20080978 Ver 1_Other Agency Correspondence_20090224

RCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
February 24, 2009
MEMORANDUM
TO: Melba McGee
Department of Environment and Natural Resources
THRU: Alan Clark, Section Chief.
Planning Section
FROM: Hannah Stallings, SEPA Coordinator
Basinwide Planning Unit and SEPA Program
SUBJECT: Davidson County - Davidson Water WTP Upgrade to 30 mgd
DWQ#14091; DENR#1491
The Division of Water Quality (DWQ) has reviewed the subject document and has the following comments that need to
be addressed in a revised EA:
1. DWQ will need to rescind the 401 Certification issued to Davidson County in July 2008 for the new raw water intake
structure since the scope of the project has changed. The county will be required to reapply once a Finding of No
Significant Impact is issued.
2. The EA references the 2003 and draft 2008 Yadkin-Pee Dee Basinwide Plan. Please update references and
information within the text as necessary based on the final July 2008 draft of the Yadkin - Pee Dee River Basinwide
Water Quality Plan. The final 2008 Plan is available at:
http://h2o.enr.state.nc.usibasinwide/Neuse/2008/documents/Yadkin-PeeDeeBasinPlan2008pript ob pdf.
3. Please update classifications (and supplemental classifications) of local water bodies based on the current information
in BIMS, which is available at: http://h2o.enr.state.nc.us/bims/reports/reportsWB.html.
4. Please update whether local waters are supporting of their best intended uses based upon the current Integrated
Report, which is available at: htip://h2o.enr.state.nc.us/tmdl/documents/200618 FINAL 000 pdf.
5. Subsection 5.3 - DWQ suggests that the text be amended to read: "Construction of the proposed project will not have
significant direct impacts ..."
6. Subsection 5.10.1.2, page 50 - Please clarify if the document should refer to the "Counties"' buffer requirements.
7. Subsection 5.10.2.1 - Please clarify whether groundwater quantity is expected to be impacted.
8. Subsections 5.10.2.2 and 5.10.2.3 should be amended to include what indirect and cumulative impacts, respectively,
future development is expected to have on groundwater resources.
9. Forest Resources
a. It is confusing that while section 5.11 states that "The amount of disturbed forested area will be approximately 4.0
acres" (similar statement also in 6.11), discussion on direct impacts to forest resources does not provide an
estimated area of impact. Furthermore, DWQ would disagree with the statement in 5.11.1 that "Due to the small
amount of trees present, any direct effects on the surrounding forest resources will be minimal" since the EA
states that approximately 4.0 acres will be disturbed by this project.
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b. Please amend the discussion of impacts to Wildlife and Natural Vegetation in sections 5 and 6 to acknowledge the
4.0 acres of forested areas that will be disturbed.
10. Cumulative Impacts
a. Page 5 of the document states that "The existing 20 mgd WTP no longer meets the capacity needs of the system's
large, growing customer base" and notes that the plant was expanded from 12 to 20 MGD in 1997. Also, the text
states that the proposed expansion will indirectly cause increased development within the WTP's service area and
that Davidson and Randolph Counties will be able to lure new business and industry to the area. Therefore, the
oft repeated statements in discussions of cumulative impacts that "adverse additive or synergistic cumulative
impacts" are not expected in the project area seem inexplicable. Furthermore, it does not correspond that the text
highlights areas/resources that will be indirectly impacted by the project but also minimizes possible cumulative
impacts resulting from this WTP expansion.
Please take this example from subsection 5.4.3 for how the discussions of cumulative impacts are disorganized
and contradictory: While the first paragraph gives examples of how cumulative impacts could occur in the
service area, the second paragraph states that cumulative impacts are not expected. Then, the third paragraph
provides information on the cumulative impacts that will occur.
The subsections on cumulative impacts need to be thoroughly revised.
b. It seems anomalous that the text states that there as a "limited service area" associated with the proposed WTP
upgrade when the current service area spans nine municipalities/water systems, two counties, and four sub-basins.
Please clarify.
c. While some of the cumulative impact discussions contain the statements that "It should be noted that new areas
are not anticipated for service" because most growth will come from infill development, others state that
"Existing areas within rural Davidson and Randolph Counties ... are the primary focus of this project." Please
clarify.
d. Also, it is confusing that while discussion in section 5 states that there will not be (indirect and) cumulative
impacts on certain resources that mitigative measures for such impacts to resources are listed in section 6. Please
amend the text to be more congruent.
11. DWQ supports the use of sediment and erosion control measures to mitigate for impacts to surface waters and
wetlands.
Please contact me at 807-6434 if I can be of any additional help.
Thank you.
Cc: Steve Tedder, Sue Homewood - WSRO
Cyndi Karoly, Ian McMillan - 401