NC0085359_201 Facilities Plan_19950911

NPDES DOCUHENT SCANNING COVER SHEET
NPDES Permit:
NC0085839
Twelve Mile Creek WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
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Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
September 11, 1995
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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Govemor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
MEMORANDUM
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41,
LDEEI-I NJ Ii
September 11, 1995
To: Bobby Blowe, Chief
Constructions Grants and Loans Sectio
From: Steve W. Tedder, Chie
Water Quality Section
Subject: Union County Twelvemile Creek WWTP
Union County
Staff of the Water Quality Section has reviewed the August 18, 1995 submittal by the
Union County Public Works Department and their consultant, McKim & Creed.
Issues raised in my memorandum dated August 9, 1995, regarding the subject project have
been resolved to our satisfaction. There are still concerns about wastewater management
issues from a broad perspective in Union County. These concerns have been discussed
with the County and their consultant and Union County has informed us that they will be
developing a county -wide wastewater management plan. Discussions have indicated that
scoping this effort will be initiated in the next several months.
If I can be of any further assistance, please do not hesitate to contact me at [phone],
extension 500.
cc: Mooresville Regional Office
Technical Support Branch
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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T2919-233-8031
McKIM & CREED/RL 08/29/95 14:12 P.001
facsimile
TRANSMITTAL
to: Ruth Swanek
fax #: [phone]
re: Preliminary Determination of NPDES Limits
date: August 29,1995
pages: 2, including this cover sheet.
Please find attached a compilation of USGS topo maps that show the location of a current
pumping station owned and operated by union County. The station is uscd to convey
wastewater from the Marshville area eventually to the City of Monroe wastewater treatment
plant. We are evaluating the alternatives of either upgrading the pump station and ultimately
impacting the Monroe plant, or diverting approximately 1 mgd to a new plant that would be
located in the vicinity of the pump station, i.e. at the intersection of Route 205 and Negro Head
Creek (now known as Salem Creek). Our questions are does sufficient flow exist in this section
of the creek (or if not, could you recommend the closest permissible discharge point?) And if so,
what would be the probable discharge criteria?
Thank you in advance for your prompt consideration. Please call if you have any questions.
Fmm the desk of...
Thomas Cadwallader
Project Engineer
McKim & Creed
5625 Dillard Road #117
Cary, NC 27511
(919) 233 - 8091
Fax: [phone]

41,
MEMORANDUM
TO: Files
FROM: Sid Riddic
DATE: August 15, 1995
M&C: 0771.0010.0W(11)
RE: Response to Comments 201 Facilities Plan, Twelve Mile Creek
On August 9, 1995, McKim & Creed received a memo from Steve W. Tedder, Chief, Water Quality
Section, to Bobby Blowe, Chief, Construction Grants and Loan Section, regarding the proposed
Twelve Mile Creek Wastewater Treatment Plant 201 Facilities Plan. In this memorandum, which
is attached, a number of additional questions were raised relating to the analysis of alternatives to
meet the wastewater needs of the Twelve Mile Creek basin. The purpose of this memorandum is
to provide additional background on the analysis of altematives and to specifically respond with the
additional information requested.
Introduction
Union County and McKim & Creed are undertaking a significant planning effort to identify needs
and evaluate alternatives to meet the wastewater requirements of the western portion of Union
County within the Twelve Mile Creek basin. Initial planning efforts were directed at resolving
capacity issues in the upper portion of the East Fork of Twelve Mile Creek in the vicinity of the Dry
Fork land application treatment system. Initial recommendations were to construct a discharge
type wastewater facility at a point on the East Fork of Twelve Mile Creek near Shannon Road. At
this point, the Creek exhibited positive flow at the 30Q2 condition and was considered to be the first
available site downstream from the Dry Fork plant, where a discharge type facility could be located.
Water quality concerns, citizen objections and limited service areas prompted the Union County
Commissioners to direct that alternatives which could meet the needs of the entire Twelve Mile
Creek basin be evaluated.
Additional planning efforts resulted in the submittal of a revised draft 201 Facilities Plant for the
entire Twelve Mile Creek basin. This document was originally submitted to the North Carolina
Division of Environmental Management in January 1995. In a February 20, 1995 letter to Mr.
Michael Shalati, Donald Safrit, P.E., enumerated concerns with the planning process and the
selected alternative which involved construction of a discharge type facility on Twelve Mile Creek
immediately downstream from NC Route 16. Water Quality Section issues included the following:
a. Needs assessment for the proposed Twelve Mile Creek project (questions arose
concerning projected flows and the possible continued utilization of Dry Fork and Waxhaw
land application sites).
MCMM&CREED

Memo to Files
August 15, 1995
Page 2
b. Alternatives analysis, specifically the evaluation of alternatives to join with other utilities
such as the Charlotte Mecklenberg Utilities Department (CMUD).
c. Speculative effluent limits and water quality concerns which would require advanced
secondary treatment as a minimum with the strong possibility that full AWT will be required
in the immediate future.
In a meeting with Mr. Safrit and his staff on March 6, 1995 these concems were discussed and on
May 10, 1995, a revised 201 Facilities planning document was personally delivered to NCDEM for
review. It was the intent of that re -submittal to respond to each area of concern defined by the
Water Quality Section, and to thoroughly and objectively evaluate and document the alternatives
analysis. We also contacted the WQS staff to request a meeting to review the revisions and were
advised that such a meeting was not desirable until staff could review the resubmittal in detail.
On August 7, 1995, the memo from Steve Tedder to Bobby Blowe was received by McKim &
Creed. This memorandum identified additional issues to be resolved in the -facilities plan review,
and specifically addressed the alternatives analysis. Issues identified in this memorandum include
the following:
a. Documentation of the cost associated with the CMUD service was not complete.
b. There were some inconsistencies in the cost analysis included in Appendix E (Present
Worth Analysis).
c. Questions were raised about overlapping service areas for Crooked Creek and Twelve Mile
Creek.
d. Long term utilization of the Waxhaw land application facility was questioned.
e. Chronic toxicity compliance was questioned.
We have evaluated each of the above items and have the following responses.
Documentation
The documentation included in the May 8, 1995 draft of the 201 Facilities Plan did not include some
critical information which was received from CMUD. This information is contained in a March 15,
1995 letter from Mr. Ben Russell, Business Manager for CMUD, to Mr. Mike Shalati, Union County
Public Works. This letter provided the cost information which served as a basis for the cost
analysis in the revised facility plan. This letter is attached, and provides for two conditions of
service which have been labeled in the facilities plan as "retail" and "wholesale."
Under the retail service condition, Union County customers would pay a flat rate estimated at
$2.00/1,000 gallons for FY96. Previous calculations by McKim & Creed had used a rate of
$1.99/1,000 gallons, and we therefore did not adjust our earlier calculations to compensate for this
MCKINI&CREED

Memo to Files
August 15, 1995
Page 3
minor increase.
For wholesale service, Union County would actually purchase capacity in the McAlpine Creek
Treatment Plant and Sludge Processing Facility, as well as the interceptors, force mains and
pumping stations which would be used to convey the Union County waste along Six Mile Creek into
the treatment plant. Under this approach, Union County would not contribute to the debt service
of CMUD facilities for which they would not receive any benefit. The wholesale rate would cover
the cost of operating the pump stations and the McAlpine Creek Treatment Plant and Solids
Processing System and was estimated at $.0565/1,000 gallons for FY97.
The letter also established the cost to purchase capacity in the CMUD system (treatment plant,
solids processing, pump stations, force mains, interceptors). The combined cost of all components
was projected to be $2,766,250 per million gallons per day of capacity. In the analysis of
alternatives, the cost to purchase capacity equal to 2.5 MGD was therefore estimated at
$6,915,000. This estimated cost is, of course, in addition to the cost to construct a major pump
station at the proposed NC 16 site, the force main, and gravity interceptor which would convey
wastewaters to McBride Branch and connect to the Six Mile Creek interceptor proposed by CMUD.
For reference, the total distance from the NC 16 site to the McAlpine plant is estimated to be about
15 miles.
Present Worth inconsistencies
As noted in the memorandum from Steve Tedder, there were some inconsistencies in the data
used in the present worth analysis of altematives. The most significant inconsistency involves the
estimated O&M cost for years 1 and 20 for Alternate #2. The total projected O&M for year 0 (start
up) was estimated at $260,000 per year. The projected O&M cost for the year 2014 (twenty years)
was estimated at $897,500. These were not correctly utilized in the present worth analysis.
With these adjustments, the projected total present worth for Alternate 2 should be $12,632,019
and is reduced by approximately $600,000, further increasing the difference in cost between
Altemate #2, and either altemative which involves connection to the CMUD system. A complete
package to support the present worth analysis is attached.
Overlapping Service Areas
Questions were raised regarding some overlapping of service areas along the ridge line separating
the Twelve Mile and Crooked Creek basins. This is the area along Old Charlotte Highway (SR
1009) which generally follows the dividing line between the two drainage basins. The flow
projections for the Twelve Mile Creek 201 plan and the currently approved 201 plan for Crooked
Creek are based on the premise that waste flows will be treated in the drainage basins where they
originate. This does not result in significant flows being transferred out of Crooked Creek and does
not result in any overlapping of service areas.
Elimination of Grant Funded Facility (Waxhaw Land Application)
�. MCKIM&CREED

Memo to Files
August 15, 1995
Page 4
The continued utilization of the Waxhaw Land Application Treatment Facility requires clarification.
Construction of the proposed surface discharge plant will require that approximately 25 acres of
the existing area used for spray fields be taken out of service. This will reduce the available spray
fields at the Waxhaw site by about 25%, and would result in a corresponding reduction in available
capacity from 250,000 g.p.d. down to 167,500 g.p.d. It is proposed that the existing Waxhaw
facility remain in service at this revised capacity to treat waste originating from the town of Waxhaw
and surrounding areas.
Chronic Toxicity
The memorandum from Steve Tedder discusses our failure to deal with chronic toxicity as a
discussion item in the 201 Facilities Plan. There appears to be two concerns about chronic toxicity,
the first being the ability of the treatment facility to produce an effluent that will meet chronic toxicity
requirements, and the second associated with the cost of the chronic toxicity tests. Proposals for
the Twelve Mile Creek Treatment Facility, as outlined in the 201 Facilities Plan, involve advanced
treatment which provides partial nutrient removal and the use of ultraviolet disinfection in lieu of
chlorine. The proposed facility will produce a higher quality effluent than the County's existing
Crooked Creek Waste Treatment Facility. The Crooked Creek facility has had no difficulty meeting
the chronic toxicity test, and we anticipate no difficulty with the proposed Twelve Mile Creek Plant.
Currently all identified waste sources are domestic in nature, and the only contribution from
industrial or commercial sources will be non -process waste associated with employee sanitary
facilities.
The cost impact of chronic toxicity testing is minimal. Using current standards Union County would
be required to test quarterly for chronic toxicity, and the cost per test in accordance with the
attached invoice from Pace Environmental is $300. Thus the cost of chronic toxicity testing for the
proposed Twelve Mile Creek facility will be $1200 per year, which is an insignificant element of cost
when compared to the overall projected O&M for the treatment facility.
Summary
The memorandum from Steve Tedder identified several relevant and pertinent issues relating to
the cost analysis for the proposed Twelve Mile Creek Wastewater Facility. We have provided the
additional cost information and clarification of the inconsistencies in the cost data, which should
allow this analysis to be concluded. The analysis confirms, as shown on the revised present worth
spread sheet, that the most financially feasible alternative, which is environmentally acceptable,
involves construction of an advanced waste treatment discharge facility on Twelve Mile Creek at
Highway 16. This alternative is 34% less expensive than Alternate 1 B, which involves pumping to
the CMUD system as a retail customer; and 36% less expensive than pumping to CMUD as a
wholesale customer.
We have also responded to a number of other issues regarding the facilities planning process, and
remain confident of our findings and recommendations.
\rdb
A
MCKIM&CREED

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section
May 23, 1995
Memorandum
To: Coleen Sullins (�
From: Carla Sanderson(
Through: Ruth Swanek ?.S
Subject: Union County.201 Facilities Plan and EA Amendment
Twelve Mile Creek Proposed Discharge
Location - south of NC16 in Union County
Speculative Limits and Water Quality Concerns
The amended 201 Facilities plan does not include the limit for Chronic Toxicity as
recommended in the speculative limits and further mentioned in the 2/20/95 memo sent to
Melba McGee. (In general, I did not see any changes from the original document,
therefore do not see how this is an amended document.) A Chronic Pass/Fail toxicity
testing requirement at 90% effluent should be included as part of the limit requirements for
this facility.
Instream data collected on Twelve Mile Creek as part of the Environmental Assessment
document was informative. The data show the need for further investigation of the creek at
the proposed discharge location. A study plan to gather data should be developed in
coordination with staff of the Water Quality Section of DEM. Additional information
collected on Twelve Mile Creek during low flow conditions (July through October) may
provide enough data to determine whether or not a modeling analysis may be performed.
Stream modeling is not normally performed for creeks with 7Q10=0. Therefore, the
collection of additional data may only be used to determine the creeks existing conditions
and ability to assimilate a discharge of several MGD. Due to the size of this proposed
discharge, it is imperative to.evaluate the creek more closely.
Please let me know if you need any additional comments at this time.

17048412567 MCKIM & CREED 909 P11 MAY 08 '95 09:49
RESPONSE TO ENVIRONMENTAL COMMENTS
TWELVE MILE CREEK WASTEWATER TREATMENT FACILITIES
1. A revised map has been included in the EA document. A copy of this map, revised to show
changes in the project, is attached to this response_
2. Facilities are shown on the attached map.
3. A detailed delineation of specific habitats impacted by the planned sewer alignment cannot
be made until the detailed alignment is resolved. The EA document and field investigations
conducted by Edward Menhinick, James Matthews, Ph.D. et al, Fred Brown, Ph.D., and
Hugh Porter provide detailed descriptions of existing conditions and habitats in reference
to county roads. Please refer to these reports. The aerial map sheets do not clarify the
exact alignment in enough detail to allow specific discussions of habitat since the alignment
is only generally defined.
The intent of these surveys was to evaluate conditions and habitat along both sides of the
creeks in order to identify areas of concern. If areas of concern were identified, the
alignment of the lines could be adjusted as necessary.
4. A detailed description of water quality conditions/characteristics of area streams is found
in Appendix B, pages 1-10. These pages describe conditions found at 17 sampling
stations. In addition, following page 16 is a table summarizing characteristics for nine (9)
9

17048412567 MCKIM a CREED
909 P12
MAY 08 '95 09:49
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
specific measurements taken in addition to estimated discharge. Figures 1 though 8
graphically display these data.
5. The US Army Corps of Engineers will be contacted regarding conducting a field
reconnaissance of the proposed alignment corridor. This reconnaissance should review
issues of concern and determine if jurisdictional areas will be impacted.
6. Union County has the following sources of water for its public water system:
Source Amount
Anson County - Pee Dee River 4.0 MGD
Catawba River near 6.0 MGD
SC Rt.5
City of Monroe 3.0 MGD
Twelve Mile Creek enters the Catawba River upstream from SC Rt. 5 and the intake for
the Catawba River Regional Water Treatment Plant serving . Union County and the
Lancaster County SC Water and Sewer District. The discharge from Twelve Mile Creek
combines with Little Sugar Creek and the Catawba River below the Lake Wylie dam to form
the raw water supply for the water plant. The other two water sources are in no way
impacted by the proposed discharge.
10

IJ
7. The public hearing transcript is incorporated in the revised 201 Facilities Plan. A copy of
the affidavit of publication will be forwarded to the NCDEM.
8. Recreation impacts of the proposed project are addressed in the revised EA document.
9. Responses to review comments from each agency are attached.

17048412567 MCKIM 2. CREED
909 P13 MAY 08 '95 09:50
RESPONSE TO AGENCY CONCERNS
TWELVE MILE CREEK WASTEWATER FACILITIES
1. Water Quality Section
Memo from Don Safrit
A number of significant concems from the NCDEM Water Quality Section have been
defined. The revisions to the 201 Facilities Plan submitted on May 3, 1995 addressed
these issues in detail. Specifically the following concerns have been addressed:
A. Concern-, Need for project.
Response:
1. Conceming the population growth in the service area, the
preliminary draft plan assumed a doubling of population the in 20
years with essentially all residents connected to the system. More
current data, compiled by the Centralina COG showed that growth
in the Twelve Mile Creek basin from 1990 through 1994 was as high
as 6.5%/year. Revised population forecasts are based on 4.5% per
year.
The population growth in subarea 1! is based on an approved plan
for a 1,354 unit subdivision which the developer indicates should be
built out in 10 years.
12

• 17048412567 MCKIM & CREED
909 P14
MAY 08 '95 09:50
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
2. Rerouting of flows from the Crooked Creek catchment into the
l.♦
Twelve Mile catchment is not proposed. What is proposed is to
reverse three specific situations where flows from the Twelve Mile
catchment are now diverted to Crooked Creek, and to not practice
such diversions on any future areas unless it is found to be cost
effective. Currently the flows being diverted amount to Tess than
50,000 gpd and will have minimal impact on flow projections or
need.
3. Failing septic systems in the area around Sun Valley are evident.
However, this is not a justification for the project.
4. The existing interceptor development is in the East Fork. Initially,
flows into the system will be limited to this subbasin, except for
limited flow from a school under design on the West Fork near NC
84.
5. The original draft and revised 201 Facilities Plans do not state that
the spray irrigation systems at Dry Fork have failed. It was noted
that samples from one of the groundwater monitoring wells have
elevated total dissolved solids concentrations, and the County has
been directed by the NCDEM to investigate the cause of the
problem. There are indications of leakage from the stabilization
lagoon, not a problem with the disposal system.
13

17048412567 MCKIM 2. CREED 909 P15 MAY 08 '95 09:50
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
In addition, the 201 Facilities Plan did not justify the need for a new
facility by eliminating a properly functioning spray irrigation system
at Waxhaw. The Plan did state that Union County has allocated
essentially all of the capacity in the Waxhaw system, and that some
action would be required to provide for future capacity.
6. The population projections have been updated to reflect recent
growth trends_ Also, in projecting wastewater flows, it was assumed
that only a small percentage of the existing population not currently
connected to a system would do so.
The analysis of alternatives has been updated to fully utilize existing
non -discharge systems as well as evaluation of options to discharge
part or all of the wastewater into the Crooked Creek system. The
details of these evaluations are fully described in the revised 201
Facilities Plan.
B. Concern: Alternative Analysis
Response:
1- We have updated the analysis of alternatives to fully explore
discharge into the CMUD system via the Six Mile Creek Interceptor
14

17048412567 MCKIM $ CREED 909 P16 MAY 08 '95 09:51
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
system. Union County has received the written correspondence
from the CMUD which confirms a willingness to provide capacity and
established two (2) options for service. In one case, the County
would simply be a "retail" customer, paying CMUD's retail rate of
$2.00/1,000 gallons.
CMUD also offered to sell capacity and charge the County a
wholesale rate, reflecting actual O&M for the McAlpine Creek
treatment plant and related systems. The estimated "wholesale"
rate would be $0.565/1,000 gallons.
The revised 201 Facilities Plan provides a detailed description of the
analysis of discharging to CMUD. On a present worth basis,
discharge to CMUD was determined to be 30% more costly than the
altemate of a treatment plant at NC 16.
2. The alternate of expanding the Waxhaw land application system was
in fact well documented, although further clarification of issues is
appropriate.
a. The Waxhaw system is currently treating about 150,000 gpd
or 60% of its rated capacity. The County does own
15

17048412567 MCKIM a CREED
909 P17
MAY 0B '95 09:51
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
approximately 250 acres at this site, but this site is fully
developed with the treatment lagoons, spray fields and
required buffer zones.
b. The alternate for a new land application system in the
Waxhaw area does in fact evaluate the alternative of
expanding the existing system. It was assumed that a
suitable site could be found adjacent to the existing site and
no additional costs were included in the capital or present
worth analyses to account for extended gravity line or
pumping to remote spray fields.
c. It is correct to note that in the projection of need, the plant
capacities evaluated were 2.5/5.0 MGD for 10 and 20 years.
However, this was done for a basis of comparison only.
d. The possibility of discharging to the City of Monroe for a five
year period at an average daily flow of 100,000 gpd is not an
option to consider. By the time Union County implements its
selected alternative for Twelve Mile Creek, approximately 3
of the 5 years will have passed, and this capacity would need
to be provided in the new system. At any rate, the capacity
16

17048412567 MCKIM 2 CREED
909 P18 MAY 08 '95 09:51
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
offered is only 4% of the projected 10 year need and is of no
consequence in evaluating long range altematives.
e. The revised 201 Facilities Plan updates costs for all
alternates previously evaluated and adds two other
alternates involving discharge of part of all of the waste into
the Crooked Creek system.
f. All discharge option include costs associated with laboratory
monitoring. The existing Crooked Creek treatment plant
budget was used to develop O&M costs. Purchase of lab
chemicals and supplies was not clearly segregated, but has
been accounted for in the O&M estimates for a new
discharge.
The first year's budget includes $51,480 for a chief operator
and shift operator. Under the County's current staffing plan,'
the chief operator and shift operator also perform much of
the laboratory testing for operations and the daily monitoring.
The budget also provides $37,500 for "maintenance", which
according to a review of existing data, includes chemicals.
By comparison, the proposed O&M costs for Twelve Mile
17

17048412567 MCKIM a CREED
909 P19 MAY 08 '95 09:52
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
Creek are significantly higher than the County provides at
Crooked Creek, including monitoring. Thus, although the
previously submitted data did not separate laboratory items,
we feel the O&M budgets provide for these costs.
g. Connection to CMUD, either as a wholesale or retail
customer is 30% more costly than developing a discharge
type facility on Twelve Mile Creek. It is our opinion that it is
not economically feasible, nor desirable for Union County to
pay a 30% premium for service.
The increase in the cost differential to connect to CMUD
(from 10% to nearly 30%) is based on the expanded service
area and estimated flows.
C. Concern: Speculative Limits and Water Quality Concerns
ResPonse:
1. Current speculative limits have concentration values for conventional
pollutants plus aquatic toxicity. Currently there are no known
industrial discharges that would trigger the need for limits on
toxicants not in domestic wastewater.
18

17048412567 MCKIM a CREED
909 P20 MAY 08 '95 09:52
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
2. It is recognized that the in -stream sampling was not specifically
correlated to statistical low flows and the observed water quality
conditions represent a snapshot of a point in time.
If the Water Quality Section intends to require in -stream sampling to
develop more accurate data for predictive models used to establish
effluent standards, a plan of study should be developed so that
sampling can occur in July through September, the expected low or
critical flow periods.
2. Geological Assessment Group
Memo from Steven Kroeger
Concern: Wording on addressing sediment and erosion control.
Response; Contract documents for all construction projects will incorporate all
requirements of the Sediment and Erosion Control Permit which must be
issued for the project by the Division of Land Resources.
3. Wildlife Resources Commission
Memo from Owen F. Anderson
A. Qoncerp., Habitat protection for Carolina Darter, Carolina Creekshell, and other
aquatic species.
Response; Habitat protection in the long term can best be accomplished by
providing a comprehensive wastewater treatment and disposal
19

1704841256? MCKIM 8. CREED
909 P21
MAY 08 '95 09:52
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
system rather than the proliferation of private systems that result
where pressures for development exist. Union County proposes
three specific steps that will enhance habitat protection.
1. The treatment plant will provide essentially complete denitrification
by biological means. This will significantly reduce ultimate oxygen
demand in the receiving stream.
2. Some biological phosphorous removal will be provided. This will
help minimize addition of nutrients which accelerate euthrophication.
3. The plant will use ultraviolet disinfection, thereby eliminating even
minute amounts of chlorine in the discharge.
B. Concern: Evaluation of alternates for treatment and disposal, particularly to
Charlotte Mecklenburg Utilities.
Response: This alternative was reviewed in detail in the January 1995 draft
Facilities Plan, although at that time, CMUD advised in personal
communication to McKim & Creed that capacity was not available.
This matter has been diligently pursued and CMUD has offered
capacity. This alternative is, however, nearly 30% more costly on a
present worth basis and is not an economically acceptable option to
Union County.
20

17048412567 MCKIM & CREED 909 P22 MAY 08 '95 09:53
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
The proposed alternative does meet a major concern of the Wildlife
Resources Commission that is avoidance of numerous small plants.
The treatment plant will be a major facility serving all of the Twelve
Mile Creek basin, and in accordance with County policy, no private
plants will be allowed where the public system is accessible.
C. Q. ncem: Nine (9) other specific concerns are herein addressed:
1. As an altemate, piping wastewater to CMUD is nearly 30% more
expensive based on a present worth analysis. If growth exceeds the
estimates in the 201 Facilities Plan, the cost difference will increase,
making the CMUD option even more expensive.
The distance from the proposed Twelve Mile Creek plant to
McAlpine Creek is nearly 15 miles and would require two major
pumping stations. This is the reason for the large differences in
present worth. Effluent quality at CMUD and Twelve Mile Creek are
expected to be similar, thus the cost of treatment will be essentially
the same, except for bioso(ids. At this time, CMUD's biosolids
program is much more costly than the system proposed for Twelve
Mile Creek.
2. The maintenance of a 100 foot vegetated buffer along creeks will be
accomplished except where steep creek banks would require
21

17048412567 MCKIM a CREED
909 P23 MAY 08 '95 09:53
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
extremely deep cuts. The additional disturbances for clearing would
frequently be more damaging than reducing the buffer. It is
proposed to resolve these issues through field reconnaissance with
the Corps of Engineers and other interested agencies.
3. The proposed disinfection system has been revised to use ultraviolet
(UV) disinfection.
4. All conditions regarding restoration and maintenance of wetlands will
be adopted in the final construction documents.
5. All conditions regarding maintenance of upland corridors will be
adopted.
6. The colony of Carolina birdfoot-trefoil (Lotus helleri) on SR 1353 is
approximately one (1) mile upstream from any planned construction.
7. Wetland delineation in the EA document was limited to general
corridors. Detailed delineation will be coordinated through the Corps
of Engineers as specific alignments are defined.
22

17048412567 MCKIM 8. CREED 909 P24 MAY 08 '95 09:53
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
8. Disturbed areas will be revegetated in accordance with any specific
requirements outlined in permits and the "Authorization to
Construct".
9. The discussion of secondary impacts has been incorporated into the
revised EA document_
4. Air Quality Section
Memo from Alan Klimek
A. Concern: Air permits.
Response', The proposed project will not include lime silos or other devices
requiring air permits.
B. Concern: Open buming during construction.
Response: Contractors who wish to use open burning during land clearing will
be required to obtain proper permits.
C. Concern: Fugitive dust emissions.
Response . Contract documents will define contractor requirements for dust
control.
23

17048412567 MCKIM & CREED 909 P25 MAY 08 '95 09:54
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
D. Concern: Odor control from facilities, specifically pump stations.
Response: The two new pump stations (Price Mill Creek and plant influent) are
located well away from existing homes. Provisions for future odor
control (i.e. ducting) will be incorporated into the design.
5, Environmental Health/Public Water Supply Section (EH/PWSS)
Concern: Water line construction or relocation will require approval of
plans/specifications by EH/PWSS.
Response: Acknowledge requirement.
6. Division of Water Resources
Concern: Potential impacts of interbasin transfer
Response: Discussed in revised 201 Facilities Plan. This project does not involve an
interbasin transfer.
7. Division of Archives and History
Concern: Cultural resources surveys not performed on plant site or along interceptor
corridors.
Response:
1. The plant will be located on an existing site, in an area previously disturbed
by construction. We question if a survey is needed.
24

17048412567 MCKIM & CREED 909 P26 MAY 08 '95 09:54
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
2. Cultural resource surveys on the interceptors could not adequately be
performed since specific alignments have to this point not been defined. We
will coordinate the need for any specific cultural resources surveys with the
Division of Archives and History.
3. The location of the proposed Price Mill Creek pump station has been shown
on the map supplied with the comments from Archives and History. The
approximate alignment of sewers along the Price Mill Creek and the East
Fork Twelve Mile Creek are also shown.
8. US Fish and Wildlife Service
US Fish and Wildlife Service comments have been reviewed. Some of the issues
addressed may be inconsistent with the comments of other State or Federal agencies. The
following will be coordinated with other agencies.
A. Concern: Install gravity sewers on the more disturbed sides of creeks and
maintain widest possible vegetative buffers.
Response: We concur with this concern and will maintain a minimum of a 100
foot buffer, except where steep terrain dictates an alignment closer
to creek banks.
B. Concern: Reduce stream crossings as much as possible and use aerial
crossings to reduce impact of sedimentation.
25

17048412567 MCKIM & CREED
909 P27 MAY 08 '95 09:54
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
Response: The number of crossings will be minimized. However, in several
areas, sharp "s" bends in the creek channel, combined with steep,
rocky abutments at the outside of the "s" tutus, suggest crossing the
creeks will have a lesser impact.
We disagree with the suggestion to use aerial crossings because of
the following:
1. Aerial crossings are more subject to damage from high water and
impact from floating debris.
2. Aerial crossings will potentially cause flooding during high water
events, particularly if piers or the pipe supports collect debris which
further blocks the creek channel.
C. Concern: The toxic impact of chlorine used in disinfection.
Response: Ultraviolet (UV) disinfection will be provided.
D. Conwm: Protection of Carolina birdfoot-trefoil (Lotus helleri) colony on Rogers
Road.
Response, This site is approximately one (1) mile upstream of the nearest
planned construction.
26

17048412567 MCKIM 2 CREEL
909 P28 MAY 08 '95 09:55
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
E. Concern: Union County should develop a regional facility to reduce/eliminate
small private plants.
Response_ This is a regional plant which will serve the entire Twelve Mile Creek
basin_
27

TEL No.704 021 6943
Apr 10,95 11:56 P.01
Q, Mir R fpMr ,
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FAX COVER SHEET DRAW
DATE: 4/11195
TO: MR. PRESTON HOWARD
FAX NO: 919-733-2496
TO: MR. DON SAFRIT
FAX teb: 919-733 2496 -
TO: MR. JOHN FEEZOR
FAX NO: 282-0121
TO: MR. RON LEWIS
FAX NO: 282-0121
TO: MR. MIKE SHALATI
FAX NC): 283-3620
FROM: MAX GOUGE, JR.
FAX: [phone]
MESSAGE:
TIME: 1:37 PM
ORIGINAL LETTER TO FOLLOW BY MAIL.
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SEWERFAX.DOC

TEL No.704 821 6943
Apr 10,95 11:57 P.02
4607 Blanchard Circle
Matthews, NC 28105
April 11, 1995
Mr. Mike Shalati
Director of Public Works
Union County Public Works Department
P. O. Box 987
Monroe, NC 28111-0987
Re: Proposed 12 Mile Creek Basin Sewer Line Plant.
Mr. Shalati:
We are requesting detailed information and/or answers
below as it relates to the 201. Facilities Plan on the
Creek waste Water Disposal System.
• Where do the current developments currently being
Crooked Creek facility reroute and connect to the
Facility? Those developments being, for example,
Monroe Rd.).
to the questions
proposed 12 Mile
served by the
12 Mile Creek
Brandon Oaks (Old
• How does the operational costs (ongoing) of a gravity line without
pump stations cost more to operate than a forced main? Please be
specific and relate this to the 12 Mile Creek Project compared to
Running Price Mill Creek Vs Davis Mine Creek.
• Rerouting the proposed line down Davis Mine Creek cuts the required
line by well over 1 mile; thereby reducing costs. If your department
and the commissioners are interested in costa and saving money, why
not this route?
• Why the Price Mill Creek Route? This route will cross mainly
undeveloped land, a good portion of which is owned by Mrs. James S.
Moore (my wife•s mother) and myself. Why is this route so paramount
to this project? Yes, I know it is within the 12 Mile Creek Basin,
as has been the previous answer.to my question. This answer does not
satisfy us. What/who else is pursuing this route? We are not going
to be satisfied until we hear a satisfactory azidwer nor or we going
to go away.
• We have not seen any geotechnical surveys on this proposed route.
Since blasting through rock appears likely, what possibilities exist
for damage to underground/aboveground structures? Our home, well and
springs are at risk. We sit on a rock formation that, it disturbed,
could damage our home. Well water is our source of water as well as

• TEL No.704 821 6943 Apr 10,95 11:57 P.03
Mr. Mike Shalati
Page Two
April 11, 1995
spring and well water for our livestock. Disruption of this could be
disastrous. Where and when will such information be available with
projections on the likelihood of damage.
• How much ditch line will be open at any given time during the project
and at what average depth.
• Does any current county commissioner have any connections either
directly or indirectly to any current or proposed real estate or
development projects that would benefit from this project? I assume
that if the answer is no, that would also mean that they would also
not become involved in any such dealings (directly or indirectly) as
long as they sit on the board. We wouldn't want the voters of Union
County to feel there were any conflicts of interest.
Please advise in writing.
Respectfully,
Max L. Gouge, Jr.
Cheryl Moor Gouge
MLG/j sd '

BY:CMUO _ ; 3-16-95 ; 7:38AM ; ADMINISTRATION-, 17042833820;S 2
CHARLOTTE
March 15,1995
Mr. Milne Shalsti
Director, Public works
Union County
Subject: Cost/Price estimates for wastewater treatment
Dear Mikes,
You rec endy inquked about the ability ofthe Cliarlotte-MecklenburgTtty Department to
accept flow from the Twelve Mile Creek basin. We do have capacity that we can make available
to Union County. We would propose to amply amend the pending Six Mile Creek agreement to
include flow from the Twelve Me Creek basin up to a combined total offive million gallons par
day. Service out be provided =der either of the two options listed below. P zdter capacity could
be wed when needed in the future.
Following are the cost numbers you requested at our meeting onMonday, March 13,1995. The
cost numbers are based on our requested budgets for FY 96 and FY 97. Beyond that time I have
estimated a 5% annual increase which is the low end of our long range rate estimate.
OPtion
Purchase service at amne rate as all of our other customer& This rate pays for treatment as well as
debt service on the ant faality, outfalls and lift stations.
FY 96 $2.00i1000 gal&
FY 97 2.10
FY 98 2.21
FY 99 232
FY 00 2.44
Option II
Purchase treatment capacity in McAlpine and pay unmet coasts.
Administration Division 5100 Brookshire Boulevard Charlotte, NC 28216 704/399-2221
Charlotte-Mecklenbwg Utility Department

;SENT BY: CMUO
3-10-95 ; 7:38AIM ; AOMINISTRATION- 17042833620►# 3
Treatment costs:
FY 96 .65/1000 gals.
FY 97 .565
FY 98 .595
FY 99 .625
FY 00 .655
Price per million gallons of treatraent capacity. Based on cost of planned expansion to 64 MCrD.
Treatment capacity = S 1.8125 million per million gallons per day.
Solids Processing Capacity: S.55 million per Dry Ton of solids. Aging that flows from
Union County would have the same cba acteristics as flows currently received by McAlpine.,
Union county would be contributing .833 Dry Tons per day of solids per million gallons of flow.
Cost -- S.458 million per million gallons of flow.
Outfall and lift station capacity :
Out 1l = S84,975 per million gallons.
Lift Station s $185,275 per million gallons.
Force Main/outfl — S225,500 per million gallons.
We would be open to discussion on how these capacity cost payments might be scheduled.
Given the time available, these capacity eclat* are estimates. We have not been able to do a
detailed cost auignment of each segment of the Six Mile Creek project and the portions of that
project you will be using. I do believe the cost numbers are in the" ha park" and provide a basis
for cliscusaice.
On Monday you made a point of the thct that you could not accept a situation whereby the Union.
County rate payers would be subsidizing Mecklenburg County customers. Fm mne you can
appreciate that CMUD could not accept an went that had Mecldenburg customers
subsic tang Union County customers.
We share your desire to reach an agreement that is beneficial to both parties and believe that is
possible. We look forward to hearings you. If you have any questions please call me at 704-
391.5062.
Sincerely,
Benjanii i B. Russel
Business Manager

UNION CO. DISCHARGERS
Permit No:
NC0024333
NC0069841
NC0058882
NC0069523
NC0066559
Facility Name
City of Monroe WWTP
Qw (mgd) Active (Y/N)
7, 9, 11
Y
Union Co.- Crooked Creek/ #��2�� 1.0, 1.3 Y
?blac4this b NFCirotc 2 olL ,,v , bq AlGD
Union Co. -Providence CC 0.125, 1.0 Y
Union Co.-Tallwood Estates
Union Co. -Public Works
NC0031186 Union Co.- S F Crooked Cr
P fco,rd zd�d
NC0080349 Six Mile Creek WWTP (private) 0.5 N
,•
0.016, 0.050 Y
1 N
0.45 N