NC0085359_Environmental Assessment_19950523

NPDES DOCIMENT :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
Instream Assessment (67b)
Speculative Limits
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(Environmental
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Assessment (EA)
Document Date:
May 23, 1995
Mimi document is printed cart reuse paper - ignore any
contemt on the reYerse side

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section
May 23, 1995
Memorandum
To: Coleen Sullins
From: Carla Sanderson
Through: Ruth Swanek
Subject: Union County 201 Facilities Plan and EA Amendment
Twelve Mile Creek Proposed Discharge
Location - south of NC 16 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.

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REMARKS
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1. No Exceptions Taken 2. Make Corrections Noted
4. Amend & Resubmit 5. Rejected - See Remarks
C. For Information
3. Other
D. Bid
H. See Remarks
5625 DILLARD ROAD, SUITE 117, CARY, NC 27511 919/233-8091 FAX [phone]
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SURVEYORS
ARCHITECTS
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MCKJM&CREED
May 8, 1995 0771.0009.04(12)
North Carolina Department of Health
Environment and Natural Resources
Division of Environmental Management
Post Office Box 29535
Raleigh, North Carolina 27626-0535
Attention: Mr. Robert L. Brown, Jr.
Construction Grants and Loans Section
RE: Revised 201 Facilities Plan
Twelve Mile Creek Basin
Union County, North Carolina
Gentlemen:
This will confirm the submittal of ten (10) copies of an updated 201 Facilities Plan covering
the planned Twelve Mile Creek project. The document was updated to respond to the
comments received in your letter dated March 9, 1995. To help with your review of the
revised Plan, we have also prepared the point -by -point response to each of the review
comments which is attached. We trust that our responses clarify the concerns which resulted
from the original reviews.
We recognize that some issues particularly related to wetland and cultural resources impacts
can not be fully evaluated until the design concepts are finalized. We then intend to contact
the appropriate agencies for input prior to submitting final plans to be reviewed.
Please review the attached materials and the revised 201 Plan and let us know if you have
further questions.
Very truly yours,
10,elac
William S. Riddick, Jr., P.E.
2331 CROWN POINT EXECIJIIVE DR. Project Manager
SUITE C
CHARLOIIF. NC 28227
704/841-2588
FAX [phone]
/car
cc: Mr. Michael Shalati, Union County Department of Public Works
Attachment
:1 edlettersdIsk10771010Vespond tel

1
RESPONSE TO TECHNICAL COMMENTS
TWELVE MILE CREEK WASTEWATER TREATMENT FACILITIES
1. As a part of efforts to obtain proper non -discharge permits for collection systems built in
western Union County, a study was done to document per capita water use. This study,
performed by Union County, demonstrated per capita flows of about 240 gpd/dwelling. This
information was reviewed by the NCDEM Engineering and Permits Section. After review,
the County was allowed by the NCDEM to use a unit flow of 300 gpd for permitting
purposes.
Union County encourages water consumption by its customers and has utility rates which
do not provide high volume discounts.
Finally, although it is obviously in the County's best interest to extend the useful life of its
utility system, there is no incentive for the County to justify capacity needs with
unrealistically low per capita consumption. The NCDEM regulations require non -discharge
permits for new sewer constructions be based on 360 gpd/residential connection unless an
adjusted design daily rate can be documented in accordance with 15A NCAC 2H.0219
(I)(3). Given that the NCDEM agreed to issue non -discharge permits using 300 gpd, we
feel that 280 gpd is a reasonable value for long range planning of wastewater needs.
2. The planned Twelve Mile Creek wastewater treatment plant and interceptors will receive
wastewaters from three (3) existing wastewater collection systems:
a. Dry Fork service area including County owned collection systems in the Sun Valley
school area.

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
b. Waxhaw, from the town's collection system.
c. Fincher Road, including developments along Chestnut Lane.
County policy requires all new subdivisions and development to connect to available sewer
systems, and for collection sewers to be provided by developers or users. This policy
remains in effect.
3. Power outage records have been requested from Union EMC, the proposed utility supplier,
to determine if standby power is required.
4. A present worth analysis comparing UV disinfection to chlorine/sulfur dioxide for disinfection
has been performed. Based on 20-year present value, McKim & Creed now recommends
UV disinfection and has adjusted the process description and cost estimate accordingly.
5. Union County has expressed a preference to continue its existing program of land
application of sludges by contracting with private haulers for transporting and applying
sludge.
We propose only those facilities that are needed by the County to comply with Section 503
regulations, including aerated holding and digestion. Since the capital costs of this option
are clearly the lowest of all available sludge handling/disposal options, a cost analysis
including present worth was not prepared.
(!, D 1
S� �� 2

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
6. Refer to Preliminary Engineering Report submitted on April 13, 1995 for calculations on
aeration horsepower requirements.
7. Refer to same Preliminary Engineering Report for calculations on digester sizing.
8. Proposed financing as described in the revised 201 Facilities Plan, submitted May 3, 1995,
includes $3.0 million from state SRF, $5.0 million from authorized G.O. bonds, and the
balance from revenue bonds. Union County is currently interviewing firms to serve as
Senior Manager for the bond placement.
9. The revised 201 Facilities Plan includes an assessment of the impact of this project, as well
as other planned utility improvements on user charges. Based on this analysis, which
recognized requirements for annual debt service (see #8) plus operations and maintenance
costs, user charges are expected to increase from $3.00 to $3.50 per 1,000 gallons. This
will increase the bill of a customer using 8,400 gallons/month by about 11 %.
10. The plant is intended to meet "advanced secondary" limits in accordance with
correspondence from the NCDEM Water Quality Section letter attached to the revised 201
Facilities Plan. The required NPDES Permit Application will be submitted by June 1, 1995.
11. Responses to question 11 are as follows:
a. The existing site is owned by Union County.
3

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
b. Approximately 20 acres or 10% of the existing spray fields will be taken out of
service for the construction. The resulting loss in capacity is 25,000 gpd. Since the
existing flows to this site are averaging 150,000 gpd, the Toss in capacity will not
impact existing customer service.
c. Federal money was used to construct the existing spray fields.
d. A proximity map is attached.
12. Requested resolution will be submitted.
13. The public hearing on the project was conducted. The revised 201 Facilities Plan includes
a transcript of the hearing.
14. No fine screen is proposed ahead of the plant headworks. A coarse bar rack (4-inch clear
spacing) is proposed to prevent large materials from entering the pump station wetwell.
The rack will be designed to allow flow to bypass directly to the wetwell if necessary, and
the rack will be removable for cleaning.
15. See response #14.
16. Descriptions of proposed buildings are as follows:
a. Chemical building(s) will house feed pumps/controls for sodium hydroxide, alum,
and polymers. Buildings will be prefabricated of precast concrete. Sizes are
estimated as shown in the table.
4

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
b. Blower budding will house positive displacement blowers for digestors. Construction
is precast concrete.
c. A building will be provided at the influent pump station to house electrical controls.
The budding type will be precast concrete or masonry block.
d. An electrical building will house MCC's. This building will be precast concrete.
e. The administrative/laboratory/maintenance facility will be cavity wall (block/brick)
construction with wood truss roof system.
Proposed sizes are listed below.
Building
Size
Estimated Cost/Foot
Chemical Buildings
Alum
120 ft2
Sodium Hydroxide
120 ft2
Polymer
192 ft2
Blower
315 ft2
Influent Pump Station
288 ft2
Electrical
144 ft2
Admin/Lab/Maintenance
Administrative
2,000 ft2
Laboratory
1,500 ft2
Maintenance
2,000 ft2
Unit costs are not yet available.
5

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
17. The 201 Facilities Plan is based on construction of the treatment plant, or alternate
systems, in two (2) 10-year phases. An analysis was not conducted to construct a 20-year
design initially, based on the following:
a. The flows at plant start-up are expected to be only 10-15% of capacity based on 2.5
MGD design.
b. The proposed cost recovery system includes $3,000/connection as an impact fee.
Constructing the entire 20-year design at this time would shift much of the cost to
existing customers, rather than the future users that the facility is actually designed
to serve.
18. The revised 201 Facilities Plan includes a more detailed analysis of population trends in the
service area, supported by documentation from records compiled by the Centralina COG.
The annual population increases in the Twelve Mile Creek basin for 1990-1994 were found
to be as high as 6.5%/year. A long term growth rate of 4.5% was used in the population
forecasts.
19. Section 3 of the revised 201 Facilities Plan and Appendix B present a revised detailed
analysis of flow projections. The per capita flow used was 104 gpd/capita (or 280 gpd per
connection). The tables in Appendix B include the following:
a. "Population served" includes 1,462 persons from Waxhaw.
b. Flow forecasts include existing and new customers (exclusive of Waxhaw) at 104
gpd.
6

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
20. Industrial flows are based on orderly development of industrially zoned areas in the Twelve
Mile Creek basin. The actual projected industrial flows are equivalent to 9.8% of the
projected residential, commercial, and institutional flow for the first 10 years and 14.3% for
the 20 year projections. Since the total project cost greatly exceeds likely funding from the
NCDEM, no further adjustment to the projections is proposed.
21. Commercial development is based on current zoning, and waste flows from such
development are based on 2,000 gpd/acre. The 10 year projections for commercial flows
are equivalent to 8.5 gpd/person. The 20 year projection is equivalent to 14.1 gpd/person.
22. Concepts for design of the proposed plant include parallel process trains rated at 1.25 MGD
each. The plant site plan will allow expansion in increments of 1.25 or 2.5 MGD for the first
phase of expansion, and 1.25, 2.5, or 5.0 MGD in subsequent expansions. The proposed
site can physically accommodate a 15 MGD plant based on this concept.
23. Appendix F presents a detailed summary of projected O&M costs. These are based on:
a. Existing County records for purchase of materials, supplies, etc.
b. Staffing levels which exceed those at other County owned plants, including Crooked
Creek.
c. Allowances for lab monitoring (costs include labor allocation, plus supplies) are -
included in the costs for labor for the plant.
d. Utility/chemical costs based on projected usage.
7

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
24. Existing collection systems are operated and maintained by Union County. The
intermunicipal agreements between the County and the Towns of Indian Trail (Fincher
Road Pump Station) and Waxhaw will be submitted.
25. The documentation regarding the public hearing process has been incorporated into the
revised draft facilities plan. A separate document which responds to the questions and
issues raised will be submitted to the County.
26. Acknowledged.
27. Ten copies of the revised 201 Facilities Plan were submitted on May 3, 1995.
8

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

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.
`.19
5. The US Army Corps of Engineers will be contadted regarding conducting a field .A."rt ,
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

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.
11

RESPONSE TO AGENCY CONCERNS
TWELVE MILE CREEK WASTEWATER FACILITIES
1. Water Quality Section
Memo from Don Safrit
A number of significant concerns 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. Concerning 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 II is based on an approved plan
for a 1,354 unit subdivision which the developer indicates should be
built out in 10 years.
12

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
2. Rerouting of flows from the Crooked Creek catchment into the
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

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

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
alternate of a treatment plant at NC 16.
2. The altemate 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

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 altemate 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

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 alternatives.
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

Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
C. Concern:
Response:
g.
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.
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.
Speculative Limits and Water Quality Concerns
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

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. Concern: 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

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

s
Response to State and Federal Agency Comments
Twelve Mile Creek Wastewater Treatment Facilities
The proposed alternative does meet a major concern of the Wildlife v
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. Concern:, 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 biosolids. 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

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

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 burning 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

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 (Le. 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

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

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" tums, 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. Concern: 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

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

RESPONSE TO CITIZEN CONCERNS
TWELVE MILE CREEK WASTEWATER TREATMENT FACILITIES
1. April 10, 1995 letter from Ms. Cynthia Lee
Letter provides support for recommended alternative.
2. April 10, 1995 letter from Mr. Richard B. Baker
Letter provides support for recommended alternative.
3. March 10, 1995 issue of Deerfield Plantation Newsletter
Information to homeowners only.
4. April 10, 1995 letter from Mr. David C. Fridy
Information only, expressed commitment to monitor County progress through all phases of
the project.
5. April 11, 1995 letter from Mr. Max L. Gouge, Jr. and Cheryl Moore Gouge
See attached letter of response from McKim & Creed.
Aye0ovrreportdtsk10771010Yespond
28

ENGINEERS
SURVEYORS
ARCTIITECTS
rIP,JIII I,',
MK1IM&CREED
May 8, 1995 0771.009.OW(11)
Mr. Mike Shalati, Director
Union County Public Works Department
Post Office Box 987
Monroe, North Carolina 28111-0987
RE: Citizen Comments
Twelve Mile Creek Wastewater Facilities
Dear Mr. Shalati:
We have reviewed the letter dated April 11, 1995 submitted by Mr. Max Gouge and
Ms. Cheryl Gouge which raised several questions regarding the planned project.
Our responses to the technical issues are as follows:
1. Rerouting of service from two (2) developing areas served by Crooked
Creek is proposed:
a. The Fincher Road pump station discharge force main will be routed
to a gravity line along Pioneer Lane to the Price Mill Creek
interceptor.
b. The Brandon Oaks pump station will be taken off-line and flow
diverted by gravity to the Price Mill Creek interceptor.
2. Comparisons of O&M costs of the proposed Price Mill Creek pump station
to an alternate gravity line to East Fork are covered in detail in Appendix C
of the 201 Facilities Plan. Specifically the O&M for the pumping concept is
about twice as costly ($18,000 vs. $27,400/year). On a 20 year present
worth basis, these costs are offset by an estimated $1.1 million in capital
costs.
2331 CROWN POINT EXECUTIVE DR 3. Rerouting lines down Davis Mine Creek does not eliminate the need for or
change line sizes on the Price Mill Creek line.
SUITE C
4. The Price Mill Creek line will allow service to an already approved 1,354 unit
CNARLOTIE. NC 28227 subdivision (Brandon Oaks) to proceed in an orderly fashion.
704184T 2588 5. Geotechnical investigations have not been performed on any of the
proposed interceptor sewer alignments, and will not be performed. Rock
FAX 104l8479764 blasting will likely be required. Contractors will be required to monitor

Mr. Mike Shalati
May 8, 1995
Page 2
blasting operations. While our experience on many other projects indicates
that damage to nearby homes is not likely, the contractors will be required
to have insurance to cover such actions.
Finally, we do not believe any nearby wells will be damaged. We will,
however, evaluate the proximity of any water supply wells on the
Gouge/Moore properties, or other areas of concern.
6. Generally, no more than 100 feet of trench will be open at any time. Each
contractor will be required to protect residents, including livestock, from
danger during construction.
7. Not a technical issue.
We will evaluate the concerns over the potential for damage to wells in this area and
respond appropriately. The final contract documents, available in late July 1995 will
define the specific responsibilities of the contractors to minimize damage to
personal property on the Twelve Mile Creek project.
Please let us know if you have further questions regarding citizen concerns on the
project.
Very truly yours,
William S. Riddick, Jr., P.E.
Project Manager
/car
:VedlettersdiskW770101citizen

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
7:7;•94rA
1=)EHNR
February 20, 1995 /}� d�
Mr. Michael Shalati, Director /(
Union County Public Works
Post Office Box 987 ft-fr (cc, —
Monroe, North Carolina 28111
SUBJECT: Proposed Twelve Mile Creek Wastewater Treatment Plant
201 Facilities Plan and Environmental Assessment Review
Union County
Dear Mr. Shalati:
Staff of the Technical Support Branch has reviewed the revised 201 Facilities Plan
and Environmental Assessment submitted in January 1995. Attached are the comments that
were sent to the State Clearinghouse in response to the review completed. Overall, staff
have significant concerns with the proposed wastewater treatment plant. The reports
contain many inconsistencies and do not provide a thorough review of all the alternatives.
Additionally, information requested in the previous review still has not been provided.
Specifically, Union County should make a more concerted effort to finalize agreements
with Charlotte -Mecklenburg Utility District (CMUD) to provide service to the western
portion of Union County, including the Six and Twelve Mile Creek watersheds.
Staff understands that a draft agreement for 3 MGD of capacity was sent to Union
County over a year ago to address the wastewater needs of the Six Mile Creek catchment,
but that the County has not finalized their commitments. Per initial staff contact with
CMUD concerning the Twelve Mile Creek service area, capacity to handle these wastewater
flows may also be available in the CMUD system.
Given the above concerns (outlined in more detail in the attached memorandum),
the Technical Support Branch would not recommend approval of the 201 Facilities Plan
and Environmental Assessment, nor support the issuance of a permit for a new discharge
into Twelve. Mile Creek.
_r
If you have any questions or would like to schedule a meeting to discuss the issues,
please contact Coleen Sullins at 919/733-5083 (ext. 550).
cc: McKim & Creed Engineers, P.
Mooresville Regional Office
Permits and Engineering Unit
Central Files
Sincerely,
Donald L. Safrit, P.E.
Assistant Chief for Technical Support
Water Quality Section
A.; William S. Riddick, Jr., P.E., Project Manager
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer
50% recycled/ 10% post -consumer paper

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section
February 20, 1995
MEMORANDUM
To: Melba McGee
Through: Monica Swihart
From: Don Safrit
Subject: Union County 201 Facilities Plan and EA
Comments on Twelve Mile Creek Proposed Discharge
Location - south of Highway 16 in Union County
As stated in the previous memorandum dated September 16,1994 (copy attached), the
Technical Support Branch continues to have concerns with the proposed wastewater
treatment plant discharge to Twelve Mile Creek. In order to issue a permit for the
discharge, the Division must fmd that the proposed system is the most practicable
alternative with the least adverse impact on the environment.
Need for Project
A thorough evaluation of the population projections and proposed service area raised many
questions. The report states that a doubling of population is projected to occur in the
Twelve Mile Creek catchment of Union County over the next twenty years. However,
certain subareas show growth rates in excess of the 100% increase without adequate
explanation. For example, Subarea 11 is projected to experience greater than a 1000%
increase in population.
A large amount of growth is projected in the upper basin areas, particularly along Old
Charlotte Road in the vicinty.of Indian Trail and Stallings. This area lies along the ridge
which divides the Crooked Creek sub -basin and the Twelve Mile Creek drainage area.
Sewer service was brought to these areas via the Crooked Creek wastewater treatment plant
(WWTP), as documented in the report, to address the failing septic systems. Since this is
an area of significant growth and Union County is in the process of expanding the Crooked
Creek WWTP, consideration should be given to continue to route wastewater flow from
this high growth area to the Crooked Creek WWTP. Existing wastewater flow within the
Crooked Creek catchment should nQt be redirected, as the plan proposes, to the Twelve
Mile Creek watershed.
The report establishes several criteria for determining the need for the Twelve Mile Creek
WWTP. Failing septic systems on the west side of the drainage basin (see Section 2.3) is
one basis. However, the report further states that problems with failing septic systems are
not currently evident (Section 3.2). Additionally, the initial interceptor development for the
first 10 years is proposed to occur only in the East Fork drainage catchment. However,

ten-year population projections appear to be based on service to both forks of Twelve Mile
Creek (see Table 3.4) instead of the East Fork drainage area only as discussed in Section
3.5.
Another stated basis of need is the failing Dry Fork spray irrigation disposal system. It
should be noted that the failure of the Dry Fork system was caused by Union County
loading it at a rate of 2.8 times the permitted capacity. Relief from the overloading has been
provided by redirecting flows to the Crooked Creek and Monroe WWTP's. In addition,
per the report, Monroe may be able to provide additional capacity. Elimination of the
existing properly functioning spray irrigation system at the Town of Waxhaw is also a
stated basis for the need of the proposed system.
The population projections and corresponding flow predictions always assume that 100%
of the population in the sub -basin will be served by the proposed wastewater treatment
plant. Although the Division continues to support regionalization of wastewater treatment
systems, a reduction in flow could certainly be achieved in this case by fully using and/or
expanding the Waxhaw spray irrigation system, the Dry Fork spray irrigation system, the
Crooked Creek WWTP, and working septic tank systems. The Division would like to see
Union County review these options, particularly in light of the possiblity of connection to
CMUD, since CMUD will be more likely to accomodate a lower flow than that calculated
when assuming service to 100% of the projected population in the sub -basin.
Alternatives Analysis
The 201 Facilities Plan documents alternatives to the discharge in Section 5 which includes
pumping the wastewater to the Six Mile Creek outfall for treatment by Charlotte -
Mecklenburg Utility Department (CMUD). Construction costs for this alternative are
projected to be $5 million less than the alternative to discharge. However, this alternative is
discounted on a present worth analysis, based on the costs associated with charges for
treatment by CMUD. As stated in the previous review, since the specific item which makes
this alternative more costly than the alternative to construct a wastewater treatment plant
with a discharge is the cost per gallon figure projected to be charged by CMUD to handle
the treatment of the wastewater, full documentation from CMUD needs to be provided to
support the cost per gallon figures in the report. Initial staff contacts with CMUD officials
have indicated that CMUD may be capable of handling the wastewater flows that are
projected to be generated in the Twelve Mile Creek drainage catchment, in addition to the
flows being generated by growth in the Six Mile Creek watershed. It is staffs
understanding that a draft agreement for 3 MGD of capacity was sent to the County over a
year ago, but IJnion County has yet to finalize their commitment. Further, CMUD stated.
that they would work with the Division and Union County to consider the additional flows
from the Twelve Mile Creek watershed. If it is determined that CMUD is not able to accept
the additional flow, a letter of confirmation from CMUD needs to be provided.
The alternative to expand the Waxhaw land application system was not adequately
addressed. The report wrongly identifies the Waxhaw permit as an NPDES permit, when,
in fact, it is a permit for a spray irrigation disposal system (WQ0005909). The spray
system, per the report, is currently treating 150,000 gallons per day (60% of permitted
capacity) on 103 acres of land, and is in compliance with the permit. The land area
available at this location and currently owned by Union County is 250 acres. The
alternatives analysis must address the feasibility of expanding the existing spray irrigation
system to handle the wastewater needs of the area. This should also be evaluated in
conjunction with the continued operation of the Dry Fork spray irrigation system.

Additionally, the report mentions that the City of Monroe, while not able to handle all the
projected wastewater needs of Union County, did commit to accepting an additional
100,000 gallons per day of wastewater from Union County. The alternatives analysis must
address the feasibility of handling all the wastewater needs through a combination of all the
above "nondischarge" options. Adjustments to the cost to connect to the CMUD
interceptor for the 20 year projection should also be addressed to reflect a reduction in
construction costs if other land application systems can adequately handle the interim needs
while the interceptor line is brought closer to the projected service area.
Finally, on the alternatives analysis of the discharge option, the full costs for operation and
maintenance of the system do not appear to be incorporated into the assessment. The costs
associated with the continued monitoring requirements are not included in the report. As a
result of the proposed size of the discharge, the monitoring frequency is projected to be
3/week at a minimum for the conventional parameters, weekly for toxicants and a quarterly
toxicity test. The instream monitoring requirements should also be factored into the
analysis.
Staff of the Technical Support Branch remain of the opinion that connection to the CMUD
interceptor is the most environmentally sound alternative and that it is economically
feasible. Further explanation is needed to verify the cost differential between the discharge
and the connection to CMUD. Additionally, it is interesting to note that the previous
analysis reviewed showed a cost differential of less than 10%, without accounting for the
costs associated with sludge handling/disposal or the costs associated with the sampling
and analyses of the wastewater. The current analysis documents a differential of 26%
(connection to CMUD being higher) and still does not include the costs for sampling and
analyses of the wastewater. Staff requests that an explanation for the increase in the
differential be provided.
Speculative Limits and Water Quality Concerns
Speculative limits for the proposed discharge into Twelve Mile Creek below Highway 16 in
Union County were provided by the Technical Support Branch (January 24, 1995 letter).
The limits reflected requirements for facilities that discharge into streams with 7Q 10da cfs
and 30Q2>0 cfs. Section 5 of the 201 Plan confirms the limits recommended in the
speculative letter (with the exception of a toxicity testing requirement of 90% chronic P/F
using ceriodaphnia). Additional limits may be applied if a component of the wastewater is
to be industrial and would contain toxicants not typically associated with domestic
wastewaters.
The information provided in Appendix B of the Environmental Assessment on the stream
study that was performed on Twelve Mile Creek, was useful in enabling further
consideration of this discharge. As mentioned in the report, stations 1 through 14 were
sampled on June 12, 13, 14 and 15, 1994 and an amended study was conducted on Dec.
23, 1994 for stations 14 though 17. The sampled area started near the headwaters of Davis
Mine Creek with two sample stations on that creek. Davis Mine Creek flows into Price
Mill Creek which flows into Twelve Mile Creek near the headwaters. Five stations were
sampled on Price Mill Creek and the remaining samples were collected on Twelve Mile
Creek. It should be noted that the stations downstream of Highway 16 (stations 14-17),
were sampled in December 1994 and are not indicative of critical low -flow conditions.
The study showed that upstream of the sample area (Davis Mine Creek), the dissolved
oxygen (DO) concentration and the percent saturation was >80%. However, the DO
concentration was below the water quality standard (documented instream at 4.7 mg/1) at

the second location in Price Mill Creek and the percent saturation was only 53%.
Dissolved oxygen concentrations recovered to >5.0 mg/1 at the next few sample locations,
but decreased again on Twelve Mile Creek below its union with Price Mil Creek. While
the remaining stations below the confluence of Price Mill Creek and Twelve Mile Creek did
not reflect DO levels outside the standard, other factors in the stream study need to be taken
into consideration. Many observations made at the sample stations characterized the creek
as "pooling". Hydraulic information, specifically the presence of pooling, should be
provided for areas downstream of the proposed discharge during low -flow conditions.
Summary
Overall, the 201 and Environmental Assessment contain many inconsistencies and do not
provide a thorough review of all alternatives. Numbers in some of the tables are not
supported by the discussion in the text. Additionally, information requested in the previous
review still has not been provided. Specifically, Union County should make a more
concerted effort to finalize agreements with CMUD for service in both the Six Mile and
Twelve Mile Creek areas. A combination of alternatives should also be considered for the
alternatives analysis discussion as well as the section discussing the justification for the
need of this project. Given the above concerns, the Technical Support Branch would not
recommend approval of the Environmental Assessment, nor support the issuance of a
permit for a new discharge into Twelve Mile Creek.
cc: Bobby Blowe
Steve Tedder
Mooresville Regional Office/Water Quality Section
Central Files

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section
February 20, 1995
MEMORANDUM
To: Melba McGee
Through: Monica Swihart
From: Don Safrit
Subject: Union County 201 Facilities Plan and EA
Comments on Twelve Mile Creek Proposed Discharge
Location - south of Highway 16 in Union County
As stated in the previous memorandum dated September 16,1994 (copy attached), the
Technical Support Branch, continues to have concerns with the proposed wastewater
treatment plant discharge to Twelve Mile Creek. In order to issue a permit for the
discharge, the Division must find that the proposed system is the most practicable
alternative with the least adverse impact on the environment.
Need for Project
A thorough evaluation of the population projections and proposed service area raised many
questions. The report states that a doubling of population is projected to occur in the
Twelve Mile Creek catchment of Union County over the next twenty years. However,
certain subareas show growth rates in excess of the 100% increase without adequate
explanation. For example, Subarea 11 is projected to experience greater than a 1000%
increase in population.
A large amount of growth is projected in the upper basin areas, particularly along Old
Charlotte Road in the vicinty of Indian Trail and Stallings. This area lies along the ridge
which divides the Crooked Creek sub -basin and the Twelve Mile Creek drainage area.
Sewer service was brought to these areas via the Crooked Creek wastewater treatment plant
(WWTP), as documented in the report, to address the failing septic systems. Since this is
an area of significant growth and Union County is in the process of expanding the Crooked
Creek WWTP, consideration should be given to continue to route wastewater flow from
this high growth area to the Crooked Creek WWTP. Existing wastewater flow within the
Crooked Creek catchment should nit be redirected, as the plan proposes, to the Twelve
Mile Creek watershed.
The report establishes several criteria for determining the need for the Twelve Mile Creek
WWTP. Failing septic systems on the west side of the drainage basin (see Section 2.3) is
one basis. However, the report further states that problems with failing septic systems are
not currently evident (Section 3.2). Additionally, the initial interceptor development for the
first 10 years is proposed to occur only in the East Fork drainage catchment. However,

ten-year population projections appear to be based on service to both forks of Twelve Mile
Creek (see Table 3.4) instead of the East Fork drainage area only as discussed in Section
3.5.
Another stated basis of need is the failing Dry Fork spray irrigation disposal system. It
should be noted that the failure of the Dry Fork system was caused by Union County
loading it at a rate of 2.8 times the permitted capacity. Relief from the overloading has been
provided by redirecting flows to the Crooked Creek and Monroe WWTP's. In addition,
per the report, Monroe may be able to provide additional capacity. Elimination of the
existing properly functioning spray irrigation system at the Town of Waxhaw is also a
stated basis for the need of the proposed system.
The population projections and corresponding flow predictions always assume that 100%
of the population in the sub -basin will be served by the proposed wastewater treatment
plant. Although the Division continues to support regionalization of wastewater treatment
systems, a reduction in flow could certainly be achieved in this case by fully using and/or
expanding the Waxhaw spray irrigation system, the Dry Fork spray irrigation system, the
Crooked Creek WWTP, and working septic tank systems. The Division would like to see
Union County review these options, particularly in light of the possiblity of connection to
CMUD, since CMUD will be more likely to accomodate a lower flow than that calculated
when assuming service to 100% of the projected population in the sub -basin.
Alternatives Analysis
The 201 Facilities Plan documents alternatives to the discharge in Section 5 which includes
pumping the wastewater to the Six Mile Creek outfall for treatment by Charlotte -
Mecklenburg Utility Department (CMUD). Construction costs for this alternative are
projected to be $5 million less than the alternative to discharge. However, this alternative is
discounted on a present worth analysis, based on the costs associated with charges for
treatment by CMUD. As stated in the previous review, since the specific item which makes
this alternative more costly than the alternative to construct a wastewater treatment plant
with a discharge is the cost per gallon figure projected to be charged by CMUD to handle
the treatment of the wastewater, full documentation from CMUDneeds to be provided to
support the cost per gallon figures in the report. Initial staff contacts with CMUD officials
have indicated that CMUD may be capable of handling the wastewater flows that are
projected to be generated in the Twelve Mile Creek drainage catchment, in addition to the
flows being generated by growth in the Six Mile Creek watershed. It is staffs
understanding that a draft agreement for 3 MGD of capacity was sent to the County over a
year ago, but Union County has yet to finalize their commitment. Further, CMUD stated
that they would work with the Division and Union County to consider the additional flows
from the Twelve Mile Creek watershed. If it is determined that CMUD is not able to accept
the additional flow, a letter of confirmation from CMUD needs to be provided.
`The alternative to expand the Waxhaw land application system was not adequately
addressed. The report wrongly identifies the Waxhaw permit as an NPDES permit, when,
in fact, it is a permit for a spray irrigation disposal system (WQ0005909). The spray
system, per the report, is currently treating 150,000 gallons per day (60% of permitted
capacity) on 103 acres of land, and is in compliance with the permit. The land area
available at this location and currently owned by Union County is 250 acres. The
alternatives analysis must address the feasibility of expanding the existing spray irrigation
system to handle the wastewater needs of the area. This should also be evaluated in
conjunction with the continued operation of the Dry Fork spray irrigation system.

Additionally, the report mentions that the City of Monroe, while not able to handle all the
projected wastewater needs of Union County, did commit to accepting an additional
100,000 gallons per day of wastewater from Union County. The alternatives analysis must
address the feasibility of handling all the wastewater needs through a combination of all the
above "nondischarge" options. Adjustments to the cost to connect to the CMUD
interceptor for the 20 year projection should also be addressed to reflect a reduction in
construction costs if other land application systems can adequately handle the interim needs
while the interceptor line is brought closer to the projected service area.
Finally, on the alternatives analysis of the discharge option, the full costs for operation and
maintenance of the system do not appear to be incorporated into the assessment. The costs
associated with the continued monitoring requirements are not included in the report. As a
result of the proposed size of the discharge, the monitoring frequency is projected to be
3/week at a minimum for the conventional parameters, weekly for toxicants and a quarterly
toxicity test. The instream monitoring requirements should also be factored into the
analysis.
Staff of the Technical Support Branch remain of the opinion that connection to the CMUD
interceptor is the most environmentally sound alternative and that it is economically
feasible. Further explanation is needed to verify the cost differential between the discharge
and the connection to CMUD. Additionally, it is interesting to note that the previous
analysis reviewed showed a cost differential of less than 10%, without accounting for the
costs associated with sludge handling/disposal or the costs associated with the sampling
and analyses of the wastewater. The current analysis documents a differential of 26%
(connection to CMUD being higher) and still does not include the costs for sampling and
analyses of the wastewater. Staff requests that an explanation for the increase in the
differential be provided.
Speculative Limits and Water Quality Concerns
Speculative limits for the proposed discharge into Twelve Mile Creek below Highway 16 in
Union County were provided by the Technical Support Branch (January 24, 1995 letter).
The limits reflected requirements for facilities that discharge into streams with 7Q 10) cfs
and 30Q2>0 cfs. Section 5 of the 201 Plan confirms the limits recommended in the
speculative letter (with the exception of a toxicity testing requirement of 90% chronic P/F
using ceriodaphnia). Additional limits may be applied if a component of the wastewater is
to be industrial and would contain toxicants not typically associated with domestic
wastewaters.
The information provided in Appendix B of the Environmental Assessment on the stream
study that was performed on Twelve Mile Creek, was useful in enabling further
consideration of this discharge. As mentioned in the report, stations 1 through 14 were
sampled on June 12, 13, 14 and 15, 1994 and an amended study was conducted on Dec.
23, 1994 for stations 14 though 17. The sampled area started near the headwaters of Davis
Mine Creek with two sample stations on that creek. Davis Mine Creek flows into Price
Mill Creek which flows into Twelve Mile Creek near the headwaters. Five stations were
sampled on Price Mill Creek and the remaining samples were collected on Twelve Mile
Creek. It should be noted that the stations downstream of Highway 16 (stations 14-17),
were sampled in December 1994 and are not indicative of critical low -flow conditions.
The study showed that upstream of the sample area (Davis Mine Creek), the dissolved
oxygen (DO) concentration and the percent saturation was >80%. However, the DO
concentration was below the water quality standard (documented instream at 4.7 mg/1) at

the second location in Price Mill Creek and the percent saturation was only 53%.
Dissolved oxygen concentrations recovered to >5.0 mg/1 at the next few sample locations,
but decreased again on Twelve Mile Creek below its union with Price Mill Creek. While
the remaining stations below the confluence of Price Mill Creek and Twelve Mile Creek did
not reflect DO levels outside the standard, other factors in the stream study need to be taken
into consideration. Many observations made at the sample stations characterized the creek
as "pooling". Hydraulic information, specifically the presence of pooling, should be
provided for areas downstream of the proposed discharge during low -flow conditions.
Summary
Overall, the 201 and Environmental Assessment contain many inconsistencies and do not
provide a thorough review of all alternatives. Numbers in some of the tables are not
supported by the discussion in the text. Additionally, information requested in the previous
review still has not been provided. Specifically, Union County should make a more
concerted effort to finalize agreements with CMUD for service in both the Six Mile and
Twelve Mile Creek areas. A combination of alternatives should also be considered for the
alternatives analysis discussion as well as the section discussing the justification for the
need of this project. Given the above concerns, the Technical Support Branch would not
recommend approval of the Environmental Assessment, nor support the issuance of a
permit for a new discharge into Twelve Mile Creek.
cc: Bobby Blowe
Steve Tedder
Mooresville Regional Office/Water Quality Section
Central Files

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
January 24, 1995
Mr. Michael Shalati, Director
Union County Public Works
Post Office Box 987
Monroe, North Carolina 28111
7:7A wovr
C�EHNF1
SUBJECT: Speculative Limits for Union County 201 Facility Plan
Proposed discharge location on Twelve Mile Creek below
NCSR 16 in southern Union County
Catawba 03-08-38
Dear Mr. Shalati:
I am writing in response to Mr. William Riddick's request for speculative effluent
limits for Union County's proposed Wastewater Treatment Plant which will be included in
their 201 Facilities Plan. This request has been reviewed by the Technical Support Branch.
Please be advised that response to this request does not guarantee that the Division
will issue an NPDES permit to discharge treated wastewater into these receiving waters. It
should be noted that a new facility involving an expenditure of public funds or use of
public (state) lands and having a design capacity of 0.5 MGD or greater (or a facility
proposing an expansion of 0.5 MGD or greater), or exceeding one-third of the 7Q10 of the
receiving stream will require the preparation of an environmental assessment (EA) by the
applicant. DEM will not accept a permit application for a project requiring an EA until the
document has been approved by the Department of Environment, Health and Natural
Resources and a Finding of No Significant Impact (FONSI) has been sent to the state
Clearinghouse for review and comment.
The EA should contain a clear justification for the proposed facility and an analysis
of potential alternatives which should include a thorough evaluation of non -discharge
alternatives. In addition, an EA should show how water reuse, conservation and
inflow/infiltration reductions have been considered. Nondischarge alternatives, such as
spray irrigation, water conservation inflow and infiltration reduction or connection to a
regional treatment and disposal system (CMUD), are considered to be environmentally
preferable to a surface water discharge. In this case, connection to Charlotte Mecklenburg
County Utility Department (CMUD) McAlpine Creek WWTP collection system should be
thoroughly evaluated as an alternative to this proposed discharge. In accordance with the
North Carolina General Statutes, the practicable waste treatment and disposal alternative
with the least adverse impact on the environment is required to be implemented. If the EA
demonstrates that the project may result in a significant adverse affect on the quality of the
environment, an Environmental Impact Statement would be required. Monica Swihart of
the Water Quality Planning Branch can provide further information regarding the
requirements of the N.C. Environmental Policy Act.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Letter to Mr. Shalati
-Page 2-
The proposed 5 MGD wastewater treatment plant site is located on Twelve Mile
Creek just below NCSR 16 in southern Union County is considered an intermittent stream;
it has no natural flow during 7Q10 conditions, but it does have a natural 30Q2 flow equal
to 2.5 cfs.
According to DEM current regulations, as stated in 15 NCAC .0206 (d) (1), where the
7Q10 flow of the receiving stream is estimated to be zero and the 30Q2 flow is estimated to
be greater than zero, proposed effluent limitations for new or expanding discharges of
oxygen consuming waste will be set at BOD5 = 5 mg/1, NH3N = 2 mg/1 and DO = 6 mg/1,
unless it is determined that these limitations will not protect water quality standards.
In addition, under current DEM procedure, dechlorination and chlorine limits are
now recommended for all new or expanding dischargers proposing the use of chlorine for
disinfection. An acceptable level of chlorine in 7Q10 = 0 flow stream is 17 µg/1 to ensure
protection against chronic toxicity. The process of chlorination/dechlorination or an
alternate form of disinfection, such as ultraviolet radiation, should allow a facility to
comply with the total residual chlorine limit.
The instream waste concentration in Twelve Mile Creek at the proposed discharge
location would be 100%. A chronic toxicity testing requirement with quarterly monitoring
would be a condition of the NPDES permit. A complete evaluation of limits and
monitoring requirements for metals and other toxicants will have to be addressed at the
time of formal NPDES application. Information concerning these constituents is not
readily available but Union County can assume that effluent limits and/or monitoring for
cadmium, chromium, nickel, lead, cyanide, mercury, copper, zinc, and silver should be
included if a percentage of the wasteflow comes from industrial users.
This information should provide some assistance in your planning endeavors. As
previously mentioned, final NPDES effluent limitations will be determined after a formal
permit application has been submitted to the Division. If there are any additional questions
concerning this matter, please feel free to contact Ruth Swanek or Michelle Wilson of my
staff at [phone].
ely,
onald L. Safrif, P
Assistant Chief for Techni
Water Quality Section
pport
DLS/MMW
cc: McKim & Creed Engineers, P.A.; William S. Riddick, Jr., P.E., Project Manager
Mooresville Regional Office
Permits and Engineering Unit
Central Files

NOV 01 '94 11:28AM MCKIM & CREED [phone] P.6/11
MEMORANDUM M&C0771.0009.0 W(11)
TO: Files
FROM: Sid Riddick
DATE: October 20, 1994
RE: Analysis of Highway 16 Site
Twelve Mile Creek Wastewater Facilities
Following the September 26, 1994 pubic meeting and concerns raised regarding the proposed
New Town Road Treatment Plant site, McKim & Creed has evaluated alternatives to relocate the
proposed site to property already utilized by Union County for wastewater treatment in Waxhaw.
This relocation would require the extension of interceptor sewers approximately 36,200 feet
downstream from the proposed location of the treatment plant near New Town Road. This
memorandum evaluates alternatives to relocate the treatment plant and interceptor sewers to the
downstream site.
Service Area Description
Relocation of the treatment plant site from New Town Road to Highway 16 would significantly
expand the potential service area for the facility to encompass both the East and West Fork of
Twelve Mile Creek. The size of the proposed service area would be approximately 76 square
miles compared to 22 square mile for the New Town Road site. It should be pointed out
however that the New Town Road site is expected to serve portions of the West Fork of Twelve
Mile Creek upstream from Highway 84 with the construction of interceptor sewers, a pumping
station and a force main in future phases of the project. This would expand the potential service
area of the New Town Road site to approximately 40 square miles. Nonetheless, from a strategic
standpoint the confluence of the two creeks near Highway 16 is a more desirable location.
The topography of the area becomes flatter moving downstream on the East Fork of Twelve Mile
Creek, The significant of this relates to the hydraulic capacity of interceptor sewers constructed
downstream from the New Town Road site. As the slope of the land becomes flatter, it will be
necessary to increase the size of the pipe in order to maintain the same hydraulic carrying
capacity. The impact of the reduction in available slope becomes evident when reviewing
alternatives for interceptor sewer construction which are described in the following paragraphs,
Flow Projections,
Previous studies prepared by McKim & Creed have evaluated growth needs and flow projections
for the entire Twelve Mile Creek Basin. The significance of relocating the treatment plant to the
Highway 16 site is that the 20 year design flow for the entire Twelve Mile Creek area tributary

NOV 01 '94 11:28AM MCKIM & CREED [phone]
V‘CPji‘
f5r61 Litilfik<96 (''°
to this site is approximately 4.8 MGD compared to 1,6 MGD for the New Town Road site,
Interceptor Sewer Alternatives
At the public hearing and in subsequent comments from citizens, it has been suggested that the
24-inch sewer be extended downstream from the New Town Road site to the Waxhaw site.
Because of a decrease in available slope described above, the extension of a 24-inch sewer will
not provide adequate hydraulic carrying capacity to meet the flow needs existing at New Town
Road or to serve additional areas between New Town Road and Waxhaw. With regards to the
sizing of interceptor sewers, McKim & Creed has conducted cost evaluations on two (2)
alternatives as described below:
Alternate 1 - Involves sizing pipelines
needs of the service area with the pipe
which range in size from 21 inches up
required at the end of the 20-year peri
P.7/11
downstream from New Town Road to meet the 20 year
flowing full at the end of 20 years. This results in pipes
to 36 inches at Waxhaw. Parallel construction would be
od.
Alternate 2 - Sizes pipes based on the methodology proposed for the New Town Road site. Pipes
are sized to handle the 20 year peak flows with the pipe flowing half full. This results in pipes
ranging in size from 27 inches south of New Town Road to 48 inches at Waxhaw.
Project cost estimates for each of these alternatives have been prepared and are shown in the
Table 1. Alternate 1 will require future parallel sewers sized to supply the same capacity as
Alternate 2.
Alternate 1
Alternate 2
TABLE
Interceptor Sewer Costs, (million S)
Twelve Mile Creek
Phase I
$ 3.75
$ 5.10
Phase II Total Cost
S 3.17 $ 6.92
-- $ 5.10
Present Worth
$ 4.06
4.63
As can be seen the initial project cost of Alternate 1 is approximately $3.75 million. The project
cost for Alternate 2 is approximately $5.1 million.
The present worth of these alternatives has been compared on the basis of a 3% annual rate of
inflation and an 8% discount rate with a 40 year project life assumed. Using this approach the
present worth of each of the alternatives has been computed. The present worth of Alternate 1
McKIM&CREED

NOV 01 '94 11:29RM MCKIM & CREED [phone]
P.8/11
is slightly over $4 million; the present worth of Alternate 2 is above $4.S6 million, On the
of this analysis, sizing sewers for essentially a 20 year need flowing full, is the basis
most
effective alternative and has an estimated initial project cost of about $3.75 million, cost
Proposed Treatment Plant
An updated estimate of project cost for the treatment plant that would be built at the Waxhaw
site has been prepared. The 20 year projected capacity of this facility would be 4.8 MGD. The
estimated project cost for the first 1,2 MGD increment is $4.98 million. Incremental expansion
costs are as shown on Table 2 with the total cost to develop 4.8 MOD of capacity estimated at
$9.43 (based on 1995 cost).
TABLE 2
Treatment Plant Costs, (million $)
NC 16 Site
Phase Cost
1 $ 4.98
2 0.95
3 3.00
4 0.50
Total (1995 costs) $ 9.43
Project Cost Adjustments
An estimate of the increase in project costs if the proposed treatment facility is relocated to the
Waxhaw location has been prepared. The additional interceptor cost will be approximately $3.75
mullion and the increase in treatment plant cost will be approximately $1 million greater than the
800,000 MGD facility proposed for New Town Road. This total increase in cost would be
approximately $4.75 million.
Summary
McKim & Creed has evaluated the alternative to relocate the proposed treatment facility and
interceptor sewers downstream from New Town Roadto property owned by Union County at
Waxhaw. The site provides a substantially larger potential service area which would include both
the East and West Forks of Twelve Mile Creek north of Highway 16. The additional sewer lines
will have an estimated cost of about $3,75 ninon. The cost to relocate the plant to Waxhaw
with an enlarged capacity will be approximately $1 million. This will increase the project cost
for lines and the plant by about $4.75 million.
bbs
MCKIM&CREED

NOV 01 '94
PROPOSED
SEWER SERVICE
AREAS

NOV 01 '94
-1
* R
0
Z
'A'
r
GENERAL GROUND PROFILE
DISTANCE
r Nollo
/
0
1
ALTERNATE
1- 20--YEARS; PIPE FULL
2- 20-YEARS PIPE lh FULL
.A:
36' (30')
48'
IIMIW. MN
PIPE 8 E (APPROXIMA'TE)
.a. iv
NQ" (27" 1 21' (21'1
38' ___ 27' ___
INTERCEPTOR ALTERNA11VES

NOV 01 '94
PROPOSED
WASTEWATER
FACILITIES

--
Checkers fall;
Hornets lose
in Paris 11 B
Metro Final (4)
8k..:4,4,.
Speedy cookies
Tasty treats are quick and easy
when you use cake mixes
1E
Wednesday
October 19, 1994
ooimirigoltmAgiggrogirogging
Attention, dieters:
Risk of big weight
swings small 1 8A
Becoming cloudy:
High in the mid-70s.
Low near 60/2C
Coming Thursday: Has push for
equal rights gone too far?/Con-
nect
A
500
DAVIE HINSHAW/Stafl
A lot of change: More houses than crops are growing in the fields
near Raeford Parker's Union County home these days.
Giving to
charities
declining
Gifts are fewer,
smaller as well
City growth defies county borders
By JEFFREY BALL
Monroe Bureau
INDIAN TRAIL — As a young
man, Raeford Parker gazed from
the front porch of his farmhouse
and saw nothing but blue sky, a
brown dirt lane and white cotton
fields.
Fifty years later, only the sky
looks the same. The road, now
paved, carries more bulldozers
and European sedans than trac-
tors. As for the fields, some bear
soybeans, but more have started
sprouting $100,000 houses.
® Building permits for single-family houses are
on the rise in counties around Mecklenburg as
people move toward county's edges and beyond.
Parker lives in the fastest -grow-
ing part of the fastest -growing
county in the Charlotte region. His
late wife's relatives, once farmers,
have sold hundreds of acres to
developers over the past decade.
But the retiree, 74, has no regrets.
"Why should 1 hold down prog-
ress?" the western Union County
resident asked. "It's happening
everywhere."
Indeed it is. An Observer analy-
sis of building data shows that
from 1990 to 1993, the pace of
single-family housing growth in
Union County surpassed the pace
in Mecklenburg.
The growth rate in other sur-
rounding counties — Iredell, Ca-
barrus, Lancaster, S.C., and Cleve-
land — also exceeded Mecklen-
burg's rate if permits for mobile
and multi -family homes are con-
sidered. That differs from the
1970s and 1980s, when Mecklen-
burg grew faster than the counties
around it.
This new picture of growth pat-
terns emerges from statistics gath-
ered by the Centralina Council of
Governments. The Charlotte -based
planning group has begun compil-
ing building data for the region.
Please see Houses/page 10A
""3• L. - mil± � 'A [,.� ., :i._.:G�� •.1'. '. ..y �'!.. 't.
RBS AR ADING=IN :THE: CHARL
A��;MAP�.O.F �:INHERE�TNE:SUBU �:SPRE QtT�REG10N�10A
Fleeing Texas floods
•
Clinton
s Korea
atom plan

2OA
City growth spreading
beyond county line
Continued from page 1A
Mecklenburg's most explosive
- growth is around the county's
edges — and no longer just in the
south.
Because of its large population.
Mecklenburg still issued more sin-
gle-family residential building per -
mils from 1990 to 1993 than any
other county in the region: about
15,000. But That number repre-
sented a slower growth rate than in
Union County.
The new study's conclusion:
Charlotte is growing up — and out.
Decentralizing growth
"At some point, you're going 10
have a similar situation (as) you
had in Atlanta," said Cynthia
Mitchell, information systems and
research director for the Carolinas
Partnership. a planning group.
If businesses follow homeown-
ers outward. the bedroom devel-
opments ringing Mecklenburg
could grow into distinct communi-
ties. That would mark a new stage
of development for the Piedmont
— one that. paradoxically. resem-
bles the region's I9th-century
roots, said Ai Stuart, a UNC Char-
lotte geography professor who
helped compile the new study.
From Ate 1880s through the
middle of this century. he said, the
Piedmont comprised a collection
of independent manufacturing
towns. Then, in the early 1970s,
the area's economy started to shift
from manufacturing to services,
and the region began to coalesce
around Charlotte.
Now. Stuart said, suburban
growth is decentralizing the region
again.
Cash and convenience account
for the quickening sprawl, analysts
said.
Housing remains cheaper in out-
lying counties than in Mecklen-
burg. And. though Traffic is thick
ening, the daily drive to work in
Charlotte still is quicker than the
commute In bigger metropolitan
areas, where many new Piedmont
suburbanites used to live.
Consider the Charlotte commut-
ers moving into developments
along Lake Norman.
"People arc coming down here
and getting houses on the lake and
they have to drive 30 minutes —
and that's a picnic," Mitchell said.
Recently Charlotte's quickest support the growth. Often, new- subdivision of 125 houses, in a
growth has been on its southeast- comers are the loudest foes of new soybean field. Clover Bend is in the
ern edge, toward Union County. facilities. Having gotten their piece same U.S. census tract where
But over the next five years of bucolic countryside, many want Parker lives and Howey farms.
development will Intensify to the to block further development The Clover Bend land "was a
north, in the UNC Charlotte area, around Them, natural. 11 was a diamond in the
predicted Mike Rose, the Central- All (hose issues are coming to a rough," said Steele, who has made
ina Council of Governments' data- head in Union County. enough money to buy his family a
center coordinator. That growth Eighth -generation farmer Frank 400-acre farm several miles cast of
will spill over into Cabarrus and HoweyJr., 28, secs them unfolding . the explosive growth he has
Iredell counties, lie said. from the seat of the tractor he helped create. "Somebody just
Get ready, it's comingdrives across his soybean and corn needed to take a chance."
Y fields. That chance has succeeded —
The council of governments' He and his father. Frank Howey, but perhaps at a cost. Last year the
study should serve as a wake-up farm hundreds of acres in the state began to investigate Clover
alarm for the counties surrounding Charlotte region's fourth fastest- Bend and a handful of other
Mecklenburg, Stuart said. growing census tract — the same nearby subdivisions.
"The fundamental message is, tract where Raeford Parker lives. In Union County admitted it let
growth is coming, like it or not," that tract, the number of building those subdivisions (rook up to a
he said. "What arc you going to do permits issued for single-family sewage -treatment plant without
about it? Are you going to wallow houses jumped 62% from 1990 to proper N.C. permits. The state still
in denial and be impacted anyway, 1993 — the greatest percentage is investigating.
or are you going to try to take increase of any area tract outside Some UI1i011 commissioners cite
control of your destiny? Mecklenburg. the crisis as evidence the County
To lake control, analysts said, "I'm getting tired o1 my land let growth overwhelm it.
the counties ringing Mecklenburg paying for kids to go to school. to The new Centratina Council of
will have to answer tough ques• go to the library, for the sheriff's Governments study may bolster
lions. They include: department," he said, "The bur- their view. It's possible that be.
• How to attract more commer- den's getting too much for people tween 1991) and 1993 Union led
cial and industrial development. who already own land in Union the region in its housing•growth
That growth boosts local tax County 10 subsidize the people the rate only because it let develop -
bases, helping fund services for developers are bringing in; merit spiral out of control.
new residents without hefty tax- Out of control? Last fall Union County scram -
rate hikes. But the competition isbled to rein in its growth. It banned
fierce: All area counties want to George Steele has brought in new subdivision sewer hookups on
woo companies that will write big hundreds of those people. its western side until the county
tax checks. He has developed subdivisions builds additional treatment plants.
• How to preserve agriculture, in Cabarrus. Iredell. Lincoln. Steele wants those new planes
the economic foundation of area Mecklenburg and York (S.C.) up and pumping sewage soon.
counties, as subdivisions eat up counties, as well as in Union, "There's no stopping this area
farmland. where he was raised and still lives. around Charlotte." he said re•
■ How 10 get new suburbanites Seven years ago he helped gently, sitting in a $200,000 model
and longtime rural residents to launch the building boom within house in Stevens Mill. one of his
agree 10 build new roads. schools sight of Raeford .Parker's Iront newer Union County subdivisions.
and sewage -treatment plaints to porch. He built Clover Bend, a "It's going to engulf us all."
Growth of single-family
homes in the Charlotte
region from 1990-93.
El 0.5%
Q 5.1%-15%
® 15.1%40%
40.1%105%
i.
\ 1.1 cola"
Clcvaland .. Gaston
1
GEORGE OAEISACHER/Slan
1 Housing sprawl across county lines
Union County surgod ahead of Mecklenburg from 1990 to 1993 in
Iho paco at which It issued building permits for singte-lamily homos.
County % Increase Number increase
Union 16.1 %
3.865
Mecklenburg 10.9%
14.773
Cabarrus B.8%
2.616
Iredell 8.5%
2.368
Lincoln .6.4%
899
Cleveland 5.5%
1,390
Lancaster. S.C. 4.9%
790
York, S.C. 4.4%
1,537
Gaston 4.0%
2.050
Rowan 2.7%
892
Stanly 2.5%
437
Anson 1.3%
93
Sourer. Cenaatina Coundl of Govammenla
Staff Sgt. Kenny Harrison moves lined -up fen
recruits out to the bus at Fort Jackson In Sc
Carolina at the reception battalion Tuesda!
which drill sergeants walk the ranks of
gender -integrated training companies, Inspec
Base
Integrated training
comes to Carolinas
Continued from page 1A
year. The Army has been coed, he
said, just not to this extent.
• Up until now, the Army has been
integrated down to the company
level, Fulton said. He explained
that 10 or 12 soldiers are assigned
to a squad: four squads make up a
platoon: four platoons a company
and five companies a battalion.
After today, evert squads will be
coed.
The men and women will not
share barracks or showers or al -
tend personal hygiene and rape
prevention
ton said. A
assigned bu•
"But 99.'
training the
said.
Physical
be different
some cases,
ample, will
push-ups in
13.
Army oft
training bec
as women e
lines.
"It's hard
just makes s
said.
Women
32,000 posit
lots, comba
defense artl
excluded kr
Smoking may raise
Associated Press
WASHINGTON — Longtime cig-
arette smokers doubled their risk
of pancreatic cancer. one of the
fastest and least treatable of the
cancers. researchers found in the
' largest study of its type.
Debra Silverman of the National
Cancer Institute said Tuesday that
the study gives powerful evidence
that cigarette smoking is the cause
of about a quarter of all pancreatic
cancers in the United States and
That a hall to cigarette smoking
could save thousands of lives.
The study, to be published today
in the Journal of the National
Cancer Institute, differs from.ear-
lier work on pancreatic cancer
because it is based on one-on-one
interviews with the cancer patients
themselves.
Pancreatic cancer is so rapidly
fatal, said Silverman, that most of
ARE YOU A SMOKER???
MEN Olt WOMEN - AGES 21-28
We are currently looting fur granter. to
participate in a marketing ruse rrl, di•rur.
Woo group m, croaking. we are not .elli, g
anything, either now or iu the future. If
yogi qualify, )„u will lie paid for your
participation.
Intrresied???
1'Iraae roll (70 t) 7711- ; 7.11, and leave
your name nod i pLune number.
the earlier sti
disease retie
the next•of•
tients had ah
"Cancer c
median sun
three montl
In the star
lento, Detroit
counties ink
atic cancer
{rt
CHARLOI
BASSETT • SING
VA HOUSE • ASI
TO NAME A FEW.
ALL
ODD CHES
rc
�I 1 -NTION ALL (
ANNOVNCING THE
l3iat- \iVrr
AT THE HORNETS NEW TRAINING CEMFJ
FRIDAY NIGHT, OCTOBER 28
Goff
told us to give."' Since this is all new to him,
The check — which covers the Blume wasn't sure what to do after
cost of 100 acres sought for a netting the gift last Wednesday. He

TENTATIVE AGENDA
UNION COUNTY
Meeting
with
Division of Environmental Management
Friday, November 4,1994
Introduction
Highway 16 Description �' V c959 t��).(LV`(J p fA
-w-ks4 a .c.L&t- 1 g YProject�"T�
IdoctAyic
Permitting Issues
Water Quality
Capacity
Funding
Other Business
Adjourn

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NOV.01 '94 11:25AM MCKIM & CREED [phone]
P.2/11
MEMORANDUM
TO: Mike Shalati
FROM: Sid Riddick
DATE: October 19, 1994
RE: Response to Public Meeting Comments
Twelve Mile Creek Wastewater Facilities
M&C0771.0009.OW(11)
On September 26, 1994 a public meeting was held to receive input on Union County's proposed
Twelve Mile Creek Wastewater Treatment Facilities project. A transcript of that meeting has
been prepared. The transcript defines a range of issues presented by meeting attendees. McKim
& Creed has reviewed this transcript and grouped the comments from the attendees into a range
of issues which are evaluated below.
1) Flow Conditions in Twelve Mile Creek - ].Number of participants expressed opinions about
the impact of high flow (flood conditions) and low flow (dry weather conditions) in
Twelve Mile Creek as justifications for not locating the facilities in the proposed location
near New Town Road. Attendees correctly pointed out that Twelve Mile Creek flows are
highly variable, ranging from near 0 to significant floods and that the depth of water can
become significant during flood conditions.
a. High flows could potentially result in flooding the areas adjacent to the Creek.
Regardless of the Location of the treatment facility, a requirement of the Division
of Environmental Management will be that the interceptor sewer lines be protected
from flooding at the 100 year flood elevation and that the treatment plant be
protected from flood damage at a similar elevation. In addition, the treatment
plant must remain functional at the 25 year flood elevation. These conditions are
uniforrnally applied to all projects and not specifically Twelve Mile Creek or
Union County. In the design of interceptor sewers, flood protection is achieved
by either sealing manholes or by extending vent elevations on selected manholes
to above the 100 year flood elevation. Protection of the treatment plant is
achieved by locating the facilities above the 100 year flood level. Union County
has a flood plain ordinance which prohibits construction in the floodway and these
provisions would apply to any wastewater facilities which are built on Twelve
Mile Creek or at other locations. As is discussed in another section of this
memorandun7, McKim & Creed's evaluation of potential treatment plant sites took
into consideration flood levels to make sure that adequate land area existing above
the 100 year flood level for construction, as well as buffers and other site
development needs,
MCKIM&REED

NOV 01 '94 12:57PM MCKIM & CREED [phone]
P.1/3
b. Low flows in Twelve Mile Creek present a different situation. The meeting
attendees expressed concern about the methods used to establish low flows, as well
as the effect that low flows might have on the County's ability to locate and/or
expand a treatment plant at the New Town. Road site.
The flow data used in establishing tentative effluent limits were prepared by the
U.S. Geological Survey (USGS) and submitted to McKim & Creed in a letter
dated November 19.. 93. (This was incorrectly reported by me to be October
1992). USGS uses statistical methods based on measurements and correlations to
establish a variety of flow conditions at the sites requested. Specifically for the
Twelve Mile Creek study we requested mean and low flow data.
USGS data provided including mean annual, 7 Q10 (7 day, 10 year low flow), and
30 Q2 flows for summer and winter conditions. These data were requested for a
total 8 sites along the East and West Forks of Twelve Mile Creek, as well as the
intersection of these two creeks at Highway 16. The following table summarizes
the flow data for the New Town Road site and for Highway 16 site.
TABLE 1
Flow Characteristics
Twelve Mile Creek
Drainage Area, sq. mile
Flow Data, MGD
Average
7Q10 Summer
7Q10 Winter
30 Q 2
7Q2
New Town
Road NC 16
22.10 76.50
12.93
0
0.27
0.30
0.17
44.62
0.02
0.97
1.62
0.71
As can be seen the New Town Road site has a 7 Q10 of 0, while the 7 Q10 at
Highway 16 is 32,Xs. Similarity the 30Q2 ranges from 0.30 MGD at New Town
Road to 1.62 MGD at Highway 16.
There appeared to be confusion at the public meeting regarding the reported flow
data from USGS and citizen assertions that Twelve Mile Creek is frequently dry
and exhibits no flow. These conditions are not mutually exclusive. It is possible
that Twelve Mile Creek is dry, i.e. no flow even though the 30Q2 value is above
MCKIM&CREED

"NOV g1 '94" 12:58PM MCKIM & CREED [phone] P.3/3
Some attendees questioned the adequacy of environmental studies with particular emphasis
on cultural and historic assets. At the time McKim & Creed was preparing a scope of
services for the facilities plan, we contacted the Construction Grants Group at NCDEM
and specifically discussed the need to undertake a cultural resources survey, It was stated
at that time that the need for the cultural resources survey would be evaluated during the
preliminary environmental review process. It was also pointed out that a detailed surveys
would potentially be required on the treatment plant site but that in a general sense
cultural resources surveys were not required for interceptor sewer construction. McKim
& Creed anticipated the need to do an archaeological survey for the treatment plant since
the scope of work for the site selection task includes allowances for this work.
Other concerns were raised by meeting attendees including the potential impact of the
project on a nearby church campground. This particular site is located approximately 1.5
miles from the location of the treatment plant. The treatment facility and interceptor
sewer construction would have no direct bearing on this resource.
Several of the attendees also questioned the potential loss of prime or unique agricultural
lands and the impact of growth on traditional agricultural life styles in the area. With
respect to prime or unique agricultural lands, the surveys did not identify any that would
be lost as a result of the construction.
5) Site Selection Procedures - A number of attendees questioned the site evaluation and
procedures used by McKim • & Creed including the impact on the environment, flows,
(both high and low), as well as the proximity to development. In addition, at least one
attendee questioned why a 1/2 mile radius was arbitrary picked by McKim & Creed as
a measure of impact on existing dwellings.
The selection of a 1/2 mile radius was selected based on our belief that homes further
than this from the site would not be directly impacted. (Direct impacts would involve
noise, visual impacts, odors, etc.) A much larger radius can be used, however. It should
be pointed out that since all of the four (4) potential sites are relatively close together, the
use of a large radius to define influents would not differentiate between the site.
It was correctly pointed out that house counts ' for the residence within the 1/2 mile
proximity of each site were in error because of a failure to count homes which have
recently been constructed in Oak, Hill Plantation. A revised house count has been
prepared which indicates a total of 23 homes either completed or under construction in
Oak Hill Plantation as of September 1994. The site selection procedure has been
amended to reflect these additional data.
Flooding of Twelve Mile Creek was also indicated to be a concern to many of the
residences who state that have seen the proposed treatment plant site under water.
According to mapping data prepared by FEMA (Federal Emergency Management
Administration) the 100 year flood level on the proposed site is such that approximately
16 acres of developeable land will remain above the 100 year flood line. Also, as
reported, McKim and Creed would be responsible for preparing a detailed physical survey
MCKfM&CREED

NOV 01 '94 12:57PM MCKIM & CREED [phone] P.2/3
0. The significance of 30Q2 is related to State rules for issuing NPDES permits.
Under current State rules, NPDES permits can be issued for locations that exhibit
positive flow at the 30Q2 condition. The New Town Road site complies with this
condition.
2) Expansion Capability - A number of comments addressed the County's ability to manage
future expansions at the New Town Road site, if in fact it is possible to obtain a permit
for the initial construction. To provide a response to this concern, on October 18, 1994,
I contacted Mr. Don Safrit who is the Chief of the Water Quality Branch of the Division
of Environmental Management. Mr. Safrit is responsible for issuing proposed effluent
limits for discharges that are responsive to water quality standards and the rules of the
State. Mr. Safrit stated that his office would look carefully at the flow requested in any
NPDES permit to make sure that the requested flow was based on sound planning
requirements and that water quality standards could be maintained. He could not provide
a definite answer regarding the County' s ability to obtain a permit for long term
expansion of the plant.
At the same time we discussed the proposed Highway 16 site. According to Mr. Safrit,
since the 7 Q 10 flow at Highway 16 is nearly zero, from a modeling and water quality
prospective, effluent limits for the Highway 16 site would be as stringent as New Town
Road. The County would face the same issues regarding flow values contains in an
NPDES permit. Again Mr. Safrit stressed that his group would wish to see a sufficient
level of planning performed so that the County could meet reasonable long term needs
(between 10 and 20 year growth) within the flow values contained in an initial NPDES
permit.
Mr. Safrit went on the state that he could provide no assurances that there would not be
future changes in regulations which would make effluent limits more stringent or would
in some manner impact the County's ability to expand at either New Town Road or
Highway 16. It is McKiru & Creed's belief that adequate planning has been done to
assign flow values to each of the sites and that a next step would be to request permit
limits at each of the reasonably viable sites based on these flow projections.
3) A number of questions related to growth, land use, and zoning. These issues should be
addressed by the Union County Planning Board and Board of Commissioners through
existing procedures.
4) Environmental Reviews - A number of the attendees questioned the environmental
assessment document for thoroughness and objectivity and suggested a number of
additional studies that should be undertaken. First, with respect to the level of detail
provided in the document, there were no items identified in the environmental assessment
that we believe would prohibit Union County from building and maintaining a treatment
facility at the New Town Road site. We have not received responses from the various
environmental agencies who will be asked to comment on the environmental assessment
document however, and other unanticipated environmental questions may arise.
MCKIM&CREED

NOV 01 '94 11:27AM MCKIM & CREED [phone] P.4/11
of the site and properly locating the 100 year flood boundary on this site. At this time
there is no reason to believe that the FEMA flood mapping is significantly in error such
that a suitable amount of land would not be available on the preferred site.
6) A number of attendees suggested that the County consider relocating the site downstream
to Highway 16. This issue was touched on briefly and it was suggested that the chief
potential drawbacks to the relocation would involve the additional cost to construct
interceptor sewers and the treatment plant. Various attendees suggested that the cost of
existing the 24-inch sewer downstream would be in the range of $2 million. This
additional cost to extend the 24-inch line was reported by McKim & Creed to be
approximately $2.7 million,
Cost estimates prepared by McKim & Creed for the 24-inch interceptor sewer were based
on well over 250,000 linear feet of sewers designed by McKim & Creed in Union County
over the past 3 years. We have maintained a careful data base of construction cost and
used this as the basis of our cost estimates.
The cost of the wastewater treatment facility was also discussed. It has been reported that
if the treatment plant is moved downstream, the County will be required to enlarge the
capacity of the facility. To verify this last concern, McKim & Creed contacted Mr. Dan
Blaisdell with the Facilities Planning Group of DEM. According to Mr. Blaisdell if
projects are to receive financial assistance (loans) through the State of North Carolina,
facilities in general must be designed in accordance with the following:
a. Interceptor sewers should' be designed to meet a 20 year planning period.
Additional capacity can be provided in the sewers with up to half the pipe
reserved for unanticipated growth beyond the 20 year period.
b. Treatment works must be designed to meet a 20 year need, although treatment
facilities may be staged in 5 to 10 years increments if this can be shown to be
more cost effective than constructing a larger facility at the outset. Specifically,
in areas of high growth, Mr. Blaisdell stated it was reasonable to use less than a
10 year phasing plan for a new wastewater treatment facility project. In any case,
if Nortb. Carolina is to participate financially in Union County's planning whatever
phasing plan is selected must be shown to be cost effective.
In earlier conversations with Mr. Blaisdell, conducted when the facilities plan was
being developed, McKim & Creed was advised that the capacity of the treatment
plant would have to be sized to be consistent with the size of the service area
which was included. In the case of the Highway 16 site there are unmet needsin
the lower portion of the service area (below New Town Road) and it is McKim
& Creed' s estimate that the capacity of the treatment plant will need to be
increased from about 800,000 gallons per day to approximately 1.2 million gallons
per day (initial capacity) to meet these needs and to comply with the State s
general planning criteria.
MCKIM&CREED

NOV 01 '94 11:27AM MCKIM & CREED [phone]
P.5/11
The net result of the above planning criteria increases the projected cost of the
interceptor sewers by approximately $3.75 million and the cost of the treatment
facility by approximately $1 million, for a total project increase of about $4.75
million. An analysis of the cost impacts of the relocation is included in a separate
memorandum,
In summary, it is acknowledged that a number of very relevant issues were addressed by citizens
who attended the September 26, 1994 public hearing. As soon as review comments are received
on the initial facilities planning document (anticipated on or around November 15, 1994) a
detailed point by point response to the citizens issues and those identified by the State Review
agencies can be prepared. At that time it may also be desirable to further evaluate the option of
a downstream location or the proposed Twelve Mile Creek project as well as alternatives to
provide funding for the additional construction costs.
bbs
pc: Mike Shalati
Mark Veenstra
MCKIM&CREED

INVOICE
PCORPORATE D
cice
ENVIRONMENTAL LABORATORIES
SOLO
TO:
CUENT NO.
t •
54 Ravenscroft Drive
Asheville, NC 28801
TEL: [phone]
FAX: [phone]
Mr. Quay Whitesides
Union County Public Works
P.O. Box 987
Monroe, NC 28110
PURCHASE ORDER NO.
PROJECT MANAGER
NUMBER
93-013000
DATE
02/28/95
PLEASE REMIT TO:
PACE, Incorporated
NW 8745
P.O. Box 1450
Minneapolis, MN 55485-8745
TERMS
DUE UPON RECEIPT
PAGE NO.
OUANTITY
DESCRIPTION
UNIT PRICE TOTAL AMOUNT
Project No A50220505
Client Reference: Pass/Fail Chronic Bioassay
Samples Rec'd: 02/18/95
2.00
2.00
ANALYTICAL
Biological Services
EACH Cerio daphnia Pass/Fail Chronic (NC)
EACH Cerio daphnia Pass/Fail Chronic (NC)
-- Subtotal: ANALYTICAL
:.CCTI
AC ! (9 1
AP?RT:M _v
DAE
Total Invoice Amount
vQ G 1 1 a-`=``�_„
Lii ?.:: i
300.00
N/C
$600.00
$600.00
$600.00
1.5% MONTHLY FINANCE CHARGE ASSESSED AFTER 30 DAYS.

DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
September 16,1994
MEMORANDUM
TO: Monica Swihart
FROM: Don Safrit
SUBJECT: Proposed Twelvemile Creek Wastewater Treatment Plant
Union County 201 Facilities Plan
There are some significant issues associated with permitting the proposed discharge
to Twelvemile Creek. Dissolved oxygen in this stream has been documented at
concentrations near the state standard of 5.0 mg/1. Elevated levels of fecal,
phosphorous and turbidity also indicate impacts to water quality in this stream.
Given that water quality concerns exist within this area, permitting a wastewater
treatment plant discharge into Twelvemile Creek should only occur if no other
environmentally and economically feasible alternative exists. Review of the
alternatives analysis included in the 201 Facilities Plan raised the possibility that
there may be a feasible alternative to the proposed discharge.
The cost analysis is not provided in enough detail to fully evaluate the various
alternatives and determine the economic feasibility of the alternatives. Specifically,
missing from the cost analysis of a new discharge is the cost associated with the
treatment and disposal of the sludge that would be created by the proposed
treatment plant. There are significant costs associated with the handling of sludge,
particularly with the new federal permitting requirements. A statement in the
report that a contractor will be hired to dispose of the sludge is not sufficient. The
cost of this mechanism to handle the sludge, or any other method of handling the
sludge, must be included in the present worth analysis of the wastewater treatment
plant discharge alternative. Also not included in this analysis is the laboratory cost
associated with sampling and analyzing the wastewater.
The alternative to connect to the CMUD interceptor line is not sufficiently
documented in the 201 Facilities Plan. No documentation is supplied in the report
from CMUD to verify the cost per gallon figure that is provided. Since this is the
specific item, per the report, that makes this alternative more costly than the
alternative to construct a wastewater treatment plant with a discharge, full
documentation from CMUD should be provided supporting this figure.
Furthermore, will these costs be passed on to the individual users through user fees
or taxes?

A comparison of the charges to the users for both of these alternatives should be
provided in the report to enable the economic feasibility to be fully evaluated.
All permit decisions require that the practicable waste treatment and disposal
alternative with the least adverse impact on the environment be utilized. It is the
staff's opinion that the alternative to connect to the CMUD interceptor is the most
environmentally feasible alternative and that it is economically feasible. Even
without including the cost of sludge handling/disposal or the costs associated with
sampling/analyzing the wastewater in the present worth analysis, the cost
differential is less than 10%. Since there are documented water quality concerns
associated with Twelvemile Creek and the cost analysis in this document is
inadequate, the staff would not recommend issuance of a permit to discharge.

.10411,40
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