20201125 Ver 1_WRC Comments_20161128

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: Lyn Hardison, Environmental Assistance and SEPA Coordinator
NCDENR Division of Environmental Assistance and Customer Services
FROM: Andrea Leslie, Mountain Region Coordinator n ��
Habitat Conservation
DATE: 28 November 2016
SUBJECT: Scoping for Cashiers Wastewater Treatment Plant, Sewer Lines, and Pump Stations
Jackson County
DEQ Project No. 17-0249
Biologists with the North Carolina Wildlife Resources Commission have reviewed the subject
document and we are familiar with the habitat values of the area. We received additional
Scoping documents from McGill Associates, which provided supplemental information to that
included in the SEPA documents. Our comments are provided in accordance with provisions of
the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667e) and the
North Carolina General Statutes (G.S. 113-131 et seq.).
The project proposes to build a new wastewater treatment plant (WWTP) to respond to current
and requested wastewater treatment capacity. In addition, the project proposes 7,840 feet of
sanitary sewer force main, 8,155 feet of gravity sewer line, an existing pump station upgrade,
and pump station replacement, all in pre -disturbed areas or along road right-of-way. This project
would supplement an existing 0.2 mgd plant on the Chattooga River by constructing a new 0.125
mgd plant and influent pump station on the Horsepasture River. Stream crossings would be
needed on the Horsepasture River and numerous tributaries.
The site proposed for the wastewater treatment plant is on a formerly forested parcel on the
Horsepasture River. A listed species and habitat assessment was performed for this parcel,
which concluded that the project was not likely to cause any adverse impact to any federally
listed species. Scrub -shrub wetlands were documented adjacent to the Horsepasture River, and a
portion of the proposed site is within the 100-year floodplain.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

17-0249 Scoping Cashiers WWTP Page 2 November 28, 2016
Jackson County
The Horsepasture River is home to the French Broad River Crayfish (Cambarus reburrus, US
Federal Species of Concern, NC Significantly Rare) and the Yellowfin Shiner (Notropis
lutipinnis, NC Special Concern). Both Rainbow Trout and Brown Trout are also found in the
Horsepature River in vicinity of the project. In addition, proposed sewer lines that would run
between Cashiers and the site would cross a number of tributaries to the Horspasture River and
the Chattooga River, some of which contain Brook Trout.
Our concerns regarding the WWTP discharge include impacts to water quality resulting from
ammonia, pharmaceutical and personal care products (PPCP)/endocrine disrupting compounds
(EDC), chlorine, and treatment plant upsets. In order to address these concerns, we recommend
the following:
• The WWTP should include measures (e.g., flow equalization and offline storage) to
ensure consistent effluent water quality and downstream protection from overflows. The
WWTP should provide a minimum of five days of storage for untreated or undertreated
wastewater. We are concerned about impacts to water quality, aquatic habitat, and
aquatic species should treatment upsets occur particularly during low flow periods (e.g.,
7Q10 or less). The Environmental Assessment (EA) should include a description of the
measures that will be used to store untreated or undertreated wastewater, as well as
measures used to ensure consistent effluent water quality and downstream protection
from overflows.
• Develop site -specific acute and chronic water quality standards for ammonia, using the
2013 USEPA's Aquatic Life Ambient Water Quality Criteria for Ammonia Freshwater.
• Studies have shown PPCP and EDC in municipal effluent can cause adverse
physiological effects to fish and freshwater mussels (Bouchard et al. 2009, Bringolf et al.
2010, Farcy et al. 2011, Gagne et al. 2011 a, Gagne et al. 201 lb, Liney et al. 2011, and
Vajda et al. 2001). The WWTP should be designed with technology that is known to
reduce or eliminate PPCPs and EDCs from wastewater. Some measures that appear to
provide effective reduction or elimination of these emerging contaminants include
membrane bioreactors, granular activated carbon, powdered activated carbon, ozonation,
and combinations of these treatment technologies. The EA should provide a discussion
on emerging contaminants, particularly PPCPs and EDCs, and the treatment measures
that will be used in the WWTP to reduce or eliminate these from the effluent.
• Finally, the disinfection system should use ultraviolet light or ozone instead of chlorine.
Chlorine is acutely toxic to aquatic organisms and can form secondary compounds that
are detrimental to aquatic life.
We are concerned about the secondary and cumulative impacts resulting from development
facilitated by the project. The Environmental Assessment (EA) should include a summary of
ordinances as they pertain to riparian buffer, floodplain, and open space protection, impervious
surface limits and stormwater management, and sediment and erosion control. Adopting
ordinances that protect wide forested riparian corridors and the 100-year floodplain along with
adequately treating stormwater in development areas are essential to protect water quality and
aquatic habitat in developing landscapes. We recommend that the Water Authority refer to the
Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to Aquatic
and Terrestrial Wildlife Resources and Water Quality

17-0249 Scoping Cashiers WWTP Page 3 November 28, 2016
Jackson County
(hLtp://www.ncwildlife.org/Portals/O/Conserving/documents/2002 GuidanceMemorandumforSec
ondaryandCumulativelmpacts.pdf ) for specific recommendations.
In addition, we have the following general recommendations:
1. Maintain a minimum 100-foot undisturbed, native, forested buffer along perennial
streams, and a minimum 50-foot buffer along intermittent streams and wetlands.
Maintaining undisturbed, forested buffers along these areas will minimize impacts to
aquatic and terrestrial wildlife resources, water quality, and aquatic habitat both within
and downstream of the project area. Also, wide riparian buffers are helpful in
maintaining stability of stream banks and for treatment of pollutants associated with
urban stormwater. In addition, these buffers will provide an adequate travel corridor for
wildlife species.
2. Avoid or minimize impacts to wetlands during construction. In addition to providing
wildlife habitat, wetland areas perform important functions of flood control and water
quality protection. Temporarily disturbed wetland areas should be returned to original
soils and contours, and reseeded with annual small grains appropriate for the season (e.g.
oats, millet, rye, or wheat) and should be allowed to revert to natural wetland vegetation.
3. The directional bore (installation of utilities beneath the riverbed, avoiding impacts to the
stream and buffer) stream crossing method should be used for utility crossings wherever
practicable, especially on streams that contain Brook Trout. The open cut stream
crossing method should be used only when water level is low and stream flow is
minimal.
4. The road crossing on the Horsepasture River should be a bridge or other spanning
structure in order to maintain upstream and downstream channel stability and aquatic
organism passage.
5. Construction within the I00-year floodplain should be avoided.
6. Sediment and erosion control measures should be installed prior to any land clearing or
construction. These measures should be routinely inspected and properly maintained.
Excessive silt and sediment loads can have numerous detrimental effects on aquatic
resources including destruction of spawning habitat, suffocation of eggs, and clogging of
gills of aquatic species.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if there are any questions about these comments.
Literature cited:
Bouchard, B., F. Gagne, M. Fortier, and M Fournier. 2009. An in -situ study of the impacts of
urban wastewater on the immune and reproductive systems of the freshwater mussel Elliptio
complanata. Comparative Biochemistry and Physiology Part C: Toxicology and Pharmacology
150(2):132-140.
Bringolf, R.B., R.M. Heltsley, J.T. Newton, C.B Eads, S.J. Fraley, D. Shea, W.G. Cope. 2010.
Environmental occurrence and reproductive effects of the pharmaceutical fluoxetine in native
freshwater mussels. Environmental Toxicology and Chemistry 29(6):1311-1318.

17-0249 Scoping Cashiers WWTP Page 4 November 28, 2016
Jackson County
Farcy, E., F. Gagne, L Martel, M. Fortier, S. Trepanier, P. Brousseau, M. Fournier. 2011. Short-
term physiological effects of a xenobiotic mixture on the freshwater mussel Elliptio complanata
exposed to municipal effluents. Environmental Research 111(8):1096-1106.
Gagne F., C Andre, P. Cejka, R. Hausler, and M Fournier. 2011a. Evidence of neuroendocrine
disruption in freshwater mussels exposed to municipal wastewaters. Science of the Total
Environment 409(19):3711-3718.
Gagne F., C Andre, P. Cejka, R. Hausler, and M Fournier. 201 lb. Alterations in DNA
metabolism in Elliptio complanata mussels after exposure to municipal effluents. Comparative
Biochemistry and Physiology Part C: Toxicology and Pharmacology 154(2):100-107.
Liney, K.E. J.A. Hagger, C.R. Tyler, M.H. Depledge, T.S. Galloway, and S. Jobling. 2011.
Health effects in fish of long-term exposure to effluents from wastewater treatment works.
Environmental Health Perspectives, April, 114 (Suppl 1): 81-89.
ec: John Swaim, McGill Associates
Allen Ratzlaff, US Fish and Wildlife Service
Steve Fraley and Powell Wheeler, NCWRC