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HomeMy WebLinkAboutNC0087866_Environmental Assessment_20020228/V( Jo (/ C �" /"Hazen and Sawyer, P.C. hIAZEN AND SA`�ER 4011WeslC2767lvd. Raleigh, INC 27607 Environmental Engineers & Scientists 919833.7152 Fax: 919 833-1828 February 28, 2002,E Mr. Jerry Perkins Public Water Supply Section Division of Environmental Health 1630 Mail Service Center ' .;n Raleigh, NC 27699-1630 Re: Piedmont Triad Regional Water Authority Greensboro, North Carolina Randleman WTP Environmental Assessment H&S Job No. 2901 Dear Mr. Perkins: Enclosed are fifteen (15) copies of a revised Environmental Assessment (EA) for the proposed Piedmont Triad Regional Water Authority Randleman Water Treatment Plant (WTP) in Randolph County, North Carolina. The EA has been revised to address comments of the North Carolina Division of Water Quality. The EA also discusses the resolution of the issues for and the final approval of the Randleman Lake project. The revised EA is being submitted for review and comment. Very truly yours, HAZEN AND SAWYER, P.C. Robert A. Berndt, P.E. Senior Associate RAB/mdb Enclosures cc: Mr. John Kime Mr. Don Cordell Perkins 2.28.02 Neu York. NY • Armonk. NY • WoaOhury. NY • Detroit. MI • Raleigh. NC • Charlalte. NC • Atlanta, Be • Fairfax. VA • Hail"Ood, FL • Boca Paton, FL • Fart Pierce, FL • Sarasota. FL • Miami. FL • Philadelphia. PA MR PIEDMONT TRIAD REGIONAL WATER AUTHORITY GREENSBORO, NORTH CAROLINA M RANDLEMAN WATER TREATMENT PLANT fm ENVIRONMENTAL ASSESSMENT J U LY 1997 REVISED FEBRUARY 2002 Im wl:;� STATE PROJECT AGENCY: North Carolina Department of Environment and Natural Resources Division of Environmental Health CONTACT: Mr. Jerry Perkins Division of Environmental Health Public Water Supply Section 919/715-3898 PREPARED BY: Hazen and Sawyer �, Raleigh, North Carolina A" s lit PIEDMONT TRIAD REGIONAL WATER AUTHORITY GREENSBORO, NORTH CAROLINA RANDLEMAN WATER TREATMENT PLANT ENVIRONMENTAL ASSESSMENT lm F" TABLE OF CONTENTS PAGE am A. Proposed Facilities and Actions 1 B. Existing Environment 2 �l C. Need for Proposed Facilities and Actions 20 D. Alternatives Analysis 22 E. Environmental Effects 25 F. Unavoidable Adverse Impacts and Mitigation Measures 40 References 43 Appendix A: Comments from N.C. Department of Environment and Natural Resources M, Review Agencies Appendix B: Mitigation Measures of the City of Greensboro for Secondary Impacts Associated with Urban Development F" Im REPORTS12904-GOMRANDLEMA.RPT I HAZEN AND SAWYER Environmental Engineers & Scientists PIEDMONT TRIAD REGIONAL WATER AUTHORITY RANDLEMAN WATER TREATMENT PLANT ENVIRONMENTAL ASSESSMENT A. Proposed Facilities and Actions The Piedmont Triad Regional Water Authority (PTRWA) is comprised of the governments me of Randolph County and the municipalities of Greensboro, High Point, Jamestown, Archdale and Randleman. The Town of Randleman and the City of Archdale are located in SIM Randolph County, while the other three municipalities are located in the adjacent Guilford County. The PTRWA was formed in 1986 for the purpose of identifying, evaluating and fm developing long-term water supply facilities for the member governments. M The proposed project consists of a water treatment plant (WTP) with a design capacity of 12 million gallons per day (mgd) to provide a supplemental treated water supply for the PEI PTRWA member governments to approximately the year 2011. The water source for the treatment plant would be Randleman Lake, an impoundment on the Deep River near the `M Town of Randleman. Construction of Randleman Lake is currently underway and a final environmental impact statement (EIS) was prepared for the reservoir project (USACE, rm 2000). The current environmental assessment does not specifically address the impacts of the reservoir project, which are included in the Randleman Lake EIS. The proposed water Mtreatment plant project also includes construction of an intake structure and raw water pumping station in Randleman Lake, and a pipeline to convey water from the intake M structure and pumping station to the water treatment plant. The locations of the proposed water treatment plant and intake structure and raw water pumping station are shown on Figure 1. A site layout of the proposed water treatment plant is shown on Figure 2. The estimated cost for the proposed treatment plant, including the intake structure and raw water pumping station, is approximately $44,600,000. This cost is based on the use of ozone for disinfection. If ultraviolet disinfection is used, the On REP0RTS2W4--00MANDLEMkRPT 1 HAMN AND SAWYER Environmental Engineers & Scientists rip 4L mm r� 1�1 rs�l m" f� �t t3 S FIGURE 1 Nsm IV fie ' °m I I " w » ML 70 INWWATE ssk (pLFASAw GARQEN) ORE ' PROPOSED INTAKE AND RAW WATER X PROPOSED WATER x 1r O PUMPING STATION j TREATMENT PLANT Lam, �i D1 • .-.-? , 1�,J --.� s — S ,_• 77 0.1 lZ 1'�,� ;�•: � r � ,• .� o; � `���. � ,,;� � .f' AIL.' �... ,� ��'� , ' �--• � ter-. � �� 1�. •,- , �i f�i— • I `1 '�� - , .. `' 1 �/ ` ''/�\i •moo � � �t• + (I • , '/'! ram'•% ,/' 't• •�.� ".. (1 v ` ` ; %��l.-� f • �� r ' , ��"�11"'�c� �",�',�--.. �,�. � &�•,r� f•, � _ ci � 1. ,� � t �_ 1� _`,{.._- - ,•, • ter-• `�. ,• �i� ,E"'` � �%�•`��-gib � � �J '� rj MY RIM 11 I �W/r"I 1 �^ /, ` �t,rr•_.�_�\ ����\� p7i RANDLEMAN WATER TREATMENT PLANT PIEDMONT TRIAD REGIONAL WATER AUTHORITI a ENVIRONMENTAL ASSESSMENT /� \, LOCATION MAP SCALE 1�� � -.QUAD: FIGURE 2 .... . -S7RL I .... .. -.. .... •$TREAM f 50F ' U FER 3 �{ o _ M f r: 1• 1 1• I I• c 1 i I L _ - I • t• 1 (n y I I• RAW WATER • x x .I -•PU ING' TATION S IJP • I'. A CC AD S R• _ I - - OZONE.G •ER TON N N i• N N ' i 1r O• O AND •'DE TRl1 U. .FL' 013,EL.6 4 •' o f -1 1� a �RM P •NO OLfI.B 2' { 6 . 1 •a. a •5.0' =.150FFE R. 1• .. .. • O p 1 AfAlNTENAN CHEMICAL Sf{Op . - .. .. - .. .. .{-• FAgLITY I . I LSTRAII f N c ➢ ... BUILDING • MAI 1 S4NiCHGEA_R' <<• i - � I I BU LD N0' O ..... i 1.5 MG cL£AIRWEI.L. •' D _ J i ' 400 :YEAzf :FLOOD 90 DI$TRIBU• ON -' IN 71 O" - RAW 9fAT6R:I OAK '{ PUMPING • - N .r ram• AND ' MAI ' 'S3X N'•. = STATION . EMI NG. .1 - _ _ . STREAM" .. '1. �AIG CLEA WE 5 R L�. i, 7 : _... LA N 1 .. . - 1 GOQ - p fl P - 1 7. ^:i� .. - •• .LAGOON 2 f 'f. ' -5D' ' $UFFER:� -• `U R .. 3 501-'� FFE 4 ti ••i NORMAL POOL EL 682 NORMAL POOL EL 682 100 YEAR FLOOD EL 690 ffi-MMD SAWYER Environmental Engineers i Scientists SITE PLAN 1 °=2001 I 'i 1 z •'h a� 1• Wa O[ . d PTRWA RANDLEMAN WATER TREATMENT PLANT SITE PLAN 0" cost would be reduced by approximately $3 million. The cost will be totally funded by the members of the PTRWA. F_" B. Existing Environment 0" 1. Topography and Soils The project area for the proposed Randleman WTP is in the Piedmont physiographic province, which has a general slope from the mountains on the west to the Coastal Plain rM on the east. The project area is located in northern Randolph County, where the hills are generally well rounded, indicating a geologically intermediate stage of erosion. The topography slopes from 850 feet in northwestern Randolph County to approximately 300 feet in southern Randolph County. The Deep River and its tributaries are deeply incised into the gently rolling hills and valleys, which generally slope from the northwest to the southeast. The Randleman Lake project area encompasses two major soil associations: (1) Helena - Wilkes and (2) Georgeville-Tirzah. The Helena -Wilkes soil association is derived primarily from acid crystalline rocks or mixtures with basic crystalline rocks and is characterized by yellow, brown, or yellowish -brown firm sandy clay to clay subsoils, often less than 18 inches thick and seldom more than 35 inches thick, and by a gray loam sand to yellowish -gray sand clay loam surface soil. Generally, the slopes range from 5 to 18 percent, resulting in medium to rapid surface runoff. Internal drainage is slow due to firm Fie subsoil and shallow parent rock. Most of the soil association is subject to severe erosion because of the predominance of coarse surface particles and the firm, fine -textured FM subsoils. a� The Georgeville-Tirzah soil association is derived primarily from the Carolina Slate Belt rocks and is characterized by light red to dark red firm silty clay subsoils and gray -brown oft fm REPORTS W4-003%RANDLEMA.RPT 2 HAZEN AND SAWYER Environmental Engineers & Scientists to red moderately firm silt loam to silty clay loam surface soils. Generally, the slopes range am from 4 to 18 percent, resulting in medium to rapid runoff. Internal drainage is medium. The surface has suffered moderate to severe erosion. Soils types at the proposed treatment plant site consist of Georgeville, Wynott-Enon and Wynott-Wilkes-Poindexter soils. The Georgeville soils are comprised of silty clay loam, with 2 to 15 percent slopes, and are gently sloping, very deep, well drained, eroded soils on uplands. They have a loamy surface layer and a clayey subsoil. Permeability is moderate and shrink -swell potential is low. Seasonal high water table is below 6 feet. The Wynott- r� Enon soils consist of gently sloping to strongly sloping Zion and Enon soils on uplands. Zion and Enon soils are moderately deep to very deep and well drained and have a loamy surface layer and a clayey subsoil. Permeability is moderately slow to slow and shrink - swell potential is high. Seasonal high water table is below 6 feet. The Wynott-Wilkes- �► Poindexter soils consist of gently sloping Wilkes, Zion and Poindexter soils on uplands. Wilkes, Zion and Poindexter soils are shallow to moderately deep and well drained and FM have a loamy surface layer and loamy to clayey subsoil. Permeability is moderately slow to moderate. Shrink -swell potential is moderate for Wilkes soils, high for Zion soils and low "m for Poindexter soils. Seasonal high water table is below 6 feet. 2. Land Use 'M The Randleman Lake project area has been heavily disturbed by human impacts, with much of the land in use as cultivated fields and pastures. The forestland has been altered to the point that its species composition does not fit easily into any of the natural community classifications. Based on the Randleman Lake Draft EIS, the predominant land uses in the Randleman Lake watershed are forest, pasture and cropland, which comprise 52.5, 11.9 and 8.0 percent of total land area, respectively (USACE, 1997). Single family residential land use comprises 13.7 percent of the total land area, and institutional, multi- family, commercial/office and industrial land uses comprise 8.0 percent. The remaining land uses, open space and water, comprise 5.9 percent. eft REPORTS2904-00MRMDLEMkRPT 3 HAWN AND SAWYER Environmental Engineers & Scientists ,.fw rat no The land use at the proposed water treatment plant site is primarily forestland, with some areas of agricultural land. 3. Surface Waters 0" The Deep River watershed is one of six major hydrologic areas in the Cape Fear River ,00, Basin and drains about 1,440 square miles. Randleman Lake will inundate portions of the Deep River and several of its tributaries, including Muddy Creek, Richland Creek, Reddicks �, (Register's) Creek, Hickory Creek and Bob Branch. Most reaches of the tributary streams are less than 50 feet wide, shallow and often turbid. The streams are subject to a flashy a� hydrology due to the rolling topography, steep gradients, narrow valleys and predominantly - clay soils that are conducive to fast runoff (USACE,1997). All of the watercourses that will be inundated by Randleman Lake are designated as Class WS-IV, Critical Water Supply Watershed by the State of North Carolina. The WS-IV classification applies to "water supplies in moderately to highly developed watersheds". The Critical Water Supply - Watershed classification is assigned to waters that are subject to a special management strategy. Nutrient Management Strategy rules for the Randleman Lake watershed (15A - NCAC 2B.0248 through .0251) have been adopted by the North Carolina Environmental Management Commission (NCEMC) and are currently in effect. The rules consist of controls on point and nonpoint sources, and are designed to address potential problems in the lake resulting from nutrient loadings to the lake. In accordance with the rules adopted by the NCEMC, all of the local governments with jurisdiction in the Randleman Lake watershed have enacted watershed protection ordinances for the watershed. In addition, all of the local governments have submitted stormwater management plans, which have been approved by the NCEMC. am Water quality in the Deep River was evaluated in the Cape Fear River Basinwide Water Quality Management Plan (NCDEHNR, 1996). Two stations on the Deep River were 6m evaluated in terms of biological and chemical ratings. A station on SR 1921 near the am Am REPORTS1 N-OOMANDLEMA.RPT 4 HAZEN AND SAWYER Environmental Engineers & Scientists AM R ra" Guilford County -Randolph County line received a biological rating of Fair, a chemical rating of partially supporting, and an overall rating of partially supporting. The support use ratings are a measure of how well a water body is supporting its designated best uses, such as water supply, swimming or fishing. Streams that are not supporting or are partially supporting their uses are considered impaired. A station at N.C. 220 Business received a al, biological rating of Good -Fair and an overall rating of support -threatened. Support - threatened waters are those where all uses are currently being supported but where water M, quality conditions are marginal and the waters may not be able to support the uses if conditions worsen. Updated water quality information on the Deep River is included in the Cape Fear River Basinwide Water Quality Plan (NCDENR, 2000). For a station on the Deep River at SR 1113 in Guilford County, a biological rating of Fair was assigned. This location, as well as the Deep River at SR 1921, received an overall rating of partially supporting because of an impaired biological community. Pollution associated with urban nonpoint sources in Greensboro and High Point are possible causes of impairment. Fecal coliform bacteria are a noted problem parameter for 6.8 miles of the Deep River from SR 1113 to SR 1921. A Total Maximum Daily Load (TMDL) will be developed to address high levels of fecal coliform bacteria in this section of the Deep River. The station on the Deep River at N.C. 220 Business received a Good -Fair biological rating, but an overall rating of fully supporting. Nonpoint source pollution will be addressed by the new watershed protection and stormwater management controls for the Randleman Lake watershed. FAM Previous intensive water quality studies of the Deep River by the North Carolina Division of Environmental Management in 1992-93 identified a number of water quality concerns, 101� including high bacteria levels; metals concentrations higher than action levels for copper, zinc and iron; a few dissolved oxygen concentrations below the instantaneous water quality � standard of 4.0 mg/L; violations of water quality standards for lindane and dieldrin; and elevated nutrient levels (NCDEHNR, 1994). Sampling for lindane and dieldrin was conducted by the North Carolina Division of Water Quality (NCDWQ) in 1997 and found no reportable concentrations (NCDEHNR,1998). Tests indicated that the waters of the Deep Affiq REPORTS12904-O031 MOLEMARPT 5 HAZEN AND SAWYER Environmental Engineers & Scientists rat River and Muddy Creek have the potential for significant problems from algae response to nutrients. Water quality in the Randleman Lake watershed has been adversely affected by a combination of low natural inflows and high flow rates of treated municipal wastewater. The High Point Eastside Wastewater Treatment Plant (WWTP) is a major contributor of flow to the Deep River. Construction of facilities for expansion and upgrading of the Eastside WWTP to provide nutrient removal is currently underway. These facilities are expected to be placed in service in the year 2003. The City of High Point has also implemented measures to minimize WWTP bypasses, or overflows or spills from the wastewater collection system to Randleman Lake. The City has an infiltration/inflow (1/1) reduction program which will enable the Eastside WWTP to operate within the hydraulic design capacity of the expanded plant. The expanded plant will have the capability to treat a peak flow of 3.0 times the design capacity of 26 mgd, or a peak wet weather flow of 78 mgd. Approximately $32.5 million is currently authorized (2002) for interceptor pipeline �► rehabilitations and replacements. In addition, $1 million is budgeted per year for replacement of obsolete sewer and water infrastructure. The continuing 1/1 reduction program will reduce the peak wet weather flows that must be processed by the plant, and will reduce the potential for overflows from the wastewater collection system and treatment plant. The design of the Eastside WWTP expansion facilities also includes measures to minimize the potential for treatment system failures. The plant expansion facilities include redundant equipment, multiple treatment trains, and alarm systems to alert operators of failure of crucial equipment. Redundant electrical power supplies will also be provided for the expanded plant. Dual power feed will be provided from two electrical substations, the Jackson Lake Substation and the Filter Plant Substation. Both substations are main delivery points for power from Duke Power Company. The proposed dual power feed system meets current regulatory requirements for treatment system reliability. Standby generators will also be provided for additional power system reliability. Operation of the expanded plant will also include preventive maintenance procedures to ensure that mom REPORTSQ904.00MANOLEMA.RPT 6 HAZEN AND SAWYER Environmental Engineers & Scientists equipment is maintained in proper working order throughout its full service life, and that equipment is replaced as needed. E" Additional water quality evaluations were conducted for the Randleman Lake EIS. These included an evaluation to predict metals concentrations within Randleman Lake resulting from the High Point Eastside WWTP discharge (USAGE, 2000). The State is expected to ensure that the High Point Eastside WWTP effluent continues to meet all water quality standards within the receiving stream (Richland Creek) as part of the NPDES permit process. Concentrations resulting from this effluent within the lake will be less than concentrations in the receiving stream; thus, compliance with appropriate NPDES permit limitations will also ensure meeting water quality standards for metals within the lake. However, the range of possible metals concentrations expected in the lake, and not just the annual average concentration, was also evaluated. For this analysis, monthly average metals concentrations for 1997 and early 1998 were reviewed. The existing NPDES permit specifies effluent limits equal to the State water quality standard for cadmium, total chromium, lead, mercury, and nickel. Chromium, mercury, and nickel were never detected above quantitation limits in either 1997 or early 1998 monitoring. For cadmium, the annual average concentration was well below the standard; however, a single observation in February 1997 of 2.2 µg/L was slightly above the permit limit and state standard of 2 µg/L. This one observation is believed to be an anomaly, and cadmium has not been detected above the quantitation limit in subsequent monitoring. Lead concentrations were well below the standard. However, violations of the plant's NPDES permit effluent limit for lead have occurred in July, August and September of 2001. While the effluent values exceeded the permit effluent limits, the influent lead concentrations were typically below the effluent limits. The reason for the increased lead in the plant effluent is unknown, although it is believed to be related to the ongoing construction of the treatment plant expansion facilities. The City of High Point has conducted detailed investigations for high lead concentrations in the wastewater collection system and the treatment plant and has found no potential sources of lead. While investigations are continuing, no further exceedances of the effluent limit for lead have occurred. In addition, based on the results of the City's previous investigations, City staff have indicated that they do not expect violations of the REPORTS'2904-OOMANDLEMA.RPT 7 HAZEN ,AND SAWYER Environmental Engineers & Scientists lead effluent limit to occur once the plant is expanded and is in normal operation. In any am event, operation of the WWTP in compliance with the existing NPDES permit is expected to result in concentrations of metals in the lake which are well below applicable standards F" for cadmium, total chromium, lead, mercury, and nickel. Silver, copper, and zinc are also monitored by High Point, but do not currently have NPDES permit limits. For these three metals, the State specifies an Action Level, rather than a water quality standard. Silver has been detected once in effluent monitoring, at a concentration well above the Action Level. This anomalous observation is likely due to an industrial process discharge and is not reflective of average loadings. NCDWQ has not _ monitored for silver within the Deep River during their intensive surveys. Further, the quantitation limit used in the analyses of the effluent is nearly 100 times greater than the Action Level. As a result, there are no data on which to base a quantitative analysis of r� silver concentrations in the lake resulting from the WWTP discharge. It is suspected, however, that average silver concentrations in the WWTP effluent will be low, and that any occasional peak loads will be rapidly diluted upon entering the lake. For copper and zinc, individual monthly average concentrations in the effluent, as well as the annual average concentration, were above the State Action Levels. For these constituents, an analysis of expected ambient concentrations within Randleman Lake was conducted. The results of the analysis conducted for the Randleman Lake EIS indicated the ranges of predicted metals concentrations in the lake segment below the discharge, as shown in Table 1. For both copper and zinc, the upper bound on the predicted concentration is well below the State Action Level, due to a combination of losses to sedimentation and dilution. The combined effect of sedimentation and dilution will also result in rapid diminution of concentrations within downstream segments of the lake, with the result that concentrations at the water intake should approach background levels. At the projected design flow from the Eastside WWTP of 26 mgd, discharge at the same metals concentrations are expected to result in maximum copper concentrations less than 2.3 µg/L, and maximum zinc concentrations less than 17.0 µg/L within the upstream Deep Pam► REPORTS129W-OOMANULEMXRPT 8 HAZEN AND SAWYER Environmental Engineers & Scientists M, 0" River arm of the lake, still well below State Action Levels. Additional information on this analysis is presented in the Randleman Lake EIS, Appendix F (USACE, 2000). Table 1 Range of Estimated Metals Concentrations (µg/L) in Upstream Deep River Arm of Randleman Lake Parameter Estimated Concentration State Action Level Minimum Maximum Copper 0.5 1.9 7.0 Zinc 2.4 14.1 50.0 Other sources of nutrients and other pollutants to the Deep River include nonpoint sources and minor point source discharges. A list of NPDES dischargers in Subbasin 03-06-08 of the Deep River watershed is included in Table 2. Urban areas in the Deep River watershed upstream of Randleman Lake include Kernersville, Jamestown, and High Point. Agricultural areas also contribute runoff to the Randleman Lake watershed. These include six operating dairies, which are located in the watershed.' In order to evaluate the risks associated with the operating dairies, an ana fecal coliform concentra ' ns in the lake was also conducted (Hazen and Sawyer, 1998). The analysis included estimates of the potential upper bound feca coliform bacteria concentrations in each segment of the lake. Segmentation of the lake for this analysis and other water quality modeling is shown on Figure 3. The predicted range of the 801" percentile of fecal coliform concentrations is shown in Table 3. ' Three of the existing dairies will cease operation on or before December 2004 due to property acquisitions by the PTRWA associated with Randleman Lake or other direct agreement with the PTRWA. REPORTM904-00"ANDLEMA.RPT 9 HAZEN AND SAWYER Environmental Engineers & Scientists TABLE 2 NPDES Dischargers in the Randleman Lake Watershed Discharger NPDFS Permit Number Discharge Location* Permitted Flow, mod* Type of Discharge Amerada Hess Corporation NCO069256 UT East Fork Deep River NL Stormwater** Ashland Petroleum Company NCO065803 UT East Fork Deep River NL Stormwater** Carolina Steel Corporation NCO084492 UT West Fork Deep River 0.0144 Groundwater Remediation Colonial Pipeline Company NCO031046 UT East Fork Deep River NL Stormwater** Crown Mobile Home Park (MHP) NCO055255 UT Hickory Creek 0.042 Domestic NCDOC — Sandy Ridge Corr. Ctr. NCO027758 UT West Fork Deep River 0.0175 Domestic Exxon Company NC0000795 UT East Fork Deep River NL Stormwater** Exxon Company, USA NCO084522 UT Jenny Branch 0.0216 Groundwater Remediation S. Guilford High School NCO038229 UT Hickory Creek 0.012 Domestic Southern Elementary School NCO038091 UT Hickory Creek 0.0075 Domestic Sumner Elementary School NCO037117 UT Hickory Creek 0.009 Domestic Hidden Forest Estates MHP NCO065358 UT Deep River 0.027 Domestic High Point Ward WTP NCO081256 UT Richland Creek 10 Municipal WTP Solids Handling High Point Eastside WWTP NCO024210 Richland Creek 16 Municipal WWTP HRS Terminals, Inc. (GNC Energy Corporation) NCO074241 UT East Fork Deep River NL Stormwater** Hickory Run Mobile Home Park (Huntington Properties, LLC) NCO041505 UT Bull Run Creek 0.035 Domestic Louis Dreyfus Energy Corporation NCO026247 UT East Fork Deep River NL Stormwater** REPORTWO04-00MRMIDLEMkRPT 10 HAZEN AND SAWYER Environmental Engineers & Scientists Table 2 (Continued) NPDES Dischargers in the Randleman Lake Watershed . Discharger NPDES Permit Number Discharge Location* Permitted Flow, mgd* Type of Discharge National Pipe and Plastics, Inc. (LCP National Plastics, Inc.) NCO036366 UT West Fork Deep River NL Cooling Water, Cooling Tower Blowdown Plantation Pipeline Company NCO051161 UT East Fork Deep River NL Stormwater** Plaza Mobile Home Park NCO041483 UT Hickory Creek 0.003 Domestic Rayco Utilities, Melbille Heights NCO050792 Muddy Creek 0.0315 Domestic Rayco Utilities, Penman Heights NCO055191 UT Muddy Creek 0.025 Domestic Star Enterprise NCO022209 UT Long Branch NL Stormwater** Triad Terminal Company NCO042501 UT East Fork Deep River NL Stormwater** William Energy Ventures (Conoco, Inc.) NC0074578 UT Long Branch NL Stormwater** Total 26.245 Total, Excluding High Point Ward WTP and Eastside WWTP 0.245 * NL = no flow limit; UT = unnamed tributary ** Located at the "tank farm" along I-40. REPORTS12804.00MMI)LEMARPT 11 HAZEN AND SAWYER Environmental Engineers & Scientists KERNERSVILLE IOAK HOLLO \\\ 1 0 1 2 3 Miles LAKE \ \ J z HIGH POINT / alz LAKE l U O WEST o ORK --� ¢ EAST 0 FORK WATERSHED TBOUNDARY 1 J OAK HOLLOW \ LAKE II ULL I' HIGH POINT RU \ — LAKE \ JAME TOW DEEP \ RIVEREXISTI/ J EASTSt R E CREEKS \ W WTP HICKORY DEEP CREEK ! / DEEP RIVER 1 RIVER \ ' RICHLAND CREEK PROPOSED EASTSIDE \ W WTP DISCHARGE \ GUILFORD COUNTY I \ DOLPH COUNTY '— — \ DEEP / ARCHDALE RIVER 3 \ MUDDY \ PROPOSED MUDDY CREEK CREEK WATER INTAKE \ 3A WATERSHED � — — \ 3B \ BOUNDARY \ \ MUDD J CREEK 2 ' DAM ADLEMAN l7FimN ffiD Sam Environmental Engineers S Scientists Table 3 Estimated Fecal Coliform Concentrations for Randleman Lake Segment Estimated Range of 80th Percentile Concentration of Fecal Coliform Bacteria During Low Flow Conditions (organisms/100 mL) Deep River 1 104-223 Deep River 2 10-23 Deep River 3A 5-11 Deep River 313 18-39 Muddy Creek 1 32-144 Muddy Creek 2 59-130 Near Dam 35-76 In all cases, the predicted range is less than the 400 organisms per 100 mL water quality standard for the 80th percentile. The conservative predictions are also less than the geometric mean water quality standard of 200 organisms per 100 mL in all segments except Deep River 1, reflecting the fact that die -off is substantially increased in a lake compared to existing free -flowing stream conditions. Reductions in fecal coliform concentrations in the lake would be primarily due to the increased residence time and �► dilution volume. Predicted concentrations are highest in the Deep River 1 segment because the dilution volume is small and the residence time is short. It was also assumed for this analysis that the High Point Eastside WWTP would discharge into Deep River 1. Since the High Point Eastside WWTP is currently planned to discharge into Deep River 2, OWN fecal coliform concentrations in all segments are expected to be below the water quality standard. M" M REPORTSV904-00MMDLEMARPT 12 HAZEN AND SAWYER Envimff rstW Engineers & Sdernism 4111 �1 The above screening analysis predictions are segment -wide averages. Therefore, exceedances of the standard for fecal coliforms may still occur in the locality of any concentrated sources, such as operating dairies. However, the predicted fecal coliform concentrations in segment Deep River 36, the location of the proposed water intake, are well below the state water quality standard of 200 organisms per 100 mL for the protection of human health. F" No sampling has currently been conducted in the Deep River for Cryptosporidium or Giardia, organisms which can cause human health concerns if present in raw water supplies. However, the proposed use of ozonation for disinfection would provide effective disinfection performance for Cryptosporidium and Giardia compared to other types of disinfection. Ultraviolet (UV) disinfection would also be effective for Cryptosporidium and Giardia inactivation. In order to address the projected impacts of nutrient loadings to the lake, the NCDWQ indicated in their comments on the Randleman Lake EIS that the PTRWA should prepare a comprehensive nutrient management plan for the Randleman Lake watershed. This plan was needed to address existing and projected nutrient loadings to the proposed lake and to determine required nutrient management measures to allow meeting the water quality standard for chlorophyll a. To address this request by the NCDWQ, modeling was conducted by Tetra Tech, Inc., and the results were summarized in the Draft Nutrient Reduction Strategy and Implementation Plan (Hazen and Sawyer, 1998). As a part of their review of this report, the NCDWQ conducted additional modeling and evaluated additional nutrient management options (Research Triangle Institute, 1998). �► The results of these two modeling studies were incorporated in a modeling study prepared by the NCDWQ and presented in the NCEMC "Report of Proceedings" on the proposed reclassification of the Deep River for water supply purposes (NCDENR, 1998). The modeling study by NCDWQ indicated that moving the High Point Eastside WWTP discharge away from shallow water to a deeper point near Freeman Mill (approximately 1.5 miles below the present outfall) would result in significantly lower eutrophication in the aft aEPORTST904-OWANDLELMRPT 13 HAZEN AND SAWYER Environmental Engineers & Scientists upper arm of the Deep River. The NCDWQ study concluded that this discharge relocation would substantially reduce the potential for eutrophication in the upper Deep River arm because of the elimination of a major source of nutrients that would support algae growth in that arm, and the ability of the lake waters to better assimilate the nutrients at the downstream site. Stringent basin -wide nutrient control measures were also proposed by NCDWQ to address expected elevated trophic conditions in the lake. In early 1997, NCDWQ staff informed the PTRWA of the need to implement a "Comprehensive Wat " as part of the State 401 water quality certification process. The Plan was to include assurances that point and nonpoint controls on nutrients would be imposed to provide protection of the lake waters. Elemen i of this plan are now specified in NC Administrative Code rules adQvted by the NCEMC on November 12, 1998 (15A 0% NCAC 213.0248 through .0251). The major elements of the rules inc u e provisions for 50- foot buffers along both sides of all perennial and intermittent streams, regulation of tree e, cutting around those streams, control of housing density within the reservoir watershed and more stringent controls within the first 1/2 mile outside the lake normal pool, limitations on nutrient loadings for the High Point Eastside WWTP based on an effluent phosphorus limit of 0.5 mg/L at the expanded 26 mgd permitted flow (in addition to relocating the discharge sm approximately 1.5 miles downstream), and other stormwater protection measures. Based on these nutrient control measures, the modeling study by NCDWQ concluded that the 0, average chlorophyll a of the reservoir should be less than 20 µg/L, with all segments predicted to average less than the standard of 40 µg/L. In adopting the rules for the `-"' Randleman Lake watershed, the NCEMC also concluded that the rules" . . . should result in a lake that will support all designated uses assigned and that the reclassification action of M' the Commission would be consistent with the requirements of the Federal Clean Water Act and the State's laws and rules" (USACE, 2000). The NCDWQ also has records that show several abandoned gold mines and at least one ftc' abandoned gold processing site (McCullers Mill) in the Randleman Lake watershed. According to NCDWQ, mercury was dumped from the McCullers Mill site into Copper Branch, a tributary of the Deep River upstream of SR 1113, after it was used to process the gold ore. Mercury is of concern due to potential food chain bioaccumulation. fm Oft REPORTS%2W4-OOMMDLEMARPT 14 HAZEN AND SAWYER Environmental Engineers & Scientists an C 'm Monitoring for mercury by NCDWQ in the Deep River downstream of Copper Branch in 1992/1993 and 1997 showed mercury concentrations below detection limits for all samples (NCDEHNR, 1994 and NCDEHNR, 1998). Based on the results of this monitoring, abandoned gold mines and gold processing sites are not expected to result in exceedances of the water quality standard for mercury in the lake. Additional t naiyses were conducted on the predicted water quality in the lake to evaluate impacts of lindane, phenolics and unidentified organic chemicals detected in NCDWQ monitoring in the Deep River drainage basin (Hazen and Sawyer, 1 }. Lindane has been found in Richland Creek downstream of the High Point Eastside WWTP. Lindane has also been identified in the Eastside WWTP effluent, but the presence of lindane is intermittent and concentrations are highly variable. Lindane is listed by the USEPA as a priority pollutant. NCDWQ has adopted a water quality standard for lindane of 10 nanograms per liter (ng/L) for the protection of aquatic life. NCDWQ monitoring in 1992 and 1993 found relatively high concentrations of lindane downstream of the High Point Eastside WWTP. For this reason, the model used for the toxic substances analyses used the upper bound estimate of mass loading of lindane (5 µg/s) observed at the monitoring location just downstream of the High Point Eastside WWTP to provide an upper bound estimate of in -lake concentrations. Assuming that the Eastside WWTP is the source of lindane concentrations in the lake, the modeling indicated that the reduction in lindane concentration from the source to the proposed water intake ranged from 71 percent based on dry year annual flows to 99.8 percent for dry year conditions during the growing season. Based on the modeling, estimated upper bound concentrations for lindane during the growing season were determined as follows: mo Nq Lam OW raw REPORTS129W-OOMANDLEMARPT 15 HAZEN AND SAWYER Environmental Engineers & Scientists Table 4 am Estimated Upper Bound Lindane Concentrations During the Growing Season Aft on Deep River 1 (Below Point of Maximum Deep River 36 Lindane Concentrations) (At Water Intake Estimated Estimated Value, Range, Value, Range, Flow Regime ng/L ng/L ng/L ng/L Dry Year 1967 5.07 3.52-5.86 0.010 0.007-0.24 Wet Year 1975 2.82 2.44-2.92 0.25 0.043-0.37 In all cases, both the best estimate and the maximum predicted lindane concentrations at either location are below the State water quality standard of 10 ng/L and the drinking water standard of 200 ng/L, despite conservative assumptions about mass loading rates. Therefore, existing lindane sources do not appear to present any risk of exceedances of s water quality standards in the lake. In 1997, NCDWQ sampled the Deep River at various locations for total recoverable phenolics (phenols). There is currently a State standard for phenols of 1.0 µg/L for water supply waters. For the 1997 sampling, 36 of 45 samples were greater than 1.0 µg/L, with a maximum of 52 µg/L. Relatively high concentrations of phenols were found in the Deep River downstream of the High Point Landfill and the Seaboard Chemical Corporation site, in Richland Creek upstream and downstream of the High Point Eastside WWTP, as well as further downstream in the Dee River. A conservative analysis was performed to ,�, p Y P o� determine the range of concentrations of phenols expected in the lake. The range of ��/y!►� predicted phenols concentrations for various segments of the lake (see Figure 3) are shown as follows: W" R021ORTS2904-00"MDLEMARPT 16 HAZEN AND SAWYER Environmental Engineers & Scientists look Table 5 am Predicted Phenols Concentrations for Randleman Lake Im am Segment Predicted Phenols Concentration, L Minimum Maximum Deep River 1 0.31 4.4 Deep River 2 0.006 0.45 Deep River 3A 0.00002 0.1 Deep River 3B 0.68 Muddy Creek 2 2.3 x 10- 0.10 Near Dam 7.8 x 10- 0 Predicted removal of phenols within the lake range from 97 to greater than 99.99 percent. �► The results suggest that there is a possibility of exceeding the State water quality standard for total phenols at the upper end of the lake (Deep River 1) and at the proposed water intake (Deep River 313). This is based on the assumption that the projected load of phenols enters directly into these segments. However, it is unlikely that the unidentified phenols that have been observed in the Deep River are the problematic chlorinated phenols covered by the State standard. This is based on the results of 1997 analyses conducted by NCDWQ for semi -volatile compounds using EPA Method 625, which AIR includes the chloro and nitro -substituted phenols which are most likely to cause taste and odor problems and are the intended targets of the North Carolina standard for total phenols (Hazen and Sawyer, 1998). In this testing, none of the 11 phenolic compounds measured by EPA Method 625 was detected above quantitation limits. In addition, once the lake is impounded, residence times will increase and will lead to increased opportunity for removal of phenols by biodegradation. Thus, concentrations are expected to decline rapidly with distance away from any source of loading. In general, ,.� unidentified phenols compounds are not expected to present a water quality problem since chlorinated phenols are not likely to be present at significant levels. However, further investigation may be needed to determine the source of phenols in the Randleman Lake / ✓ watershed. The PTRWA is inthe process of developing a monitoring program in am fft' REPORTS1290-MMANOLEMA RPT 17 HAZEN AND SAWYER Environmental Engineers & Scientists wra c� cooperation with the NCDWQ to provide long-term monitoring of water quality in the lake following completion of construction. This monitoring would be conducted by the PTRWA and would include phenols, among other parameters. If this monitoring detects any water quality problems, the NCDWQ has the authority under the Critical Water Supply Watershed designation for the Randleman Lake watershed to adopt additional rules to protect water quality in the lake. Water quality monitoring for organic substances was conducted by NCDWQ in 1992-93 and 1997 in the Upper Deep River. In reporting these data, NCDWQ noted the presence of many "unidentified peaks" in the organics analyses. The unidentified peaks were detected using EPA -approved gas chromatographic (GC) methods used to monitor water quality for chlorinated pesticides and PCBs, acid herbicides, organophosphate pesticides, semivolatile organics and volatile organics. Unidentified peaks are routinely followed up with additional analysis using mass spectrometry (MS) methods when the peaks occur above a threshold activity level (indicating relatively high concentration). The activity level MR threshold for proceeding to MS analysis is equivalent to a concentration in water for most compounds of approximately 5 µg/L. None of the unidentified peaks on the chlorinated Rai pesticide, acid herbicide or organophosphate pesticide GC scans in the Deep River samples were present at sufficient concentrations to merit further identification by MS dft methods. This is an indication that the unidentified compounds were present at low concentrations. On the semivolatile GC scan, many of the unidentified peaks are assumed �^ to represent phenolic compounds, as discussed above. In general, the unidentified peaks likely include a mixture of naturally -occurring compounds, synthetic compounds contained in nonpoint stormwater runoff and compounds associated with the High Point Eastside WWTP. However, the unidentified peaks are present at concentrations below the threshold required to pursue identification by MS methods and are unlikely to involve a significant human health risk or adversely affect water quality in the lake. "s REPORTS12904-0031RANDLEMARPT HAZEN AND SAWYER Environmente! Engineers & Scientists ar FAA 4. Groundwater Groundwater in the Upper Cape Fear River Basin is stored in the surface layer of loose, incoherent rock material (regolith) and in the underlying bedrock. The surface layer contains nearly all groundwater and has an average thickness of 50 feet and an average depth to water table of 15 feet. The maximum availability of groundwater in the Randleman Lake area is estimated to be approximately 0.29 to 0.36 mgd per square mile (USAGE, 1997). Potential concerns related to groundwater in the Randleman Lake area include the Seaboard Chemical Corporation site and the High Point Landfill, both of which are now am closed. These two sites have been identified as sources of toxic substances that have contaminated groundwater at each site. Previous modeling studies have predicted that ,7-* contaminated groundwater from these sites would have no significant adverse impact on the use of Randleman Lake as a water supply or the ability of the proposed water treatment plant to meet requirements of the Safe Drinking Water Act (USACE, 1997). Other remedial investigation studies have been completed and, along with subsequent reports, are currently being evaluated by the North Carolina Division of Waste Management (NCDWM) (Blasland,1999; Environmental Resources Management,1999a and 1999b; SEI, 1999). When the NCDWM evaluation of these reports has been completed, the reports will be revised as necessary and the appropriate remedial measures for the sites will be determined. Pending completion of this evaluation, the NCDWM has indicated that the above reports "provide alternatives that can achieve our goals for protection of the environment at the site and in adjacent waters of the Deep River dft or the Randleman Reservoir, if it is constructed" (NCDENR, 1999b). NCDWM also indicated that they "remain confident that it is technically feasible and economically viable "" to achieve a drastic reduction in any pollutants leaving the site and accordingly minimize the potential of any pollutants from this site causing any violations of water quality in the lake. Furthermore..., the NCDWM has a strong commitment that the overriding criteria for actions from our division will be that all water quality standards and uses will be protected AUR REPORTWN4.00"ANDLEMIIRPT 19 HAZEN AND SAWYER Environmental Engineers & Scientists in the lake." The USEPA has also expressed "confidence that the programs NCDENR are considering are adequate to prevent significant amounts of contaminants in the proposed lake water" (USEPA, 1999). C. Need for Proposed Facilities and Actions 4M Randleman Lake would provide a safe and dependable water supply for the Piedmont sift Triad region to satisfy estimated water demands for a 50-year planning period. Due to regional growth in water demand, water shortages have already occurred in the region. The EIS for Randleman Lake contains annual average water demand projections for the PTRWA members (USACE, 2000). Water demand projections were presented for conditions with and without consideration of water conservation. Water conservation is estimated to provide a reduction in water demand of 2.5 percent each decade, or 12.5 ,ram percent over the 50-year planning period for Randleman Lake. Water demand projections from the Randleman Lake EIS are presented in Table 6. Existing raw water sources for the PTRWA members have a combined 50-year safe yield Ma of approximately 60 mgd. Based on the water demand projections presented above, an annual average water demand with water conservation of approximately 81 mgd is s� projected for the year 2020. The portion of the year 2020 water demand to be met by water from Randleman Lake is approximately 21 mgd. Assuming a typical maximum day to annual average water demand ratio of 1.5, the projected treatment capacity required for the Randleman WTP in the year 2020 is approximately 31 mgd. Based on the water demand projections, the proposed initial Mr Randleman WTP capacity of 12 mgd will meet water supply needs of the PTRWA members to approximately the year 2011. OM Faft REPORTSV904-003VMDUBMRPT 20 HAZEN AND SAWYER Environmental Engineers & Scientists Table 6 SY50 versus Projected Water Demands for PTRWA Members Existing Water Demand, mgd PTRWA SYSo, Year Year Year Member mgd 2000 2010 2020 Greensboro 36.0 37.6 44.2 51.9 High Point 22.7 13.8 17.0 21.0 Jamestown 0.0 0.5 0.7 0.9 Archdale 0.0 0.9 1.4 1.9 Randleman 1.4 1.1 1.3 1.5 Randolph County 0.0 0.0 2.0 7.8 TOTAL 60.1 53.9 66.6 85.0 Total, with Water Conservation 60.1 53.9 66.6 80.8 Minimum Total Water Demand to be Met from Randleman Lake (annual average)* -- -- 6.5 20.7 Projected Treatment Capacity Required for Randleman WTP (maximum day) -- -- 9.8 31.1 Source: Randleman Lake EIS, December 2000 * Based on difference between total water demand with water conservation and the total of the existing 50-year safe yields (SY5o) of PTRWA members. Actual water withdrawn from Randleman Lake may be greater because of specific water supply needs of individual PTRWA members. per REPORTS12904-00WIANDLEMA.RPT 21 HAZEN AND SAWYER Environmental Engineers & Scientists D. Alternatives Analysis Alternatives to the proposed construction of the Randleman WTP include (1) the no action alternative and (2) constructing the proposed treatment plant at another location. The no action alternative is not considered viable because it would not meet water supply and water treatment needs of the PTRWA members, even assuming water conservation measures are taken by the members. Projected water demands will exceed the capacity of the existing water supply sources around the year 2005. In addition, it is not feasible to modify the existing water supply reservoirs in order to increase their safe yield because they are located in areas essentially surrounded by urban development. Also, Greensboro and High Point, the largest water users, have developed their water supply watersheds to the maximum extent feasible. For these reasons, the no action alternative is not considered a viable alternative to the proposed project. Constructing the proposed treatment plant at another location is not considered feasible because of water quality considerations. Modeling studies by Black and Veatch have indicated that the area in the lower portion of the lake to the west of U.S. 220 Bypass ,M would have the highest water quality in the lake (USACE, 1997). An evaluation of alternative water supply sources, including wastewater reuse/recycling, is not included in this EA because that evaluation is included in the Randleman Lake EIS. The Draft EIS identified Randleman Lake as the preferred alternative for the future water supply for the PTRWA members. Since the Draft EIS was published in 1997, the State of � North Carolina has issued a 401 Water Quality Certification for the proposed lake (NCDENR, 1999a), and the NCEMC has reclassified the Deep River and its tributaries in °- the Randleman Lake watershed as WS-IV, Critical Water Supply Watershed (NCDENR, 1998). The USEPA has also reviewed the additional studies and evaluations conducted since the Draft EIS was published and concurred with the NCEMC conclusions (USEPA, 1999). Additional information on the Randleman Lake alternatives evaluation is contained in the final EIS for the Randleman Lake project (USACE, 2000). Ow REMRT92W4-003~DLEMkRPT 22 HAZEN AND SAWYER Ernrirowwtal Engineers & Sdentlsts Evaluation of treatment system alternatives for the proposed plant involved a review of AM design criteria and operations of several water treatment plants that treat typical North Carolina surface waters. The treatment plants reviewed included those serving the City of Greensboro (Townsend Plant), the City of High Point (Ward Plant), and the City of Raleigh (E.M. Johnson Plant). The High Point Ward Plant withdraws water from High Point Lake, located on the Deep River upstream of Randleman Lake. Both Greensboro and High Point are members of the PTRWA. All three treatment plants use conventional treatment methods (i.e., coagulation, settling and filtration) and have provided drinking water that meets or exceeds current USEPA drinking water standards. These plants represent the range of raw water quality and plant performance expected for the proposed Randleman WTP. All of the plants currently provide treated drinking water by coagulation with alum, mixing with mechanical rapid mix and flocculation equipment, settling of particulate matter in settling basins, and filtration with dual media sand and anthracite filters. The current primary disinfection process for microorganisms at each of these plants is free chlorine disinfection. The High Point and Raleigh plants use chloramine as a residual disinfectant, while the Greensboro plant uses free chlorine. Of the three plants reviewed, only Raleigh had evaluated the use of ozone to achieve higher levels of disinfection. Raleigh has chosen to construct an ozone process in anticipation of proposed USEPA Disinfectants/Disinfection By -Products (D/DBP) regulations, Stage 1 of which was promulgated in December 1998 and Stage 2 of which is expected to be promulgated in mid-2003. These regulations, along with other proposed regulations, will require higher levels of disinfection in the treatment process, as well as lower allowable levels of disinfection byproducts in the drinking water. At the time of the �.► Randleman WTP design study, the other communities were starting to evaluate existing treatment processes to assess their ability to meet the proposed new regulations. MQ The proposed Randleman WTP would include conventional treatment processes similar to the three existing plants evaluated. The Randleman WTP design is currently based on the use of ozone for disinfection. The filtration process would be designed to allow future No f, REPORTWW4.00"AHDLEMA.RPT 23 HAZEN AND SAWYER Environmental Engineers S Scientists �9 • conversion to granular activated carbon media, and would contain air/water backwash underdrains for efficient cleaning of the filter media. MW Flexibility would be provided in the disinfection scheme to allow the use of free chlorine disinfection as a backup for ozone disinfection. For either application, chloramine would be used as the distribution system residual disinfectant to minimize disinfection byproduct formation. The use of chloramine as the residual disinfectant would result in the need for the utilities receiving Randleman WTP water to either switch to chloramine, or to segregate em the portion of the distribution system receiving Randleman water to eliminate mixing of the two residual disinfectants. Mixing of chloraminated water and water with free chlorine MR E� could result in taste and odor problems, as well as residual die -off. The plan for the Randleman WTP is to provide chloraminated water due to the need to control trihalomethanes (THMs) and haloacetic acids (HAAs) in the distribution system. It is expected that all PTRWA member utilities will use chloramine as the residual disinfectant; therefore, no isolation of the distribution systems is needed. Ozone is currently planned to be used as the primary disinfectant to ensure that the drinking water will meet future disinfection requirements (currently proposed by the USEPA) for Giardia and Cryptosporidium. Ozone is a strong disinfectant and is also very effective for control of tastes and odors, and for color removal. Control of tastes, odors, and color will be important as the new reservoir reaches equilibrium, and later as the reservoir undergoes normal seasonal cycles of turnover and periodic algae blooms. Effective disinfection will be important considering the urban and agricultural areas in the watershed, as well as the point source input from the Eastside WWTP into Randleman Lake. Ultraviolet (UV) light is also being considered as an alternative to ozone for disinfection. UV disinfection has not been used extensively for water treatment disinfection in the U.S., but is considered to be able to provide a level of disinfection comparable to ozone at less cost. The use of UV light has also been recently recognized by the USEPA as an acceptable means of inactivating Cryptosporidium. This organism has been the driving "M REP0RTSQN4.003\RANDLEMARPT 24 HAZEN AND SAWYER Environmental Engineers & Sciengsts 6" F" force behind new drinking water rules (Long Term 2 Enhanced Surface Water Treatment Rule) that are expected to be promulgated in mid-2003. The USEPA is currently in the process of developing guidance manuals for the design and operation of UV systems. Another alternative to ozone for disinfection that is being considered is post -filtration membrane treatment. Membranes would provide a positive physical barrier to microbes such as Giardia and Cryptosporidium. However, its cost may be higher than that for UV disinfection. In addition, previous use of post -filtration membrane treatment for water treatment disinfection is also relatively limited in the U.S. The plant would be designed to have the capability to add advanced processes, such as dual filtration or granular activated carbon, in the future should they be required. However, no additional water treatment costs are required as a function of the expected water quality in the lake. The proposed level of technology is the same as that which would be used for any surface water supply reservoir in the Piedmont of North Carolina in order to meet expected drinking water standards. The basic design philosophy for the Randleman WTP is to provide flexibility for additional treatment capacity or "advanced processes" in a cost- effective manner. The initial plant facilities would be designed to meet the more stringent regulations expected to be in effect at the time the plant is placed in service. E. Environmental Effects Environmental effects of the proposed project for different categories are discussed in the following sections. WR 1. Water Supplies and Surface Water Quality P' The proposed project will have no significant adverse effects on water supplies. Of the current downstream water supplies, the Gulf-Goldston Sanitary District currently obtains about 135,000 gallons of water a day (0.21 cfs) from the Deep River at Gulf (Chatham County) and delivers it to a service population of 1,300. Operation of the Randleman WTP FM REPORTS M4-00MMDLEMA.RPT 25 HAZEN AND SAWYER Environmental Engineers & Scientists no would decrease the average flow in the Deep River at Gulf by about 60 cfs (5 perct However, the Randleman Lake project would increase low flows by about 12 cfs. Thus, proposed Randleman WTP would not significantly impact the Gulf-Goldston water supply, which is located approximately 70 miles downstream from the Randleman Lake dam site. Floyd Browne and Associates owns and operates a 1.5 mgd water treatment facility for Lee County near Cumnock, about 5 miles downstream from the Gulf-Goldston intake (75 miles below Randleman Lake). This system currently withdraws about 500,000 gallons of water per day (0.77 cfs), primarily to supply a poultry processing plant. As with the Gulf-Goldston plant, this facility would not be impacted by the Randleman WTP because normal flows would be reduced only slightly, and low flows would be increased by about 12 cfs. The proposed treatment facilities would make additional water supply from Randleman Lake available to meet the water demands of the PTRWA members. Watershed protection requirements under the N.C. Administrative Code (15A NCAC 2B.0248 through .0251), including riparian buffer and stormwater requirements, apply to all new development in the Randleman Lake watershed, including the proposed water treatment plant. A riparian buffer of 50 feet is required to be protected and maintained on all sides of FM surface waters, such as intermittent streams, perennial streams, lakes or ponds, as identified on 1:24,000 scale U.S.G.S. topographic maps, or Soil Survey maps developed by the USDA, Natural Resources Conservation Service. As shown on Figure 2, the buffer width for the proposed treatment facilities exceeds 50 feet, with only the solids lagoons being close to the required buffer width of 50 feet. The minimum buffer width for the rest of FA the proposed treatment facilities is approximately 200 feet, not including future treatment facilities. Aportion of the a a reserved for future facilities would be cleared and replanted r MR in grass cover, which would be kept mowed. This cleared area would be outside the 50- foot riparian buffer area. Cleared areas within the buffer around the lake not required for treatment plant operation or planned for future treatment facilities would be protected after construction and allowed to revegetate naturally with forest vegetation. two REPORTS M4-003\RMDLEMAR" 26 HAZEN AND SAWYER Environmental Engineers & Scientists MR The Randleman Lake watershed stormwater requirements include restrictions impervious surfaces. These include a six -percent built -upon area for nonresident., -r development in the critical area for the low -density option. The proposed water treatment plant is in the critical area, which extends for 1/2 mile around the proposed lake normal pool. An impervious surface restriction of 30-percent built -upon area applies for nonresidential development for the high -density option, with engineered stormwater controls used to Pq control runoff from the first inch of rainfall. Considering only the treatment plant site area of approximately 110 acres, the estimated amount of impervious surfaces for the initial treatment plant construction is approximately 4.6 percent. For the initial treatment plant construction plus projected future facilities, the amount of impervious surfaces is approximately 8.6 percent. The Randleman Lake watershed protection rules also allow cluster development on a project -by -project basis. This applies to conditions where the MR overall density of the project meets the associated density requirements, but the density in the area of concentrated development exceeds the density requirements. Other restrictions apply to cluster developments, as specified in the rules. It is believed that the proposed treatment facilities would meet the density requirements for the low -density option under the cluster development provision. This is based on the assumption that the ,MV additional buffer area of approximately 3,000 acres to be owned by the PTRWA around the lake is included in the total site area for the proposed treatment plant project. This buffer ,., area will remain in a vegetated or natural state and would provide additional water quality protection for the lake. A buffer width of 200 feet around the lake will be owned by the PTRWA, which exceeds the state requirement of 50 feet to be controlled around public drinking water supply reservoirs. Including the lake buffer area, the six -percent limit on impervious surfaces for the low -density option would be met for the proposed initial and future treatment facilities. M" In order to provide further protection of the water supply from the lake, any hazardous materials at the proposed treatment facilities would be properly stored, including spill prevention/containment measures to ensure that no hazardous materials are released into the lake. Chemical feed systems would meet all requirements of the N.C. Division of Water Quality and N.C. Division of Environmental Health for public water supplies, and REPORTW904-OOMANDLEMA RPT 27 HAZEN AND SAWYER Environmental Engineers & Scientists would also meet the requirements of the N.C. Building Code. Chemical -handling areas would have automatic sprinklers for fire suppression. The proposed project will have no significant effects on surface water quality. Access roads to the plant site and from the main plant site to the raw water intake and pumping station would cross two perennial streams and one intermittent stream. These roads would be brid ed over the streams to minimize impacts on surface water quality. The proposed treatment plant is expected to have an NPDES permit for discharge of effluent water from treatment facilities for settled solids and filter backwash water. The treated water (supernatant) would be discharged to Randleman Lake and would be expected to have effluent limits for total suspended solids and settleable solids of 30 mg/L and 0.1 mL/L, respectively. Based on experience with other water treatment facilities, no adverse impacts ,,,. on water quality are anticipated for this discharge (See Sections E.10, Environmental Effects, Introduction of Toxic Substances, and E.11, Environmental Effects, Eutrophication of Receiving Waters below). Some short-term impacts on surface waters will occur due to construction activities. These impacts will be minimized by maintenance of effective erosion and sediment control measures in accordance with the requirements of the North Carolina Sedimentation Pollution Control Act. Specific elements of the erosion control measures for construction of the proposed treatment facilities conform to, or are similar to, the more stringent requirements for sensitive watersheds (15A NCAC 46.0024). These include side slopes for grass -lined ditches no steeper than three horizontal to one vertical and side slopes for temporary swales no steeper than two horizontal to one vertical. Geotextile lining and/or riprap would be used where necessary for velocity protection. In addition, a ground cover sufficient to restrain erosion would be required to be planted or otherwise provided within 15 working days or 90 calendar days following completion of construction or development, whichever period is shorter, on that portion of the tract (disturbed area) upon which further active construction is not being undertaken. This would apply to those areas reserved for future plant expansions. An erosion and sedimentation control plan will be submitted to the N.C. Department of Environment and Natural Resources, Division of Land Resources for approval prior to construction. n.� REPORTW904.003\RPNOLEMARPT 28 HAZEN AND SAWYER Emirs .tal Engineers 8 Scie OSM a" Om am oft The proposed project would also result in the diversion of water from the Cape Fear River Basin to other river basins. The impacts of this diversion are addressed in the Randleman Lake EIS (USACE, 2000). The PTRWA has already obtained a permit from the N.C. Environmental Mana ent Commission authorizing this interbasin transfer. It is possible that interbasin transfers to the Haw River from the proposed Randleman WTP could affect the water supplies from Jordan Lake, which is located on the Haw River approximately 4.2 miles upstream of its confluence with the Deep River. These transfers, which would occur in the form of treated wastewater, could affect the dependability of the water quality and water supply storage of Jordan Lake through adverse impacts on nutrient and dissolved oxygen levels in the lake. Such effects, if they occur, may not be apparent for years or decades depending upon the rate of increase in interbasin transfer. In addition, such FM effects could be influenced by a number of factors, such as advances in water and wastewater treatment technology, the destinations of water allocations from Randleman M, Lake and Jordan Lake, and hydrologic changes due to alteration of land uses in the MM drainage basins of the two reservoirs. Water quality problems in Jordan Lake are discussed in the NCDWQ Cape Fear River P" Basinwide Management Plan (NCDEHNR, 1996). Issues raised in the plan include excessive loadings of oxygen -demanding materials and nutrients from both point and O, nonpoint source discharges. It is expected that water quality problems in Jordan Lake will be addressed by additional controls applied to point and nonpoint source discharges under Ow the basinwide management planning process to reduce excess pollutant loadings to the am Jordan Lake watershed. Indirect and cumulative effects of the proposed project will result from increased urban development in the service areas of the PTRWA members and increased wastewater flows from their respective wastewater treatment plants. Increased urban development will result "m in increased nonpoint source discharges to surface waters. Nonpoint source controls, in accordance with requirements of the North Carolina Nonpoint Source Pollution Ow Management Program, will help to minimize impacts of nonpoint source discharges. Control of nutrients from nonpoint source discharges will be by the riparian buffer and sm REPORTS\2904-00"ANDLEMARPT 29 HAZEN AND SAWYER Environmental Engineers & Scientists ., stormwater requirements of the Nutrient Management Stategy rules referenced above. These watershed protection measures are more stringent than those applied in any other WS-IV classified water body in the state. The NCDWQ is also requiring that the PTRWA member governments conduct post -impoundment water quality monitoring studies to evaluate actual lake water quality. Should post -impoundment water quality conditions require reduction of nutrient flows into the system, additional restrictions or alternative strategies would be adopted as required. Any plans for future wastewater treatment plant expansions will be subject to the requirements of North Carolina regulations under the National Pollutant Discharge Elimination System (NPDES) program, the North Carolina Environmental Policy Act, and the Nutrient Management Strategy rules for the Randleman Lake watershed. These rules (15A NCAC 2B.0249) stipulate that there shall be no new or _ expanding permitted wastewater discharges in the watershed, with the exception that the High Point Eastside WWTP may be allowed to expand provided that any new permit contains concentration and mass limits predicted to provide a level of water quality in Randleman Lake which meets all designated uses of those waters. For the purposes of the rule, permitted wastewater discharges means those facilities permitted to discharge domestic wastewater or wastewaters containing phosphorus. Domestic wastewater from the proposed Randleman WTP would be treated in on -site treatment facilities, with no discharge to Randleman Lake. 2. Groundwater Quality The proposed project will have no significant direct or indirect and cumulative effects on .. groundwater quality. Groundwater monitoring wells, if required for proposed solids handling facilities at the treatment plant, will be monitored to ensure that no adverse impacts to groundwater occur from treatment plant operation. Most current users of water from the water distribution systems of the PTRWA members are served by central wastewater facilities. New housing areas are generally connected to central water and wastewater service at the same time. Therefore, the proposed project would not be Asks expected to have a significant adverse effect on groundwater through increased wastewater disposal through individual septic systems. r REPORTW904-00MRMDLEM APT 30 HAZEN AND SAWYER Ewwrnental Engimmns 8 Scientists As referenced above, existing groundwater contamination at the Seaboard Chemical Corporation and High Point Landfill site has raised concerns about water quality in Randleman Lake. Remedial investigation studies on this site have been completed and FMR are currently under review by the NCDWM. Pending the final approval of these remedial investigation studies, the NCDWM has indicated that it is confident that it is technically feasible and economically viable to achieve a drastic reduction in any pollutants leaving the site and accordingly minimize the potential of any pollutants from this site causing any violations of water quality in the lake. The appropriate remedial measures for the site to protect groundwater quality and surface water quality in Randleman Lake will be determined upon completion of NCDWM review of the remedial investigation studies. FM 3. Changes in Land Use The land use of the proposed treatment plant site would be changed as a result of the proposed construction. The water treatment plant site would be changed from partially undeveloped, wooded land and partially cultivated land to land developed for municipal FM water treatment plant uses. Some areas of the site would remain undeveloped and would provide buffer for water quality protection for Randleman Lake. a, Indirect and cumulative impacts will consist of the change in land use for presently undeveloped or agricultural land to residential, commercial and industrial land uses. The increased water treatment capacity will allow future extensions of the water distribution systems of the PTRWA members to serve newly developed areas. Future development will be in accordance with land use plans of the PTRWA members. 4. Wetlands fan No wetlands will be directly affected by the proposed project. The soils on the proposed mom treatment plant site are upland soils and, based on Randolph County soils maps, are neither hydric soils nor soils with hydric inclusions as classified by the U.S. Department of am ram+ REPORTS\2904-OOMMDLEMARPT 31 HAZEN AND SAWYER Environmental Engineers & Scientists FOR MM Agriculture, Natural Resources Conservation Service (formerly Soil Conservation Service). Therefore, the lands on the project site are not expected to be classified as wetlands. Indirect and cumulative effects on wetlands will be limited because new development will tend to take place on nonwetland sites. Wetland areas are generally avoided for residential and industrial development when suitable upland sites exist. This is due to the aM presence of high groundwater levels and the fact that hydric soils may also have high shrink -swell potential. Such conditions lead to soil movement, which is detrimental to building foundations. Use of wetlands also would require a permit from the U.S. Army Corps of Engineers. ,M 5. Prime or Unique Agricultural Lands The proposed project will have a minor effect on agricultural lands due to the elimination of approximately 15 acres of agricultural land on the treatment plant site. The loss of agricultural land is not significant in terms of the total agricultural land in Randolph County. M9 Indirect effects on prime agricultural lands will occur from future development for new residential, commercial and industrial development as a result of the increased water rM treatment capacity. Ow 6. Public Lands, Scenic and Recreational Areas MM No public lands, scenic or recreational areas will be affected by the proposed project. Randleman Lake will offer the opportunity for recreational use, including nature study and bird watching in the buffer area, and possibly fishing or boating. The proposed treatment plant would not affect such recreational uses. Indirect and cumulative effects on public lands, scenic and recreational areas are not expected to be significant. e REPORTS M4.00MANDLEMXRPT 32 HAZEN AND SAWYER Environn-entW Engineers & Scientists 7. Areas of Archaeological or Historic Value Oft An archaeological survey has been conducted for Randleman Lake to record archaeological resources on the project site and, where possible, to determine if these IM resources are potentially eligible for listing on the National Register of Historic Places (Coastal Carolina Research,1997). Surveys were also conducted on a small area of about 0114 50 acres in the vicinity of the proposed treatment plant site. No sites that appear to be eligible for inclusion in the National Register of Historic Places were found on this site. Therefore, the proposed project is not expected to directly impact archaeological or historic resources. Indirect and cumulative effects on historical and archaeological resources include potential adverse impacts of development projects that may be facilitated by the proposed project. If such projects occur, they would be subject to state and local review and permit programs. Development may also result in the discovery of additional archaeological resources, which may provide information on the area's prehistory. Some historic sites may be preserved or protected through renovation for other uses. 8. Air Quality and Noise Levels Construction of the proposed project would result in a short-term increase in airborne dust, construction equipment exhaust emissions, smoke from burning of cleared vegetation and noise in the immediate project area. These impacts can be minimized by limiting construction to normal daytime working hours and by minimizing burning of vegetation - through the use of timber harvesting and chipping of brush and tree branches. Indirect and cumulative effects on air quality and noise levels will result from residential, commercial and industrial development which occurs as a result of the increased water treatment capacity. a" foal REPORTM904-OOMANDLEMA.RPT 33 HAZEN AND SAWYER Environmental Engineers & Scientists 9. Shellfish, Fish and Wildlife and their Habitats Habitat for wildlife will be altered by construction of the proposed water treatment plant. Land cover at the treatment plant site is currently partly undeveloped, wooded land and partly cultivated fields. Approximately 35 acres would be affected by the proposed construction, including approximately 20 acres which are wooded, and approximately am fm 15 acres which are farmland. Wildlife inhabiting the wooded areas will probably be lost, although some may be accommodated on adjacent similar habitat. No wetlands habitat would be affected by the proposed treatment plant construction. Based on information from the N.C. Natural Heritage Program and information presented in tAMMI he Randleman Lake EIS, no species listed as endangered or threatened, or proposed for such listing by the State of North Carolina or the U.S. Fish and Wildlife Service, are MIA expected to be impacted by the proposed project. The Federally endangered Cape Fear shiner (Notropis mekistocholas) is located in Randolph County, but its closest known M" location is approximately 22 miles below the Randleman Dam site. The Biltmore carrion - flower (Smilax biitmoreana), a State Candidate species, occurs about 1 mile downstream of the project area on the west bank of the Deep River. The Biltmore carrion -flower occurs in dry to mesic forests, over felsic or mafic rocks. Neither of these species would be r'" significantly affected by the proposed project. The State and Federally endangered Schweinitz's sunflower (Nelianthus schweinitzii) also occurs in Randolph County but is not Onk known to occur within a 1-mile radius of the proposed project. The proposed project would have no significant effect on fishery resources. Roads will be bridged over existing streams fm on the plant site to minimize impacts to aquatic species. Fan Indirect and cumulative impacts of the proposed project will consist of a reduction in wildlife habitat from urbanization and extensions to the service areas of PTRWA members. '= Fragmentation of existing wildlife habitats will increase. Native vegetation will be replaced with urban species, and wildlife will withdraw from the expanding service area due to rM increased human disturbances and loss of suitable habitat. Increases in urban runoff will cause some adverse impacts on aquatic wildlife habitat, especially during seasonal low am MMI REPORTS12904-00"ANDLEMARPT 34 HAZEN AND SAWYER Environmental Engineers & Scientists - r — flow periods because of the low dilution capacity of the receiving streams. Control measures adopted in accordance with the Nutrient Management Strategy rules for the Randleman Lake watershed will reduce the impacts of the increased urbanization. 10. Introduction of Toxic Substances No toxic substances are expected to be introduced into the environment as a direct result of the proposed project. The proposed water treatment facilities would include residuals lagoons for settling and storage of coagulation solids and clarification of filter backwash water. The lagoon supernatant would be discharged to the lake at a point downstream of the raw water intake. An NPDES permit would be obtained for this discharge. Residual solids in the lagoons would consist of the suspended material in the raw water that is removed in the sedimentation and filtration processes, and the coagulant, polymer, and _ powdered activated carbon (PAC) that are added in the rapid mix process and removed along with the suspended matter. Concerns have been raised regarding the effect of toxic substances from the Seaboard Chemical Corporation and High Point Landfill site in the upper part of the lake on the water quality in the lake. Prior to completion of remedial investigation studies on these sites, a .. screening approach was taken to assess whether the maximum reasonable loading rate from these sites would potentially result in violations of water quality standards in the lake r (Hazen and Sawyer, 1998). This approach was applied to the ten organic solvent priority pollutants which have been detected in groundwater at the site, and is expected to overestimate the likely concentrations which will occur in the lake. However, if these very conservative screening estimates can be shown to still be below relevant water quality standards, it can be concluded that contaminated groundwater from the site will not result in exceedances of water quality standards in the lake. The analysis was based on a �- groundwater flow rate of 50,000 gallons per day (gpd) and the maximum contaminant concentrations detected in the groundwater monitoring conducted by NCDWQ. The results of this analysis are summarized in Table 7. REP0RTS2904-000WANOLEb RP 35 HAZEN AND SAWYER EmimnmenW Engineers 8 Stle SM Table 7 Screening of Toxicants from the Seaboard Chemical Corporation and High Point Landfill Compound Maximum Screening Concentration (ng/L) at Deep River 3B Water Intake Standard or Criterion n /L Chlorobenzene 7.0 488,000 1,2-Dichlorethane 0.13 380 1,1-Dichloroethylene 0.52 57 Vinyl Chloride 0.84 2,000 Benzene 0.002 1,190 2-Chlorophenol 0.36 120,000 Methylene Chloride 1.3 4,700 1,1,2,2- Tetrachloroethane 1.3 172 1,1,2-Trichlorethane 0.54 600 Toluene 2.9 11,000 Based on the screening of toxic chemicals from the Seaboard Chemical Corporation and High Point Landfill site conducted by Tetra Tech, Inc., the reduction in maximum screening concentrations from the source to the proposed water intake ranged from 98 to 99 percent (Hazen and Sawyer, 1998). For this location, the maximum screening concentration was well below the applicable standard or criterion for each pollutant. Based on the screening analysis, no exceedances of water quality standards associated F with groundwater loading from the Seaboard Chemical Corporation and High Point Landfill site are expected. Therefore, significant amounts of toxic substances from this site are not expected in the raw water or in the supernatant discharge from the treatment plant residuals lagoons. ^ REPORTS\2904-003\RANDLEMA.RPT 36 HAZEN AND SAWYER Envimnmanlal Engineers & Scientists a rVM am Pon am ON Consultants for Seaboard Group II and the City of High Point have recently prepared reports on additional studies conducted on the Seaboard Chemical Corporation and High Point Landfill site. One of these reports presented the results of a study which examined the impacts of the site on human health and site ecology (Environmental Resources Management, 1999a). Findings and conclusions of this study relating to surface water quality are summarized as follows: • Four constituents of potential concern (COPCs) and nine COPCs were identified in the northern and southern intermittent streams, respectively. Only two COPCs, barium and iron, were identified in the Deep River. It was noted that the northern and southern intermittent streams are piped where they intersect landfill material. In addition, the presence of the organic COPCs in surface water at concentrations of potential concern is very localized, and several organic COPCs are volatile constituents which may volatilize once entering a surface water system. • The inorganic COPCs found in the surface water are not considered to be site -related. Their presence is believed to be associated with naturally -occurring levels of inorganics in surface water. This was confirmed by an evaluation of background inorganic constituents in the Deep River. Therefore, no further evaluation of ecological risks with respect to surface water is warranted. A second report presented the results of a Feasibility Study (FS) conducted for the site (Environmental Resources Management, 1999b). The purpose of the FS was to identify and evaluate remedial alternatives for addressing potentially unacceptable risks to human health and the environment identified from the remedial investigation and risk assessment studies completed for the site. The ultimate goal of the FS was to determine the most appropriate remedial approach for the impacted media at the site that is consistent with current and future uses of the site and the requirements of the Administrative Order by Consent (AOC) entered into by the NCDENR and Seaboard Group II and the City of High Point. A summary of critical issues from the FS is presented as follows: • Past activities at the Former Seaboard Chemical facility and the Riverdale Drive [High Point] Landfill have resulted in volatile organic compound (VOC) contamination of soils and ground water at the Site. Contaminant levels in ground water exceed the North Carolina G-1 ground water quality standards. REP0RTS%2904.003► MDLEAkRPT 37 HAZEN AND SAWYER Environmental Engineers & Scientists PAM • Ground water flow at the Site is heavily controlled by structural geologic features, with discharge to the adjacent Deep River and on -site intermittent streams. Contamination �► was generally not detected in surface water from the Deep River, although contamination was detected in the southern intermittent stream. go FM • Conservative surface water modeling efforts completed to date indicate that anticipated worst -case ground water contaminant loading from the Site to the Deep River (or Randleman Lake) will not present unacceptable risks to users of drinking water that is withdrawn from the water supply intake at the downstream Randleman Lake (Tetra Tech, 1998). The ground water modeling simulations indicate that under certain conditions, ground water discharge and contaminant loading to the Deep River/Randleman Lake may increase following filling of the reservoir (SEI, 1999). Implementation of a periodic ground water and surface water monitoring program will provide an early warning system against potentially increased risks, and will serve as a trigger for the implementation of the supplemental remedial measures (pump -and -treat systems), if needed. A surface water monitoring program will be implemented by the PTRWA after the filling of Randleman lake. Based on the above reports, plus the planned water quality monitoring program, there are not expected to be significant amounts of toxic substances in the raw water or in the supernatant from the residuals lagoons as a result of the existing ground water contamination at the Seaboard Chemical Corporation and High Point Landfill site. Mh Other potential sources of toxic substances to Randleman Lake were evaluated in Appendix F of the Randleman Lake EIS, and included the High Point Eastside WWTP; the rpm closed Jackson Lake Road Landfill; potential spills of hazardous waste from 1-85 and other highways that cross the reservoir; other open and closed landfills; Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (Superfund) sites; Toxics Release Inventory (TRI) sites; and Resource Conservation and Recovery Act ,", (RCRA) sites (USACE, 2000). Other parameters of concern found in the Deep River or its tributaries, including lindane, phenols, and unidentified organic chemicals, were also IM evaluated in the Randleman Lake EIS. Based on the evaluations in the EIS, there are no toxic substances present at levels that would adversely affect the quality of the Randleman 4M Lake water in terms of its use as a water supply. Therefore, the proposed discharge from ern REPORTS2904-00M MIDLEMARPT 38 HAZEN AND SAWYER Environmental Engineers & Scientists the residuals lagoons is not expected to result in a significant discharge of toxic substances to the lake. Some toxic substances will be introduced as a result of increased discharges from the wastewater treatment plants of PTRWA members. The discharge of toxic substances from these wastewater treatment plants will be minimized by monitoring and control measures provided under existing industrial pretreatment programs, and by compliance with NPDES permit requirements for effluent toxicity and toxic substances. In some cases, wastewater discharges will be required to meet more stringent treatment requirements because of the use of downstream waters for water supply purposes. 11. Eutrophication of Receiving Waters _ The proposed project will not involve a significant discharge of nutrients and would not have a significant impact on eutrophication of receiving waters. In accordance with the r Nutrient Management Stategy rules for the Randleman Lake watershed (15A NCAC 2B.0249), the proposed discharge of supernatant from the residuals lagoons will not result in a discharge of phosphorus in excess of the amount removed in the raw water. The proposed water treatment plant would use a phosphate compound (zinc orthophosphate) to inhibit corrosion in the finished water distribution system. However, this phosphate would be added downstream of the point at which filtered water would be removed for filter p backwashing. Therefore, none of the added phosphate would be discharged to the residuals lagoons or to Randleman Lake. In addition, most of the phosphorus present in — the raw water would be removed as a precipitate with the coagulation solids (using alum or ferric chloride). The amount of alum to be added would range from 30 to 50 mg/L as alum. This amount of alum is sufficient to precipitate 2.8 to 4.7 mg/L of phosphorus. In comparison, the predicted total phosphorus concentration in the lake is estimated at approximately 0.06 mg/L. Therefore, the amount of alum added is well in excess of the amount required to precipitate the phosphorus in the raw water. Similar results would apply if ferric chloride is used as the coagulant. The precipitated phosphorus would remain with the stored solids in the residuals lagoons and would not result in a significant ^^ REPORTS2W4-00"MDLEMARPT 39 HAZEN AND SAWYER Environmental Engineers & Scientists rm discharge of phosphorus in the lagoon supernatant. This conclusion cannot be supported FM with information from other water treatment plants because nutrients are typically not required to be monitored for water treatment plant residuals treatment system discharges. Indirectly, the proposed project will result in increased wastewater discharges from the wastewater treatment plants of PTRWA members. Nutrient discharges from these treatment plants will be controlled under the provisions of the NPDES permits for these discharges and the Nutrient Management Strategy rules for NPDES discharges for the Randleman Lake watershed (15A NCAC 213.0249) (see Section E.3, Environmental Effects, Surface Waters above) . Impacts of increased discharge of nutrients from urban runoff associated with increased development will be minimized by enforcement of watershed protection and erosion and sediment control measures of the PTRWA member governments, developed in accordance with the Nutrient Management Strategy rules (15A NCAC 26.0248 through tam .0251). Drainage and stormwater management requirements for development projects will also minimize adverse effects from new development. PAN Mn rAP F. Unavoidable Adverse Impacts and Mitigation Measures Construction of the proposed water treatment plant will result in some adverse environmental impacts that cannot be avoided. However, use of appropriate control measures, careful design, and good construction practices will minimize adverse effects. Unavoidable adverse effects include: (1) During Construction Activity • Air pollution occurs form windblown dust, engine exhaust and burning of cleared vegetation. REPORTSV904-00MRANEDLEMARPT 40 HAZEN AND SAWYER Environmental Engineers & Scientists Some soil erosion occurs. (2) Long -Term Effects • Long-term effects will consist of the change in land use and loss of wildlife habitat associated with the conversion of presently undeveloped and agricultural lands to a water treatment plant site. Reduction of adverse impacts will be achieved by ensuring that sound construction practices are required by the contract specifications for the project. All local, State and Federal regulations designed for environmental protection would be followed. Measures to mitigate indirect and cumulative impacts associated with urban development include watershed protection measures, stormwater management controls, zoning controls, and erosion and sediment control ordinances of the PTRWA members. Both Randolph County and Guilford County have taken measures to protect the water quality of the proposed Randleman Lake by establishing watershed protection ordinances that establish water critical areas. The ordinances were adopted by the two counties in 1987 and 1988 on the recommendation of the PTRWA. Watershed protection measures of the respective County ordinances are discussed in the Draft Randleman Lake EIS (USACE, 1997). These ordinances were adopted to protect the watersheds of proposed, as well as existing, water supplies. Mitigative measures for urban development in the Greensboro and High Point service areas are further addressed in the environmental assessments for the expansion of the Greensboro T.Z. Osborne WWTP (Hazen and Sawyer, 1991 and 1995) and the High Point Eastside WWTP (Hazen and Sawyer and Davis -Martin -Powell, 1997). Watershed protection ordinances were adopted and stormwater management plans were developed by all the PTRWA member governments in accordance with the Nutrient Management Strategy rules for the Randleman Lake watershed (15A NCAC 2B.0248 through .0251). REPORTS12904-003�RANDLEMARPT 41 HAZEN AND SAWYER EnvImnmental Engineers & Scientists oft Additional mitigation measures to be provided by the City of Greensboro to minimize secondary impacts on wildlife and fisheries habitat associated with urban development are addressed in the environmental assessment for the Randleman Water Transmission Main for the City of Greensboro (Hazen and Sawyer, 2000). These measures address the provision of forested buffers, restoration of degraded riparian areas, prohibiting fill and development in the 100-year flood plain, and development and maintenance of stormwater control structures to reduce urban runoff. A detailed discussion of the City's current and proposed mitigation measures to minimize secondary impacts associated with urban development in the Greensboro service area is included in Appendix B. PQ R" MCI a" P" PIq f, "m REPORTS12904-00"AHDLEMXRPT 42 HAZEN AND SAWYER Environmental Engineers & Scientists REFERENCES 1. Blasland, Bouck & Lee, Inc., "Former Seaboard Chemical Corporation and Riverdale Drive Landfill, Remedial Investigation Report, Jamestown, North Carolina, Volumes 1,2 and 3," March 17, 1999. oft 2. Coastal Carolina Research, Inc., "Archaeological Survey, Proposed Randleman � Reservoir, Randolph and Guilford Counties, North Carolina," prepared for the Piedmont Triad Regional Water Authority, April 1997. 3. Davis -Martin -Powell & Associates, Inc. and Hazen and Sawyer, "Environmental Assessment for the Eastside Wastewater Treatment Plant Expansion and Upgrade," prepared for the City of High Point, January 1997. 4. Environmental Resources Management, "Seaboard Chemical Company and City of FM High Point Riverdale Drive Landfill, Jamestown, North Carolina, Human Health and Ecological Risk Assessment," March 1999 (1999a). 5. Environmental Resources Management, "Draft Seaboard Group II and the City of �+ High Point, Feasibility Study for the Former Seaboard Chemical Corporation Facility and the City of High Point Riverdale Drive Landfill, Jamestown, North Carolina," April 30, 1999 (1999b). 6. Hazen and Sawyer, "T.Z. Osborne Wastewater Treatment Plant Expansion, Environmental Assessment," prepared for the City of Greensboro, August 1991. 7. Hazen and Sawyer, "T.Z. Osborne Wastewater Treatment Plant 40 mgd Expansion, Environmental Assessment," prepared for the City of Greensboro, March 1995. a" fait REPORTS12904.0MRIWDLEMkRPT 43 HAZEN AND SAWYER Environmental Engineers & Scientists +s Owl 8. Hazen and Sawyer, P.C., "Draft Nutrient Reduction Strategy and Implementation Plan, Randleman Lake," prepared for the Piedmont Triad Regional Water Authority, March 1998. 9. Hazen and Sawyer, P.C., "Randleman Water Transmission Main, Environmental Assessment," prepared for the City of Greensboro, Revised August 2000. ohm 10. North Carolina Department of Environment, Health and Natural Resources, Division of Environmental Management, Water Quality Section, "Review of Deep River/Carbonton Water Quality Investigations, 1992/1993," 1994. 11. North Carolina Department of Environment, Health and Natural Resources, Division of Water Quality, Water Quality Section, "Cape Fear River Basinwide Water Quality Management Plan," October 1996. 12. North Carolina Department of Environment, Health and Natural Resources, Division of Water Quality, Water Quality Section, Environmental Sciences Branch, "Water Quality Monitoring Data for Waters in the Upper Deep River Area, May 5, 1997- September 3, 1997," March 1998. 13. North Carolina Department of Environment and Natural Resources, "Report of Proceedings, Proposed Reclassification of Segments of the Deep River (Proposed Randleman Reservoir)," Environmental Management Commission Meeting, November 12, 1998. 14. North Carolina Department of Environment and Natural Resources, Letter to John Kime, PTRWA, from A. Preston Howard, Jr., Director, NCDWQ, Transmitting the 401 Water Quality Certification, March 11, 1999 (1999a). M f" REPORTS12904-OOMANDLEMARPT 44 HAZEN AND SAWYER Envimm mW Engineers & Scie"sm 4M "' 15. North Carolina Department of Environment and Natural Resources, Letter to Robert F. McGhee, USEPA, from William L. Meyer, Director, Division of Waste Management, Summarizing Updated Information on the Remedial Investigation of the Seaboard Chemical Corporation and High Point Landfill Site, September 3, 1999 (1999b). OM 16. North Carolina Department of Environment and Natural Resources, Division of Water Quality, Water Quality Section, "Cape Fear River Basinwide Water Quality Im Plan," July 2000. 17. Research Triangle Institute, "Eutrophication Modeling for the Randleman Lake Project, Final Report," submitted to the North Carolina Department of Environment and Natural Resources, Division of Water Quality, September 30, 1998. AM 18. Synesis Environmental, Inc. (SEI), "Seaboard Chemical Corporation Facility and City of High Point Former Riverdale Drive Landfill, Groundwater Flow and Transport Model Report," April 30, 1999. ,m 19. U.S. Army Corps of Engineers, Wilmington District, "Draft Environmental Impact ,N, Statement, Randleman Lake, Guilford and Randolph Counties, North Carolina," June 1997. 20. U.S. Army Corps of Engineers, "Final Environmental Impact Statement, Randleman M1 Lake, Guilford and Randolph Counties, North Carolina," prepared for the Piedmont Triad Regional Water Authority, Hazen and Sawyer, P.C., December 2000. 21. U.S. Department of Agriculture, Soil Conservation Service, "Hydric Soils List" for Randolph County. REPORTSMU-00MMIDLEMARPT 45 HAZEN AND SAWYER Environmental Engineers & Scientists AM e� 22. U.S. Environmental Protection Agency, Letter to Dr. G. Wayne Wright, USACE, from Robert F. McGhee, Director, Water Management Division, Summarizing the EPA's Conclusion on Water Quality Issues for the Proposed Randleman Lake, October 19, 1999. an REPORTS12904-00MM MEMARPT 46 HAZEN AND SAWYER ErMmnff*MW Engineers & Scientists Appendix A Comments from N.C. Department of Environment and Natural Resources Review Agencies MM PIEDMONT TRIAD REGIONAL WATER AUTHORITY RANDLEMAN WATER TREATMENT PLANT ENVIRONMENTAL ASSESSMENT The following responses address comments received from review agencies on the July 1997 Environmental Assessment. Responses to Comments of Lee G. Spencer, Regional Engineer, Public Water Supply Section, Winston-Salem Regional Office in a Memorandum dated August 20, 1997. The environmental assessment (EA) has been updated to include additional water quality information prepared for the Final EIS for Randleman Lake, and to reflect the fact that Randleman Lake has been approved is currently under construction. The EA now references the reclassification of the Randleman Lake watershed as WS-IV, Critical Water Supply Watershed; the Nutrient Management Strategy rules that have been adopted for the Randleman Lake watershed (15A NCAC 213.0248 through .0251); the watershed protection ordinances adopted by all of the jurisdictions in the Randleman Lake watershed; and the stormwater management plans which have been submitted by all the local governments and approved by the NCEMC. Pq Responses to Comments of A. Preston Howard, Jr., Director, Division of Water Quality in a Memorandum dated December 19, 1997. so See responses to comments of Lee Spencer. Responses to Comments of Steve Zoufaly, Division of Water Quality in a Memorandum mot dated September 12, 1997. See responses to comments of Lee Spencer. In addition, compliance with the water supply watershed development requirements and consideration of constructing the proposed facility using more protective development procedures than the state's minimum criteria is addressed in Section E.1, Environmental Effects, Water Supplies ,AR and Surface Water Quality. 0" Randleman WTP EA responses to state comments Page 1 MAY 14 099 03:4epM MAY 13 199 01:05" EHM-PUBLIC AFFAIRS t. . -% •` R I�el JAMes e. Huwrlf. � �irON�+OR MEMORANDUM( P .1 /e NORTH CAROLINA DEPARTMENT OF F_NVIRONMENY AND NATURAL RESOURCES ww�e 1•tcoawr°+' sccwerAft► TO: Faith Abbott P� FROM. Melba McCrea. RE: #8 74 Piedmont Triad Regional Water Authority, Randleman Water Treatment Plant SA. Randolph County DATE: January 16,1999 The Department of Environment and Natural Resources has completed its review of fine proposed project. +Che attached comments identify . :. information that our review agencies would Iike for the applicant to consider and address if this project is to proceed. Generally speaking, this project cannot function Without the approval of the Randleman Reservoir. In our Randleman Reservoir DEIS project comments dated October 2, 19,97. major emphasis was placed on the future water quality of the reservoir. Our agencies also identified a number of other deficiencies with the DETS and asked that the Corps of Engineers not approve the project until additional efforts could be made in resolving agency concerns. Since this project and the Randleman water mains proposal seem to center around the Randleman Reservoir proposal being approved, the department believes that its too premature to specifically respond to this proposal Therefore., it is recommended that the Piedmont Triad Authority not move forward too quickly in developing further environmental documentation without final approval of the Randleman Reservoir project. Final concurrence with this project would not be warranted until our Concerns were satisfaaorily addros* and appropriate conditions were implemented in the proposed Randleman Reservoir project. Again, our primary interest at tliis time is to continue to communicate and work r.o. liax 276fs7, IOwl.i14►� Nc �7c+ +•7Gtt7 + 5t 2 NOaTM 3wt_IyOURY STN6E•� gA�.ElGM NC Z7b04 Prtoty� 9t s-73'-�188� t=AX 8t Q•71$•8000 WWw•E14Nd•STATE.NC.USM14Nf / Am eQVAL OPPORTUNITY r ^F1F9 tK^'r8VG AaTepM CWPLAW441 •WOK. MCC-4t-re t0% P40ST-C*F42 +ML11 "P>RR MAY tz4 '��J e�3 i PM EHNR- PUBLIC AFFAIRS �: 8 cioseiy with the Corps of Engineers and the Piedmont Triad Regional A- 'Water Authority staff so issues can be resolved in an efficient manner. Thank you for the opportunity to respond. Attachments "M Aw am am .. 000 t.= ..••..•.• t*M Y �14 • y9�9 UV W i m EHNR- PUBLIC AFFAIRS PP:8 we Im State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Wayne McDevitt, Secretary A. Preston Howard, Jr., P.E., Director December 19, 1997 MF,MnRANDIIM TO: Melba McGee 1 FROM: A. 'Preston Howard, Jr., P.E. RE: Comments on DENR# 874; DWQ#I l 763 Piedmont Triad Regional Waver Authority (PTRWA) Randleman Water Trmavnent Plant EA Randolph County The proposed project consists of an Environmental Assessment (EA) on a proposed Water Treatment Plant and intake to be fixated at the future Randleman Lake water supply resatvoir in Randolph County. The; project will email construction and operation of a 12 million gallon per day (MGD) water trt;aunent plant to supply treated water to several local governments in the Triad area, including Randolph County and the municipalities of Greensboro, High Point, Jamestown, Archdale and Randleman. Thesc local governments comprise the Piedmont Triad Regional Water Authority (MWA), which is the "applicant" for the project. Eventual expansion of the WTP to 24 MGD is predicted to be needed w meet the projected SO -year demand in the project service area, however, that withdrawal is _ not considered part of the current F.A. •�► The Division has reviewcd th;: EA on :he project and has the following comments. I . The Division is very concerned about the; future water quality in the proposed Randleman Reservoir, especially incrcasrs in nutrients from point and non -point `f sources as a result of the urbanization to be served by this proposed water treatment plant (sec: attached comments). Them is a sarong likelihood that a biological response to eutrophication in the future reservoir will result in high Chlorophyll a concentradon:,;, requiring a highor degree of treatment. The proposed Tmatment Plant could be dramatically affected by the final design of the reservoir, the Final EIS for the Randleman Reservoir, the Nutrient Reduction Strategy and Watershed Management Plan (currently under development by PTRWA as a condition of it's 401 Certification for the reservoir), and the not-yet- complemd water quality testing of the propo.wA irnpounded waters. 2. On page 5 under the heading of "Groundwater''. the EA implies that then: will be no significant adverse impacts frotn the contaminated groundwatef at the Seaboard Chemical/ High Point landfill sites. As discussed in DWQ's comments on the DEIS for the reservoir, DWQ will not be able to verify this suitement until the 19998 �+ P.O. Box 29535, Raleigh, North Carolina 27626-OS35 Telephone 919-733-5083 FAX 919-715-5637 An Equal Opportunity Affirmative Action Employer s6% Tecycledt iwo post-consumef paper am • MAY 14 '99 of : T9PM THNk' PUBLIC AFF-AIRS P. 4/8 DEHM #974 Randleman WTP DWQ Comments page 2 a' Remedial Investigation report on the sites is complete. Indications are that Contaminants may be at greater levels than previously reported. F, In addition. DWQ has records that show several abandoned gold mines and at least one abandoned gold processing site (McCullers Mill) are in the Randleman Lake watershed. McCullers Mill is whccc mercury was dumped into the Copper Branch of the Dccp River after it was used to process the gold ore. Mercury is of concern "" due: to potential food chain bioaccumulation. This issue was not adequately discussed in the Water Treatment Plant EA or the Randleman Lake EIS. Water Quality studies of the Deep River conducted by DWQ from July 1992 to October / 1993 also found phenol values above laboratory detection levels at all Sampling stations in the Upper Deep River study ama. Pesticides were also found along with violations or water quality standards for Lindane and Dieldrin. The Division therefore requests that an updated analysis 1 modeling of the predicted metal and toxicant lev is in0__�ace w ern an t results provided inr TreatmentPlant EA. Elevate concentrations of lead, mercury, nickel, lindane, dieldrin, as well as possible other unknown contaminants may be of concern in the msorvoir and should be adequately assessed in the EA. The EA. should provide discussion of the steps that will be taken to mitigate these concerns and protect the future water supply from the sources of these toxic chemicals. 3. In combination with the issues discussed in item 2 above and the Division's experience with other eutrophic water supplies. DWQ is concerned about the ability of the future Randleman water to be adequately treated for public consum don. The EA should provide a discussion of the mei s o ra . gat wru ue used to address the treatabibty concerns associated with the, eutrophicauon and the predicted levels of other contaminants in the: future reservoir water. This discussion of various treatment methods should use the most recent water quality testing; studies available and address all environmental and human health impac[s, as well as cost comparisons among the methods proposed. The EA should distinguish all cost estimates as to initial or incurring costs. 4. If water treatment will result in the need to dispose of backwash wasi: wags, the method of disposal and environmental impacts must he, addressed. Characterization of the future backwash or other wastewaters from the WTP (including toxicants) must be provided and the method or mitigation of the; impact addressed. S. The assumption put forth in the EA that filter backwash and of#'luert from the WTP (which will be discharged back into the reservoir) will not contain any nutrients should be supported with, data acid concentration information from other similar facilities. Other similar water trcuunent plants should be investigated, such as Cary's WTP. where the water supply is eutrophic and has a high nutrient load. b. Reclassification of the Randleman Watershed to a Water Supply (WS) Classification will he required ptior to use of the, water for public consumption. The Management Plan and Nutrient Strategy required as pan of the 401. Certification for this project will need to bcs approved and adopred (and to effect) by F, MAY 14 .' 9 03 s 49Pj1 P :gig ray i • eor••� i e.!•fNR •PUBLIC AFFAIRS 5 DEEM ##874 RandIetnan WTP DWQ Comments page 3 FM local governments either prior to or simultaneously with the roclassification of the Randleman Watershed for Water Supply purposes. Additional discussion on the classification process and required construction practices in water supply "'� rewamrshods is provided in the; attached memo from Steve Zoufaly with DWQ's Clualcations and Standards Unit, 7. On page 8 of the EA a statement is made that the proj= will have no adverse effects on other water su�PIles. Discussion should be as Whe e noten ' acts water withd n downstrea�th&aw In addition,prop sed interbaodn V/ transfer o wa er from the Deep River tRiver Basins will result in PAR additional nutrient inputs into Jordan Lake: which is already experiencing cutrophication problems. The EA should discuss whether this addition of nutrients will exacerbate the existing cutrophic conditions in Jordan Lake. If the applicant should have any questions on these comments, I can be reached at, (919) 733-7015. a hA974 R=d =au wm� attachrncnts cc: DWQ gaff DER - Public War SUMly lz�al FAR M" IM IM P.6/8 MAY 14 199 03:49PM �. MAY 13 '99 01:07PM EHNR•PUBLIC AFFAIRS DIVISION OF WATER QUALITY Water Quality Section September 12, 1997 Past it Fax Note 767t r To@L4 A CoJDeo3. Co. M PAona k E�ax rr Fe: M MEMO_RANDUM ' Michelle Suverkrubbe 7 FROM: Stevo Zoufal Y _- SUBJECT: Environmental Review Number 874 - Randleman Water Treatment Plant EA - Guilford and Randolph Counties _ Thank you for the opportunity to comment on the Environmental Assessment for the proposed Randleman Reservoir Water Treatment Plant. As you arc aware, there is considerable discussion occurring presently pertaining to the proposed Randleman Reservoir. Since the section of the Deep River where the reservoir is proposed to be constructed is not currently classified for use as a water supply source. a reclassification will be required. Additional water quality evaluations are currently underway to assess the _ suitab;lity of reclassifying the Deep River (Randleman Reservoir) as a raw water supply source. Prior to use as a raw water supply source. the River Environmental Management Commission trust reclassify the Dccp (Randleman Reservoir) for water supply use. Typically the Division of Environmental Health Public, Warr Supply Section, does not grant approval to withdraw water for consumption until the water supply reclassification has occurred. Even though there is a direct correlation between the reservoir and the water supply intake, a separate analysis is being conducted for the reservoir, therefore my comments will be limitod to the assessment of the proposed water treatment facility. ' The water treatment plant construction will need to comply with the water cupply watershed development requirements by limiting the amount of impervious surface area and using the appropriate buffer size_ Due to the close proximity of the water treatment plant to the intake. consideration should be given to constructing the facility using more protective development measures than the state's minimum criteria for water supply whenever possible. For example, minimizing impervious watershed protection surface area. incorporating a buffer that is larger than the minimum requirements, making certain that any hazardous materials are properly stored with adequate spill prevention/containment measures designed into the Caeility including a spill remediation, and incorporating the requirements of the Division of Land Resource's more stringent sedimentation and erosion control requirements (15A NCAC 48 .0024) throughout the construction phase. If you have any questions please give me a call at 733-5083. cxt. 566. Enclosure cc: Colccn Sullins 'R Lisa Martin Zk R uidleman Res. WTP.mem M" MAY 14 '99 03:50PM P.7i8 MAY 13 '99 01:0?PM EHNR•PUBLIC AFFAIRS P.2 • t. MC-ADMIN-CODE Page 1 �+ 15A NCAC 48.0024. DESIGN STANDARDS IN SENSITIVE WATERSHEDS 15A NCAC W- 0024 NORTH CAROLTB4 ADMINISTRATIVE CODE TITLE 15A. DEPARTHE i1T OF ENVYRONMENT . HEALTH, AND NATURAL RFSOUF%C"za CHAPTEIR 4. SEDIMWrATION CONTROL SUBCHAPTER 4B. EROSION AND SEDntM CONTRox. .0024 DESICM STPSMAR3)S IN SENSITIVE WATERSHEDS (a) Uncovered areas in M' cones shall be 1 imi ted at any r-=.16 to a maximum total area within the boundaries of the tract of 20 acres. 0n1y the portion o! t-he Land -disturbing activity within, a HOW zone shall be governed by �► this Rule-. Larger art -as may be uncove-ad within the boundaries of the tract wits th& written 3ppYovai of the Director. (b) Erosion and sedimcntati.on Control measures, structures, and devices wi ;i^.in HQW zones shall ba sn plarLZ�d. designed and constructed '-o i provde protection from zt= runoff of the. 25 yaar sto= a which produces the maxim:m Peak rate of runoff as calculated according to procedures in the United States Department- of Agricultural Soil Conservation Service's "National Engineering Field Manual for Conservation Practices" or according to procedures adopted by any other agency of this stxtc or the United States or any generally recognized orgar-Lzacion Or assaci&ticn. (c) Sediment basins within HgW zone. mall be designed and constructed such that the basin will have a settling efficiency of at least 70 percent for the 40 micron t0.04 ►) size soil particle transported into the basin by the runoff of that two-year storm which produces the maximum beak rate of rwnofi as calculated according to procedures in the United States Depax-tme.,nt of Agriculture soil Conservation Services -National Engineering Field Man+1 for Conservation Practices" or according to procedures adopted by any ether agsncy of this state or chi United States or any generally recognized organization or association. (d) Newly constructed open channels in zones shall be designed and constructed with side slopes no ..teepec than ewo horizontal to one vertical if a vegetative cover is used for stabilization unless soil condiz:ons permit a steeper slope or whence the slopes are stabilized by using rnec�ann�8lthevgle structural devices or other acceptable ditch liners. In *ny for side slopes shall be sufficient to restrain accelcral:ed erosion. (e) pursuant to G.S. 113A-57(3) ,previsions for a ground cover sufficient to restrain erosion lnuat be provided for any portion of a land -disturbing �*+ ng activity in a HQW tone within 15 working days or 60 calendar days follow'. completion of construe+uion or development, whichever period is shorto-,r. *2031.9 fag History Note: Statutory Authority G.S. 113A-54.(b); 113A-54(c)(1); Eff. NaY 1• 1990. E&tor+s Note: Title 15 Department of Natural Resources and Community Develoement, has been recodified as Title 15A, Depart-Mn, of c'*,nvs.ronment. Health, and Natural Resources effective November 1, 1989. The recodi-£ication was pursuant co G.S. 143B-279.1. Copyright (c) West Publishing Co. 1996 No claim to Odgirtal U.S. Govt. works. me State of North Carolina Department of Environment, Health and Natural Resources • Winston-Salem Regional office James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary ED HNF;Z August 20, 1997 MEMORANDUM TO: Faith Abbott, Environmental Engineer Public Water Supply Section Raleigh Central Office FROM: Lee G. Spencer, Regional Engineer Public Water Supply Section ;h-16 Winston-Salem Regional Office SUBJECT: Piedmont Triad Regional Water Authority Randleman Water Treatment Plant Environmental Assessment - July 1997 Randolph County RM This office has reviewed the above referenced Environmental Assessment (EA) . We have a number of concerns about the proposed Randleman Lake for a public water supply source. As you know, I sent a memorandum on the recent draft Environmental Impact FM sent (EIS) for Randleman Lake to Melba McGee on August 11, 1997. A number of the concerns about the EIS apply to this EA. 00 There is one primary concern about the EA for the Water Treatment Plant. Is the proposed water supply suitable for use as a public water supply source, and has the best available water source in this area for a public water supply been chosen? North Carolina General Statute (NCGS) 130A-316 charges us with examination of waters, sources, and surroundings which are proposed to be used as a public water supply. We are to determine whether om the waters and their sources are suitable for use as a public water supply source. NCGS 130A-317 further charges us with advising all persons of the most appropriate source of public water supply. No With the above in mind, this office would like to have some issues adequately addressed. These include alternatives analysis, watershed protection, and water quality issues. Comments': on each of these issues are outlined below: I - Alternatives Analysis This office is aware that a new public water supply source A.is. " sorely needed in this area due to growth and economic prosperity. However, we would like to make sure that all other alternatives to Pam 585 Waughtown Street, ���� FAX 910-771-4633 ' Winston-Salem, North Carolina 27107-2241 NvfCAn Equal Opportunity/Affirmative Action Employer Voice 910-771-4600 I Xt , 509/a recycled/ 10% post -consumer paper Randleman WTP EA August 20, 1997 fm Page 2 this project have been sufficiently explored and eliminated. If the Randleman Lake project goes through, as the EIS points out, there will be a substantial interbasin transfer from the Deep River basin to the Haw River Basin. In stream waste concentrations of both Greensboro's and High Point's wastewater effluent flows are very high. A significant portion of the flow into the proposed Randleman Lake Reservoir will be from High Point's wastewater effluent flow. With this in mind, has consideration been given to Greensboro (the largest user) conducting wastewater reuse/recycling within their own basin? Indeed, this would provide incentive for optimum wastewater treatment, and would perhaps be a model for our part of the country. Why is this alternative not listed in the EA? MR Why are withdrawals from the Dan or Yadkin Rivers not listed as alternatives in the EA? Interbasin transfers and water rights issues would come into play, but water quality in each of these streams is considered good. Also, these streams are already classified and used for public water supply. Why is purchasing finished water from Burlington and/or Winston-Salem not listed as an alternative in the EA? II - Watershed Protection Continued urbanization of this already stressed watershed is mm of concern (see water quality issues below). Why are local water supply watershed ordinances in place for Guilford County, Randolph County, and Greensboro, but not for High Point, Jamestown, Archdale, and Randleman? Will all the water supply watershed ordinances, once in place, adequately address non -point source pollution? Do the large animal operations on the Muddy Creek arm of the proposed lake pose a pollution and health risk from runoff and spills? III - Water Quality Issues A DEM memorandum dated March 2, 1993, revealed water quality problems on this portion of the Deep River. This memorandum states that "A review of the data reveals that quite a bit of data exceed water quality standards both as presently classified as well as if these waters were classified as a water supply." This memorandum goes on to say that testing indicated that a lake situation downstream has the potential for significant problems from algal response to nutrients. `m This office received on August 22, 1995, two reports on water MW Mo Randleman WTP EA August 20, 1997 fm Page 3 quality in the Deep River. Both documents were approved on September 28, 1994, by Steve Tedder, Chief of the Water Quality Section. One is entitled "Water Quality Monitoring Data For Waters in the Upper Deep River Area, July 28, 1992 - October 7, 1993", and the other is entitled "Review of Deep River/Carbonton Water Quality Investigations, 1992/1993". These reports were very informative and obviously the result of a great deal of work. Both of these reports reference various water quality violations and chemical detections in the Deep River. During the sampling period, water quality violations were found for dissolved oxygen, fecal coliform bacteria, Lindane, and Dieldrin. Action level exceedences were found for copper, zinc, and iron. Detection levels were found for phenols, and 1,376 unidentified organic M=+ chemicals. Elevated nutrient levels were found throughout the study area. These reports all reveal water quality problems on the Deep River. Two of the reports indicate that a lake situation in the study area has the potential for significant problems from algal response to nutrients. How will these problems with water quality be addressed?? Another potential water quality issue is Inflow/Infiltration S in High Point's wastewater collection system which will cause sewage to bypass the new tertiary WWTP during larger storm events and be collected in the proposed lake. Has this issue been FM addressed in light of the long retention time in the proposed lake? Has there been any sampling for Cryptosporidium or Giardia parasites in light of their resistance to many disinfection am parasites and in light of the large dairy farms in the Muddy Creek watershed of the proposed lake? Have all identified sources of pollution, both point and non - point, been addressed in light of the proposed Randleman Lake Reservoir for a public water supply source on the Deep River? Will the finished, treated water from this proposed facility be compatible with all 6 users and their other water sources and treatment techniques? If adequate answers to the above issues and questions can be provided, we will not object to this project. However, until water quality in the lake meets all water supply water quality standards, we will have reservations about this project. This office would like to see all the above issues addressed in the Environmental Assessment. cc: Jessica G. Miles, Section Chief, Public Water Supply ow Aft Ow an FM Appendix B Mitigation Measures of the City of Greensboro for Secondary Impacts Associated With Urban Development am MR MR a" MEMORANDUM To: Richard Huffman, Water Resources Cc: Allan Williams, Ann Mayson From: Scott Bryant & Jeremy Thomas, Storm Water Services Re: Preliminary Response to State Wildlife Resources' Comments on Randleman Water Transmission Main EA - Project No. 1038 CR' Revised Draft for Internal Review Date: June 5, 2000 6M Background The March 20, 2000 letter from the State Wildlife Resource Commission (WRC) provides comments on the Environmental Assessment EA prepared for the City of P ( ) P p tY Greensboro Randleman Water Transmission Main project. In this letter the WRC requests that the City implement additional measures beyond those listed in the EA to mitigate secondary development resulting from this project. The additional requested measures, as noted in the WRC's letter, include: 1. A minimum 100-foot forested riparian buffer should be maintained along all perennial streams within the project service area. These buffers would help minimize impacts to water quality, aquatic and fisheries resources and provide travel corridors and habitat areas for wildlife displaced by secondary development. The areas could be protected by implementation of riparian buffer rules, obtaining conservation easements or purchasing riparian property. 2. Restore degraded riparian areas within the project service area. This could include re - vegetation with trees or other native species beneficial to wildlife. Restoration of these areas would improve wildlife habitat and provide more effective buffer areas to protect downstream water quality and aquatic resources. The restored areas should be protected by implementation of riparian buffer rules, obtaining conservation easements or purchasing the riparian property. MR 3. Prohibit fill and development in the existing 100-year floodplain within the project service area. ® 4. Develop and maintain stormwater control structures to reduce urban runoff into streams within the project service area. Reducing urban runoff will minimize impacts to downstream water quality, aquatic resources, and riparian and stream habitats. RM er r. Response The City of Greensboro is a proactive community in natural resources and water resources protection, including innovative programs in stormwater and watershed management. Some of the City's current ordinance requirements, policies and programs in natural resources management may exceed State and Federal requirements and provide a benchmark for other communities. Planned future programs for the City will aim to continue to benefit the quality of life for the Greensboro community, by optimally protecting its natural and water resources, stream wildlife and aquatic habitat through lam proactive, watershed -based programs. Before each requested measure is addressed individually, below are highlights of several �+ proactive programs initiated by the City of Greensboro: Stormwater Management Ordinance (Section 27-22): The purpose of this ordinance is �+ to protect, maintain, and enhance the public health, safety, and general welfare by establishing minimum requirements and procedures to control the adverse effects of increased stormwater runoff associated with new development or re -development within ' the City of Greensboro. This ordinance requires new development or redevelopment projects within the city to implement and maintain stormwater control structures, as necessary, to reduce urban runoff impacts to downstream receiving waters. Watershed -Based Stormwater Management Master Planning: The City is currently in the process of collecting survey and attribute information on stormwater conveyance rm-1 systems in the City's watersheds including pipes, inlets, culverts, channels, water bodies, etc. This information along with other data such as land use, soils, and topography will be used in hydrologic, hydraulic, and pollutant loading models to evaluate existing and ®' future potential problems such as flooding and drainage problems, problems resulting from non -point source pollution, stream restoration needs, and to identify areas for stream buffer protection, stormwater and non -point source controls, and storm sewer 'A' infrastructure retrofits, for example. Stream Identification and Mapping Project for Watershed Protection: The purpose of this proactive project is to field visit streams within the Reedy Fork (Greensboro) WS- III water -supply watershed to determine the breakpoints from intermittent to perennial streams. The methodology for determining breakpoints for the perennial streams will be established by field criteria approved by the City, State Division of Water Quality (DWQ), and other stakeholders including regulators and special interest groups. This project will allow the City to most accurately determine its stream resources within local watersheds so they can best be protected. OR Stream Corridor Restoration and Reforestation Program: This innovative project is focused on restoring and reforesting public stream corridors which are maintained by the City of Greensboro to the extent practicable. More information on this and other City stormwater management and water resources protection programs may be found on the City's web site at — http://www.ci.greensboro.nc. us/env_sves/Storm%20Water%20Services/mainindex.htm 2 om Response to Requested Measure 1 _ • Stream Buffers for Water -Supply Watershed Protection: The City of Greensboro requires stream buffers on perennial streams as specified in the State's Water -Supply Watershed Protection rules and Randleman Lake Water Supply Watershed Nutrient Ram Management Strategy. Buffers on intermittent streams are also required in the Randleman Watershed. The water supply watershed protection requirements meet State of North Carolina mandates. MM • Citywide Stream Buffers: Through the City's proactive Storm Water Management Ordinance, stream buffers are required on all open perennial streams and significant f U-' drainageways (drainage greater than 50 acres) inside and outside of water -supply watershed areas. This buffer requirement is a City initiative (not required by the State or other regulatory agencies) to improve the health of local stream systems, to F protect water resources, and to promote wildlife habitat along stream corridors. The buffers specified in this ordinance are measured 50' from the most applicable of (1) top of stream bank, (2) top of steep slopes adjacent to the stream bank, or (3) edge of contiguous wetlands. • The City enforces "Drainageway and Open Space Dedication" requirements. Where significant streams are present on land proposed to be sub -divided, the land area within the 100-year floodplain or a minimum average width of 200' along the stream is required to be dedicated to the City of Greensboro. The purpose of the open space is to provide means for natural flooding, greenways, and passive recreational activities. r • Forested riparian buffers are not mandated by the State. , .ter'` 3 d ism • The City is in the process of developing and implementing a Stream Corridor Restoration and Reforestation program for publicly maintained stream systems. This program will provide increased forestation and vegetation along streams in the city and should be consistent with the goals of the WRC. Response to Requested Measure 2 • It is envisioned that riparian areas adjacent to the transmission main corridor would be re -vegetated if impacted during construction. All reasonable and practicable efforts will be taken throughout the project construction to minimize impacts to riparian areas in the project vicinity. • As noted above, the City is developing a revised Stream Corridor Restoration and Reforestation Program. The current initiative is to allow the banks of streams along public land to grow naturally, in addition to planting new trees and lesser vegetation. This policy is to help thwart stream channel degradation, provide shading to the stream, and encourage stream and wildlife habitat. It is envisioned that the policy may expand, if consistent with development of watershed master plans, to allow land c. adjacent to banks of streams to grow naturally. This would further protect stream resources and allow for increased wildlife habitat. • The City encourages stream restoration activities. The NCDOT has completed two stream restoration projects (one in a City park) in Greensboro. Several other restoration projects are proposed by private parties. One goal of the City's watershed master planning will be to identify and prioritize streams that need to be restored to promote local water and natural resources goals and objectives. This information can be used to guide stream restoration efforts through City capital improvements and private expenditures. `$' Response to Requested Measure 3 • The City currently participates in the FEMA National Flood Insurance Program and is in good standing. The City enforces flood damage prevention requirements through the City's development ordinance. Although fill and development in the regulatory Fft (100-year) floodplain (outside of the floodway) is allowed by FEMA and City ordinance, the City does not encourage fill and development within the floodplain. • The City prohibits fill and development within FEMA regulatory floodways throughout the city limits. ,,�, • The City's floodplain development ordinance was developed to satisfy State and Federal standards for FEMA regulatory streams and floodplains. • The City does not regulate streams or floodplains outside of the city limits. • As part of the master planning programs, the City will update the floodplain maps and also project the base floodplain as a result of future development. This tool will allow the City to direct future development activities to eliminate or minimize impacts to the floodplain. It is envisioned that floodplain information may be available via the internet to increase awareness and understanding of local streams and floodplains. Response to Requested Measure 4 • The City requires newly developed areas within the water -supply watershed areas to construct and maintain stormwater controls and improvements. The City also requires, above State minimum requirements, that developments classified as "low density" (typically less than 24% built -upon area) be required to implement non- structural and/or structural best management practices. This program includes 12 factors that generally rate the impact of the proposed development upon receiving waters. If a development has a rating below a passing score, then a structural control must be implemented. • The Stormwater Management Ordinance (effective citywide) requires that new development sites evaluate impacts to the downstream system as it relates to erosion, am o drainage, and flooding problems. Where potential problems are determined, the applicant is required to reduce flow rates discharged from the site through methods FW such as structural controls or improve the downstream conveyance system to make it more resistant to stream bank erosion, for example. • In addition, the City has been awarded an $800,000 grant by the State's Clean Water Management Trust Fund to create an innovative 20-acre urban wetland located on the South Buffalo Creek and floodplain near Freeman Mill Rd and I-40. The primary ' objective is to treat, to the maximum extent practicable, the first flush of rainfall runoff (stormwater) from the upstream watershed to improve the quality of water in the South Buffalo Creek. The area of the watershed is approximately 13 square miles. A secondary objective is to provide an environmental education and recreation facility for the public in Greensboro, as well as increased wildlife habitat. MR F, M M fm Im As part of the watershed master planning efforts, the City envisions identifying other areas to implement "regional" stormwater and non -point source pollution controls similar to the urban wetland mentioned above. 5