NC0024210_201 Facilities Plan_19971219

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
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December 19, 1997
TO. Bobby Blowe, Construction Grants & Lo SeCtI911
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THROUGH: Steve Tedder, Water Quality Section Chier
FROM: Coleen Sullins, Regional / Program Management CoordinatioALLcb,
Water Quality Section
RE: Final Comments on High Point Eastside Wastewater Treatment Plant
Upgrade and Expansion, 201 Plan & EA
High Point, Randolph and Guilford Counties
The Division has reviewed the revised EA and 201 Facilities Plan Amendment for
the City of High Point. In addition to the attached comments from Ron Linville, WSRO,
the Division has the following final comments on the project:
Due to the inter -relatedness of this proposed High Point Eastside Wastewater
Treatment Plant expansion and the proposed Randleman Reservoir, the
Division would like to reiterate previous DWQ comments on the water quality
issues related to this project. The Division remains concerned about the water
quality in the future Randleman Lake, and the effect of the expanded High
Point Discharge to this situation. Preliminary modeling of the watershed by
Hazen and Sawyer and Tetra -Tech indicate that the predicted water quality
concems in the future system would be phosphorous driven (predominantly
from the Eastside Plant) and that chlorophyll a standards may not be met
throughout the various segments of the lake, due to eutrophication that could
occur from predicted phosphorous concentrations. %
2. DWQ has committed to issuing a 401 Water Quality Certification on the
reservoir project, subject to the condition that Piedmont Triad Regional Water
Authority (PTRWA) develop a Nutrient Reduction Strategy and Watershed
Management Plan for the Randleman Lake Watershed. As discussed with
PTRWA on 10/24/97 and the City of High Point on 10/31/97, this Plan will
need to be developed to determine the level of nutrient reductions required in
the watershed to assure compliance with water quality standards and protecdon
of public health, aquatic life, and recreational uses in the future Randleman
Reservoir. The modeling being performed for this Plan will be required to
establish the maximum load of nutrients the reservoir can receive from all
sources. The Plan will also need to define the specific management strategies
necessary to achieve the nutrient reductions required, and demonstrate how
these reductions will be accomplished and sustained into the future for the
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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High Point Eastside WWTP EA
4P
WQ Section - Final Comments
December 19, 1997
page 2
watershed. This Plan is to be developed with DWQ involvement. The Plan
will have to be approved by the Governor and adopted into rules by the
Environmental Management Commission.
Ile City of High Point (along with all other local governments with planning
jurisdiction in the Randleman Watershed) will be required to address nutrient
contributions from existing and future land use changes and develop measures
to reduce nutrient loadings. This will more than likely require the
implementation of specific non -point source mitigation measures and land use
controls to reduce these loads.
3. In addition to reducing the phosphorous loads from other non -point sources in
the watershed, High Point will need to reduce -the discharge levels of
phosphorous from the Eastside Plant as much as possible, since it's
contribution to the reservoir's phosphorous load is estimated to be 8 1 % of the
total phosphorous load. As discussed at the October 31, 1997 meeting with
the City of High Point and their consultant, the High Point Eastside
Wastewater Treatment Plant would be required to meet the following limits -
0.5 mg/l Phosphorous - monthly average, year round
6.0 mg/l Nitrogen - monthly average during summer months
(April - Oct.)
If the City is interested in further reductions in the phosphorous limits with a
potential for an offset in the nitrogen limit, DWQ would consider such a
request. However, this proposal must be adequately addressed in the
modeling studies being prepared for the Nutrient Reduction Strategy and
Watershed Management Plan for the Randleman Lake Watershed.
My number is [phone], ext. 550 if there are any questions.
mls:\High Point/ final EA memo to CG&L
Eastside 201 Plan
cc: DWQ staff (10 copies)

DIVISION OF WATER QUALITY
Winston—Salem Regional Office
MEMORANDUM
TO:
Michelle Suverkrubbe
THROUGH:
Steve Mauney
FROM:
Ron Linville
VP
SUBJECT:
Comments on City of High Point
Eastside 201 Upgrade & Expansion
DATE:
971001
The WSRO has given this document a cursory review.
It is not certain that the exact nitrogen and phosphorus limits have been established that
are being utilized by the consultant. Depending on the impact of the proposed lake, post aeration
may need to be enhanced. Previous inspections have found leaking side walls in some treatment
units. Will these walls be repaired or replaced? In considering the plants historical performance
for potential exceedances, the consultant should review and consider the number of samples
taken per month and the analytical preciseness utilized for nickel. This metal is not currently
limited and may or may not have received the same scrutiny as limited parameters. The
document appears to adequately review Inflow from an engineering perspective utilizing average
flow values; however, the document needs to address instantaneous high flows and the
extraordinary activities required at the WWTP whenever these high flows have occurred.
(Essentially, only half the plant (8.0 MGD) is utilized to treat a disproportionate amount of high
flows while the other half is more or less shut down.) The WSRO does not view this as "not
excessive" as it causes minimal treatment. If an additional $10,000,000 is needed to resolve
some of the M then why is only $7,000,000 requested in the 1997 Bond Referendum? Is the
total amount needed $10 or $17 million?
The WSRO continues to believe that this expansion. is connected directly to the
Randleman Lake project and anticipated urbanization of the lake; therefore, the expansion should
also address secondary issues about the future watershed. To repeat our previous assertion, it
is very likely that the City of High Point will redouble their efforts to provide better watershed
protection,, wastewater treatment and water quality preventive measures as they will have vested
health and safety interests. The DWQ should emphasize that the state's watekshed protection
ggidelines, are minimums and not optimum ggidelines. The WSRO would encourage optimal
protection measures (especially in reducing future curb and gutter runoff by providing stringent
stormwater controls as well as providing for maximum wetland/stream and associated buffer
protection measures) instead of the state minimum requirements due to the magnitude of current
concerns and the predevelopment opportunity to avoid preventable degrading impacts.
cc: WSRO
Central Files

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