NC0081281_ENVIRONMENTAL ASSESSMENT_20080324

NPDES DOCUWENT SCANNINO COVER :CMEET
NPDES Permit: NC0081821
Richmond County WTP
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Staff Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Permit
History
Document Date: March 24, 2008
This document is priaited on reuse paper-igaiore any
content oa the reverse side

W AT§ Michael F.Easley,Governor
\� 61 William G.Ross Jr.,Secretary
rNorth Carolina Department of Environment and Natural Resources
0 Coleen H.Sullins,Director
Division of Water Quality
March 24,2008
MEMORANDUM
TO: Steven R. Gandy, Ph.D.,P.E.
Municipal Engineering Services Company,P.A.
THRU: Dianne Reid, Supervisor
Basinwide Planning Unit and SEPA Program
FROM; Hannah Stallings 1,
Division of Water Quality
SUBJECT: Richmond County
Water Treatment Plant—4.6 MGD Upgrade
DENR#1380,DWQ#13767
This document is in need of thorough revision. Not only does it notmeet the requirements of the Department of
Administration's Envi.roninental Assessment Guidelines(referenced the Division of Environmental Health's
(DEH)EA Factsheet
(http•//www.deh.elu•.state.nc.us/PWS/srfIFactsheets/Factsheet EA procedures for Applicants v2.0.doc)),it is
internally inconsistent and not well organized. Also, comments that we(The Division of Water Quality (DWQ))
submitted on this document on December 07,2007,were not addressed. DWQ requests that you rewrite this
document to comply with DEH's guidance and in accordance with the following comments, and that you provide
an itemized response to these comments to aid in our review:
1. Please amend the title page to reflect that the Division of Environmental Health is the lead DENR agency for
this project.
2. DWQ's previous comments on this project were not included in Appendix H-10. Please include any and all
correspondence that has been submitted on this project in an appendix.
3. The previous EA documented need for only a 4.0 MGD upgrade. What has called for an increase in the
requested capacity to 4.6 MGD? (Unanswered comment from December 07, 2007.)
4. Page 3—Please explain how this project will remedy any "poor ground water quality in currently non-
serviced areas" since"the distribution system will not be expanded"in the currently proposed project
according to the Secondary Impact Statement in Appendix H-9.
5. Page 3 states "The plant expansion is in essence necessitated by peak usages by its largest recipients:
Progress Energy, Burlington Industries, and the City of Rockingham, where demand is dramatically higher
during hot weather and/or drought conditions."
a. Please explain what is meant by "in essence."
b. Page 1 states that"The direct purpose of the capacity expansion is to accommodate industries, such as
Viking Pools,LLC and Trinity Chemicals, which recently moved to the area or expanded their operations
NorthCarolina
�atcrr�r!!�
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 Phone[phone] Customer Service '
Internet: www.ncwaterguality.org Location: 512 N.Salisbury St. Raleigh,NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

Mr. Gandy
Page 2
3/24/2008
in Richmond County, respectively"and page 22 states that"The expansion is needed due to the plant's
operation at full capacity for periods during the suminer months of 2007 and even losing water levels
within elevated tanks during these stressful periods while operating at full capacity." Please clarify the
need for this project.
6. The EA does not contain a clear purpose for the proposed project. Please amend the text so it is easier to
discern whether the project's purpose simply to provide capacity for existing industry(while allowing
modestly for their,expansion) or whether it also includes planned excess capacity for future service area
expansions.
7. Page 10 states that"water currently discharged can be recycled to the settled water plant, and then be used to
create non-potable cooling water for the Progress Energy Plant in Richmond County. This is being
incorporated into the design of the upgrade."
a. DWQ requests that the County submit a letter from Progress Energy stating that they are aware of these
plans and agree to accept a specific volume of wastewater from the facility.
b. Please provide a plant schematic/flow diagram detailing this proposed disposal option.
8. Page 10 states "The NPDES permit will remain in effect until its expiration to provide redundancy for plant
operation in the event of a line failure or similar emergency,but will be used only as a backup to the proposed
reuse plan." Please clarify this statement. Is it Richmond County's intent to request rescission of the NPDES
permit upon completion of this expansion, or does the facility intend to retain the permit as a backup disposal
option? If a surface water discharge is to be retained as a backup disposal option for an additional volume of
wastewater generated as a result of this expansion,then Richmond County will need to modify its NPDES
permit to cover the additional waste flow. As stated in our November 2007 comments, any increase in
wastewater will require the applicant to submit an Engineering Alternatives Analysis to NPDES staff. The
current NPDES permit does not allow the discharge of any wastewater in excess of the facility's current
design capacity.
9. Pages 10 and 16—Please correct that Tony Chen is neither the Department head for nor an employee with the
Division of Water Quality.
10. The document does not mention NPDES permit NCO081281 (currently held by the facility)nor the increase
in wastewater(filter backwash)expected as a result of the proposed expansion. There is also no discussion of
the Engineering Alternatives Analysis (EAA)or the permit modification that will be required by this
proposed expansion. Although the existing permit does not contain a flow limit, any change in wastewater
characteristics at this facility will require a permit modification. If any change in wastewater treatment units
is proposed,this project will also need to apply for an Authorization to Construct permit.
Please find attached the EAA guidance document. NPDES staff typically prefers that the EAA be wrapped
into the EA document to avoid potential unforeseen complications; however the EAA may be submitted at a
later time,if desired. (Unresolved comment from December 07, 2007.)
11. This document does not correctly address secondary and cumulative impacts.
Secondary impacts are indirect impacts caused by and resulting from a specific activity that occur-later in time
or further removed in distance than direct impacts,but are reasonably foreseeable. Indirect impacts may
include growth inducing effects and other effects related to induced changes in the pattern of land use,
population density or growth rate, and related effects on air and water and other natural systems,including
ecosystems.
Cumulative impacts are environmental impacts resulting from:incremeritall"effects of In.-activity:when added

Mr. Gandy
Page 3
3/24/2008
to other past, present, and reasonably foreseeable future activities regardless of what entities undertake such
other actions. Cumulative impacts are the reasonably foreseeable impacts from individually minor but
collectively significant activities.
[15A NCAC 01C .0103j
Page 12 states "It should be noted that water supplied to the towns was at a level during the summer months
that extended or surpassed the water treatment plant's capacity to produce. The ability to meet these needs in
following year(s) is, therefore, not expected to culminate in significant secondary and cumulative effects
detrimental to the environment or community."
a. Continued pumping of a non-permitted volume from the Lake is likely to result in damage to the
environment.
b. This is an incorrect use of the terms secondary impact and cumulative impact. Please review the
definitions of these terms and correct the discussion of secondary and cumulative impacts in the
document. (Please contact DEH directly to address this issue.)
Please review the North Carolina Wildlife Resources Commission's Guidance Memorandum to Address
and Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and Water
Quality (attached). This document provides definitions and examples of SCIs and also cites examples of
mitigative measures that can lessen the SCIs of projects.
Amend the above statements appropriately.
12. Page 12—As mentioned previously, references to providing areas that currently relying on potable wells as
being a benefit of this project should be removed since this project does not involve an expansion of the
distribution system.
13. The discussion of project effects on land use on pages 14 and 15 does not address land use impacts. Please
amend this discussion using the Environmental Assessment Guidelines.
14. Please amend the discussion of the project's impact on water resources to include a discussion of how it will
effect water quality (please see the Environmental Assessment Guidelines).
15. The EA does not contain a lengthy discussion of how "the plant's expanded capacity will allow sufficient fire
flow for industry and buffer capacity for distribution system extension when the County chooses to expand
the system" as indicated on page 22. Please add such a discussion to the document, if necessary, for project
justification. Also, please explain what is meant by "sufficient fire flow for industry."
16. Richmond County's current NPDES permit expires on February 28, 2009. At that time, the facility will
receive additional monitoring requirements in accordance with the Division's 2007 strategy for permitting
conventional water treatment plants. That strategy recommends a flow limit and whole effluent toxicity
monitoring, along with several other requirements. A copy of that document is attached.
Please contact me at 733-5083, ext. 555. if I can be of any help in resolving these issues.
Thank you.
Attachments
Cc: B.K. Jones—Richmond County Public Works Department
Jim McRight— DEH
Belinda Henson — FRO
Toya Fields—Western NPDES Program

Engineering Alternatives Analysis (EAA) Guidance Document
North Carolina Division of Water Quality/ NPDES Unit
NOTE: The N.C. Division of Water Quality (DWQ) will not accept an NPDES application for a new or
expanding wastewater treatment plant. discharge unless all. the required application requirements are
submitted. A complete NPDES application will include the following items:
NPDES Application Form (in triplicate)
Application Fee
Engineering Alternatives Analysis (in triplicate)
Local Government Review Form (non-municipals only)
Failure to submit all of the required information will result in return of the incomplete package. If you have
any questions about these requirements, contact the NPDES Unit staff at 919-733-5083. Application forms,
applicable fees, and guidance documents are available on the NPDES website at
htip://h2o.enr.state.nc.us/NPDES. Completed applications should be mailed to:
NCDENR/DWQ/NPDES Unit,1617 Mail Service Center,Raleigh,NC 27699-1617.
Background
The NPDES permit program was enacted in 1972 as part of the Clean Water Act. The original goal of the program
.was to eliminate all point source discharges to surface waters by 1985. Although this goal was not achieved, the
NPDES program continues to strive toward it. In that light, an Engineering Alternatives Analysis (EAA) is
required with any NPDES application for'a new or expanding wastewater treatment plant discharge, in
accordance with 15A NCAC 2H.0105(c)(2). In order for an.NPDES application to be approved, the EAA must
provide complete justification for a direct discharge to surface water alternative,and demonstrate that direct discharge
is the most environmentally sound alternative selected from all reasonably cost-effective options [per 15A NCAC
2H.0105(c)(2)].
The purpose of this EAA Guidance Document is to provide guidance to the regulated community for the evaluation of
wastewater disposal alternatives. The impetus behind this comprehensive guidance was based on the following: 1) a
majority of new NPDES applications were being returned as incomplete due to inadequate EAA submissions; and 2) a
few recent court cases resulted in unfavorable pilings for the NPDES discharger due in part to inadequate EAAs.
DWQ most frequently returns EAAs as incomplete due to inadequate flow justification, inadequate alternatives
evaluations,and/or lack of documentation/references used to design and cost alternatives.
Please note that this guidance document is designed primarily for domestic wastewater discharges. For other proposed
discharges such as water treatment plant discharges from ion exchange and reverse osmosis units, some alternative.
disposal options may not be technologically feasible. `ylithin this guidance document,we have attempted to point out
where such technological limitations may exist. You are urged to review NPDES permitting guidance documents on
the NPDES website,which discuss some of the limited disposal options for some discharges.
Please note that if a proposed municipal expansion is subject to SEPA Environmental Assessment
(EA)/Environmental Impact Statement (EIS) requirements, the EAA requirements should be incorporated into the
SEPA document. In addition, the NPDES Unit cannot accept an application for anew/expanding NPDES discharge
until departmental review of the SEPA document is complete and a Finding of No Significant Impact (FONSI) has
been submitted to the State Clearinghouse for circulation.
The following step-by-step outline should be used for the preparation of all EAA submissions. If an EAA submission
lacks any of these basic elements, the NPDES application will be returned as incomplete.
EAA Guidance Document Version: June 23, 2005
Page 1 of 8

STEP 1. Determine if the proposed discharge will be allowed
Before beginning any engineering evaluation of alternatives, you must first determine if the proposed wastewater
discharge will be allowed. Otherwise, time and money may be spent needlessly for an EAA preparation that will
ultimately be rejected on the basis of existing water quality restrictions. There are several potential restrictions to a
wastewater discharge to surface waters,including:
■ Zero flow stream restrictions [15A NCAC 2B.0206(d)(2)] apply,to oxygen-consuming waste in zero-flow
streams. In order to determine streamflow at the proposed discharge location, contact the' U.S.
Geological Survey at 919-571-4000.
■ Receiving stream classification restrictions [e.g., ORW,WS, SA,NSW, and HQ class waters have various
discharge restrictions or require stricter treatment standards]. Stream classifications are available on the
DWQ website and from the DWQ Standards & Classifications Unit at 919-733-5083, while wastewater
discharge restrictions for various stream classifications are presented in state regulations [ 15A NCAC
2B.0200].
■ Basinwide Water Quality Plans. These basin-specific plans list NPDES permitting strategies that may
limit wastewater discharges to particular streams within the basin due to lack,of stream assimilative
capacity, etc. Basin .plans are available on the DWQ website, or you may contact the DWQ'Basinwide
Planning Unit at 919-733-5083.
■ Impaired waters and TMDLs. Certain waterbodies listed as impaired on the,303(d) list and/or subject to
impending TMDLs may have wastewater discharge restrictions. The list of 303(d) impaired waters is
located on the DWQ website, or you may contact the DWQ Modeling/TMDL Unit at 919-733-5083.
■ Presence of Endangered Species. If endangered species are present in the proposed discharge location,
there may be wastewater discharge restrictions. Endangered species information may be included in the
Basinwide Water Quality Plan, or you may contact the U.S. Fish and Wildlife Service.(919-856-4520),
N.C. Wildlife Resources Commission (919-733-3633), or the N.C. Natural Heritage Program (9197733-
7701).
Municipal applicants.
As a public service, the NPDES Unit will evaluate whether a proposed municipal discharge is considered allowable.
The municipality needs to initiate this review by submitting a letter, request for Speculative Effluent Limits to the
NPDES Unit. If the proposed discharge appears to be allowable, the NPDES Unit will prepare speculative effluent
limits for a maximum of 2 flows and 2 discharge locations using water quality.models. The municipality can then use
the speculative limits to prepare preliminary engineering design and cost estimates for the direct discharge alternative
within the EAA. In limited instances where complex water quality models are necessary to develop speculative limits
and determine potential water quality impacts, some municipalities have undertaken the modeling effort (with DWQ
review) in order to expedite this portion of the NPDES permit review process.
Non-municipal applicants.
Due to staff constraints, the NPDES Unit cannot prepare speculative limits for non-municipal applicants. Thus, it is
your responsibility to make your own determination as to whether the proposed discharge might be allowed by the
Division, by evaluating the water quality factors listed above. It is highly recommended that you discuss the proposed
discharge with the applicable DWQ Regional Office and/or NPDES Unit staff, who may be able to provide input on
the likelihood of a new/expanding discharge. As a first step, you must obtain streamflow, estimates for the proposed
discharge location to ensure that the receiving stream is not subject to zero flow restrictions. 'Low flow data
(specifically, the summer 7Q10 and 30Q2 flow statistics) can be obtained for a nominal fee from the U.S. Geological
Survey in Raleigh at 919-571-4000. The low flow data must be submitted with the EAA, and will be used by the permit
writer to develop permit limits. You must also verify that the proposed action (i.e., construction of a wastewater
treatment plant and its appurtenances) is consistent with local zoning and/or subdivision ordinances. You will need to
request the local government(s) to complete a Local Government Review Form (Attachment A), and include the
signed and notarized form with your NPDES application package.
EAA Guidance Document Version: June 23, 2605
Page 2 of 8

All applicants.
If you conclude that the proposed discharge will pass the "allowable discharge" criteria, then begin the E.AA
preparation by summarizing the following general information about the proposed project:
■ Provide a description of the proposed project. If the project will be constructed in phases; provide a
schedule for constructing each additional phase,and provide the projected flow per phase (see STEP 2).
■ Applicant name,mailing address,phone number,contact person
■ Facility name, address,county,phone number,contact person
■ EAA preparer's name,mailing address, phone number, contact person
STEP 2. Provide reasonable projections for population and flow
Residential Population Projections.
Facilities requesting an NPDES discharge permit for new or expanding domestic wastewater discharges must
document the population to be served within the service area over a 20-year planning period. The NC State
Demographics unit provides population data for each county and municipality and can be accessed on the Internet at
http://www.demog.state.nc.us. If 20-year population projections for specific areas are not available, a linear
extrapolation of population trends from the past decade should be used. Any deviation from a linear projection
method must be clearly justified. If population projections include future annexations,include a proposed annexation
schedule as well as any annexation requirements that must be met.
Municipal Flow Projections.
Justification of flow as well as a demonstration of need shall be provided. Mere speculation is not sufficient. Flow
projections should represent average anticipated flows, since permit flow limits are based on monthly averages.
Pealing factors used to design various components of the wastewater collection system (e.g., collector sewers,
interceptor sewers, pumping stations) should not be used in the justification of the average anticipated flow. For
municipal wastewater dischargers, flow must be justified using the Clean Water State Revolving Fund (CWSRF)
criteria available on the Internet at http://wvrw.nccgl.net/fap/cwsrf/201ggi.html. Exceptions to these flow criteria
may be approved on a case-by-case basis provided adequate justification is supplied.
■ Current Flow- Provide current flows including residential, commercial, industrial, and non-excessive
infiltration/inflow (I/I) based on actual flow data or water billing records. Current residential flow and
current commercial flow may be based on water billing records minus a 10% consumptive loss. Current
industrial flow may be based on dual metering to determine consumptive losses. Current non-excessive
I/I should also be determined in accordance with CWSRF criteria. If I/I is demonstrated to be above
CWSRF criteria, that infrastructure contributing to excessive I&I must either be repaired or replaced
prior to any request for flow expansion.
■ Future Residential Flow- Provide 20-pear residential flows based on projected residential growth.
Multiply the projected growth in residential population by 70 gallons per day per capita.
■ Future Commercial Flow- Provide 20-year commercial flows based on projected residential growth.
Multiply the projected growth in residential population by 15 gallons per day per capita.
■ Future Industrial Flow- Provide flow for future documented industrial flow. A nominal allowance for
future unplanned industrial expansions may be considered by the Division, provided the basis is clearly
justified and current land-use plans and local zoning allow for such industrial growth.
■ Future Non-excessive I/I- A nominal allowance for non-excessive I/I for new sewer lines may be
considered by the Division,provided the basis is clearly justified.
Non-Municipal Flow Projections.
Flow may be justified in accordance with 15A NCAC 2H .0219(1) for various activities (e.g., new subdivisions, new
schools, various commercial activities). For other proposed discharges (e.g., groundwater remediation, water
EAA Guidance Document Version: June 23, 2005
Page 3 of 8

treatment plant filter backwash, industial facilities), the flow projections will be based on engineering design
considerations and/or production projections rather than population projections.
STEP 3. Evaluate technologically feasible alternatives
Since a goal of the Clean Water Act is to minimize or eliminate point source discharges to surface waters, any
proposal for a new or expanding wastewater discharge must include evaluation of wastewater disposal alternatives in
addition to direct discharge. Particularly for dischargers of domestic wastewater, this evaluation should investigate the
feasibility of the following wastewater disposal alternatives:
■ Connection to an existing wastewater treatment plant(public or private)
■ Land application alternatives, such as individual/community onsite subsurface systems, drip irrigation,
spray irrigation
■ Wastewater reuse
■ Surface water discharge through the NPDES program
■ Combinations of the above
In order for the applicant to eliminate a wastewater disposal alternative, you must either show that the alternative is
technologically infeasible, or that it would be cost prohibitive to implement relative to a direct discharge alternative.
Please note that for some alternatives, it might be easier to prove an alternative is not viable based on high cost rather
than technological feasibility. For example, for a large municipal expansion that would require several hundred acres
for a land application alternative, it might be easier to simply assume that the required acreage could be purchased and
calculate the present value costs (including current market land costs) for this option, rather than evaluating whether
land application is technologically infeasible due to lack of available land and/or poor soil conditions. For those
alternatives identified as technologically feasible, you must develop and compare costs, based on a.preliminary level
design effort(see STEP 4).
The Division recognizes that wastewater disposal alternatives may be limited for some non-domestic wastewater
scenarios,and a full alternatives evaluation may not be warranted. If there is some question as to whether an alternative
may be eliminated, contact the NPDES Unit staff. Some scenarios that might not require a full alternatives evaluation
include:
■ Water Treatment Plant Discharges. Discharges from water treatment plants (WTPs) that utilize a
membrane technology (e.g., reverse osmosis, nanofiltration) or ion exchange system tend to generate
highly concentrated wastestreams. These wastestreams are not amenable to land application and do not
have to be evaluated for this alternative. However, since these wastestreams can also have a toxic impact
on a receiving freshwater system, proposed new discharges from these WTPs to freshwaters will not be
considered for an NPDES permit unless you can demonstrate that the environmental impacts would be
minimal based on dilution modeling. You should investigate whether the wastewater can be piped to a
stream with sufficient dilution, or whether a local WWTP might accommodate this discharge. Please
note that discharges from WTPs that utilize greensand filtration or conventional technology produce a
wastestream that is not saline, therefore no disposal alternatives can be automatically ruled out as
infeasible for these other WTPs. Refer to the NPDES website for permitting strategies for reverse
osmosis,ion exchange,greensand filtration,and conventional WTPs.
■ Groundwater Remediation System Discharges. You will need to evaluate whether WWTP connection,
land application, infiltration galleries, in-situ groundwater remediation wells, or closed-loop groundwater
remediation wells are viable disposal alternatives. While land application might be a feasible alternative in
rural areas,it would not be a feasible alternative in downtown Charlotte,where there is no land available
for wastewater application. In this instance,you may simply state that land application is infeasible based
on land constraints within the city. You will also need to evaluate connection to an existing WWTP (in
accordance with Alternative A), since there are some municipalities that have accepted this wastestream
EAA Guidance Document Version: June 23, 2005
Page 4 of 8

in the past. If the municipality will not accept the wastestream, the connection alternative is also
considered technologically infeasible. Please note that in-situ and closed-loop groundwater remediation
wells are permittable well types and further guidance is available through the Aquifer Protection Section.
Aside from these exceptions,you should proceed with the alternatives evaluation in accordance with the following
requirements. If you have any questions about these requirements, contact the NPDES Unit staff.
Alternative A. Connection to an Existing Wastewater Treatment System.
You must evaluate the feasibility of connecting to an existing wastewater treatment system served by a municipality or
other entity holding a valid NPDES or Non-Discharge Permit. All connection options should include an evaluation
of a gravity line and/or force main with pump station(s).
1. Existing Sewerage System:
(a) Identify whether there are existing sewer lines within a five-mile radius, or consider a greater radius if
cost effective for the project size.
(b) Provide a preliminary indication of flow acceptance from existing municipal or private WWTPs
under consideration for connection. If a municipal or private WWTP cannot accept the wastewater,
include a letter documenting such and consider this alternative technologically infeasible.
(c) If an existing sewerage system will accept the wastewater, evaluate the piping/pumps/resources
necessary to connect to the existing wastewater treatment plant. Attach a topographic map or a site
drawing showing the physical route of this alternative. Conduct a Present Value Cost Analysis per
STEP 4.
2. Planned Sewerage System: Determine if a regional sewerage system within a five mile radius is projected
to be available within the next five years to receive waste from the project site. If applicable, determine
availability date and flow acceptance projection from appropriate authority.
Alternative B. Land Application.
Land application disposal alternatives include individual/community onsite subsurface systems, drip irrigation, and
spray irrigation.
1. Provide an estimate of the best case hydraulic loading rate based on County Soil Surveys or from a soil
evaluation performed by a soil scientist. Include calculations showing the hydraulic loading rate
and the total area of land needed for the land disposal system,including buffers.
2. Assess the availability of land. If insufficient land is available onsite, assume that the necessary land can
be purchased and estimate the land purchase cost based on local real estate prices. Alternatively,provide
documentation to demonstrate that insufficient land is available for sale in the project area (include
letters from adjacent property owners indicating no interest in selling property).
3. Provide a description of the wastewater treatment system and the non-discharge application system.
Include a site plan showing the proposed layout, the application area, any existing structures, proposed
structures,and other uses within the site.
4. Explain the proposed reuse plan if reclaimed water will be used by a third party.
5. Conduct a Present Value Cost Analysis per STEP 4. For the reclaimed water system include the
potential revenue generated by selling the water.
6. Provide all calculations, documentation and maps as necessary to support assumptions and conclusions.
7. Note:The design of land application systems must meet the treatment and design requirements specified
in 15A NCAC 2H.0219 or 15A NCAC 18A.1900.
8. Note: Proposed discharges from groundwater remediation systems must evaluate the potential for an
infiltration galleiy treatment alternative.
Alternative C. Wastewater Reuse.
You must evaluate reusing all or a portion of the wastewater generated. Some municipalities are currently reusing
wastewater within the confines of their %VWTP property for irrigation, toilet flushing, backwashing, etc., while other
municipalities have established progressive reuse programs for residential irrigation. Reuse applications might include
golf course irrigation, crop irrigation (e.g., hardwood or pine plantation, grasses), athletic field irrigation, landscape
uses, and commercial/industrial uses. Some of these reuse applications will be evaluated under Alternative B, Land
EAA Guidance Document Version: June 23, 2005
Page 5 of 8

Application. The design of reclaimed water systems must meet the treatment and design requirements specified.in
15A NCAC 2H.0219.
Alternative D. Direct Discharge to Surface Waters.
1. No new or expanding(additional) discharge of oxygen-consuming waste will be allowed to surface waters
of North Carolina if both the summer 7Q10 and 30Q2 streamflows are estimated to be zero, in
accordance with 15A NCAC 2B.0206(d). Private applicants must contact the Federal USGS in Raleigh at
919-571-4000 and obtain (generally for a nominal fee), the receiving streamflow data (s7Q10, 30Q2,
annual average streamflow) at the proposed discharge location. This information must be included in the
EAA,and will be used to develop permit limits.
2. All direct discharge systems of oxygen-consuming wastes should be evaluated both with tertiary filtration
[BODS= 5 mg/1,NH3-N= 1 mg/1] and without,and assuming a weeldy sampling regime.
3. Provide a description of the proposed wastewater treatment facilities, including a schematic diagram of
the major components and a site plan of the treatment facility with outfall line(s).
4. Provide documentation of the-availability of required land and/or easement agreements.
5. Conduct a Present Value Cost Analysis per STEP 4.
6. Note: All direct discharge treatment systems must comply with Reliability Requirements specified in 15A
NCAC 2H.0124 as well as Minimum Design Requirements specified in 15A NCAC 2H.0219.
Alternative E. Combination of Alternatives.
You should evaluate the possibility of a combination of wastewater alternatives that would minimize or eliminate a
direct discharge alternative. For example, consider whether the facility can operate a land application system during
the dry season when streamflows are at their lowest and provide less dilution, and operate an NPDES discharge
system during the wet season when soils may not be as amenable to land application and the receiving stream
provides its greatest dilution.
STEP 4. Evaluate economic feasibility of alternatives
To provide valid cost comparisons among all technologically feasible wastewater alternatives identified in STEP 3,a 20-
year Present Value of Costs Analysis (PVCA) must be performed. A preliminary design level effort is considered
appropriate for comparing feasible options and their associated costs. For the PVCA cost comparison, all future
expenditures are converted to a present value cost at the beginning of the 20-year planning period. A discount rate is
used in the analysis and represents the time value of money(the ability of money to earn interest). Present value is also
referred to as "present discounted value" or "present worth".
The PVCA should include all monetary costs associated with construction, startup and annual .operation and
maintenance of a facility: All unit cost information must be provided, and costs must be referenced. Costs can,be
referenced in paragraph format by summarizing the sources utilized (e.g., vendor quotes, realtor land quotes, past
bids, Means Construction Index, etc). Vender quotes received for treatment units or other components, as well as
realtor land quotes, shall be included as well. For each treatment alternative identified as technologically feasible,
costs should include,but not be limited to,the following:
Capital Costs
■ Land acquisition costs
■ Equipment costs
• Labor costs
" Installation costs
■ Design costs
EAA Guidance Document Version: June 23, 2005
Page 6 of 8

Recurring Costs
■ Operation and maintenance costs (with replacement costs)
■ Laboratory costs assuming a weekly monitoring regime for discharge systems and a monthly regime for
non-discharge systems
■ Operator and support staff costs
■ Residual disposal costs
■ Connection fees and subsequent user fees
■ Permit and compliance fees
■ Utility costs (power,water,etc.)
Lost Opportunity Costs
J
PVCA Calculation Method.
The following standard formula for computing the present value must be used in all cost estimates made under this
evaluation:
n C
PV= Co +Y, r
+r)
Where:
PV =Present value of costs.
Co = Costs incurred in the present year.
Ct = Costs incurred in time t.
t =Time period after the present year (The present year is t= 0)
n = Ending year of the life of the facility.
r = Current EPA discount rate. EPA adjusts this rate annually on October 1, and it can be accessed from
the Internet at http:/www.nccgl.net/fap/cwsrf/201gui.h.tml.
If recurring costs are the same in years 1 through 20,then Ct=C and the formula reduces to:
PV= C +
Y(1+
As an example,assuming capital costs (Co) of $2 million,annual recurring costs (C) of$40,000,and a discount rate (r)
of 5.625%,the 20-year(n=20) present value of costs would equal:
PV= capital costs + recurring costs X [(1+0.05625)20—1] / [0.05625(1+0.05625)20]
PV= $2,000,000 + $40,000 X [1.98/0.168]
PV= $2,000,000 + $471,428
PV= $2,471,428
PVCA Sumrnary Table.
The EAA must include a Summary Cost Table,which summarizes present worth costs developed for all technologically
feasible wastewater alternatives. The summary should include a breakdown of capital costs and recurring costs. In
some situations,the Division may require the applicant to refine cost estimates for some alternatives, or possibly collect
actual soil data to better characterize the land application alternative. Ultimately, the final determination on cost
effectiveness is made by the Division with consideration of monetary costs as well as potential environmental impacts.
EAA Guidance Document Version: June 23, 2005
Page 7 of 8

Attachment A. Local Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c)(6) allows input from local governments in the issuance
of NPDES Permits for non-municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non-municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and(if such an ordinance is in effect)whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
■ Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail,return receipt requested.
■ If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified
mail card(s),within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
■ As evidence to the Commission that the local government(s) failed to respond within 15 days,the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the
15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located-is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government
(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [ ] No [ ] If no,please sign this form,have it notarized,and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes[ ] No [ ]
If there is a zoning or subdivision ordinance in effect,is the plan for the proposed facility consistent with the ordinance? Yes
No[ ]
Date Signature
(City Manager/County Manager)
State of ,County of 1
On this day of ,personally appeared before me,the said
name to me known and known to me to be the person described in
and who executed the foregoing document and he (or she)acknowledged that he(or she) executed the same and being duly sworn
by me,made oath that the statements in the foregoing document are true.
My Commission expires .(Signature of Notary Public)
Notary Public (Official Seal)
EAA Guidance Document Version: June 23, 2005
Page 8of8

NPDES PERMITTING STRATEGIES FOR POTABLE WATER TREATMENT PLANTS
September 2007
Background
In 1992, the Division of Water Quality(Division)implemented a general water treatment plant(WTP)
permitting strategy that was intended to apply to WTPs. However, after further research and discussion,it was
agreed that different technologies in water treatment yield very different pollutants of concern and impacts on the
environment. As a result,four permitting strategies were developed specifically geared towards certain water
treatment processes. This document summarizes the permit application and permit development procedure for
WTPs and serves as a reference tool for permit writers and pernittees. Other available resources include
Assessment and Recommendations for Water Treatment Plant Permitting:Findings of the Water Treatment Plant
Workgroup, and the Conventional WTP Report,both of which further explain the collaborative interdepartmental
effort and data study that went into the development of these permitting approaches.
L PERMIT APPLICA TION PR 0 CESS
An NPDES permit application is available on the NPDES website. The application is titled Standard Form
C-WTP and can be used for all WTPs,regardless of technology. This application differs from those used in the past
in that new applicants are required to submit a complete source water analysis and an engineering alternatives
analysis that fully explores all feasible alternatives to a surface water discharge. New facilities using ion exchange
(IE)or reverse osmosis(RO)technology are also required to perform a water quality model. New IE(includes
water softeners) and RO discharges will not be permitted in freshwater unless it is demonstrated that the
environmental impact would be minimal.
Based on their potential impacts to aquatic life all new IE and RO facilities, and conventional WTPs with a
discharge of over 0.5 MGD, must also initiate a tiered notification process that will serve to alert other divisions
and agencies through the Customer Service Center(CSC). The notification process,as illustrated in Figure 1,is
initiated when a new or expanding WTP project is first presented to a permitting agency or the CSC. When an
agency is first contacted,it becomes that agency's responsibility to direct the applicant to the CSC and notify a
CSC permit coordinator.
Figure 1—Water Treatment Plant Notification Flowchart
Water Treatment Plant Notification Process
Potential Applicant Acronym Ivey:
(planning/design phase DW O-Div of W ater Quality
Permitting Agency
(DEH,DW O,DWR,DLR,DCM) DEH-Div of Environmental
Health
DLR-Div of Land
Permit Coordinator Resources
Customer Service Center DWR-Div of Water
Resources
Tic,1 Notification ACOE-US Army Corps of
Engineers
DCM-Div of Coastal
M anagem enl
DWQ DE. DLR DWR ACOE DCM DMF WRC USFWS NHP NMFS DMF-Divol Marine
Fisheries
WRC NC Wildfire
Applicant Resources Commission
(with formal application) S USFW -US Fish and
Permitting Agency SFWe Service
1� (DEH,DW Q,DWR,DLR,DCM) NHP-NC Natural Heritage
\\\y Program
NMFS-National Marine
Permit Coordinator Fisheries Service
SEPA-Stale
Customer Service Center Environmental Policy Act
Tier II Notification
I I I I I Notifi anon Wa
DWO DE. DLR DWR ACOE DCM �DMF WRC USFWS NHP NMFS IWRC USFWS NHP NMFS I SEPA Pfo Cess
Permitting Agencies Comment/Review Agencies
t

Once the CSC has been contacted they will distribute a notice,via email,summarizing the proposed project
to the appropriate agency contacts. Tier I notification should begin for new or expanding WTPs upon initial contact
by the applicant,regardless of project stage. Following Tier I notification,each agency will determine its level of
involvement(i.e.requests for additional details,participation in meeting, etc.). Tier II notification should begin
when a significant development in the process has occurred, such as when a permit application has been filed or an
environmental document has been submitted. Throughout the process, CSC will coordinate communication with
the agencies and the applicant. Additional notifications may be necessary to update agency representatives of
important developments or to coordinate ineetings. Again,these various tiers of notification will only include a
summary of developments. Agency involvement is discretionary. The notification process concludes once all
applicable permits are issued.
As previously mentioned,this process should only apply to new IE/RO facilities and conventional plants
with a predicted discharge of greater than or equal to 0.5 MGD. Copies of proposed draft permits for these
facilities should also be forwarded to the US Fish and Wildlife Service and the Wildlife Resource Commission.
No inter-agency notification will be required for greensand filter systems.
II. PERMIT DEVELOPMENT FOR MEMBRANE AND ION EXCHANGE WATER TREATMENT PLANTS
2.1 Background
In 2002,the Division established an inter-departmental Workgroup,which then led to the development of a
technical subcommittee tasked to study the impacts of membrane and sodium cycle cationic ion exchange WTPs on
receiving waters. The subcommittee first identified potential environmental concerns and then conducted an
analytical study,data review, and analysis of several existing WTPs in North Carolina. Foremost amongst water
quality concerns were the total residual chlorine(TRC) and chloride levels present in discharges and the potential
toxicity of these pollutants on the receiving stream. Based on the results of the analytical study,the following
permitting strategy has been adopted for all WTPs using membrane and ion exchange technologies.
Portions of this strategy pertaining to the use of"membrane"technologies will primarily involve reverse
osmosis(RO),nanofiltration(NF),microfiltration(MF),and ultrafiltration(UF)processes for the treatment of
groundwater. Though less common, electrodialysis/electrodialysis reversal(ED/EDR)processes also use
membrane technology and should be guided by the membrane permitting strategy. Other portions of this document
pertain to WTPs using ion exchange(IE) as a primary or secondary component of the treatment system. "Water
softeners" are also IE processes. It is important to determine whether any part of the permittee's water treatment
process uses an ion exchange system. If so, their permit may incorporate relevant components of this strategy,
however the permit writer should use discretion when considering relative volumes of wastewater components.
These technologies(both membrane and IE)are of particular concern because they concentrate dissolved solids,
generating highly concentrated wastestreams. The wastes can have a toxic effect on the receiving water,
particularly if the system is freshwater in nature. For this reason,new discharges from membrane and IE WTPs
should not be uermitted into freshwaters unless it can be demonstrated that the environmental impacts would be
minimal. All new IE/RO dischargers must perform dilution modeling_
2.2 Pollutants of Concern
Based on a review of actual data from existing IE and RO facilities,iron,copper,chloride and zinc showed
reasonable potential to exist in concentrations that may exceed water quality standards. In addition, arsenic and
fluoride seem to pose a particular concern for membrane WTPs,while manganese and lead were typically found in
significant concentrations in IE process effluent. Chlorine was determined to be a parameter of concern for IE's in.
general.however it is important to note that TRC could potentially be problematic for any facility that chlorinates
its finislied water. Any treatment prior to discharge(i.e.feed disinfection,pH adjustment,antiscalant additives)
should be considered when determining permit limits. The only additives that should be introduced prior to
separation of product water and reject stream are acids(to reduce deposits)and corrosion inhibitors. Any other
additives might introduce additional pollutants of concern. Facilities must obtain approval and request a permit
-2-

modification for any significant change that would alter the characteristics or nature of the discharge. Tables 1 and
2 provide sample effluent limits and summarize the minimum recommended monitoring requirements for
membrane and)E WTPs.
Table 2.1:Monitoring Re uirernents or Membrane WTPs
The Minimum Monitoring Requirements for Membrane WTPs included below identifies various pollutants of concern
including conventional parameters,nutrients,and toxicants. A brief rationale for the inclusion of these contaminants can be
found in Appendix A. Other toxicants were not included because they were either not detected or rarely detected in the
effluent data surveyed,however,if a pollutant specific problem is detected in the receiving stream,effluent,or source water
then a monitoring requirement may be added for that parameter. Likewise,if data indicate that a pollutant is not present in
the facility's discharge,that parameter may be dropped from the requirements.These are minimum monitoring requirements.
Limits should be added if the facility shows reasonable potential to exceed water quality standards for toxicants. New
facilities should monitor for parameters of concerns regardless'of whether or not there is a water quality standard. Monitoring
requirements can be te-evaluated during subsequent renewals.
EFFhUENT F x ' r �ty " LIMT 1 S MONITORING REQUIREMENTS`
+.
CHARACTERISTICS M )
i M iY 4 l` ! ?`tt Y 'h 3S 4d YL F l }
�= Monthly Average < Weekly Daily Measurement, Sample
' ; .�� w 1 ��Z #x-, �-
t � t + + � a x Avera MaXlmumY-0 Lle C �_;I e LoQatloni'
q �{ , c
,:':c,.. .n .,. w{,hae> 6...,. ..._...b .,4 ,�-2 t. ..lit,..y..4. dF2,�rta; J' _ Y._
Flow Limited Continuous E
Temperature See Table 5:1 Grab E,U,D
Salinity See Table 5.1 Grab E,U,D
Conductivity See Table 5.1 Grab E,U,D
pH Saltwater:6.8—8.5 See Table 5.1 Grab .E,U,D
Freshwater: 6.0—9.0
Dissolved Oxygen See Table 5.1 Grab E,U,D
Total Dissolved Solids See Table 5.1 Grab E
Freshwater:
Total Residual Chlorine 17 28 µg/L See Table 5.1 Grab E
Saltwater:
13 µ /L
Total Arsenic Limit based on potential See Table 5.1 Grab E
Total Copper Limit based on potential See Table 5.1 Grab E
Total Chloride Limit based on potential See Table 5.1 Grab E
Total Iron Limit based on potential See Table 5.1 Grab E
Total Fluoride Limit based on potential See Table 5.1 Grab E
Total Zinc Limit based on potential See Table 5.1 Grab E
Ammonia Nitrogen Limit based on potential See Table 5.1 Grab E
Total Nitrogen(TN)3 Quarterly Grab E
Total Phosphorus(TP)3 Quarterly Grab E
Whole Effluent Toxicity
Quarterly Grab E
Monitoring4
Notes:
1. Sampling locations:E=Effluent,U=Upstream of discharge location,D=Downstream of discharge location.
2. Limit and monitor only if the facility adds chlorine to water that is eventually discharged.
3. Facilities under 0.05 MGD should only monitor for nutrients if discharging into a NSW. Monitoring frequency should align
with basin-specific requirements if those are more stringent.
4. See section on WET testing for details(Table 5.2).
-3 -

Table 2.2:Monitoring Requirements for Ion Exchange WTPs
The Minimum Monitoring Requirements for Ion Exchange WTPs included below identifies various pollutants of concern
including conventional parameters,nutrients,and toxicants. A brief rationale for the inclusion of these contaminants can be
found in Appendix A. Other toxicants were not included because they were either not detected or rarely detected in the
effluent data surveyed,however if a pollutant specific problem is detected in the receiving stream then a monitoring
requirement should be added for that parameter.Likewise,if data indicate that a pollutant is not present in the facility's
discharge,that parameter may be dropped from the requirements. These are minimum monitoring requirements. Limits
should be added if the facility shows reasonable potential to exceed water quality standards for toxicants. New facilities
should monitor for parameters of concerns regardless of whether or not there is a water quality standard. Monitoring
requirements can be re-evaluated during subsequent renewals.
i
EFFLUENTl i € LIMITS i<"' Alf' 'a MONITORING;RE=T"JIREMENTS
_ SS .*. 'm 49
CHARACTERISTICS � > fx f� 4 Ma
a
a
a
a
a
a
`bf1 Monthly We6ldy,%
x � r Dai1y� Measurement Sample Samplea
• ,...� ,�.�����xy� ,��;�,A�erage•„x ..,�verage,�„ ���'��Maxxmum ;FrequencY.�;.A ����Type?�`,ti �aLocation?,
Instantaneous
Flow Limited or E
Continuous3
Temperature See Table 5.1 Grab E,U,D
SaIinity See Table 5.1 Grab E;U,D
Conductivity See Table 5.1 Grab E;U,D
Saltwater:6.8-8.5
pH See Table 5.1 Grab E,U,D
Freshwater: '6.0-9.0
Dissolved Oxygen See Table 5.1 Grab E,U,D
Total Dissolved Solids See Table 5.1 Grab E
Total Suspended Solids' 30 m /L 45 m /L See Table 5.1 Grab E
Freshwater:
Total Residual Chlorines 17-28 µg/L See Table 5.1 Grab E
Saltwater:
13 /L
Total Copper Limit based on otential See Table 5.1 Composite E
Total Chloride Limit based on potential See Table 5.1 Composite E
Total Iron Limit based on potential ' See Table 5.1 Composite E
Total Manganese Limit based on potential See Table 5.1 Composite E
Total Lead Limit based on potential See Table 5.1 Composite E
Total Zinc Limit based on potential See Table 5.1 Composite E
Ammonia Nitrogen Limit based on potential See Table 5.1 Composite E
pluoride7 Limit based on potential See Table 5.1 Composite E
Total Nitrogen(TN)8 Quarterly Composite E
Total Phosphorus(TP)8 Quarterly Composite E
Whole Effluent Toxicity Quarterly _ Composite E
Monitoringb
Notes:
1. An exception to the composite sampling is provided by 15A NCAC 2B.0505(C),which states that facilities with design
flows under 30,000 gallons per day may use grab samples to characterize their effluent.
2. Sampling locations:E=Effluent,U=Upstream of discharge location,D=Downstream of discharge location.
3. For intermittent discharges,instantaneous flow monitoring is required and the duration of the discharge must be reported.
Include provisions for monitoring the instantaneous maximum flow rate from the facility.
4. For existing plants,TSS limits may need to be phased in over a period of time to allow for the construction of new treatment
facilities
5. Limit only in effect if the facility uses chlorinated water in the filter backwash process(and discharges filter backwash).
6. See section on WET testing for details(Table 5.2).
7. Fluoride monitoring should apply only if the facility backwashes with fluoridated,finished water.
8. Facilities under 0.05 MGD should only monitor for nutrients if discharging into a NSW. Monitoring frequency should align
with basin-specific requirements if those are more stringent.
-4-

2.3 Instream Monitoring
Both RO and IE WTPs will require instream monitoring. This requirement may be waived for facilities
discharging to zero flow streams. For discharges where no water quality model was performed,the facility should
monitor 50 feet upstream and at least 100 feet downstream of the outfall. For discharges where a model was
performed, locations should be determined on a case-by-case basis,but should take in consideration the size and
shape of the effluent plume.
III. PERMIT DEVELOPMENT FOR CONVENTIONAL WATER TREATMENT PLANTS
3.1 Background
Following the completion of the IE/RO report, a second workgroup was formed whose objectives dealt
exclusively with concerns associated with the discharge of filter backwash from conventional treatment processes.
This report summarizes NPDES permitting strategy recommendations for conventional water treatment plants
based upon chemical and physical data from various facilities around North Carolina. The assessment and strategy
detailed here applies only to those facilities using surface water sources and the referenced technologies.
Most of the state of North Carolina(west of I-95)uses surface water as a drinking water source. It is
generally recognized that the water quality issues associated with surface water are those relating to particulate
matter,microbiological content,color,taste and odor. Conventional treatment processes are designed to address
these water quality issues. A conventional treatment process is described by the American Water Works
Association as including coagulation, flocculation and sedimentation,usually followed by filtration and
disinfection.
3.2 Pollutants of Concern
Aluminum,calcium,magnesium, and manganese were detected effluent data from the five conventional
WTPs used to supply data for this report. All five facilities had high maximum predicted concentrations for these
parameters,therefore they are considered to be pollutants of concern and should be monitored. Zinc should be
monitored if a permittee uses zinc orthophosphate as a corrosion inhibitor.
In addition to pH,flow,and total residual chlorine,which will be limited, the permit writer may need to
determine the necessity of a limit for some other parameter of concern that may have been identified in the
application. DWQ will perform a reasonable potential analysis(RPA)on any available data to determine the need
for monitoring or limits.For existing facilities collecting toxicant data,the RPA would employ these data.The
reasonable potential procedure may also be used as a tool for analyzing the source water of proposed water
treatment plants. Table 3 provides sample effluent limits and summarizes the minimum recommended monitoring
requirements for conventional WTPs.
-5-

r
Table 3.1:Monitoring Requirements For Conventional WTPs
The Minimum Monitoring Requirements for Conventional WTPs included below identifies various pollutants of concern
including conventional parameters,nutrients,and toxicants. A brief rationale for the inclusion of these contaminants can be
found in Appendix A. Other toxicants were not included because they were either not detected or rarely detected in the
effluent data surveyed,however,if a pollutant specific problem is detected in the receiving stream,effluent,or source water
then a monitoring requirement may be added for that parameter. Likewise,if data indicate that a pollutant is not present in
the facility's discharge,that parameter may be dropped'from the requirements. These are minimum monitoring requirements.
Limits should be added if the facility shows reasonable potential to exceed water quality standards for toxicants. New
facilities should monitor for parameters of concerns regardless of whether or not there is a water quality standard.' Monitoring
requirements can be re-evaluated during subsequent renewals.
:' EFFLUENT " F "; EIMITS MONITOR=ING REQLJIR11t1TS` r'
s C�IARACTERISTICS ,. ?�. r„ £ Q, x a_ E
S t. 4
Moitly ' �s 4ely Daxly Maximum Nleaurement� >Sample Type Ml
`jample
rffi
Flow' Limited Continuous Effluent
TSS 30 m /L 45 m /L See Table 5.1 Grab Effluent
H Freshwater: 6.0—9.0 See Table 5.1 Grab Effluent
Total Residual Chlorine'- 17-28 µg/L See Table 5.1 Grab Effluent
Aluminum Quarterly7 Grab Effluent
Calcium Quarterl 7 Grab Effluent
Magnesium Quarterly7 Grab Effluent
Manganese Quarterly7 Grab Effluent
Fluoride See Table 5.1 Grab Effluent
Total Zinc 3 See Table 5.1 Grab Effluent
Ammonia Nitrogen 4 See Table 5.1 Grab Effluent
Total Copper See Table 5.1 Grab Effluent
Total Iron. See Table 5.1., . Grab Effluent
Total Phosphorus(TP)5 Quarterly Grab Effluent
Total Nitrogen(TN)5 Quarterly Grab Effluent
Whole.Effluent Toxicity
e Quarterly Grab Effluent
Monitorin
Notes:
1. See Appendix A for guidance on determining an appropriate flow limit.
2. Limit and monitor only if the facility adds chlorine to water that is eventually discharged.
3. Zinc should only be monitored if a Permittee uses zinc orthophosphate as a corrosion inhibitor.
4. Facilities using chl6ramination will be required to monitor ammonia nitrogen on a quarterly basis.
5. Facilities under 0.05 MGD should only'monitor for nutrients if discharging into a NSW. Monitoring frequency should align
with basin-specific requirements if those are more stringent.Parameters should be monitored in conjunction with toxicity
test.
6. See section on WET testing for details.
7. Parameter should be monitored in conjunction with toxicity test.
IV. PERMIT DEVELOPMENT FOR GREENSAND WATER TREATMENT PLANTS
4.1 Background
The following permitting strategy applies to new and existing water treatment plants using greensand
filtration to generate potable water from groundwater. This categorization would also include many community
well systems, "iron filters",and"manganese filters"as long as they do not"backwash filters with a sodium solution.
The permit writer should contact the facility to verify that there is not a briny discharge. This permitting strategy
-6-

does not apply to any other kind of cationic exchange unit used in water treatment. If any portion of the water
treatment process includes an ion exchange/water softener unit, then the RO-IE Permitting Strategy will apply as
well.
Typically, a greensand filtration unit is preceded by the use of an aeration tower along with potassium
permanganate to oxidize dissolved iron in the ground water. The particulate ferric hydroxide (and some minor
quantities of soluble ferrous material)is then removed via filtration through a manganese based greensand media.
Greensand is a proprietary material that does not require sodium cycle regeneration, only backwash with finished
(potable)water. Since the discharge from such a facility is not as saline as that from a sodium cycle cationic
exchange unit,this may be considered a more enviromnentally friendly technology for the treatment of
groundwater. For that reason,unlike other types of ion exchange systems,non-discharge options are sometimes an
alternative and should be explored for new permits. Filter backwash water is usually collected in a settling basin,
and the supernatant is then discharged to surface waters or a regional treatment works.
4.2 Pollutants of Concern
Typical chemical additives to such treatment systems are an anti-sealant(such as zinc orthophosphate),fluoride,
chlorine and potassium pennanganate.
Table 4.1:Monitoring Requirements For Greensand WTPs
The minimum monitoring requirements for greensand WTPs included below identifies various pollutants of concern
including conventional parameters and toxicants. A brief rationale for the inclusion of these contaminants can be found in
Appendix A. Other toxicants were not included because they are not expected to be detected,however if a pollutant specific
problem is detected in the receiving stream then a monitoring requirement may be added for that parameter. Likewise,if
data indicate that a pollutant is not present in the facility's discharge,that parameter may be dropped from the
requirements. Limits should be added if a facility shows reasonable potential to exceed water quality standards for
toxicants. New facilities should monitor for parameters of concerns regardless of whether or not there is a water quality
standard. Monitoring requirements can be re-evaluated during subsequent renewals.
,LIMITS g r ;. <d _ ; 1VONITORIIVG REQUIItE1V1ESs ,.
C[gAIZACTRIiISTICS �i �E a en :r
s %u Monthly K r Daily Maximum Measurement 6 Sample z $ Sample ,
�k F ji'?�y.r` _+�i a,T �J f ��� $ ��s£�
requencY.. f. . ;_STY :e., E.z. .G, I ocahonu�4,
Flow' Limited Instantaneous Effluent
Total Suspended Solids 30.0 mg/L 45.0 mg/L See Table 5.1 Grab Effluent
Total Residual Chlorinez Freshwaters:17-28 µg/L See Table 5.1 Grab Effluent
Saltwater:13 Vg/L
Fluoride3 Based on potential See Table 5.1 Grab Effluent
Total Iron See Table 5.1 Grab Effluent
Total Zinc' See Table 5.1 Grab Effluent
Total Manganese See Table 5.1 Grab Effluent
pH Freshwater:6.0—9.0 s.u. See Table 5.1 Grab Effluent
Footnotes:
1. For instantaneous flow monitoring,the duration of the discharge must be reported in addition to the total flow.
2. The TRC monitoring requirement applies only if the Permittee backwashes with chlorinated water.
3. Fluoride should be monitored if the permittee backwashes with fluoridated finished water.
4. Zinc shall be monitored if the Permittee uses any zinc-based additive in the water treatment process.
-7-

V. IMPLEMENTATION
5.1. Aonitoring Frequency
In order to be consistent with the monitoring guidance employed for other permits across the state,
monitoring frequencies will be based on the flow divisions used to define facility class in the 15A NCAC 08C
.0302 regulations. Requirements described in 15A NCAC 2B .0508(d) for water supply plants were used as
guidance. Table 5 summarizes the monitoring requirements. After sufficient data have been collected(eight to 12
data points over at least one year) the permittee may petition for a reduction in monitoring.
Table 5.1: WTPMonitoring Requirement
Facility Class Conventional Parameters and Toxicants
(Effluent and Instream)
Permitted Flow<0.5 MGD If limited - 2/Month
Not limited -Monthly
Permitted Flow>_0.5 MGD If limited - Weekly
Not limited-2/Month
5.2. Whole Effluent Toxicity Testing
Membrane,ion exchange, and conventional WTPs should be required to conduct quarterly WET tests for
monitoring purposes. Eventually,the Division may choose to use this data to develop additional policy. The type
of WET test conducted will vary depending on receiving stream characteristics. In addition,the level of available
dilution and tidal effects will determine whether the facility should perform an acute or chronic test, while the type
of water(freshwater or saltwater) will determine which organism should be used. Table 1 summarizes WET-
testing requirements. Appendix A includes sample WET language.
Greensand filter systems will not be required to monitor whole effluent toxicity.
Table 5.2: WET Test Requirements-Monitor Only
Discharge Condition Test
Dilution IWC<0.25% Acute 24-hour Pass/Fail at 90%
IWC>_0.25% Chronic test at IWC (maximum 90%)
Tidal Effects Modeled Tidal discharge Chronic test at chronic mixing zone characteristics
Tidal Discharge-not modeled' Acute 24-hour Pass/Fail at 90%
Freshwater Acute test organism: Fathead minnow
Chronic test organism: Ceriodn hnia dubia
Water Type Acute test organism: Fathead Minnow OR Mysid Shrimp
Saltwater OR Silverside Minnow(permittee's choice)
Chronic test organism:Mysid shrin1p 2
Notes:
I. Applies to existing dischargers only.
2. Permittee may choose to conduct comparison studies showing Ceriodophnia duhio to be greater than or equal to Mvsid
Shrimp in degree of sensitivity to the facility's effluent.
5.3. Peer Agency Review
At a minimum, the permit writer should consider providing a copy of draft permits for all membrane and
ion exchange facilities to the following agencies: Division of Marine Fisheries(for saltwater discharges), US Fish
and Wildlife Service (Sara Ward),Wildlife Resources Commission, and the Division of Environmental Health.
Draft permits proposing a discharge to shellfish waters (SA)must also be sent to the Shellfish Sanitation for review.
-,q-

Major permits for conventional water treatment plants should also be sent to the same agencies.
Permits for greensand filter systems will not require inter-agency notification.
5.4. Special Considerations—SA Waters
SA waters are,by default, classified as High Quality Waters. Therefore,limits should be calculated using''/z the
water quality standard. Draft permits proposing a discharge to SA waters should be sent to the Shellfish Sanitation
for review.
-9-

APPENDIX A. RATIONALE FOR PARAMETER INCLUSION
L CONVENTIONAL PARAMETERS
Conductivity(IE and RO facilities)
Conductivity provides information on the inorganic nature of a wastewater by tracking the relative concentration of ions.
By requiring effluent and instream monitoring of conductivity,it may be possible to assess some of the ionic impacts of
the discharge on the receiving stream.
Dissolved Oxygen(IE and RO facilities)
Low dissolved oxygen concentrations were observed in the effluent of the facilities evaluated.A facility may petition
DWQ to reduce/eliminate DO monitoring requirements if they can demonstrate that the discharge has no significant
impact on DO levels in the receiving stream.
Flow
Flow is an important consideration for dilution modeling and mixing zone calculations.Continuous flow monitoring is
required for all but intermittent discharges. All water treatment plants will have flow limits,determined by either the
facility design or the maximum monthly average flow in the most recent three-year period. For new facilities the flow
limit may be determined based on the proposed discharge flow as submitted by the permittee,provided reasonable
justification supports the flow.
Temperature(IE and RO facilities)
Literature reviews indicate that temperature is a potential cause for concern. If a permittee can demonstrate that its
discharge is not significantly impacting temperature in the receiving stream,the permittee may petition DWQ to
reduce/eliminate the temperature monitoring requirements.
Total Dissolved Solids(all types except RO)
Total dissolved solids can be a good general indicator of potential toxicity and may be present in elevated concentrations
in the wastestream. Since some existing WTPs only have minimal treatment prior to discharge,TSS limits may need to
be phased in over a period of time to allow for the construction of new treatment facilities.
PH
Some of the chemicals used in water treatment can depress or raise pH,and as such,it should be monitored and limited.
For discharges to fresh waters,pH will be limited in the range of 6.0-9.0 standard units. For salt waters,pH should be
limited between 6.8 and 8.5 standard units.
Salinity (IE and RO facilities onl))
If effluent salinity is much higher than the salinity of the receiving stream,there may be localized acute toxic effects.
H. TOXICANTS
Arsenic (ROfacilities only)
For-membrane systems,average values of arsenic were slightly below the aquatic life standard and the maximum values
observed exceeded standards.
Calcium(conventional WTPs only)
Calcium is a pollutant of concern for conventional WTPs and should be monitored in conjunction with the facility's WET
test.
Chloride(IE.and RO facilities)
Foremost.among the water quality concerns for ion exchange and membrane plants are the levels of chlorides present and
the effect of these discharges on the receiving stream.
Copper(IE,RO, and conventional systems)
A data survey indicated the potential for copper to be present in concentrations exceeding NC water quality standards
(WQS). While average values were slightly below the aquatic-life standard,maximum detected levels exceeded the
standards. Since this is an action level parameter,it will be monitored but not limited unless toxicity can be linked to the
presence of this parameter in the potable water byproduct.
Fluoride
Fluoride can be a pollutant of concern for conventional,IE and greensand systems if potable,fluoridated water is used for
backwash water.
- 10-

In membrane plants,fluoride levels can be quite high if the source water contains fluoride. In many of the facilities
sampled,fluoride levels in membrane WTP discharges showed reasonable potential to exceed water quality standards.
Iron
Iron is typically a primary pollutant of concern for all types of water treatment processes. This parameter should be
monitored(with no limit)since no WQ standard currently exists.
Lead(IE systems only)
Lead values present in the IE discharges studied demonstrated the potential to exceed NC water quality standards.
Manganese(all facilities except RO)
Similar to Iron,manganese is a frequently occurring parameter of concern. However since there is no WQ standard for
this pollutant,it should be monitored without a limit.
Total Residual Chlorine
Chlorine is introduced through the use of finished water in the filter backwash process,and adds a toxic component to
backwash effluent. Note that it's also possible for chlorine to mask toxicity from other sources. Using non-chlorinated or
dechlorinated water sources during the backwash process can reduce TRC toxicity,however if a WTP discharges filter
backwash water and uses chlorinated water in the backwash process,the discharge will receive a TRC limit from 17-28
µg/L as a daily maximum(for freshwaters). All Saltwater dischargers should receive a daily maximum limit of 13 µg/L.
Most plants will need to build dechlorination facilities to achieve this level in their discharge.
Zinc
Zinc is a pollutant of concern for all types of facilities. This is an action level parameter and should be monitored without
a linut.
III.NUTRIENTS
Ammonia
The ammonia nitrogen results at conventional water treatment plants indicated very low levels in the potable water by-
product. It is important to note,however,that none of the facilities surveyed use chloramination to disinfect the source
water. DEH regional office staff has suggested that facilities using chloramines for disinfection should have finished
water ammonia levels between 0.2-0.5 mg/L but may have levels higher than this. For this reason,those conventional
treatment facilities using chloramination will be required to monitor ammonia nitrogen on a quarterly basis.
A review of data for IE and RO plants indicated that levels of ammonia nitrogen were considerably higher than
background:In addition,a member of WTPs discharge to nutrient sensitive waters,making the need to monitor effluent
nutrient levels necessary. Therefore,TN and TP will be monitored quarterly. When sufficient effluent data have been
collected,the need for nutrient limits will be assessed on a case-by-case basis.
Nitrogen and Phosphorus
Nutrient monitoring will be added for all facilities except greensand filters. Monitoring should be added according to
basin specific requirements,in order to be consistent with other dischargers throughout the state
IV. WET TESTING
Because of the potential toxic effects of WTP discharges,all WTPs(except greensand filters)will be required to monitor
for toxicity. Limits will not be implemented at this time.
V. SAMPLE TYPE
Membrane WTPs
Although variability may occur between plants and within a particular facility,the Workgroup felt that grab samples were
adequate to characterize the effluent. After reviewing existing data,the consistency in the individual source water and the
treatment process over time suggests that grab samples are appropriate.
Ion Exchange [,VIPs
Over the course of the regeneration cycle,the effluent characteristics can experience significant variability. Composite
samples should be collected for all parameters except flow,total residual chlorine,temperature,dissolved oxygen,TDS,
- 11 -

salinity,conductivity and pH. These parameters can only be measured properly using grab samples.An exception to the
composite sampling is provided by 15A NCAC 2B.0505(C);which states that facilities with design flows under 30,000
gallons per day may use grab samples to characterize their effluent.
IV.ADDITIONAL PARAMETERS OF CONCERN
Additional parameters of concern,most notably metals,may be identified in the application package and source water
data. Source water data should be entered into a Reasonable Potential Analysis(RPA)in order to assess the need for
limits. Such determinations are to be made on a case-by-case basis.
r
- 12-

APPENDIX B—SAMPLE WET MONITORING LANGUAGE
CHRONIC TOXICITY MONITORING(QRTRLY)
The pernttee shall conduct quarterly chronic toxicity tests using test procedures outlined in the"North Carolina Ceriodaphnia
Chronic Effluent Bioassay Procedure,"Revised February 1998, or subsequent versions.
The effluent concentration defined as treatment two in the procedure document is XX%.The permit holder shall perform
quarterly monitoring using this procedure to establish compliance with the permit condition.The tests will be performed
during the months of , , and I . Effluent sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form
(MR_1)for the month in which it was performed,.using the parameter code TGP3B.Additionally,DWQ Form AT-1 (original)
is to be sent to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Section
1621 Mail Service Center
Raleigh,N.C. 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section no later than 30 days after the end of
the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association
with the toxicity tests,as well as all dose/response data.Total residual chlorine of the effluent toxicity sample must be
measured and reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a unonth in which toxicity monitoring is required,the permittee
will complete the information located at the top of the aquatic toxicity(AT)test form indicating the facility naive,permit
number,pipe number,county,and the month/year of the report with the notation of"No Flow"in the comment area of the
form.The report shall be submitted to the Environmental Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,then monthly monitoring will
begin immediately.Upon submission of a valid test,this monthly test requirement will revert to quarterly in the months
specified above.
Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality
indicate potential impacts to the receiving stream,this permit may be re-opened and modified to include alternate monitoring
requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document,such as minimum control organism survival,
minimum control organism reproduction,and appropriate environmental controls,shall constitute an invalid test and will
require immediate follow-tip testing to be completed no later than the last day of the month following the month of the initial
monitoring.
I
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11c," ions`T v:i_f.!`ice'=iCf:;?C'... ::57.lti.S.. }�..�1{t'f' ,i.:';r?
- 13 -
l

►s�
P a
y
North Carolina Wildlife Resources Commission
Charles R. Fullwood, Executive Director
GUIDANCE MEMORANDUM TO ADDRESS AND MITIGATE SECONDARY AND
CUMULATIVE IMPACTS TO AQUATIC AND TERRESTRIAL WILDLIFE RESOURCES
AND WATER QUALITY
(August 2002)
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Page 2
August 2002
CSI Mitigation Measures
Executive Summary
Thousands of acres of land are developed each year in North Carolina, and this
development consists of many individual and often unrelated projects. Without proper
safeguards,the cumulative effects of land development can transform the landscape and
negatively impact the environmental character and natural functions of the ecosystems. North
Carolina projects a population increase of more than 3 million new individuals by the year 2020
(N. C.Progress Board 2001);therefore, it is imperative that coordinated measures be
implemented to protect wildlife resources and their habitats.
When development is conducted in an unplanned and amorphous or ambiguous pattern it
can have more serious impacts on ecosystem function. Rapidly developing landscapes can result
in stream degradation due to increases in stormwater runoff, sedimentation and other pollutants,
and riparian habitat losses. Some of the greatest impacts of development,both land-based and
near-water development,occur on water quality in our streams and rivers. Many of our native
species of aquatic organisms have become highly imperiled as a result. The decline in
freshwater species is a direct reflection of declining quality of our streams and rivers, and rare
and sensitive species are particularly affected by secondary and cumulative impacts associated
with urban development due to their sensitivity to slight habitat alterations.
A more comprehensive approach to project review is necessary if we are to effectively
protect the environmental resources of the State. This approach should scrutinize the cumulative
and secondary impacts (CSI) associated with all projects subject to State Environmental Policy
Act(SEPA)requirements as closely as direct impacts. Cumulative effects are defined as effects
resulting from the incremental impact of the proposed activity when added to other past,present,
and probable future activities in the area. Cumulative effects can occur from individually minor
but collectively significant activities taking place over a period of time. Secondary effects are
defined as probable effects caused by and resulting from the proposed activity although they are
later in time or-further removed in distance.
Presently, cumulative and secondary impacts are often not fully addressed in an
environmental review. The Department of Environment and Natural Resources (DENR),has
identified as part of the 2000 strategic plan the need to develop a policy for evaluating and
mitigating the cumulative and secondary impacts..Identification of measures to mitigate for
secondary and cumulative impacts was determined to be an important component of addressing
impacts.
This document was primarily authored by biologists with the N. C. Wildlife Resources
Commission and the N. C. Division of Parks and Recreation. Significant contributions were
provided by the CSI Working Group,which includes representatives from numerous state
agencies concerned with the conservation of natural resources. The U. S. Fish and Wildlife
Service,which supports these recommendations, also provided constructive review of the
document.
This document is intended to serve as a guidance memorandum for local governments to
assist with addressing secondary and cumulative impacts associated with public projects.
Implementation of these recommendations will assist in the mitigation of impacts to water
quality,to fish and wildlife and their habitat generally, and in situations where federally
threatened and endangered species exist. Alternatives to these measures will be examined on a
case-by-case basis, provided that the same level of protection is afforded. The recommendations
provided herein are intended to be applied to new developments or to existing developments for

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August 2002
CSI Mitigation Measures
which significant modifications or expansions are proposed. Incorporation of the measures that
are outlined throughout the document by local governments will alleviate the concerns of the
natural resource agencies and will provide for a smoother and more timely review of
environmental documents and permits.
The recommendations presented in this document to avoid or mitigate these impacts are
based on the best available science and were obtained by a synthesis of scientific information in
journals,publications,reference books, and personal communication with professionals familiar
with North Carolina aquatic species and other natural resources. However,the recommendations
may be revised as more information becomes available about species' habitat requirements and
measures necessary to protect aquatic and terrestrial habitat and water quality. It is envisioned
that through the active participation and initiative of local governments in partnership with State
resource and regulatory agencies,the concerns regarding impacts of significance will be
alleviated and the review of environmental documents and permits will be more efficient and
effective.
Recommendations include measures regarding:
• Forested buffers
• Stream and wetland resources
• Infrastructure locations
• Floodplains
• Impervious surfaces and stormwater treatment
• Erosion and sediment control

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August 2002
CSI Mitigation Measures
Preface
This document is intended to serve as a guidance memorandum for local governments to
assist with addressing secondary and cumulative impacts associated with public projects.
Implementation of these recommendations will assist in the mitigation of impacts to water
quality,to fish and wildlife and their habitat generally, and in situations where federally
threatened and endangered species exist. Alternatives to these measures will be examined on a
case-by-case basis,provided that the same level of protection is afforded. The recommendations
provided herein are intended to be applied to new developments or to existing developments for
which significant modifications or expansions are proposed. Incorporation of the measures that
are outlined throughout the document by local governments will alleviate the concerns of the
natural resource agencies and will provide for a smoother and more timely review of
environmental documents and permits.
Agencies,municipalities, landowners, and the public share a responsibility to protect and
conserve fish and wildlife,which are public resources. Efforts to minimize secondary and
cumulative impacts may not show immediate rewards,however such efforts are important to
prevent future damage to riparian and stream systems and to rebuild degraded areas. These
efforts will also help meet the anti-degradation standard established in Rule 15A NCAC 02B
.0201,which provides for the maintenance,protection, and enhancement of existing uses.
During the fall of 2001 and through 2002 the N. C. Department of Environment and
Natural Resources (DENR) established and guided a Cumulative and Secondary Impact(CSI)
Working Group. This group was made up of a variety of staff from Divisions within DENR.
The CSI Working Group undertook the task of identifying, drafting, and developing a system
and protocol for ensuring that cumulative and secondary impacts are adequately addressed
during the review of documents required under the N. C. Environmental Policy Act.
Identification of mitigation measures effective in reducing potential negative impacts associated
with projects was a major component of this endeavor;therefore, a"mitigative measures"
subgroup was formed. This document was developed as a result of that effort.
This document was primarily authored by biologists with the N. C. Wildlife Resources
Commission (NCWRC) and the N. C. Division of Parks and Recreation, and significant
contributions were provided by the mitigative measures subgroup. The document includes
comments, ideas, and suggestions from the entire CSI Working Group,which includes
representatives from the N. C. Division of Coastal Management,N. C. Division of
Environmental Health,N. C.Division of Land Resources,N. C. Division of Marine Fisheries,N.
C.Division of Parks and Recreation,N. C. Division of Water Quality,N. C. Division of Water
Resources,N. C. Office of Legislative and Intergovernmental Affairs, and the NCWRC.
Constructive comments from many of these agencies improved the document. The U. S.Fish
and Wildlife Service (USFWS), which supports these recommendations, also provided
constructive review of the document.
The NCWRC and the Division of Parks and Recreation recognize that ongoing
development and change to the natural landscape will continue and that continued economic
development is critical to the citizens of the state. Furthermore, a healthy state is dependent
upon a healthy economy and a healthy.natural environment, both of which are integrated
components. How and where change to the landscape occurs makes all the difference in the
future of a sustainable economy and healthy natural environment. The assembled information
consists of recommendations,that when,implemented by a local government, will

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August 2002
CSI Mitigation Measures
simultaneously work to maintain or improve water quality,protect aquatic habitat,permit
economic expansion, and preserve the character of the land.
Introduction
Thousands of acres of land are developed each year in North Carolina, and this
development consists of many individual and often unrelated projects. Without proper
safeguards,the cumulative effects of land development can transform the landscape and
negatively impact the environmental character and natural functions of the ecosystems. North
Carolina projects a population increase of more than 3 million new individuals by the year 2020
(N. C. Progress Board 2001);therefore, it is imperative that coordinated measures be
implemented to protect wildlife resources and their habitats. Most citizens want a clean
environment and a healthy economy,therefore measures must be implemented statewide to
allow economic growth without significant and irretrievable impacts to North Carolina's
environment.
Some of the greatest impacts of development, both land-based and near-water
development, occur on water quality in our streams and rivers. Many of our native species of
aquatic organisms have become highly imperiled as a result. Approximately one-third of North
American freshwater fish species (Williams et al. 1989) and 72%of freshwater mussel species
(Williams et al. 1993) qualify for classification as"endangered", "threatened", or"special
concern"at the federal level, and habitat loss is a primary culprit,particularly for mussels. In
North Carolina, 21%of freshwater fishes and 53%of freshwater mussel species are designated
endangered,threatened, or of special concern at the state level (LeGrand et al. 2001). The
decline in freshwater species is a direct reflection of declining quality of our streams and rivers.
Federally endangered and threatened species are particularly affected by secondary and
cumulative impacts associated with urban development due to their sensitivity to slight habitat
alterations. A high proportion of listed species occurs within areas of the state that are
developing the most rapidly; some have lost major reaches of their habitats within the past few
decades, others are in danger of being extirpated from entire river basins, and one species has
been extirpated from the state, and thus is extinct(Carolina Elktoe,Alasmidonta robusta).
When development is conducted in an unplanned and amorphous or ambiguous pattern it
can have more serious impacts on ecosystem function. Rapidly developing landscapes can result
in stream degradation due to increases in stormwater runoff, sedimentation and other pollutants,
and riparian habitat losses. Measures that may mitigate these impacts include preservation of
forested stream buffers of appropriate size,reduction of impervious surfaces, and effective
stormwater treatment.
The recommendations presented in this document to avoid or mitigate these impacts are
based on the best available science and were obtained by a synthesis of scientific information in
journals,publications, reference books, and personal communication with professionals familiar
with North Carolina aquatic species and other natural resources. However,the recommendations
may be revised as more information becomes available about species' habitat requirements and
measures necessary to protect aquatic and terrestrial habitat and water.quality.
General Mitigation Measures for All Watersheds (more extensive measures apply to
watersheds that support federal endangered and threatened species)
Although riparian zones constitute a small percentage of the landscape, they frequently
perform important ecological functions and contain a disproportionately high number of wildlife

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August 2002
CSI Mitigation Measures
species in comparison to most upland habitats (Fischer et al. 2000;Knutson and Naef 1997). As
a matter of policy,the American Fisheries Society strongly urges that riparian areas be
considered unique and distinctly valuable habitats, and that such areas be declared of critical
environmental concern (AFS 1985). Riparian areas perform many functions that are essential to
maintaining water quality, aquatic species survival, and biological productivity.
With regards to the measures required to protect streams from pollutants,the further the
intervention occurs from the source,the greater the costs to society (Reeves et al. 1991);
resulting in a gradient from prevention to interdiction to restoration(Waters 1095). Watershed
protection has been the most successful method of habitat rehabilitation(Reeves et al. 1991);
however, given the difficulty of totally preventing or eliminating pollutants (e.g. sediment) at the
source, interdiction such as the use of riparian buffers is an important tool in reducing damage to
streams (Waters 1995). The functions of riparian zones are well documented and convey
sometimes subtle but critical benefits to society. These functions are listed below.
Forested riparian area functions
• Reduce pollutants and filter runoff
• Improve air quality and lower ozone levels
• Maintain stable water flows
• Help sustain natural channel morphology
• Help maintain water and air temperature by providing shade
• Stabilize stream banks
• Provide most of the organic carbon and nutrients to support the aquatic food web
• Provide sources of large woody•debris for the stream channel
• Help reduce,the severity of floods
• Facilitate the exchange of groundwater and surface water
• Provide critical wildlife habitat
Numerous studies have evaluated buffer widths needed for stream protection. Often
these have focused on a single parameter,which has resulted in a large variation in
recommended buffer widths (Appendix A). For a buffer to effectively perform for all riparian
processes,wider contiguous buffers (100-300 feet) are recommended (Knutson and Naef 1997;
May and Horner 2000; Martin et al. 2000;Palik et al. 2000; Richards and Hollingsworth 2000;
Stewart et al. 2000). Effective buffer sizes depend upon specific site conditions, such as slope
and soil type. Although variable widths may be more applicable in some circumstances,they are
often more difficult to understand, implement, and enforce. Therefore,we offer generalized
recommendations of minimum buffer widths for predictable application across the North
Carolina landscape. Because specific conditions differ, some deviations from the general
recommendation may be acceptable, however deviations should be kept to a minimum.
Discussions regarding buffers or riparian corridors refer to forested buffers where the dominant
vegetation consists of native trees and shrubs.
Streams with wide, forested riparian corridors in developed areas are essential for the
protection of water quality and aquatic habitats. Natural riparian corridors are diverse, dynamic,
and complex biophysical habitats (Naiman et al. 1993), and riparian ecosystems have the
greatest,vulnerability to alteration (Knutson and Naef 1997; and references therein). The
maintenance of riparian habitat may yield the greatest gains for aquatic and terrestrial wildlife
across the landscape while involving the least amount of area.
Numerous significant and negative consequences can result when headwater streams are
lost(Meyer and Wallace 2001), and the effects of degradation accumulate;therefore,the
condition of the stream in the lower reaches is closely dependent on the condition in the

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August 2002
CSI Mitigation Measures
headwaters (Vannote et al. 1980). In addition,headwater streams can significantly reduce
nutrient export to rivers (Alexander et al.2000; Peterson et al. 2001).
1. We recommend the maintenance or establishment of a minimum 100-foot native forested
buffer along each side of perennial streams and 50-foot native forested buffer along each
side of intermittent streams and wetlands throughout the present and future service areas
or the entire municipal jurisdiction (EPA 2000; Stewart et al. 2000). We additionally
encourage the implementation of buffers on ephemeral streams due to the important
functions that they provide as headwater streams (Alexander et al. 2000; Peterson et al.
2001). Buffers should be measured horizontally from the edge of the stream bank
(Knutson and Naef 1997),which may result in wider buffers on higher gradients, and
must be provided over the entire length of stream, including headwater streams. Further,
we recommend leaving 30%of the development area as greenspace,which would include
buffers and wetlands and ensure that the greenspace is connected to natural resources.
Wide, contiguous riparian buffers have greater and more flexible potential than other
options to maintain biological integrity (Horner et al. 1999) and could ameliorate many
ecological issues related to land use and environmental quality (Naiman et al. 1993). As
expansion of developed areas continues into the watershed,wildlife habitat can change,
become fragmented, and even disappear. Riparian buffers provide travel corridors and
habitat areas for wildlife displaced by development. In addition,riparian buffers serve to
protect water quality by-stabilizing stream banks, filtering capacity of stormwater runoff,
and provide habitat for aquatic and fisheries resources.
2. We recommend that delineation of streams be conducted for the municipal service area
according to U. S. Army Corps of Engineers (USACOE) or N. C. Division of Water
Quality (NCDWQ)methodology. This information can be found at
http://h2o.enr.state.nc.us/ncwetlans/strmfrm.html (accessed May 2002). U. S. Geological
Survey (USGS) maps underestimate the extent of streams. Recent research has shown
that USGS maps can underestimate total stream length in the Piedmont of North Carolina
by 25 % (Gregory et al. in press).
3. We recommend that sewer lines,water lines, and other utility infrastructure be kept out
of riparian buffer areas (Knutson and Naef 1997; and references therein). All utility
crossings should be kept to a minimum,which includes careful routing design and the
combination of utility crossings into the same right-of-way (provided there is not a safety
issue). Discontiguous buffer segments can impair riparian functions disproportionate to
the relative occurrence of the breaks in the buffer(May and Horner 2000; Van Sickle
2000), and multiple crossings can result in cumulative impacts. The directional bore
(installation of utilities beneath the riverbed, avoiding impacts to the stream and buffer)
stream crossing method should be used for utility crossings wherever practicable, and the
open cut stream crossing method should'only be used when water level is low and stream
flow is minimal. Manholes or similar access structures should not be allowed within
buffer areas. Stream crossings should be near perpendicular(75'to 105°)to stream flow
and should be monitored at least every three months for maintenance needs during the
first 24 months of the project and then annually thereafter. Sewer lines associated with
crossing areas should be maintained and operated at all times to prevent the discharge to
land or surfacematers. We recommend a minimum 50-100 feet setback on all streams,,
lakes, and wetlands for these structures,which falls in line with the recommended buffer
widths. In circumstances where minimum setbacks cannot be attained, sewer lines shall
be constructed of ductile iron or other substance of equal durability. Further,pesticides

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CSI Mitigation Measures
(including insecticides and herbicides) should not be used for maintenance of rights-of-
way within 100 feet of perennial streams and 50 feet of intermittent streams, or within
floodplains and wetlands associated with these streams.
4. Avoid the removal of large trees at the edges of construction corridors. Re-seed
disturbed areas with seed mixtures that are beneficial to wildlife. Avoid fescue based
mixtures because fescue is invasive and provides little benefit to wildlife. Native, annual
small grains appropriate for the season are preferred and recommended (See
http://www.esb.enr.state.nc.us/wetplant/wetland_plants.htm, and
http://www.co.mecklenburg.ne.us/coeng/Storm/services/vegetation/vegetation.htm).
Where feasible,use woody debris and logs from corridor clearing to establish brush piles
and downed logs adjacent to the cleared right-of-way to improve habitat for wildlife.
Allowing the corridor area to revegetate into a.brush/scrub habitat would maximize
benefits to wildlife. For areas adjacent to residential areas, a native shrub/grass option
may also be beneficial. Minimize corridor maintenance and prohibit mowing between
April 1 and October 1 to minimize impacts to nesting wildlife. We suggest a
maintenance schedule that incorporates only a portion of the area—one third of the area,
for example—each year instead of the entire project every 3 or 4 years. Herbicides and
pesticides should never be used in wetland areas or near streams, as described above in
item 3.
5. We recommend that the local governments prohibit commercial or residential
development within the 100-year floodplain. Undeveloped floodplains strongly influence
aquatic systems, support a combination of riparian and upland vegetation used by aquatic
and terrestrial wildlife, supply a rich source of food to aquatic communities (Junk et al.
1989), and provide an important sediment trapping function(Palik et al. 2000). The
filling of floodplains increases the potential for flooding of adjacent properties and
interferes with the natural hydrologic process of the waterways. It also disrupts the
continuity of migration corridors for wildlife. Instead,we recommend that developers set
aside a portion of the land to be developed as green space and concentrate these areas
along the streams and rivers (see Item 1 above). In addition we encourage"infill" (new
development in unused or underutilized land in existing urban areas) development in
urbanized portions of the jurisdiction and recommend the site practices for infill and
brownfield development issued by the U. S.Environmental Protection Agency (EPA)
(http://www.epa.gov; accessed May 2002)and the Center for Watershed Protection
(http://www.cwp.org/; accessed May 2002). Floodplain maps may need to be updated to
reflect development of the watershed. Floodplain remapping studies in Charlotte showed
that buildout conditions would result in a floodplain width change from an average of
429 feet to 611 feet
(http://www.co.mecklenburg.nc.us/coeng/storm/floodinfo/floodmaps.htm; accessed May
2002)
6. We recommend that the local government limit impervious surfaces to less than 10%of
the watershed(Schueler 1994;Arnold and Gibbons 1996; Doll et al. 2000; Mallin et al.
2000; May and Horner 2000; Stewart et al. 2000; Paul and Meyer 2001). The
construction of roadways and other impervious surfaces in new neighborhoods can
produce short-term direct impacts as well as long-term cumulative effects. Multiple
studies have shown that stream degradation occurs at approximately 10% coverage by
impervious surfaces (Schueler 1994; Arnold and Gibbons 1996; Doll et al. 2000; Mallin
et al. 2000; May and Horner 2000; Stewart et al. 2000;Paul and Meyer 2001). Likewise,
the Wake County Watershed Management Plan Task Force performed a correlation

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CSI Mitigation Measures
analysis of impervious surfaces to watershed classification based on water quality data,
and they found that watersheds of unimpaired streams averaged 8% imperviousness,
impacted streams averaged 11%, and degraded streams averaged 24%
(http://projects.ch2m.com/WakeCounty/; accessed May 2002).
We also recommend that the local government provide for sufficient open space to
effectively reduce impervious surface so that predevelopment hydrographic conditions
are maintained, limit curb and gutter in new developments, and prevent direct discharges
of stormwater into streams. To achieve no net change in the hydrology of the watershed,
we recommend installation of grassed swales in place of curb and gutter and on-site
stormwater management(i.e.bioretention areas or other attenuation measures). These
designs often cost less to install (Kwon 2000) and significantly reduce environmental
impacts from residential development. Information regarding financing stormwater
management can be found at http://stormwaterfinance.urbancenter.iupui.edu/(accessed
May 2002).
Many of these recommendations have been applied in Maryland to protect the
Chesapeake Bay from water quality degradation(MDE 2000). Suggested examples to
accomplish the<10%impervious goal are using conventional designs at a level of<10%
imperviousness or using conservation clusters with higher densities,with dedicated open
space and other stormwater control measures to mimic the hydrograph consistent with an
impervious coverage of less than 10%. Reduction of road widths is one method to reduce
overall impervious surface coverage. The N. C. Department of Transportation(NCDOT)
has issued road guidelines that allow for the reduction in street widths when compared to
standard secondary road guidelines. This material can be found at
http://www.doh.dot.state.nc.us/operations/tnd.pdf(accessed May 2002). In addition,
there are site planning practices that,when incorporated with the above mentioned road
building guideline, can further reduce the amount of impervious surface within a site (see
recommendations in the document Better Site Design(Center.for Watershed Protection;
http://www.cwp.org/; accessed May 2002).
7. Use bridges for all permanent roadway crossings of streams and associated wetlands to
eliminate the need to fill and culvert,where practicable. If culverts must be used,the
culvert should be designed to allow passage of aquatic organisms. Generally,this means
that the culvert or pipe invert is buried at least one foot below the natural streambed. If
multiple cells are required, the second and/or third cells should be placed so that their
bottoms are at stream bankfull stage. This will allow sufficient water depth in the culvert
or pipe during normal flows to accommodate movements of aquatic organisms. If
culverts are long and sufficient slope exists,baffle systems are recommended to trap
gravel and provide resting areas for fish and other aquatic organisms. If multiple pipes or
cells are used, at least one pipe or box should be designed to remain dry during normal
flows to allow for wildlife passage. In addition, culverts or pipes should be situated so
that no channel realignment or widening is required. Widening of the stream channel at
the inlet or outlet of structures usually causes a decrease in water velocity causing
sediment deposition that will require future maintenance. Finally,riprap should not be
placed on the streambed. ,
8. We recommend that municipalities incorporate the elements listed below into their
erosion and sediment control plans (see Brown and Caraco 2000 for additional
information). Sediment is considered the most important cause of water pollution in the

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CSI Mitigation Measures
United States (Waters 1995), and construction is considered the most damaging phase of
the development cycle to aquatic resources (Brown and Caraco 2000).
a) Minimize clearing and grading and only perform these operations in the context of an
overall stream protection strategy.
b) Protect waterways by preventing clearing adjacent to waterways, and stabilize
drainage ways.
c) Phase construction for larger construction sites (>25 acres)to reduce the time and
area that disturbed soils are exposed.
d) Stabilize soils as rapidly as possible(<2 weeks) by establishing a grass or mulch
cover.
e) Protect steep slopes, and avoid clearing or grading existing steep slopes as much as
possible.
f) Establish appropriate perimeter controls at the edge of construction sites to retain or
filter concentrated runoff from relatively short distances before it leaves the site.
g) Employ advanced settling devices that contain design features which include greater
wet or dry storage volume,perforated risers,better internal geometry, use of baffles,
skimmers and other outlet devices, gentler side-slopes, and multiple cell construction.
h) Implement a certified contractors program so that trained and experienced contractors
are on-site.
i) Sedimentation impacts should be minimized by regular inspection of erosion control
measures, and sediment control devices should be maintained in good and effective
condition at all times. Erosion and sediment controls should be reassessed after
storms. The incorrect installation of erosion control.structures and those not properly
maintained can result in sedimentation impacts to nearby streams and wetlands.
Specific Mitigation Measures for Waters Containing Federally Listed Species
Federally endangered and threatened species are particularly affected by secondary and
cumulative impacts associated with urban development due to their sensitivity to habitat
degradation and resulting high probability of extirpation. A high proportion of listed species
occurs within portions of the state that are developing the most rapidly; some have lost major
reaches of their habitats within the past few decades, others are in danger of being extirpated
from entire river basins, and one species has been extirpated from the state, and thus is extinct
(Carolina Elktoe,Alasmidonta robusta). It is not just single species that are in danger of being
lost in some systems, but entire faunas and communities.
For those watersheds that support federally endangered and threatened species,the
following additional conditions shall be followed. These measures provide a higher degree of
protection and also serve to protect the state-listed species and the general biotic integrity of
these systems. The natural resource agencies' concerns regarding indirect effects to threatened
and endangered species will be alleviated by adoption of these measures.. The attached map
(Appendix B) shows the location of NCDWQ designated 14 digit hydrologic unit code (HUC)
drainage basins that support federally endangered and threatened species, and provide an
indication of where the more extensive measures will apply. This map may be updated, as more
information becomes available.
Stormwater

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1. Permits for new developments exceeding 6% imperviousness shall be required to include
stormwater controls designed to replicate and maintain the hydrographic condition at the
site prior to the change in landscape and at a minimum include provisions that satisfy WS
II-HQW minimum standards (WSII-HQW waters as precedent; Schueler 1994; Arnold
and Gibbons 1996;Doll et al. 2000;Mallin et al. 2000; May and Horner 2000; Stewart et
al. 2000). This can be achieved through a variety of measures (see Item 6 above).
2. Insufficient information exists in the literature for the minimum buffer widths necessary
to ensure the continued survival of federally endangered and threatened aquatic species.
Therefore,the following minimum buffer recommendations are based on the best
scientific information available and the opinion of biologists most familiar with the
species in the state. The minimum recommended buffer widths may actually need to be
more or less stringent; and therefore,recommended widths may be modified as more
information becomes available. A 200-foot native, forested buffer on perennial streams
and a 100-foot forested buffer on intermittent streams, or the full extent of the 100-year
floodplain, shall be required for new developments. Detailed studies have resulted in
recommendations of 200-foot buffers and wider for protection of priority habitats in the
U. S. (Knutson and Naef 1997, and references therein;'Martin et al. 2000;Richards and
Hollingsworth 2000). If wooded buffers do not exist,then these areas shall be
revegetated or allowed to naturally revegetate (so long as the area is pervious)to increase
the functionality of a forested buffer. (Knutson and Naef 1997, and references therein;
200-foot buffers on Randleman Lake;200-foot buffers associated with protection of
aquatic endangered species habitats required for Buckhorn Reservoir Expansion Project
in 1995—City of Wilson).
3. Grassed swales shall be used in place of curb and gutter for new developments, except in
areas with>5%slope. Check dams, level spreaders, and other associated best
management practices shall be used to minimize the effect of stormwater runoff entering
the riparian buffer areas. In areas where slopes exceed 5%, stormwater collected in piped
conveyance systems shall be directed away from surface waters and best management
practices shall be employed at both the intake and the outlet areas. Curbs and gutters
may be used in combination with sidewalks in areas where clustering of uses increases
the net local density to a level greater than 4 dwelling units per acre. This will separate
the pedestrian portion of a street-scape from the automobile portion and will encourage
greater pedestrian mobility within the cluster development(see recommendations in
Pedestrian Facilities Users Guide at
http://www.walkinginfo.org/insight/features articles/userguide.htm; accessed May.
2002). Clustering development away from riparian areas will also allow for greater
stream protection.
4. We recommend that that direct discharges of stormwater to streams not be allowed.
Effective energy dissipation at the pipe outlet shall be accomplished to prevent scour of
the stream channel and buffer. Stream habitats are maintained most effectively when
stormwater runoff is dispersed through a vegetated or grassed buffer zone prior to
entering the riparian buffer. The ditching or piping of stormwater except when used in
combination with grassed swales, level spreaders and check dams shall not be allowed in
the riparian buffer. At no time should any mandated vegetated buffer zone be used for
these engineered devices. In addition,the use of trees—particularly, evergreen species—
can be an effective component of an integrated stormwater management plan and can
reduce the amount of surface water runoff by as much as 7%on a site due to interception,
transpiration, and other processes (see http://www.sustainable-

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CSI Mitigation Measures
communities.agsci.ubc.ca/bulletins/TB—issueforest.pdf, and
http://wcufre.ucdavis.edu/urban.htm; accessed May 2002).
5. Emergency management procedures shall provide for the containment of runoff from
fighting residential, commercial,or industrial fires and for the removal and clean up of
any hazardous spills that may endanger nearby streams, instead of flushing contaminants
into waterways.
Wastewater Infrastructure
1. Force mains shall be used to the greatest extent practicable. Gravity sewer lines shall be
installed to follow along the outside of the 100-year floodplain contour unless topographic
features, existing development,or other conditions restrict this technique.
2. Public and private sewer lines adjacent to streams shall parallel streams and be sited as
far as practicable from stream and tributary corridors (Knutson and Naef 1997; and
references therein). A minimum 200-foot buffer shall be provided for perennial streams
and a 100-foot buffer for intermittent streams to maintain the integrity of the buffer or the
full extent of the 100-year floodplain. Sewer lines close to streams shall be constructed
of ductile iron or other substance of equal durability, similar to the guidance under the
general.mitigation measures item number 3.
3. No new sewer lines or structures shall be installed or constructed in the 100-year
floodplain or within 50 feet of wetlands associated with a 100-year floodplain(Knutson
and Naef 1997; and references therein).
4. Septic tanks, lift stations,wastewater treatment plants, sand filters, and other
pretreatment systems shall not be located in areas subject to frequent flooding(areas
inundated at a 10-year or less frequency)unless designed and installed to be watertight
and to remain operable during a 10-year storm. Mechanical or electrical components of
treatment systems shall be above the 100-year flood level or otherwise protected against
a 100-year flood'(As per rule 15A NCAC 18A .1950—Location of Sanitary Sewage
Systems).
5. Only aerial crossings elevated sufficiently to reduce the risk of flood damage or
directional boring stream crossings shall be allowed. The placement of these crossings
will be limited to major stream or creek confluences. Manholes or similar access
structures shall not be allowed within buffer areas. Stream crossing areas shall be
monitored once a quarter for maintenance needs.
Water and Utility Infrastructure (Electricity, Telecommunications, and Gas)
1. All water lines and utilities shall follow roads or meet the requirements associated with
sewer line placements (Killebrew 1993;Knutson and Naef 1997; and references therein).
Stream crossing guidance is presented under the general mitigation measures item
number 3.

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CSI Mitigation Measures
Maintenance of Rights-of-Ways
1. Insecticides and herbicides shall not be used-within 200 feet of streams, floodplains, and
associated wetlands (Knutson and Naef 1997; and references therein) except when
needed to protect native flora and fauna from exotics and when using appropriately
labeled products, such as biopesticides (http://www.epa.gov/pesticides/biopesticides/;
accessed May 2002).
2. Native, forested plant communities shall be maintained within 200-foot buffer area of
streams, floodplains, and associated wetlands. A closed canopy will be maintained over
streams. Emphasis will be placed upon trimming trees, instead of tree removal,within
200 feet of streams, floodplains, and associated wetlands (Knutson and Naef 1997; and
references therein).
Sediment and Erosion Control
1. In addition to the items listed under the general mitigation measures, locally enforced
stringent erosion and sedimentation control requirements shall be developed and
implemented for all construction. The development of these requirements shall be fully
coordinated with the state and federal agencies involved in aquatic endangered species
protection. These measures shall be state-of-the-science and significantly exceed state
minimum requirements for sediment and erosion control. Local ordinances shall be
developed to prevent"forestry exemptions"from turning into development opportunity
without meeting the conditions identified in this memorandum.
2. Fill or buildings shall not be allowed in the 100-year floodplain(as described in previous
sections).
Additional Recommendations for Federally Listed Species
1. The local government shall solicit assistance and concurrence from resource agencies
such as NCDWQ,N. C. Division of Land Resources,NCWRC,N..C.Natural Heritage
Program, and USFWS during the initial development and assessment of best management
practices for stormwater management, sediment and erosion control, utility placement,
etc.
2. Maps shall be developed of the anticipated construction lines of utilities associated with
expanded service areas. This information shall become part of a Geographic Information
System(GIS) database housed and maintained by the local government. Surveys or
reviews will use maps and field determinations,when necessary, in conjunction with
USACOE and NCDWQ delineation criteria for wetlands and waters. As infrastructure or
development is planned or developed, field surveys should be conducted to assess
impacts and means to avoid impacts. Field surveys (delineation) or intensive map
reviews (including soil surveys,National Wetland Inventories (NWI)maps,USGS maps,
watershed protection maps of all wetlands and waters) shall be completed and mapped
with GIS technology. All GIS databases and associated files shall be provided to state
and federal agencies upon request.

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CSI Mitigation Measures
3. Local governments shall encourage and offer incentives for new developments, as part of
the subdivision review process,to use low impact development technique for stormwater
control (Low Impact Development;EPA Document# 841—B-00-002 and 84 1-B-00-003),
and reduce impediments to implementing the plan. Proposed projects that are subject to
NCEPA review shall identify as a part of the subdivision review process anticipated
impervious surface amounts prior to plat approval.
4. Developers and builders, including land-clearing operators, shall be required to
participate in a local government stormwater and sediment erosion control education
program. Certification and bonding is recommended.
5. Infiltration practices(e.g.,reduced road widths, rain gardens,parking lot bioretention
areas, increased sheet flow instead of ditching;and disconnect impervious areas)to
maintain predevelopment hydrographic conditions shall be emphasized over detention
ponds. Condition information should include the base flow for low flow conditions.
6. Conservation Reserve Program lands and restoration of prior converted wetlands shall be
encouraged to help manage overall stormwater impacts as part of a regional integrated
stormwater management plan.
7. Site gas stations, car washes, and other"spill"land uses at least 200 feet from streams
and wetlands.
8. The local government shall provide an environmental check-off list that a developer must
complete before the issuance of development approvals to ensure protection of aquatic
habitats for threatened and endangered species and that proper state and federal permits
have been obtained. This shall preclude the issuance of any subdivision plan, building,
and utility permits without inclusion of pertinent protective measures. This process shall
ensure that land clearing does not occur without a site plan, including erosion control.
9. A watershed impact evaluation board shall be established to review projects within the
service area with aquatic, endangered species. The board would ensure compliance,
preview infrastructure and development plans, and be eligible to seek funding for
conservation initiatives designed to protect and preserve aquatic, endangered species.
10. We encourage local governments to consider retrofit options, including abandonment of
chronic problem areas especially where projects exist in floodplains and are on failing
septic systems. These areas should not be candidates for sewer service. Local
governments should explore all buyout opportunities of these areas prior to exploration of
providing sewer services to these areas. In addition,this should apply to schools and
other public institutions. These public facilities should be relocated to more suitable
areas. Local governments are encouraged to strengthen local land development codes to
ensure that privates lands donated to the public for usage of schools and other public
facilities (i.e. fire, police, or medical facilities) are located outside of the 100-year
floodplain so as to avoid future problems.
11. We recommend the use of conservation easements,public ownership, or deed restrictions
to ensure the perpetual conservation of natural buffer areas.

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Literature cited
AFS (American Fisheries Society). 1985. AFS policy statement#14: Strategies for stream
riparian area management. AFS,Bethesda,Maryland. Available:
http://www.fisheries.org/Public_Affairs/Policy_Statements/Index_policy_statements.sht
ml. (May 2002).
Alexander,R.B.,R. A. Smith, and G.E. Schwarz. 2000. Effect of stream channel size on the
delivery of nitrogen to the Gulf of Mexico. Nature 403:758-761.
Arnold, C. L., and C. J. Gibbons. 1996. Impervious surface coverage—the emergence of a key
environmental indicator. Journal of the American Planning Association 62:243-258.
Brown, W., and D. Caraco. 2000. Muddy water in-muddy water out? Watershed Protection
Techniques 2(3):393-403.
City of Wilson. 1995. EIS for the Buckhorn Reservoir Expansion.
Doll,B.A.,D.E. Wise-Frederick, C. M.Buckner, S. D. Wilkerson, W.A. Harman, and R. E.
Smith. 2000. Hydraulic geometry relationships for urban streams throughout the
piedmont of North Carolina. Pages 299-304 in P.J. Wigington, Jr. and R.L. Beschta, eds.
Proceedings of the American Water Resources Association International Conference on
riparian ecology and management in multi-land use watersheds,Portland, Oregon.
EPA(U. S. Environmental Protection Agency). 2000. Model ordinances to protect local
resources. EPA, Office of Water, Washington,D. C. Available:
http://www.epa.gov/owowwtrl/NPS/ordinance/index.htm. (May 2002).
Fischer,R.A., C. O. Martin, and J. C.Fischenich. 2000. Improving riparian buffer strips and
corridors for water quality and wildlife. Pages 457-462 in P. J. Wigington, Jr. and R. L.
Beschta, eds. Proceedings of the American Water Resources Association International
Conference on riparian ecology and management in multi-land use watersheds,Portland,
Oregon.
Gregory, J. D.,E. Fleck, S. D. Smith, D. Penrose, J. Lawson, and R. Darling. In press.
Defining, identifying, and mapping headwater streams in North Carolina. Water
Resources Research Institute, University of North Carolina,Raleigh.
Horner,R. R., C. W. May, E. H. Livingston, and J.Maxted. 1999. Impervious cover, aquatic
community health, and stormwater BMPs: is there a relationship? Proceedings of the
- Sixth Biennial Stormwater Research Conference,Tampa,Florida.
Junk, W. J.,P. B. Bayley,and R. E. Sparks. 1989. The flood pulse concept in river-floodplain
systems. Pages 110-127 in D.P.Dodge, ed. Proceedings of the International Large
River Symposium. Canadian Special Publication of Fisheries and Aquatic Sciences 106,
Ottawa.
Killebrew, C.,J. 1993. Oil and gas activities. Pages 209-220 in C. F. Bryan and D. A.
Rutherford, eds. Impacts on warmwater streams: guidelines for evaluation. Southern
Division,American Fisheries Society,Little Rock,Arkansas.

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Knutson,K. L., and V. L.Naef. 1997. Management recommendations for Washington's priority
habitats: riparian. Washington Department of Fish and Wildlife, Olympia.
Kwon, H. 2000. An introduction to better site design. Watershed Protection Techniques
3(2)623-632.
LeGrand, J. E., Jr., S. P. Hall, and J. T. Finnegan. 2001. Natural Heritage Program list of the
rare animal species of North Carolina. North Carolina Natural Heritage Program,
Division of Parks and Recreation,Department of Environment and Natural Resources,
Raleigh.
Mallin,M.A.,K.E. Williams,E. C.Esham, and R. P. Lowe. 2000. Effect of human
development on bacteriological water quality in coastal watersheds. Ecological
Applications 10:1047-1056.
Martin, C. O.,R.A. Fischer, and H.H.Allen. 2000. Riparian issues on Corps of Engineers and
DOD Military Lands. Pages 317-322 in P. J. Wigington, Jr. and R. L. Beschta, eds.
Proceedings of the American Water Resources Association International Conference on
riparian ecology and management in multi-land use watersheds,Portland, Oregon.
May, C. W., and R. R. Horner. 2000. The cumulative impacts of watershed urbanization on
stream-riparian ecosystems. Pages 281-286 in P. J. Wigington,Jr. and R. L. Beschta,
eds. Proceedings of the American Water Resources Association International Conference
on riparian ecology and management in multi-land use watersheds,Portland, Oregon.
MDE(Maryland Department of the Environment). 2000. 2000 Maryland stormwater design
manual,volumes I and II. Center for Watershed Protection and MDE,Water
Management Administration, Baltimore,Maryland. Available:
http://www.mde.state.md.us/environment/wma/stormwatermanual/. (May 2002).
Meyer, J.L., and J. B. Wallace. 2001. Lost linkages and lotic ecology: rediscovering small
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achievement and challenge. Blackwell Science, Oxford, U. K.
Naiman, R. J., H. Decamps, and M. Pollock. 1993. The role of riparian corridors in maintaining
regional biodiversity. Ecological Applications. 3:209-212.
North Carolina Progress Board. 2001. North Carolina 20/20 Report. Available:
http://www.ncpb.state.nc.us/scoreboard.htm. (May 2002).
Palik,B. J.,J. C.Zasada, and C. W. Hedman. 2000. Ecological principles for riparian
silviculture. Pages 233-254 in E. S. Verry, J. W.Hornbeck, and C. A.Dolloff, eds.
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Paul,M. J., and J. L. Meyer. 2001. Streams in the urban landscape. Annual Review of Ecology
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Peterson,B. J., W. M. Wollheim,P. J. Mulholland, J.R. Webster,J.L. Meyer, J. L. Tank,E.
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Reeves, G. H., J.D.Hall, T. D. Roelofs,T.L. Hickman, and C. O.Baker. 1991. Rehabilitating
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forest and rangeland management on salmonid fishes and their habitats. American
Fisheries Society Special Publication 19,Bethesda,Maryland.
Richards, C., and B.Hollingsworth. 2000. Managing riparian areas for fish. Pages 157-168 in
E. S.Verry,J. W.Hornbeck, and C.A.Dolloff, eds. Riparian management in forests of
the continental eastern United States, Lewis Publishers, Boca Raton,Florida.
Schueler,T. 1994. The importance of imperviousness. Watershed Protection Techniques.
1(3):100-111.
Stewart, J. S., D.M.Downes,L.Wang, J.A. Wier], and-R. Bannerman. 2000. Influences of
riparian corridors on aquatic biota in agricultural watersheds. Pages 209-214 in P. J.
Wigington, Jr. and R.L. Beschta, eds. Proceedings of the American Water Resources
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river continuum concept. Canadian Journal of Fisheries and Aquatic Sciences 37:130-
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Van Sickle,J. 2000. Modeling variable-width riparian buffers,with an application to woody
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riparian ecology and management in multi-land use watersheds,Portland, Oregon.
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Fisheries Society Monograph 7,Bethesda,Maryland.
Williams, J. D., M.L. Warren,Jr.,K. S. Cummings,J. L. Harris, and R. J.Neves. 1993.
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endangered,threatened, or of special concern: 1989. Fisheries 14(6):2-20.

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Appendices
Appendix A.Minimum riparian habitat buffer widths needed to retain various riparian habitat
functions as reported in the literature.
Riparian habitat function Perpendicular distance Source
from
stream in meters (feet
inparentheses)
Filter Nutrients 36(118) Young et al. 1980(MN)
(General)
Filter Nitrogen 18(59)retention of only Daniels and Gilliam 1996(NC)
20-50%of surface
ammonium and 50%of
nitrite and nitrate
9(29)grass Dillaha et al. 1989 in Osborne and Kovacic
1993
30(98) Doyle,et al. 1977 in Osborne and Kovacic
1993
31(102)94%reduction in Hanson et al. 1994
ground water nitrate
30(100)78%reduction in Hubbard 1997(GA)
groundwater nitrate
16(52) Jacobs and Gilliam 1985 C
10(32) James,et al.(in press)in Osborne and
Kovacic 1993
55(180) Jordan et al. 1993 MD)
25 82 Lowrance,et al. 1984
10-40 33-131 Lowrance 1992 GA
16 52 or 39 127grass Osborne and Kovacic 1993 (IL)
19(62)—70-80%reduction Peter'ohn and Correll 1984(MD)
50 164 80-90%reduction Peter'ohn and Correll 1984(MD)
30(98) Pinay and Decamps 1988 in Osborne and
Kovacic 1993
27(88)grass Schnabel 1986 in Osborne and Kovacic
1993
30(98) Spruill 2000(NC)
17-20(56-66)or 31(100) Williams et al.2000(GA)
to produce lowest
simulated outputs
21(70)reduced surface N Young et al. 1980(MN)
by 67%and ammonium by
71%[recommended 40m
(118)]
27(88)grass Young,et al. 1980 in Osborne and Kovacic
1993

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CSI Mitigation Measures
Riparian habitat function Perpendicular distance Source
from
stream in meters (feet
in arentheses
Filter 10(32)-20(65) Aubertin and Patric 1974 in Osborne and
Sediment/Phosphorus Kovacic 1993 WV
Nearly 50%of 137Cs Cooper et al 1987(NC)
labeled sediment moved
over 100m(328)in riparian
area
16(52) Cooper and Gilliam 1987 in Osborne and
Kovacic 1993
6-18 20-59 Daniels and Gilliam 1996 C
9(30)(grass filter) Dillaha et al. 1989(VA);Dillaha et'al. 1988
(VA);Ma ette et al. 1989
9(29) Haupt and Kidd 1965 in Osborne and
Kovacic 1993 (ID
55 180 Jordan et al. 1993
Most sediment deposited Lowrance et al. 1988(GA)
within V 30(98)of buffer
but extends 80(262)in
riparian buffers
30(98)removed 75-80% Lynch et al. 1985
from storm water in logged
areas
28 92 for 81%efficiency Mander et al. 1997 Estonia
16(52)or 39 127 grass Osborne and Kovacic 1993 IL
19(62)trapped 90%of Peterjohn and Correll 1984(MD)
sediment
50(164)trapped 94%of Peterjohn and Correll 1984(MD)
sediment
50(164)for 84%total and Peterjohn and Correll 1984(MD)
73%soluble P removal
efficiency
15(49)-15(147) Trimble and Sartz 1957 in Osborne and
Kovacic 1993
30(100)recommended for Wenger 1999
trapping sediment
17-20(56-66)or 28(92)to Williams et al.2000(GA)
produce lowest simulated
outputs
21(69)for 67%total and Young et al. 1980(MN)
69%soluble P removal
efficiency
27(90)removed 93% Young et al. 1980(Iv";Horner and Mar
sediment from feedlot; 1982 in Castelle et al. 1994
23(75)removed only 33%
from dairy farm runoff

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CSI Mitigation Measures
Riparian habitat function Perpendicular distance Source
from
stream in meters(feet
in parentheses
Filter Contaminants 9(30)(fecal coliform/grass Coyne et al. 1998(KY)
filter
15-80(49-262)adequate Phillips 1989(NC)
for nonpoint source
pollution
Erosion Control 55 180 Jordan et al. 1993 MM
30 100 Raleigh et al. 1986 in Knutson and Naef
Stream Type 20x bankfA width each Llhardt,et al.2000(Eastern U.S.)
Maintenance side(E channel type
(Rosgen 1996) streams>10 ft wide at
bankfull and<5%slope)
IOx bankfull width each Llhardt,et al.2000(Eastern U.S.)
side(other channel type
streams>10 ft wide at
bankfull and<5%slope)
Entire floodplain+ Llhardt,et al.2000(Eastern U.S.)
>30(100)(For identifiable
floodplain and terrace
slopes)
>61(200) 5%slope) Llhardt,et al.2000 astern U.S.)
Large Woody Debris >30 100 Fetherston,et al. 1995(Pacific NW)
Majority of recruitment Knutson and Naef 1997(review)
within 45 148
46(150) Robinson and Beschta 1990
Water Temperature 10(32)-20(65) Aubertin and Patric 1974 in Osborne and
Control Kovacic 1993 WV
>30(100)provides shading Beschta et al. 1987 in Castelle et al. 1994
of old growth forest and Knutson and Naef
10(32) Brazier and Brown 1973 in Osborne and
Kovacic 1993 OR
12(39) Corbett,et al. 1978 in Osborne and Kovacic
1993 C
31(101) Lynch and Corbett 1990 in Osborne and
Kovacic 1993 (PN
Microclimdte Influence >45(148)and up to Brosofske,et al. 1997(WA)
300(985)
61-122 200-399 Chen et al. 1990 in Knutson and Naef

Page 21
August 2002
CSI Mitigation Measures
Riparian habitat function Perpendicular distance Source
from
stream in meters(feet
in arentheses
Food Resources >30(100)particulate Palik,et al.2000(Eastern U.S.)
organic matter O
Instream habitat and 73-275(240-902)semi- Burke and Gibbons 1995 (SC)
aquatic resources aquatic resources
>30(100)to minimize Davies and Nelson 1994(Australia)
short-term logging impacts
on streams
15-30(50-100)for Johnson and Ryba 1992 in Knutson and
minimum maintenance Naef
>30(100) May and Horner 2000(WA);Martin et al.
2000 MI,VA ;Stewart et al.2000 WI
>61(200) Richards and Hollingsworth 2000(Eastern
U.S.)
164(534)semi-aquatic Semlitsch 1998(multi state)
resources
Appendix A literature cited
Beschta,R. L., R. E. Bilby, G. W. Brown, L. B. Holtby, and T. D. Hofstra. 1987. Stream
temperature and aquatic habitat: Fisheries and forestry interactions. Pages 878-882 in A.
J. Castelle,A. W. Johnson, and C. Conolly. 1994. Wetland and stream buffer size
requirements—a review. Journal of Environmental Quality.
Brosofske,K. D., J. Chen,R. J.Naiman,and J.F.Franklin. 1997. Harvesting effects on
microclimate gradients from small streams to uplands in western Washington.
Ecological Applications 7:1188-1200.
Burke, V. J. and J. W. Gibbons. Terrestrial buffer zones and wetland conservation: A case study
of freshwater turtles in a Carolina Bay. Conservation Biology 9:1365-1369.
Chen,J.,J. F. Franklin, and T. A. Spies. 1990. Microclimatic pattern and basic biological
responses at the clearcut edges of old-growth Douglas-fir stands. In K. L. Knutson, and
V.L.Nae£ 1997. Management recommendations for Washington's priority habitats:
riparian. Washington Department of Fish and Wildlife, Olympia. 181 pp.
Cooper,J. R., J. W. Gilliam, R. B. Daniels, and W. P.Robarge. 1987. Riparian areas as filters
for agricultural sediment. Soil Science Society of America Journal 51: 416-420.
Coyne,M. S., R. A. Gilfillen,A. Villalba, Z.Zhang, R. Rhodes, L. Dunn, and R. L. Blevins.
1998. Fecal bacteria trapping by grass filter strips during simulated rain. Journal of Soil
and Water Conservation. 53(2):140-145.
Daniels,R. B. and J. W. Gilliam. 1996. Sediment and chemical load reduction by grass and
riparian filters. Soil Science Society of America Journal 60:246-251.

Page 22
August 2002
CSI Mitigation Measures
Davies,P. E. and M.Nelson. 1994. Relationships between riparian buffer widths and the effects
of logging on stream habitat, invertebrate community composition and fish abundance.
Australian Journal of Marine and Freshwater Resources 45:1289-1305.
Dillaha, T.A.,R. B. Reneau, S.-Mostaghimi, and D.Lee. 1989. Vegetative filter strips for
agricultural nonpoint source pollution control. Transactions of the ASAE 32(2):513-519.
Dillaha, T. A., J.H. Sherrard,D. Lee, S.Mostaghimi, and V. O. Shanholtz. 1988. Evaluation of
vegetative filter strips as a best management practice for feed lots. Journal of the Water
Pollution Control Federation 60(7):1231-1238.
Fetherston, K. L.,R. J.Naiman,R. E. Bilby. Large woody debris,physical process, and riparian
forest development in montane river networks of the Pacific Northwest. Geomorphology
13:133-144.
Hanson, G. C.,P.M. Groffman, and A. J. Gold. 1994. Denitrification in riparian wetlands
receiving high and low groundwater nitrate inputs. Journal of Environmental Quality
23:917-922.
Horner,R. R. and B. W. Mar. 1982. Guide for water quality impact assessment of
highway operations and maintenance. Pages 878-882 in A. J. Castelle,A. W. Johnson,
and C. Conolly. 1994. Wetland and stream buffer size requirements—a review. Journal
of Environmental Quality.
Hubbard, R. K. 1997. Riparian buffer systems for managing animal waste. In S. Wenger.
1999. A review of the scientific literature on riparian buffer width, extent and vegetation.
Institute of Ecology, University of Georgia,Athens, GA. 59 pp.
Jacobs, T. C. and J. W. Gilliam. 1985. Riparian losses of nitrate from agricultural drainage
waters. Journal of Environmental Quality 14(4):472-478.
Johnson,A. W. and D. M.Ryba. 1992. A literature review of recommended buffer widths to
maintain various functions of stream riparian areas. In K.L. Knutson and V. L.Naef.
1997. Management recommendations for Washington's priority habitats: riparian.
Washington Department of Fish and Wildlife, Olympia. 181 pp.
Jordan,T. E.,D. L. Correll, and D. E. Weller. 1993. Nutrient interception by a riparian forest
receiving inputs from adjacent cropland. Journal of Environmental Quality 22:467-473.
Knutson,K. L. and V. L.Naef. 1997. Management recommendations for Washington's priority
habitats: riparian. Washington Department of Fish and Wildlife, Olympia. 181 pp.
Llhardt, B. L., E. S. Verry, and B. J. Palik. 2000. Defining riparian areas. Pages 23-42 in E. S.
Verry,J. W. Hornbeck, and C. A. Dolloff, eds. Riparian management in forests of the
continental eastern United States,Lewis Publishers, Boca Raton,Florida.
Lowrance, R. 1992. Groundwater nitrate and denitrification in a Coastal Plain riparian forest.
Journal of Environmental Quality 21:401-405.
Lowrance, R. R., S.McIntyre, and C. Lance. 1988. Erosion and deposition in a
field/forest system estimated using cesium-137 activity. Journal of Soil and Water
Conservation 41(4):266-271.

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CSI Mitigation Measures
Lynch;J.A.,E. S. Corbett, and K. Mussallem. 1985. Best management practices for controlling
nonpoint source pollution on forested watersheds. Journal of Soil and Water
Conservation 40:164-167.
Magette, W. L.,R. B. Brinsfield,R.E. Palmer and J.D. Wood. 1989. Nutrient and sediment
removal by vegetated filter strips. Transactions of the ASAE 32(2):663-667.
Mander, U.,.V. Kuusemets, K.Lohmus, and T.Mauring. 1997. Efficiency and dimensioning of
riparian buffer zones in agricultural catchments. Ecological Engineering 8:99-324.
Martin, C. O., R. A.Fischer, and H.H. Allen. 2000. Riparian issues on Corps of Engineers and
DOD Military Lands.Pages 317-322 in P. J. Wigington,Jr. and R.L.Beschta, eds.
Proceedings of the American Water Resources Association International Conference on
riparian ecology and management in multi-land use watersheds,Portland, Oregon.
May, C.W. and R. R. Horner. 2000. The cumulative impacts of watershed urbanization on
stream-riparian ecosystems. Pages 281-286 in P. J. Wigington, Jr. and R. L. Beschta,
eds. Proceedings of the American Water Resources Association International Conference
on riparian ecology and management in multi-land use watersheds,Portland, Oregon.
Osborne, J.L. and D.A. Kovacic. 1993. Riparian vegetated buffer strips in water-quality
restoration and stream management. Freshwater Biology 29:243-258.
Palik,B. J., J. C. Zasada, and C. W. Hedman. 2000. Ecological principles for riparian
silviculture. Pages 233-254 in E. S. Verry, J. W. Hornbeck, and C:A. Dolloff, eds.
Riparian management in forests of the continental eastern United States,Lewis
Publishers, Boca Raton, Florida.
Peterjohn, W. T., and D. L. Correll. 1984. Nutrient dynamics in an agricultural watershed.
Observations on the role of a riparian forest. Ecology 65:1466-1475.
Phillips, J. D. 1989. Nonpoint source pollution control effectiveness of riparian forests along a
Coastal Plain river. Journal of Hydrology 110:221-237.
Raleigh,R. F., T. Hickman,R. C. Soloman, and P. C.Nelson. 1984. Habitat suitability
information: rainbow trout. In K. L.Knutson, and V. L.Naef. 1997. Management
recommendations for Washington's priority habitats: riparian. Washington Department
of Fish and Wildlife, Olympia. 181 pp.
Richards, C., and B. Hollingsworth. 2000. Managing riparian areas for fish. Pages 157-168 in
E. S. Verry, J. W. Hornbeck, and C.A. Dolloff, eds. Riparian management in forests of
the continental eastern United States,Lewis Publishers,Boca Raton,Florida.
Robison, E. G., and R. L. Beschta. 1990. Identifying tress in riparian areas that can provide
coarse woody debris to streams. Forestry.Science 36:790-801.
Semilitsch,R. D. 1998. Biological delineation of terrestrial buffer zones for pond-breeding
salamanders. Conservation Biology 12:1113-1119.
Spruill, T. B. 2000. Statistical evaluation of effects of riparian buffers on nitrate and ground
water quality. Journal of Environmental Quality 29:1523-1538.

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CSI Mitigation Measures
Stewart, J. S.,D. M. Downes,L.Wang, J. A. Wierl, and R.Bannerman. 2000. Influences of
riparian corridors on aquatic biota in agricultural watersheds. Pages 209-214 in P. J.
Wigington,Jr. and R. L. Beschta, eds. Proceedings of the American Water Resources
Association International Conference on riparian ecology and management in multi-land
use watersheds,Portland, Oregon.
Wenger, S. 1999. A review of the scientific literature on riparian buffer width, extent and
vegetation. Institute of Ecology,University of Georgia,Athens, GA. 59 pp.
Williams,R. G.,R. Lowrance, and S. P.Inamdar. 2000. Simulation of nonpoint source
pollution control using the riparian ecosystem management model (REMM). Pages 433-
438 in P. J. Wigington,Jr. and R. L. Beschta, eds. Proceedings of the American Water
Resources Association International Conference on riparian ecology and management in
multi-land use watersheds,Portland, Oregon.
Young,R. A., T. Huntrods, and W.Anderson. 1980. Effectiveness of vegetated buffer strips in
controlling pollution from feedlot runoff. Journal of Environmental Quality 9(3):483-
487.

T-
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CSI Mitigation Measures
wn
Appendix B. N. C. Division of Water Quality designated 14 digit hydrologic unit code (HUC)
drainage basins that support federally endangered and threatened species.
(July 2002: Map maybe updated as more information is acquired)

MEMORANDUM
March 19, 2008
TO: Hannah Stallings
SEPA Coordinator
FROM: Toya Fields
Western NPDES Program
SUBJECT: Richmond County Water Treatment Plant (WTP)
Environmental Assessment
NPDES staff has reviewed the revised EA for the proposed expansion of the Richmond
County Water Treatment Plant. This facility currently holds NPDES permit NC0081281.
Page 10 of the document states that "water currently discharged can be recycled to the settled
water plant, and then be used to create non-potable cooling water fir the Progress Energy Plant
in Richmond County. This is being incorporated into the design of the upgrade." We request
that the applicant submit a letter from Progress Energy stating that they are aware of
these plans and agree to accept a specific volume of wastewater from the Richmond
County facility. We also request a plant schematic/flow diagram detailing this proposed
disposal option.
The EA document goes on to state "The NPDES permit zoill remain in effect until its
expiration to provide redundancy for plant operation in the event of a line failure or similar
emergency, but will be used only as a backup to the proposed reuse plan". We would like
additional clarification on this statement. Is it Richmond County's intent to request
rescission of the NPDES permit upon completion of this expansion, or does the facility
intend to retain the permit as a backup disposal option? If a surface water discharge is
to be retained as a backup disposal option then Richmond County will need to modify
its NPDES permit to cover the additional wasteflo4 that will be generated as a result of
this expansion. As stated in our November 2007 comments, any increase in wastewater
will require the applicant to submit an Engineering Alternatives Analysis to NPDES
staff. The current NPDES permit does not allow the discharge of any wastewater in
excess of the facility's current capacity.
Richmond County's current NPDES permit expires on February 28, 2009. At that time,
the facility will receive additional monitoring requirements in accordance with the
Division's 2007 strategy for permitting conventional water treatment plants. That
strategy recommends a flow limit and whole effluent toxicity monitoring, along with
several other requirements. A copy of that document is attached.

MEMORANDUM
November 7, 2007
TO: Hannah Stallings
SEPA Coordinator
FROM: Toya Fields
Western NPDES Program
SUBJECT: Richmond County Water Treatment Plant(WTP)
Environmental Assessment
NPDES staff has reviewed the EA for this proposed expansion of the Richmond County
WTP. The document does not mention NPDES permit NC0081281 (currently held by
the facility) or the increase in wastewater(filter backwash)expected as a result of the
proposed expansion. There is also no discussion of the Engineering Alternatives
Analysis(EAA) or the permit modification that will be required by this proposed
expansion. Although the existing permit does not contain a flow limit, any change in
wastewater characteristics at this facility will require a permit modification. If any
change in wastewater treatment units is proposed,this project will also need to apply for
an Authorization to Construct permit.
I've attached the EAA guidance document. NPDES staff typically prefers that the EAA
is wrapped into the EA document to avoid potential unforeseen complications,however
the EAA may be submitted at a later time,if desired.

�OF W AT4 RQ Michael F.Easley,Governor
G William G.Ross Jr.,Secretary
rNorth Carolina Department of Environment and Natural Resources
.0 Coleen H.Sullins,Director
Division of Water Quality
October 9, 2007
MEMORANDUM
TO: Steven R. Gandy,Ph.D.,P.E.
Municipal Engineering Services Company,P.A.
FROM: Hannah Stallings
Division of Water Quality
SUBJECT: Richmond County
Water Treatment Plant—4.6 MGD Upgrade
DENR#1380,DWQ#13767
The Division of Water Quality offers the following comments:
1. The previous EA documented need for only a 4.0 MGD upgrade. What has called for an increase in the
requested capacity to 4.6 MGD?
2. The EA does not contain a clear purpose for the proposed.project. Please amend the text so it is easier to
discern whether the project's purpose simply to provide capacity for existing industry (while allowing
modestly for their expansion) or whether it also includes planned excess capacity for future service area
expansions.
3. Secondary and Cumulative Impacts (SCIs):
a. There are instances where terms are improperly used:
■ Page 14: "A secondary impact of the project as it applies to land use would be the increased runoff
from the larger amount of impermeable surface created through construction of the building."
■ This describes a direct impact of construction.
■ Page 14: "Cumulatively,the impact should be minor, and perhaps beneficial if topsoil removed is
relocated to farms which have experienced erosion and lack in good topsoil."
■ Incorrect usage of"cumulative impact."
■ Page 15: "To prevent secondary effects of sediment traveling off site to receiving streams and
ditches, silt fencing will be used at the edge of the construction limits to retain sediment lost due to
erosion in the even of precipitation or inclement weather."
■ This describes a direct impact of construction.
Please review the North Carolina Wildlife Resources Commission's Guidance Memorandum to Address
and Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and
Water Quality. This document provides definitions and examples of SCIs and also cites examples of
mitigative measures that can lessen the SCIs of projects.
Amend the above statements appropriately.
DAhCarolina
�lltifl'R�l'lf
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh,NC 27699-1617 Phone[phone] Customer Service
Internet: www.newaterguality.org Location: 512 N.Salisbury St. Raleigh,NC 27604 Fax [phone]
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

b. Page 13: "It should be noted that water supplied to the towns was at a level during the summer months
that extended to or surpassed the water treatment plant's capacity to produce. The ability to meet these
needs in the following year(s) is,therefore,not expected to culminate in secondary and cumulative effects
detrimental to the environment or community. The expansion will be sufficient to supply the [County's]
immediate need while allowing a buffer capacity for some limited growth. There will not,however,be
such excess that migration to the County is expected to overwhelm the natural resources and environment
in the proximity of the municipalities served, the demand for more water is currently on the distribution
system. Therefore, significant residential growth is unlikely,but rather the ability to supply.those
currently on failing wells or wells with poor water quality will be enhanced."
i. What is the planning horizon for the proposed project?
ii. While the extent of SCI may not"overwhelm"the local environment,SCI will nevertheless result
from this project.
c. While the direct impact of laying a distribution system to.serve"the Diggs community, southeast Hamlet,
the Hoffman community and extensions along Boyd Lake Road and NC 117"will not be realized with the
subject project,this project will allow for this enhancement at some later date. As noted on pages 1 and
2, this "expansion should allow for growth both in the industrial and residential areas after completion of
the expansion" and page 3 states that, "The expected expansions are to remedy supply problems
associated with . . . development pressures in currently non-serviced areas." Also,the discussion of
alternatives on page 4 acknowledges growth resulting from the proposed project: "With planned
expansions of the Diggs community, southeast Hamlet, extensions to the Hoffman community,it would
be unlikely that the smaller expansion of 2.3 MGD could facilitate incoming industry,residential
expansions and leave capacity to allow for future growth as the plant is currently operating near its design
capacity." Therefore,the impacts of laying the lines and the development that will take place within
those areas that will not receive immediate benefits from this expansion are the SCIs of this project and
must be covered under the Environmental Assessment(EA)written for this project and the Finding of No
Significant Impact(FNSI) issued by the State.
i. Please amend the main text of the EA appropriately to account for these impacts.
ii. Also, the "Secondary Impact Statement"in section H-9 needs to be updated to acknowledge the
secondary (and cumulative)impacts that will result from this project as already recognized in the
discussed distribution system expansion.
Please contact me at 733-5083,ext. 555,if I can be of any help in resolving these issues.
Thank you.