20061203 Ver 2_Western Wake Comment Summary on 053107 PDT Materials (6-28-07)_20070628

Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Purpose and Need Statement and Plan of Study Document

Melba McGee - NC DENR
Purpose and I find the purpose and need statement consistent with the conditions
1 Need issued by the Environmental Management Commission, the No response required.
department and the previous SEPA DEIS.
The department reiterates that the proposed project must be
operational and discharge effluent to the Cape Fear River by January
2 Plan of Study 1, 2011. The department remains committed to the schedule No response required.
established by the Environmental Management Commission in the
July 12, 2001 Interbasin Transfer Certificate.
The word SEPA should be dropped from future materials distributed to

3 General the NEPA EIS Project Delivery Team. When a document is approved
Concur.
Comment through the NEPA process, it is in compliance with the SEPA review
process.
Paul Barth - New Hill Community Association
Wake County's Urban Service Areas are areas that are expected to be
absorbed by municipalities and will not be under County planning
jurisdiction in the future. Short Range Urban Service Area (SRUSA) is
land that is expected to become part of a municipality within the next 10
years, and Long Range Urban Service Area (LRUSA) is land that is
expected to become part of a municipality more than 10 years into the
future. Eventually, the County's planning jurisdiction will include only non-
First sentence - need to clearly define "service area". Does "service urban areas (such as the water supply watersheds).
area" include Long Range Urban Service Area (LRUSA) as Apex
stated at the meeting? I don't believe it should be included in "service Extraterritorial jurisdiction (ETJ) is area outside of a Town's current
area". The maps showing New Hill as being part of Apex's "service corporate limits that is likely to become part of the Town's corporate limits
area" are not correct. New Hill is not projected to be included in within the next 10 years and is part of a municipal planning area. Towns
4 Purpose and Apex's municipality due to a Wake County 5 mile exclusion zone have zoning and regulatory authority in their ETJs. Wake County
Need around Shearon Harris Nuclear Plant. This means New Hill will not be reviews Towns' requests to extend their ETJs. Water and sewer service
annexed into Apex in foreseeable future. Wake County does not want is extended into new areas through the municipal annexation process.
development or growth within this 5 mile exclusion area due to
evacuation concerns should an emergency occurs at Shearon Harris The WRF Service Area is the Partners' planned utility service area. This
Nuclear Plant. Road system could not handle an emergency service area includes areas that are planned to receive utility service in
evacuation with a large population. the future. The Partners' utility service area is planned through 2030 and
is expected to include the New Hill area by 2030.
Wake County's Southwest Area Land Use Plan recommends that
development within the 5-mile radius of the Harris Nuclear Plant be put
on hold until the Wake County Commissioners adopt a plan for this area
that addresses the concerns listed in the comment. However, the area is
still included in the LRUSA and is expected to become part of a
municipality at some point in the future.
These factors are defined in later sections of the Plan of Study (Direct
Plan of Study,
In the first paragraph, would like to see which "factors" will be Environmental Impacts, Secondary and Cumulative Environmental
5 Alternative considered
. Impacts, Environmental Justice, Endangered Species, Project Costs). In
Analysis addition, these factors will be discussed during future PDT meetings, and
participants will have opportunity to provide input on defining them.

Plan of Study, In alternative number four (4) - "Independent Systems", does this
No, the Independent System wastewater management option is defined
6 Alternative mean each town treating their own wastewater within their municipality
" as each town acting independently to address their wastewater capacity
Analysis and then discharging treated wastewater into one of the
Alternative
" needs. This option includes no regional collaboration among the towns.
Discharge Locations
?
Plan of Study, In alternative eight (8) - "Water Reuse System", will this include The PDT will help define what will be included in the evaluation of each of
7 Alternative calculating expected revenue from sale of potable water thereby the eight wastewater management options.
Analysis reducing total project cost?
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Purpose and Need Statement and Plan of Study Document
lm
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Plan of Study, :
::
Are impacts to private wells, ponds, streams/creeks included within the mmm:
8 Direct areas mentioned? Private wells are critical to every home owner in Yes, impacts to these resources will be included in the EIS.
Environmental New Hill area. Ponds and streams/ creeks are vital for irrigation on
Impacts farms, water for livestock and recreational fishing.
The Secondary and Cumulative Impact Master Mitigation Plans address
Plan of Study, Area covered needs to include the New Hill community. In this case, impacts within each Town's planning area, which includes the urban
Secondary and probably Apex states that New Hill is in their LRUSA. Current plans service area (USA), extraterritorial jurisdiction (ETJ), and the Land Use
9 Cumulative from each partner town only cover secondary and cumulative impacts Plan boundary. The Plans also include areas that are subject to
Environmental within their municipalities. This is a point we brought to the attention of boundary and urban service area agreements with other Towns. The
'
Impacts DENR but was not satisfactorily addressed. New Hill area is included in Apex
s Master Mitigation Plan. Additional
secondary and cumulative impacts will be addressed in the EIS as
recommended by the US Army Corps of Engineers.
Need to include data provided by WWP at the request of DENR.
"
" The PDT will help define what data should be used for evaluations.

Plan of Study, Simply using
US Census Bureau data and GIS mapping
in not
Sentence 2 under the heading "Environmental Justice" will be revised to
10 Environmental acceptable. Initial data provided by VWVP only using this type of data state that "US Census Bureau data, GIS mapping, and other available
Justice was determined by New Hill and DENR to be inaccurate, incomplete, data will be used to determine the existence of all minority and low-
and distorted. Also, similar data needs to be developed for each of the
income populations..."
alternative sites. This too was provided by WWP to DENR.
In the USACE NEPA process, it is the responsibility of the applicant to
Plan of Study, Should change phrase "the preferred alternative" to "each alternative". identify its preferred alternative. The Biological Assessment is required
11 Endangered Each site needs to be evaluated. Until each site is evaluated, you
'
" by the US Fish and Wildlife Service and must be completed before the
Species won
t have the information necessary to arrive at a
preferred
" USACE can issue a Section 404 permit. The EIS will include a
alternative
. discussion of all resources, including endangered species, for the
reasonable range of alternatives evaluated.
Each alternative should have supporting data as to how numbers were
derived. An alternative that might have an increase cost might also
have cost reductions which need to be proved. For example, one

12 Plan of Study, alternative might cost $3 million dollars more due to length of pipe line
Concur -project costs will include supporting data.
Project Costs or pumping station capacity but there might be cost savings for an
alternative such as reduce land cost, elimination of crossing US 1 /
railroad tracks, or potential mitigation plan which might reduce or
eliminate any cost increase.
Also, each alternative should have expected rate increase per
Plan of Study, customer based on a higher cost. For example, if an alternative costs A User Charges analysis for the preferred alternative will be included in
13 Project Costs $23 million dollars more vs. preferred site, need to know what impact
"
" the EIS. The PDT will have opportunity to define further evaluations
this has on total customer base -
service area
. A per customer needed.
impact might be less than one dollar.
Commissioner George Lucier, Commissioner Patrick Barnes, and William Sommers - Chatham County
Chatham County does have the potential of direct environmental
impact stemming from the fact that approximately 8.5 miles of the
effluent force main will pace through Chatham County on its way to the
Cape Fear River just below the Buckhorn Dam.... We believe this may
well have a direct environmental impact on the area in a variety of
ways: existing underground drainage courses, trees, shrubs and other
land-needed growth, all of which will then be subject to additional
disturbance by the Phase II parallel force main.
Plan of Study,
Direct The EIS will address impacts associated with the effluent force main,
14
Environmental However, there is currently very little information on the details of including factors listed in the comment. The Project Partners have
Impacts these force mains and we are, therefore, in a difficult position to committed to providing this information to Chatham County.
assess the direct environmental impact that the two force mains will
have in the project area where the mains are to be laid. We therefore
request that US ACE view this very diligently and allow, as well,
representatives of Chatham County, including our engineering and
environmental staff, to discuss these two construction phases with the
Western Wake Waste Water Project's experts in order to get a much
clearer view of the potentially direct environmental impacts that may
affect Chatham County.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Purpose and Need Statement and Plan of Study Document
IN
...the NC Department of Energy and Natural Resources (NCDENR)
and the Environmental Management Commission (EMC) have made a
conscious policy decision to give waste water allocations to Western
Wake Waste Water treatment and to put Chatham County on the shelf
of " spray and drip" waste water disposal, particularly in servicing large
scale developments in Chatham. This is gradually having a negative,
cumulative affect on the County, so much so, that it is one of the
important reasons that the Chatham Board of Commissioners recently Growth will be addressed by the Secondary and Cumulative
Plan of Study, unanimously passed a one year "moratorium" on large scale Environmental Impact section of the EIS. The Project Partners have
Secondary and development in that we might be endangering the environment with a commissioned a water quality assessment modeling effort to determine
15 Cumulative plethora of uncoordinated waste water and storm water systems the overall assimilative capacity of the Cape Fear River. The NC Division
Environmental damaging the landscape. of Water Quality's QUAL2E water quality assessment model for the Cape
Impacts Fear River is being revised to evaluate a number of potential discharge
'
...the Western Wake project may promote large-scale annexations for scenarios to determine whether the Project Partners
project will exclude
residential and commercial development along Chatham's eastern other future discharges.
boarder. And these, in turn, will have a substantial, if secondary,
environmental impact on Chatham's future.
We ask that the US ACE put this issue at the top of its agenda in
determining the details of the EIS as they affect
Chatham County vis a vis the Western Wake Waste Water
Treatment project.
Another secondary environmental impact of the Western Wake WW
project concerns the spreading of "digested sludge (biosolids)" on
Chatham County lands from Apex's Middle Creek WWTP, Cary's
North and South WFRs. and Holly Springs WWTP. ....the potential
acreage now being used for biosolid spread in Chatham County could
jump to 1,933 acres, nearly tripling the current "spread" acres in use....
This is a potentially alarming increase in the spreading of digested
Plan of Study, sludge. While DENR - and the US EPA - have endorsed the use of Impacts from disposal of biosolids generated by the project will be
Secondary and biosolid application, many practitioners and scientist are not convinced
"
" addressed in the EIS. In addition, the NC Division of Water Quality
16 Cumulative of their
beneficial
attributes...... requires that all applications for Authorization to Construct a wastewater
Environmental treatment facility include a sludge management plan. The Project
Impacts ....the Orange County Board of Commissioners recently contracted Partners are currently planning to dispose of biosolids from the Western
with the UNC Department of Public Health to study complaints by Wake Regional WRF at a composting facility.
Orange county residents who may have been affected by biosolid
spreading via OWASA....
We believe that US ACE should review this situation carefully with
DENR and DWQ and wait for the results of the UNC Study before they
make a decision regarding the potential problems that may be
associated with the expansion of biosolids spreading caused by
implementation of the Western Wake WWT Project.
Shari Bryant - NC Wildlife Resources Commission
Purpose and
17 Need,
Regulatory In the second sentence "Basis" should be changed to "Basin". Concur; revision will be made.
Mandate No. 1
Buzz Bryson - Progress Energy
In the first sentence, "The proposed project consists of ...", I'd
suggest adding "and associated infrastructure (access roads, electric/
Purpose and communications lines, etc)". All that might be implied, but if roads or
'
18 Need electric lines don
t follow same right-of-way as sewer lines, footprint Concur - this phrase will be added.
would be enlarged. And if pumping stations have independent back-
up power, I'd presume those are diesel generators, and thus will have
fuel tanks.
In the next sentence, I'd suggest changing "... provide wastewater
Purpose and service for planned growth and development ..." to "provide
" The sentence will be revised to state that the purpose of the project is to
"
19 Need wastewater service for anticipated growth
. Probably a subtle and provide planned wastewater service for anticipated growth and
insignificant difference, but I'm not sure that growth and development development..."
are ever "planned" very well.
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Western Wake Regional Wastewater Management Facilities
NEPA EIS
Comment Summary - Purpose and Need Statement and Plan of Study Document
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20
Purpose and :
::
On the next-to-last line in paragraph on reg mandate no. 1, I'd insert mmm:
Will delete references to "draft" in references to EIS.
Need "draft" before environmental impact statement.
21 Plan of Study Might want to add a heading/paragraph to include addressing Section Historic and archaeological resources are listed under heading "Direct
"
106 of NHPA requirements. Or adding in intro sentence. Environmental Impacts.
These impacts will be included in the EIS.
The purpose of using EEP's schedule of fees for estimating mitigation
In the last sentence under the "Project Costs" paragraph, mitigation costs is to generally compare costs of alternatives. At this level of
22 Plan of Study under EEP will be required only for permanent impacts, correct? comparison, permanent and temporary impacts are not differentiated.
Assuming temporary impacts are restored. Impacts will be defined in more detail for mitigation purposes during
preparation of a Section 404 permit application.
NC DENR DWQ Construction Grants and Loans Section
Planned Growth and Development: Since this is the first part of the
three-pronged P&N, consider adding a separate subsection. The P&N
23 Purpose and related to planned growth and development should be stated clearly Concur - a subsection for growth and development will be added, and a
Need and then backed up with a concise summary of the flow projections for summary of growth projections will be added.
the Western Wake Partners (the Partners). This information should be
written so that the public will be able to understand it.
Consider changing "fog" to "In" in the title of this mandate.
Additionally, this section of the Purpose and Need should be expanded
to include the following verbiage, which is consistent with the Finding
Purpose and of No Significant Impact and Environmental Assessment for the Town
Need, of Holly Springs, dated February 16, 2007:

24 Regulatory
Mandate No. 2 - "The NC Division of Water Quality has stated that any Authorizations
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Concur.
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Enrichment for expansion of the Utley Creek WWTP either include or will include a

Harris Lake condition stating that the treated effluent must be removed from Utley
Creek by the date established in the Certificate Authorizing the Towns
of Cary, Apex, and Morrisville and Wake County to Increase Their
Transfer of Water from the Haw River basin to the Neuse River basin
under the Provisions of G.S. 143-215.221."
General Comments: To keep the alternatives analysis process as
simple as possible, it would be helpful to describe the project as Concur - headings will be revised. Effluent pump station is inherent in
containing five different components: (1) wastewater management WRF site selection process, but alternative effluent pipeline routes are
Plan of Study, alternatives, (2) alternative discharge locations, (3) the WWWRF site, possible. Effluent pump station will be moved to WRF section, and raw
25 Alternatives (4) raw wastewater pumping and conveyance facilities, and (5) outfall wastewater and effluent force main will be described under one
Analysis configurations. Using consistent terminology for each project "Alternative Pumping and Conveyance Facilities" heading. Discussion
component throughout the document and PDT meetings will keep the will be added to clarify that wastewater management option and
reader from getting confused. It is also suggested that "Alternative discharge location will be evaluated first, the WRF site and pipelines will
Effluent Pumping and Conveyance" be eliminated from the Scope of be evaluated next, and the outfall configuration will be evaluated last.
Anaylsis, since it is inherent in the WRF site selection section.
Plan of Study
Direct, Sec., and It would be good to indicate what the scope would be for each
26
Cumulative Env. category where impacts will occur. (See table provided in comment Concur - table will be reviewed with PDT.

Impacts letter.)
This table summarizes and paraphrases some lengthy comments. Refer to comment letters/emails for complete text of comments.
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