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HomeMy WebLinkAboutNC0048861_Staff Comments_20111031NPDES DOCUMENT SCANNINL COVER SHEET NPDES Permit: NC0048861 Creswell WWTP Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Correspondence Owner Name Change 5714 (Ixte e4 Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Document Date: October 31, 2011 This document is printed on reuse paper - ignore any content on the reYerse side 1--;U October 31, 2011 To: Hannah Headrick Subject: Comments on ERR for Collection System to Creswell WWTP NC0048861 DENR # 12-0103 DWQ # 14400 From: Ron Berry, DWQ/ NPDES Complex Permitting ` 1 This ERR is for the addition of a new STEP collection system to accept domestic wastewater from Scuppernong Township, and connect to the existing Creswell WWTP NC0048861 for treatment. The Division considers this part of the approved expanded capacity for Creswell WWTP which means the WWTP treatment capacity for 0.2 MGD must be operational to accept this new influent. The existing non -expanded treatment works has numerous problems and does not use BAT and cannot accept any new influent sources. The ERR does mentions the treatment works will be expanded to 0.2 MGD but does not clearly state that the required expanded capacity will be operational prior to accepting the Scuppernong Township domestic wastewater. Technical correction 2.1.3 "secondary standards" show be "equivalent to secondary standards". Direct application of secondary standards ref +wire the facility to meet 85% removal of BOD and TSS. Note: Tracking sheet and cd returned with comments attached. RE DWQ#14400 - Creswell and Scuppernong Township project From: Berry, Ron Sent: Monday, October 31, 2011 11:21 AM To: Headrick, Hannah Cc: Belnick, Tom Subject: RE: DWQ#14400 - Creswell and Scuppernong Township project Hannah, A modified NPDES permit was issued in July 2009 for an upgrade treatment system with a permitted flow of 0.2 MGD. The upgrade replaces a antiquated treatment lagoon system with problems with a modern system. There is no reopener condition in the NPDES permit so any comments related directly to the NPDES permit discharge should be made at the next schedule renewal we have no further comments to offer. Ron Ron Berry ron.berry@ncdenr.gov Engineer I DWQ/Point Source/NPDES Complex Permitting Unit NCDENR Phone: (919) 807-6396 Fax: (919) 807-6495 office: Archdale Building Room 925N Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Headrick, Hannah Sent: Monday, October 31, 2011 11:03 AM To: Berry, Ron Subject: FW: DWQ#14400 - Creswell and Scuppernong Township project Further info from Heather. Hannah Headrick, DWQ's SEPA Coordinator ***Please note my new name and email address (hannah.headrick@ncdenr.gov)*** (919) 807-6434 Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical location: 512 N. Salisbury Street, Raleigh, NC 27604 http://portal.ncdenr.org/web/wq/ps/sepa E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Patt, Heather Sent: Monday, October 31, 2011 11:02 AM To: Headrick, Hannah Subject: RE: DWQ#14400 - Creswell and Scuppernong Township project Thanks Hannah, Sorry I didn't explain further I thought I was going to be out today so I wanted to get comments to you... I have in my notes from a previous conversation with someone -maybe WARO, that Creswell actually wanted nutrient removal but the CWMTF didn't want to fund them for that, b/c there was no documented need for it.... since we don't impair waters based on duck & Page 1 RE DWQ#14400 - Creswell and Scuppernong Township project alligator weed (which is just really big chlorophyll a). This facility needs nutrient reductions, as it's just a matter of time before the little chlorophyll a's become a problem. (although we don't do much monitoring in this region, so who knows when it will actually get detected) From: Headrick, Hannah Sent: Monday, October 31, 2011 10:39 AM To: Belnick, Tom Cc: Berry, Ron; Patt, Heather; Painter, Andy Subject: RE: DWQ#14400 - Creswell and Scuppernong Township project Ron sent me his comments and I forwarded him Heather's concerns. Hannah Headrick, DWQ's SEPA Coordinator ***Please note my new name and email address (hannah.headrick@ncdenr.gov)*** (919) 807-6434 Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical location: 512 N. Salisbury Street, Raleigh, NC 27604 http://portal.ncdenr.org/web/wq/ps/sepa E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Belnick, Tom Sent: Monday, October 31, 2011 10:38 AM To: Headrick,Hannah Cc: Berry, Ron Subject: RE: DWQ#14400 - Creswell and Scuppernong Township project I'm confused- we already issued permit for expansion. Ron is lead on this one. Tom Belnick Supervisor, Complex NPDES Permitting Unit NC DENR/Division of Water Quality 1617 Mail Service Center, Raleigh, NC 27699-1617 (919) 807-6390; fax (919) 807-6495 E-mail correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. From: Headrick, Hannah Sent: Monday, October 31, 2011 8:10 AM To: Belnick, Tom subject: DWQ#14400 - Creswell and scuppernong Township project Tom - Heather's comment is that nutrient removal should be required and not just a possibility for this proposed upgrade due to duck weed and alligator weed problems in the nutrient sensitive (although not classified NSW) Scuppernong River. Please pass this along to whoever you have reviewing this so we can get any necessary dialogue/hashing of comments rolling before this one gets close to the due date. Thanks. Hannah Headrick, DWQ's SEPA Coordinator ***Please note my new name and email address (hannah.headrick@ncdenr.gov)*** (919) 807-6434 Page 2 • RE DWQ#14400 - Creswell and Scuppernong Township project Mailing address: 1617 Mail Service Center, Raleigh, NC 27699-1617 Physical location: 512 N. Salisbury Street, Raleigh, NC 27604 http://portal.ncdenr.org/web/wq/ps/sepa E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. Page 3 Pt2A/// •ibt4,4 fi/ •StY4 revtoit- /0 Ac.) i/ ---- /00 bite cre /viedttrl obe*o tee/A/4C el toitro,,t),01 Wastewater Treatment and Collection System and Water Supply Line Improvements Washington and Tyrrell Counties, N.C. USDA RURAL DEVELOPMENT NEPA ENVIRONMENTAL REPORT 22 September 2011 Lead Agency Contact: Mr. Doug Causey USDA Rural Development 403 Government Circle, Suite 3 Greenville, NC 27834 252-752-2035 (phone) 252-931-0560(fax) Mr. Bill White Mayor, Town of Creswell PO Box 68 Creswell, NC 27928 (252) 797-485 Municipal Contact: Engineering Contact: Mr. Gary D. Hartong, P.E. 301 West 14th Street Greenville, NC 27834 (252) 757-1096 Prepared By: Mr. Willie Mac Carawan. Manager, Tyrrell County PO Box 449 Columbia, NC 27925 (252) 796-1371 Robert J. Goldstein & Associates, Inc. ENVIRONMENTAL CONSULTANTS 1221 Corporation Parkway, Suite 100 Raleigh, NC 27610 Tel (919) 872-1174 Fax (919) 872-9214 RJG&A Project No. 10037 TABLE OF CONTENTS Executive Summary 3 1.0. Purpose and Need for the Project 4 1.2. Purpose and Need 4 2.0. Alternatives to the Proposed Action 5 2.1 Wastewater Treatment 5 2.1.1 No Action 5 2.1.2 Optimization of Existing Facilities 6 2.1.3. Regionalization with the Creswell WW TP (Preferred Alternative) 7 2.2 Wastewater Collection 7 2.2.1 Low -Pressure Septic Tank Effluent Pump (STEP) System 7 2.2.2 Gravity Collection System 8 2.2.3 Vacuum Collection System 8 2.3 Waterline 8 2.3.1 No -Action Alternative 8 2.4.1 Preferred Alternative 8 3.0. Affected Environment and Project Impacts 9 3.1. Land Use 9 3.1.1. General Land Use 9 3.1.2. Important Farmlands 11 3.1.3. Formally Classified Public Lands 11 3.2. Floodplains 12 3.2.1. Affected Environment 12 3.2.2. Project Impacts 12 3.2.3. Mitigation 12 3.3. Wetlands 13 3.3.1. Affected Environment 13 3.3.2. Project Impacts 13 3.3.3. Mitigation 14 3.4. Historic Properties 14 3.4.1. Affected Environment 14 3.4.2. Project Impacts 14 3.4.3. Mitigation 15 3.5. Biological Resources 15 3.5.1. Affected Environment 15 3.5.2. Project Impacts 16 3.5.3. Mitigation 16 3.6. Water Resources 17 3.6.1 Affected Environment 17 3.6.2. Project Impacts 18 3.6.3. Mitigation 19 3.7. Coastal Resources 20 3.7.1. Affected Environment 20 3.7.2. Project Impacts 20 3.7.3. Mitigation 20 3.8. Socio-Economic and Environmental Justice 22 3.8.1. Affected Environment 22 3.8.2. Project Impacts 22 3.8.3. Mitigation 22 3.9. Miscellaneous Issues 22 3.9.1. Air Quality 22 3.9.2. Transportation 23 1 3.9.3. Noise 23 4.0. Summary of Mitigation 24 4.1. Measures to Avoid and Minimize Direct Impacts 24 4.2. Tyrell County Flood Damage Prevention Ordinance 24 4.3. Tyrrell County Subdivision Ordinance 25 Literature Cited 25 5.0. Correspondence 28 5.1. Scoping Materials Sent to USEPA, USACOE, FEMA, and USFWS 15 October 2010 28 5.2. Responses to Federal Scoping Received as of 30 November 2010 48 5.3 Response to Scoping Comments Submitted to Federal Agencies, 15 October 2010 55 5.4. Summary of Environmental Review Comments 2007-2008 56 6.0. Exhibits 693 Table 1.0 Soil Impacts in the Service Area and Project Construction Area Table 2.0 Estimated Wetland and Stream Impacts in the Project Construction Area Table 3.0 Protected Animal and Plant Species Table 4.0 Summary of Air Quality Monitoring Data Figure 1.0 Service Area Figure 2.0 Soils in Project Area Figure 3.0-3.1 FEMA Flood Hazard Zones in the Project Area Figures 4.0-4.11 Wetland and Stream Impacts in the Project Construction Area Figure 5.0 Surface Water Qualifications in the Project Area Figure 6.0 Recreation Areas, Historic Sites, and Protected Species in the Project Area State and Federal Permits Required CAMA Permit FEMA Form 81-93 7.0. List of Preparers 119 APPENDICIES APPENDIX A APPENDIX B APPENDIX C APPENDIX D Vegetation and Wildlife Communities in the Project Area Protected Species Descriptions Civil Rights Impact Analysis Certification Tyrrell County Septic System Survey 2 Executive Summary Robert J. Goldstein and Associates (RJG&A) has prepared an environmental review (ER) pursuant to the National Environmental Policy Act for the Town of Creswell and TyreII County's Scuppernong Township Low Pressure STEP System. The lead agency is USDA Rural Development (RD). The 23-square mile Scuppernong Township in Tyrrell County is unsewered. Residential and commercial establishments dispose of wastes using pit toilets, straight piping, and septic systems. A 2001 survey by The Wooten Company found 24% of homes surveyed used straight piping and 33% had poorly functioning septic systems that were close to failure. The predominant soils in the service area are poorly suited for septic absorption fields due to wetness and slow percolation. The lack of topographic relief with much of the project area less than 10 feet above mean sea level presents an additional challenge to septic systems. A regional solution is needed to eliminate known and suspected septic tank failures, outhouse pit -toilets, and straight -piping wastewater disposal. Scuppernong Township in cooperation with the Town of Creswell in Washington County, proposes to replace its.insufficient and failing wastewater disposal facilities a new low pressure septic tank effluent pump (STEP) sewer collection system. The system will include with 31 miles of force main, two pump stations, and two main trunk lines. The project will be constructed mostly within roadside right-of-way. To accommodate increased flows the existing Creswell wastewater treatment plant (WVVfP) (NPDES Permit NC0048861) will be upgraded from 0.064 to 0.2 MGD using membrane bioreactor (MBR) technology to produce reuse quality effluent. This project will enable abandonment of Creswell's three existing wastewater lagoons. The new collection lines will transfer wastewater from Tyrrell County's Scuppernong Township to the Town of Creswell's upgraded WWTP with discharge to the Scuppernong River in Washington County. The STEP system will serve Scuppernong Township's existing 320 homes and businesses, the Eastern 4-H Environmental Education Conference Center off Bulls Bay Road, and limited future residential development all within Tyrrell County. As part of the same project, 1.75 miles of 6-inch waterline will be installed along the northern side of US 64 and US 94. This line will improve water pressure and fire flows to existing users in the area and provide potable water for several commercial and residential establishments currently relying on wells. All above -ground improvements associated with this project will be constructed to remain operational during the 500-year flood event through either fill or flood -proofing above flood elevations. This report contains descriptions of environmental resources in the project area, possible impacts, and efforts to mitigate these impacts. Information used in completing this report was obtained through on -site reconnaissance by RJG&A biologists, supplemental literature, and information obtained from the project engineers (The Wooten Company), and state and federal resource agencies. A description of the proposed project was sent to the US Fish and Wildlife Service, Federal Emergency Management Agency, US Environmental Protection Agency, and US Corps of Engineers on 15 October 2010. Scoping of the North Carolina state agencies and the State Historic Preservation Office occurred in 2007. Responses to scoping and comments to an original draft EA can be found in Section 5.0, Once accepted by RD as their environmental review document for the proposed project, this report will be made available to the public for review and comment. The availability will be advertised in local newspapers with a distribution covering the entire service area, and will include instructions for obtaining a copy, submitting comments, and the timeframe within which comments must be received. 3 1.0. Purpose and Need for the Project 1.1 Project Description Scuppernong Township in Tyrrell County, in cooperation with the Town of Creswell in Washington County, proposes to remedy its insufficient and failing wastewater disposal facilities with a new low pressure septic tank effluent pump (STEP) sewer collection system. The project includes 31 miles of force main, including two pump stations and two main trunk lines. The project will be constructed mostly within roadside right-of-way (Figure 1.0). To accommodate increased flows the existing Creswell wastewater treatment plant (WVVTP) (NPDES Permit NC0048861) will be upgraded from 0.064 to 0.2 MGD using membrane bioreactor (MBR) technology to produce reuse quality effluent. This project will enable abandonment of Creswell's three existing wastewater lagoons. The new collection lines will transfer wastewater from Tyrrell County's Scuppernong Township to the Town of Creswell's upgraded VVWTP with discharge to the Scuppernong River in Washington County. The STEP system will primarily serve Scuppernong Township's existing 320 homes and businesses, the Eastern 4-H Environmental Education Conference Center off Bulls Bay Road, and limited future residential development all within Tyrrell County, replace inadequate or failing existing septic and unconnected disposal systems, and upgrade effluent quality at the Creswell treatment and disposal facility. Included in the funding for wastewater system improvements is approximately 1.75 miles of 6- inch waterline that will close a hydraulic loop for the Town of Creswell's water system (Figure 1.0). This waterline, from Alligood Road west along the north side of US 94, will provide better water pressure and fire flows to existing users in the area and provide potable water for several commercial and residential establishments on this segment of US 94. The waterline will be constructed on the same side of the road and located between 11 and 20 feet from the proposed sewerline. No additional impacts will result from the waterline construction except minimal temporary impacts to land use and habitats, which have been included in the sewer impact calculations and mitigation discussions. 1.2. Purpose and Need The population in Tyrrell County in 2005 was 4,203, with approximately 673 persons in the Scuppernong Township project area. Population growth in Tyrrell County between 1990 and 2000 was 7.1 %, compared to the 21.4% growth for the state overall. Unemployment in 2005 averaged 7.3% and the poverty rate in 2004 stood at 22.2% (US Census Bureau, 2007). The North Carolina Department of Commerce (NCDC) classifies Tyrrell County as an economically depressed Tier 1 county (NC Dept. of Commerce, 2007). Wastewater collection and disposal in the Scuppernong Township project area is inadequate or non-existent, with wastewater straight - piped to ditches and the use of outhouses and poorly functioning septic systems widespread. A 2003 survey conducted by the Martin -Washington -Tyrrell County Health Department revealed that approximately 24% of systems had straight piping, 19% showed signs of surfacing effluent, 23% were constructed on inadequately -sized lots, and 33% were in threat of imminent failure. The 4H Environmental Conference Center also owns and operates an onsite low pressure pipe wastewater disposal system that is inadequately sized to treat projected wastewater flows. The widening of US 64 to a four -lane road may increase residential and commercial development, putting additional stress on natural systems. In the absence of public wastewater collection and treatment, untreated wastewater would continue to be introduced to the environment and adverse impacts to Tyrell County's natural systems will increase over time. 4 Creswell owns and operates the Creswell VWVTP, that has a permitted flow of 64,000 gallons per day (GPD) and discharges to the Scuppernong River. According to the September 2007 DWQ Pasquotank River Basin Basinwide Water Quality Plan, the Creswell VVVVTP reported significant non-compliance issues with biochemical oxygen demand (BOD) and in January of 2007, received civil penalty assessments and a Notice of Violation (NOV) for BOD violations (N.C. Division of Water Quality, 2007a). To remedy the issues discussed above, and to accommodate flows from the Scuppernong Township, the Creswell WWTP must expand and upgrade its operations. The 23 square mile Scuppernong Township service area is unsewered. Residential and commercial establishments dispose of wastes using pit toilets, straight piping, and septic systems. A 2001 survey by The Wooten Company found 24% of 82 homes surveyed used straight piping and 33% had poorly functioning septic systems close to failure. The results of this survey are included as Appendix C. The predominant soils in the service area are severely limited septic absorption fields due to wetness and slow percolation. The lack of topographic relief with much of the project area less than 10 feet above mean sea level presents an additional challenge to septic systems. A regional solution is needed to eliminate known and suspected septic tank failures, outhouse pit -toilets, and straight -piping wastewater disposal in the Scuppernong Township 2.0. Alternatives to the Proposed Action 2.1 Wastewater Treatment Although not discussed in detail herein, Tyrrell County initially considered construction of its own facilities, and merging with the adjacent Town of Columbia treatment system. Neither option was considered viable for the County. Acquiring a new NPDES permit for the area, given its relatively low service needs was determined to be both time and cost prohibitive. The Town of Columbia declined the request to extend sewer service westward and northward of the Scuppernong River, which it considers its natural service area boundary. Given these restrictions, four alternatives for providing sewer service to Scuppernong Township are presented below: 1) No Action, 2) Optimization of Existing Facilities, 3) Non -Discharge, and 4) Regionalization with Creswell's WWTP. 2.1.1 No Action Under the no -action alternative, the Scuppernong Township service area would continue repairing and/or building onsite septic systems. Most existing septic systems in Scuppernong Township are not maintained and either failing or in danger of failure. Straight piping of gray water into ditches is common (Appendix C). These conditions impact both ground- and surface water in the proposed service area and adjacent Albemarle Sound. The Washington and Tyrell County Governments have come under pressure to address public health concerns associated with inadequate wastewater treatment options. The existing three - cell facultative lagoon treatment system in Creswell would continue to operate as is. This would do nothing to accommodate projected growth in the Creswell area, or to remedy the severe on - site wastewater disposal problems in the Scuppernong Township service area. Light commercial and residential growth may follow the recent expansion of US 64 in the proposed service area to a four lane highway, and area soils are inadequate to support on -site septic systems. Additionally, the recently completed Eastern 4H Environmental Education and Conference Center's existing low pressure pipe field system is inadequately sized, and incapable of providing year-round treatment for the facility. 5 This alternative would do nothing to accommodate projected growth in the service area, remedy existing straight -pipe discharges and failing septic system public health concerns, or provide service to the area's new 4H facility, and was not considered further. 2.1.2 Optimization of Existing Facilities The existing Creswell WVVfP design offers limited operational flexibility to manage variations in flow volume and influent pollutant loads. In the mid 1980s the plant functioned well under its current design. This was a time of declining population and no demonstrated need from major water consuming commercial or industrial users. However, solids build-up in the system has resulted in sporadic violations of the Total Suspended Sediment (TSS) effluent limits. Due to the relatively simple nature of the existing three -cell facultative lagoon system, no significant operational changes can be made to adjust the treatment process. This alternative would not achieve compliance with current effluent limits given the projected increase in users and proposed service area expansion. This alternative was not considered further. 2.1.3 Non -Discharge (Land Application and Wastewater Reuse) 2.1.3.1. Land Application The land application alternative would be to construct a non -discharge spray irrigation facility with an onsite treatment/storage lagoon. Soil moisture limits for most soils in the study area for use as spray irrigation facilities. Areas with prime farmland soils such as Altavista, Augusta, or Conetoe series soils and little or no development would be the best application sites. A hydraulic water balance indicates that a 33.1 million gallon storage and stabilization lagoon would provide a detention time of 63 days. Approximately 110 acres (92-acre sprayfield, 8-acre lagoon, and 10-acre buildings) would be needed for sprayfield construction. Estimated land acquisition and construction costs are $3.5 million and annual operation and maintenance costs are $100,000. Four potential sites were identified, but were later eliminated because of inadequate size and soil conditions, interference with agricultural operations, or projected land use changes near U.S. 64. Most suitable locations in this area contain multiple drainage ditches which require buffers when associated with land application. These buffers substantially limit the usable acreage on suitably -sized parcels. This alternative was determined to be both land- and cost -prohibitive and was not considered further. 2.1.3.2. Wastewater Reuse To be in compliance with North Carolina reuse water regulations, wastewater must be highly treated. The existing three -cell facultative lagoon secondary treatment system is not sufficient to provide these levels of treatment. The lack of reuse customers in the area also render this alternative difficult to pursue as a dedicated disposal method. NC Administrative Code 2T wastewater design rules stipulate 120 gallons per capita per day in the absence of site -specific information. The per capita water consumption within the Tyrrell County Water and Sewer Districts is 50 gallons per day for most users. This disparity is largely due to plentiful groundwater resources in the area. The groundwater level is at or near the ground surface in much of the study area. Even during growing season, depths to groundwater greater than six feet are rare. Under these circumstances, reuse water has virtually no value to potential irrigation customers. Also, the quality of local groundwater requires softening prior to human consumption. The softening process produces water with a high sodium content that limits its usefulness for irrigation. Irrigation with high sodium water creates the need for gypsum addition, meaning that a knowledgeable prospective irrigation customer may request compensation to accept the water, rather than pay to receive the reclaimed water. 6 Reuse is not a practical alternative for the Town of Creswell's treated wastewater, and for the Tyrrell County Water and Sewer Districts. Producing and transporting reclaimed water would increase operational costs. These costs would offset by additional sewer user charges, already expected to be disproportionately high in comparison to median household incomes. This alternative is cost prohibitive and not feasible in the project service area, and was not considered further. 2.1.3. Regionalization with the Creswell WWTP (Preferred Alternative) Under this alternative, wastewater collected in the Scuppernong Township service area of Tyrrell County will be transported to the Town of Creswell's VVWTP for treatment and disposal. Creswell operates a 64,000 GPD lagoon system providing secondary treatment and discharges to the Scuppernong River. The Town of Creswell will provide sewer service to development within and beyond its corporate limits. However, the additional wastewater will require the Creswell WWTP to upgrade and expand its capacity. This alternative requires minimal land disturbance, and•operation and maintenance costs would be shared by Tyrrell County and the Town of Creswell. The anticipated cost for upgrading and expanding Creswell's WWTP to provide 0.2 MGD of tertiary treatment is $4.47 million. The treatment system under consideration is a state-of-the-art membrane bioreactor (MBR) system. MBR systems are capable of producing effluents meeting state reuse quality criteria and can be configured to provide nutrient removal capabilities. Creswell has an existing NPDES permit, and because of the improved effluent quality expected from an upgraded MBR tertiary treatment facility, it is expected that NC DWQ will permit the expansion. Upgrade of the existing Creswell \NWTP from a .064 MGD three -cell facultative lagoon secondary treatment facility, to a 0.2 MGD MBR tertiary treatment facility discharging to Scuppernong River is the preferred alternative for providing wastewater treatment in the service area. Conjunctive reuse of effluent was explored (subsection 3, above), but was determined to not be feasible because no reuse opportunities exist in the service area and the cost of transporting treated wastewater is prohibitive. 2.2 Wastewater Collection The proposed regional Town of Creswell WWTP would serve the Town of Creswell and Tyrrell County Water and Sewer Districts. The Tyrrell County Water and Sewer Districts do not own or operate any wastewater collection facilities within the proposed service area. The Town of Creswell operates a low pressure septic tank effluent pump (STEP) system. Each customer discharges wastewater via gravity to a septic tank which settles out solids and traps oil and grease. The clarified effluent from the tank is then pumped via a low horsepower (0.4 hp) pump through a series of small diameter force mains before discharging to the Creswell WWTP. Creswell's STEP system was built in 1981 and serves approximately 185 residential, 30 commercial, and one institutional customers. The system is comprised of 30,700 linear feet of 2- inch, 22,500 linear feet of 3-inch, 6,400 linear feet of 4-inch, and 900 linear feet of 6-inch poly- vinyl chloride (PVC) main piping. Creswell is responsible for maintaining septic tanks and effluent pumps. No upgrade to the Creswell WWTP's current service area is proposed. 2.2.1 Low -Pressure Septic Tank Effluent Pump (STEP) System Under this collection system alternative, a 31-mile network of small diameter (2-8 inch) force main piping and individual septic tanks and effluent pumps would be installed to service Scuppernong Township at a cost that Tyrrell County would provide, supplemented with outside financing. To reduce collection line sizes and STEP pump horsepower, two intermediate lift stations would be located near the 4H Center and Travis interchange to pump wastewater to Creswell. These lift 7 stations would allow for greater flexibility in long term operation and maintenance of the collection system. Minimal land disturbance would occur as nearly all collection lines will be laid in road rights -of -way at an excavation depth of three feet. New septic tanks would be located adjacent to existing septic tanks on private properties The Water and Sewer Districts would own and maintain the septic tanks and effluent pumps which would lessen the burden on the homeowner. The homeowner would be responsible for providing plumbing connection to the new tank and the monthly electrical costs associated with operation of the effluent pump. A low pressure sewer system is the most economically feasible means of providing sewer service to residents of this rural area. 2.2.2 Gravity Collection System A conventional gravity sewer is not feasible for this region. The combination of minimal surface relief, high groundwater tables, necessary line sizes and excavation depths, and lack of user density would drive the cost of such a system to levels that simply are not affordable. Because of the usual high groundwater levels in this area, inflow and infiltration to the system would be a substantial concern. The gravity collection system alternative was determined to be cost- and functionally prohibitive, and was not considered further. 2.2.3 Vacuum Collection System Vacuum systems are not feasible for such an expansive service area. At a minimum four central vacuum stations would be required. These stations would drive the costs of system construction and operation and maintenance beyond the financial capabilities of sewer users. High groundwater levels and the increased potential for inflow and infiltration would also be of greater concern with use of a vacuum system. The vacuum collection system alternative was determined to be cost and functionally prohibitive, and was not considered. 2.3 Waterline Included in the funding for the above wastewater system improvements is approximately 1.75 miles of 6-inch waterline that will close a hydraulic loop for the Town of Creswell's water system (Figure 1.0). Construction of this waterline, from Alligood Road west along the north side of US 64, will provide better water pressure and fire flows to existing users in the area and provide potable water for several commercial and residential establishments on this segment of US 64. The waterline would be constructed on the same side of the road and located between 11 and 20 feet from the proposed sewerline. No additional impacts will result from the waterline construction except minimal temporary impacts to land use and habitats, which have been included in the sewer impact calculations and mitigation discussions. 2.3.1 No -Action Alternative The No Action Alternative would continue allowing residents and businesses located along Highway 94 to use well water. No capital costs would be incurred by Creswell to pursue this alternative, but no improvements to Creswell's water system would result from this course of action. 2.4. / Preferred Alternative The Preferred Alternative would be to loop Creswell's water system by connecting the existing water main at Alligood Road to the existing water main at the Creswell Speedway along Highway 94. This alternative would provide redundancy, increase water pressure, improve water quality and provide existing residents and businesses along this corridor a safe supply of potable water. The estimated construction cost for the water line is $100,000. 8