UPDATE MAY 14, 2024 – The specific Assessment segments we addressed in PUBLIC COMMENTS for the 2024 303(d) list are detailed HERE.

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ORIGINAL POST – The NC Dept of Environmental Quality is accepting public comments through April 26, 2024, on a proposed list of streams, rivers, reservoirs and other water bodies considered to be “impaired,” or that do not meet water quality standards. They’re also seeking input about which waterways on the list should be prioritized for a management or restoration plan (a “TMDL” plan) across the next 10 years. After the public comment period, the list will be submitted to the U.S. Environmental Protection Agency. The EPA requires this list every two years from North Carolina and other states.

This post is a summary of items we’ve found that need to be put in front of the NCDEQ and EPA as Public Comments for 303(D) assessment and TMDL consideration. We’re updating this daily, so check back for more additions. There are so many issues here that we had to create a MAP – click HERE.

But first, a correction is in order: I’ve been telling you that Jamestown started getting its drinking water from Randleman Lake/PTRWA at some point “about two years ago.” I recently discovered that Jamestown was switched over to Randleman Lake/PTRWA water, delivered through High Point and Greensboro pipes in 2010.

Here’s the page from Jamestown’s 2010 water planning report (link to the full report HERE):

The 2024 303(D) list has no new additions from our Bull Run/Deep River Sub-Watershed or the Deep River/Randleman Water Supply network.

WHY none of our waterways are tested or monitored for chemicals or metals (Jamestown’s landfills sit on top of old Deep River Gold & Copper Mining operations) is a mystery. The lack of data and response from facility operators and state agencies, employees and administrators has been – and continues to be – very disappointing.

Here’s the short list:

1. BULL RUN STREAM (WS-IV, CA*) is NOT known to the EPA as a major water supply stream. It is improperly labeled in North Carolina’s 303(D) Integrated Files as an “Aquatic Life” stream (for fish). The NC DEQ’s Surface Water Classifications database shows Bull Run was classified WS-IV CA* on March 31, 1999. The data set that the NC DEQ reports to the EPA does not identify Bull Run, which runs through the D.R. Horton construction site, as a critical water supply stream. Therefore, Bull Run is misclassified in the EPA’s “Hows My Waterway” and ECHO databases as a non-water supply stream. Swipe through the slides below for the visuals:

2. COPPER BRANCH (WS-IV*) is not known to the EPA as a water supply stream. It was classified WS-IV* by the NCDEQ in 1999, but it is not listed in the NCDEQ’s 303(D) Integrated Files data, and NO data exists for Copper Branch in the EPA’s “How’s My Waterway” database. Copper Branch runs along the southern border of an old Superfund site (APAC Asphalt – TCE in groundwater) and receives water runoff from the site, flows beneath Riverdale Drive, through the Martin Marietta Quarry, and into Deep River (details HERE). Before it reaches APAC Asphalt from the west, Copper Branch flows through the middle of the McCulloch Castle Gold Mine and Mill properties. Swipe through the slide show below for visuals:

3. DEEP RIVER (17-3.3) from High Point City Lake to Dillon Road (WS-IV*) is not known to the EPA as a water supply stream. It was classified WS-IV* by the NCDEQ in 1999, but it is not listed in the NCDEQ’s 303(D) Integrated Files data, and NO data exists for this segment of Deep River in the EPA’s “How’s My Waterway” database. Swipe through the slides below for the visuals:

4. DEEP RIVER segment 17-(3.7) (WS-IV CA*) from Dillon Road to Oakdale Dam is on the Impaired List; but the NCDEQ told us that was an error, then failed to correct it: In the agency’s Fact Sheets, an NCDEQ employee added notes in January 2023, stating that the “Impaired” segment of Deep River shown in red (between the abandoned Oakdale Cotton Mill and Dillon Road/Teknor Apex) was a misclassification:

She wrote in her notes that the correct impaired/red stream is an unnamed tributary that runs between Deep River and the residential community of Broadstone Village, based on a biological test sample taken in 2015:

The employee states in the notes that the correction will be shown on the 2024 list; but it isn’t, as shown below:

5. INCOMPLETE & INCONSISTENT FACILITIES DATA. The permitting, compliance, discharge and monitoring data for companies that are discharging chemicals and contaminants into the Bull Run/Deep River Sub-Watershed is inconsistent, incomplete and wrong.

For example: Alberdingk Boley is a German acrylic dispersions/resin manufacturer that emits toxins to the air and has spilled thousands of gallons of wastewater to a tributary to Bull Run – yet its storm water permit is for Food Warehousing.

The Division of Air Quality monitors Alberdingk Boley under the proper SIC Code (2821) for PLASTICS MATERIAL AND RESIN MANUFACTURING (Air Permit no. 09206R05). The Division of Water Resources, however, gave Alberdingk Boley a “General” water discharge permit under the SIC Code for “WAREHOUSING, FOOD AND KINDRED” (Permit no. NCG060104). This type of stormwater/wastewater permit is a generic permit for finished products and it frees Alberdingk Boley from the stringent monitoring and oversight that it SHOULD have, particularly since it sits so close to the Fox Hollow and Adams Farm residential communities and discharges/spills directly to our drinking water supply. Here’s Alberdingk’s 2023 pretreated wastewater report (below), followed by a screenshot of the first page of its wastewater permit for “Food Warehousing” (tap to view):

Same thing with resin maker Teknor Apex, which sits a block off Main Street in the middle of Jamestown. The Division of Air Quality issued a permit under SIC Code 3087 for CUSTOM COMPOUNDER OF PURCHASED PLASTICS RESINS (permit no. 10379R01). The Division of Water Resources wrongly gave it a General NPDES permit for FINISHED APPAREL, PRINTING, LEATHER, RUBBER & MISC. MANUFACTURING (see the permit category HERE). To make matters worse, the stretch of Deep River where Teknor Apex discharges is segment 17-3.3 described above – the EPA doesn’t even have 17-3.3 listed as a WATER SUPPLY (WS-IV*) stream, and it links to the “IMPAIRED” mistake made by the NCDEQ employee.

Another facility, also a block from Jamestown’s Main Street restaurants, is Highland Container (aka HOOD Container), a corrugated cardboard manufacturer in town. This has the very same General stormwater permit as resin compounder Teknor Apex (a water discharge permit for companies in the FINISHED APPAREL (cutting & sewing), PRINTING, LEATHER, RUBBER & MISC. MANUFACTURING). Highland/HOOD Container‘s Air Emissions Permit (05793/R08) is for “CORRUGATED & SOLID FIBER BOX MANUFACTURING” but it was rescinded last May because Hood told the state it doesn’t emit as much sulfur dioxide, nitrogen oxide, carbon monoxide and toxic air pollutants as they used to. These pics of Highland/HOOD Container were snapped March 8, 2024 at 3:40 in the afternoon:

Very little info exists in the EPA’s Echo database for the facilities that are currently permitted to discharge into our waterways. Since beginning this project two years ago, we have been repeatedly told that North Carolina is “in the process” of getting all of its information uploaded. TWO YEARS.

This is a tired excuse, and now it’s a dangerous one, since the EPA doesn’t have a clue about how unready, unfit, and unprepared this water system and municipality is when it comes to handling the frenzied onslaught of development that is currently clear-cutting hundreds of acres along Bull Run and Deep River.

It’s even more confusing (and dangerous) here in Jamestown because Jamestown’s Town Manager – despite numerous demands from residents – REFUSES to incorporate the 2020 RANDLEMAN WATERSHED RULES in our town’s Land and Water Ordinances as mandated by the State following their adoption in March 2019 and June 2020.

In the latest draft of his Stormwater Management Plan (Jamestown’s NPDES MS4 permit has been expired since February 2022) the town manager lists an outdated program for Post-Construction Site Runoff Control that is no longer in existence: 15A NCAC 02B .0251, Randleman Lake Nutrient Management Strategy. The NC Assembly replaced it in 2020 with 15A NCAC 02B .0721 (Randleman Lake Water Supply Watershed Stormwater Requirements).

We assume this may be what led to the Division of Water Resources’ ERROR – they issued a 401 water quality permit for a new Windsor Homes development in our protected/critical Randleman Watershed referencing “Jordan Lake Nutrient Strategy” rules instead of our 2020 Randleman Watershed Rules.

We also assume this is why Jamestown’s town planner felt she could make a MAJOR EXCEPTION to the Division of Water Resources’ 401 permit when she UNDID the buffer protections. The Division of Water Resources’ corrected 401 permit LIMITS IMPACTS to perennial streams at 138 linear feet, and to wetlands at .028 acres. Jamestown’s town planner undid those limits with a one-page letter to the developer, Windsor Homes, giving them the right to permanently impact 19,506 SQUARE FEET of our water supply stream buffers (a stream crosses the site and flows downhill to Bull Run and Deep River). Her letter to Windsor Homes’ engineer (who is also the Director of the Piedmont Triad Regional Water Authority – which sells us our Randleman Lake drinking water) is below.

Oddly, in her letter the town planner suggests she is applying a new 2020 Randleman Watershed Rule here – 15A NCAC 02B .0724. But she failed to apply the new rule that defines this as a MAJOR EXCEPTION (impacts greater than one-third of an acre of riparian buffer) and thus requires: (1) a complete application package, (2) preliminary findings, and (3) a 30-day public posting of those findings BEFORE a final decision is made. That would be Randleman Watershed Rule 15A NCAC 02B .0611.

6. CHAOTIC, CONFUSING, CONSTANTLY-IN-MOTION ZONING. The chaotic makeup of Jamestown’s Zoning Map leaves too many facilities and streams unmonitored and in question. When we raised this issue about several facilities, and asked who has responsibility for notifying the local community about spills and threats to our streams, we were told “It’s [fill in the blank] Jamestown’s … High Point’s… Greensboro’s… Guilford County’s… responsibility.” Examples: Alberdingk Boley has a front door address in Greensboro, but discharges to Jamestown and has had two major spills into a tributary to Bull Run on the back side of the property); Kersey Valley Landfill, GFL Construction & Demolition Landfill, Eastside Wastewater Plant and High Point Material Recovery are addressed in Jamestown and discharge to Deep River, but are under the authority of High Point, which has a different drinking water system.

7. CONTAMINANT SOURCES NOT REPRESENTED: Deep River from Oakdale Dam to Randleman Dam (NC17-4). The presence of all of these dischargers and contaminated sites in such close proximity to Deep River, Bull Run and Richland Creek (which brings the worst of High Point’s industrial wastewater over to Deep River and our water supply) makes Deep River segment NC17-(4) one of our most threatened waterway segments.

The upper part of this segment (from Oakdale Dam to Kivett Drive) is only assessed for biological/fish health, and a review of the DWR’s Fact Sheets shows no water assessment data for ANY of our streams after 2019. Jamestown residents have tested for chemicals, including PFAS and 1,4-Dioxane, in our tap water and so we know these chemicals are in our surface waters. They need to be monitored and tested on a regular consistent schedule. This is what the NCDEQ has for this segment (NC17-(4)a), which is not on the impaired list (because it hasn’t been tested in years):

8. INSUFFICIENT INFO for DEEP RIVER (WS-IV CA*) from Kivett Drive to Coltrane Mill Road (NC17-4(b)). This segment isn’t on the IMPAIRED LIST because the NCDEQ has “INSUFFICIENT INFO.” This is that really bad stretch of Deep River that gets the discharged and leaching toxins and contaminants from Seaboard Chemical dump and its 1,4-Dioxane phytoremediation tree forest, Kersey Valley Landfill, GFL Construction & Demolition Landfill, and the Eastside Wastewater Treatment Plant:

9. INSUFFICIENT INFO FOR REDDICKS CREEK (WS-IV CA*), which discharges into Deep River between Jamestown and Randleman Lake. The upper forks of Reddicks Creek travel through three 18-hole golf courses (Sedgefield and Grandover). Golf courses are notorious for heavy use of turf chemicals:

10. INSUFFICIENT INFO for RICHLAND CREEK (WS-IV*) 6.4 miles from source to a point .4 miles upstream of Kersey Valley Road in Jamestown (segment number 17-7-(0.5)). Richland Creek gets all the industrial wastewater from Thomas Buses (lead), Innospec (1,4 Dioxane), and a bunch of textile and furniture companies, then brings it over here to Deep River:

We say “Insufficient Info” exists because this is the list of dischargers that we KNOW about, and yet Richland Creek isn’t even considered to be a Water Supply Stream until it reaches Kersey Valley Landfill:

Look at the “miraculous improvement” in Richland Creek’s water quality once it starts picking up the runoff and groundwater from Kersey Valley Landfill, which sits atop the old gold and copper mines — This is Richland Creek (WS-IV, CA*) from Kersey Valley Road to Deep River (the classification WRONGLY says “to Randleman Reservoir” and designates the distance as 1.7 miles. Randleman Reservoir is 11 miles downstream. This segment ends when it merges into Deep River just before Eastside Wastewater Treatment Plant), segment NC17-7-(4):

And finally, here are two more locals that made the list — for biological/fish degradation: the East Fork of Deep River, WS-IV* (NC17-2-(.3)b) and Long Branch, WS-IV CA* (NC17-2-1) from the Gas Pipeline Tank Farm:

NOTE: “Year Reported” doesn’t mean “Year Tested.” The 2022 “assessment” for Deep River from Dillon Road to Oakdale Dam is from water tests conducted in 2015 and 2018, and many of the results are shown as “DATA INCONCLUSIVE.” The DWR employee states that this means there’s “not enough data collected during this assessment period to make a determination of the status of the instream water quality condition.”

Despite two years of focused outreach to our local government and the NC Department of Environmental Quality, our water supply sources – Deep River, Bull Run and Richland Creek – haven’t been fully tested for chemicals, metals and organic compounds (which we now know exist in these streams because they’re in our drinking water – water that flows to our faucets AFTER its been treated).

According to a report by Lisa Sorg in NC Newsline, the lack of testing here in Jamestown could be due to inadequate staffing in the Winston Salem Regional Office. “DEQ lacks the staff to conduct comprehensive sampling, meaning some data are under reported,” Yadkin Riverkeeper Edgar Miller told Sorg. Miller’s watershed, encompassing more than 7,200 miles, includes Winston, Statesville and Lexington.

For our Deep River/Randleman Watershed, “comprehensive” is the million-dollar word. Over the past year, we’ve uploaded and screenshot thousands pages of inspections, engineering data, assessment reports, memoranda, correspondence, violations and monitoring reports for the pollutant sources and contaminated sites within our local watershed bubble – about a three mile radius extending outward from Jamestown Town Hall.

Within this bubble, contaminated wastewater flows and seeps into Deep River from dozens of industrial facilities, chemical plants, active and inactive dumps and landfills – either directly, or via Bull Run, Richland Creek and their tributaries. In addition, underground aquifers and groundwater contribute contaminated water from unremedied Superfund sites (Seaboard, the Asphalt plant on Riverdale Drive, Monarch/Riverdale Global on Scientific), contaminated Brownfield sites (80 acres along West Gate City Blvd.), and their toxic fields, lagoons, pits and underground storage tanks.

Lisa describes the the 303(d) list as “a tally of impaired and threatened waterways, based on their designated uses.”

Within the Jamestown/Deep River bubble, the only stream segments that are on the 2024 303(d) list are two small portions of Deep River, and they’re wrongly assessed for “aquatic life” (fish health) instead of “water supply” (human health).

This is a terrible misrepresentation of our waterways, and it is about to do us a great amount of harm.

From Sorg’s article: “Environmental watchdogs often conduct their own sampling to nominate a segment of waterway to the list. In the western part of the state, Broad Riverkeeper Dave Caldwell sampled parts of that watershed that wound up on the latest round of proposed listings. In 2021, the previous White Oak Waterkeeper, Becca Drohan, collected data that was accepted by DEQ; the sampled waters are included in this draft of newly listed impaired waters.”

Here’s the long view of Deep River (below, left). The red spot at the bottom of the satellite image (right) is where the two photos were snapped:

The purple circles on the map below are “Monitoring Stations” from years past that still pop up on the EPA’s “How’s My Waterway?” map. This should be enough to prove why it was important then, and why it is important now.

Circled in red – next to each of those old “Monitoring Stations” – is the last year for which water test data exists in the EPA’s database. Some of the metals and organic contaminants detected include mercury, lead, nickel, arsenic, cyanide, xylene, manganese, benzene, aluminum, fecal coliform, and so on.

The next map includes the NAMES of the industrial dischargers. [NOTE: since then that list has GROWN: see our new map HERE: https://thejamestowner9.com/jamestown-nc-map/]

With D.R. Horton’s 1500-homes/apartment development about to be squeezed into 467 acres along the banks of Bull Run and its tributaries, downhill from 80 total acres of contaminated Brownfield sites, safeguarding Jamestown’s compromised water system should be at the very top of this town’s TO DO list.

This lack of response and refusal to provide public data is what led to the launch of The Jamestowner.