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HomeMy WebLinkAboutNC0024210_Environmental Assessment_19961001DIVISION OF WATER QUALITY October 1, 1996 MEMORANDUM TO: Michelle Suverkmbbe THROUGH: Ruth Cole Don FROM: Jasor SUBJECT: Revised Environmental Assessment High Point - Eastside W WTP Guilford County The Technical Support Branch has reviewed the revised Environmental Assessment (EA) prepared by Davis -Martin -Powell & Associates, Inc. for the City of High Point's proposal to expand the Eastside Wastewater Treatment Plant from 16 MGD to 26 MGD. The revised document was found to address most of the concerns raised in Farrell Keough's initial memo, dated May 1, 1996, but some items were overlooked in the revisions. Our comments are as follows: The current version of the document still does not contain a clear characterization of efforts that will be undertaken by the pemrittee to address the significant water quality concerns relating to several toxicant parameters discharged by the Eastside facility. Mr. Keough's memo specifically requested that effluent and instream data for cyanide, lead and nickel collected by the permittee be included in the document,And-ftf a thorough zzl-:i w, ill discussion of the mitigative measures planned to address the regularly high levels of the e parameters. Discharge monitoring reports from the Eastside plant have shown that the facility has regularly reported effluent levels of cyanide and nickel over the past two years that would constitute violations of the daily maximum limits stipulated in the facility's NPDES permit. In the last two years of available compliance data the facility has reported effluent levels as high as 130 µg/l for cyanide, 266 µg/1 for nickel and 18 µg/l for lead. Permitted daily maximum limits for these parameters are 5.0 µg/l, 88 µg/1 and 25 µg/1, respectively. If the proposed Randleman Reservoir is constructed for water supply purposes, this area of the Deep River and its tributaries would be reclassified as a water supply)and the Eastside W WTP permit limit for nickel would be lowered to 25 µg/1. Also during the past two year period, DWQ ambient stations, located immediately downstream of the High Point discharge on Richland Creek and the Deep River�have recorded frequently detectable amounts of lead and nickel instream. Lead has been recorded at instream levels as high as 24 µg/1, only 1.0 µg/1 shy of a water quality violation, and instream nickel levels have been reported as high as 26 and 27 µg/1. Monthly sampling at these ambient sites has historically resulted in frequent detections of nickel, often at levels in access of the 25 µg/1 instream standard for water supply waters. Given that water supply designation is a realistic potential in this area of the Deep River, and the resulting public health implications would need to be addressed, the EA should be revised to contain a specific plan as to what actions the City will take to deal with problem toxicants, such as potentially reissuing pretreatment permits with reduced metals allocations to achieve the lower loading levels to the WWTP. Thank you again for the opportunity to comment on the revised Environmental Assessment. Please let me know if I can be of any further assistance in this matter. cc: Winston-Salem Regional Office Dave Goodrich - Permits & Engineering Tom Poe - Pretreatment Central Files Page 1 Note for Jason Doll From: Coleen Sullins Date: Mon, Sep 30, 1996 4:16 PM Subject: RE: High Point Eastside EA To: Michelle Suverkrubbe Cc: Dave Goodrich; Jason Doll I think this is doable for us (Jason - advise if otherwise). I apolgize for creating problems on the deadlines. Unfortunately with well over 500 other permitting issues inhouse at anyone point in time (between discharge and nondischarge it is probably higher than that), it is very difficult for us to complete something as complex as an EA review in 2 or even 3 weeks. THis is the beginning of a permitting process - if we could spend the time upfront to get it right, the tailend of the process (the issuane of the permit) could be sped through much quicker with fewer hurdles and rocks in the road. If the issues are not thoroughly addressed in the EA, we end up being put in a very difficult situtation when we attempt to issue the permits (all sorts of acusations about trying to bypass the appropriate involvement by other interested parties). Plus we have even had to go back in and redo some environmental documents (Camp LeJeune, Cary to name a few EIS projects). And if that is not enough, we even have lawyers requesting that they be sent a copy of the secondary impacts analyses being done and threatening to sue us over improper procedures if they weren't adequately addressed. Hence my concern that this process not be unduly rushed and that we have an opportunity to get the documents in their best possible shape upfront. Coleen From: Michelle Suverkrubbe on Mon, Sep 30, 1996 2:51 PM Subject: RE: High Point Eastside EA To: Coleen Sullins I will hold my letter to the consultant until tomorrow or Wednesday to get your comments attached. Please let me know if you all cannot get your comments to me by then - I am going to send them a letter by Thursday no matter what. We can always add your comments during the DEHNR review stage. I am trying to do a better job expediting in-house EAs since lately I have gotten in a little bit of trouble for not making sure they get through DWQ in two -three weeks (that is what I was told to make happen). By the way, the first SEPA Workgroup meeting is set for Oct. 24 (Thursday) 10:30 to 12:30 in the 11th floor conference room. Hope to see you then. A final SEPA Workgroup list is being sent out to WQ Branch Heads, Steve T., and Bobby Blowe the end of this week. Michelle From: Coleen Sullins on Mon, Sep 30, 1996 2:00 PM Subject: RE: High Point Eastside EA To: Michelle Suverkrubbe Cc: Alan Clark; Jason Doll; Ruth Swanek Michelle - Jason and I just got a chance to talk about the Highpoint WWTP expansion. We Page 2 have problems with the toxicant data asssociated with this facility. Jason is putting together something on this one and hopes to have something done by tomorrow. THis is a significant issue since we have instream data that is above the WQ standards for certain metals. Coleen From: Michelle Suverkrubbe on Fri, Sep 27, 1996 5:10 PM Subject: High Point Eastside EA To: Coleen Sullins; Ruth Swanek Cc: Alan Clark I have not seen anything from you both on this revised EA (second time through DWQ), so I am assuming everything is OK (comment due date to me was 9/9). I am sending them a letter with the regional office's comments and a "go-ahead" to make changes for DEHNR review. If you have any further concerns with this project, please let me know and I will make sure you have an opportunity to comment on the revised document when it goes through DEHNR. FYI - The regional office was concerned with: 1) assurances that the abandoned outfall line under the landfill will be prevented from providing a "french drain" for leachate and, 2) they asked about additional automatic on -site power generation or redundant power lines for power outages. Thanks. Environmental DWO - Water Tracking Sheet erection ITidLT[U:7_\�t7it�i TO: Env. Sciences Branch * Wetlands Iff John Dorsey ❑ Eric Galamb (DoT) ❑ Greg Price (airports) ❑ Steve Kroeger Bio. Resources, Habitat, End. Species ❑ Trish MacPherson ❑ Kathy Herring (forest/oxw/ttQw) Toxicology ❑ Larry Ansley Planning Branch FROM: Michelle Suverkrubbe, Planning Branch IN Tecal Support Branch ch Colleen Sullins, P&E ❑ Dave Goodrich, P&E, NPDES ❑ Carolyn McCaskill, P&E, State ❑Y_..B radley Bennett, P&E, Stormwater III Ruth Swanek, Instream Assess. (modeling) ❑ Carla Sanderson, Rapid Assess. Operations Branch ❑ Dianne Wilburn, Facility Assessment ❑ Tom Poe, Pretreatment ❑ Lisa Martin, Water Supply Watershed Regional water Quality Supervisors ❑ Asheville ❑Mooresville ❑ Washington ❑ Fayetteville ❑ Raleigh ❑ Wilmington eWinston-Salem Attached is a copy of the above document. Subject to the requirements of the North Carolina Environmental Policy Act, you are being asked to review the document for potential significant impacts to the environment, especially pertinent to your jurisdiction, level of expertise or permit authority. Please check the appropriate box below and return this form to me along with your written comments, if any, by the date indicated. Thank you for your assistance. Suggestions for streamlining and expediting this process are greatly appreciated! 1 UU L.aLL lcaWl WU aL. phone: (919) 733-5083, ext. 567 fax: (919) 715-5637 e-mail: michelle@dem.ehnr.state.nc.us ml0ci emo.doc DAVIS - MARTIN - POWELL & ASSOCIATES, INC. dmp ENGINEERING LAND PLANNING • SURVEYING 218 GATEWOOD AVENUE • SUITE 102 HIGH POINT, NC 27262 PHONE (910) 886-4821 • FAX (910) 886-4458 August 19, 1996 Re: City of High Point, NC Eastside WWTP Expansion Environmental Assessment Job No. E-1971 (BF) Mr. Alan R. Clark Basinwide Planning Group DEHNR PO Box 29535 Raleigh, NC 27626-0535 Dear Mr. Clark: We are enclosing three (3) copies of the Environmental Assessment (EA) in regards to the referenced project which has been revised in accordance with your review comments. Additional exhibits depicting the service area, the Randleman Lake, and downstream Deep River waters are included. More detailed existing Deep River water quality information is included in Section 2.04. Additional mitigative measures have been added to and expanded upon in Section 8. Pretreatment program information has been added as Section 3.05. The September 18, 1995 speculative limits DEHNR letter has been added to Appendix A. These items, as, well as others mentioned in your review comments, are included in the revised EA. If the revised EA meets with your approval, please let us know and we will send additional copies to you for review by various agencies. Thank you for your cooperation in these regards. Very truly yours, DA MARTI POWELL & A CIATES t a L.KC-Neill/ P.E. RLM/res c: Mr. Perry Kairis Mr. Robert DiFiore File State of North Carolina Department of Environment, Health and Natural Resources Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director Mr. Randy McNeil Davis -Martin -Powell & Associates, Inc. 218 Gatewood Avenue, Suite 102 High Point, NC 27262 Dear Mr. McNeil: A�� "r****i Flit June 6, 1996 c_C,,,la r/ (,-p,r +SUN S+Li'i' Uil J fji(M-V +i RE: EA for High Point's Eastside Wastewater Treatment Plant Expansion and Upgrade My apologies for not having provided comments on the subject environmental assessment (EA) to you earlier. I have had a chance to review the EA and have included comments from our Division's Technical Support Branch. The EA does a reasonably good job of touching on many key issues and at least mentioning the possible primary and secondary impacts of the proposed expansion. It appears that most, although not all, of the comments from reviewers at the scoping stage had been addressed. For example, item 6 in the letter from the Division of Forest Resources was not included (acres of forest impacted) and a couple of items listed in the letter from DEM's regional office also need to be expanded upon (Section 7.02, below). Where the EA falls down is in the following areas: 1) not adequately defining the affected area, 2) inadequately describing the existing water quality of the Deep River and Richland Creek, 3) not quantifying some of the secondary impacts of development, and 4) failing to describe how, in Chapter 8, water quality and other environmental impacts associated with the enlarged discharge and increase in stormwater runoff from land use changes will be mitigated in Richland Creek and Deep River. Each of these is discussed in more detail, below: 1) Project Area Maps: First, the EA needs a map (or maps) that show the boundaries of both the existing and proposed service areas in addition to the WWTP facility location maps. These mapped lines represent the area in which development and land use changes will be taking place as a consequence of enlarging the plant. It is understood that the boundaries of the proposed service area may need to be estimated; however, this should not preclude making an effort to depict the extent of the future service area. As a minimum, the map should include municipal boundaries, major roads, major streams and lakes, major interceptors and the WWTP facility. Second, the EA should include a map of the waters downstream of the facility that are affected by the discharge. This should include a map of Richland Creek and the Deep River downstream from the plant to at least Carbonton Dam. Use support ratings of Richland Creek and the Deep River should be indicated on the map (color use support map attached). Third, a map also needs to be included of entire the proposed Randleman Reservoir. This should include the extent of the normal and flood pools as well as the WWTP discharge location. P.O. Box 29S3S, Raleigh, North Carolina 27626-OS3S Telephone 919-733-SO83 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer Mr. Randy McNeil June 6, 1996 Page 2 2) Water QXality: Biological and ambient water quality data collected by DEM indicate that water quality in Deep River below the plant is impaired. The discussion of surface waters in Section 2.04 needs to expanded. Information is available from the Randleman Reservoir EIS and DEM's Cape Fear Basinwide Water Quality Management Plan. 3) Secondarv�,; In addition to showing the service area, the EA should quantify the land area (acres or square miles) within the existing and proposed service areas and estimate before and after population. It should also include acres of land cover by major types within the existing and proposed service areas (can use types already mapped at city of county level), and to then quantify, to the extent possible, how these numbers will change by the time the plant is at full capacity. Of particular interest is the change in impervious surface area that will occur. This can be used to gain some understanding of the changes in stormwater runoff, expected changes in nutrient loadings and potential stream impacts from increased runoff rates and scouring. 4) Section 8 - Mitigative Measures: This project entails significantly increasing the size of a major wastewater treatment plant discharge just upstream of a controversial proposed water supply reservoir on a river whose water quality is considered impaired. The plant will facilitate increased development in the watershed draining to the reservoir which could have adverse affects on water quality in the reservoir and in other urban streams. The potential primary and secondary impacts of this project on the environment are significant. And yet the only mitigating measures listed in Chapter 8 address onsite erosion control, onsite construction limits 'and treatment system failure. Without adequate mitigation of the potential adverse impacts of this project a Finding of No Significant Impact (FONSI) could not be justified for this EA. To be fair, there are many potentially effective mitigating measures presented in chapter 7, not the least of which are some of the proposed improvements to the waste treatment plant and the ongoing improvements to the collection system to address significant inflow and infiltration problems. The mitigating measures presented in Section 7 need to be added to Section 8. They can either be repeated in Section 8, or preferably, a brief reference to mitigating measures can be included in various subsections of Section 7 with the more complete presentation of the mitigating measures placed in Section 8. This would help avoid repetition and use the available space in the EA most efficiently. (In regard to space and length, it is noted that the text is double-spaced. Making a single-spaced document should provide ample room to add the additional material requested while still meeting the 30-page limit.) While the above recommendation for beefing up Section 8 by moving mitigative measures from Section 7 will be helpful, a number of the mitigative measures need to be expanded upon. More specifically, a number of subsections in Section 7 make reference to impacts being mitigated by various local programs. However, it is unclear what these programs are, who the responsible governing agency is and how the programs will mitigate impacts. Each of the following programs needs to be described in sufficient detail to explain how the impacts will be mitigated and by whom. - Section 7.01 (Changes in Land Use) states that "adverse impacts from future development will be minimized by enforcement of local Planning and Zoning Ordinances." What are these adverse impacts and how will they be mitigated? - In Section 7.05, how will conducting development "consistent with local zoning regulations" mitigate the loss of agricultural lands due to growth that is facilitated by this project? - Section 7.08 needs to acknowledge that the increased development accommodated by this project will increase automobile usage which in turn can increase air emissions.. - In Section 7.10, what are the provisions of the "local watershed restrictions and zoning ordinances" that will mitigate the indirect effects of future residential and industrial development in the watershed area? y Mr. Randy McNeil June 6, 1996 Page 3 In Section 7.11, what are the "proper runoff control measures and proper stormwater management " measures that will be used to minim»E impacts of new development in the service area on shellfish or fish and their habitats. In Section 7.12, how will impacts to wildlife and their habitats be minimized by "local planning and Industrial Pretreatment Ordinances, as well as by local Stormwater Management Programs". Who are the responsible governing agencies for each of these programs and what are the provisions that will muMize impacts. To what extent will impacts be minimized, if at all? In regard to Section 7.02, Table 1 on page 29 needs to be expanded (or a new table added) to show the actual loadings in lbs/day of each of the listed parameters for existing limits at 16 MGD and the proposed limits at 26 MGD. For those parameters with summer and winter limits, corresponding summer and winter loadings should be presented. Also, Section 7.02 needs to be revised to address the comments contained in the attached May 1, 1996 memorandum from Farrell Keough to Alan Clark. In addition to more explicitly discussing the potential algal blooms in the proposed reservoir, what is being done to address those concerns listed at the bottom or the attached memorandum regarding cyanide, foaming and color in the effluent, and pretreatment opportunities. Please contact me if you have any questions. Sincerely, �L /( ZL.., Alan R. Clark Supervisor Basinwide Planning Group Attachment (May 1 memorandum) cc: Ruth Swanek Coleen Sullins Farrell Keough Boyd DeVane North Carolina Division of- Environmental Management Water Quality Section I Rapid Assessment Group May 1, 1996 MEMORANDUM To: Alan Clark From: Farrell Keoulox Through: Carla Sanderson CY Ruth Sw Don S t Subject: High Point - Eastside Waste Water Treatment Plant NCO024210 Guilford County Environmental Assessment I have reviewed the Environmental Assessment for the High Point - Eastside WWTP referenced as Job No. E-1971. We request the following be addressed : Section 7.02 Surface Water Quality I reviewed instream data, (attached) from the NCDEM Water Quality Ambient Monitoring Network. Data from two stations; 02.0994.8400 on Richland Creek at SR 1145 near High Point and 02.0995.0000 on Deep River at SR 1921 near Randleman was reviewed for nutrients. The Deep River Watershed has shown problems with the assimilative capacity of nutrients, therefore nutrient limits have been recommended for this proposed expansion. As indicated by this data, nutrients in these waterbodies are at levels which have a strong potential for algal blooms. This is especially acute at the Richland Creek site during the more critical summer months. This document should review this issue, especially as it relates to Randleman Lake and the increased residence time that could precipitate excessive algal growth. The instream monitoring taken by the facility should also be thoroughly reviewed in this document, with special attention to the issue of nutrient loading. The ambient monitoring stations also showed elevated levels of copper, lead, nickel, and zinc. Aluminum and sulfates were also detected. The levels for nickel would not meet the standard if the proposed Randleman Lake water supply reclassification is approved. Sulfates would also need to be reviewed if this proposed reclassification is approved. This situation needs to be thoroughly adder in this document. Instream monitoring for lead and nickel are required in the current permit, therefore review of this data should be included in this document as well as discussion of the data for its potential impact on the proposed water supply reclassification. Appendix A should contain the letter of speculative limits, dated September 18, 1995 sent to the Director of Utilities for the Town of High Point for verification that all recommended limits are being addressed. Appendix A contains a letter from the Winston-Salem Regional Office dated June 26, 1995 and outlines numerous issues which need attention in this report. We concur with the requests made in this letter and note that the following need attention in this document: a. Cyanide concerns in effluent. c. Foaming and color in effluent (previous and future complaints). f. Pretreatment opportunities and potential improvements [noted in the next comment section is a review of instream data which has metals well above detection levels] Thank you for this opportunity to review and comment. cc: Coleen Sullins Permit File NORTH CAROLINA DEPARTMENT OF ENVIRONMENT HEALTH AND NATURAL RESOURCES DIVISION OF ENVIRONMENTAL MANAGEMENT April 23, 1996 M E M O R A N D U M TO: Monica Swihart THROUGH: Steve Mauney ',LXA FROM: Ron Linville �l i j SUBJECT: Environmental Assessment for City of High Point Eastside POTW Expansion Guilford County The following comments are provided for you consideration and review. They are enumerated by the EA page numbers for your convenience. These comments are intentionally brief due to time constraints. 1. Additional treatment capacity is also necessary at this Facility due to significant inflow which may cause this plant -to provide only primary treatment during severe or long-term inclement weather. It is probable that inflow and flow throughs could contribute to current stream conditions below the POTW. This expansion appears to be somewhat belated due to recent sewer ex ensions and concerns about inflow into the collection system. 2. It is possible that wetlands may be located near the discharge trough of the existing POTW. The Corps of Engineers should determine if any impacts could occur instead of depending on a soils distribution "surrounding the site" (contact John Thomas w/ COE @ 919/876-844lx25). 6. Average daily flows of 16 MGD and peak hydraulic flows of 32 MGD are indicated in the document. Periods when routine flows of around 12.5 MGD have been exacerbated by instantaneous flows in excess of 3-4 times the daily permitted flow of 16.0 MGD are not unusual. 9. Consideration may need to be given to insuring that the abandoned outfall running through the landfill is not and does not provide an opportunity for pollutants to leach out through a french drain effect. 10. The 201 study included only High Point and Jamestown. The Region is concerned that inflow concerns may be more pronounced for Sedgefield and Archdale (both tributary to Eastside) as well as High Point. Jamestown may be in better shape. Inflow investigation and flow coordination by all parties tributary to the City of High Point's WWTP should be helpful. 13. Data which correlates high instantaneous flows with inflow and treatability during inclement weather events should be provided. This would further understanding of how these events could (even after expansion) negatively affect the Randleman Dam Watershed if it is built. 19. The EA's focus on the expansion allowing for future extensions of sewer into newly developed areas should also address the issue of repair and replacement of portions of the collection system currently contributing to significant inflow. Without such considerations, is it likely that point source nutrients could be discharged during inclement weather by flow throughs providing only partial treatment? Are there combined sewers that provide for the transport of urban runoff from the downtown area? 25. It is likely that the Eastside expansion "will result in a reduction in nutrients discharged to the receiving waters in the Deep River Basin". It is also likely that an enhanced I&I Program could also provide for further reductions. 26. The POTW (if the Randleman Lake is built) should insure that inclement weather events do not reduce the capacity of the WWTP to provide continual removal of nutrient loads during and after those events. 27. What type of redundant power supplies are proposed (on -site' automatic generator or dual power sources). Previous known failures are believed to have been intrinsic to the POTW. These comments are based on a general understanding of conditions relative to this WWTP and are expressed for the benefit and consideration of the City of High Point and the - proposed Randleman Dam project which is also discussed in the EA. a:\hipt.eam DIVISION OF WATER QUALITY February 20, 1996 MEMORANDUM TO: Michelle Suverkrubbe THROUGH: Ruth Swanek25) Coleen Sullins Don Safrit FROM: Jason Doll SUBJECT: Revised Environmental Assessment High Point - Eastside W WTP Guilford County The Technical Support Branch has reviewed the revised Environmental Assessment prepared by Davis -Martin -Powell & Associates, Inc. for the City of High Point's proposal to expand the Eastside Wastewater Treatment Plant from 16 MGD to 26 MGD. The document appears to address the concerns raised in our previous comments, but given the potential controversy concerning this expansion, some additional comments should be made for the record. In our previous comments we emphasized concerns with high effluent levels of nickel, lead and cyanide and the potential for violations of instream water quality standards for these parameters if the receiving waters are reclassified for use as a water supply. We requested that the document be revised to include some characterization of available effluent and instream data for the parameters in question and a discussion of mitigative measures intended to address this problem. An appendix was added to the revised EA with the appropriate effluent and instream data and a cge paragraph section (8.08) was added at the end of the main body of the document describing the measures to be taken. The data appendix is clear and useful, but the section on mitigation is somewhat lacking in specific measures to be taken. Section 8.08 states only that the toxicant parameters in question are a concern, and as Randleman Lake is constructed, the headworks analysis will be updated and industrial allocations will be adjusted accordingly. In short, the revisions made were the bare minimum necessary to meet our requests. Our comments are not intended to prevent the document from proceeding in the review process. This concern should be noted in light of the potential reclassification of this area of the Deep River to a Water Supply. If elevated instream levels of these problem parameters persist the reclassification process and the development of Randleman Lake as a water supply may be impeded. Thank you again for the opportunity to comment on the revised Environmental Assessment. Please let me know if I can be of further assistance in this matter. cc: Winston-Salem Regional Office Coleen Sullins - Permits & Engineering Central Files ENVIRONMENTAL ASSESSMENT for the EASTSIDE WASTEWATER TREATMENT PLANT EXPANSION & UPGRADE Prepared Jbr Ike CITY OF HIGH POINT, NC Stale Reriew llgencr NC Department of Environment, Health & Natural Resources Contact Person: Ms. Michelle Suverkrubbe Prepared Jointly Bv: HAZEN AND SAWYER, P.C. DAVIS-MARTIN-POWELL & ASSOCIATES, INC. 4011 Westchase Blvd. 218 Gatewood Avenue, Suite 102 Raleigh, North Carolina High Point, North Carolina JOB NO_ E-1971 ran " MR SECTION 1 MM PURPOSE IM The purpose of this Environmental Assessment for the City of High Point's Eastside Wastewater R, Treatment Plant (WWTP) is to discuss environmental impacts that expanding and upgrading the WWTP may have on the surrounding areas and communities that will be served by the expanded WWTP. See Exhibit 1 for the vicinity map that indicates the location of the Eastside WWTP. The proposed project will expand and upgrade the existing Eastside WWTP from a capacity of 16 million gallons per day (MGD) to 26 MGD. This increase in treatment capacity will allow the facility to adequately process anticipated wastewater flows as well as enhance existing treatment processes. The upgraded plant will be designed to achieve greater levels of treatment and higher quality effluent, which will be required to minimize adverse impacts on water quality in the proposed Randleman Lake. See Exhibits 4 and 5 for the location of the proposed Randleman Lake. rM The additional treatment capacity is necessary to accommodate anticipated growth and development in the existing and expanding service area which has and will lead to extensions of the wastewater collection and transmission system into newly developed areas. This report discusses the effects of this upgrade on the surrounding environment. rM rM M M SM Environmental Assessment for the City of High Point; Job No. E-1971 - 1 - FEt MR M SECTION 2 EXISTING ENVIRONMENT fan 2.01 Topography MR The proposed project is located in the Jamestown Township east of High Point, North Carolina. More specifically, the project is located at the site of the existing Eastside WWTP, along Richland Creek near the Riverdale Road crossing of Interstate 85. (See Exhibits 1 and 5). The existing plant site varies in elevation from 680 feet to 800 feet above mean sea level. The area to be disturbed is limited predominantly to the existing plant site in areas that were FM cleared and graded during construction of the existing treatment plant process units. 2.02 Land Use The project site is bounded on the south and east by Interstate 85 and Richland Creek. The area downstream of the project site, across Interstate 85, is primarily undeveloped woodland. The area to the west of the project site is mixed agricultural and woodlands. North of the project site, across Riverdale Road, is the City of High Point Landfill and the closed Seaboard Chemical Corporation site. 'u' 2.03 Solis The soils at the plant site have generally been cut or filled to accommodate the existing ran WWTP components. As a result of this cutting and filling, the natural distribution of soil series and types have been altered. The soils on land surrounding the site are typically well -drained Enon and Wilkes series soils. Pon fm Environmental Assessment for the City of High Point; Job No. E-1971 - 2 - FMI rya 2.04 Surface Watem The existing Eastside WWTP site borders Richland Creek. No other surface waters are M contiguous to the site. The existing treatment facility discharges effluent to Richland Creek, a FIR small urban stream with a 7Q10 flow of 1.0 CFS. Richland Creek is designated as a Class C FM stream under the North Carolina Surface Water Classifications and Water Quality Standards. The discharge into Richland Creek is located just upstream of Richland Creek's confluence with the ,�, Deep River in the Cape Fear River Basin. Fan Other major point source discharges in the Deep River Basin segment of the Cape Fear River Basin include the Randleman WWTP, Asheboro WWTP, Robbins WWTP, and Sanford rm WWTP. Nonpoint source discharges into the Deep River service area are predominantly from Pq urban surface water runoff or farmland runoff. Point source discharges to the Deep River are of concern because of their impact on Fin downstream dissolved oxygen. In addition, the Eastside WWTP is a very significant contributor SMI of point source nutrients to the Deep River. These nutrients can cause algal blooms, which also reduce the amount of dissolved oxygen in the waters. This reduction of dissolved oxygen and M excessive nutrients can affect normal growth of wildlife species and can lead to a eutrophic state for downstream surface waters. Biological and ambient water quality data collected by the Division of Environmental W Management (DEM) indicates the water quality in the Deep River, below the Eastside Plant, is r,f, impaired. (See Exhibit b). Surface waters like the Deep River are rated as either fully supporting, support -threatened, partially supporting, or non -supporting. The terms refer to how the classified uses of the water are being supported. The term "impaired" refers to surface waters that are rated either partially supporting or not supporting of their specific classified uses. Environmental Assessment for the City of High Poin4 Job No. E-1971 3 - Mq MR The Deep River sub basin from High Point to its confluence with the Haw River contains 16 small darns. These dams slow the river's velocity and limits the systems assimilative n capacity. These 16 impoundments, which affects stream velocity, point source nutrient loading ,a, such as WWTP discharges, and non -point source loadings, play a significant role in the IM eutrophication of stream. The river's inability to adequately assimilate the nutrients in the stream is directly related to the impaired ratings for the river. Although non -point source and an array fm of other NPDES point -source discharges contribute to nutrient loading in the Deep River, M sampling data implicates that Richland Creek, receiving waters for the High Point Eastside WWTP, as a significant contributor of point -source nutrients to the Deep River. F" Low levels of lead and nickel have been discovered upstream of the City of High Point's FM reservoirs during their analysis of the efficiencies of the recently constructed water quality ponds located upstream of City Lake. Their periodic findings are believed to be anthropogenic in MR nature. Randleman Lake, a proposed regional supplemental drinking water supply for the Cities of High Point, Greensboro, and Archdale and the Town of Jamestown, as well as surrounding areas � within Randolph and Guilford Counties, will be constructed on the Deep River downstream of ,-, the Eastside WWTP and will back up water into the effluent channel of the existing WWTP. Fa, (See Exhibits 2 and 5). 2.05 Water Supply M The existing City of High Point water supply treatment and transmission facilities consist of two raw water pumping stations and associated raw water transmission mains; two water filtration plants with associated clearwells and high service pumping facilities; distribution mauls; run two elevated storage tanks, and a ground storage repump facility. 0" Environmental Assessment for the City of High PoM4 Job No. E-1971 -4- pa OR MCI The two reservoirs, High Point City Lake and Oak Hollow Lake, are the sources of water supply for the City of High Point. City Lake was constructed in 1928 and has served as the primary water source since its construction. In 1971, Oak Hollow Lake was constructed to r-or, supplement the City Lake supply. After Oak Hollow Lake was completed, stored water could be released through the intake structure to allow waters to flow downstream to City Lake. Previous engineering reports indicate that the average dependable daily yield of City Lake and �+ Oak Hollow Lake combined is 22 MGD. rMI Each reservoir currently has a raw water pumping station and transmission system capable of delivering raw water to either of the two existing water filtration plants. The primary raw '=' water pumping station located downstream of City Lake includes four pumps with capacities ranging from 8 MGD to 20 MGD each. The Oak Hollow Raw Water Pump Station located just behind Oak Hollow Dam includes three pumps with capacities ranging from 8 MGD to 12 MGD M each. Raw water is transmitted through a system of mains to either of the two existing water filtration facilities. The primary water filtration plant, Ward Plant, has an existing water rM production capacity of 16 MGD. The secondary water filtration plant, Kearns Plant, is an M extremely old facility and has an emergency backup water production capacity of 8 MGD. Plans Fq are being completed for the expansion of the Ward Plant from 16 to 32 MGD capacity. The City of High Point has recently constructed three regional water quality ponds upstream P, of the City Lake Reservoir and an additional biological pond is proposed upstream of Oak Hollow Lake. The existing 22 MGD combined safe yield for the High Point Reservoirs and the planned 32 MGD water treatment capacity should provide the City with adequate water supply until 2010, OR Environmental Assessment for the City of High Poin4 Job No. E-1971 -5- ram ran after which time an additional water supply source will be needed. Construction of Randleman Lake is proposed to supplement the capacities of High Point's and Greensboro's raw water supplies to meet long-term water needs for the area. Randleman Lake is planned to provide an Fm additional safe yield of 48 MGD, of which 10 MGD is allocated to the City of High Point. 2.06 Groundwater Groundwater is utilized for individual residencies in rural areas of Guilford County. No major potential groundwater aquifers are located in the area. Most wells produce less than 25 gallons per minute. Groundwater quality is normally good, except for high iron levels in some Fall areas. No water supply wells are located in the vicinity of the Eastside Wastewater Treatment rm Plant site. W OR M M Pq PIR ran Environmental Assessment for the City of High Point, Job No. E-1971 -6- ram F" SECTION 3 MISTING WASTEWATER FACILITIES 3.01 General The City of High Point is located in the northern Piedmont of North Carolina in southwestern Guilford County. The wastewater service area includes High Point, Archdale, Jamestown, and the Sedgefield Sanitary District, as well as surrounding areas located adjacent raq to the High Point corporate limits. The existing City of High Point sewer system includes approximately 500 miles of sewers, 25 wastewater pumping stations, and two wastewater treatment plants. A major ridge line through the City separates two distinct watersheds: the Cape Fear River Basin to the east and the Yadkin River Basin to the west. Gravity sewers to the east of the ridge flow to the Eastside FMR WWTP, and those to the west flow to the Westside WWTP. The Eastside Plant provides service MI to the northern, eastern, and southern areas within and surrounding the City, while the Westside Plant provides service to western areas only. The Eastside Plant also receives flows from the rMR City of Archdale, the Town of Jamestown, and the Sedgefield Sanitary District. "`' 3.02 Plant Description The Eastside Plant was originally constructed as a trickling filter process and was subsequently modified during the early 1960's to a trickling filter/activated sludge process. '-' During the early 1980's, the Eastside Plant was expanded to provide treatment for an average daily flow of up to 16 MGD and a peak hydraulic flow of 32 MGD. Flow is transported to the plant site by two major outfalls: the Perry Outfall and the Richland Creek Outfall. - Preliminary treatment includes bar screens, flow measuring, and grit removal. Parallel bar screens are Environmental Assessment for the City of High Poin4 Job No. E-1971 -7- FM rM r-M provided for the removal of large solids and stringy materials. The influent flow rate is then M measured by a 3' - 0" wide Parshall flume which discharges to parallel aerated grit chambers. Flow is then split and distributed to four primary clarifiers. The preliminary treatment units and ra, the primary clarifiers are designed to accommodate all influent flows up to the 32 MGD peak M M9 rate. The flow is then split equally between two independent secondary treatment trains. One-half of the plant flow is routed through the trickling filter/activated sludge train. Primary effluent is received by the trickling filter influent pumping station, where it is lifted by vertical diffusion vane pumps to the trickling filters. Within this train, the trickling filters are followed by aeration basins and secondary clarifiers. Effluent from the secondary clarifiers is F%I lifted by screw pumps and combined with effluent from the second train. The second, parallel rW, process train consists of aeration basins and secondary clarifiers. No intermediate pumping is required for this train. Flow is routed by gravity through this train to a junction box and is `w$ combined with the first train's secondary effluent before tertiary treatment by conventional gravity fml filtration. Following filtration of the combined flows, the tertiary effluent is disinfected, by chlorination and discharged over a cascade aeration system to an effluent channel and downstream plant outfall pipes. Flow is then discharged by gravity into Richland Creek. r-I, In 1990, a four -million gallon influent flow equalization tank was constructed to reduce Pal peak influent flow rates to levels that could be passed through the plant while maintaining adequate treatment levels. M The solids handling facilities constructed in a previous expansion of the Eastside Facility included dissolved air flotation (DAF) thickeners, anaerobic digesters, a liquid storage lagoon, FM and belt filter presses. The digesters have recently been converted to lime stabilization tanks and MR Environmental Assessment for the City of High Poin4 Job No. E-1971 -8- rAq the belt filter presses are currently not in service. The City of High Point currently disposes of lime stabilized sludge by land application in the liquid state. Primary sludge is transferred directly from the primary clarifiers to the lime stabilization/mixing tank. Secondary sludge wasted from the activated sludge processes is pumped to the dissolved air flotation thickening tanks. Thickened secondary sludge is transferred FM to the lithe stabilization/mixing tank where it is mixed with the primary sludge. The lime M stabilization/mixing system includes two tanks operating in series. The first tank includes aline fm feed system and nixing facilities. The second tank is currently being utilized to store stabilized sludge only at this time. Plans have been completed and construction has begun to add mixing equipment to the second tank, as well as to replace the transfer pumps between the two tanks. Two other construction contracts are in progress to allow abandonment of the sludge land application program. The existing belt filter presses are being replaced with high solids centrifuges to dewater the liquid sludge. An incineration facility is also being added to further RM reduce waste sludge volumes and stabilize the sludge. Incinerator ash will be disposed of in a landfill. � 3.03 Existing NPDES Permit The existing NPDES permit limitations for the Eastside Plant are as follows: MCI Flow 16.0 MGD BOD Summer 8.0 mg/1 BOD Winter 16.0 mg/l TSS 30.0 mg/l NH3 N Summer 3.0 mg/l NH3 N Winter 6.0 mg/1 DO 6.0 mg/l Fecal Coliform 200/100 ml Mn Environmental Assessment for the City of High Point; Job No. E-1971 -9- FOR wq , The existing Eastside NPDES permit was issued on February 1,1993 and expires on March 31,1996. The State Department of Environment, Health & Natural Resources has just issued the MR NPDES permit for continued operation at the 16 MGD capacity. The NPDES limits are identical ,a,,, to the previous permit and will remain active until March 31, 2001 or until the plant is expanded. 3.04 Collection System M Flow is transported to the Eastside Plant by two major outfalls: the Perry Outfall and the P9 Richland Creek Outfall. The Richland Creek Outfall was originally constructed in the early 1900's to provide sewer service to the southeastern area of High Point. In order to provide additional capacity for the growing southeastern area, as well as additional capacity to FER accommodate wastewater from the Archdale area, a portion of the Richland Creek Outfall was rm replaced in 1972. The Perry Outfall was constructed in the late 1950's to serve the northeastern areas of High Point. A municipal solid waste landfill has been constructed over a portion of this MIR outfall. The landfilling operation has progressed to a point that portions of the outfall are being covered by up to 70 feet of fill. The over 35-year old concrete pipeline shows signs of concrete deterioration. A pump station and force main is being constructed to allow abandonment of the W portion of the outfall located under the landfill. See Exhibit 5 for location of major outfalls FIR which contribute to the Eastside WWTP. Flow is transported to the Westside Plant by three outfalls: the Rich Fork Creek Outfall, the `'" Kool Pool Outfall, and the Ensley Creek Outfall. These outfalls were originally constructed prior to 1950 utilizing 3-foot lengths of clay pipe material with grouted joints. Segments of each outfall have been rehabilitated or replaced during the past 20 years. A sewer system pq infiltration/inflow (1/I) analysis was included in the original 201 Facilities Plan that was prepared rXI by Black & Veatch during 1975 and a comprehensive High Point sewer system report was prepared by Hazen & Sawyer during 1988. The I/I study in the original 201 included a cost .Om Environmental Assessment for the City of High Point; Job No. E-1971 -10- . caa M effective analysis that indicated that the collection systems of High Point and Jamestown did not experience excessive I/I. Therefore, it was determined that it would be cost effective to transport and treat these I/I flows. At that time, the City of Archdale had not constructed a central sewer M collection system. The purpose of the 1988 study was to identify firture needs within the sewer rim collection and treatment system. The 1988 study indicated that a number of the major outfalls were approaching capacity and future plans should include replacing the near -capacity pipelines M to accommodate long-term future growth. The 1993 City Bond Issue included funds for outfall rim pipeline rehabilitations and replacements. Plans are currently being prepared to address I/I-related sewer main pipeline rehabilitations on the most deteriorated pipeline segments within the M collection system. Approximately $9.15 million was included in the 1993 Bond Issue for sewer M system renovations and I/I reduction. $4.5 million is being utilized to install gravity sewer, the Riverdale Road Pump Station, and a force main to allow abandonment of the deteriorated I/I- `-E' laden concrete outfall located under the existing landfill. After the existing outfall located under SMI the landfill is abandoned, the groundwater quality of any waters following the abandoned pipeline route will be monitored to assure it is not providing a "french drain" for leachate. In addition, Pq the abandoned sewer line will be internally televised to determine the amount of infiltration of ,a, ground water that is occurring. $1.6 million is being utilized to reduce I/I in the most F=► deteriorated segments of the Kool Pool, Kindergarden, and Colbert Outfalls. $2.9 million has been identified to reduce I/I in the most deteriorated sections of the Perry, Deep River, and M Mechanicsville Outfalls. The City's five-year plan for 1997-2002 includes an additional financial ran commitment of $7.0 million for further sewer system rehabilitation and the 2002-2007 long-range plan includes ongoing sewer system rehabilitation financial support. In addition, the City of High M Point is devoting a crew to ongoing I/I evaluations and sewer system repairs. M Environmental Assessment for the City of High Poin4 Job No. E-1971 -11- I'm ' 3.05 Industrial Pretreatment Program Major industries that contribute wastewater to the Eastside Plant include furniture and textile M manufacturing facilities, as well as other industries that provide products that are utilized by these manufacturers. The principal industrial wastewater generators include furniture manufacturers, textile manufacturers, textile chemicals processors, coatings manufacturers, electroplaters, steel drum cleaners, and dairies. The wastewaters discharged by the significant industries are regulated M by the City of High Point Industrial Pretreatment Program. The Industrial Pretreatment Program allows a systematic approach to regulate industrial wastewater discharges in order to ninininuize disruptions of the City's treatment plant processes. The Industrial Pretreatment Program sets forth uniform requirements for direct and indirect contributors to the wastewater collection system and treatment plants to enable the City of High Point to comply with State and Federal requirements of the Clean Water Act and General M Pretreatment Regulations included in EPA 40CFR - Part 403. The objectives of the Industrial Pretreatment Program are as follows: F • To prevent the introduction of pollutants into the municipal wastewater system which will M interfere with the operation of the system or contaminate the resulting solids; • To prevent the introduction of pollutants into the municipal wastewater system which will pass through the system, inadequately treated, into any waters of the State or otherwise be P' incompatible with the system; • To improve the opportunity to recycle and reclaim wastewaters and solids from the system; • To protect both municipal personnel who may come in contact with wastewater solids and effluent in the course of their employment, as well as the general public; F" • To provide for equitable distribution of the cost of operation, maintenance, and improvement of the municipal wastewater system; and Environmental Assessment for the City of High Poin4 Job No. E-1971 -12- RR M To ensure the municipality complies with its NPDES or Nondischarge Permit conditions, solids use and disposal requirements, and any Federal and State laws to which the municipal wastewater system is subject. rAR The Industrial Pretreatment Program provides for regulating industrial discharges by Mal issuance of Discharge Permits for significant industrial customers. Specific industrial pollutant discharge limitations are determined by a headworks loading analysis of the wastewater treatment M influent flows and any applicable Federal categorical regulations. M The Industrial Pretreatment Program includes provisions for surcharges of certain pollutants for industrial customers that discharge high strength (nondomestic) wastewater. The specific `a' pretreatment discharge limit for each pollutant is based upon historical discharge records of existing or similar industries, the continuously -updated treatment plant influent headworks analysis, and Federal categorical regulations. p, More stringent industrial user effluent limitations may be necessary to control concentrations P, of specific concerns such as nickel, lead, cyanide, color, etc. High concentrations of lead, nickel, M and cyanide have been identified as potential problems by State Officials. The effluent limitation for lead has not been violated during the past four years. The effluent limitation for nickel is FM violated 1 - 3 occasions per year. The effluent limit for cyanide of 5 /.cg/1 cannot be accurately Rn quantified and studies at another municipality has indicated a more quantitively accurate level obtainable by standard testing methods would be in the 20 ,ugA range. The effluent concentration RR of cyanide has not exceeded the 20 ILO for the past twelve months. See Appendix C for lead, nickel, and cyanide analytical characteristics. The continued emphasis on and the enforcement F" of the Industrial Pretreatment Program is the most economical means of controlling toxicity and heavy metals in the plant effluent. pq Environmental Assessment for the City of High Point; Job No. E-1971 -13- MR w�a ran SECTION 4 M, NEED FOR PROPOSED FACILITIES AND ACTION Population projections for the City of High Point service area provide the basis for planning of „7 necessary wastewater treatment facilities improvements to accommodate the associated wastewater system flows. For the purpose of this project, the projections are presented through the year 2015. Projections are provided for both existing and future service areas. The existing service areas include High Point, Jamestown, Archdale, and the Sedgefield Sanitary District. Future service areas include areas where major interceptors have or are being constructed to provide service to growing areas. M" The U.S. Census Bureau estimated the 1992 population for the City of High Point at 69,424. W Census population projections for Guilford County were utilized to project future populations for the City of High Point as follows: fan M M MR An analysis of historical water consumption records for the 12-month period from June 1994 to June 1995 indicates approximately 67 percent of water sold is returned to the Eastside WWTP and 33 percent is returned to the Westside Plant. Hi Point flow projections for the Eastside Plant are as pe � P J follows: ran MM Environmental Assessment for the City of High PoM4 Job No. E-1971 - 14 - M roq M M M * Based on Eastside Plant flow data for 1995. To project future flows expected at the Eastside WWI?,, existing and future service area flow projections were combined, as follows: * Based on Easuide Plant flow data for 1995. The projected peak month flow included above is based upon a ratio of the highest recorded monthly average flow during the past years divided by the ADF for the same period, or approximately FMq a peak month to ADF factor of 1.25. The preceding projections indicate that the expected 2015 ADF for the Eastside Plant will be 24.5 MGD, with a corresponding peak month average daily flow of 30.6 MGD. Along with continued growth in population, it is anticipated that more stringent NPDES permit effluent limits will be imposed. This comes from the observance of significant nutrient problems in the downstream areas of the Deep River. The Eastside WWTP effluent contributes over 70% of the Deep ' River flow at its permitted flow of 16 MGD. Phosphorus and nitrogen concentrations are of concern in terms of their effect on Randleman Lake and downstream waters. OR Environmental Assessment for the City of High Poin4 Job No. E-1971 = 15 - FM The Eastside Plant is estimated to reach its current permitted capacity of 16 MGD before the year 2000, and the 20 year flow projections indicate an. expected flow increase to 26 MGD by 2015. Based upon this information, speculative future effluent limits for a capacity of 26 MGD has been established. See Table One on Page 35 for a comparison between the existing 16 MGD NPDES limits and the proposed 26 MGD limits. As shown in the Table, more stringent limits for BOD, NH3-N, and nickel are proposed and new limits are proposed for phosphorus, nitrogen, residual chlorine, fluoride, phenols, and mercury. The continued emphasis and the enforcement of the Industrial Pretreatment Program is the most economical means of controlling toxicity and metals in the plant effluent. M ran Mom] r1M MR M rim M9 MR fm Environmental Assessment for the City of High PoM4 Job No. E-1971 -16- MIL] caq " Pnp SECTION 5 TM ANALYSIS OF ALTERNATIVES 5.01 No Action Alternative In the last few years, the Eastside WWTP has received flows approaching and, in 1995, nearly reaching its permitted capacity of 16 MGD. Current regulations require that the plant be expanded to adequately treat expected wastewater flows or that development be curtailed to M produce wastewater flows within the capacity of the existing treatment plant. Therefore, no M action would mean a moratorium on development generating new wastewater collection system connections or would require any future development in the service area to be served by 'R privately -owned treatment systems, septic tanks, or other subsurface disposal systems. Historical records indicate that most soils in the service area are not suitable for subsurface disposal systems. Also, privately -operated package wastewater treatment facilities have typically resulted in inadequately treated effluent being discharged to surface waters. For these reasons, the no M action alternative is not considered a feasible alternative. 5.02 Relocated Wastewater Treatment Plant Alternative M' Relocation of the Eastside WWTP to an alternate location is not cost-effective. The existing service area topographic features and the existing major outfalls that terminate at the existing Eastside headworks facilities restrict relocation options. Since a majority of the existing treatment facilities are of recent construction and their operation is reliable, excessive, unnecessary cost would be required to replace the existing processes at an alternate location. In addition, the existing plant site has adequate space for the proposed expansion. If an alternate site was available, additional social, environmental, and Environmental Assessment for the City of High Poin4 Job No. E-1971 - 17 - MR MR political issues would make implementation of the proposed project much more difficult. An alternative site located downstream could possibly increase the overall service area but is not M considered feasible because of the proximity of the proposed Randleman Lake. M Expansion of the existing WWTP at its current location is more cost-effective than IM construction of a new facility at an alternate location. Therefore, construction of a relocated treatment facility is not a feasible option. rs, 5.03 Pion -Discharge Alternatives Land application is not considered a feasible option for the proposed treatment plant expansion. The area required for land application of the proposed 10 MGD addition flow would ,;, be more than 3,000 acres. It is highly unlikely that a parcel or parcels of land that size could M be found within close proximity to the plant. Even if suitable land is available, the cost to purchase the land and the cost to transport the effluent would be very high and would make this M alternative not cost effective compared to the proposed plant expansion. M 5.04 Wastewater Plant Expansion Alternative The proposed treatment plant expansion will increase the existing plant capacity from 16 M MGD to 26 MGD. Expansion of the existing facilities would occur on the existing plant site. W Expansion and upgrade of the existing plant will allow further development in the service area and allow the facility to produce a higher quality effluent. The proposed plant expansion is the FOR most cost-effective alternative. A Preliminary Engineering Study has been prepared that analyzes various processes that can achieve nitrogen and phosphorus nutrient effluent limits included in FMq the state issued speculative NPDES limits for a plant capacity of 26 MGD. MR MR FUR Environmental Assessment for the City of High PoM4 Job No. E-1971 -18- r=V MR SM pq SMI rim MI FMI FM W M P" M SECTION 6 PROPOSED FACILITIES AND ACTIONS, FUNDING SOURCES The proposed Eastside Treatment Plant expansion will increase the existing plant capacity from 16 MGD to 26 MGD. The layout of the plant improvements proposed for construction is shown on Exhibit No. 3. The proposed upgrade and expansion will include new barscreens, new grit removal system, two additional primary clarifiers, new blower and administration building, activated sludge facilities for biological phosphorus and nitrogen removal, additional final clarifiers, additional effluent filters, and new ultraviolet disinfection facilities. The project will also include the replacement of outdated pumps, valves, valve operators, and miscellaneous equipment, as well as the conversion of existing structures into additional flow equalization and sludge storage tanks. The current ongoing construction project at the Eastside Plant to expand the waste solids handling facilities is part of the phased construction for plant expansion to 26 MGD capacity. Liquid sludge blending/storage renovations, sludge concentration by new dry solids centrifuges, and the installation of a fluid bed incineration unit are being constructed to accommodate existing and future waste sludge capacity needs. The Eastside Plant is estimated to reach its current permitted capacity of 16 MGD before the year 2000. Based upon the estimated flow projections, the following schedule for plant upgrade and expansion is as follows: • Preparation of plans and Specifications August 96 - August 97 • Construction of Upgrade and Expansion October 97 - December 99 Environmental Assessment for the City of High Poin4 Job No. E-1971 =19- po The estimated construction cost for the upgrade and expansion of the Eastside Treatment Plant from 16 MGD to 26 MGD capacity is $35,000,000. It is anticipated that a local Sewer Bond Issue will be developed to finance the construction of the proposed improvement. The City of High Point may also apply for SRF-State Revolving Fund Loan monies to help finance the cost of the proposed improvements. Environmental Assessment for the City of High PoM4 Job No. E-1971 - 20 - rya SECTION 7 ENVIRONMENTAL CONSEQUENCES ran 7.01 Changes In Land Use Inq The proposed Eastside WWTP expansion will be limited to the existing plant site property boundaries. The proposed plant expansion is not expected to cause any changes in land use in the immediate area. A secondary indirect impact on land use will result from the continued expansion of the ,a, service area and continued development of surrounding, currently undeveloped lands. The Faq increase in wastewater treatment capacity will allow future expansions of the wastewater collection system to serve newly developed areas. Exhibit 5 indicates the existing system service area which includes approximately 29 square miles and two growth areas which are expected to develop during the next twenty years. One area located northwest of the existing service area MR includes b square miles and a similar area located east of the existing service area includes 5/ r" square miles. 7.02 Surface Water Quality Fm The Eastside WWTP discharges its effluent into Richland Creek, a small urban tributary of (W, the Deep River in the Cape Fear River Basin. Other major point source discharges in the Deep River Basin segment of the Cape Fear River Basin include the Randleman WWTP, Asheboro WWTP, Robbins WWTP, and Sanford WWTP. Nonpoint source discharges into the Deep River service area are predominantly from urban surface water runoff or farmland runoff. Point source discharges to the Deep River are of concern because of their impact on MR downstream dissolved oxygen. In addition, the Eastside WWTP is a very significant contributor M Environmental Assessment for the City of High Poin4 Job No. E1971 =21- ran rya , am of point source nutrients to the Deep River. These nutrients can cause algal blooms, which also reduce the amount of dissolved oxygen in the waters. This reduction of dissolved oxygen and excessive nutrients can affect normal growth of wildlife species and can lead to a eutrophic state FM for downstream surface waters. MR Speculative future effluent limits for the Eastside WWTP expanded to 26 MGD have been established and are shown in Table 1 on Page 37, along with a comparison to the limits for the M existing 16 MGD plant. The future speculative limits were provided in a letter from Mr. Steve W. Tedder to Mr. Linwood E. O'Neal dated September 15, 1995 (See Appendix B). As shown in the table, the limits for nickel will be reduced and a new limit for phenols will be added upon F&I construction of Randleman Lake. W Several other effluent limits will be reduced as a result of the Eastside WWTP expansion. The BODS limit (in mg/1) will be reduced from 8 to 5 during the summer months and from 16 '"' to 10 during the winter months, or a reduction of 38 percent. The NH3 N limit (in mg/l) will FER be reduced from 3 to 2 during the summer months and from 6 to 4 during the winter months, or a reduction of 33 percent. M New limits for fluoride, mercury, residual chlorine, phosphorus, and total nitrogen are Pq included in the speculative limits. The nutrient limits will help to minimize the algal blooms and dissolved oxygen reduction in downstream waters. Therefore, the additional treatment processes SM for nutrient reduction will enhance the quality of plant effluent. ,.� Nonpoint source discharges to the Deep River are primarily from roadways and farmland. P" As the areas are developed, there will be more roadway runoff and less farmland runoff. Nutrient loadings from nonpoint sources are expected to increase slightly with the proposed M project because of the conversion of undeveloped land to land developed for urban uses. MR Environmental Assessment for the City of High Point, Job No. E-1971 -22- PMR Sm 7.03 Groundwater Quality The proposed project will be confined to the existing plant site which is well drained. No 'I' water supply wells will be affected by the construction of the proposed improvements. P" Secondary benefits will result from continued service area expansion, which will allow reduced dependency on septic tanks and other subsurface disposal systems and allow the M elimination of existing failing subsurface disposal systems in the expanding service area. Elimination of the failing systems will improve groundwater quality. 7.04 Wetlands and Flood Plains Fm The existing plant and the proposed expansion facilities are confined to an area where there fm is no evidence of wetland vegetation and the soils are well drained. Based on Flood Insurance Rate Maps from the National Flood Insurance Program, the 100- M year flood elevation for Richland Creek is approximately 688.8 feet. The proposed Randleman RM Lake will have a normal pool elevation of 682 feet. At this elevation, the lake will be just below the bottom step of the plant effluent cascade aeration structure. The previously proposed Corps of Engineers lake would have had a 100-year flood elevation of 694.5 feet. The Corps lake Pm design is larger than the currently proposed Randleman Lake. Based on preliminary design Pq information, the 100 year flood for the currently proposed Randleman Lake will be between 689.0 and 690.0 feet. See Exhibit 2 for various flood elevations expected adjacent to the existing MR plant site. rAl With the proposed Randleman Lake, the existing cascade aeration system will be slightly impacted. During a flooding event, aeration of the effluent will be reduced, possibly requiring W additional means of aeration. (See Exhibit 2 for expected flood elevation and plant effluent elevations). MR Environmental Assessment for the City of High Point, Job No. E-1971 -23- M1 PIR 7.05 Prime or Unique Agricultural Lands The proposed project is expected to have no effect on the existing agricultural land to the west of the plant. No other agricultural lands are located near the site. M, Secondary impacts may be a future reduction of agricultural lands due to continuing growth FIR and development of the service area allowed by the increase in treatment capacity. 7.06 Public Lands, Scenic, and Recreational Areas M The proposed project site is located across Riverdale Road from the existing High Point MR Solid Waste Landfill and the closed Seaboard Chemical Corporation site and is bounded on the south and east by Interstate 85 and Richland Creek. There are no public lands, parks, scenic, or M recreational areas that will be affected by the proposed construction at the existing treatment plant rm site. The North Carolina Division of Parks and Recreation, National Heritage Program is not aware of any parks or recreational areas or wild or scenic rivers that would be adversely affected r" by the proposed project. 7.07 Archaeological and Historic Sites There are no archaeological or historic sites that will be affected by the proposed project M due to its location on the existing plant site. Based on a file data search, North Carolina ram Department of Cultural Resources staff indicated that they are not aware of any structures of historic or archaeological importance within the boundaries of the proposed construction. Fm 7.08 Air Quality The overall effect of the project on air quality will be negligible. Short-term effects on air quality will include windblown dust and exhaust emissions generated during construction. Long- M term effects on air quality are expected to be negligible since the proposed expanded plant will utilize treatment processes similar to the existing plant. Measures to control odors from existing M and proposed process units will be included in the proposed expansion project. fm Environmental Assessment for the City of High Poin4 Job No. E-1971 _ 24 MR MR Burning of trees and brush resulting from minor clearing of the site may be permitted by air pollution regulations under the jurisdiction of the Guilford County Health Department. If burning is not permitted, the waste materials will be properly disposed of in a landfill or M, recycled. The expanding service area will ultimately lead to an increase in population and automotive usage which will, in turn, increase air emissions. M+ 7.09 Noise Levels Long-term noise levels are not expected to increase significantly due to construction of the proposed project. Short-term increases in noise levels associated with construction activity can �► be expected. The facility's remote location and its proximity to Interstate 85 further support the belief that noise levels should not be a significant problem. 7.10 Water Supplies The proposed Eastside WWTP expansion will not have any effect on the existing water supplies that serve the City of High Point. These supplies, High Point City Lake and Oak Hollow Lake, provide an average dependable combined daily yield of 22 MGD. It has been Mn estimated that this water supply will be adequate for the City until 2010. The proposed n Randleman Lake (See Exhibit 4), upon completion, will supply the surrounding communities with a planned safe yield of 48 MGD. The more stringent effluent limitations to be imposed upon the expanded Eastside Plant will control the quantity of nutrients released into the Randleman Lake. Indirect effects on the water supply will result from future residential and industrial run development in the watershed area due to the increased capacity of the treatment plant. rM MR Environmental Assessment for the City of High Point; Job No. E-1971 = 25 - PM rAq 7.11 Shellfish or Fish and Their Habitats The proposed plant expansion will not adversely affect shellfish, fish, or their habitats. run Direct impacts due to siltation during construction will be mitigated by erosion control measures M implemented in accordance with North Carolina and Guilford County erosion control regulations. FM An Erosion Control Plan that has been approved by the NC Division of Environment, Health and Natural Resources, Division of Land Resources will be included in the project design plans. The expanded plant will also include enhanced treatment to reduce nutrient concentrations and to reduce the potential for chronic toxicity by discontinuing the use of chlorine for disinfection. Indirect impacts from the proposed project will result from new development in the service FOR area. Increasing urban runoff will occur due to new development. fam 7.12 Wildlife and Their Habitats The existing plant site is cleared and planted in grass which is mowed and offers limited M habitat for wildlife. Since the plant expansion will be confined to the existing site, no adverse impacts to wildlife or their habitat are expected. Approximately one acre of plant site wooded area will be cleared to facilitate construction. CA" Birds and small animals that feed on the grassy areas of the plant site may temporarily leave M because of construction activities, but should return during and after construction is completed. Traffic and noise from construction activities may cause wildlife inhabiting adjacent forest F&' habitats to temporarily move further into the forested areas. Some species will adjust to the rMl disturbances and return to the site during construction while others will return to the vicinity after construction is completed. Indirect impacts from the proposed project will result from new development in the service M area. Some natural wooded areas along with their wildlife habitat will be replaced by housing or industry, thus impacting wildlife species in the developed areas. Environmental Assessment for the City of High Poin4 Job No. E-1971 =2b- PIM raq , 7.13 Introduction of Toxic Substances The expansion of the Eastside Plant should have no significant adverse impacts relating to M toxic substances. The existing NPDES permit requires effluent chronic toxicity testing on a quarterly basis. The plant consistently passes the effluent toxicity test. The proposed plant expansion will include ultraviolet disinfection, thereby eliminating the potential for chlorine - related effluent toxicity. M The City's aggressive Industrial Pretreatment Program continuously monitors and controls M toxic organic and inorganic chemicals discharged to the sewer system. The program includes a headworks analysis to allocate selected pollutants from industries. The analysis is periodically Pon submitted to NCDEM and was last approved during May 1994. 7.14 Eutrophication of Receiving Waters r� The proposed upgrade and expansion of the Eastside WWTP will result in reduction in M nutrients discharged to receiving waters in the Deep River Basin. There is no effluent limit for total nitrogen in the current NPDES permit for the Eastside Plant. Future limits projected by NCDEM include a monthly average effluent limits for total nitrogen of 6 mg/1 during the months rm of April through October. As for nitrogen, there is presently no effluent limits for phosphorus W in the current NPDES permit. NCDEM projects a future limit for phosphorus of 1 mg/l as a monthly average. P+ Since the expanded wastewater treatment plant will discharge into the proposed Randleman I, Lake, the effluent from the plant will be treated to more advanced treatment levels. The expanded plant will be designed to meet nutrient limits which will preclude or minimize the mn potential for eutrophication in Randleman Lake and other downstream receiving waters. M Mq Environmental Assessment for the City of High Poin4 Job No. E-1971 -27- . V=q 1;1 ' SECTION 8 MITIGATIVE MEASURES M Various measures are planned to minimize adverse environmental impacts during construction and operation of the proposed expanded Eastside WWTP. These measures will address short and long- term impacts of the proposed project. 8.01 Changes In Land Use ,un The proposed Eastside WWTP expansion will be limited to the existing plant site property boundaries. The proposed plant expansion is not expected to cause any changes in land use in fnIq the immediate area. (E, A secondary indirect impact on land use will result from the continued expansion of the service area as indicated on Exhibit 5 and continued development of surrounding, currently FIM undeveloped lands. The increase in wastewater treatment capacity will allow future expansions of the wastewater collection system to serve newly developed areas. The growth pattern will, however, be controlled and orderly in accordance with the City of High Point Development Ordinance. The purposes of the Development Ordinance include the following: ';' • Prevent overcrowding of land. • Facilitate the adequate and economic provision of transportation, water, sewage, schools, parks, and other public services. `�' • Protect water quality within the Watershed Critical Areas and the General Watershed Areas SIR of designated water supply watersheds. ran MR Environmental Assessment for the City of High Poin4 Job No. E-1971 - 28 - rR ran , • Require appropriate setbacks for buildings and other structures to facilitate the safe movement of vehicular and pedestrian traffic, provide adequate fire lanes, and ensure adequate distance from dust, noise, and fumes created by vehicular traffic. • Encourage development in areas which have major streets and utility lines in place but are experiencing little or no development. • Protect water quality, preserve wildlife habitats, and protect natural features such as streams, ,a, lakes, wetlands, and trees. • Reduce the amount of grading necessary for site preparation. • Create a better quality of life for the community by encouraging preservation of existing FOR trees and vegetation. M • Provide the separation necessary to permit certain land uses to co -exist harmoniously which might not do so otherwise. By enforcing the Development Ordinance as the wastewater system expands, adverse impacts as a result of expanding system will be mitigated. 8.02 Water Qua#ity �+ The expanded capacity NPDES point discharge into Richland Creek, tributary to the Deep River in the Cape Fear River Basin, will include effluent limitation as established by the Division of Environmental Management (see Table 1 on Page 35 for comparison of existing 16 MGD and speculative 26 MGD limitations). The speculative limit provided by DEM takes into account all upstream and downstream water quality issues including the proposed Randleman Lake and are FOR based upon the findings of the Cape Fear River Basinwide Water Quality Management Plan. MR As indicated in the table, effluent limitations have been established for several non - previously regulated parameters and other effluent limitations will become more stringent. Environmental Assessment for the City of High Poin4 Job No. E-1971 -29- MR on Nutrient limits for phosphorus and nitrogen will be imposed to minimize downstream nutrient M M, related impacts. Effluent limitations will also be established for fluoride, mercury, and chlorine. The proposed plant expansion will utilize ultraviolet light as the disinfectant, e ' ating chlorine residuals and the potential for developing casonigenic chlorine compounds downstream. More stringent limits for nickel and new limits for phenols will be added upon construction of Randleman Lake. Several other effluent limitations will be reduced as a result of the Eastside rm WWTP expansion. The BODS limit will be reduced approximately 38 percent based upon rAn concentration and only a mass (lbsjday) increase of less than 2 percent. The NH3-N limit will be reduced 33 percent based upon concentration and only a mass increase of 8 percent. M The proposed plant expansion will be designed with flexibility to exceed the proposed M effluent limitations. The design expansion to 26 MGD average daily flow will include provisions for treatment of peak flows up to 3 times design flow or 78 MGD. Activated sludge facilities `m for biological and nitrogen removal will be included. The potential changes in water quality caused by the increase in service area willbe minimized by the City of High Point Development Ordinance which includes Watershed M Management and protection features. The purposes of these watershed use regulations to control rm non point discharges are as follows: M • Protect those portions of designated water supply watersheds which he closest to existing and proposed water supply reservoirs from activities which could degrade water quality in r-I" the reservoirs. • Reduce the volume of nutrients and other chemicals which could enter the water supply by MR reducing the rate of runoff which any given development will generate. M am Environmental Assessment for the City of High Poin4 Job No. E-1971 -30- pq • Minimize land disturbance to reduce the amount of sediment washing into streams and lakes and to enhance the infiltration of runoff into soils, thus alleviating the sedimentation of RM water supply lakes which reduces their storage capacity, shortens their useful life, and ran makes them less able to withstand drought. • Reduce the probability of the release of harmful chemicals into water supply reservoirs, FOR either through natural catastrophe or human error. rM • Provide for natural and engineered methods for managing the stormwater which flushes contaminants off of built -upon areas in the water supply watersheds and which may reach IM water supply reservoirs unless controlled. r&i • M nimize pollution entering municipal reservoirs to assure the public health and the public provision of a continued supply of safe drinking water thereby protecting the water quality of these water supply reservoirs and promoting public safety. �' • Encourage a low intensity of land development in the most sensitive portions of the water supply watersheds (Watershed Critical Areas) thereby reducing the risks to water quality posed by higher density residential and non-residential uses. rM The construction of an expanded WWTP plant, which complies with DEM NPDES point M, discharge effluent limitations and the enforcement of the non point discharge watershed management and protection features of the City's Development Ordinance, will mini »e adverse impacts to water quality. �-, The City of High Point has also constructed three, and are planning a fourth, regional water quality improvement ponds located upstream of their water supply reservoirs. 8.03 Groundwater Quality MI The proposed project will be confined to the existing plant site which is well drained. No water supply wells will be affected by the construction of the proposed improvements. Environmental Assessment for the City of High Point; Job No. E-1971 =31- rim , am Secondary benefits will result from continued service area expansion, which will allow MI reduced dependency on septic tanks and other subsurface disposal systems and allow the elimination of existing failing subsurface disposal systems in the expanding service area. ,a, Elimination of the failing systems will improve groundwater quality. 8.04 Infiltration/inflow Reductlon Program The City of High Point's commitment to infiltration/inflow M reduction will allow the MI Eastside Plant to operate within hydraulic design parameters. A major pumping station and force ran main are under construction that will eliminate an I/I laden outfall segment which is also routed under an existing solid waste landfill. Approximately $9.3 million was authorized in 1993 for M outfall pipeline rehabilitations and replacements. Plans are currently being prepared to address I/I related sewer main pipeline rehabilitations on the most deteriorated pipeline segments within the collection system. S+ The continuing I/I reduction program will reduce the peak wet weather peak flows which must be processed through the plant, and coupled with the expanded peak design capacity of 3.0 M times the projected 20 year average daily flow, design capacity of 26 MGD will allow the plant M to adequately treat peak flows and eliminate the existing reduction in treatment efficiencies caused by high I/I laden flow events. FIR 8.05 Erosion Control The construction of the proposed project will be performed in accordance with an approved Erosion Control Plan. The Erosion Control Plan will include measures to control erosion during M all phases of project construction. These measures will be used to prevent excess sediment runoff from the construction areas. r, IM Environmental Assessment for the City of High Poin4 Job No. E-1971 - 32 - M, FM Potential secondary erosion control impacts related with the development of the expanding service area will be minimized by the City of High Point Erosion and Sediment Control Ordinance. The purpose of the Ordinance is as follows: Pq • Regulate certain land -disturbing activity to control accelerated erosion and sedimentation MP to prevent the pollution of water and other damage to lakes, watercourses, and other public and private property by sedimentation. Fq • Establish procedures through which the purposes of soil erosion and sedimentation control rM can be fulfilled. The enforcement of the Ordinance will mitigate future erosion control concerns associated M with ongoing development. 8.06 Construction Umits raq Construction limits will be clearly defined before construction commences to prevent the disturbance of areas outside the limits of the proposed project improvements. The purpose for setting construction limits is to prevent excess destruction of natural woodlands and grasslands in the surrounding areas. By setting these construction limits, `'�' surrounding wildlife will be minimally disturbed. M 8.07 Treatment System Failure The design of the proposed expansion facilities will incorporate measures designed to minimize the likelihood of treatment system failure. The proposed expansion will include redundant equipment, parallel treatment processes, and alarm systems to alert operators of failure of crucial equipment. Redundant electrical power supplies will also be provided as part of the M project improvements. The main and backup power supplies will each be sized to provide adequate power to operate critical plant components until full electrical power service is restored. Operation of the expanded plant will include preventive maintenance schedules designed to keep Environmental Assessment for the City of High Poin4 Job No. E-1971 -33- Faq rMbi equipment in proper working order throughout its full service life and to replace equipment as needed. 8.08 Continued Pretreatment Program Enforcement am The continued emphasis and the enforcement of the Industrial Pretreatment Program will minimize toxicity and heavy metals concentrations in the wastewater flows. Effluent and MR instream concentrations of lead, nickel, and cyanide are a concern at this time. Appendix C M, reviews four years of characteristics for each of the three mentioned parameters. The effluent limit for lead has not been violated during the past four years. The effluent limit for nickel are MR violated 1 - 3 occasions per year. The effluent limit of 5 ,ug/1 for cyanide cannot be accurately W determined by standard methods and a more quantitively accurate level obtainable would be in the 20 gg/l range. As Randleman Lake is constructed and the effluent limit for nickel drops the M9 Pretreatment Program, Headworks analysis will be updated and the industrial allocations will be FM adjusted as necessary to comply these or other problem toxicants in the wastewater stream. M M FIR FM Environmental Assessment for the City of High Poin4 Job No. E-1971 -34- am TABLE I EASTSIDE WWTP EXISTING AND ESTIMATED FUTURE NPDES PERMIT LIMITS FOR ......................................... .................................. ............. ......................... ...................................... ...................................... ............. .............. .......... Am.......O....r WWI ........................................................ .............. .... ............. M3 ;i ............. ................ .................... ......... . .................... ..........MMOVI ....... ........... Flow 16 MGD 26 MGD BOD5, Summer 8 mg/l, 1,068 lbs/day 5 mg/l, 1,084 lbs/day BOD5. Winter 16 mg/l, 2,136 lbs/day 10 mg/l, 2,168 lbs/day NH3-N Summer 3 mg/l, 400 lbs/day 2 mg/l, 434 lbs/day M NH3 N Winter 6 mg/l. 800 lbs/day 4 mg/l, 868 lbs/day Dissolved Oxygen 6 mgn, 800 lbs/day 6 mg/l. 1,301 lbs/day Total Phosphorus No Limit 1 mg/l. 216 lbs/day Total Suspended Solids 30 mg/l, 4,003 lbs/day 30 inglIs 6,505 lbs/day Total Nitrogen No Limit 6 mg/l. 1,301 lbs/day tt Fecal Coliforms 200/100 nil 200/100 ml Residual Chlorine No Limit 17 Mg/l, 3.69 lbs/day pH 6-9 SU 6-9 SU Cadmium 2 og/l, 0.27 lbs/day 2 gg/l, 0.43 lbs/day Sm Chromium 50 ligIls 6.67 lbs/day 50 jig/I, 10.84 lbs/day Nickel 88 ug1l, 11.74 lbs/day 88 -/zg/l, 19.08 lbs/day Nickel t -- 25 jig/19 5.42 lbs/day Lead 25 gg/Is 3.34 lbs/day 25 ILgllg 5.42 lbs/day Cyanide 5 jig/l, 0.67 lbs/day 5 ye, 1.08 lbs/day Fluoride No Limit 1.8 mg/l, 390 lbs/day Mercury No Limit 0.012 Ag/l, 0.004 lbs/day Phenols t No Limit 1.0 jugft, 0.22 lbs/day t Monitoring is also required for chronic toxicity (quarterly) and priority pollutants (annually). Fm Future limits as given in a letter to Mr. Linwood E. O'Neal from Mr. Steve W. Tedder dated September 18, 1995 - See Appendix. Winter limits are shown in parentheses where applicable. Limits are monthly averages except for DO which is a daily average and cyanide, fluoride, phenols, and metals which are daily t Limit to be applied if Randleman Lake is constructed. ism tt Limit for Total Nitrogen required during months of April through October. Far? RM Environmental Assessment for the City of High PoM4 Job No. E-1971 -35- MR Mq om CYANIDE Concentration, pg/L* Pw, ran.. - May 93 13.0 January 95 130.0 June `93 29.0 February `95 <5 July `93 25.0 March `95 64.0 August `93 8.0 April `95 18.0 September `93 7.0 May `95 28.0 October `93 5.0 June `95 36.0 November `93 39.0 July 695 15.0 December `93 6.0 August `95 40.0 September `95 21.0 January `94 504.0 October `95 <5.0 February `94 12.0 November `95 6.0 March `94 21.0 December `95 <5.0 April `94 6.0 May `94 38.0 January `96 <5.0 June `94 6.0 February `96 18.0 '&' July `94 9.0 March `96 5.0 August `94 8.0 April `96 7.0 September `94 24.0 May `96 <5.0 run October `94 7.0 June `96 10.0 November `94 10.0 July 496 6.0 rm December `94 17.0 August `96 8.0 September `96 9.0 FUR rya F, me * Maximum concentration in a given month Maximum effluent limit is 5 /tg/l Apparent quantitation level approximately 20 jL&4 FM M faq 5/93 12.6 rqm 6/93 12.0 7/93 8.9 8/93 11.6 9/93 <5 10/93 <5 11/93 <5 12/93 <5 1/94 142.0 <5 2/94 7.5 12.0 3/94 127.0 6.0 4/94 9.2 18.0 5/94 9.2 <5 �-► 6/94 19.8 <5 7/94 8.3 <5 8/94 22.5 <5 ran 9/94 15.0 <5 10/94 7.0 <5 P19 11/94 9.0 <5 12/94 10.7 <5 RIM M * Maximum concentrations in a given month NPDES limit is 25 ,u&4 r•� w LEAD Concentration, pg/L* 1/95 13.1 <5 2/95 6.5 6.2 3/95 9.4 <5 4/95 26.7 <5 5/95 170.0 5.2 6/95 11.6 7.3 7/95 10.3 <5.0 8/95 24.2 9.5 9/95 14.6 <5.0 10/95 9.5 <5.0 11/95 10.6 <5.0 12/95 8.0 <5.0 1/96 7.7 <5.0 2/96 7.1 <5.0 3/96 6.9 <5.0 4/96 14.1 <5.0 <5 <5 5/96 18.3 <5.0 5.6 <5 6/96 29.4 17.7 6.9 11.0 7/96 21.3 7.1 10.0 <5 8/96 23.4 <5.0 <5 <5 9/96 11.8 6.2 7.9 8.3 10/96 12.1 10.8 8.8 <5 rw NICKEL Concentration, pg/L* f=, 5/93 <12.5 1/95 75.0 44.0 6/93 48.0 2/95 <50 72.0 7/93 24.0 3/95 125.0 58.0 8/93 11.0 4/95 <50 22.0 9/93 17.0 5/95 230.0 26.0 10/93 104.0 6/95 364.0 266.0 11/93 71.0 7/95 .<50 34.1 12/93 20.0 8/95 62.0 63.0 9/95 <50 12.4 1/94 618.0 142.0 10/95 <50 12.6 2/94 <50 38.0 11/95 80.4 <10.0 3/94 83.0 70.0 12/95 <50 15.9 4/94 <50 <50 5/94 <50 49.0 1/96 46.8 22.4 P+ 6/94 104.0 167.0 2/96 37.4 13.7 7/94 81.0 68.0 3/96 136.7 10.3 8/94 59.0 82.0 4/96 66.9 26.4 <10 <10 9/94 89.0 73.0 5/96 18.4 18.0 <10 <10 10/94 50.0 31.0 6/96 12.0 13.8 <10 <10 11/94 <50 65.0 7/96 47.3 20.9 <10 27.5 12/94 <50 18.0 8/96 14.9 13.3 <10 10.6 9/96 30.6 16.3 10.2 <10 'a' 10/96 35.2 12.2 <10 28.6 MR * Maximum concentrations in a given month NPDES effluent limit 88 /ug/l FM Reduction to 25 q&4 with Randleman Lake .F" FM fzR Om