response to Comment 11 part (2) a.
will be part of the final evaluation.
b. Threatened and Endangered Species and Species of Special Concern
Considerations:
A measurable parameter should be used to determine whether a site should be Concur - The parameter "known T&E or SHNA occurrences within 0.5 mile of site" was
eliminated due to threatened and endangered (T&E) species considerations. used as a factor during WRF site selection but was not used to eliminate sites. Concur that
T&E Species or SHNAs adjacent or nearby should not constitute a reason for occurrences on actual sites would be an appropriate criterion for site elimination.
elimination of a site.
5) Socioeconomic
a. Site Proximity to Residences and Neighborhoods:
It appears as if this criteria mainly concerns buffers. Since buffers would be
adequately addressed in the Site Topography and Acreage Requirements, this Concur.
criteria should be eliminated.
b. Site Proximity to Schools, Churches, and Other Sensitive Land Uses
WRF Candidate i. Please define what other sensitive land uses would be (e.g., hospitals, nursing This category will include proximity to schools, churches, hospitals, retirement facilities, and
Site Screening to homes, cemeteries) so that it will be clear what all sensitive land uses are. Also, cemeteries. Cultural resources will include historic structures and districts, cemeteries, and
Determine Those define what cultural resources would be (e.g., historic sites and archaeological
archeological sites.
10 Analytical Sites Considered as
sites).
(contd) Framework Reasonable ii. Define what criteria would be used to determine to determine the bright line as Occurrences on actual sites would be an appropriate criterion for site elimination.
Alternatives to the to whether a site would be acceptable.
Proposed Project 6) Water Reclamation Facility Development Factors
Site a. Engineering Feasibility:
The facets of this criterion would appear to be inherent in the engineering
design of the proposed facility. Consider removing this criterion from the This criterion has been included under Constructability.
analysis.
b. Site Acquisition and Availability:
This criterion seems to have been handled at the very beginning of the analysis. This criterion has been removed - it is addressed under Displacements.
Consider removing this criterion from the analysis.
7) In the last paragraph of this section, the second sentence states that "...sites be
compared and contrasted according to factual determinations made within each
factor instead of providing numerical scoring, weighting factors, or other numerical See response to Comment 5 part (5) a.
techniques in order to discriminate between sites." The methodology used to
eliminate sites should be further defined.
8) In conjunction with the previous comment V.7, even though no numerical
scoring/weighting is proposed for the screening factors listed, this sentence
intimates that some screening factors are more important than others. If this is the Sentence will be eliminated.
case, the factors' importance should be clarified in the framework. If this is not the
case, consider rewording or eliminating this sentence.
9) When presenting the results of this study, please provide the data in both tabular
and map format so that those reviewing the results will have all of the information Concur.
they need.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
SEE SK
1. The second sentence states, "in addition to the NEPA criteria, factors related
to the practicability of each site and its ability to meet the Western Wake Project
Partners' goals and objectives will also be documented during this analysis." It See response to Comment 5 part (6).
appears that the goals and objectives are inherent within the criteria and thus should
Detailed Evaluation not be an additional factor in this analysis.
11 Analytical of Reasonable 2 The third sentence states, "These evaluations can be used in order to support
Framework Alternative WRF selection of a subset of preferred alternative sites where the evaluations of NEPA
Sites criteria do not reasonably distinguish between alternatives." It is not clear whether
this relates to the above intermediate analysis or the detailed analysis that will be See response to Comment 5 part (6).
discussed at a later date. Regardless, because this is an environmental analysis
and document, the focus needs to remain on the NEPA criteria and not encompass
the goals and objectives.
Paul Barth - New Hill Community Association
A single wastewater treatment plant has many issues:
-Single point of failure NCDENR generally prefers regional solutions to wastewater management. The Partners
- long raw sewage lines crossing miles of sensitive land posing risk to water have selected a single treatment facility as their approach to a regional solution. The single
supplies, wetlands, lakes, ponds and other runoff collection areas plant allows the Partners to achieve economies of scale regarding operational costs. The
Analytical Alternate - No easy access to the sewage lines that snake through farms and woodlands. Partners' pipelines will be included in a collection system permit, which requires the
12
Framework
Management Option This will delay locating and repairing a sewage spill.
Partners to maintain access to all their pipelines. They will be required to purchase
- In the Analytical Framework Document, Page 3 of 8, comments are made by the easements for the pipelines and maintain the easements and pipelines. Building treatment
WVVP regarding air quality impacts and increased environmental risks of raw plants close to the towns will require even more pipelines to be constructed to convey
wastewater spillage with long pipelines. Having multiple sewage treatment plants wastewater around the service area.
close to the towns, eliminates long pipelines of untreated sewage and reduces air
quality impacts and environmental risks of raw wastewater sewage spills.
An alternative to a single wastewater treatment plant would be to treat the sewage
as close to its generated source as possible, therefore minimizing the risk of a
sewage spill, providing readily accessible treated water for secondary uses and
reducing the size of all piping that transverses the southern end of Wake county.

Analytical
Alternate This would eliminate a single point of failure and maintains responsibility for the
This alternative was not selected as the Partners' proposed regional solution for wastewater
13 Framework Management Option operations to the municipalities that generate the waste. Sites in and around the treatment and would result in construction of additional pipelines, adding cost and impacts.
area north of US 64 could serve Cary, Morrisville, Wake County portion of RTP and
parts of Apex. Sites in and around Beaver Creek (sites 8, 9, 10) could serve Apex.
Holly Springs would continue with their current wastewater treatment plans. Effluent
from the north of US 64 could be combined with effluent from the Beaver Creek
station and Holly Springs and pumped collectively to a point south of US 1.
Reconfigure the remaining lands from sites 19, 20, 21, 22, and 23 which sum to
Alternate Option for over 710 acres and come up with a workable site for the sewage plant. Don't just
"
"
14 Analytical Progress Energy say we are going to put it
here
and work to disprove that location where ever it See response to Comment 9 b.
Framework (PE) Property may be, but diligently work out a solution of where to place the plant on PE property.
Do the right thing from the beginning. Overcome the miniscule obstacles and make
it work for the betterment of all of Wake County.
Even if PE says that they are proposing to raise the lake level to encompass an
Alternate Option for additional 3500 acres and will most likely need to mitigate the land that is flooded by
15 Analytical Progress Energy designating an additional 3500 acres this is still only 7000 acres out of the 14,300 USACE and the Project Partners are currently working to obtain written correpondence
'
Framework (PE) Property acres that are not currently being used by PE for utility power generation. Certainly addressing Progress Energy
s long-term plans.
a 60 to 100 acre plot that will be suitable for a sewage plant can be found on the
remaining 7,300 acres.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
SEE SK
Alternate Option for Page 1 - Instead of ruling out lands that are planned for development at the outset The Partners and USACE must reduce the number of WRF sites from 30 to a reasonable
Analytical Lands that are of the selection process, evaluate the other factors for a favorable solution to begin number. This criterion for elimination inludes sites that are already developed or are already
16 Framework Planned for with, and then in the final analysis, if it is between two sites, one that is planned for approved for specific, proposed development. This is an appropriate criterion for site
"
"
Development development and one that is not, then make that choice. elimination. Sites that are
planned
for future development could address any site, and this
is not a criterion for site elimination.
Page 3 - Stating "Accommodating the additional reactors would conceivably require
the water conservation pool of Harris Lake to be raised up to or above elevation of
240 feet" is at this point speculation. Where is the documented commitment for any USACE and the Project Partners are currently working to obtain written correpondence
reactor expansion? In fact, expansion is not guaranteed. Approval depends on
' addressing Progress Energy's long-term plans.
many factors which are too far into the future to be considered today. Even PE isn
t
sure that they will pursue additional reactors! Reference News and Observer article
dated May 31, 2007 (attached)
All sites would require buffer acreage. If no buffer is included for a site, the Partners will
Page 4 - Any site that is located on PE property would not require "buffer acreage,, have no control over the future use of the buffer area. The Partners have no control over
therefore site acre requirements should be reduced to 60 or 100 acres at most. future Progress Energy plans with regard to land and must consider buffer acreage for any
17 Analytical Plant PE long Shearon term Harris Also, all currently defined sites on PE property were drawn arbitrarily. PE sites are potential WRF site.
Framework
plans not parcel specific like all of the non PE property sites. A site on PE property could
Progress Energy sites are drawn based on parcel boundaries where appropriate; however,
be located anywhere suitable for a WRF, even considering speculative plans to add some Progress Energy owned tracts are large and would have to be divided to establish
one or more nuclear reactors. WRF site boundaries. It is agreed that the boundaries of a potential WRF site could be
drawn with more flexibility than those of other sites.
Preparing this NEPA document is starting from the beginning of the Corps' proccess. The
Page 5 - Stating that "Constructing the WRF on PE property would likely require cost data and previous site rankings are being re-evaluated to be consistent with the NEPA
unreasonable site development costs" is irrelevant. When sites were original process and the direction of the PDT.
defined and ranked, cost was included as a factor and still the top (3) sites were on
" The statement regarding PE sites having potentially large adverse environmental impact
PE property. Also stating PE sites
have potentially large adverse environmental
" and public interest is not meant to include any implications about impacts other sites may
impact and public interest
implies Site 14 has less or no adverse impacts. This is have. All impacts will be addressed in the site evaluation process. The site development
certainly not true! costs referred to on page 5 apply only to those sites that would be impacted by an increase
in the level of Harris Lake.
Page 5 - If the purpose of screening is to "limit unavoidable adverse effects across Site 14 cannot be excluded during the initial and intermediate site screening process,
key public interest factors" ... consistent with NEPA criteria", then Site 14 definitely because it is the Partners' preferred site. However, data for Site 14 will be shown along
qualifies for exclusion due to it's environmental justice impact, being adjacent to with data for other candidate sites. Site 14 will be compared to the other final 1 to 4 WRF
New Hill Historic District and two historic churches with cemeteries and sites that are identified for final detailed evaluations. Socioeconomic factors for all sites will
playgrounds. be considered during the site evaluation process.
Analytical Candidate Site Page 6 - Physical Environment (Level of Intensity). An alternative should be
18 Framework Screening implemented without costly mitigation for or displacement of existing developed
land. WWP is trying to mitigate away an environmental justice issue by offering a
few commercial property owners access to sewage and water at an estimated This issue is more appropriately discussed at a later date.
mitigation cost of $3 million. Residential property owners in the New Hill community
(documented to ACE via First Baptist Church petition dated March 23, 2007) are not
willing to trade their current quality of life to placate a few commercial property
owners.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
SEE SK
Page 6 - Socioeconomic (Site proximity to residences). Locating the facility on PE
property would not impact any residents. There are thousands of acres available to Number of displacments will be considered in the site screening.
buffer the plant at no additional project cost to WWP.
18 Analytical Candidate Site Site 14 cannot be excluded during the initial and intermediate site screening process,
(contd) Framework Screening Page 7 - Socioeconomic (Site proximity to churches and other sensitive land uses). because it is the Partners' preferred site. However, data for Site 14 will be shown along
Site 14 definitely qualifies for exclusion due to it's being adjacent to New Hill Historic with data for other candidate sites. Site 14 will be compared to the other final 1 to 4 WRF
District and two historic churches with cemeteries and playgrounds. sites that are identified for final detailed evaluations. Socioeconomic factors for all sites will
be considered during the site evaluation process.
Page 7 - Site acquisition and availability. PE property best meets this requirement.
It can be acquired timely, requires no displacement of families/homes, minimizes See response to Comment 9 d.
subdividing property because only 60 to 100 acres is required not 200 acres, and
there would be no recombining parcels of property. PE property is a 100% match.
Water reclamation Page 7 - We oppose eliminating "numerical scoring." This process started with Preparing this NEPA document is starting from the beginning of the Corps' proccess. Data
19 Analytical facility development numerical scoring and should not be changed at this late date. Changing the rules already presented is being re-evaluated to be consistent with the NEPA process and the
Framework factors of engagement now makes it impossible to bridge back to data already presented direction of the PDT. The site selection evaluation will include an evaluation based on
and published. WWP have been inconsistent in this process - using numerical social parameters.
scoring to determine that the best sites were on PE land, and then when they didn't Consideration of issues related to environmental justice will be discussed at PDT Meeting
get the results they wanted, arguing against the very scoring system they devised. No. 5.
What they don't like is having to include scoring on issues such as environmental
justice, which they didn't include in the beginning. Also see response to Comment 11 part (5) a.
New Hill community's recommended wastewater management option is:
- Cary expand their existing facilities to support Cary, Morrisville, and Wake County
portion of RTP South The option of each town acting independently is included in the Wastewater Management
Apex expand their existing facilities to support Apex Options narrative. Combining the towns' treated effluent would result in more pipelines
Effluent wastewater from Cary, Apex and Holly Springs facilities would be being installed to convey raw wastewater and treated effluent around the service area. This
combined at a central regional facility in New Hill and sent to Cape Fear River below will result in higher cost and increased environmental impacts from the additional pipelines.
Buckhorn Dam
This would be a sub-option of Option 2 (Regional System).
Wastewater Benefits include:
20 Management Provides a regional solution per DENR recommendation
Options Eliminates the environmental justice issue in New Hill
Eliminates environmental risk when a wastewater spill occurs
Pumping and maintenance costs of treated wastewater are far less than those for
raw sewage (see previous response)
Grey water can be used in the towns where generated
Reduces economic impact to New Hill community
This sub-option of Option 2 is especially relevant in light of the reduction in WWP
future daily discharge capabilities after Chatham County obtains a significant portion
of the current WWP 38 mgd capacity approved by DENR.
I would like to see the PDT meetings extended if necessary so key elements of the PDT Meetings will be extended if necessary to allow sufficient discussions. The purpose of
21 General NEPA process can have sufficient quality discussions. My concern is that each key the meetings is to receive input from PDT members, and concerns and issues will be
Comment document will be glossed over and the process will continue without serious addressed.
consideration given to New Hill community concerns and issues.
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NEPA EIS
Comment Summary - Comments on Materials Presented at August 23, 2007 PDT Meeting No. 4
SEE SK
City of Durham's permitted wastewater treament capacity is 40 mgd (2 plants). Wastewater
I asked "What is the City of Durham's permitted discharge limits, current flow, and treated at City's 2 plants in fiscal year 2006-2007 was 19.34 mgd (average day flow).
Comment excess capacity". Response gave me (1) value - permitted capacity. Response
Summaryfrom Number 3, Option 4, then went on to talk about total WVVP capacity requirements and how City of
'
' Durham County's permitted wastewater treatment capacity is 12 mgd. In fiscal year 2006
22
7/26/07 PDT
item 2 Durham and Durham County couldn
t handle it. I didn
t ask if they could. Response the plant treated 4.07 mgd (average day flow).

Meeting Materials also states these facilities don't have excess capacity for "other town's service
"
'
"
areas.
I
d like to see a document that states these facilities would not sell
any Wastewater treatment plants are not built with excess capacity - they are sized based on
capacity" to another town. planned development of service areas. The City and County do not have excess capacity
available.
Comment I asked "Let Durham continue to handle South RTP wastewater treatment. Currently, the Town of Cary contracts with Durham County, not the City of Durham, to
Summaryfrom Number 4, Option 4, Reduces costs and capacity requirements of new WRF." Response mentions handle the wastewater flow from RTP South. It is handled at Durham County's Triangle
23 7/26/07 PDT item 1 agreement Cary has with Durham County. I was asking about City of Durham, not WWTP. In order for the City of Durham to handle wastewater flows, a new pipe would need
'
Meeting Materials Durham County. Is the response still the same? to be constructed to convey wastewater to the City
s plants (South Durham WRF or North
Durham WRF). Map of treatment plant locations will be available at PDT meeting.
The primary reason that this option is infeasible is that it would require an NPDES permit for
additional flow to be discharged into Jordan Lake. It is beyond the limits of technology to
treat this additional wastewater flow to levels that would be allowed for Jordan Lake.
Comment I stated "Factors listed are inherent in any option that looks at regional solutions and Nutrient loadings in the lake are already overallocated.
24 Summaryfrom Number 4, Option 4, should not be used to discount any option." Response states that options must It is true that there will be some institutional complexity associated with interlocal
7/26/07 PDT item 2 meet Purpose and Need. What does Purpose and Need have to do with a agreements for any regional solution. However, the point was that contracting with the City
Meeting Materials particular factor (i.e. new interlocal agreement) being used to eliminate an option? of Durham to expand the South Durham WRF will add even more institutional complexity,
because rather than having a single interlocal agreement among the 4 Partners, this would
introduce another level of complexity for the Partners to create a new interlocal agreement
with the City of Durham.
Comment According to the Durham Comprehensive Plan, maximum month flows at the South
25 Summaryfrom Number 4, Option 4, 1 asked "What is the date South Durham WRF expects to hit capacity?" Is the 18 Durham WRF will reach 18 mgd in 2025. This amount will be 90 percent of the plant's
7/26/07 PDT item 3 mgd their max capacity or is this how much they will be discharging by 2025? design capacity, so an expansion or upgrade will need to be considered to treat additional
Meeting Materials flows.
Comment I asked for "inflow rates". Response says they are not being provided because
26 Summary from Number 5, Option 4, these capacities are small in comparison with the Partners wastewater capacity See response to Comment 22 for amount of wastewater treated at the plants in fiscal year
7/26/07 PDT item 1a needs. Not acceptable answer. Shouldn't assume why question was asked. 2006.
Meeting Materials
Comment The Western Wake Partners' Phase 1 flow requirements exceed the total capacity of
Summaryfrom Number 5, Option 4, Harnett County's wastewater treatment capacity. While Harnett County could be contracted
27
7/26/07 PDT
item 1 b, c, d, a Need more discussion on this for feasibility. to expand to meet these needs, this was not evaluated because of extensive conveyance
Meeting Materials impacts for raw wastewater and impacts to Jordan lake operations. Because these impacts
would be greater, this is not a feasible alternative.
* This table does not include all attachments/tables that were included in original comments. Refer to comment letters/emails for attachments and tables.
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