20061203 Ver 1_Fax_20060707

State of North Carolina
Dept. of Environ. & Nat. Res.
Division of Water Resources
Mike Easley, Governor
William G. Ross, Jr., Secretary
John N. Morris, Director
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1611 Mail Service Center Raleigh, NC 27699-1611
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NCDENR
North Carolina Departrnent of Environment and
Division of Water Resources
Michael F. Easley, Governor
July 7, 2006
Mr. Monte Matthews
Raleigh Regulatory Field Office
U.S. Army Corps of Engineers
6508 Falls of the Neuse Road, Suite 920
Raleigh NC 27615
Subject: Western Wake Regional Wastewater Management Facilities
Corps Action ID No. 200620159
Mr. Matthews:
William G. Ross Jr., Secretary
John Morris, Director
The Division of Water Resources (DWR) submits the following comments following review of the
application for Section 404 and 401 permits under the federal Clean Water Act by the Western Wake
Regional Wastewater Management Facilities Project Partners ("applicant") for the construction and
operation of the Western Wake Water Reclamation Facility (WRF), pumping stations, pipelines and
other associated appurtenances ("project°).
General Comments
The permit application does not provide enough detailed information on which DWR can make a
proper review of project impacts to water resources. Although the permit application is based in part
on the state's Environmental Impact Statement (EIS), the application should contain sufficiently
detailed information to evaluate the proposed final design project plans and supporting data not
available at issuance of the final EIS.
DWR requested additional information concerning various aspects of the project during the drafting of
the EIS. However, the applicant stated that requests for additional information could not be fulfilled
until final design. The lack of additional information did not allow a complete consideration of
alternatives and the associated impacts. DWR expects that additional project information,
alternatives and associated impacts will be provided and evaluated during this permitting review.
The application states that the N.C. Division of Water Quality (NCDWQ) must act on the request for
certification within sixty days or action by NCDWQ will be deemed waived. The application also says
that a complete jurisdictional determination will be completed by the USACE on project areas outside
the WRF site. The application also states that construction methodologies will be finalized in the final
design stage of the project. Given the ambiguities contained within the application, DWR questions
whether NCDWQ can make a determination within sixty days.
1611 Mail Service Center, Raleigh, North Carolina 27699-1611 One
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Natural Resources

Mr. Monte Matthews, USACE July 7, 2006
Western Wake WRF 4041401 Permit Application
Environmental Impacts
DWR has concerns regarding the environmental impacts that will result from the proposed project.
Secondary and cumulative impacts are addressed for the planning areas of the Towns of Apex, Cary,
Holly Springs, and Morrisville in their respective Secondary and Cumulative Impacts Master Mitigation
Plan. The Department of Environment and Natural Resources (DENR) approved the plans, and
DENR signed a memorandum of agreement with each town concerning their plan's use.
The draft EIS states: "The discharge to the Cape Fear River is outside the Planning Areas of the
Towns addressed in the SCI Master Mitigation Plans. However, the WRF will not serve any
populations outside the Planning Areas; thus, the infrastructure proposed as part of this project will
not have secondary impacts outside the areas described in the SCI Master Mitigation Pions."
Environmental impacts, however, are not necessarily limited to artificial boundaries such as municipal
planning areas. DWR requests that the USACE evaluate the proposed final design project for
environmental impacts that may extend beyond municipal planning areas.
The applicant stated in the draft EIS that "[tJhere will be cumulative direct impacts on the Cape Fear
River. These cumulative direct impacts were evaluated through the use of the QUAL2E model."
However, the QUAL2E model is not suitable for determining the environmental impacts to aquatic
biota associated with the physical presence of the discharge pipe and diffuser, flow diversion during
low-flow periods and dewatering of aquatic habitat directly downstream of the structure during low
flow.
Cape Fear River discharge
DWR requests that the USACE consider the environmental impacts associated with the proposed
instream effluent diffuser as well as a bankside discharge.
The applicant stated during the drafting of the EIS that "[f]urther discussion with NCDWQ has
indicated that they are open to a bank discharge, and during final design it well be evaluated with a
mixing model along with the diffuser." The draft EIS (Appendix 8: Preliminary Engineering Report,
Technical Memorandum 28) states that "it is anticipated that the outfall will take the form of a mid-
stream diffuser, rather than a bankside discharge, because the diffuser results in more mixing."
However, the document goes on to state that "[t]he effluent is to be highly treated, so that it meets all
water quality criteria for the river at the end of the pipe, without the need for a mixing zone for any
dilution."
The draft EIS lacked additional information requested that could be used to evaluate the impacts of
the instream pipeline and diffuser. The applicant proposed to provide the requested information
during final design. During drafting of the EIS, the process was approaching the midpoint of final
design. Additional information should be available and should be provided in the application.
The draft EIS did not provide a refined stage-discharge-return period analysis mentioned in Appendix
B: Preliminary Engineering Report, Technical Memorandum 29 and requested by DWR. The draft
EIS did not adequately address DWR's request for detailed channel profile information for the line of
the discharge pipe, the diffuser and the southern passage channel. This information would help
resource agencies determine the extent and frequency of low flows and associated water depths,
how these depths compare with the height of the pipeline in the river, and evaluate the impacts of the
diffuser on aquatic habitat, fish passage and navigability.
JUL-7-2006 FRI 15:40 TEL:[phone] NAME:DWQ-WETLANDS P. 3

Mr. Monte Matthews, USACE
Western Wake WRF 404/401 Permit Application
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WRF Site
In light of the recent system failure within the Town of Cary's sewage collection network and the
subsequent discharge of 7.9 million gallons of raw sewage into Swift Creek and the associated
closing of Lakes Wheeler and Benson to pubic use, the Corps should consider the impacts of system
failures. The Corps should also consider the alternative of resiting the WRF to Site 8, the location of
the Beaver Creek Pump Station. Site 8 was the second preferred altemative and would convert
23,560 feet of raw sewage pipeline to treated effluent pipeline. This resiting would reduce the
impacts associated with potential system failure.
Thank you for the opportunity to comment on this permit application. We look forward to reviewing
the additional information. If we can provide further assistance, please contact our office at (919}
733-4064.
~fi~Cerely,
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Fred R. Tarver, III ~:
cc: Cyndi Karoly, DWQ
Melba McGee, OLIA
ec: Shari Bryant, WRC
Dale Suiter, USFWS
Sarah McRae, NHP
JUL-7-2806 FRI 15:41 TEL:[phone] NAME:DWQ-WETLANDS P. 4