NC0085359_staff comments_19950809

DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
August 9,1995
MEMORANDUM
TO: Bobby Blowe
Construction Grants
FROM: Steve W. Tedder
SUBJECT: Proposed Twelverru�€Creek Wastewater Treatment Plant
Union County 201 Facilities Plan
The Water Quality Section staff continue to have concerns with the proposed wastewater
treatment plant discharge to Twelvemile Creek in Union County. As stated in previous
memoranda dated September 16,1994 and February 20,1995, in order to issue an NPDRS permit
for a discharge, the Division must find, in accordance with North Carolina General Statute
§143-215.1(b)(2), that the proposed system is the practicable waste treatment and disposal
alternative with the least adverse impact on the environment.
Each successive report on the Union County proposed discharge has provided additional
clarification on the need and the alternatives available to the County. However, the
overriding issue of organized planning for wastewater needs remains unresolved. This is
particularly of concern with the Twelvemile Creek proposed facility as a result of the
proximity to the Charlotte Mecklenburg Utility District (CMUD) Six Mile Creek interceptor.
As stated in the previous request for additional information on the CMUD alternative, full
documentation from CMUD must be submitted to support the cost figures provided in the report.
It is interesting to note that with each successive report the cost of this alternative continues to
rise, but the requested documentation is not provided to support the figures.
The lack of overall planning for growth and the subsequent wastewater disposal needs has been
demonstrated numerous times. Examples date back several years and include:
1.
The construction and operation of sewer collection projects without obtaining the required
permits. This action overloaded the Dry Fork spray irrigation operation by a factor of
greater than 2.5 times the permitted capacity and likely contributed to the current
compliance problems at this facility (groundwater issues).
2. In 1993 meetings on the Crooked Creek wastewater treatment plant with staff, Union
County officials indicated that the maximum need at this facility would not exceed 1.9
MGD at ultimate buildout. Since that time, the staff have received requests for
speculative analyses for a discharge of up to 6 MGD. Additionally, part of the
Twelvemile Creek proposal is to re-route some of this flow out of the Crooked Creek
wastewater facilities.
3. Union County has also verbally committed to eliminating a series of existing small
wastewater treatment plants to prevent proliferation of new facilities in the Six Mile
Creek drainage basin through connection to the CMUD interceptor. However, the Water
Quality staff have not been able to obtain any firm written commitment from the County.

Staffs understanding is that CMUD has forwarded a proposal to Union County on the
details for implementing an agreement on sewer service to the Union County Six Mile
Creek drainage basin, to which there has been no official response.
4. In reviewing the various documents, Crooked Creek and Twelvemile Creek proposals, the
staff continue to find what appear to be overlapping areas of service for the two
wastewater treatment plants. Additionally, the issue of eliminating an existing grant
funded wastewater treatment plant (Waxhaw spray system) that is properly functioning
appears not to have been addressed.
The amended 201 Facilities Plan does provide some of the additional information and more
specific detail as requested in the previous memoranda. However, there are still
inconsistencies in the numbers (the summary of numbers in worksheet 1 in the present worth
analysis do not match the numbers in the calculation sheets for alternative 2) and missing
information, such as not including the limit for Chronic Toxicity as recommended in the
speculative limits and further mentioned in the 2/20/95 memorandum on the project, the
documentation from CMUD, or documentation of the present worth calculations.
The Water Quality Section acknowledges that significant growth is occurring in the western
portion of Union County as a result of the proximity to the Charlotte -Mecklenburg area and
concur that the County must develop plans to address the wastewater needs associated with
that growth. However, unless an overall coordinated planning effort is undertaken, the staff is
concerned that the most cost effective and environmentally sound alternative will not be
implemented. The end result may be continued inefficiencies, higher wastewater disposal costs
and detrimental water quality impacts.
cc: A. Preston Howard, Jr., P.E.
Rex Gleason, MRO
Don Safrit
Ruth Swanek
Monica Swihart