NC0025879_Revised EA_20100729

ENVIRONMENTAL ASSESSMENT
TOWN OF ROBBINSVILLE
WASTEWATER TREATMENT PLANT RELOCATION
GRAHAM COUNTY, NORTH CAROLINA
McGill
A S S O C I A T E S
Engineering • Planning • Finance
Asheville, North Carolina
FEBRUARY 2010
REVISED JUL Y 29, 2010
06561

TABLE OF CONTENTS
EXECUTIVE SUMMARY.......................................................................I
1.0 PURPOSE AND NEED FOR PROJECT................................................2
2.0 ALTERNATIVES TO THE PROPOSED ACTION ..............................5
3.0 AFFECTED ENVIRONMENT................................................................7
4.0 SUMMARY OF MITIGATION.............................................................16
5.0 CORRESPONDENCE............................................................................19
6.0 EXHIBITS / MAPS..................................................................................20
• Figure I — Project Area Topographic Map
• Figure 2 — Proposed Project Preliminary Site Plan
• Figure 3 — Existing and Future Service Areas
• Figure 4 — Impacted Wildlife Habitat
• Proposed Alternative — Itemized Cost Estimate
• Environmental Justice and Civil Rights Impact Analysis Certification
• WWTP Compliance Evaluation Inspection Report
• FEMA Standard Flood Hazard Determination Form
• Environmental Assessment July 2010 (SEPA EA) — Robbinsville
Wastewater Treatment Plant Relocation
7.0 LIST OF PREPARERS...........................................................................21
Environmental Assessment i Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

EXECUTIVE SUMMARY
This report was prepared by McGill Associates, P.A. for use by the Town of
Robbinsville, Graham County and the United States Department of Agriculture (USDA)
Rural Development office in analyzing the environmental impacts of the proposed
project. The proposed project area is located in Graham County, North Carolina in the
northern portion of the Tovvn of Robbinsville. The Town of Robbinsville's existing
Wastewater Treatment Plant (WWTP) is located on a small site in the downtown area and
has no room for expansion. The existing WWTP is nearing the end of its useful life and
does not have sufficient capacity to treat future projected flows. The proposed project
will relocate the WWTP to a larger site away from the downtown area and improve
capacity to treat future projected flows. The proposed project is intended to proactively
protect human health and sanitation by ensuring adequate wastewater treatment service is
provided to area residents and businesses.
The estimated cost of construction for the new WWTP, to include the required
pump station and sewer lines to convey flow to the new WWTP is S6,500,000. The
estimated total project cost is $7,964,000. The proposed funding for this project includes
a combination of grants and loans from the United States Department of Agriculture's
Rural Development program. An Environmental Assessment (EA) was previously
completed for this project in January 2009 in anticipation of submission to the North
Carolina Department of Environment and Natural Resources in conjunction with
application for a National Pollutant Discharge Elimination System (NPDES) permit for
the proposed WWTP. The January 2009 EA was revised in July 2010. However, since
project funding is now being pursued through the United States Department of
Agriculture — Rural Development (USDA-RD) office, this EA has been compiled in
USDA-RD format with the previous EA submitted as an attachment for reference.
Information obtained for this report was collected from various Town, County, State and
Federal agency websites, as well as from correspondence with agency personnel. The
level of review for this project should be consistent with an "Environmental Assessment"
and this assessment should support a certification that little or no adverse environmental
impacts will occur due to this project.
Environmental Assessment 1 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

1.0 PURPOSE AND NEED FOR PROJECT
1.1 Project Description (Proposed Action
The proposed project generally consists of constructing a new WWTP on a 12-
acre parcel north of the existing WWTP on the Cheoah River. The capacity of the new
plant would be increased to 850,000 gpd from the existing wastewater treatment facility's
capacity of 630,000 gpd. The proposed WWTP will discharge treated effluent to the
Cheoah River, a Class C;Tr water in the Little Tennessee River Basin, which will require
a new NPDES permit. It should be noted that the existing WWTP will be abandoned and
its outfall on Long Creek and its associated NPDES permit will be eliminated after
completion of this project.
The new WWTP is proposed to include a mechanical bar screen, oxidation ditch;
clarifiers, disk filters, UV disinfection equipment, an aerobic digester, belt filter press
system, an operations building, and a backup generator. It will also be necessary to
construct approximately 2,000 linear feet of 12-inch gravity sewer and a new pump
station with approximately 900 linear feet of 10-inch force main to convey flow from the
existing WWTP to the new WWTP. Additionally, the project will include providing
water service to and rerouting the access road around the proposed site. Figure 1 and
Figure 2, located in Section 6.0 of this report, illustrate the general project area and
preliminary relocated WWTP site plan.
1.2 Purpose and Need of Proiect
The ToNmi of Robbinsville is a small community located in central Graham
County, in the southwestern portion of North Carolina. The existing Robbinsville
Wastewater Treatment Plant is located adjacent to US 129 on the north side of town, near
the confluence of the Cheoah River and Long Creek. The WWTP was originally
constructed in 1964 with a capacity of 130,000 gpd; major upgrades to the WWTP were
completed in 1986 and the capacity was increased to 630,000 gpd. Robbinsville currently
operates their wastewater treatment plant under NPDES Permit Number NC0025879.
The plant receives wastewater flow from residential, commercial, and industrial
customers in Robbinsville and currently treats, on average, approximately 395,000 gpd.
Environmental Assessment 2 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

The Robbinsville area has experienced moderate growth in recent years and there
has been interest by surrounding communities to connect to Robbinsville's sanitary sewer
system. Robbinsville will need to expand its wastewater treatment capacity to a total of
850,000 gpd during the twenty-year planning period to accommodate future growth and
to provide service to the surrounding communities.
Since the plant was last upgraded in 1986, treatment equipment is nearing the end
of its useful life. The North Carolina Division of Water Quality recently conducted a
compliance evaluation inspection of the WWTP and found that the reliability of the
WWTP is very marginal. A copy of the compliance evaluation inspection, which resulted
in a Notice of Violation, is included in Section 6.0 of this report. The inspection found
several structural and equipment operational problems at the WWTP. Additionally, there
is limited solids -handling capacity at the existing plant. Sludge must be stored for a
period of time and then pumped and hauled to another facility for processing. Upgrades
to the existing facility to accommodate treatment improvements and future growth are
restricted by its site. The WWTP is located on a small parcel which is surrounded on the
south and east by existing buildings, on the north by US 129 and on the west by Knight
Street. There is no room to improve the existing WWTP at its current site. For this
reason the Town of Robbinsville needs to relocate their existing treatment plant to a new,
larger location. The new WWTP will be constructed on the Cheoah River on a 12-acre
parcel of land owned by the Town and situated north of the existing WWTP. The new
outfall will be downstream of the existing outfall and on the Cheoah River instead of
Long Creek, which is a tributary of the Cheoah River. The existing WWTP would remain
in service while the proposed replacement plant is being installed. Upon start-up, testing,
and approval of the new plant's components, the existing plant will be demolished and
the existing outfall on Long Creek will be abandoned.
If no action is taken to relocate and improve the existing outdated WWTP, many
treatment components near the end of their useful lives will fail. Component failure may
cause inadequate treatment capacity for extended periods of time until components can be
repaired or replaced. Lack of space becomes an issue which will lead to increased
replacement costs or the inability to replace treatment equipment at all as it fails. Also, as
was shown in the flow projections, the existing treatment plant will approach its capacity
Environmental Assessment 3 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

in the coming years. By 2020, the wastewater flog is expected to exceed the plant's
capacity. At this flow rate the Town of Robbinsville will need to limit connections to its
system and would likely not be able to serve potential customers in the surrounding
communities.
The Graham County Health Department has confirmed that many of the existing
septic systems in the area are inadequate and do not meet current State requirements.
Clusters of higher density development and inadequate septic systems have created many
situations where property owners are unable to address their current septic system
problems. These problems include inadequate areas for leach fields, systems located in
close proximity to the lake, insufficient capacity in septic tanks, and inadequate systems
due to existing topography. In addition, there are areas where subsurface conditions
consist of a relatively thin layer of soil over bedrock. In these situations, the wastewater
from these systems follows the subsurface bedrock layers without receiving the benefit of
natural purification through the soil, with the potential to surface in Lake Santectlah.
Without the ability to connect to public sewer systems. and as these septic systems fail,
area surface waters would experience negative impacts from untreated or improperly
treated wastewater. Failing septic systems present health issues for residents exposed to
contaminated surface waters. Also groundwater contamination could become an issue,
especially with older shallow private wells. Therefore, taking no action is not a desirable
alternative in that it does not proactively protect public health and sanitation for current
and future residents of Graham County.
Environmental Assessment 4 Town of Robbinsville
McGill Associates P.A_ Wastewater Treatment Plant Relocation
July 29, 2010

2.0 ALTERNATIVES TO THE PROPOSED ACTION
Note: to maintain consistency between the Preliminary Engineering Report (PER) and
this Environmental Assessment, the below Alternative numbers correspond to the PER
Alternative numbers.
This section evaluates Altematives to the proposed project that would enable the
Town of Robbinsville to ensure adequate wastewater treatment capacity and capability
for area residents and businesses. All feasible Alternatives are compared in Table 1I-1
below. A revised Engineering Alternatives Analysis may be found in Section 6.0 of this
report. The Alternatives evaluated are as follows:
2.1 Alternative 1 - No Action
This Alternative has been discussed in Section 1.2 of this report.
2.2 Alternative 2 -- O timum Operation of Existing Facilities
Please see the attached July 2010 Environmental Assessment, section 3.2 for
information regarding this Alternative.
2.3 Alternative 3 — Proposed WWTP with Land Application 1 Reuse
Please see the attached July 2010 Environmental Assessment, section 3.3 for
information regarding this Alternative.
2.4 Alternative 4 — Regional System/Connection to Existing Treatment Facility
Please see the attached July 2010 Environmental Assessment, section 3.4 for
information regarding this Alternative.
2.5 Alternative 5 — Proposed WWTP with Con'unctive Reuse
Please see the attached July 2010 Environmental Assessment, section 3.5 for
information regarding this Alternative.
2.6 Preferred Alternative 6 — Proposed Robbinsville WWTP at a New Location
with 850,000 gpd Capacity
Please see the attached July 2010 Environmental Assessment, section 3.6 for
information regarding this Alternative.
Environmental Assessment 5 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

Table 11-1 Comparison of Alternatives
New
Alternative WWTP
Required?
Land
Required?
(acres)
Potential Estimated
Environmental Capital
Impact Level Cost
Estimated
Annual O&M
Cost
Total24-Year
Present Worth
Cost,
1
Not Feasible
2
Not Feasible
3
Yes
64
Moderate Cost Prohibitive
4
Not Feasible
5
Yes
64
Moderate
$11,660,000
5450,000
$17,208,500
6
Yes
12
Low
$7,964,000
$425,000
$13,204,250
Note:
1. 20-year Presew Rorfh based on discount rate of 5_ 125%
Environmental Assessment 6 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

3.0 AFFECTED ENVIRONMENT
3.1 Land Use/Important Farmland/Form ally Classified Lands
3.1.1 Affected Environment
Please see the attached July 2010 Environmental Assessment, sections 4.1-4.3,
4.5-4.6, and 4.11 for information regarding land use within the project area.
Figure 5, located in the attached July 2010 Environmental Assessment, presents
soil types within the project area. Although there are approximately 2 acres of
prime farmland soils in the proposed project area; it can be assumed that no prime
or important farmlands will be impacted by this project. This is a reasonable
assumption since the impacted property with farmland soils is currently owned by
the Town of Robbinsville. The land is currently being used for municipal
purposes and does not have sufficient area to produce significant agricultural
crops. There is little forested habitat or fallow field habitat within the project
construction area that would provide continuous wildlife habitat. Approximately
0.83-acres of forest habitat that could support wildlife will be altered due to the
proposed project. Figure 4, located in Section 6.0 of this report, illustrates the
wildlife habitat permanently impacted by the proposed project.
3.1.2 Environmental Consequences
Please see the attached July 2010 Environmental Assessment, section 5.1, 53-5.4
for information regarding environmental consequences of altered land use within
the project area. Cumulative and secondary impacts associated with the project
include the potential construction of sewer lines within the Town of Robbinsville
and western Graham County service areas. Due to the topography and natural
boundaries of the area, sewer lines will likely follow major roads and natural
drainage features to serve existing businesses and residences in previously
developed areas. Sewer line extensions are not expected to spur high density
development due to topographic site constraints coupled with the relatively small
amount of land available for development. Much of the greater Robbinsville area
is part of the Nanahala National Forest, which will serve as the major factor in
Environmental Assessment 7 Town of Robbinsville
McGill Associates P,A. wastewater Treatment Plant Relocation
July 29, 2010

limiting future development growth. The western Grahain County future service
area, which extends northwest of the Town of Robbinsville along US-129 and
includes several small communities, contains approximately 2,900 acres and is
bounded by the Nanahala National Forest and Lake Santeetlah. Almost all of the
western Graham County future service area is currently developed with mostly
residential properties and includes a few small commercial properties. Although a
small portion of the larger residential properties could potentially be further sub-
divided for residential and commercial purposes, the total potential development
is insignificant due to the topography of the available land. Additionally, the
Town of Robbinsville's future service area extension is generally limited to major
roadway corridors that connect the Town to neighboring communities. These
roadway corridors have already been developed and are also constrained by local
topography and Nanahala National Forest boundaries. Based on a review of
service area topography and land use, it is expected that the proposed project will
not significantly alter current land use. Figure 3, located in Section 6.0 of this
report, illustrates the existing and future service areas as well as the Nanahala
National Forest Boundaries.
3.1.3 Mitigation
No additional mitigation measures will be needed for important farmland or other
land use other than Federal, State and local ordinances which govern future
development. Due to prevailing topography throughout Graham County, the
majority of land classified as important farmland is located near waterways.
Relevant governance includes County flood damage prevention ordinances and
the State's applicable erosion control, water quality and water body buffer
regulations. These ordinances and regulations serve to control the alteration of
natural floodplains, stream channels and natural protective barriers. The control
of filling, grading and all other development that may increase erosion or flood
damage further protects important land resources.
Environmental Assessment $ Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

3.2 Floodplains
3.2.1 Affected Environment
The proposed project area has limited suitable sites available for WWTP
construction due to factors such as local topographic conditions, hydraulic
constraints, and available property. The proposed WWTP site was selected based
on site constructability, land availability, and proximity to point of discharge.
Portions of the proposed WWTP property are located within the 100-year
floodplain. Due to prevailing topographic conditions, some of the proposed
improvement structures may be located within the 100-year floodplain but under
no circumstances will construction take place within the 100-Year floodway. The
exact dimensions and location of improvement structures will be determined upon
completion of project design. A Federal Emergency Management Agency
(FEMA) Standard Flood Hazard Detennination Form has been completed for the
proposed WWTP site and may be found in Section 6.0 of this report. Please see
the attached July 2010 Environmental Assessment, section 4.14 for further
information regarding the floodplain within the project area.
3.2.2 Environmental Consequences
The direct environmental consequence of constructing portions of the new WWTP
within the floodplain will be the potential for untreated wastewater and treatment
chemicals to be released into the environment during flood events.
3.2.3 Mitigation Measures
Proposed WWTP structures will be constructed outside of the floodway and above
the 500-year floodplain to the maximum extent topographically possible. If
construction within the floodplain is necessary, open -top basin walls will extend a
minimum of 2-feet above the 100-year floodplain elevation, -which is above the 500-
year floodplain elevation, and water -tight access hatches will be utilized to prevent
wastewater and chemical release in the event of a flood event. The proposed WWTP
will be designed to ensure that system operational integrity and functionality remain
intact during 500-year flood events. The proposed project will avoid disturbing
riparian vegetation and the project specifications will state that all construction in
Environmental Assessment 9 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

floodplain areas will be restored to pre -project conditions. Native vegetative cover
will be restored to the extent practicable and no frll will be allowed. if it is
determined that construction will take place within the 100-Year floodplain, a no -
rise permit or letter of conditional map revision will be applied for through
appropriate Federal, State and local agencies. The Owner will also carry flood
insurance on all insurable above ground structures located within the 100-year
floodplain for the life of Rural Development loan. Additionally, the Owner will
enact a binding resolution to prohibit service to structures proposed to be built in
100-year floodplains. The resolution will be in place prior to USDA Rural
Development's approval of final plans and specifications. Along with a copy of the
resolution, the Owner will provide evidence satisfactory to USDA Rural
Development that the resolution is fully enforceable and has been adopted in a
manner consistent with all applicable local and State requirements.
3.3 Wetlands
3.3.1 Affected Environment
There are no wetlands identified in the proposed project area. Please see the
attached July 2010 Environmental Assessment, section 4.4 for information
regarding the delineation of wetlands within the project area.
3.4 Cultural Resources
3.4.1 Affected Environment
There are no known archaeological, historic or cultural resources within the
project area. Please see the attached July 2010 Environmental Assessment,
sections 4.7 and 5.5 for information regarding historic and cultural resources
within the project area. An archaeological study of the proposed project area has
been completed and is included in the Appendix of the attached July 2010
Environmental Assessment. Additionally, the North Carolina State Historic
Preservation Office has reviewed the archaeological study and has concurred that
no negative impacts to cultural or archaeological resources will occur as a result
of the proposed project. A copy of the concurrence letter is provided in section
5.0 of this report.
Environmental Assessment 10 Town of Robbinsville
McGill Associates P_A_ wastewater Treatment Plant Relocation
July 29, 2010

3.4.2 Environmental Consequences
No impacts to archaeological or historic resources are expected as a result of the
proposed project.
3.4.3 Mitigation Measures
Although no impacts to archaeological or historic resources are expected as a
result of the proposed project, project plans and specifications will contain
conditions such that if archaeological or historic artifacts are discovered during
construction, construction will be temporarily suspended. The State Historic
Preservation Office, Tribal Historic Preservation Office and Rural Development
office will be consulted to develop an appropriate plan of action prior to resuming
construction activities.
3.5 Biolo ical Resources
3.5.1 Affected Environment
Please see the attached July 2010 Environmental Assessment, sections 4.12-4.13
for information regarding biological resources within the project area.
3.5.2 Environmental Conse uences
A protected species survey was conducted by C1earWater Environmental
Consultants, Incorporated on July 19, 2010, which is within the optimum tirne
period for readily identifying Virginia spiraea. Virginia spiraea was not observed
within the proposed WWTP site area, proposed sewer line corridor or the
proposed outfall location along the Cheoah River. Additionally, the proposed
project area does not appear to contain suitable habitat to propagate Virginia
spiraea. The completed Virginia spiraea species survey report may be found in
Attachment E of the enclosed July 2010 SEPA EA, located in Section 6.0 of this
report. Please see the attached July 2010 Environmental Assessment, sections
5.10-5.13 for additional information regarding environmental consequences of the
proposed project on biological resources within the project area.
Environmental Assessment 11 ToNvn of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

3.5.3 Mitigation Measures
Measures to mitigate potential impacts to biological resources will include current
best management practices such as sedimentation and erosion controls, storm
water management and local land use planning ordinances as well as those
measures described in Sections 6.7-6.9 of the attached July 2010 SEPA EA.
3.6 Water Quafi, Issues
3.6.1 Affected Environment
Please see the attached. July 2010 Environmental Assessment, section 4.10 for
information regarding water resources within the project area.
3.6.2 Environmental Consequences
Please see the attached July 2010 Environmental Assessment, section 5.10 for
information regarding environmental consequences of the proposed project on
water resources within the project area.
3.6.3 Mitigation Measures
When hydraulically possible, construction limits will be designed to maintain a
50-foot buffer from all waters and in no case will the minimum 25-foot trout
buffer be encroached upon. Directional boring techniques will be utilized to
avoid disturbance of streams and riparian buffers. Where it is physically or
economically prohibitive to employ directional bore methods, crossings will be
made perpendicular to the stream flow and stream banks will be restored to pre -
construction conditions; at all times, the conditions of Nationwide Permit 12 will
be adhered to. Additionally, construction equipment will be kept out of streams
by operating from banks in a manner that minimizes disturbance to woody
vegetation. The proposed project utility alignment "rill avoid disturbing riparian
vegetation. Sedimentation and erosion control measures will be installed and
regularly maintained during construction until permanent ground cover is
established. Equipment will be regularly inspected and maintained in an effort to
detect and prevent leaking fluids from entering the waterway. The WWTP
facility will also implement and maintain a stormwater management plan.
Environmental Assessment 12 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

The proposed WWTP will have superior effluent quality as compared to the
existing WWTP. Tertiary treatment and nutrient removal efforts will be
integrated into design of the proposed WWTP to limit levels of nitrogen,
phosphorus; bio-chemical oxygen demand, and total suspended solids and
maintain compliance with the new National Pollutant Discharge Elimination
System permit issued by the North Carolina Division of Water Quality,
3.7 Coastal Resources
There are no coastal resources within the proposed project area.
3.8 Socio-Economic I Environmental Justice Issues
An Environmental Justice and Civil Rights Impact Analysis Certification has been
completed by the USDA RD office. The USDA RD office has certified that no
major environmental justice or civil rights impacts are likely to result if the
proposed project is implemented. A copy of the Environmental Justice and Civil
Rights Impact Analysis Certification may be found in Section 6.0 of this report.
3.9 Miscellaneous Issues
3.9.1 Air Quality
3.9.1.1 Affected Environment
Please see the attached July 2010 En«ronmental Assessment; section 4.8 for
information regarding air quality within the project area.
3.9.1.2 Environmental Consequences
Please see the attached July 2010 Environmental Assessment, section 5.6 for
information regarding environmental consequences on air quality within the
project area due to the proposed project.
3.9.1.3 Mitigation Measures
To control the amount of dust that becomes airborne due to construction activities
associated with the proposed project, construction areas will be lightly sprayed
with water as necessary. Additionally, construction equipment exhaust pollutants
will be mitigated through the use of standard emission control systems; operation
Environmental Assessment 13 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

of construction equipment will be on a temporary basis, dependent upon the final
construction schedule.
3.9.2 Transportation
3.9.2.1 Affected Environment
The proposed project will include construction of utility lines along and near
Town and State roads. The majority of the construction will take place along road
shoulders within regularly maintained right-of-way.
3.9.2.2 Environmental Consequences
Impacts to transportation within the project area include temporary lane closures
and potential temporary impairment of highway safety.
3.9.2.3 Mitigation Measures
During project construction, the contractor will provide, erect and maintain all
necessary barricades, suitable and sufficient warning lights, danger signals and signs,
sufficient number of flagmen and other devices necessary to direct traffic, if
required; to provide proper advance warning of construction; to maintain the safety
of the public and to minimize delays, obstructions or other conditions which would
cause significant back up of traffic or other"'Ise inhibit traffic flow. The contractor
will also notify local emergency services and property owners of work in their
respective area, the extent and schedule of the work and the effect on the property
owners well in advance of the work and shall maintain driveway access to the extent
possible or provide temporary parking locations.
In general, the traffic will be allowed to pass through the project at all times.
During working hours, one lane will be blocked with the other lane passable. All
signing and channelizing will be moved along the project to maintain proper
distance from the construction activity. These signs wrill be in accordance with
the Standards and Guidelines for Work Zone Traffic Control as published by the
U.S. Department of Transportation and the standards set forth by the North
Carolina Department of Transportation. All ditches, trenches and holes will be
backfilled at the end of each construction day and flashing lights or other similar
Environmental Assessment 14 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

warning signals will be provided overnight if site conditions dictate their
necessity.
3.9.3 Noise
3.9.3.1 Affected Environment
Please see the attached July 2010 Environmental Assessment, section 4.9 for
information regarding noise within the project area.
3.9.3.2 Environmental Consequences
Please see the attached July 2010 Environmental Assessment, section 5.7 for
information regarding environmental consequences on noise levels within the
project area due to the proposed project.
3.9.3.3 Mitigation Measures
Construction activities will be limited to normal daytime hours (7 a.m. to 7 p.m.,
Monday through Friday) to minimize noise related disturbances to the local
community. Large construction equipment will be equipped with proper noise
attenuation devices such as mufflers and silencers to minimize construction
related ambient noise level increases. Additionally, permanent mechanical
equipment at the proposed WWTP will be housed in noise attenuating enclosures
to minimize noise pollution.
Environmental Assessment 15 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

4.0 SUMMARY OF MITIGATION
A summary of mitigation measures for each environmental resource as described
under the subsections of section 3.0 is provided below.
Floodplain5
Proposed WWTP structures will be constructed outside of the floodway and above the 100-
year floodplain to the maximum extent topographically possible. If improvements must be
made within the floodplain, open -top basin walls will extend above the 500-year floodplain
and water -tight access hatcbes will be utilized to prevent wastewater and chemical release in
the event of a flood event. The proposed project will avoid disturbing riparian vegetation
and the project specifications will state that all construction in floodplain areas will be
restored to pre -project conditions. Native vegetative cover will be restored to the extent
practicable and no fill will be allowed. Appropriate Federal, State and local agencies will be
consulted to with to minimize potential adverse impacts to the floodplain and all applicable
permits will be acquired prior to construction.
Biological Resources
A protected species survey was conducted by Clearwater Environmental Consultants,
Incorporated on July 19, 2010, which is within the optimum time period for readily
identifying Virginia spiraea. Virginia spiraea was not observed within the proposed
WWTP site area, proposed sewer line corridor or the proposed outfall location along the
Cheoah River. Additionally, the proposed project area does not appear to contain
suitable habitat to propagate Virginia spiraea. Measures to mitigate potential impacts to
biological resources will include current best management practices such as
sedimentation and erosion controls, storm water management mitigation and the
mitigation described in the "July 2010 SEPA EA" in Sections 6.7, 6.8, and 6.9. Impacts
to forested areas, located at the proposed WWTP site, will be lessened by minimizing the
construction boundaries and required site clearing to the maximum extent feasible.
During construction, riparian vegetation will be preserved as much as possible and trees
that must be removed outside of the immediate construction boundary will be cut near
ground level, leaving the stump and roots in place to provide for ground stability and
Environmental Assessment 16 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 20 10

possible re -growth. Aquatic habitat impact along the Cheoah River will be further
mitigated through the tertiary treatment of wastewater prior to discharge. Upon
completion of utility line construction, all construction corridors will be stabilized and
returned to pre -impact conditions which will include seeding along utility right-of-ways.
Water Quality Issues
Riparian buffers zones will be maintained to the maximum extent possible. Directional
boring techniques will be utilized to avoid disturbance of streams and riparian buffers.
Additionally, construction equipment will be kept out of streams by operating from banks
in a manner that minimizes disturbance to woody vegetation. Sedimentation and erosion
control measures will be installed and regularly maintained during construction until
permanent ground cover is established. Equipment will be regularly inspected and
maintained in an effort to detect and prevent leaking fluids from entering the waterway.
The WWTP facility will also implement and maintain a storm water management plan.
Tertiary treatment and nutrient removal efforts will be integrated into design of the
proposed WWTP to limit levels of nitrogen, phosphorus, bio-chemical oxygen demand,
and total suspended solids and maintain compliance with the new National Pollutant
Discharge Elimination System permit issued by the North Carolina Division of Water
Quality
Air uali
To control the amount of dust that becomes airborne due to construction activities
associated with the proposed project, construction areas will be lightly sprayed with
water as necessary. Additionally, construction equipment exhaust pollutants will be
mitigated through the use of standard emission control systems; operation of construction
equipment will be on a temporary basis, dependent upon the final construction schedule.
Trans ortation
In general, the traffic will be allowed to pass through the project at all times. During
project construction, the contractor will erect and maintain all necessary measures to direct
traffic, provide proper advance warning of construction, maintain the safety of the public,
minimize delays, obstructions or other conditions which would cause significant back up of
traffic or otherwise inhibit traffic flow. The contractor will also notify local emergency
Environmental Assessment 17 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29.2010

services and property o-wners of work in their respective area, the extent and schedule of the
work and the effect on the property owners well in advance of the work and shall maintain
driveway access to the extent possible or provide temporary parking locations.
Noise
Construction activities will be limited to normal daytime hours (7 a.m. to 7 p.m., Monday
through Friday) to minimize noise related disturbances to the local community. Large
construction equipment will be equipped with proper noise attenuation devices such as
mufflers and silencers to minimize construction related ambient noise level increases.
Additionally, permanent mechanical equipment at the proposed WWTP will be housed in
noise attenuating enclosures to minimize noise pollution.
Environmental Assessment 18 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

5.0 CORRESPONDENCE
The following correspondence is included within this section:
Project Support Letters
1. North Carolina Department of Environment and Natural Resources,
Division of Water Quality
2. North Carolina Department of Cultural Resources, State Historic
Preservation Office
Comment Request Letter
1 Clearwater Environmental Consultants, Inc.
Comment Response Letters
4. Eastern Band of Cherokee Indians, Tribal Historic Preservation Office
5. North Carolina Department of Administration, State Clearinghouse
6. North Carolina Department of Crime Control and Public Safety, Division
of Emergency Management
7. North Carolina Department of Cultural Resources, State Historic
Preservation Office
8. North Carolina Department of Environment and Natural Resources
9. North Carolina Department of Environment and Natural Resources,
Division of Environmental Health
10. North Carolina Department of Environment and Natural Resources,
Division of Water Quality
11. North Carolina Wildlife Resources Commission
12. United States Fish and Wildlife Service
Environmental Assessment 19 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

TUL-17-20DB 37:13 FR:1Dri:1�RT B?82964663 T0:5252251B F:?,,4
'O A T-- l,�tichael F_ Ezsl=y, Governor
Z Wfflielm G. ribs;.lr., saare,gry
a4 F;r lmnrtant encl Iti3tulml Resources
�3 `rr Ceteen )i, sulllr� i�fre�sot
j � �i�rlsion ofVd�tsr G�uatiiy
p rshevil}e Regional Once
tUR.IYACE AIAT ER PROTECTtOlk
Mr. Robart Cagla, Jr., N4aycr
Town or Rabbirsvilla
Past G;t[Ge SOX 129
1= obN'trsuil le, NeTth Care ina 28771
SUBji=CT:asta,F,r�[}ter i reatment Plait Expanslon
I own ofRobbl AsvNa
IgPDES Permit number NCOG25879
Graham County
Dear Mr. Cagle:
I've been infcrrmad that the Town of Robbinsville is seeking funding 10 design and
construct a new wastawater treatment plant, I am In favor aTr such a protect and wish you
success in arranging funding. The rate at which the volume of WssteWater being treated
is increasing give time for an ordariy prooess of planning, designing and constructing a
new, larger treatment plant. The present plant ls. located on a very restrictive place of
land. A new plant on a iargar pieoa of land will give the Town the aptien of utilizing a
receiving stream having a greater 7-day, 1D-year low how than noes the present receiving
stream.
Again, I wish you success in your endeavors to secure fuRding For the Robbir:sville
Wastewater Treatment expansion. Should I be able to assist in this matker, please do not
hesitate to Gall.
Slr�cerEly,
'O'-�Vavis
Environmental Engineer
CO: Mike M oUll Associates
Ka th Haynes
SurFace Water Protection Gantral Has
Asheviile Fires
G-,W013DATA%DRNr1%AfQ\GmhamlRobbins�,iIle Colls--Llon SyMe.mlRebbins�riile-\NWTP 1;xp3nsiQn.DB,�o❑
PIP
�,Iti,Caro'i�na
2090 U.S. l-Jgh4«y 73, Sv-fRT1n2nc-2, NJC 2'c-778 i aE.?-Ph^n=_; (52-F) 293-4509 Fn,:: (&-25) 288-7 :)43 Grstcrria, Se7vic3 1 377 n2-374A

O3t2g/2Q1©
08:39 NC STATE HISTORIC PR-SERUATION y 912252522513 NO.BE5 P02
North Carolina Department of Cultural Reso-.reel
State Historic preservation office
Pctcc p_ SanaUccl� -�'�n nixes ar
Offrcc c#Arr!ti<<cs and Hisso'y
Seedy E2V-.V Prue, C3ovecrccr Diriaion of ElimJe es liceourcac
Linda A,. Gard,-, Sccrcmry D--Vid Brook, Director
Jeffrey J. Crow, Deputy $ecrrnry
1l�arch 22, 2010
Joseph WM6-ms
Y CGrill.Associ�tcs
PO Box 2259
Asheville, NC 28802
Re: Ro�abarla Ie Waste Later Xreatir�e zt Plant Relocation, Graham Co�rrty, CIS �$-2529
Dear Mr. Wifli'-U s:
razzk you fas yo>a-1letter of Mazc17 S, 207 Q, tr:�nsmitsiug the axclzaeological sr-veq report by TRC
Z-no'iscnmeaW Corporation fos the above project. The report meets ous a delin,es and those of the Setreta=y
of the irlretior.
Dtmi:ag the course of the survey, one site was located witun the project area. For purposes Of campliancc With
Section 106 of the National. Historic preservation Act, we concur that M GH561 /561 ** is not eligible for
listyr-g in the N46onal Register of Historic Places.
This site does not remin sufiicieut stalbsurface integrity ox artifact d,easity to 3 field inforrrsadon imporrant to
history or ptel dory.
1 e report authors 1 the recoromcnd.ed that no further archaeologic -al investigation be canducredfic- in ca�ectio�l
with this project. We cosacur with this recomma--Idat�an since rl-le project wsll not involve Sigaiftcarit
�G�l�e[ZIOgLGaI Se50Li.TG�S.
The abova cotiun,ents are made Pursuant to Section 106 of the Na tioxr a I- istcric PreselvArlon Acr and the
Advisory Council on klisto.tic Preservr.ti,an,s Regulations fox Compliance with Section 106 codified at 36 CI"R
Part 800,
-n=k 701-1 for your cooperation and coasi4era.tion. Ifpou have questions concemax�.g the above rom !neat,
please contact Renee Gledhill -barley, U17irOa rental a;evview cool-dirlatox, at 919/807-6579. In all n3Lure
communication concem�zg this �aroject, please cite the shove referenced tracking nx�,nber.
Sincerely,
Sandbcck
cc: Paul Webb aad Wee Nilson, TRC Eizvironznen.tal Carpnration
La= tics: i09 as��ors c 5cc S:L cigtti SAC 2- 'i h�s�u�g % dcl:asc: 4617 NIL!, S—';C0 Cmusr, ju:lclyr1, NC 276B9-46i7 {�L-�6�mtr'P (979) B77-G57d/907.L•544

CLEARWATER ENVIRONMENTAL
CONSULTANTS, INC.
719 Oakland Street
Hendersonville, NC 28791
[phone]
FAX [phone]
Ms. Valerie McMillan
N.C. State Clearinghouse
1301 Mail Service Center
Raleigh, NC 27699-1301
LETTER OF TRANSMITTAL
DATE:
10.21.08
PROJECT: 494
ATTENTION:
Valerie
RE: Robbinsville Waste Water Treatment Plant
WE ARE SENDING YOU ® ATTACHED ❑ UNDER SEPARATE COVER VIA THE FOLLOWING ITEMS:
COPIES DATE NO. DESCRIPTION
16 10.21.08 Scoping Letter
THESE ARE TRANSMITTED AS CHECK BELOW:
❑ For approval
® For your use
❑ As requested
❑ For review and comment
REMARKS:
❑ Approved as submitted
❑ Approved as noted
❑ Returned for corrections
❑ Materials returned after loan to us
❑ Resubmit copies for approval
❑ Submit copies for distribution
❑ Return corrected prints
EJ
Enclosed are 16 copies of the scoping letter for the relocation and upgrade of the Robbinsville Waste
Water Treatment Plant. Please distribute and publish in the N.C. Environmental Bulletin.
Please do not hesitate to call me [phone] if you have any questions.
COPY TO: SIGNED:
CLEARWATER ENVIRONMENTAL CONSULTANTS, ZNC.

0
OR?.? October 21, 2008
Dear Concerned Citizen
RE: Robbinsville Waste Water Treatment Plant relocation and upgrade
Robbinsville
Graham County, North Carolina
The Town of Robbinsville is proposing to relocate the existing Robbinsville Waste Water
Treatment Plant (WWTP) to a new, larger location. The Town has acquired a 12 acre
parcel of land situated north of Robbinsville on the Cheoah River suitable for a new
facility. This Environmental Assessment (EA) reviews the proposed plans and potential
effects on the environment.
The Town of Robbinsville owns and operates a wastewater treatment plant that provides
service to the area within the Town limits as well as some outlying areas. The existing
Robbinsville WWTP accepts sanitary flow from approximately 450 residential properties
and 157 commercial properties in the Robbinsville area. There is also a large industry,
Stanley Furniture, and several smaller industries which are connected to Robbinsville
sanitary sewer system. The current W WTP capacity is 630,000 gallons per day (gpd).
The existing WWTP consists of an influent pumping station, grit removal, a comminutor,
a circular extended aeration tank with center clarifier, sludge holding, UV disinfection,
and gravity effluent to Long Creek. Current average daily wastewater flows to the
treatment facility are approximately 300,000 gpd.
The Robbinsville WWTP was originally constructed in 1964 with a capacity of 130,000
gpd. There were major upgrades installed at the plant in 1986 to increase the capacity to
630,000 gpd. Since this last upgrade in 1986, treatment equipment is nearing the end of
its useful life. There is limited solids -handling capacity at the existing plant. Sludge must
be stored for a period of time and then pumped and hauled to another facility for
processing. Upgrades to the existing facility to accommodate treatment improvements
and future growth are restricted by its site. The existing WWTP cannot be improved at its
current site.
The proposed Robbinsville WWTP is to be relocated on a 10-acre parcel of land owned
by the town and situated north of Robbinsville. The proposed WWTP is approximately
0.2 miles north of the existing Robbinsville WWTP (Figure 1). Utilizing Census data
from North Carolina, the future population in 2028 to be served by the Robbinsville
WWTP is approximately 9,270 persons. In order to accommodate this projected
population, a capacity of approximately 830,000 gpd is necessary at the proposed
Robbinsville WWTP.

We invite your comments on this proposal. If you have specific comments or concerns
on the proposed action, please send them to , Division of Environment and
Natural Resources, 1634 Mail Service Center, Raleigh, NC 27699-1634.
Submit your conu-nents by December 1, 2008 and be as specific as possible. Comments
should contain the following:
• Name, address, and telephone number (if possible)
• Title of the project on which the comments are being submitted.
• Specific facts or comments along with supporting reasons that the person believes
the Responsible Officials should consider.
Comments received in response to this solicitation, including names and address of those
who com vent, will be considered part of the public record on this proposed action and
will be available for public inspection. Comments submitted anonymously will be
accepted and considered; however, those who submitted anonymous comments will not
have standing to appeal the subsequent decisions under 36 CFR Part 215 or 217.
Additionally, pursuant to CFR 1.27(d) any person may request the agency to withhold a
submission from the public record by showing how the Freedom of Information Act
(FOIA) permits such confidentiality. Persons requesting such confidentiality should be
aware that, under the FOIA, confidentiality may be granted in only limited
circumstances, such as to protect trade secrets. The N.C. Division of Water Quality will
inform the requestor of the agency's decision regarding the request for confidentiality,
and where the requestor is denied, the agency will return the submission and notify the
requestor that the comments my be resubmitted with or without name and address within
seven days.
For additional information regarding this proposed project, contact Mr. at
(919) 715- or Mr. R. Clement Riddle at [phone].

S
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CLEARWATER
Robbinsville WWTP Site Enviro=cntal Consultants, Inc.
Graham County, 718 Oakland Street Toga Map
North Carolina
Hendersonville, NC 28791 Figure
828-698-9800

FEB 2 2 2010
Eastern Band of Cherokee Indians
Tribal Historic Preservation Office
P.O. Box 455
Cherokee, NC 28719
Ph: 828-554-6852 Fax [phone]
DATE: February 18, 2010
TO: USDA., RU
Attn: Pamela H. Hysong,
Area Specialist
PO Box 8
Horse Shoe, NC 28742
PROJECT(s): Comments regarding Wastewater Treatment Plant Relocation Town
of Robbinsville, Graham County, NC.
The Tribal Historic Preservation Office of the Eastern Band of Cherokee Indians would
like to thank you for the opportunity to comment on this proposed Section 106 activity
under 36 C.F.R. 800.
The EBCI THPO concurs with the archeologist's recommendations that no archeological
sites eligible for inclusion on the National Register ofA such, the EBCI aces e encountered believes
during the recent phase I archeological field survey.
that the proposed project may proceed as planned. In the event that project plans change,
or cultural resources or human remains are discovered, all work should cease, and this
office should be contacted to continue government to government consultation as defined
under Section 106 of the rational Historic Preservation Act of 1966, as amended•
if we can be of further service, or if you have any comments or questions, please feel free
to contact me at [phone].
i
rely
Tyler Howe
Tribal Historical Preservation Specialist
Eastern Band of Cherokee Indians

Michael F.--Lasley, Governor
North Carolina
Depaz f ment oz AdininiStrat ion
October 233. 2008
l��lr. Clement Riddle
Robbinsville Waste Water Treaunre_nt Plat
c/o Clear+n'atcr E11vironlnzntal Cons-L:L ists
71-8 Oalda'Ed Street
Henderson-ville NC 28791
Dear -Mr. Riddle:
CEO Project
t
!Date Relieved- Jb• —4-4 0
Britt Cobb, Secretary
Subject: Scopv.Lg - Relocation. and upgrade of the Robbinsville Waste Water Treatn}ent Plant in
Grahai- i County
Tlie N. C. State Clearinghouse has zeceived the above prof m for intergoveriuizental review. This
project has been assigned State Application Number 09-E-0000-0110. Please use this nm-nber with
all iilgj:iries or correspondence with this office.
Review of this project should be completed on or before 11124/2008 . Should you have any
questions, please call [phone].
Sincerely,
Valerie -W. McMillan, Director
State Environin- ;tal Policy Act
II,.0.77gAddress 3elerho!m.: (91r)07-- 425 Locationdrlress:
13C1 hf�i1 yen i _Center Fer ;3:9)733-9371 116 `Nest 1On-is street
z=le;�h.7.0 _?G95-]301 5tateCeu:ierni]-u:-OC R71ieivh,North caro!'.ne
2-!il �I�: �`<<�Brf',11:"1 GSl;ll�;lnl Li 1103.a C,tr�i'

z.y
Y
z� 9H�F
Norte. Carolina
D e,p artm- it � o ' Adinini s ahoP-
Michael F. Easley, Govem or Britt Cobb, Secretary
Noy -ember 25, 2408
1N1r. Clement Riddle
Robbinsville Waste Water Treatment Plant��'r}c` y
CIO Clearv7ater Envirol�nental Conslita,
718
Qaldand Street
Hende,rscmdlle, NC 28791
Re: SCH Pile g 09-E-0000-0110; SC©PING; Relocation and upgrade of the Robbinsville Waste
Water Treatment Plant in Graham County
Dear Mr. Riddle:
The above referenced envirormental impact information has been submitted to the State Clearinghouse
under the provisions of the National EnvirOl'lnental Policy Act. According to G.S. 113A-10, A�rhen a
state agency is required to prepare au envircm-rental d.ocu_nent Colder the provisions of federal law, the
enviror rental doclunent meets the provisions of the State Environmental Policy Act. Attached to this
letter for your consideration are the co=-ji nts made by agencies in the course of t11Ls revievq.
If any•alriher eavirornDental review docl_urients are prepared for This project, they shottild be fo>v� aided to
this office for intergove>--Tvnenta1 review.
Should you have any questions, please do net hesitate to call.
Sincerely,
Valerie W. McMillan, Director
State Enviro=ental Policy Act
Attacluiaents
cc: Region A
TelePltane: 7-242 Loc¢r"'orr
(919j80Atic(r�ss:
Ala Cirr; t Udress: 116 1Vest Jones street
Fax [phone] i 1 �-;,1eiE:jj, T<o:-ti C3rclinl
3�1 mail 5en�i e Gen_er Gta'e Courier Y51 61-u0
•�=-r�,,rif -,aferre.u.rnF�>llfc�z t�doa.r;c.;oi>

INTo,L til CaYoRna Depart�i�ent of Crime Centaol aid u lie safety
Division ofEmergency Management
Office ofGeospatial and Technology NianaatMent
4 719 Mail Senice Center • Raleigh, NC 27699-4719
114ichael F. Easley
Governor
November 3, 2008
pis. Valerie McN ilL51T)
State Clearinghouse
N.C. Department of Adi ; 'stration
1301 Mail Service Center
Raleigh, North Carolina 27699-1301
r. .
fL:�
Aryan E. B ea�ty
S ecretary
Subject: Intergovernmental Review State N',amber: 09-E-0000-0110
Relocation and upgrade of Robbinsville Wastewater TreatnIent Plant in CJraham
County
Dear Ms. Valerie McMillian:
As requested by the North Carolina State Clearinghouse, the forth Carolina Department of
Crime Control and Public Safety Division of Emergency Management Office of Geospatial
and Technology Management (GTM) reviewed the proposed project listed above and has
provided comments herein. It is our understanding that the Town of Robbinsville is planning
to replace and upgrade their wastewater treatment facilities at a location near the Cheoah
River as it drains into Santeetlah Lake. The project will have a treatment capacity of .
approximately 950,000 gallons per day, but no details (e.g. plant layout or elevations) of the
facilities are provided in the package.
The GTM has the following comments:
1) As shown on the Graham County DF1RM Panel 5 66 1, the proposed project includes
areas within the newly detailed studied special flood hazard area of the Cheoah River
and within its regulatory floodway. Any proposed construction (including demolition)
within the floodway will require, prior to construction, approval of either a no -rise
study with a no -rise certification for projects that do not increase base flood elevation
or for projects that result in an increase in base flood elevations, the approval of a
Conditional Letter of Map Revision.
2) Construction of the in -water facilities may involy e the placement of temporary coffer
dams, trench boxes or similar structures to facilitate installation. if the structures are
expected to be in place during all or a part of the hurricane season (June 1 through
Location: 1812 Tillery Place, Suite 105 Raleigh, NC '27604 ° [phone]
An Equal opportunity/Af kirmative Action Ernpicyer

Paget oft
NovCmber 3, 2008
December li, they sbould be considered `in -place` for the proposed condition of a no -
rise evaluation.
;) Please consult the To-s�,m of Robbinsville and Graham County floodplain
adrniuistrators for guidance on higher standards for iloodplaia, dev(=,lc)p-rent as defined
in local ordinances.
Thank yGu for your caoperation and censiderabion. If you have any qucstons cancerni�lg the
above camments, please contact me at [phone]. or by email at kashe,, a;ncem.ora cr at
the address shown on the focter of this document.
Sincerely,j
Kejaneth W. the, P.E., CFNI
Assistant Director
c: Randy Mundt, NC NFIP State Coordinator
Location: 1 S12 Tillery Place; Suite 105 ° ?Raleigh, hTC Z7604 ° (919) 715-5 711
An Equal OpportunitylAff:Imalive Ac on Employer

ILI
r
NORTH C ROLINA S`TA1E OLARTNGHOUS
LDZpAPLT1ENT Off' ADBST),� + STRATlON
I14 T_ RGOVERRME-INTAL REVIEW QU
DATE -,�TCzI-VED: 10/23/20DB
AC _ FS?0NS:k:j:11/19/2C09
R:,VIEW CL0SED:11/24/2008
Ts3 R.EN- SLED 3sLL-E�.RLEY
CLEA-R!I� SIHOUSE COORD A` �d'lr ,� rjr � 64
SOT
AR.Chi -r]-DEPT OF CU�, PE
R-STORY 7 - !'_•SC � 51?,;_� �
Gov
�j
r�riflEN �z5_Rz_T� Ir-Nr�a,aj
CC&PS EI�J, GiI�Ocs�_� L
DEER LEGISLATTv-1 nErAItS C' f
DEPT OF CUT. :RESOURCES
DF,?T OF TRsNSPCR=rTIOT�
C Yf N C F" LANN 3 " C OIq :I F l 7
�E ta-Iag
�ROJ7 CT TN 'ATION
APPLIC�_'�'T: ROhbinS "le ��aste rater _reatment Plant
TYPE: Nat' cnal En.-i roi-rental po- icy 'ct
EFcD: Scopi_zg
DESC: Relocation ar_d "pgrada of thR Rohbir.S�il1e baste Water�'ea�ment Piar.t _r Gramm
County
The attached project has been submitted to the N. C. Srate Clearinghouse for
eJiein . - ease e'�] E'a' ar:d stib-Lbyour-esoonse by the ahoy*e
1Ptc-COveTT y;�? L31 - -
indicated date to 1301 Dail Ser'Tice Center, Rale_gn 1uC 2iG99-1s01.
rmew ti.[.a is r_eeded, please contact this oz-ice at (919)3C7-2�25.
=
If additional ..
RS A RESULT OF THIS RE'dIEW THE yC--�LOINING IS SUBMT_TTED:
-NO COr,'ll'°ENT
COI MENTS ATTACHED
SIGNED BY:
DATE: �� . I ;� - OZ

Sri¢
g"d riK�� C;F-C Pfolect # `l�f
r �s Date RadeVed
aLL
I\Torth Coroli a De 2�rtrt en of Cultural Resources
stare I-Estaric Preservation Office
Pe-ez b. Saadhezk, a drnirisswtoz o rF,.L c f A_,C ,jvtts znd Hi torn
_ 4iclza 1 F. a sled, Gore-ao Dil•ision of Historical
'esoucc_s
'L�isbe" a r ins, sersetary Dated 3_ook, rµectoz
�?c,-e,-r_bet 14, 20Q8
R. Clement Riddle
CleatWater Ravironmental Cons Liltarns, Inc.
718 Oak -land Street
Hendersonville, NC 28791
Re: Robbins --idle Waste Water Treatment Plant Relocation, Graham Coin-q, CH GS- -29
Dees 'N1r. Riddle:
We have received the above~e project fox re3ie'a from -le State Cleaziaghcuse, and hay e tl e follow ng
cor=ents.
We have deternnined that the project as proposed v,,,iJ not affect any ),1staric s-suctures.
There are r>o k�o�x n recorded archaeological sites xdtl'n the project boundaries. Hot -ever, the soarces Based
n ever been systematically surveyed to det odne, tht tLoe den � of taco dad sites ainllle ar a�there is a high
an the topo�aplic and hydrological srtu2� ,
probability for the presence of prelv.storic or Historic archaeological sites.
fy and
` t recommend that a corrlprehensiti e szry ey be conducted by p ed or d stra ed by thnctd e e pi peo ed pro act.
evaluate the signifrcarace of archaeological ust btna that id p be g
Potential effects on urLknovrn resources must be assessed poor to the instiatien of constr-uct~on activities.
Ts o copies of the resulting archaeological survey report, as welt as one copy of the appropriate site forms,
sUould be forwarded to us For review and comment as soon as they ate available and. well u� ad��ance o£ any
construction activities.
?, list of archaeological consultants vaho have conducted ox expres d, solotrrsts I contract , or any o-ffiEr North
Carolina is av fable at `V ,u va.arch.dcr.state.nc,us consults.littr. Tl_ b
experienced archaeologst, may be contacted to conduct the recommended survey.
`the National Historic Preservation Act and the
The 2-bov e corrrmcnts are made pursuant to Section 106 0�
Ad�riscLy Cots7cil en HistnLic Prese>�Tation's Regu'adorrs for Compliance'W'Becton ton 106 codified at 36 CFR
Part B00.

11z ou for your cooperation ar-d conside== on, if you have questions conce?sirig the abovecorree�t,
phase cor__act Renee Gledl ill -Earley, envirO=ental res ew cocrc ator, at 919�'SQ7-Gbr9. T a1 fuizrU
co_zunun.aaron mnccrning this pra;tct. please ate t'�c abo t refcrenced tracking n=- T.
Sincerely,
P per Sandbeck
` cc: NCDN- ER
sta%e Clt=' ghouse

NCDENR
North Carolina Depa[Lment a, Environment and Natural Resaume
hfiichael F. Easley, Governor William G. Ross Jr., Sacretary
1,7
COIN
.N- MIA
TO: Valerie McMillan
State Clearir_grovre
FROM: Malba McGee
rrD]ECt ReviLw Coordinator
RE 09-0110 Scoping for the Robbin.svilie �n�astewater Treatment
?!a --,It Re? ocaticn and upgrade in Graha-1 County
DRT";: ldovenber 19, 200E
re
lY?e, repart�nent Cf ,,nvi ronment and Natural ResOuXCeS i'las reviewed the
vieOf
glis re
rope ed Pror�ments The will attached be provided during
ng r the t envi rcr_mentalW review
specific c
process.
Thank you for the ODpOrtullity to respond. Eo during the preparation
the
of the environmental document,
additiol-'I i n=ormation is needed, L'�e
applicant is encouraged to notify our respective divisions.
Rt Lach-men s
One
1601 hail SeFvice Center, Raleigh, North Caroiina 27699-1601 Nbft .Ca olina
Phone: [phone] FAK 919-715-30661 lntemet; enr.state. nc.u,sIENPR 1�

DEPARTMENT OF ENVIRONi\(iEN T AIND project
umber
NATURAL URA} RESOURCES
DIVISION OF 'NVIR0NWN1lEI T AL HEALTH LCIDILJrnity
Graham
Inter -Agency Project Review Response
Project Flame yo�rn ARubbiasr-ilie Type cf Project Relocation and sip�rade of
the Rob bin svilie Waste
Water Treat tent Plant.
Con-imerts prcvided by:
❑ Regional Program Person
Regionai Super,risor for Pub�ic Vvater supply Sec ion
❑ Central Office program person
Dame Jim Adams-Ashev=_ile RO
Telephone number:
Program with;n Division of Environmental Health:
❑ Public Water Supply
❑ Othc-F, Name of Program:
Response (check all applicable):
Er No objection to pmect as proposed
❑ No comment
❑ lnsuticient information to comp4ete review
❑ comments attached
Date 10/ 9/2008
0V2� �a
or-IV�
Q DOA r!
.yl
pul,iiU'V^f-3tar Supply Suction Enviren-nental Rev�evd Caordinator fcr the
Division �t En4rironmer`al ' laalth

iitliartrfle:M u1 _n`<'l;anment: a ,1 <atur2l KESCY�raes
1--INTERGOVERNMENTAL REVMW - PROJECT COMMILINTS r "'..t i;in _err lJ � 0 7_te gate:
?.ter erieh' oit".i5 praject it !,,as beer, determined t'_iat the ENIt Dennitfs) andlD; app-cva:s instate msy need to be a'otai'.ted in o.der for t',tis p-o;e t toco:np}y r': iih 13a It
Carolina ? au'. Questions regardin; these permits sltarld be addressed to dte Regional C* ? indicw.ed oc':ne revers o'tlterorm. A'.] applicati ns, in;ern,ation and guidelines
.elative to Chest plans and penr,is arc availab]e from the amt Regi�nal Cfice.
.)vernal iroeess Tine
'EP�FiTS 3FEC'ti AFTNZA=NP?ZOC=DUFESorRbQtiFFI,F NTS (statutorytimtIimit.)
Permit to cDnstr ct operate'+2s1 'r'ater _,eatment
4pp.jcatian K days befo e begirt cDnstuctim ar eward of hors run:ian
3ry days
❑
facilities, sewd, t7,mrn extensions & sewer sj'S:e s
cortacs. Dn-site inspect Dn. Post-appiicai Dn iecJtnical aDafe,_nce usu21.
(9D days)
i
not disaha-eing into state su-ia_c watsrs.
l
F-pplication I K daps before begin activ'.ty. DIl-site i tspeation.Pre-application
IUDES - permit to discharge intD surf ace wa_er aitd.'o;
conference us'.tai. Additionally, obtair, perm to construct'�:astt;'atsr
9C-12C da•'s
❑
permitto operate a d consL,tct lti•astewaie; izai;ties
--eatmeu'. ani'.ity-granted a er[ NFDES. ren'y -hne, SO a's af,er receipt of
(N1A)
d'.;char ing in c sia'te s'.3rface Waters.
glans Dr ssns of1vPD�s' permit-vinichever is rater"
3rJ da's
❑
1ti'eter Use P'.^-nit
Pre-zppliaa fan techricat cut fc: ^nee u5Lz11} : °cessary
i V?A)
Co-nplete applicaaDr.:nuai he received and pe- at issued prior to the
7 days
Il CDRS_*'JCtADn F ,r-it
nstalla,ion of a Weir
(35 dgys)
Application cop} must be. se-,'ed on each adjacent ripatim pYape-•y e''�aler.
On -site inspectiDn- Pre -application conferenceus'cal. Fil'.ing may requite
55 days
❑
]rodeo snd sill?e, nit
Easement to Fill from KC, Depa"tment efAdministratroa and Federal
(9D days)
Dredge and Fill Permit.
. tense be ubmt tied ar.d pe ri[ ra vi ed prior to
kpplicu-fun s
pr.-Mitto consncf &. operate Air Pollution Abatemen'
co?ts=;tion end ape -a -ion ei the source. li a pe $t is requirad is an
days
❑
facir,ties atdlor Emission SOUTa—m %S per 15 A NCAC
area without focal then there are additional ;scuretnents snd
area
(2Q.0102 thru 2Q.33DC)
;imel:n s (2Q.0133}.
I Permjt'Lo curtsiruct a Dpera's , rarsportation Facility as
Application must he submitte3 at least 90 days p-iorto cons Dction n7
oD days
❑
per 15 ANCAC (2D.080➢, 2Q.0501)
nodificatior of the sour=e,
Any open bur ;ng associated with su'biert propnsal
i
❑
?nust be in comp3iance whit 15.4 NCAC 2D.1900
D-niclition orrencvstiDns ofstructures containing
asbestos .pate-izl must he iii cnmplianc-t with 15 A
64 days
❑
i
NCAC 2C.1 i 1 C (a) (1) which requires notification and
N`.4
190 days)
removal prior to detnDlitan. Contact A sbe5tcs Contra]
Group 919 ?07-595D.
i
Connplex So,jmt Permit requirsd a:t=w 15 A 74G4C
❑
i 2D.0 806
The Sedimmta`iaa Pollution C3ntrol Act of i 973 must beproperly addressed for arty land disturbing activiy. An erosian
sedime3:tatian c07 1rD1 plan will be required if one orr„ore acres
to be d;st&nDed. Flat :Pied will: proper RagiurL] Grunt (Land Quality
2p de)'s
Section) At least 33(7 days bef am beginning activiy. A fse Df
$ for ht first acre or any pal, titan acre. An express review option is
(3p days)
zvRilaUle with additional fees,
Sedimanta:ion and eresim control must be addressed in accD ante withNCDt)T"s app. o-ved prog:at:t. Particu'tar attention should be given to
(3D Czys)
©
design and installati-an of appropriate perimeter sediment trapping devices as well as stable s'.Drm'vatercorveyances end ou ets,
t
0n-site insp coon usual. Surey bond fled ,With £ NP.baad cntD:tnt varies
wilt tape mine and number ❑f acres of st:eetcd land: Any arc rni_ted greater
3a days
❑
I Is4iring Penn;"
than one acre must be permi:led.-te appropriate band must be received
(5D days)
beforethepermit can be issutb.
''
Dn site inspec On by I:,C, Divi85m Forest B.eso'L�rms if pt nit exceeds 4 da)'s
l day
❑
Tlo�it CarolinaEurr,ingperrit
On site i:ape :ion by N,C- Dirisian Forest Rtio:'aces -enui:ed ",i +ttaretitan
] dzy
Sprdal Ground Clearance i3umine e m1t -22
'
? t:,�e acres of ground cle=ri::g activitiss are 3nvo:ve.'., its?ec:gars shn';ld be
❑
CDJntic5 in consent RC, wllh 0, 9FRlG Sci!s
l !requested at least ;en says'aefore zctNa! bun 3s olanne3."
!
9t1-120 days.
©
ail Refuting Facilities
NIA
[NIA)
? 3f permit required, app:ica:iD,t 6Dcays befDre begin cansc,tction. ,4ppl.icant
:-gust airs N-C. quali:itd s^gi'teeY tD: prepare plaits, inspect consU ucdon.
ct-tt, cnastructicn is a-cD-ding to ENR apprc„ed p;ans, hr=_y a1.5o require
permit p:73ef ia:sCC[:o--jj`zj p'"-am..":'�d C 4C'4 pn.-.nit From CDina Of
30 -a}S
l
Dar.) Saiet;' Per; i1
--a'.ne :s. An is r c=io:: D. site is necessa}°toveri:3'Hau Cl- ssr?cation.l
- _ r -
f5 days;

E �: e-auto •drill E(.PiD'mxy nil ar dRS we:]
71
IueopryJcal '.:plarativnPennit
❑ � Slats ,al;as Construction Pernit
[ 14C1 ^later Qua1i'y CeriincatiDn
❑ CAIfAPer,—Jtfer? u=uR3eve'opment
SFECJ4L �PPL?C�TIC' PP.4CEDUR� Drp,EQiJ2 M':-iTS
File surety bond ofiS,ODOwith }1rTit r.1115ing to State Drlgc conditional taat
any well o7mtd by drill operator shall, upDr a'3and011 ent, be plLgged
according oltvRry:esa:idre2LlatiDr.s.
Ap�!ication filed with ENR at ins, 10 dEys prior+tD issue of pu6L
Applicationby!etter, No standard applimtim-Dnn,
Application fees based Dr. structure size is obarged. Must in::iL,de d scriptiaas
& dra�uinQs ofsGpGt re p_oofc o,Nnersh'p ofripariE
T=50.00 f c ml-st aceotnpary Gppii cation
Elg5;1.00 lee must nccompany a�piicatiDn
C."dJ.S Fe: rit fcr ].�JvnR de1'f:opmen[
>e'e-al�eo3eticsronumaa3kareloca:d;norneartijep.-D Ctarea.'_.`Rnyrronane;tnedsto5 rov�dos d p!e_senory,
KC, Geodc:ic 5'arvev, Sox =-6E7 Raleigh; :�C i"-:1
I] ALandonment of any wells, if required must be i7, accDrdance ,'i9l Tif e 15.4 Subchapter 2C.C100.
' NDdficaticn of Cne p_DpAr,_gional ofi',ce is reque_ted if "D-phan"under Dund s:Dzge tams (USTS) Ere d!srnrl!ed during ary e,:cav5tba Dperation.
❑ I CD:rnliance with 15,ANt ° f = �G,)0 (CD?stal swm, water Rules) is required.
Tai Pamlico nrT�e',,e Piparian Duffer RUIeZ requirtts
Qther cnmm e rts ;at ac t additiDnal rages a=- necessary,
Al
TY, F r
LL e
ti
i-y1�f,,u
to cite commant autt70: ity)
l3D-ma! Rmmss Ti_r,e
(S:aCL1t�i]' tll a t]i�li t�
i p days
IA
'_ 0 dzvs
?ti!A
15-2D nays
N;.q
60 dsivs
(130 day.)
55 dfi\'S
i5D d_),sl
2_ d-ys
(Z5 deys)
45 dayF
REGIONAL OFFICES
Qu�stians regarding #r?e,e permits should be add_Gssed to 'I?,Regional O=ce marled'aelaw,
Asl}ile Regional Office ❑ Moores)-illeRegiaaal Office ❑ V+ilrningtanRegional Offtce
L09Om S H;gr Nay 70 610 East Canter AVCrlae, Suite 301 127 Care.inal Drive Exter_sion
Swa:manca, NC 2877 B Moc'res-�'iL'e, IBC 28115 Wilt lington, NC 29405
(828) 2R6-4500 (7Ci4) 663-1699 [phone]
Fayetteville ette;rille Regional O tce ❑ Raleigh Regional Office ❑ Winston-Salem Regional Office
2251, girth Green Street,> Site 714 3 900 B a , uu Drive, Suite 101 c 851Jaught�v�n Street
Raleial�,NC 27609 ���i .ston-Calelll, NC 27107
ayGtteville, NC2R301-5043 �. 335 777-��00D
(910) 43?-33u0
(919) 791-^-.200
❑ Washington RtgloFial Office
43 �7 ashii: c,i .S.ruare Rail
j�'asl"tiii� o , NC 2789

r-,�- IN A I �.
GO
C<
1.4ie`.:as1 F. ?asley, Grvtmcir
ti�illin-� u. R^r5 ]r., ecfz y
id�r_h Carolina Depa: anent of �n ir�nmert and l�atu 4; P esources
Coleen H. 5u!!ins, Di`ee=or
aF'WL'_er tiL:r]itti'
Ncvamber 19, 2008
?l�EI�ZORAI��DU�� ,
TO: \,Telba 1�TcGe al Resources r r�q
Department of Env;; onnaent and Natax `'
S
i Danne Reid, LpervisoT J /
TL�U:
g t and SEPA PrL
Basinwide Plannin Unit am
FROM: Hanr,al� Stallings, SEPA Coordinator
Basics wide' Planning Unit and SEPA Program
SUBJECT: Scoping Document
Graham County
Robbinsville WWTP Expansion
DENR','09-0110, DWQ"14047
The Division of eater Quality (DWQ} has reviewed the subject project and has the fallowing con�rnents
and concerns:
1. Please find attached DWQ's SEPA EA Gaidance and tal docu A G idmc Both oDo neDt that Robb d other
should use in the development cf its enviraruen
gtlida ice can be accessed at htt :l/h2o.enr.state.nc.uslse a r.
2. Please find enclosed DENR's Guiarace jor P `ram thidentaationrof anddnutiigat on foxes -c ndarY
and C>-cr�z.ulccizve IrrLpcccts. This document will
-LI
and Cwnua tie impacts that >ray accompany the proposed WWTP expansion.
3. The EA should include th5 NPDES permit number (NCG025879}.
4. The Division of Water Quality (Division)t out
tiletteanth� applicant will spffculativa need to prepare anuEngineering
'7119I2009. As statUd in the specul
Alteiaatives Analysis (EAA), in accordance with Division guidance, before any approval of the
proposed expansion. The EAA will need to justify the requested expansion flow of 1.0 NiGD, as well
as evaluate alternatives to a direct discharge to surface waters.
5. D-FQ is colscerned that an increased dceedances Thischai7gc al theeief oeed'� ecluz at Robbinscation may cause ville provide
viola+ions, especially chlorophyll a ex
modeling to demonstrate that the phosphorus content of its proposed 950,00Q'�1GD discharge -Iin ]ld
not cause inzpaixnaerit of surface waters. PleasteGerLnontact cmail ll t for athy guidance onrioodel �1�odeling
and TMDL Unit, at [phone] or katll .s
de-,� elopanent.
Please contact one at 507-6434 if I can be of any additional help.
Thant: you.
Cc: Roger Ed v arils — AR
O,e
Locnriia 1�iorthCa olina
Phone i9191 c07-G=,00 c ��LIJi!I�
A4ailing ?,3dress 512
Fix i919; a+ ' 9= 2704
lu] 7 Ner
Nail 5ti'ice Center p_a1ti_'': IBC

North Carolina Wildlife Resolirces C0I-'UnIS Sion
Gordon Myers, Fxecutiv-1 Dsrtaor
9 --
l�F:MORAIL ter;
AUf _ y
TO: Melba McGee, !�iavironmei,-tal Coordinator 2Qa L=a
Office of Legislative and Iutergoveerwuental Affairs c -P,�,
Nortiz Carolina Dep ardent of Enviroz��ent and Natural Resourc jBF;�4
CP
FROM: Dave McHenfY, Habitat Conservation Biologist ti
DATE: November 3, 2008
SUBJECT: Robbinsville W ' Relocation and Upgrade, Graham County
OLU No. 09-0110
Biologists v�,ith the North Carolina Wild lle Resources Commission (Commission) revie-v,Ted the
Envirormental Assessment (EA) for the proposed Robbinsville �d 'fP relocation and upgrade in Graham
County. The -W- TP would no longer discharge to Long Creek, but ft-ther downstream into the Cheoah
River near Santeetlah Lake. Also, capacity would be increased from 630, 000 to 950,000 gallons per day.
Commission comments are provided under provisions of the Fish and Vildiife Coordination Act (48 Stat.
401, as amended, 16 U.S.C. 661 et seq.) a -ad the North Carolina Environrnesatal Policy Act (G.S. 113A-1
et seq., as amended; 1 NCAC-25).
The EA does not include sufficient infoa-1nation to assess tlae probable effects of the project an fish and
wildlife resources. Is order for the Commission to provide a meaningful review, the EA should include the
following information:
l . Include descriptions of fish aad wildlife resources in the project area and a listing of federally or
state designated threatened, endangered or special concern species. When practicable, potential
borrow areas to be -used for project eonsn-nctian should be i;icluded in the inventories. A full
listiDg of designated species can be developed through consultation N�,hh The Natural Heritage
Program and the U.S. Fish and ��ildlife Service.
2. Include descriptions of any Streams or v,,etlands affected by the project.
3. Include project maps identifying wDtland areas. Identification of wetlands may be accomplished
rough coordination with the U.S. Anny Cores of Engineers (COE). I the CO E is no
tt
consulted, then the person delineating wetlands should be identified and the criteria listed.
:I fling Address: Division ofloland Fisheries • I721 Mail Service Ce,�ter . Raleigli, NC 27699-1721
(01 M 7f17_('I(17 R

Robb irs Y :I I e W-W TIP
Pa-ge ?
G=aban,
�+. l�ro� ide a description of project activities that T-�0 occur in V%7etl�ds or streams, such as fill or
cLannel alteration. acre-ffe of -Wed impacted by altez�ative project desiPs a'�ould be listed.
5. Provide, a description and a cover roe map shO inn aoreage R141ure habitat;n�pacted
of upland �,
by the project.
5. Discuss the potential cumulative and secondary Effects oia habitats frons toe �nu-astrLcture
iT!1prOVelriPLt project, as iM1'Sll as auv �'�' dative LTtB�Si'_r tHat Ere needed to ofsCt IoSe effZc15.
(a) Yncl`ade specific -reas�tres that will be used to address stony ;Water rL'.aof . include spe.,TM
requirements for resideiitial, cc,rr�ercial a �d i-rdw�ial deg elapm�Lts and BI�3 lLat will be
required.
(h) Trclade specifc Measures l_a-1 +rill be used to protect straanl corridors, ripr^Sial7 habitat, and a
�imurn of the l OD -year floodplaiu from filling and de�-elopment. Ccmm.itn:ents bV the
project sponsors to protect area stearns with riparian buE-ers -11-Ou-01 Purchase cr
conservation ease -meat are of particular uiterest.
{cj Include specific me; surer that will Delp mitigate the impacts to flsli and-Midlife of the region and
help maiatain rbe functioas of aquatic resources.
7_ Discuss the extent to which the ProjUct will rent i loss, dcgradatian or frabeatation of-wildlife
habitat (,;wetlands and uplands).
8 _ Discuss any mews proposed to avoid or reduT ce i acts of the project or to mitigate
unavoidable habitat losses.
9. Tzolude a list of doa.�r�ent preparers that shows each individual's prafessioaal backgroLnd and
qualifications.
provide comments on this project. If you need to disouss
The Commission appreciates the oppartuaity to �
these comments please call me at (828) 452-�422 e Fez sion 24.

Um'te,d States Depar mtnt- of th-, Intmor
FISH A'\TD W DLIFE SERVICE
Asheville Field Office
160 Llicoa Street
Ashevilie, North Carolina 2ES01
January 15, 2009
Ms. Anna SaLberg
Project Biologist
ClearWater EnVirormental Consultants, L"c.
718 Qaldand Street
Hendersonville, North Carolina 28791
Dear Ms, Salzberg.
Subject: Listed Species Assessnnent, Treatme-nt Plant Site, Graham
County, North Carolina
In your letter of Deceujber 1% 2008 .you requested our. coinnzents on the .subject project; We
have ruviewedtlne information -you presented arnd ;are pray-iding the follo ,,,ing con-3ments i7i
accoidamc -with the provisions of the Fish.and_Wildhfa Coordivation�:Act; as amended
(16 U.S.C. 661-667e),.and section 7 of the Endangered Species Act of 1973, as amended.:
(16 U.S.C. 1531-1543) (Act).
your letter does not include a description of the project or any potential impacts. It is impossible
for us to give a detailed assessment without a complete set of plans that includes the exact
location of the projecf and specific details regardi_n.g project plans and construction techniques.
The purpose of this letter is only to infor n you of federally listed species that occur within the
geographical area indicated on the neap you sent, and we have included a detailed list of
information that -will be required for us to fully assess the potential direct, indirect, and
cun-iulative impacts of any construetionldevclopnierit proj ects in this area.
Ezrda ;eyed Species. Based on the project location a-nd information you presented, there
appears to be suitable habitat for tine federally threatened Virginia spiraea (Spriraea Virgi7zi.aria)
tiA,ithin the proposed project area, our records indicate that this species has been found near the
proposed project site. Your letter did not indicate -\vhether surreys have been conducted for this
or other rare plant species within lie project impact area. -unless. the area has been specifically
5 v�eyed for this .listed species or no appropriate Habitat exists, a Sur-vey.sh uldbe_c
u-o7lduemd-16!
ensirr _tl r1tlus_s cz�c� s<i�ot_i advei ent -lace .. We recoin�zeiid:'�at surveya for tins species be
caza'eted during its floc�v erLig period (kune tlnz-cugh July).: Suz-veys should be..coi ducted along

the elltireroute of the proposed ltility I:at and at the proposed location of the new wastewater
treatment ulant.
In accordance with the Act, before ally federas or rung 1 g can be issued for
this project, it is the responsibility of the appropriate federal regtuatorylpernnitting agency(ies) to
detmniDc whether the project May affect any federally endangered or tlu•eatelned species (listed
species) or designated critical Habitat. If it is determined that this project may affect any listed
species or designated critical habizat, section 7 co-Isultation wth this office must be i litiated,
At t17-is stage of proj ect dc-�,,elopmelnt and without More speclflc5 about coLstruCtioLn locatlolns and
techYniques, it is difficult for us to assess potential envizonmertal impacts (d xect, ndHect, and
cumulative). We therefore reco=end that any cmdronlnelntal dcc=ent pre__,arcd for this
project include the follo-��71ncl (if appl_cable);
1. A complete analysis and comparison of the available alternatives (the build
and no -build alternatives)-
Z. An assessment of any develops -cent that will impact the 100-year fioodplain.
3. A description of the fishery and wildlife resolTrces vVithin exisLiln9 and
required additional rights -of -eras and any areas, such as borrow areas, that
may be affected directly or indirectly by the proposed project.
4. The acreage and a description of the wetlands that will be filled as a result of
the proposed project. Wetlands affected by the proposed project should be
mapped in accordance with the Federal hllanual for Identifying and
DelineaiingJurisdictional 5'etlands. We recommend contacting the
U.S. Army Corps of Engineers (Caips) to determine the need for a
Section404 Clean eater Act peimit. Avoiding and minimizing wetland
i_zn:pacts is a part of the Corps' permitting process,' and wc v,rill consider other
potential alternatives ill the review of any pemits .
5. The extent (lineal- feet as well as discharge) of any grater courses that will be
impacted as a result of the proposed project. A description of any streams
should include the classification (Rosgen 1995, 1996) and a description of the
biotic resources.
6. The acreage of upland habitat, by cover type, that will be eliminated because
of the proposed proj eat.
7. A description of all expected secondary and curuulative cnvirom-lnental
impacts associafed with this proposed work. The assessmennt should specify
the extent aid type of development proposed for the project area once the
work is complete and hmv future growth ,Vdll be maintained and supported
with rebard to sewer lines, water lines, parking areas, and any proposed
ro adv ra}, s .

S. A discussion about the --x-tt It to wEch the projC-ct',7V111 result ill the loss,
degradation; or fiaginertation of 5,�,ildlife habitat :,�7oM direct coilstructiei7
iiiipacts and :'rozii secondary devtloi m-eiit iipacts:
9. I �itigatioil measures that will be employed to a -void, cliiniliate, reduce, or
coiatp5I!Sate for labitat value losses (wetland, riverine, and �ipland} associated
with any phase of the prapesed project.
ii�'e appreciate the epporiuiiity to provide tll,s rx=IeYA.;. If we C= be of assistwnce or if you
ldo not hesitatia_act Mr. L�ryan Tompkins of ouz staff at
have any clue,stions, p = "ea�o �-, to co� skins project, please reference
828/258-3939, Ext. 240. hi any fc.�u-e coiTespcncience cci_cerni_n�
our Log'rIurnber 4-2-09-085.
Brian P. Cole
Field Supervisor

6,0 EXHIBITS / MAPS
The following exhibits and maps are included within this section:
I. Figure 1 --- Proposed Project Area Topographic Map
2. Figure 2 — Proposed Project Preliminary Site Plan
3, Figure 3 — Existing and Future Service Areas
4. Figure 4 — Impacted Wildlife Habitat Map
5. Proposed Alternative — Itemized Cost Estimate
6. Environmental Justice and Civil Rights Impact Analysis Certification
7. Compliance Evaluation Inspection Report
8. FEMA Standard Flood Hazard Determination Form
9, Environmental Assessment, July 2010 — Robbinsville Waste Water Treatment
Plant Relocation
Environmental Assessment 20 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010

-IGURE PROPOSED PROJECT AREA
WASTEkld' TER TREATMENT PLANT RELDWA ON
1940 r -� ,: TOWN OF ROBBINSVILLE
' • ,+Hi$ jaDd`"- ` ' GRAHAM C('i'_ NORTH CAROUNA
�a =RQPOSEC
IVFLU ENT PUPil` 3 r+T C'N AIJ
CORCE ?RAIN iG C
:yam,*' 11 � � • :�� �` �� — 1L -�, � n c = - "','- -
ti
1NlArrP SITE r_• der�a�
PROPOSED y� .�^"
1�
S Yr=R LINEi G ZROPC�SEu
• l__-r LIEN7C11 FOP F S T r f I CNI ,Z.-
�te� - j `• �' _ �iROBBII wo
�•�� n- \- ., ` ,+_ _— } "`,. (Bm.qM. iw ±•. •RAIL tiu 8�w ,2� `
• �' r' �I
Q7 J ,vim '°l
au fi ear Gap . ( _ e�� _
r `i _ ' `j1' 4" l
91i ;•�`` •rye •-`. `` o - •�a.'y� ,—til l �* �„ �--I
' _'• ,�- �i •s> fit`. k_k •`.f, K'
S.
wa i .� N;... �w . - • Y { u ,i I aff f e$
ti8�9$
1127
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,.� _ � ' ,. , ' '`-L'` `1 - --- ; �i �i ,,r �L �•._ �. -. Alt
7, '•'ir� �`•' \\ � y � _ ram_—• ��•�
`• .•. _�F !'13209,
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Hi .T�T�I- F.I,T. . -7 f �• - I _ L�.� I. �`� t-'I +J •I; S-'� \ r

FIGURE 2 PROPOSED 1/%//-`►STEWATER TRErs\-I Mill- j�,l rt
CLAN l Pj7\lFI--l(vJlNARY SITF PLAl`l
WASTE IVATEf ; f FLEA f-MENT PLANT REL OC r,,, l ION
'-OWN f-)F ROBBINSVILLE
GRAHAM GOM',ITY, HORTF-1 CAI-ZUI.lMA
I

TDt'EN OF ROBBffYSVILLE
WAST-r-wA T ER TREATMENT ?LAWT RELOCATION
Preliminary Cost Estimate
Proposed Alternative - Relocate 1 1,7P
DE5CRiPT101J �.C.i3AII;TI7Ty
UNIT -I
UNIT PRICE �.
E�TEfr'SIpW .
?A RT o. Sevept Lines ar•d r''.imp Stztion
1
io
lJY iization
1 j
LS
c16,D00
$1n,000
2
12" DIP Sanitary 5e+ner
1,900
LF
$48
$91,200
3
B" DIP Sanitary Sewer
250
LF
$40
$10,DOD
4' Dia. Sanitary S=_v��er Msn;neles
12
to
$1,80D
$21,1300
4
+vl V+raterright lids
4' Dia. Sanitary Sewer Mlanho!as
2
EA
t2,D00 I
54,OD0
5
+n,; 'd+'eteright Lids and l'e'rts k
Sanitary Seaver Service Taps per detail I
_ EA
55DO
$2,D0C
6
iincluQinp rnax. 20' of 4" olp=1
I
20" DIE. X 0.250" +veil thickness steel
LF
$275
+22,G00
7
:.")casement pipe, bored and jacked, complete
B0
with carrier piue
Submersibie Sewer Pump station complete wv th
8
sits vrark, fencing, pumps, piping, electrical and
i F..A I
$375,DD0
$375,000
€ g
emeraencv oanerator
10' DEP Sewer Force Main
9D0 LF
$35
$31,500
10
CABC shoulders and parking lots
200 11 ONS
$2D
$4,0DD
1lsrashed Stone Undercut par 6" depth
620 LF
$4
$2,4aO
1
increments as directed !DV Enalneer
12
Rack Excavation
250 GY
$50 I
515,000
1 3
Select Backnll
25D CY
$12
$3,D0R
14
Silt Fence installation per details
740 LF
$3
$2,220
SUBTOTAL - PART A
$60D,000
PART 8-'VVastewater_Treatment P.iani.
1
Mobilization
1 I LS
:300,000
$300,000
2
Machanical Bar Soreen and C!nannel
1 LS
$200,OOD I
$2D0,000
2
Wastewater Treatment Basin {Concrete}
1 LS
$700,000
$ IOU, ODD
3
`
Process Treatment Equipment, instalied
1 LS
M0,00O
$500,000
4
Secondary Clarifiers - Basins
1 LS
$400,000
$400,000
5
Secondary Clarifiers - Equipment, instal!=_d
1 LS
$30D,D00
$300,000
5
I
Disk Filters
1 LS
$500,0DD
j $5DO,000
7
UV Disinfection System
1 LS
$300,ODD
$300,DD0
B
Clarifier Splitter Scx
1 LS
$50,000
$50,D00
g
Sludge Purnp Station
1 LS
$250,0D0
$250,D00
r,0
Aerobic Digester
1 LS
$4,00,000
$400,0DO
11
Belt Filter Press System
1 LS
$300,D00
$300,000
12
DperationslS}udge Processing 3uHding
1 LS
$400,00D
$400,000
13
! Sitework, including bypass road
1
LS
$30D,000
$300,D00
14
Yard Piping
1
LS
$200,DDD
$200,00D
15
Eiectrica!
1
LS
$800,000
$800,000
SUBTOTAL - PART B
$5,900,00D
TOTAL CONSTRUCTION COSTS_;
56,50D,000
1 0% Contingency
$650,000
Preliminary Eng'tn=eying
$2L� 5,000
Enuironnental
Assessment
$40,000
DesigniContract Administration
$429,000
Construction
Observation
$250,000
Geotechnical during design
$5,DOG
Material Testing during Constr,
$5,000
Easement Acquisition
530,000
LegaliAdministraticn
M,000
TOTAL PROJECT. COSTS � $7,S64,0G0

Form RD 2006-38
(Rev. Q7-07)
Rural Development
Environmental Justice (£J) and Civil Rights Impact Analysis (CRIA)
Certification
1 . Applicant's name and proposed project description: Tow- of svil1=_ constraution cf a new
wastewater treatment plan-
2. Rurai Development's loanlgrant proaramlguarantee or other Agency action: water and j__,, ironme7tal
Proara�s
3. 0 Attach a map of the proposal's area of effect identifying location or EJ populationsm location of the proposal,
area of impact or
❑ Attach results of EJ analysis from the Environmental Protection Agency's (EPAs) Em iroMapper with
proposed project location and impact footprint delineated. Y
4. Does the applicant's proposal or Agency action directly, indirectly or cumulatively affect the quality and/or level of
services provided to the community?
❑i Yes ❑ NO ❑ N?A
5. Is the applicant's proposal or Agency action likely to result in a change in the current land use patterns (types of land
use, development densities, etc)?
Yes —] No F7 N/A
6. Does a demographic analysis indicate the applicant's proposal or Agency's action may disproportionately affect a
significant minority and/or low-income populations?
El Yes II No N/Lk
If answer is no, skip to item 12. If answer is yes, continue xith items 7 through 12.
7. Identify, describe, and provide location of EJ population
8. If a disproportionate adverse affect is expected to impact an EJ population, identify type/level of public outreach
implemented.
9. Identify disproportionately high and adverse impacts on EJ populations.
10. Are adverse impacts appreciably more severe or greater in magnitude than the adverse impacts expected on non-
minority/low-income populations?
Yes ❑ No ❑ N/A
11. Are alternatives and/or mitigation required to avoid impacts to EJ populations?
Lj Yes ❑'�To ❑N/A
If yes, describe
12. I certify that I have reviewed the appropriate documentation and have detennined that
❑No major EJ or civil rights impact is likely to result if the proposal is implemented.
A major EJ or civil rights impact is likely to result if the proposal is implemented.
Pamela �k n�._�r c c.:� �i..'__� r C3-35-2010
uys g
Tame and Title of Certif}ing Official' Date

L
TE1 �cr; g ��!,15 �., : _� S "W ^ .
ofr I'b1 ,T.il,� �-f�at J.1'1c12011 0
The Owrler hias requested � DA Rural l�.evelcpment loanlgrant f mdil�g t Lo�zgil the iv ater and
Envi_olu.�ental F-1-0gams to constlLrct, in a different location?, a new Nvastewater rreatrne-it plant
O WTI 1) with a capacity of .85 I� CD, -de existing � � rT:l i,avirlg a .63 �'2
capacA, . The existing p1mat located rear the intersection of Cld Hv 129 and i ght Stre( will
be abandoned. The new plant NN611 be cm'str-acted, on property owner_ for by the that is
located or. Sandl,ole toad. The location is adjaeelt to the tatvra's corporate li bits.
Tl e project C�L51St5 pr'1212r1iV Gi Co115t""Lict101 CI Clarifiers, a r necilai' cal Dar screed, anoxtCrtSCi1
ditch, disk filters, U d sinfccticn equ'pmnent, an aerobic digester, a belt filter press system, an
operations building, and a backnp generator. 'n addition, 2,0'M linear feet of 12"' graviy sewer
and a new pump station writh about W0 linear feet of 10'' force train is needed_ to convey flow,
from the existing WWTP to the new WVVTP.
The project is needed because the existing pladit is in an advanced state of deterioration. The
benefit of this project is that the new system will enable the town to continue providing sanitary
sewer services to its residents and other urbanized areas near the towns limits.
Having consulted the EPA EnviroMapper envirom-rental Justice Ceograpllic Assessment tool,
the following has been considered:
01 Per Capita Income: i he existing WWTP and the proposed WWTF are both located in
areas with income between $0415,000. Both sites are adjacent to an area of income
ranging between $15,000-$25,000. Ho-wever, the town's overall MMI. 's $14,608, far
below the $22,500 poverty level. It does not appear that low income areas were targeted
in locating the new W1hlTF.
S Percent Ivlinority: The town of Robbinsville racial make up is show in the chart below.
The area is predominantly white, with the next predornir_arit race being Native Arnerican..
Both the existing and proposed v WTP sites are located on the edge of areas being 0-10%
minority and 10-20% mdriority. Little difference is found in the raciai make up of the
areas around the existing or proposed 1 WTP sites.
Population Density: The existing site is located on the edge of a sv all area with a density
of 0-100 people per block. The new site is located in an area with a density of 100-2000
per block. First, the reason that the population density of the eNisting _WWTP is so low is
that it is located in downtown Robbinsville, near a commercial area with r_linimal
population. The new site is a slig`ltly more populous; llcwever, the site itself is isolE.ted
with few residences nearby.
i'ercerlt elov� roverty: The new �� �re'Tr is located ir. an are€ th t is 4G-100% below
pove� ty, anet adjacent to an area ti�at s 30-10% below poverty. 3ased upon census data,

3'�.5 o of the pC�lllati0ii Oi the T OShnh of t0 ubir jVL�e 1haS ',L?Cal?he below ih-e pO�%er �, level.
,z r ;T M g targeted fcr an area of
does not anDear ghat .the locatici� of tlhe Lew �n'1t _F is belr�
extreme poversiT...tlhe entire t�Vv'Lh, oil al.7 rlids an LrCOrne that IS $a, �i0 bel0ih tlhe
poverty lever.
The location of the news VtT_VT_"P project is Sandhole road. I't was se?ected oecalase it is aL•eady
ClAned by the T o)km, ana because of its p_"CXLTliiY CCU he Che0al2 :V T L1 Eh'� �Cl] i e Heated
wastexxater will be discharged. ne e�'sting discharges into Long reek; a tributary of
Clieoai River. In thhat the relaiac.ement plant be l3aalt on tmvn-onvned a_hcl iih ligglltlV
por,'Ulated area, that because of tern a1h and vegetation «ill be Screeaed ftoin view of Most
ly
SUr"Olii`_ding urppences. and the rnodest size Of L e new1'�T Eli � , t 115 �lrojeCt ap?ec 5 t0 Co T-D,
mI
wLli envi-Tom-neri1-sgE, 1-di
-ace, CGlor, ilat_Ch'_1al origin, Or Li1CCI3ie t�°`tl] rZSl3eCl to _lle C eve 0lirleiht, iTriplell=eihtatzCrzF a,d
c
en-forcernellt of e-.virorn:Erital laws, regulations, unc� Txolicies.
The racial makeup of the T o)vn of Robbinsville is as follcv,-s:
White
Btack
A-M -ricaq ksiaii
Nativa
U'-re
'va :�i-
Hispan c e1-
lndiaii
Hawaiian
Othek
Mare
Latina (of
Pacific!
R'ac
REC35
`?3y r Ece)
lsiander
705
4
33
Q
4
5
5

Knight Street, Robbinsville - Google Maps
Page 1 of I
p , Address Knight St [Get Coogle.Maps on your phone
'0 e
Go SIc-, Robbinsville, NC 28771 Textthe word "GMAPS�"to 4,616453
Wailfahala
Nationsi FDi est
A.
gw
2
OU .122;
a Narvahala
Nd,,ioiial Forest
02010 Google - Map data (02010 Gol&oera

Robbinsville town, forth Carclina - Fact greet - American Fact- inner
r- ;ge i of 2
American FactFinder_
FAc o SKEET
Roboinsviile town, North Caroline
3ensus 2000 Den-,ogrepylC Prcfle Highlights:
General Characteristics - shoe more >>
Total population
Male
Female
Median age (years)
Under 5 years
18 years and over
65 years and over
One race
White
Black or African American
American Indian and Alaska Native
Asian
Native Hawaiian and Other Pacific Islander
Some other race
Two or more races
Hispanic or Latino (of any race)
Household population
Group quarters population
Average household size
Average family size
Total housing units
Occupied housing units
Owner -occupied housing units
Renter -occupied housing units
Vacant housing units
Social Characteristics - show mpora >>
Population 25 years and over
High school graduate or higher
Bachelor's degree or higher
Civilian veterans (civilian population 18 years and
over)
Disability status (population 5 years and over)
Foreign born
hrale, Now married, except separated (population 15
years and over)
Female, Now married, except separated (population
15 years and over)
Speak a language other than English at home
(population 5 years and over)
Economic Characteristics - show more >>
In labor force (population 16 years and over)
Mean travel time to +stork in minutes (workers 16 years
and over)
Median household income in 1999 (dollars)
Median family income in 1999 (dollars)
Per capita income in 1999 (dollars)
Families below poverty level
Individuals below poverty level
Housing Characteristics - show more»
View a Fact Sheet for a race, ethnic, or ancestor group
Number
Percent
'J.5.
747
map
brief
359
48A
49.1 %
map
brief
388
51.9
50.9%
map
brief
36.8
(X)
35.3
map
brief
57
7.6
6.8%
map
562
75.2
74.3%
135
18.1
12.4%
map
brief
742
99.3
97.6%
705
94.4
75.1%
map
brief
0
0.0
12.3%
map
brief
33
4.4
0.9%
map
brief
0
0.0
3.6%
map
brief
0
0.0
0.1 %
map
brief
4
0.5
5.5%
map
5
0.7
2.4%
map
brief
5
0.7
12.5%
map
brief
741
99.2
97.2%
map
brief
6
0.8
2.8%
map
2.14
(X)
2.59
map
brief
2,85
(X)
3.14
map
393
map
346
88.0
91.0%
brief
168
48.6
66.2%
map
178
51.4
333%
map
brief
47
12.0
9.0%
map
Number
Percent
U.S.
466
256
54.9
80.4%
map
brief
23
4.9
24.4%
map
60
10.7
12.7%
map
brief
216
32.3
19.3%
map
brief
3
0A
11.1%
map
brief
133
51.8
56.7%
brief
136
42.5
52.1%
brief
23
3.4
17.9%
map
brief
Number
Percent
U.S.
295
51.4
63.9%
brief
19.5
(X)
25.5
map
brief
14,688
(X)
41,994
map
21,705
(X)
50,046
map
10,275
(X)
21,587
map
50
26.5
9.2%
map
brief
257
34.5
12.4%
map
Alumoer
Percent
'.S.

_0 r ilsV__we
age 2 of 2
Single-fami}y okwner-occulpied homes 56
Median value (collars) 70,600
Median of selecied morthiy owner costs (%',)
With a mortgage (dollars) 650
Not -norigaged (dollars) 228
(X) Not applicable.
Source: U.S. Census Bureau, Summary File 1 (SF 1) and Summary File 3 (SF 3)
brief
(X) 119,600 map brief
(X) brief
(7;) 11088 map
(: } 295
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. Av"A
NCDENR
North Carolina Department of Environment and Nat ral Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
Robert Cagle, Jr, Mayor
Town of Robbinsville
PO Box 129
Robbinsville NC 28771
March 17, 2010
Dee Freeman
Secretary
Subject: NOTICE OF VIOLATION
NOV-201 Q-PC-0264
Compliance Evaluation Inspection
Robbinsville WWTP
Permit No. NCO025879
Graham County
Dear Mayor Cagle:
Enclosed please find a copy of the Inspection Report from the inspection conducted on
February 25, 2010. The Compliance Evaluation Inspection was conducted by Keith Haynes and Don
Price of the Asheville Regional Office. The treatment facility was found to be in violation of Permit
NCO025879 for the following:
Inspection Area
Compliance Issue
Operations &
The operations building in disrepair with leaking roof and
Maintenance
cracks in the cinder block walls.
Influent Sampling
Influent samples are not being collected using a composite
sampler. Manual collection of influent samples is permitted if
the method outlined in the NPDES permit are followed.
Bar Screens
Plastics and condoms are not being caught by the barscreen
and are found floating throughout the plant.
ses--riot-adewatelysl .
Adjustments should be made so that any scum or floating
solids are properly removed.
SURFACE WATER PROTECTION—ASHEVILLE REGIONAL OFFICE One
2090 U.S. Highway 7D, Swannanoa, NC 28778 NarthCarolna
Phone: (82$) 296-45001FAX: $28 299-7G431Custamer Service: 1-877-623-6748 rr�
Intern -al: www ngwalergvaritv.org ��t�lal

Page Two
Inspection Area
Compliance Issue
Aeration Basins
it was observed that all diffusers in the aeration basin were not
operational. Signs indicate possible diffuser failure due to
stoppage and deterioration of the drop pipe to the diffuser.
Pump Station -
There is no telementry nor is there stand-by power to operate
Influent
the influent pumps in the event of a power failure.
Please refer to the enclosed Inspection Report for any additional observation and
comments.
To prevent further action, carefully review these violations and deficiencies and respond in
s+ ting=t-o=this--office=within fifteen-('1-5)-working day of receipt of -this letter.- You should-addres-s-te--
causes of noncompliance and all actions taken to prevent the recurrence of similar situations. If you
should have any questions, please do not hasitate to contact Keith Haynes at 828/296-4500.
Sincerely,
r
Roger C. Edwards, Regional Supervisor
Surface Water Protection
Attachment
cc: ARO
McGill wl attachment
Enforcement w/ attachment
S:ISWP%Graham%Wastewater\Municipal%Robbinsviile VJWTP 258791NOV-2010-PC-0264.doc

United States Environmental Protec$on Agency
Form Approved,
EPA Washington, D.C. 20450
OMB No. 2040-0057
Water Comdiance inspection Report
Approval axpires8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/molday Inspection Type Inspector Fac Type
1 , NJ 2 151 31 N00025879 1 11 121 _0/02/23 117 151 Cl 191 SI 201
I
Remarks
21 i l i1111 11111111111i s
Inspection Work Days Facility Self -Monitoring Evaivation Rating 131 QA------- ---
84
67i j 69 70L IJ 11I 1 72I n;l 73( L 74 75 1 1 1 1 1 Li
---Section B: Facilit}r Data
Name and Location of Facility Inspected (For Industrial Users discharging to P0T1N, also include
Entry TimelDate
Permit Effective Date
POTW name and NP➢ES permit Number)
Rcbbi-:=_ville k'iti"T_
10:30 W. 10/02/25
07%12/G1
Exit Time/Dale
Permit Expiration Date
L S Hwy 125
Robbinsvil_e NC 28771
11:30 AN 10/02/25
Name(s) of Onsite Representative(s)lTitles(s)lPhane and Fax Number(s)
Other Faci€€ty Data
M-1uhael J. Ladd/CRC/n22-479-642B/
Name, Address of Responsible OffrcialfFitielPhone and Fax Number
Contacted
kcbert Cagle,?O Box 126 Robbinsville NC 25771//826-479-3250/826479572
les
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement .Operations & Maintenance M Self -Monitoring Program
Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See aftachment summary)
Name(s) and Signature(s) of Inspectors) AgencylOffice/Phone and Fax Numbers Date
Keith Rayncs ARO wQ//828-i96-4SCO/ &b
AV -
Don Price .(LR } Peirt Source Pranc_�//828-296-45DC/ -' t fa o
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Rover C Edwards -rLC ARO WQ//828-256-4500/ -7
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

NPBES yr,'mo/day Inspection Type
3 i
NC0025879 11 12i 10r32/2517 18 C[
fcor_t.)
Section D: Summary of FindingfCommants (Attach additional sheets of narrative and checklists as necessary)
The facility appeared to be producing a clear effluent at the time of the inspection and operating as well as it
could, considering the condition of the pump station, diffused aeration syatem, and secondary clarifiers. It
was evident that the collection system is still experiencing a large amount of 1&I as the mixed liquor in the
aeration was very low in solids content. Another area of concern is the lack of standby power for the site,
particularly for the influent pump station.The current VWVTP does not allow for "sludge" wasting and solids
management. It appears that the system periodically experiences "flow surges" and spills solids into the
effluent. Due to the flow in the receiving stream, which is very swift, no indications were observed at the
time of the inspection of any solids accumulation in the receiving stream. Reliability of this VWVTP is very
—f= margl`rra�k=rnajdr upset=could=occar-wi&i prolonged -loss -of power he existing Lab and operation—
building is in dire need of a roof as there were extensive signs of "roof leaks" in the building. Future leaks
could compromise records, reports, Lab analysis, lab equipment and data collection.
Page # 2

Permit: W,025879
Inspection Date: 0212512010
Owner -Facility: Robbinsville MTP
Inspection Type: Compliance Evaluation
Operations & MalntenanCe Yes ND NA NE
Is the plant generally clean with acceptable housekeeping? DODO
Does the facility analyze process control parameters, for ex: IVILSS, MCRT, Settleable Solids, pH, DO, Sludge ■ 0 rl ❑
Judge, and other that are applicable?
Comment: Overall site is clean, but WVVTP is above ground and is showing
indications of age and wear. A temporary "portable" hose is
attached to the access ladder and connected to a "portable" stand-by pump. There is no
_ __...___indication this is.a."temporary" correction to_reliability.of.the WWTP operation. ___---
Permit
(€f the present permit expires in 6 months or less). Has the perm ttee submitted a new application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment -
Pump Station - Influent
Is the pump wet well free of bypass lines or structures?
is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Comment; There is no telementry nor is there stand-by power to operate the influent
pumps in the event of a power failure. there are signs in the wet -well section of the
station of accumulations of grease, debris, and grit. There is no indication of a means to
remove the grease, debris, and grit. It can eventually cause problems with the pump
station.
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional? 0 ■ ❑ 0
Is sample collected above side streams? ■ n n ❑
Is proper volume collected? n ■ 0 ❑
Is the tubing clean? ■ n ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ❑ ■ ❑ ❑
Page # 3

Permit: NC0025870
Inspection Date: 02,2512010
Owner - i=acllity: Robbinsville V*VTP
Inspection Type: Comphance Evaluation
Influent Sampling
Is sampling performed according to the permit?
Comment: Influent samples are not being collected using a composite sampler.
Manual collection of influent samples is permitted if the method outlined in the NPDES
permit are followed.
Flow Measurement - Effluent
------
s ow me er use or repo mg? --- Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment:
Type of bar screen
n■nn
- -
■nnn
■nnn
■nnn
a.Manual
■
b.Mechanicai
Are the bars adequately screening debris?
n
■
n
n
Is the screen free of excessive debris?
■
n
n
Is disposal of screening in compliance?
■
n
❑
n
Is the unit in good condition?
■
n
n
n
Comment: Plastics and condoms are not being caught by the barscreen and are
found floating throughout the plant.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
■
❑
❑
n
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
❑
n
n
Are weirs level?
■
n
❑
n
Is the site free of weir blockage?
n
■
❑
n
Is the site free of evidence of short-circuiting?
n
■
n
n
Is scum removal adequate?
n
■
n
n
Is the site free of excessive floating sludge?
■
n
n
n
Is the drive unit operational?
■
❑
n
n
Is the return rate acceptable (low turbulence)?
■
n
n
In
Is the overflow clear of excessive solids/pin floc?
■
n
n
Page ## 4

Perrnit: NCO025579
Inspection Date: 02+2512C10
Owner -Facility. Robbinsville VV)ArFP
Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA HE
Is the sludge blanket ievel acceptable? (Approximately '14 of the sidewall depth) ■ ❑ n I]
Comment: The skimmer arm does not adequately skim the surface, Adjustments
should be made so that any scum or floating solids are properly removed. Debris
consisting of grease,tampons, condoms, and other floating material is accumulating
between the weir and scum baffle creating a "continuous" condition of short circuiting
and weir blockage,
Aeration Basins -__ _- --- - --- _ _- . - - -- ----_- -__= � �-
Yes —Ho
rfa
-NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
[I
D
D
Are surface aerators and mixers operational?
■
❑
❑
❑
Are the diffusers operational?
❑
■
D
n
Is the foam the proper color for the treatment process?
■
0
n
n
Does the foam cover less than 25% of the basin's surface?
■
n
rl
n
is the DO level acceptable?
n
n
n
■
Is the DO level acceptable?(1.0 to 3.0 m9.r4)
❑
n
rl
■
Comment: Signs observed on the Aeration Basin indicated all diffusers were not
operational. Signs indicate possible diffuser failure due to stoppage and deterioration of
the drop pipe to the diffuser.
Disinfection - UV
Yes
No
NA
HE
Are extra UV bulbs available on site?
■
n
n
n
Are UV bulbs clean?
■
0
❑
0
Is UV intensity adequate?
■
Cl
❑
0
Is transmittance at or above designed level?
■
rl
is there a backup system on site?
D
■
D
D
Is effluent clear and free of solids?
■
Q
❑
D
Comment: There is no back-up disinfection
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? _
Are the receiving water free of foam other than trace amounts and other debris? ■ n n 0
If effluent (diffuser pipes are required) are they operating properly? ❑ n ■ ❑
Comment:
Page # 5

Permit NCO025879 Owner -Facility. Rabbinsvilia WVvTP
Inspection Date: 02125!201D Inspection Type: Compliance Evaluation
Effluent Sampling
Yes
No
NA HE
Is composite sampling flow proportional?
n
■
❑ ❑
Is sample collected below all treatment units?
■
n
n ❑
Is proper volume collected?
■
n
Q In
Is the tubing clean?
■
Q
❑ ❑
klsroptmratret Ior esarrpletoragertkept at iessthan-or equal to fi 0 degrees CeEsins) .- -
--
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
n
n n
Comment: There is no indication in logs and on the "controller" for the effluent sampler
that samples are collected flow proportional.
Page # 6

DEPARTMENT OF HOMELAND SECURITY See The Attached O.M_B. No. 1660-0040
FEDERAL EMERGENCY MANAGEMENT AGENCY Instructions Expires December31, 2011
STANDARD FLOOD HAZARD DETERMINATION FORM (SFHDF)
SECTION I - LOAN INFORMATION
1. LENDER NAME AND ADDRESS 2. COLLATERAL (Building/Mobile Home/Personal Property) PROPERTY ADDRESS
(Legal Description may be attached)
3. LENDER ID NO. 4_ LOAN IDENTIFIER 5. AMOUNT OF FLOOD INSURANCE REQUIRED
SECTION 11
A. NATIONAL FLOOD INSURANCE PROGRAM (NFIP) COMMUNITY JURISDICTION
Town of Robbinsville Graham NC 370106
B. NATIONAL FLOOD INSURANCE PROGRAM (NFIP) DATA AFFECTING BUILDINGIMOBILE HOME
1. NFIP Map Number or Community -Panel Number 2. NFIP Map Panel Effective/ 3. LOMAILOMR 4. Flood Zone 5. No NFIP Map
—(Community name if not the same as "AlRevised Date
r" YES
3700566100J 0211 B109 AE
Date
C. FEDERAL FLOOD INSURANCE AVAILABILITY (Check all that apply)
1. ix Federal Flood Insurance is available (Community participates in NFIP). Ix Regular Program r Emergency Program of NFIP
2. 177.Federal Flood Insurance is not available because community is not participating in the NFIP.
Building/Mobile Home is in a Coastal Barrier Resources Area (CBRA) or Otherwise Protected Area (OPA). Federal Flood Insurance may
3. r' not be available.
CBRAIOPA Designation Date:
D. DETERMINATION
IS BUILDINGIMOBILE HOME IN SPECIAL FLOOD HAZARD AREA
YES F- NO
(ZONES CONTAINING THE LETTERS "A" OR "V")?
If yes, flood insurance is required by the Flood Disaster Protection Act of 1973.
If no, flood insurance is not required by the Flood Disaster Protection Act of 1973.
E. COMMENTS (Optional)
Design provisions include raising tops of structure walls above the floodplain elevation to protect the structures from floods.
This determination is based on examining the NFIP map, any Federal Emergency Management Agency revisions to it, and any
other information needed to locate the building/mobile home on the NFIP map.
F. PREPARERS INFORMATION
NAME, ADDRESS, TELEPHONE NUMBER (If other than Lender) DATE OF DETERMINATION
McGill Associates, P.A.
55 Broad Street, Asheville, NC 28801
[phone] May 12, 2010
FEMA Form 89-93 DEC 08 This form may be locally reproduced

STANDARD FLOOD HAZARD DETERMINATION FORM INSTRUCTIONS
PAPERWORK BURDEN DISCLOSURE NOTICE
Public reporting burden for this data collection is estimated to average 20 minutes per response. The burden estimate includes the
time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and
submitting this form. You are not required to respond to this collection of information unless a valid OMB control number is displayed
on this form. Send comments regarding the accuracy of the burden estimate and any suggestions for reducing the burden to:
Information Collections Management, Department of Homeland Security., Federal Emergency Management Agency, 5D0 C Street,
SW, Washington, DC 20472, Paperwork Reduction Project (1660-0040) NOTE: Please do not send your completed form to
the above address.
SECTION 1
1. LENDER NAME. Enter lender name and address.
2. COLLATERAL Buildin !Mobile Home/Personal Prope PROPERTY ADDRESS: Enter property address for the insurable
collateral. In rural areas, a postal address may not be sufficient to locate the property. In these cases, legal property descriptions may
be used and may be attached to the form if space provided is insufficient.
3. LENDER ID NO. The lender funding the loan should identify itself as follows: FDIC -insured lenders should indicate their FDIC
Insurance Certificate Number,; Federally -insured credit unions should indicate their charter/insurance number; Farm Credit institutions
should indicate their UNINUM number. Other lenders who fund loans sold to or securitized by FNMA or FHLMC shouid enter FNMA
or FHLMC selleriserviice number. .
4. LOAN IDENTIFIER: Optional. May be used by lenders to conform with their individual method of identifying loans.
S. AMQUNTOF FLOOD INSURANCE REQUIRED: Optional. The minimum federal requirement for this amount is the lesser of: the
outstanding principal loan balance; the value of the improved property, mobile home and/or personal property used to secure the loan,
or the maximum statutory limit of flood insurance coverage. Lenders may exceed the minimum federal requirements. National Flood
Insurance Program (NFIP) policies do not provide coverage in excess of the value of the buildinglmobiie homelpersonal property.
SECTION 2
A. NATIONAL FLOOD INSURANCE PROGRAM NFIP COMMUNITY JURISDICTION
1. NFIP Community Name. Enter the complete name of the community (as indicated on the NFI P map) in which the building or mobile
home is located. Under the NFIP, a community is the political unit that has authority to adopt and enforce floodplain management
regulations for the areas within its jurisdiction. A community may be any State or area or political subdivision thereof, or any Indian tribe
or authorized tribal organization, or Alaska Native village or authorized native organization. (Examples: Brewer, City of, Washington,
Borough of; Worchester, Township of; Baldwin County; Jefferson Parish) For a building or mobile home that may have been annexed
by one community but is shown on another community's NFIP map, enter the Community Name for the community with land -use
jurisdiction over the building or mobile home.
2. County6esl. Enter the name of the county or counties in which the community is located. For unincorporated areas of a
county, enter "unincorporated areas." For independent cities, enter "independent city."
3. State. Enter the two -digit state abbreviation. (Examples: VA, TX, CA)
4. -NFIPCommunity Number. Enter the 6-digit NFIP community number. This number can be determined by consulting the
NFIP Community Status Book or can be found on the NFIP map; copies of either can be obtained from FEMA's Website
http://msclfema.gov or by calling 1-800-358-9616. If no NFIP Community Number exists for the community, enter "none."
B. NFIP DATA AFFECTING SUILDINGIMOBILE HOME
The information in this section (excluding the LOMAILOMR information) is obtained by reviewing the NFIP map on which the
buildinglmobile home is located. The current NFIP map may be obtained from FEMA by calling 1-800-358-9616. Scanned copies of
the NFIP maps can be viewed on FEMA's website at http://msc.fema.gov. Note that even when an NFIP map panel is not printed, it may
be reflected on a community's NFIP map index with its proper number, date, and flood zone indicated; enter these data accordingly.

1. N,FIP Ma Number or Communi -Panel Number. Enter the 11-digit number shown on the NFIP map that covers the building or
rob:ile home. (Examples: 480214 D022C; 5$103C0075F). Some older maps will have a 94git number (Example: 12345601A). Note
that the first six digits will not match the NFIP Community Number when the sixth digit is a "C" or when one community has annexed land
from another but the NFIP map has not yet been updated to reflect this annexation. When the sixth digit is a "C", the NFIP map is in
countywide format and shows the flood hazards for the geographic areas of the county on one map, including flood hazards for
incorporated communities and for any unincorporated county contained within the county's geographic limits. Such countywide maps
will list an NFIP Map Number. For maps not in such countywide format, the NFIP will list a Community -Panel Number on each panel.
If no NFIP map is in effect for the location of the building or mobile home, enter "none."
2. NFIP Ma P nel EfF ctivelRevise D te. Enter the map effective date or the map revised date shown on the NFIP map. (Example:
6/15/93) This will be the latest of all dates shown on the map.
3. LOMAILOMR. If a Letter of Map Amendment (LOMA) or Letter of Map Revision (LOMR) has been issued by FEMA since the
current Map Panel Effective/Revised Date that revises the flood hazards affecting the building or mobile home, check "yes" and specify
the date of the letter; otherwise, no entry is required. Information on LOMAs
and ue MRsss is available
LOMAs and LOMRs following
soudceo.it.
" The community's official copy of its NFIP map should have a copy
of all • For LOMAs and LOMRs issued on or after October 1, 1904, FEMA publishes a list of these letters twice a year as a compendium in
the Federal Register. This information is also available on FEMA's website at http:llmsc.fema.gov.
" A subscription service providing digitized copies of these 4etters on CD-ROM is also available by calling 1-800-358-9616.
4. Flood Zone. Enter the flood zone(s) covering the building or mobile home. (Examples: A, AE, A4, AR, ARIA, ARIAS, AR/AO, V, VE,
V12, AH, AO, B, C. X, D) if any part of the building or mobile home is within the Special Flood Hazard Area (SFHA), the entire
building or mobile home is considered to be in the SFHA. All flood zones beginning with the letter "A" or W" are considered Special
Flood Hazard Areas (SFHAs). Each flood zone is defined in the legend of the NFIP map on which it appears. If there is no NFIP map
for the subject area, enter "none."
5. No NFIP Mao. if no NFIP map covers the area where the building or mobile home is located, check this box.
C. FEDERAL FLOOD INSURANCE AVAILABILITY. Check all boxes that apply; however, note that boxes 1 (Federal Flood Insurance is
available ...) and 2 (Federal Flood Insurance is not available ...) are mutually exclusive. Federal flood insurance is available to all
residents of a community that participates in the NFIP. Community participation status can be determined by consulting the NFIP
Community Status Book, which is available from FEMA and at http:Nmsc.fema.gov. The NFIP Community Status Book will indicate
whether or not the community is participating in the NFIP and whether participation is in the Emergency or Regular Program. If the
community participates in the NFIP, check either Regular Program or Emergency Program. To obtain Federal flood insurance, a copy
of this completed form may be provided to an insurance agent.
Federal flood insurance is prohibited in designated Coastal Barrier Resources Areas (CBRA) and Otherwise Protected Areas (OPAs)
for e of the CBRA or OPA
Coastal buildings
Bar Barrier Resources System may be obtainefd on FEMA's webst[mproved after the dtetat http://www.fema..gov� fipc Information about the
obra shtm
D. DETERMINATION. if any portion of the building/mobile home is in an identified Special Flood Hazard Area (SFHA), check yes (flood
insurance is required). If no portion of the building/mobile home is in an identified SFHA, check no. if no NFIP map exists for the
community, check no. If no NFILP map exists, Section B5 should also be checked.
E. COMMENTS. Optional.
F. PREPARER'S INFORMATION, if other than the lender, enter the name, address, and telephone number of the company or
organization performing the flood hazard determination. An individual's name may be included, but is not required.
Date of Determination. Enter date on which flood hazard determination was completed.
MULTIPLE BUILDINGS: If the loan collateral includes more than one building, a schedule for the additional buiidingslmobile homes
indicating the determination for each may be attached. Otherwise, a separate form must be completed for each building or mobile home.
Any attachments should be noted in the comment section. A separate flood insurance policy is required for each building or mobile home.
GUARANTEES REGARDING INFORMATION: Determinations on this form made by persons other than the lender are acceptable only
to the extent that the accuracy of the information is guaranteed.
FORM AVAILABILITY: Copies of this form are available from the FEMA fax -on -demand line by calling (202) 648-FEMA and requesting
form #23103. Guidance on using the form 'Ina printed, computerized, or electronic format is contained inform #23110, This information
is also available on FEMA's website http:llwww.fema.govinflplsfhdform.shtm.
PURPOSE OF FORM: In accordance with P.L. 103-325, Sec. 1365, (b) (1), this form has been designated to facilitate compliance
with the flood insurance purchase requirements of the National Flood Insurance Reform Act of 1994.

ENVIRONMENTAL ASSESSMENT
Robbinsville Waste Water Treatment Plant Relocation
Graham County, North Carolina
mraham
�.
V1
Applicant: Graham County
12 North Main Street
Robbinsville, North Carolina 28771.
Applicant Contact: Bobby Smith, Vice Mayor, Town of Robbinsville
Lead Agency: Department of Environment and Natural Resources
Division of Water Quality
Post Office Box 29535
Raleigh, North Carolina 27699-1633
Contact Person:
Prepared by:
Hannah Stallings
Division of Water Quality
919-807-6300
[e-mail]
Environmental Consultant:
Mr. R. Clement Riddle
ClearWater Environmental Consultants, Inc.
718 Oakland Street
Hendersonville, NC 28791
[e-mail]
July 2010
Project Engineer:
J. Meleski, P.E.
McGill Associates
55 Broad Street
Asheville, NC 28801
[e-mail]

Table of Contents
1.0
Introduction ............................................................................................................. 1
1.1
Project Location .......................................... .......................................................
1
1.2
Description of Project .........................................................................................
1
2,0
Project Purpose and Need .......................................................................................
2
2.1
Existing Facilities... .......... I ..................................................................................
2
2.2
Need for Sewer Service ......................................................................... ............ 3
2.2.1
Future Service Population ............................................................................ 1.13
2.2.2
Future Wastewater Flows ................................................................................ 5
3.0
Alternatives Analysis ............. ................................................................................
6
3.1
Alternative I No Action........ ........................................................................... 6
3.2
Alternative 2 - Optimum Operation of Existing Facilities .................................
7
3.3
Alternative 3 - Proposed WWTP with Land Application/Reuse ........................ 7
3.4
Alternative 4 - Regional System/Connection to Existing Treatment Facility ....
8
3.5
Alternative 5 - Proposed WWTP with Conjunctive Reuse .................................
8
3.6
Alternative 6 - Project as Proposed (Preferred Alternative) ..............................
8
4.0
Description of Existing Envirom-nent ........ 1.11 ................................. .................
10
4.1
Topography/Physiography ................................................................................
10
4.2
Soils ...................................................................................................... ............
10
4.3
Land Use ...........................................................................................................
10
4.4
Wetlands ...........................................................................................................
11
4.5
Prime or Unique Agricultural Lands ................................... .............................
11
4.6
Public Lands and Scenic, Recreational, and State Natural Areas .....................
11
4.7
Areas of Archeological or Historical value ......................................................
12
4.8
Air Quality ........................................................................................................
12
4.9
Noise Level .......................................................................................................
13
4.10
Water Resources (Surface Waters and Groundwater) ......................................
13
4.11
Forest Resources ...............................................................................................
14
4.12
Shellfish or Fish and Aquatic Habitats .............................................................
15
4.13
Wildlife, Natural Vegetation, and Protected Species ........................................
15
5.0
Predicted Environmental Effects of the Project ....................................................
17
5.1
Topography/Physiography ................................................................................
17
5.2
Soils ...................................................................................................................
17
5.3
Land Use ...........................................................................................................
17
5.4
Wetlands ...........................................................................................................
18
5.5
Prime or Unique Agricultural Lands .................................................................
18
5.6
Public Lands and Scenic, Recreational, and State Natural Areas .....................
18
5.7
Areas of Archeological or Historical Value ......................................................
19
5.8
Air Quality ........................................................................................................
19
5.9
Noise Level .......................................................................................................
19
5.10
Water Resources ...............................................................................................
20
5.11
Forest Resources ...............................................................................................
21
5.12
Shellfish or Fish and Aquatic Habitats .............................................................
21
5.13
Wildlife, Natural Vegetation, and Protected Species ........................................
22
5.14
Introduction of Toxic Substances .....................................................................
23
6.0
Mitigative Measures .................................. ...........................................................
24
11

6.1
TopographyiPhysiology....................................................................................24
6.2
Soils...................................................................................................................24
6.3
Wetlands...........................................................................................................
24
6.4
Air Quality........................................................................................................
24
6.5
Noise.................................................................................................................
25
6.6
Water Resources...............................................................................................
25
6.7
Forest Resources...............................................................................................
26
6.8
Shellfish or Fish and Aquatic Habitats.............................................................
26
6.10
Introduction of Topic Substances.....................................................................
27
7.0
References and List of Preparers..........................................................................
28
7.1
References.........................................................................................................28
72
Preparers...........................................................................................................
28
8.0
List of State and Federal Pen -nits Required..........................................................
29

List of Figures
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Figure 8
List of Attachments
Vicinity Map
USGS Topographic Map
Site Plans
FEMA Flood Insurance Rate Maps
USDA Soils Maps
Aerial Photograph
Stream and Wetland Delineation Map
Future Service Area
Attachment A Engineering Alternatives Analysis dated July 2010
Attachment B SHPO Correspondence dated November 14, 2008
Attachment C TRC Archaeological Survey Report dated February 2009
Attachment D FWS Correspondence dated January 15, 2009
Attachment E Virginia Spiraea Species Survey Report, July 20, 2010
IV

1.0 Introduction
The Town of Robbinsville is a small community located in central Graham County, in the
southwestern portion of North Carolina. The existing Robbinsville Wastewater
Treatment Plant (WWTP) is located adjacent to US 129 on the north side of town, near
the confluence of the Cheoah River and Long Creek. The WWTP was originally
constructed in 1964 with a capacity of 130,000 gallons per day (GPD). There were major
upgrades installed at the plant in 1986, when the capacity was increased to 630,000 GPD.
Robbinsville currently operates their wastewater treatment plant under National Pollutant
Discharge Elimination System (NPDES) Permit No. NC0025879. The plant receives
wastewater flow from residential, conunercial, and industrial customers in Robbinsville
and currently treats, on average, approximately 395,000 GPD.
Since the plant was last upgraded in 1986, treatment equipment is nearing the end of its
useful life. There is a limited solids -handling capacity at the existing plant. Sludge must
be stored for a period of time and then pumped and hauled to another facility for
processing. Upgrades to the existing facility to accommodate treatment improvements
and future growth are restricted by the current site. The WWTP is located on a small
parcel which is surrounded on the south and east by existing buildings, on the north by
'US 129, and on the west by Knight Street. There is no room to improve or expand the
WWTP at its current location. For this reason, the Town of Robbinsville needs to
relocate the existing treatment plant to a new, larger location.
1.1 Project Location
The proposed Robbinsville WWTP is located immediately north of Robbinsville
along the Cheoah River, between river mile 17 and 18, in Graham County, North
Carolina. The proposed sewer line extension will provide a connection between
the existing WWTP and the proposed relocated WWTP. The sewer line extension
will parallel US Highway 129 and Sandhole Road. The majority of the proposed
sewer line extension is located within the road right of way along US Highway
129 and Sandhole Road. A site vicinity map (Figure 1) and US Geological
Survey (USGS) topographic map (Figure 2) are included for review.
1.2 Description of Project
The new )A7WTP is proposed to be constructed on a 12-acre parcel of land owned
by the Town and situated north of Robbinsville and the existing plant near the
Cheoah River. The new outfall will be downstream of the existing outfall and on
the Cheoah River instead of Long Creek (a tributary to the Cheoah River). The
existing WWTP would remain in service while the proposed replacement plant is
being installed. Upon start up, testing, and approval of the new plant's
components, the existing plant will be demolished and the existing outfall to Long
Creek will be abandoned. A new sewer main connection line, the majority of
which will be located with road rights -of -way, will be constructed to connect the
existing plant to the proposed plant.
1

The Robbinsville area has experienced moderate growth in recent years and there
has been interest by western Graham County communities, including the Town of
Santeetlah and other surrounding areas, to connect to Robbinsville's sanitary
sewer system. Robbinsville will need to expand its wastewater treatment capacity
to a total of 850,000 GPD during the 20 year planning period to account for future
growth and to provide service to the surrounding communities of Graham County.
Additionally, the proposed treatment facility is to include a dual train package
treatment plant employing conventional suspended -growth, activated sludge
processes. In addition, it will be necessary to construct a pump station at the
effluent of the existing Vi1WTP in order to convey flow to the new WWTP.
The Engineering Alternatives Analysis (Attachment A) and site plans (Figure 3)
are included for review.
2.0 Project Purpose and Need
2.1 Existing Facilities
The Town of Robbinsville is located in central Graham County, North Carolina
and has a population of approximately 740 residents according to the July 2008
Municipal Estimates calculated by the North Carolina State Office of Budget and
?Management. The sanitary sewer collection system is owned and operated by the
Town of Robbinsville and treats wastewater from Robbinsville and outlying
areas.
Wastewater is treated at the Robbinsville WWTP, which currently has a capacity
of 630,000 GPD. The existing facility consists of an influent pumping station,
grit removal, a comminutor, a circular extended aeration tank with center clarifier,
sludge holding, UV disinfection, and gravity effluent to Long Creek. Current
average daily wastewater flow to the treatment facility is approximately 395,000
GPD.
The existing Robbinsville WWTP accepts sanitary flow from approximately 450
residential properties and 157 commercial properties in the Robbinsville area.
There is also a large industry, Stanley Furniture, and several smaller industries
which are connected to Robbinsville's sanitary sewer system. Based on 2008 US
Census data, the average household population density for Graham County is
2.142 persons per household. Therefore, the current residential service population
consists of approximately 964 persons in an approximately 430-acre area centered
on the Town of Robbinsville.
2

2.2 Need for Sewer Service
2.2.1 Future Service Population
Graham County has become a popular tourist destination with attractions such as
the Great Smoky Mountains, the Joyce Kilmer Memorial forest, Fontana Lake,
Lake Santeetlah, the Appalachian Trail, the Cherohala Skyway, the Tail of the
Dragon, and the Stecoah Valley Cultural Arts Center. The North Carolina
Department of Transportation (NCDOT) currently has plans to construct a new
four lane highway (Corridor K Bypass) which is proposed to connect NC
Highway 28 with US Highway 129. The proposed Corridor K Bypass will
generally follow NC Highway 143 and connect to US Highway 129 south of the
Robbinsville town limits. NCDOT has indicated that the proposed Corridor K
Bypass is scheduled to begin construction in 2016. It is anticipated that the
proposed Corridor K Bypass will increase travel and tourism in the Town of
Robbinsville area and spur commercial growth and wastewater service demand
along the proposed route.
Graham County has been experiencing moderate growth over the past several
years. According to the North Carolina Office of State Budget and Management
(OSBM) website, Graham County's population grew from 7,993 in April 2000 to
8,087 in July 2008. This data represents an annual growth rate of approximately
0.15%. It is anticipated that the growth rate will gradually increase as a result of
the proposed Corridor K Bypass and several other projects and developments
planned for the area. Graham County is currently planning projects for the area
which include a new 30,000 square -foot Justice Center and County Service
Building, a Downtown Agricultural Center and a Call and Data Center.
Additionally, private development to accommodate tourism, such as 24-room
motel, has been initiated in the area.
The existing Robbinsville WWTP serves 450 residential customers and 157
businesses within the Town and immediate surrounding area. According to the
OSBM website, the average household size in the service area is 2.142 persons
per household. The resulting existing service area population is 964 persons.
Assuming an annual growth rate of 0.15%, the estimated population within the
existing service area will increase to approximately 1,004 persons in the 20-year
planning period.
It is anticipated that the Town of Robbinsville will expand its service area to the
southern Tulula Creek drainage basin along US Highway 129 and to the eastern
Sweetwater Creek drainage basin along NC Highway 143, which comprise the
major developed corridors of the area and present the greatest potential for
growth. These service areas include the communities of Bear Creek, Cheoah and
Tulula; these communities consist primarily of residences with some small
businesses which developed along the highways. Based on a residence count
within the future expanded service area, approximately 1,493 existing homes, or
J

3,198 persons could potentially be served by the proposed WWTP. Assuming
that the expanded service area grows at 0.15% annually, it is estimated that the
population within the service area will increase to approximately 3,298 persons in
the 20-year planning period.
The future western Graham County service area is generally located along US
Highway 129 and NC Highway 143 west of the Town of Robbinsville. The
westernGraham County service area includes the Town of Lake Santeetlah, as
well as the unincorporated communities of Santeetlah Shores, Buffalo Creek,
Ground Squirrel Branch, Cross Creek, and Snowbird. The western Graham
County service area consists primarily of permanent and seasonal residential
homes mainly clustered in the Town of Lake Santeetlah and in the communities
around the lake. Based on an existing residence count within the western service
area, approximately 1,026 homes, or 2,198 persons may be served by the
proposed WWTP. The OSBM website indicates that the Town of Lake
Santeetlah grew at a rate of 0.75% annually between 2000 and 2008; however, for
the purposes of this report it is assumed that the western Graham County service
area will grow at a rate of 0.15% annually. Assuming that the service area grows
at 0.15% annually, it is estimated that the population within the service area will
increase to approximately 2,278 persons in the 20-year planning period.
The total projected future population to be served by the proposed WWTP during
the 20-year planning period is 6,580 persons. The projected senlice area will
accommodate anticipated growth along the existing major developed corridors
and Santeetlah Lake areas. Extending sewer service to these areas is feasible
since most existing housing and future anticipated development is located near
local drainage features. Table 1 below summarizes expected population growth
within the future Robbinsville WWTP service area. Figure 8, located in
Appendix A, illustrates the future service area for the proposed relocated WWTP.
Table 1: Robbinsville WWTP Service Population Projection
Year
Service Area
2010
2020
2030
Existing Robbinsville
964
984
1004
Expanded Robbinsville
3198
3248
3298
Western Graham County
2198
2238
2278
Total Po ulation
6,360
6,470
6,580
Percent Increase
2%
2%
4

2 2.2 Future Wastewater Floes
The future wastewater demands are estimated based on the current flows and
projected population growth within the existing Robbinsville service area as well
as the expanded Robbinsville and western Graham County service areas. Table 2
below shows estimated flow increases for the 20-year planning period. The future
population in 2030 to be served by the Robbinsville W`WTP is approximately
6,580 persons. Residential wastewater flows from this increase are estimated at 70
gpd per capita. In accordance with North Carolina Department of Environment
and Natural Resources Division of Water Quality (NCDENR DWQ) Construction
Grants & Loans guidelines, commercial wastewater flows from this increase are
estimated at 15 gpd per capita. According to the flow projections, a capacity of
approximately 850,000 gpd is necessary at the proposed Robbinsville WWTP.
Table 2: Estimated Future Wastewater Flows
Approxinnate Flow - 2010
Projected Floe - 2030
Type of flow
(GPD)
(GPP)
Residential
44,276
47,076
Corrunercial/Institutional
31,536
32,136
Industrial
38,430
38,430
Robbinsville Expanded Service Area
- - - - -
280,330
Western Graham County Service Area
- - - - -
193,630
Industrial Reserve
- - - - -
11,424
Infiltration/Inflow
240,480
240,480
Total Flow
354,722
843,506
Flow Calculation Dotes:
Current and future flows are based on the guidelines published the NCDENR DWQ
Construction Grants and Loans Section for engineering and planning documents.
1. Current Residential = 49,196 gpd x 0.90 = 44,276 gpd
2. Future Residential = 44,276 gpd + ((1,004 - 964 persons) x 70 gpd/capita)=47,076gpd
3. Current Commercial/Institutional = 35,040 gpd x 090 = 31,536 gpd
4. Future Commercial/Institutional = 31,536 gpd + ((40 x 15 gpd/capita) = 32,136 gpd
5. Current Industrial = 42,700 gpd x 0.90 - 38,430 gpd
6. Robbinsville Expanded Service Area = 3,298 persons x 85 gpd/capita = 280,330 gpd
7. Western Graharn County Service Area = 2,278 persons x 85 gpd/capita = 193,630 gpd
8. Industrial Reserve = 10% current = (44,276 + 31,536 + 38,430)gpd x 0.10=11,424gpd
9. Infiltration/inflow based on non -excessive I/1 (3,000 gpd-inch-mile)
= 3,000 gpd x 80.16 inch -miles of sewer pipe = 240,480 gpd

3.0 Alternatives Analysis
This section describes the alternatives to the proposed project that would enable
Robbinsville to fulfill the defined purpose and need. The NPDES permit for the existing
Robbinsville \VWTP allows 630,000 GPD of treated effluent to be discharged to Long
Creek with secondary treatment limits. Since the proposed plant outfall is closer to Lake
Santeetlah than the outfall pennitted with the existing plant. the discharge limits must
meet tertiary criteria according to the DWQ. Table 3 below provides a summary- of
preliminary design criteria for the proposed Robbinsville WWTP at its capacity of
850,000 GPD. A flow diagram schematic and preliminary site plan for the proposed
facility is also provided at the end of this section. Robbinsville currently pumps sludge
from their sludge holding tank on a regular basis. The Town of Robbinsville would like
to have the ability to condition and dewater sludge at the new facility. Two different
methods of completing this expansion were reviewed as described below.
3.1 Alternative 1 — No Action
This alternative consists of no action being taken to relocate the existing, outdated
Robbinsville WWTP to a new, larger site. Many treatment components of the
existing facility are nearing the end of their useful lives. Lack of space for
expansion becomes an issue which will lead to increased replacement costs or the
inability to replace treatment equipment it fails. Also, as was shown in the flow
projections, the existing treatment plant will approach its capacity in the coining
years. By 2020, the wastewater flow is expected to exceed the plant's capacity.
At this flow rate the Town of Robbinsville will need to limit connections to its
system and would probably not be able to allow the sanitary flow from the
western Graham County service area to be sent the Robbinsville WWTP.
Existing properties in the areas immediately surrounding Robbinsville and in the
western Graham County service area have on -site septic systems. Without the
ability to connect to public sewer systems, and as these septic systems fail, area
surface waters would experience negative impacts from untreated or improperly
treated wastewater. Failing septic systems present health issues for residents
exposed to contaminated surface waters. Also groundwater contamination could
become an issue, especially with older shallow private wells.
Because the current system is aging and there is a need to decommission
inadequate and failing septic systems, this alternative is not feasible for this
proj ect.
6

3.2 Alternative 2 - Optimum Operation of Existing Facilities
An alternative to increasing discharged flow at the proposed W_WTP location is to
rehabilitate the existing WWTP and replace portions of the existing collection
system to decrease the amount of I,/I into the collection system. Although some
reduction in Ill is possible through collection system rehabilitation and/or
replacement projects, the capital costs required to reduce l,rl volumes to
accommodate future flows is currently unknown. Furthennore, since the existing
NVWTP is not equipped with dual train treatment processes, the rehabilitation of
the existing WWTP components while keeping the treatment processes
operational would not be possible without extensive pump and haul activities
during construction. There is not sufficient space available at the current site to
accommodate redundant treatment facilities and/or sludge storage and treatment
facilities. The pump and haul scenario would require a sufficient number of
tanker trucks to haul approximately 395,000 gallons per day with additional
tanker trucks on hand to accommodate peak flows during wet weather. The
tanker trucks would have to haul the wastewater to three separate NV\VTP's within
a one -hour radius since no single neighboring WWTP has sufficient capacity to
accept the all of the Robbins-61le WWTP flows. Additionally, user charge fees
for disposal would apply, which would greatly increase construction cost. The
total cost, logistics, and risks involved with pumping and hauling wastewater
from the existing `VWTP during construction activities makes this Alternative
infeasible.
3.3 Alternative 3 - Proposed WWTP with Land Application/Reuse
The planned total flow of 850,000 GPD at the proposed new treatment plant
results in an increase of 220,000 GPD beyond the current plant capacity and
discharge permit. A typical acceptable land application rate for soils in this
region is 1 inch per week, which equates to 0.089 GPD per square foot. At
220,000 GPD, the area required with offsets would be 2,247,200 square feet, or
approximately 64 acres. Based on a review of current property listings of 50
acres or greater in Graham County near Robbinsville, the market price for land
appears to be approximately $30,000 per acre. Therefore, the cost of the 64 acres
would be estimated at approximately $1,920,000, assuming that a suitable site for
land application could be located and purchased.
In addition to the cost of the property, there would be significant capital costs
associated with providing for wet/freezing weather storage facilities (typically 30
days minimum), a 5-day holding pond for insufficiently treated effluent,
installation of a pumping and transmission system to convey the effluent to the
site, and installation of an irrigation system. All of the above costs would be in
addition to the required 850,000 GPD wastewater treatment facility. It should be
noted that the actual volume of wet/freezing weather storage required would be
based on a water balance evaluation, and may be greater than the assumption of
30 days of storage. The preliminary estimated cost is $17,371,000.
7

Because of the additional holding capacity and infrastructure required and cost of
additional lands, land application is not a feasible alternative for this project.
3.4 Alternative 4 - Regional SystenrlConnection to Existing Treatment
Facility
There are no other public- or privately -owned wastewater treatment facilities
within a 5-mile radius of the Town of Robbinsville; therefore, interconnection is
not a feasible alternative for this project.
3.5 Alternative 5 - Proposed W'L'4'TP with Conjunctive Reuse
Relocation of the existing facility to a new WWTP site with conjunctive reuse
would include a land application reuse system and all of the other facilities
described above in the land application alternative, with the exception of the
vet/freezing weather storage facilities, and the 5-day holding pond. The storage
and 5-day holding pond would not be required because if the facility were to be
permitted with conjunctive reuse, the treated effluent could be discharged to the
Cheoah River during periods when the irrigation system could not be utilized due
to weather or insufficiently treated effluent. The preliminary estimated cost for
this option is $11,660,000.
Because of the additional infrastructure required, cost and difficulty in procuring
additional lands, and increased potential to impact enviromnental resources, this
Alternative will not be further considered.
3.6 Alternative 6 — Project as Proposed (Preferred Alternative)
This option includes the construction of a new WWTP on a 12-acre parcel north
of the existing WNVTP near the Cheoah River. The capacity of the new plant
would be increased to 850,000 gpd from the existing wastewater treatment
facility's capacity of 630,000 gpd. under this alternative the plant will discharge
treated effluent to the Cheoah River, a Class C;Tr water in the Little Tennessee
River Basin, which will require a new NPDES permit. It should be noted that the
existing WWTP outfall to Long Creek and its associated NPDES permit will be
eliminated after completion of this project.
The NPDES permit for the existing Robbinsville WWTP allows 630,000 gpd of
treated effluent to be discharged to Long Creek with secondary treatment limits.
Since the proposed plant outfall is closer to Lake Santeetlah than the outfall
perinitted with the existing plant, the discharge limits must meet tertiary criteria
according to NCDENR DWQ. Table 3 below provides a summary of the
preliminary design criteria for the proposed Robbinsville WWTP at its capacity of
850,000 gpd. Figure 3 illustrates the general project area and the preliminary
proposed WWTP site layout. Robbinsville currently pumps sludge from their
8

sludge holding tank on a regular basis. The Town would like to have the ability
to condition and dewater sludge at the new facility.
This Alternative consists of installing concrete package type treatment plant units.
The treatment facility is proposed to include a mechanical bar screen, oxidation
ditch, secondary clarifiers, tertiary disk filter, ultra violet treatment tank, aerobic
digester, belt press filter system, operations building, and effluent line to the
Cheoah River. In addition, it will be necessary to construct approximately 2,000
linear feet of gravity sewer, an influent pump station and approximately 1,000
linear feet of force plain to convey wastewater from the existing WWTP to the
proposed relocated WWTP. The preliminary estimated cost for this option is
S7,964,000.
Table 3 - Proposed Robbinsville NN'WTP Preliminary Design Parameters
Status_ E = Existing, P= Proposed
It is recommended that the Town of Robbinsville pursue construction of Alternative
Number 6. This Alternative is the most cost effective solution to ensure adequate
wastewater treatment capacity within the future service area. This Alternative has a
lower potential to impact environmental resources within the area, will be the most cost
effective feasible Alternative to operate and maintain, and presents the least problems
associated with land acquisition, design and construction.
9

4.0 Description of Existing Environment
4.1 TopographylPbysiography
The project site is located in south-central Graham County. This area is within
the Mountain physiographic region of North Carolina and more specifically the
Southern Metasedimentary Mountains ecoregion. This ecoregion contains steep,
dissected, and biologically diverse mountains that are densely forested. The
WWTP outfall and a portion of the property purchase for the proposed WWTP
site is located within the 100-year floodplain of the Cheoah River; the majority of
the sewer line extension is immediately adjacent to the 100-year floodplain. As a
result of this location, very little relief is present on site; a constant elevation of
approximately 1,960 feet above mean sea level (MSL) is maintained throughout
the project area. A USGS topographic map (Figure 2) and flood insurance rate
snaps (Figure 4) are included for review.
4.2 Soils
According the Natural Resources Conservation Service Web Soil Surrey, soils
along the sewer system route consist primarily of Junaluska-Brasstown (JbE)
complex (30 to 50 percent slopes), Reddies (RdA) fine sandy loam (0 to 3 percent
slopes), Udorthents-Urban land (UdA and UoA) complex (2 to15 percent slopes),
and Udorthents-Urban land complex (0 to 5 percent slopes), and Braddock clay
loam. (BkC2). Reddies fine sandy loam is classified as moderately well drained,
moderately rapidly penmeable soils found on flood plains of the Blue Ridge. The
Junaluska and Brasstown series consists of moderately deep, well drained,
moderately permeable soils on ridges and side slopes of the Southern Appalachian
Mountains. The Udorthents series consists of well drained soils on flood plains.
Soils present within the project area are not listed in the 2008 National Hydric
Soils List. A soils map and legend have been included for review (Figure 5).
4.3 Land Use
The proposed Robbinsville WWTP is located in primarily undeveloped
agricultural land areas. The proposed connector line is located within the rights -
of way for US Highway 129 and Sandhole Road. The rights -of -way are adjacent
to residential housing and industrial property. An aerial photograph of the project
area is included for review (Figure 6).
The proposed WWTP service areas have been predominately rural residential and
agricultural; however, as development continues, the service area is becoming
urbanized.
10

4.4 Wetlands
Potential wetland areas within the WWTP and connector line corridor were
evaluated for the presence or absence of three wetland criteria outlined in the
Corps of Engineers NVedands Delineation Manual (1987 Manual). All of
following criteria must be met for a subject area to be considered a jurisdictional
wetland: presence of hydric soil and hydrophytic vegetation; and evidence of
wetland hydrology and connectivity. Indicators of hydrology include, but are not
limited to, saturation in the upper 12 inches of the soil profile, drift lines, water
marks, and sediment deposits. Findings of a hydrological connection can be
supported through the existence of soils defined as hydric. In general, hydric soils
have a chroma 1 or less, with or without oxidized root channels; or chroma 2 or
less with oxidized root channels in the upper 12 inches of the "A" horizon.
Vegetation holding a "FAC", "FAC=''; "FACW", or "OBL" designation are
considered to be hydrophytic. Plant communities in subject areas must include
hydrophytic vegetation at a proportion of at least 50 percent to meet the
bydrophytic vegetation criteria,
Waters of the US in the forin of wetlands are not present within the Robbinsville
WWTP project area. A stream and wetland delineation map is included for
review (Figure 7).
4.5 Prime or Unique Agricultural Lands
Prime farmland, as defined by the US Department of Agriculture, is land that has
the best combination of physical and chemical characteristics for producing food,
feed, forage, fiber, and oilseed crops and is available for these uses. Areas
including Reddies fine sandy loam soils are classified as "prime farmland".
Reddies fine sandy loam is found along approximately 500 linear feet of the
corridor and within the proposed 12-acre WWTP project area. The Natural
Resource Conservation Service has determined that there are approximately 1,024
acres of prime agricultural fannland in Graham County; the proposed project will
have an affect on approximately 2 acres of land defined as "prime farmland".
4.6 Public Lands and Scenic, Recreational, and State Natural Areas
There is no formally designated park lands, scenic, recreational, or state natural
areas within the proposed Robbinsville WWTP project area. Two-thirds of
Graham County is the Nantahala National Forest. It is the home of Joyce Kilmer
Memorial Forest, Slickrock Creek Wilderness Area, Snowbird Backeountry Area,
Nantahala National Forest, and borders the Great Smoky Mountains National
Park. Lake Santeetlah's shoreline is more than 75% National Forest. Fontana
Lake has approximately 25 miles of waters and the entire north shore is in the
Great Smoky Mountain National Park and much of the southern shoreline is in
National Forest.
II

4.7 Areas of Archeological or Historical value
The State Historic Preservation Office (SHPO) was contacted regarding the
potential for historical or cultural resources. By letter dated November 14. 2008,
(Attachment B) the SHPO stated that the project as proposed will not affect any
historic structures. However, the SHPO also stated that based on the topographic
and hydrological situation, and the density of recorded sites in the area, there is a
high probability for the presence of prehistoric or historic archaeological sites.
The SHPO recommended that a comprehensive survey be conducted by an
experienced archaeologist to identify and evaluate the significance of
archaeological remains that may be dainaged or destroyed by the proposed
project.
On December 8 and 9, 2008, TRC Environmental Corporation (TRC) completed
an archaeological survey of the proposed Robbinsville WWTP site. The survey
identified one small, multicomponent prehistoric and historic site in the
southeastern corner of the project area, west of an unnamed stream and north of
the Cheoah River. Due to the extremely low density of artifacts, the absence of
temporally diagnostic artifacts from intact stratigraphic contexts, and the presence
of obviously disturbed soils, the site appears to have no research potential and is
recommended ineligible for the National Register of Historic Places. Based on
the result of the investigation, TRC recommends that no additional cultural
resource or archaeological investigations be required at the site. TRC's final
Archaeological Survey report dated February 2009 is included for review
(Attaclunent C).
4.8 Air Quality
The federal Clean Air Act of 1970, as amended in 1977 and 1990, provides for
primary and a secondary ambient air standards. The Environmental Protection
Agency (EPA) has established National Ambient Air Quality Standards
(NAAQS) for six criteria pollutants: carbon monoxide (CO), sulfur dioxide (SOA
nitrogen dioxide (NOA particulate matter (PM-10 and PM-2.5), lead (Pb), and
ozone (03). North Carolina has also incorporated the NAAQS with the addition
of one criteria pollutant: total suspended particulates. North Carolina expanded
its air quality monitoring network by adding 36 sites for measuring fine
particulates (dust) under a new health -based standard that the EPA adopted in
1997. The EPA (EPA Greenbook, 2008) classifies Graham County, located in
western North Carolina, as an air quality attainment area. The existing WWTP
has not received significant odor complaints despite its downtown location.
12

49 Noise Level
Aural impacts near the project area are primarily associated with road travel. The
proposed sewer line corridor is located primarily along US Highway 129 directly
outside the town limits of Robbinsville. US Highway 129 is the main route
through Robbinsville and runs north -south following the Cheoah River and Lake
Santeetlah. As such, this road is heavily traveled, mainly during rush hours; it is
expected that noise levels increase during this time. The 12-acre site proposed for
the new WVtiITP is located in an agricultural/industrial area with minimal noise.
The minor portion of the corridor located along Sandhole Road receives limited
volumes of traffic and is considered a rural area with little noise pollution.
4.10 Water Resources (Surface Waters and Groundwater)
The Robbinsville WWTP and sewer line corridor is located within the Little
Tennessee River Basin and more specifically, the Little Tennessee River Subbasin
04-04-04,
Subbasin 04-04-04 includes the Cheoah River and all of its tributaries and has a
total land area of 221 square miles. Much of this subbasin lies within the
Nantahala National Forest and is minimally impacted. According to the
Basinwide Water Quality Plan published by the NC Division of Water Quality
Basinwide Planning Program dated March of 2007, the estimated percent of land
cover is 94% forest, 2.1 % surface water, 0.5% urban land, 0.2% cultivated crops,
and 3.2% pasture or managed herbaceous lands.
The Basinwide Water Quality Plan also includes "Use Support Ratings" for
aquatic life and recreation. The portion of the Cheoah River within the project
area is rated as "Supporting" for aquatic life and recreational uses.
The reach of the Cheoah River where the sewer line corridor and WWTP will be
located is classified as a C, WS-III water, Trout, CA. Class WS-III waters are
those waters protected as water supplies for drinking, culinary, or food -processing
purposes, which are generally in low to moderately developed watersheds or
protected areas and meet average watershed development density levels specified
by the DWQ.
A Critical Area (CA) designation is applied to areas adjacent to a water supply
intake or reservoir where risk associated with pollution is greater than from the
remaining portions of the watershed. The DWQ describes high and low density
options for development within these areas.
A Trout Waters (Tr) designation is a supplemental classification intended to
protect freshwaters for natural trout propagation and survival of stocked trout.
This designation affects wastewater discharges and limits development
13

restrictions within a 25-foot undisturbed stream buffer zone. This buffer is a
requirement of NC Division of Land Resources (DLR).
The Little Tennessee Basin is one of six basins in North Carolina that drain the
western slope of the Eastern Continental Divide and flow into the Tennessee
River System. Based on the North Carolina Water Supply Plan published by the
Division of Water Resources in January 2001, the Little Tennessee River Basin
has about 1 % of the state's residents and contains all or part of 8 municipalities in
6 counties. Robbinsville is the only urban area in the subbasin. The USGS 1995
summary of water use estimated total water use in the basin at 84.5 MGD, almost
exclusively coming from surface water sources. The USGS estimated total basin
population at 73,520. Residential water demand was estimated at 3.7 MGD with
about one -thirds of this demand being supplied by public water systems. Overall,
public water systems supplied 2 MGD from surface water and 0.7 MGD from
ground water for both residential and non-residential uses. The remaining
residential water demand was met by 2.3 MGD of self -supplied ground water. In
addition, about 2.7 MGD of self -supplied water was withdrawn for non-
residential water uses.
According to the Basinwide Water Quality Plan, there are no NPDES individual
stormwater permits within the Little Tennessee River Subbasin. There are three
permitted NPDES discharges within the subbasin. The existing Robbinsville
WWTP, a minor municipal discharger, releases 0.63 MGD into Long Creek, a
tributary of the Cheoah River. The town's water treatment plant discharges 0.1
MGD to Rock Creek, a headwater tributary to Long Creek. Wide Creek Trout
Sales has an unlimited discharge to Snowbird Creek, a tributary to Lake
Santeetlah. At the time of the report, none of the facilities were required to
monitor whole effluent toxicity.
Clearwater Environmental Consultants, Inc. (CEC) has accessed NPDES spatial
data from the NC OneMap and cross referenced this data with data from the
Basinwide Water Quality Plan. CEC has verified that the three NPDES
wastewater discharges mentioned above are the only discharges within Little
Tennessee River Subbasin.
4.11 Forest Resources
The proposed sewer line extension is located primarily within road rights -of -way.
As such, only a small portion of forested land is within the sewer line extension
corridor; however, forested land is prevalent adjacent to the corridor. A narrow
riparian buffer is present at the location of the Long Creek crossing.
Approximately 6 acres of the 12-acre proposed WWTP site is forested.
14

4.12 Shellfish or Fish and Aquatic Habitats
Aquatic habitats are present within the Cheoah River and Long Creek, Because
Long Creek floes through a residential and agricultural area with a very narrow
riparian buffer, it is somewhat degraded. Aquatic species have been observed
utilizing these waterbodies.
4.13 W ldlife, Natural Vegetation, and Protected Species
The predominant land use within the Robbins-61le WWTP project area is
agricultural, residential, and light industrial. There is little forested habitat or
fallow field habitat that would provide continuous wildlife habitat. Some natural
vegetation is present along rights -of -way edges and within the proposed WWTP
property. Utilization of the area by wildlife is likely; however, wildlife
utilization, with the exception of a few songbird species. was not observed. The
proposed project area could not be considered unique or significant in its
contribution to wildlife habitat.
Protected Species
CEC has conducted a file review of records maintained by the US Fish and
Wildlife Service (FWS) and North Carolina Natural Heritage Program (NHP).
The desktop literature survey involved a review of FWS list of protected species
in Graham County and the Robbinsville USGS topographic quad on which NHP
identifies current and historic occurrences of listed species for that locale. Nine
element occurrences (EOs) have been reported in the Robbinsville Quad. The
NHP database identifies 5 EOs within a 2-mile radius of the project site. All
identified species are listed in Table 4 below.
15

Table 4 -- Threatened and Endangered Species
State Federal , EO
Maior Groff Scientific Name Common Name Status Status Location
Invertebrate Alasmidonta LEIktoe
alachian �� gath
Animal raveneliana
Invertebrate Paravitrea Ramp Cove F
5upercoil
Animal lacteodens
5C None 2 mite
Nonvascular Megaceros A Hornwort SY R L� None Both
Plant aenigmaticus
Piantular Euphorbia purpurea Glade Spurge 5R-T FSC — QI uad !
�� —
Vascular Rhododendron Cumberland SR P None Both
Plant cumberlandense Azalea
Vertebrate Clinostomus sp. 1 Smoky Dace ��SC FSC Quad
Animal
Vertebrate Cryptobranchus HeIIbender SC FSC Quad
Animal alleganiensis
Vertebrate Junaluska ���
Animal Eurycea Junaluska Salamander T FSC Quad
Lon tail
An meal ate Eurycea longicauda Salamander SC None 2-mile
Vertebrate [Halia
eetusAnimal ephalus 13a1d Eagle J None Quad
Vertebrate I Eastern Small 5C FSC Quad
Animal Myotis leibii footed Myotis
Definition of Federal and State Status Codes:
E = endangered.
FSC = federal species of concern.
SC = special concern.
SR = significantly rare.
T = threatened.
T(S/A) = threatened due to similarity of appearance.
By letter dated January 15, 2009 (Attachment D), the FWS has indicated that
suitable habitat for the federally threatened Virginia spiraea (Spir-aea virginiana)
may be present within the project boundary. The FWS recommends conducting a
survey during the flowering period of late May through late July to ensure the
species is not inadvertently lost.
A protected species survey was conducted by CEC on July 19, 2010, which is within
the optimum time period for readily identifying Virginia spiraea. Virginia spiraea
was Trot observed within the proposed WWTP site area, proposed sewer line
corridor or the proposed outfall location along the Cheoah River. Additionally,
the proposed project area does not appear to contain suitable habitat to propagate
Virginia spiraea. The completed CEC Virginia spiraea species survey report may
be found in Attachment E of this report.
16

5.0 Predicted Environmental Effects of the Project
5.1 Topograph},/Physiography
Construction of the proposed WWTP and connector line will result in direct
changes in topography in the immediate vicinity of the connector line; however,
impacts will be short -teen and minor because the line will be installed entirely
underground and the ground contours will be restored to pre-existing conditions.
During construction, some topographic impacts may occur as a result of
temporarily displaced soil. Any displaced soil will be used as backfill once the
line has been installed. The `VWTP outfall and a portion of the WWTP will be
located within the 100-year floodplain of the Cheoah River. Installation of the
WWTP and connector line is not expected to have significant direct impacts on
the topography and physiography of the area.
Installation of the N'v-WTP and connector line is not expected to have significant
indirect or cumulative impacts on the topography and physiography of the area.
5.2 Soils
Construction of the proposed W'WTP and connector line will result in direct
impacts to soil in the immediate vicinity of the water line. Soil disturbance will
occur along the entire length of the connector line corridor. A trench will be dug
and soil will be side cast and stockpiled for use as backfill after the line is
installed. Direct impacts to the soil as a result of the project include churning and
aeration as a result of digging; and compaction as a result of activities associated
with backfill of the trench. Contaminants will not be introduced to the soil during
the construction process. Installation of the WWTP and connector line is not
expected to have significant direct impacts on the soils of the area.
Installation of the WWTP and connector line is not expected to have significant
indirect or cumulative impacts on the soils in the area.
5.3 Land Use
Construction of the WWTP and connector line will have no effects on land use of
the project area. The entire connector line corridor is within road rights -of -way.
Roadways in the vicinity of the connector line corridor will not be affected. The
WWTP will be constructed on a vacant parcel of land. Land use on this parcel
and surrounding parcels will not be affected by the project. Installation of the
NVWTP and connector line is not expected to have significant indirect or
cumulative impacts on the land use in the area.
17

Cumulative and secondary impacts associated with the project include the
potential construction of sewer lines within the Town of Robbinsville and western
Graham Countv service areas. Due to the topography of the area, sewer lines will
likely follow major roads and natural drainage features to serve existing
businesses and residences in areas with a high potential for septic system failure.
Sewer line extensions are not expected to spur high density development due to
topographic site constraints. Based on a review of service area topography and
land use, it is expected that the proposed project will not significantly alter current
land use.
5.4 Wetlands
There are no wetlands located within the project boundary. Construction of the
WWTP and connector line will not result in direct impacts to wetlands within the
project boundary. Cumulative and secondary impacts associated with the project
include the potential construction of sewer lines within the Town of Robbinsville
and western Graham County service areas. Sewer line extensions are not
expected to spur high density development or otherwise impact wetland areas.
5.5 Prime or Unique Agricultural Lands
Construction of the proposed WWTP and connector line will result in direct
impacts to soil and prime or unique agricultural lands in project area.
Approxiinately 2 acres of land within the project area has a farmland
classification; however, the disturbance will be short-term and minor. Two acres
accounts for approximately 0.2% of the prime or unique agricultural land for
Graham County. All disturbed area within the connector line corridor will be
returned to pre -impact conditions.
Installation of the WWTP and connector line is not expected to have significant
direct impacts on prime or unique agricultural lands in the area.
Future growth in the project vicinity may change the land use from agricultural to
urban. However, this is unlikely to have a significant affect because nearly all of
the agricultural fields are located within the 100-year floodplain and it is likely
unsuitable to develop.
Installation of the WWTP and connector line is not expected to have significant
indirect or cumulative impacts on the prime or unique agricultural lands in the
area.
5.6 Public Lands and Scenic, Recreational, and State Natural Areas
The proposed WWTP and connector line will not affect any formally designated
public lands; or scenic, recreational, or state natural areas. Construction of the
proposed project will not affect any informal scenic or recreational site functions.
18

5.7 Areas of Archeological or Historical Value
On December 8 and 9, 2008, TRC completed an archaeological survey of the
proposed Robbinsville AA1WTP site. The survey identified one small.
multicomponent prehistoric and historic site in the southeastern corner of the
project area, west of an unnamed stream. and north of the Cheoah River. Due to
the extremely low density of artifacts, the absence of temporally diagnostic
artifacts from intact stratigraphic contexts, and the presence of obviously
disturbed soils. the site appears to have no research potential and is recommended
ineligible for the National Register of Historic Places. Based on the result of the
investigation, TRC recommends that no additional cultural resource or
archaeological investigations be required at the site. TRC's final Archaeological
Survey report dated February 2009 is included for review (Attachment C).
installation of the WWTP and connector line is not expected to have significant
direct, indirect, or cumulative impacts on areas of archaeological or historical
value in the area.
5.8 Air Quality
Construction of the proposed WWTP and connector line will result in direct
impacts on air quality in the immediate vicinity of the project area. Construction
of the WWTP and connector line will be associated with short-term localized air
quality impacts such as increases in suspended particulate matter due to dust
emissions from the construction site and exhaust emissions from diesel and/or
gasoline powered equipment. Installation of the WWTP and connector line is not
expected to have significant direct impacts on air quality in the area.
Urban growthh induced by this project and others in the vicinity may affect long
term air quality in Grahain County; however, the NC Division of Air Quality
continues to monitor air quality in western North Carolina and is likely to set
further guidelines to meet federal and state air quality standards, if necessary.
Installation of the WWTP and connector line is not expected to have significant
indirect or cumulative impacts on air quality in the area.
5.9 Noise Level
Construction of the proposed N"VTP and connector line will result in direct
impacts to noise levels in the immediate vicinity of the water line. Construction
of the proposed WWTP and connector line will be associated with a short-term
noise impact caused by operation of construction equipment. Construction will be
limited to daylight hours and in accordance with any local noise ordinances. Once
19

construction of the water line is completed, no long-term noise impacts are
expected from the operation of the water line. Installation of the WWTP and
connector line is not expected to have significant direct iinpacts on noise levels in
the area. Y
Urban growth resulting from this project or others may affect long-tem noise
levels due to traffic and construction in rural areas. Careful planning and zoning
decisions may be helpful in protecting residents from future excessive noise. In
the future, mitigation measures such as noise barriers adjacent to highways may
be helpful in protecting residential areas from excessive noise.
Installation of the WWTP and connector line is not expected to have significant
indirect or cumulative impacts on noise levels in the area.
5.10 Water Resources
Construction of the proposed WWTP and connector line will result in direct
impacts to surface water in the immediate vicinity of the plant outfall along the
Cheoah River. Impacts include a temporary increase in turbidity during
construction. Upon completion of construction, the construction area will be
stabilized and turbidity is expected to quickly return to baseline conditions. The
Long Creek crossing will be directionally drilled; therefore, no impacts to the
Long Creek will occur. No other significant adverse impacts to surface waters are
anticipated from the project construction.
Installation of the WWTP and connector line is not expected to have significant
indirect or cumulative impacts on surface waters in the area.
The project will reduce risks to groundwater resources by providing infrastructure
to eliminate existing septic systems and discourage proliferation of new septic
systems. Water quality in the vicinity of these failing septic systems is expected
to improve. However, induced urban growth may create new sources of potential
groundwater containination.
Installation of the WWTP and connector line is not expected to have significant
direct, indirect, or cumulative impacts on ground water in the area.
The Cheoah River is the source of drinking water for the area. The potential for
increase development resulting from this project may increase stone water runoff
in the vicinity of the project. The use of appropriate storm water control measures
will minimize the potential affects of storm water run off in the Cheoah River
project area. Most of the Cheoah River watershed lies within the Nantahala
Forest and is protected from urban development. No long term adverse affect to
potable water is likely as a result from this project.
20

5.11 Forest Resources
Construction of the proposed WWTP and connector line will result in direct
minor impacts to forest resources in the inunediate vicinity of the WWTP.
Impacts associated with the connector line will be minor because there is little to
no forest area within the road rights -of -way. Some tree removal (approximately 1
acre) may be necessary for construction at the N V4'TP site. Installation of the
WWTP and connector line is not expected to have significant direct impacts on
forest resources in the area.
Indirect and cumulative impacts to forest land associated with induced growth is
likely to occur within the small service area. However, the project area is
surrounded by extensive National Forest lands and forestry will likely continue to
be a major land use category in the vicinity of the project area.
Installation of the WWTP and connector line is not expected to have significant
indirect or cumulative impacts on forest resources in the area.
5.12 Shellfish or Fish and Aquatic Habitats
Construction of the proposed WWTP and connector line will result in direct
minor impacts to aquatic habitats in the immediate vicinity of the outfall on the
Cheoah River. Construction of the proposed outfall within the Cheoah River may
result in a short term impact to the fishery resources of the Cheoah River and
habitats for other aquatic species in the immediate downstream area. These
impacts may include increased turbidity in the water due to the resuspension of
stream sediments during installation of the intake and temporary loss of fish.
habitat in the construction area.
Every reasonable effort will be made to minimize these impacts using appropriate
mitigation measures.
As soon as in -stream or on -bank construction is complete, turbidity levels are
expected to return quickly to baseline conditions. Fish species in the area are
expected to return immediately. No long term significant impacts to fishery
resources or habitats in the Cheoah River, its tributaries, or any other surface
waters in the project vicinity are expected as a result from this project.
Installation of the WWTP and connector line is not expected to have significant
indirect or cumulative impacts on aquatic habitats in the Cheoah River.
The Long Creek crossing will be directionally drilled; therefore, installation of the
connector line is not expected to have significant direct, indirect, or cumulative
impacts on aquatic habitats in Long Creek.
21

5.13 Wildlife, Natural Vegetation, and Protected Species
The majority of the construction activities associated with proposed WWTP and
connector line will occur in existing road nights -of -way or fallow fields. There is
very little forest habitat that will be disturbed. The wildlife species and habitats
associated with the connector line corridor will be temporarily disturbed or
displaced. Because the areas that will be disturbed provide relatively common
habitat, this short tern impact is not considered to be significant.
Once the connector line is installed, the impacted areas will be returned to
preexisting conditions and planted with herbaceous species that will provide
similar habitat to preexisting conditions. This corridor may be used by a variety
of species to forage, migrate, or inhabit.
Fragmentation and degradation of terrestrial habitats may occur due to induced
development in the project area. However, much of the immediate service area is
Nantahala National Forest and provides vast acreage of protected wildlife habitat.
Induced development from this project is unlikely to have an adverse impact on
wildlife species. Efforts will be made to avoid the rights -of -way during the
months of April through September to minimize destruction of nests and young
animals.
Installation of the WWTP and connector line is not expected to have significant
direct, indirect, or cumulative impacts on wildlife and natural vegetation within
the project area.
Protected Species
By letter dated January 15, 2009 (Attachment D), the FWS has indicated that
suitable habitat for the federally threatened Virginia spiraea (Spiraea virginiana)
may be present within the project boundary. The FWS recommends conducting a
survey during the flowering period of late May through late July to ensure the
species is not inadvertently lost.
A protected species survey was conducted by CEC on July 19, 2010, which is within
the optimum tune period for readily identifying Virginia spiraea. Virginia spiraea
was not observed within the proposed WWTP site area, proposed sewer line
corridor or the proposed outfall location along the Chcoah River. Additionally,
the proposed project area does not appear to contain suitable habitat to propagate
Virginia spiraea. The completed CEC Virginia spiraea species survey report may
be found in Attaclunent E of this report.
22

5.14 introduction of Toxic Substances
Construction of the proposed WWTP and connector line will not result in the
introduction of toxic substances within the project boundary. Potential
introduction of toxic substances during construction may include exhaust
emissions, oil, fuel, and other vehicle fluids. Escape of these substances will be
prevented by proper vehicle maintenance and collection and disposal of fluid
containers. Contractors will be instructed to take precautions to ensure that no
uncured concrete is allowed to contact surface waters. Following construction,
the project is not expected to release hazardous substances.
Following construction, the project is not expected to release hazardous
substances, but will reduce or eliminate leakage or overflow of untreated waste
water.
Toxic substance introduction to streams via stonn water may increase as the
service area becomes more urbanized. Vehicle fluids, heavy metals, fertilizers,
pesticides, detergents, paint, solvents, pavement, and construction materials may
contribute to stone water toxicity. Strategies that promote stone water dispersal
and soil infiltration rather than channeling to streams will help reduce storm water
pollution resulting from new development.
23

6.0 'mitigative Measures
6.1 Topography/Physiology
hmpacts to the topography of the project area will be lessened through the use of
ive measures, specifically rectification. Construction of the
appropriate mitigat
WWTP and connector will result in temporary changes in the local topography.
Upon completion of the installation of the line, ground contours will be returned
to pre -impact conditions rectifying any temporary impacts to topography.
Additionally, an erosion and sediment control plan utilizing BMPs will be
implemented at the site further reducing impact to topography at the site.
By letter dated December 3, 2008, the North Carolina Division of Emergency
Management indicates that the project includes areas within a flood hazard area
and requires either a no -rise certification or the approval of a Conditional Letter
of Map Revision. All certification or approval in association with floodplain
development will be sought for this project.
6.2 Soils
impacts to the soil in the project area will be lessened through the use of
appropriate mitigative measures, specifically minimization and rectification. Soil
disturbance will occur along the entire length of the connector line corridor.
However, the minimum amount of soil necessary to install the line will be
excavated. Soil will be returned to the trench after excavation. Surface waters
and wetlands will be protected from sidecast soil by an erosion and sediment
control plan utilizing BMPs. Utilization of BMPs will prevent the fouling of
surface water by soil.
6.3 Wetlands
Impacts to wetlands will require authorization from the US Army Corps of
Engineers (Corps) and/or the DWQ. Through this permit process, the Town of
Robbinsville will be required to avoid, minimize, and mitigation for wetland
impacts associated with the project. Additionally, the permitting process will
ensure limited impact to wetlands if the service area is expanded.
6.4 Air Quality
hnpacts to air quality will be lessened through the use of appropriate mitigative
measures, specifically avoidance and minimization. All construction equipn-ient
on site will be in good, working order and free of mechanical problems involving
exhaust and emissions; this will minimize impacts on air quality. Equipment will
be inspected to ensure emissions standards are met or exceeded. Techniques
employed to suppress and avoid dust production may include wetting down
24

access roads, temporary installation of stone to cover dust, or installation of
mulch.
6.5 Noise
Impacts to noise levels will be lessened through use of appropriate mitigative
measures, specifically minimization. In order to minimize noise related
disturbances to the local community, construction activities will be limited to
nonnal daytime hours (7 a.m. to 7 p.m., Monday through Saturday) wherever
possible. In addition, large construction equipment will be equipped with proper
noise attenuation devices such as mufflers and silencers to minimize construction
related ambient noise level increases.
6.6 Water Resources
Impacts to water resources will be lessened through use of appropriate mitigative
measures, specifically avoidance and minimization. The proposed WWTP and
connector line corridor was selected to avoid and minimize stream and wetland
crossings where possible. Surface water crossings have been avoided through the
use of directional drilling on the Long Creek. Use of the crossing method has
completely avoided impacts associated with the Long Creek crossing.
Additionally, contractors will be required to observe proper vehicle maintenance
and collect and dispose of waste material (such as oil, transmission fluid, etc.)
appropriately to prevent harmful substances from entering surface waters. An
erosion and sediment control plan utilizing BMPs will be implemented at the site
further reducing impact to water resources at the site.
The Town of Robbinsville's existing raw water intake is located upstream of the
existing and proposed WWTP outfalls; the proposed project will have no impact
on the Town's current water supply source. While there is potential for a future
water intake source located at Lake Santeetlah, the WWTP outfall on the Cheoah
River should not be adversely impact lake water quality. The proposed WWTP
will have superior effluent quality as compared to the existing WWTP. Tertiary
treatment and nutrient removal efforts will be integrated into design of the
proposed WWTP to limit levels of nitrogen, phosphorus, bio-cheinical oxygen
demand, and total suspended solids and maintain compliance with the new
National Pollutant Discharge Elimination System permit issued by the North
Carolina Division of Water Quality.
Impacts to surface waters will require authorization from the Corps and/or the
DWQ. Through this permit process, the Town of Robbinsville will be required to
avoid, minimize, and mitigate for surface water impacts associated with the
project.
25

6.7 Forest Resources
Impacts to forest resources will be lessened through use of appropriate mitigative
measures, specifically avoidance, minimization, and reduction. Forested areas are
restricted to the WWTP parcel. During construction, riparian vegetation will be
preserved as much as possible and trees that must be removed outside of the
immediate construction boundary will be cut near ground level, leaving the stump
and roots in place to provide for ground stability and possible regrowth. An
erosion and sediment control plan utilizing BMPs will also be implemented at the
site further reducing impact to forest resources at the site.
The Cheoah River holds a WS-111 water classification. This classification
requires that a 30-foot vegetated buffer for low -density projects and 100-foot
vegetated buffer for high -density project be maintained on project sites.
6.8 Shellfish or Fish and Aquatic Habitats
Impacts to aquatic habitats will be lessened through use of appropriate mitigative
measures, specifically avoidance and minimization. Aquatic habitats may be
temporarily affected during construction. As soon as in -stream or on -bank
construction is complete, the area will be stabilized. Turbidity levels are expected
to return quickly to baseline conditions. Fish species in the area are expected to
return immediately after turbid waters are gone from the area. Additionally, an
erosion and sediment control plan utilizing BMPs will be implemented at the site
further reducing impact to aquatic habitats at the site. Additionally, tertiary
treatment of wastewater will mitigate impacts to the Cheoah River aquatic habitat.
6.9 Wildlife, Natural Vegetation, and Protected Species
Impacts to wildlife and native vegetation will be lessened through use of
appropriate mitigative measures, specifically avoidance and minimization.
Construction of the proposed WWTP and connector line corridor will include the
removal of natural vegetation and cause some wildlife to temporarily move out of
the area. Impacts to wildlife and natural vegetation will be minor. During
construction, removal of riparian vegetation will be avoided and preserved as
much as possible and trees that must be removed outside of the immediate
construction area will be cut near ground level, leaving the stump and roots in
place to provide for ground stability and possible re -growth. Upon completion of
construction, the connector line corridor will be returned to pre -impact conditions
which will include seeding along road nights -of -way. It is expected that wildlife
and wildlife utilization will quickly return to pre -impact levels once construction
is complete and large construction equipment leaves the site.
WE

6.10 Introduction of Toxic Substances
Introduction of toxic substance will be lessened through the use of appropriate
mitigative measures, specifically avoidance and minimization. Contractors will
be instructed to take precautions to ensure that no uncured concrete is allowed to
contact surface waters. Following construction, the project is not expected to
release hazardous substances.
27

7.0 References and List of Preparers
7.1 References
Engineering Alternatives Analysis. Proposed Wastewater Treatment Plant
Relocation. Town of Robbinsville. Graham County, North Carolina. Joseph J.
Meliski, PE, McGill Associates. July 2010.
Little Tennessee River Basinwide Management Plan, 2007. North Carolina
Division of Water Quality.
Department of the Ant-ty. Corps of Engineers Wetland Delineation Manual. U.S.
An- y Corps of Engineers, Washington D.C. 1987,
NC Administrative Code 2H.0219 Minimum sewer design code.
FWS, October 2008, computerized literature search for species likely to occur
within the project area.
FWS. January 15, 2009, letter documenting species likely to occur within the
project area.
NC Natural Heritage Program, October 2008, computerized literature search for
species likely to occur within the project area.
NC Natural Heritage Program, December 31, 2008, letter documenting species
likely to occur within the project area.
Natural Resources Conservation Service, October 2008, computerized literature
search for soil types and descriptions likely to occur within the project area.
7.2 Preparers
R. Clement Riddle, F.W.S.
C1earWater Enviroiunental Consultants, Inc.
Bachelor of Science in Natural Resources, 1991
Master of Planning, 1998
Professional Wetland Scientist, 2009
J. Meliski, P.E.
McGill and Associates
Professional Engineer
28

8.0 List of State and Federal Permits Required
SEPA Review process and Finding of No Significant Impact
DWQ
Sewer Line Non -Discharge Extension Pennit
DWQ
Soil and Erosion Control Permit
DLR
Road Crossings Approval
DOT
Wetlands/Waters of the U.S. Crossing Permit
DWQ, Corps
Floodplain Development Pen -nit
DWQ
NPDES pen -nit
DWQ
Stonnwater Management Plan
DWQ
29

FIGURES

Robbinsviiie WWTP
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Existing VVWTP t1,7 rVy
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ClearWater F nvironmental Consultants, Inc.
Graham County, Site Vicinity Map
North Carolina Hendersonville,
Oakland Street Figure 1
Hendersonville, North Carolina 28791
QI)Q_FOQ-osnn

F URE 2 - PROPOSED PROXT AREA
1 ASTEVYA T ER TREATMiENT PLANT RELOCATION
TOXIN OF ROBBiNS11ILLE
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GWWAM COI INTY, CAROLINA

NOTE: THE ILLUSTRATED WETLAND AND STREAM LOCATIONS ARE APPROXIMATE. THESE AREAS HAVE NOT
BEEN FLAGGED IN THE FIELD. ALTHOUGH CLEARWATER ENVIRONMENTAL CONSULTANTS, INC_ IS CONFIDENT
IN OUR ASSESSMENT, THE US ARMY CORPS OF ENGINEERS IS THE ONLY AGENCY THAT CAN MAKE FINAL
DECISIONS REGARDING JURISDICTIONAL WETLAMD/WATERS OF THE U.S. DELINEATIONS, THEREFORE, ALL
PRELIMINARY DETERMINATIONS ARE SUBJECT TO CHANGE UNTIL WRITTEN VERIFICATION IS OBTAINED,
CLEARWATER ENVIRONMENTAL CONSULTANTS, INC. STRONGLY RECOMMENDS A COMPREHENSIVE DELINEATION
AND SURVEY. CLEARWATER ENVIRONMENTAL CONSULTANTS, INC- STRONGLY RECOMMENDS THAT IVRITTE14
VERIFICATION BE OBTAINED FROM THE CORPS PRIOR TO CLOSING ON THE PROPERTY, BEGINNING ANY SITE
�! WORK OR MAKING ANY LEGAL RELIANCE ON THIS DETERMINATION.
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PHONE: [phone] DRAWNeY: DMO y►E`�Lr2ND DELINEATION MAP
Environmental Consultants, Inc_ FAX: [phone] DATE: 0I.02.09
EEC PROJECT NO.: 49A GRAHAM COUNTY, N. C.

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Robbuisville WWT_ Site Enviromnental Consultants, h1c, P�I« E Map
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Figtre 4a
Hendersonville, NC 28791
North arolina 528-698-9500

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ATTACHMENT A
ENGINEERING ALTERNAI`IVES ANALYSIS

ENGITSEERING ALTERNATIVES ANALYSIS
PROPOSED WASTEWATER TREATMENT PLANT
RELOCATION
TOWN OF ROBBINSN71LLE
GRAHAM COUNTY, NORTH CAROLINA
J. MELISKI, PE
McGM
A S S O C I A T E S
Engineering • Planning • Finance
Asheville, North Carolina
JANUARY 2009
REVISED JULY 2010
06561

TABLE OF CONTENTS
A. SUMMARY, CONCLUSION & RECOMMENDATION .....................1
B. CURRENT SITUATION..........................................................................3
C. FUTURE SITUATION..............................................................................5
D. ALTERNATIVES ANALYSIS...............................................................10
E. PRESENT WORTH ANALYSIS...........................................................15
F. SITE ISSUES............................................................................................20
Appendices
1 Existing NPDES Permit No. NCO025879 with Speculative Limits Letter
2 Preliminary Cost Estimates
McGill Associates, P.A. i Town ofRobbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

A. SUM VIA.RY, CONCLUSION AND RECOMMENDATION
The Town of Robbinsville is a small community located in central Graham
County, in the southwestern portion of North Carolina. The existing Robbinsville
Wastewater Treatment Plant (N'VWTP) is located adjacent to US 129 on the north
side of town, near the confluence of the Cheoah River and Long Creek. The
WWTP was originally constructed in 1964 with a capacity of 130,000 gpd. There
were major upgrades installed at the plant in 1986, when the capacity was
increased to 630,000 gpd. Robbinsville currently operates their wastewater
treatment plant under NPDES Permit No. NC0025879. The plant receives
wastewater flow from residential, coriunercial, and industrial customers in
Robbinsville and currently treats, on average, approximately 395,000 gpd.
Since the plant was last upgraded in 1986, treatment equipment is nearing the end
of its useful life. There is limited solids -handling capacity at the existing plant.
Sludge must be stored for a period of time and then pumped and hauled to another
facility for processing. Upgrades to the existing facility to accommodate
treatment improvements and future growth are restricted by its site. The WWTP
is located on a small parcel which is surrounded on the south and east by existing
buildings, on the north by US 129, and on the west by Knight Street. There is no
room to improve the existing WWTP at its current site.
For this reason the Town of Robbinsville needs to relocate their existing treatment
plant to a new, larger location. The new W W"1 Y will be constructea ozi a j -a4i U
parcel of land owned by the Town and situated north of Robbinsville and the
exiting plant near the Cheoah River. The new outfall will be downstream of the
existing outfall and on the Cheoah River instead of Long Creek, which is tributary
to the Cheoah River. The existing NVWTP would remain in service while the
proposed replacement plant is being installed. Upon start-up, testing, and
approval of the new plant's components, the existing plant will be demolished and
the existing outfall to Long Creek will be abandoned.
McGill Associates. P.A. 1 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

The Robbinsville area has experienced moderate growth in recent years and there
has been interest by surrounding communities to connect to Robbinsville's
sanitary sewer system. Robbinsville will need to expand its wastewater treatment
capacity to a total of 850,000 gpd during the twenty (20) year planning period to
account for future growth and to provide service to the surrounding communities.
Several alternatives are evaluated in Section D of this report and the most
appropriate cost effective solution for replacement of the existing wastewater
treatment plant was selected. It is assumed that costs to expand the collection
system, and to connect new consumers, are similar in price and scope for each
viable treatment option. Treatment alternatives have been evaluated on an
estimated construction cost basis as well as a present worth basis over a twenty-
year operations period, and have been conducted in accordance with the North
Carolina Department of Environment and Natural Resources Division of Water
Quality (NCDENR DWQ) guidelines.
The treatment facility is proposed to include a mechanical bar screen, oxidation
ditch, secondary clarifiers, tertiary disk filter, ultra violet treatment tank, aerobic
digester, belt press filter system, and operation building. In addition, it will be
necessary to construct approximately 2,000 linear feet of gravity sewer, an
influent purnp station and approximately 1,000 linear feet of force main to convey
wastewater from the existing WWTP to the proposed relocated WWTP. The
capital cost for the recommended alternative is estimated to be approximately
$7,964,000.
McGill Associates, P.A. 2 Town of RobbinsvilIe
January- 2009, Revised July 2010 Engineering Alternatives Analysis

B. CURRENT SITUATION
1. Existing Wastewater Collection System
The Town of Robbinsville is located in central Graham County, North
Carolina and has a population of approximately 738 residents according to
2008 population data provided by the North Carolina Office of State
Budget and Management (OSBM) website: (http://www.0sbm.state.nc.us).
The sanitary sewer collection system is owned and operated by the Town
of Robbinsville. Wastewater is collected from the Town of Robbinsville
as well as sorne outlying areas.
2. Wastewater Treatment Plant
Wastewater is treated at the Robbinsville WWTP, which currently has a
capacity of 630,000 gpd prior to its discharge into Long Creek, a Class
C;Tr water in the Little Tennessee River Basin, under NPDES permit
number NC0025879. The existing facility consists of an influent pumping
station, grit removal, a colnuninutor, a circular extended aeration tank with
center clarifier, sludge holding, U-V disinfection, and gravity effluent to
Long Creek. Current average daily wastewater flows to the treatment
facility are approximately 395,000 gpd. The Robbinsville WWTP has
generally demonstrated the capability of complying with its NPDES
Permit limits for the last several years.
3. Population and Demographics
The existing Robbinsville WWTP accepts sanitary flow from
approximately 450 residential properties and 157 commercial properties in
the Robbinsville area. There is also a large industry, Stanley Furniture, and
several smaller industries which are connected to Robbinsville's sanitary
sewer system. According to OSBM data, the average household
population density for Graham County is 2.142 persons per household.
Therefore, the current residential service population consists of
approximately 964 persons in an approximately 430-acre area centered on
McGill Associates, P.A. 3 Town of Robbinsville
January 2009, Revised July 2 0 t 0 Engineering Alternatives Analysis

the Town of Robbinsville. A more detailed explanation of current service
population estimates is provided in Section C of this report.
McGill Associates, P.A. 4 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

C. FUTURE SITUATION
1. Robbin"le Service Area Population Projections
Graham County has become a popular tourist destination with attractions
such as the Great Smoky Mountains, the Joyce Kilmer Memorial Forest,
Fontana Lake, Lake Santeetlah, the Appalachian Trail, the Cherohala
Skyway, the Tail of the Dragon, and the Stecoah Valley Cultural Arts
Center. The North Carolina Department of Transportation (NCDOT)
currently has plans to construct a new four lane highway (Corridor K
Bypass) which is proposed to connect NC Highway 28 with US Highway
129. The proposed Corridor K Bypass will generally follow NC Highway
143 and connect to US Highway 129 south of the Robbinsville town
limits. NCDOT has indicated that the proposed Corridor K Bypass is
scheduled to begin construction in 2016. It is anticipated that the
proposed Corridor K Bypass will increase travel and tourism in the Town
of Robbinsville area and spur commercial growth and wastewater service
demand along the proposed route.
Graham County has been experiencing moderate growth over the past
several years. According to the North Carolina Office of State Budget and
Management (OSBM) website, Graham County's population grew from
7,993 in April 2000 to 8,087 in July 2008. This data represents an annual
growth rate of approximately 0.15%. It is anticipated that the growth rate
will gradually increase as a result of the proposed Corridor K Bypass and
several other projects and developments planned for the area. Graham
County is currently plain- ing projects for the area which include a new
30,000 square -foot Justice Center and County Service Building, a
Downtown Agricultural Center and a Call and Data Center. Additionally,
private development to accommodate tourism, such as 24-room motel, has
been initiated in the area.
:McGill Associates, P.A. 5 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

The Graham County Health Department has confirmed that many of the
existing septic systeins in the area are inadequate and do not meet current
State requirements. Clusters of higher density development and
inadequate septic systems have created many situations where property
owners are unable to address their current septic system problems.
Problems include inadequate areas for leach fields, systems located in
close proximity to the lake, insufficient capacity in septic tanks, and
inadequate systems due to existing topography. In addition, there are
areas where subsurface conditions consist of a relatively thin layer of soil
over bedrock. In these situations, the wastewater from these systems
follows the subsurface bedrock layers without receiving the benefit of
natural purification through the soil, with the potential to surface in Lake
Santeetlah.
The most cost effective solution for providing sewer service to the
residents of the western Graham County service area is to construct a
centralized sanitary system that would pump flow via a series of pump
stations to the relocated Robbinsville WWTP. The relocated WWTP
should therefore have enough capacity for not only the Town of
Robbinsville and area surrounding the Town, but also for the western
Graham County service area.
The existing Robbinsville WWTP serves 450 residential customers and
157 businesses within the Town and immediate surrounding area.
According to the OSBM website, the average household size in the service
area is 2.142 persons per household. The resulting existing service area
population is 964 persons. Assuming an annual growth rate of 0.15%, the
estimated population within the existing service area will increase to
approximately 1,004 persons in the 20-year planning period.
It is anticipated that the Town of Robbinsville will expand its service area
to the southern Tulula Creek drainage basin along US Highway 129 and to
the eastern Sweetwater Creek drainage basin along NC Highway 143,
McGill Associates, P.A. 6 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

which comprise the major developed corridors of the area and present the
greatest potential for growth. These service areas include the communities
of Bear Creek, Cheoah and Tulula; these comununities consist primarily of
residences with some small businesses which developed along the
highways. Based on a residence count within the future expanded service
area, approximately 1,493 existing homes, or 3,198 persons could
potentially be served by the proposed WWTP. Assuming that the
expanded service area grows at 0.15% annually, it is estimated that the
population within the service area will increase to approximately 3,298
persons in the 20-year planning period.
The future western Graham County service area is generally located along
US Highway 129 and NC Highway 143 west of the Town of Robbinsville.
The western Graham County service area includes the Town of Lake
Santeetlah, as well as the unincorporated communities of Santectlah
Shores, Buffalo Creek, Ground Squirrel Branch, Cross Creek, and
Snowbird. The western Graham County service area consists primarily of
pen-nanent and seasonal residential homes mainly clustered in the Town of
Lake Santeetlah and in the communities around the lake. Based on an
existing residence count within the western service area, approximately
1,026 homes, or 2,198 persons may be served by the proposed WWTP.
The OSBM website indicates that the Town of Lake Santeetlah grew at a
rate of 0.75% annually between 2000 and 2008; however, for the purposes
of this report it is assumed that the western Graham County service area
will grow at a rate of 0.15% annually. Assuming that the service area
grows at 0.15% annually; it is estimated that the population within the
service area will increase to approximately 2,278 persons in the 20-year
planning period.
The total projected future population to be served by the proposed WWTP
during the 20-year planning period is 6,580 persons. The projected
service area will accommodate anticipated growth along the existing
McGill Associates, P.A. 7 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

major developed corridors and Santeetlah Lake areas. Extending sewer
service to these areas is feasible since most existing housing and future
anticipated development is located near local drainage features. Table C-1
below summarizes expected population growth within the future
Robbinsville WWTP service area.
Table C-1. Robbinsville WWTP Service Population Projection
Year
Service Area
2010
2020
2030
Existing Robbinsville
964
984
1004
Expanded Robbinsville
3198
3248
3298
Western Graham County
2198
2238
2278
Total Population
6,360
6,470
6,580
Percent Increase
2%
2%
3. Future Wastewater Flows
The future wastewater demands are estimated based on the current flows
and projected population growth within the existing Robbinsville service
area as well as the expanded Robbinsville and western Graham County
service areas. Table C-2 below shows estimated flow increases for the 20-
year planning period. The future population in 2030 to be served by the
Robbinsville WWTP is approximately 6,580 persons. Residential
wastewater flows from this increase are estimated at 70 gpd per capita. In
accordance with North Carolina Department of Environment and Natural
Resources Division of Water Quality (NCDENR DWQ) Construction
Grants & Loans guidelines, commercial wastewater flows from this
increase are estimated at 15 gpd per capita. According to the flow
projections, a capacity of approximately 850,000 gpd is necessary at the
proposed Robbinsville WWTP.
McGill Associates, F.A. 8 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

Table C-2: Estimated Future Wastewater Flores
Approximate Flog: - 2010
Projected Flow - 2030 �
Type of Flow
(GPD)
(GPD)
Residential
44,276
47,076
CommerciaUInstitutional
31,536
32, 136
Industrial
38,430
38,430
Robbinsville Expanded Service Area
- - - - -
280,330
Western Graham County Service Area
- - - - -
193,630
Industrial Reserve
- - - - -
11,424
Infiltration/Inflow
240,480
240,480
Total Flow
3541722
843,506
Flow Calculation Notes:
Current and future flows are based on the guidelines published the NCDENR DWQ
Construction Grants and Loans Section for engineering and planning documents.
1. Current Residential = 49,196 gpd x 0.90 = 44,276 gpd
2. Future Residential = 44,276 gpd + ((1,004 — 964 persons) x 70 gpd/capita)=47,0769pd
3. Current Commercial/Institutional = 35,040 gpd x 0.90 = 31,536 gpd
4. Future Co=ercial/Institutional = 31,536 gpd + ((40 x 15 gpd/capita) = 32,136 gpd
5. Current Industrial = 42,700 gpd x 0.90 = 38,430 gpd
6. Robbinsville Expanded Service Area = 3,298 persons x 85 gpd/capita = 280,330 gpd
7. Western Graham County Service Area = 2,278 persons x 85 gpd/capita = 193,630 gpd
8. Industrial Reserve = 10% current = (44,276 + 31,536 + 38,430)gpd x 0.10=11,424gpd
9. Infiltration/Inflow based on non -excessive Ill (3,000 gpd-inch-mile)
— 3,000 gpd x 80.16 inch -miles of sewer pipe = 240,480 gpd
McGill Associates, P.A. 9 Tuwn of Robbinsville
January: 2009. Revised July 2010 Engineering Alternatives Analysis

D. ALTERNATIVES ANALYSIS
1. Alternative No. I No Action
This alternative consists of no action being taken to relocate the existing,
outdated Robbinsville WWTP to a new, larger site. Many treatment
components of the existing facility are nearing the end of their useful
lives. Lack of space becomes an issue which will lead to increased
replacement costs or the inability to replace treatment equipment at all as
it fails. Also, as was shown in the flow projections, the existing treatment
plant will approach its capacity in the coming years. By 2020, the
wastewater flow is expected to exceed the plant's capacity. At this flow
rate the Town of Robbinsville will need to limit connections to its system
and would likely not be able to provide sewer service to the western
Graham County service area.
Existing properties in the areas immediately surrounding Robbinsville and
in the western Graham County service area have on -site septic systems.
Without the ability to connect to public sewer systems, and as these septic
systems fail, area surface waters would experience negative impacts from
untreated or improperly treated wastewater. Failing septic systems present
health issues for residents exposed to contaminated surface waters. Also
groundwater contamination could become an issue, especially with older
shallow private wells.
Therefore, "No Action" is not a feasible alternative and will not be
discussed in further detail.
2. Alternative No. 2 Proposed Robbinsville WWTP at a new location
with 850,000 gpd Capacity
This option includes the construction of a new WWTP on a 12-acre parcel
north of the existing WWTP near the Cheoah River. The capacity of the
new plant would be increased to 850,000 gpd from the existing wastewater
McGill Associates, P.A. 10 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

treatment facility's capacity of 630,000 gpd. Under this alternative the
plant will discharge treated effluent to the Cheoah River, a Class C;Tr
water in the Little Tennessee River Basin, which will require a new
NPDES permit. It should be noted that the existing W-WTP outfall to
Long Creek and its associated NPDES permit will be eliminated after
completion of this project.
The NPDES permit for the existing Robbinsville WWTP allows 630,000
gpd of treated effluent to be discharged to Long Creek with secondary
treatment limits. Since the proposed plant outfall is closer to Lake
Santeetlah than the outfall pennitted with the existing plant, the discharge
limits must meet tertiary criteria according to NCDENR DWQ. Table D-1
below provides a summary of the preliminary design criteria for the
proposed Robbinsville WWTP at its capacity of 850,000 gpd. Figure i
and Figure 2, located at the end of this section, illustrate the general
project area and the preliminary proposed WWTP site layout.
Robbinsville currently pumps sludge from their sludge holding tank on a
regular basis. The Town would like to have the ability to condition and
dewater sludge at the new facility.
This Alternative consists of installing concrete package type treatment
plant units. The treatment facility is proposed to include a mechanical bar
screen, oxidation ditch, secondary clarifiers, tertiary disk filter, ultra violet
treatment tank, aerobic digester, belt press filter system, operations
building, and effluent line to the Cheoah River. In addition, it will be
necessary to construct approximately 2,000 linear feet of gravity sewer, an
influent pump station and approximately 1,000 linear feet of force main to
convey wastewater from the existing WWTP to the proposed relocated
WWTP. The preliminary estimated cost for this option is $7,964,000.
McGill Associates, P.A. 11 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

Table D-1: Proposed Robbins-61le WWTP Preliminary Design Parameters
Influent Characteristics mg 11 Effluent Re uirernents m 11
BOD TSS
TKN
BOD TSS
TKN
250 250
40
5 / 10 j 30
nla
Treatment Units
U)
Influent Screen
Capacity
P
Manual Bar Screen
2.5 m d peak flow
Activated Sludge Process
Volume
Air Required
P
Aeration Basins
850,000 qal.
3,800 SCFM
Settling
Volume
Overflow Rate
P
Clarifiers
167,000 gal.
400 dlsf ADF
Disinfection
Type
P
Ultra Violet Light
Open Channel, Low Intensity J Hi h Output
Solids Handling
co
Storage
Volume
Air Required
P
Aerobic Digester
198,000 gal.
660 SCFM
Sludge Disposal
Ca acit
E
Removed bx contract sludge hauler
NIA
Status: E = Existing, P= Proposed
3. Alternative No. 3 Optimum operation of Existing Facilities
An alternative to increasing discharged flow at the proposed WWTP
location is to rehabilitate the existing WWTP and replace portions of the
existing collection system to decrease the amount of 1/1 into the collection
system. Although some reduction in 1/1 is possible through collection
system rehabilitation and/or replacement projects, the capital costs
required to reduce 1/1 volumes to accommodate future flows is currently
unknown. Furthermore, since the existing WWTP is not equipped with
dual train treatment processes, the rehabilitation of the existing WWTP
components while keeping the treatment processes operational would not
be possible without extensive pump and haul activities during
construction. There is not sufficient space available at the current site to
accommodate redundant treatment facilities and/or sludge storage and
treatment facilities. The pump and haul scenario would require a
sufficient number of tanker trucks to haul approximately 395,000 gallons
per day with additional tanker trucks on hand to accommodate peak flows
McGill Associates, P.A. 12 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

during wet weather. The tanker trucks would have to haul the wastewater
to three separate WWTP's within a one -hour radius since no single
neighboring WWTP has sufficient capacity to accept the all of the
Robbinsville WWTP flows. Additionally, user charge fees for disposal
would apply, which would greatly increase construction cost. The total
cost, logistics, and risks involved with pumping and hauling wastewater
from the existing WWTP during construction activities makes this
Alternative infeasible.
4. Alternative No. 4 Proposed WWTP with Land Application / Reuse
The planned total flow of 850,000 gpd at the proposed new treatment plant
results in an increase of 220,000 gpd over the current plant capacity and
discharge pen -nit. A typical acceptable land application rate for soils in
this region is 1" per week, which equates to 0.089 gpd per square foot. At
220,000 gpd, the area required would be 2,471,900 square feet, or
approximately 57 acres. Approximately 64 acres will be required to meet
set back limits. Based on a review of current property listings of 50 acres
or greater in Graham County near Robbinsville, the market price for land
appears to be approximately $30,000 per acre. Therefore, the cost of the
64 acres would be estimated at approximately $1,920,000, assuming that a
suitable site for land application could be located and purchased. In
addition to the cost of the property, there would be significant capital costs
associated with providing for wet/freezing weather storage facilities
(typically 30 days minimum), a 5-day holding pond for insufficiently
treated effluent, installation of a pumping and transmission system to
convey the effluent to the site, and installation of an irrigation system. All
of the above costs would be in addition to the required 850,000 gpd
wastewater treatment facility. It should be noted that the actual volume of
wet/freezing weather storage required would be based on a water balance
evaluation, and may be greater than the assumption of 30 days of storage.
The preliminary estimated cost is $17,371,000.
McGill Associates, P.A. 13 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

5. Alternative No. 5 Regional System 1 Connection to Existing
Treatment Facility
There are no other public- or privately -owned wastewater treatment
facilities within a 5 mile radius of the Town of Robbinsville; therefore,
this option will not be evaluated further.
6. Alternative No. 6 Proposed WWTP with Conjunctive Reuse
Relocation of the existing facility to a new WWTP site with Conjunctive
Reuse would include a land application reuse system and all of the other
facilities described above in the Land Application option, with the
exception of the wet/freezing weather storage facilities, and the 5-day
holding pond. The storage and 5-day holding pond would not be required
because if the facility were to be permitted with conjunctive reuse, the
treated effluent could be discharged to the Cheoah River during periods
when the irrigation system could not be utilized due to weather or
insufficiently treated effluent. The preliminary estimated cost for this
option is S11,660,000.
McGill Associates, P.A. 14 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

FIGURE 4 PROPOSED PROJECT AREA
WASTEWATER TREATMENT PLANT RELOCATION
��"1�• -�- TOWN _OF ROBBiNSVILLE1940
--
- :f Hirs nla a. - ' Y—GR4HAM COUNTY, NORTH CAROLNA —
PROPOSED
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FIGURE
2 PROF'08FID \AIA�-l'PTF\n/ATER'J-RE.Al i)Al N I
PLANT PRI-A
IMINAF-Vil" '-:olTL I-'I-.Ai\J
WASTEWATER TREATMENT
PLANT P-\El-oCjLW\ I 101\1
TOWN OF
ROBBINSVILLE
GIV\I-lAivi Col lid-1-Y, illONTI I CAROI 10,1A

E. PRESENT WORTH ANALYSIS
A present worth analysis has been performed on the technically feasible
alternatives to determine the most cost effective solution for meeting the future
wastewater treatment needs of the Town of Robbinsville. These alternatives
include Alternative No. 2 — Proposed Robbinsville W WTP at a new location with
850,000 gpd Capacity, Alternative No. 4 - Land Application/Reuse, and
Alternative No. 6 -- Proposed NVWTP with Conjunctive Reuse.
Alternative No. 2 — Proposed Robbinsville WNAITP at a new location with
850,000 gpd Capacity
The estimated capital cost for Alternative is 57,964,000. Table E-1 below
presents an itemized cost estimate for this Alternative.
McGill Associates, P.A. 15 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

Table E-1
Capital Cost for Alternative No. 2
Proposed Robbinsville WWTP at a new location with 850,000 gpd Capacity
ITEM
NO.
DESCRIPTION
QTY
UNIT
UNIT PRICE
EXTENSION
PART A - Sewer Lines and Pump Station
1
Mobilization
1
LS
$16,000
$16,000
2
12" DIP Sanitary Sewer
1,900
LF
$48
$91,200
3
8" DIP Sanitary Sewer
250
LF
$40
$10,000
4
4' Dia. Sanitary Sewer Manholes w/ Watertight lids
12
EA
$1,800
$21,600
5
4' Dia, Sanitary Sewer Manholes w/ Watertight lids and Vents
2
EA
$2,000
S4,000
6
Sanitary Sewer Service Taps per detail
(including max. 20' of 4" pipe)
4
EA
$500
$2,000
7
20" Dia. X 0.250" wall thickness steel encasement pipe, bored
and jacked
80
i F
5275
$22,D00
8
Submersible Sewer Pump station complete with site work and
emergency generator
1
EA
$375,000
$3 75,000
9
10" DIP Sewer Force Main
900
LF
$35
$31,500
10
CABC shoulders and parking lots
200
TONS
$20
$4,000
11
Washed Stone Undercut per 6" depth
620
LF
$4
S2,480
12
Rock Excavation
250
CY
S60
$15,000
13
Select Backfill
250
CY
$12 E
$3,600
14
Silt Fence installation Per details
740
LF
$3
$2,220
SUBTOTAL - PART A
$600,000
PART B - Wastewater Treatment Plant
1
Mobilization
1
LS
$300,000
$300,000
2
Mechanical Bar Screen and Channel
1
LS
$200,000
$200,000
2
Wastewater Treatment Basin (Concrete)
1
LS
$700,000
S700,000
3
Process Treatment Equipment, installed
1
LS
$500,000
$500,000
4
Secondary Clarifiers - Basins
I
LS
$400,000
$400,000
5
Secondary Clarifiers - Equipment, installed
I
LS
$300,000
S300,000
6
Disk Filters
1
LS
S500,000
$500,000
7
UV Disinfection System
1
LS
S300,000
$300,000
8
Clarifier S litter Box
l
LS
$50,000
$50,000
9
Sludge Pump Station
1
1 LS
$250,000
$250,000
10
Aerobic Digester
1
LS
$400,000
$400,000
11
Belt Filter Press System
1
LS
$300,000
$300,000
12
Operations Sludge Processing Building
1
LS
$400,000
$400,000
13
Sitework, including bypass road
1
LS
$300,000
$3003000
14
Yard Piping
1
LS
' $200,000
$200,000
15
Electrical
I
LS
S800,000
$800,000 k
SUBTOTAL - PART B
$5 900,000
TOTAL CONSTRUCTION COSTS
S6,500,000
10% Contingency
$650,000
Preliminary Engineering
$25,000
Environmental Assessment
$40,000
Design/Contract Administration
$429,000
Construction Observation
$250,000
Geotechnical during design
$5,000
'.Material Testing
$5,000
Easement Acquisition
$30,000
Legal/Administration
$30,000
TOTAL PROJECT COSTS
S7,964,000
McGill Associates, P.A. 16 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

Based on similarly sized facilities, the annual O&M costs are estimated at $0.50
per gpd, or $425,000 per year for an 850,000 gpd facility.
The twenty-year present worth cost of Alternative No. 3, using a discount rate of
5.125% (per current NCDENR DWQ Construction Grants and Loans guidelines)
is calculated below:
PW = $7,964,000 + $425,000 x (PIA, 5.125%, 20 yr.)
PW — $7,964,000 + ($425,000 x 12.33) — $13,204,250
PRESENT WORTH = $ 131204,250 for ALTERNATIVE NO. 2
Alternative No. 6 — Proposed WWTP with Conjunctive Reuse
In order to estimate the cost for constructing a new 850,000 gpd-capacity
Robbinsville WWTP with a land application system; several assumptions had to
be made.
These assumptions include:
1. Adequate land for disposal can be found within 10,000 LF of the
proposed WWTP site.
2. Land Application site is approximately square with no unsuitable
areas and only acreage necessary for irrigation is purchased.
3. Site elevations are technically feasible to be irrigated with a single
pump station.
These assumptions were made based on a best -case scenario and it is therefore
likely that the actual costs associated with constructing these facilities would be
greater than the estimates represented here. Based on the cost estimates presented
here the cost of constructing a land application system (Alternative No. 4) will be
significantly greater than Alternative No. 6 and therefore it is not necessary to
perform a more detailed estimate for Alternative No. 4.
McGill Associates, P.A. 17 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

Table E-2
Capital Cost for Alternative No. 6
Proposed WWTP with Conjunctive Reuse
ITEM
DESCRIPTION
QUANTITY
UNIT
UNIT
PRICE
'TOTAL
1
Mobilization
1
LS
$60,000
$60,000
2
850,000 GPD WWTP w/
Tertiary Treatment
I
LS
$5,900,000
$5,900,000
3
Collection System
Improvements
1
LS
$600,000
$600,000
3
Spray Irrigation Pump
Station
1
LS
$100,000.00
S150,000
4
Spray Irrigation Force
Main to Site
10.000
LF
$35.00
$350,000
5
Spray Irrigation
Distribution Pipe
45,000
LF
$15.00
$675,000
6
Spray Irrigation Spray
Guns
130
EA
$1,500.00
$195,000
ROUNDED CONSTRUCTION SUBTOTAL
$7,930,000
Contingencies (10%)
$793.000
Preliminary Engineering
$25,000
Environmental Assessment
$40,000
Design / Contract Administration
$555,000
Construction Observation
$317,000
Geoteclnucal Services during Design
$20,000
Materials Testing during Construction
$10,000
Land/Easement Acquisition
S1,940,000
Legal/Administration
$30,000
TOTAL ROUNDED PROJECT COST
I-11W,000
The annual O&M costs for this alternative would be similar to the O&M costs
described in Alternative No. 2 for the WWTP, plus additional O&M costs for the
spray irrigation system. Table E-3 includes an estimate of the annual O&M costs
for Alternative No. 6.
McGill Associates, P.A. 18 Town of Robbinsvi[le
January 2009, Revised July 2010 Engineering Alternatives Analysis

Table E-3
Annual O&M Cost Estimate for Alternative No. 6
Proposed WWTP with Conjunctive Reuse and Spray Irrigation System
Item
Annual Cost
WWTP O&M (Alt. No.2)
$425,000
Spray Irrigation System
$25,000
Total
$450,000
The twenty-year present worth cost of Alternative No. 6, using a discount rate of
5.125% (per current NCDENR DWQ Construction Grants and Loans guidelines)
is calculated below:
PW = $11,660,000- $450,000 x (PIA, 5.125%, 20 yr.)
PW = $11,660,000 + ($450,000 x 12.33) = $ 17,208,500
PRESENT WORTH = S 17,208,500 for ALTERNATIVE NO. 6
Present Worth Analysis Conclusions
Based on the above analysis, the 20-Year Present Worth to construct a new
wastewater treatment plant (Alternative No. 2) is $13,204,250, and the 20-Year
Present Worth for the Proposed WWTP with Conjunctive Reuse and Spray
Irrigation System (Alternative No. 6) is $17,208,500. Therefore the recommended
alternative is to construct a new wastewater treatment plant with a treatment
capacity of 850,000 gpd.
McGill Associates, P.A. 19 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

F. SITE ISSUES
A portion of the property purchased for the proposed wastewater treatment plant
is located within the 100-year floodplain of the Cheoah River. The 100-year
flood elevation is approximately 1954-feet. Construction of the proposed WNVTP
will have to been completed in accordance with Graham County zoning and
floodplain administration requirements, as well as all necessary pen -nits will be
obtained prior to construction.
McGill Associates, P.A. 20 Town of Robbinsville
January 2009, Revised July 2010 Engineering Alternatives Analysis

APPENDIX 1
NPDES Permit No. NCO025879

�oF v4A rF��
Q 'G
The Honorable Bobby Cagle, Jr.
Town of Robbinsville
P.O. Box 126
Robbinsville, North Carolina
Dear Mayor Cagle:
(� 2 4 Z, 1:tichael F. lcy, Govemar
R"illiam G. Ross Jr., Secretary
13ot,,h Carolina Department of Environment and Natural Resources
Cole= H..Sulfins, Du=tar
Division. of,W atsr Quality
October 30 2007 _ ,
Subject: issuance of NPDES
Permit NC0025879-'-`_�
Robbinsville SFU
Graham County
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge, permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
betwean North Carolina and the U.S. EnAronmental Protection Agency dated May 9, 1994 (or as
subsequently amended).
Please note that this permit requires the submittal of a Wastewater 1>♦ I agernent pion (Attachrt�ent A.(
by June 1, 2DOS.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150E of the North
Carolina General Statutes, and filed with the Office of Administrative Bearings (6714 Mail Service Center,
Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division: The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to
obtain other permits which may be required by the Division of Water Quality or permits required by the Division of
Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may
be required. If you have any questions conceming this permit, please contact Bob Guerra at telephone number
(919) 733-50B3, extension 539.
Sincerely,
/01�- Coleen B. Sullins
Enclosure: NPDES Permit NCO025879
cc: Central Files
Asheville. Regional Office I Surface Water Protection,
NPDES Unit
No�isCaroliria
N. WLh Carolina Division of Water Quality 161714.ail Smri= Center Raleigb NC 27699-1617 Phone [phone] cussam.-r srrNdce
1nt.--net w . w.ncwateroua't;tv.o. 1.00aticm: 512 N. Sai:sbury Sn RaieiQh, NC 27604 Fax (9I9) 733-2496 I -S77 a23�?48

Pewit NCO025879
SURpT EhjENT TO ?-R� rl COV7 SHEET
All previous �EES P
I�Termits issued to this faeity, vqhether for operation or
discharge are hereby revoked. As of this permit issuance, any preMusly issued
permit bearing this number is no longer effective. Therefore, the exclusive authority
to operate and discharge from this facility arises undincer
the
ereu f conditions,
requirements, germs, and pro
The Town of Robbinsville is hereby authorized to:
1. Continue to operate an existing 0.63 MGD wastev.ater treatment facility vvith the
following components:
• Influent lift station
Circular extended -aeration plant
Center -feed clarifier
• Aerobic sludge digester, thickeners and belt press
UV disinfection and
Continuous flow measurement
This facility is located at the corner of Old Hwy 129 and Knight Street in the
Town of Robbinsville in Graham County.
2. Discharge from. said treatment works, through Outfall 001, into Long Creek,
classified C-Trout haters in the Little Tennessee River Basin, at the location
specified'on the attached map.

Permit NCO025879
A. t I.) EFli .LUENT U1161TATf O NS AND MQ NITO R ENG R.EQU IRENIE EFTS
During the period beginning on the effective date of this permit and izs�jr g urLtil expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified belov,:
r
0.631A
ContinUOU-3
L� CQrdlr-g
I or E
Flow
BOD, 5-day (20°C)2
30.0 mgf L 45.0 =ng/L
3/Week
Composite
I & E
Total Suspended
30.0 mg/L 45.0 nmg/L
3 Week
/
Composite
I & E
Solids2
NH3 as N
4.2 mg/L 12.6 mg/L
Weekly'
Composite
E
(April 1 - Oct 31
NH3 as N
11.5 mg/L 34.5 mg/L
Weekl y.
Composite
E
(Nov 1 - March 31
Fecal Coliform
200/ 100 m1. 00J 104 m�T
3/Week
Grab
E
geometric meant
28 ug/L
3/Week
Grab
E
Total Residual
Chlorine3
T
Total nitrogen
Monitor aril Report
Semi-
annually
Composite
E
(NO2+NQ3TTKNj
Monitor and Report
Semi-
Composite
E
Total Phosphorus
annuall
_
a
Monitor and Report �
3 / week
Grab
E
H
W aste�iater.
Submittal within 180 days of permit
Not Applicable
Management Flans
issuance date
Footnotes:
1 • Sample Locations: E - Effluent, 'I - Influent. Upstream = at least 50 feet above discharge point.
2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not
exceed 15% of the respective influent Value (85 % removal)-
3. Limits and monitoring for total residual chlorine apply only if chlorine is added to the waste
stream`durfng the treatment process.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. Submittal of Wastewater Management Plan by June 1, 2008 - Attachment A (2)
There shall be no discharge of floating solids or visible foam in other than trace
amounts.

PerT it NTC0025879
i�To later than 180 days after the effective date of This permit, the Perrnitlee shall
submit to the Division a ;wastewater management plan. The plan shall include, at
a minimum, the following elements:
• mature flows. Provide estimates of wastewater flows and
characteristics for the next 10-20 years and the basis for those
estimates, including assumptions and calculations.
• Alternatives analysis. Conduct a technical and economic evaluation
of wastewater disposal alternatives, specifically including at ?east the
following alternatives:
connection to Lhe City of Gastonia wastewater collection system
a conversion to a spray irrigation system
implementation of a reuse program
Q any combination of the above options
The analysis and report should be consistent with the EAA guidance
document provided by the Division.
• Facilities assessment. Describe deficiencies and operational
difficulties in the existing collection and treatment systems that affect
performance or permit compliance., Identify potential improvements to
correct those deficiencies. At a minimum, evaluate the followdng
considerations:
inflow and infiltration,
• diversion of wasteloads during peak flows,
equipment repairs and preventative maintenance,
removal of accumulated solids, wastes, other debris
optimization plan. Develop a plan for optimization, rehabilitation,
expansion and/or replacement of the collection and treatment systems
to achieve op+inmurn performance. Identify specific measures and key
tasks, including those in the above facilities assessment, and provide
an estimated schedule for completion of each.
Y Biosolids management plan. Develop an operations plan to be used
(and describe the procedures currently used) for managing septage /
biomass in the treatment system, including associated solids wasting
and disposal, to promote optimum treatment system performance.
Identify operating parameters to be used and target values or ranges of
values where appropriate.
• Communications plan. Describe a plan for informing utility
customers of them potential impacts on treatment system performance
and appropriate practices for minimizing those impacts, including a
schedule for implementation of the plan. At a minimum, include the
following elements:
oil and grease contributions to the collection and treatment
system,
• introductory material for new tenants, describing acceptable waste
disposal practices
con=on practices that adversely affect the coLection/treatrnent
system
notufIcation procedures in case of emergencies.

Permit NCO025879
STATE, OF NORTH CAROLINA
DEPAR I MEN T OF EN-VIRONME T AND NATURAL RESOURCES
DIVISION OF WATER O-uAJ- 11TY .
PERMI
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of Forth Carolina General Statute f 43-215.1, other
lawful standards and regulations promulgated and adopted by the North Carolina
Environmental Management Commission, and the Federal Water Pollution Control
Act, as amended, the
Town of Robbinsville
is hereby authorized to discharge wastewater from a facility located at the
Robbinsville VJWTP
Corner of Old Hwy 129 & Knight Street
Robbinsville
Graham. County
to receiving waters designated as Long Creek in the Little Tennessee'River. Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, II,11I and IV hereof.
This permit shall become effective December 1, 2007.
This permit and authorization to discharge shall expire at midnight on November
30, 2012.
Signed this day October 30, 2007..
a Cole ' H. SulEns, Director
Di 'ion of Water Quality
By Authority of the En,.�onmental ?Management Conunission

f';iCf iaat F. i asiey, Governor
State Of W tb Carolina
V+rlBarn G. Ross, 3r., Secretary
Department of E-ivironl-nent and Na.u, al Resrjurtes
Coleen 14. Sullins, Dit mr
d ^� DD visio-n of Water Quality
July 29, 2008
The Honorable Bobby Cagle, lviayor
Town of Robbinsville
P.O. Box 126
Robb nsville, North Carolina
Subject: Speculative buts for Robbii+svll? W V TP
NPDES Permit No. NC0025879
Graham County
Dear Mayor Cagle:
This letter is in response to the request for speculative effluent limits for relocation and an
expansion of the Robbinsville WWTP from 0.63 M- GD to 1.0 MGD. Mx. David L. Honeycutt of
McGill A,:,--,sociates submitted this request to our office on your behalf.
Receivm-z Stream.. The speculative request was for a relocation of Robbiasville's discharge to
the Cheoah River and to cease discharge into Long Creels. Cheoah River is classified as a C
Trout waterbody in the Little Tennessee River Basin. The best usage of these waters includes
aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation,
and agriculture. The Trout designation is for those graters which have conditions that shall
sustain and allow for trout propagation and survival of stocked trout on a year-round basis.
The proposed Robbinsville W-WTP discharge point in the Cheoah River has a drainage area of
55.3 square miles, with an estimated average flow of 160 cfs; a sumnner 7Q10 flow of 26 cfs and a
v,rinter 7Q10 fl ow' o€ 38 cfs.
Speculative Limits. Based on current available information, speculative effluent limits for the
discharge of the current permitted flow of 0.63 MGD to the Cheoah rn.
river are presented i
Table 1. Speculative limits for an expansion flaw of 1.0 MGD to Cheoah River are presented in
'Fable 2. These Limits are recommended by Best Professional Judgment for protection of the
receiving waters based on the proposed discharge into the headwater arm of Santeetlah Lake.
Although this segment of the Cheoah River is not impaired, the Division has applied terd,-ay
limits to this proposed discharge to protect the river for its best usage. Current resources w-itfiin.
the Division do not allow for conducting a lake model to determine if less stringent limits may
be a viable option. if the Town of Robbinsville does not concur with these limits, you may
contract an outside resource to model this segment of the Cheoah River for determination of
effluent limits at the relocation site. The Division zviill evaluate the model and limits upon its
completion.
1617 f�ai 5anica rYantar, Raleigh, l`orth Ce'oiir�3 7�SS i517 : =iaphone (919) 897-a350 FAY [phone] 1po�Caoiina
512 h. 5ailshury StreeT Raleigh, hop h Carolina 276L4r Oa rye inter -net at _J/hzo.enr_sata.nc. �sj r�£ LCr IItf
_ ..... n......�..,R..IhIFr.-r�4ir ro 4-rtinn, m�l�vaf

Letter to ltia}- or Cagle
page 2
At this time the Division does not believe rutnennts (phoss,�horus and nitrogen) are a concern, so
no efrluer�t nutrient limits will be is -reposed a: this time_ How eTer, ir�tream monitoringar1l be
required.
A cornplete evaluation of these limits and monitoring frequencies, in fddidan to rnoritaxing
regturements .for metals and ether toxicants, will be addressed upon receipt of a formal NPDES
permit request. The reco=wded limits for am, morLia (NH3-N) are calculated to protect
against an'mionia to)city;nsearn.
`the followirig procedure has been recently implemented by the Division of Water QuiV
,D��� Q): Total residual chlorine (TRCI cornrliance ley, el. c!Lan ; to 50 u4 L Effectii� e Maich 1,
20CS, the Division received EPA approval to allow a 50 ug/l TRC cos=spl;ance level. This charge
is due to analytical difficulties wiuh MC measurements. Facilities Will still be required to report
actual result; on their rnon&ly discharge monitoring report (DMR) submittals, but for
compliance purposes, all TRC values reported below 50 ug / 1 will be considered to be in
compliance with the permit. The permittee shall continue to record and submit all values
reported by a North Carolina certified laboratory (including field certified), even if these values
fall below 50 ug/1.
TABLE 1. Speculative Limits for RobbinMile WWTP, 0.63 MGD, relocation to
Cheoah River
Effluent Characteristic
Effluent Limitations
Monthly
Weekly Averad
Daily Maximum
Average
Flow
0.630 MGD
BOD5 (summer)
5 mg/L
7.5 mg/L
BOD3 (winter)
10 m /1
15 Tn %1
NH3 as ITT (summer)
2 / L
b m� /L
NH3 as N (ivintex)
4 m /L
12 m,-/L
TSS
30 mg/L
45 nzo,/L
Dissolved Oxygen
Daily every ;e not
6.0 m /L
Total Residual Chlorine
28 u�/L
pH
6.0 - 9.0 S.U.
Fecal coliforrn (geometric
200/100 mL
400/100 mL
mean)

Letter to Mayor Cagle
page 3
TABLE 2. Spec�adve Limits for Babbizs��lle ���� 1"l'f �.0 14�LG1�F -eloeatiar� �o
Cllea3hR_iver
Effluent Characteristic
Flow
SODS (srnler)
BODS (-winter)
lv 13 as N (s srnrne
'N-H3 as N (vvinter)
TSS
Dissolved Oxygen
Total residual Chlorine
Fecal co iforrn (geometric
_
?-'.faLZeIit L1Il7Sltat1Oi15
Monthly
Weekly Average
Daily ax SlT 5
Average
LO IVIGD
-
^5 n1�/r
7.5 mn/L
J10 rn�/L
� 15 n-Lg/F
1 ma/ L
3 mg/L
2 mg, IL
6 ing/L
30 mg/L
43 mglL
Daily average not
< 6.0 mg/L
�6109.0S.U.
?8 u4/L
' 00/100 mL
400/100 mL
Chronic Toxicity 5.7%*
* Toxicity test W-M be conducted quarterly.
En4ineerin6 Alternatives Analvsis (EAA). please note ffiat the Division cannot guarantee that.
an N7PD.ES permit modificadon for the relocation or the expansion to 1.0 MGD will be issued
with these speculative }units. Final decisions can only be made aftex the Division receives and
evaluates a formal permit application for the Towns proposed expansion. In accordance uTiih
the North Carolina General Statutes, the practicable wastewater treatment and disposal
alternative with the least adverse impact on the environment is required to be implemented.
Therefore, as a component of all N-PDES permit applications for new or expanding, flow, a
detailed engineering alternatives analysis (EAA) must be prepared. The F-A�A must justify
requested flows, and provide an analysis of potential wastewater treatment alternatives.
Alternatives to a surface water discharge, such as spray/drip irrigation, wastewater reuse, or
inflow/infiltration reduction, are considered to be environmentally preferable. A copy of the
EAA guidance document is attached to this letter. Permit applications for new or expanding
now will be returned as incomplete if all EAA requirements are not adequately addressed. If
you have any questions regarding these requirements, please cc)ntact the DTATQ NPDES
Program at 919-907-6300.

Letter to Mayor Cagle
page 4:
T_ne fee schedule for I\PDES permits has changed as of September 1, 2007. Application fees for
this major mo 1 'cation «.*ill be $260 should the Town pursue this relocation at &..e existing flow=
or $1030 for the relocation and expansion to 1.0 MC-D. if you have any questions about these
speculative limits or NI MES permitt?ng requirements, please feel free to contact Jackie �To�+•ell
at [phone].
Respectfully,
/5san A. Wilson, P.E.
Supen-iscr, Western '-\7`DES Program
Attachment: EAA Gu ida.nce Document
cc: (without Attachment)
U.S. Fish and Wildlife Service, Ecological Services,.PO Box 33726, Raleigh, NC 276 6-
Asheville Regional Office/Surface Water Protection Supervisor
Dan Blaisdell/ Construction Grants and Loans
Central Files
NTDES Permit File
4

APPENDIX 2
PRELIMINARY COST ESTIMATES

TOWN OF ROBBINSVILLE
WASTEWATER TREATMENT PLANT RELOCATION
_
Preliminary Cost Estimate
Proposed Alternative - Relocate
VIWTP
q ND_, .
DESCRIPTION allANTITYl UNIT
UNIT PRICE .', .
EXTENSION
PART A • Sewer.:Lines and .Pump StatlDh
1
Mobilization
1 LS
$16,000
816.000
2
12" DIP Sanitary Sewer
1,9D0 LF
$46
$91,200
3
8" DIP Sanitary Sewer
250 LF
$40
$10,000
n
4' Dia, Sanitary Sewer Manholes
12 EA
$1,B00
$21.,500
Y
vo Watertight lids
4' Dia. Sanitary Sewer Manholes
2 EA
$2,000
$4,000
5
w; watertight lids and Vents
Sanitary Sewer Service Taps per detail
4 EA
$560
$2,000
6
!includinq max. 20' of 4" pica)
20" Dia. X 0.250" wall thickness steel
7
encasement pipe, bored and jacked, complete
80 LF
$275
$22,000
with carrier piDe
Submersible sewer Pump station complete with
8 site work, fencing, pumps, piping, electrical and
1 EA
$375,000
$375,004
g
emergency Generator
10' DIP Sewer Force Main
900 LF
$35
$31,500
10
CABC shoulders and parking lots
200 TONS
$20
$4,000
Washed Stone Undercut per 6" depth
620 LF
$4
$2,4B0
11
increments as directed by Enpineer
250 CY
$60
$15,000
12
Rock Excavation
13
Seiect Backfill
250 CY
$12
$3,000
14
Silt Fence installation per details
740 LF
$3
$2,220
SUBTOTAL - PART A
$600,000
PART B -Wastewater Treatment Plant
1
Mobilization
1 LS
$300,000
$300,000
2
Mechanical Bar Screen and Channel
1 LS
$200,000
$200,000
2
Wastewater Treatment Basin ICcncretel
1 LS
$700,D00
$700,000
3
Process Treatment Equipment, installed
1 LS
$500,060
$500,000
4
Secondary Clarifiers - Basins
1 LS
$400,000
$400,000
5
Secondary Clarifiers - Equipment, installed
1 L5
$300,000
$300,000
6
Disk Filters
1 LS
$500,000
$500,000
7
UV Disinfection System
1 LS
$300,000
$300,000
8
Clarifier Spiitter Box
1 LS
$50,000
$50,000
9
Sludge Pump Station
1 LS
$250,000
$250,000
10
Aerobic Digester
1 LS
$400,000
$4D0,000
11
Belt Filter Press System
1 LS
$300,DD0
$300,000
12
Operations,'Sludge Processing Building
1 LS
$400,000
$400,000
13
Sitework, inciuding bypass road
1 LS
$300,000
5300,000
14
Yard Piping
1 LS
$200,000
$200,000
15
Electrical
1 LS
$800,000
$800,00D
SUBTOTAL - PART S
$6,900,000
TOTAL CONSTRUCTION COSTS. _
$6,500,000
10% Contingency
$650,000
i
Preliminary Engineering
$25,000
1
Environmental
Assessment
$40,000
DesignlContract Administration
$429,000
Construction Observation
$250,000
Gevtechnical during design
$5,000
Material Testing
during Constr.
$5,000
Easement Acquisition
$30,000
- '
Legal/Administration
$30,000
TOTAL PROJECT COSTS $7,964,000

3
4
Yrooess reatmem wu�yi„c�,�. ,._:���
Secondary CIa-ifiers - Basins
--
1 LS $400,000 ;
$ 00,000
5
Secondary Clarifiers - Equipment, instaiied
LS $3DO,ODO
$30Q,D00
6
Ms k Filters
1 LS $5DD,000
$500,000
7
UV Disinfection System
1 LS $300,D00
$300,000
B
Clarifier Splitter Box
1 LS $50,OD0
$50,ODO
9
Sludge Pump Station
1 LE $250,003
$250,000
10
Aerobic Digester {
1 LS $40D,DQ0
$400,DOD
11
Belt Filter Press System
1 LS $300,ODO
$3OO,D00
12
DperationslSludae Processing Building
1 LS $400,003
$4D0,000
13
Sitework, including bypass road
1 LS $3OD,OOD
$300,DD0
14
Yard Piping
1 LS $2DD,DDO
$200,OD0
15
Flect6cal
1 LS $800,OOD
SSD0,000
SUBTOTAL - PART B
$5,900.000
PART C - Wastewater Disposal -
1
Mobilization
1 LS $60,000
$60,D00
2
5pray Irrigati0n Puma Station
1 LS $150 ODD
$150,006
3
F;pray Irrigation Force [Vain t0 Si?e
10 DOD LF $35
$350,OD0
4
Sprev Irri ation Distribution Pie
45 ODD LF $15
$575,0DD
5
Irrigation Spray Guns
130 EA $1,500
$195,300
SUBTOTAL - PART C
$1,430,ODD
TOTAL CONSTRUCTION COSTS
$7,930,000
10% Contingency
$793,DOD
I
?refiminary Engineering
$25,000
-
-
Environmentai Assessment
$40,000
Deslgn!Contram Adpnin:stration
$555,000
Construction Dbservatiun
$317,000
-
Geotechnical during design
$20,DD0
Material Testing during Constr.
;1QOOQ
-'
-
Land/Fasement Acquisition
i $1,940,000
LegallAdministratlon
$30,000
i
TOTAL PRDJECT COSTS
1$71.660,000

SHpa CORRESPONDENCE

CEC Project #
r Date pecieved . t� . CA
North. Carolina Department of Cultural resources
State Historic Presen ation Office
Peter 3. �„nrlhec'_:, Adr�_inis4arar
Michael : _ Easley, Gov=nw OE ice of.krchives and History
Lisherh C. Evans, Secrerarl Division of Historical Resources
Jeffrey;- Crow, Depary Secretary David Brook, ➢hector
NovembcrJ4, 2008
R. Clement Riddle
ClearWater Environmental Consultants, Inc.
718 Oakland Street
Hendersonville, NC 28791
Re: Robbins—vUe Waste Water Treatment Plant Relocation, Graham County, CH OS-2529
Dear -Mr. Riddle:
We have received the above project for revnew from the State Clearinghouse, and have the following
comments.
We have determined that the project as proposed will not affect any historic structures.
There are no known recorded archaeological sites within the project boundaries. However, the project area has
never been systematically surveyed to determine the location or significance of archaeological resources. Based
on the topographic and hydrological situation, and the density of recorded sites in the area, there is a high
probability for the presence of prehistoric or historic archaeological sites.
We recommend that a comprehensive survey be conducted by an experienced archaeologist to identify and
evaluate the significance of archaeological remains that may be damaged or destroyed by the proposed project.
Potential effects on unknown resources must be assessed prior to the initiation of con-situction activities.
Two copies of the resulting archaeological survey report, as well as one copy of the appropriate site forms,
should be forwarded to us for review and comment as soon as they are available and well in advance of any
construction activities.
A list of archaeological consultants who have conducted or expressed an interest in contract work in North
Carolina is available at wtit�varch.dcr.state.nc,us consults.htm. The archaeologists listed, or any other
experienced archaeologist, may be contacted to conduct the recommended survey.
The above comments are made pursuant to Section 106 of the National Historic Preseivation Act and the
Advisory Council on Historic Preservation's Regulations for Cornpliance with Section 106 codified at 36 CFR
Part 800.

Thank you for your cooperation and consideration. If you have questions conce-ming the above comment,
please contact Renee GledhM-Earley, enviro=ental review coordinator, at 919/807-6579. In all futiate
communication concerning this project, please cite the above referenced tracking number.
Sincerely,
Pa�
6P ter 5andbeck
cc: NCDNER
State Clearinghouse

ATTACHMENT C
TRC ARCHAEOLOGICAL SURVEY

ARMH-EOLOGICAL SURVEY FOR THE PROPOSED
ROBBINSVILLE NNI ASTEWATER TREATMENT PLANT,
GRAHAM COUNTY, NORTH CAROL A_
Submitted to:
CLEARWATER ENV]RONTMENTAL CONSULTANTS. TNC.
718 Oakland Street
Hendersonville, NTorth Carolina 28791
I0
TRC ENVIRONMENTAL CORPORATION
50101 Governors Drive, Suite 250
Chapel Hill, North Carolina 27517
Authored by:
Michael Nelson and Paul Webb
February- 2009

ABSTRACT
TRC Environmental Corporation (TRC) has completed an archaeological suT-ey of the proposed
Robbinsville Wastewater Treatment Plant site, which is situated on a narrow tract on the north side of the
Cheoah River, north of Robbimville in Graham County. The proposed plant site is located north of and
adjacent to the Cheoah River and is bounded by Sandhole Road to the north. Most of the tract is wltldn a
relatively flat and open field, with an existing mobile home at the western end of the field. The remaining
part of the tract to the west narrows between the road (north) and the river (south) until reaching the
junction with -US Hightivay 129/NC 143. A proposed pipeline then runs south along the east side of the
highway until it reaches the present Nvastewater treatment plant at the corner of US Highvvay 129iNC 143
and King Street (SR 1156).
The survey identified one small, muiticomponent prehistoric and historic site (31GH561.561**) in the
southeastem corner of the fieldrproject area, west of an unnamed stream and north of the Cheoah River.
Due to tine extremely lo�v density of artifacts, the absence of temporally diagnostic artifacts from intact
stra.tigraphic contexts, and the presence of obviously disturbed soils, 31GH5611561** appears to have no
research potential and is recommended ineligible for the NRHP. Based on the results of these
investigations, it is recommended that no additional cultural resource investigations be required for this
project.
iii

The author would life to thank Anna Salzburg and Cleinent Riddle of Clearwater Environmental
Consultants, Inc.; for their assistance and support of this project.
For TRC, Brenda and Mandy T erkhoin sen7ed as Field Technicians under the
direction of Michael -Nelson. Artifact analyses were conducted by Tasha Benyshek and Laura James.
The graphics were produced by Matt Pare, and the report ti as edited by Heather Millis.
-�7

CANTTE TS
,ABSTRACT .................... ........_I. ........ ...........................
.... ..... ...........................................
............ i i
ACKNOWLEDGMENTS ................................................. ......... .............. ....................................
.......,......,v
FIGURES .........................
ix
1. INTRODUCTION ..................................... ....................................1
2. ENVIROR \jENTAL SETTING ............................................. ......................... ......... .
..................... ........ 3
3
PROJECT SETTING............................._........................................
............................
....... ....
PHYSIOGRAPHY, HYDRCLOGY, GEOLOGY, AND SOILS........................................................3
FLORAAND FAUNA..........................................................................................................................1
3. CLZTCTRAL BACKGROUNTD................................................................................................................
5
PREHISTORICOVERVIEW ..............................................................................................................
5
5
Paleoindian Period (ca. 10,000-8000 B.C.)...............................................................................
Archaic Period (ca. 8000--1000 B.C.)..........................................................................................5
7
Woodland Period (ca. 1000 B.C.-A.D. 1000) ........................................... ...........................
.....
10
Mississippian Period (ca. A.D. 1000-1540)................................................................................
I I
HISTORICCHEROKEE OCCUPATION.........................................................................................
Early Historic Period Cherokee Settlements..............................................................................
11
Eighteenth through Twentieth Century Cherokee Settlements...................................................12
EURO-A-MERICAN SETTLEMENT................................................................................................13
4. RESEARCH GOALS AND METHODS..............................................................................................
17
RESEARCHGOALS................................................................................................................1.....17
17
RESEARCHMETHODS............ ................ ....... ...............................................
17
Background Research .................... ...................... ......................
..................
Archaeological Field Methods ...........................................................................I........17
is
.................................................
.
Laboratory Methods ........................................ .........
................
is
NRHl' Eligibility Elraluations........................................... .............. .....................
...............
5. RESULTS.............. ..................................... ..................................................
............ 21
21
BACKGROUNDRESEARCH .......... ..............................................................................
*.................
23
ARCHAEOLOGICAL FIELD SURVEY ............................ ....................................
....................
23
31GH561/561 **..................................
6. SUMMARY AND RECOM-MEN`IDATIONS.........................................................................................29
REFERENCES CITED- ....................................................._..............._.
31
AFPENDLX 1. ARTIFACT INVENTORY
Vil

FIGURES
I. I. Location of the Robbins-ille WWTP and site 31GH561i561"....................
5.1. Williams (1838) neap of the Cheoah River valley...............................................................................22
5.2. USGS (1935) map showing the project vicinity..................................................................................24
5.3. 0verview of the project area, facing northivest...................................................................................25
5.4. Site 31GH561/561 * plan view rnap...................................................................................................26
S.5. Southeastern corner of site 31 GH561i561 **....................................................................................... 27
Lx

L INTRODUCTION
TRC. Environmental Corporation (TRC) has completed an archaeological surrey of the proposed
Robbinsville Wastewater Treatment Plant site, which is situated on a narrow tract on the north side of the
Cheoah River, north of Robbinsville in Graham County (Figure 1.1). This study was conducted to
determine the location and significance of any possible cultural resources on the tract, in order to comply
with Section 106 of the National Historic Preservation Act and so that the information can be considered
for planning purposes. The background study was conducted on December 2, 2008, and the field survey
took place from December 8-9, 2008.
The proposed plant site is located north of and adjacent to the Cheoah River and is bounded by Sandhole
Road to the north. most of the tract is within a relatively flat and open field, with an existing mobile home
at the western end of the field. The remaining part of the tract to the west narrows between the road
(north) and the river (south) until reaching the junction with US Highway 129rNC 143. A proposed
pipeline then runs south along the east side of the highway until it reaches the present wastewater
treatment plant at the coiner of US Highway 129/NC 143 and King Street (SR 1156).
lackground research identified no previously recorded archaeological sites or other cultural resources
that might be impacted by the project, although a small historic period cemetery is reportedly situated on
a hilltop just north of the tract. The archaeological survey included a pedestrian survey (walkover) of the
entire tract, including the field and the proposed pipeline along the existing roadways, followed by shovel
testing at 20-m intervals within areas with less than 50 percent surface visibility and exhibiting less than
15 percent slope. A hand auger also was used to search for buried cultural deposits at selected locations
where alluvial sediments might be present.
The work identified one small, multicomponent prehistoric and historic site (31GH561/561**) in the
southeastern comer of the field/project area, west of the unnamed tributary and north of the Cheoah River.
Due to the extremely low density of artifacts, the absence of temporally diagnostic artifacts from intact
stratigraphic contexts, and the presence of obviously disturbed soils, 31GH561/561 ** appears to have no
research potential and is recommended ineligible for the NRHP. Based on the results of these
investigations, it is recommended that no additional cultural resource investigations be required for this
prof ect.
This report is organized in the following way. Chapter 2 provides information on the natural environment,
and Chapter 3 presents a summary of the regional culture history, including information on local history
and previous research in the project area. Chapter 4 specifies the research goals and methods, and the
results of the background and field research are presented in Chapter 5. A summary of the project and
recommendations are provided in Chapter 6, which is followed by a list of references cited. Appendix 1
contains the artifact inventory. An archaeological site form for 31GH561/561" has been submitted under
separate cover.

I
L
' '� r: 1. Htg6la>}d � ^` � _�. ,�- �L � i �~' "�� ;�� _ r 1 l '�" `�•` �.
Gap ;Vr-
IA I le
s�
Pr j ct Area4 ; ( y �" �'t tiY 9F`T ✓ ' ! rTonl�er G
i—� ' ,� y ~�] �� rA, YL •2fs MII '�• .tom L-
RAIL _ Q�CP j I�
'PAR -, �. f •.J
l 1 . /
.n�,�, �' - = `.- = .E•� .ram _.
F 1autiey.Gata
�. � G' - 'jib •�,; _ � 1 '`a :��:
LHT-
qj
Cr ,'I 1 . - q�t�J Q ( �i ••�► � ��" .1• �r 'i,jf�p :ty'��' � �' l `-. `--
].�ws7I
I WA
22
r� • S r � .. 5 I r I. �. Ti^
f � -- r l �f I- � � } �-•�' " '''� ! r• ' �\' � '-fir •� `� ^,� ��-_/� _
L'SGI %.3 �lnr�al ,<�aQ�dp�:if,ry D I
Ae[ddunilk..NC70.�0
hu[
D 4000 Nvllh
N
sac J Feet �
D
GA 5[
kilametet
Figure I.I. Location of the Robbinsviile WWTP and site 31GH561161**
2

PROXECT SETTING
The proposed Robbinsville Wastewater Plant site is situated north of the town of Robbinsville, north of
and adjacent to the Cheoah River. The tract lies within an open field, and is bounded by Sandhole Road to
the north. The remaining part of the tract to the west narrows between the road (north) and the river
(south) until reaching the junction -with LS Highway 129,NC 143. A proposed pipeline then runs south
along the east side of the highway until it reaches the present wastewater treatment plant at the corner of
US Highway 129;NC 143 and King Street (SR 1156).
PffYS10GRAPHN7,1RYDROLOGY, GEOLOGY, ANTD S-OfLS
The study area is situated in the Appalachian SunImit region of extreme southwestern North Carolina.
The topography of Graham County ranges from steep rugged mountain ranges to narrow river valleys,
with an estimated 90 percent of the county having a slope of 30 degrees or more (Millsaps and Millsaps
1992.iv). The project area lies in a level field north of the Cheoah River, at an elevation of approximately
1,960 feet AMSL. Elsewhere in the county, elevations range from 1,086 feet at Calderwood Lake and
1,940 feet at Santeetlah Lake to 5,470 feet at Haw Knob in the Unicoi Mountains west of the project area.
The project area is drained by the Cheoah River, which flows immediately south of the tract. From this
point the Cheoah flows north into Santeetlah Lake; the former channel then nuns northwest to its
confluence with the Little Tennessee River a short distance east of the Tennessee border, although the last
several miles of the river are largely dry due to the diversion of water for the Santeetlah Powerhouse on
Cheoah Reservoir. The Little Tennessee is part of the Tennessee River system, and flows west through
Calderwood, Chilhowee, and Tellico reservoirs before joining the Tennessee River west of Maryville,
Tennessee. The Tennessee River flows first southwest, then west, and then almost due north through the
Mid -South before reaching the Ohio River a short distance above its confluence with the Mississippi.
The immediate project area is underlain by metamorphic rocks of the Wehutty Formation of the Great
Smoky Croup of the Blue Ridge Belt, which contains dark gray, graphitic and sulfidic slate, mica schist,
metagraywacke, and metaeonglomerate (NCGS 1985).
There is no modern soil mapping available for the project area; although the tract is shown as lowland
soils by Goldston and Gettys (1953). As discussed elsewhere in this report, the alluvial soils on the tract
have been disturbed by filling.
FLORA AND FAUNA
The study area and the rest of the Southern Appalachians are part of the Oak -Chestnut Forest Region,
which includes a number of distinct forest types that vary with elevation. The pre-2e-century vegetation
in the river valleys and coves and on the sheltered mountain slopes was dominated by tulip poplar
(Liriodendron tulipifera), ash (Fray inus spp.), hemlock (Tsuga spp.), white basswood (rdia spp.),
buckeye (Aesculus spp.), oak ((2uercus spp.), red maple (.4cer rubrurn), chestnut (Castanea dentata), and
walnut (Juglarzs nigra). The higher elevations supported wild cherry (Prunus serotirza), oak, maple, birch
(Betula spp.), and beech (Fagus grandifoha). Clingmans Dome and other higher elevations were covered

with balsam (actually Fraser) fir (Abies fraseri) and rhododendron (Rhododendron spp.) (Holmes
1911:38; Ferkins and Gettys 1947:9).
Extensive logging in the late 19"' and early 20t' centuries removed much of the virgin timber from
Graham and adjacent counties. By the late 1920s most of the accessible timber had been cut, and much of
the area was covered by secondary growth, The chestnut blight also resulted in further alterations in forest
composition. Species present in upland forests today include oaks, pines (Pinus spp.), birch, hickory
(Carya spp.), dogwood (Corpus spp.), sounvood (Okydendruin arboreum), cherry, honey locust
(GIeditsia triacanzthos), black gum (,Nr ,ssa sylvatica), tulip poplar, white basswood, hemlock,
c.ucumbertree (31agnolia acurninata), and buckeye, Valley species include pines, oaks, souiw-ood,
dogwood, hickory, and locust (Gleditsia spp_) (Perkins and Gettys 1947:9).
In addition to arboreal species, the forests supported a variety of undergrowth species. The latter included
several varieties of edible berries, such as blackberries and raspberries (both Rubus spp.) and
huckleberries (Gaylassacia spp.), as well as numerous other species used for food and medicinal purposes
by both the Cherokee and later Euro-American settlers (Mooney and Olbrechts 1932; Oliver 1999:29).
The varied forests in the area supported a substantial and diverse fauna, as indicated by both early historic
period observations and modern inventories (Davis 1990:32; Stupka 1960). Ecological analysis indicates
that white-tailed deer (Odocodeus virginianus) would have inhabited the forests at a rate of about 400
head per 10 square miles (Dorwin 1975), although densities likely varied by season and by local
topography and vegetation. Other large and small mammals were also common. Black bear (Ursus
americanus) were present in densities of about 5 per 10 square miles, and elk (Cervus elaphus) probably
occupied the region during some intervals when human populations were low (Dorwin 1975). Wolves
(Canis sp.) were also present, along with panthers or mountain lions (Fells concolor), bobcats (Lynx
rufus), gray foxes (Urocyon cinereoargenteus), raccoons (Procyon lotor), beavers (Castor canadensis),
otters (Lutra canadensis), muskrats (Ondatra zibethica), mink (111ustela visors), opossums (Didelphis
rnzarsupialis), gray squirrels (Sciurus carolinensis), and fox squirrels (Sciurus niger) (Limey 1995; Oliver
1989:31; Shelford 1963; Stupka 1960). Avian species of possible econoinic importance included turkey
(Meleagris gallopavo) and smaller species; other species may have been valuable non-food resources as
well. The Little Tennessee and its tributary streams would have provided a variety of fish, including
catfish (Ictaluridae), sunfish (Centrarchidae), largemouth (Micropterus salmoides) and smallmouth
(.kficropterus dolonzieui) bass, and brook trout (Salvelinus fontinaalis).
4

3. CULTURAL BA-CKGROUND
PREIlTSTORCC GVERV'17-1'h'
This chapter presents a brief overview of the prehistoric and historic period occupations of the study area
and the Appalachian Highland region. Much of the earlier part of the cultural sequence for the region is
based on Coe's (1964) investigations of the prehistoric cultures of forth Carolina, coupled with more
recent research across the mountains in Tennessee (e.g., Davis 1990; Kimball 1985). The later prehistory
of western North Carolina has been refined by various researchers, including Dickens (1976). Keel
(1976), Purrington (1983), Riggs and Rodning (2002), Ward and Davis (1999), and av etmore (2002).
The prehistory of western forth Carolina can be divided into four basic tune and cultural periods. These
periods—Paleoindian, Archaic, Woodland, and '11,1ississippian---are characterized by both social and
technological differences. Several authors (e.g., Dickens 1976:10; Keel 1976:19; -Ward and Davis 1999;
Wetmore 2002) divide some or all of these periods into phases, some of which overlap in time and name
but vary in precise definition.
Paleoindlan period (ca. 10,000-8000 B.C.)
The Paleoindian period represents the earliest well -documented human occupation of the Southeast. Key
diagnostic artifacts of this period are fluted and unfluted lanceolate projectile points; a variety of flake
tools, such as endscrapers, gravers, retouched blades, and burins, are also found. Almost all of the
Paleoindian materials found in the region have come from surface contexts, and as a result few data are
available concerning regional subsistence or social organization (Anderson 1990). Hunting of late
Pleistocene megafauna is inferred based on evidence from other areas, although direct evidence for use of
animals of any kind is rare in the Southeast. Most, if not all, Paleoindian populations probably relied
extensively on other animal and plant foods as well (Meltzer and Smith 1986; Purrington 1983).
Paleoindian populations are believed to have been highly mobile, and settlements are thought to have
included small temporary camps and less common base camps that were occupied by loosely organized
bands. Paleoindians selected high -quality lithic materials for tools, and many sites are linked to important
source areas. The high degree of curation in the tool assemblage (and the low frequency of clearly
diagnostic artifacts) makes recognition of Paleoindian assemblages problematic. Keel (1976:17) suggests
that the earlier Clovis phase (pre-9000 B.C.) populations may have been confined to south of an east -west
line at the latitude of Asheville because of permafrost to the north. The later Paleoindian phase appears to
include Dalton (Goodyear 1982) and perhaps Hardaway ('Ward 1983) points and related cultures,
although both types of artifacts are also very rare in the Appalachian Sununu region.
Archaic Period (ca. 80€10-1000 B.C.)
The Archaic period began with the onset of the Holocene, post -glacial climatic conditions in the East, and
has been subdivided into three subperiods: the Early, Middle, and Late Archaic. Diagnostic projectile
points are the primary criteria used to identify and date distinct Archaic manifestations. As a whole, the
Archaic may be seen as a relatively long and successful foraging adaptation, with subsistence based on
hunting, fishing, and the collection of wild plant resources. The period is also marked by a general
increase in the density and dispersal of archaeological remains. Group size gradually increased during this
period, culminating in relatively large populations.

Early Archaic (ca. 8000-6000 B.C.). During the Early Archaic period, the mixed coniferous forests
present in much of the Southeast were replaced by mixed hardwood communities dominated by oak,
hemlock, beech, and maple (Claggett and Cable 1982:212). A modern faunal assemblage was in place
following the extinction of the Fleistocene meaafauna. Diagnostic markers of the Early Archaic period in
western North Carolina and eastern Tennessee include Kirk projectile points of the comer notched
tradition (ca. 8000-6800 B.C.) and bifurcate -based points such as the St. Albans, LeCroy, and Kanawha
types (ca. 6900-5800 B.C.) (Kimball 1985). Low regional population densities and a continued high
degree of group mobility are inferred for this period in the mountains, where most known sites are located
in high upland areas (Bass 1975). The nature of more general land use patterns and strategies for
technological organization remain the subjects of discussion, however (e.g., Claggett and Cable 1982). To
the .vest in Tennessee, Kimball (1992) has proposed an ongoing change from logistical to residential
mobility patterns during the Early Arehaic period, perhaps as a result of the first signs of warming
climatic conditions.
Middle Archaic (ca. 6000-3000 B.C.). Dururg the Middle Archaic, the cool, moist conditions of the early
Holocene are generally considered to have given way to the warmer, drier climate of the mid-I-lolocene
Hypsithermal interval. Extensive estuarine marshes and riverine swamps began to emerge in coastal
regions as sea levels ceased their post -Pleistocene rise by 3000 B.C. The northern hardwoods vegetational
matrix in those regions was replaced by an oak -hickory forest, which was in turn replaced by a southern
hardwoods -pine forest characterized by the species occupying the region today (Claggett and Cable
1982:212-216; Delcourt and Delcourt 1983, 1985). Subsistence economies became increasingly
diversified, and the first use of estuarine shellfish resources and possibly anadromous fish may have
begun at this time. Exactly how the Hypsithermal affected the relatively higher altitudes of western North
Carolina is unclear, however, and there is increasing evidence that parts of the Mid -Holocene were much
wetter than previously supposed (Leigh 2002; Leigh and Webb 2006).
Archaeologically, the transition from the Early Archaic to the Middle Archaic is characterized by the
appearance of stemmed rather than notched projectile points, and an increased incidence of groundstone
tools such as atlatl weights, axes, and grinding implements. The Middle Archaic witnessed the first
substantial occupation in the Smoky Mountains and most adjacent regions (Bass 1975:109). Three
subperiods within this period are recognized in most of North Carolina. These are identified by the
presence of Stanly (ca. 6000-5000 B.C.), Morrow Mountain (ca. 5000-4200 B.C.), and Guilford (ca.
4200-3500 B.C.) projectile points, following the classic Archaic sequence first identified by Coe (1964).
Morrow Mountain sites are frequently encountered in the uplands of western North Carolina (e.g.,
Purrington 1981), and occur both at high elevations and along lower elevation drainages where they exit
the mountains (Yu 2001). All three types of Middle Archaic points are found in the area, although the
Smoky Mountains appear to mark the western extent of the distribution of Guilford points (Bass 1975;
Derwin 1975).
Late Archaic ca. 3000--1000 B.C.. During the Late Archaic period, population levels in the mountains
appear to have risen markedly. Sites occur in a wide range of environmental zones, although most major
settlements were in riverine or estuarine settings (Bass 1975; Ward 1983). In particular, many Late
Archaic sites in the Smoky Mountains region appear to be situated near quartzite sources (Bass 1975:77;
Shumate and Kimball 2001). The existence of formal base camps occupied seasonally or longer is
inferred, together with a range of smaller resource -exploitation sites, such as hunting, fishing, or plant
collecting stations (Claggett and Cable 1982; Mathis 1979; Ward 1983). Although data from the
immediate area is lacking, some sites from this period contain evidence of prepared floors, post molds
from structures, and features such as storage pits, all of which indicate a more sedentary lifestyle than is
suggested for earlier periods. Grinding implements, polished stone tools, and carved soapstone bowls
became fairly common, suggesting increased use of plant resources, and possibly changes in subsistence
strategies and cooking technologies. Although regional evidence is minimal, the first experiments with
m

horticulture probably occurred at this time, with the cultiN ation of plants such as squash (Cucurbita pepo),
sunflower (Helianthus sp.), and Ch.enopodiwn (Cowan 1985; Ford 1981; Smith 1989).
The Late Archaic has been divided into a series of subperiods or phases, identified primarily by the
presence of diagnostic projectile points_ Late Archaic occupations in the Appalachian Summit region are
marked by a variety of large- to small -stemmed points. The most prominent of these is the Savannah
River type, a large, broad -bladed, square stemmed point that appears ca. 3000 B.C. and lasts to ca. 1500
B.C. Subsequent Late .Archaic sites frequently contain slightly smaller stemmed points of the Iddins
Undifferentiated Stemmed, Otarre Stemmed, and Small Savannah River types ONTard and Davis 1999:71).
Size reduction of these stemmed forms; on the average, is clearly indicated over the course of the Late
ArchaiclEarly Woodland in the region (Oliver 1981, 1985). Soapstone vessels were in use during the Late
Archaic in some areas, and towards the end of this interval pottery appears along the coastal regions
(Sassaman 1993).
'%Xoodland Period (ca> 1t�Q0 B.0.-A-0-
. 1000)
The Woodland period began about 1000 B.C. and continued until the appearance of the Mississippian
period, around A.D. 1000. Across the Eastern Woodlands the period is marked by the appearance of
widespread pottery, a greatly increased role for horticulture in subsistence economies, and an elaboration
of mortuary ceremonialism, including the appearance of burial mounds.
In the greater Southeast, the Woodland began with a gradual transition from the Late Archaic. Although
this transition period is not well understood, Woodland occupations appear to be marked by increasing
sedentism and improvements in food storage and preparation technologies. Subsistence strategies
represent a continuation of earlier hunter -forager ways, but with an increased reliance on the cultivation
of native plants (Yarnell and Black 1985). Religious expressions, as evidenced by increased
ceremonialism, and the development of burial mounds seem to have become more complex during the
Woodland period. Large triangular projectile points are diagnostic of the Early to Middle Woodland,
while smaller triangular points are in use by the later portion of the Woodland, presumably coinciding
with the introduction of the bow and arrow. Ceramics became more refined and regional differentiation of
wares, particularly in temper, paste, and surface decoration, became evident during this time. The
Woodland period in the Appalachian Summit area is summarized in Wetmore (2002).
Early Woodland ca. 1000-200 B.C.. Initial Woodland occupations are generally thought to reflect a
largely unchanged continuation of Late Archaic lifeways coupled with the first widespread introduction
of ceramics. The earliest Early Woodland manifestation in the project area is the Swannanoa phase, Nvhich
dates ca. 1000-300 B.C. A single date is available for western North Carolina frown a probable feature
containing a portion of a Swannanoa fabric impressed conoidal pot; that uncalibrated date is 2120±40
with a 2-sigama range of 352-42 B.C. (Benyshek and Webb 2006). The hallmark of the Early Woodland is
distinctive thick, crushed quartz or coarse sand tempered fabric impressed and cord marked ceramics.
Plain, check stamped and simple stamped wares are thought to occur late in the Early Woodland period
(Keel 1976.260-266; Ward and Davis 1999:140-143; Wetmore 2002:254--257). Vessel forms consist of
unrestricted conical pots and simple bowls. Eastern Tennessee's Watts Bar and northern Georgia's
Kellogg phases are similar stylistically to Swanmanoa materials, as are Vinette ceramics from as far away
as eastern New York (Ward and Davis 1999:142).
Early Woodland projectile points consist of smaller stemmed point forms (including OtarreiGypsy and
Swannanoa stemmed) that are the terminal expressions of the large stemmed point tradition associated
with the Late Archaic. Large triangular varieties are first seen in this period, including Transylvania and
Garden Creek types, which are morphologically equivalent to Badin and Yadkin Piedmont types (Keel

1976; Oliver 1985). Although Swannanoa site distributions have not been thoroughly docu wrntcd, it is
apparent that the settlement pattern included both Iarge floodplain sites, such as Warren Wilson, Garden
Creek, and Tuckasegee, along with numerous small upland extractive camps. lirect evidence is lacking,
but it seems likely that the Early Woodland inhabitants of the region were engaged in at least some degree
of horticulture (Ward and Davis 1999.145). Based on evidence at Phipps Bend in eastern Tennessee, deer,
elk, and turkey were the animals primarily hunted in the Early Woodland (Lafferty 1981). To date, no
Early Woodland structures have been definitely identified in the region.
Middle Woodland (ca. 200 B.C.-A.D. 900). The Middle Woodland period is characterized by intensified
long-distance trade throughout the Eastern Woodlands, and there is increasing evidence that some western
North Carolina groups participated in the Hopewell exchange network (Chapman and Keel 1979; Keel
1976; Wetmore 2002:263). Sites with 1Viiddle Woodland components that have been the focus of
intensive investigations in the region include Garden Creek in Haywood County (Keel 1976), Biltmore
Mound (Kimball and Shumate 2003; Kimball et al. 2004) and Bent Creek (Shumate and Kimball 2006) in
Buncombe County, Ela (Wetmore 1989) and Cherokee EMS (Benyshek 2007) ul Swain County, Harshaw
Bottom in Cherokee County (Robinson 1989), Tuckasegee in Jackson County (Keel 1976), the Tyler-
Loughridge site in McDowell County (Robinson 1996), and the Icehouse Bottom site in Monroe County
in eastern Tennessee (Chapman 1973; Cridlebaugh 1981).
Bass (1975:81) reports that while over 50 percent of Middle Woodland sites in his sample occurred on the
floodplain, 40 percent were located above the valley in coves and on benches. Numerous large and small
sites dating to this period have been found, suggesting periodic aggregation and dispersion or some kind
of a village/base camp —specialized resource extraction station settlement dichotomy. By Connestee times,
however, sites occur most often in the floodplains and a higher percentage are present on the first rise
above the river than in the preceding Pigeon or Swannanoa phases (Wetmore et al. 2000). Horticulture is
thought to have become increasingly important during this period, although mast resources remain the
most visible dietary contributor. Possible late Middle Woodland cultigens in the region include maygrass,
little barley, sumpweed, maize, and perhaps Chenopodium (Benyshek 2007; Chapman and Crites 1987;
Crites 2004; Robinson 1989; Webb 2002; Wetmore 2002). Evidence for the use of animal resources is
scarce from Middle Woodland sites in the area, save Biltmore Mound where preservation is excellent.
The faunal information from that Connestee phase mound area may not be representative of overall diet
and species utilization, however, since much of the assemblage may have derived from feasting or other
ceremonial activities. The faunal assemblage is dominated by terrestrial species (including white-tailed
deer, turkey, box turtle, raccoon, and squirrel), with much less representation of aquatic resources such as
fish and mussels (Whyte 2004).
Diagnostic early Middle Woodland ceramics in western North Carolina include the Pigeon series, which
Keel (1976:256-260) defines as including check stamped, simple stamped, plain, brushed, and
complicated stamped varieties with crushed quartz temper. Vessel forms include conical jars,
hemispherical bowls, and tetrapodal and shouldered jars with flaring rims. Pigeon ceramics are relatively
common in the region but are generally found in mixed contexts (Ward and Davis 1999.146), perhaps
indicative of stable populations inhabiting the same areas for long periods of time.
Subsequent Middle Woodland ceramics consist of the Connestee series, which consists of generally thin,
sand tempered wares that are most often plain or decorated with simple stamped, cord narked or brushed
surfaces. Crushed quartz temper was added in small amounts. Fabric impressed and check stamped sherds
are also included in the series. Plain necks are characteristic, with punctated shoulders rarely occurring
(Keel 1976:247-255). Swift Creek ceramics are often found as a minority ware on Middle Woodland sites
in the area (Kimball and Shumate 2003; Robinson 1989; Ward 1977). Also present but extremely rare are
Ohio Hopewellian ceramics (or locally made copies) and figurines, as have been identified at Garden
Creek, the Biltmore Mound site, and Icehouse Bottom (Keel 1976; Kimball and Shumate 2003). Lithic

artifacts characteristic of the late Diddle Woodland consist of large triangular and side notched projectile
gulars, Pigeon side notched), gorgets, and also a prismatic blade
points (Garden Creek and Connestee trian
and polyhedral core technology that was probably ultimately derived from the Hopewellian Midwest
(Chapman and Keel 1979:157). Copper is also found on Middle Woodland sites in the area, such as the
Garden Creek _Mound, Cherokee EMS, and Peachtree sites, but is rare (Chapman and Keel 1979).
Connestee Phase populations engaged in mound building, evidenced by such substructure mounds as
Garden Creek N?o. 2 and the Biltmore Mound, and interacted with Hopewellian populations in the
Midwest and elsewhere (Keel 1976; Kimball and Shumate 2003; Ward and Davis 1999:151-153).
Connestee series sherds are present on Hopewellian sites, and small numbers of Hopewellian ceramics
and bladelets made of Flint Ridge (Chio) chalcedony are present at the Garden Creek site, the Liltmoze
:Mound site, and at Icehouse Bottom (Chapman 1973; Chapman and Keel 1979; Kimball and Shumate
2003; Moore i 9S4}. _Marine shell was also traded (Kimball et al. 2004). It has been hypothesized that
western _North Carolina was one source of the mica that vas traded and used widely during this period.
Architectural information is limited, although at Garden Creek Mound No. 2. a square stiucture
measuring approximately 6 in across was identified at the base of the pre -mound layer and was attributed
to the Connestee occupation (Keel 1976). At Ela, eight circular structures 7--8 in in diameter were
ied as representative of Connestee phase constructions (Wetmore 1989, 2402).
dentifi
Late Woodland (ca. A.D. 600-1000). The Late Woodland period in much of the Southeast saw the
emergence of sedentary village life and intensive maize (Zea mays) horticulture and the development of
complex tribal and chiefdom -level political structures. Certainly, by A.D. 1044, many interior
Southeastern groups were producing substantial amounts of corn, which continued into the '_Mississippian
period when wild food resources were supplemental to cultivated ones (Starry 2003:88--89).
In the Appalachian Summit, the Late Woodland is largely invisible, raising questions about its character
there (Wetmore 2002). A similar lack of recognition of distinctive Late Woodland components has been
described in northern Georgia (Rudolph 1991). Part of the problem may be the lack of specific diagnostic
artifacts useful for unequivocally identifying sites of this period (i.e. plain sherds, small triangular
projectile points), but it is also possible that the Appalachian Summit region was more lightly populated
during this time and that small, dispersed sites were most typical.
An apparent Late Woodland manifestation was identified by Keel and Egloff (1984) at the Cane Creek
site in Mitchell County; the distinctive, largely plain -surfaced assemblage from that site is similar to
Connestee wares and was associated with a radiocarbon date of 1340±90 B.P. (uncalibrated). Based on
radiocarbon dates from several sites, Robinson ct al. (1994, 1996) have suggested that the Connestee
phase may have lasted well into the Late Woodland period; similarly, Anderson and Schuldenrein
(1985:720) suggest that some materials identified as Middle Woodland Cartersville Phase in the central
Piedmont of Georgia and South Carolina may actually be Late Woodland in age. Plain -surfaced ceramics
predominate in the contemporaneous Simpson's Field assemblage, and the longevity of simple stamped
and plain assemblages was demonstrated at the Rucker's Bottom and Bullard sites, which returned late
Late Woodland dates from contexts containing those wares (Anderson and Schuldenrein 1985). Other
parallels may also exist further to the south in Georgia, where the Late Woodland Vining Phase ceramics
are largely plain and simple stamped (Elliott and Wynn 1991; Meyers et al. 1999; Pluckhahn 1997; Worth
1996).
Scattered Napier and Late Swift Creek ceramics and components (such as those at the Cullowhee Valley
School [3]JK32] [Greene 1996:120-1211, Biltmore 11 [31BN175} [Hall and Baker 19931, Ravensford
[31SW781136], Hominy Creek [31B-N'828] [Pare et al. 20071, and Sneed [31JK466] [Benyshek 2008a]
sites) also occur in the region and reflect influences from the south during this period. For northern

Georgia, Rudolph (1991) notes that Caldwell's Swift Creek "13 complex" wares are characteristic of the
Late Woodland in that area; these wares have finer -lined stamping than classic Swift Creek pottery, and
occur with Napier forms at sites in the upper Chattahoochee and Savannah River valleys, such as
Annewakee Creek, Tugalo, and Simpson's Field (Wood et al. 1986). The B-complex Swift Creek and
Napier wares appear to be a Late Woodland marker for western North Carolina as well, if perhaps
infrequent ones. Salvage operations at the multicomponent Cullowhee Valley School site produced sherds
similar to the ones found at the single component Sneed site (David Moore, personal communication
2007), and a radiocarbon date obtained from Feature IS at CUllowbee, Valley School is close to the Late
Swift Creek dates from the Sneed Site (Benyshek 2008a). The accepted date range of the Late Swift
Creek component at Simpson's Field is very similar to the Sneed and CulloNvhee Valley School site dates
(Eenyshek 2008a).
1\1jss ssippian period (ca. A.D. 1000-1540)
The Mississippian period in the Southeast is marked primarily by the increasing intensification of maize
horticulture, the establishment of increasingly hierarchical social structures and settlement systems, and
an increase in ceremonialism expressed architecturally in the construction of flat-topped substructure
mounds. Increasing evidence exists that territorial boundaries between chiefdoms were closely maintained
during the Mississippian period, although individual chiefdoms rose and fell in cyclical patterns. Studies
of relations between native chiefdoms and Spanish expeditions suggest that some type of supra -chiefdom
level organization was maintained through a system in which paramount chiefs traveled from fief to fief,
displaying royal powers and prerogative and receiving gifts and tribute from subservient chiefdoms
(Smith and Hally 1992).
The Pisgah phase (ca. A.D. 1000-1450) corresponds with the early centuries of the Mississippian period
in parts of western North Carolina (Dickens 1976:13-14). Sites with substantial percentages of Pisgah
pottery are found primarily in the eastern and central parts of the Appalachian Summit region, and range
from small sites such as Brunk (Moore 1981) to nucleated villages with substructure mounds, such as
Garden Creek (Ward and Davis 1999:160-161). Pisgah pottery is also found in the western part of the
summit region as well, however, and into northern South Carolina, southwestern Virginia, and
northeastern Tennessee (Dickens 1976). Diagnostic Pisgah artifacts include small triangular projectile
points and distinctive rectilinear complicated stamped vessels with collared rims. Dickens (1976) suggests
that finer -lined complicated stamping and a lack of rim elaboration characterize the earlier portion of the
Pisgah phase, and Moore (1981) has documents such materials from the Brunk site. Maize and other
crops were important sources of food, but floral and faunal remains document the persistence of wild
resources as major components of the diet (Ward and Davis 1999:171).
Warren Wilson is the most extensively explored late Pisgah village to date, and work there documented at
least seven palisade lines and 16 structures, including seven typical "Southern Appalachian
Mississippian" structures with entry trenches (Dickens 1976; Ward 1986). Garden Creek Mound and
Village also contains a Pisgah component, and the principal mound (Mound No. 1) at that site was
constructed during the Pisgah phase (Dickens 1976). Recent work at two locations on the Qualla
Boundary suggests that Early Pisgah structures were of flexed pole construction, as opposed to the single
set, rigid post construction seen on late Pisgah and Qualla sites (Benyshek 2008b; Benyshek and Webb
2008). That work also suggests that Early Pisgah components exhibited more dispersed settlement
patterns than at least some Late Pisgah components, such as Warren Wilson.
The Qualla phase represents the final centuries of Native American autonomy in the region. Although
elements of the material culture, belief systems, place names, and social structure of Mississippian society
lingered in the region well into the 19"' century (and in some cases to the present day), this period is
10

largely one of social change due to increasing Euro-American intrusion and settlement in the region. This
part of the Native American occupation of the region is discussed belowas part of the historic
background of the region.
fffSTORIC CIT-EROKEE OCCUPATION
Early HistarlePeriod Cherokee Settlernarts
The first Euro American incursion into westem North Carolina took place in 1540, when Hernando de
Soto's expedition passed through the area. Several different reconstructions of de Soto's route have been
proposed, with some scholars (e.g.., Swanton 1985:201-202) suggesting that he crossed Cherokee country
by way of the Hiwassee River valley. Another reconstruction (Hudson et al. 1984) suggests that de Soto
crossed the Blue Ridge further to the north at Sw Emanoa Cap, and then continued along the French
Broad River into Tennessee; it is also possible that the expedition followed a somewhat more northerly
route along the Toe River (Hudson 1997:193). The route through Swannanoa Gap also may have been
followed by Juan Pardo, a Spanish explorer who traversed much of the same area in 1567-1569 (Hudson
1990:27-46).
Whatever the precise routes of these explorers, it is clear that the ancestral Cherokees' first encounters
with Europeans occurred in the mid-16t' century. These encounters were to have dramatic effects. The
introduction of European diseases to which the native populations had little resistance caused a major
reduction in population levels and extensive changes in political organization. Elsewhere in the Southeast,
the fragmentation and reformation of political groups resulted in a general decrease in social complexity
and the total disappearance of some prehistoric societies (Smith 1987). Although the Cherokees
underwent substantial disruption, they managed to retain control of portions of their homeland.
The historic -period Cherokee occupation of western. North Carolina is known archaeologically as the
Qualla phase (ca. A.D. 1450-1838). Although early formulations of the phase (Dickens 1976) divided it
into two segments (Early Qualla, ca. A.D. 1450-1650; and Late Qualla, ca. A.D. 1650-1838), more recent
analysts (Riggs and Rodning 2002; Rodning 2004, 2008; Ward and Davis 1999) suggest a tripartite
division. Following this latter scheme, the early Qualla phase predates A.D. 1500, and thus was likely
contemporaneous with at least the latter part of the Pisgah occupations in the region. These authors
suggest that Qualla represents an ill situ development in the Upper Little Tennessee and Hiwassee basins
and likely is not a direct derivative of the Pisgah phase. Early Qualla phase ceramics show affinities to the
more southern Savannah and Wilbanks styles, and samples froin COweta Creek and 31SW291 are
characterized by grit tempered, primarily rectilinear complicated stamped wares (Riggs and Rodning
2002:39), sometimes with "sawtooth" rims. Red filming also occurs (Rodning 2004). Pisgah collared and
punctated rims are not an uncommon occurrence with these Early Qualla wares, however, and late Pisgah,
Wilbanks-like, and shell tempered ceramics were identified along with Qualla ceramics in Early Qualla
contexts at Ravensford (Webb and Benyshek 2005). Early Qualla domestic structure forms are similar, if
not identical, to those of the Late Pisgah phase (Benyshek and Webb 2008).
Subsequent Middle Qualla phase (ca. A.D. 1500-1700) ceramics are characterized by jar forms with
notched applique, or more often, folded and notched everted to flared rims, and also by the presence of
carinated or cazuela bowls with incised designs. Curvilinear complicated stamping predominates,
although rectilinear designs are also present (Rodning 2004). By the Late Qualla phase (post-A.D. 1700),
some variations occur; incised ceramics became much less common, while rectilinear stamped designs,
rims with notched applique strips or fillets, and check stamping became more common in later, pre -
Removal (pre-1838) assemblages. Sometime around the end of the Middle Qualla phase, domestic
structure forms change to paired writer and summer dwellings often attached by entryway trenches.
11

Summer dwellings were rectangular in shape, while winter houses were circular to octagonal (Benyshek
i.p.; Benyslek and Webb 2008; Shumate et al. 2005; Webb and Benyshek 2008; Webb et al. 2005).
The Qualla subsistence base was mixed, and included cultivation of maize, beans, and other foods as well
as wild plant gathering, hunti;ig, and fishing (Dickens 1976:14). The Late Qualla phase is marked by the
increasing appearance of European goods at Cherokee sites, as well as shifts towards more European -
style architecture (Dickens 1976:15). Although small triangular projectile points are found in early and
'_1\/iiddle Qualla assemblages, these disappear with the increasing prevalence of European firearms after
A.n 1700.
Eighteenth through Twentieth Center- , Chen3kaa Settlements
During most of the I S`s century, the Cherokees were concentrated in towns and villages scattered
throughout much of present-day western North Carolina, eastern Tennessee, northeastern Georgia, and
northwestern South Carolina. The towns in western North Carolina were known as the Middle Towns, the
Out Towns, and the Valley Towns; the present project area falls at the northwestern edge of the Valley
Towns. The Out Towns were located to the northeast in the Tuckasegee and Oconaluftee drainages. The
Lower Towns were situated some distance to the southeast, and the Overbill Towns lay to the west, across
the mountains ill Tennessee (Greene 1996; Smith 1979). The late 18t' century was marked by a general
shift to a more dispersed settlement pattern (Dickens 1976:15), but some nucleated settlements remained
in the region into the 19'h century.
The 186 century brought the continuous arrival of Europeans and the resulting loss of Cherokee lands.
With the signing of the Treaty of Hopewell in 1785, the Cherokee lost their remaining lands east of the
Blue Ridge (Mooney 1900:61-62). A subsequent treaty in 1791 resulted in additional cessions, but failed
to stop Euro-American incursions and the resulting conflicts (Mooney 1900:68-77). A third treaty, signed
in 1798, ceded additional land in North Carolina. The early 19�h century witnessed the increasing
acculturation of many Cherokees, largely as a result of increasing contact and intermarriage with white
traders and settlers. Other Cherokee resisted changes to their traditional lifestyles, especially those
residing in western North Carolina (Riggs 1988:10-11). Accounts by contemporary observers indicate
that the population of that area was strongly traditionalist, and contained the highest proportion of
fullbloods to be found in the Cherokee Nation (McLoughlin and Cosner 1984:224-225).
A large area to the north and east of the study area was ceded to the U.S. government by the Calhoun
Treaty of February 1819 (Royce 1884, 1887), and most of the Graham County area remained in Cherokee
control for fewer than 20 more years. Most remaining Cherokee land claims in North Carolina were
abolished with the signing of the Treaty of New Echota in 1835, which set in motion the forced removal
of many of the remaining Cherokees to lands in the Arkansas Territory (Mooney 1900:123-133; Riggs
and Greene 2006; Thomason 2003). The cruelty of this march, known as the Trail of Tears, has been well
documented. The principal late 18'h- to early 19a'-century settlement in the project area was known as
Cheowa or Buffalo Town, and was located along the Cheoah River in the vicinity of what is now Lake
Santeetlah. This town was noted as Cheowe on early to mid-18t'-century maps, and generally placed in
the vicinity of Robbinsville. Although the settlement is not documented in the Revolutionary War period,
in 1809 Buffalo Town had a population of 171 (Riggs 1996).
The most detailed information on Cherokee populations in the Cheoah Valley dates to the Removal
period. In 1837-1838 the U.S. Army Corps of Engineers surveyed the Cherokee lands in North Carolina
covered by the Treaty of New Echota, recording the locations of Cherokee houses, fields, and other
improvements (Riggs 1996). The sure eyors' notebooks that were prepared are useful in locating Cherokee
homesteads in the vicinity, and when coupled with the 1835 census and 1936-37 property valuations
12

provide considerable data on the local inhabitants. Although the notebooks detailing sun'eys in the project
vicinity cannot be located, the composite surveyors' map provides some information on Cherokee
settlement in the area (Williams 1838). The map bears the notation `Buffalo Town" near the future site of
Robbinsville, and depicts at least four structures near the project. One of those is situated on the broad
alluvial landforrn across the river south of the project tract, and others are situated along the river to the
north and souih. None are situated on or adjacent to the project tract, however.
The forced removal of the Cherokees from North Carolina began in June of 1838, with the arrest and
concentration of most of the remaining Cherokees in six removal forts and stockades across the area that
had been relinquished by the Treaty of New Echota. One of those forts, Fort Montgomery, was located at
the current site of Robbinsville. Although most Cherokees were removed from westem North Carolina by
late 1838 (Finger 1984:29), an estimated 1,100 Cherokees managed to evade removal and remain in their
ng around Quallatown (near the confluence of the
former lands. Approximately 700 Cherokees livi
Cconaluftee River and Soto Creek, up the Tuske- ee drainage some distance northeast of the project area.)
were allowed to remain in the East, including some of the citizen Cherokees who had been granted (and
subsequently lost) reservations some years earlier (Finger 1984:29; Riggs 1988:19}. After the death of
Chief Yonagusta ill 1$39, that group had been increasingly assisted by William H. Thomas, a white
merchant who was Yonagusta's adopted son. Thomas worked on the Cherokees' behalf for the next 40
years, acquiring land for both individual Cherokees and the tribe. Thomas eventually acquired some
73,000 acres for these communities, mostly within the present-day Qualla Boundary.
As noted by Finger (1984:17-18), Riggs (1996:72), and others, the residents of Buffalo Town contracted
with William H. Thomas, the patron of the Oconaluftee, Cherokees, to secure their exemption from
removal. Perhaps for this reason, and perhaps due to the abysmal state of transportation in the area, many
of the Buffalo Town residents were allowed to remain in the area (Duggan 1998). That group later
became the nucleus of the Snowbird Band of Cherokee Indians, which eventually coalesced with the
Qualla Cherokees to form the Eastern Band of Cherokee Indians in 1889 (Neely 1991). Finally, still other
Cherokees remained due to their assistance to the U.S. Army in the Tsali affair (Finger 1984; Jurgelski
2006; King and Evans 1979; Webb 2004), or had managed to hide out and evade capture during the
summer and fall of 1838.
The mid-19`'- through 20t"-century social and political history of the Eastern Band of Cherokee Indians
has been described in detail by Finger (1984, 1991), Hill (1997), Mooney (1900), and others, and needs
only be recapped here. The Cherokees' rights to the lands bought by Thomas were confined by a federal
court decision in 1874, providing some measure of security to the local population. In 1989, the
Cherokees in North Carolina were officially incorporated under state law as the Eastern Band of
Cherokee Indians (Finger 1984). Most Cherokees continued to practice a farming economy throughout
the 19`h century, although hunting, fishing, and gathering wild plant foods were also important subsistence
activities. Logging became an important source of jobs for a time beginning in the late 1800s, although
most logging jobs were gone by the early 19309. Although the Cherokee population has increasingly
become outwardly acculturated since the growth of the modern tourist industry beginning in the 1930s, d
it
has preserved a distinct cultural and ethnic identity through the retention of the Cherokee languagea
a
aspects of both day-to-day and ceremonial life (Riggs et al. 1997:19).
ELTRO-AA'1ERICAN SETTLEMENT
The earliest Euro-American settlement in the area was Robbinsville, which developed around a trading
post first established by Thomas Cooper and William H. Thomas in the early 1840s near the site of Fort
Montaomery (one of the six Removal forts); earlier names of the settlement included Cheoah Valley and
Fort Njontgomery (Riggs and Greene 2006; Sheffey 1992:2; Thomason 2003:E35). Graham County was
13

formed in 1872 from Cherokee County, and the county seat was established at Robbinsville (Corbitt
1950:107-108). As in Swain County to the east, the lack of adequate transportation routes hindered
development of the area. For many years the Tatham Gap Road, built along an earlier road that had been
constructed by the Army in 1839 to facilitate removal of the Cherokees from the Cheoah Valley,
remained the major route to nearby Andrews. A road to Topton and the 'Murphy Branch Railroad was
opened in the early 1900s, however, and greatly facilitated access to the area (Sheffey 1992:2).
The late 19a' century saw increasing settlement, as well as the earliest development of the logging
industry in the area. Logging in Graham County began in the 1880s with work on Santeetlah, West
Buffalo. and Snowbird creeks; as elsewhere, the earliest logging utilized splash dams. More substantial
operations were organized in the early 1900s, including those of the NVI-citing 1��lanufacturing Company,
which was based at Judson in Swain County, but logged most of eastern Graham County. Other major
operations in Graham County included those of the Kanawha Hardwood Lumber Company, the Babcock
Lumber and Land Company, and the Bemis Hardwood Lumber Company (1\7othstein 1972).
Hydroelectric development reached Graham County in the 1910s and 1920s, when construction was
begun on Cheoah Lake (1916) and Lake Santeedah (1925). Lake Santeetlah was completed in 1928. The
lake has a surface area of 2,881 acres and about 78.8 miles (126.7 km) of shoreline (Joy 2002:3), and
inundated much of the Cheoah Valley below Robbinsville. By 1939, local boosters were touting the
benefits of the growing tourist industry, and emphasizing the proximity to the Great Smoky Mountains
National Park as well as local mountain views and the "picturesque Santeetlah and Tapoco lakes"
(Anonymous 1932). Modern-day Graham County draws much of its income from tourism, including that
focused around the county's four lakes as well as the Joyce Kilmer Memorial Forest (located only a few
miles north of the project area).
PREVIOUS ARCHAEOLOGICAL RESEARCH
Western North Carolina has been the subject of archaeological research for over a century, and most
trends in the history of North American archaeology are reflected in the region. As early as the 1880s,
workers from the Valentine Museum in Richmond investigated several mound sites in the region, but
none were in Graham County (Dickens 1976:7). The museum's work was primarily oriented toward
recovering artifacts, although in some cases the resulting data have been useful in addressing present-day
research questions (e.g., Dickens 1976:91). Also i_n the 1880s, researchers from the Smithsonian
Institution's Bureau of Ethnology excavated sites in Buncombe and Henderson counties as part of their
investigations into the origin of the "Mound Builders" (Thomas 1894). That work was instrumental in
demonstrating that the mounds in western North Carolina and elsewhere had in fact been built by
American Indians and were not the products of a mysterious, vanished race.
Early 20`b-century work in western North Carolina continued to focus on mound explorations. Between
1915 and 1919, George Heye and associates excavated at the Garden Creek site in Haywood County and
at other nearby sites (Harrington 1922; Heye 1919; Heye et al. 1918). Although that work was designed to
gather artifacts for Heye's Museum of the American Indian in New York, it did provide some data on the
antiquity of the Cherokees in the region (Dickens 1976:7-8). Subsequent work in 1933 and 1934 by the
Smithsonian Institution at the Peachtree Mound and Village in Cherokee County was also designed to
investigate the relationship between the Cherokees and prehistoric cultures in the area (Setzler and
Jennings 1941). Also in the 1930s, George MacPherson (1936a, 1936b) and Hiram Wilburn conducted
surveys of numerous sites in Great Smoky Mountains National Park to the north of Graham County.
Although many of their data were to be incorporated into later research (Bass 1975), at the time their
work had little impact on the understanding of the red on's prehistory. Several reservoirs (including
14

Cheoah, 5anteetlah, and Fontana lakes) were constructed in and adjacent to Graham County during the
1910s-1940s, but no archaeological work -was conducted as part of those projects.
Tntensive, systematic work in the Appalachian Swnmit region did not begin until 1964, when the
University of North Carolina instituted the Cherokee Archaeological Project. This project, which lasted
until 1971, included large-scale surveys and salvage excavations; as well as intensive investigations of
late prehistoric and historic Cherokee sites (Purrington 1983:98-99; Z lard 1979; �ti'ard and Davis
1999:17-18). Data from this project, reported in several theses, dissertations, and other publications (e.g.,
Dickens 1976; Egloff 1467; Keel 1976), provide much of the background information on the Appalachian
Summit region. Very little, if any, of this work was conducted in Graham County, however.
Beginning in the 1470s, new federal cultural resource legislation and management procedures resulted in
an increasing number of archaeological projects in the Graham County area. Most of the CPU, (Cultural
Resource Management) projects conducted in Graham County have been related io activities on
Nantahala National Forest, and include work by Bassett (1998, 1999, 2000), Burchett et al. (1994),
Snedeker et al. (1992), and others. Other projects have been related to transportation improvements or
other activities, including work by Ayers (1976), Baker (1980), Benyshek and Webb (2004), Collins and
Eblen (1978), Garrow (1981); Riggs (1998), and Webb et al. (2009). Other major recent projects in
Graham County include surreys of Cheoah, Santeetlah, and Calderwood reservoirs for the Tapoco
relicensing project (Joy 2002, 2003).
15

4. RESEARCH GOALS AN-D METHODS
? ESFARM COALS
The primary goal of the survey was to systematically gather data on any archaeological resources present
within the survey tract for the purposes of regulatory compliance_ In addition, the archaeological field
data were to be combined with information obtained in the background research to address the nature of
the prehistoric and historic period occupations of the area.
RESEAL RC.0 1t IR T1710D S
Specific research methods were utilized for the background studies, field research, analysis, and reporting
stages of the pmj ect. The methods used in each stage of research are outlined below.tl
Background Research
Background research was conducted to gather information on any known cultural resources on and
adjacent to the tract, and included examination of the following materials:
• Narional Register and historic structures files at the North Carolina State Historic Preservation Office,
Western Division of Archives and History (SHPO);
• Archaeological site files and reports at the Western Division of Archives and History and the North
Carolina Office of State Archaeology (OSA);
• North Carolina cemetery survey publications and online resources; and
• Historical reaps and other materials at the UNC-Chapel Hill North Carolina Collection, the Nomb Carolina
State A rchit,es, and similar repositories.
Archaeological Field '-Methods
The archaeological survey complied with all pertinent state and federal regulations including the North
Carolina Office of State Archaeology's (OSA) Guidelines for Preparation of Archaeological Survey
Reports in North Carolina. The field survey was conducted by a team of three, consistinCN
of the Field
Director and two Archaeological Technicians.
The survey included a pedestrian walkover, followed by systematic shovel testing of suitable landforms at
20-nm intervals and supplemental 10-m interval testing as needed to determine site boundaries. All shovel
tests were excavated to sterile subsoil or at least 75 cm below surface. All soil was screened through '/-
inch screen for uniform artifact recovery. Once cultural artifacts were found, additional shovel tests were
excavated at 10-m intervals in cardinal directions to determine site boundaries. Furthermore, given the
location of the project area within a floodplain terrace along a major river, the possibility of deeply buried
soils existed. To this end a hand auger was used to facilitate excavations deeper than the 75 to 100 cm
below surface reached with shovels. Auger holes Were not excavated in all of the shovel tests, but a
sufficient number were tested to indicate that no buried cultural soils exist in the project area.
17

Laborgz.ory M.etliod.s
Following the completion of field work, the artifacts were returned to TRC's Asheville office for
processing, cleaning, and analysis. Artifacts were classified according to regionally appropriate
typologies, and the artifact assemblage for the identified site was analyzed to determine the prehistoric
and historic components present and the range of materials and activities represented.
Lithic Artifacts. The chipped stone assemblage was sorted into formal tool (e.g., biface, scraper),
expedient tool (retouched and/or utilized flake), and debitage (manufacturing waste) categories.
Information on raw material type (e.g., quartzite, quartz, chert, etc.) was recorded for all lithic artifacts.
The following categories were used in the analysis of the Robbins"V-11le assemblage.
U'nmodifr.ed Debitage. Counts and raw materials were recorded for debitage categories. Presence or
absence of cortex was noted. Most of the chipped stone artifacts examined are larger than 1/ inch due to
the nature of the recovery technique.
Fire Cracked Rock (FCR). Often difficult to identify definitively with the varied metamorphic rocks typically
present within cultural contexts in the mountains, fire cracked rock is defined as any cobble that exhibits
irregular angular surfaces broken from apparent exposure to fire and exhibits no use wear or fracturing from
percussion. Reddening is not a necessary criterion for classification as fire cracked rock, although it is often
associated depending on rock type.
Raw material Iderztfcatiorzs. Chipped stone raw materials were identified based on macroscopic
characteristics. The categories utilized include quartz, quartzite, and chert.
Ceramic Artifacts. The single sherd recovered was classified by surface decoration and aplastic content to
the extent possible. The aplastic (inclusion) content was documented as the type (or raw material) of the
inajor material present. Sand temper was identified using fine (< 0.25 mm) to medium (0.25-0.5 mm), or
coarse (>0.5 mm) categories. The coarse sand category may represent the "grit" tempered designation
used by some researchers in the area.
Surface decoration was recorded by type (e.g., curvilinear complicated stamped, cord marked), and major
decorative mode characteristics were recorded. The surface decoration—aplastic content from the
preliminary analysis was compared to published type descriptions (Keel 1976); type naives are applied as
feasible.
Historic Artifacts. Historic artifacts were classified according to material type and function. Every effort
was made to describe artifacts as precisely as possible, including the identification of specific artifact
varieties, manufacturers, or brands.
NRHP Eligibility Evaluations
The significance of each resource was assessed in terms of its eligibility for the National Register of
Historic Places, following the NRHP EIigibility Criteria as outlined in 36 CFR 60.4 (USDOI 1991). The
NRHP Eligibility Criteria state:
The quality of significance in American history, architecture, archeology, engineering, and culture
is present in districts, sites, buildings, structures and objects that possess integrity of location,
design, setting, materials, worlcmanship, feeling and association,
UR

(a). That are associated ,�vith events that have made a significant contribution to the broad pasterns
of our history; or
(b). Tnat are associated with the jives of persons significant in our past; or
(c). T%at embody the distinctive characteristics of a type, period; or method of construction; or that
represent the work of a master, or that possess higb artistic values; or that represent a significant
and distinguishable entity whose components may lack individual distinction; or
(d). That have yielded, or may be likely to yield, information important in prehistory or histo7;1.
19

5. RESULTS
BACKGROb�'D RESEARCH
Prev�o,usly Krn ow i Architectural Resources
A reconnaissance -level architectural survey of Graham and Swain counties historic structures was
completed from 1997-1998 (Williams 1998), and a number of structures were recorded in and near
Robbinsville. Within a one -mile radius of the project tract, seven significant architectural resources are
recorded, with at least two nominated to or listed on the National Register of Historic Places (NRHP).
The resources include the Graham County Courthouse (listed on NRHP) (ca. 1942), Junaluska's Grave
(nominated to the NRHP) (ca. 1955), the Robbinsville Train Depot; the former Robbinsvillc High School
(now the elementary school), the farmer First Baptist Church and two late I SP- to early 20"'-century
houses in the downtown Robbinsville area. With the exception of Junaluska's Grave, which dates to the
mid-19'" century, all of the structures date to the late 191 to early 201' centuries. All of the structures,
while within a one mile radius, are sufficiently blocked from the proposed wastewater treatment plant by
distance and vegetation so their -view sheds would not be adversely affected by the proposed
development.
Knov�m and Potential Cemeteries
The published Graham County cemetery survey depicts the Wakefield Cemetery, which contains two
apparent 19"'-century graves, just north of the project tract; it is described as "located on crest of hill
behind Harry Owens house on the Old Wakefield Farm" (Millsaps and Millsaps 1992). Based on this
description, the cemetery is clearly located outside the project area. No evidence of any unrecorded
cemeteries was observed by TRC in the survey area.
Previously Known Archaeological Sites
The archaeological site files and records at the SHPO (Western Branch) contained information on six
previously recorded archaeological sites within a one mile radius of the project area; there were no
previously recorded sites within the immediate project area. The six sites located nearby include sites
31GH2, 31GH33, 31GH46, 31GH220, 31GH456, and 31GR101 (temporary field site number, official
site number apparently not assigned [Ayers 19761). These sites range from a surface scatter of prehistoric
artifacts (31GH2), to a presumed multicomponent prehistoric to historic Native American habitation site
(31 GH46), to the structural cement remains of a mid-20`''-century Civilian Conservation Corps camp
(3IGH456). None of the sites are considered eligible for the XRHP.
Historic Map Data and Potential Site Locations
The earliest detailed map showing the project area is the composite U.S. Army Corps of Engineers' map
constructed immediately prior to the Cherokee Removal. Although the detailed surveyor's notebooks for
the project vicinity cannot be located, the composite map (Williams 1838) bears the notation "Buffalo
Town" near the future site of Robbinsville (Figure 5.1), and depicts at least four structures near the
project. One of those is on the broad alluvial landform across the river south of the project tract, and
others are along the river to the north and soutb. None are on or adjacent to the project tract, however.
21

Figure 5.1. Williams (1838) map of the Cheoah Ril-ervalley.
22

More recent maps provide some information on late 191"- and 20'�-century developments in the project
area. The earliest detailed topographic map of the area dates to 1906 (liSGS 1906), it depicts a road
following the general course of US 129 past the project tract, but does not depict any structures in the
area. A subsequent and more detailed planimetric map dating to 1935 shows the general pattern of
settlement in the area, but does not show any structures on or adjacent to the project tract (USGS 1935)
(Figure 5.2).
ARCR_ >E0LOGICAL i~':iELD SUR�T_Y
The archaeological surrey of the Robbinsville WW-TP property- included excavation of 42 trausect and
delineation shovel tests (l figure 5.3), seven of which were auger probed at their base to search for intact
cultural levels. One small multicomponent prehistoric and historic site (31GH561/561**) was found in
the southeastern corner of the field/project area, west of the unnamed tributary and north of the Cheoah
River. Although artifacts were recovered from depths of up to 55 cm below surface, there was no
indication of deeply buried intact cultural surfaces. In fact, two shovel tests encountered PVC pipes (one
at 46 cm and one at 72 cm below surface) buried beneath disturbed soils.
31GH561/561y*
Component: Woodland to Protohistoric; 201' century historic
Site dimensions: 50 m e-w x 30 m n-s
UTNIs (NAD 27): E244625 N3913300
Landform: Cheoah Rimer floodplain
Elevation: ca. 1,960 ft A1�4sL
Soil Type: silty clay loam, some distizbance
Recommendation: Ineligible
Descriytion: Site 31GH561/561** is a very low -density prehistoric and historic artifact scatter situated in
disturbed soils, and is located in the southeastern corner of the open field in the floodplain north of the
Cheoah River and west of an unnamed tributary (Figure 5.3). The site is bounded to the north by
consecutive negative shovel tests, to the east by the urnanied tributary, and to the west and south by
consecutive negative shovel tests and the Cheoah River (Figures 5.4 and 5.5).
The former landowner stated that he had built the floodplain up over time by depositing soil and gravel,
and few shovel tests revealed consistent soil profiles. The soil profiles indicate apparent disturbed
contexts, often with modem debris (i.e., plastic, cloth) occurring beneath the prehistoric artifacts; gravel
and cobble deposits were also found in some shovel tests. One typical soil profile found in three of the
positive shovel tests involved a dark brown (10YR 3/3) silty clay loam A horizon, that extended to a
maximum depth of 30 cm below surface. That stratum was underlain by dark yellow ish brown (l OYR
4/6) silty clay that was from 15 to 20 cm thick and extended to 50 cm below surface. This stratum was
underlain by a 12 to 20 cm thick layer of yellowish brown (1 OYR 5/4) silty clay to strong brown (7.5YR
5/8) clay. This lower stratum gradually changed to yellowish brown (10YR 5/4) clay that continued up to
80 cm below surface.
Another soil profile found in two negative shovel tests near the road at the northern end of the site
involved a top layer of dark brown (7.5YR 3/4) silt loam extending to 30 cm below surface. This was
underlain by dark brown (7.5YR 3/3) silty clay extending to approximately 55 to 60 cm below surface.
Beneath this was reddish brown (SYR 4/4) clay extending to 75 cm below surface. An auger hole
excavated to 142 cm below surface revealed a soil change to yellowish brown (I OYR 5/4) loamy sand.
23

• i
�lytpn Cain
14
GGCCnt NO24
J /•' r • �.' Tu6%er Gap
Project area
f .
r �` rsnpiV *'~ �:3,� , 1 ;rw99EL;,.G,��
QBFINSViLL, 1
I o - " 1
r
IM
f AQ i
auN, ni p
CP
i�+file
W D 4000 No;I
h=ilamctu
Figure 5.2. USGS (1935) map showing the project vicinity.
24

Figure 5.3. Overview of the project area., facing northwest
25

res rxz TRJ
E460 E490 E500
I I I
A
Augertestatshovel test
O
Negative shovel tcz
O
Posifive prehistoric slave) less
Pnsipve prehistoric aid historic shovel lest
_
r — Sib! boundary
Approximnle contour line
I N520--
Nsoo—OA
M
Shed
lgi 4
O OA OA O
O O OA • O Q
` fo-
�@ a
l �r«e m
r
0 i
0 0 0 OA 0 • 1
0 r
N460— \. \ O O
?It x Q
k
C',s �
0 Mmers 15
1
t
Figure 5.4. Site 31GH561/561 ** at Robbinsville WWTP project area.
26

�" Jam' -ii S °C � r � 1, c f ,S7yifdff �Iff '-, ' - �'�' Y '� � t, � yP
. r' _
I � _
._ t7�• -_ m.tib. - _�
t - ' � � °.
Rom. ` g� {
� r� �'� 'fir � .. r .., - .. .- V 5 fI— % - --- '_
q'_`L - �_-- T i
!i .._ .__�.. - -__- - - -. — -

Fifteen artifacts (12 prehistoric and three historic) were recovered from nine positive shovel tests. The
artifacts includes 10 debitage fragments (eight quartz; one quartzite, and one chert), a fire cracked rock
(FCR) fragment, and a ceramic sherd with an unidentified surface treatment. The historic artifacts include
two pieces of clear bottle glass and a heavily corroded nail fragment. None of the artifacts are diagnostic
of a specific time period; although the single prehistoric ceramic sherd indicates a Woodland to
Mississippian occupation, and the historic artifacts date to the 20'b century.
Due to the extremely low density of artifacts, the absence of diagnostic artifacts from intact stratigraphic
contexts, and the presence of obviously disturbed soils, site 31 GH561/561 ** appears to have no research
potential. Consequently, this site is recommended ineligible for the NRHP.
28

6. SUINDIARY M\-D RECOMMENDATIONS
The background research for this project identified no previously identified structures, archaeological
sites, or cemeteries within the project area. A small 19'h century cemetery is reportedly situated on high
ground north of the project area, but will not be affected by construction of the wastewater treatment
plant.
The archaeological survey identified a single site; 3IGH561'561**. Site 31GH561l561** is a low -density
site in a disturbed context, and appears to have no research potential. Consequently, this site is
recommended ineligible for the N-RFIP, and no farther archaeological survey is recommmended for this
proj ect.
� 9

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39

APPENDIX 1: ARTIFACT INVENTORY

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ATTACIIMENT D
FWS CORRESPONDENCE

Urdted States Dga.rtnient of the hitei-10l
FISH AND WLL = SERVICE
Asheville Field Offace
160 7illicoa 5teet
Asheville, Noma Carolina 2SE01
January 15, 2009
Ms. Anna Salzb:.ra
Project Biologist
ClearWater Environmental Consultants, Lie.
718 Daldand Street
Hendersonville, North Carolina 29791
Dear Ms. Salzberg:
Subject: Listed Species Assess-ment, Robbinsville Wastewater Treatment Plant Site, Graham
Col- y, INlorth Carolina
In your letter. of December 15% 2008;-y6u requested:our. co=entonlhe subj'ectproject_ Nt,
have-reyiewedthc:Dfo=a'donyoupresented-and,;areprov-idurg htfol:awingcorrrments�n
accordance with the provisions -of the Fish .axi.dNildlife Coordi.nationAct, as amended.:
(16 U S.C.:-661-66Ne and section 7 afthe Endangered Species:Act of_1973, as amended:
(16 U.S.C. 1531-154-D) (Act).. .
Your letter does not include a description of the project or any potential impacts. It is impossible
for us to give a detailed assessment without a complete set of plans that includes the exact
location of the proj ect and specific details regarding project plans and construction techniques.
The purpose of tl�s letter is only to inform you of federally listed species that occur within the
geographical area indicated on the map you seat, and v,,c have included a detailed list of
information that will be required for us to fully assess the potential direct, indirect, and
cumulative impacts of any construction/development projects in this area.
Endangered Species. Based on the project location and infoianation you presented, there
appears to be suitable habitat for the federally threatened Virginia spiraea (Spri rczea virginial.a)
within the proposed protect area. flux records indicate that this species has been found near the
proposed project site. Your letter did not indicate whether surveys have been conducted for this
or other rare plant species within the project impact area. Unless the area has been specifically
surveyed for this listed species or no -appropriate habitat exists, a survey should be conducted to
ensue that this species is not. nad:vei tently lost. We reco=evdAhat surveys for this:spvcies be
conduatd Gene t1-zough J'aly).. Surveys -should be-conducttd along

the entire rout of the proposed utility line and at the proposed location oftl;'e r_.ew YT as.Ezvater
treatment plant.
In aCCorda=-e ;with the Act, bt ore airy federal authonzationlpermits or Sanding can be issued for
this project, it is the responsibility of the appropriate federal regulatory/perrnilmmcy agency(reS) to
determine whether the project may affect any federally endangered or ihreatened species (listed
species) or designated critical habitat. If it is determUled that this proj eCt nay affect any listed
species or designated critical habitat; section 7 consultation with this office mast be initiated.
At this stage of prof ect develop iciat L--nd without more specifics about construction locations and
.eclit�icliies, it _s difricult for us to assess potential cnZ,iyonmental impacts (direct, indirect, and
cumulative). We therefore recommend that any enmlron cr_tal cocunient prepared far this
project include the following (if applicable):
1. A complete analysis and comparison of the available alternatives (the build
and no -build alternativcs).
2. An assessineiit of any development that will impact the 140-year floodplaiil.
3. A description of the fishery and wildlife resources within existing and
required additional rights -of -way and any areas, such as borrow areas, that
may be affected directly or indirectly by the proposed project.
4. The acreage and a description of the wetlands that will be filled as a result of
the proposed project. Wetlands affected by the proposed project should be
mapped in accordance with the Federal Manual for Ident�ing and
Delineating Jurisdictional Wetlands. We recommend contacting the
U.S. Army Corps of Engineers (Corps) to determine the need for a
Section 444 Clean Water Act permit. Avoiding and minimizing wetland
impacts is a part of the Corps' pennitting process,' and we will consider other
potential alternatives in the re'View of any permits.
5. The extent (linear feet as v,=ell as discharge) of any water courses that will be
impacted as a result of the proposed project. A description of any streams
should iiiclude the classification (Rosgen 1995, 1996) and a description of the
biotic resources.
6. The acreage of upland habitat, by cover type, that will be eliminated because
of the proposed project.
7. A description of all expected secondary and cumulative envirc=eiital
impacts associated with this preposcd work. The assessment should specify
the extent and type of development proposed for the project area once the
work is complete and how future growth will be maintained and supported
,,with regard to sewer lines, water lines, parl�ing areas, ar_d any proposed
roadways,

$. � discussion about the exteri to �,-�Lch tl:e proj ect -twill resL�lt in The loss,
degradaticn, or i7agr entation of =,�IlLife habitat from direct cor_stn ciicn
impacts and mom secondary developinent impac-s
1•�itigation measures That -Mll be er_mloyed to a�-oid, eliminate, reduce, cr
compensate for habitat value losses (-weiland, riveiiue, and upland) associated
v,� ih any phase of T-e proposed project.
We appreciate the opporuiiy to provide these comments. rf tin e can be of assistance or if you
r asTe my, cuestions, p'_e? se do not hesitatc to contact nfx. Bry`zn Tompltins of our staff at
$2$1258-3939, Ext. ? 0. In am, futTxe co respcndmme concUrnirg this project, please refcrerice
our Log N-amber i 2-09-085.
5ip�.erely,
Brian P. Cole
Field Supervisor

ATTACHMENT E
VIRGINIA SPIRAEA SPECIES SURVEY REPORT

ClearWater Environmental Consultants, Inc.
www.c"Tenv.cam
Survey for Virginia Spiraea .(Spriraea virginiana)
Robbinsville WWTP
July 20, - 2010
1.0 INTRODUCTION
The following report details the results of the survey for the potential occurrence of
Virginia spiraea. (Spriraea virginiana) listed as" a federally threatened species and known
to occur in Graham County, NC. The US Fish and Wildlife Service (USFWS) provided
comments on the proposed relocation of the Robbinsville WWTP on January 15, 2009.
The USFWS recommended that a site specific survey be conducted for this species
(Virginia spiraea) during its flowering period (June -July). Surveys should be conducted
along the entire route of the proposed utility line and at the proposed location of the new
wastewater treatment plant.
The proposed Robbinsville WWTP is located immediately north of Robbinsville along
the Cheoah River, between river mile 17 and IS, in Graham County, North Carolina. The
proposed sewer line extension will provide a connection between the existing WWTP and
the proposed relocated WWTP. The sewer line extension will parallel US Highway 12.9
and Sandhole Road. The majority of the proposed sewer line extension is located within
the road right of way along US Highway 129 and Sandhole Road. A site vicinity map
(Figure l) and US Geological Survey (CJSGS) topographic map (Figure 2) are included
for review.
2.0 METHODOLOGY
The follow-up survey was conducted on July 19, 2010 by Clearwater Environmental
Consultants, Inc., Clement Riddle and Julie Mitchell, Botanist. The survey for Virginia
spiraea was conducted along the Chcoah River at the proposed site for the replacement
WWTP location and connector sewer line right-of-way (Figure 1).
Virginia spiraea habitat includes rocky flood secured riverbanks in gorges or canyons. The
river banks were walked and included in the survey. All species observed were identified
and recorded in the table below.
224 South Grove Street, Suite F
Hendersonville, NC 28792
828-698-9800 Tel
828-698-9003 Fax

PLANT LIST
WASTE WATER TREATMENT PLANT --FIELD WORK
PFRFORMFI) ATI,Y 19.2010
Static
Scieniifi`cNarne=
Cummun_Nxme`..
Canopy
Acer rubrum
red maple
Carpinus.carohniana
ironwood
Platdnus occidentalis
Anmrican sycamore
SaIix nigra
black willow
Understory
Ailanthus altissima
tree -of -heaven
Albizia julibrissin
mimosa
Halesia tetraptera var. tetraptera
common silverbell
Nyssa sylvatica
black gum
Shrub
Alnus serrulata
tag alder
Cornus ainomum
si]ky dogwood
Kalmia lati olia
mountain laurel
Leucothoe fontanesiana
dog hobble
Rhododendron maximum
rosebay rhododendron
Rosa multora
multiflora rose
Rubus s p.
blackberry
Salbc nigra
black willow
Herb
Agrimonia parviflora.
Southern agrimony
Ambrosia artemisiifolia
ragweed
AnemaneIla thalictroides
wind flower
Boehmeria cylindrica
false nettle
Cicuta maculata var. maculata
water hemlock
Eu atorium fistulosum
Joe-Pye- weed
Galium hi locum
bedstraw
Glechoma hederacea
ground ivy
Hylodesmum nud&rwn
tick -trefoil
Impatiens capensis
jewel weed
Lobehapuberula
downy lobelia
Maianthenium racemosum ssp.
racemosum
false Solomon's seal
Persicaiia. spp.
smartweed
Phytolacca americana
poke weed .
Polystichum acrostichoides
Christmas fern
Potentilla indica
Indian strawberry
Prunella vulgaris var. vulgaris
heal-all
Reynoutria ja onica
Ja anese knotweed
Sanicula canadensis var. canadensis
snakeroot
Thelypteris noveboracensis
New York fern
Trolium pratense
red clover
Verbesina alternifolia
common wingstcm
Yiola spp.
violet
XanthorhLa sim licissima
ye ot
Vine
Lonicera japonica
Japanese honeysuckle

Strariun
5cienhfic Name.'
Cdh 6vNm Fi�ae
Menis ermum canadense
moonseed
Smilax rotundifolia
common'greenbrier
Parthenocissus guinquefolia
Virginia creeper
_Toxicodendron-radicans
- poison ivy
Yitis aestivalis
summer. grape
Vitis rotundifolia van rotundifolia
muscadine
Grass/Sedge
Carex s p.
g
Cinna arundinacea.
Dichanthelium clandestinum
common woodreed
deertongue witchgrass
Mierostegium A.minium
Ngalese.browntop
CONCLUSION
During completion of our survey for the Robbinsville WWTP, Virginia spiraea was not
observed. It is the opinion of Clearwater Environmental Consultants, Inc. that Virginia
spiraea is not likely to be present within the site. As such, development of the proposed
Robbinsville WV+rTP is not likely to cause an adverse impact to this species.
Although no threatened and endangered species were identified during this survey,
because of the transitory nature of some of the listed threatened and endangered species
and the particular flower/fruiting periods of some plants, it is possible that endangered
species populations and locations may change over time. Therefore, any potential
findings at a later date should be fully investigated and coordinated with appropriate
agencies to prevent potential adverse impacts.

7.0 LIST OF PREPARERS
This report has been prepared through the efforts of the following organizations:
J. Meliski, PE
Bachelor of Science in Civil and Environmental Engineering, 1998
McGill Associates, P.A.
55 Broad Street, Asheville, North Carolina 28801
2. R. Clement Riddle, Professional Wetland Scientist
Bachelor of Science in Natural Resources, 1991
Master of Planning, 1998
Professional Wetland Scientist, 2009
ClearWater Environmental Consultants, Inc.
718 Oakland Street, Hendersonville, NC 28791
3. Paul Webb, Principal Archaeologist
Michael Nelson, M.A.
TRC Environmental Corporation
50101 Governors Drive, Chapel Hill, North Carolina 27517
Environmental Assessment 21 Town of Robbinsville
McGill Associates P.A. Wastewater Treatment Plant Relocation
July 29, 2010