United States
Environmental Protection
Agency
Region 4
345 Courtland St., N.E.
Atlanta, GA 30365
904/9/90-005
EPA
July 1990
ssEPA
FINAL
ENVIRONMENTAL
IMPACT STATEMENT
Durham - Eno River Wastewater
Treatment Plant and Service Area
City of Durham, Durham County, North Carolina
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FINAL ENVIRONMENTAL IMPACT STATEMENT
DURHAM-ENO RIVER WASTEWATER TREATMENT PLANT AND SERVICE AREA
Prepared By
Environmental Protection Agency, Region IV ft/
345 Courtland Street, N.E., - ...
Atlanta, Georgia 30365
In Cooperation With 4 rf..
State of North Carolina
Department of Environment, Health,
and Natural Resources
Division of Environmental Management
This Final EIS addresses wastewater facilities and management options for the
City of Durham, North Carolina. Numerous wastewater management alternatives
have been evaluated with particular attention to water quality in the area's
surface water and the impacts of projected population growth on the natural
and human resources of Durham and the surrounding area.
Comments and inquiries should be forwarded to:
Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30365
(404) 347-3776
FAX (404) 347-5056
Approved By
A. ^
G(/eer C. Tidwell JD —
Regional Administrator
Environmental Protection Agency
Region IV
Date
„!!!! r
VVU ,7 V ; •
7^
George T. EJylerett, Ph.D.
Director
Division of Environmental
Management
Date
i/ir-io
Library Region IV
US Environmental Protection Agmcv
345 Courtland Street
Atlanta, Georgia 30365
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TABLE OF CONTENTS
Durham - Eno River Final EIS
Page
Acknowledgements ii
Executive Summary ES-1
Part A. Purpose of this EIS and Background ES-1
Part B. Key Environmental Considerations ES-2
Part C. Alternatives Evaluation ES-3
Part D. Preferred Alternative ES-7
Part E. Agency Decision - Technical Bases
and Rationale ES-7
Part F. Recommendations ES-8
Part G. Mitigative Measures ES-8
Preferred Alternative 1
Introduction 1
Description of the Preferred Alternative 2
Project Phasing 2
Financial Alternatives 10
User Charges 11
Impacts of the Preferred Alternatives 13
4.3.1 through 4.3.11 of DEIS 13
Mitigative Measures 28
Letters Received and Responses to Letters R-l
Public Hearing Responses PH-1
Letters Not Requiring a Response NR-1
Transcript of EIS Public Hearing T-l
Appendices to Final EIS
Appendix A - Durham Code A-l
Appendix B - NCDEM Guidelines for Obtaining a
Protective Surface Water Classification B-l
Appendix C - Consent Judgment (JOC #89-03) between
State of North Carolina and City of Durham C-l
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ACKNOWLEDGMENTS
This Environmental Impact Statement was prepared with the valuable assistance
from individuals who represented a wide spectrum of interests. EPA. gratefully
acknowledges individual contributors and those who represented community,
city, county, and state agencies and provided both effort and intellect to
evaluate the numerous, complex facets of wastewater disposal impacts on eco-
logical and community resources. Special recognition is given to the City of
Durham's Water Resources Department for their generous cooperation, in
addition to water quality and field data; and the North Carolina Department of
Natural Resources and Community Development's Water Quality Section for their
superior field studies and modeling of area surface waters. These con-
tributors are listed below.
Association for the Preservation of Eno River Valley - Margaret Nygard
Allenton Realty - Ralph Cochran
Consulting Engineer - C. Page Fisher
Durham Chamber of Commerce - Frank Smiley
City of Durham Emergency Management - Deryl L. Bateman
City Council of Durham - Virginia Englehard
Durham City Engineering Department - Kenneth E. Wright
Durham City/County Planning Department - A. Paul Norby and Richard Hails
Durham City Water Resources Department - A. Terry Rolan
Durham County Engineering Department - Douglas C. Cullinane
Durham County Emergency Management - Ted Cope and Bill Colley
Durham County Health Department - John Upton
Durham Research Properties, Inc. - Gerald Strickland
Duke University, School of Forestry and Environmental Studies - Ken Reckhow
Federal Highway Administration - John Tidwell
North Carolina Wildlife Federation - Michael Corcoran
North Carolina Division of Environmental Management and Community Development,
Water Quality Section - Trevor Clements and Tom Stockton
North Carolina Department of Agriculture - Robert Sutter
City of Raleigh Public Utilities Department - Carl Simmons
Save the Water! - Jim Clark and Kathy Register
Sierra Club - Edward C. Harrison
Sierra Club Capital Group - David Howells
Organon Teknika - Edward Gormley
Triangle J Council of Governments - Edward Holland
U.S. Army Corps of Engineers, Wilmington District - Coleman Long
Water Resources Research Institute, North Carolina State - David Moreau
ii
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EXECUTIVE SUMMARY FOR ENVIRONMENTAL IMPACT STATEMENT
DURHAM-ENO RIVER WASTEWATER TREATMENT PLANT AND SERVICE AREA
DURHAM, NORTH CAROLINA
Draft [ ] Final [X]
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
Type of Action: Administrative Action [X]
Legislative Action [ ]
EXECUTIVE SUMMARY
A. Purpose and Background
The purpose of this Environmental Impact Statement is to evaluate waste-
water treatment alternatives for the Durham-Eno River wastewater treatment
plant service area and the impacts of those alternatives. Current wastewater
practices use residential on-lot treatment and a 2.5 mgd Eno River wastewater
treatment plant. The City of Durham had determined that existing wastewater
treatment needs, failing on-lot septic tank systems, and future needs
associated with rapid population growth within the Urban Growth Boundary will
necessitate an expansion of the Eno River wastewater treatment plant to 12 mgd
or more. It was felt by all levels of government involved as well as by the
general public that an Environmental Impact Statement was necessary to
thoroughly evaluate alternatives for wastewater treatment and disposal.
ES-1
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B. Key Environmental Considerations
A primary consideration of the preferred alternative was water quality
impacts to Falls Lake, which is both a recreation area and the City of Raleigh
drinking water supply. Falls Lake was formed, starting in 1983, by the
impoundment of the Neuse River. The reservoir bottom topography is wide and
shallow in the upper northern portion, whereas the southern lower portion is
narrow and deep. Tributaries to the upper portion of Falls Lake include the
Eno River, the Little River, the Flat River, and Ellerbe Creek. The upper
portions of Falls Lake are highly eutrophic. Lakes are said to be eutrophic
when they are overenriched with nutrients, which leads to excessive algae
growth, nuisance weeds, low transparency, and generally poor aesthetics.
Eutrophication also impairs the quality of water drawn for water supply
because it leads to problems relating to taste, odor, and trihalomethane
formation.
Phosphorus is the nutrient limiting algal growth in Falls Lake. The
current phosphorus load to Falls Lake is approximately 204 tons/year. Non-
point sources account for about 115 tons/year (56%) and the point source dis-
charges from the three plants, prior to consolidation by the N-EC alternative,
would contribute about 39 tons/year (19%) to Falls Lake. With, the effluent
limits described above, the expected TP loads for Alternative N-EC Phase A and
B are 34 and 32 tons/year, respectively. Both of these loads are reductions
from the existing 39 tons/year point source load.
Another major issue of this EIS was non-point source pollution.
Increased non-point source pollution is a basin-wide secondary impact associ-
ated with population growth and land development created by expanded waste-
water treatment plant capacity. It was estimated that the year 2010 non-point
source load of TP for the EIS study area would be approximately 18 tons/year.
It was recommended that the Durham County and City Watershed Ordinances and
Sedimentation and Erosion Control Ordinance be strengthened to improve best
management practices (BHP's) for better control of non-point sources of
pollution. Some of the BMP's that should be applied include impervious cover
ceilings, land use controls, detention basins, infiltration facilities, silt
fence curtains, and buffer strips. Additional mitigation of non-point source
ES-2
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loads should involve the formation of a Multi-County Consideration Committee
to handle watershed and non-point source pollution issues. Consideration
should also be given toward upgrading the existing WS-III designation on Lake
Michie and Little River Watersheds to a WS-II or WS-I designation (NCDEM fresh
surface water classification, 15A NCAC 2B.0211).
C. Alternatives Evaluation
Sixteen potential wastewater treatment alternatives were considered at
the start of the EIS process. The alternatives included four different
treatment plant locations and six wastewater disposal options. The 16
alternatives were derived by combining various treatment plant locations and
disposal options. The alternatives were screened on the basis of technical
feasibility and implementability. With input from a 24-member review
committee comprising local citizens, county and city agencies, and the
business community, seven alternatives were selected for further analysis by
EPA and NCDEM.
One alternative for wastewater treatment in the EIS study area was No-
Federal Action. This alternative assumes that Federal funds through State
Revolving Fund loan programs would not be available to the City of Durham, and
that future wastewater management facilities are developed by local funding.
Other alternatives, shown in Figure ES-1, are described as follows:
a. EN-ER A 12 mgd advanced tertiary treatment plant at the Eno
River location discharging to the Eno River.
b. EN-LA A 12 mgd secondary treatment plant at the Eno River
location with wastewater disposal via land application.
c. N-EC A 29 mgd advanced tertiary treatment plant at the North-
side location discharging to the Ellerbe Creek. A 12 mgd
pump station at the Eno River location conveys study area
wastewater to Northside.
ES-3
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a. Alternative EN-ER
b. Alternative EN-LA
c. Alternative N-EC
d. Alternative NT-EC/LA
Eno River
Pump Station
Northside
WWTP
Treyburn
Figure ES-1
Wastewater Management Alternatives
ES-4
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e. Alternative N-NR
Effluent
Conveyance Line
Falls Lake
. MNburnto Dam
Crabtree Creek
iNeuse River
f. Alternative R-NR
Norlhslde
Pump Station
Effluent
Conveyance Un i
Neusa River
Neuu River I
'wSW'
g. No Federal Action Alternative
Eno River
Figure ES-1 (Continued)
Wastewater Management Alternatives
ES-5
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d. NT-EC/LA Modification of N-EC using a 3 mgd secondary treatment
plant at the Treyburn location with land application dis-
posal. Northside facility is 26 mgd. Eno pump station is
9 mgd.
Modification of N-EC using the Neuse River as a new
disposal location.
A 29 mgd pump station at the Northside location. Raw
wastewater conveyed to Neuse River wastewater treatment
plant (Raleigh). Advanced tertiary treatment facility
with discharge to the Neuse River.
A 2.5 mgd advanced tertiary treatment facility at Eno
River location to treat wastewater from failing on-lot
systems. A 2 mgd secondary treatment facility at Treyburn
location with land application disposal. On-lot systems
and package treatment plants serve remaining needs for
wastewater treatment.
The alternatives with Neuse River discharges (N-NR and R-NR) involved a
40-mile pipeline to convey wastewater or effluent to the Neuse River. Imple-
mentation concerns and high cost related to this pipeline removed Alternatives
N-NR and R-NR from consideration. The land application alternative, EN-LA,
would have required five disposal sites in northern Durham County with an
estimated total land area of 7,695 acres. The prohibitively high cost of such
a land acquisition eliminated this alternative from consideration. Alterna-
tive NFA was not considered feasible because it would require future
development to be served by package plants and on-lot systems. Use of these
facilities is not acceptable because of environmental and public health
impacts associated with inadequately treated wastewater discharges caused by
upset conditions and poor maintenance. Water quality monitoring and modeling
conducted by NCDEM indicated that the Eno River was not a suitable receiving
water for the proposed 12 mgd of wastewater discharge. For this reason,
Alternative EN-ER was removed from consideration.
e. N-NR
f. R-NR
NFA
ES-6
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D. Preferred Alternative
Expansion of the Northside wastewater treatment plant under the pre-
ferred alternative would occur in two phases. Phase A would expand the plant
from 9.5 to 20 mgd. Three effluent limits for this phase would be 5 mg/L
BOD5, 1 mg/L NH3-N, and a seasonal total phosphorus (TP) limit of 0.5 mg/L
April-October and 2 mg/L November-March. Water quality monitoring and
modeling are needed to confirm the adequacy of these limits prior to the con-
struction of Phase B. Phase B, which would be initiated in 1995 and on-line
in 1998, would expand the Northside facility from 20 mgd to 29 mgd. Effluent
limits would be the same as those for Phase A, except TP would be lowered to
1.0 mg/L November-March. The 2.0 mg/L TP limit proposed for Phase A is based
upon North Carolina's year-round 2.0 mg/L limit requirement for Nutrient
Sensitive Waters. However, given the eutrophic conditions in the Ellerbe
Creek headwaters of Falls Lake, a stricter 1.0 mg/L limit may be required.
The necessity of this limit should be evaluated during Phase A monitoring and
modeling.
E. Agency Decision - Technical Bases and Rationale
Following comment and input by the Review Committee, EPA and NCDEM
selected Alternative N-EC to be the EIS preferred alternative. Alternative
N-EC had the lowest cost and highest potential for implementability of the
seven alternatives. Alternative N-EC would consolidate three existing waste-
water treatment plants (the Eno River, Northside, and Little Lick Creek
facilities) into one state-of-the-art advanced tertiary treatment facility.
Water quality in the Eno River and Little Lick Creek would improve because
discharges from the old existing plants would be removed. Ellerbe Creek would
benefit from both increased flow and the improved quality of wastewater dis-
charged from the upgraded Northside plant. Additional considerations that
prompted the selection of N-EC were that the Northside plant was already
slated for an upgrade, and the site was sufficiently accessible and large
enough to expand to 29 mgd.
ES-7
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F. Recommendations
Phased construction (A and B) of the preferred alternative will allow
impacts to be assessed and mitigated prior to the ultimate expansion of the
Northside facility to 29 mgd. During Phase A, mitigation efforts should
include water quality monitoring/modeling, non-point source pollution BMP's,
conveyance line construction impact mitigation, and sludge disposal evalua-
tion. The entire collection and conveyance system for the preferred alterna-
tive would be constructed during Phase A. Necessary mitigation activities
include noise reduction, traffic routing, sediment/erosion controls, rights-
of-way conversions to greenways, and conveyance line placements to avoid
archaeological and historical areas. At a Phase A design capacity of 20 mgd,
the Northside facility will generate 5,400 dry tons/year of sludge. Approxi-
mately 1,080 acres of land will be required to dispose of this sludge at
agronomic rates. In terms of toxic metal content, the Northside sludge is
expected to be suitable for land application. Also, there appears to be suf-
ficient acreage in Durham and surrounding counties for land application during
Phase A. The viability of this sludge disposal method should be further
evaluated prior to Phase B of the preferred alternative.
During the operation of the Northside Plant at the 20 mgd level, Ellerbe
Creek would be monitored by NCDEM to assess the impacts upon the stream.
This would need to be done as a condition for receiving permission to expand
to 29 mgd. Additionally, the City of Durham is required by its NPDES permit
to conduct whole effluent toxicity testing on the Northside discharge.
G. Mitieative Measures
Mitigation efforts for Phase A of the preferred alternative should
include water quality monitoring, non-point source BMP's, and continued
evaluation of the sludge disposal operation. Water quality monitoring should
be included as a requirement for the NPDES permit to ensure water quality
standards are met, and to confirm water quality projections made during Phase
A. This process will determine if expansion to 29 mgd can be granted. Non-
point source BMP's will become increasingly important as land use development
ES-8
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continues in the Eno, Northside, and Little Lick Basins during Phase B.
Structural BMP's should be implemented and maintained. Enforcement of non-
structural BMP's involving impervious cover ceilings and land use controls
should continue.
It may be necessary to evaluate the sludge land application disposal
operation. It was estimated that 8,400 dry tons per year of sludge would be
generated by a Phase B capacity flow of 29 mgd, and that 1,680 acres of land
would be required to dispose of this sludge at agronomic rates of application.
Innovative and alternative means for sludge disposal, such as use in the
cement industry, may become preferable to the land application disposal
method.
ES-9
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Preferred Alternative
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I*. 0 PREFERRED ALTERNATIVE
4.1 INTRODUCTION
The preferred alternative would expand the existing Northside wastewater
treatment plant from 9.5 to 20 mgd during Phase A, and from 20 mgd to 29 mgd
during Phase B. The existing Eno River and Little Lick Creek wastewater
treatment plants would be eliminated and sewage from their drainage areas
would be pumped to the Northside facility. The expanded Northside facility
would be designed and constructed to achieve state-of-the-art BOD and
phosphorus removal. Non-chlorine disinfection would be used to reduce the
toxic effects of discharge. Also, ultraviolet disinfection may be used to
eliminate the formation of chlorination by-products. Water quality
improvements to the Eno River and Little Lick Creek will occur when the
existing wastewater discharges are eliminated. Ellerbe Creek water quality
improvement is expected during low flow conditions because of flow
augmentation by the highly treated wastewater effluent. These water quality
improvements should also have a positive impact on the Eno River, Ellerbe
Creek, and Little Lick Creek headwaters of Falls Lake. Water quality
monitoring and modeling for Ellerbe Creek and Falls Lake should be conducted
during Phase A of the preferred alternative to confirm expected water quality
improvements and to determine effluent limits for Phase B.
The preferred alternative is referred to with the acronym "N-EC."
Alternative N-EC had the lowest cost and best potential for implementability
of all the seven alternatives that were evaluated. It would result in a
centralized, highly advanced tertiary treatment facility at a plant that is
already planned for an upgrade, the Northside WWTP. The land application
alternatives were not feasible because of the cost and unavailability of land
suitable for spray irrigation.
Editor's Note: To facilitate cross-references with the Draft Environmental
Impact Statement (EIS) published in September 1989, the chapter headings in
this Final EIS have remained the same as in the Draft.
1
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4.2 DESCRIPTION OF THE PREFERRED ALTERNATIVE
4.2.1 Project Phasing
The existing Northside WWTP has a design capacity of 9.5 mgd average
daily flow. The proposed facility would provide 29 mgd of treatment capacity
to the existing Northside Service Area, the Little Lick Service Area, and the
Eno River Service Area. Projected flows from these three service areas are
listed in Table 4-1 and graphed in Figure 4-1. By the year 2010, wastewater
flow from the Eno River Service Area is projected to equal 12 mgd, or 40
percent of the total capacity need for the area tributary to the Northside
WWTP. The incremental flow increase in year 1993 is a result of a 1.6 mgd
discharge from Mitsubishi.
A Finding of No Significant Impact was issued by NCDEM on April 28, 1989
for an expansion of the Northside WWTP to 20 mgd. NCDEM did not consider an
application for an expansion to 29 mgd so as to not preclude or bias the
findings of this EIS. The preferred alternative would be implemented with a
two phase schedule. The first phase would involve expansion of the Northside
plant from 9.5 mgd to 20 mgd. During the first phase, water quality
monitoring and modeling of Ellerbe Creek and Falls Lake would continue. A
priori projections of water quality improvements and impairments would be
refined and updated during this time. Effluent limit requirements for the
second phase, i.e., the expansion from 20 to 29 mgd, would be further
evaluated during this monitoring and modeling. As seen from Figure 4-1,
wastewater flows from the three service areas are projected to exceed 20 mgd
in 1998. Therefore, the second phase of the two-phase project schedule would
have to be completed and on-line by 1998.
The existing capacity of the existing Northside WWTP is 9.5 mgd. As seen
in Table 4-1, flow to the Northside basin will use this capacity prior to
completion of the first phase expansion in 1993. For this reason the Eno and
Little Lick plants should remain on line through at least the year 1993. It
is the recommendation of this EIS that the failing on-lot system areas be
given preference over new development when sewer extension permits are granted
to the County of Durham. Assuming all the lots in the developments listed as
2
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32
30
28
26
24
22
20
18
16
14
12
10
8
6
4
2
0
PROJECTED WASTEWATER FLOWS
TOTAL AREAS TRIBUTARY TO NORTHSIDE WWTP
ij
.£}¦'
GT'
,0"
. , , , , , , ,
to 1992 1994 1996 1998
2000
YEAR
2002 2004 2006 2008 2010
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Table 4-1
Projected Wastewater Flows Per Service Area
(units iri mgd)
Year
Eno River*
Little Lick
Northside
Total
1990
3.7
0.9
8.8
13.4
1991
4.0
1.1
9.2
14.3
1992
4.2
1.2
9.5
14.9
1993
6.0
1.3
9.9
17.2
1994
6.3
1.6
10.0
17.9
1995
6.5
1.8
10.1
18.4
1996
6.9
2.0
10.2
19.1
1997
7.2
2.2
10.4
19.8
1998
7.6
2.5
10.5
20.6
1999
8.0
2.7
10.6
21.3
2000
8.3
2.9
10.8
22.0
2001
8.7
3.2
10.9
22.8
2002
9.1
3.5
11.0
23.6
2003
9.5
3.8
11.2
24.5
2004
9.8
4.1
11.4
25.3
2005
10.2
4.3
11.5
26.0
2006
10.6
4.6
11.7
26.9
2007
10.9
4.9
11.8
27.6
2008
11.3
5.2
12.0
28.5
2009
11.7
5.5
12.2
29.4
2010
12.0
5.9
12.4
30.3
* Total wastewater generation capacity of service area. Includes flows from
existing on-lot systems.
Source: Eno River Flows - See Section 2.2.3.
BUTp1i!v^1Ck«arid U°rJhstde Service Area flows obtained from Northside
Durham ^ Environmental Assessment, January 1989. City of
4
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concentrated failure areas (see the County of Durham Department of Health June
25, 1987 letter in Appendix A) are allotted the NCDEM standard flow of 360
gpd/dwelling unit, the amount of capacity that must be reserved for failing
on-lot systems is 0.8 mgd. The 360 gpd/dwelling unit flow is based upon NCDEM
design criteria. Actual flows would probably be less than this amount and the
amount of capacity needed for failing on-lot systems would be slightly less
than 0.8 mgd.
Table 4-2 summarizes the key milestone dates of the project schedule for
the treatment plant expansion work. The tentative dates listed in the table
are given for planning purposes only and may not reflect actual project
timing. Conveyance facility construction would run concurrent
with the treatment plant construction beginning in 1990. However, due to the
immediate need for sewers throughout the Eno River Service Area and the
economic advantage of initially installing ultimate conveyance capacity as
opposed to future paralleling, conveyance facility construction should occur
during the first phase of the preferred alternative.
Respectively, about 5,400 and 8,400 dry tons per year of sewage sludge
would be generated by the Phase A, 20 mgd and the Phase B, 29 mgd flows of the
preferred alternative. About 1,080 and 1,680 acres, respectively, would be
required to land apply this sludge at agronomic rates. The City of Durham
currently has discontinued disposing of Northside sludge in the landfill cover
material and is considering land application for sludge disposal. As part of
this process, a contractor contacted farmers and estimated that 1,200 to 1,500
acres of agricultural land would be available for sludge application (Personal
Communication with City of Durham Department of Water Resources, July 1989).
The City of Durham is initiating a Comprehensive Sludge Management Study to
further evaluate options for sludge disposal. One of the issues for
Comprehensive Sludge Management Study is the draft regulations for sewage
sludge disposal published by EPA in the February 6, 1989 Federal Register.
These regulations, which currently are in the public comment phase, will
affect land application of sewage sludge. At this time, it is assumed that
sludge generated by the preferred alternative will be land applied at
agronomic rates.
5
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Table 4-2
TWO-PHASED PROJECT SCHEDULE
A. Phase A
1. Design, Bidding, Project February 1990 - Spring 1991
Financing
2. Construction (Expansion from Summer 1991 - Fall 1993
9.5 mgd to 20 mgd)
3. Facilities Startup Fall 1993
4. Water quality monitoring/ Prior to Phase B
modeling of Ellerbe Creek
and Falls Lake
B. Phase B
1. Design, Bidding, Project January 1995 - Spring 1996
Financing
2. Construction (Expansion from Summer 1996 - Fall 1998
20 mgd to 29 mgd)
3. Facilities Startup Fall 1998
4. Water quality monitoring/ Prior to Phase B
modeling of Ellerbe Creek
and Falls Lake
6
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The ultimate cost to the users of the sewerage system would include
capital costs for facility construction and annual costs for facility
operation and maintenance. The capital costs would include collection and
conveyance sewers, wastewater treatment facilities, and treated effluent and
sludge disposal facilities. The expanded Northside WWTP and the collection
and conveyance facilities would serve the Eno, Little Lick and Northside
Service Areas. However, the EIS study area includes only the Eno Service Area
and the costs presented in this report reflect costs only to the Eno Service
Area. To obtain the Eno River Service Area share of total construction costs,
total Northside costs were multiplied by the Eno Service Area's portion of the
expanded WWTP capacity (29 mgd - 9.5 mgd -19.5 mgd). The factor used was
61.5% (12 mgd/19.5 mgd). The collection and conveyance costs represent those
facilities serving only the Eno area.
Table 4-3 lists the estimated costs in 1992 dollars for the construction
and operation of new collection and conveyance facilities to serve the Eno and
Treyburn basins of the Eno Service Area. Project costs include the costs for
construction of gravity collector sewers and conveyance interceptors,
conveyance system pumping stations, and a 12 mgd pumping station at the Eno
River WWTP site with a 20,600 feet force main to convey sewage generated in
the two basins to the Northside WWTP. Project costs for the facilities were
estimated to total approximately $51,296,000, with $42,688,000 and $8,608,000
allocated to the Eno and Treyburn basins, respectively.
As noted in the previous section, two wastewater treatment plant
construction schedules were considered for expansion of the Northside WWTP
from 9.5 mgd to 29 mgd. Table 4-4 lists the estimated costs for construction
of the treatment facilities associated with the two project schedules. The
two-phase construction schedule includes Phases A and B. The Eno River
Service Area share of the Phase A (expansion of the Northside WWTP from 9.5
mgd to 20 mgd) construction was estimated to cost approximately $16,188,000 in
1992 dollars. The share of the Northside plant expansion of 20 mgd to 29 mgd
during Phase B was estimated to cost an additional $18,079,000 in 1997
dollars, the combined total present worth costs for the two phase
construction schedule of $42,496,000.
7
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Table 4-3
WASTEWATER CONVEYANCE COST EVALUATION
N-EC WASTEWATER MANAGEMENT ALTERNATIVE
DURHAM-ENO RIVER EIS
Total EDUs
(Year 2010)
Project Costs
Collection Sewers(l)
Conveyance Sewers
Pump Stations
Contingencies
Right-of-Ways
Total Project Cost(2)
Annual O&M Costs
Eno
Basin
25,900
$18,655,000
12,925,000
5,333,000
5,170,000
605.000
$42,688,000
Treyburn
Basin
4,719
$ 2,233,000
2,971,000
1,260,000
1,888,000
206.000
$8,608,000
Total Eno
Service Area
30,619
20,938,000
15,896,000
6,593,000
7,058,000
811.000
$51,296,000
$ 427,000
(1) Includes 4-inch residential service connection and in-street 8-inch
collector sewer. Assumes 80 feet collector sewer per EDU at $22/linear
foot.
(2) 1992 dollars.
Source: Gannett Fleming Environmental Engineers, Inc.
8
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Table 4-4
WASTEWATER TREATMENT COST EVALUATION^)
NORTHSIDE WASTEWATER TREATMENT PLANT EXPANSION AND UPGRADE
DURHAM-ENO RIVER EIS
Phase a(2)
Phase
Project Costs
Unit Process Construction
Miscellaneous Structures
Non-Component Costs
Contingencies, Water Quality
$ 9,728,400
0
2,724,000
$10,865,100
0
3,042,000
Monitoring
3.735.700
4,172.200
$18,079,500
$ 3,287,000(5)
$42,296,000(6)
Total Project Cost
$16,188,100
Annual O&M Costs
$ 2,865,000(4)
Total Present Worth
Notes: (1) Costs for Eno Service Area, 12 mgd treatment capacity.
(2) Expansion from 9.5 mgd to 20 mgd. Construction completed 1993.
Project costs given in 1992 dollars.
(3) Expansion from 20 mgd to 29 mgd. Construction completed 1998.
Project costs given in 1997 dollars.
(4) O&M costs for treating 17.2 mgd average annual design flow
projected for facility in 1993 costs in 1993 dollars.
(5) O&M costs for treating 20.6 mgd average annual design flow
projected for facility in 1998. Costs in 1998 dollars.
(6) Total present worth for two-phase schedule in 1989 dollars
(combination of Phase A and B).
Source: Gannett Fleming Environmental Engineers, Inc.
9
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4.2.2 Financing Alternatives
The Eno pump station, Northside WWTP expansion project would be funded by
local funding sources. The collection system costs would be paid for by bonds
issued by Durham County. In 1986, the county developed a 10 year master plan
that detailed public improvements. This master plan will be financed by two
bond issues - the first paying for the first 5 years and the second paying for
the last 5 years. The first bond issue allotted for $34 million, $27 million
of which was to be used for wastewater projects with the remaining $7 million
set aside for water projects. The second bond issue will occur around 1991.
The Eno collection system construction costs would be paid for out of these
bond issues. (Personal communication with Durham County Manager's office and
Durham County Engineer's Office).
The City of Durham would like to have a referendum passed in November
1990 to allow the issuance of a bond to cover the treatment plant construction
and upgrade costs. The tentative amount of the bond authorization for
improvements to both the Farrington Road Plant and Phase A of the Northside
plant would be approximately $92.5 million, although the actual amount issued
would most likely be less than this amount and would probably be phased over a
period of several years. After the bond referendum is passed, the City of
Durham would have seven years over which to issue the bond amount. (Personal
communication with City of Durham Financing Office).
In addition to local funding, the City of Durham could also receive money
from the State Revolving Loan Fund (SRLF), supported by federal money, and the
Grant Fund, supported by state money. These funds are described in more
detail below. It is expected that no EPA construction grants money would be
available as construction grants funds have been replaced by the SRLF.
State Revolving Loan Fund. In 1989, the State of North Carolina received
a capitalization grant from the EPA to start a revolving loan fund to finance
wastewater projects. The money in this fund is disbursed in a manner similar
to the construction grants program in that the state maintains a priority list
of projects and only interceptors and treatment works are eligible for
funding.
10
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The maximum yearly disbursement for a project is $7.5 million. However,
if the project is phased, money can be applied for every year the project
remains on the priority list. The interest rate charged for monies loaned
from this fund is the lessor of 4% or 1/2 of the national tax exempt bond
rate. North Carolina bases the bond rate on 20 year treasury bonds.
The preferred alternative of expanding and upgrading the Northside
Wastewater Treatment Plant and replacing the Eno River WWTP with a pump
station is being evaluated for placement on the priority list in fiscal year
1990. (Personal communication with NCDEM, May 1989).
Grant Fund. In addition to the State Revolving Loan Fund started with
the Federal EPA money, the State of North Carolina maintains a similar fund
using money appropriated from the state budget. Currently, this fund does not
have a large budget and the maximum yearly disbursement for a project is $3
million. A separate priority system from that used by the State Revolving
Loan Fund is used to determine which projects are eligible for funding. All
costs associated with the wastewater project, including collection system and
land acquisition, are eligible for funding. The Eno pump station, Northside
expansion project is not currently on the priority list for this money but
will be evaluated for possible priority status in the future. (Personal
communication with NCDEM, May 1989).
4.2.3 User Charges
Under the preferred alternative, all users of the expanded Northside WWTP
would pay the same rate except that county residents would continue to pay
twice the rate of city residents. User charges would be based on cost per 100
cubic feet of wastewater generated. The generation rate is assumed to be
equivalent to the rate of water usage as measured by the user's water meter.
However, in cases in which wastewater meters are installed, the sewer charge
would be based on the sewage meter reading.
The purpose of this cost analysis is not to predict exact user charges
that customers would expect to pay, but rather to estimate the charges under
"worst case" conditions, to assess the affordability of the preferred
11
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alternative. If the project falls within EPA affordability guidelines
(presented below) under "worst case conditions" it would be considered
affordable to the community and no further analysis would be needed. However,
if the project falls outside affordability guidelines, further analysis would
be required.
Standard affordability criteria (EPA, 1983) consider a project affordable
to the community if it falls within the guidelines below.
1.0% of median income if income is less than $10,000.
1.5% of median income if income is between $10,000-$17,000.
1.75% of median income if income is above $17,000.
The 1987 median family income for Durham County, as measured by the Bureau of
Census, was $33,253. In 1989, HUD determined the median family income of the
Durham Metropolitan Statistical Area to be $40,300. Using either income
figure places the Durham area falls within the affordability criteria of 1.75%
of median income.
The assumptions used in generating the analysis are outlined below:
o Number of households based on Moderate Growth Scenario.
o All construction costs (conveyance and treatment) would be paid for
by the local community.
o No state or federal low interest rate loans or grants would be
obtained.
o The Treyburn Development would pay for its conveyance system. No
other developer, business or industry contribution to conveyance
system costs was assumed at this time.
o The 1987 median income value from the Bureau of Census will be used
to calculate percentage of median income values.
12
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o All bonds would be amortized over 20 years with an interest rate of
7.12%. This interest rate was chosen because the current bond
floated by Durham County carries an interest rate of 7.12% (Personal
Communication with Durham County Manager's Office).
o All project costs were translated into 1989 dollars using an
interest rate of 8.78%.
The charges were calculated both as costs per 100 cubic feet of
wastewater and as annual costs per household. All results are presented in
Table 4-5.
The user charges for the preferred alternative would be added to the
existing user charges which are $1.16/100 cf for city residents. The total
annual user charge would be about $340, assuming 215 gpd/household. Divided
by the 1987 Durham County median family income of $33,253, the percent of
median income for an annual charge of $340 is 1.02%, which is well below the
1.75% EPA affordability criteria.
4.3 IMPACTS OF THE PREFERRED ALTERNATIVE
4.3.1 Surface Water Resources
Eno River. The water quality of the Eno River is expected to improve
with the preferred alternative because the existing Eno River WWTP would be
removed. The annual reduction in loads to the Eno River would be
12,700 lb/yr B0D562,000 lb/yr TN, and 4,300 lb/yr TP. Higher dissolved
oxygen levels and fewer algal blooms (lower chlorophyll-a) would be expected.
The quantity of water flowing in the Eno River would decrease below the
existing plant upon implementation of the preferred alternative. The natural
low flow in this stretch of the Eno River is approximately 1.5 cfs (NCDEM,
1989). The current discharge by the Eno River WWTP adds another 1.8 cfs.
Removal of the Eno River WWTP discharge would reduce downstream Eno River
water flow by about 55 percent during low flow conditions. Low flows in the
13
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Table 4-5
USER CHARGES FOR ENO SERVICE AREA1
N-EC WASTEWATER MANAGEMENT
ALTERNATIVE
Two Phase
Phase A^
(19931
Construction
Phase B^
(19981
Construction Costs
(Conveyance & Treatment)
$45,629,000
$9,148,000
O&M Costs
$ 2,550,642
$2,877,608
Annual Debt Payment^
$ 4,348,000
$5,220,000
Total Cost (O&M + Debt)
$ 6,888,642
$8,097,608
Eno Service Area Flow Contribution
6.92 MGD
8.24 MGD
User Charge/100 cf
$2.05
$2.00
Number of Households in Eno Service Area^
32,200
38,300
User Charge for the Preferred Alternative
$214
$211
Existing User Charge
$116
$116
Total Annual User Charge
$330
$327
1 All costs in 1989 dollars.
2 Expansion of Northside WWTP to 20 MGD.
3 Expansion of Northside WWTP from 20 MGD to 29 MGD.
^ Bond interest assumed 7.12%, amortized over 20 years. (Capital Recovery
Factor - 0.0953).
5 Based on 215 gpd per residential equivalent dwelling unit.
Source: Gannett Fleming Environmental Engineers, Inc.
14
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Eno River are the result of increased withdrawals and consumptive use of water
from the Eno River.
Ellerbe Creek. With the preferred alternative, Ellerbe Creek would
receive significantly higher treated effluent compared to the existing
Northside WWTP discharge. The 29 mgd expansion is estimated to reduce BOD
loads from 259 tons/year to 228 tons/year and NH3-N loads would be reduced
from 173 tons/year to 46 tons/year (NCDEM, 1989). The preferred alternative
should have a beneficial effect on water quality because of these pollutant
load reductions and because the increased volume of discharge should cause
greater reaeration in Ellerbe Creek. In spite of these expected improvements
to Ellerbe Creek water quality, NCDEM modeling still indicates that DO
standard violations are possible. The modeling predicts that violations are
expected to be less severe and less extensive than existing violations. There
is some chance the violations would not occur because of model uncertainty.
The purposes of the Phase A water quality monitoring and modeling are to
reduce this uncertainty and document the necessary effluent limits for Phase
B.
Falls Lake. Falls Lake is a highly eutrophic body of water with mean
chlorophyll-a concentrations that can exceed 60 ug/L during warm months in its
headwaters (NCDEM, 1989; and USACOE, 1988). Falls Lake receives point source
discharges from the Northside WWTP and other smaller treatment plants as well
as nonpoint source pollution from urban and agricultural areas. Both point
source and nonpoint source phosphorus loads contribute to the eutrophication
of Falls Lake. The point source phosphorus tends to have a more dramatic
seasonal eutrophication impact because nearly 100 percent of point source
phosphorus is bioavailable and that it is fed to the receiving waters on a
continual basis. Nonpoint source phosphorus, although substantially less
bioavailable in immediate runoff due to adsorption by particulate matter, is a
long term contributor to eutrophication because it tends to settle in the lake
where it may be resuspended in a bioavailable form.
To investigate the point source versus nonpoint source phosphorus issue,
annual inputs from these sources were compared. The average annual input of
total phosphorus (TP) to Falls Lake is 206 tons/year (USACOE, 1987). Nonpoint
15
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source pollution accounts for 115 tons/year or 56 percent of this total
phosphorous load. Although basin wide strategies are needed to mediate the
total phosphorus load to Falls Lake, point source TP controls appear to be the
most important component required to improve Falls Lake water quality,
particularly in the headwaters section of the Lake. Although nonpoint sources
contribute more than 50 percent of the TP load, the lower degree of
bioavailability associated with nonpoint phosphorus and its infrequent input
(i.e., during storm events) make it potentially less important than point
source controls. When an effluent dominants the flow of a receiving water, as
is the case in Ellerbe Creek during summer base flow conditions, then high
effluent concentrations of bioavailable phosphorus being continuously
discharged will cause eutrophication problems when conditions are right (i.e.,
adequate residence times, adequate sunlight, warm temperatures, and so on).
This fact is the reason that large algal blooms have occurred downstream of
the existing Eno River WWTP and Northside WWTP in the upper lake watershed.
The three treatment facilities that would be consolidated by the
preferred alternative (Eno, Northside, and Little Lick) discharged
approximately 39 tons/year during 1988. With TP effluents of 0.5 mg/L
(April-October) and 2.0 mg/L (November-March), the Northside facility would
discharge 34 tons/year and 50 tons/year respectively at Phase A and Phase B
flow limits of 20 and 29 mgd. It is the recommendation of this EIS that the
TP winter month effluent be lowered from 2.0 mg/L to 1.0 mg/L during Phase B.
This reduction would lower the annual TP load from 50 tons/year to 32
tons/year, which represents a reduction of annual TP loads for both existing
and the Phase A conditions, i.e., 39 and 34 tons/year.
Tables 4-6 and 4-7 present the total nutrient loads projected for the EIS
study area given the two growth scenarios described in Sections 3.3.2.1 and
3.3.2.2. NCDEM (1989) estimated that nonpoint source pollution TN and TP
loads for the Northside and Little Lick Basins would be 128 and 16 tons/year,
which is very similar to the loads projected for the Eno Basin (i.e., 153 and
18 for the moderate growth scenario).
16
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TABLE 4-6
NONPOINT SOURCE LOADING FACTORS
(lb/ac/yr)
Total
Total
Nitrogen
Phosphorus
Land Use.
TN
TP
Rural Residential, R-l
3.0
0.2
Low Density Residential, R-2
6.7
0.8
High Density Residential, R-3
8.8
1.1
Commercial, C-4
13.2
1.6
Industrial, 1-5
11.3
1.4
Office and Research, O/R-6
12.2
1.5
Agricultural, A-7
9.9
2.5
Open Space, 0-8
0.6
0.1
SOURCE: Watershed Management Study, Lake Michie and Little River Reservoir
Watersheds. November, 1988. County of Durham
TABLE 4-7
PROJECTED LAND USE ACRES, NONPOINT, AND POINT SOURCE LOADS
(lb/yr), Year 2010
Land
Low Scenario
Moderate Scenario
Use
Acres
TN
TP
Acres
TN
TP
R-l
19,600
58,800
3,920
19,600
58,800
3,920
R-2
18,800
125,960
15,040
14,900
99,830
11,920
R-3
2,100
18,480
2,310
6,400
56,320
7,040
C-4
700
9,240
1,120
1,100
14,520
1,760
1-5
1,000
11,300
1,400
1,800
20,340
2,520
0/R-6
2,200
26,840
3,300
2,500
30,500
3,750
A-7
1,500
14,850
3,750
1,500
14,850
3,750
0-8
20,800
12,480
1,664
18,900
11,340
1,512
Subtotal
66,700
277,950
32,504
66,700
306,500
36,172
Nonpoint
(tons/yr):
138
16
153
18
Point Source
(tons/yr):
420
20.
740
32
Total
558
38
893
50
NOTE: Acres are for the EIS Study Area, measured from Plates 14 and 15.
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4.3.2 Groundwater Quality & Quantity
The preferred alternative N-EC would have a positive impact to
groundwater quality associated with sewering failing on-lot system areas.
There would be reduced nutrient loads to surface waters, decreased public
health problems, and improved aesthetics. Areas of failing on-lot systems
within the City of Durham defined Urban Growth Area would be provided sewer
service during Phase A of the Preferred Alternative.
4.3.3 Terrestrial Ecosystems
Impacts to terrestrial ecosystems would result from conveyance system
construction. This construction would be a short-term impact involving an
initial right-of-way width clearing of about 80 feet. Impacts also would
include long-term loss of natural vegetation and wildlife habitat from
maintenance of a 20-foot right-of-way. Natural areas identified in Plate 10
that could be impacted in this way include Willie Duke's Bluff, Eno River
Corridor, Little River Corridor, Wanderlust Diabase Uplands, Cabin Branch
Bottomlands, and Cub Creek Greenway. Parks and Greenways that could be
impacted include Willowhaven Country Club, Eno River State Park, Falls Lake
Lands, River Forest Park, and Eno Greenway. Conveyance line routes should be
planned so that they do not adversely impact these natural areas, especially
the Falls Lake Lands used for game lands. Table 4-8 shows significant plants
and animals that were listed by Sutter (1987) as being located within the
natural areas identified in Plate 10. At this time, no U.S. Fish and Wildlife
Service nationally endangered plant or animal species are permanent residents
along the conveyance line locations shown in Plate 5. Several species are
listed as Primary Proposed (PP) or Significantly Rare (SR) in North Carolina
by the Plant Conservation Program. These species are not legally protected at
this time (Sutter, 1987).
4.3.4 Aquatic Ecosystems
Ways in which the preferred alternative could impact aquatic ecosystems
include stream crossings and erosion and sedimentation associated with
conveyance system construction. The preferred alternative would involve the
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Table 4-8
NATURAL AREAS, PARKS AND GREENWAYS, AMD WILDLIFE AREAS
WITH POSSIBLE CONVEYANCE SYSTEM IMPACTS (ALTERNATIVE N-EC)
Significant Plant
Location or Animal Coupon Name
A Atlantic Isopyrum
A, E Douglass's Bittercress
A Dutchman's Breeches
A Ginseng
A Chestnut Oaks
A Shagbark Hickories
A James' Sedge
A Glade Fern
A Ualking Fern
A Banebarry
B,C Roanoke Bass
B,C Carolina Madtom
B Notched Rainbow
B Atlantic Pigtoe
D wild Blue Indigo
E Lewis's Heartleaf
F Red Cedars
Significant Plant or
Animal Scientific Name Status
Isopyrun biternatum SR
Cardamine douglassii SR
Dicentra cucullaria
Panex quinquefolius
Quercus michauxii
Carya ovata
Carex jamesii
Athyriun pycnocarpon
Asplenium rhizophyllun
Actaea pachypoda
Ambloplites cavifrons
Noturus furi osus
Villosa constricta
Fusconaia masoni
Baptisia austral is SR
Hexastylis lewisii PP
Juniperus virginiana
Significance
Plant species of state significance
occurring in rich bottomland forests.
Plant species of state significance
occurring in rich bottomland forests.
Regionally rare plant species
associated with rich slopes and bottom-
lands.
Regionally rare plant on the state's
special concern list.
Uncommon plants found here (Willie
Duke's Bluff).
Rare and threatened species of fish.
Rare and threatened species of fish.
Rare and threatened species of fish.
Rare and threatened species of fish.
Significantly rare species of plant.
State-listed primary proposed plant
species.
Aesthetically important.
Location Key
A Willie Duke's Bluff
B Eno River Corridor
C Little River Corridor
D Wanderlust Diabase
Uplands
E Cabin Branch Bottomlands
f Cub Creek Greenway
PP or SR: Listed as Primary Proposed (PP) or SijjnifIcantly Rare (SR) in North Carolina by the Plant
Conservation Program; species that my become Endangered or Threatened in the near future.
These species are not legally protected.
Source: R. D. Sutter, et al, Inventory of Nature Areas and Rare Species of Durham County, 1987.
19
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Table 4-9
POSSIBLE STREAM CROSSINGS ASSOCIATED
WITH THE N-EC PREFERRED ALTERNATIVE
A. Intermittent or Unnamed Stream
1. Approximately 20 throughout the service area
B. Named Streams
1. Crooked Creek - crossing near confluence with Eno River.
2. Eno River - crossing near old Eno WWTP.
3. Eno River - crossing near Falls Lake.
4. Cabin Branch Creek - crossing near SR1631 (Snow Hill Road).
5. Small reservoir near SR1002 (Mason Road) and Roxboro Road.
6. Little River - crossing between SR1628 (Orange Factory Road) and
Norfolk and Western RR near Fairntosh. Wetlands may preclude the
placement of this stretch of interceptor.
7. Ellerbe Creek - crossing at proposed Northside WWTP.
20
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construction of 12 pump stations, approximately 200,000 feet of conveyance
line, and an estimated 27 stream crossings. Possible stream crossings are
listed in Table 4-9. The number could be reduced by designing line placements
to minimize stream crossings. Fish and amphibians of special concern are
listed in Table 4-8. No aquatic plants or animals within the EIS Study Area
have been listed by the U.S. Fish and Wildlife Service as nationally
endangered.
A direct impact to an aquatic ecosystem outside the EIS Study Area would
occur with the Northside WWTP discharge to the Ellerbe Creek. Biological
sampling conducted by NCDEM between 1979-81 indicates that the Ellerbe Creek
is in poor biological condition. As described in Section 4.3.1, chemical
quality of the Ellerbe Creek is expected to improve with the implementation of
the preferred alternative. Whether the biological quality will improve
depends upon the quality of the wastewater effluent and effects of channel
erosion induced by the increased flow.
4.3.5 Economic fUser Charges)
The economic impact of the preferred alternative would be the cost to
consumers who use the system. Section 4.2.3 describes that under worst case
conditions the annual cost per household would be about $340, which is less
than the 1.75 percent of median family income EPA affordability criterion.
4.3.6 Noise. Odor and Air Quality
The greatest noise and air quality impacts would be associated with
conveyance system construction. These impacts would be short-term, noise and
dust related.
Twelve pump stations would be constructed with the preferred alternative.
Existing residential areas that are nearby proposed pumping stations include
Willowhaven Country Club, Continental Drive, Thunder Road, Dawn Trail,
November Drive, and Riverdale Drive. Specific site placement of pumping
stations should be designed to minimize possible noise impacts in these areas.
Operation of the pump stations would create noise levels that should, on
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average, be untioticeable beyond a distance of 300 to 500 feet. With proper
noise controls, composite transmission loss should be at least 50 dBA.
Built-in noise controls could include double glaze windows, masonry exteriors,
acoustical sealing of doors as well as caulking of building openings including
pipes and vents. In addition to operation noises, there would be traffic
noise and dust from pump station inspections. If pumping facilities are
properly operated and maintained, odors should not be noticeable.
4.3.7 Archaeological and Historical Areas
Archaeological and historical areas are identified in Section 3.3.1.5 and
Plate 12. Archaeological site locations were obtained from the Durham County
Inventory of Critical Lands (TJCOG, 1985). Based on this information,
the Northside wastewater treatment plant expansion site is not on an
historical or archaeological site. However, excavation during the
construction of conveyance lines could permanently destroy archaeological
sites if care is not taken to preserve them. There are eight archaeological
sites in the vicinity of proposed conveyance lines (Table 4-10).
Preconstruction surveys by professional archaeologists should be conducted to
minimize the potential for impacting these sites. Similarly, blasting and
right-of-way acquisition could be conducted to minimize impact on historical
areas and structures.
The conveyance lines may traverse the Bennehan-Cameron Plantation
District, which is listed on the National Register. Another historic
structure, West Point Hill, is in the immediate vicinity of the conveyance
line proposed for the preferred alternative. To minimize the impacts on these
sites, the conveyance line locations should be altered or mitigative measures
used to enhance preservation during construction. Cemeteries nearby proposed
conveyance system locations (Table 4-10) should be avoided during planning and
design.
4.3.8 Recreation
The preferred alternative has two possible impacts to recreation areas:
direct impacts associated with conveyance line construction and secondary
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Table 4-10
POSSIBLE CONVEYANCE SYSTEM IMPACT TO
CULTURAL RESOURCE SITE BY ALTERNATIVE N-EC
Site Name
A. Archaeological Sites
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
B. Historical Sites
Benneham-Cameron
Plantation District
(National Register)
C. Old Mill Sites
West Point Mill
Semnett's Mill
Locations-
Northeast of Eno River
Wastewater Treatment Plan
(two sites).
Rose of Sharon Church.
Junction of Cabin Branch
and Snow Hill Road.
East Side of Little River
Between Snow Hill Road and
Oxford Highway, south of
Little River Reservoir.
Adjacent to Old Oxford
Highway and below Fairntosh.
Along Eno River west of the
Wastewater Treatment Plant
on Rippling Stream Road.
Junction of Cabin Branch and
Snow Hill Road.
North of Weaver (two sites).
Norfolk and Western Railroad
at Treyburn; between Snow
Hill Road and Oxford Highways.
Eno River and Crooked Creek
Confluence.
Eno River near State Prison.
Description
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
Plantation; house
in Georgian style;
collection of
outbuildings.
Textile mill used
to produce cotton.
Textile mill used
to produce cotton.
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TABLE 4-10 (Cont'd.)
POSSIBLE CONVEYANCE SYSTEM IMPACT TO
CULTURAL RESOURCE SITE BY ALTERNATIVE N-EC
D. Cemeteries
N.A. Norfolk and Western Railroad N.A.
at Treyburn near Benneham-
Caraeron Plantation District.
N.A. Old Oxford Road south of N.A.
Stageville Road and north of
Snow Hill Road.
N.A. West of Carrington Jr. High. N.A.
1 Sites within 1,000 feet of proposed conveyance system components.
N.A. - Not available.
24
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impacts associated with population growth. A conveyance line map (Plate 5)
was compared to the recreation area map (Plate 10) to assess direct impacts.
Table 4-11 lists recreation areas that could be directly impacted by
conveyance line construction. Impacts would primarily be short-term, and
include erosion, noise and dust. In addition to the sites listed in Table
4-11, the Northside Wastewater Treatment Plant is adjacent to the proposed
route for the Ellerbe Creek Greenway. Long-term impacts, such as noise, dust,
and odors associated with plant operation, to this proposed recreation area
can be minimized with good plant management.
It appears from Table 4-12 that the Durham Study Area has sufficient
acreage of recreational areas to support an increase in population brought on
by the advent of public sewer. However, the areas will require improvements
and more frequent maintenance to handle increased use. Much of the
recreational area is contained in the Eno River State Park which may receive
heavy use from outside the study area.
Although the present park system acreage is currently more than
sufficient for the Durham area, it is important to maintain the park acreage
to population ratio. Therefore, as the population of the Durham area
increases, the amount of land dedicated to parks and open space should also
increase proportionately. Land should be acquired by the County through
fee-simple purchase or the dedication of land by developers as development
occurs.
4.3.9 Transportation
The population growth resulting from expanded wastewater facilities will
generate additional traffic and create demands for an improved roadway system.
Proposed transportation system expansions are described in the thoroughfare
plan for the Durham-Chapel Hill-Carboro (D-CH-C) Urban Area, a planning
document delineating transportation facilities to satisfy projected needs.
This document was prepared by the Transportation Study Group of the D-CH-C
Urban Area with assistance by the NC Department of Transportation. The plan
was reviewed during February and March 1988 and a Public Comment and Final
Recommendations Report No. 3 was issued in March 8, 1989. Several short-term
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Table 4-11
Recreation Areas Impacted by Northside Wastewater Treatment Plant
and Its Conveyance System-'-
Site Name
Eno River State Park
Falls Lake Lands
Eno Greenway
River Forest Park
Location
Along Eno River
Surrounding Falls
Lake
N. Roxboro Road
N. A.
Description Acreage
State-owned; hiking 1007.0
trails; boat ramp.
Owned by U.S. Army
Corps of Engineers;
national area.
City-owned, hiking 27.0
and jogging trails.
State-owned; hiking N.A.
trails.
1 Impacted sites defined as those within 1,000 feet of proposed conveyance
system components.
Table 4-12
Recreation Acreage
Year Population National Standard for Urban Park
1985 32,700 5.0 acres/1,000 population
1995 47,400 5.0 acres/1,000 population
2010 85,300 5.0 acres/1,000 population
Park Acres
163.5 need
1,325.0 have
237.0 need
426.0 need
Source: Urban Planning and Design Criteria, Joseph De Chiara and Lee
Koppelman, 1982.
26
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impacts that would be associated with thoroughfare construction are noise,
dust, erosion, and loss of habitat. Stream crossing would represent the major
impact to the natural environment. Long-term impacts would also be associated
with new thoroughfares. Adjacent homes would experience higher noise levels
and carbon monoxide (CO) gas from vehicle exhaust.
Roadways proposed by the thoroughfare plan would cross the Water Quality
Basin Area; an area in which density controls are needed to control nonpoint
source pollution. More roadways ultimately threaten watershed quality if
rigorous nonpoint source runoff controls are not employed. A transportation
EIS should be prepared for any transportation expansions that would lead to
additional growth in the Water Quality Basin Area.
4.3.10 Communitv Services
Population increases projected during the planning period will
necessitate additional fire, police, ambulance, school, and health care
facilities and services. Failure to maintain or increase the existing
facilities and service will result in a decreased standard of living in the
area.
Projected fire protection needs are typically based on the number of
firemen per 1,000 persons and water availability. However, the actual needs
are based on the density, height and age of buildings, and the use and
effectiveness of fire protection codes. The actual needs should be determined
by the individual fire companies and these needs should be supported by local
citizens and government. Table 3-20, presented in Section 3.3.2.5, provides a
general indication of future needs for fire protection.
Similarly, the adequacy of police protection is typically evaluated by
the number of officers per 1,000 persons. Police service needs are,
therefore, directly related to population increases, but are also impacted by
the amount of commercial development and local crime rates. A preliminary
projection of the number of officers that will be required over the next 20
years is given in Table 3-20.
27
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Ambulance and health care service needs are tied to the number of people
in an area and the age of the population. Table 3-10, presented in Section
3.2.2, contains a projection for the number of hospital beds that will be
needed through the planning period. Ambulance service needs are best
projected by local persons. More detailed population analysis is needed to
make a more detailed estimation of future needs in this area.
Educational facility requirements are set by population levels and
composition and local policies on class size. Table 3-20 includes estimates
on the number of children in the various school age groups. The number of
classrooms, sizes of libraries, and other facilities needed to service these
children should be determined by local school district policymakers.
4.3.11 Summary
A summary of impacts associated with the preferred alternative is given
in Table 4-13. There are 29 impacts, 19 of which require mitigation. This
table provides a description of the impacts and a course of mitigation
associated with each impact. These descriptions are generalized. However, it
should be noted that some impacts will be significantly easier to mitigate
than others.
4.4 MITIGATIVE MEASURES
One of the major issues involved with this EIS has been nonpoint source
pollution. Nonpoint source pollution would be a basin-wide secondary impact
associated with population growth and land development resulting from the
provision of a larger wastewater treatment facility, Nonpoint sources
currently contribute 56 percent of the total phosphorus load to Falls Lake.
This loading could increase with future population growth, if controls are not
used to reduce nonpoint source pollution. Nonpoint source pollution controls
are commonly referred to as Best Management Practices (BMP's). Table 4-14
lists existing BMP s for the EIS study area. The ordinances requiring these
BMP's need strict enforcement to ensure BMP effectiveness. Structural BMP's
require maintenance to further ensure effectiveness. In addition, the
28
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TABLE 4-13
IMPACTS OF THE PREFERRED ALTERNATIVE
Type of Impact
Surface Water
Activity
Impact
Eliminate Eno River
a.
Improved water quality.
a.
discharge.
b.
Higher dissolved oxygen
b.
c.
Fewer algal blooms.
c.
d.
Reduced flow during low
flow conditions.
d.
Mitigation
None required.
Hone required.
None required.
At upstream loca-
tions reduce
withdraws and
increase flow
augmentation.
Increase Ellerbe a.
Creek discharge to b.
30 mgd. TP effluent
limit - 0.5 mg/L c.
(April-October) d.
Lower instreani TP conc.
Increase flow during low
flow conditions.
Improved water quality.
Possible toxicity and
chlorophyll-a impairment
in Ellerbe Creek/Falls
Lake.
a. None requi red.
b. None requi red.
c.
d.
None required.
Continue stream
monitoring
Groundwater
3. Continued TP loadings
to Falls Lake.
1. Provide sewer service
to failing septic tank
areas.
a. Continued violations of
chlorophyll-a standard.
Reduce NO3 and pathogen
contamination.
Terrestrial Ecosystems 1. Construction of sewage a. Loss of natural vegeta-
cortveyance system. tion along right-of-ways.
Aquatic Ecosystems
2.
Erosion and sedimenta-
tion during construe-
tion of conveyance
system.
Transfer WW discharge
from Eno River to
Ellerbe Creek.
Short-term adverse impact
to aquatic ecosystem.
a.
Improve biological
quality of the Eno River.
Potential improvement of
Ellerbe Creek biological
quality.
a. Nonpoint source
controls. Phos-
phate detergent
ban.
a. None required.
a. Use already
cleared areas.
Minimized right-of-
way width.
a. Best management
practices. Site
inspections and
line placement to
minimize stream
crossings.
a. None required.
b. None required.
3. Excavation during
stream crossings.
a. Disruption of aquatic
life and habitat.
a. Erosion and sedi-
mentation controls.
Stream encroachment
permit.
29
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TABLE 4-13 (Cont'd.)
IMPACTS OF THE PREFERRED ALTERNATIVE
Type of Impact
Economics
Activity
1. Cost of wastewater
treatment.
Impact
Estimated annual user
costs would be $340 per
household (see Table 4-5).
Mitigation
a. None - unavoidable
impact.
Noise, Odor and
Ai r Quality
1. Construction of sewage
conveyance lines.
a. Short-term construction
noise and dust.
Temporary noise
barriers. Limit
construction to
normal working
hours.
2. Operation of pump
stations
a. Low level, localized noise. a.
Acoustically
design punp
stations.
Nonpoint Source
Pollution
Archaeological
Sites
Historic Areas
3. Emergency generator
operation at pump
stations.
1. Agricultural and
urban runoff
1. Conveyance line
construction
Conveyance tine
construction
2.
Secondary population
growth
a. Loud noise (93-104 dBA)
during operation.
a. Increased loads of nutrients, a.
heavy metals, and toxics.
Impacts from excavation
near the 8 sites identified
in Table 4-9.
Possible impacts to
Bemeham-Cameron Plantation
District and West Point
Mill.
Increased visitation and
possible vandalism through-
out study area.
Acoustically
design generator
placement. Limit
maintenance to
daytime hours.
Structural Best
Management
Practices and Land
Use Controls.
Preconstruction
survey by profes-
sional archaeolo-
gist to assess
possible impacts.
Reroute proposed
interceptor corri-
dors. Use protec-
tive barrier,
mechanical (rather
than blasting)
rock removal.
Minimize vegetation
removal.
a. More frequent main-
tenance, zoning of
surrounding areas.
30
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TABLE 4-13 (Cont'd.)
IMPACTS OF THE PREFERRED ALTERNATIVE
Type of Impact
Recreation Areas
Activity
1. Conveyance line
construction
2. Secondary population
growth
Impact
Construction impacts near
Eno State Park, Falls Lake
Lands, Eno Greenway and
River Forest Park.
Increased visitation and
possible vandalism through-
out study area.
Mitigation
Use already
cleared land.
Minimize vegeta-
tion removal.
Use corridors for
trails. Use
noise and dust
controls.
More frequent
maintenance,
zoning of sur-
rounding areas.
Maintain acreage -
population ratio
for recreation
facilities.
Transportation
Comnunity Services
1. Road construction
2. Increased traffic
1. Secondary population
growth
a. construction related delays
and detours.
a. Additional traffic and
congestion.
b. increased noise, vehicle
fumes, and potential for
spills.
a. Additional demand for
services and facilities.
a. Plan traffic and
pedestrian control.
a. Improve current
roadways and build
new roadways.
b. Improve traffic
movement in the
study area.
a. Increase personnel
and facilities to
meet demand.
31
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following recommendations should be instituted to mitigate nonpoint source
pollution impacts associated with the preferred alternative:
o An emphasis should be placed on the nonstructural land use control
BMP's as well as structural BMP's because they have a lower risk of
failure and do not require maintenance.
o Within the EIS Study Area and northern Durham County, the one lot per
two acres and 6 percent impervious cover ceiling should be extended to
include not only the WQCA, but also the WQBA.
o The Durham County and City Sedimentation and Erosion Ordinance should
evaluate its present enforcement program and enhance existing programs
as are needed.
o The multi-county coordination committee proposed by the County of
Durham (1988) should be formed to handle regional coordination of
watershed and nonpoint source pollution issues.
o In the Little River Reservoir and Lake Michie watersheds,
consideration should be given to upgrading the WQBA and WQCA from a
WS-III to a WS-II or WS-I classification. This stricter designation
would reinforce local nonpoint source control programs.
Two impacts shown in Table 4-13 involve water quality impairment by the
wastewater discharge. One is possible toxicity in Ellerbe Creek as a result
of the stream being 90-95 percent wastewater during low flow conditions. The
other is a continuation of chlorophyll-a violations in Falls Lake as a result
of TP loads. Mitigation of these impacts cannot be achieved by stricter
effluent limits because limit-of-technology TP effluent limits are proposed
for the preferred alternative. The following mitigation is recommended for
water quality impacts:
32
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TABLE 4-14
EXISTING BEST MANAGEMENT PRACTICES WITHIN THE EIS STUDY AREA
Ordinance/Program
Durham County and City
Watershed Ordinances
Type of BMP
Nons true tural
Structural
Durham County and City
Sedimentation and
Erosion Control
Ordinance
Structural
Description
1. One lot per 2 acres (6%
impervious cover) in Water
Quality Critical Area.
2. One lot per acre (15%
impervious cover) in Water
Quality Basin Area.
3. Other land use restrictions,
e.g., no industry within the
WQCA.
1. Infiltration trenches,
detention basins, and open
space for infiltration. (In
addition to the nonstructural
BMP's.)
1. For land disturbing
activities:
o silt fence curtains
o buffer zones
o graded slopes
o detention basins
North Carolina Cost
Share Program
Agricultural
1. List of practices include:
o conservation tillage
o diversions
o filter strips
o sediment basins
o agricultural waste
structures
o strip cropping
33
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Impact
Mitigation
1. Erosion of Ellerbe Creek
1. Bank Stabilization.
2. Toxicity of Northside
Discharge
2. Industrial Pretreatment.
Effluent Monitoring.
3. Total Phosphorus Loads
to Ellerbe Creek and
Falls Lake
3. State-of-the-art Removal.
Water Quality Modeling/
Monitoring. Nonpoint Source
Controls.
If violations of the chlorophyll-a standard continue and it Is determined that
the discharge is a significant contribution to these violations, NCDEM should
pursue a variance or similar arrangement until proper improvements can be
made.
Another preferred alternative impact is noise related resulting from pump
station operation. A specific location away from the nearest noise sensitive
receptor should be planned for each pump station. In addition, it is
recommended that noise mitigation strategies be prepared as part of the pump
station designs. Typical criteria for such strategies are that 55 dBA daytime
and 45 dBA nighttime noise levels be achieved at the pump station property
line. Wherever impacts are possible, a noise mitigation specialist should be
consulted to ensure proper acoustical design.
Additional impacts for the preferred alternative (Table 4-13) are related
to conveyance line construction. Noise and dust, short-term in nature, should
be mitigated by limiting construction to normal daytime work hours and using
noise barriers where necessary. Other construction impacts could affect
aquatic and terrestrial ecosystems. Specific resources that may be impacted
have been identified in Sections 4.3.4 and 4.3.3. NCDEM will require an
assessment on the potential for impact to rare and endangered plants and
animals, and will require coordination with appropriate state agencies to
determine the extent of those surveys. The type and magnitude of mitigative
measures required to protect a specific resource vary widely, depending upon
the value of the resource and the expected impact. Three degrees of
mitigation and corresponding potential mitigation measures are presented in
Table 4-15. One concern is a number of possible stream crossings (Table 4-9)
34
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TABLE 4-15
GENERAL MITIGATIVE MEASURES FOR INTERCEPTOR CONSTRUCTION
Degree of
Mitigation Potential Miti^ative Measures
High Completely re-route interceptor construction in specific areas
to avoid impacting resource.
Go ahead with construction: re-establish resources elsewhere.
Go ahead with construction: restore resource to original
condition.
Seek expert guidance in planning and construction of corridors.
Moderate Re-route interceptor slightly so as not to disturb resource.
Re-establish topographic contours after construction and
replant vegetation.
Time construction to minimize some adverse impacts.
Establish environmentally sound construction techniques to
mitigate soil losses, habitat losses, and visual intrusions
during and after construction.
Confine construction to previously disturbed areas if possible.
Route construction outside of dripline of major trees.
Locate interceptor out of streambeds; do not interfere with
stream flow or wetland processes.
Low Practice environmentally sound construction and backfill
techniques to reduce soil subsidence and erosion.
Practice restorative post-construction techniques and
maintenance of corridors.
35
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and impacts that may occur in floodplain and wetland areas. The following
mitigation measures should be applied:
o F1oodolains. Pump stations that must be placed in the floodplain are
unavoidable impacts. Such locations will require flood protection,
presumably levees, which will reduce the floodplain area. It is
recommended that sites contained within levees be kept as small as
possible to minimize the loss of floodplain.
o Wetlands. Wetlands may be encountered along stream corridors.
Construction in wetlands requires a permit from the U.S Army Corps of
Engineers, as authorized by Section 404 of the Clean Water Act.
Wetland impacts can be minimized through use of carefully controlled
construction techniques and by the development of artificial wetlands
to replace natural areas destroyed by construction.
Increased demands for recreational facilities and services should be met
through a combination of public and private funds. An increasing number of
recreational facilities are being developed by developers and maintained
through homeowners associations. This is an effective method of providing
localized recreational facilities without using public funds. Larger
facilities are more likely to require public funding.
Construction impacts on the transportation system can be mitigated
through the measures listed in Table 4-15 and by scheduling construction as
much as possible during non-peak traffic hours. Excessive noise in
residential areas can be mitigated through highway grading and structural
noise barriers. Statistical analysis of spill probabilities associated with
vehicular accidents determined that the likelihood of toxic chemical release
to Falls Lake Watershed is extremely remote. It is recommended that Durham
County investigate the use of roadside detention facilities to reduce impacts
of spills on water supply in their region. Traffic congestion mitigation
requires adequate projection of future traffic levels, planned roadway
expansion, and new road construction.
36
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Increased demands on community services are best met through the addition
of staff and facilities. Preliminary projections for staffing requirements
are provided in Table 3-20. Some staffing requirements and facility
development costs can be offset through cooperation with private developers,
as discussed in Section 4.3.
EPA-funded projects are subject to the requirements of Section 106 of the
National Historic Preservation Act of 1966, the Archaeological and Historic
Preservation Act of 1974, Executive Order 11593, and regulations of the
Advisory Council on Historic Preservation (36 CFR Part 800). In essence,
these laws and regulations require mitigation of impacts to historic or
archaeological sites on, or eligible for, the National Register of Historic
Sites. Mitigation would involve certification from the Division of Archives
and History that the construction will not affect any known archaeological or
historic sites on or eligible for the National Register.
37
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Comment Letters and EPA Responses
to Comments on the Draft EIS
-------
Letters Requiring a Response
R-JC-1 Jim Clark - Save the Water!
R-GA-1 George Andrews - Durham County Resident
R-TR-1 A. Terry Rolan, Director - City of Durham, Department of Water
Resources
R-SC-1 Ed Harrison - Sierra Club, Land Use Chair
R-SC-2 David Howells - Sierra Club, Water Quality Chair
R-KH-1 Kenneth Holt, Environmental Health Scientist, Center for
Disease Control
R-JL-1 James Lee, Regional Environmental Officer, U.S. Department of
the Interior
R-CJ-1 Chester Jenkins, Mayor, City of Durham
R-CD-1 City of Durham, Department of Water Resources
R-LS-1 Lawrence Saunders, Chief, Planning Division, Department of the
Army
R-DB-1 David Brook, Deputy State Historic Preservation Officer
R-BDV-1 W. Boyd DeVane - North Carolina Division of Environmental
Management, Department of Environment, Health, and Natural
Resources
R-RH-1 Richard Hamilton, Assistant Director, North Carolina Wildlife
Resources Commission
R-CT-1 Carol Tingley, North Carolina Department of Environment,
Health, and Natural Resources, Division of Parks and
Recreation
R-ST-1 Steve Tedder, Chief, Water Quality Section, Division of
Environmental Management, Department of Environment, Health
and Natural Resources
R-l
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R-JC-1
SAVE THE WATER!
We all need clean, safe and pure water to drink
Official Comments
to the
JimClaik United States Environmental Protection Agency
President and the
North Carolina Division of Environmental Management
on the
Draft EIS, Durham-Eno River Sewage Plant
presented at the Public Hearing
February 20, 1990
Good evening... I'm Jim Clark, President of Save The Water
and a candidate for Durham County Cotnmis s ioner. I am also
speaking this evening as a member of the EPA Advisory and Over-
sight Committee that has been meeting over the past two years
to help prepare this landmark environmental study. On behalf
of Save The Water, I first called for this critically important
Environmental Impact Statement in July of 1985. In December of
1986 we finally persuaded the state Division of Environmental
Management to begin this required study under the North Carolina
Environmental Policy Act and then engaged the U.S. Environmental
Protection Agency to join the study under the National Environ-
mental Policy Act in 1987. The Durham community is fortunate to
have this comprehensive environmental study to protect our vital
drinking water supplies and we want to thank Mr. Bob Lord at EPA
for arranging the study and Mr. John Hamilton at EPA and Mr.
Trevor Clements at the State for their hard work on this EIS.
The good news is that this environmental study has averted
a major environmental mistake... the proposed expansion of the
Eno River sewage plant. Because of this study, the Eno River sewage
plant will be closed and removed. That is a major victory for
everyone who has worked so hard over the past five years to protect
the drinking water supplies for Duham and Raleigh. It is now clear
that if we had not been involved and successfully initiated this
study, the Eno River sewage plant would have been expanded and
precious drinking water would have been pollute^.
The bad news is the study shows that there is no really good,
ecologically safe- alternative and that even the " Preferred
Alternative " has major environmental problems.
We support the consolidation of the Eno River, Little Lick
and Treyburn sewage plants into the Northside sewage treatment plant
Post Office Box 15795, Durham, North Carolina 27704
R-2
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but we are very concerned about the continued pollution of Ellerbee
Creek and Falls Lake which is, of course, the sole source of drinking
water for the city of Raleigh.
This environmental study shows that Ellerbee Creek has been
assigned a " poor biological rating, " and that during low flow
conditions Ellerbee Creek could suffer " possible toxicity as a
result of the stream being 90% - 95% wastewater. " Already
Ellerbee Creek is officially listed as an " Impaired Water "
under the Clean Water Act and the city is supposed to have an
effective strategy to clean the creek up. It is rather ironic
that the city's clean up strategy includes dumping three times
more wastewater than Ellerbee Ceek now receives. We are also
very concerned about the prediction by the State that water
quality violations will probably still occur even after the
new, state of the art sewage treatment plant is built.
Save The Water is also very concerned about the potential
disposal and environmental problems from the sludge that will
be generated by the new sewage plant. At least 5,400 dry tons
of sludge is supposed to be spread on 1,080 acres of land but
that assumes that the sludge will not have high concentrations
of toxics and heavy metals and that over a thousand acres of
land can be found nearby for sludge disposal. Land is scarce
in Durham County and officials in Orange County have already
moved to block disposal there so sludge disposal is definitely
a serious problem. We request that more study be given to
this problem and a specific solution be identified along with
potential costs before Durham proceeds with any new sewage plants.
A8 you know, Save The Water has consistently been very
concerned with two key neighborhood and citizen issues. The
first is establishing as permanent policy that all of the
city and county neighborhoods with failing septic tanks be
served first as the highest priority for new treatment capacity,
and that all of the neighborhoods be sewered before any new
developments squeeze them out once again. From last week's
Advisory Committee meeting we understand this to be the EPA
recommendation as well. It just makes sense to solve the
existing environmental problem we have with failing septic tanks
first before giving very precious treatment capacity to new
development.
The second citizen concern we have is the projected " rate
shock " or the doubling or tripling of water and sewer rates
to help pay for the sewage plant expansion. We are strongly
opposed to putting the burden for new growth on the backs of
Durham's citizens with a doubling or a tripling of water and
sewer rates. That's not fair.. .that's not right so we ask the
City to find other ways to finance the proposed improvements
without any " rate shock ".
It was the consensus of the Advisory and Oversight Committee
that in view of the potential ecological problems associated with
R-3
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CONT'D
the expansion of the Northside sewage plant that a permit and
expansion be considered only up to 20 mgd. After the new sewage
plant was fully functioning any additional proposals for plant
expansions would require additional study of the effluent from
the new plant and the condition of Ellerbee Creek and another
state permit before any further expansion could take place.
We ask EPA, the state DEM and the City to honor that
consensus. Because of our concern about the continued pollution
of Ellerbee Creek, we must strongly oppose any combined or
provisional permit for an expansion of Northside to 29 mgd. We
do not believe that Ellerbee Creek can possibly assimilate that
much wastewater and the jury is still out as far as this EIS is
concerned so no expansion beyond 20 mgd can be permitted at this
t ime .
We also stongly request that the proposed Eno River pump
station be limited to not more than 8 mgd. And we ask the EPA,
the state DEM and the city to agree to hold the Treyburn
developers to their promise to close the Treyburn sewage plant
when the new Northside plant comes on line. Treyburn promised
that their sewage plant was an interim solution until the new
public sewage plant was built and that they would close it as
soon as new capacity was available and we ask you to hold them
to that important public commitment.
One other crucial fact that has emerged from this EIS is
on page 3-42. " The Snow Hill Diabase Glade which is located
at the junction of Snow Hill Road and Old Oxford Highway has
more rare species than any other site in the Piedmont of North
Carolina. The Smooth Coneflower and Tall Larkspur are found
in the Snow Hill Diabase Glade. " This fact is so critically
important because the proposed Outer Loop would go right
through the Snow Hill Diabase Glade and with the Endangered
Species Act and other key envionmental laws there is no chance
the Outer Loop could pass the EIS process and damage such an
ecologically special and valuable area so it is time for
the city and county to abandon any plans for the drinking water
polluting outer loop.
Once again, this EIS clearly points out that even the
" Preferred Alternative " has serious environmental problems
including the impacts on Ellerbee Creek, the 27 stream crossings
of the 38 miles of new sewer lines and the 12 pump stations that
would be constructed. The EIS shows natural areas that would be
negatively impacted as well as valuable archaeological and hist
sites that would be damaged and impacted. Even under best case°riC
there will be erosion and sedimentation pollution and substant'
nonpoint source water pollution from the new growth stimulated *
by the proposed sewage plant expansion.
We request that both the EPA and the state Division of
Environmental Management require the most stringent mitisati
measures possible to minimize the environmental damage. 00
R-4
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As the EIS points out, Falls Lake is already highly
eutrophic with more than half of the phosphorus pollution
coming from storm water runoff or non point source pollution.
We can't afford to make any more mistakes when it comes to
protecting our drinking water supplies.
Save The Water applauds the EPA and the state for
strongly recommending needed improvements to our local
watershed protection ordinances including a recommendation
for WS-I watershed classification and protection and a
6% impervious surface limitation.
Natually, the members of Save The Water are very
reluctant to accept the substantial environmental damage that
the Northside sewage plant expansion would cause. In conclusion,
we ask that the proposed sewage plant expansion be appoved
only if:
1. The permit limits the expansion to the agreed 20 mgd.
2. The Eno River pump station is limited to 8 mgd.
3. The Eno River Sewage Plant, the Little Lick Sewage
Plant and the Treybun Sewage Plant are closed and
removed as promised.
4. The first new treatment capacity, and all necessary
treatment capacity is allocated and reserved as the
highest priority for complete sewer service to all
of the neighbohoods with failing septic tanks.
5. There is no unfair water and sewer " rate shock "
that doubles or triples water and sewer rates.
We ask you to incorporate our requests into your final
recommendations in the Final EIS.
We ask that our comments and all public, state and federal
comments be included in the Final Environmental Impact
Statement and that the public be given one more opportunity
to comment on this vital environmental study in a Final Public
Hearing after the Final EIS is published.
As you know, we are making extremely important long range
decisions with very high environmental stakes. Mistakes could
pollute our drinking water so we ask both EPA and the state
Division of Environmental Management to incorporate our comments
into the final decisions as you follow through on the rest of
this vital Environmental Impact Statement decision making
process.
Thanks again for helping us save our drinking water.
,S incer el y,
\^im Clark
'0re8 ident
R-5
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Letter R-JC-1
Final EIS
Jim Clark
Save the Water!
Section 3.3 of the Draft EIS discusses the environmental impacts of all
the alternatives, while Section 4.3 discusses the environmental impacts
of the Preferred Alternative. Table 4-13 lists the environmental impacts
q£¦ the Preferred Alternative and potential mitigation measures. Most of
the impacts from the preferred alternative can be mitigated. Further-
more, many areas that have failing septic systems that threaten public
health will now be connected to the public sewer system. The wastewater
flows from the basin will be conveyed to the new and expanded Northside
Plant with discharge to Ellerbe Creek. Stream conditions in Ellerbe
Creek may actually improve and a monitoring program will be put into
place to review the impacts of increased wastewater discharges into this
stream.
Biological sampling conducted by NCDEM between 1979-81 indicates that
Ellerbe Creek is in poor biological condition. As described In Section
4.3.1 of the Draft EIS, chemical quality of the Ellerbe Creek is expected
to improve with the implementation of the preferred alternative. Whether
the biological quality will improve depends upon the quality of the
wastewater effluent and effects of channel erosion induced by the
increased flow.
With the preferred alternative (Section 4.3), Ellerbe Creek would receive
significantly higher treated effluent compared to the existing Northside
WWTP discharge. The 29 mgd expansion is estimated to reduce BOD loads
from 259 tons/year to 228 tons/year and NH3-N loads would be reduced from
173 tons/year to 46 tons/year (NCDEM, 1989). The preferred alternative
would have a beneficial effect on water quality because of these pol-
lutant load reductions and because the increased volume of discharge
should cause greater reaeration in Ellerbe Creek. In spite of these
expected improvements to Ellerbe Creek water quality, NCDEM modeling
still indicates that instream dissolved oxygen (DO) levels may fall below
R-6
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Letter R-JC-1
Final EIS
Jim Clark
Save the Water!
the 5.0 mg/L minimum daily average standard. However, the modeling
predicts that these low DO conditions are expected to be much less severe
and less frequent than existing DO conditions. Following implementation
of Phase A, Ellerbe Creek water quality monitoring and modeling would be
conducted to reduce the uncertainty in these modeling predictions and to
document the necessary effluent limits for Phase B.
3. Since the quality of Durham's sludge is expected to remain relatively
free of metal and toxic contaminants and agricultural land is readily
available, Durham's sludge will be applied to farmland for agricultural
utilization. As such, the sludge will serve as a soil supplement
supplying nutrients needed for crop growth. The NCDEM has a positive
approach toward sludge disposal by land application. Their permitting
requirements include soil, crop, and sludge analyses and evaluations.
Sludge can be land applied to either dedicated or nondedicated sites.
For the purpose of this EIS, it was assumed that sludge from all of the
wastewater management alternatives would be land applied to nondedicated
sites at agronomic rates.
Respectively, about 5,400 and 8,400 dry tons per year of sewage sludge
would be generated by the Phase A, 20 mgd and the Phase B, 29 mgd flows
of the preferred alternative. About 1,080 and 1,680 acres,, respectively,
would be required to land apply this sludge at agronomic rates. The City
of Durham is considering land application for sludge disposal. As part
of this process, a contractor contacted farmers and estimated that 1,200
to 1,500 acres of agricultural land would be available for sludge appli-
cation (Personal Communication with City of Durham Department of Water
Resources, July 1989). The City of Durham is initiating a Comprehensive
Sludge Management Study to further evaluate options for sludge disposal.
Under the preferred alternative, all users of the expanded Northside WWTP
would pay the same rate except that county residents would continue to
R-7
-------
Letter R-JC-1
Final EIS
Jim Clark
Save the Water!
pay twice the rate of city residents. User charges would be based on
cost per 100 cubic feet of wastewater generated. The generation rate is
assumed to be equivalent to the rate of water usage as measured by the
user's water meter. However, in cases in which wastewater meters are
installed, the sewer charge would be based on the sewage meter reading.
The economic impact of the preferred alternative would be the cost to
consumers who use the system. Section 4.2.3 of the Draft EIS describes
that under' worst case conditions the annual cost per household would be
about $340, which is less than the 1.75 percent of median family income
EPA affordability criterion (4.3.5).
The rates proposed in the Draft EIS are for planning purposes only and
could be higher or lower. However, it is important to note that rates
will be based upon actual usage of the system. Those who use it will be
charged accordingly.
5. Both NCDEM and the City of Durham have indicated they would conduct
extensive monitoring in Ellerbe Creek after the''fJorthside Plant is
expanded to 20 mgd. This monitoring would provide information to assess
the impacts on Ellerbe Creek and assist in determining if the stream can
absorb the further impacts of expanding the Northside Plant from 20 to 29
mgd. It is not expected that the Northside Plant would be expanded to 29
mgd until these impacts are fully assessed by the monitoring program.
6. Toxicity in Ellerbe Creek is possible as a result of the stream being
90-95 percent wastewater during low flow conditions. Another possibility
is a continuation of chlorophyll-a violations in Falls Lake may occur as
a result of TP loads. Mitigation of these impacts cannot be achieved by
stricter effluent limits because limit-of-technology TP effluent limits
are proposed for the preferred alternative. If violations of the
R-8
-------
Letter R-JC-1
Final EIS
Jim Clark
Save the Water!
chlorophyll-a standard continue and it is determined that the discharge
is a significant contribution to these violations, the City of Durham may
want to pursue a variance or similar arrangement until proper
improvements can be made.
For the Ellerbe Creek preferred alternative, N-EC, applying more
stringent effluent limitations to the Durham Northside wastewater
treatment plant would improve Ellerbe Creek TN and TP conditions.
Increasing the plant flow to 20 mgd from the existing average flow of 6.1
mgd is expected to have a beneficial flow augmentation effect. The
increased flow would shorten the travel time necessary for the Northside
wastewater effluent to flow through Ellerbe Creek into Falls Lake, which
would decrease the likelihood of DO and chlorophyll-a violations. In
spite of these expected improvements to Ellerbe Creek water quality,
NCDEM modeling still indicates that DO standard violations are possible.
Although modeling predicts that violations, if they occur, would be less
severe and less extensive than existing violations.
The Preferred Alternative proposes 12 mgd of flow from both the Eno River
Basin and Treyburn. The 12 mgd is based upon a moderate growth scenario
that projects population and wastewater flows to the year 2010.
Therefore, the 12 mgd provides for some growth and expansion in the Eno
River Basin.
Eno River Service Area (mgd)
Eno Basin - 9.036 mgd
Treyburn Basin - 2.928 mgd
11.964 mgd or 12 mgd
-------
Letter R-JC-1
Final EIS
Jim Clark
Save the Water!
Environmental impacts are discussed in Response No. 1, R-JC-1. The
number of possible stream crossings could be reduced by designing line
placements that minimize stream crossings.
In regard to archaeological and historical impact, EPA-funded projects
are subject to the requirements of Section 106 of the National Historic
Preservation Act of 1966, the Archaeological and Historic Preservation
Act of 1974, Executive Order 11593, and regulations of the Advisory
Council on Historic Preservation (36 CFR Part 800). In essence, these
laws and regulations require mitigation of impacts to historic or
archaeological sites on, or eligible for, the National Register of
Historic Sites. Mitigation would involve certification from the Division
of Archives and History that the construction will not affect any known
archaeological or historic sites on or eligible for the National
Register.
(1) Phase A of the Preferred Alternative limits the wastewater plant to
20 mgd.
(2) The Eno River pump station will be designed for 12 mgd to accommo-
date projected flows to 2010. Lower capacity would simply result in
another costly expansion by the year 2000 (see Table 4-13 in Chapter
4 of the Draft EIS).
(3) It is anticipated that the Eno River, Little Lick and Treyburn
Sewage Treatment Plants will be taken out of service once their
flows are conveyed to the expanded Northside treatment plant.
R-10
-------
Letter R-JC-1
Final EIS
Jim Clark
Save the Water!
(4) Those areas that have failing septic systems will be serviced by the
expanded collection system and hopefully the real problem areas can
be targeted for early service.
(5) Rates quoted in the Draft EIS are for planning purposes only.
Actual rates could be higher or lower.
All comments made in the Draft EIS are incorporated in this Final EIS
along with responses to pertinent comments.
R-ll
-------
R-GA-1
February 20, 1990
Prepared statement for the EPA staff at public hearing of the
above mentioned date, regarding the EIS Draft on the Eno Waste
Water Treatment Plant.
My name is George Andrews. 1 have been a resident of Durham
County my entire life. I have resided in the Northern part of the
county for the last seven years.
I would first like to say, that 1 whole heartedly concur with the
earlier comments made by Mr. Jim Clark.
I want to commend the EPA for the work which has gone into the
EIS draft and for the draft itself.
My specific personal comments concerning the draft , are, I'm
sure important, — vital— and truly significant to all families
and homeowners in Durham County; particularly those with an acute
sense of fairplay.
While this is not a quote verbatim, The EIS draft projects water
and sewer rates must increase by 100 - 200% to assist with
financing water and sewer capacity expansion for planned
development. A Durham City official recently conceded an
expectation of at least a 100% increase for the same reason.
To have to experience this kind of rate shock is almost
unbelievable and would be grossly unfair to existing individual
homeowners.
Recently, I received a survey conducted by the City Engineering
Department, Division of Water and Sewer, 120 E. Parish Str.,
Durham, NC. The survey asked four questions. I want to focus on
the first question, which asked If I would be willing to pay
$2500.00 for water and Sewer lines for a 100 front ft. property.
As much as I would like to have city water and sewer services and
while I would accept my responsibility to pay for my own installation,
of water and sewer lines, pay city taxes after annexation, and
then pay for the service monthly; I would not, in addition want
to have to exDerience rate shock over and above everything else
sr and sewer infrastructure costs for rich
The second point is that any capacity expansion ultimately
approved should undoubtedly go first to the many, many individual
homeowners, particularly in the Northern part of the county who
are experiencing failing septic systems and significant water
quality problems.
~Tm(3 iSPA _5stVrrES If- r"»-4£. tilS pOJ&T it"
-&i -rue r>C»l-U-oM-W
-si**-* ST o e>« ^ ^
R-12
-------
Page -2-
I hope you will give considerable weight to the points I have
made here, as I have a deep and sound conviction they reflect the
sentiments of a great many people in the Northern part of the
county; People who at sometime in the not-to-distant future may
not have access to acceptable water and sewer infrastructure at
any price due to an understandably ever increasing treatment
capacity crunch.
In closing, I would like to thank you again for your efforts and
to request any assistance from you which may be available to aid
those in the county who currently have the most immediate need
for treatment capacity.
I would like these comments to become a part of the record of
this meeting. Thank you!
R-13
-------
Letter R-GA-1
Final EIS
George Andrews
Durham County Resident
1. See Response No. 4, R-JC-1
Additionally, Section 4.2.2 - Financing Alternatives of the Draft EIS
discusses the Federal and State funds that may be available to finance
the project. Unfortunately, residents of the proposed sewer service area
must also bear some of the cost, and based upon Table 4.5, rates may
increase significantly. However, these estimates are for planning
purposes only. Actual rates could be higher or lower.
2. In Section 4.2.1 - Project Phasing of the Draft EIS, the DEIS states:
"It is the recommendation of this EIS that the failing on-lot system
areas be given preference over new development when sewer extension
permits are granted to the County of Durham".
Also, Appendix A of the DEIS discusses the on-lot problem areas of the
proposed project and recommends sewer service to these locations.
3. All comments made at the public meeting will be incorporated into the
Final EIS.
R-14
-------
R-TR-1
CITY OF DURHAM
NORTH CAROLINA
DEPARTMENT OF WATER RESOURCES
101 CITY HALL PLAZA
DURHAM. NORTH CAROLINA 27701
(919) 560-4381
February 20, 1990
Mr. John Hamilton* Project Officer
Eno River EIS
Environmental Protection Agency
Region IV
345 Courtland Street* N.E.
Atlanta* Georgia 30365
SUBJECT: Durham Eno River Wastewater Treatment Plant
Environmental Impact Statement
Dear John:
Please find attached my comments on the Draft Environmental
Impact Statement. As you are well aware* the City of Durham has
already received a permit for the expansion of the Northslde
Plant from Its current permitted capacity of 10 MGD to a
permitted capacity of 20 MGD* 1n order to provide the capacity
needed for existing and projected development 1n the Northslde
and Little L1ck Creek service areas. The original reason for
development of the Eno EIS was to assist the State 1n making a
decision on the Issuance of a permit for wastewater treatment to
serve the needs of the Durham Area Eno Basin. Because of the
phased approach recommended by the EIS* a clear statement 1s
needed on the permitting action which 1s being recommended by the
EPA and the State of North Carolina 1n this joint EIS* so that
the City of Durham can make reasonable plans for the orderly
expansion of the Northslde facility. I would like to suggest
that 1f the final recommendation of the EIS 1s a Northslde Plant
with a capacity of 29 MGD, then 1t should be recommended that a
permit be Issued for this amount. The concerns for Water Quality
Modeling could be addressed In such a permit through conditions
written Into the permit that would require the necessary
monitoring and modeling prior to the issuance of the
authorization to construct facilities beyond the existing
permitted capacity of 20 MGD. In this way* all the parties
concerned would have a clear understanding of what will be
required prior to further expansion of the Northslde WWTP.
I would like to personally thank you and the Environmental
Protection Agency and the North Carolina Division of
Environmental Management and your consultant Gannett Fleming*
Environmental Engineers, Inc. for the tremendous efforts put
M'm
m
I ;i8j»69i I
<3 \ £
CITY OF MEDICINE
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER
R-15
-------
Department uf Water Resources
Mr. John Hamilton
Page Two
February 20, 1990
forth 1n preparing this Environmental Impact Statement. I truly
believe that the final outcome of this process has resulted 1n
the selection of an alternative that will be good for both the
City of Durham and the protection of our environment.
ATR/cbt
0290004.jh
Attachments
cc: Mayor Chester Jenkins
City Council Members
Mr. Orvllle W. Powell
Mr. Cecil A. Brown
Mr. George Everett
Mr. Gordon C. Ruggles
Ms. Pat White, TJCOG
S1ncerely»
DEPARTMENT OF WATER RESOURCES
A. T. Rolan
D1rector
R-16
-------
Letter R-TR-1
Final EIS
A. Terry Rolan, Director
City of Durham, Department
of Water Resources
1. Section 4.2.1 - Project Phasing of the Draft EIS states:
"A Finding of No Significant Impact was issued by NCDEM on April 28,
1989 for an expansion of the Northside WWTP to 20 mgd. NCDEM did
not consider an application for an expansion to 29 mgd so as to not
preclude or bias the findings of this EIS. The preferred alterna-
tive would be implemented with a two phase schedule. The first
phase would involve expansion of the Northside plant from 9.5 mgd
to 20 mgd. During the first phase, water quality monitoring and
modeling of Ellerbe Creek and Falls Lake would continue. Any prior
projections of water quality improvements and impairments would be
refined and updated during this time. Effluent limit requirements
for the second phase, i.e., the expansion from 20 to 29 mgd, would
be further evaluated during this monitoring and modeling." (EPA/
NCDEM should probably address the issue of a "permitting action").
*-17
-------
R-SC-1
Regional Groups
in North Carolina
BLUE RIDGE GROUP
Boone
BROAD RIVER GROUP
Shelby
CAPE FEAR GROUP
Wilmington
CAPITAL GROUP
Raleigh
CENTRAL
PIEDMONT GROUP
Charlotte
COASTAL GROUP
New Bern
CYPRESS GROUP
Greenville
FOOTHILLS GROUP
Winston-Salem
HEADWATERS GROUP
Durham
HORACE KEPHART
GROUP
Fayetleville
PIEDMONT PLATEAU
GROUP
Greensboro
RESEARCH TRIANGLE
GROUP
Chapel Hill
SANDHILLS GROUP
Southern Pines
SMOKY MOUNTAINS
GROUP
Bryson City
SOUTH MOUNTAINS
GROUP
Morganion
WENOCA GROUP
Asheville
SIERRA CLUB
North Carolina Chapter
715 Arnette Avenue
Durham N.0, 27701
Mr. Heinz J* Mueller, Chief
Environmental Policy Section
U.S. Environmental Protection Agency - Region IV
3^5 Gourtland Street
Atlanta, Georgia 303^5
Dear Mr. Mueller1
This is a written edition of oral conments presented on February 2), 1^90
concerning the Draft EIS for the Durham-Eno River Wastewater Facilities.
Comments are on behalf of the N.C. Chapter of the Sierra Club, which I serve
as Land Use Chair, and of the Headwaters Grbup of the Sierra Club, w'i'ch I
represented on EPA's Review Committee for this EIS. Statements here axe meant
to support fully the positions taken on this DEIS by Professor David HowellSi
Water Quality Chair for the N.C Sierra Club, and as well support positions
taken over the last several years by the Headwaters Group and by the Conser-
vation Council of N.C.. for which I made EIS Scoping Requests in 1987.
First, I want to reiterate in particular certain of Prof. Howells' positions!
(a) that Alt, N-EX3 appears to be the best choice under the circumstances as
long as the inter-phase study is conduct>dd",as planned and the City of Durham
consistently provides high quality operation and maintenance! (b) that a
reexamination of the water rate structure i3 needed to prevent the encourage-
ment of waste{ (c) that surcharges be used to reduce organic leadings; and»
above all,(d)"that thA EIS. addretea the crucial faet that the upper end of
Falls Lake is still not classified bjr the State for water-sunoly uses.
I would add that current local watershed regulations are keyed to Stite
surface water classifications in ter^s of regulatory boundaries. This issue
will be discussed elsewhere in these co^ents.
In addition, I wanted to note that fhis lengthy process of EIS preparation -
starting with NCDEM's request in Fall 1986 - has proven the importance of full
investigation and citizen participation in protecting water quality. Originall'
the DEM expressed an "intent to issue" a perlit to expand the discharge of th'
Eno River Wastewater Plant from 2.5 to 10 MGD. The Eno River Association, ac'
companied by the Conservation Council, the N.C. Sierra Club, and the N.C.
Wildlife Federation, asked for extensive further study in an 313. This citise#
request, it must be emphasized, was based not only on foars of pointsource
impacts on Falls Lake's water supplies, but also on the l»nd use impacts of
nonpotnt pollution resulting from development in the entire watershed where
sewer service might exist, and in other areas affected by development infra-
structure. Our conceons about pointsource impacts appear to have been fully j
confirmed bjr the State's studies, which have led to Alt. N-EC, not an expansi®
of the Eno River Plant but instead a closure.
The scopinr: requests I submitted in 1987 to DEM and EPA focussM on the need
for any EIS to comply fully with, first, the N.C. Environmental Policy Acfc,
and, second, the National Environmental Policy Act, by thoroughly examining
To explore, enjoy, and protect the wild plates of the earth; tn prartxrr and promote thr ie\poiwtble mr nf fits rnrth\ r,
'I'l'/ >rKOttt
-------
2
not only the direct effects, but also the indirect effects ind si/^nlflcane" ">f t.M3
action, and as well "possible conflicts between the proposed activities and obinctives"
of different government plans, policies and controls In the affected area. We -\sksd
feqth DEM and EPA to recommend mitigation measures on the part of local governments!
specifically, comprehensive stormwater management studies In both City and Countyj
priorities for sewer servicei Installation of greenwajr trails simultaneous with Install-
ation of sewer lines served by any treatment expansion. We also asked both agencies
to recommend prompt and timely implementation of recommendations from the Eno River
Capacity Use Study and the Little River/Lake Michie Watershed Study.
Because this final request was made not only in scopin/r documents but also by representa-
tives from environmental groups in the EI3 Review Committee, we are disappointed that
the Capacity Use Area Study - the most comprehensive of its kind In this region - was
not considered at all in this EIS. The downstream boundary of its study area was some
three miles below the Eno discharge. Because of this significant omission, I asked the
N.C, Natural Heritage Program to use the C.U.A. Study in its comments on this EIS,
which focussed on biological Impacts of flow reductions, particularly threatened species;
Another singular omission - significant in view of the number of Review Committee requests
for consideration - is discussion in Section 3.3.2.'+. of a proposed interstate-level
thoroughfare Intended to serve major industrial and commercial development in the Eno
River Service Area - the "Northern Durham Freeway." As presently proposed, this express-
way would move between sections of the sewer service area by crossing the Water Quality
Critical Area of Little River Reservoir at polftts-1.^ miles directly upstream from the
public watefc supply intake and «7 mile upstream from the pool level. The 19A8 regional
thoroughfare plans clearly states this road would serve heavy development in the Eno
baain, development too heavy to exist without centralized sewer, and ignoring this
major indirect effect of the action may constitute a failure tn comply-'vith ^0 CFR Part
1502.16 (b) and Part 1508.8 (b) (Regulations for Implementing N3PAf) the
mitigation measures requested by the Conservation Council in 19^7. The wastewater plants
of the City of Durham are currently operating under a Judicial Order of Consent (9/l^/P9).
Among many provisions relating to wastewater treatment, there is one regarding mnpoint
pollution. Section (p) requires that Durham
Provide a certification for all new development projects (excludes City or County
projects for areas with failing on-site treatment systems) in the Eno River Service
Area requirihg non-discharge permits for sewer lines indicating that the projects
comply with State watershed protection guidelines regarding watercourse Vjf'-jr? -.nd"
stormwater control (but not land use restrictions) for Class WS-II watersheds as
defined in DEM Report 87-05..."Guidelines for Obtaining a Protective Surface Water
Classiflcation." Plans and specifications to verify compliance with watershed protect-
ion guidelines must also be provided.
We request that EPA strongly recommend that this be a condition in the NCDEM permit for
operation of any wastewater facility serving the Eno Basin, by extending this provision
"beyond the period when the Eno River EIS is approved. We also request that DBM nnd EPA
investigate Durham's full compliance with this provision of the Court Order. The Eno
River is distinguished among streams in the Durham urban services area by Its consistent
support of classified surface water uses, and occasional excedence of standards. Both
State and Federal anti-degradation statutes, and forthcoming NPD3S storfwat^r fitting
programs, may make controls of this nature mandatory, particularly in river banh'.n of
good water quality such as the Eno.
Ed Harrison
It-19
-------
Letter R-SC-1
Final EIS
Ed Harrison
Sierra Club
The Eno River Capacity Use Investigation (State of North Carolina
Division of Water Resources, August 1987) was used extensively in the
preparation of the Task 305 Background Information Report (1988) and the
draft Baseline Environmental Report (1987). It is referenced in both of
these documents. Conclusions of the Capacity Use Investigation are
incorporated in the Draft EIS via these two supporting documents.
A complete assessment of the impacts of the proposed Thoroughfare Plan is
outside the scope of this EIS. However, information was presented in
Section 3.3.2.4 on the proposed Thoroughfare Plan and a map of the
proposed transportation systems presented in Plate 16. Furthermore, a
Toxic Spill Analysis was conducted for a potential toxic spill at the Red
Mill Road crossing of the Eno River. This analysis is contained in
Technical Appendix III to the Draft EIS.
Since the City of Durham is a party to the Judicial Order of Consent it
is assumed that the City is abiding by the provisions of the Consent
Order including Section (p).
These are good points, but they are primarily enforcement actions which
go beyond the scope of this EIS.
R-20
-------
R-SC-2
Regional Groups
•n North Carolina
BLUE ridge group
Boone
Broad river groi/p
Shelby
CAPE FEAR GROUP
Wilmington
CAPITAL GROUP
Raleigh
CENTRAL
PIEDMONT GROUP
Charlotte
COASTAL GROUP
New Bern
CYPRESS GROUP
Greenville
FOOTHILLS GROUP
Winston-Salem
HEADWATERS GROUP
Durham
HORACE KEPHART
GROUP
Fayetteville
piedmont plateau
GROUP
Greensboro
Research triangle
group
Chapel Hill
SANDHILLS GROUP
Southern Pines
Smoky mountains
group
BtVson City
south mountains
group
Morgamon
WENOCA GROUP
Asheville
SIERRA CLUB
North Carolina Chapter
'• 9 1 3 Larchmont Drive
Raleigh, N.C. 27612
Mr. Heinz J. Mueller, Chief
Environmental Policy Section
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Mueller:
I served on your EIS Review Committee for the Durham-Eno
River Wastewater Facilities, Durham, North Carolina, and
would like to comment on the Draft EIS. I cannot attend
the public hearing scheduled for February 20 and ask that
these comments be considered along with oral comments.
Alternative N-EC appears to be the best choice under the
circumstances as long as the inter-phase study is conduct-
ed as planned and the City of Durham consistently provides
the required high quality operation and maintenance to
assure design performance. The history of BOD- violations,
however, does raise serious questions as to what can be
expected.
It is unclear to me how the required effluent BOD^ can be
attained with the proposed unit processes. I am referring
to the unit processes cited in Table 3-2. Perhaps, there
are omissions in the table.
I presume that stand-by power and pumping equipment will
be provided for the 12 mgd. pumping station at the Eno
River site. Any bypassing of raw sewage could have
disasterous consequences.
Annual priority pollutant analysis would appear to be a
minimum requirement. I suggest that any new industries
be given close scrutiny in this regard including an initial
priority pollutant analysis.
I was pleased to see conservation measures being consider-
ed. The list of measures should also include a reexamina-
tion of the water rate structure to assure that this not
encourage waste and unnecessary loading on the treatment
plant. I strongly endorse the use of surcharges to reduce
organic loadings - as proposed.
To explore, enjoy, and protect the wild places of the earth; to practice and promote the responsible use of the earth's ecosystems and resources
R-21
-------
- 1 -
There are more reasons than stated on page 2-20 for reqiring indust-
rial waste pretreatment. The most important would appear to be to
avoid upset of the plant's biological systems by toxic components.
Is it advisable to provide for seasonal limits for phosphorus when
a eutrophic lake serving as an important water supply source is
immediately downstream? Isn't it likely that most phosphorus will
be adsorbed on particulate matter and settle out, being available
for recycling whenever growth factors are favorable?
In reading the section on primary impacts on surface water resources,
I am struck by the lack of mention of the fact that the portion of
Falls Lake bordering the Durham region is still classified as "C"
and that the City of Durham has not taken steps to protect that
watershed area through inclusion as a critical watershed area. This
question was raised by Rep. Joe Hackney during a hearing by the
Legislative Research Committee. The response by the City's repre-
sentative - as I recall it - was that Durham had acted to protect
its water supply sources and it was up to Raleigh to do the same.
I am enclosing copies of correspondence between the Division of
Environmental Management and me pertaining to this and copies of
the City of Raleighs request to the State to reclassify. I am
told that the Division of Environmental Management has taken no
steps toward reclassification of the full lake WS-III. The point
here is not that the State is failing to protect lake waters as
presently classified, but that the "C" classification is leading
Durham into a posture of disregarding critical watershed desig-
nation and thus permitting an intensity of development along the
lower Eno River that is almost certain to have an undesirable
effect on the State Capital's water supply. I believe that this
issue is germain to the Eno River Wastewater Treatment plant EIS.
I hope these comments will be useful to you in preparing the final
EIS and related actions.
CC : Councilwoman Mary Cates
Ed Harrison
Bill Thomas
Randy Schenck
Bill Holman
Steve Tedder, DEM
David H. Howells
Water Quality Chair
North Carolina Chapter
Sierra Club
R-22
-------
Letter R-SC-2
Final EIS
David Howells
Sierra Club
Table 3-2, as included in the draft EIS, is complete. BOD removal for
each of the alternatives will be accomplished by either the conven-
tional activated sludge unit process or the biological phosphorus removal
unit process. Biological phosphorus removal is a modification of the
conventional activated sludge process that achieves biological uptake of
phosphorus, BOD removal, and nitrification by contacting the wastewater
with a cycle of anaerobic, anoxic, and aerobic sludges. Since its
introduction in the 1970's, the biological phosphorus removal process has
become a proven method for the combined removal of BOD and phosphorus.
Providing standby power and duplicate pumping units is a standard design
practice incorporated in all large wastewater pumping stations. The Eno
River pumping station will be designed to handle the projected peak
instantaneous wastewater flow with one pump out-of-service. The facility
will also be equipped with an emergency generator to provide backup power
during periods when the main power supply is interrupted.
Section 2.3.6 - Industrial Pretreatment of the Draft EIS discusses the
limits imposed by the City of Durham. These limits are generally more
stringent than the Federal guidelines. Furthermore, the DEIS states in
Section 2.3.6 that:
"The effluent from any future industries would be evaluated to
establish the discharge permit limits that the industries would be
required to meet. An additional measure to control hazardous
materials at industries is the Emergency Planning and Community
Right to Know Act (SARA Title III). It requires that industries
submit Emergency and Hazardous Chemical Inventory Forms to a local
fire company, the Local Emergency Planning Committee, and the State
Emergency Response Commission (40 CFR Part 370)".
P.-23
-------
Letter R-SC-2
Final EIS
David Howells
Sierra Club
4. There are seasonal limits proposed for Total Phosphorus (TP). TP
effluent limits of 0.5 mg/L (April-October) and 2.0 mg/L (November-March)
have been established. The Draft EIS recommended that the 2.0 mg/L
(November-March) be lowered to 1.0 mg/L to obtain further reductions at
TP loadings.
5. For response to this comment, the reader is referred to the following
letter.?
K-24-
-------
06/11.-'90
10: 26
US E. P. A. - Ul. D.
004
Response to David Howells letter R-SC-2
We agree with Mr. Howells that it is important, to note that
the entire lake is not classified a water supply. The
Environmental Management Commission, in their original actions,
declined to classify the upper portions of the Lake as water
supply because of the dischargers in that area and the probable
unsuitability for using those waters as water supplies. They did
indicate a desire to provide necessary protection for all water
supply intakes. There have been requests to classify the upper
portions of the Lake as water supply and the Division of
Environmental Management is doing monitoring to determine if the
quality of those waters is acceptable. If it appears they meet
the conditions for reclassification, an official request will be
made to the Commission to take the issue to public hearing.
Durham and Durham County have both provided some additional
protection for those portions of the Lake not classified as water
supply, especially in the areas around the Little Lick, Panther,
and Ellerbe creek portions of the Lake. Reclassification of the
entire Lake would bring more nonpoint source protection to the
remaining portions of the Lake. The City of Durham should
evaluate the impacts of such a reclassification and provide the
information to the Division of Environmental Management as they
consider this action.
enonote
R-25
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DEPARTMENT OF HEALTH & HUMAN SERVICES
R-KH-1
Cemers for Disease CL';"r"
Atlanta GA 30333
February 15, 1990
Heinz J. Mueller, Chief
Environmental Policy Section
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. MUeller:
We have completed our review of the Draft Environmental Impact Statement
(DEIS) for the Durham-Eno River, North Carolina Wastewater Treatment Plant
and Service Area. We are responding on behalf of the U.S. Public Health
Service. Technical assistance for this review was provided by the
Environmental Sanitation Group, Environmental Hazards and Health Effects
Division, Center for Environmental Health and Injury Control, Centers for
Disease Control.
This DEIS has been well written and generally describes potential impacts
and appropriate mitigation measures. We do, however, offer several
comments for your consideration.
We agree with and encourage the idea that conservation should be viewed as
a long-term method of reducing water consumption and promoting more
efficient use of scarce water resources. While the DEIS notes that the
use of water saving devices is a conservation measure, it does not
indicate if the measure will be used. Consideration may be given to
requiring water conservation devices as part of the building permit
system.
On page 3-12, Table 3-2 is unclear as to what is the BOD removal process
for alternatives "EN-ER, NT-EC/IA (Northside), N-EC, N-NR, and R-NR."
It is stated on page 4-34 that "if violations of the chlorophyll-a
standard continue, and if it is determined that the discharge is a
significant contribution to these violations, NCDEM should pursue a
variance or similar arrangement until proper improvements can be made."
If the chlorcphyll-a standard is expected to continue to be violated, the
discharge may be a significant contribution. Therefore, it may be prudent
to plan for this now rather than postponing such actions.
R-26
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Page 2 - Mr. Heinz J. Mueller
Thank you for the opportunity to review and comment on this DEIS. Please
insure that we are included on your mailing list for future DEIS's which
may indicate potential public health impact and are developed under the
National Environmental Policy Act (NEPA).
Sincerely yours,
Kenneth W. Holt, M.S.E.H.
Environmental Health Scientist
Center for Environmental Health
and Injury Control
R-27
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Letter R-KH-1
Final EIS
Kenneth W. Holt
U.S. Department of Health
and Human Services
Center for Disease Control
1. The requirement of water conservation devices is a city/county matter
that must be implemented at that level.
While we promote the use of water conservation practices, they are not
used in developing flow projections since there are no assurances that
the individual home owner will actually put into use any water
conservation measures or devices.
2. Table 3-2 on page 3-12 of the draft EIS includes two unit processes
capable of removing BOD. The conventional activated sludge process is
proposed for BOD removal for alternatives EN-LA and NT-EC/LA (Treyburn).
The remaining alternatives will use the biological phosphorus removal
unit process for BOD reduction. Biological phosphorus removal is a
modification of the conventional activated sludge process that achieves
biological uptake of phosphorus, BOD removal, and nitrification by
contacting the wastewater with a cycle of anaerobic, anoxic, and aerobic
sludges.
3. We would agree with this statement. If a detailed monitoring program
shows that chlorophyll-a violations continue to occur, then the imple-
mentation of Best Management Practices must take place in the EIS study
area. Table 4-14 of the Draft EIS provided a list of BMP's that are
currently in use in the Basin. Since non-point sources are a major con-
tributor to Total Phosphorus loading, they must be implemented and
enforced.
R-28
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R-JL-1
United States Department of the Interior
OFFICE OF THE SECRETARY
Office of Environmental Affairs
Richard B. Russell Federal Building
75 Spring Street, S.W.
Atlanta, Georgia 30303
feb i g r::'3
FEB 1 5 1330
ER-90/4
Mr. Heinz J. Mueller, Chief
Environmental Policy Section
U.S. Environmental Protection Agency
345 Courtland Street, NE
Atlanta. Georgia 30365
Dear Mr. Mueller:
The Department of the Interior has reviewed your Draft Environmental Imca
Statement on Durham-Eno River, North Carolina Wastewater Treatment Plant
and Service Area. We provide the following comments.
The document does not mention the mineral resources Cclav and crushed
stone) of the area. We believe that mineral resources would not be
significantly affected by any of the proDOsed alternatives. Nevertheless
we suggest that subsequent versions of the document include a description
of mineral resources of the area. If no impacts would occur, then a
statement to that effect should be included. Such an inclusion would
provide users of the documents with knowledge that mineral resources had
been considered during project planning.
Thank you for the opportunity to comment.
Sincerely.
R-29
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Letter R-JL-1
Final EIS
James Lee
U.S. Department of the
Interior
1. The geology and soils of the area were discussed in Chapter 3 of the
Draft EIS. Although the location does have several active crushed stone
and shale/clay quarries, these quarries should not be affected by the
proposed project. The primary purpose for reviewing geology and soils
was to determine groundwater resources in the study area.
R-3U
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R-CJ-1
CITY OF DURHAM
NORTH CAROLINA
THE MAYOR
101 CITY HALL PLAZA
DURHAM, NORTH CAROLINA
27701
February 23, 1990
Mr. John Hamilton, Project Officer
Eno River EIS
Environmental Protection Agency
Region IV
345 Courtland Street. N.E.
Atlanta* Georgia 30365
SUBJECT: Draft EIS# Durham-Eno River, North Carolina
Wastewater Treatment Plant and Service Area
Dear Mr. Hamilton:
I would like to take this opportunity to express the City of
Durham's appreciation to you and your staff for the thorough and
professional manner 1n which the above subject study has been
conducted. I would like to have the following comments included
as a part of the Public Hearing record.
The City of Durham, North Carolina requests that both Phase A
(already permitted) and Phase B as described In Chapter Four
(4) be recommended for permitting Immediately, with the
provision that Phase B authorization to construct be
contingent on satisfying water quality requirements as
determined by the State. This action will allow for much
more effective project planning 1n Phase A and will enable
the City of Durham to adjust revenue forecasting over a
longer and more stable planning period, thereby minimizing
"rate shock".
The City of Durham, North Carolina requests strong emphasis
be placed on the fact that the preferred alternative has
positive Impacts on existing water quality of the Neuse Basin
and that those costs related to Improving water quality be
funded by both the State and Federal funds to the maximum
amount possible. Currently only about 22% of the project has
tenatlve commitment for funding with revolving loans from the
Federal Government.
r4' #
<2, A D / £
CITY OF" MEDICINE
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER
R-31
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Mr. John Hamilton
Page Two
February 23> 1990
3. The City of Durham requests that 1n Section 4.3# some
discussion be provided concerning the positive economic
effects of providing wastewater capacity for orderly growth
1n northern Durham County* specifically 1n the areas of
employment and small business opportunities.
Your assistance in having these comments included in the Hearing
Record will be appreciated.
CLJ/cbt
0290315.jh
cc: Mr. George Everett» Division of Environmental Management
Mr. Orvllle W. Powell# City Manager
City Council Members
Mr. A. T. Rolan* Director# Department of Water Resources
S1ncerely»
R-32
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Letter R-CJ-1
Final EIS
Chester L. Jenkins, Mayor
City of Durham
The preferred alternative of this draft EIS involves a 29 mgd advanced
treatment plant at the Northside location with discharge to Ellerbe
Creek. The DEM has already issued NPDES permit NC0023841 for a 20 mgd
expansion of the Northside facility. At this time, neither EPA nor DEM
anticipate the need for an additional EIS or public hearing prior to the
issuance of a permit for the 29 mgd expansion. DEM will not make a final
permitting decision or issue authorization to construct until impacts to
water quality from the Phase A expansion have been observed through the
critical portion of at least one summer period (i.e., June through
September). Thus, the time period for Phase B expansion approval will be
affected by the date that the Phase A expansion actually comes on-line.
It is expected that this decision will be made within 12 to 24 months
following the on-line data for Phase A.
In making the permitting decision, DEM will analyze any effluent data and
samples which have been collected in the receiving stream, Ellerbe Creek,
including the self monitoring data collected by the City of Durham (Table
1). In addition, DEM plans to collect supplemental information for
modeling purpose and further water quality impact evaluation. Emphasis
will be placed on dissolved oxygen (DO), instream toxicity, and
eutrophication through updating DEM's current water quality models and/or
performing additional analyses. Evaluation criteria will center around
maintenance of State water quality standards and supporting "Best Use" of
the receiving waters as defined by Ellerbe Creek's water quality
classification.
Section 4.3.1 - Surface Water Resources of the DEIS enumerates all the
positive effects the proposed project will have on the Neuse Basin.
Section 4.2.2 - Financing Alternatives of the DEIS discusses the various
State and Federal monies available for the project. According to this
R-33
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Table 1: Instream Monitoring Requirements
Ellerbe Creek, Durham County, North Carolina
Northside WWTP Phase A Expansion
A. October - May Sampling Requirements
Effluent
Measurement
Sample
Sample
Characteristic
Frequency
Type
Locations
BOD, 5 day, 20oC
Three/week
Grab
U1,U2,U3
Dissolved Oxygen
Three/week
Grab
U1,U2,U3
Fecal Coliform
Three/week
Grab
U1,U2,U3
Temperature
Three/week
Grab
UI,U2,U3
Conductivity
Three/week
Grab
U1,U2,U3
B. June - September Sampling Requirements
Effluent
Measurement
Sample
Sample
Characteristic
Frequency
Type
Locations
Dissolved Oxygen
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
Temperature
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
Conductivity
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
Total Nitrogen
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
Total Phosphorus
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
Ammonia-Nitrogen
Weekly (am & pm)
Grab
U1 ,U2,U3,U4,U5,U6
Total Kjeldahl N
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
Phosphate
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5)U6
PH
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
Chlorophyll_a
Weekly (am & pm)
Grab
U1,U2,U3,U4,U5,U6
C. Notes:
1. Sampling to begin June 1991 and continue until
the issuance of the NPDES permit for the Phase B
expansion (29 mgd).
2. Sample locations are U1 - East Club Boulevard,
U2 - Glenn Road, U3 - Red Mill Road, U4 - Old
Railroad Trestle, U5 - New Railroad Trestle,
U6 - 185 or other site near mouth of Falls Lake.
3. Following completion of the Phase A expansion
the NCDEM will add Ellerbe Creek to the list
of streams scheduled for biological assessment
classification.
R-34
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section, up to $10.5 million would be available on an annual basis for
this project.
3. It is difficult within the context of the Draft EIS to quantify
employment and small business opportunities in the EIS study area.
Section 3.3.2.3 of the Draft EIS looks at Economics and Employment and
discusses the positive impacts the project will have on employment and
economic growth in the study area.
R-35
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R-CD-1
COMMENTS BY THE CITY OF DURHAM
DEPARTMENT OF WATER RESOURCES
DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR DURHAM-ENO RIVER WASTEWATER TREATMENT PLANT AND SERVICE AREA
DATED SEPTEMBER, 1989
Page ES-6 Description of Preferred Alternative This
section discusses the proposed phasing of the Northslde
Expansion and the recommended limits associated with the
phased expansion. This section should be revised to clearly
state what the State of North Carolina and the Environmental
Protection Agency proposes for the permitting process. It
should include how these Issues will be addressed by
revisions to the existing permit for the Northslde Plant.
As stated 1n this paragraph, the necessity for a more
stringent phosphorus limit of 1 mg/L, should be evaluated
during the phase A monitoring and modeling program. The
requirements for this monitoring and modeling program should
be clearly defined both 1n terms of parameters to be
monitored and modeled as well as sample locations and the
duration of the monitoring program 1n order to generate the
quantity of data needed to carry out the predictive
modeling. Phase A of the Northslde Expansion will not be
completed before January, 1994. If the Phase B Expansion is
to be completed on time, there would only be one year of
monitoring with the new facilities on line prior to the
initiation of the Phase B construction 1n January, 1995.
Approximately one year would be required 1n order to design
the facilities needed for Phase B. The facilities being
provided 1n Phase A which will include both biological
phosphorus removal and chemical phosphorus removal should be
capable of meeting the 1 mg/L phosphorus limit if that 1s
required. However, if more stringent limits for other
paramaters were required which would result in a significant
change 1n the facilities needed in Phase B as a result of
the proposed monitoring and modeling program, then a
redesign of the Phase B facilities would be required. This
would result in a delay of Phase B Implementation. Because
of this problem, it would be helpful to the City of Durham
for the monitoring and modeling determination to be made
based on the available data at that time and should be
decided no later than January> 1994.
2. Page ES-7 - The third paragraph discusses mitigation
efforts. It may be helpful to Include in the appendix, a
copy of the C1ty of Durham's Watershed Protection Ordinance
in addition to the County Ordinance. It may also be helpful
to include a copy of the Judicial Consent Order entered into
R-36
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by the State and the City which addresses some of the
concerns Included in the mitigation for Phase A. It may
also be helpful to Include In this section a discussion of
the Impact of the recent change 1n the State guidelines for
the protection of water supply watersheds which severely
limits the land area available for land application of
sludges 1n the Durham area. It may also be helpful to
Include a discussion of the proposed demonstration project
by the City of Durham for sludge land filling and treatment
of sludge by high ph lime stabilization or cement kiln dust.
A copy of the proposals presented to the State of North
Carolina 1s attached.
Page 2-8 - The flow projections contained in Table 2-3
appear to predict an annual average flow of 12 MGD. Recent
changes 1n the enforcement strategy of the Division of
Environmental Management have resulted 1n a determination
that a maximum monthly flow which exceeds the permitted
capacity of the treatment facility 1s considered a violation
of the NPDES Permit. With this problem 1n m1nd» 1t would
appear that the annual average flow projections should be
adjusted by a peaking factor in order to determine the
actual treatment plant capacity needed 1n order to avoid a
violation of the monthly average flow.
Page 3-2 - The City of Durham has recently had the firm of
Hazen and Sawyer» Consulting Engineers evaluate the routing
of the force main from the Eno Plant to the Northslde Plant.
The route selected by Hazen and Sawyer differs slightly from
that shown In the EIS. We would suggest that the EIS be
amended to reflect the current thinking of the City relative
to this force main routing. A copy of the analysis and
routing by Hazen and Sawyer Is attached.
Page 3-11 - The EIS does not recognize that both Eno and the
Northslde Plants are currently required by the NPDES Permit
to show no whole effluent chronic toxicity. Because of the
current concern for the creation of chlorlnatlon by-products
even 1n a facility which would Include both chlorlnatlon and
dechlorination, the City plans to Include ultraviolet
disinfection 1n lieu of chlorlnatlon and dechlorination for
the expanded Northslde Plant. The EIS should be amended to
reflect the current NPDES requirements and to address the
Issue of chlorlnatlon by-products.
Page 3-12 - Table 3-2 on this page Includes only biological
phosphorus removal under the Northslde alternatives. Can 1t
be assumed that this process will also meet the nitrification
requirements at this facility?
Page 3-29 - The water quality modeling effort completed 1n
March* 1989 1s referred to on this page. The discussion
Includes the Involvement of NCDEM Technical Support Unit and
USEPAt but makes no mention of the efforts by the City of
R-37
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Durham during the summer of 1988 in collecting the required
water quality data. Because of the level of effort put
forth by the City of Durham's staff in accumulating this
data, it would appear that some mention of our involvement
would be appropriate.
8. I Page 4-8 - Table 4-3 on this page does not appear to agree
I with Table 3-5 on Page 3-18.
Page 4-9 - Table 4-4 appears to have some areas related to
footnotes which should be corrected 1n the final document.
This Table should also be revised to make clear that these
costs do not include any cost for upgrade to the existing
Northside Plant and does not include any cost for the Lick
Creek Pump Station and Force Main which are included in the
current City's estimates. These costs also do not include
new facilities for sludge handling at the Northside Plant
which result from the loss of sand drying beds which will
result from the construction of the new facilities. These
costs also do not include any cost for the proposed sludge
demonstration project which 1s included in the City's
estimate of cost. These cost also do not include any cost
associated with expansion capacity needed 1n the Little Lick
Creek and Northside service areas. Based on detailed
preliminary engineering efforts by Hazen and Sawyer* I would
estimate that all of the above would be equal to
approximately $36,224,000 with approximately $5,604,000 of
that cost being associated with capacity expansions for the
Northside and Little L1ck Creek Basins. A copy of the cost
summary prepared for the City by Hazen and Sawyer for both
the Northside and Farrington Road projects which attempts to
distinguish the cost for Improvements to these facilities
for both upgrading of treatment as well as expansion of
capacity Is provided for your Information.
10. Page 4-10 - The date for the City Bond Referendum should be
changed to November, 1990. The tenatlve amount of the bond
authorization for improvements to both the Farrington Road
Plant and Phase A of the Northside Plant would be
approximately $92.5.
11. Page 4-13 - A copy of the City's current projections of the
rate impact of the proposed bond Issue 1s attached for your
1nformat1 on.
12. Page 4-17 - Table 4-7 Indicates that the point source
nitrogen and phosphorus loads would be the same for both the
low growth scenario and the moderate growth scenario. This
does not seem to be a reasonable assumption. Is there an
error in this table?
R-38
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Letter R-CD-1
Final EIS
Department of Water
Resources
City of Durham
1. The response to this comment is contained in the response to Letter
R-CJ-1 comment Number 1.
2. Both the City of Durham's Watershed Protection Ordinance and the Judicial
Consent Order have been appended to the Final EIS. Sludge disposal is an
on-going issue to be resolved between the City of Durham and the NCDEM
(see Judicial Order of Consent, Appendix C). At this time,
land application is one of several options for sludge disposal.
3. All the facilities described in the draft EIS are referred to in terms of
their annual average design flows. In practice, any wastewater treatment
facility to be provided as part of the Durham project should be designed
with sufficient capacity to treat the maximum monthly flow and still
achieve the effluent requirements. The NPDES permit for the treatment
facility will set forth the conditions for the discharge of both the
maximum monthly flow and the annual average flow. Therefore, it is not
necessary to adjust the annual average flow projections to avoid a
violation of the NPDES permit for influent flows equal to or less than
the projected monthly maximum flow.
4. Routing of sanitary sewers for the purposes of the draft EIS have been
shown in Plate 5 of the draft EIS. As is standard engineering practice,
site survey will determine the precise route during the design phase of
the project.
5. The fact that the City of Durham is required by its NPDES permit to
conduct whole effluent toxicity testing of the Northside discharge is
added to the Executive Summary of this final EIS. Chapter 4 is amended
to point out that ultraviolet disinfection may be used to eliminate the
formation of chlorination by-products.
R-39
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Letter R-CD-1
Final EIS
Department of Water
Resources
City of Durham
6. Your assumption is correct. The biological phosphorus removal processes
referred to in Table 3-2 were sized and costed to include sufficient
detention time in the oxic stages of the process to achieve the required
level of ammonia oxidation.
7. The City of Durham along with the NCDEM technical support unit should be
credited for the water quality modeling effort performed during the
summer of 1988.
8. Table 4-3 - Total Project Costs - as noted are reported in 1992 dollars.
Although not specifically noted on Table 3-5, its costs are reported in
1989 dollars. The difference between the reported costs in the two
tables corresponds to the variation in dollar years.
9. As stated on page 4-7 of the Draft EIS, the EIS study area includes only
the Eno Service Area and the costs presented in the report reflect costs
only to the Eno Service Area. Therefore, your statement on the other
costs required for service to the Northside and Little Lick Basins not
included in the report is correct. However, as you reported, Table 4-4
of the Draft EIS does contain several errors regarding footnotes. This
Table will be corrected in the final document.
10. In Section 4.2.2 of the final EIS, the date for the City Bond Referendum
is changed to November 1990.
11. The correct point source loads for the low growth scenario are 420
tons/yr total nitrogen and 20 tons/yr total phosphorus. These numbers
are shown in Table 4-7 of the final EIS.
R-40
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R-LS-1
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
WILMINGTON, NORTH CAROLINA 28402-1890
March 1, 1990
IN REPLY REFER TO
Planning Division
Mr. Heinz J. Mueller, Chief
Environmental Policy Section
U.S. Environmental Protection
Agency, Region IV
3*»5 Courtland Street, NE.
Atlanta, Georgia 30365
Dear Mr- Mueller:
Thank you for the opportunity to review the Draft Environmental Impact
Statement for the Durham-Eno River Wastewater Facilities, Durham, North
Carolina. The report is well written and appears to address most of our
concerns about potential impacts to Falls Lake and the government-owned lands
that surround the project. The following comments are provided for your
consideration.
We share your concern about potential water quality impacts to Falls Lake,
particularly in the Ellerbe Creek arm of the project and support your plan to
monitor water quality and to do further modeling at Falls Lake during Phase A
(upgrading and operation of the Northside Treatment Plant from 9.5 mgd to
20 mgd). Since the determination that Falls Lake can absorb the additional
wastewater without ill effects is based on modeling and assumptions that in
turn rely upon skillful technical operation of an
treatment facility, information obtained from tbe Bonit°r^g and nodellng
should be extremely useful in determining how well state-of-the-art technology
is performing at the treatment facility and how, or » P t f
Phase B (increase capacity from 20 mgd to 29 mgd). Given the importance of
Falls Lake for water supply, recreation, and fish and wildlife, please
continue your already intensive efforts to protect and enhance water quality
conditions.
It appears from plate 5 that several force mains and
proposed to oroas federally-owned lands at Falls Lake that are designated for
permanent wildlife management. In fact, gravity 1 ne ~J\
the waterfowl subimpoundments which will be operated t° attra ^ato y
waterfowl for hunting. It is the policy of the Corps that these lands are not
available for utility easements if there are alternatives. Such alternatives
would include use of private lands, highway rights-of-way, and use of existing
utility easements. Prior to submitting a request for use of Falls Lake
R-41
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-2-
project lands, the Falls Lake Resource Manager should be contacted so that
appropriate Wilmington District elements can field review any preliminary
plans with you. Final plans should be submitted to that office with your
request for approval.
The first sentence under Falls Lake, on page 4-15, should read,
"Falls Lake is a highly eutrophic body of water with mean chlorophyll-a
concentrations that can exceed 60 ug/1 during warm months in its headwaters
(NCDEM, 1989; and USACOE, 1988)." The second sentence under the second
paragraph of Falls Lake, on page 4-15, should read, "The average annual input
of total phosphorus (TP) to Falls Lake is 206 tons/year (USACOE, 1988)." All
references to the average annual input of TP to Falls Lake should use the
206 tons/year figure. This figure represents the average for the 4-year
period of July 1983 through June 1987 as reported in Falls Lake. N.C.. Water
Quality Study. Year 4 (July 1986-June 1987). which was prepared in 1988 for
the U.S. Army Corps of Engineers, Wilmington District, by Water and Air
Research, Inc.
Department of the Army permit authorization, pursuant to Section 404 of
the Clean Water Act of 1977, as amended, will be required for the discharge
of excavated or fill material in waters of the United States or any adjacent
and/or isolated wetlands in conjunction with the proposed action. Specific
permit requirements will depend on design of the project, extent of fill
work within streams and wetland areas (dimensions, fill amounts, etc.),
construction methods, and other factors. When final plans are developed,
including the extent and location of development within waters of the United
States and wetlands, they should be submitted to our Regulatory Branch for a
project-specific determination of Department of the Army permit requirements.
Again, thank you for the opportunity to participate in the development and
evaluation of alternative plans and to review the DEIS. If there are any
questions about our comments, please contact Mr. Coleman Long, Environmental
Resources Branch, at (919) 251-4751.
R-42
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Letter R-LS-1
Final EIS
Lawrence Saunders
U.S. Department of the Army,
Corps of Engineers
1. The impact to Falls Lake lands has been noted on page 4-18, Section 4.3.3
and Table 4-11 of the draft EIS. Mitigation measures, including
rerouting sewer corridors, are listed in Table 4-15 of the draft EIS.
The routing of sanitary sewers shown in Plate 5 has been for planning
purposes. Site surveys during the design phase will determine exact
locations.
2. The comment has been noted and incorporated in the final EIS.
R-43
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R-DB-1
^98«8B
North Carolina Department of Cultural Resources
James G. Martin, Governor
Patric Dorsey, Secretary
Division of Archives and History
William S. Price, Jr., Director
March 2, 1990
Mr. Heinz 0. Mueller, Chief
Environmental Policy Section
U.S. Environmental Protection Agency
Revion IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: Draft EIS, Durham-Eno River Wastewater
Facilities, Durham County, CH 90-E-0000-0444
Dear Mr. Mueller:
We have received notification from the State Clearinghouse concerning
the above project.
In terms of archaeological resources, the information contained in your
document is out of date and the site location map should not have been
included. The site location information was supplied to the staff of
the Triangle J Council of Governments in 1985 with the understanding
that this information was not to be made available to the general public
or to be published. According to North Carolina General Statutes 70-13,
the locations of archaeological sites are confidential to avoid the risk
of harm to the resources. Publication in a public document such as the
draft environmental impact statement is definitely harmful to the
preservation and integrity of the archaeological resources in question.
Plate 12 and any other specific locational references to archaeological
resources should be deleted from this document prior to the publication
of the FEIS.
In the future, your staff should consult with the State Historic Preservation
Office concerning potential project effects upon archaeological resources
rather than rely on second-hand information which may or may not be
correct.
The area of the Northside wastewater treatment plant has been surveyed
previously by an archaeologist and the expansion will have no effect
upon archaeological resources. The DEIS shows the location of several
pumping stations, force mains, and gravity sewers that may have an
adverse effect upon such resources. We recommend that those facilities
outside of existing rights-of-way be surveyed by an experienced archaeologist
prior to project construction.
109 East Jones Street • Raleigh, North Carolina 25MM 27601-2807
R-44
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Page Two
Enclosed is a list of archaeological consultants who have conducted or
expressed an interest in conducting contract work in North Carolina.
Individual files providing additional information on the consultants may
be examined at the State Historic preservation Office's Office of State
Archaeology, 421 North Blount Street, Raleigh. If additional names are
desired, you may consult the current listing of the members of the
Society of Professional Archeologists, or contact the society's secretary/
treasurer, J. Barto Arnold, III, P.O. Box 13265, Austin, Texas 78711-
3265. Any of the above persons, or any other experienced archaeologist,
may be contacted to conduct the recommended investigations.
We have conducted a search of our maps and files and have located nine
structures of historical or architectural importance within the general
area of the project. Due to the nature of the proposed work, however,
we anticipate no impacts upon these historic structures.
The above comments are made pursuant to Section 106 of the National
Historic Preservation Act of 1966 and the Advisory Council on Historic
Preservation's Regulations for Compliance with Section 106, codified at
36 CFR Part 800.
Thank you for your cooperation and consideration. If you have questions
concerning the above coimient, please contact Ms. Renee Gledhill-Earley,
environmental review coordinator, at 919/733-4763.
Sincerely,
Lwviq tsrooK
Deputy State Historic Preservation Officer
DB:slw
Enclosure
cc: State Clearinghouse
R-45
-------
Letter R-DB-1
Final EIS
David Brook
State Historic Preservation
Office
1. For response to this entire letter, the reader is referred to the
following letter by Heinz J. Mueller, Chief, Environmental Policy
Section, EPA Region IV, Atlanta.
R-46
-------
^°sr4.
vT
USB
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\
'*1 PflO^t0
V
> REGION IV
ZOURTLAND STI
ANTA. GEORGI/
MAR 1 5 1990
345 COURTLAND STREET. N.E
ATLANTA. GEORGIA 30365
Mr. David Brook . Q_
Deputy State Historic Preservation oincer
North Carolina Department of Cultural Resources
109 East Jones Street
Raleigh, North Carolina 27601-2807
Re: Draft EIS, Durham-Eno River Wastewater
March 2, 1990, Comment Letter
Dear Mr. Brook:
Thank you for the referenced letter and your comments on the Draft
BIS. We appreciate the time you spent in reviewing the material, and
are pleased the project does not appear to have any impact upon
historic structures.
Your letter expressed concern that the archaeological site location
data were made available in the Draft EIS/ and that these data were
provided by the the Triangle J Council of Governments. My staff
obtained the site locations from the Durham County Inventory of
Critical Lands, published in 1985 by the Triangle J Council of
Governments. As this Inventory is a public document describing area
historical resources, my staff reasonably assumed the site data were
cleared for publication. We share your concern for the protection of
archaeological sites, and will coordinate with your office to protect
these resources.
Your letter contained the comment that our cultural resources
material was not up to date, and may or may not be correct. Further,
Your staff indicated by telephone (March 9, 1990) that more current
information would not have been forthcoming had we asked for it.
This poses for us an obvious dilemma: since new site material 1) is
not present in the Draft EIS, 2) would not have been available to us
had we requested it, and 3) was not made available to the public, it
would appear the lack of current information your stated need for
site confidentiality. We are somewhat mystified as to the basis of
this comment.
Our cultural resources data in the Draft EIS consisted of dots on a
USGS quad sheet which were displayed to determine their proximity to
wastewater treatment facilities, interceptor
facilities. Since specific street addresses of the sites were not
provided in the Draft EIS, we do not believe the security of these
resources was seriously compromised.
R-47
-------
Mr. David Brook
Page 2
I want to reiterate my offer to cooperate with your Department in
future planning on federal projects in North Carolina. Your request
for more consultation on matters concerning historical resources is
appropriate.
Sincerely, Uo-v*
Heinz J. Mueller, Chief
Environmental Policy Section
Federal Activities Branch
R-48
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04/03/90 14:15 US E.P.A. - W. D. 002
~ 922 P02
ftPR 03 '90 11:29 DEHNIR LIBRARV
R-BDV-1
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Sfrcrf * Raleigh, North Carolina 27611
Jame* G. Martin, Governor ,-,i i * n oon George T Everett, Ph.D.
William W Cobey, Jr., Secretary ' Director
Mr. John Haunilton
U.S. Environmental Protection Agency
345 Courtland Street, JUS
Atlanta, OA 30365
Dear Mr. Hamilton:
Enclosed are comments received from the North Carolina
Wildlife Resources commission and the Division of Parks and
Recreation concerning the draft Bno River EIS. Theses comments
were recevied prior to February 26, 1990. since that time we
have wet with representatives from tooth agencies and offer the
to1lowing summaries and guidance in responding to their concerns.
Wildlife Reaouroes Commianlon
WRC supports the preferred alternative but has concern®
regarding secondary impact® of the project on WRC Qamelands and
wetlands in the upper reaches of the Falls take and its
tributaries. Listed below are specifics issues of conaern to WRC.
1- Reduction of flows tc? hfadwaters of falls Lake and leys
available water in Hat creak for guMmpoun&nenti
An important feature of the Gamalands is a aeries of
waterfowl subimpoundments located along Flat Creek just upstream
from its confluence with the Bno River (highlighted in green on
the enclosed map). These are diked high ground or flood plain
lands that are to be flooded each Fall for use by overwintering
waterfowl, water is to be pumped in from Plat creek. The
ffubimpoundents are now under construction and are to be flooded
for the first time this coming Fall (October/November). Even
though the pumping sites are located upstream from the Eno> the
reach of Flat Creek from which the water would be pumped is part
of the impounded backwaters of Falls Lake, just like the lower
end of the Bno.
wrc staff are concerned that reducing the flow to the Bno
could reduce the amount of water available for pumping, although
they have no evidence that this Will or will not oocur. The US
Army Corps of Engineers designed the dikes and have information
ftitttttfcm FnrrvntJon *mym
t>n tTAJtr R.U* M.mfc Omit** TWwfcow «l»?JWOIS
R-49
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04/03/90 14:16 US E.P.A. - W. D. 003
APR 03 '90 11:30 DEHNR LIBRARY 822 P03
Mr. John Hamilton
April 2, 1990
Page 2
on the water depths in the area and the volume of water available
for pumping, TheY Should also have information on the flow rate
and capacity o£ the pumps. While DEM is not convinced that there
will be a significant problem, it is a sensitive issue that
should be addressed.
2. Construction of sewer lines across State Gamelands and
wetlands in the vicinity of Falls Lake;
For many years the Corps and State leasing agencies have
taken a strong stand against allowing roads and utility
corridors (water and sewer, natural gas, electricity) to be
constructed on or across these lands. Without such a policy, the
agencies are concerned that the resources at the site would be
become fragmented and be made more susceptible to intrusion from
dirt bikes and ATV's, serious problems elsewhere on project
lands. It is therefore recommended that the EIS inform readers
of this policy and that an effort be made to ensure that the
sewer lines shown in the BIS be routed so as not to encroach on
project lands other than along existing highway corridors.
WRC also recommends that sewer lines be routed, to the extent
possible, to avoid impacting wetlands (both on and off the
project lands), and, where impacts are unavoidable, that proper
mitigation be provided as set forth in their letter.
3. Secondary impacts of induced development encroaching
on flamelands boundarlesT
WRC has been concerned for a number of years with the
potential impact of residential development along the edge of the
Gameland areas. At the present time, hunting is allowed on these
lands; however, as more homes are built along the project
boundaries, hunter safety zones will encroach into the Gamelands
and possibly cause the elimination of hunting in some area*.
This does not appear to be an issue that can be resolved through
this EIS. Chancel are that it would eventually occur with or
without this project. It is recommended, however, that the Bis
acknowledge this as a potential long term secondary impact that
should be brought to the attention of the local governments.
4. Support for implementation of nonpoint source BMP'a.
WRC believes all efforts should be made to have nonpoint
sources BMP's implemented within the BIS project area.
Division of Parka and Recreation
The Division of Parks and Recreation (DPR) has two major
areas of concern as presented below.
R-50
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04/03/90 14:16 US E.P.A. - W. D. 004
APR 03 "90 11:30 DEHNR LIBRARY 622 P04
Mr. John Hamilton
April 2, 1990
Page 3
1.
Reduced flow in the Brio River and impacts to rare,
threatanoa and endangered Aquatic spenles.
DPR Advises that a number of listed or ..
threatened or endangered animal species may b© AJh*kit^a the
reach of the Eno below the plant discharge. In fan*, while no
recent studies have been performed to ¦determine*whether *"y
inhabit the area, DPR believes that the reach of the riv«rfe.low
the outfall could provide a unique I !? £# X«!??£ SiSS*
the Eno due to the artifically high flow of water from the plant
during extreme low flow periods.
While it is recognized that llml-Hed flow on the ®n°
oan at times be stressful to aqujtlo life, DEM £eJ;£®v** 1®
long term impacts to water quality from removing the plant would
outweigh the flow benefits. Just recently, for example, the
Plant failed its whole effluent toxicity teat due to
residual chlorine levels (0.8 wg/1) Jj®£ JjJS ?' ld ii !«*.'
in particular, are very sensitive to chlorine and would
hard by auoh events.
A spokesperson for our Biological Assessment aroup, which has
conducted many surveys of the Eno upstreamfromtheplant, has
stated that even during the extreme low fwi '
aquatic benthos in the Eno were readily d5?ina thoae
biological quality of the atrearo «aamedto^improve^ring those ^
periods meaning that biologists were able to find higher
numbers and a wider variety of poliution intolerant benthic
species. Overall, little impact would be expected from removal
of the discharge and many benefits miyht be re 1
2. Proximity of sewer lines to registered nffr^ral ayyas.
DPR is concerned that the DRIS does not vwieiwllr Jtate
what «ffartH it anv will be made to avoid registeted natural
««« It la r«eonmend«d that th« BIS b» " rlf«"(«•'
to address avoidance ot there ?J?a»* ^ ^sf2T r 3? (g? which
th« DIM ceiuir»m«nt» found in IS* SCAC (3,
-------
Letter R-BDV-1
Final EIS
W. Boyd DeVane
North Carolina Department of
Environmental Management
1. The preferred alternative will remove approximately 1-2 mgd of wastewater
flows from the Eno River and 10-12 from proposed maximum flows. This is
a positive impact since the Eno River will no longer be a receiving
stream for wastewater. There will be some reduction in flows that are
inevitable if wastewater collected in the Eno River watershed are
conveyed to the Ellerbe Creek Watershed. The more important
consideration is non-point sources continuing to be a threat to the Eno
River. Best management practices as discussed in Chapter 4 of the Draft
EIS must be put into place to reduce non-point problems. There is also
the possibility of augmenting flows on the downstream section of the Eno
River with discharges from the Little River Reservoir. Any flow
augmentation, however, would be a second priority to meeting the potable
water needs placed upon this reservoir.
2. See Response No. 1, R-LS-1.
Additionally, efforts will be made to avoid impacting wetlands. However,
if it becomes necessary to cross a wetland, the required permits will be
obtained and mitigation will be established.
3. Section 3.3.2.9 of the Draft EIS - Archaeological, Historical, and
Recreational Resources, discusses the secondary impacts of a population
increase. It is acknowledged that the growth impacts in the area could
eliminate hunting in many areas.
4. Elimination of failing on-lot systems will reduce much of the non-point
source pollutants. Section 4.3.1 - Surface Water Resources of the DEIS
states that:
"Although non-point sources contribute more than 50 percent of the
TP load, the lower degree of bioavailability associated with
R-52
-------
Letter R-BDV-1
Final EIS
W. Boyd DeVane
North Carolina Department of
Environmental Management
non-point phosphorus and its infrequent input (i.e., during storm
events) make it potentially less important than point source
controls".
Section 4.4 of the Draft EIS discussed the use of BMP's as a mitigative
factor in reducing non-point source pollution.
5. See Response No. 4, R-CD-1.
Additionally, every effort will be made both during and after
construction of the proposed project to avoid identified natural areas.
Compliance with the North Carolina Department of Natural Resources can be
expected.
K-53
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04/03/90 14:17
APR r '50 11:31 DEHNR LIBRARY
US E. P. A. - W. D.
005
^ North Carolina Wildlife Resources Commission
512 N. Salisbury Street, Raleigh, North Carolina 27611, 919*733-3391
Charles R, Futlwood, Executive Director
MEMORANDUM
TO I
FROM:
Melba McGee, Planning and Assessment
Dept. of Environment/ Health &*Natural Resources
DATE«
SUBJECT!
Richard D. Hamilton
Assistant Director
February 23, 1990
QiCkiA-i & fc)fcM^5Vs
Durham-Eno River Wastewater Facilities EIS,
Project #90-0444, Durham County, North Carolina.
The Wildlife Resources Commission (WRC) has reviewed
the Environmental Impact Statement (EIS) and biologist® on
our staff are'famillar with habitat values of the project
area. Our ooaAents are provided in accordance with
provisions of the North Carolina Environmental Policy Act
(G.S. 113A-1 et seq., as amended; 1 NCAC 25 and the Fish and
Wildlife Coordination Act (48 Stat. 401, as amended; 16
V.S.C• 661 et seq•)•
Of the alternatives proposed in the EIS, the WRC
supports the preferred alternative N-EC. However, we have
several concerns with potential impacts to wildlife,
associated habitat and possible mitigation.
One of these concerns is the alteration to the flow
regime of the Eno River by elimination of the wastewater
discharge. While such elimination will improve water
quality in the Eno River, it will also result in a 55
percent flow reduction during low flow'conditions. The WRC
has several waterfowl impoundments nearing completion in the
area - specifically on Little River and Flat River. These
impoundments utilise stream water for filling and any
diminution of supply, particularly in low water situations,
will drastically affect project operation. We feel this
impact has not been thoroughly addressed from a mitigation
R-54
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04/03^90 14:IS
APR 03 '90 11:32 DEHNR LIBRARY
US E. P. A. - w, p.
822 P06
006
Memo Page 2 February 23, 1990
standpoint, Wg recommend mitigation in the form of water
allocation from either wells or municipal water supply to
flood these impoundments should the need occur.
Construction of sewage conveyance lines with proposed
crossings of Falls Lake Gamalands, wetlands and/or flood
plains should be rerouted and primary and secondary impacts
resulting from unavoidable circumstances should receive a
high degree of mitigation as defined in the sis. A
mitigation alternative to consider is to require land use
2oning|that 'Would create a no-development buffer adjacent to
gamej^Ms which would help protect these valuable
recreational lands from secondary impacts associated with
inoreisito development.
Wetlands loss should b^jnitigated, in, accordance with
the WRC jaitigation policy, and any lar$6^ Reived should;'
be prp^fci^lj-against'¦¦iyfeMHdevelopj^ •l'a«s§and
placerfftander' wRC jurisdiction. ' We ''aisd.^'r#6opiand,thl£,^''
conveyance line right-of-ways be revegatated'tfith plant
speoies''compatible with wildlife habi€l$;?ahKancemi^^'''•
§ms>, strongly, uygas,, implementat^pn, ^Aha, B|§g\..
tvplans (BMP) tQ:»ot»ot:..aqa4^1il?afl^oAj|it^am^»ii
Afi" Withou£;;&4'£^
ftlrpr' compliance fcheMe valuable a<|f$p[a in
ct area will undergo significant environmental"
degradation.
> i j. \ •«, /» ¦
Thank you for the opportunity to review and comgte,nt on
this Ek project. if we can provide further assistance-,
please oall on US.
RBH/lp
co: Denny Baumbarger# wildlife Management.Coordinator
Roger Jones, District 5 Fisheries Biologist
Larry Warlick, District 5 Wildlife Biologist
R-55
-------
Letter R-RH-1
Final EIS
Richard Hamilton, Assistant
Director
North Carolina Wildlife
Resources Commission
1. While it is true that there will be a predicted 55 percent flow reduction
in the Eno River by the elimination of the wastewater discharge during
low flow conditions, the Section 4.1 states that:
"Water quality improvements to the Eno River and Little Lick Creek
will occur when the existing wastewater discharges are eliminated.
Ellerbe Creek water quality improvement is expected during low flow
conditions because of flow augmentation by the highly treated
wastewater effluent. These water quality improvements should also
have a positive impact on the Eno River, Ellerbe Creek, and Little
Lick Creek headwaters of Falls Lake".
Recommending water allocation for the waterfowl impoundments is probably
beyond the scope of the EIS.
2. See Response No. 1, R-BDV-1.
3. See Response No. 2, R-BDV-1.
Additionally, an effort will be made to revegetate any impacted areas
with species compatible with wildlife habitats.
4. See Response No. 4, R-BDV-1.
R-56
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P>4/03/90 14:18
APR 03 '30 11:32 PEHNR UBRRRY
US E. P. ft. - y. D.
007
822 P07
R-CT-1
,n..
State of North Carolina
Department of Environment, Health, and Natural Resources
Dlvlilon of ftrlw and Reawtan
512 North Salisbury Street • Raleigh, North Carolina 27(511
u" *¦ S
February JO, 1990
M&ORANDUM
M«lba McGefe *
FROM. Carol Tinglsy £
SUBJECTr 90-0444 EPA DEIS, Durham-Eno River Wastewater Treatment Plant
The Division of Park* and Recreation has reviawad tha Craft. Environmental
mpaot Statement for the Durham-Eno River Wastewater Treatment Plant and
•rvica Area, U* have two major concerns with the project a* proposed:
adverse impacts to equatic species in the Bno Rivar resulting from reduced
ow volume*i and, adverse impacts to significant natural areas resulting from
construction of conveyance lines.
^guatit'i falfflPtT
^^v*rting wastewater discharge from the Eno Rivar to Bllerbe Creek
ouid Improve the river's water quality, the detrimental impacts of reduced
owvolumes on the river's squatio communities could actually outweigh any
enafita. Section 4,3,1 of the DEIS states that removing the existing dis-
8n 'ron ®no Riv*r would result in a 55% reduction in water flow in the
~v° during low-flow conditions. Low-flow periods are the time of greatest
woil«#v0n tha fauna, so a flow reduction of the proposed Magnitude
# VBry si®"ifleant. Furthermore, the predioted reduction was calculat-
or current conditions\ future additional reductions in Eno River flow may
suit from meeting the increased water demands of northern Orange and Durham
bounties.
flow conditions are alreedy creating environmental problema in tha
.. v,, ' According to the Eno River Capacity Use Investigation conduct-
D *not Pltad the DEIS), current levels of monthly flow, measured
to « baseline established from record* between 1941 and 1970, have
lRBIII tiaJ i _ > . _ . _ ^ < a . ^ . m *
__ —. ^
—WW that the existing situation i« the river's ^aP4\lty^
habitat, and that continue low °°dul0Ve7 8-n* ft* (Main ReP°tt, ^
support populations of Roanoke bass _ ^37),
River Area Capacity Use Investigation,
R-57
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04/03/90 14:19 US E. P. ft. - u. p. 00Q
APP 03 '90 11:33 DEHNR LIBRARY 022 PBS
Melba McGee
February 19, 1990
Pag« Two
The aquatic communities that would be affected by the reduction in flow
contain a number of threatened or significantly rare species of anigals, not
adequately rscognieed in tha DEIS. Table 4-8 of tha VZ18 list* only four
animaU of special significance the roanoke bass (Awblopl^taa cavlfrons).
Carolina madtom (Noturus furlosus), notched rainbow rauasal (Villosa
constricts). »nd Atlantic pigtoe mussel (foscanala masonl). Although none of
thaaa were designated as listed species, reflecting conditions existing At the
tine of the Durham County Inventory (Sutter, 1987), legal protection is now
being adopted by the State of North Carolina for all these species except for
the notched rainbow. The roanoka bass end Caroline aadtoa are both proposed
for Special Concern status, while the Atlantic pigtoe Is considered Threatened
within North Carolina, and is also a possible candidate for Federal listing
(John Alderman, Piedmont Project Leader, Nongeaa and Endangered Wildlife
Program; per*, coam.).
N&w listings are also proposed for a number of other specie. recorded from the
Eno River, but not mentioned in the DEIS. The new listings are baaed on
recant, more complete research into the status of the populations and habitats
of these species. The green floater muasel (Uttiftona. aniridia) is orat>o**d
as State Endangered; tha yellow lampmuaael (LamproJog;d aB
State Threatened i and the Neuee River waterdog (Ke&t^gSS^Siaii) proposed
as Special Concern. In addition to these species already* recorded for the
Eno, several others that have been proposed for Hating can also be expected
to occur in the Eno (John Alderman, pers. comm.). These include the trianola
floater (^wnid^U HSJkiH*). brook floater (Alesmidhnt* verrucosa). Ld
squavfoot (BtropMVf unM^uy), all of which are proposed f orSt^^reat-
ened status. There is also an historic record for tha dwarf vedsa mussel
(4iiilataSSSaa) fro® the Little River. This is a candidate for
federal Endangered status and ahould also be carefully looked for in the Eno
before any further environmental degradation takes place (J. Alderman, pars,
conan.).
Many of the above species are highly vulnerable to extreme or chronic low flow
conditions. Recent studies have shown that many of these species are alreadv
in severe decline throughout the state due to extensive habitat disturbances
Therefore, flow reductions in the lower Eno River could result in
Mta. to th. p««,tun, "
flow reductions, the two positive effects on,aquatic eoanuni^e.
mentioned in the OBIS are comparatively alniv. First, the water auslity
enhancement this project would bring about for Ellerbe Creek is a«2t!
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... 04/03/90 14:20 us E.p.A> _ UiD_
APR 03 '90 11:34 DEHNR LIBRARY 022 P09
Melba McGee
February 19, 1990
Pag# Three
The potential significance of these effects on aquatic communities has been
largely overlooked in the DElt), Table 4-J2 lists as » mitigation for reduced
flow the possibility of reducing upstream watar withdrawal* and increasing
upstream flow augmentation. Because of tha significant impacts of flow
traduction, we would like to see a detailed discussion of the feasibility of
these mitigation measures, the effactlvtntSS of such measures in minimising
the effects of the proposed flow diversion, and the means by which a commit-
ment to these measures can be insured. Any approval of the propose^ project
should be contingent on the concurrent implementation of adequate mitigation.
If tha proposed mitigation measures cannot adaquataly compensate for the
anticipated flow reduotion, additional project design alternatives which do
not involve total removal of tha Eno River discharge need to be considered •
Seyer Line Construction
Our second major conoern with the proposed project relatea to the potential
for damage to terrestrial communities due to construction of new sewer lines.
While these secondary impacts would follow from the adoption of any of the
alternative plans described in the DEI9, the preferred plan would affect the
greatest number of sites. As shown in Table 3-12* areas that would be affect-
ed under the N-EC plan include portions of the Eno River State Park* Falls of
the Neue* Came lands, River forest Park» Eno Greenway, and six natural areas
included in the Durham County Inventory: Willie Duke's Bluff* Wanderlust
Diabase Uplands, Cabin Branch Bottomlands, Cub Creek Greenway, Little River
Corridor, and Eno River Corridor•
In the discussion of mitigation efforts, tha DEIS suggests that "conveyance
line routes should be planned so that they do not impact these natural areas,
especially the Falls Lake Lands used for gsme lands" (p. 4-18). There is an
EHC regulation that prohibits all construction of sewer Unas or extensions on
sites listed on the State Registry of Natural Areas unless the N.C. Environ"
mental Management Commission agrees that no prudent, feasible or technologi-
cally possible alternative exists (T15< 02H.0205 3E). This regulation applies
to Willie Duke's Bluff, Cabin Creak Bottomlands, and sections of the Bno Rivar
State Park, all of which have been ragisterad. It may also come to apply to
other sites included on tha abovo list.
We not* that the sewer line routes shown in the.DEIS are not alwaye consistent
with tha City of Durham's recent sewer line rotate proposal. Sinoe alternative
sewer line routes are not presented or disoussed in tha DBIS, we assume that
tha routes shown in the document are not meant to indicate the final route
selection, but only to show a possible alternative. If thia is the case, the
DBI8 should make this clear, so that approval of tha routes shown In the
document is not implied. Selection of sewer line routes should undergo a
separate, detailed environmental review, complete with an evaluation of
environmentally less damaging alternatives. If the eoonomic or technological
viability of the proposed treatment plant alternative is dependant on the >
siting of any conveyance line through a natural area, so that future evalua-/
tlon of alternatives would be constrained, that should be stated, /
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04/03/90 14:21 _US E. P. A. - Ul. D. 010
ftPf? 03 '90 21:34 DEHNR LIBRARY 822 P10
Melba McGee
February 19, 1990
Pag® Four
We Are also concerned about the offsets nf increased development prasaure on
rare species and significant natural area* in the project's service area.
Improved mechanisms for protecting theaa areas ahmild go hand hand with any
actions that would result In accelerated development.
In summary, the proposed project may result, in an improvement in water quality
for the Eno River, and we agree that the alternative of expanding the Eno
River wastewater plant to a 12 mgd discharge would be detrimental, tfeverthe-
less, the impacts of the project on aquatic communities in the river and
terrestrial cottounitieie along the sewer lines .are potentially of major
significance. Both of these issues need further evaluation of alternatives
and clarification of mitigative measures.
Thank you for th® opportunity to review this project.
cct Charlea Roa, Natural Heritage Program
5111
R-60
-------
Letter R-CT-1
Final EIS
Carol Tingley
State of North Carolina
Department of Environment,
Health, and Natural
Resources
Division of Parks and
Recreation
1. For response to the issues raised concerning both aquatic impacts and
sewer line construction, the reader is referred to Letters R-BDV-1 and
R-CJ-1 and the responses to those letters.
R-61
-------
Ub/ll/ya 10:^6 US E .P.O. -W.D.
State of North Carolina
Department of Environment, Health, and Natural Resources
DMslon of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
May 30, 1990
Mr. John Hamilton
Environmental Policy Section
Federal Activities Branch
Environmental Protection Agency, Region IV
345 Courtland street
Atlanta, Georgia 30305
Dear Mr. Hamilton:
We have reviewed the draft version of the Final Environmental
Impact Statement and have the following comments. We hope these
comments will provide enough information to enable the consultant
to prepare the final document. However, we ask that we he
informed as soon as possible of any problems that you or the
consultant see that could deter its completion. Also, we would
appreciate you letting us know when all the changes have been
made and document is complete.
11.) On page ES-2, the statement on line 10 on "two existing
ordinances" should be written to give an better idea of
what those ordinances are. Also, the "15 NCAC 28.0211" on
line 19 should read "15A NCAC 2B .0211".
On page 4-18, section 4.3.3, the statement on line 10
says the conveyance line routes should "not impact these
natural areas." It should be made clear what "impact"
means. Is this "do not cross" or "do not adversely
impact"?
3.) on the response to letter r-jc-1, the 50 mg/1 should read
5.0 mg/1. Also, the 5,400 and 8,400 dry tons per day
(item 3.) seem to be in error. Are these dry tons per
year? Item 6 should be modified from "NCDEM may want to
pursue a variance" to "the city of Durham may...".
4.) In the Agency response to letter R-SC-2, I have attached
a proposed response to number five for consideration.
Muttm hivwMlw hyi
I>nw 776R7 RxMtrh Nort* Ovotlrw Z?61t-766? T«tephorx 919-735-7015
R-62
George T. Everett, Ph.D.
Director
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06/11/90 10:26 US E. P. P. - Ul. D. 003
Mr. John Hamilton
May 30, 1990
Page 2
5.) In the Agency response to letter R-CJ-l, number 1, the
third sentence should be rewritten to read as follows:
"At this time, neither EPA nor NCDEM anticipate the need
for «n additional EIS prior to the issuance of a permit
for the 29 mgd expansion." Also, the Table referenced as
Table 1 is missing station ul as an upstream monitoring
location for part B, June-September sampling
requirements.
6.) In the response to letter R-CD-1, a proposed EIS response
to item number I is attached as provided in Trevor
Clements' May 24, 1990 letter to Boyd DeVane. (The other
comments in the letter have been incorporated in the
above responses.)
7.) In response to letter R-BDV-l, item 1, it is probably
correct to say that the preferred alternative will remove
approximately 1-2 mgd of wastewater from the Eno River
(10-12 from the proposed maximum flows), since the
existing flow from the Eno plant is less than 2 mgd, your
response should be reworded to more precisely provide
this information.
If you have any
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06/1l/ye
lid: 27
US E. P. A. - U.D.
005
DIVISION OF ENVIRONMENT AT. MANAGEMENT
May 2U, 1990
M EM QUANDUM
To i
Boyd DeVane
From i
Trevor Clements
Subjecti Durham-Eno River Final EIS Review
Per your request* I have reviewed the Final. CIS for the
Durham-ENO River Service area. Focus was placed on review and
comment, t.o the letter* submitted to HPA regarding the draft
EIS and EPA's subsequent response. Th<» following comments are
offeredi
Regarding the response to Jim Clark CR-JC -1)<
Item 6 - Should modify "NCDEM may want t:n pursue a variance"
to "the City of Durham may ...."
Regarding the response to Chester Jenkins
-------
Letter R-ST-1
Final EIS
Steve Tedder, Chief
Water Quality Section
North Carolina,
Division of Environmental
Management
1- All of the comments and responses in this letter have been incorporated
with the final revision of the Final EIS.
R-65
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Public Hearing Responses
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Public Hearing Responses
R-FS-1 Frank Smiley, Chamber of Commerce in Durham
R-KR-1 Ken Reckhow, Associate Professor of Water Resources at Duke
Univeristy
R-BH-1 Becky Heron, Vice Chair of Durham County Board of Commissioners
PH-1
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recommendation of the EIS is the Northside plant with a
capacity of 29 million gallons per day, then it should be
recommended that a permit be issued for this amount. The
concerns for water quality modeling could be addressed in
such a permit through conditions written into the permit
that would require the necessary monitoring and modeling
prior to the issuance of the authorization to construct
facilities beyond the existing permitted capacity of 20 MGD.
In this way, all the parties concerned would have a clear
understanding of what would be required prior to further
expansion of the Northside plant.
I would like to personally thank you and the
Environmental Protection Agency and the North Carolina
Division of Environmental Management and your consultant,
JGannett Fleming, Environmental Engineers, for the tremendous
effort put forth in preparing this environmental impact
statement. I truly believe that the final outcome of this
process has resulted in the selection of an alternative that
will be good for both the City of Durham and the protection
af our environment. Thank you.
PRESIDING OFFICER HAMILTON: Thank you, Terry.
Mr. Smiley, would you like to speak?
STATEMENT OF FRANK SMILEY
MR. SMILEY: Mr. Chairman, my name is Frank
Smiley with the Chamber of Commerce in Durham. And unlike
(Mr. Smiley's question is on the next page of transcript.)
PH-2
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the fi.rst speaker tonight who has yet to disclose to any of
us whether Save the Water represents one person or maybe as
many as three or four. I want you to understand that the
Greater Durham Chamber of Commerce represents over 1,500
businesses in the county and over 3,500 individuals. Our
directory list is available for you and the public at any
time.
I want to speak to you tonight only in support of
the statement just presented by Terry Rolan, particularly
in the section where he said that he would like to suggest
that if a final recommendation of EIS is a northside plant
with a capacity of 29 MGD, then it should be recommended
that a permit be issued for this amount.
We in the Chamber of Commerce strongly support
that proposal from the City of Durham. Thank you very much.
PRESIDING OFFICER HAMILTON: Thank you, sir.
Dr. Reckhow.
STATEMENT OF DR. KEN RECKHOW
DR. RECKHOW: My name is Ken Reckhow. I'm an
Associate Professor of Water Resources at Duke University,
and I'd like to start out by complimenting John Hamilton and
EPA and the Division of Environmental Management, as well as
Gannett Fleming for — for a superb job. I thought that the
report was first rate and the patience and deliberations
over the course of our study and the work with the committee
, „ 4-hf» next page of transcript.)
(Dr. Reckhow's question is
PH-3
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Letter R-FS-1
Final EIS
Public Meeting
Frank Smiley
Chamber of Commerce in
Durham
1. See Response No. 1, R-TR-1.
PH-4
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R-KR-1
21
«ras excellent.
I'd like to use the opportunity — this
apportunity to raise a couple of issues with regards to
tfaste water treatment in Durham. The first issue is that I
tiope that in the future that the public presentations of the
Dond issue — the bond referendum by the City correctly
notes the fact that a portion of the cost of the waste water
treatment plant, both this as well as Harrington, is
associated with growth. And a portion is associated with
our — our need to meet state and federal water quality
standards, but a portion is associated with growth.
And I think it's important that the citizens of
Durham are aware of the fact that there is a cost to growth.
And in making their decision with regards to the bond, they
explicitly accept that, if, indeed, the bond is approved.
That's one issue.
The second issue I would like to use this
spportunity to raise is that if the 20 MGD plant is approved
and built on Ellerby Creek that, we use the opportunity
after that plant is in place and after we have acquired some
water quality data on the impact of that discharge on
Ellerby Creek, we use those data and we use that opportunity
bo study and model the impact of the 20 MGD plant on the
receiving water bodies and we, in turn, use that to make a
judgment concerning whether or not the proposed 29 MGD is
PH-5
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Letter R-KR-1
Final EIS
Public Meeting
Ken Reckhour
Associate Professor of Water
Resources at Duke
University
1. See Response No. 1, R-TR-1 and Response No. 1, R-CJ-1.
PH-6
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R-BH-.1
32
you have a transcript of what...
MR. HARRISON: Yeah. Do you want one or two?
PRESIDING OFFICER HAMILTON: One would be
sufficient.
(Mr. Harrison proffers document to Hearing Officer
Hamilton.)
PRESIDING OFFICER HAMILTON: Thank you very much.
Ms. Register, would you like to speak? I have
you down as a "maybe."
MS. REGISTER: No.
PRESIDING OFFICER HAMILTON: Okay.
All right. I have exhausted all of the people who
wished to speak as they registered. Are there any people
who would like to make any comments at this time?
MS. HERON: I would.
PRESIDING OFFICER HAMILTON: Yes, ma'am.
STATEMENT OF BECKY HERON
MS. HERON: I'm Becky Heron and I'm Vice Chair of
the Durham County Board of Commissioners. And I just
wanted to bring out just two or three concerns that I have
and I think probably the Board has, but specifically/
myself. I feel that any new capacity that will become
available because of the expansion of the plants/ that this
should go to neighborhoods with failing septic tanks and
also to areas that property has not been developed because
PH-7
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it did not meet the requirements for septic tanks.
My second concern is the — in your report, I
believe you stated that there could be a substantial
increase in water rates with these future expansions. And
that is a concern of mine also. The impact that this will
have on low income people and that I just don't think the
rate payers need to subsidize these new expansions that
would go to new development. They certainly should pay
their fair share.
I also feel that as the Eno plant is phased out,
that it should be completely closed and removed from the
site so there's no temptation to go back. And any package
plants in the service area should be — the use of those
plants should be discontinued and closed out and removed so
that they would come under this new capacity and we would
not have the problems that we are having now in certain
parts of Durham County with package plants.
Those are my comments. Thank you.
PRESIDING OFFICER HAMILTON: Thank you very much.
Are there any other people that wish to make any comments at
this time? Terry.
STATEMENT OF TERRY ROLAN
MR. ROLAN: I'd like to just clarify one point.
Mr. Andrews referred to the City Engineering Department at
Parrish Street. That is the County Engineering Department
PH-8
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Letter R-BH-1
Final EIS
Public Meeting
Becky Heron
Vice Chairman of Durham
County Board of
Supervisors
1. See Response No. 2, R-GA-1.
2. See Response No. 1, R-GA-1.
3. The Eno River Wastewater Treatment plant would be converted to a pumping
station. Dismantling of the current facility is really a decision by the
City of Durham. However, it is assumed that the Eno River plant would no
longer have a valid NPDES permit from NCDEM. Users of package treatment
plants would be required to be a part of the new systems just as homes
with failing septic systems would be required to join the new wastewater
collection system.
PH-9
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Letters Not Requiring A Response
-------
Letters Not Requiring a Response
iNK-tis-i Hazen and Sawyer, Demonstration Landfill Project
NR-HS-2 Hazen and Sawyer, Design Criteria for Eno Pump Station and Force
Main
NR-HS-3 Hazen and Sawyer, CKD Pilot Unit
NR-SC-3 David Howells, Sierra Club, Water Quality Chair
NR-CR-1 Dempsey Benton, Jr., City of Raleigh, City Manager
NR-CR-2 Avery Upchurch, City of Raleigh, Mayor
NR-1
-------
NR-HS-1
YW HAZEN AND SAWYER, p.c.
/jSj^ \ CONSULTING ENGINEERS
January 3, 1990
Mr. J. Gordon Layton, Head
Solid Waste Section
Dept. of Environment, Health, and
Natural Resouces
P.O. Box 2091
Raleigh, NC 27602-2091
Re: City of Durham
Demonstration Landfill Project
Dear Gordon:
Enclosed please find a draft conceptual plan for a demonstration
landfill project for the City of Durham, NC. The intent of the project is to
investigate the viability of co-disposal of sludge with municipal solid waste
on a relatively small scale and under controlled conditions. We feel that the
information and knowledge obtained through this project will be extremely
beneficial to the State as a whole since many municipalities are presently
faced with the difficult task of funding alternative means of sludge disposal.
We respectfully request your review of this conceptual plan; and if your
schedule permits, we would like to set up a meeting 1n mid January to discuss
1t further and answer any questions you or your staff maiy have. Please give
me a call after you have had a chance to review the plan, and we can arrange a
meeting. Please feel free to distribute copies of the plan to other
Interested Divisions within the Department of Environment, Health, and Natural
Resources.
Needless to say, we are very excited about this project and look forward
to working very closely with you and your staff as 1t develops. Thank you for
your time and consideration.
Very truly yours,
HAZEN AND SAWYER, P.C.
Robert S. D1F1ore, P.E.
Vice President
RSD/jhl
Enclosures
cc: Mr. Terry Rolan
Mr. Tom Glenn
Mr. Tom Bastable
Mr. Gordon Ruggles
Mr. M1ke Hebert
Ms. Terrl Compton
WOWKTWASe BOULEVARD . SUTTES50 • RALEGH, NC 27607 . (919)833-7152 • FAX |S19) 833-1828
WMHKNC OWOTT6.MC NEWKMTNEWS.VA MOU.YWOOO.R. «W«M(.NV
NR-2
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Conceptual Plan for a Demonstration
Co-disposal Landfill Project ^
City of Durham, North Carolina
($0
^"3^™^«S^SSKK?~Sssss
demolition landfill. The City is presently n ajs0 inciudes provisions Oranae County.
SSS3SSS »^J?SSSS!»2B3K,—»«
®TPO) of solids are generated with ove M the municipal solid waste landfll. Incorporate
J" the past, the City disposed of
^'Q sludge with dally and final cover rnQ groundwater c®n*®*52__i» of Health - Solid and
<*ea throughout the State. Concerns rattle*L®„,ptedthe State Depa^omeain ^
^ ESSTS&d as an Interfm *dg. <*»-
disposal of sludge In a liquid or solid ^rryV „fl d
Method unttr long-term options can be Identlfle
SLUDGE MANAGEMENT PLAN t expansions, a comprehen-
^ P>Qrt of the City's long-term planning ^or?^!^Qptoind disposal
^sludge management plan, includingtreatrn forsludgerrlanl2®^.m*/ m-vesselcomposting,
^ evaluating both short- and looo-t^eCCHjlsposal with MSW, irwess
p^®^on the economic evaluations o^^'j^JJ^'cwi^o^aSMs'racorTirnended for the short
tam^S3 Sewage Sludge Requirements, the
Wpta"); „ contract opera10' to augment and provide back-up to the
• Continue land application byxo"Ja
Intermediate and long-term disposal p
HAZEM AND SAWYER. EC. JjJ
EngtaMi*
NR-3
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ISSUED FOR REVIEW ONLY
. Implement cement-kiln-dust (CKD) stabilization facilities at both the Northside and Farrington
Road Wastewater Treatment Plants. The CKD process will be utilized as a primary means of
sludge disinfection and stabilization, and will condition the sludge to a form where it can be
more readily marketed and/or disposed of. It is the intent that CKD stabilization could continue
to be used for back-up regardless of which long-term disposal alternative is implemented,
. Pursue co-disposa! of sewage sludge with MSW as a primary disposal means for stabilized
(digested) sludge and a secondary means of disposing CKD stabilized sludge.
CO-DISPOSAL WITH MSW
As previously discussed, the practice of disposing sewage and water plant sludges in MSW landfills was
widely used in North Carolina prior to the ban on this method in March, 1989. Since that time several
municipalities have been forced to find alternative disposal methods, and many have turned to contract
land application programs. However, rising costs, competition for available land, proposed tighter
restrictions on sludge application rates, and other factors have created much concern relative to
long-term success of this disposal method and have compelled municipalities to look toward other,
more reliable disposal methods to augment and/or backup their land application programs.
Much has been written in the past relative to the advantages and disadvantages of co-disposal. As
new landfills are constructed with positive groundwater protection features such as synthetic liners and
leachate collection systems, many concerns relative to co-disposal should be minimized. The ad-
vantages of this alternative include:
• An economically viable method to dispose of digested and/or CKD stabilized sludge at a time
when other disposal alternatives are facing both sharp increases in cost and/or tighter
regulatory requirements.
. Provide a source of material to augment daily and final cover requirements.
. Enhance biodegradation rates, leachate quality, and gas production, reducing volume over
the long-term and providing a potential energy resource.
Although sludge Is considerably denser than compacted solid waste, the total volume generated is
relatively small compared to the total solid waste stream. Sludge will also tend to fill voids within the solid
waste cells. Based on existing sludge and solid waste generation rates, approximately 1200 cubic yards
(c.y.) of landfill volume are required per day as compared to 120 c.y. required for sludge, an ap-
proximate 10:1 ratio. This ratio would be even greater if all of or a portion of the sludge could be utilized
for daily cover.
As new hi-tech lined landfills are developed, emphasis will be placed on minimizing total surface area
to be lined, thus encouraging mounding or going up In elevation to the maximum extent practical. This
approach, however, will likety result In a shortage of available on-site cover soils requiring expensive
Importation of off-site materials. The use of digested or CKD stabilized sludge to either augment or
substitute for on-site cover soils can, therefore, provide a substantial economic benefit.
Finally, there has been considerable debate relative to the overall short- and long-term effects of sludge
on MSW landfills. Rates of biodegradation, gas production, and lmpdcts on leachate quality have been
studied, although primarily on a theoretical and/or bench scale basis. Very little full-site data is available'
especially under new hi-tech landfilllng methods employing liners, leachate collection and more
sophisticated gas monitoring and extraction systems.
V
HAZEN AND SAWYER, P.c.
Engineers
NR-4
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I
SUED FOR REVIEW ONLY
In an effort to better define and understand th©s© complex technical issues and to maintain as many
economically viable and environmentally sound alternatives for both sludge and solid waste disposal,
the City proposes to develop a demonstration co-disposal landfill project. It is intended that the project
be a cooperative and coordinated effort between the City's Water Resources and Sanitation Depart-
ments, the State of North Carolina, Department of Environment. Health and Natural Resources- the
academic community as well as other Interested private and public sector agencies. Including the U.S.
Environmental Protection Agency (USEPA).
demonstration landfill project
The proposed demonstration project will be a multi-celled, lined state-of-the-art landfill, designed to
accept both siudae and solid waste under several different conditions. Special emphasis will be placed
on features to facilitate the collection of data relative to leachate quantities and quality, gas produc-
tion. etc. The primary goal of the project is to demonstrate the viability of co-disposal of sludge and solid
waste as an environmentally sound, economically attractive means for sludge disposal.
•t Is proposed mat the facility be located on a parcel of land adjacent to the Northside WWTP and the
existing city landfill (see drawing SK-1, attached). A site with approximately eight and one-half (8.5) acres
of usable landfill space is available. The site offers substantia advantages due to its close proximity to
the existing Northside treatment plant and City landfill including short haul distances, facilities for
handling and treating leachate, availability of existing equipment, i.e., compactors, excavators,
bulldozers, scales, etc., and other operational considerations.
The active landfill area will be configured to provide for as many as four (4) discrete cells to accom-
niodate different sludge and solid waste combinations. For example.one^cell may recdvewkd waste
alone, one cell may receive only sludge and others recede comMrKrttonsot_sludge CdlgesteoloXKD
stabilized) and solid waste. The residential compactor truck fracflon of the MSW stream would Be
targeted (preferably after recyclables have been removed) since It Is likely that thlsfractlon of the waste
stream will continue to be landfllled In the future.
Individual cells would generally be sized based on volumetrte ratios of the various combinations of
siudae and Mlld wa^a so that ceUs would fill over the same period. Therefore, comparative data relative
*> teaoh^ellnd<=°" eva,uated on a C0rnm0n "me Scnle'A pre"mln0,Y
layout of the cells Is Included In Sketch SK-2 attached.
The demonstration co-dlsposal land® project will provide some additional short-term benefits for both
•he City's Water Resources and Sanitation Departments, inciuaing.
• An alternative means of sludge disposal until EPA Port 503 Sewage Sudge Regulations are
finalized.
• Additional life at the City's existing landfill by diversion of a portion of the waste stream to the
demonstration site.
- . . .. c». trine can be used as a cover (or mixed with natural soils) In
' Thlswlflallow so*dem0ns1ra,l0n
landfill to be utilized at the existing landfill where mounding is being practiced.
_l. .i. i. MHno nnd "hands-on" experience with the construction, opera-
' ™ln™ceofllners.teachate,^ Pr'°rt°
Ing those systems on a much target and costlier scale m the future.
HAZEN AND SAWYER, p.c. 1*7
nr_5 Engineer# /Ml
-------
ISSUED FOR REVIEW ONLY
r
PROJECT PARTICIPATION COSTS AND FUNDING
In order for the project to be Implemented, it must gain the full support of the Department of Environment,
Health and Natural Resources, since the practice of co-disposal is presently not allowed under Solid
Waste Branch regulations. The information and knowledge obtained from this project may provide
significant benefits to other counties and municipalities throughout the State. Through the State, the U.S.
Environmental Protection Agency should be consulted to not only gain their support on a technical basis
but also explore the funding potential of an Innovative project of this nature.
It Is further proposed to utilize environmental engineering students from the academic community to
aid in the comprehensive sampling, monitoring and testing programs that will be required. Private sector
support and involvement should also be sought through liner material suppliers, etc., since this would
provide them with an excellent forum to demonstrate their products under a variety of conditions.
Preliminary capital costs for an 8.5-acre demonstration landfill project are estimated at approximately
$1,580,000 Including engineering and contingencies. This is somewhat higher on a per-acre basis than
a full-scale (100+ acre) landfill since economies of scale are not realized for such a small facility. Assuming
24,500 wet tons of sludge and approximately 148,000 tons of solid waste are disposed of over the life of
the landfill, the capital cost for disposal would equate to approximately $9.16/ton exclusive of operating
costs.
In summary, co-disposal of sludge with solid waste may be an environmentally sound and cost-effective
means of sludge disposal for many municipalities across the State. For small municipalities it may be the
only affordable means of sludge disposal. With all new MSW landfills requiring positive groundwater
protection including liners and leachate collection systems, several of the previous environmental
concerns relative to co-disposal are minimized.
The City of Durham is committed to developing long-term solutions to both sludge and solid waste
disposal. Tens of millions of future dollars will be spent by both the Water Resources and Sanitation
Departments in Implementing their respective long-term disposal methods. This is an opportune time to
give strong consideration to all viable alternatives that integrate sludge and solid waste disposal.
SUMMARY
V
HAZEN AND SAWYER, p.c. Tfl
Engineers L&*
NR-6
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ISSUED f OR Q*«
Capital Cost Estimates for an 8.5 Acre Demonstration Landfill
Cost per Usable Acre = $186,000
Item
TInif
Onantitv
Total Dollars
Land Acquisition
10,000/AC
14
140,000
Access Roads/Paving
LS
—
30,000
Liner System (Single, 60 MIL)
50,000/AC
8.5
425,000
Leachate Collection
25,000/AC
8.5
212,500
Leachate Pumping
LS
—
80,000
fencing
25/LF
4,000
100,000
Monitoring Wells
3,000 EA
8
24,000
Site Clearing
5,000/AC
8.5
42,500
Stormwater Retention/
Erosion Control
LS
—
40,000
Liner Earthwork
20,000/AC
8.5
170,000
Subtotal
1,264,000
®ngineering and Contingencies @
25%
316,000
Total
SI.580.000
;iR-7
HAZEN AND SAWYER, p.c. Yf7
Engineer# LWLl
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EXHIBIT SK-I
HAZEN AND SAWYER. P.c.
Consulting Engineers
RALHQH, NORTH CAROLINA
CITY OF DURHAM
DEMONSTRATION LANDFILL PROJECT
LOCATION MAP
NR-8
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EXHIBIT SK-2
HAZEN AND SAWYER, PC.
Consulting Engineer*
RALBGM. NORTH CAROLINA
CITY OF DURHAM
prunKISTRATlON LANDFILL PROJECT
CELL LAYOUT
NR-9
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NR-HS-2
YW7HAZEN AND SAWYER, p.c.
\ CONSULTING ENGINEERS
DATE: December 7, 1989
MEMORANDUM
TO: Northside STP File
FROM: Don Cordell
SUBJECT: Design Criteria for Eno Pump Station and Force Main
Based on the anticipated outcome of the Eno EIS, wastewater from the Eno
basin, including Treyburn, will be pumped to the Northside STP. This memo
develops preliminary design criteria, operating protocol and suggests sizes
for the Eno to Northside force main.
Existing and Future Facilities
Flows from the following pumping stations are considered:
P.S. "G" - existing interim pump station at Treyburn; will be
replaced by future P.S. "A" at Treyburn. Pumps into
existing 12-inch force main.
DTI - proposed temporary pump station to serve Durham Tech at
Treyburn; will be replaced by future P.S. "A" at
Treyburn. Pumps into existing 12-inch force main.
P.S. "A" - future permanent pump station at Treyburn. All
wastewater from Treyburn will ultimately be tributary to
this station.
Eno P.S. - proposed pump station that will replace existing Eno STP
Lutraville - existing pumping station at Eno Industrial Park that
discharges to gravity sewer tributary to existing Eno
STP. Treyburn P.S. "C" and "TB" currently pump to this
station. These flows will be rerouted to P.S. "A" at a
future date.
4000 WESTCHASE BOULEVARD • SUTTE560 • RALEIGH, NC 27607 . (919) 833-7152 • FAX (9191833-1820
"«»t« CHARWTTENC NEWPORT NEWS, VA HOUYWOOO.Fl. NEWYOAKNV
NR-10
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Memorandum to Northside STP File
December 7, 1989
Page 2
A 12-inch force main is in service from Treyburn to the existing Eno STP.
From Infinity Rd. at Snowhi11 Rd. to the southwestern boundary of Treyburn, a
30—in pipe intended for the permanent force main from Treyburn is in place and
currently in use as a potable water line feeding Treyburn. This line can be
converted to wastewater service when flows dictate.
Design Objectives and Assumptions
The City desires to minimize series pumping, particularly in the case of flows
from Treyburn P.S. "A". Given the existing or proposed location of the major
pump stations, it is reasonable and economical to share a common force main
from the Eno STP to the Northside plant. Initial flows from pump station G
and DTI at Treyburn will be repumped at Eno. Once pump station A at Treyburn
is on-line, the Eno P.S., P.S.A at Treyburn and lutraville will share a common
force main to the Northside STP. Force mains, pumps and wet wells should be
sized such that pumps at each station move along their respective pump curve
to adjust to the total flow in the force main possible under any combination
of pumps. No other interlocks between pump stations would be required under
this scenario.
Dfislon Wastewater Flows
, . .u. cnn FT5 with input from H&S based
Design flows are generally derived from t ^ ^ ^
on anticipated development of Treyburn. ^ ^ ^
average dally flow. Flows were ^ m phased tmpUme„tat1on
conditions represented by three variation Ra,Pd on the
of P.S. A at Treyburn and ultimate
present rate of development at
-------
Memorandum to Northside STP File
December 7, 1989
Page 3
DESIGN FLOWS IN MGD
Initial
Condi tion
Initial
Condition
Ini tial
Condition
Year
2010 Ultimate
ADF PHF ADF PHF
Pump Station "A"
ADF PHF
ADF PHF
Treyburn "G" 0.44 1.1
DTI
0.05 0.135
Treyburn "A" — 0.6a 1.6a 3.0 7.5 3.0 7.5 3.0 7.5
a Hydraulic limit of 12-inch FM
Force Main Routing and Profile
Force main from Eno to Northside assumed to parallel existing gravity sewer
from Eno to Old Oxford Highway (SR 1004) and then parallel County Hamlin Road
project to a point east of Ellerbee Creek and then parallel to Creek on City
property to Northside plant. Additional R/W requirements expected to be
minimal, if any. Alternate routings not considered. Plan of force main route
included as Attachment No. 1.
Profile from P.S. G to Northside STP included as Attachment No. 2.
Controlling high point occurs near the intersection of Old Oxford Highway and
Hamlin Road. (See related discussion under Hydraulic Considerations.)
Hydraulic Considerations
Force main data is as follows:
Eno
6.0 15.0 6.0 15.0 6.0 15.0 9.0 22.5 20 50
Prior to P.S. "A" P.S. "A" P.S. "A"
Construction on-line use on-line use
use 12-inch FM 12" FM 30" FM
Trevburn P.S. A Eno P.S.
Total Length
to interconnection
to high point
Hazen and Nil Hams "C"
33,000 ft.
11,200 ft.
21,000 ft.
110
24,800 ft.
3,000 ft.
12,800 ft.
110
inR-12
-------
Memorandum to Northside STP File
Oecember 7, 1989
Page 4
Preliminary pipeline sizes were selected based on the following criteria:
Maximum velocity at PHF: 6-8 fps
Maximum TDH - + 200 feet; Limited by maximum head for non-clog pumps
Selections are as follows:
Trovhnm to Eno Enp to NQrth?ide
Initial Condition "A" 12
Initial Condition "B" 12
Initial Condition "C" 30
Year 2010 30 n
Ultimate 30 36 + 30
r * T»/Mih„rn tn Fnn are based on previous design work with
Force main sizes for Treyburn to too die
,i .. . . ... nlat.e several combinations were considered
all or portions of each line in place.
for the Eno to Northside section.
Based on anticipate Initial flow conditions, the Eno force main must be at
least 30-inch diameter to limit T0H to less than 200 ft. (See Attachment
for head conditions based on 24-1nch.> If a 30-1nch line Is provided
additional pipe capacity will be needed by the design year of *0 °. Max,.Um
total flow through the 30-1nch line for a TDH of 200 feet would be 26-27 mgd
-------
Memorandum to Northside STP File
December 7, 1989
Page 5
be selected based on the highest TDH condition that would prevail when both
pump stations are on-line. When either station pumps alone, the discharge
rate would increase along the characteristic pump curve. TDH determinations
should be adjusted based on ground profile surveys of the final force main
route.
Design conditions would be as follows:
P.S. "A" Eno P.S.
0
TDH-
•feet
0
TDH-
¦feet
mad
Alone
Combined
mad
Alone
Combi m
Initial Condition
"A"
—
—
15
116
—
Initial Condition
" B"
1.6
143
157
15
116
119
Initial Condition
"C"
7.5
108
131
15
116
130
Design 2010
7.5
108
149
22.5
134
153
Ultimate
7.5
106
165
50
162
176
Lutraville flows are assumed to be introduced into the common force main
downstream of the controlling high point. Attachment 4 also indicates the
available flow that can be introduced at this point without influencing the
hydraulics for P.S. "A" or Eno. The minimum flow under any condition (2.3
mgd) is significantly greater than flows anticipated from the Lutraville
station.
Downsizing of the force main beyond the high point was also evaluated (see
attachment 5). If the pipe size were reduced to 30-inches, flow from
Lutraville would influence Eno/P.S. A hydraulics by the year 2010.
Maintaining the force main at 36-1nches avoids this complication and this
approach 1s recommended.
Minimum Pumping Rate
Given the size of the Initial force main relative to actual flows expected
when the system Is placed Into service, 1t will not be practical to maintain
scouring velocities during the early service year*. For large diameter force
mains, experience on other projects (primarily Florida) Indicates that low
initial velocities do not complicate system operation or compromise
performance. Velocities of 0.5 fps have been used successfully. To the
NR-14
-------
Memorandum to Northside STP File
December 7, 1989
Page 6
extent that deposition does occur, local velocities within the line would
increase based on the effective pipe cross-section. Given this experience,
pumping rates of 2-2.5 mgd are considered acceptable and can be used for pump
selection. Design capacities will probably dictate higher pumping rates.
Variable Speed Pumping
While it is of potentially less significance for the early year flows, the
range of flows expected is such that variable speed pumping equipment should
be provided at the Eno and perhaps at P.S. A as well. Variable speed will
become mandatory at the higher flows since the force main will terminate at
the Northside Plant with no opportunity for peak, attenuation. For a multiple
pump design, it would not be necessary for every unit to be equipped with
variable speed. If at least two units were variable speed (for mechanical
redundancy), additional units could be constant speed.
NR-15
-------
-------
Oi-Dec-89
(1) Inftlal Condition A => Before Punp Station A
System Characteristics fro* Eno River to Northside
Flow Pipe D Length Velocity Static H TDH
(MGD) (in.) (ft.) (ft/sec) (ft.) (ft.)
ADF 6 24 12800 3.0 100 128
PHF 15 24 12800 7.4 100 217-
2-4 &to Vv
N4
scssustsssissssesssssstUKtsssss
(2a) Initial Condition B » Pump Station A
System Characteristics for 12" Force Main.
ADF
PHF
Flow
(MGD)
0.6
1.6
0.6
1.6
Pipe D
(in.)
12
12
12
12
length Velocity
(ft.) (ft/sec)
11200 1.2
11200 3.2
11200 1.2
11200 3.2
Coofcine PSA Flow with
Eno River Flow
Additional Total
Flow
(HGO)
6
15
0
0
Flow
(HGO)
6.6
16.6
0.6
1.6
Pipe
Dia.
(in.)
24
24
24
24
Length
(ft.) (ft/sec)
9800 3.3
9800 8.2
9800 0.3
9800 0.8
Velocity Static H
(ft.)
95
95
95
95
TDH
(ft.)
122 A*-
250-»—
103
144
SSSS8SSS8S8SSSS£SSSSSSSSSStSSSSS3SBt88S8S8tS88StlSSS8SSSSSSSSSS8S3SSSSSS8SS8SS8::sSSS58SS3SSS:S:SS::sS:s:
(2b) Initial Condition B «> Eno Pump Station
System Characteristics from Eno to Northside
Conbined Eno River Flow with P.S. A Flow
53
5*9
I
ADF
PHF
Flow
(MGD)
6
15
6
15
Pipe D
(in.)
24
24
24
24
Length Velocity
(ft.) (ft/sec)
3000 3.0
3000 7.4
3000 3.0
3000 7.4
Z4-
TV#
Additional Total Pipe
Flow Flow Dia.
(MGD) (MGD) (in.)
0.6 6.6 24
1.6 16.6 24
0 6 24
0 15 24
Length Velocity Static H
(ft.) (ft/sec) (ft.)
9800 3.3 100
9B00 8.2 100
9800 3.0 100
9800 7.4 100
TDH
(ft.)
125
235-
121
217
(3a) Initial Condition C -» Pump station A
System Characteristics for 30" Force Main.
Flow Pipe D Length Velocity
(MGD) (in.) (ft.) (ft/sec)
ADF 3 24 11200 1.5
PHF 7.5 24 11200 3.7
3 24 11200 1.5
7.5 24 11200 3.7
(3b) Initial Condition C => Eno Pimp Station
System Characteristics from Eno to Northside
ADF
PHF
Flow
(MGD)
6
15
6
15
Pipe D
(in.)
24
24
24
24
Length Velocity
(ft.) (ft/sec)
3000 3.0
3000 7.4
3000 3.0
3000 7.4
Combine PSA Flow with
Eno River Flow
Additional Total Pipe
Flow Flow Dia.
(MGD) (MGD) (in.)
6 9 24
15 22.5 24
0 3 24
0 7.5 24
Length Velocity Static H
(ft.) (ft/sec) (ft.)
9800 4.4 95
9800 11.1 95
9800 1.5 95
3.7 95
9800
Combined Eno River Flow with P.S. A Flow
TDH
(ft.)
135
312 -
105
148
Additional
Total
Pipe
Static
Flow
Flow
Dia.
Length
Velocity
Head
TDH
(HGO)
(MGD)
(in.)
(ft.)
(ft/sec)
(ft.)
(ft.)
3
9
24
9800
4.4
100
140
7.5
22.5
24
9800
11.1
100
316
0
6
24
98D0
3.0
100
121
0
15
24
9800
7.4
100
217
-------
30-Nov-89
<1) Initial Condition A => Before Pump Station A
System characteristics from Eno River to Northside
Flow Pipe 0 Length Velocity Static H TDH
(MGD) (in.) (ft.) (ft/sec) (ft.) (ft.)
ADF 6 36 12800 1.3 100 104
PHF 15 36 12800 3.3 100 116
p*fe. //&
(2a) Initial Condition B =>
Pump Station A
Combine PSA Flow with
System
Characteristics for
12" Force Main.
Eno River Flow
Additional Total
Pipe
Flow
Pipe D
Length Velocity
Flow ; Flow
Dia.
Length
Velocity
Static H
TDH
(MGD)
(in.)
(ft.) (ft/sec)
(MGD) * (MGD)
(in.)
(ft.)
(ft/sec)
(ft.)
(ft.)
ADF
0.6
12
11200 1.2
6 6.6
36
9800
1.4
95
105
PHF
1.6
12
11200 3.2
15 16.6
36
9800
3.6
95
157
0.6
12
11200 1.2
0 0.6
36
9800
0.1
95
103
1.6
12
11200 3.2
0 1.6
36
9800
0.4
95
143
Add. Q
fSlaywittm <3? (frtw lufrtH/tUc*
^ C/lea*/
30.3
20.3
36.3
35.3
(2b) Initial Condition B -> Eno Pump Station
System Characteristics from Eno to Northside
Flow Pipe 0 Length Velocity
(MGD)
(in.)
(ft.)
(ft/sec)
ADF
6
36
3000
1.3
PHF
15
36
3000
3.3
6
36
3000
1.3
15
36
3000
3.3
Combined Eno River Flow with P.S. A Flow
Additional
Total
Pipe
Flow
Flow
Dia.
Length
Velocity
Static H
T0H
(MGD)
(MGD)
(in.)
(ft.)
(ft/sec)
(ft.)
(ft.)
0.6
6.6
36
9800
1.4
100
103
30.3
1.6
16.6
36
9800
3.6
100
119
20.3
0
6
36
9800
1.3
100
103
30.9
0
15
36
9800
3.3
100
116
21.9
00
H
I
pei
S3
(3a) Initial Condition C => Pump Station A
System Characteristics for 30" Force Main.
Flow
Pipe D
Length
Velocity
(MGD)
(in.)
(ft.)
(ft/sec)
ADF
3
30
11200
0.9
PHF
7.5
30
11200
2.4
3
30
11200
0.9
7.5
30
11200
2.4
Combine PSA Flow with
Eno River Flow
Additional Total Pipe
Flow Flow Dia. Length Velocity Static H T0H
(MGD)
(in.)
(ft.)
(ft/sec)
(ft.)
(ft.)
6
9
36
9800
2.0
95
102
27.9
15
22.5
36
9800
4.9
95
131
14.4
0
3
36
9800
0.7
95
97
33.9
0
7.5
36
9800
1.6
95
108
29.4
(3b) Initial Condition C => Eno Pump Station
Combined Eno River
Flow with P.S. A
Flow
System
Characteristics from Eno to Northside
Additional Total
Pipe
Static
Flow
Pipe D Length Velocity
Flow Flow
Dia. Length
Velocity
Head
TDH
(MGD)
(in.) (ft.) (ft/sec)
(MGD) (MGD)
(in.) (ft.)
(ft/sec)
(ft.)
(ft.)
ADF
6
36 3000 1.3
3 9
36 9800
2.0
100
106
27.9
PHF
15
36 3000 3.3
7.5 22.5
36 9800
4.9
100
130
14.4
6
36 3000 1.3
0 6
36 9800
1.3
100
103
30.9
15
36 3000 3.3
0 15
36 9800
3.3
100
116
21.9
-------
FtfUt/
jtMcLeAMLO**/- 4
fye Z//3
30-NOV-89
(4a) Year 2010 => Punp Station A System
System Characteristics from PSA to Northside
ADF
PHF
Flow
(MGD)
3
7.5
3
7.5
Pipe 1
Dia.
(in.)
30
30
30
30
Pipe 2
Dia
(in.)
0
0
0
0
Velocities
(ft/sec)
Eq Pipe 0
(in.)
30.0
30.0
30.0
30.0
Length
(ft.)
11200
11200
11200
11200
V 1
0.95
2.37
0.95
2.37
V 2
0.00
0.00
0.00
0.00
Addtional Total Pipe Static
Flow Flow Dia. Length Velocity Head TDH «—
(MGD) (MGO) (in.) (ft.) (ft/sec) (ft.) (ft.) *
9 12 36 9800 2.6 95 105 24.9
22.5 30 36 9800 6.6 95 149 6.9
0 3 36 9800 0.7 95 97 33.9
0 7.5 36 9800 1.6 95 108 29.4
fd+jttniumt tpf/renvl
r*3orv*.')
(4b) Year 2010 =>
Eno Pimp Station System
Combined Eno River
Flow with
P.S. A Flow
System
Characteristics from Eno to Northside
Velocities
Pipe 1 Pipe 2
(ft/sec)
Addtional
Total
Pipe
Static
Flow
Dia. Dia Eq Pipe D
Length
V 1 V 2
Flow
Flow
Dia.
Length Velocity
Head
TDH
(MGD)
(in.) (in.) (in.)
(ft.)
(MGD)
(MGD)
(in.)
(ft.) (ft/sec)
(ft.)
(ft.)
ADF
9
0 36 36.0
3000
0.00 1.97
3
12
36
9800 2.6
100
110
24.9
PHF
22.5
0 36 36.0
3000
0.00 4.93
7.5
30
36
9800 6.6
100
153
6.9
9
0 36 36.0
3000
0.00 1.97
0
9
36
9800 2.0
100
106
27.9
22.5
0 36 36.0
3000
0.00 4.93
0
22.5
36
9800 4.9
100
134
14.4
(5a) Ultimate Flows => Punp Station A System
System Characteristics from PSA to Northside
ADF
PHF
Flow
(MGD)
3
7.5
3
7.5
Pipe 1
Dia.
(in.
.)
30
30
30
30
Pipe 2
Dia
(in.)
0
0
0
0
Velocities
(ft/sec)
Eq Pipe D
(in.)
30.0
30.0
30.0
30.0
Length
(ft.)
11200
11200
11200
11200
V 1
V 2
0.9
2.4
0.9
2.4
0.0
0.0
0.0
0.0
Addtional
Flow
(MGD)
Velocities
(ft/sec)
(5b) Ultimate Flows => Eno Pump Station System
System Characteristics from Eno to Northside
Pipe 1 Pipe 2
Velocities
(ft/sec)
Flow
Dia.
Dia
Eq Pipe D
Length
V 1
V 2
(MGD)
(in.)
(in.)
(in.)
(ft.)
ADF
20
36
30
43.2
3000
2.7
2.4
PHF
50
36
30
43.2
3000
6.8
6.0
20
36
30
43.2
3000
2.7
2.4
50
36
30
43.2
3000
6.8
6.0
Combined Eno River Flow with P.S. A Flow
Addtional
Flow
(MGD)
3
7.5
0
0
Total
Flow
(MGD)
23
57.5
20
50
i
C6
SZ
Total
Pipe 1
Pipe 2
Eq. Pipe
Flow
Dia.
Dia.
Dia.
Length
V 1
V 2
TDH
l
(HGD)
(in.)
(in.)
(in.)
(ft.)
(ft.)
20
23
36
30
43.2
9800
3.1
2.8
108
36.8
50
57.5
36
30
43.2
9800
7.8
6.9
166
2.3
0
3
36
30
43.2
9800
0.4
0.4
97
56.8
0
7.5
36
30
43.2
9800
1.0
0.9
106
52.3
Velocities
.
(ft/sec)
Pipe 1
Pipe 2
Eq. Pipe
Dia.
Dia.
Dia.
Length
V 1
V 2
TDH
(in.)
(in.)
(in.)
(ft.)
(ft.)
36
30
43.2
9800
3.1
2.8
114
36.8
36
30
43.2
9800
7.8
6.9
176
2.3
36
30
43.2
9800
2.7
2.4
111
39.8
36
30
43.2
9800
6.8
6.0
162
9.8
-------
250
240
230
220
210
200
190
180
170
160
150
140
130
120
110
^t> Ft*)
System Curve -
Flows from PSA
Jfyp Jo
Eno Pump Station (2010)
/=^< 3//3
•> 3.0 - 7.5 MGD
o
CM
t
&
55
7.5 MGD from PSA
16 20
O No Flow from PSA
-------
280
270
260
250
240
230
220
210
200
190
180
170
160
150
140
130
120
110
100
+
-------
124
122
120
118
116
114
112
110
108
106
104
102
100
System Curve For Eno Pump Station
Eno Pump Station Prior to PSA
Cvl
CSI
I
oS
z
~
Flow (MGD)
All flow from Eno
-------
380
360
340
320
300
280
260
240
220
200
180
160
140
120
100
80
+
System Curve For Pump Station A
Initial Condition 8
Flow (MGD)
15.0 MGD from Eno O No Flow From Eno
-------
121
120
119
118
117
116
115
114
113
112
111
110
109
108
107
106
105
104
103
102
101
System Curve For Eno Pump Station
Initial Condition B
n 1
2
1.6 MGD from PSA
n 1 r
6 8
Flow (MGD)
10
12
~T
14
11
O
No Flow from PSA
-------
TJ
O
U
X
~
c
Q*
0
|—
System Curve For Pump Station A
135
130
125 -
120 -
115 -
110 -
105 -
100 -
95 -<~
Initial Condition C
-------
134
132
130
128
126
124
122
120
118
116
114
112
110
108
106
104
102
100
-h
Fn***
System Curve For Eno Pump Station ^
Initial Gondition C
Flow (MGD)
7.5 MGD from PSA o No Flow from PSA
-------
-------
System Curve - Eno Pump Station (2010)
Flows from PSA => 3.0 — 7.5 MGD
Flow (MGD)
7.5 MGD from PSA o No Flow from PSA
-------
170
160
150
140
130
120
110
100
90
System Curve — Pump
Flows from Eno —> 20
Station
- 50 MGD
A (Ult.)
50 MGD from Eno
Flow (MGD)
O No Flow from Eno
-------
180
170
160
150
140
130
120
110
100
+
FtMJ
System Curve - Eno Pump Station (Ult.)
Flows from PSA — > 3.0 — 7.5 MGD
Flow (MGD)
7.5 MGD from PSA O No Flow from PSA
-------
06-Dec-89
(1) Initial Condition A => Before Pump Station A
System Characteristics from Eno River to Northside
ADF
PHF
Flow
(MGD)
6
15
Pipe D Length
(in.) (ft.)
36 12800
36 12800
Velocity Static H TDH
(ft/sec) (ft.) (ft.)
1.3 100 104
3.3 100 116
h+**
I
Add.
w/ d=
3#
20.3
36.3
35.3
3a"
I
Q Add. Q
w/ d=
1#
6.3
22.3
21.3
(2b) Initial Condition B => Eno Pump Station
System Characteristics from Eno to Northside
Combined Eno River Flow with P.S. A Flow
Additional
Total
Pipe
Add. Q Add. Q
Flow
Pipe D
Length
Velocity
Flow
Flow
Dia.
Length
Velocity
Static H
TDH
w/ d= w/ d=
(MGD)
(in.)
(ft.)
(ft/sec)
(MG0)
(MGD)
(in.)
(ft.)
(ft/sec)
(ft.)
(ft.)
36 30
ADF
6
36
3000
1.3
0.6
6.6
36
9800
1.4
100
103
30.3 16.3
PHF
15
36
3000
3.3
1.6
16.6
36
9800
3.6
100
119
20.3 6.3
6
36
3000
1.3
0
6
36
9800
1.3
100
103
30.9 16.9
15
36
3000
II
II
II
II
II
1!
II W
II •
II W
II
II
II
II
0
ssssstessssani
15
eies:i;::
36
:SSS3S8S«
9800
3.3
100
116
21.9 7.9
(3a) Initial Condition C ¦> Pump Station A
System Characteristics for 30" Force Main.
ADF
PHF
Flow
(MGD)
3
7.5
3
7.5
Pipe D
(in.)
30
30
30
30
Length
(ft.)
11200
11200
11200
11200
Velocity
(ft/sec)
0.9
2.4
0.9
2.4
Combine PSA Flow with
Eno River Flow
Additional
Flow
(MGD)
6
15
0
0
Total
Flow
(MGD)
9
22.5
3
7.5
Pipe
Dia.
(in.)
36
36
36
36
Length
(ft.) (ft/sec)
9800 2.0
9800 4.9
9800 0.7
9800 1.6
Velocity Static H TDH
(ft.) (ft.)
95 102
95 131
95 97
95 108
Add. Q Add. O
(3b) initial Condition C => Eno Pump station
System Characteristics from Eno to Northside
ADF
PHF
Flow
(MGD)
6
15
6
15
Pipe D
(in.)
36
36
36
36
Length Velocity
(ft.) (ft/sec)
3000 1.3
3000 3.3
3000 1.3
3000 3.3
Combined Eno River Flow with P.S. A Flow
t
Addi tional
Flow
(MGD)
3
7.5
0
0
Total
Flow
(MGD)
9
22.5
6
15
Pipe
Dia.
(in.)
36
36
36
36
Length
(ft.)
9800
9800
9800
9800
Veloci ty
(ft/sec)
2.0
4.9
1.3
3.3
Static
Head
(ft.)
100
100
100
100
TDH
(ft.)
106
130
103
116
w/ d=
36
27.9
14.4
33.9
29.4
Add. Q
w / d=
36
27.9
14.4
30.9
21.9
w/ d-
30
13.9
0.4-
19.9
15.4
Add. O
w/ d=
30
13.9
0.4 -
16.9
7.9
(A
Z
^ o.$ C/<
fadSfecf t&fV'
gk.
-------
06-Dec-89
(4a) Year 2010 => Pimp Station A System
System Characteristics from PSA to Northside
ADF
PHF
Flow
(HOD)
3
7.5
3
7.5
Pipe 1
Dia.
(in.)
30
30
30
30
Pipe 2
Dia
(in.)
0
0
0
0
Velocities
(ft/sec)
Eq Pipe 0
(in.)
30.0
30.0
30.0
30.0
Length
(ft.)
11200
11200
11200
11200
Addtional
Total
Pipe
Static
Add. Q
Add. Q
1
V 2
Flow
Flow
Dia.
Length
Veloci ty
Head
TDH
w/ d=
u / d=
(MGD)
(MGO)
(in.)
(ft.)
(ft/sec)
(ft.)
(ft.)
36
30
0.95
0.00
9
12
36
9800
2.6
95
105
24.9
10.9
2.37
0.00
22
5
30
36
9800
6.6
95
149
6.9
-7.1
0.95
0.00
0
3
36
9800
0.7
95
97
33.9
19.9
2.37
0.00
0
7.5
36
9800
1.6
95
108
29.4
15.4
(4b) Year 2010 => Eno Pump Station System
System Characteristics from Eno to Northside
ADF
PHF
Flow
(MGD)
9
22.5
9
22.5
Pipe
Dia.
(in.)
Pipe 2
Dia
(in.)
36
36
36
36
Eq Pipe D
(in.)
36.0
36.0
36.0
Combined Eno River
Flow with
P.S. A Flow
Veloci ties
(ft/sec)
Addtional
Total
Pipe
Static
Add. 0
Length
V 1
V 2
Flow
Flow
Dia.
Length Velocity
Head
TDH
w/ d=
(ft.)
(MGD)
(MGD)
(in.)
(ft.) (ft/sec)
(ft.)
(ft.)
36
3000
0.00
1.97
3
12
36
9800 2.6
100
110
24.9
3000
0.00
4.93
7.5
30
36
9800 6.6
100
153
6.9
3000
0.00
1.97
0
9
36
9800 2.0
100
106
27.9
3000
0.00
4.93
0
22.5
36
9800 4.9
100
134
14.4
(5a) Ultimate Flows => Pimp Station A System
System Characteristics from PSA to Northside
Velocities
ADF
PHF
Flow
(MGD)
3
7.5
3
7.5
Pipe
Dia
(in.)
30
30
30
.30
Pipe 2
Dis
(in.)
0
0
0
0
Eq Pipe D
(in.)
30.0
30.0
30.0
30.0
Length
(ft.)
11200
11200
11200
11200
Velocities
Addtional
Total
Pipe 1
Pipe 2
Eq. Pipe
Static
V 1 V 2
Flow
Flow
Dia.
Dia.
Dia.
Length
V 1
V 2
Head
TDH
(MGD)
(MGD)
(in.)
(in.)
(in.)
(ft.)
(ft.)
(ft.)
0.9 0.0
20
23
36
30
43.2
9800
3.1
2.8
95
108
2.4 0.0
50
57.5
36
30
43.2
9800
7.8
6.9
95
166
0.9 0.0
0
3
36
30
43.2
9800
0.4
0.4
95
97
2.4 0.0
0
7.5
36
30
43.2
9800
1.0
0.9
95
106
Combined Eno River
Flow with
P.S. A Flow
Velocities
Velocities
(ft/sec)
(ft/sec)
Addtional
Total
Pipe 1
Pipe 2
Eq. Pipe
Static
V 1 V 2
Flow
Flow
Dia.
Dia.
Dia.
Length
V 1
V 2
Head
TDH
(MGD)
(MGD)
(in.)
(in.)
(in.)
(ft.)
(ft.)
(ft.)
2.7 2.4
3
23
36
30
43.2
9800
3.1
2.8
100
114
6.8 6.0
7.5
57.5
36
30
43.2
9800
7.8
6.9
100
176
2.7 2.4
0
20
36
30
43.2
9800
2.7
2.4
100
111
6.8 6.0
0
50
36
30
43.2
9800
6.8
6.0
100
162
(5b) Ultimate Flows => Eno Putp Station System
System Characteristics from Eno to Northside
ADF
PHF
Flow
(MGO)
20
50
20
50
Pipe 1
Dia.
(in.)
36
36
36
36
Pipe 2
Dia
(in.)
30
30
30
30
Eq Pipe D
(in.)
43.2
43.2
43.2
43.2
Lengili
3000
3000
3000
3000
-------
NR-HS-3
WHAZEN AND SAWYER, p.c.
fjft \ CONSULTING ENGINEERS
January 26, 1990
Mr. Arthur Mouberry, Regional Supervisor
Department of Environment, Health 4
Natural Resources
Division of Environmental Management
3800 Barrett Drive
Room 101
Raleigh, NC 27609
Re: CKD Pilot Unit
City of Durham, NC
Dear Mr. Mouberry:
In response to your request for more Information pertaining to the
cement kiln dust (CKD) sludge stabilization pilot unit to be demonstrated at
the wastewater treatment plants In Durham, NC, we have enclosed the following:
Equipment description Including a brochure on the batch mixer and a
sheet of photos of the pilot unit.
Process description.
Site plans showing proposed location of pilot unit and heat curing
area at both Morthslde and Farrfngton Road WWTP. Existing sand
drying beds will be used for the heat curing areas at both plants.
Runoff from these areas Is collected and returned to the head of
the treatment plant.
An area next to the existing drying beds w171 be paved to accommodate
the pilot unit at Northslde. Drainage from this area will be collected and
drained to the existing subnatant lines from the drying beds. The area will
be used for sand storage In the future.
NR-33
-------
Mr. Arthur Mouberry
January 26, 1990
Page 2
We are requesting approval to operate the unit at the Northside and/or
Farrington Road WWTP for 30 to 90 d^ys at a processing rate of approximately
100 wet tons of sludge per day. The City of Durham will monitor and record
the temperature, pH and solids concentration of the treated sludge for the
duration of the pilot test. The stabilized sludge will then be distributed to
the general public and various city and state organizations such as Parks and
Recreation and NCDOT. Written information clearly stating appropriate uses
and warnings regarding N-V1ro soil will accompany all sludge distributed.
If you have further questions, please call.
Very truly yours,
HAZEN AND SAWYER, P.C.
Robert S. DiFiore, P.E.
Yice President
RSD/jhl
Enclosures
cc: Mr. A.T. Rolan
Mr. Tom Glenn
Mr. Gordon Ruggles
Ms. Terri Compton
NR-34
HAZEN ANO SAWYERpC
-------
CEMENT KILN DUST PILOT FACILITY
CITY OF DURHAM, NC
Equi pment Descri pti on:
One McLanahan 15 cy Batch Mixer, Truck Mounted (Brochure Attached)
One 1,000 cf Fastway Self-Erecting Portable Silo complete with dust
collector, metering valve, and 12" screw auger
Process Description:
Dewatered sludge from the stockpile (approximately 30 percent solids
concentration) 1s loaded 1n the batch mixer with a front-end loader. Cement
kiln dust (CKD) 1s metered Into the mixer with the 12" screw auger at a ratio
of approximately .3 tons CKD per wet ton of sludge. The mixture 1s thoroughly
blended and removed from the mixer with a built-in drag chain conveyor.
The mixed material is then transported with front-end loaders to the
heat curing area and allowed to heat cure ^t a minimum of 52 degrees C for at
least 12 hours. The pH will be maintained at 12 or above for 72 hours. The
treated sludge will be dried to a minimum of 50 percent solids, thereby
producing N-Y1ro Soil PFRP.
HAZEN AND SAWYER, pc
NR-35
-------
CONTINUOUS
AND BATCH-TYPE
SLUDGE MIXERS
-------
McLANAHAN PL
BLEN DM ASTER.
p0R CONTINUOUS MIXING.
and 3naflan ^lendmaster Pu9 Mixers put power
tj durability to work in a variety of mixing applica-
carjS F°r dePencJat,'l'ty and overall processing
c Pability, it can't be beat for mixing sludge with wood
aisPs 0r other bulking agents for composting. It can
tion provide uniform mixing required in lime stabiliza-
n sludge for soil additive or land fill applications.
P^SIGN FEATURES AND BENEFITS.
I a'®ndrnaster box is fabricated from steel plate, ribbed
, nd "anged for maximum rigidity.
anged hopper accommodates attachment of
, Uxi|iary chutes or hoppers provided by others.
shafts of structural steel pipe have steel screw
9nts equipped with renewable wearing shoes
feed end. Shafts are flanged at both ends for
*asy maintenance.
® bolt-on paddles are high carbon steel,
p^-treated to a Brinell of 500 to 600.
• A bases are welded to the shafts.
sh r'Ction bearin9s support paddle
" 'aits. Bearings are mounted outboard
' Th Sealecl with Spirolox ring seals.
e Blendmaster is V-belt driven by two
°tors mounted on adjustable base
ates. Variable speed drives are
arable. Drive can be located
, p eecl or discharge end.
r°tective top covers over entire
'Xing sections are removable for
a'ntenance and inspection.
Six*
Capacity
TPH 9
Motor Hoc*«pow«r
a i«nn apy—
WdgM
Liu
Untnr
4 700 *
an
? m 20
9.000 #
i*n
P rffl 30
11 800 #
11C\
? at 40
14 700 1
aa- * ?n'
M5 _
? at so
24.500 t
Pug Mill capacity is directly prop°n,0M« .u «
o! final mixture and paddle shaft h.p.m.
(Shown with
covers removed)
Optional Vent
NR-37
-------
JL
MILL MIXERS.
BATCH MIXER.
FOR INTERMITTENT MIXING
Versatility in a mixer provides several options for
customer requirements. That's why McLanahan's
30" x 15' Batch Mixer is available in stationary and
portable designs to meet your specific needs. A port-
able unit, powered by a diesel or tractor PTO engine,
can be trailer mounted and outfitted with rubber tires
for plant mobility. The stationary batch mixer is
powered by an electric motor.
DESIGN FEATURES AND BENEFITS.
• The Batch Mixer can handle up to 405 cubic feet of
feed material having a combined bulk density of
50# per cubic foot.
• The Mixer box is fabricated from steel plate at
ends, sides and bottom also using steel plate to
assure maximum strength and rigidity.
• Two paddle shafts with weld-on carbon steel paddles
are flanged for easy maintenance.
• Anti-friction bearings support paddle shafts.
• Drag chain conveyor advances mixed material to the
discharge end smoothly and efficiently with sturdy
conveyor flight bars. Drag chain and discharge door
are hydraulically powered for continuous reliable
operation.
» The unit is hydraulically operated via conveniently
located operator controls. Each shaft is indepen-
dently powered by a shaft-mounted reducer which is
equipped with its own hydraulically operated gear
motor.
• Optional trailer, fabricated from structural steel
channels and heavy-duty pipe, is among a number of
additional features which may be specified,
depending upon your job requirements.
NR-38
-------
BLENDMASTER.
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batch mixer.
V^ —
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Mct.anahan
CORPORATION
200 Wall Street, Hollidaysburg, PA 16648
(814) 695-9807 TELEX: 866602
Australian Licensee: Noyes Bros. Pty. Ltd.,
Sydney, N.S.W.
08m.,
Printed in USA
NR-39
-------
-------
%
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p-
ir*
-------
Muoirnjv sunt
ULOWmZT 1HMU1UI r*a/TT
tmmTuna u
fifT HAZEN AND SAWTER. r.c.
CJTY OF DURHAM, N. C.
DEPARTMENT OP WATER RESOURCES
FARRfNGTON ROAD WWTP
GENERAL PLANT SITE
LA TOUT PLW*
JUC 'WW
A*"
-------
NR-SC-3
In xf°l,a' Gr°"PS
Nor*h Carolina
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footic
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Shelby
CAP|LFf"vr group
'¦niington
Cap'Tal group
Raleigh
Pip^EntRal
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Ch:irlottc
C°A*rAL «ROUP
Ne* Bern
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Urham
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,r°L*nsboro
TRIANGLE
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SS
-------
- 2 -
remains, however, a possibility of another mistake remains.
It was noc clear from your response, incidentally, whether the
Division required the installation of standby power at that
pump station or whether the corrective action simply applies
t o new permit s.
An even more troublesome problem involves local government
land use decisions in areas bordered by Class C waters where
downstream WS-III waters are presumed to be protected by Par.
.0203. This was disclosed at the September 23, 1988 meeting
of the General Assembly's Watershed Protection Legislative
Study Committee. In commenting on the relative amounts of crit-
ical watershed protection areas provided to Durham's Flat and
Little River watersheds vs Raleigh's Falls Lake watershed,
Representative Joe Hackney asked for an explanation. Terry Roland,
Durham's Water Resources Director, answered forthrightly that
in the City's ordinance Durham tried to use existing stream
classifications (C) as guidance for critical watershed desig-
nation. As Representative Hackney observed, "Durham has done
a good job in protecting its watersheds." There is far less
protection provided for Raleigh's Falls Lake watershed because
of the lower C classification of adjacent waters. So, it is
perfectly clear in this situation that Raleigh's watershed is
not receiving the same protection as Durham because of the
fact that Par. .0203 does not influence local land use decisions.
All of this seems to argue for reclassification of all of Falls
Lake waters to WS-III as promptly as possible so that there can
be no further infractions of these kinds.
By copies of this letter to Mayor Avery Upchurch, Members of
the Raleigh City Council, and City Manager Dempsey Benton, I
am suggesting that Raleigh might find it in its own interest
to initiate a reclassification request to bring all Falls Lake
waters within a WS-III classification.
Thank you for your attention to this important matter.
CC: EMC Chairman Charles Baker
Mayor Upchurch
Members of Raleigh City Council
Raleigh City Manager Benton
Kim Martin Shaffer
Linda Rogers
Ed Ho 11 and
Bill Ho 1man
iill Heaton
Members WQ Comn.(drafts)
Sincerely yours, a
David H. Howells
Water Quality Chair
N.C. Chapter Sierra Club
NR-44
-------
NR-CR-1
S/Vorth Carolina
November 9, 1988
Mr. Paul Wilms, Director
N. C. Division of Environmental Management
P.O. Box 27687
Raleigh, NC 27611-7687
Subject: Reclassification of the City of Raleigh Raw Water Reservoirs
Dear Mr. Wilms:
In January of 1986 the City requested consideration by your staff of reclas-
sifying our raw water supply reservoirs (L^kes Benson and Wheeler and Falls
Lake). Your staff responded in April of that year, indicating the difficulties
in supporting the specific reclassifications we had requested for the Lakes,
but we understood your staff intended to proceed with reclassification of
all of these lakes to the highest classification they could support to the
N. C. Environmental Management Ccnmission. Recently, we have learned that
only the-lower portion of Falls Lake (fron Little^Lick Creek arm to the dam)
currently is classified as WS-III. Although the City realizes the WS-III
classification carries no discharge or watershed development restrictions
we wish to request you consider reclassification of the entire lake frem the
dam to the confluence of the Eno and Flat Rivers to maintain consistency
through the lake to WS-III.
Also, pursuant to the intent of the City Council's Resolution No. 1986-77
(cop^r attached). I wish to request on their behalf reclassification of the
various streams which are tributaries to Falls l*ke and
lake Wheeler and their various tributary streams to the highest classification
which their existing condition can be supported by staff to the N. C. Enviro
mental Management Carmission. We believe the following tributary reclassifi-
cations can be supported by your staff's investigation:
Lake Wheeler WS"[I NSW
7 e ™>eeJfr WS-II NSW
Long Branch NSW
Lynn Branch _ NSW
height Branch ^
„ f MS"" ^
Dutchman's Branch TT MCUJ
Swift Creek "S"11
ornrFS 77? wfst iiAnr.FTr sinFFt raieigh. Non?H cahoiina ?7r,o?
NR-45
-------
Lake Benson WS-II NSW
Silver Lake, Yates Mill Pond and Stream WS-II NSW
Buck Branch WS-II NSW
Reedy Branch WS-II NSW
Swift Creek WS-II NSW
Falls Lake
Beaverdam Creek WS-II NSW
Robertson Creek WS-II NSW
Reedy Branch WS-II NSW
Cedar Creek WS-II NSW
Sftiith Creek WS-II NSW
Little Beaverdam Creek WS-II B NSW
Little Beaverdam Creek WS-II NSW
New Light Creek WS-II NSW
West Prong WS-II NSW
Buckhorn Creek WS-II NSW
Mill Creek WS-II NSW
Rocky Branch WS-II NSW
Upper Barton Creek WS-II NSW
Upper Barton Creek WS-II NSW
Unnamed Tributary @ Canp Adventure WS-II B NSW
Unnamed Tributary @ Canp Adventure WS-II NSW
Lower Barton Creek WS-II NSW
Water Fork WS-II NSW
Pierce Creek WS-II NSW
Lowery Creek WS-II NSW
Horse Creek WS-II NSW
Mud Branch WS-II B NSW
Mud Branch WS-II NSW
Cedar Creek WS-II NSW
Jennys Branch WS-II NSW
Honeycutt Creek WS-II NSW
Unnamed Tributary @, Carrp New Life WS-II B NSW
Unnamed Tributary @ Canp New Life WS-II NSW
C*i behalf of the City, I wish to thank you for your consideration and coopera-
tion of this matter. If you or your staff have any questions concerning our
request, please direct them to either Carl Simnons or Dale Crisp at (919)
890-3400. We look forward to the additional protection these reclassifications
will provide to our raw water supplies water quality in the near future.
City Manager
DEBjr/spw
ccs Public Utilities Director
Assistant Public Utilities Director
NCDEM Attn: Steve Zoufaly
NR-46
-------
NR-CR-2
Qity Of Raleigh
SWorth Garolina
Fft 0 5
PEB
m
January 29, 1990
Mr. Heinz J. Mueller, Chief
Environmental Policy Section
United States Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Mueller:
On behalf of the City o£ Raleigh « »ould lite to o^end gu for
study that was done on the Eno Biver^was ewad ^ that this process
Demg a part of your review team on this project
worked quite well.
The City concurs in the findings of the draft EIS C°nS°1"
idation of the treatment facilities in northern will provide the
Northside Treatment Plant, along with the mxtxga^ve measujes^w111 provide the
best water quality protection for this upper rea
In closing I realize «*.t^his was STl
accorrrnodated in this report. The City is ry ff
thank you for all of your efforts.
City of Raleigh
ACU/spw
cc: Mayor of Durham
OFFICES • 222 WEST HARGETT STREET • RALEIGH, NORTH CAROLINA 27602
NR-47
-------
Transcript of Public Hearing
February 20, 1990 on Draft EIS
-------
1
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1
BEFORE THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
)
In the Matter of: )
ENVIRONMENTAL IMPACT STATEMENT )
)
PUBLIC HEARING
February 20, 1990
Durham City Hall
Durham, North Carolina
The above entitled matter came on for Public
Hearing pursuant to Notice at 7:03 p.m.
PRESENT WERE:
ON behalf of the Environmental Protection Agency
JOHN HAMILTON, Presiding Officer
MARK MUMMERT, EPA Contractor on EIS
BOYD DEVANE, North Carolina Division of
Environmental Management, Water
Quality Section
T-l
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Jim Clark
George Andrews
Terry Roland
Frank Smiley
Dr. Ken Reckhow
Ed Harrison
Becky Heron
Terry Rolan
2
INDEX OF SPEAKERS
Page 7
Page 15
Page 18
Page 19
Page 20
Page 22
Page 32
Page 33
T-2
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3
PROCEEDINGS
PRESIDING OFFICER HAMILTON: Good evening. This
is the public hearing meeting. My name is John Hamilton. I
represent the Environmental Protection Agency of Region IV,
and I will be tonight's hearing officer. Heinz Mueller was
scheduled to be the hearing Officer, but he has influenza.
So, he was unable to make it today.
I want to welcome everybody to the hearing. This
is a public hearing. This is your hearing, and its purpose
is to make information available to the public on the Eno
River Waste Water Treatment Plant expansion.
We want to receive public and Agency comments on
the Draft Environmental Impact statement that was released
in December of 1989, so please feel free to participate. If
lyou have not filled out a registration card when ycu cans
in, please do so now and indicate your interest in making a
statement if you wish to do so. Even if you don't wish to
make a statement, fill out a card anyway so we can have your
mailing address. This will become part of our official
hearing record and it also gives us a way to provide
information on the results of the hearing.
With me tonight on my left is Boyd DeVane. He
represents North Carolina Division of Environmental
Management, Water Quality Section. On my right is Mark
Mummert. He is EPA's contractor on this EIS. He's followed
T-3
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3
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4
the project for approximately two years and is very familiar
with the technical details.
Our court reporter is Bill Warren.
Are there any elected officials here tonight?
Please stand and identify yourself.
(No response.)
PRESIDING OFFICER HAMILTON: Okay, I don't see any
officials.
The authority for tonight's hearing comes from
the National Environmental Policy Act, which is often
referred to as NEPA. This requires the examination of any
action carried out by the federal government that may have
an impact on the environment.
In addition, Title II of the Clean Water Act
provides money for construction and upgrading of publicly
owned waste water treatment plants. Subsequent amendments,
however, have replaced the Title II money with a loan
program known as the State Revolving Loan Program, which is,
by and large, under state control.
North Carolina requested in May of 1987 that EPA
prepare the Environmental Impact Statement. Under EPA rules
and regulations, all findings of the EIS are to be made
public, and the public has the right to comment on the draft
up to 45 days after its being available. And, this
particular draft was available January 6th of 1990.
T-4
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All comments that are made at this hearing are
^>eing recorded by our court reporter, and these will become
part of the final EIS.
The type of hearing we are having tonight is an
informational type of hearing and I wanted to lay out some
of the ground rules that we will follow. There will not be
any cross-examination of any speakers. This is an
information type hearing, so if you wish to make a
statement, you may do so. I will not permit cross-
examination of speakers by anyone. If you wish to ask
questions of the speakers after the hearing, you, of course,
are free to do so. I may interrupt on occasion and ask for
the people who have made statements to maybe repeat what
they've said for purpose of clarification.
When you are speaking, please identify yourself
|so the court reporter can identify you in the transcript.
And, if you have a written statement, I would appreciate
jyour submitting that. If you submit a written statement,
[this will become part of the EIS.
If you are an individual, I'm going to ask you to
(limit the length of your time to approximately three or four
(minutes. If you represent a group, we'll give you more time
|to speak, maybe five or six minutes.
All comments will be accepted by EPA up to 45
days after the Notice of Availability, and let me correct
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ar the record that the Draft was available on January 6,
)90 — January 5, 1990, not the 6th. That makes the close
- close of comments will end the end of business day the
5th of February.
The Draft EIS will then be revised and prepared
5 a final EIS, and the final EIS will include a summary of
Jie findings, what our preferred alternative is going to be,
transcript of the hearing. The document will then be made
mailable to the public.
The EIS will then go to the Regional
dministrator of Region IV, and he will make his
etermination and publish a Record of Decision which will
ppear in the Federal Register. And, if you've registered
or this hearing, you will then be advised of the Regional
dministrator's decision at that time.
We had planned to give a technical presentation
f the material here today, going through the process; but
s I look around the room, I see largely familiar faces, so
'm going to ask if there are any here tonight who would
ike to hear the technical presentation. Alternatively, I
ould waive the technical presentation and get on to the
»ublic comments. Is there anybody here who wishes to see
;he technical presentation?
(No response.)
PRESIDING OFFICER HAMILTON: Don't be bashful.
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We've got it prepared. We're ready to do it. On the other
hand, if y'all know what the issues are — in that case,
since there are no comments, no requests for the technical
presentation, I'm going to waive the technical aspect of
what we' re doing here and open the floor to public comments.
MR. MUMMERT: John, should I get the people who
just came in?
PRESIDING OFFICER HAMILTON: The question is ~ go
ahead and get the people who have just come in.
All right. The first person that registered to
speak was Jim Clark. So, Jim, I'» going to turn things over
to you.
STATEMENT OF JIM CLARK
MR. CLARK: Good evening. I'm Jim Clark,
President of Save the Water and a candidate for the Durham
County Commission. I am also speaking this evening as a
member of the EPA Advisory and Oversight Committee that has
been meeting over the past two years to help prepare this
landmark environmental study.
On behalf of Save the Water, I first called for
this critically important Environmental Impact statement in
July of 1985. in December of 1986, we finally persuaded the
State Division of Environmental Management to begin this
required study under the North Carolina Environmental Policy
net, and then, fortunately, engaged the 0. S. Environmental
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rotection Agency to join the study under the National
nvironmental Policy Act of 1987.
The Durham community is fortunate to have this
omprehensive environmental study to protect our vital
rinking water supplies, and we'd like to thank Mr. Bob Lord
t EPA for arranging the study and Mr. John Hamilton at EPA,
r. Trevor Clements at the State for their hard work on this
IS.
The good news is that this environmental study
as averted a major environmental mistake, which was the
roposed expansion of the Eno River Sewage Plant. Because
f this study, the Eno River Sewage Plant will be closed and
emoved, and that is a major victory for everyone who has
orked so hard over the past five years to protect the
rinking water supplies for Durham and Raleigh. It is now
lear that if we had not been involved and successfully
nitiated this study, the Eno River Sewage Plant would have
een expanded and precious drinking water would have been
olluted.
The bad news is the study shows that there is no
eally good ecologically safe alternative, and even the
preferred alternative" has major environmental problems,
fe support the consolidation of the Eno River Little Lick
md Treyburn Sewage Plant into the Northside Sewage
treatment Plant, but we're still very concerned about the
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continued pollution of Ellerby Creek and Falls Lake which
Ls, of course, the sole source of drinking water for the
:ity of Raleigh.
This environmental study shows that Ellerby Creek
las been assigned a "poor biological rating" and that during
Low flow conditions, Ellerby Creek could suffer "possible
:oxicity as a result of the stream being 90 to 95 percent
raste water." Already, Ellerby Creek is officially listed
is an impaired water under the Clean Water Act, and the city
.s supposed to have an effective strategy to clean the
ireek up. It's rather ironic that the city's clean-up
itrategy includes dumping three times more waste water than
lllerby Creek now receives.
We're also very concerned about the prediction by
he State in this Environmental Impact Statement that water
iiality violations will probably still occur, even after the
ew state-of-the-art treatment plant is built.
Save the Water is also very concerned about the
otential disposal and environmental problems from the
ludge that will be generated by the new sewage plant. At
east 5,400 dry tons of sludge is supposed to be spread on
,080 acres of land; but, that assumes the sludge will not
ave high concentrations of toxics and heavy metals and that
zer 1,000 acres of land can be found nearby for sludge
Lsposal. Land is scarce in Durham County, and officials in
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range County have already moved to block disposal there.
So, sludge disposal is definitely a serious
roblem. We request that more study be given to this
erious problem and a specific solution be identified, along
ith potential costs, before Durham proceeds with any more
ewage plants.
As you know, Save the Water has consistently been
oncerned with two key neighborhood and citizen issues. The
irst is establishing as permanent policy that all of the
ity and county neighborhoods with failing septic tanks be
erved first as the highest priority for new treatment
apacity and that all of the neighborhoods be sewered before
ny new development squeezes them out once again.
From last week's Advisory Committee meeting, we
mderstand this is to be the EPA recommendation as well. It
ust makes sense to solve the existing environmental proble®
re have with failing septic tanks before giving very
>recious treatment capacity to new development.
The second citizen concern we have is the
>rojected rate shock or the doubling or tripling of water
md sewer rates to help pay for this sewage plant expansion-
tfe are strongly opposed to putting the burden of new growth
:>n the backs of Durham citizens with the doubling or
tripling of water and sewer rates. That's just not fair.
Sfou know, that's not right, so we ask the city to find
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sther ways to finance the proposed improvements without any
infair rata shock.
It was the consensus of the Advisory and
)versight Committee that in view of the potential ecological
>robiems associated with the expansion of the Horthside
iewage Plant that a permit and expansion be considered only
ip to 20 million gallons a day. After the new sewage plant
as fully functioning, any additional proposals for plant
xpansion would require additional study of the actual
ffluent from the new plant and the condition of Ellerby
reek before any other state permit could be issued. We
sk the EPA and the State Division of Environmental
anagement and the city to honor that consensus.
Because of our concern about the continued
allution of Ellerby Creek, we must strongly oppose any
jmbined or provisional permit for an expansion of Northside
> 29 million gallons a day. We do not believe that Ellerby
reek can possibly assimilate that much waste water, and the
Lry is still out as far as this EIS is concerned, so we
slieve that no expansion beyond 20 million gallons should
permitted at this time.
The fact is, we really don't need the sewage
gaplants. We've got much better things to do with our
tid money and our tax money, such as improving our schools t
Lch is a much higher priority than big, expensive sewage
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lants.
We also strongly request that the proposed Eno
Liver pump station be limited to not more than 8 million
fallons a day, and we ask that EPA and the State Division of
Invironmental Management and the city agree to hold the
'reyburn developers to their promise to close the Treyburn
Jewage Plant when the new Northside Plant comes on line.
Treyburn promised that their sewage plant would
)e an interim solution until the new public sewage plant was
>uilt and that they would close it as soon as new capacity
ms available, so we ask you to hold them to that important
>ublic commitment.
One other crucial fact that has emerged from this
SIS is on page 3-42, and I quote the study. It says, "The
3nowhill die base glade, which is located at the junction of
Jnowhill Road and Old Oxford Highway, has more rare species
:han any other site in the piedmont of North Carolina. The
smooth cone flower and tall larkspur are found in the
Jnowhill die base glade."
This fact is so critically important because the
proposed outer loop highway would go right through the
Sncwhill die base glade. And with the Endangered Species
\.ct and other key environmental laws, there is no chance
that the outer loop could pass the EIS process and damage
such an ecologically special and valuable area. So, it's
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:ixne for the city and county to abandon any plans for the
irinking water polluting outer loop.
Once again, this EIS clearly points out that even
:he preferred alternative has serious environmental
•roblems, including the impacts on Ellerby Creek, the 27
tream crossings of the 38 miles of new sewer lines, and the
2 pump stations that would be constructed.
The EIS shows natural areas that would be
egatively impacted, as well as valuable archeological and
istorical sites that would be damaged and impacted. Even
nder best case, there will be erosion and sedimentation
Dilution and substantial non-point source water pollution
com the new growth stimulated by the proposed sewage plant
spans ion. We request that both EPA and the State require
?.e most stringent mitigation measures possible to minimize
le environmental damage.
As the EIS points out, Palls Lake is already
.ghly eutrophic, with more than half of the phosphorus
•llution coming from storm water runoff or non-point source
llution. We can't afford to make any more mistakes when
comes to protecting our drinking water supplies. Save
e Water applauds the Environmental Protection Agency and
e State for strongly recommending needed improvements to
r local watershed protection ordinances, including a
commendation for WS1 watershed classification and
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irotection and a 6 percent impervious surface limitation.
Naturally, the members of Save the Water are very
:eluctant to accept the substantial environmental damage
:hat the Northside Sewage Plant expansion would cause. But,
.n conclusion, we ask that the proposed sewage plant
ixpansion be approved only if, number 1, the permit limits
:he expansion to the agreed 20 million gallons a day.
Number 2, that the Eno River pump station is
.imited to 8 million gallons a day.
Number 3, that the Eno River Sewage Plant, the
kittle Lick Sewage Plant, and the Treyburn Sewage Plant are
ill closed and removed as promised.
Number 4, that the first new treatment capacity
ind all necessary treatment capacity is allocated and
reserved as the highest priority for complete sewer service
:o all the neighborhoods with failing septic tanks.
And, number 5, that there is no unfair water and
sewer rate shock that doubles or triples water and sewer
rates for Durham County citizens. We ask you to incorporate
Dur request into your final recommendations in the final
SIS.
As you know, we are making extremely important
long-range decisions with very high environmental stakes.
Mistakes could pollute our drinking water, so we ask both
EPA and the State Division of Environmental Management to
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incorporate our comments into the final decisions as you
follow through on the rest of this vital Environmental
Impact Statement decision-making process.
As far as the potential rate shock, I would say
to the voters, let's just say no to water and sewer rate
shock." Vote for Jim Clark for County Commissioner, and
together, we'll fight the doubling and tripling of our water
and sewer rates. Thanks again for helping save our water.
PRESIDING OFFICER HAMILTON: Thank you, Jim.
Mr. George Andrews.
STATEMENT OF GEORGE ANDREWS
MR. ANDREWS: My name is George Andrews. I have
teen a resident of Durham County my entire life. I have
esided in the northern part of the county the last seven
¦ears.
I'd first like to say that I wholeheartedly
oncur with the earlier comments made by Mr. Clark. I want
o commend the EPA for the work which has gone into the EIS
raft and the Draft itself.
PRESIDING OFFICER HAMILTON: Mr. Andrews, could
ou get closer to the microphone, please, sir?
MR. ANDREWS: Yes, sir.
My specific personal comments concerning the draft
re, I'm sure, important, vital and truly significant to all
amilies and homeowners in Durham County, particularly those
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Lthin an acute sense of fair play.
While this is not a quote verbatim, the EIS Draft
rojects water and sewer rates must increase by 100 to 200
srcent to assist with financing water and sewer capacity
xpansion for planned development. A Durham city official
ecently conceded an expectation of at least a 100 percent
ncrease for the same reason. To have to experience this
ind of rate shock is almost unbelievable and would be
rossly unfair to existing individual homeowners.
Recently, I received a survey conducted by the
ity Engineering Department Division of Water and Sewer, 120
ast Parrish Street. The survey asked four questions. Now,
want to focus on the first question which asked if I
ould be willing to pay $2,500 for water and sewer lines tot
100-foot front property.
As much as I would like to have city water and
ewer services and while I would accept my responsibility to
ay for my own installation of water and sewer lines, pay
ity taxes after annexation, and then pay for the service
onthly, I would not, in addition, want to have to
xperience rate shock over and above everything else to
ubsidize the water and sewer infrastructure costs for rich
.evelopers.
The second point is that any capacity expansion
iltimately approved should undoubtedly go first to the man
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nany individual homeowners, particularly in the northern
part of the county, who are experiencing failing septic
systems and significant water quality problems. The EPA
states in the EIS Draft, it was informed by the Durham
Zounty Public Health Department in — it was either 1987 or
1988, that as many as 50 percent of all systems in northern
Durham County were currently failing.
I hope you will give considerable weight to the
points I have made here, as I have a deep and sound
conviction they reflect the sentiments of a great many
people in the northern part of the county. People who at
some time in the not-too-distant future may not have access
to acceptable water and sewer infrastructure at any price
due to an understandably ever-increasing treatment capacity
crunch.
In closing, I would like to thank you again for
your efforts and to request any assistance from you which
[nay be available to aid those in the county who currently
Lve the most immediate need for treatment capacity. I
tfould like these comments to become a part of the record of
this hearing. Thank you.
PRESIDING OFFICER HAMILTON: Thank you, Mr.
Andrews. If I could have a copy of those. Thank you very
much.
(Mr. Andrews proffers document to Hearing Officer
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amilton. )
HEARING OFFICER HAMILTON: Mr. Rolan.
rATEMENT OF TERRY ROLAN
MR. ROLAN: My name is Terry Rolan. I'm Director
f Water Resources for the City of Durham, and I would like
3 just read the letter that I've just given John.
"Please find attached my comments on the Draft
nvironmental Impact Statement. As you are well aware, the
ity of Durham has already received a permit for the
xpansion of the northside plant from its current permitted
apacity of 10 million gallons a day — per day, to a
ermitted capacity of 20 million gallons a day in order to
rovide the capacity needed for existing and projected
evelopment in the Northside and Little Lick Creek service
.reas.
The original reason for development of the Eno
IIS was to assist the State in making a decision on the
.ssuance of a permit for waste water treatment to serve the
teeds of the Durham area Eno Basin. Because of the phased
ipproach recommended by the EIS, a clear statement is needed
in the permitting action which is being recommended by the
!PA and the State of North Carolina in this joint EIS so
;hat the City of Durham can make reasonable plans for the
>rderly expansion of the Northside facility.
I would like to suggest that if the final
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recommendation of the EXS is the Northside plant with a
rapacity of 29 million gallons per day, then it should be
recommended that a permit be issued for this amount. The
concerns for water quality modeling could be addressed in
such a permit through conditions written into the permit
bhat would requite the necessary monitoring and modeling
prior to the issuance of the authorization to construct
facilities beyond the existing permitted capacity of 20 MGD.
tn this way, all the parties concerned would have a clear
inderstanding of what would be required prior to further
jxpansion of the Northside plant.
I would like to personally thank you and the
Jnvironmental Protection Agency and the North Carolina
division of Environmental Management and your consultant,
Sannett Fleming, Environmental Engineers, for the tremendous
iffort put forth in preparing this environmental impact
Itatement. 1 truly believe that the final outcome of this
irocess has resulted in the selection of an alternative that
¦ill be good for both the City of Durham and the protection
f our environment. Thank you.
PRESIDING OFFICER HAMILTON: Thank you, Terry.
Mr. Smiley, would you like to speak?
TATEMENT OF FRANK SMILEY
MR. SMILEY: Mr. Chairman, my name is Frank
miley with the Chamber of Commerce in Durham. And unlike
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he first speaker tonight who has yet to disclose to any of
s whether Save the Water represents one person or maybe as
any as three or four. I want you to understand that the
reater Durham Chamber of Commerce represents over 1,500
usinesses in the county and over 3,500 individuals- Our
irectory list is available for you and the public at any
ime.
I want to speak to you tonight only in support of
he statement just presented by Terry Rolan, particularly
.n the section where he said that he would like to suggest
;hat if a final recommendation of EIS is a northside plant
rith a capacity of 29 MGD, then it should be recommended
;hat a permit be issued for this amount.
We in the Chamber of Commerce strongly support
;hat proposal from the City of Durham. Thank you very much-
PRESIDING OFFICER HAMILTON: Thank you, sir.
Dr. Reckhow.
STATEMENT OF DR. KEN RECKHOW
DR. RECKHOW: My name is Ken Reckhow. I'm an
Associate Professor of Water Resources at Duke University/
ind I'd like to start out by complimenting John Hamilton an£*
SPA and the Division of Environmental Management, as well aS
Sannett Fleming for — for a superb job. I thought that
ceport was first rate and the patience and deliberations
3ver the course of our study and the work with the committ®0
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/as excellent.
I'd like to use the opportunity — this
ipportunity to raise a couple of issues with regards to
raste water treatment in Durham. The first issue is that I
ope that in the future that the public presentations of the
ond issue — the bond referendum by the City correctly
otes the fact that a portion of the cost of the waste water
reatment plant, both this as well as Harrington, is
ssociated with growth. And a portion is associated with
ur — our need to meet state and federal water quality
tandards, but a portion is associated with growth.
And I think it's important that the citizens of
lrham are aware of the fact that there is a cost to growth,
id in making their decision with regards to the bond, they
cplicitly accept that, if, indeed, the bond is approved,
tat's one issue.
The second issue I would like to use this
portunity to raise is that if the 20 MGD plant is approved
d built on Ellerby Creek that, we use the opportunity
ter that plant is in place and after we have acquired some
ter quality data on the impact of that discharge on
lerby Creek, we use those data and we use that opportunity
study and model the impact of the 20 MGD plant on the
:eiving water bodies and we, in turn, use that to make a
igment concerning whether or not the proposed 29 MGD is
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ppropriate.
In effect, I'm saying we revisit the analysis
hat was so well done at this point, but does not have the
enefit of the actual plant in place and has a water quality
valuation of that plant.
Thank you.
PRESIDING OFFICER HAMILTON: Thank you, Ken.
Mr. Harrison.
TATEMENT OF ED HARRISON
MR. HARRISON: I have written comments for you,
iut the oral will be a little looser than they are.
PRESIDING OFFICER HAMILTON: Thank you.
MR. HARRISON: I'm Ed Harrison from Durham. I
ras a member of the EIS Review Committee. These comments
ire on behalf of the North Carolina Chapter of the Sierra
:iub, for which I am the Land Use Chair, and they are meant
:o support fully the positions taken on the EIS by Professor
)avid Howell, who is the Water Quality Chair for the North
:arolina Sierra Club. And, as well, they support positions
:aken over the last four years by the Head Waters Group of
:he Sierra Club and by the Conservation Council of North
Carolina, for whom I made a scoping request to DM and to EPA
In 1987.
I wanted to reiterate some of David Howell's
positions, and then I'll move on from there. He believes
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1 that alternate NEC, which is the recommended alternate,
' appears to be, as he says, "The best choice under the
1 circumstances as long as the interphase study is conducted
1 as planned and the City of Durham consistently provides high
guality operation and maintenance." And X support that
language completely.
He also believes, as we do in Durham, that a re-
examination of the water rate structure is needed to grant
encouragement of waste, and we are both real encouraged, as
are our many Sierra Club members, to see any consideration
of conservation at all in the impact statement, and I will
add, I feel it needs to be a somewhat expanded
consideration. And there is at least one public interest
group in Durham that has put together some studies on
conservation.
And Professor Howell and I also advocate the use
of surcharges to reduce organic loadings. I think we'll see
in the future that that concept is going to be carried a lot
further. The Sierra Club, this year, is going to begin
advocating a pollution tax.
And, above all — and I will expand a lot beyond
what Professor Howell said, we would like the EIS to
address the crucial fact that the upper end of Palls Lake is
still not classified by the state for water supply uses.
I'd add that current local watershed
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agulations, particularly those in Durham County, which has
ost of the jurisdiction out there. Everything outside the
ity limits is under Durham County's zoning ordinance in
hat part of the county; that they — those regulations are
ey to the state surface water classifications in terms of
egulatory boundaries. The boundaries for different parts
f the regulated watershed area flex depending on whether it
s a WS or a class C.
And none of us were really aware of that. I had
o tell Professor Howell. I think Mr. DeVane will
nderstand that, you know, you tell Professor Howell he's
xong, he says, I think you're wrong, too. And, I told
im, actually, I was right. And he checked with the
division, and it turned out I was right. I read the
ratershed ordinance real carefully eight or ten times, and
hat's what I came out with.
And I wanted to note that this lengthy process of
:is preparation, starting with the DEM'S request in fall
.986 to the City, proves the importance of full
.nvestigation and citizen participation in protecting water
reality. It turns out that originally, the DEM expressed a*1
.ntent to issue a permit. That's the term, "intent to
.ssue." I'm someone who reads every permit that's intended
:o issue or deny in the state, and most of them are intend
:o issue. And, the permit, of course, was to expand the
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lischarge from two and a half to ten million gallons a day.
Four environmental groups, the Eno-River
Association, along with the Conservation Council, the North
larolina Sierra Club, and the North Carolina Wildlife
"ederation, went to Paul Wilms, then Director of DEM, and
sked for extensive further study in EIS. And the request,
want to emphasize, was based not only on fears of point
ource impacts on Falls Lake's water supplies, but also on
he land use impacts of non-point pollution which will
esult from development in the whole watershed where there
ight be sewer service and in other areas affected by
svelopment infrastructure.
And it looks like our point source concerns were
lite justified. They were confirmed by the state studies,
lich is, of course, not an expansion, but a closure of the
Lant. That's a lot of difference. That's a lot different
:om the permit that was supposed to be issued. And I
link maybe we'll see that there are a lot of other permits
•ound the state that if this kind of study were done — I
iuldn't wish it on anybody. I've talked with Mr. Rolan
enty about this. You wouldn't wish it on anybody, but it
y change the status of quite a few permits when they come
for renewal throughout North Carolina.
The scoping request that I gave to DEM in 1987 and
an to EPA focused on the need for any impact statement to
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amply fully with first, the North Carolina Environmental
alicy Act, CEPA, as we call it. And second, the National
nvironmental Policy Act. And this would be by thoroughly
xamining not only the direct effects, but also the indirect
ffects and significance of the action, as well as "possible
onflicts between proposed activities and objectives of
tate, local, and federal governments; plans, policies, and
ontrols in the affected area."
And we asked — and particularly in the case of
)EM, I made this request after a lot of discussion with the
itaff. We asked the agencies to recommend mitigation
leasures on the part of local governments, taking the Sierra
Hub position, which we are holding more strongly through
:he 80's and now into the 90's that a lot of environmental
rontrol can be happening at the local level that isn't.
Lnd I think the state Sediment Control Program is the best
ixample of that.
And the specific mitigation measures that we
isked for were comprehensive storm water management studies
ind programs in both city and county, priorities for sewet
service, and what seems like a minor request, but if you'r®
3n a city commission that deals with this, it's pretty
tiajor, installation of greenway trail simultaneous with
Installation of sewer lines served by any treatment
axpansion.
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And we also asked both agencies to recommend
prompt and timely implementation of recommendations from
both the Eno River Capacity Use Study and the Little River
Lake Nickie Watershed Study.
And because this final request about these
studies was made not only in scoping documents, but also by
nyself and a number of other environmental group
representatives in the EIS Review Committee/ we were
iisappointed with the Capacity Use Study ~ which is the
dost comprehensive of its kind in this region, really, the
Jivision of Water Resources has ever done in North Carolina,
fas not considered and not referenced in the impact
statement. And this is not because the service area was not
.ncluded. The downstream boundary of the study area was
:hree miles below the Eno discharge, not above.
And because of this significant omission, X asked
;he North Carolina Natural Heritage Program, which deals
rith endangered, threatened, and special concern species, to
se the Capacity Use Study and its comments on the impact
tatement. And you should have had a set of comments from
harles Rowe, the Director of that program, which focus on
he biological impacts of flow reductions, particularly in
hreatened species.
I would recommend that you pay some attention to
hat Natural Heritage comments. You will see some things
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ou really haven't seen. They're a pretty smart shop and
hey get into a lot of stuff. And I was really sorry that
articularly the Capacity Use Study was omitted.
Another omission, and that's one omission — but
t's nothing in view of how many times in the Review
lommittee we asked that it be considered, is in Section
324, which discusses transportation. And there is no
tention of a proposed interstate level thoroughfare intended
;o serve major industrial and commercial development in the
Ino River service area called the Northern Durham Freeway.
And as presently proposed, this expressway would
love between sections of the sewer service area by crossing
;he water quality critical area of the Little River
reservoir at points, by my measurement on large scale maps,
-.4 miles directly extreme from the water supply intake
.tself and .7 of a mile from the pool.
The 1988 regional thoroughfare plans, which still
rontain this proposal, clearly states this road would serve
:ertain heavy development in the Eno Basin, development
/hich is too heavy to exist without central sewer. And, I
/anted to contend that ignoring this major indirect effect
>f the action may constitute a. failure to comply. And, I've
jot the numbers here. It's regulations for implementing
4EPA, 40CPR, 150216(B). That's the language that still
stands.
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And finally, besides wanting you to correct
omissions, I wanted to make a request to address the
concern that David Howell has raised regarding the lack of
water supply classification for the Durham sections of upper
Falls Lake and at the same time, address the mitigation
measures that the Conservation Council asked for three years
ago.
The waste water plants in Durham are currently
operating under a judicial order of consent of September 14,
1989. And there are a lot of provisions relating to waste
water treatment, and I don't want to address those.
There is one unique provision regarding non-point
pollution. It's Section P on page 11 of that document.
And, I think Mr. DeVane said he was going to try to get the
JOC today. The section requires that Durham must provide a
certification for all new development projects, excluding
city or county projects for areas of failing on-site
treatment systems in the Eno River service area, which
require non-discharge permits for sewer lines. Indicating
that the projects comply with state watershed protection
guidelines regarding water course buffers and storm water
control, but not land use restrictions for class WS2
watersheds, as defined in the DEM report guidelines for
obtaining a protective service water classification. And it
also requires that plans and specifications to verify
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ompliance have to be provided.
These particular provisions in those guidelines,
rhich are rapidly over the course of this year turning into
regulations, require, among other things, on all-new
levelopment to control the first half inch of runoff and
:hat there be a 50-foot minimum vegetative buffer adjacent
:o all perimeter tributaries.
Those are provisions that are complied with
/ithin the areas regulated by Durham's both county and city
watershed ordinance. In a lot of cases, the person on the
planning staff who spends the most time with those
ordinances indicates to me that no other sections of the
zoning ordinance outside the watershed ordinance, address
:hese at all. That there are no such requirements.
There are stream buffer requirements within the
:ity and within the territory. They are not.nearly so
stringent and there are now velocity control requirements,
3ut that is not the same as the runoff control, according to
)EM. I think it's not out of the question the city could
pull this off, and that's why I'm bringing it up.
And we were requesting that EPA strongly
recommend that this be a condition in the DEM permit for
operation of any waste water facilities serving the Eno
Basin by extending this provision beyond the period when the
Eno River EIS is approved. The last sentence of the
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provision says that it would go off on approval of E1S.
And this could be restricted to the Eno Basin. And for one
reason in particular that of all the streams in the urban
services area of Durham, that Eno is distinguished by being
one that supports its uses.
There are an awful lot of streams around here.
Ellerby Creek is one which has no recent history —
j certainly none in this century, of supporting fishable or
swimmable standards, and certainly not water supply. But
the Eno — very likely, in large part because of the state
and city park buffers, tends to be fairly high quality and
also that there are no major point sources above the Durham
plant, except for Hillsborough.
And we also would like DEM and EPA to see that
Durham is actually complying with this provision in the
judicial order. And it's conceivable that both state and
federal anti-degradation statutes, insofar as we understand
them, and forthcoming NPDS storm water permitting programs
could make controls of this nature mandatory. And it would
be a good idea to move ahead and get them underway. And
this would be particularly in river basins of good water
quality, such as the Eno.
Thank you. No particularly new ideas here, but I
wanted to get them across.
I PRESIDING OFFICER HAMILTON: Okay, thank you. Do
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rou have a transcript of what...
MR. HARRISON: Yeah. Do you want one or two?
PRESIDING OFFICER HAMILTON: One would be
:uf f icient.
(Mr. Harrison proffers document to Hearing Officer
lamilton.)
PRESIDING OFFICER HAMILTON: Thank you very much.
Ms. Register, would you like to speak? I have
rou down as a "maybe."
MS. REGISTER: No.
PRESIDING OFFICER HAMILTON: Okay.
All right. I have exhausted all of the people who
wished to speak as they registered. Are there any people
urtio would like to make any comments at this time?
MS. HERON: I would.
PRESIDING OFFICER HAMILTON: Yes, ma'am.
STATEMENT OF BECKY HERON
MS. HERON: I'm Becky Heron and I'm Vice Chair of
the Durham County Board of Commissioners. And I just
wanted to bring out just two or three concerns that I have
and I think probably the Board has, but specifically,
myself. I feel that any new capacity that will become
available because of the expansion of the plants, that this
should go to neighborhoods with failing septic tanks and
also to areas that property has not been developed because
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it did not meet the requirements for septic tanks.
My second concern is the — in your report, I
believe you stated that there could be a substantial
increase in water rates with these future expansions. And
that is a concern of mine also. The impact that this will
have on low income people and that I just don't think the
rate payers need to subsidize these new expansions that
would go to new development. They certainly should pay
their fair share.
I also feel that as the Eno plant is phased out,
that it should be completely closed and removed from the
site so there's no temptation to go back. And any package
plants in the service area should be — the use of those
plants should be discontinued and closed out and removed so
that they would come under this new capacity and we would
not have the problems that we are having now in certain
parts of Durham County with package plants.
Those are my comments. Thank you.
PRESIDING OFFICER HAMILTON: Thank you very much.
Are there any other people that wish to make any comments at
this time? Terry.
STATEMENT OF TERRY ROLAN
MR. ROLAN: I'd like to just clarify one point.
Mr. Andrews referred to the City Engineering Department at
Parrish Street. That is the County Engineering Department
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hat he received correspondence from, rather than the City.
just wanted to clarify that. The City's address is City
:all Plaza.
PRESIDING OFFICER HAMILTON: Thank you.
Okay, are there any other comments?
(No response.)
PRESIDING OFFICER HAMILTON: I want to clarify
omething that — several of the speakers have alluded to
.he Review Committee, and I think it would be worthwhile
ust to tell everyone what the Review Committee was. This
ras a group of, oh, about 24, 25, 26 people — it fluctuated
is people dropped off and wished to be added, that was
ormed in November/December of 1987. I was not at the
>roject at that time, but I think it was formed under Bob
.ord, my predecessor. And this Review Committee had a wide
representation, including citizens, scientists,
snvironmental interests, state and city people, engineers
ind developers, real estate people.
And we met seven times. The first meeting was, I
jather, an introductory meeting. I was not there. That
/as on January 28th of '88. We met again in April of '88.
ie introduced the contractor and what the study was going to
ie. On July 28, 1988, we helped make the land use maps of
:he draft that you — some of you have seen, these large
Eold-out maps. We met again in October and developed the
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growth rate scenarios, which were particularly difficult
because we had to prognosticate what the growth of an area
is going to be 20 years down the line. And, I hope we've
done it well. It's impossible to predict exactly what the
future will bring. On April 6th, we met again and looked at
the alternative evaluations and saw what alternatives would
work and what would not, largely predicated upon cost and
environmental considerations. The 19th of June, we worked
on the draft alternative report. And, we met again just
last week, February 13, 1990. We were concerned with rates,
what performance requirements would be and some of the
concerns concerning the second update from 20MGD to 29 or 30
MGD.
And I want to take this time to thank most
sincerely the committee members. We would meet at 7;00 or
7s30 and wouldn't get through until sometimes 11:00, 11:30
in the evening. And an awful lot of hard work was put into
this by the committee members, and they waded through
volumes of technical material that we had generated and had,
I think, significant impact. It was a good group and lively
discussions and I think it certainly changed the direction
of many issues that we were examining. And it was an
excellent group to work with, and I think the process was
extremely helpful to us because many, many of the
recommendations the group put in — the group requested, we
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iid, in fact, incorporate. I would say, most of the
recommendations that the group made were, in fact, included
Ln the draft.
We will — I acknowledge the omissions that Ed
iarrison referred to, and we will, on the final draft, put
Ln the Eno Capacity Study that he referenced. We missed —
af the hundreds of documents that we reviewed, this one
slipped through, and we will correct that omission in the
Einal draft.
Boyd, do you have anything you want to say?
MR. DEVANE: John, I just want to thank you and
thank EPA and the consultant. I've been impressed
throughout this with the — especially the patience of John.
I feel like he's been very open in considering comments,
diverse comments from many different people. I've just been
impressed with the way he's handled it, and I think he'll
consider the comments that he's heard tonight in preparing
the final document. I feel good about the process. I feel
good — I reiterate his comments about the committee. It
was a learning process for us. I learned especially a lot
from attending those meetings, and I appreciate the time
that you've put in it, too.
PRESIDING OFFICER HAMILTON: All right. Thank
you very much.
I'm going to ask one more time if there is anybody
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in the audience that wishes to have any comments.
(No response.)
PRESIDING OFFICER HAMILTON: Thank you very much.
I'm going to adjourn the meeting at this time. Thank you
for your attention.
(Whereupon, the hearing was adjourned at 7:58
p.m.)
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REPORTER'S CERTIFICATE
IASE TITLE: Environment Impact Statement
SEARING DATE: February 20, 19 90
LOCATION: Durham, North Carolina
I hereby certify that the proceedings and evidence
are contained fully and accurately on the tapes and notes
reported by me at the hearing in the above case before the
Environmental Protection Agency.
DATE: March 1, 1990
WILLIAM L. WARREN
Brandenburg & H2£ty
231 Fairview Road
Ellenwood, GA 30049
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APPENDIX A
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8 24-4
DURHAM CODE
tion with Fayetteville Street; extending then approx-
imately four hundred (400) feet with the centerline of
Fayetteville Street to its intersection with the I. L.
"Buck" Dean Freeway,
c. Planning requirements. No development, land-disturbing
activity, or site improvement activity shall occur within
the district and no building permit shall be issued for
construction or other activity within the district prior
to the approval of a site plan for the subject property.
All such site plans shall comply with the site plan
provisions of Section 24-12.1 "Site Plans" and shall be
approved by city council. All development activities or
site work conducted after the approval of the site plan
shall comply with the specifications of the approved
site plan for the subject property. The subdivision re-
view board may approve minor amendments to the
approved site plan for development in the district,
d. Building height limits. Buildings within the downtown
transition area district may exceed the maximum height
limit established for the underlying zoning district
provided a use permit is granted by the board of
adjustment.
Before granting a use permit for a building to exceed
the maximum height limit established for the under-
lying zoning district, the board of adjustment shall
make the findings set forth in section 24-20.B.5 and
shall also find that:
(1) The proposed plan provides adequate light, air
and open space for an urban environment.
(2) The proposed plan adequately protects surround-
ing properties from adverse effects.
(3) The proposed plan provides for safe traffic and
pedestrian movements.
8. Regulations for development within critical watershed areas.
a. /Intent and purposeJ In order that the City of Durham,
Durham County and surrounding areas may continue
to have a healthy economic climate, it is essential that
adequate supplies of drinking water be assured. Con-
Supp. No. 20
A-l
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ZONING
S 24 4
flicts can arise in meeting this goal when industrial,
urban or suburban development occurs within areas
that are close to water supply reservoirs. Sedimenta-
tion and erosion from development can and has re-
duced the storage capacity of reservoirs. Storm runoff
from developed areas can introduce pollutants into the
drinking water supply, making water treatment more
complicated and expensive. Effluent from nearby waste-
water treatment plants can release phosphorous and
other pollutants into the water supply, making water
either undrinkable, expensive to treat, or unusable for
recreation purposes. Certain types of industrial land
uses create the risk of chemical spills occurring and
contaminating the nearby reservoir before the spill
can be contained.
The purpose of the critical watershed district is to
establish measures to protect the quality of the present
and future water supply for the city, county and neigh-
boring localities. Because these protective measures
allow some latitude with land uses, and because the
district is not intended to prescribe a specific land use,
but rather a range of acceptable land uses, the critical
watershed district is designed as an overlay district.
Within the range of land uses which can be located
within the district, there are established in this sec-
tion performance standards which apply to develop-
ment which occurs there.
b. Establishment of district The critical watershed dis-
trict may be established for certain lands within the
watershed of any public drinking water reservoir which
lies within or adjacent to Durham County. The district
shall consist of two parts: (1) a Water Quality Critical
area; and (2) a Limited Industrial Area.
A water quality critical area may be established for
land which lies adjacent to the shoreline of the reser-
voir at normal pool level and extends within the wa-
tershed area of the reservoir to a point beyond either
the ridge line of the reservoir watershed or one mile
Supp. No. 20
1802.1
A-2
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5 24-4
DURHAM CODE
from the shorelines of the reservoir at normal pool
level, whichever is the shorter distance. The bound-
aries for the critical area shall be set at places readily
identifiable on the official zoning map, such as streams,
roads or property lines. In a case where the one mile
distance is the shortest applicable distance, and where
there are no nearby identifiable features on the zoning
map to place the critical area boundary, said boundary
may be set at the nearest identifiable map feature
between one and two (2) miles from the shoreline at
normal pool level.
A limited industrial area may be established for the
remaining part of the watershed area of the reservoir.
For portions of the watershed draining directly to the
A II (water supply) segments of the reservoirs, any
limited industrial area may extend from the water
quality critical area to the boundaries of that portion
of the watershed. For portions of the reservoir water-
shed not draining directly to the A II segments of the
reservoir, the limited industrial area may extend from
the water quality critical area boundary to a distance
of up to one-half 06) mile from any publicly held lands
acquired for the reservoir. The limited industrial area
shall not overlap the water quality critical area, but
shall be placed only in those areas meeting the above
criteria which also extend beyond the water quality
critical area. The boundaries for the limited industrial
area shall be set at places readily identifiable on the
zoning map, such as streams, roads or property lines.
c. Site plan requirement Except for single-family detached
homes constructed within a "minor" subdivision of
less than five (5) parcels, all forms of development
within the critical watershed district shall be required
to have a site plan prepared and approved before any
building permits or and disturbing activity takes place.
All single-family homes exempted from the site plan
requirement are still subject to all other requirements
of this section and in order to receive a building per-
A-3
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ZONING
§ 24-4
Supp. No. 20
mit, a scaled drawing shall be submitted which indi-
cates how the applicable requirements will be met. All
site plans required under this section shall conform
with the site plan provisions of section 24-12.1, and
unless other requirements in the zoning ordinance spec-
ify otherwise, final approval authority shall be vested
in the subdivision review board. All development ac-
tivities or site work conducted after approval of the
site plan shall conform with the specifications of said
site plan. Minor amendments to established site plans
for development in the district may be amended through
action of the subdivision review board. For the pur-
poses of this section, development shall be defined as
any new building activity (1) outside any subdivisions
of record which are at least partially complete and (2)
consistent with the elements described in the defini-
tion for development found in section 24-1.
Land use restrictions. Generally, the underlying zon-
ing district(s) shall control the land uses permitted,
within the critical watershed district. Besides those
limitations, however, there may be several other per-
mitted use limitations which apply. Those further lim-
itations are:
(1) Water quality critical area. In addition to the limi-
tations on permitted uses prescribed for the un-
derlying zoning district, the following restrictions
shall apply to the water quality critical area por-
tion of the district.
(a) Industries. No industries or any other busi-
nesses which distribute or warehouse indus-
trial materials may be located within the water
quality critical area.
(b) Offices. Offices shall only be permitted on land
parcels of no less than one acre. Also, no office
use on a single parcel of land shall have more
than three thousand (3,000) square feet of gross
floor area. Offices shall meet all other require-
ments of this section. These restrictions shall
not be construed as to prohibit home occupa-
tions as defined in section 24-12P.
1802.3
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5 24-4
DURHAM CODE
(c) Commercial and service establishments. Uses
which provide for the sale of motor fuel for
motor vehicles are prohibited within the water
quality critical area. Other commercial and
service establishments shall only be permit-
ted on land parcels of no less than one acre.
Also, no commercial or service establishment
on a single parcel of land shall have more
than three thousand (3,000) square feet of gross
floor area. Commercial and office uses shall
meet all other requirements of this section.
These restrictions shall not be construed as to
prohibit home occupations as defined in sec-
tion 24-12P.
(d) Residential There are no additional restric-
tions on the type of residential land use al-
lowed within the water quality critical area.
(e) Landfills or waste disposal No landfills or
waste disposal facilities of any kind (except
for septic tanks) may be located within the
water quality critical area.
(2) Limited industrial area. In addition to the limita-
tions on permitted uses prescribed in the underly-
ing zoning district, the following restrictions shall
apply to the limited industrial area.
(a) Industries. Only those industries which do not
use, store or produce quantities or substances
equal to or exceeding the threshold amounts
listed on the CERCLA or Michigan Lists of
hazardous materials may be located within
the limited industrial area within a use per-
mit. For industries classified as "Tier HI" in-
dustries (which excludes industries using haz-
ardous wastes and industries using or produc-
ing substances which present an immediate
hazard to health, safety or the environment),
which use or produce one or more substances
on the above lists in at least the threshold
amounts, a use permit from the board of ad-
Supp. No. 20
1802.4
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ZONING
S 24-4
justment shall be required. No Tier I or II
industries shall be allowed within the limited
industrial area.
In addition to the normal review criteria con-
sidered for the use permit, the board shall
consider the special requirements for hazard-
ous materials uses found in section 24-12KK
of the zoning ordinance. The board, in issuing
such use permit, may designate conditions it
feels are reasonable and appropriate to en-
sure continued compliance with the require-
ments for the use permit, as described in sec-
tion 24-12KK.2.
(b) Offices. There are no additional restrictions
on the type of office land uses allowed within
the limited industrial area.
(c) Commercial and service establishments. There
are no additional restrictions on the type of
commercial and service establishments allowed
within the limited industrial area.
(d) Residential There are no additional restric-
tions on the type of residential land use al-
lowed within the limited industrial area.
(e) Toxic or hazardous waste disposal No facili-
ties which dispose of toxic or hazardous wastes
may be located within the limited industrial
area.
e. Impervious surface limitations. In order to prevent an
excessive amount of stormwater runoff from damag-
ing the water quality of the reservoirs, it is necessary
to encourage as much infiltration as possible of runoff
from hard surfaces onto land areas which can absorb
and filter runoff. For the purposes of this section, an
impervious surface is defined as a surface composed of
any material that impedes or prevents natural infil-
tration of water into the soil. Impervious surfaces may
include, but are not limited to: Roofs, streets, parking
areas, tennis courts, driveways, patios, sidewalks, and
any concrete, asphalt or compacted gravel surface. Im-
Supp. No. 20
1802.5
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§ 24-4
DURHAM CODE
pervious surface calculations for an individual devel-
opment, shall be cumulative for original construction
or any subsequent additions which are made. The fol-
lowing impervious surface limits shall be applied to
the critical watershed district as specified below.
(1) Water quality critical areas. There shall be a limi-
tation of no more than six (6) per cent of the land
area of that portion of a single development lo-
cated within the boundaries of the water quality
critical area which may be covered by an impervi-
ous surface. Roof areas of residential buildings
may be excluded from the impervious surface cal-
culations if roof runoff is kept from directly or
indirectly entering street or parking/driveway drain-
age systems, but rather is directed to infiltrate
the first one inch of stormwater across lawn or
natural vegetation areas within the confines of
the particular development in which the roof is
located.
(2) Limited industrial areas.
(a) For a development or portion of a develop-
ment within the limited industrial area which
does not have public sewer service connected
to it, there shall be a limitation of no more
than twelve (12) per cent of the land area of
that development within the limited indus-
trial area which is covered by an impervious
surface.
(b) For a development or portion of a develop-
ment within the limited industrial area which
does have public sewer service connected to
it, there shall be a limitation of no more than
thirty (30) per cent of the land area of that
development within the limited industrial area
which is covered by an impervious surface.
(c) Exceptions to the impervious surface limita-
tions specified in (a) and (b) above may be
granted by city council, upon recommendation
from the subdivision review board. Consider-
ation of whether to grant such relief shall be
Supp. No. 20 i ono r
A-7
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ZONING
§ 24-4
based on a demonstration, to the council's sat-
isfaction, that the site plan reflects special
features to safeguard against contamination
of stormwater leaving the property, including
the infiltration, retention or detention of the
first one-half (%) inch of stormwater runoff
from impervious surfaces.
Special runoff and drainage control requirements. It is
necessary to impose several requirements on devel-
opment in the critical watershed district in order to
prevent damage to water quality that is not necessar-
ily attributed to an individual property within a de-
velopment. These requirements are as specified below.
(1) Stormwater runoff retention. For development within
the water quality critical area, measures shall be
employed to infiltrate or retain the first one-half
(V2) inch of stormwater runoff from impervious
surfaces during a storm occurring within a twenty-
four-hour period. For development within the lim-
ited industrial area, measures shall be employed
to infiltrate, retain or detain (detention being least
preferred) the first one-half (%) inch of stormwater
runoff. Methods to accomplish that infiltration,
retention or detention shall be shown on the site
plan. The area to which this requirement shall
apply may be for each individual lot within a
single development, or, the development as a whole.
If the developer elects to satisfy this requirement
for the development as a whole, the site plan shall
indicate how any devices or structures used to
accomplish the retention or infiltration shall be
maintained.
(2) Reserved.
(3) Street runoff and drainage. New streets constructed
within the water quality critical area shall not
require curb and gutter. New streets which cross
perennial streams within the water quality criti-
cal area shall be designed in such a way to avoid
direct runoff from pavement surface into the stream
1802.7
A-8
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$ 24 4
DURHAM COUP,
it crosses. Such design features shall be indicated
on the site plan.
(4) Underground fuel or chemical tanks. There shall
be no underground fuel or chemical storage tanks
allowed within either the water quality critical
area or the limited industrial area. For the pur-
poses this section, underground refers to the burial
of such tanks below the surface of the ground or
the covering of them by a berm built above grade.
Spill containment measures (i.e. dikes, double-lined
tanks, etc.) must be taken for any fuel or chemical
tank.
g. Sewer service limitations. .Several limitations on sewer
service and wastewater treatment facilities are imposed
within the critical watershed district in order to pre-
vent discharges of untreated or inadequately treated
wastewater into the water supply, and to prevent dense
urban development patterns from encroaching into the
district, creating risks of stormwater runoff contami-
nation. Those limitations and restrictions are described
below.
(1) Water quality critical areas. The following sewer
facilities restrictions shall apply within the water
quality critical area portion of the district.
(a) Wastewater treatment facilities. No new pub-
lic or private wastewater treatment plants or
community sewage treatment facilities of any
kind shall be allowed.
(b) Sewer service. No sewer lines shall be extended
into the water quality critical area, except for
cases meeting either of the following two (2)
criteria:
(i) Public gravity flow sewer lines to serve a
development pursuant to a contract be-
tween the city and a developer which was
executed prior to June 1, 1987, may be
allowed, subject to such limitations and
conditions as the city council may prescribe,
(ii) Public gravity flow sewer lines may be
extended to an already existing use.or
Supp. No. 27 1 802.8
A-9
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ZONING 24-4
structure for which a health hazard has
been documented by the county health
department, subject to city council approval.
(2) Limited industrial areas. The following sewer fa-
cilities restrictions shall apply within the limited
industrial area portion of the districts.
(a) Wastewater treatment facilities. No privately
owned discharging wastewater treatment fa-
cilities shall be allowed within the limited
industrial area, and no expansions of existing
private discharging wastewater treatment fa-
cilities shall be allowed.
(b) Industrial pretreatment plants. Pretreatment
facilities for use by industrial firms to pre-
pare wastewater for discharge into the public
wastewater collection or treatment system shall
be allowed within the limited industrial area.
(c) Discontinued use of private surface discharge
facilities. After a reasonable time to comply is
set by the city council, no person shall con-
tinue to operate or use a private surface-
discharge sewage treatment system when pub-
licly owned sewer lines are extended to or
adjacent to the property served by the private
system.
h. Application of these regulations to project partially com-
plete. For any development which has received before
August 13, 1984, either preliminary plat approval or
site plan approval, and which is at least partially com-
plete, any subsequent phases of said development in-
cluded in the plat or plan which was approved may be
completed without being subject to the additional reg-
ulations imposed in the critical watershed district. Any
additions, expansions, or phases which deviate signifi-
cantly from a site plan or preliminary plat approved
before that date shall be subject to the critical water-
shed district regulations. The subdivision review board
shall make the determination as to whether any change
from a previously approved plat or plan is significant.
A development shall be deemed at least partially com-
Supp. No. 27 ]802_9
A-10
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<> 24-4
IJ'-'KHAM COOK
plete if occupancy permits have been issued for any of
the structures contemplated in the approved plat or
plan.
9. Stream buffer area.
a. Buffer required. A permanent undisturbed buffer area
shall be provided a long both sides of all streams. The
purpose of this buffer area shall be to provide for infil-
tration of storm water into the ground, to help main-
tain a stream's capacity for carrying off storm water
by reducing sedimentation, and to improve water qual-
ity by filtering out pollutants before they reach the
stream. Within the required buffer area, no clearing
or grading other than selective thinning and ordinary
maintenance of existing vegetation shall be permitted.
b. Width of buffer. The width of the required buffer area
shall be based on the size of the drainage basin served
by a stream and shall be determined as follows:
(1) Major streams. A buffer area which is a minimum
of fifty (50) feet wide shall be provided parallel to
the channel of all mjyor streams. The width of
this buffer area shall be measured from the edge
of the stream bank. Major streams shall be de-
fined as those watercourses which have a drain-
age basin of at least one (1) square mile and are
those streams for which floodway and floodway
fringe boundaries are established on the official
City of Durham Flood Boundary and Floodway
Maps.
(2) Minor streams. A buffer area which is a minimum
of twenty-five (25) feet wide shall be provided par-
allel to the channel of all minor streams. The
width of this buffer area shall be measured from
the edge of the stream bank. Minor streams shall
be defined as those watercourses which have a
drainage basin of less than one (1) square mite
and greater than fifty (50) acres,
c. Variance from buffer requirements. In a case where an
individual property has been rendered unusable due
to the establishment of the buffer area, and where a
SuppNo'27 1802.10
A-ll
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ZONING
§ 24-4.1
proposed use would otherwise be in compliance with
existing zoning ordinances, there shall be grounds for
a variance, provided that the conditions set forth in
section 24-20.C. "Variances" of the zoning ordinance
are met.
The board of adjustment shall grant the minimum
variance necessary to afford appropriate relief under
this section. The board may attach such reasonable
conditions to the grant of a variance as it deems nec-
essary to achieve the purposes of this section. Vari-
ances which involve construction within established
floodway fringe districts shall be granted only in com-
pliance with the floodway requirements of section
24-4.D.4.
d. Uses permitted by right. The following developments
are permitted as a matter or right in stream buffer
areas: Streets, driveways, bridges, culverts, overhead
utility lines, railway lines, creek and storm drainage
facilities, stream obstruction removal, stream recon-
struction, sewage or water treatment plant outlets,
water supply intake structures, recreation uses and
other similar public, community or utility uses. Such
developments shall be designed in a manner which
minimizes intrusion into the required buffer area. (Ord.
No. 5055, §§ 3, 10, 1-2-79; Ord. No. 6289, § 1, 10-3-83;
Ord. No. 6947, § 1, 9-5-84; Ord. No. 6472, § 1, 9-6-84;
Ord. No. 7610, §§ 1, 2, 5-6-85; Ord. No. 6919, § 1,
5-5-86; Ord. No. 6984, § 1, 6-16-86; Ord. No. 7211, §S
5-7, 5-18-87; Ord. No. 7271, § 1, 7-28-87; Ord. No.
7299, § 1, 8-17-87; Ord. No. 7374, § 1, 11-16-87; Ord.
No. 7428, § 3,12-7-87; Ord. No. 7504, § 1, 5-16-88; Ord.
No. 7647, § 2, 10-3-88; Ord. No. 7934, § 1, 10-16-89)
Sec. 24-4.1. Rural district.
A. Purpose and intent The purpose of the rural districts is to
protect and preserve the open, rural character of nonurban land;
to protect and preserve agricultural lands, horticultural lands
and forest lands for the performance or maintenance of their func-
tions and to encourage the location of such uses in areas of least
conflict with potential urban uses, and to control, through the
Supp. No. 32 1802.10.1
A-12
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appendix b
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GUIDELINES FOR OBTAINING A PROTECTIVE
SURFACE WATER CLASSIFICATION
North Carolina Department of
Environment, Health, and Natural Resources
Division of Environmental Management
Water Quality Section
DECEMBER, 1987
Revised
September, 1989
This document has been approved
R. Paul Wilms
Director
Date
B-l
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Table of Contents
Page
Purpose 1
WS Classification 1
Initial Changes 1
Actions Needed 2
Point Source Strategy 4
Nonpoint Source Strategy 4
WS-I Program Outline 7
WS-II Program Outline 9
WS-III Program Outline 11
Legal Mechanisms 12
Further Information 12
B-2
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PURPOSE
The purpose of the water supply (WS) protection program is to
provide an opportunity for communities to work together with the
state in providing enhanced protection for their water supply
from pollution sources. If local governments develop a watershed
management program that controls pollutants from nonpoint sources
in their particular watershed, the state will control the number
and type of point sources allowed in the watershed. Combining
the efforts of these governing bodies should provide and maintain
a desirable level of watershed protection.
The guidelines presented here are not rules, but are minimum
criteria that should be used by local governments as a pattern
f°r establishing their individual water supply watershed
Protection standards. However, General Statue 143, ammended June
23, 1989, will establish mandatory minimum management
requirements by January 1, 1991. By July 1, 1992 all local
governments must have approved local water supply management and
Protection ordinances that at least meet the minimum mandatory
reqviirements. it is anticipated that mandatory requirements
will be similar to the requirements presented in this document.
CLASSIFICATION
New water supply classifications became effective February
» 1986 and have three classes (WS-I, WS-II and WS-III). These
glasses are defined according to the amount and types of permit-
point source discharges as well as a requirement to control
"onpoint sources of pollution. Class WS-I watersheds must have no
P°iht source discharges. Domestic discharges (including schools
fid individual homes) and approved non-process (cooling) water
5£scharges are allowed in Class WS-II watersheds. In addition,
and ws-li watersheds must have local land use management
t«??ranis to protect water supplies from nonpoint sources of
bv Jution- AU nonpoint source control programs:must be water sSpply classes were revised. At P^^these
&t0fr ® are considered to have a nonpoint sou. ,,nJigtur>jed and
ttfeam which requires the watershed to remain undisturbed ana
inhabited (since that was the requirement for Class A
B-3
-------
waters). All other waters previously classified as A-II became
Class WS-III. Many of these waters may qualify for either the
WS-I or WS-II classification. Reclassification of WS-III waters
to a more protective class is initiated on the request of a local
water authority or government followed by a detailed watershed
evaluation by DEM and the development of a watershed protection
program by local governments. Once the official resolution is
received from the local governing body, any new application for
an NPDES permit (point source discharge) in a proposed WS-I or
WS-II watershed will be closely evaluated and may not be acted on
until the reclassification procedure is complete.
ACTIONS NEEDED
There are five main actions local government must take in
order for the state to proceed with the local government's
request. These actions include:
1. collecting water supply information,
2. determining the most appropriate WS classification
based on state guidelines,
3. developing control strategies,
4. adopting and implementing control strategies, and
5. submitting a proposed protection package to the EMC.
In collecting water supply information, a community must
define its actual water supply needs over a reasonable planning
period, determine all potential water supply sources and describe
the selected watershed in detail. The next action is to determine
the appropriate "WS" classification. This may require assistance
by DEM or other state agencies for specific data needs,
evaluation of the data base by the state, and state
recommendations for classification of the watershed. The third
action (develop control strategies) includes specific strategies
for controlling nonpoint sources of pollution. The fourth action
is adoption/implementation of these strategies by local
government and adjoining jurisdictions within the watershed. The
final local government action is to submit the watershed
management package to the EMC for its preliminary assessment.
The state will take two actions after the final local
watershed protection plan is submitted to DEM and the EMC. First,
public hearing(s) will be held in the vicinity of the water
supply to provide the EMC with oral and written comments from the
public about the proposed water supply classification. After all
comments are summarized in the proceedings report, the hearing
officer will review the document and any other related material.
Upon completion of the review, the hearing officer will submit
the local water supply protection plan and the reclassification
action along with his or her recommendation to the EMC for
appropriate action. Table 1 summarizes the state and local
actions needed.
2
B-4
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Table 1
Actions Needed by Local and State Government
I. Local Government Actions
A. Collect Water Supply Information
1. Define water needs (projected volume over time) 1
2. Determine potential water supply sources (location &
yield) x
3. Define specific watershed with respect to:
a) land use 2
b) point sources 3
c) nonpoint sources 3'4
d) water quality 3
B. Determine Appropriate WS Classification 3
1. State will provide assistance with specific
watershed data needs if necessary
2. Evaluate baseline data
3. Recommend classification (WS-I, WS-II, WS-III)
C. Develop Control Strategies
1. Point sources 3
2. Non-point sources 3,4
D. Adopt and Implement Control Strategies
Adopt necessary regulations and ordinances to control
the sources of nonpoint source pollution
E. Submit Proposed Classification Package to the Environ-
mental Management Commission for Preliminary Assessment
State Actions
A. Provide Guidance and Technical Assistance
B. Hold Public Hearing(s)
C. Present Final Package to Environmental Management
Commission for Appropriate Action _
Cooperation with Division of Water Resources
Cooperation with Division of Community Assistance
Cooperation with Division of Environmental Management
Cooperation with Divisions of Soil and Water
Conservation, Land Resources, Environmental Health and
Forest Resources
3
3-5
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POINT SOURCE STRATEGY
The Division of Environmental Management (DEM) already has a
well established point source program and is delegated authority
by the U.S. Environmental Protection Agency to issue National
Pollution Discharge Elimination System (NPDES) permits. This
program regulates discharges by permitting, monitoring, and
reducing pollutants from entering North Carolina's surface
waters. By preventing or limiting the number and type of
dischargers into WS-I and WS-II watersheds, the potential
pollutants that are associated with these sources will be greatly
reduced or eliminated from a water supply watershed. Large
WS-III watersheds are also being investigated for possible toxic
sources. Thorough investigations have already been completed on
two Piedmont reservoirs documenting both point and nonpoint
sources of toxicants with recommendations for future DEM action.
Other WS-III watersheds will also be investigated in the future
to document potential water quality problems.
Within a water supply (WS) watershed much greater scrutiny
will be placed on any point source discharger. Close attention
will be paid to compliance records, ambient data, bioassays,
benthic macroinvertebrate evaluations, facility age and possible
violations. The Division of Environmental Health in the
Department of Environment, Health and Natural Resources must
approve any discharger that locates within WS classified waters.
In some cases, communities are actively trying to remove point
source dischargers from their water supply watersheds. Methods
have included connecting the facility to a sewer line; converting
the discharger to a nondischarging land application system; or
constructing a large nondischarging subsurface system. These
strategies should also greatly reduce the risk of contamination
from point source dischargers.
In addition the General Procedures section, 15 NCAC 2B .0101
(e)(5) designates all WS-I and WS-II water supply watersheds as
High Quality Waters (HQW). The supplemental HQW classification
is implemented to protect waters with quality higher thatu the
standards. The provisions of the HQW classification can be found
in the Antidegratation Policy, 15 NCAC 2B .0201 (d)(1). Within
HQW watersheds new NPDES wastewater dischargers will be required
to meet more stringent treatment standards as described in 15
NCAC 2B .0201 (d)(1)(B). Also, discharges from new single family
residences will be prohibited. Those existing single family
residences that must discharge will install a septic tank, dual
or recirculating sand filters, disinfection and step aeration.
NONPOINT SOURCE STRATEGY
Local governments within a water supply watershed need"to
develop their own nonpoint source control program. All programs
should address methods of controlling surface water runoff from
new development. The statewide program guidelines only deal
with surface water pollution sources; however, the Division of
Environmental Health in the Department of Environment Health and
Natural Resources and DEM's Groundwater Section also have
4
B-6
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FIGURE 1
SURFACE WATER SUPPLY WATERSHED
(guideline concept)
m
Portion of watershed
outside critical area
Critical area is 1/2 to
1 mile zone surrounding
reservoir or water
intake point
Ridgeline
(boundary of
watershed)
Reservoir
-------
regulations addressing subsurface water pollution sources.
DEM guidelines address two portions of a watershed: the
portion outside the critical area, and the critical area as shown
in Figure 1. Control measures for the portion of the watershed
outside of the critical area should include: 1) density limits
on new development; 2) natural vegetative buffers adjacent (both
sides) to all perennial tributaries flowing to the reservoir or
direct intake with width determined from a minimum 50 foot buffer
plus 4 times the slope (ex. 5% slope, buffer = 50 + 4 * 5 = 70');
3) hazardous materials inventories and certain restrictions
placed on their use, storage and transportation; and 4) control
of runoff from the rainfall from new development if the
impervious surface is greater than the set standards. Generally,
WS-I watersheds should only have low density development and
therefore would not require structural controls. The primary
structural means of controlling runoff should be the use of wet
detention basins. Methods for sizing and designing wet detention
basins can be found in the EPA document "Methodology for Analysis
of Detention Basins for Control of Urban Runoff Quality",
(September 1986) and the State of Maryland document "Feasibility
and Design of Wet Ponds to Achieve Water Quality Control", (July,
1986) [both documents are available from DEM].
The critical area, defined as the area adjacent to the
reservoir or water intake location, needs the greatest amount of
protection because of its proximity to the water supply. The
critical area should extend 1/2 to 1 mile from the reservoir's
high water mark or intake point depending on the watershed size.
A water supply watershed equal to or greater than 100 square
miles should have a 1 mile critical area while watersheds less
than 100 square miles could have as little as a 1/2 mile critical
area. The reasoning behind this recommendation is that larger
watersheds will have more potential sources of pollution;
therefore, more protection should be provided near the intake by
the creation of a larger critical area.
Control measures within the critical area should include: 1)
no sewer connections (only allow septic tanks) except to deal
with specific problems; 2) density limits on new development of
1 dwelling/2 acres (approx. 6% impervious surface); 3) natural
vegetative buffers adjacent (both sides) to all perennial
tributaries flowing to the reservoir or direct intake with width •
determined from a minimum 50 foot buffer plus 4 times slope (ex.
for 5% slope, buffer = 50 + 4 * 5 = 70') (for more details of
this method refer to Orange County Soil Erosion and Sedimentation
Control Ordinance, see contact person listed in Appendix D); 4)
no commercial or industrial areas within the critical area.
specific strategies for WS-I, WS-II and WS-III watersheds ^
nave been compiled in the form of program outlines. These
outlines are given in Tables 2 to 4. It should be noted that
ttie minimum acceptable requirements for a
.^t^fX:Xca^on* Local governments are encouraged to take more
actions to provide greater protection (less risk of a
pollution event degrading the water quality of the source).
6
B-8
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Table 2. PROGRAM OUTLINE FOR WS-I
£OAL
Protect water supplies in undeveloped watersheds from being polluted by
point and nonpoint sources and allow the watershed to remain in
Primarily an undeveloped state.
APPROACH , . . , • x. » *
State Action - prevent any NPDES applications (point sources) from
being permitted in a WS-I watershed. _
2- Local action - develop, implement, and enforce a comprehensive
nonpoint source control program to reduce water pollution from human
activities within the watershed in areas such as agriculture,
commercial & residential development, mining, landfills, forestry
and toxic & hazardous materials.
liSCAL ACTIONS
Entire Watershed . . .
a) local sedimentation and erosion controlprogram _
b> county soil and water plans for critical erosion areas,
c) land use mapping and planning,
d) recommended land use :regulaj-ions dwelling unit per 2 acres;
1) development should be limitea to Jl u * ^
small businessess or simi a ld be restricted to
SSiiiSS! arefIt"£ J «.«
rjstXonedi"h of rSEfiS. development should not exceed 35%
built-upon. area, . ssume the ultimate responsibility
' £:rthn?o^rnoperSon and maintenance of all stonwater
control structures in adjacent to all
3) a vegetative buffer ®ho^fch y be determined by adding 50
perennial tributaries; widt y . buffer width would be
to 4 times the slope (ex. tor a* F ,
50 + 4 * 5 = 70 ft), . . _ ali hazardous materials
4) inventory should be ^tershed and hazardous spill
used and stored in the wat appropriate,
strategies should be except where permitted with
5) no land application of sludje except vft P^ nQ
special conditions on a case im-
practicable alternative allowed (existing areas may be
6) landfills should not be
allowed on a case-by-case basiJ. wastewater is allowed,
7) a non-discharging systemo d wastewater originates
but only in cases were the treateu w
2, within the watershed. where water suppiy intake is
Critical Area - portion of watersne
located mile from .the reservoir's
a) area to encompass one half or 0 ile distance upstream from
conservation pool ?£ watershed is less than 100 square
water intake site (1/2 mile
iuiLcs)
recommended land use deal with specific problem
1) no sewer connections except to
areas; limited number of small
7
B-9
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2) no commercial or industrial development,
3) new development limited to a density of 1 dwelling/ 2 acres
or 80,000 square foot lot size (approx. 6% built-upon area),
4) vegetative buffer around reservoir at least 100 feet and
greater depending on soil type and slope; stream or river
used as direct intake will have buffer 100 feet from banks
landward for a distance of 1/2 or 1 mile upstream (1/2 mile
if watershed is less than 100 square miles); if 50 plus 4
times slope is greater than 100 feet then this value should
be used as the width of the buffer,
5) no permanent structures should be built in the vegetative
buffer,
6) no industrial or commercial hazardous material use or storage
(limited existing uses may be allowed),
7) no land application of sludge,
8) special ordinances to consider - floodway, sedimentation,
unsuitable land, zoning, subdivision, mobile home, etc. •&.
3. Special Use Provisions -New development not complying with the above
requirements could be allowed on a case-by-case basis if special
safeguards against contamination are proposed and approved by the
appropriate state authority.
8b-io
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Table 3. PROGRAM OUTLINE FOR WS-II
• GOAL
Protect water supplies in moderately developed watersheds from being
Polluted by point and nonpoint sources and allow the watershed to remain
ln a moderately developed state.
' approach
1• State Action - Limit the number and type of NPDES applications
(point sources) to be permitted in a WS-II watershed to domestic
discharges only. Exceptions may be made by the EMC for some mining
and non-process industries. WS-II watersheds are classified as HQW
and therefore NPDES wastewater dischargers are subject to treatment .
standards as set in 15 NCAC 2B .0201 (d) (1) 'lOc-tLAc tvi
Local Action -develop a comprehensive nonpoint source control
program to reduce water pollution from human_ activities within the
watershed from agriculture, commercial & residential development,
raining, landfills, forest and from toxic & hazardous materials.
Under some circumstances a water supply having a potential WS-II
rating may request a WS-I classification. This would require
documentation of steps to be taken in removing any point source
(within 3 months). After one year, documentation must be submitted
to DEM which indicates the progress toward removal of these point
sources.
^2£AL actions (Nonpoint sources)
Entire Watershed
a) local sedimentation and erosion control program,
b) county soil and water plans for criteria erosion areas,
c) land use mapping and planning,
d) recommended land use regulations should include the following
requirements:
1) all new development should control the runoff from rainfall
events as outlined below:
impervious % runoff to control
12 - 30 1st1/2"
30 - 70 1st 1"
2) local governments should assume the ultimate responsibility
for the proper operation and maintenance of all stormwater
control structures in the watershed,
3) vegetative buffer should be maintained adjacent to all ^
perennial tributaries, with width in feet equal to 50 plus 4
times the slope (ex. for 5% slope, buffer width would be 50
+ 4 * 5 = 70 ft)
4) all hazardous materials that are used and stored in the
watershed should be inventoried, ...
5) the land application of sludge material is allowed, but
should be limited to areas in the headwaters of the watershed
away from the critical area and should primarily handle
domestic and municipal sludge,
6) new landfills are notaTlowed (existing areas may be allowed
2 on a case-bv-case basis) . . . . . „
Critical Area - portion of watershed where water supply intake is
located,
9
B-ll
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a) area to encompass one half or one mile from reservoirs
conservation pool elevation or one mile distance upstream from
water intake (1/2 mile if watershed is less than 100 square
miles)
b) recommended land use regulations,
1) no sewer connections except to deal with specific problem
areas; limited number of small businesses,
2) no commercial or industrial development.
3) new development limited to 1 dwelling/2 acres or 80,000
square foot lot size (approx. 6% built-upon area),
4) vegetative buffer around reservoir at least 100 feet and
greater depending on soil type and slope; stream or river
used as direct intake will have buffer 100 feet from banks
landward for a distance of 1/2 or 1 mile upstream (1/2 mile
if watershed is less than 100 square miles), if 50 plus 4
times the slope is greater than 100 feet, then use this value
as the width of the buffer,
5) no permanent structure should be built in the vegetative
buffer,
6) no hazardous material use or storage (limited existing uses
may be allowed),
7) no land application of sludge material,
8) special ordinances to consider - floodway, sedimentation,
unsuitable land, zoning, subdivision, mobile home, etc.
3. Special Use Provisions - New development not complying with the
above requirements could be allowed on a case-by-case basis if
special safeguards against contamination are proposed and approved
by the appropriate state authority.
D. STATE ACTIONS (Point sources)
1. Identify domestic dischargers and their effluent characteristics
a. Review compliance and ambient water quality data related to
facility.
b. Review facility age and water quality violations.
c. Seek additional physical, chemical or biological data that may
be needed, especially toxicant and bioassay data.
2. Recommend methods to control any point source problem. This may
include modifying treatment procedures, installing new equipment,
upgrading an entire system, and wastewater treatment reliability
measures may be needed. A spill/failure containment plan may also
be required.
3. Evaluate the potential for future domestic dischargers (number,
type, and location).
10
B-12
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Table 4. PROGRAM OUTLINE FOR WS-III
A WS-III water supply would have the same requirements as
the old A-II classification. This classification has no
categorical restrictions on watershed development or discharges
unlike the restrictions placed on WS-I and WS-II water supplies
However, these watersheds also need protection^from sources or
point and nonpoint pollution. DEM has an ongoing program to
investigate toxic substances in large watersheds (typically
WS-III water supplies). To date, two Piedmont water-supply
sources have been evaluated. The resulting reports include
in-depth evaluations of possible toxicant sources in the
watersheds, analysis of available toxicant data from point and
nonpoint sources, and recommendations for future DEM actions to
protect these lakes from toxicants._ Future studies will focus
other large watersheds to address similar water quality concern.
The nonpoint source control program for a WS-III watershed
would be similar to one for a WS-II watershed and allow sewer
extensions outside the critical area (designed to mimic th
-------
LEGAL MECHANISMS
There appear to be five legal bases that local governments
can utilize in implementing a nonpoint source control program.
They include general ordinance-making power, zoning authority,
subdivision control, soil erosion/sedimentation control, and
local board of health regulations. All these devices have
certain jurisdictional questions that must first be answered.
For assistance in deciding which legal mechanism to utilize,
please contact the local Regional Office of the Division of
Community Assistance or the Institute of Government in Chapel
Hill.
FURTHER INFORMATION
Specific information about the different aspects of the water
supply protection program can be obtained in the form of
appendices to this basic guideline document. These subjects
include definitions of water supply terms, background of new WS
classification, communities with WS protection regulations,
communities with surface water supplies, specific items for
structural and nonstructural nonpoint source control measures,
maps of WS-I, WS-II, and WS-III locations and water quality
standards that apply. Please contact Steve Zoufaly, Coordi-
nator, Water Supply Protection Program, DEHNR - DEM, P.O. Box
27687, Raleigh, North Carolina, 27611 or call (919) 733-5083 to
obtain copies of this material.
12
B-14
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appendix c
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STATE OF NORTH CAROLINA
COUNTY OF DURHAM
IN THE -GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
89 CVS 03348
STATE OF NORTH CAROLINA, ex rel
William W. Cobey, Jr., Secretary,
Department of Environment, Health,
and Natural Resources, and
ex rel ENVIRONMENTAL MANAGEMENT
COMMISSION,
Plaintiff,
v.
CITY OF DURHAM,
Defendant.
£
'71
n
CONSENT JUDGMENT^
(JOC # 89-03) J
THIS CAUSE came on to be heard this day before the
undersigned Judge of Superior Court upon joint appearance by
the parties, who have announced to the court that all
. between them as alleged in the
matters in controversy Detw««=»
, «,fctled and that they have consented to
Complaint have been settxea
consent Judgment upon the following
the entry of the conseuu
stipulations and terms:
STIPULATED FACTS
!. The plaintiff U the sovereign State of North
of Environment, Health, and
Carolina. The Department
/tiehnr) is an agency of the State
Natural Resources (DEHNKJ
ncGS 1430-275, fit sea? and William
established pursuant to
,e it8 secretary. The Environmental
W. cobey, Jr. is 1" f
IMC) is an agency of the State
Management commission
«t" -toi ;NC0S'<• -14^®SS3.
established pursuant 'to*
c-l
-------
2. The defendant, City of Durham, in the County of
Durham, North Carolina, is an incorporated municipality
established and created under North Carolina law. The
current mayor of Durham is Wilbur P. Gulley, upon whom
service of process may be made pursuant to Rule 4(j)(5)a of
the Rules of Civil Procedure.
3. The City of Durham holds North Carolina NPDES
Permit No. NC0047597 for operation of an existing wastewater
treatment works, the Parrington Road Wastewater Treatment
Plant, and for making an outlet therefrom for treated
wastewater to New Hope Creek, Class "C-NSW" waters of this
State, in the Cape Fear River Basin. The City of Durham
holds North Carolina NPDES Permit No. NC0026336 for
operation of an existing wastewater treatment works, the Eno
River Wastewater Treatment Plant, and for making an outlet
therefrom for treated wastewater to the Eno River, Class
"C-NSW" waters of this State, in the Neuse River Basin. The
City of Durham holds North Carolina NPDES Permit No.
NC0026310 for operation of an existing wastewater treatment
works, the Little Lick Creek Wastewater Treatment Plant, and
for making an outlet therefrom for treated wastewater to
Little Lick Creek, Class "C-NSW" waters of this State, in
the Neuse River Basin. The City of Durham holds North
Carolina NPDES Permit No. NC0023841 for operation of an
existing wastewater treatment works, the Northside
Wastewater Treatment Plant, and for making an outlet
therefrom for treated wastewater to Ellerbe Creek, Class
C-2
-------
"C-NSW" waters of this State, in the Neuse River Basin.
The City of Durham does not have approved facilities and
permits to entirely accommodate sludge disposal for these
wastewater treatment facilities. The City cannot
consistently comply with Toxicity limits proposed in the
NPDES Permits for these four wastewater treatment plants and
these limits have been adjudicated by the City. The City is
noncompliant with the final effluent limit for Mercury
contained in the NPDES Permit at the Farrington Road WWTP
and will not be able to meet the proposed limits for Nickel,
, — - in the draft NPDES Permit.
Cadmium, and Lead contained in
intensive water quality field and monitoring studies
indicate that existing final limits for oxygen-consuming
.a„nna the dissolved oxygen standards in
wastes are not protecting tne
* River and Ellerbe Creek. Nutrient
New Hope Creek, the Eno River
. poad. Eno River and Northside
inputs from the Farrington Roaa,
x. „ianK? are contributing to local
wastewater treatment plants
-nd violations of the chlorophyll a
eutrophication problems an
„_-nAards in the downstream receiving
and dissolved gases standards
c fco consolidate the four wastewater
waters. The City wants to cons«
treatment facilities into two expanded
eliminating the remaining facilities. This
i mav cause the two facilities to
consolidation of the plants may cau*
, design capacities for flow.. This order
exceed their current design
„ orderly transfer of flows during the
will allow the orderly
. . n,noe «m reroire preparation of-
construction period.
- tor.
plans and specific.$t4&^:-"*
-------
of, additional treatment works as v/ell as detailed planning
evaluations to comply with sludge disposal, toxicity
reduction and pretreatment program requirements.
The noncompliance with final effluent limitations and
requirements constitutes causing and contributing to
pollution of the waters of the State, and the City is within
the jurisdiction of the Commission as set forth in NCGS
Chapter 143, Article 21.
4. The City of Durham, due to its noncompliance and
desire to expand its present waste treatment capacity, must
provide financing for, plan and construct treatment works
which will treat the wastewater presently being discharged
and any additional wastewater desired to be discharged, to
the extent that the City will be able to comply with final
permit effluent limitations and requirements.
5. In response to the National Municipal Policy, 49
F.R. 3832, January 30, 1984, adopted by the United States
Environmental Protection Agency for assuring compliance with
the federal Clean Water Act, 33 U.S.C. §1342, by
publicly-owned treatment works, and in recognition of that
Act's July l, 1988, deadline for compliance [§1311 of the
Act initially required compliance by July 1, 1977, but
extensions of time were granted until July 1, 1988 if
construction was required for compliance, pursuant to
§1311(i)], the Department and Commission have identified the
Farrington Road Wastewater Treatment Plant, the Eno River
Wastewater Treatment Plant, the Little Lick Creek Wastewater
Treatment Plant, and the Northside Wastewater Treatment
C-4
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5
Plant of the City of Durham as facilities which were not in
compliance due to extraordinary circumstances. The City has
appropriated funds and contracted with a consulting engineer
who will investigate in detail the present procedures at the
treatment facilities and the waste streams being received,
and will make recommendations for changes and procedures
Viri no the City into compliance with final
necessary to bring *
affluent limitations. The City has also indicated that it
will redraw boundaries o£ the service areas for the E„o
River and Northside Wastewater Treatment Plants to address
• ^rilities and existing on-site wastewater
existing raciJ-n-J-co
treatment systems.
STIPULATED TERMS
6. The defendant, City of Durham, waives service of
process, accepts service of the Complaint, and admits ail
averments contained in the Complaint.
7. The defendant, City of Durham, shall pay all court
costs in this cause.
8. The parties agree that this Consent Judgment
supersedes the requirements of any previously entered
Special Orders by Consent and constitutes full settlement of
all matters referred to in the Complaint, with the following
caveat: the plaintiff reserves all rights . to otherwise
assess appropriate ...civil pftaalti.es' pursuant yta.*j tNCGS
143-215.6
-------
(>
Farrington Road Wastewater Treatment Plant, the Sno River
Wastewater Treatment Plant, the Little Lick Creek Wastewater
Treatment Plant and the Northside Wastewater Treatment Plant
by the defendant City of Durham, including but not limited
to any failures to comply with interim effluent limitations
and monitoring requirements, with the exception of the
interim effluent limitation for effluent toxicity which both
parties agree may be heard and considered by the court on an
appropriate motion for relief of any civil penalties imposed
by DEHNR. The parties further agree this Consent Judgment
is supplementary to the obligations of the defendant under
state and federal water quality statutes.
9. The defendant, City of Durham, agrees to perform
all of the following:
(a) During the period of this Consent Judgment, meet
and comply with the final terms and conditions of the
permits for each of the City's wastewater treatment
plants, except as such terms and conditions are
modified by Attachments A, B, and C attached hereto.
(b) Upon entry of the Consent Judgment, undertake the
following activities in accordance with the indicated
time schedule:
1) Plant Construction
i) Submit plans and specifications to
DEHNR, which are sufficient to obtain
its approval, "for improvements to the
Farrington Road Wastewater Treatment
Plant and the Northside Wastewater
Treatment Plant, including description
funding sources no later than *
months after issuance of NPDES Perffli-t®
for the expanded facilities which
a capacity of at least 20 mgd per pl*nt*
C-6
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j_i) Award contracts no later than 6 months
after approval of plans and
specifications 'by DEHNR, for the
respective plant.
iii) Begin construction (contractor on site
and mobilizing) no later than. 3 mouths
after contract award for the respective
plant.
iv) Complete construction (all treatment
units necessary for achieving compliance
are functional) no later than 3 years
after construction initiation for the
respective plant.
,) cease the discharges from the Eno River
wastewater Treatment Plant and the
Tittle Lick Creek Wastewater Treatment
Plant no later than 1 month after
completion of construction at the
Northside WWTP.
•\ in-ain compliance with all final
Affluent limitations at the Farrington
fell and Northside WWTPs no later than 3
months after construction completion of
the respective plant.
2) Sludge Management
i)
Submit a short-terra sludge management
plan to DEHNR which is sufficient to
obtain its approval, on or before
October It 1989. This plan must include
an inventory of all existing sludge
including the identification of
permanent and temporary sludge holding
Unities, provisions for the disposal
Of all existing sludge and all sludge
«inerated in the interim, and provisions
X? the return of all identified
temporary sludge .holding areas to their
original state.
.M Baain implementation of the approved
short-tarn Plan
approval by DEHNR of the plan
sSittedunder 2(1) ahow.
. ^ for sludge disposal from
1U' 2£"tto buttle? J» raHKS
is sufficienfcx•. i obtain L
approval on or ¦
C-7
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8
This plan may be flexible in that
alternative disposal methods may be
proposed for various stages in the life
of the expanded facilities.
iv) Complete disposal of all sludge in
temporary holding facilities identified
in the short-term management plan and
return to their original state no later
than 1 year after approval of the
short-term sludge plan by DEHNR.
v) Begin implementation of the approved
plan for disposal of sludge from the
expanded facilities no later than 3
months after construction completion.
Toxicity Evaluation
i) Obtain the services of a consultant
laboratory for the purpose of conducting
toxicity reduction evaluations at the
four wastewater treatment plants on or
before September 1, 1989.
ii) Submit a plan for toxicity reduction
evaluations for the four wastewater
treatment plants to DEHNR which is
sufficient to obtain its approval, which
includes but is not limited to waste
minimization, identification of toxic
constituents and treatment for removal
of toxicity on or before November 1,
1989. The proposals for the Eno River
and Lick Creek WWTPs may include a bench
scale treatment test using the proposed
treatment scheme at the expanded
Northside WWTP, and using influent
concentrations in the approximate
concentrations which these facilities
will contribute• to the Northside
facility when connected.
iii) Begin implementation of the approved
toxicity reduction evaluation plan no
later than 60 days after approval of the
plan by DEHNR.
Pretreatraent
i) Submit a plan for a long-term monitoring
program for all four . wastewater
treatment facilities to DEHNR which is
sufficient to obtain its approval, to
C-8
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9
collect data to derive removal
efficiencies over each unit operation
and collect data for upstream and
domestic contributions for use in future
headworks analyses, on or before August
1, 1989.
ii) Begin implementation of the approved
monitoring plan no later than 30 days
after approval by DEHNR.
(c) During the time in which this Consent Judgment is
effective, comply with the interim effluent limitations
and monitoring requirements contained in Attachments A,
B and C Notwithstanding their inclusion in this
Order the' requirements contained in Attachments A, B,
and C shall be considered as normal permit limitations,
wit-h All riahts, obligations, liabilities, procedures,
aid defences under state and federal law available to
bo?h partes for violation of these limitations.
Specifically, penalties assessed, if any, for violation
of the requirements in Attachments A, B, and C may be
hWt to appropriate challenge under the
fSminiRtrative Procedures Act. Additional monitoring
Administrative^ ^ ^ Director on a case-by-case
may be r q ^ monitoring requirements may be
contained in either a new NPDES permit or a letter from
the Director.
» Ufar than 14 calendar days after any date or
ia'ffied for accomplishment of any activity
time idairtjtija submit to the DEHNR, attention
listed in siat . ^on Qf Environmental Management,
Director or " f compliance or noncompliance
written no"%-he case of noncompliance, the notice
therewith. m ^ fc _ent 0f the reason(s) for noncom-
shall include a s _ . £on(s) taken, and a statement
pliance, ^ which subsequent dates or
iSsi£f«n9accMpli«l"snt of listed activities nay be
affected.
annual reports to the Raleigh Regional
(e) Submit s^iannu P^tion on slu ^!^?^t^ due on August 1 of each year
activities. The of activities ft* the laet 6
will be a brief summ»*jr
will be
months.
months.
if) Submit quarterly reports tpj£h&^l«igth-*e.gionai
Office concerning tlftf :progrea» :«adte on ithe : toxicity; •
reduction evaluations'.
C-9
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10
(g) Reopen some or all industrial pretreatment permits
if it is determined that the toxicity can be reduced
most effectively through pretreatment at the
industries.
(h) Enforce the water conservation provisions of the
State Building Code as it applies to new residential
construction (Volume 11 - Chapter IV 401.2, 401.3).
(i) Implement the pretreatment program as approved by
the Director, including the enforcement of both
categorical pretreatment standards and local limits.
Modify the City's sewer use ordinance to adopt new and
modified local limits as necessary to ensure compliance
with State and Federal pretreatment regulations.
(j) Continue its program of infiltration/inflow
identification and correction and submit reports to the
DEHNR Raleigh Regional Office by the last day of each
calendar quarter.
(k) Deny acceptance of any septage, sludge, or residue
from any domestic or industrial septic tank, pretreat-
ment facility, or wastewater treatment facility into
the Eno River and Lick Creek Wastewater Treatment
Plants or into any portion of the sewerage systems that
are tributary thereto.
(1) Design of the expanded treatment facilities at the
Farrington Road and Northside WWTPs shall include the
necessary facilities for the positive removal of grease
and scum from the affected process units and/or
facilities to keep grease from entering the primary
treatment units. Design shall include provision for
acceptance of grease -trap pumpage.
(m) Should it become necessary to by-pass treatment
components, the City of Durham must obtain approval
from the Director. Scheduled by-passes will only begin
after prior approval has been received from the
Director. Unforeseen by-passes' must be reported to the
Director as quickly as possible but in no case later
than 24 hours after the event begins and must be
followed up within five (5) working days with a written
request for approval. By-passes conducted in
accordance with the Director's approval will not
constitute a violation of this consent judgment.
ifi Require conn©ction of dwelling units within the
to the city's sanitary sewer system when
. . listing wastewater disposal system is determined.
J;® T®, inadequate or "failing" based upon written
Manaiimf^ ^ either the Divisipn of Environmental
anagement or the Durham County Health Department.
C-10
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11
(o) Give priority for extension of sewer lines and
installation of sewer taps to areas within the citv
limits when the Durham County Health Department-
identifies them through written notification to the
City that a health hazard exists due to "failina"
septic tank systems. g
(p) Provide a certification for all new development
projects (excludes City or County projects for areas
with failing on-site treatment systems) in the Eno
River Service Area requiring nondischarge permits for
sewer lines indicating that the projects comply with
State watershed protection guidelines regarding
watercourse buffers and stormwater control (but not
land use restrictions) for Class "WS-II" watersheds as
defined in DEM Report No. 87-05 (December 1987)
"Guidelines for Obtaining a Protective Surface Water
Classification". Plans and specifications to verify
compliance with watershed protection guidelines must
also be provided. Submission of certifications and
plans/specifications is only required until the Eno
River Environmental Impact Statement is approved.
(q) Provide provisions detailing the City's redrawing
of the service area boundaries of the Eno River WWTP
and the Northside WWTP to reflect the pumping of
450,000 GPD of wastewater from the Mitsubishi facility
to the Northside WWTP and to reflect the pumping of
410 000 GPD of wastewater from Durham County areas to
the' Northside WWTP to accommodate areas with failing
on-site treatment systems.
(r) Provide provisions for pumping from the Farrington
Road and Little Lick Creek WWTPs to the Northside WWTP
i-f necessary. The allowance of this pimping is
pursuant to the provisions of NCGS 143-215.67(b).
Submit Plans and specifications for pump stations
and outfall lines from the Eno River, Lick Creek, or
tht Farrinaton Road WWTP within 90 days of the last day
of the month in which the 12 mohth flow average reaches
2 13 m
-------
1 2
(t) Advertise the above-mentioned pump stations and
outfall lines for bids within 45 days of the last day
of the month in which the 12 month flow average reaches
either 12.35 mgd at the Farrington Road WWTP (unless
construction of the Farrington Road WWTP expansion will
be completed within 9 months), 1.4 3 mgd at the Lick
Creek WWTP, or 2.38 mgd at the Eno River WWTP.
(u) Begin construction of any of the above-mentioned
pump stations within 6 months of the last day of the
month in which the 12 month flow average reaches either
12.35 mgd at the Farrington Road WWTP (unless
construction of the Farrington Road WWTP expansion will
be completed within 9 months), 1.43 mgd at the Lick
Creek WWTP, or 2.3 8 mgd at the Eno River WWTP.
(v) Withdraw the request for an adjudicatory hearing
concerning the limits contained in the current NPDES
permits for the Farrrington Road, Eno River, Little
Lick Creek, and Northside WWTPs by contacting the
Office of Administrative Hearings no later than 14 days
following issuance of this Consent Judgment.
10. This consent judgment may be reopened after the
toxicity reduction is complete:
(i) to include additional construction dates, and an
extension of the deletion of toxicity limits and/or
relaxation of metals limits, if once the cause of the
chronic toxicity is identified, it is determined that
tested and proven treatment technologies are available
to reduce the toxicity and the treatment can be
performed most efficiently and cost effectively at the
City of Durham Wastewater Treatment Plants; or
(ii) to extend the deletion of toxicity limits and/or
relaxation of metals limits until construction will be
completed to allow time for industries to install
necessary treatment facilities if it is determined that
the treatment can most efficiently and cost effectively
C-12
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13
be conducted through pretreatment; or (iii) to include
an extension of the deletion of toxicity limits and
additional requirement for a toxicity reduction
evaluation plan if implementing the approved toxicity
reduction plan necessitates such extensions.
11. This consent judgment may be reopened to include
additional time to submit a description of funding sources
and any other dates affected, if adequate documentation of
the need for additional time is submitted to the Director of
the Division of Environmental Management.
12. Additional sources of waste flows are prohibited
by NCGS 143-215.67 (a). However, notwithstanding the entry
of this Consent Judgment, the plaintiff Commission, or its
ritv of Durham to accept additional
delegate, may allow the City o
Farrinqton Road Wastewater Treatment
waste flows to it.
wastewater Treatment Plant, Lick Creek
Plant, Eno River Wasteware
oianfc and Northside Wastewater
wastewater Treatment Plant
to the provisions of NCGS-
Treatment Plant, pursuant
~*nriate. in addition, waste flows
143-215.67(b), where appropriate.
Treatment Plant may not exceed
to the Eno River Wastewater Tre
• -he pendency of the 'Eno Hiver Environmental
2.5 MGD during the pen
The Division of Environmental Management
Impact Statement. *" v • .
„,M-by-ca«e basis aach »ewer llne
may review on a S4rvice jjsi to determine whether
submitted in the ,...lines for watershed orotsction
it complies with State ^Unes
in Class "WS-II* wat'arsBoto."
C-13
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1 4
13. Unless excused under Paragraph 14, the defendant
City of Durham, shall pay the plaintiff Department and
Commission the following stipulated penalties for failure to
meet the deadlines set out in Paragraph 9(b):
DEADLINE
PENALTY AMOUNT
1) Plans and specifications
2) Award Contracts
3) Construction initiation
4) Construction completion
5) Cease discharge from Eno
River and Little Lick Creek
WWTPs
6) Compliance as of the date
specified in paragraph
9 (b) (1) (vi)
Northside WWTP
Farrington Road WWTP
7) Short-term sludge
management plan
8) Implement short-term
sludge management plan
9) Sludge management plan
for the two expanded
facilities
10) Close out sludge
storage areas
11) Implement sludge management
plan for the two expanded
facilities
12) Obtain consultant for TRE
13) Submit TRE plan
$100/day for first 7
days, and
$500/day thereafter
same
same
same
same
$10,000 (single penalty)
$10,000 (single penalty)
$100/day for first 7
days, and
$500/day thereafter
same
same
same
same
same
same
C-14
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15
14) Implement TRE plan same
15) Submit pretreatment same
monitoring plan
16) Implement pretreatment same
monitoring plan
Payments shall be made by certified check, made payable to
the "Department of Natural Resources and Community Develop-
ment", and shall be made within fourteen (14) days following
demand by the plaintiff-
14. stipulated penalties are not due if the defendant,
the plaintiff Department, or this
City of Durham satisrie*
^-i.'ance was caused by events or
Court, that non-compliance
W rr>nA the defendant's control. Such events
circumstances beyond
not include failure to obtain state or
or circumstances d
- ^ilure to schedule or pass necessary
federal grant funding,
nt-her failures to obtain necessary
bond referenda, or
frhe consent judgment is reopened in
financing(unless
oarMraph HI, -"V lnclude dela*s caused
accordance with p 9 , , .
nrovided that such delays could not be
by contractors P ^ 4. »* * j *.
, by the Defendant and that Defendant
reasonably ant P ^ ^ and minimize such delays.
has made its best • concerrling whether stipulated
Any dispute which
*11 in the first instance be subject to
penalties are due « ^ parties, initiated by
informal negotrat on ^ cMmot resolve the dispute
written request. ^ ^ request, the dispute may
within 30 days f party to tk# -Swjrt-rHIa# jadieial
be referred W ^ -ay xe«r :«e
resolution. " 6X19
C-15
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16
matter to the Court prior to the expiration of the 30-day
period; and the 3 0-day period may be extended or shortened
by mutual agreement of the parties or by Court order. The
filing of a petition seeking dispute resolution as to the
payment of stipulated penalties will not extend or postpone
the defendant-City obligations, and upon dispute resolution
the defendant-City shall have the burden of proof.
15. Notwithstanding any provision of this order to the
contrary, in the event that, during the pendency of this
Order, fines are assessed or other enforcement action is
brought against the City for violation of the toxicity
limits contained in Attachments A and B, the court may
determine whether such fines may be imposed, and in what
amount, taking into account among other things, the
feasibility of compliance with the limits and the
reasonableness of the City's efforts to comply.
16. The terms of this Consent Judgment may be enforced
by and through the contempt powers of the Court.
17. This Consent Judgment shall terminate three (3)
years and six (6) months after construction initiation;
except that determinations of final1 compliance made by the
State, payment of any due penalties by the Defendant, and
request for dispute resolution may be made within 60 days
thereafter. Following the expiration of this Consent
Judgment, any permit violations will be subject to all
enforcement procedures as allowed by G.S. 143-215.6.
C-16
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IT IS THEREFORE, upon the consent of the
e parties and
without the taking of any 'testimony, ORDERED ADJUDGED and
DECREED;
1. The above stipulated facts and terms, as agreed to
by the parties, are hereby made specific findings and orders
of this Court.
2. The parties, with Court approval, may jointly
modify the provisions of this Consent Judgment.
3. The Court shall retain necessary jurisdiction of
this matter for purposes of enforcing the terms of the
Consent Judgment; for purposes of determining any matters in
dispute; and for purposes of determining any motions for
further relief based on changes of circumstances.
C-17.
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1 M
This the it day of JjfiV+fal. 1989
HQPHT- '
BY CONSENT:
FOR THE/CITY OF DUR
City Manager
ktuj^ k.
Assistant City Attorney
FOR THE DEPARTMENT OF
ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
AND^CWVIRQNHKNTAL MANAGEMENT COMMISSION
Director, Division of
Environmental Management
LACY H. THORNBURG
ATTORNEY GENERAL
ASSISTANT ATTORNEY GENERAL 0
Judge of Superior Court
C-18
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ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 1 of 42
Farrington Road WWTF
NPDES Permit No. NC0047597
(Suunmer: April 1 - October 31)
During the period beginning on the effective date of the Order and lasting until December 31, 1989, the
permittee is authorized to discharge from outfall serial number(s) - 001. Such discharges shall be
limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monthly Avq. Weekly Avg.
Flow « **
BOD, 5Day, 20°C **
Total Suspended Residue
NH, :
Dissolved Oxygen (minimum)
Fecal; Caliform (geometric mean)
Residual.Chlorine
Temperature
Total Nitrogen (N02 + NO., + TKN)
Total; ^Phosphorus
Mercury
Zinc
Copper
Cyanide
Chromium
Nickel;
Cadmiwv;
Lead::;
Toxicity;.
Pollutant Analysis
Oil :..Sr Grease
Conductivity
Total Phosphorus
TK$;;
NOj + NO-
NH^ • as, N
PH •
10.0 MGD
7 - 0 mg/1
30.0 mg/1
2.0 mg/1
5.0 mg/1
1000/100 ml
10.5 mg/1
45.0 mg/1
3.0 mg/1
5.0 mg/1
2000/100 ml
75.0 ug/1
****
*****
50.0 ug/1
Monitoring Requirements
Measurement Sample *Sample
Frequency Type Location
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Daily
Daily
Daily
Daily
Quarterly
Annually
Monthly
*
*
*
*
*
*
*
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
I or E
I ,E
X,E
E
E,U,D
E,U,D
E
E,U,D
E
E
E
E
E
E
E
E
E
E
E
E
E
U,D
U,D
U,D
U,D
U,D
U,D
U,D
o
-------
ATTACHMENT A
Page 2 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
* Sample locations: E - Effluent, I - Influent, U - Upstream fifty (50) feet above discharge,
D - Downstream 1) at DN^ above subimpoundment, 2)at NCSR 1107, 3) at DN5 five miles downstream.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September
and once per week during the remaining months of the year.
** The monthly average effluent BOD5 and Total suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).
*** Daily maximum limitation.
**** See Attachment B, Pages 1 and 2 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 99%, °
October, January, April and July. "
***** S.^e, Attachment C, Page 1 of 4.
The. pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
sfaail be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
-------
ATTACHMENT A
Page 3 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim (Winter: November 1 - March 31)
During the period beginning on the effective date of the Order and lasting until December 31, 1989, the
permittee is authorized to discharge from outfall serial number(s) - 001. Such discharges shall be
limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
Measurement Sample
"Sample
20°C
* *
Flow
BOD, 5Day, «-v ^ **
Total Suspended Residue
NH3 as, N: ..
Dissolved'Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (NO-
Total Phosphorus
Mercury
Zinc
poppert
+ NO, + TKN)
Chromi-urrt
Nickel,
Cadmium"
iead
Toxicity
pollutant
Oil & Grease
Conductivity
Analysis
Monthly Aver.
Weekly Avg.
Frequency
Type
Location
10.0 MGD
Continuous
Recording
I or E
10.0 mg/1
15.0 mg/1
Daily
Composite
I,E
30.0 mg/1
45.0 mg/1
Daily
Composite
I,E
4.0 mg/1
6.0 mg/1
Daily
Composite
E
5.0 mg/1
5.0 mg/1
Daily
Grab
E,U,D
1000/100 ml
2000/100 ml
Daily
Grab
E,U,D
Daily
Grab
E
Daily
Grab
E,U,D
Monthly
Composite
E
Weekly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
***
Monthly
Grab
E
75.0 ug/1
50.0 ug/1
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
****
Quarterly
Composite
E
*****
Annually
E
Monthly
Grab
E
*
Grab
U,D
CM
I
O
-------
ATTACHMENT A
Page 4 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
Sample locations: E - Effluent, I - Influent, U - Upstream fifty (50) feet above discharge,
D - Downstream at NCSR 1107.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September
and.-'once per week during the remaining months of the year.
The monthly average effluent BODc and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).
Daily maximum limitation.
See Attachment B, Pages 1 and 2 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 99%,
October, January, April, and July. ^
CM
I
Attachment C, Page 1 of 4. °
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
'Shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 5 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
(Summer: April 1 - October 31}
During the period beginning on January 1, 1990 and lasting until December 31, 1990, the permittee is
authorized to discharge from outfall serial number(s) - 001. such discharges shall be limited and
monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monthly Avq. Weekly Avq.
**
Flow n **
BOD, 5Day, 20 C
Total-Suspended Residue
NH3 as N
Dissolved Oxygen (minimum)
Fecal-Collform (geometric mean)
Residaal • Chlorine
Temperature
$OtaMmt*ogen (NO, + NO^ + TKN)
Total Phosphorus
Mercury
Zinc
Copper
Cyanide-
Chromium
Nickel ^
'Cadmium^::
Lead
Toxicity
¦Pollutant Analysis
Oil & Grease
'Conductivity
iTo t a 1- Pho spho ru s
Sa
NO? + NO,
tm* as .nj
:phj
13.0 MGD
7.0 mg/1
30.0 mg/1
2.0 mg/1
5.0 mg/1
1000/100 ml
10.5 mg/1
45.0 mg/1
3.0 mg/1
5.0 mg/1
2000/100 ml
2.0 mg/1
***
75.0 ug/1
50.0 ug/1
*****
******
Monitoring Requirements
Measurement sample *Sample
Frequency Type Location
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Daily
Daily
Daily
Daily
Quarterly
Annually
Monthly
*
*
*
*
*
*
*
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
I or E
I/E
I,E
E
E,U,D
E,U,D
E
E,U,D
E
E
E
E
E
E
E
E
E
E
E
E
E
U,D
U,D
U,D
U,D
U,D
V,D
U,D
-------
ATTACHMENT A
Page 6 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
Sample locations: E - Effluent, I - Influent, U - Upstream fifty (50) feet above discharge,
D - Downstream l)at DN2 above subimpoundment, 2) at NCSR 1107, 3) at DN5 five miles downstream.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June', July, August and September
.and once per week during the remaining months of the year.
The monthly average effluent BOD,- and Total Suspended Residue concentrations shall not exceed
15% of the respective influent values (85% removal).
Quarterly average limitation.
Daily maximum limitation.
See Attachment B, Pages 1 and 2 of 16; Chronic Toxicity (fieriodaphnia) Monitoring only at 99%,
October, January, April and July.
* See Attachment C, Page 1 of 4.
,The pH shall not be" less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 7 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
(Winter: November 1 - March 31)
During the period beginning on January 1, 1990 and lasting until December 31, 1990, the permittee is
authorized to discharge from outfall serial number(s) - 001. Such discharges shall be limited and
monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
Monthly Avq.
Weekly Avq.
Measurement.
Frequency
Sample
Type
*Sample
Location
20°C
**
**
Flow
BOD, 5Day,
Total Suspended Residue
NH3 as N '
pi s scSJ.yed'^ Oxygen (minimum)
Fecal "Coliform (geometric mean)
Residual Chlorine
Temperature
Total-tlftrogen (NO,
Total Phosphorus
Mercury
Zinc
Copper
Cyanide.
Chromiupi:
NickeJL "v
Cadmium''
Lead
Toxicity :
Pollutant^Analysis
Pil & <3££ase
Conductivitv
N03 +
TKN)
13.0 MGD
Continuous
Recording
I or E
10.0 mg/1
15.0 mg/1
Daily
Composite
I,E
30.0 mg/1
45.0 mg/1
Daily
Composite
I>E
4.0 mg/1
6.0 mg/1
Daily
Composite
E
5.0 mg/1
5.0 mg/1
Daily
Grab
E,U,D
1000/100 ml
2000/100 ml
Daily
Grab
E,U,D
Daily
Grab
E
Daiiy
Grab
E,U,D
***
Monthly
Composite
E
2.0 mg/1
Weekly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
****
Monthly
Grab
E
75.0 ug/1
50.0 ug/1
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
Daily
Composite
E
*****
Quarterly
Composite
E
******
Annually
E
Monthly
Grab
E
*
Grab
U, D
-------
ATTACHMENT A
Page 8 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
Sample locations: E - Effluent, I - Influent, U - Upstream fifty (50) feet above discharge,
D - Downstream at NCSR 1107.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September
and once per week during the remaining months of the year.
The monthly average effluent BODn and Total Suspended Residue concentrations shall not exceed
15% of the respective influent values (85% removal).
Quarterly average limitation.
Daily maximum limitation.
See Attachment B, Pages 1 and 2 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 99%,
October, January, April, and July.
* See Attachment C, Page 1 of 4.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
-------
ATTACHMENT A
Page 9 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim (Summer: April 1 - October 31)
During the period beginning on January 1, 1991 and lasting until 3 months after construction
completion, the permittee is authorized to discharge from outfall serial number(s) - 001. Such
discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
o **
20 C
Flow
BOD,.BDSy; ~ **
Total Suspended Residue
NH3 as N
Dissolved Oxygen (minimum)
FecaleColiform (geometric mean)
Re s iduai-Chlorine
Temperature
Monthly Avg.
13.0 MGD
7.0 mg/1
30.0 mg/1
2.0 mg/1
5.0 mg/1
1000/100 ml
Total Nitrogen (NO- +
Totalephosphorus
Mercury
Zinc
Copper
Cyanide
Chromium
Nickel
Cadmium
Lead
ttoxicity
Pollutant Analysis
Oil & Grease
Conductivity
Total Phosphorus
NO- + NO,
NH, as U
NOj + TKN)
2.0 mg/1
***
****
75.0 ug/1****
75.0 ug/Ltll,
4.5 ug/1****
34.5 ug/1
*****
******
Weekly Avg.
10.5 mg/1
45.0 mg/1
3.0 mg/1
5.0 mg/1
2000/100 ml
50.0 ug/1
50.0 ug/1
2.0 ug/1
25.0 ug/1
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Daily
Daily
Daily
Daily
Quarterly
Annually
Monthly
*
*
*
*
*
Sample
Type
*Sample
Location
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Grab
Grab
Grab
I or E
I,E
I,B
E
E,U,D
E,\J,D
E
E,U,D
E
E
E
E
E
E
E
E
E
E
E
E
E
U,D
U,D
U,D
U,D
U,D
UsD
-------
ATTACHMENT A
Page 10 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
Sample locations: E - Effluent, I - Influent, U - Upstream fifty (50) feet above discharge,
D - Downstream l)at DN2 above subimpoundment, 2) at NCSR 1107, 3) at DN5 five miles downstream.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September
and once per week during the remaining months of the year.
The monthly average effluent BOD,- and Total Suspended Residue concentrations shall not exceed
15% of the respective influent values (85% removal).
Quarterly average limitation.
Daily maximum limitation.
See Attachment B, Pages 3 and 4 of 16; Chronic Toxicity (Ceriodaphnia) P/F at 99%, October,
January, April and July.
* See Attachment C, Page 1 of 4.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
Shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in'Other than trace amounts.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 11 of 42
Fax rxngton Road WWTP
NPDES Permit No. NC0047597
(Winter: November 1 - March 31)
During the period beginning on January 1, 1991 and lasting until 3 months after construction
completion, the permittee is authorized to discharge from outfall serial number
-------
ATTACHMENT A
Page 12 of 42
Farrington Road WWTP
NPDES Permit No. NC0047597
Sample locations: E - Effluent, I - influent, U - Upstream fifty (50) feet above discharge,
D - Downstream at NCSR 1107.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September
and once per week during the remaining months of the yea:.
The monthly average effluent BODe and Total Suspended Residue concentrations shall not exceed
15% of the respective influent values (85% removal).
Quarterly average limitation.
Daily maximum limitation.
cn
See Attachment B, Pages 3 and 4 of 16; chronic Toxicity (Ceriodaphnia) P/F at 99%, October, °
January, April and July.
See Attachment C, Page 1 of 4.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 13 of 42
Eno River WWTP
NPDES Permit No. NC0026336
(Summer: April 1 - October 31)
During the period beginning on the effective date of the Order and lasting until Deceiriber 31, 1990, the
permittee is authorized to discharge from outfall serial number(s) - 001. Such discharges shall be
limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
**
* *
+ N03 + TKN)
Flow.
BOD, 5t>ay, 20 C
Total Suspended Residue
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residiial Chlorine
Temperature
Total. Nitrogen (NO-
Total Phosphorus
Cadmium
Chromium
Nickel
Lead
Copiper
Zinc
Si1vet
Toxicity
Pollutant Analysis
Oil & Grease
Monthly Aver.
2.5 MGD
5.0 mg/1
30.0 mg/1
2.0 mg/1
7.0 mg/1
1000/100 ml
Weekly Avg.
7.5 mg/1
45.0 mg/1
3.0 mg/1
7.0 mg/1
2000/100 ml
2.0 mg/1
"k * *
* ***
*****
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Quarterly
Annually
Monthly
Sample
* Sample
location
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Grab
X or E
I ,E
1,E _
£
E,U,D »
E,t3,D
E
E ,U ,D
E
E
E
E
E
E
E
E
E
E
E
E
-------
ATTACHMENT A
Page 14 of 42
Eno River WWTP
NPDES Permit No. NC0026336
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).
Quarterly average limitation.
See Attachment B, Pages 5 and 6 of 16. Chronic Toxicity (Ceriodaphnia) Monitoring only at 72%,
October, January, April and July.
*See Attachment C, Page 2 of 4.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and S
shall be monitored daily at the effluent by grab sample. u
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week duririg June, July, August and September and
orice per week during the remaining months of the year.
-------
ATTACHMENT A
Page 15 of 42
Eno River WWTP
NPDES Permit No. NC0026336
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim (Winter: November 1 - March 31)
During the period beginning on the effective date of the Order and lasting until December 31, 1990, the
permittee is authorized to discharge from outfall serial number(s) - 001. Such discharges shall be
limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
Flow r, **
BOD, 5pay, 20°C **
Total:Suspended Residue
NH. as^N1,
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 + TKN)
Total Phosphorus
Cadmium
Chromium
Nickel
Lead
Copper
2inc
Silver
Toxicity ;v
pollutant ''.Analysis
911 & Grease
Other Units
(Specify)
Measurement
Sample *
Sample
Monthly Avg.
Weekly Aver.
Frecruencv
Type Location
2.5 MGD
Continuous
I
H
P
1
I or E
10.0 mg/1
15.0 mg/1
Daily
Composite
X,E
30.0 mg/1
45.0 mg/1
Daily
Composite
I,E
4.0 mg/1
6.0 mg/1
Daily
Composite
E
5.0 mg/1
5.0 mg/1
Daily
Grab
E,\J,D
1000/100 ml
2000/100 ml
Daily
Grab
E,U,D
Daily
Grab
E
Daily
Grab
E.U.D
***
Monthly
Composite
E
2.0 mg/1
Weekly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
Monthly
Composite
E
* * * *
Quarterly
Composite
E
*****
Annually
E
Monthly
Grab
E
-------
ATTACHMENT A
Page 16 of 42
Eno River WWTP
NPDES Permit No. NC0026336
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).
Quarterly average limitation.
See Attachment B, Pages 5 and 6 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 72%,
October, January, April and July.
*See Attachment C, Page 2 of 4.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September and
once per week during the remaining months of the year.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 17 of 42
Eno River WWTP
NPDES Permit No. NCGQ26336
(Summer: April 1 - October 31}
During the period beginning January 1, 1991 and lasting until 1 month after construction completion of
the Northside WWTP, the permittee is authorized to discharge from outfall serial number(s) - 001.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow £ *
BOD, 5Day, 20 C **
Total Suspended Residue
NH, as'N:-
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
Monthly Avg.
2.5 MGD
5.0 mg/1
30.0 mg/1
2.0 mg/1
7.0 mg/1
1000/100 ml
Total" Nitrogen (NO- +
Total Phosphorus
Cadmium
Chromium
Nickel
Lead
Copper
zinc
Silver
Toxicity
Pollutant Analysis
Oil & Grease
N03 +
TKN)
***
2.0 mg/1^^
6.3 ug/1****
104 ug/1****
104 ug/i****
47 ug/1
*****
******
Weekly Avg.
7.5 mg/1
45.0 mg/1
3.0 mg/1
7.0 mg/1
2000/100 ml
2.8 ug/1
69 ug/1
69 ug/1
35 ug/1
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Daily
Daily
Daily
Daily
Monthly
Monthly
Monthly
Quarterly
Annually
Monthly
Sample
TYPe
*Sample
Location
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Grab
I or E
I,E
I,E
E
E,U,D
E,U,D
I.U.D
E
E
E
E
E
E
E
E
E
E
E
E
-------
ATTACHMENT A
Page 18 of 42
Eno River WWTP
NPDES Permit No. NC0026336
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal)
Quarterly average limitation.
Daily average limitation.
See Attachment B, Pages 7 and 8 of 16; Chronic Toxicity (Ceriodaphnia) P/F at 72%, October,
January, April and July.
See Attachment C, Page 2 of 4. ^
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September
and once per week during the remaining months of the year.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 19 of 42
Eno River WWTP
NPDES Permit No. NC0026336
(Winter: November 1 - March 31)
During the period beginning on January 1, 1991 and lasting until 1 month after cons true tio.ncoraplet ion
of the Northside WWTP, the permittee is authorized to discharge from outfall serial number(s) - 00,1>
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Flow **
BOD, 5Day, 20°C **
Total Suspended Residue
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
Monthly Avq.
2.5 MGD
10.0 mg/1
30.0 mg/1
4.0 mg/1
5.0 mg/1
1000/100 ml
Weekly Avq.
15.0 mg/1
45.0 mg/1
6.0 mg/1
5.0 mg/1
2000/100 ml
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Sample
Type
Recording
Composite
Composite
Composite
Grab
Grab
*Sample
Location
X or E
I rE
I ,E
E
E,U,D £
E,U,D i
Residual Chlorine
Daily
Grab
E
Temperature
Daily
Grab
E,U,D
Total Nitrogen (NO- + NO^ + TKN)
***
Monthly
Composite
E
Total Phosphorus
2.0 mg/1****
Weekly
Composite
E
Cadmium
6.3 ug/1****
2.8 ug/1
Daily
Composite
E
Chromium
104 ug/1****
69 ug/1
Daily
Composite
E
Nickel
104 ug/1****
69 ug/1
Daily
Composite
E
Lead
47 ug/1
35 ug/1
Daily
Composite
E
Copper
Monthly
Composite
E
Zinc
Monthly
Composite
E
Silver
Monthly
Composite
E
Toxicity
* * * * *
Quarterly
Composite
E
Pollutant Analysis
******
Annually
E
Oil & Grease
Monthly
Grab
E
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ATTACHMENT A
Page 20 of 42
Eno River WWTP
NPDES Permit No. NC0026336
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream.
The monthly average effluent BOD5 and Total Suspended Residue Concentration .shall not^^cceed 15%
of the respective influent values (85% removal).
Quarterly average limitation.
Daily average limitation.
See Attachment B, Pages 7 and 8 of 16; Chronic Toxicity (Ceriodaphnia) P/F at 72%, on-nTy*!-
January, April and July.
00
* See Attachment C, Page 2 of 4. ^
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September and
once per week during the remaining months of the year.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 21 of 42
Lick Creek WWTP
NPDES Permit No. NC0026310
{Summer: April 1 - October 31)
During the period beginning on the effective date of this order and lasting until December 31, 1990,
the permittee is authorized to discharge, from outfall serial number(s) - 001. Such discharges!shall
be limited and monitored by the permittee as specified below: -
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
Monthly Avg.
Weekly Avq.
Measurement
Frequency
Sample
•gyp®
*Sample
Location
Flow
BOD, 5Day, 20oC **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 + TKN)
Total Phosphorus
Toxicity
Pollutant Analysis
Oil & Grease
1.5 MGD
Continuous
Recording
I or E
5.0 mg/1
7.5 mg/1
Daily
Composite
I,E
30.0 mg/1
45.0 mg/1
Daily
Composite
I,E
2.0 mg/1
3.0 mg/1
Daily
Composite
E
6.0 mg/1
6.0 mg/1
Daily
Grab
E,\JrD
1000/100 ml
2000/100 ml
Daily
Grab
E,U,D
Daily
Grab
E
Daily
Grab
E/U,D
2.0 mg/1***
Monthly
Composite
E
Weekly
Composite
E
Quarterly
Composite
E
*****
Annually
E
Monthly
Grab
E
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ATTACHMENT A
Page 22 of 42
Lick Creek WWTP
NPDES Permit No. NC00263i0
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream at the brieve at SR
1814.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal). •
Quarterly average limitation.
See Attachment B, Pages 9 and 10 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only" at'"99%,
October, January, April and July.
*See Attachment C, Page 3 of 4. g
I
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September and
once per week during the remaining months of the year.
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ATTACHMENT A
Page 23 of 42
Lick Creek WWTP
NPDES Permit No. NC0O2631O
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim. (Winter: November 1 - March 31)
During the period beginning on the effective date of this order and lasting until December -31, 1990,
the permittee is authorized to discharge from outfall serial number(s) - 001. Such discharges'"shall
be limited and monitored by the permittee as specified below:
Effluent Characteristics
**
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
Monthly Avq.
Weekly Avq.
Measurement
Frequency
Sample
Type
*Sample
Location
Flow
BOD, 5Day, 20oC
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 + TKN)
Total Phosphorus
Toxicity
Pollutant Analysis
Oil & Grease
1.5 MGD
Continuous
Recording
X. or E
10.0 mg/1
15.0 mg/1
Daily
Composite
I,E
30.0 mg/1
45.0 mg/1
Daily
Composite
I,E
4.0 mg/1
6.0 mg/1
Daily
Composite
E
6.0 mg/1
6.0 mg/1
Daily
Grab
E,U,D
1000/100 ml
2000/100 ml
Daily
Grab
E,U,D
Daily
Grab
E
Daily
Grab
E,\J ,D
2.0 mg/1***
Monthly
Composite
E
Weekly
Composite
E
****
Quarterly
Composite
E
*****
Annually
E
Monthly
Grab
E
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ATTACHMENT A
Page 24 of 42
Lick Creek WWTP
NPDES Permit No. NC0026310
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream at the bridge at SR
1814.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).
Quarterly average limitation.
See Attachment B, Pages 9 and 10 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 99%,
October, January, April and July.
*See Attachment C, Page 3 of 4. 5
u
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week duriftg June, July, August and September and
once per week during the remaining months of the year.
-------
ATTACHMENT A
Page 25 of 42
Lick Creek WWTP
NPDES Permit No. NCG026310L
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim (Summer: April 1 - October 31)
During the period beginning on January X, 1991 date of this order and lasting until 1 month after
construction completion of the Northside WWTP, the permittee is authorized to discharge frean outfall
serial number(s) - 001. Such discharges shall be limited and monitored by the permittee a:6 specified
below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monitoring Requirements
Flow
BOD, 5Day, 20oC **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 +¦ TKN)
Total Phosphorus
Toxicity
Pollutant Analysis
Oil & Grease
Monthly Avq.
1.5 MGD
5.0 mg/1
30.0 mg/1
2.0 mg/1
6.0 mg/1
1000/100 ml
2.0 mg/1***
** **
*****
Weekly Avq.
7.5 mg/1
45.0 mg/1
3.0 mg/1
6.0 mg/1
2000/100 ml
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Quarterly
Annually
Monthly
Sample
Type
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Grab
*Sampie
Location
I or E
I,E
I,E
E
B/U,D
E
E,\J,D
E
E
E
E
E
-------
ATTACHMENT A
Page 26 of 42
Lick Creek WWTP
NPDES Permit No. NC0026310
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream at the bridge at SR
1814.
The monthly average effluent BOD5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal)..
Quarterly average limitation.
See Attachment B, Pages 11 and 12 of 16; Chronic Toxicity (Ceriodaphnia) P/F at 99%, October,
January, April and July.
*See Attachment C, Page 3 of 4.
-4"
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and "
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September an<
once per week during the remaining months of the year.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 27 of 42
Lick Creek WWTP
NPDES Permit No, NC0026310
(Winter: November 1 - March 31)
During the period beginning on January 1, 1991 and lasting until 1 month after construction completion
Df the Northside WWTP, the permittee is authorized to discharge from outfall serial nuniber{s) 001.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
* Monitoring Requirements
Flow
BOD, 5Day, 20oC **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 + TKN)
Total Phosphorus
Toxicity
Pollutant Analysis
Oil & Grease
Monthly Avq.
1.5 MGD
10.0 mg/1
30.0 mg/1
4.0 mg/1
6.0 mg/1
1000/100 ml
2.0 mg/1***
****
*****
Weekly Avq.
15.0 mg/1
45.0 mg/1
6.0 mg/1
6.0 mg/1
2000/100 ml
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Quarterly
Annually
Monthly
Sample
TYPe -
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Grab
*Sample
Location
I or E
I,E
I,E
E
E,U,D
E
E,T3,T>
E
E
E
E
E
-------
ATTACHMENT A
Page 28 of 42
Lick Creek WWTP
NPDES Permit No. NC0026a&9o
Sample locations: E - Effluent, I - Influent, U - Upstream, D - Downstream at the bridge at SR
1814.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).-
Quarterly average limitation.
See Attachment B, Pages 11 and 12 of 16; Chronic Toxicity (Ceriodaphnia) P/F at 99%, ©Sfcefceirv;
January, April and July.
*See Attachment C, Page 3 of 4.
I
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
Stream samples shall be collected three times per week during June, July, August and September and
once per week during the remaining months of the year.
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ATTACHMENT A
Page 29 of 42
Northside WWTP
NPDES Permit No. NC0023841
EFFLUENT LIMITATIONS and MONITORING REQUIREMENTS - Interim {Summer: April 1 - October 31)'
During the period beginning on the effective date of this order and lasting until Decembert31, 1989,
the permittee is authorized to discharge from outfall serial number(s) - 001. Such discharges shall
be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
Other Units (Specify)
Flow
BOD, 5Day, 20oC **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 + TKN)
Total Phosphorus
Mercury
Cadmium
Chromium
Nickel
Lead
Cyanide
Copper
Zinc
Toxicity
Pollutant Analysis
Oil & Grease
Monthly Avq.
10.0 MGD
12.0 mg/1
30.0 mg/1
8.0 mg/1
5.0 mg/1
1000/100 ml
Weekly Avq.
18.0 mg/1
45.0 mg/1
12.0 mg/1
5.0 mg/1
2000/100 ml
* * *
****
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Daily
Daily
Daily
Daily
Monthly
Monthly
Monthly
Quarterly
Annually
Monthly
Sample:
Type
* Sample
Location
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Composite
Grab
I or E
!,e
13
E
E,U,B
E,U,D
E
E,U,D
E
E
E
E
E
E
E
E
E
E
E
E
E
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ATTACHMENT A
Page 30 of 42
Northside WWTP
NPDES Permit No. NC0023841
Sample locations: E - Effluent, I - Influent, U - Upstream see pages 41 and 42 of attachment A,
D - Downstream see pages 41 and 42 of Attachment A.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).
See Attachment B, Pages 13 and 14 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 99%,
October, January, April and July.
See Attachment C, Page 4 of 4.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and «>
shall be monitored daily at the effluent by grab sample. "?
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
-------
ATTACHMENT A
Page 31 of 42
Northside WW3L
NPDES Permit No. NC0023841
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim {Winter: November 1 - March 31)
During the period beginning on the effective date of this order and lasting until December :-31, 1989,
the permittee is authorized to discharge from outfall serial number(s)•- 001. Such discharges shall
be limited and monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
Other Units (Specify)
Flow
BOD, 5Day, 20oC **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 + TKN)
Total Phosphorus
Mercury
Cadmium
Chromium
Nickel
Lead
Cyanide
Copper
Zinc
Toxicity
Pollutant Analysis
Oil & Grease
Monthly Avq.
10.0 MGD
24.0 mg/1
30.0 mg/1
16.0 mg/1
5.0 mg/1
1000/100 ml
* * *
* * * *
Weekly Avq.
36.0 mg/l<
45.0 mg/1
24.0 mg/1
5.0 mg/1
2000/100 ml
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Daily
Daily
Daily
Daily
Monthly
Monthly
Monthly
Quarterly
Annually
Monthly
Sample'
M
Recording
Composite
*Sample
Location
Composite
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Composite
Grab
1 or E,
I ,E
X,E
E
E,V,D
E
E,\J ,D
E
E
E
E
E
E
E
E
E
E
E
E
E
o\
<*
o
-------
ATTACHMENT A
Page 32 of 42
Northside WWTP
NPDES Permit No. NC0023841
Sample locations: E - Effluent, I - Influent, U - Upstream see pages 41 and 42 of atfesaphment A,
D - Downstream see pages 41 and 42 of Attachment A.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall npfcossseeed 15%
of the respective influent values (85% removal).
See Attachment B, Pages 13 and 14 of 16; Chronic Toxicity (Ceriodapfcnia) Monitoring only at 99%,
October, January, April and July.
See Attachment C, Page 4 of 4.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and J
shall be monitored daily at the effluent by grab sample. t
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Pagre 33 of 42
Northside WWTP
HPDES Permit No. KC0023841
(Summer: April 1 - October 31;|~
During the period beginning on January 1, 1990 and lasting until Deceittber 31, 1990, the permittee is
authorized to discharge from outfall serial number(s) ~ 001. Such discharges shall be limit®! aa
-------
ATTACHMENT A
Page 34 of 42
Northside WWTP
NPDES Permit No. NC0023841
Sample locations: E - Effluent, I - Influent, U - Upstream see pages 41 and 42 of atfcS&hment A,
D - Downstream see pages 41 and 42 of Attachment A.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall noTT-eSSSed 15%
of the respective influent values (85% removal).
Quarterly average limitation.
See Attachment B, Pages 13 and 14 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 99%,
October, January, April and July.
*See Attachment C, Page 4 of 4.
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ATTACHMENT A
Page 35 of 42
Northside WWTP
NPDES Permit Ho. NC0023841
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim {Winter: November 1 - March 31)
During the period beginning on January11, 1990 and lasting until December 31, 1990, the permittee-is
authorized to discharge from outfall serial number(s) - 001. Such discharges shall be limited and
monitored by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
other Units (Specify)
Flow
BOD, 5Day, 20oC **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (NQ2 + N03 +- TKN)
Total Phosphorus
Mercury
Cadmium
Chromium
Nickel
Lead
Cyanide
Copper
Zinc
Toxicity
Pollutant Analysis
Oil & Grease
Monthly Avq,
10.0 MGD
24.0 mg/1
30.0 mg/1
16.0 mg/1
5.0 mg/1
1000/100 ml
Weekly Avq.
36.0 mg/1
45.0 mg/1
24.0 mg/1
5.0 mg/1
2000/100 ml
2.0 mg/1***
****
*****
Measurement
Frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Daily
Daily
Daily
Daily
Monthly
Monthly
Monthly
Quarterly
Annually
Monthly
Sample * sample
Type : Locatioi
Composite
Composite
Grab
Grab
Grab <¦
Grab
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Composite
Grab
I or E
I,E
I/E
B '
E,U,D
E,\J,D
E
E,U,D
B
E
S
E
E
E
E
E
E
E
E
E
E
-------
ATTACHMENT A
Page 36 of 42
Northside WWTP
NPDES Permit No. -NC00231&41
Sample locations: E - Effluent, I - Influent, U - Upstream see pages 41 and 42 of attachment A,
D - Downstream see pages 41 and 42 of Attachment A.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall not exceed 15%
of the respective influent values (85% removal).
Quarterly average limitation.
See Attachment B, Pages 13 and 14 of 16; Chronic Toxicity (Ceriodaphnia) Monitoring only at 99%,
October, January, April and July.
*See Attachment C, Page 4 of 4. 1
I
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
-------
ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 37 of 42
Northside WTB
» NFBES Permit No. NC0Q23*.
(Summer: April 1 - October 31)
During the period beginning on January 1, 1991 and lasting until 3 months after construction
completion, the permittee is authorized to discharge from outfall serial number(s) - 001,. Such
discharges shall be limited and monitored, by the permittee as specified below:
Effluent Characteristics
Discharge Limitations
Other "Units {Specify)
Monitoring Requi reroents
Flow
BOD, 5Day, 20oC **
Total Suspended Residue **
NH3 as N
Dissolved Oxygen (minimum)
Fecal Coliform (geometric mean)
Residual Chlorine
Temperature
Total Nitrogen (N02 + N03 + TKN)
Total Phosphorus
Mercury
Cadmium
Chromium
Nickel
Lead
Cyanide
Copper
Zinc
Toxicity
Pollutant Analysis
Oil & Grease
Monthly Avg.
10.0 MGD
12.0 rog/1
30.0 rag/1
8.0 mg/1
5.0 mg/1
1000/100 TTll
2.0 mg/1***
4.5 ug/1****
15.0 ug/1****
50.0 ug/1****
34,5 ug/1****
*****
******
Weekly &vg,
18.0 mg/1
45.0 mg/1
12.0 mg/1
5.0 mg/1
2000/100 ml
2.0 ug/1
50.0 ug/1
75.0 ug/1
25.0 ug/1
Measurement
frequency
Continuous
Daily
Daily
Daily
Daily
Daily
Daily
Daily
Monthly
Weekly
Monthly
Daily
Daily
Daily
Daily
Monthly
Monthly
Monthly
Quarterly
Annually
Monthly
Type
*Sarople
Location
Recording
Composite
Composite
Composite
Grab
Grab
Grab
Grab
Composite
Composite
Composite
Composite
Composite
Composite
Composite
Grab
Composite
Composite
Composite
Grab
I or E
I ,E
I,E
2,11,D
E
E,\J,D
E
E
E
B
E
E
E
E
E
E
E
E
E
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ATTACHMENT A
Page 38 of 42
Northside WWTP
NPDES Permit No. NC0023841
Sample locations: E - Effluent, I - Influent, U - Upstream see pages 41 and 42 of attachment A,
Downstream see pages 41 and 42 of Attachment A.
The monthly average effluent B0D5 and Total Suspended Residue Concentration shall npt exceed 15%
of the respective influent values (85% removal).
Quarterly average limitation.
Daily maximum limitation.
* See Attachment B, Pages 15 and 16 of 16; Chronic Toxicity (Ceriodaphnia) P/F at 99%, October,
January, April and July.
vO
IT)
See Attachment C, Page 4 of 4. i
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
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ATTACHMENT A
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Interim
Page 39 of 42
Northside WWTP
NPDES Permit No. NC0023841
(Winter: November 1 - March 31)
During the period beginning on January 1, 1991 and lasting until 3 months after construction
completion, the permittee is authorized to discharge from outfall serial number(s) - 001. i Such
discharges shall be limited and monitored by the permittee as specified below: >
Effluent Characteristics
Discharge Limitations
Other Units (Specify)
Monthly Avq.
Weekly Avq.
Monitoring Requirements
Measurement
Frequency
Sample'
SEE®
~Sample
Location
Flow
10.0 MGD
Continuous
Recording
I or
E
BOD, 5Day, 20oC **
24.0 mg/1
36,0 mg/1
Daily
Composite
I,E
Total Suspended Residue **
30.0 mg/1
45.0 mg/1
Daily
Composite
I,E
NH3 as N
16.0 mg/1
24.0 mg/1
Daily
Composite
E
Dissolved Oxygen (minimum)
5.0 mg/1
5.0 mg/1
Daily
Grab
E,U,
D
Fecal Coliform (geometric mean)
1000/100 ml
2000/100 ml
Daily
Daily
Grab
E,U<
rD
Residual Chlorine
Grab
E
Temperature
Daily
Grab
ErU
,D
Total Nitrogen (N02 + N03 + TKN)
Monthly
Composite
E
Total Phosphorus
2.0 mg/1***
Weekly
Composite
E
Mercury
Monthly
Composite
E
Cadmium
4.5 ug/1****
2.0 ug/1
Daily
Composite
E
Chromium
75.0 ug/1****
50.0 ug/1
Daily
Composite
E
Nickel
75.0 ug/1****
50.0 ug/1
Daily
Composite
E
Lead
34.5 ug/1****
25.0 ug/1
Daily
Composite
E
Cyanide
Monthly
Grab
E
Copper
Monthly
Composite
E
Zinc
Monthly
Composite
E
Toxicity
*****
Quarterly
Composite
E
Pollutant Analysis
******
Annually
E
Oil & Grease
Monthly
Grab
E
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ATTACHMENT A
Page 40 of 42
Northside WWTP
NPDES Permit No. NC0023841
Sample locations: E - Effluent, I - Influent, U - Upstream see pages 41 and 42 of attachment A
D - Downstream see pages 41 and 42 of Attachment A.
The monthly average effluent BOD5 and Total Suspended Residue Concentration shall not exceed 15
of the respective influent values (85% removal).
Quarterly average limitation.
Daily maximum limitation.
See Attachment B, Pages 15 and 16 of 16; Chronic Toxicity (Ceriodaphnia) P/F at 99%, October,
January, April and July.
00
m
* See Attachment C, Page 4 of 4. i
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and
shall be monitored daily at the effluent by grab sample.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
Upstream and downstream samples shall be grab samples.
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ATTACHMENT A
INSTREAM MONITORING REQUIREMENTS - Final
Page 41 of 42
Northside WWTP
NPDES Permit No. NC0023841
During the period beginning on the effective date of this order and lasting until 3 months after
construction completion, the permittee is authorized to discharge from outfall serial number(s) - OoA.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristics Discharge Limitations Monitoring Requirements
Other Units
(Specify)
Measurement
Sample
* Sample
Monthly Avg.
Weekly AvgJ
Frequency
Type
Location
BOD, 5Day, 20oC
three/week
Grab
U1,U2,U3
Dissolved Oxygen
three/week
Grab
SJ1,XJ2,U3
Fecal Coliform (geometric mean)
three/week
Grab
U1,U2,U3
Temperature
three/week
Grab
\J1,U2,U3
Conductivity
three/week
Grab
m,U2,U3
9v
ir»
t
u
Sample locations: U1 - East Club Boulevard, 112 - Glenn Road, \J3 - Red Mill Road
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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ATTACHMENT A
Page 42 of 42
Northside WWTP
NPDES Permit No. NC0023841
INSTREAM MONITORING REQUIREMENTS - Final Summer (June 1 - September 30)
During the period beginning on the effective date of this order and lasting until 3 months after
construction completion, the permittee is authorized to discharge from outfall serial number(s) -
Such discharges shall be limited and monitored by the permittee as specified below;
001.
Effluent Characteristics
Discharge Limitations
Monitoring Requirements
Dissolved Oxygen
Temperature
Conductivity
Total Nitrogen
Total Phosphorus
NH3 as N
TKN
P04
PH
Chlorophyll a
Other "Units (Specify)
Monthly Avg.
Weekly Avg.
Measurement
Sample
*Sample
Frequency
TYPe
Location
o
Weekly
(am
&
pm)
Grab
U2,
U3,
U4,
U5,
U6 f
Weekly
(am
&
pm)
Grab
U2,
U3,
U4,
U5,
U6 «
Weekly
(am
St
pm)
Grab
U2,
U3,
U4,
U5,
U6
Weekly
(am
St
pm)
Grab
U2,
U3,
U4,
U5,
U6
Weekly
(am
St
pm)
Grab
U2,
U3,
U4,
U5,
U6
Weekly
(am
&
pm)
Grab
U2,
U3,
U4,
U5,
U6
Weekly
(am
&
pm)
Grab
U2,
U3,
VA,
U5,
U6
Weekly
(am
&
pm)
Grab
U2,
U3,
U4,
U5,
U6
Weekly
! am
St
pm)
Grab
U2,
U3,
U4,
U5,
U5
Weekly
(am
St
pm)
Grab
U2,
U3,
U4,
U5,
U6
* Sample locations: U2 - Glenn Road, U3 - Red Mill Road, U4 - Old Railroad Trestle, U6 - 1-85 or
alternative site near mouth of Ellerbe Creek.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
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ATTACHMENT B
Page 1 of 16
Farrington Road WWTP
NPDES Permit No. NC0047597
Chronic Toxicity Monitoring Requirement (Quarterly)
Pages 1 and 2 of Attachment B shall be effective fr
the effective date of this order until Decemeber 31
The City of Durham shall conduct chronic toxicity
using test procedures outlined in: ests
1. The North Carolina Ceriodaphnia chronic efflimm-
bioassay procedure (North Carolina Chronic z
Bioassay Procedure - Revised *February 1987 >
subsequent versions. * >) or
The effluent concentration defined as treatment two in
North Carolina procedure document is 99%. The City sh ii
perform quarterly monitoring using this procedure to
establish compliance with order condition. The first- *¦
will be performed within thirty days from the effectiv^J «.
of this Order. Subsequent tests will be performed in th
months of October, January, April and July. Effluent
sampling for this testing shall be performed at the npdvc;
permitted final effluent discharge below all treatment
processes.
All toxicity testing results required as part of this or^
will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the month in which it was performed, usina the
parameter code TGP3B. Additionally, DEM Form AT-1
(original) is to be sent to the following address:
Attention:
Technical Services Branch
North Carolina Division of Environmental Manacr&m»n*-
Post Office Box 27687 sement
Raleigh, North Carolina 27611-7687
Test data shall be complete and accurate and include all
supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all
dose/response data. Total residual chlorine of the efflux*,
toxicity sample must be measured and reported if emplov^T
for disinfection of the waste stream, ***.
Should any test data from this monitoring requirement or
tests performed by the North Carolina division of
Environmental Management indicate potential impacts to th©
receiving stream# this'^«der vigay' be -reopened "add modified - -#.«
include alternate moniitotfiatfg* - j^quirementSi,
C-61
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ATTACHMENT B
Page 2 of 16
Farrington Road WWTP
NPDES Permit No. NC0047597
Note: Failure to achieve test conditions as specified
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
C-62
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ATTACHMENT B
Page 3 of 16
Farrington Road WWTP
NPDES Permit No. NC0047597
Chronic Toxicity Testing Requirement (Quarterly)
.» a attachment B shall be effective from
Pages 3 and 4 of 3 months after construction completion.
January 1, lyyi utaiA
.*• shall at no time exhibit chronic
SxiSitfifan^two Consecutive toxicity tests, using test
procedures outlined in.
rv>riodaphnia chronic effluent
1.) The North Caro:^ortFcSiolina Chronic Bioassay
bioassay proceaune , rv 1987} or subsequent versions.
Procedure - Revised 'February
^nn^ration at which there may be no
The effluent f reproduction or significant
observable inhibition ^ treatment tWo in the North
mortality is 99% The City shall perform
Carolina procedure docum ^is procedure to establish
quarterly monitoring_^der condition. Tests performed on or
compliance with the ora ^ performed during the months of
after October 1, . Juiy. Effluent sampling for
October. *t. the NPDES permitted final
this testing shall oe f treatment processes,
effluent discharge below aii
• ¦. w.,tina results required as part of this permit
All toxicity teftin%:® d on the Effluent Discharge
condition will be J the month in which it was
Monitoring Form (MJ-1J code TGP3B. Additionally,
performed, using the param ^ ^ gent tQ the following
DEM form AT-1 (origma
address:
Technical Services Branch
Attention: Teen olina Division of
Environmental Management
P.O. Box 27687
Raleigh/ N.C. 27611
¦> ai.a and accurate, and include all
Test data shall J^gfcal measurements per formed in
.5 & effluent
^response data, ^^eaa^ed and reported if chlorine is
toxicity sample must the waste stream.
employed for disinfectip »
, ___itoring test indicate a .
Should any sinale 9"?^^ liSts, then i.
to meet specif*®® eh tiroe- d single test ia
will begin
passed. "P°n P"?^Se ™ontha spec««d above,
revert to quarterly *«
c-63
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ATTACHMENT B
Page 4 of 16
Farrington Road WWTP
NPDES Permit No. NC0047597
Should any test data from this monitoring requirement or
tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the
receiving stream, this order may be reopened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
In the event the City of Durham submits split/sample test
results performed by two different certified labs and one
result indicates a "pass" while the other result indicates a
"fail", the AT-1 forms will be examined by Divisional Staff
and if no protocol violations exist, the "pass" will be
accepted.
C-64
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ATTACHMENT B
Page 5 of 16
Eno River WWTP
NPDES Permit No. NC0026336
chronic Toxicity Monitoring Requirement (Quarterly)
* fi of Attachment B shall be effective from the
elfectLe date of SL order until December 31, 1990.
The City of Durham ^*11 conduct chronic toxicity tests
using test procedures outlined m.
i The North Carolina Ceriodaphnla chronic effluent
The wort dure (North Carolina Chronic
Bioassay Procedure - Revised 'February, 1987) or
subsequent versions.
«anfration defined as treatment two in the
The effluent co™;entrati document is 72%. The City shall
North Carolina tQrino using this procedure to
perform quarter 1% , . order condition. The first test
establish complia:nee w thirty days from the effective date
will be Pe5formeoubseauent tests will be performed in the
of this Order. Subseq & 1 and July> Effluent
months of October, r pertor^ed at the NPDES
sampling for ^f—iSent discharge below all treatment
permitted final effluent
processes.
results required as part of this Order
All toxicity testinL;[ affluent Discharge Monitoring Form
will be entered on tne w. it wag perf0rmed, using the
(MR-1) for the month indditionally, DEM Form AT-1
parameter code TGg3B. following address:
(original) is to be sent w
¦peehnical'services Branch
• Vision of Environmental Management
North Carolina Division^
Raleigh, North Carolina 27611 7687
v i ate and accurate and include all
Test data shall be c^fcal measurements performed in
supporting toxicity tests, as well as all
association with the toxic r*sidual chiorine of the effluent
dose/response data. . _ measured and reported if employed
toxicity sample rou® waste stream,
for disinfection of the was
.UAa monitoring requirement or
Should any test *at? *rS*rth caroling Division of
tests performed by the N eate potential impacts to the
Environmental be reopened knd modifiai to*
include^! ternate
C-65
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ATTACHMENT B
Page 6 of 16
Eno River WWTP
NPDES Permit No. NC0026336
Note: Failure to achieve test conditions as specified in
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
C-66
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ATTACHMENT B
Page 7 of 16
Eno River WWTP
NPDES Permit No. NC0026336
Chronic Toxicity Testing Requirement (Quarterly)
Pages 7 and 8 of Attachment B shall be effective from
January 1, 1991 until 1 month after construction completion.
The effluent discharge shall at no time exhibit chronic
toxicity in any two consecutive toxicity tests, using test
procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent
bioassay procedure (North Carolina Chronic Bioassay
Procedure ~ Revised *February 1987) or subsequent versions.
The effluent concentration at which there may be no
observable inhibition of reproduction or significant
mortality is 72% (defined as treatment two in the North
Carolina procedure document). The City shall perform
quarterly monitoring using this procedure to establish
compliance with the order condition. Tests performed on or
after October 1, 1990 will be performed during the months of
October, .Tanuary, April and July. Effluent sampling for
this testing shall be performed at the NPDES permitted final
effluent discharge below all treatment processes.
All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge
Monitoring Form (MR-1) for the JS*!?
performed, using the parameter code Additionally,
tyom f0rm at-1 (original) is to be sent to.the following
DEM
address:
Technical Services Branch
Attention. Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
, and accurate and include all
Test data shall be al measurements performed in
supporting chemical/physical ^ ^ WQn ftg aU
association with the tax r*gi{jual chlorine of the effluent
dose/response data, jlow d reported if chlorine is
toxicity mU ¦»«^rean.
employed for disinfecti
c-67
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ATTACHMENT B
Page 8 of 16
Eno River WWTP
NPDES Permit No. NC0026336
Should any test data from this monitoring requirement or
tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the
receiving stream, this order may be reopened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
In the event the City of Durham submits split/sample test
results performed by two different certified labs and one
result indicates a "pass" while the other result indicates a
"fail", the AT-1 forms will be examined by Divisional Staff
and if no protocol violations exist, the "pass" will be
accepted.
C-68
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ATTACHMENT B
Page 9 of 16
Little Lick Creek WWTP
NPDES Permit No. NC0026310
Chronic Toxicity Monitoring Requirement (Quarterly)
Pages 9 and 10 of Attachment B shall be effective from the
effective date of this order until December 31, 1990.
The city of Durham shall conduct chronic toxicity tests
using test procedures outlined in:
1. The North Carolina Ceriodaphnia chronic effluent
bioassay procedure {North Carolina Chronic
Bioassay Procedure - Revised *February, 1987) or
subsequent versions.
The effluent concentration defined as treatment two in the
North Carolina procedure document is .99%. The City shall
perform quarterly monitoring using this procedure to
establish compliance with order condition. The first test
will be performed within thirty days from the effective date
of this Order. Subsequent tests will be performed in the
months of October. January# April and July. Effluent
sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment
processes.
All toxicity testing results required as part of this Ordsr
will be entered on the Effluent Discharge Monitoring Form
(MR-1) for the month in which it was performed, using the
parameter code TGP3B. Additionally, DEM Form AT—1
(original) is to be "sent to the following address:
Attention:
Technical Services Branch
North Carolina Division of Environmental Management
Post Office Box 27687
Raleigh, North Carolina 276,11-7687
Test data shall be complete and accurate and include all
supporting chemical/physical measurements performed in
association with the toxicity of
dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if employed
for disinfection of the waste stream.
c^,,, rf«ta from this monitoring requirement or
£ the North Carolina Division of
EnJ?r^™^?I? Manaaement indicate potential impacts to the
rencVe™™rs?re^?a?Sn0Wer ^reopen,* *nd ™dieW tcr,
include alternate monitoring' Requirements.
e-69
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ATTACHMENT B
Page 10 of 16
Little Lick Creek WWTP
NPDES Permit No. NC0026310
Note: Failure to achieve test conditions as specified in
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
C-70
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ATTACHMENT B
Page 11 of 16
Little Lick Creek WWTP
NPDES Permit No. NC0026310
Chronic Toxcity Testing Requirement (Quarterly)
Paaes 11 and 12 of Attachment B shall be effective from
January 1, 1991 until 1 month after construction completion.
The effluent discharge shall at no time exhibit chronic
toxicity in any two consecutive toxicity tests, using test
procedures outlined in:
1.) The North
ProcedureP-°Revised "February 1987) subsequent versions.
Thp effluent concentration at which there may be no
rne ertiuenc cum-e n»oroduction or significant
observable inhibition of^ J treatment two in the North
mortality is 99% (d .» The city shall perform
Carolina procedure d t^is procedure to establish
quarterly m°^J°"^g_rder condition. Tests performed on or
compliance with the o performed during the months of
after October 1, 1990 July. Effluent sampling for
Octoberr January, Apr:ii an^^x. the NPDES permitted final
this testing shall be perform t processes,
effluent discharge below an
^ results required as part of this permit
All toxicity testing r the Effluent Discharge
condition will be ®^®rf the month in which it was
Monitoring Form (MR 11i_rameter code TGP3B. Additionally,
performed, using the par.am ^ sent to the following
DEM form AT-1 (original)
address:
, . __. Technical Services Branch
Attention. Tc Car0una Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
. 4.* accur3it6, cind incXudfi ^11
Test data shall be complet urements performed in
supporting chemical/physicalas well as all
association with the t^iHgidual chlorine of the effluent
dose/response data. TotaXjesiau^ reported if chlorine is
toxicity sample must be m waste stream,
employed for disinfection of the w
_i» monitoring test indicate a .
Should any single f^its, then monthly monitoring
failure to meet specif led "tfcgfc-a. single "test r±»-,
will begin immediately . monthly test requirement jWiil
passed, upon Reified above:
revert to quarterly
c-71
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ATTACHMENT B
Page 12 of 16
Little Lick Creek WWTP
NPDES Permit No. NC0026310
Should any test data from this monitoring requirement or
tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the
receiving stream, this order may be reopened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
In the event the City of Durham submits split/sample test
results performed by two different certified labs and one
result indicates a "pass" while the other result indicates a
"fail", the AT-1 forms will be examined by Divisional Staff
and if no protocol violations exist, the "pass" will be
accepted.
C-72
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ATTACHMENT B
Page 13 of 16
Northside WWTP
NPDES Permit No. NC0023841
Chronic Toxicity Monitoring Requirement (Quarterly)
Pages 13 and 14 of Attachment B shall be effective from t-h~
effective date of this order until December 31, 1990.
The City of Durham shall conduct chronic toxicity tests
using test procedures outlined in:
1- The North Carolina Ceriodaphnia chronic effluent
hioassay procedure (North Carolina Chronic
Bioassay Procedure - Revised *February, 1987)
subsequent versions. '
The effluent concentration defined as treatment two in the
North Carolina procedure document is 99%. The City shall
perform quarterly monitoring using this procedure to
establish compliance with order condition. The first test
will be performed within thirty days from the effective dat
of this Order. Subsequent tests will be performed in the
months of October, January, April and July. Effluent
sampling for this testing shall be performed at the NPDES
permitted final effluent discharge below all treatment
processes.
All toxicity testing results required as part of this Order
will be entered on the Effluent Discharge Monitoring Form
(MR-l) for the month in which it was performed, using the
parameter code TGP3B. Additionally, DEM Form AT-1
(original) is to be sent to the following address:
Attention;
Technical Services Branch
North Carolina Division of Environmental Management
Post Office Box 27687 nT:
Raleigh, North Carolina 27611-7687
Test data shall be complete and accurate and include all
supporting chemical/physical measurements performed in
association with the toxicity tests, as well as all
dose/response data. Total residual chlorine of the effluent
toxicity sample must be measured and reported if employed
for disinfection of the waste stream.
Should any test data from this monitoring requirement or
tests performed by the North Carolina pivision of
Environmental Management indicate potential impacts to
receiving stream, thisOrdermaT be- reopened; andrmodified to
include alternate monitoring retirements*
C-73
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ATTACHMENT B
Page 14 of 16
Northside WWTP
NPDES Permit No. NC0023841
Note: Failure to achieve test conditions as specified in
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
C-74
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ATTACHMENT B
Page 15 of 16
Northside WWTP
NPDES Permit No. NC0023841
Chronic Toxicity Testing Requirement (Quarterly)
Pages 15 and 16 of Attachment B shall be effective from
January 1, 1991 until 3 months after construction completion.
The effluent discharge shall at no time exhibit chronic
toxicity any two consecutive toxicity tests, using test
procedures outlined in:
1.) The North Carolina Ceriodaphnia chronic effluent
bioassav procedure (North Carolina Chronic Bioassay
Procedure -Revised -February 1987) or subsequent versions.
The effluent concentration at which there may be no
observable inhibition of reproduction or significant
mortalitv is 99% (defined as treatment two in the North
Caroling document). The City shall perform
quarterly monitoring using this procedure to establish
romnliance with the order condition. Tests performed on or
after October 1, 1990 will be performed during the months of
after octocer , Ar)rii and July. Effluent sampling for
SiS testing shall be perf?Sg/at the NPDES permitted final
effluent discharge below all treatment processes.
An testing results required as part of this permit
^^^n ^Tn be entered on the Effluent Discharge
condition will be entered^ ^ ^ which ifc m
Monitoring Foot ' r,raR10^i- code TGP3B. Additionally,
KM Wnto be sent~to the following
address:
Attention: Technical services Branch
Attend North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test data shall be complete and accurateandinclude all
Test data anaxx icai measurements performed in
supporting chemical/PY tests, as well as all
association with the tox *sidual chlorine of the effluent
dose/response data. Tot x , reported if chlorine is
employed -te Stream.
. .. _,_rferlv monitoring test indicate a
Should any single S*jarte Y th< \ monthly monitoring
failure to meet ^.LiinglO: ttitris'
will begin lmmedlately un ^ test"requirement will- •
revert' to quarterly in '3?A
C-75
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ATTACHMENT B
Page 16 of 16
Northside WWTP
NPDES Permit No. NC0023841
Should any test data frora this monitoring requirement or
tests performed by the North Carolina Division of
Environmental Management indicate potential impacts to the
receiving stream, this order may be reopened and modified to
include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in
the cited document, such as minimum control organism
survival and appropriate environmental controls, shall
constitute an invalid test and will require immediate
retesting(within 30 days of initial monitoring event).
Failure to submit suitable test results will constitute
noncompliance with monitoring requirements.
In the event the City of Durham submits split/sample test
results performed by two different certified labs and one
result indicates a "pass" while the other result indicates a
"fail", the AT-1 forms will be examined by Divisional Staff
and if no protocol violations exist, the "pass" will be
accepted.
C-76
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