NC0087866_Comments_20240407

From: Krisdena Foronato
To: SVC_DEQ.publiccomments
Subject: [External] John F. Kime WTP NCO087866
Date: Sunday, April 7, 2024 10:17:52 PM
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2621 Glasshouse Rd
Jamestown NC 27282
April 6, 2024
NCDEQ-DWR
Water Quality Permitting Section
1617 Mail Service Center
Raleigh NC 27699-1617
Email: [e-mail]
RE: NPDES Wastewater Permit NC0087866 John F. Kime WTP
Dear NCDEQ:
I am writing this letter in response to the public notice regarding public comments for the Piedmont Triad
Regional Water Authority's application for an NPDES Wastewater Permit NC0087866 John F. Kime WTP
permit renewal. As a High Point resident and taxpayer, I am highly concerned about how the PTRWA is
operated and monitored, as the PTRWA appears to operate on a different set of rules than its
counterparts, appears to abscond reporting requirements, refuses to provide pertinent public record
documents without paying a fee, and fail to keep their customers and stakeholders informed and updated
on various PTRWA activities and water quality issues.
In reviewing the very limited documentation found on the NCDEQ Laserfiche database, I find it interesting
that on the PTRWA renewal application, under Section 4: Operation Information (40 CFR
122.21(f)(4))>4.3 Operator status, they indicate PTRWA is "Local Govt." While The PTRWA Board of
Director members are appointed by local municipalities, which fund PTRWA operations with taxpayer
dollars, the PTRWA operates more like a private corporation. In reviewing the PTRWA operations, you
will find:
The PTRWA website, www.ptrwa.org, provides basic and minimal information:
o Under "General Project Information", their last "weekly discharge records" are dated
9/16/15 with no further updates.
o Under the "Board of Directors",

■ You will find an all -male board with the appearance of little or no diversity. Why
is PTRWA funded by tax dollars, yet its Board not representative of the
communities it represents?
■ One member in particular, a Town of Jamestown appointee, Mr. Rich Glover,
currently serves as Board Chair, possess conflicts of interest, including:
• not residing in the Town of Jamestown (stated on public record he
lives in Greensboro —residency is a requirement of Town of Jamestown
"volunteers")
• being a former employee of a Town of Jamestown contractor,
Jamestown Engineering (5/1995-12/2021)
• working as a consultant for various municipalities
• representing a 4718 Harvey Road property owner (under his new
company, Glover Engineering, 1/2022-Present) for public hearings
regarding a high -density development in the Town of Jamestown, which
resides in a critical and protected Lower Randleman Lake Watershed
WS-IV and has its own NC General Statutes (see 15 NCAC 02b). None
of his conflicts of interest were mentioned when he spoke in front of the
Town of Jamestown Planning Board public hearings on 6/13/2022 and
7/18/2022 nor during the Town Council public hearings held on
11/15/2022 and 12/22/2022 (he spoke at the latter meeting).
■ The PTRWA website does not provide actual PTRWA Board of Director
meeting schedules (i.e., dates, time, location), meeting agendas or meeting
minutes. Since these meeting occur in the middle of the day, it appears PTRWA
meetings are also does not live stream or record these meetings for public
viewing, as outlined in NC General Statutes.
o Under "Construction", it appears the PTRWA Board of Directors have authorized the
purchase of a $120 M Reverse Osmosis Treatment System due to "address emerging
compounds", i.e., PFAS/PFOS. Why hasn't the public been notified and/or educated of
this fact?
o Under "Recreation", it appears fishing is allowed, yet there are no warnings advising
whether or not these fish should be eaten. Yet, as previously stated above,
under "Construction", the PTRWA is requesting $120 M to address "emerging
compounds" and looking at the 2023 Annual Drinking Water Quality Report (PWSID#
NC3076010), which exceed the EPA's recommended guidelines for these contaminants,
you would think the PTRWA and/or NC Wildlife Resources Commission would be issuing
warnings on consumption of fish caught in the Randleman Reservoir.
o Under "Educational Opportunities",
■ What is PTRWA doing, outside of being directly contacted, to educate its
shareholders, customers and the general public regarding the Randleman
Reservoir water quality?
■ Where are these educational materials housed and why are they not available
on the PTRWA website?
Per a COMPLIANCE EVALUATION INSPECTION letter, dated 2/9/2024 and signed by Jennifer
Graznak, Assistant Regional Supervisor, under "Item(s) of Concern", it states,
"Meritech, Inc. (NC certified lab #165) has been contracted to analyze some permit -required
parameters but has not been listed in the laboratories used on discharge monitoring reports
(DMRs). All labs used to analyze required parameters must be listed on that month's DMR."
So, the above is a non-compliance issue that was only recently noticed? The PTRWA's reasoning
regarding why they were using Meritech (NC Certified lab #165) to perform discharge monitoring
reports (DMRs) seems rather questionable and not convincing. In reviewing the results submitted
by Meritech Inc., the results reported, in many cases are not actual amounts, but generalizations
(i.e., '5" or "<" thresholds). How long have these reports been inaccurately performed and

reported, and why is PTRWA only getting a slap on the wrist for not following reporting guidelines
and requirements?
[Source:
https://edocs.deg. nc.gov/WaterResources/DocView.aspx?id=3140453&dbid=0&repo=WaterReso
urces&searchid=fa29cd09-e5c7-4993-bacc-fc2f557657d8]
- Per "Draft of NPDES Permit NC0087866" dated March 5, 2024 and signed by Sara Bassett,
Environmental Specialist I, it states:
"Section A (3) has been added due to a history of failed WET tests. The Division is aware the facility is
looking into this issue."
And
"The Whole Effluent Testing ["WET"] outlined in Section A. (4) has been updated to Pass/Fail per the
Division's 2020 strategy"
Due to the history of failed WET tests,
o Has the problem been identified and/or resolved?
o Has an investigation been performed to identify the reason for failed WET tests?
o Does the current permit (NC0087866) have WET limits?
o Should there be WET limits incorporated into the PTRWA permit?
[Source:
https://edocs.deg. nc.gov/WaterResources/DocView.aspx?id=3167676&dbid=0&repo=WaterReso
urces&searchid=fa29cd09-e5c7-4993-bacc-fc2f557657d8]
- Per "NPDES Electronic Reporting Requirements" letter dated June 24, 2016 and signed by Jeffrey O
Poupart (for S, James Zimmerman P G), it outlines the electronic reporting requirements for PTRWA.
However, looking at the NCDEQ Laserfiche, there is very basic and minimal information regarding the
John F. Kime WTP is available. These are public records, therefore:
o Is PTRWA properly submitting these documents electronically?
o Where are these documents housed?
o Who is responsible for uploading documents to the NCDEQ Laserfiche database, and
why are they not performing this responsibility?
o If electronic submission is mandated/required, why does the March 5, 2024 Draft
Permit letter allow PTRWA to submit all toxicity test results via email?
- Per NPDES PERMIT ISSUANCE letter dated August 18, 2017 and signed by S. Jay Zimmerman,
P.G., it indicates:
o Randleman Lake WTP was updated to John F. Kime WTP. How does the previous
documentation for Randleman Lake WTP tie into the John F. Kim WTP in NCDEQ
Laserfiche database and how does this affect the review of current permit?
o It states the classification is WS-IV CA*, where CA standards for "Critical Area", by
definition states, "the area adjacent to a water supply intake or reservoir where risk
associated with pollution is greater than the risk associated with pollution from the
remaining portion of the watershed." Yet based on this definition, nothing is being done
for upstream monitoring of the highly contaminated Upper Deep River as well as the Bull
Run and Richland Creek branches, both heavily dotted with industrial contaminators and
environmental polluters.
■ When was the last Biological, Chemical and Macroinvertebrate study for John
F. Kime WTP and Upper Deep River performed? I cannot find anything in the
NCDEQ Laserfiche database supporting any study that has been performed
since the late 1990s for the Randleman Reservoir and nothing in the last 20

years for the Upper Deep River. These studies should be performed on a
decennial basis. So, where are the reports?
o Upstream from the John F. Kime WTP, there have been 2 significant spills by
Alberdingk Boley (10/27-10/31/2022 and 11/8/2023) and High Point Eastside WWTP is
operating with an expired permit and incurring numerous fines on an almost weekly
basis, yet the PTRWA reports no significant events have occurred in the last 5 years? I
find this hard to believe. Eapecially when the Alberdingk Boley spill in October, 2022,
endured for 5 days.
o The fact that the Jamestown WWTP (closed in 1985), Eastside WWTP, and Richland
Creek have received Poor and Very Poor ratings and have been identified as potential
contamination sources, yet no further studies have been performed exact sources of
contamination, makes me believe the John F. Kim WTP and the Randleman Reservoir
are just as polluted and the PTRWA is not being truthful in their submissions. Mind you,
the contamination of Jamestown WWTP, Eastside WWTP and Richland Creek have
been known since the 1970s and continues today, almost 50 years later. Yet nothing is
being done to address, monitor, or identify source point polluters of the Bull Run, Deep
River and/or Richland Creek.
The current request by the PTRWA to increase output is directly related to development in the area.
Many of these developments are high -density and being developed on critical and protected watersheds:
o As I type, D.R. Horton is clearing the Johnson Farm located along Mackay/Guilford
College Rds (2221, 2207 Guilford College and 5300, 5230, 5303 Mackay Rds) in the
Town of Jamestown. As a community member, I have not seen anything indicating the
proposed development has been reviewed by the Army Corps of Engineers, nor have I
seen a public notice/hearing regarding such review. Why is that?
o 4718 Harvey Rd, Jamestown. Another high -density development is currently under
construction.
o A horse farm, located at 1903, 1905 and 1915 Guilford College Rd, is currently going
through the public hearing process with the Town of Jamestown Planning Board.
o For all 3 developments, I encourage you to take a look at the Town of Jamestown LDO
(https://library.municode.com/nc/'amestown/codes/land development ordinance). Per
Section 4.4 Technical Review Committee>4.4-3 Powers and Duties (f), the Planning
Director, Public Service Director, Town Manager, Planning Board representative, and
other agencies/individuals as appropriate (on an as -need basis) serves as the "watershed
review board", yet in reviewing the TRC meeting agenda/minutes, nothing about
watersheds are mentioned for the D.R. Horton development or 4718 Harvey Rd. Why is
that and how is this acceptable? Does this mean the decision of Town of Jamestown's
TRC trumps NCDEQ and Army Corp of Engineers?
o For all 3 developments, I recommend you look up addresses on Guilford County GIS.
All 3 sites involve high density developments in the Lower Randleman Watershed WS-IV,
yet the Town of Jamestown's Planning Board and Town Council approved these
developments. Was the Army Corp of Engineers ever notified about these
developments? Considering the Lower Randleman Watershed WS-IV has its own NC
General Statute, I find it hard to believe these developments were approved without
review and public notice for public comments on these proposals. And, if a public notice
did occur, it was not properly advertised or promoted by the Army Corps of Engineers.
o Based on the above information, I suggest the NCDEQ revisit the North Carolina
Division of Water Quality's Memorandum regarding the 1997 Upper Deep River Study
Report, dated January 13, 1998 and authored by Jay Sauber—specifically Appendix I & II
of —as it directly relates to dischargers and the estimations of future land use condition in
Guilford County. The information presented in this report is completely opposite of how
development in Guilford County is currently being handled. If there is a new report
addressing current population projections and development related to the John F. Kime
WTP or the Upper Deep River, it is not available in the NCDEQ Laserfiche [Source:

https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=100389&dbid=0&repo=Wat
erResources&searchid=fa29cd09-e5c7-4993-bacc-fc2f557657d81
OTHER ISSUES RELATED TO RANDLEMAN RESERVOIR/JOHN F. KIME WATER QUALITY
- Since the 1970s, decennial biological, chemical and macroinvertebrate studies have identified and
supported the Jamestown WWTP (closed around 1985), Richland Creek, and the Deep River are highly
contaminated, receiving ratings of Poor/Very Poor. While Jamestown WWTP, Richland Creek, and the
Deep River are identified as potential sources, further studies have not been done to identify the point
source discharges. Meanwhile the contamination of these bodies of waters continues as I write my public
comments. Also, it has been documented during low periods 74% of the Deep River is wastewater.
[Source: Water Quality Evaluation Upper Deep River, Cape Fear River Basin, 1983. North Carolina
Department of Natural Resources and Community Development Division of Environmental Management
Water Quality Section, February, 1985.]
- Per public record documents dating back to the 1990s, many former employees and citizens spoke
against the Randleman Reservoir, citing contamination of area waters and soils due to unsafe
containment and dumping practices by various industrial businesses along the Deep River. Yet,
construction of the Randleman Reservoir proceeded.
- The Deep River was never intended to be a public drinking water source, yet the Deep River empties
into the Randleman Reservoir, which operates with minimal oversight, monitoring, and/or enforcement.
- Around 1985, the Jamestown WWTP closed. It was identified as severely contaminated and in need
of repairs. Rather than spend the money to repair Jamestown WWTP, it was decommissioned. The
untreated, contaminated waters now flow downstream to Eastside WWTP, which is now incurring
frequent air and water quality violations because of the lack of monitoring and enforcement of industrial
contaminators and environmental polluters upstream from Eastside WWTP. These violations should be
affecting the Randleman Reservoir considering the contamination flows downstream.
- Due to projected population increases over the next decade, Guilford County is booming with
developments. However, many local municipalities are erroneously approving high -density developments
on critical and protected watersheds that possess specific NC General Statutes requiring developers to
abide by low- to medium -density development restrictions. However, no one at the regional, state, or
federal level is properly monitoring these developments. These developments are not only destroying the
watersheds but are having disastrous effects on the WWTPs. Meanwhile the developers profit from these
developments and incur zero consequences for their destruction, and taxpayers are left paying the price
in contaminated drinking water, higher taxes to correct the problem, and health and safety issues.
- Information regarding NC0087866 in NC Laserfiche is sparse at best; From 3/31/2016 to 3/8/2024,
there have been only 10 entries into the database regarding John Kime WTP. So there have been zero
issues with the Randleman Reservoir since its inception? With all the industrial contaminators and
environmental polluters upstream along the Bull Run, Richland Creek, and Deep River and various
violations/spills, it seems quite implausible that the Randleman Reservoir and/or John F. Kime has a
perfect record over the last 5 years of operation.
- A review of www.ptrwa.org, PTRWA fails to provide:
o PTRWA Board of Directors meeting schedule
o PTRWA Board of Directors meeting agenda and minutes
How can PTRWA monitor traffic on their website, when their website has "T' listed as the number of
Visitors to their website per their "Web Counter"?

Since the PTRWA is essentially owned by the municipalities of Archdale, Greensboro, High Point,
Randleman, Town of Jamestown, and Randolph counties, should its Board of Directors be abiding by
Chapter 33 C of the North Carolina General Statutes (link:
https://www.nclea.neVEnactedLeaislation/Statutes/HTML/ByArticle/Chapter 143/Article 33C.html)?
How is PTRWA upholding its public notice requirements when the information is not even available on
their website?
- When I submitted a FOIA to obtain PTRWA meeting agenda and minutes, Mr. Greg Flory advised
me I would need to pay $500.00 to obtain these records. These public records should be posted at time
of advertisement of meeting, both of which do not happen on www.ptrwa.org. I was advised by Mr. Flory
PTRWA advertises Board meetings via High Point Enterprise, however, the PTRWA services Archdale,
Greensboro, High Point, Randleman, Town of Jamestown, and Randolph County. Why do they advertise
only in one newspaper? I doubt the High Point Enterprise readership and subscribers covers all these
areas.
- Per an Affidavit, it appears the NCDEQ advertised the public notice for the John F. Kime permit in
the Greensboro News and Record. Again, the PTRWA services Archdale, Greensboro, High Point,
Randleman, Town of Jamestown, and Randolph County. How does this properly serve public notice
requirements when interested parties are located in various municipalities in 2 different counties (Guilford
& Randolph)? [Source:
https://edocs.deg. nc.gov/WaterResources/DocView.aspx?id=3187915&dbid=0&repo=WaterResources&s
earchid=cd7a 1 af5-d97f-4bc5-95d3-e7ea70c8ac1 c&cr=1 ]
ADDITIONAL QUESTIONS:
- Since the PTRWA operates as "Local Govt" and is funded by taxpayer monies, why does it operate
like a private entity?
- Why does the NC Laserfiche only contain 10 documents related to the John F Kime WTP
(NC0087866) dated 2016, 2017, 2022 and 2024? According to a letter dated June 24, 2016, per NPDES
Electronic Reporting Rule, the PTRWA was required to electronically submit documents, DMRs (effective
12/21/2016) as well as Notice of Intent to discharge in compliance with an NPDES general permit, Sewer
Overflow/Bypass Events, and NPDES program reports (effective 12/21/2020), yet the NCDEQ Laserfiche
is lacking a majority of this information. Why is that?
- Regarding Consumer Confidence Reports, John F. Kime (a.k.a. Randleman Reservoir) serves as a
public drinking water source for Guilford County, Randolph counties and surrounding communities.
Operating as a "local govt" providing a public drinking water source for Guilford and Randolph County
residents, why is PTRWA only monitoring and reporting minimal reporting requirements? Why are they
not held to more stringent standards? (link: http://www.ptrwa.org/wtp.htm) Also, since it consists of
multiple municipalities, shouldn't PTRWA be offering a combined Consumer Confidence Report of all
municipalities it serves?
- How is it PTRWA has recently advised they are purchasing $120M reverse osmosis treatment
system due to "emerging compounds" (a.k.a. PFAS/PFOS) detected in the Randleman Reservoir. Yet the
public is only notified after its Board of Directors approves the purchase of a $120M Reverse Osmosis
Treatment System?

As you can see there are huge problems with the John F. Kime (Randleman Reservoir). They do not
follow the rules nor is anyone holding them accountable. Meanwhile the unmonitored contamination of the
Upper Deep River flows downstream and empties into the Randleman Reservoir, yet the PTRWA is
claiming they have not encountered any deviances in their monitoring. Yet, there is a need for a $120M
reverse osmosis treatment system?
Something is very wrong here. And it is the job of the NCDEQ to make sure the PTRWA is complying with
all applicable laws and regulations for the health and safety of its customers. I request the NCDEQ
incorporate accountability and transparency requirements to their permit as they have been operating
without major oversight and this should be a huge compliance issue, considering they are receiving
taxpayer monies to operate facility and are playing the system to their benefit. I would also request a
public hearing regarding this matter.
Regards,
Kv6sd M.IZeeie,