NC0021946_Return_20031211

NPDES DOCUHENT SCANNING COVER SHEET
NPDES Permit:
NC0021946
Rosman WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Return „ft
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
December 11, 2003
Thisa document is printed on reuse paper - igriore any
contexit cork the reszerse side

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P. E., Director
December 11, 2003
The Honorable Johnny H. Rogers, Mayor
Town of Rosman
Post Office Box 636
Rosman, North Carolina 28772-0636
*VA
NCDENR
Subject: NPDES Permit Application
Return # 2204
Town of Rosman WWTP
Transylvania County
Dear Mayor Johnny H. Rogers:
In accordance with Division policy, we must hereby return the permit application for expansion received
on May 16, 2002. This application is being returned pending resolution of the issues with the Preliminary
Engineering Report (July 18, 2003 edition) that was submitted to the DWQ Construction Grant and Loans
Section.
If you have any questions about the NPDES permitting process, contact me at the 919-733-5083 ext. 512.
Questions about permitting restrictions unique to your area should be directed to the Asheville Regional Office,
Water Quality Section at (828)-251-6208.
Attachments
cc: Asheville Regional Office/Water Quality Section
K. Lawrence Horton III, P.E. /Construction Grants and Loans
Alex Marks/DWQ Planning Branch
NPDES Permit File
Micheal Osborne, P.E. /WK Dickson 616 Colonnade Drive Charlotte, N.C. 28205
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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5 1 1,01
of
November 7, 2003
The Honorable Johnny H. Rogers, Mayor
Town of Rosman
Post Office Box 636
Rosman, North Carolina 28772-0636
SUBJECT:
Dear Mayor Rogers:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
Coleen H. Sullins, Deputy Director
Division of Water Quality
NOV 1 3 20
Town of Rosman
Preliminary Engineering Report
July 18, 2003 Amendment
Project No. E-SRG-T-02-0131
The Construction Grants and Loans Section has completed its technical and
environmental review of the subject Rosman Preliminary Engineering Report. A copy of the
comments resulting from this review is attached for your reference. These comments are also
being sent directly to your consulting engineer, W. K. Dickson, by copy of this letter. A revised
Preliminary Engineering Report that incorporates responses to these comments should be
submitted for our review and approval as soon as possible. Providing thorough and complete
responses to these review comments in a timely manner is necessary to avoid delays of the
project approval.
In an effort to reduce the schedule for the Preliminary Engineering Report approval, it is
suggested that the town and their engineer resolve the environmental issues and concerns
discussed in the attached comments by directly contacting the commenting agencies.
If you or your engineer have any questions or need assistance in resolving these
environmental issues, please call Ms. Hannah Stallings at [phone]. If you have any
questions concerning the technical review issues, please contact Mr. Rob Brown at
Construction Grants and Loans Section 1633 Mail Service Center
Web Site: www.nccgl.net
Raleigh, North Carolina 27699-1633 [phone]
FAX [phone]
NCDENR
Customer Service
1-877-623-6748

The Honorable Johnny H. Rogers, Mayor
Page 2
November 7, 2003
[phone]. Also, if there are questions concerning this review, you may contact me at
[phone].
Siricerely,
L__
K. Lawren Horton, III, P.E., Supervisor
Facilitie valuation Unit
RB/dr
Attachment (all cc's)
cc: J. Michael Osborne, P.E., W.K. Dickson
Dave Goodrich, DWQ
DWQ Asheville Regional Office
Daniel Blaisdell, P.E.
PMB/DMU/FEU/STAG/ SRG

1
TOWN OF ROSMAN
Technical Review Comments
For Rosman Preliminary Engineering Report
Project No. E-SRG-T-02-0131
November 7, 2003
General
1. On page 1 of the Executive Summary the existing WWTP is listed as a 0.90 mgd plant. This
appears to be a typographical error and should be revised.
2. A portion of this project is to be funded by a State Tribal Assistance Grant (STAG) from
federal funds. Therefore, please provide a section in the PER that addresses public
participation. One public hearing, with 30-day notification, is required.
a) A copy of the Preliminary Engineering Report should be available for review by the
public at least 15 days prior to the public hearing. The hearing should identify the
problem, discuss the selected alternative, identify the size of the projected loan, discuss
any associated inter -local agreements, and identify the effect this project will have on the
monthly sewer bill for a typical residential user.
b) Place an advertisement for the hearing in the local newspaper that identifies the time and
location of the public hearing, advises when and where a copy of the Preliminary
Engineering Report can be observed, provides a brief description of the proposed project,
advises how much funding is required, and identifies the source of funding.
c) Provide a transcript or detailed summary of the hearing, an affidavit of publication of the
hearing notice, and a copy of the resolution from the governmental unit agreeing to
implement the selected alternative. The Public Hearing must be held and this information
must be provided before the draft FNSI can be sent to EPA.
3. Again, since federal funding is included in this project, all real property associated with the
project must be acquired in accordance with the Uniform Relocation and Real Property
Assistance Act of 1970.
4. The Table of Contents should be revised to reflect any changes in the report. For example,
The Table lists the `Analysis of Option 2, Improve Rosman WWTP' as being on page 25 and
it is actually on page 27.
Section II
1. (Reference Page 9) On page 9 it is documented that the WWTP is located in a flood prone
area and falls within the 100 year flood area, therefore compliance with Executive Order
11988-Floodplain Management must be demonstrated. The objective of this Executive Order
is " ... avoid direct and indirect support of floodplain development whenever there is a
Page 1 of 5

practicable alternative ...." The following should be provided in the revised 201 Facilities
Plan:
a) A facilities plan must first demonstrate that steps have been taken to avoid
construction/modification of the floodplain. The project has to demonstrate that there are
no reasonable sites outside the floodplain that can be utilized to locate the proposed
facilities.
b) If there are sites outside the floodplain that will accommodate the proposed facilities and
it is still the desire of the applicant to construct in the floodplain, it must be demonstrated
that locating the project outside the floodplain will place a financial burden on the users.
c) If the applicant wants to construct the proposed facilities in the floodplain, the facilities
plan must demonstrate that construction will have no adverse impact on increasing flood
levels in the floodplain.
Section III
1. (Reference Page 12) Additional future flow is projected due to a proposed condominium
complex in northeast Rosman and an existing mobile home park. The population from the
condominiums and the mobile home would already be included in the accelerated 2.5%
growth rate justified on page 13. Therefore flow attributed to these areas should not be
included in the flow projections.
2. (Reference Page 13) Additional future flow is also projected from areas to be annexed into
the Rosman sewer system: Although these areas are listed as being outside the town's
existing service area, a town's growth normally would be expected to expand its service area.
Therefore the growth attributed to this item would also already be included in the growth rate
justified for the town. Please provide discussion outlining any special circumstances that
would justify inclusion of this flow as additional to the flow justified due to the accelerated
growth rate. Special circumstances would include a Capital Improvement Plan or other
planning document.
3. (Reference Page 13) Flow projections should be based on 70 GPD per capita for domestic
flow and 15 GPD per capita for commercial flow. This section should be revised to reflect
these daily flow amounts.
4. The cost of providing capacity for those flows not justified in the comments above will not
be eligible for grant or loan funding. A reserve -capacity -cost -ratio (RCCR) will be
established, if necessary, and used to determine our level of participation. In order to
facilitate the generation of this ratio, the following should be provided:
a) Demonstrate that the facility is capable of operating properly at both 0.250 millions of
gallon per day (mgd) and the revised flow reflective of the revisions requested by these
comments.
Page 2 of 5

_1
b) Provide a detailed cost estimate for the design capacity reflected by the revisions
requested above. This cost should be compared to the cost of the design capacity at 0.250
mgd. These cost estimates will be used to develop a RCCR factor that is applied to the
total project cost to determine the total eligible cost.
c) Section V should be revised, as appropriate, to indicate how the project costs will be
funded, and the economic impact on users.
5. (Reference Page 9) It is documented on this page that the Rosman Public Schools are
responsible for influent flow surges at the plant. Have any measures been undertaken to
abate these surges?
Section IV
1. (Reference Page 16) In discussing the `Failing Sewer Mains', this page notes that certain
sections are believed to be major sources of infiltration. What is the basis of this belief,
overflows, surcharges, etc.?
2. (Reference Page 16) It is recommended that sewers be extended into unsewered areas. Is
documentation of problems in the unsewered areas (failing septic tanks, public health
problems, etc.) available? If so please provide, or in the altemative, provide discussion as to
the problems in theses areas.
3. (Reference Page 16) Are the unsewered areas in comment 2 within the town limits?
4. (Reference Page 27) The report should list the reuse effluent limits that will be required and
document that the plant will be capable of meeting these limits.
5. It is our understanding that the reuse flow will be diverted to a `.sump pump' and then sprayed
on the application fields. Confirm that adequate capacity will exist at the 'sump pump'
station to provide for irrigation both at beginning flow and during average driest months.
6. (Reference Pages 34 & 35, Figure 8) The reuse application buffers utilized appear to be
greater than those required by NCAC 2H.0219(k)(1)(c)(i)(III)-(V) (attached). Please discuss
this.
7. (Reference Page 36) Initial reuse flow is estimated as 4,713,283 gallons per year, or about
13,000 gallons per day. Page 34 speaks of a future expansion of the reuse system. The
following should be addressed:
a. Will the reuse system as designed be capable of providing increased flow should
additional reuse sites become available?
b. Discuss the feasibility of expanding the reuse program in the future. Include a discussion
of any potential sites (farms, etc.) nearby. Also, discuss the town's plan for promoting
reuse.
Page 3 of 5

8. The report should list the NPDES effluent limits that will be required and document that the
plant will be capable of meeting these limits.
9. The addition of effluent turbidity monitoring is discussed in the reuse narrative; however, the
cost of this monitoring is not noted in the project costs estimates on pages 39-42. If the cost
of the monitoring is included in another line item, please identify that item. If not, the cost
estimate should be revised to include turbidity monitoring.
10. The revised report should address how sludge management will comply with 40 CFR 503
Regulations including a discussion of the methods that will be used to comply with pathogen
and vector attraction reduction.
11. Please confirm that the proposed project design will comply with NCAC 2H.0219 -Minimum
Design Requirements, and NCAC 2H.0124 - Reliability Requirements. (A copy of .0219
&.0124 is attached for reference).
12. Provide the engineering calculations/support for the sewer line layout and line size selections
and confirm the capacity of a designed gravity sewer line to carry a peak daily flow of
2.5*ADF at /2 full at the minimum available slope.
Section V
1. (Reference Page 40) In Items 6 and 7 on this page, is the cost for the structures to house the
final filter station and UV disinfection units included in the cost estimates provided?
2. (Reference Page 48) Total grant sources available as documented on this page are
$4,629,200. The estimated capital cost of the selected alternative is $4,838,550 (page 42).
Estimated grant funding and capital cost should be updated, or the source of funding for the
remaining $209,350 capital cost should be identified.
Section VI
1. The revised report should include a `Project Cost and Summary Table' for the selected
project scope that includes:
a) Capital cost of sewer rehabilitation, sewer extensions and the WWTP.
b) Engineering costs.
c) Land acquisition costs.
d) Total estimated project cost.
Appendix F
1. (Reference Appendix F) The Letter of Acceptance from the Transylvania County landfill
documents adequate capacity only until 2008. This report covers a 20-year planning period;
hence, a disposal site for the full length of the planning period must be identified, or a plan to
dispose discussed.
Page 4 of 5

5
Figures
1. (Reference Figure 1) From the flow projection in this figure, the population in Rosman is
estimated at around 580 in the year 2000. On page 13 of the report, the estimated flow in
2000 is documented as 490. One of these should be revised to eliminate this discrepancy.
Page 5 of 5

IIENT OF ENVIRONMENT AND NATURAL RESOURCES
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History Note
Statutory Authority G.S. 143-213(24): 143-215; 143-215.1;
143-215.3(a)(1),(4);
Eff. December 1, 1976;
Amended Eff. March I, 1993; October 1, 1987; December 1,
1984; June 7, 1981.
.0124 RELIABILITY
All facilities shall provide adequate reliability
measures, which, in the opinion of the Director,
will insure continued treatment and disinfection
where the interruption of such treatment would
render the waters unsafe for their best intended
uses. The reliability measures shall include the
following:
(1) For new or hydraulically expanding facili-
ties with mechanically operated components, and
for any facility designated by the Director, multi-
ple (dual at a minimum) components such as
pumps, chemical feed systems, aeration equip-
ment and disinfection equipment; and
(2) At least one of the following:
(a) dual or standby power supply on site, or
(b) approval by the Director that the facility:
(i) serves a private water distribution sys-
tem which has automatic shut-off at power
failure and no elevated water storage tanks,
and
(ii) has sufficient storage capacity that no
potential for overflow exists, or
(iii) can tolerate septic wastewater due to
prolonged detention, and
(iv) would have de minimus impacts as a
result of power failure, or
(c) a demonstration that the waters that
would be impacted by a power failure are
classified as C Waters, the applicant may be
allowed to show a history of power reliability
that would demonstrate that an alternative
power source would not be needed or demon-
strate other measures which provide compara-
ble assurances that surface waters will not be
impacted during power failures;
(3) For new or hydraulically expanding me-
chanical facilities, the treatment plant must con-
tain parallel units for components in the liquid
line (screening, primary sedimentation, biologi-
cal treatment units, chemical and physical treat-
ment units, clarifiers, disinfection and effluent
filters), unless the applicant can demonstrate to
the satisfaction of the Director that this require-
ment is unwarranted for a particular case; and
ENVIRONMENTAL MANAGEMENT
(4) For mechanical facilities with a design ca-
pacity equal to or greater than 5.0 mgd, continu-
ous operation, 24 hours, seven days per week,
with each shift staffed by at least one certified
wastewater operator shall be provided on or be-
fore October 1, 1993, unless the applicant can
demonstrate to the satisfaction of the Director
that this requirement is unwarranted for a par-
ticular case; and
(5) For facilities permitted under this Section,
the permittee must designate an Operator in Re-
sponsible Charge and a back-up operator as re-
quired by the Water Pollution Control System
Operators Certification Commission as estab-
lished in 15A NCAC 8A .0202; and
(6) In order to insure the proper operation and
maintenance of facilities permitted under this
Section, the Operator in Responsible Charge, or
back-up operator when appropriate, must oper-
ate and visit the facility as required by the Water
Pollution Control System Operators Certification
Commission as established in 15A NCAC 8A
.0202; and
(7) Compliance with other reliability measures
that, in the opinion of the Director, are necessary
in a particular case.
History Note
Statutory Authority G.S. 143-214.1; 143-215.1(b};
143-215.3(a)(1);
Eff. December 1. 1984;
Amended Eff. March 1, 1993; October 1, 1987.
.0125 PERMIT REQUIREMENTS FOR PEAT
MINING
(a) Policy. Studies on peat mining in North Car-
olina have identified effects that could adversely
impact the existing uses of the waters of the state.
As there is no experience with peat mining in
similar ecological systems, the effectiveness of pro-
posed control and mitigation measures has not
been demonstrated and must be estimated by using
methods of analyses that are not well tested by
experience. Many of the impacts of large-scale peat
mining and subsequent reclamation may be irre-
versible and may not be realized until years or
decades after peat mining is initiated. In addition,
the estuarine/wetland systems have intricate inter-
connections which are not well understood at pres-
ent and which are essential to the viability of the
very valuable public estuarine resources. Recogniz-
ing the unknowns associated with peat mining, this
Rule specifies procedures and requirements that
are necessary to ensure compliance with the water
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15A NCAC 2H.0218 DEPARTMENT
OF ENVIRONMENT AND NATURAL RESOURCES
unless the additional flow is allowed as part of a
special order or judicial order.
(e) Modification of a Local Program. After a lo-
cal sewer system program has been approved by
the Commission, any modification of the program
procedures or requirements specified in Paragraph
(a) of this Rule must be approved by the Commis-
sion to assure that the procedures and require-
ments remain at least as stringent as the state-wide
requirements of the Commission.
(0 Appeal of Local Decisions. Appeal of individu-
al permit denials or issuance with conditions the
permit applicant finds unacceptable shall be made
to the local program authority or to an appropriate
judicial level. The Commission will not consider
individual permit denials or issuance with condi-
tions to which the permittee objects. This Para-
graph does not alter the enforcement authority of
the commission as specified in G.S. 143-215.1(f).
(g) The Division shall maintain a list of all local
units of government with approved local sewer
system programs and make copies of the list avail-
able to the public upon request and payment of any
reasonable costs for reproduction. The 'list can be
obtained from: Permitting and Engineering Unit
Supervisor, Division of Environmental Manage-
ment, Water Quality Section, 'P. O. Box 29535,
Raleigh, North Carolina, 27626-0335.
History Note
Statutory Authority G.S. 143-215.1; 143-215.3(a)(1);
Eff. February 1, 1986:
Amended Eff. February 1, 1993; October 1. 1987.
.0219 MINIMUM DESIGN REQUIREMENTS
(a) All facilities requiring a permit pursuant to
this Section shall be designed following good engi-
neering practice. The plans and specifications for
all projects must be sealed by a Professional Engi-
neer. The only exceptions from the Professional
Engineer requirement are those allowed in Rule
.0205(d)(1)(A)(iii) of this Section.
(b) Waste, including treated waste, shall not be
placed directly into. or in contact with, GA classi-
fied groundwater unless such placement will not
result in a contravention of GA groundwater stan-
dards, as demonstrated by predictive calculations
or modeling methods acceptable to the Director.
(c) Impoundments, trenches or other excava-
tions made for the purpose of storing or treating
waste will not be excavated into bedrock unless the
placement of waste into such excavations will not
result in a contravention of assigned standards. as
534
demonstrated by predictive calculations or model-
ing methods acceptable to the Director.
(d) The bottoms of earthen impoundments,
trenches or other similar excavations with the ex-
ception of nitrification fields, infiltration systems,
and sewer line excavations shall be at least four
feet above the bedrock surface, except that the
bottom of excavations which are less than four feet
above bedrock shall have a liner with a hydraulic
conductivity no greater than 1 x 10-7 centimeters
per second. Liner thickness will be that thickness
necessary to achieve a leakage rate consistent with
the sensitivity of classified groundwaters. Separa-
tion distances or liner requirements may be re-
duced if it can be demonstrated by predictive cal-
culations or modeling methods acceptable to the
Director, that construction and use of these treat-
ment and disposal units will not result in contra-
vention of assigned standards.
(e) Waste shall not be applied or discharged onto
or below the land surface when the vertical separa-
tion between the waste and the seasonal high water
table is less than one foot. If the area is to be
utilized for industrial waste and has a separation of
less than three feet, and in other areas as designat-
ed by the Director, a demonstration must be made
using predictive calculations or modeling methods,
acceptable to the Director, that such placement
will not result in contravention of classified
groundwater standards.
(f) Treatment works and disposal systems utiliz-
ing earthen basins, lagoons, ponds or trenches,
excluding nitrification fields, infiltration systems,
and holding ponds containing non -industrial treat-
ed effluent prior to spray irrigation, for treatment,
storage or disposal shall have either a liner of
natural material at least one foot in thickness and
having a hydraulic conductivity of no greater than
1 x 10-6 centimeters per second when compacted,
or a synthetic liner of sufficient thickness to exhibit
structural integrity and an effective hydraulic con-
ductivity no greater than that of the natural materi-
al liner.
(g) Except as otherwise provided by these re-
quirements or by terms of a permit, all waste
treatment, storage and disposal facilities must
maintain and operate a groundwater monitoring
system as approved by the Division. The monitor-
ing system must be designed to assess the impact of
any discharge on the quality of the underlying
groundwaters and must be based on the results of
the hydrogeologic investigation.
ENVII
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ENVIRONMENTAL MANAGEMENT
(h) For pumping stations:
(1) no by-pass or overflow lines;
(2) multiple pumps shall be provided capable
of pumping at a rate of 2.5 times the average
daily flow rate with any one pump out of service.
Pump--on/Pump-off elevations shall be set such
that 2-8 pumping cycles per hour may be
achieved in the pump station at average flow. If
extended detention times are necessary due to
phased development, the need for odor and cor-
rosion control must be evaluated by the appli-
cant;
(3) at least one of the following shall be re-
quired:
(A) dual source or standby power supply on
site or;
(B) telemetry systems with sufficient num-
bers of standby generators and personnel for
distribution or;
(C) approval by the Director that the pump
station:
(i) serves a private water distribution sys-
tem which has automatic shut-off at power
failure and no elevated water storage tanks,
and
(ii) has sufficient storage capacity that no
potential for overflow exists, and
(iii) is connected to facilities that can toler-
. ate septic wastewater due to prolonged de-
tention or;
(D) where the waters that would be impact-
ed by a power failure are classified as C, the
applicant may be allowed to show a history of
power reliability that would demonstrate that
an alternative power source or other reliability
measures would not be needed;
(4) screened vents for all wet wells;
(5) high water audio and visual alarms;
(6) protection from a 100 year flood;
(7) restricted access to the site and equipment;
(8) all-weather roadway to the site.
(i) For sewer systems and sewer system exten-
sions:
(1) All building drains and building sewers
which are approved by the local building inspec-
tor in accordance with the North Carolina Build-
ing Code are deemed to be permitted by the
Environmental Management Commission;
(2) All sewers shall be designed based upon at
least minimum standards which include:
535
15A NCAC 2H.0219
(A) wastewater flow rate at design loading
should result in the sewer flowing approxi-
mately half full. The sewer must also be evalu-
ated as to its ability to carry peak loadings;
(B) a velocity of two feet per second;
(C) construction and operation shall not re-
sult in water pollution;
(D) infiltration rate limited to 100 gallons
per day per inch of pipe diameter per mile of
pipe;
(E) construction and operation consistent
with all applicable local ordinances;
(F) for public gravity sewers, a minimum
eight inch diameter pipe and for private gravi-
ty sewers, a minimum sit inch diameter pipe;
(G) minimum separations
(i) Storm sewers (verti-
cal) 12 inches
(ii) Water mains (vertical -
water over sewer)
or (horizontal)
(iii) In benched trenches
(vertical)
18 inches
10 feet
18 inches
(iv) Any private or public
water supply source,
including any WS-1
waters or Class I or
Class II impounded
reservoirs used as a
source of drinking wa-
ter 100 Feet
(v) Waters classified WS-
II, WS-III, B, SA,
ORW, HQW, or SB
[from normal high wa-
ter (or tide elevation)] 50 feet
(vi) Any other stream, lake
or impoundment 10 feet
(vii) Any building founda-
tion 5 feet
(viii) Any basement 10 feet
(ix) Top slope of embank-
ment or cuts of 2 feet
or more vertical
height 10 feet
(x) Drainage systems
(I) Interceptor drains 5 feet
(II) Ground water
lowering and sur-
face drainage
ditches 10 feet
(xi) Any swimming pool 10 feet

,4i
..-217211
15A NCAC 2H.0219 DEPARTMENT
OF ENVIRONMENT AND NATURAL RESOURCES
(xii) Ferrous sewer pipe with joints
equivalent to water main stan-
dards, shall be used where these
minimum separations cannot be
maintained. The minimum separa-
tion shall however not be less than
25 feet from a private well or 50 ft
from a public water supply well;
(H) three feet minimum cover shall be pro-
vided for all sewers unless. ferrous material
pipe is specified. Ferrous material pipe or oth-
er pipe with proper bedding to develop design
supporting strength shall be provided where
sewers are subject to traffic bearing Loads;
(I) the maximum separation between man-
holes shall be 425 feet unless written documen-
tation is submitted with the application that
the owner/authority has the capability to per-
form routine cleaning and maintenance on the
sewer at the specified manhole separation;
(J) drop manholes shall be provided where
invert separations exceed 2.5 feet;
(K) manholes shall be designed for 100—year
flood protection;
(L) an air relief valve shall be provided at all
high points along force mains;
(M) odor and corrosion control must be sat-
isfactorily addressed by the applicant for all
sewers and force mains with extended travel
times.
(j) For treatment works and disposal systems:
(1) no by-pass or overflow lines;
(2) multiple pumps if pumps are used;
(3) at least one of the following:
(A) dual source/dual feed or automatically
activated standby power supply on site, capa-
ble of powering all essential treatment compo-
nents under design conditions; or
(B) approval by the Director that the facility:
(i) serves a private water distribution sys-
tem which has automatic shut-off at power
failure and no elevated water storage tanks,
and
(ii) has sufficient storage capacity that no
potential for overflow exists, and
(iii) can tolerate septic wastewater due to
prolonged detention; or
(C) where the waters that would be impact-
ed by a power failure are classified as C Wa-
ters, the applicant may be allowed to show a
history of power reliability that would demon-
536
strate that an alternative power source or oth-
er reliability measures would not be needed;
(4) protection from 100 year flood;
(5) buffer zones of at least the following dis-
tances, and greater where necessary to comply
with Section .0400 of this Subchapter or to ad-
dress particular site or waste characteristics:
(A) Any habitable residence or place of pub-
lic assembly under separate ownership
or which is to be sold:
(i) for spray irrigation
systems (application
area) not covered by
15A NCAC 2H
.02 19(k) 400 feet
(ii) for surface residual
application 400 feet
(iii) for subsurface resid-
ual injection 200 feet
(iv) for facultative la-
goons 400 feet
(v) for activated sludge
plants or surface
sand filters 100 feet
(vi) for soil remediation
sites 100 feet
(B) Any private or public wa-
ter supply source 100 feet
(C) Streams classified as WS
or B:
(i) for subsurface dis-
posal
(ii) for non -discharge
surface disposal ex-
cept for high rate
infiltration systems 100 feet
(iii) high rate infiltration
systems 200 feet
(D) Waters classified SA or
SB:
(i)
all systems except
for high rate infil-
tration systems
50 feet
100 feet
from mean
high water
(ii) high rate infiltration
systems 200 feet
from mean
high water
(E) Any other stream, canal,
marsh, or coastal waters
(i) for subsurface dis-
posal
50 feet
ENVI]

:CES
oth-
!ded;
dis-
nply
ad-
pub -
ship
feet
feet
feet
feet
feet
met
'eet
eet
eet
aet
:et
an
er
•et
an
er
et
ENVIRONMENTAL MANAGEMENT
(ii) for non -discharge
surface disposal ex-
cept for high rate 100 feet
infiltration systems
(iii) high rate infiltration 200 feet
systems
(iv) wastewater treat-
ment facilities
(F) Any Class I or Class II
impounded reservoir
used as a source of
drinking water
(i) all systems except
for high rate infil-
tration systems
(ii) high rate infiltration
systems
50 feet
100 feet
from normal
high water
(G) Any other lake or im-
poundment:
(i) for subsurface dis-
posal
(ii) for surface disposal
except for high rate
infiltration systems
(iii) high rate infiltration
systems
(H) Any building foundation
except treatment facili-
ties:
(i) for subsurface dis-
posal
(ii) for surface disposal
(I) Any basement
(i) for subsurface dis-
posal
(ii) for surface disposal
(J) Any property line
(i) for spray irrigation
(ii) for other surface
disposal systems
(iii) for subsurface resid-
uals injection
(iv) for other surface
treatment systems
(v) for other subsurface
-systems
(vi) for soil remediation
sites
200 feet
from normal
high water
50 feet
100 feet
200 feet
10 feet
15 feet
15 feet
15 feet
150 feet
50 feet
50 feet
50 feet
50 feet
50 feet
537
15A NCAC 2H.O219
(K) Top of slope of embank-
ments or cuts of two feet
or more in vertical
height
(i) for systems other
than rapid infiltra-
tion systems
(ii) for rapid infiltration
systems
(L) Any water line from a
disposal system
(NI) Drainage systems (Ditch-
es, drains, surface water
diversions, etc):
(i)
Interceptor drains
and surface water
diversions (upslope)
(I) for subsurface
disposal
(II) for surface dis-
posal other
than spray ir-
rigation sys-
tems and rapid
infiltration sys- 10 feet
terns
(III) for spray irri-
gation systems 100 feet
(IV) for rapid infil-
tration sys- 200 feet
tems
(ii) Interceptor drains
and surface water
diversions (down -
slope)
(I) for subsurface 25 feet
disposal
(II) for surface dis-
posal other
than spray ir-
rigation sys-
tems and rapid
infiltration sys-
tems
(III) for spray irri-
gation systems
(1V) for rapid infil-
tration sys-
tems
(iii) Groundwater lower-
ing and surface
drainage ditches
(I) for subsurface
disposal
15 feet
100 feet
10 feet
19
co-
ml
°ss
ss
ti-
15
in
m
d
y
10 feet
J
25 feet
100 feet
200 feet
25 feet

15A NCAC 2H.0219 DEPARTMENT OF ENVIRONMENT AND NATURAL. RESOURCES
(II) for surface dis-
posal other
than spray ir-
rigation and
rapid infiltra-
tion systems
(III) for spray irri-
gation systems
(IV) for rapid infil-
tration sys-
tems
(N) Any swimming pool
(i) for subsurface dis-
posal
(ii) for surface disposal
(0) Any other nitrification
field (except repair area)
(P) Any well with the excep-
tion of an approved
groundwater monitoring
well
(Q) Public right-of-way sur-
face disposal
25 feet
100 feet
200 feet
15 feet
100 feet
20 feet
100 feet
50 feet
(6) flow equalization of at least 25 percent of
the facilities permitted hydraulic capacity must
be provided for all seasonal or resort facilities
and all other facilities with fluctuations in in-
fluent flow which may adversely affect the per-
formance of the system;
(7) preparation of an operational management
plan, including restricted access to the site and
equipment, and, if appropriate, a crop manage-
ment plan;
(8) except for facilities for single family resi-
dences or as approved by the Director, appropri-
ate monitoring wells designed to assess the im-
pacts on the groundwater of any discharge and
constructed in accordance with 15A NCAC 2C
.0100;
(9) a minimum of 30 days of residual holding
must be provided.
(k) For Use of Reclaimed Water: It is the intent
of the Commission to encourage the beneficial use
of the state's water resources concurrent with the
protection of public health and the environment.
(1) The following are requirements for use of
reclaimed domestic or municipal water:
(A) Where reuse is the only managed option
utilized (e.g., reuse option such as spray irriga-
tion alone):
(i) Aerated flow equalization facilities with
a capacity based upon either a representative
538
diurnal hydrograph or at least 25 percent of
the daily system design flow.
(ii) All essential treatment units shall be
provided in duplicate.
(iii) The treatment process shall produce a
tertiary quality effluent (filtered or equiva-
lent) prior to discharge to the irrigation
pond with the following quality:
(I) a monthly average TSS of less than
or equal to 5 mg/I and a daily maximum
TSS of less than or equal to 10 mg/1;
(II) monthly geometric mean fecal coli-
form level of less than or equal to '%too ml
and a daily maximum fecal coliform of less
than or equal to 23f oo ml;
(III) a monthly average BOD5 of less
than or equal to 10 mg/I and a daily maxi-
mum BOD5 of less than or equal to 15
mel;
(IV) a monthly average NH; of less than
or equal to 4 mg/I and a daily maximum
NH; of less than or equal to 6 mg/1.
(iv) Continuous on-Iine monitoring and re-
cording for turbidity or particle count and
flow shall be provided prior to discharge to
the irrigation ptmd.
(v) Effluent from the treatment facility
shall be discharged to a five-day side -stream
detention pond if either the turbidity exceeds
10 NTU or if the fecal coliform levels cannot
be met. The facility must have the ability to
return the effluent back to the treatment
facility or otherwise meet the effluent re-
quirements prior to discharge to the irriga-
tion pond.
(vi) There must be no public access to the
wastewater treatment facility or the five-day
detention pond. There shall be a 50 foot
buffer from the five day side -stream deten-
tion pond to property lines. The five day
side -stream detention pond shall have either
a liner of natural material at least one foot in
thickness and having a hydraulic conductivi-
ty of no greater than 1 x 10-6 centimeters
per second when compacted, or a synthetic
liner of sufficient thickness to exhibit struc-
tural integrity and an effective hydraulic
conductivity no greater than that required of
the natural material liner. Liner require-
ments of the five day side -stream detention
pond or separation distances between_ the
bottom of the five day side -stream detention
ENVI

ICES
nt of
ll be
ice a
tiva-
Ltion
than
Rum
ng/1;
;oh-
) ml
less
less
axi-
15
han
um
re -
to
lity
am
'ds
lot
to
:nt
re-
;a -
he
ay
)ot
�n-
ay
er
in
/i-
rs
is
c-
ic
of
e-
m
le
ENVIRONMENTAL MANAGEMENT
pond and the groundwater table may be re-
duced if it can be demonstrated by predictive
calculations or modeling methods acceptable
to the Director, that construction and use of
the five day side -stream detention pond will
not result in contravention of assigned
groundwater standards at the compliance
boundary.
(vii) The size of any irrigation pond, that
follows the five day detention pond, shall be
justified using a mass water balance based
upon a recent 25 year period utilizing
monthly average precipitation data, potential
evapotranspiration and soil drainage data
that are available from, or are representative
of, the area involved. There shall be a 50 foot
buffer from the irrigation pond to property
lines. No liners or minimum separation be-
tween the bottom of the irrigation pond and
the groundwater table will be required if it
can be demonstrated by predictive calcula-
tions or modeling methods acceptable to the
Director, that construction and use of the
irrigation pond will not result in contraven-
tion of assigned groundwater standards at
the compliance boundary.
(viii) An automatically activated standby
power source or other means to prevent
improperly treated wastewater from entering
the irrigation pond shall be provided.
(ix) There shall be a certified operator of a
grade equivalent or greater than the facility
classification on call 24 hours/day.
(B) Where reuse is utilized in combination
with other managed wastewater options (e.g.,
reuse options and discharge via National Pollu-
tant Discharge Elimination System (NPDES)
permit):
(i) Aerated flow equalization facilities with
a capacity based upon either a representative
diurnal hydrograph or at least 25 percent of
the daily system design flow.
(ii) All essential treatment units shall be
provided in duplicate.
(iii) The treatment process shall produce a
tertiary quality effluent (filtered or equiva-
lent) prior to reuse with the following quali-
ty:
(I) a monthly average TSS of less than
or equal to 5 mg/1 and a, daily maximum
TSS of less than or equal to 10 mg/1;
539
15A NCAC 21-1.0219
(II) a monthly geometric mean fecal co-
liform level of less than or equal to 14hoo ml
and a daily maximum fecal coliform of less
than or equal to No ml;
(III) a monthly average BOD3 of less
than or equal to 10 mg/I and a daily maxi-
mum BOD5 of less than or equal to 15
mg/1;
(IV) a monthly average NH3 of less than
or equal to 4 mgil and a daily maximum
NH3 of less than or equal to 6 mg/1.
(iv) Continuous on-line monitoring and re-
cording for turbidity or particle count and
flow shall be provided prior to reuse.
(v) Effluent from the treatment facility
shall not be discharged to the reuse distribu-
tion system if either the turbidity exceeds 10
NTU or if the fecal coliform levels cannot be
met. The facility must have the ability to
return the effluent back to the treatment
facility or otherwise meet the effluent re-
quirements prior to final disposition.
(vi) An automatically activated standby
power source or other means to prevent
improperly treated wastewater from entering
the reuse distribution system shall be provid-
ed.
(vii) There shall be a certified operator of a
grade equivalent or greater than the facility
classification on call 24 hours/day.
(viii) No storage facilities are required as
long as it can be demonstrated that other
permitted disposal options are available if
the reclaimed water cannot be completely
utilized.
(C) Specific requirements for use of re-
claimed domestic or municipal water:
(i) Reclaimed water for land application
to areas intended to be accessible to the
public such as residential lawns, golf
courses, cemeteries, parks, school grounds,
industrial or commercial site grounds, land-
scape areas, highway medians, roadways
and other similar areas:
(I) The rate of application shall be site -
specific and shall be in accordance with
the recommendations of either a soil scien-
tist, agronomist or an individual with at
least three years experience in the compre-
hensive evaluation of soils. The application
rate may take both the maximum soil ab-

15A NCAC 2H.0219 DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
sorption and water needs of the receiving
crop into consideration.
(II) Notification shall be provided to in-
form the public of the use of reclaimed
water (Non Potable Water) and that the
reclaimed water is not intended for drink-
ing.
(III) The compliance boundary and the
review boundary for groundwater shall be
established at the property boundary. No
buffer between the application area and
property lines shall be required. No deed
restrictions or easements will be required
to be filed on adjacent properties. Land
application of effluents must be on proper-
ty controlled by the generator unless a
contractual agreement is provided.
(IV) There shall be a 100 foot buffer
from the edge of spray influence and any
surface waters classified SA, including
wetlands as delineated and designated by
the appropriate state or federal agency.
There shall be a 25 foot buffer from the
edge of spray influence and any surface
waters not classified SA, including wet-
lands as delineated and designated by the
appropriate state or federal agency or any
swimming pool.
(V) There shall be a 100 foot buffer from
the edge of spray influence and any water
supply well. There shall be a 10 foot buffer
from the edge of spray influence and any
nonpotable well.
(VI) Complete plans and specifications
for the entire system, including treatment,
storage, application, and distribution facil-
ities shall be required in accordance with
Rule .0205(d)(7) of this Section. Treatment
works previously permitted will not need
to be shown unless they are directly tied
into the new units or are critical to the
understanding of the complete process.
(VII) A city, county, municipal or other
governmental entity that provides re-
claimed water to an approved distribution
system may submit a program description
for local approval of irrigation systems.
The program submission shall consist of
design guidance, cross -connection preven-
tion, customer education, loading rate de-
termination procedures and a complete
description of how the program will be
managed.
540
(ii) Reclaimed water for industrial pur-
poses such as process water or cooling wa-
ter, aesthetic purposes such as decorative
ponds or fountains, fire fighting or extin-
guishing, dust control, soil compaction for
construction purposes, street cleaning, vehi-
cle washing and other similar reuse options.
Notification shall be provided to inform em-
ployees or the public of the use of reclaimed
water (Non Potable Water) in these systems
and that the water is not intended for drink-
ing.
(iii) Reclaimed water used for urinal and
toilet flushing or fire protection in sprinkler
systems located in commercial or industrial
facilities can be approved by the department
if the applicant can demonstrate that public
health and the environment will be protect-
ed.
(iv) Reclaimed water shall not be used for
irrigation of direct food chain crops.
(v) Reclaimed water shall not be used for
swimming pools, hot -tubs. spas or similar
uses.
(vi) Reclaimed water shall not be used for
direct reuse as a raw potable water supply.
(D) The .following are requirements for do-
mestic or municipal reuse systems that distrib-
ute reclaimed water:
(i) All reclaimed water valves, storage fa-
cilities and outlets shall be tagged or labeled
to warn the public or employees that the
water is not intended for drinking. Where
appropriate, such warning shall inform the
public or employees to avoid contact with
the water.
(ii) All reclaimed water piping, valves, out-
lets and other appurtenances shall be color -
coded, taped, or otherwise marked to identi-
fy the source of the water as being reclaimed
water.
(I) All reclaimed water piping and ap-
purtenances shall be either colored purple
(Pantone 522) and embossed or integrally
stamped or marked "CAUTION: RE-
CLAIMED WATER —DO NOT DRINK" or
be installed with a purple (Pantone 522)
identification tape or polyethylene vinyl
wrap. The warning shall be stamped on
opposite sides of the pipe and repeated
every 3 feet or less.
EN1

CES
pur-
wa-
itive
ttin-
for
-ehi-
ons.
em-
ned
ems
ink -
and
kler
rial
ient
blic
Bct-
for
for
ilar
for
)ly.
lo-
ib-
fa-
!ed
he
:re
he
ith
1t-
)r-
ti-
ed
p-
�le
!ly
E-
or
2)
yl
m
ENVIRONMENTAL MANAGEMENT
(II) Identification tape shall be at least 3
inches wide and have white or black letter-
ing on purple (Pantone 522) field stating
"CAUTION: RECLAIMED WATER —DO
NOT DRINK". Identification tape shall be
installed on top of reclaimed water pipe-
lines, fastened at least every 10 feet to
each pipe length and run continuously the
entire length of the pipe.
(III) Existing underground distribution
systems retrofitted for the purpose of dis-
tributing reclaimed water shall be taped or
otherwise identified as in Subpart (I) or
(II) of this Paragraph. This identification
need not extend the entire length of the
distribution system but shall be incorpo-
rated within 10 feet of crossing any pota-
ble water supply line or sanitary sewer
line.
(iii) All reclaimed water valves and outlets
shall be of a type, or secured in a manner,
that permits operation by authorized person-
nel only.
(iv) Above ground hose bibs (spigots or
other hand operated connections) shall not
be present. Hose bibs shall be located in
locked, below grade vaults which shall be
clearly labeled as being of nonpotable quali-
ty. As an alternative to the use of locked,
below grade vaults with standard hose bib
services, hose bibs which can only be operat-
ed by a special tool may be placed in non -
lockable underground service boxes clearly
labeled as nonpotable water.
(v) Tank Trucks
(I) Tank trucks and other equipment
used to distribute reclaimed water shall be
clearly identified with advisory signs.
(II) Tank trucks used to transport re-
claimed water shall not be used to trans-
port potable water that is used for drink-
ing or other potable purposes.
(III) Tank trucks used to transport re-
claimed water shall not be filled through
on -board piping or removable hoses that
may subsequently be used to fill tanks with
water from a potable water supply.
(vi) Cross -Connection Control
(I) There shall be no direct cross -con-
nections between the reclaimed water and
potable water systems.
541
15A NCAC 2H.0219
(II) Where both reclaimed water and
potable water are supplied to a reclaimed
water use area, a reduced pressure princi-
ple backflow prevention device or an ap-
proved air gap separation shall be install-
ed at the potable water service connection
to the use area. The installation of the
reduced pressure principal backflow pre-
vention device shall allow proper testing.
(III) Where potable water is used to
supplement a reclaimed water system,
there shall be an air gap separation, ap-
proved and regularly inspected by the po-
table water supplier, between the potable
water and reclaimed water systems.
(2) The use of treated industrial effluents or
other industrial water streams created prior to
final treatment that are to be used in industrial
processes such as cooling water make-up, pro-
cess waters, or fire fighting or extinguishing,
shall not require a non -discharge permit as long
as the recycle system operates as a closed -loop
system. Other uses of reclaimed industrial water
are subject to the following requirements:
(A) The generator shall demonstrate that the
quality of the effluent is such that employee
health and safety is -protected and all other
applicable state and federal health and safety
requirements are met. If domestic wastewater
is in the industrial wastewater, the monthly
geometric mean fecal coliform level shall be
less than or equal to ilioo ml and the daily
maximum fecal coliform shall be less than or
equal to ` ioo ml prior to reuse.
(B) Use of treated industrial effluents exter-
nal to industrial processes shall be subject to
the following requirements:
(i) Reclaimed water for land application
areas under the control of the subject facility
such as industrial or commercial site
grounds, landscape areas, highway medians,
roadways and other similar areas:
(I) The rate of application shall be site -
specific and shall be in accordance with
the recommendations of either a soil scien-
tist, agronomist or an individual with at
least three years experience in the compre-
hensive evaluation of soils. The application
rate may take both the maximum soil ab-
sorption and water needs of the receiving
crop into consideration.
(II) Notification shall be provided to in-
form employees or guests of the use of
'.k

15A NCAC 2H.0219 DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
reclaimed water (Non Potable Water) and
that the reclaimed water is not intended
for drinking.
(III) There shall be a 100 foot buffer
from the edge of spray influence and any
surface waters classified SA, including
wetlands as delineated and designated by
the appropriate state or federal agency.
There shall be a 25 foot buffer from the
edge of spray influence and any surface
waters not classified SA, including wet-
lands as delineated and designated by the
appropriate state or federal agency or any
swimming pool.
(IV) The compliance boundary and the
review boundary for groundwater shall be
established at the property boundary. No
buffer between the application area and
property lines shall be required. No deed
restrictions or easements will be required
to be filed on adjacent properties. Land
application of effluents must be on proper-
ty controlled by the generator unless ap-
propriate contractual agreements are pro-
vided.
(V) There shall be a 100 foot buffer from
the edge of spray influence and any water
supply well. There shall be a 10 foot buffer
from the edge of spray influence and any
nonpotable well.
(VI) Complete plans and specifications
for the entire system, including treatment,
storage, application, and distribution facil-
ities shall be required in accordance with
Rule .0205(d)(7) of this Section. Treatment
works previously permitted will not need
to be shown unless they are directly tied
into the new units or are critical to the
understanding of the complete process.
(VII) If the industrial reuse system is
completely non -discharge, storage require-
ments shall be in accordance with Sub-
parts (k)(I)(A)(vi) and (k)(1)(A)(vii) of this
Rule.
(ii) Reclaimed industrial water may be
used for purposes such as decorative ponds
or fountains, dust control, soil compaction
for construction purposes. street or parking
lot cleaning, vehicle washing and other simi-
lar reuse options. Notification shall be pro-
vided to inform employees of the use of
reclaimed water (Non Potable Water) in
542
these systems and that the water is not in-
tended for drinking.
(iii) Reclaimed industrial water used for
urinal and toilet flushing or fire protection in
sprinkler systems located in commercial or
industrial facilities can be approved by the
department if the applicant can demonstrate
that public health and the environment will
be protected.
(iv) Reclaimed industrial water shall not
be used for irrigation of direct food chain
crops.
(v) Reclaimed industrial water shall not be
used for swimming pools, hot -tubs, spas or
similar uses.
(vi) Reclaimed industrial water shall not
be used for direct reuse as a raw potable
water supply.
(C) The following are requirements for in-
dustrial reuse systems that distribute reclaimed
water within the property boundaries of the
generating facility:
(i) All reclaimed water valves, piping, stor-
age facilities, outlets and other means of
distribution shall be tagged or labeled to
inform employees that the water is not in-
tended for drinking. Where appropriate,
such notification shall inform the employees
to avoid contact with the water.
(ii) Cross —Connection Control
(I) There shall be no direct cross -con-
nections between the reclaimed water and
potable water systems.
(II) Where potable water is used to sup-
plement a reclaimed water system, there
shall be an air gap separation, approved
and inspected by the potable water suppli-
er, between the potable water and re-
claimed water systems.
(D) The following are requirements for in-
dustrial reuse systems that distribute reclaimed
water outside the property boundaries of the
generating facility:
(i) All reclaimed water valves, storage fa-
cilities and outlets shall be tagged or labeled
to warn the public or employees that the
water is not intended for drinking. Where
appropriate, such notification shall inform
the public or employees to avoid contact
with the water.
(ii) All reclaimed water piping, valves, out-
lets and other appurtenances shall be color -
EN\

1RCES
lot in-
ed for
Lion in
:ial or
by the
istrate
at will
ill not
chain
not be
ias or
11 not
atable
Dr in-
iimed
)f the
. stor-
ns of
=d to
at in-
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.-con-
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sup -
there
-owed
ippli-
I re-
r in-
imed
f the
e fa-
;eled
the
here
Form
itact
out-
a1or-
ENVIRONMENTAL MANAGEMENT
coded, taped, or otherwise marked to identi-
fy the source of the water as being reclaimed
water.
(1) All reclaimed water piping and ap-
purtenances shall be either colored purple
(Pantone 522) and embossed or integrally
stamped or marked "CAUTION: RE-
CLAIMED WATER —DO NOT DRINK" or
be installed with a purple (Pantone 522)
identification tape or polyethylene vinyl
wrap. The warning shall be stamped on
opposite sides of the pipe and repeated
every 3 feet or less.
(II) Identification tape shall be at least 3
inches wide and have white or black letter-
ing on purple (Pantone 522) field stating
"CAUTION: RECLAIMED WATER —DO
NOT DRINK". Identification tape shall be
installed on top of reclaimed water pipe-
lines, fastened at least every 10 feet to
each pipe length and run continuously the
entire length of the pipe.
(III) Existing underground distribution
systems retrofitted for the purpose of dis-
tributing reclaimed water shall be, taped or
otherwise identified as in Subpart (I) or
(II) of this Paragraph. This identification
need not extend the entire length of the
distribution system but shall be incorpo-
rated within 10 feet of crossing any pota-
ble water supply line or sanitary sewer
line.
(iii) All reclaimed water valves and outlets
shall be of a type, or secured in a manner,
that permits operation by authorized person-
nel only.
(iv) Above ground hose bibs (spigots or
other hand operated connections) shall not
be present. Hose bibs shall be located in
locked, below grade vaults which shall be
clearly labeled as being of nonpotable quali-
ty. As an alternative to the use of locked,
below grade vaults with standard hose bib
services, hose bibs which can only be operat-
ed by a special tool may be placed in non -
lockable underground service boxes dearly
labeled as nonpotable water.
•
(v) Tank Trucks
(I) Tank trucks and other equipment
used to distribute reclaimed water shall be
clearly identified with advisory signs.
(II) Tank trucks used to transport re-
claimed water shall not be used to trans-
543
15A NCAC 2H.0219
port potable water that is used for drink-
ing or other potable purposes.
(III) Tank trucks used to transport re-
claimed water shall not be filled through
on -board piping or removable hoses that
may subsequently be used to fill tanks with
water from a potable water supply.
(vi) Cross -Connection Control
(I) There shall be no direct cross -con-
nections between the reclaimed water and
potable water systems.
(II) Where both reclaimed water and
potable water are supplied to a reclaimed
water use area, a reduced pressure princi-
ple backflow prevention device or an ap-
proved air gap separation shall be install-
ed at the potable water service connection
to the use area. The installation of the
reduced pressure principal backflow pre-
vention device shall allow proper testing.
(III) Where potable water is used to
supplement a reclaimed water system,
there shall be an air gap separation, ap-
proved and regularly inspected by the po-
table water supplier, between the potable
water and reclaimed water systems.
(1) Wastewater Flow Rates:
(1) In determining the volume of sewage from
dwelling units, the flow rate shall be 120 gallons
per day per bedroom. The minimum volume of
sewage from each dwelling unit shall be 240
gallons per day and each additional bedroom
above two bedrooms will increase the volume by
120 gallons per day. Each bedroom or any other
room or addition that can reasonably be expect-
ed to function as a bedroom hall be theconsidered
a bedroom for design purposes.
occu-
pancy of a dwelling unit exceeds two persons per
bedroom, the volume of sewage shall be deter-
mined by the maximum occupancy at a rate of
60 gallons per person per day.
(2) The following table shall be used to deter-
mine the minimum allowable design daily flow
of wastewater facilities. Design flow rates for
establishments not identified below shall be de-
termined using available flow
data,
patterns, water-using
eru ing
fixtures, occupancy or operation
other measured data.

15A NCAC 2H.0219 DEPARTMENT
OF ENVIRONMENT AND NATURAL RESOURCES
Type of Establishments
Airports, also RR Stations,
bus terminals. (not in-
cluding food service fa-
cilities)
Barber Shops
Bars, Cocktail Lounges
(not including food ser-
vices)
Beauty Shops
Bowling Alleys
Businesses (other than
those listed in this table)
Camps
Construction or work
camps
Summer camps
Camp grounds Without
water and sewer hook-
ups
Travel trailer/recreational
vehicle park with water
and sewer hookup
Churches (not including
food service, day care
and camps)
Country Clubs —Resident
Members
• Nonresident Members
Day Care Facilities
Factories (exclusive of in-
dustrial wastes) — per
shift
Add for showers — per
shift
Food Service Facilities
Restaurants (including
fast food)
24-hour Restaurants
Single -Service (exclusive
of fast food)
Food Stands
(1) Per 100 square feet
of total floor space
(2) Add per employee
Hospitals
Laundries (self-service)
Marinas
With bathhouse
Meat Markets
(1) Per 100 square feet
of total floor space
(2) Add per employee
Daily Flow
For Design
5 gal/passenger
50 gal/chair
20 gal/seat
gal/booth or
125 bowl
50 gal/lane
25 gal/employee
60 gal/person
60 gal/person
100 gal/campsite
120 gal/campsite
3 gal/seat
60 gal/person
20 gal/person
15 gal/person
25 gal/person
10 gal/person
40 gal/seat or
40 gal/15 ft2 of
dining area,
whichever
is greater
50 gal/seat
25 gal/seat
50 gal
25 gal
300 gal/bed
500 gal/machine
10 gal/boat slip
30 gal/boat slip
Type of Establishments
Motels/Hotel
with cooking facilities in
room
Nursing/Rest Homes
With laundry
Without laundry
Offices — per shift
Residential Care Facilities
Resort (e.g. condominiums,
apartments, motels, ho-
tels)
Restaurants
Schools
Day Schools
With cafeteria, gym,
and showers
With cafeteria only
With neither cafete-
ria nor showers
Boarding
Service Stations
Stadiums, Auditoriums,
Theaters, Drive-ins
Stores, shopping centers
and malls — Note: if
food service is included,
add 40 gal/seat
Swimming Pools and Bath-
houses
Daily Flow
For Design
120 gal/room
175 gal/room
120
60
25
60
200
40
40
gal/bed
gal/bed
gal/person
gal/person
gal/room
gal/seat or
gal/15 ft2 of
dining area
(whichever
is greater)
15 gal/student
12 gal/student
10
60
250
gat'student
gal/person
gal/water closet
or urinal
5 gal/seat or space
120 gal/1000 ft2
10 gal/person
(3) An adjusted daily sewage flow may be
granted upon a showing that a sewage system is
adequate to meet actual daily water consumption
from a facility included in Subparagraph (1) or
(2) of this Paragraph. Documented, representa-
tive data from that facility or a comparable facili-
ty shall be submitted, consisting of at least 12
consecutive monthly total water consumption
readings and daily total water consumption read-
ings for at least 30 consecutive days of water use.
The daily readings shall be taken during a pro-
jected peak sewage flow month. The adjusted
design daily sewage flow shall be determined by
taking the numerical average of the daily read-
ings that fall within the upper 10 percent of the
daily readings when ranked in descending order.
50 gal (m) For Treatment and Disposal of Soil Contain-
25 gal ing Petroleum Products:
544
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ENVIRONMENTAL MANAGEMENT
15A NCAC 2H.0219
(1) Landfarming of Soils Containing Petrole-
um Products at Minimum Rates. Petroleum con-
taminated soils shall be incorporated into the
native soils of the receiver site immediately upon
application. Liming, fertilization, and aeration of
the soils mixture shall be optional, unless other-
wise required by the Division. Subsequent appli-
cation of petroleum contaminated soils onto the
same receiver site shall not occur for at least 18
months from the date of the most recent applica-
tion of petroleum contaminated soils and shall
cause the receiver site to be reclassified as a
"dedicated remediation site" unless the permit -
tee or applicant can demonstrate, through soil
sampling and contaminant analytical procedures
approved by the Department, that the petroleum
contaminant level in the upper eight inches of
the receiver site soils is below analytical detec-
tion levels;
(2) Landfarming of Soil Containing Petroleum
Products at Conventional Rates. Landfarming of
soils containing petroleum product at an applica-
tion thickness greater than one inch shall require
fertilization, liming, and aeration of the native
soils andpetroleum contaminated soils mixture
as approved by the Division. Application thick-
ness shall be based upon the nature of the receiv-
er site soils, depth to the seasonal high water
table, the intended cover crop, and the source of
contamination. in accordance with procedures
approved by the Division. Operation of the land -
farming program shall not result in contraven-
tion of classified groundwater or surface water
quality standards. Subsequent application of pe-
troleum contaminated soils onto the same receiv-
er site shall not occur for at Least 18 months from
the date of the most recent application of petrole-
um contaminated soils and shall cause the re-
ceiver site to be reclassified as a "dedicated
disposal site" unless the permittee or applicant
can demonstrate, through soil sampling and con-
taminant analytical procedures approved by the
Department, that the petroleum contaminant lev-
el in the upper eight inches of the receiver site
soils is below analytical detection levels;
(3) Containment and Treatment of Soil Con-
taining Petroleum Products:
(A) A containment structure designed to
bioremediate or volatilize soil containing pe-
troleum products shall be constructed of either
a synthetic liner of at least 30 mils thickness or
of a one foot thick liner of natural material,
compacted to at least 95 percent standard
545
proctor dry density and with a permeability of
less than 1 x 10-7cm/sec.
(B) The bottom of the containment structure
shall be at Ieast three feet above the seasonal
high water table or bedrock.
(C) A leachate collection system must be in-
stalled in order to prevent runoff from the
petroleum contaminated soils within the con-
tainment structure, or steps taken to avoid
accumulation of stormwater within the con-
tainment structure.
(4) Disposal of Petroleum Contaminated Soils
at Dedicated Sites. Subsequent applications of
petroleum contaminated soils at dedicated sites
shall not recur until such time as it can be
demonstrated, by computer modeling or pre-
dictive calculations, that additional applications
of contaminated soils will not result in the con-
travention of any applicable environmental stan-
dards. Disposal of petroleum contaminated soils
at dedicated sites• shall conform to procedures
established by the Division.
(n) For Systems utilizing Infiltration Galleries:
(1) An infiltration gallery shall be designed
such that its largest surface dimension is greater
than its depth and no vertical piping shall be
installed within the trench.
(2) An infiltration gallery shall be designed
such that discharges from the infiltration gallery
which reach the water table must be within the
zone of influence of any on -site groundwater
recovery system, and must not cause or contrib-
ute to the migration of contaminants into previ-
ously uncontaminated areas. Predictive modeling
shall be used to estimate the zone of influence,
infiltration rate, groundwater movement and
flow direction.
(o) Additional requirements:
(1) distance between water supply wells and
waste facilities in accordance with Rule 2C
.0107(a) of this Chapter or, if a greater area may
be impacted, a distance in accordance with the
perimeter of compliance described in Subchapter
2L of this Chapter;
(2) compliance with the groundwater stan-
dards specified in Subchapter 2L of this Chapter;
(3) where applicable compliance with rules on
"coastal waste treatment disposal" found in Sec-
tion .0400 of this Subchapter; and
(4) For subsurface disposal systems, compli-
ance with rules on subsurface disposal systems
found in 15A NCAC 18A .1900. Copies of these

15A NCAC 2H.0219 DEPARTMENT
OF ENVIRONMENT AND NATURAL RESOURCES
Rules are available from The Division of Envi-
ronmental Health, P.O. Box 29535, Raleigh,
North Carolina 27626-0535.
(p) Alternative Design Criteria may be approved
by the Director. This approval will only be given in
cases where the applicant can demonstrate that the
Alternative Design Criteria will provide the follow-
ing:
(1) Equal or better treatment of the waste; and
(2) Equal or better protection of the waters of
the state; and
(3) No increased potential for nuisance condi-
tions.
History Note
Authority G.S. 143-215.1; 143-215.3(a)(1);
Eff. October 1, 1987;
Amended Eff. February 1, 1993; August 1, 1988;
RRC Objection Eff. April 18. 1996 due to lack of statutory
authority;
Amended Eff. June 1, 1996.
.0220 CERTIFICATION OF COMPLETION
Prior to the operation of any sewer system, treat-
ment works or disposal system for which an indi-
vidual permit has been issued in accordance with
this Section, a certification must be received by the
permitting agency from a professional engineer
certifying that the sewer system, treatment works
or disposal system has been installed in accordance
with the approved plans and specifications. For
facilities with phased construction or where there
is a need to operate certain equipment under actu-
al operating conditions prior to certification, addi-
tional certification may be needed as follow-ups to
the initial, pre -operation, certification.
History Note
Statutory Authority G.S. 143-215.1;
Eff. October 1, 1987;
Amended Eff. February 1, 1993.
.0221 OPERATIONAL AGREEMENTS
Prior to issuance or reissuance of a permit pur-
suant to this Section for a wastewater facility as
specified in G.S. 143-215.1(dl), the applicant must
either provide evidence to show that the applicant
has been designated as a public utility by the State
Utilities Commission or enter into a properly exe-
cuted operational agreement with the Division of
Environmental Management. The requirement for
assurance of financial solvency will be made on a
case by case determination.
546
History Note
Statutory Authority G.S. 143-215.I(dl );
Eff. October 1. 1987.
.0222 THE WASTEWATER TREATMENT
WORKS EMERGENCY FUND
(a) In cases in which water quality standards are
violated or an environmental health threat exists,
monies from the Wastewater Treatment Works
Emergency Maintenance, Operation and Repair
Fund may be used at the discretion of the Director
to correct the cause of such conditions.
(b) In this, the Director shall:
(1) Ensure the fiscal integrity of the fund;
(2) Use the fund only as a measure of last
resort to protect water quality or public health
when all other compliance and enforcement pro-
cedures have failed;
(3) Limit the use of the fund to wastewater
treatment works with design flow capacities of
less than or equal to one hundred thousand gal-
lons per day (100,000 GPD);
(4) Notify the permittee by certified mail of the
intention to take emergency corrective action
and to recoup monies spend;
(5) Make every effort to recoup fund expendi-
tures. including collection costs, from the parties
responsible; and
(6) Coordinate use of the fund with the pro-
gram of the Public Utilities Commission when a
permittee is also a regulated utility.
History Note
Statutory Authority G.S. 143-215.3(a); 143-215.313(c);
143-215.3B(e);
Eff. August 1, 1988;
Amended Eff. February 1, 1993.
.0223 DEMONSTRATION OF FUTURE WASTE-
WATER TREATMENT CAPACITIES
In order to insure that treatment systems do not
exceed their hydraulic treatment capacities, no per-
mits for sewer line extensions will be issued to
wastewater treatment systems owned or operated
by municipalities, counties, sanitary districts or
public utilities after January 1, 1994 unless they
meet the following requirements:
(1) Prior to exceeding 80 percent of the waste-
water treatment system's permitted hydraulic ca-
pacity (based on the average flow of calendar
year 1993 or any subsequent calendar year), the
permittee must submit an approvable engineer-
ing evaluation of their future wastewater treat-
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TOWN OF ROSMAN
Environmental Review Comments
Wastewater Treatment Plant Replacement, Collection System
Improvements, and New Spray Irrigation Site
Project No. E-SRG-T-02-0131
November 5, 2003
Unresolved Issues
1. All of the proposed wastewater collection, transport, reuse, and treatment plant facilities for
the selected alternative must be identified on an 8 Y2" x 11" topographical map. The length
and size of all replacement/rehabilitation/extension sewer lines must also be provided on a
topographical map.
Please adjust the legend for the facilities maps so that the full text description of the
proposed project is visible.
2. Identify the source of Rosman's potable water, and indicate if the supply is adequate to serve
future needs.
Please provide the name of the aquifer from which the supply is taken and comment on
the adequacy of the supply.
3. The Corps of Engineers should evaluate the proposed project sites to determine if
jurisdictional wetlands will be impacted. A letter of confirmation should be provided from
the Corps. The report needs to indicate that steps will be taken to avoid construction in
wetlands and/or appropriate mitigative measures will be implemented to minimize adverse
impacts.
Such documentation was not found.
4. Executive Order 11988: Floodplain Management — requires an action or project to avoid, to
the extent possible, the long- and short-term adverse impacts associated with the direct and
indirect occupancy and modification of floodplains. The environmental assessment needs to
demonstrate that steps have been taken to avoid the construction of a new wastewater
treatment plant and transport facilities in the 100-year flood plain. The report needs to
document that there are no other feasible sites, which are not in the 100-year floodplain,
available for constructing the wastewater treatment plant.
If it is not economically feasible to place the facilities in a non -flood prone area, please
state so and explain why this is the case.
Please identify the change in local topography that will be created by this project. Identify
and evaluate any encroachments of the project on flood plains.
5. What policies and regulatory measures (e.g., flood plain protection, wetland preservation,
greenway conservation, stormwater runoff, riparian buffers, etc.) are available to protect
water quality from secondary growth and development?
In the discussions on Floodplain Impacts and Mitigation and Water Quality Impacts and
Mitigation, it is stated that local regulations to protect these environmental sectors from
adverse impacts of new development are discussed in Section 5.0. The discussion found
in Section 5.0 is misleading. The narrative provided on the Watershed Protection
Ordinance enacted by Transylvania County and the Town of Rosman is irrelevant since
Page 1 of 5

none of the areas addressed by the ordinance are in Rosman. Please only discuss
measures that are enforceable in the Town of Rosman when discussing mitigative
measures that will lessen the environmental impact of the proposed project.
Proposed Project Description
1. Please provide an estimate of the total number of acres to be disturbed and the acreage of the
footprint of the entire project.
2. Please address any site improvements, such as grading or filling, that may be necessary at the
new WWTP location.
3. The Environmental Assessment states that "The digested and dewatered sludge ... will be
hauled by truck to an approved landfill or land applied on agricultural land approved by
DENR for this purpose." Please clarify if this statement reflects an uncertainty of which
disposal option will be pursued or whether there will be two means of disposal for the
biosolids produced from the proposed project.
Purpose and Need
1. The Environmental Assessment states that "Wastewater flows will increase due to population
growth, expansion of the collection system into unserved areas, and planned industrial
expansion." In the Executive Summary, it is stated that "Most of the additional wastewater
flow will come from existing residents not yet connected to public sewer." Please resolve
these conflicting statements.
2. Please provide more information concerning the type of industrial expansion mentioned in
the narrative.
Project Alternatives
1. Please add a section to the discussion of project alternatives that discusses optimizing the use
of the existing facilities.
2. Please add a section to the discussion of project alternatives that discusses a non -discharge
alternative for all of the effluent from the proposed facility.
Existing Environment & Project Impacts
Geography and Land Use
Existing Environment
1. If applicable, identify the current zoning classification of the project sites and the
surrounding areas. Additionally, please discuss how the current land use fits into the entire
area in terms of conservation, development, and ecological function.
Land Use Impacts and Mitigation
1. The Environmental Assessment states that:
"No significant direct or indirect land use impacts are anticipated, and no
project -specific mitigation is needed. Compatibility issues among adjacent
land uses will be addressed by Town planning and zoning boards in
accordance with zoning and development ordinances. Local ordinances and
programs that help minimize adverse impacts of new development are
discussed in section 4.0"
This statement is in conflict with the earlier statement that "The project will convert about
two acres of fallow agricultural land to public utility use." Please resolve these conflicting
Page 2 of 5

statements.
Soils and Important Farmlands
Existing Environment
1. In addition to listing the soil types present in the project area, please provide a description of
the soils themselves. Also include a discussion of any soil types that might prove to be a
constraint to the project such as any fill or wetland soil types.
Important Farmland Impacts and Mitigation
1. Will this project cause any soil disturbance or contamination? If soil is expected to be
contaminated, discuss the contaminant.
2. If soil is to be moved, how many square yards/feet will be moved and to what location?
Floodplains
Floodplain Impacts and Mitigation
1. The Environmental Assessment states that "Removal of the old WWTP and restoration of the
previous floodplain grade will in part mitigate the hydrologic impacts of the new WWTP
structures." Please provide a discussion of the anticipated effects from the unmitigated
impacts of flooding that will be realized from the proposed project.
Jurisdictional Wetlands and Waters
Existing Environment
1. While this section does describe the physical condition of the wetlands at the project sites
and surrounding areas, further description of the wetlands is necessary. Please describe the
primary function of the wetland (e.g., flood control, wildlife habitat, groundwater recharge),
and other factors that indicate the relative importance of the function to the total wetland
resources of the area.
Jurisdictional Wetlands and Waters Impacts and Mitigation
1. The Environmental Assessment states that "Impacts to streams and wetlands from
construction of the proposed sewerlines and effluent outfall will be permitted using COE
Nationwide Permit 12 and its corresponding DWQ General Water Quality Certification." If
possible, please be more specific and state actual measures that will be taken to mitigate for
environmental impacts of the proposed project.
2. The Environmental Assessment states that "Crossings may be constructed by trenching or
directional drilling; the project engineers have not yet determined for each crossing which
method will be most feasible." If trenching will be used, please discuss the mitigative
measures that will be performed to lessen the environmental impact resulting from this
action.
Air Quality
Existing Environment
1. Please address whether there have been any previous odor problems or complaints due to the
existing facilities.
Noise
1. Please discuss the current noise levels on the site with a measurable benchmark, if possible.
Page 3 of 5

2. At what distance will increased noise levels associated with the proposed project be heard?
Will surrounding properties be affected by noise level?
Water Resources
Groundwater Resources
1. Please expand upon the discussion of groundwater resources to include water quality, depth
of the aquifer, and recharge rates.
2. Please confirm whether Rosman's wells serve all to be served by the proposed project.
Water Quality Impacts and Mitigation
1. Please address how the proposed project will affect groundwater resources.
2. Please address any impact that application of effluent at the spray irrigation facility may have
on groundwater resources.
Forest Resources
1. Please add this section and provide a listing of the types of forest resources (for example,
hardwoods/pines) at or near the site.
2. If any forest resources are destroyed by this activity, describe the forestry practices to be
used. If forest resources will not be impacted by the proposed project, please state so.
Fish and Wildlife Resources
Fish and Aquatic Habitats
1. An estimate is provided on the approximate number of shellfish species in the project area.
Please be more specific and provide a listing of the species present.
2. Are there categories of shellfish beds/fish habitats at or near the site? Are these closed beds,
highly productive areas, or spawning areas?
Fish and Wildlife Habitat Impacts and Mitigation
1. Please address the direct impacts that the proposed project will have upon shellfish and/or
fish during construction.
2. The Environmental Assessment states that "Sewer lines crossing streams will be buried
below the stream bed and will not pose a barrier to movement of aquatic animals after
construction is complete." On page 11, it is stated that "Crossings may be constructed by
trenching or directional drilling; the project engineers have not yet determined for each
crossing which method will be most feasible." If trenching will be used, please discuss the
mitigative measures that will be performed to lessen the environmental impact resulting from
this action.
State and Federal Protected Species
Protected Species Impacts and Mitigation
1. The Environmental Assessment states that "Aquatic protected species known from the
French Broad River ... might be present near the Rosman WWTP, but are unlikely to be
adversely affected by project construction or operation, as instream construction will be
minor ..." Previous statements in the Environmental Assessment display an uncertainty of
the stream crossing method that will be used. Since it is not yet clear which crossing method
will be used, it is misleading to state that "instream construction will be minor." Please
modify this statement as appropriate once a crossing method is decided upon.
Page 4 of 5

Socio-Economics & Environmental Justice
1. Prior to the issuance of a Finding of No Significant Impact, the Construction Grants and
Loans Section prefers that the applicant determine what impact the proposed project will
have on minority and low-income populations as consistent with Executive Order 12898 -
Federal Actions to Address Environmental Justice in Minority Populations and Low -Income
Populations. This task includes the following:
(a) Identify and document the existence of minority and low-income populations in
the service area, or such populations that exist in proximity to the service area;
(b) If minority and/or low-income populations exist, an explanation must be provided if
there are disparities in the provision and location of sewer treatment and transport
facilities between the general population and the minority and/or low-income
populations;
(c) Document if the minority and/or low-income populations have suffered historically
from environmental and health risks or hazards. If the minority and/or low-income
populations are impacted by the proposed plan, did the citizens have the opportunity to
participate in the decision -making process? If the subject populations have not
participated in the decision -making process, additional public participation efforts may
be required; and
(d) If the minority and/or low-income populations are impacted disproportionately
and/or adversely by the proposed plan, the applicant may need to re-evaluate
alternatives and develop mitigative measures to minimize adverse impacts.
Summary of Mitigation
1. Please move these sections of the narrative to their corresponding areas under the discussion
of impacts and mitigation for each section of the Existing Environment & Project Impacts.
This will provide a clearer description of how these various measures will operate to mitigate
indirect and cumulative adverse impacts of future urban growth in the proposed project's
service area.
Other
1. Please be certain that information on the existing facilities contained in the Preliminary
Engineering Report and the Environmental Assessment are alike.
2. Please be certain that the alternatives analysis contained in the Preliminary Engineering
Report and the Environmental Assessment are alike.
3. Please be certain that any issues raised in the technical review of the Preliminary Engineering
Report are reflected in the text of the Environmental Assessment.
4. Several agencies reviewed the report. The attached comments from the North Carolina
Wildlife Resources Commission, the United States Fish and Wildlife Service, the Water
Quality Section, and the Division of Environmental Health must be addressed.
Page 5 of 5

Re: Rosman permit (NC0021946)
Subject: Re: Rosman permit (NC0021946)
Date: Tue, 14 Oct 2003 16:26:57 -0400
From: Dave Goodrich <[e-mail]>
To: Jackie Nowell <[e-mail]>, Joe Corporon <[e-mail]>,
Alex Marks <[e-mail]>
Please wait for CG&L's letter and then return it based on them needing to
address those concerns. Joe & Alex - Please watch out for this in the
mail! If you would, let's make sure that all four of us know what's
happening with this project. Jackie - You are likely to get out of this
project after it is returned.
Thanks,
Dave
Jackie Nowell wrote:
> Rosman's permit at 0.090 MGD was issued on 10/23/2000 by Charles with an
> effective date of 12/1/2000 and expires on 9/30/2005. An inhouse
> request for modification to 250,000 gpd was submitted on 12/17/2001 and
> again on 5/16/02 with the updated Form 2A. The 5/02 app indicates that
> this is for a proposed 250,000 GPD plant. There is also notation " that
> an " I/I study has been performed. Damaged sewer lines will be
> rehabilitated w/ installation of new proposed WWTP". This app was
> probably submitted in response to I&I problems and as a solution to the
> 80-90 rule if flows are averaging 70, 000 GPD.
> However, they do have a current permit for 90,000 GPD and it expires in
> 2005.
1 of 1 10/14/03 5:16 PM

Michael F. Easley, Governor
MEMORANDUM
TO:
FROM:
RE:
TE:
ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Willia oss Jr., Secretary
CE.,/
Hannah Stalling
Construction Grants and Loans
Melba McGee
Project Review Coordinator
#1243 EA for Wastewater Facilities, Town of Rosman,
Transylvania County
September 30, 2003
The referenced project has been circulated among our internal
divisions.
The attached comments should be considered prior to finalizing the
environmental document. I recommend that you notify our commenting
divisions directly to discuss their recommendations. After you have
addressed agency concerns a memorandum should be provided to me verifying
the resolution. These concerns will need to be resolved and acknowledged
in the environmental document prior to State Clearinghouse review.
Thank you for the opportunity to respond.
Attachments
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] FAX: [phone] Internet: www.enr.state.nc.us/ENR
An Equal Opportunity \ Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P. E. Director
Division of Water Quality
- Coleen H. Sullins, Deputy Director
Division of Water Quality
MEMORANDUM
TO:
Melba McGee
Department of Environment and Natural Resources
FROM: Alex Marks
Division of Water Quality, Water Quality Section
SUBJECT: Environmental Assessment: Town of Rosman, Wastewater Treatment Plant Replacement,
Collection System Improvements, and New Spray Irrigation Site
DENR #1243
DATE: September 25, 2003
The Water Quality Section of the Division of Water Quality (Division) has reviewed the subject
Environmental Assessment (EA). The Town of Rosman proposes to construct a new 0.25
million gallon per day (mgd) wastewater treatment plant, upgrade and expand its sewage
collection system and construct a new 17 acre spray irrigation facility for partial disposal of
treated wastewater. The Division's Planning Branch offers the following comments:
1. Please provide maps that illustrate the project's service area boundary, city and county
boundaries, and water bodies within the service area.
2. Remove sections 5.1.1 and 5.2.1 regarding local watershed protection ordinances as
according to the document neither jurisdiction's regulations contain such an ordinance.
3. Beyond the drainage requirement within its subdivision ordinance, Transylvania County has
not provided adequate mitigation for the project's indirect and cumulative water quality
impacts. Does the county have any other programs or regulations to minimize the effects of
development on water quality such as those to minimize impervious surface coverage?
4. Is the stream bank buffer program the only mechanism that the Town of Rosman has to
provide mitigation for the project's water quality impacts? Has Rosman considered
expanding its stream buffer program or a variation of it throughout the service area? Does
the city have any other programs or regulations to minimize the effects of development on
water quality such as those to minimize impervious surface coverage?
The Division's NPDES permitting section is currently reviewing the subject document and will
be contacting either the applicant or the Division's Construction Grants and Loan Division
regarding a conference to discuss the proposal.
I may be contacted at 919.733.5083 x555. thanks
Nl..�r.P+l�
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-16I7 [phone]
Customer Service
1-877-623-6748

North Carolina Wildlife Resources Commission 0
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: Melba McGee, Environmental Coordinator
Office of Legislative and Int r overnmentall Affairs
FROM: Owen F. Anderson, o�iui in egion Coordinator
Habitat Conservation Program
DATE: September 3, 2003
SUBJECT: Environmental Assessment for Wastewater Facilities, Town of Rosman,
Transylvania County, NC, DENR Project No. 1243
Biologists with the North Carolina Wildlife Resources Commission have reviewed the
subject project. Our comments are provided in accordance with provisions of the Fish and
Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d.) and the North
Carolina Environmental Policy Act (G.S. 113A-1 et seq., as amended; 1 NCAC 25).
The new plant would increase the current capacity of 90, 000 gallons per day to 250,000
gallons per day and would provide for the Town's wastewater needs for 20 years.
The proposed plant would be a tertiary treatment facility and use ultraviolet disinfection.
Additionally, the Town proposes to replace and rehabilitate approximately 3, 200 feet of aging
vitrified clay sewer lines in the downtown area, construct 12,600 feet of new gravity sewer
extensions into unserved neighborhoods and 4, 600 feet of new raw wastewater force main. A
pump station beside Coats American Manufacturing will be upgraded to handle expected flows
from the Calvert Road service area to the north and another pump station will be abandoned and
replaced with gravity line.
The new facilities will include a spray irrigation area on the French Broad River
floodplain. The spray irrigation fields will receive 0.3-0.8 million gallons per month during the
months of April through November.
We concur with the need to replace the failing wastewater treatment plant and collection
system. The project should decrease the direct impacts to the French Broad River from leaking
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] ext. 281 • Fax: [phone]

EA Town of Rosman W fP & Lines 2
Transylvania County, French Broad River
September 3, 2003
collection systems and improve water quality by implementing tertiary treatment and ultraviolet
disinfection.
The EA does a good job of describing the project and environmental impacts. Although
the project is smaller than most wastewater treatment plant expansions, we are concerned about
the potential for secondary and cumulative impacts associated with this project. The treatment
capacity is nearly triple the capacity of the existing plant. Due to the high -quality resources
within the French Broad River Basin and the significant amount of the area that is within the
100-year floodplain, we are concerned that the expanded infrastructure could result in secondary
and cumulative impacts associated with new development.
Many of the streams in the area are classified as trout waters by the Division of Water
Quality and/or designated as trout waters by the NCWRC. The protection of these streams is
most important to fish and wildlife resources and to public recreation and tourism. Trout streams
are especially sensitive to increase sedimentation and loss of forested riparian buffers. These are
two impacts associated with development. Additionally, we are concerned about the impacts to
the 100-year floodplain and increased stormwater.
The ordinances outlined in the EA do not appear to address riparian buffer protection,
100-year floodplain protection, wetland protection or stormwater management. Although the
floodplain ordinance does state that the structure must be elevated and the structure should not
result in an increase in floodplain elevation. We do not believe that this protects the floodplain
from incremental fill that overtime results in cumulative impacts to the floodplain and receiving
waters. The respective ordinances do not provide sufficient protection for wetlands, riparian
habitat or stormwater.
We are not opposed to this project. However, measures to protect important fish and
wildlife resources from secondary and cumulative impacts associated with the expanded
infrastructure are insufficient. The following items need to be addressed prior to our
concurrence with the EA.
1. Much of Rosman is within the 100-year floodplain. Ordinances are needed that prevent
the filling of the 100-year floodplain. The ordinance concerning floodplain protection
discussed in the EA provides insufficient protection and does not appear to meet the
requirements of Executive Order 11988.
2. What measures, ordinances and/or initiatives will be implemented to protect existing
forested riparian corridors and establish forested riparian corridors where they are
currently lacking? The initiatives should include how smaller headwater streams and
seeps will be protected since these are often must vulnerable to impacts from filling.
Fragmentation of habitat is also an issue and is most appropriately addressed by
maintaining wide riparian corridors. The 30-foot building setback does not adequately
protect riparian habitat. Recommendations on buffer widths and other guidance on
secondary and cumulative impacts can be found at
www.ncwildlife.org/pg07_WildlifeSpeciesCon/pg7c3_impacts.pdf

EA Town of Rosman W w fP & Lines 3 September 3, 2003
Transylvania County, French Broad River
3. What measures and/or local ordinances will be implemented to mitigate the impacts of
increased stormwater from development? Both quantity and quality of stormwater need
to be addressed. Sediment is also of particular interest.
4. The treatment plant is going to be built within the 100-year floodplain. This appears to
be contrary to the Executive Order 11988 that protects floodplains. Alternate sites
outside of the 100-year floodplain should be considered and discussed.
5. A no connect ordinance is needed for development occurring within floodplains or within
wetlands, since lots platted prior to Oct 5, 1984 would be allowed up to Y2 acre of wetland
impact.
6. It is strongly recommended that the Town of Rosman develop and implement low impact
development requirements for new residential, commercial and industrial development.
The website included above will be helpful in developing low impact guidance.
Thank you for the opportunity to provide input during the planning stages of this project.
If we can provide further assistance or clarification of these comments, please contact me at
[phone] ext 24.
cc: Brian Cole, Supervising Biologist, USFWS, Asheville

DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL HEALTH
Inter -Agency Project Review Response
Town of Rosman Project Name Type of Project
Comments provided by:
❑ Regional Program Person
❑ Regional Engineer for Public Water Supply Section
❑ Central Office program person
Name:
Page 1
Project Number
1243
County
Transylvania
Wastewater Treatment Plant
replacement, collection system
improvements, and new spray irrigation
site
Date:
Telephone number:
Program within Division of Environmental Health:
❑ Public Water Supply
❑ Other, Name of Program:
Response (check all applicable):
❑ No objection to project as proposed
❑ No comment
[xt Insufficient information to complete review
T1�t "town of. l M.' �u�p�,- Wad Sr b� z S 541.1" 1� 1 ¶n1.
4r4 ul 16 4-4r
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(r)rpby. aAOeeaued
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Return to:
Public Water Supply Section
Environmental Review Coordinator
for the
Division of Environmental Health

DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL HEALTH
Page 2
Project Number
County
Inter -Agency Project Review Response
Project Name
Type of Project
❑ The applicant should be advised that plans and specifications for all water system
improvements must be approved by the Division of Environmental Health prior to the
award of a contract or the initiation of construction (as required by 15A NCAC 18C
.0300et. seq.). For information, contact the Public Water Supply Section, (919)
733-2321.
❑ This project will be classified as a non -community public water supply and must comply with state and federal drinking water monitoring requirements. For more information the
applicant should contact the Public Water Supply Section, [phone].
❑ If this project is constructed as proposed, we will recommend closure of _ feet adjacent waters to the harvest of shellfish. For information regarding the shellfish
sanitation program, the applicant should contact the Shellfish Sanitation Section at (252)
726-6827.
❑ The soil disposal area(s) proposed for this project may roduce
a mosquito reeding
problem. For information concerning appropriate mosquito control measures,bthe
applicant should contact the Public Health Pest Management Section at [phone].
❑ The applicant should be advised that prior to the removal or demolition of dilapidated
structures, a extensive rodent control program may be necessary in order to prevent the
migration of the rodents to adjacent areas. For information concerning rodent control,
contact the local health department or the Public Health Pest Management Section at
[phone].
❑ The applicant should be advised to contact the local health department regarding their
requirements for septic tank installations (as required under 15A NCAC 18A. 1900 et.
sep.). For information concerning septic tank and other on -site waste disposal methods,
contact the On -Site Wastewater Section at [phone].
❑ The applicant should be advised to contact the local health department regarding the
sanitary facilities required for this project. g g
0 If existing water lines will be relocated during the construction, plans for the water line
relocation must be submitted to the Division of Environmental Health, Public Water
Supply Section, Technical Services Branch, 1634 Mail Service Center, Raleigh, North
Carolina 27699-1634, [phone].
❑ For Regional and Central Office comments, see the reverse side of this form.
Reviewer
Section/Branch Date

AtilFzr
Y State of North Caro,. .
• ihiCDENR Department of Environment and Natural Resources
•
jio
Project Number:0 Id 4. Due Data: .
INTERGOVERNMENTAL REVIEW - PROJECT COMMENTS
Altar review of this project it has been determined that the CENR peonit(s) and/or approvals indicated may need to be obtained in order for this project
to comply with North Carolina Law. Questions regarding these permits should be addressed to the Regional Office indicated on the reverse of this form.
All applications, information and guidelines relative to these plans and permits are available from the same Regional Office.
PERMITS
.SPECIAL APPLICATION PROCEDURES or REQUIREMENTS
Normal Process Time
(Statutory Time Umit)
D
Permit to construct & operate wastewater treatment
facilities, sewer system extensions & sewer systems
not discharging into state surface waters.
Application 90 days before begin construction or award of construction
contracts. On -site inspection. Post -application technical conference usual.
30 days
(S0 days)
0
NPDES-permit to discharge into surface water and/or
permit to operate and construct wastewater facilities
discharging into state surface waters.
Application 180 days before begin activity. On -site inspection preapplication
conference usual. Additionally, obtain permit to construct wastewater treatment
facility -granted after NPOES. Reply time, 30 days after receipt of plans or issue
of NPDES permit -whichever is later.
f
i
90 -120 days
(N/A)
Water Use Permit
•
Preapplication technical conference usually necessary
30 days
(N/A)
ED
Well Construction Permit
. Complete application must be received and permit issued prior to the
installation of a well.
7 days
(15 days)
•
El
Dredge and Fill Permit
Application copy must be served on each adjacent riparian property owner.
On -site inspection.Preapplication conference usual. Filling may require Easement
to Fill from N.C.Department of Administration and Federal Dredge and Fill Permit.
55 days
(90 days)
Ea
Permit to construct & operate Air Pollution Abatement
facilities and/or Emission Sources as per 15 A NCAC
(20.0100, 20.0300, 2HA600)
N/A
60 days
0
Any open burning associated with subject proposal
must be in compliance with 15 A NCAC 20.1900
N/A
60 days
(60 days)
ID
Demolition or renovations of structures containing
asbestos material must be in compliance with
15 A NCAC 20.1110 (a) (1) which requires notification
and removal prior to demolition. Contact Asbestos
Control Group 919-733-0820.
O
Complex Source Permit required under 15 A NCAC
20.0800
ie Sedimentation Pollution Control Act of 1973 must be properly addressed for any land disturbing activity. An erosion & sedimentation
control plan will be required if one or more acres to be disturbed. Plan filed with proper Regional Office (Land Quality Section) at least 30
days before beginning activity. A fee of 540 for the first acre or any part of an acre.
20 days
(30 days)
0
The Sedimentation Pollution Control Act of 1973 must be addressed with respect to the referenced Local Ordinance.
30 days
0
Mining Permit
On -site inspection usual. Surety bond filed with DENR. Bond amount varies with
type mine and number of acres of affected land. Any are mined greater than
one acre must be permitted. The appropriate bond must be received before
the permit can be issued.
30 days
(60 days)
LD
North Carolina Burning permit
On -site inspection by N.C.Division of Forest Resources if permit exceeds 4 days
.
1 day
(N/A)
ED
Special Ground Clearance Burning Permit-22 counties
in coastal N.C..with organic soils.
.
On -site inspection by N.C. Division of Forest Resources required "if more than five
acres of ground clearing activities are involved. Inspections should be requested
at least ten days before actual burn is planned.'•
1 day
(N/A)
Q
Oil Refining Facilities
N/A
90 -120 days
(N/A)
0
'
Dam Safety Permit
If permit required, application 60 days before begin construction. Applicant
must hire N.C. qualified engineer to: prepare plans, inspect construction, certify
construction is according to DENR approved plans. May also require permit under
mosquito control program, and a 404 permit from Corps of Engineers.
An inspection of site is necessary to verify Hazard Classification. A minimum
fee of S200.00 must accompany the application. An additional processing fee
based on a percentage orthe total project cost will be required upon completion.
30 days
(60 days)

�....
PERMITS
SPECIAL APPLICATION PROCEDURES or REQUIREMENTS
Normal Process Time
(Statutory Time Lime
10 days
(N/A)
❑
Permit to drill expioratory oil or gas well
Fie surety bond of 55,000 with DENR running to State of N.0 conditional that any
well opened by drill operator shall, upon abandonment, be plugged according
to DENR rules and regulations.
❑
Geophysical Exploration Permit
Application filed with DENR at least 10 days prior to issue of permit Application
by letter. No standard application form.
10 days ,
(N/A)
El
State Lakes Construction Permit
Application fees based on structure size is charged. Must include descriptions
& drawings of structure & proof of ownership of riparian property.
15 - 20 days
(N/A)
❑
401 Water Quality Certification
WA
55 days .
(130 days)
❑
CAMA Permit for MAJOR development
,
$250.00 fee must accompany application
60 days
(130 days)
❑
CAMA Permit for MINOR development
$50.00 fee must accompany application
22 days .
(25 days)
❑
Several geodetic monuments are located in or near the project area. If any monument needs to be moved or destroyed, please notify:
N.C. Geodetic Survey, Box 27687 Raleigh, N.0 27611'
❑
Abandonment of any wells, if required must be in accordance with Title 15A.Subchapter 2C0100.•
❑
Notification of the proper regional office is requested if "orphan' underground storage tanks (USTS) are discovered during any excavation operation.
Compliance with 1 SA NCAC 2H 1000 (Coastal Stormwater Rules) is required.
45 days
(N/A)
*
Other comments (attach additional pages as necessary, being certain to cite comment authority)
Qu tions regarding these
Asheville Regional Office
59 Woodfin Place
Asheville, N.C. 28801
[phone]
❑ Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville, N.C. 28301
[phone] .
REGIONAL OFFICES
permits should be addressed to the Regional Office marked below.
❑ Mooresville Regional Office
919 North Main Street
Mooresville, N.C. 28115
[phone]
❑ Raleigh Regional Office
3800 Barrett Drive, P.O. Box 27687
Raleigh, N.C. 27611
[phone]
❑ Washington Regional Office
943 Washington Square Mall
Washington, N.0 27889
[phone]
❑ Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, N.C.28405
[phone]
❑ Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, N.C. 27107
[phone]

•
-R4 ie6-No l:-'Lia- T- OL-ct
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
September 3, 2003
Ms. Hannah Stallings
Environmental Assessment Coordinator
Construction Grants & Loans Section
North Carolina Department of Environment and Natural Resources
1633 Mail Service Center
Raleigh, North Carolina 27699-1633
Dear Ms. Stallings:
8
Subject: Town of Rosman, Wastewater System Improvements, Preliminary Engineering Report
and Environmental Assessment, Transylvania County, North Carolina
On August 8, 2003, we received a copy of the Preliminary Engineering Report and
Environmental Assessment (Report/EA) for the subject improvements, and on August 27, 2003,
we received amendments to the Report/EA. We have reviewed the Report/EA and provide the
following comments in accordance with the provisions of the Fish and Wildlife Coordination
Act, as amended (16 U.S.C. 661-667e), and section 7 of the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531-1543) (Act).
The Town of Rosman proposes to construct a new 0.25-million-gallon-per-day wastewater
treatment plant, upgrade and expand it sewage collection system, and construct a new 17-acre
spray irrigation facility for partial disposal of the treated wastewater. Two action alternatives
were considered for upgrading the wastewater treatment facilities --improving and expanding the
current system or tying into the Town of Brevard's municipal sewage system. Improving and
expanding the current facility is the preferred alternative.
Because of the expected and current population growth of the Rosman area, it is important to
plan development that minimizes environmental impacts. Further, we must assume the proposed
improvements (capacity) to the wastewater treatment plant will facilitate the development. Thus,
in addition to the direct impacts of project construction, we are also concerned about the
secondary and cumulative impacts of the proposed project. Unless proactive measures are taken
in the early planning stages, we do not believe secondary and cumulative impacts will be
minimized. Adopting ordinances that protect wide forested riparian corridors and the 100-year

floodplaini and that adequately treat storm water in development areas is essential to the
protection of water quality and aquatic habitat in developing landscapes. The North Carolina
Wildlife Resources Commission has developed a "Guidance Memorandum to Address and
Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial Wildlife Resources and
Water Quality" that we support and encourage you to use. It can be accessed at
http://www.ncwildlife.org/pg07 wildlifespeciescon/pg7c3_impacts.pdf
The Report/EA states that "... sewerline construction corridors will cross one 0.05 acre wetland
and three streams .. and "... the sewerline corridors will also be [sic] closely parallel four
streams, where temporary clearing of stream bank vegetation may occur." The Report/EA does
not detail the process used to avoid or minimize wetlands/stream impacts. We strongly
recommend undisturbed forested buffers for all intermittent streams, perennial streams, and
wetlands. We recommend minimum buffers of 50 feet on intermittent streams and 100 feet on
perennial streams. Buffer minimums should be doubled on streams known to contain, or
influence waterways that contain, federally protected species. Disturbed wetland/riparian areas
should be returned to their original soils and contours. Plant communities should be
reestablished that would result in wetland plant community succession into habitat of equal or
greater value than the habitat that was destroyed. Temporarily disturbed wetlands should be
reseeded with annual small grains appropriate for the season (e.g., oat, millet, rye, wheat, or rye
grass) and be allowed to revert to natural wetland vegetation. The crossing of wetlands and
streams should be minimized, located at narrow areas, and made perpendicular to the stream. All
unavoidable stream crossings should be accomplished using directional boring.
The Report/EA states that the proposed project is not likely to affect protected aquatic species
and that there is no habitat in the project area for any federally protected terrestrial species. In
view of this, we believe the requirements under section 7(c) of the Act are fulfilled. However,
obligations under section 7 of the Act must be reconsidered if: (1) new information reveals
impacts of this identified action that may affect listed species or critical habitat in a manner not
previously considered, (2) this action is subsequently modified in a manner that was not
considered in this review, or (3) a new species is listed or critical habitat is determined that may
be affected by the identified action.
In summary, we believe both action alternatives will result in a higher -quality effluent and
improved downstream water quality. However, unless direct impacts to streams, wetlands, and
riparian areas are minimized and secondary and cumulative impacts are addressed, these gains in
water quality could be easily negated.
We appreciate the opportunity to provide these comments. If we can be of any assistance or if
you have any questions, please do not hesitate to contact Mr. Allen Ratzlaff of our staff at
'Executive Order 11988 requires federal agencies to consider and protect floodplain functions. We believe
the recent examples of flooding in eastern North Carolina highlight the importance of avoiding the "... long- and
short-term impacts associated with the occupancy and modification of floodplains ..." and that we should "avoid
direct and indirect support of floodplain development ...." We encourage you to review Executive Order 11988.

828/258-3939, Ext. 229. In any future correspondence concerning this project, please reference
our Log Number 4-2-02-084.
Sincerely,
--(7) 6244/_-)
hrian P. Cole
State Supervisor
cc:
Mr. Owen Anderson, Mountain Region Coordinator, North Carolina Wildlife Resources
Commission, 20830 Great Smoky Mtn. Expressway, Waynesville, NC 28786

�►WK
i DICKSON
Engineers • Planners • Surveyors
Landscape Architects
August 22, 2003
Ms. Jacquelyn M. Nowell
NCDENR — NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Town of Rosman Wastewater Improvements
Engineering Alternatives Analysis
Permit No. NC0021946
WKD #10583.10.CL - I
Dear Ms. Nowell:
Thank you for your assistance with the review status of the referenced project. Per our
telephone conversation yesterday, I have enclosed the Wastewater Flow Projection section
from the Preliminary Engineering Report (Amended July 18, 2003), which was recently
submitted to Construction Grants and Loans for approval. This information amends the flow
projection/justification provided in the Engineering Alternatives Analysis submitted to you in
May 2002 by Robert D. Wilroy, PE. I trust that you will find these flow projections
sufficient justification for a design flow of 0.25 MGD for the Rosman WWTP and approve
the NPDES Permit Application accordingly.
Please feel free to call me with any questions.
Sincerely,
W.K. Dickson & Co., Inc.
Michael Osborne, PE
Project Manager
Enclosure
cc: N1r. K. Lawrence Horton, III, PE — NCDENR Construction Grants and Loans
616 Colonnade Drive
Charlotte, North Carolina 28205
704.334.5348
Fax [phone]
www.wkdickson.com
Other Offices:
Asheville, NC
Atlanta, GA
Boca Raton, FL
L\proj\Rosman\1058310CL\INowef082203
Columbia, SC
Hickory, NC
Raleigh, NC
Wilmington, NC

III. WASTEWATER FLOW PROJECTIONS
The determination of the quantity of sewage to be treated for a community is
fundamental to the design of disposal facilities. Planning for future wastewater
treatment needs requires estimating future increase in flows received by the
treatment plant. To estimate these future flows, the rate of increase must be
predicted and a planning period must be selected to design and size treatment
facilities. The rate of increase in sewage to be removed from a community
depends on the population and the per capita contribution of the sewage.
Planning Period
Selecting a planning period which is short sighted may result in higher long-term
capital improvement costs. Selecting a planning period which is too lengthy can
result in equipment becoming obsolete or worn out before its maximum capacity
is reached.
For wastewater collection components, such as piping, manholes and related
structures, 40 years is a commonly used planning period. For treatment works
and mechanical equipment, such as pumps, blowers, controls, etc. a commonly
assumed planning period is 20 years. This is not to say that mechanical
equipment will provide trouble free service for 20 years, rather that mechanical
equipment often becomes obsolete by advances in technology and repairs can
become costly beyond a twenty year period. Changes in regulatory agency
requirements can also affect the service life of a treatment facility, but this is a
difficult factor to predict in making long range projections.
It is recommended that the Town of Rosman's plans for expansion of their
existing wastewater treatment facility be based on a 20 year planning period and
the collection system improvements based on a 40 year period. For this report,
11

the planning period will be through the year 2021 for the plant facility and 2041
for the collection system.
Wastewater Flow Projection
The accuracy of a population study relies on the accuracy of population data
available from a number of sources. The population data used for this report was
obtained from demographic information made available by the State of North
Carolina Office of State Planning.
Existing Wastewater Flows
Flow records listed in Table 1 indicate an average daily flow into the existing
'MNTP of at least 68,000 gpd. ►. s /) it s-)4
Table 1
Wastewater Flow Records
Annual Averages from DMRs
YEAR
AVERAGE FLOW (MGD)
MAX DAILY FLOW
(MGD)
Aug 2001 - Sept 2000
0.068
0.090
Aug 2000 - Sept 1999
0.074
0.143
Aug 1999 - Sept 1998
0.043
0.197
Aug 1998 - Nov 1997*
0.061
0.094
4,
Residential Additional Flows
A condominium complex is planned for the near future on the northeast side of
Rosman and will be developed in two phases. Each phase will contain 84 units
(168 units total). There is also a mobile home park off of Calvert Road in
northern Rosman with approximately 34 mobile homes, which are currently
serviced by septic tanks. Sewer line extensions to this mobile home park and the
12

condominium complex are included in this PER as Sewer Project C. The Town
Mayor has also indicated that approximately 200 to 300 additional residential
sewer connections are planned to be annexed into the Rosman sewer system
and will be required to connect to the Town's sewer system. The total number of
additional units will be 402 (168+34+200). According to 2000 Census figures,
there are 2.33 people per household in the Town of Rosman. The total number
of residents for these additional units is 937. At 100 GPD/person, the flow from
these units will be approximately 93,700 GPD.
Census population figures from the NC Office of State Planning for the Town of
Rosman indicate a population of 385 for the year 1990 and 490 for the year
2000. This is a total increase of 27.3% or 2.44% annually over 10 years. Based
on these figures, the population in the year 2020 projected from a population of
490 will be 794 people. This is 304 additional residents. At 100 GPD/person, the
additional residential flow created will be 30,400 GPD.
The total additional residential flow from the above mentioned sources will be
124,100 GPD from a population increase of 1,241 (937+304) residents.
Commercial and Industrial Flow
Commercial flow is normally estimated at 40 GPD per capita. The additional
commercial flow based 40 GPD/capita for 1,241 people is 49,640 GPD.
Industrial flow is projected based on 10% of domestic and commercial flows.
The total additional domestic and commercial flow is 173,740 GPD (124,100
GPD+49,640 GPD). Ten percent of this flow is 17,374 GPD.
The total 20 year projected flow for the WVVfP is 259,114 GPD, including the
existing average daily flow, additional residential, commercial and industrial
flows.
13

The magnitude of dry weather (customer) flows being experienced by the
wastewater treatment facility, regardless of Ill, supports the need for expanding
the treatment capacity. The projected flows to the year 2022 were considered in
conjunction with the age and condition of the existing facility. A new waste
treatment facility with a 250,000 GPD capacity is recommended for the Town of
Rosman.
14

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ENVIRONMENTAL REVIEW TRACKING SHEET
DWQ - WATER QUALITY SECTION
DATE: 7/31/2003
TO: Env. Sciences Branch (WQ Lab, MSC 1621)
o Trish MacPherson (T/E species, lotic systems)
p Kathy Herring (forest/ORW/HQW)
Q Jay Sauber (ecosystems)
O Matt Matthews (toxicology)
o Dianne Reid (intensive survey)
Non -Discharge Permitting Unit (Archdale 12th)
O Kim Colson (sewer collection, reuse)
Wetlands/401 Unit (Parkview Bldg, MSC 1650)
❑ John Dorney (COE, 401, construction)
O John Hennessy (DOT)
Q Cyndi Karoly (dredging)
0
of t Source Branch (Archdale 9th) liz
Christie Jackson (NPDES, reverse osmosis)
Bradley Bennett (stormwater)
O Tom Poe (pretreatment) (Archdale 7th)
TYPE: EA
DENR#
DWQ#
1155
13004
EOOZ 1 E 7nr
Regional Water Quality Supervisor
0
Planning Branch (Archdale 6th)
O Darlene Kucken (basinwide planning)
D Tom Reeder (classifications & standards)
O Alan Clark (management planning)
O Steve Zoufaly (water supply)
D Michelle Woolfolk (modeling) (Archdale 7th)
O Gloria Putnam (coastal nps)
O
0
0
A copy of the environmental document for the project described below is attached. Subject to the requirements of
the NC Environmental Policy Act, you are being asked to review the document for potential significant impacts to
the environment, especially pertinent to your jurisdiction, level of expertise or permit authority. Please return the
completed form along with your written comments, if any, by the date indicated. Thank you. IF AN EXTENSION
IS NEEDED, PLEASE EMAIL A REQUEST TO THE SEPA COORDINATOR PRIOR TO THE RESPONSE
DEADLINE.
Project:
Town of Rosman WWTP Improvements
NO COMMENT
Response Deadline
COMMENTS ATTACHED (OR EMAILED)
SIGNATURE
os
DATE
Return To: Alex Marks: Marks: [phone] ext. 555; [e-mail]5ic)ofi`T
Local Government Assistance Unit/Planning Branch; Archdale 6th; MSC 1617; fax: [phone]
Notes:
(SA-' fly. �� \_,JO./)\ rjo{,
J

TOWN OF ROSMAN
WASTEWATER TREATMENT PLANT REPLACEMENT, COLLECTION
SYSTEM IMPROVEMENTS, AND NEW SPRAY IRRIGATION SITE
TRANSYLVANIA COUNTY, N.C.
NEPA ENVIRONMENTAL ASSESSMENT
DWQ-CGL Project No. E-SRG-T-02-0131
NC DENR Project Review No. 1155
State Clearinghouse No.
NPDES Permit No. NC0021946
Municipal Contact:
Mr. Johnny Rogers, Mayor
Town of Rosman
P.O. Box 636
Rosman, NC 28772
[phone]
20 JANUARY 2003
Lead Agency Contact:
Mr. Bobby Blowe
NC Division of Water Quality
Construction Grants & Loans
1633 Mail Service Center
Raleigh, NC 27699-1633
[phone]
EA Prepared By:
t
RECEIVED
11
JUL 25 2003'
CONSTRUCTION GRANS&
LOAN SECTION
Project Engineer:
Mr. Michael Osborne, P.E.
W.K.Dickson & Company
616 Colonnade Drive
Charlotte, NC 28205
[phone]
Robert J. Goldstein & Associates, Inc.
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive
Raleigh, North Carolina 27616-3175
Tel [phone] Fax [phone]
RJG&A Project No. 2237

TABLE OF CONTENTS
Executive Summary 3
1.0. Proposed Project Description 4
2.0. Purpose and Need 4
3.0. Project Alternatives 5
3.1. No Action Alternative 5
3.2. Rosman Sewer System Improvements 5
3.3. Wastewater Connection to Town of Brevard 6
3.4. New Rosman WWTP with River Discharge and Land Disposal (Preferred). 6
4.0. Existing Environment & Project Impacts 7
4.1. Geography and Land Use 7
4.1.1. Existing Environment 7
4.1.2. Land Use Impacts and Mitigation 7
4.2. Soils and Important Farmlands 8
4.2.1. Existing Environment 8
4.2.2. Important Farmland Impacts and Mitigation 8
4.3. Floodplains 8
4.3.1. Existing Environment 8
4.3.2. Floodplain Impacts and Mitigation 9
4.4. Formally Classified Public Lands 9
4.5. Archaeological and Historical Resources 9
4.6. Jursidictional Wetlands and Waters 10
4.6.1. Existing Environment 10
4.6.2. Jurisdictional Wetlands and Waters Impacts and Mitigation 11
4.7. Water Resources 12
4.7.1. Existing Environment 12
4.7.1.1. Surface Waters and Usage Classifications 12
4.7.1.2. Existing Surface Water Quality 12
4.7.1.3. Groundwater Resources 13
4.7.2. Water Quality Impacts and Mitigation 13
4.8. Coastal Resources 14
4.9. Fish and Wildlife Resources 14
4.9.1. Fish and Aquatic Habitats 14
4.9.2. Wildlife and Terrestrial Habitats 15
4.9.3. Fish and Wildlife Habitat Impacts and Mitigation 15
4.10. State and Federal Protected Species 16
4.10.1. Existing Environment 16
4.10.2. Protected Species Impacts and Mitigation 17
4.11. Air Quality 17
4.11.1. Existing Environment 17
4.11.2. Air Quality Impacts and Mitigation 18
4.12. Noise 18
4.13. Transporation 18
4.14. Socio-Economics & Environmental Justice 18
4.15. Introduction of Toxic Substances 19
1

5.0. Summary of Mitigation 19
5.1 Transylvania County. 19
5.1.1. Watershed Protection Ordinance 19
5.1.2. Flood Damage Control Ordinance. 19
5.1.3. Subdivision Control Ordinance. 20
5.1.4. Manufactured Home Park Ordinance. 21
5.2. Town of Rosman 21
5.2.1. Watershed Protection Ordinance 21
5.2.2. Stream Bank Buffer Zone. 21
5.2.3. Wastewater Connection Ordinance. 21
6.0. LITERATURE CITED 22
TABLES
Table 1. DAQ Ambient Air Quality Monitoring Data near Transylvania County.
Table 2. Protected Animal and Plant Species Known From Transylvania County.
FIGURES
Figure la-b. Rosman WWTP and Sewer System Improvements, Transylvania County, NC
Figure 2. Rosman Existing and Proposed WWTP Site Layout
Figure 3. Rosman Proposed Spray Irrigation Field Site Layout
Figure 4a-c. Locations of Jurisdictional Wetlands and Streams in the Project Construction Areas
Figure 5a-e. Digital Aerial Photos of Wetlands and Streams in the Proposed Construction Areas
APPENDICES
Appendix A. NPDES Speculative Effluent Limits
Appendix B. Agency Comments and Responses
2

Executive Summary
The Town of Rosman in southern Transylvania County proposes to construct a new 0.25
MGD wastewater treatment plant, upgrade and expand its sewage collection system, and
construct a new 17 acre spray irrigation facility for partial disposal of the treated wastewater
(Figure 1). The new WWTP site is 0.5 mile southeast of downtown Rosman, on Town property
adjacent to the existing 0.09 MGD plant, on the north floodplain of the French Broad River
(NPDES Permit # NC0021946). The old WWTP will be removed and the site revegetated. The
proposed spray irrigation site is agricultural land 0.5 mile east of the WWTP, also on the north
floodplain of the French Broad River.
The proposed WWTP is designed for 0.25 MGD peak month average flow and 0.75
MGD maximum daily flow. The treatment process will include an automatic rotary screen at the
plant influent, a two stage sequencing batch reactor (SBR) secondary treatment system with flow
equalization, rotary fine cloth tertiary filters on the discharge from the flow equalization basins,
and dual ultraviolet light (UV) disinfection (Figure 2). The treated wastewater will enter a
collection basin from which a portion will be land applied on the new spray irrigation field and
the remainder discharged to the French Broad River via a cascade aerator. Based on
hydrogeologic and soils investigations, the spray irrigation site will receive 0.3 to 0.8 million
gallons per month during April through November, and will not be used during December
through March (Figure 3). The new river discharge will be 400 feet upstream of the present
effluent discharge pipe. New wastewater sludge processing facilities will include an aerobic
digester, belt press for dewatering, and storage basins.
The collection system improvements include replacement or rehabilitation of
approximately 3,200 feet of deteriorating vitrified clay sewerlines in the downtown area, 12,600
feet of new gravity sewer extensions, and 4,600 feet of new raw wastewater force main. The
existing pump station beside Coats American Manufacturing will be upgraded to handle the
increased flows from the expanded service area to the north, and another existing pump station
along SR 1388 will be abandoned when its effluent force main is replaced by a gravity sewer.
The majority of proposed gravity sewers and force mains will be installed alongside
existing public road rights -of -way. The off -road segments are almost entirely in fields or lawn, as
is the new WWTP site and spray fields. Other than minor nuisance noise, dust, and traffic
interference during construction, the project is expected to have negligible direct impacts on
natural and cultural resources. The project will allow approximately 300 septic systems to be
retired, many of which are on shallow soils and would not meet modern standards if built today.
The new WWTP will produce a higher quality effluent than the current plant, and will no longer
discharge residual chlorine, thus benefitting aquatic life.
Indirect and cumulative impacts are expected to be minor, projected growth is only about
300 new residents. Most of the additional wastewater flow will come from existing residents not
yet connected to public sewer. Nonetheless, local regulations and programs to mitigate potential
adverse impacts of future growth in the service area are discussed in section 5.0.

segments crossing agricultural fields or lawns, nearly all proposed garvity lines and force mains
will be installed within existing public road rights -of -way, thus minimizing construction impacts.
The deteriorating clay sewerlines downtown will be repaired using trenchless technology
wherever possible, which will also minimize construction impacts.
3.3. Wastewater Connection to Town of Brevard
The Town of Brevard, eight miles northeast of Rosman, operates the nearest municipal
WWTP (2.5 MGD permitted capacity) to which Rosman could possibly connect (W.K.Dickson,
2001). This alternative would require that a new pump station be installed beside the old Rosman
WWTP, 46,500 feet of force main be constructed from Rosman to the Brevard collection system,
and Brevard's Gallimore Road and Neely Road pump stations be expanded to handle the
additional flow from Rosman. The effluent would be discharged to the French Broad River ten
miles downstream of Rosman. Because the preferred alternative (new Rosman WWTP) will yield
a high quality effluent and will accommodate partial wastewater reuse during dry weather,
connection to Brevard would have negligible water quality benefit, although it would consolidate
wastewater treatment. The total dynamic head required for the force main would be 155 feet (75
feet static head + 80 feet friction head loss), requiring two 50 horsepower pumps. The total
estimated present worth cost of this option (excluding upgrade of Brevard's pump stations)
including Rosman's sewer improvement is $6.27 million. The present worth cost does not
include improvements to Brevard's system, which are likely significant. A combination of force
main and gravity sewer segments to accommodate sewer service along portions of the US-64
corridor bewteen the two towns was also considered, but would be significantly more expensive
to construct and operate, and is not justified by the current development potential in this area.
The Brevard alternative is nearly $600,000 more costly than the preferred alternative, requires
much greater land disturbance and numerous stream crossings, and was therefore rejected.
Additionally, improvements to Brevard's system will likely increase this alternative to over $1
million more than the preferred alternative. Another problem with this alternative is sizing of the
force main. If the pipe is sized for the 40-year projected wastewater flow, then it may suffer from
insufficient scouring velocity, corrosion, and odor problems during the short term, when flows are
much less than design capacity. If sized for the 20-year flow, it may develop unacceptable
friction head loss as flow increases, and would need to be replaced prematurely.
3.4. New Rosman WWTP with River Discharge and Land Disposal (Preferred).
The alternative of building a new 0.25 MGD WWTP with tertiary treatment in a field
adjacent to Rosman's existing WWTP has a present worth cost of $5.7 million, with river
discharge and an effluent force main and spray fields to receive five percent of the total annual
effluent. Although five percent is a small portion of the total effluent, the potential environmental
benefit is proportionately much greater because land disposal will be at its maximum during hot
dry weather when aquatic life in the French Broad River would be most sensitive to pollutant -
induced stress. This option was selected as the preferred alternative.
The Town investigated other land disposal options and industrial reuse, but no other
economically feasible sites could be located (W.K. Dickson, 2001, 2002). The Town will
continue to encourage non -discharge alternatives and support future wastewater reuse customers.
The improved effluent quality from the new WWTP may be more suitable for industrial reuse
than that from the existing plant.

1.0. Proposed Project Description
The Town of Rosman in southern Transylvania County proposes to construct a new 0.25
MGD wastewater treatment plant, upgrade and expand its sewage collection system, and
construct a new 17 acre spray irrigation facility for partial disposal of the treated wastewater
(Figure 1). The new WWTP site is 0.5 mile southeast of downtown Rosman, on Town property
adjacent to the existing 0.09 MGD plant (to be retired), on the north floodplain of the French
Broad River (NPDES Permit # NC0021946). The old WWTP will be removed and the site
revegetated.
The proposed WWTP is designed for 0.25 MGD peak month average flow and 0.75
MGD maximum daily flow. The treatment process includes an automatic rotary screen at the
plant influent, a two stage sequencing batch reactor (SBR) secondary treatment system with flow
equalization, rotary fine cloth tertiary filters on the discharge from the flow equalization basins,
and dual ultraviolet light (UV) disinfection (Figure 2). The treated wastewater will enter a
collection basin from which a portion will be land applied on the new spray irrigation field and
the remainder discharged to the French Broad River. The new river discharge will be 400 feet
upstream of the present effluent discharge pipe, and will include a cascade aerator to boost
dissolved oxygen in the effluent. This treatment process will yield a higher quality effluent than
the existing plant, and residual chlorine will no longer be discharged. Speculative effluent limits
are provided in Appendix A.
New wastewater sludge processing facilities will include an aerobic digester, belt press
for dewatering, and sludge storage basins. The digested and dewatered sludge (approximately 20
percent dry solids) will be hauled by truck to an approved landfill or land applied on agricultural
land approved by DENR for this purpose.
The collection system improvements include replacement or rehabilitation of
approximately 3,200 feet of aging vitrified clay sewerlines in the downtown area, 12,600 feet of
new gravity sewer extensions into unserved neighborhoods in northern Rosman, and 4,600 feet of
new raw wastewater force main. The existing pump station beside Coats American
Manufacturing will be upgraded to handle expected flows from the Calvert Road service area to
the north, and another existing pump station along SR 1388 will be abandoned when its effluent
force main is replaced by a gravity sewer.
The proposed spray irrigation site is on the French Broad River floodplain 0.5 mile east
of the WWTP, and is presently in pasture use (Figure 3). It will require 3,800 feet of four inch
diameter force main from the new WWTP to the spray field, 8,400 feet of spray distribution lines,
and 125 spray heads. Based on hydrogeologic and soils investigations, the spray irrigation site
will receive 0.3 to 0.8 million gallons per month during April through November, and will not be
used during December through March. Approximately five percent of the total annual treated
effluent will be land applied, most of which will be during dry weather when river flow is lowest.
The spray fields will be used to grow forage crops for animal feed.
2.0. Purpose and Need
The exising 0.09 MGD Rosman WWTP was built in 1969 and has been upgraded several
times over the past 30 years, but many basic structures are worn out and outdated. The
downtown sewer collection system, comprised of vitrified clay pipe, is also in poor condition,
with excessive inflow and infiltration. During wet weather inflow to the WWTP may exceed
twice the permitted treatment capacity, and shards of broken clay pipe have occasionally
4

damaged the influent pumps. Even after the cracked sewers are replaced or re -lined, the existing
WWTP will not have adequate capacity to serve the many homes in northern Rosman currently
using septic systems, plus new residential and industrial development.
The Engineering Alternatives Analysis for this project (W.K.Dickson, 2002) uses a 20
year planning period for the WWTP and 40 year planning period for the collection system. The
Town of Rosman's population is projected to grow from approximately 490 persons in 2000 to
794 persons in 2020. Wastewater flows will increase due to population growth, expansion of the
collection system into unserved areas, and planned industrial expansion. Approximately 300
homes with septic systems will be annexed into Rosman and connected to public sewer, and a
mobile home park north of Rosman (with septic systems) is also planned to be served. A
condominium complex is planned in northeastern Rosman, which will include 168 three -bedroom
units. Assuming 100 gallons per day per person, service to these existing homes and proposed
condominiums will yield 0.124 MGD, in addition to the 0.068 MGD average daily flow that the
WWTP currently treats. Another 0.067 is projected for commercial growth and the retirement of
an industry's existing WWTP. The proposed new WWTP capacity of 0.25 MGD is based on the
total of these flow projections.
Aside from treatment capacity, the project is also needed to provide more
advanced treatment technology to protect water quality in the French Broad River, which is
designated Class B-Tr by the N.C. Division of Water Quality (DWQ). Biological monitoring by
DWQ indicates excellent to good water quality both upstream and downstream of the Rosman
WWTP. An increase in permitted flow without improvements in effluent quality might degrade
water quality. The two stage sequencing batch reactor (SBR), rotary fine cloth tertiary filters, and
UV disinfection to be installed in the new plant are expected to achieve 10 ppm of biochemical
oxygen demand (BOD), 10 ppm of total suspended solids (TSS), 2 ppm of total nitrogen (TN),
and no residual chlorine; concentrations well below the speculative effluent limits issued by
DWQ. Dual components of each treatment stage will prevent treatment failures while any
component is out of service for repairs.
3.0. Project Alternatives
3.1. No Action Alternative
The no action alternative will leave Rosman with an aging wastewater collection and
treatment system and increasingly frequent treatment failures, especially during wet weather, due
to continuing deterioration of the wastewater infrastructure. Aquatic life below the effluent
discharge will continue to be exposed to chlorine disinfectant, a toxicant no longer necessary with
modern UV disinfection. Neighborhoods in northern Rosman dependent on private septic
systems will remain so, including many older systems that would not meet current environmental
health standards. New development beyond the current wastewater service area may be severely
restricted due to lack of suitable sites for new septic systems. Also, the no action alternative will
not support DWQ's stated goal of consolidating wastewater treatment into fewer WWTPs with
more advanced treatment. For these reasons, the no action alternative was not considered further
(W.K.Dickson, 2001, 2002).
3.2. Rosman Sewer System Improvements
The proposed collection system improvements are based on need for sewer service, and
are the same regardless of where the wastewater is treated and disposed. Except for a few

4.0. Existing Environment & Project Impacts
4.1. Geography and Land Use
4.1.1. Existing Environment
The Town of Rosman is located at the western edge of the Chauga Belt, immediately east
of the Blue Ridge Escarpment (N.C. Division of Land Resources, 1985). The Brevard Fault Zone
traverses this area, and the predominant underlying rock is Henderson gneiss of the Cambrian
period., much of which lies within the 100 year floodplain of the French Broad River. Elevations
in the project area range from 2,175 feet above mean sea level (NGVD of 1929) along the banks
of the French Broad River to 2,400 feet on ridgetops in northern Rosman, as indicated on the
USGS topographic quadrangle of Rosman, N.C. The downtown area is on a terrace mostly
between 2180 and 2200 feet above mean sea level. The proposed WWTP site elevation is
approximately 2,180 feet and the average spray field site elevation is approximately 2177 feet.
Rosman's corporate limits encompass 275 acres, and its current population is about 575
residents. The town's economy is based on small industries, agriculture, forestry, and tourism.
The major highways through Rosman are US-64, US-178, and SR-1388 (old US-64).
Commercial development is minor, and mostly concentrated in the downtown area. The few
industries in town are mainly along the upland edge of the French Broad River floodplain. Land
above 2,200 feet is very hilly with steep slopes, and is mainly in low -density residential and
forestry uses. There is limited undeveloped land in Rosman that is not either flood -prone or on
steep slopes. Rosman does not have golf resorts or luxury retirement developments comparable
to those that have proliferated elsewhere in Transylvania and neighboring counties.
4.1.2. Land Use Impacts and Mitigation
The new WWTP site is adjacent to the existing WWTP, bordered by the French Broad
River to the west and farm fields to the north and east. The new site is approximately 400 feet
from the nearest residence, located across the river to the southwest. The project will convert
about two acres of fallow agricultural land to public utility use, but will have negligible effect on
adjacent land uses. The old WWTP will be removed and the site revegetated.
The proposed spray fields are presently in use for grazing cattle and horses. Grazing use
will be temporarily interrupted during installation of the spray distribution piping and spray
heads, but once this infrastructure is in place grazing will resume on a rotational basis, on days
when no effluent is being sprayed. The existing agricultural land use will be preserved, although
land ownership will change from private to municipal.
Sewerline and force main construction will be mostly within public road rights -of -way,
where land use impacts will be negligible. Where the lines cross agricultural fields and
institutional lawns, these uses will resume after construction is complete. No buildings will be
allowed in the permanent sewer easements, and trees will be excluded by periodic mowing.
The expanded wastewater collection system will serve about 10 acres beyond the present
Town limits at the northern end of New Town Road (SR 1371) northwest of Rosman and about
60 acres in the Calvert Road (SR 1129) area northeast of Rosman. Both areas are predominantly
residential, with single family homes and manufactured homes. Further infill development may
occur in these areas with or without the project, but the expected population growth is only about
300 people over the next 20 years. There is no designated water supply watershed in the
proposed Rosman service area, and no impervious surface area restrictions apply.

No significant direct or indirect land use impacts are anticipated, and no project -specific
mitigation is needed. Compatability issues among adjacent land uses will be addressed by Town
planning and zoning boards in accordance with zoning and development ordinances. Local
ordinances and programs that help minimize adverse impacts of new development are discussed
in section 4.0.
4.2. Soils and Important Farmlands
4.2.1. Existing Environment
Soils on the proposed WWTP site are mapped as Suncook loamy sand (Su) and Rosman fine
sandy loam (Ro) (King et al., 1974). The proposed spray fields are mapped as Rosman fine sandy
loam (Ro), Transylvania silt loam (Tr), and Toxaway silt loam (Tn). These floodplain soil series are
designated prime farmlands by the U.S. Natural Resources Conservation Service (NRCS) only where
they have been drained and/or protected from flooding during the growing season, and are outside of
incorporated municipal limits. The WWTP site is within Town limits and thus does not qualify as
prime farmland. The spray field site is beyond Town limits, in active agricultural use, and appears to
meet the prime farmland definition.
Upland soils in the expanded Rosman service area include Ashe and Edneyville soils (AnD-
F), Brevard loam (BvB-E), Chester fine sandy loam (ChD-E), Delanco fine sandy loam (DeB), Tate
fine sandy loam (TeB-D), and Tusquitee loam (TsD). Proposed off road sewer segments that
traverse areas mapped as prime farmland soils (DeB and BvB) occur from the Coats American pump
station northward to Calvert Road.. Some portions of these segments are already developed in
residential and industrial uses, and no longer qualify as prime farmland, but approximately 2,000 feet
is grassland and appears to meet the prime farmland definition.
4.2.2. Important Farmland Impacts and Mitigation
The spray field site will be maintained in agricultural use following installation of the spray
irrigation infrastructure. The project will ensure that this prime farmland remains in agricultural use
for many years. The sewerline segments traversing prime farmland soils north of the Coats
American pump station will be buried and will not interfere with future agricultural use of this land.
However, provision of public sewer in this area may encourage future residential, commercial, or
industrial development of this land. Soil loss during construction will be minimized by following a
DENR approved Erosion and Sedimentation Control Plan, submitted to the DENR Asheville
Regional Office at least 30 days prior to construction.
4.3. Floodplains
4.3.1. Existing Environment
USGS maintains a stream gage on the French Broad River at Rosman (gage # 03439000)
2,500 feet upstream of the WWTP site. The peak flood during the period of record at this gage
(1936 to 2001) was 2,188.8 feet on 4 Oct 1964. During the past 50 years (1952-2001), the annual
peak flood elevation exceedances at this gage are as follows:
Peak Flood Elevation at Rosman Gage: 2,180 2,182 2,184 2,186 2,187 2,188
Number of Years Exceeded (out of 50): 49 38 22 8 3 1
8

The existing WWTP, proposed WWTP site, and proposed spray irrigation fields are
entirely within the FEMA 100-year floodplain of the French Broad River. There is no other
suitably flat land for these facilities near Rosman. The FEMA 100-year flood elevation at the
WWTP site is 2183.4 feet above mean sea level (NGVD of 1929), based on HEC-2 flood
modeling by the project engineers.
The French Broad River floodplain is narrow upstream of Rosman and through the
downtown area, including the USGS gage site, but widens considerably in southeastern Rosman
beginning about 1,500 feet downstream of the Rosman gage. The floodplain remains wide along
most of its course from the Rosman WWTP site downstream to Brevard. Another USGS gage on
the French Broad River at Calvert (SR 1129 bridge), 12,600 feet downstream of the Rosman
gage, operated from 1924 to 1955. The river bed drops 19.2 feet from the Rosman gage to the
Calvert gage, and the difference in peak flood elevations between the two gages is 19 to 21 feet
during the 19 years of gage data overlap (1936-1954). Assuming a more or less continuous
channel gradient between these two gages, the 100-year flood elevation at the spray field site 0.6
mile downstream of the WWTP is approximately 2180 to 2181 feet.
4.3.2. Floodplain Impacts and Mitigation
A HEC-2 flood modeling study was performed by W.K.Dickson & Company to ensure
that the new WWTP will not significantly raise the 100-year flood level in this area. Removal of
the old WWTP and restoration of the previous floodplain grade will in part mitigate the
hydrologic impacts of the new WWTP structures. The new WWTP is designed to operate
continuously during 100-year flood events, when the river stage will be roughly three feet above
the surrounding floodplain elevation. The effluent spray heads in the spray field will have
negligible hydrologic effect, and all other sewerlines and spray field piping will be buried below
existing grade. Local regulations regarding new development in flood -prone areas are discussed
in section 5.0.
4.4. Formally Classified Public Lands
No formally classified lands (e.g. national parks, national forests, wildlife refuges, wild
and scenic rivers, state parks, or Native American -owned lands) occur in the project construction
area or expanded wastewater service area. No impacts to formally classified lands are anticipated
and no mitigative measures proposed.
4.5. Archaeological and Historical Resources
The State Historic Preservation Office (SHPO) reviewed the project maps and reported
three previously recorded archaeological or historic sites in the Rosman project vicinity. A
cultural resources survey of the WWTP site, spray field site, and off road sewerline segments was
conducted during spring 2003 as requested by SHPO, and will be submitted as a separate report.
One of the three previously reported sites was re -assessed and found to be significant,
and the Town and project engineers have redesigned a portion of the project to avoid impacts to
that site. No new significant site was found during the survey.
9

4.6. Jursidictional Wetlands and Waters
4.6.1. Existing Environment
RJG&A biologist Gerald Pottern surveyed for jurisdictional wetlands and non -wetland
waters along the proposed construction corridors during October 14-15, 2002. Jurisdictional
wetlands were delineated using the COE Wetlands Delineation Manual (Environmental Laboratory,
1987) and the most recent supplementary technical literature for hydrophytic vegetation, hydric soils,
and hydrology indicators. Non -wetland stream channels were identified using COE and NC-DWQ
field indicators. Approximate locations of wetlands and waters in or adjacent to the construction
corridors are shown on USGS topographic base maps in Figure 4a-c, and detailed mapping on aerial
photography base maps is provided in Figures 5a-e.
GA: French Broad River at Turnpike Road; non -wetland jurisdictional stream; 80 feet wide;
perennial steep banks; cobble, gravel, and sand substrata; narrow buffer of sycamore, black willow,
and tulip poplar along banks; adjacent use residential. Proposed gravity line A replacement begins
at east bank of river.
GB: Unnamed tributary of French Broad River along New Town Road; non -wetland jurisdictional
stream; 3 to 5 feet wide; indicated as intermittent on soil map, but appears perennial; cobble, gravel,
and sand substrata; narrow buffer of upland scrub vegetation between road and stream; adjacent
uses residential and forest. Proposed gravity line C is parallel to and may cross this stream.
GC: Unnamed tributary of French Broad River south of football field, between Main Street and SR
1388; includes 0.05 acre jurisdictional wetland plus inflowing and outflowing non -wetland streams.
Wetland vegetation includes a few trees and shrubs (silver maple, red maple, black willow, and
silky dogwood) but is predominantly marsh/scrub (blackberry, rushes, sedges, goldenrod, aster,
duck potato, and water primrose). Inflowing and outflowing streams are 2 to 4 feet wide; sand,
gravel, and organic detritus substrata; banks mowed outside of wetland area; not shown on either
USGS quadrangle or soil map, but appear perennial; dace and chubs present. Adjacent uses
institutional (school ballfield and church. Proposed gravity line E will cross this wetland and is
parallel to the inflowing stream.
GD: Unnamed tributary of French Broad River along Ashe Road (SR 1385); non -wetland
jurisdictional stream, flows into GC west of SR 1388; 2 to 4 feet wide; not shown on either USGS
quadrangle or soil map, but appears intermittent; sand and gravel substrata; narrow buffer of upland
scrub vegetation; adjacent uses are school and residences. Proposed gravity line E is parallel to this
stream.
GE: Unnamed tributary of French Broad River along WWTP access road; non -wetland
jurisdictional ditch; may be a channelized natural stream; flows into French Broad River south of
existing WWTP; 5 feet wide; not shown on either USGS quadrangle or soil map, but appears
intermittent; sand, silt, and organic detritus substrata; narrow buffer of floodplain upland scrub
vegetation (tag alder, black willow, silky dogwood, blackberry, and multiflora rose); adjacent uses
are WWTP and agriculture. Proposed influent gravity line to WWTP and effluent force main to
spray field are parallel to this ditch.
GF: Galloway Creek south of Coats American Mfg; non -wetland jurisdictional stream; 4 to 6 feet
wide; sand and gravel substrata; narrow buffer of floodplain scrub vegetation south of Coats pump
station, but banks mowed at proposed force main crossing west of pump station; shown as
intermittent on USGS quadrangle, but appears perennial; dace and chubs present; adjacent uses are
industrial and agricultural. Proposed force main from expanded Coats pump station to SR 1388 will
cross this stream.
10

GG: Unnamed tributary of French Broad River northeast of Coats American Mfg; non -wetland
jurisdictional stream; 2 to 5 feet wide; sand and silt substrata; adjacent land is pasture and lawn;
banks completely mowed; shown as intermittent on USGS quadrangle, and appears intermittent.
Proposed gravity line from Calvert Road (SR 1129) will cross this stream.
The proposed spray field property is bordered by the French Broad River and contains a
small man-made pond near the southeast corner of the property. The site has been in continuous
agricultural use for many years, and RJG&A did not survey these fields for hydric soils. A
hydrogeologic study prepared by S&ME (2002) reports that the water table on the spray field site
during the growing season is two feet or more below the land surface, and thus the site is unlikley
to contain wetlands. The spray field design includes a buffer of natural vegetation at least 100 feet
wide from the river bank and the pond. The majority of the spray field property is mapped as
Rosman fine sandy loam and Transylvania silt loam, which are generally non-hydric soils (King
et al., 1974). The only portion of the property mapped as hydric soil (Ponzer muck) is a narrow
band adjacent to the river and pond, which will be within the undisturbed buffer.
4.6.2. Jurisdictional Wetlands and Waters Impacts and Mitigation
The proposed WWTP site is bordered by two non -wetland streams: the French Broad
River to the west and an unnamed tributary/ditch (GE) to the east. The only impact to the river
will be installation of the new effluent outfall structure, which will require clearing a short
segment (20 feet or less) along the river bank. Riparian forest vegetation will be restored after the
effluent line and outfall structure are installed, except for a 10 foot wide permanent access
corridor which will be mowed. The ditch along the eastern edge of the WWTP site will not be
disturbed by project construction. No wetlands on the spray field site will be affected.
The sewerline construction corridors will cross one 0.05 acre wetland (GC) and three
streams (GB, GF, and GG). The sewerline corridors will also be closely parallel to four streams
(GB, GC, GD, and GE), where temporary clearing of stream bank vegetation may occur.
Crossings may be constructed by trenching or directional drilling; the project engineers have not
yet determined for each crossing which method will be most feasible. Impacts to streams and
wetlands from construction of the proposed sewerlines and effluent outfall will be permitted using
COE Nationwide Permit 12 and its corresponding DWQ General Water Quality Certification.
Minor impacts to these waters during construction will be minimized by following all relevant
Section 404/401 Permit conditions and a DENR-approved Erosion and Sedimentation Control Plan.
COE and DWQ will determine during the Pre -Construction Notification (PCN) review process
whether additional mitigation is necessary. Compensatory mitigation other than post -construction
restoration of streams and wetlands is not routinely required for impacts of this small magnitude
permitted under NWP 12. ,
Future development supported by this project may affect other wetlands in the expanded
wastewater service area. COE Nationwide Permit 39 allows filling of up to 1/2 acre (0.2023 ha)
jurisdictional waters on each lot created or subdivided prior to October 5, 1984. Lots containing
wetlands that are presently undevelopable due to poor soils for septic systems may be developed
and wetlands impacted after municipal sewer service is provided.
11

4.7. Water Resources
4.7.1. Existing Environment
4.7.1.1. Surface Waters and Usage Classifications
The Rosman service area is in DWQ French Broad River sub basin 04-03-01, and USGS
Hydrologic Unit 06010105, which comprises the uppermost reaches of this river basin. The French
Broad River's drainage basin area upstream of the Rosman WWTP is 68 square miles, annual
average flow is 240 cfs, and the 7Q10 low flow estimated by DWQ is 55.5 cfs during summer and
63.4 cfs during winter. The river's drainge basin area adjacent to the proposed spray field (below the
mouth of East Fork French Broad River) is 100 square miles.
The N.C. Division of Water Quality (DWQ) classifies surface waters of the state based on
their intended best uses. The primary classification system distinguishes waters used for public
water supply (WS-I through WS-V), frequent swimming (B), and all other uses (C). Class C uses
include fishing, boating, aquatic life, irrigation, and wastewater disposal. One or more supplementary
classifications may apply to waters of any primary classification. The supplementary classifications
include nutrient -sensitive waters (NSW), swamp waters (Sw), trout waters (Tr), high quality waters
(HQW), and outstanding resource waters (ORW).
The French Broad River from its source at the confluence of the North Fork French Broad
River and the West Fork French Broad River (1.6 miles upstream of Rosman WWTP) downstream
to Nicholson Creek near Brevard is designated Class B-Tr. Some segments of the North Fork and
West Fork upstream (northwest) of the Rosman service area and all of the East Fork French Broad
River (southeast of Rosman) are designated Class B-Tr-HQW based on their high biological
diversity. Galloway Creek is designated Class C. The remaining streams in Rosman's expanded
wastewater service area are unnamed tributaries of the French Broad River and are not listed in
DWQ's stream classification system; by default they are assigned the same classification (Class B-
Tr) as the stream to which they are tributaries.
There is no designated public water supply watershed in the Rosman area. Rosman's public
water supply is drawn from three groundwater wells with a combined 12 hour yield of 0.113 MGD
(1997 Local Water Supply Plan for Rosman). In 1997 the water system served 470 residents, annual
average daily water use was 0.062 MGD,, and peak day use was 0.099 MGD. Brevard's public water
supply is drawn from Cathey's Creek, a tributary of the French Broad River.
4.7.1.2. Existing Surface Water Quality
DWQ evaluates stream segments and lakes with respect to their designated usage
classifications based on physical, chemical, and biological monitoring (benthic macroinverebrates
and fish communities) at five year intervals, and assigns use support ratings based on each segment's
assigned surface water usage classification (N.C. Division of Water Quality, 1999).
The West Fork French Broad River at US-64 and North Fork French Broad River at SR
1322, both upstream of Rosman, were rated excellent based on several biological samples from 1989
to 1997 (N.C. Division of Water Quality, 1999). The East Fork French Broad River , which joins the
French Broad River 0.5 mile downstream of the Rosman WWTP, was rated excellent based on two
samples in 1989, but has not been re -sampled during the past decade. The West Fork, North Fork,
and East Fork are high -gradient rocky streams with narrow floodplains, whereas the main stem of the
French Broad River below Rosman has a nearly flat gradient and broad floodplain. Between the US-
178 bridge in downtown Rosman and the SR 1129 bridge 12,600 feet downstream the river bed
drops 19 feet, a slope of 0.0015 (= 0.15 percent slope).
12

Six biological samples collected between 1986 and 1997 from the French Broad River at
Calvert Road (SR 1129) two miles below the Rosman WWTP were all rated excellent, indicating
that the existing Rosman WWTP has not adversely affected the river's biological community.
However, some of the smaller French Broad River tributaries in the Rosman vicinity, including
Galloway Creek, Morgan Mill Creek, Peter Weaver Creek, and Glady Fork, were rated good -fair to
poor due to impacts of agriculture, development, and a solid waste landfill. No site -specific data for
the other small streams in the project service area are included in the French Broad River Basinwide
Water Quality Management Plan (N.C. Division of Water Quality, 1999). Those on the river
floodplain have mostly been channelized and have minimal woody riparian vegetation. Many small
stream segments through downtown Rosman are piped through culverts.
The twenty mile segment of the French Broad River from Rosman downstream to Nicholson
Creek (near Brevard) and the West Fork, North Fork, and East Fork French Broad Rivers were all
rated fully suppporting their designated Class B-Tr or Class B-Tr-HQW uses based on 1993-1997
chemical and biological data (N.C. Division of Water Quality, 1999). Peter Weaver Creek (north of
the proposed Calvert Road service area) was rated partially supporting its Class C-Tr uses.
Galloway Creek and all unnamed tributaries in the Rosman service area were not assigned use
support ratings.
4.7.1.3. Groundwater Resources
Rosman is in the Felsic Gneiss (GNF) hydrogeologic unit, with an average well yield of
approximately 17 gallons per minute (gpm), adjusted for a typical 154-foot deep, 6-inch diameter
well (Daniel and Payne, 1990). Rosman's three municipal wells yield 80, 44, and 32 gpm
respectively (1997 Local Water Supply Plan for Rosman). Most residents within Rosman town
limits are supplied by the public water distribution system. Many homes beyond town limits in the
future wastewater service area rely on private wells. In 1997 there were 24 water service
connections to customers using private septic systems for wastewater disposal.
4.7.2. Water Quality Impacts and Mitigation
During construction the French Broad River and tributaries in the project area may
experience temporary, localized water quality impacts including increased turbidity, sediment load,
and construction vehicle fluids and emissions. Potential impacts will be minimized following
proper erosion control and construction practices, and applicable ACOE and NC-DWQ conditions
for Nationwide Permit 12. Most of the sewerline corridors are along roadsides, but where off -road
and parallel to streams they will be installed as far from the stream as practicable to minimize
impacts to riparian vegetation. After the construction areas are stabilized and re -vegetated,
operation and maintenance of the WWTP and sewer system is not likely to have significant adverse
impacts on water quality provided that it is properly maintained to prevent sewerage overflows or
treatment failures. The new WWTP site will preserve the existing 50 foot wide buffer of natural
riparian vegetation along the river, except for a narrow corridor for the effluent outfall
perpendicular to the buffer. The spray field site will retain buffers at least 100 feet wide along the
river.
The sewer system expansion will allow over 300 existing septic systems and one industrial
WWTP to be retired, and will discourage proliferation of new septic systems and package WWTPs
in the expanded service area. The project will also accommodate new development, including 168
proposed condominium units and commercial and industrial growth (section 2.0).
13

Permitted WWTP capacity will increase from 0.090 MGD to 0.250 MGD, but during dry weather a
significant portion of this flow (10 to 20 percent) will be land applied rather than discharged to the
river. Even if the entire permitted capacity were discharged to the river, the instream waste
concentration (IWC) during summer 7Q10 conditions will be only 0.25 MGD / 35.8 MGD = 0.0070
= 0.70 percent IWC. Considering the improved level of treatment provided by the new WWTP
and spray field (section 1.0), the effluent is unlildey to adversely affect the French Broad River's
water quality.
Indirect and cumulative water quality impacts may accrue from induced development in the
expanded wastewater service area, which will increase from the present 275 acres to about 340
acres. Urban stormwater pollutants may include heavy metals, pesticides, solvents, detergents,
motor vehicle fluids, silt, excess nutrients, and coliform bacteria. Increased impervious surface area
may cause stream channel instability due to higher peak flows, and may reduce base flow in these
streams during dry weather. However, new development in these areas will likely occur with or
without the project. It is debatable whether lower density development with septic systems or
higher density development with public sewer will have less overall water quality impact. Local
regulations to protect water quality and riparian areas from adverse impacts of new development are
discussed in section 5.0.
4.8. Coastal Resources
Transylvania County is not a coastal county and no impacts to coastal resources will occur.
4.9. Fish and Wildlife Resources
4.9.1. Fish and Aquatic Habitats
The French Broad River and most major tributaries in the Rosman area are designated
trout streams. The river is 80 to 100 feet wide in the project area, with a generally narrow buffer
of riparian trees along the banks. In some areas the banks are mowed and support only
herbaceous vegetation. Most of the floodplain from Rosman downstream has been cleared for
agriculture or development. The size distribution of stream bed particles shifts from coarser
particles (boulder, cobble, and coarse gravel) upstream of Rosman to finer particles (cobble,
gravel, and sand) downstream of Rosman as the river bed gradient becomes flatter and channel
meanders become more prominent.
Typical fishes in this segment of the French Broad River and tributaries in the Rosman
area include the brook trout (Salvelinus fontinalis), rainbow trout (Oncorhynchus mykiss), brown
trout (Salmo trutta), stoneroller (Campostoma anomalum), river chub (Nocomis micropogon),
golden shiner (Notemigonus crysoleucas), whitetail shiner (Cyprinella galacturus), Tennesse
shiner (Notropis leuciodus), mirror shiner (Notropis spectrunculus), warpaint shiner (Luxilus
coccogenis), fatlips minnow (Phenacobius crassilabrum), blacknose dace (Rhinichthys atratulus),
longnose dace (Rhinichthys cataractae), creek chub (Semotilus atromaculatus), northern hog
sucker (Hypentelium nigricans), white sucker (Catostomus commersoni), black redhorse
(Moxostoma duquesnei), rock bass (Ambloplites rupestris), redbreast sunfish (Lepomis auritus),
bluegill (Lepomis macrochirus), smallmouth bass (Micropterus dolomieu), greenside darter
(Etheostoma blennioides), greenfin darter (Etheostoma chlorobranchium), gilt darter (Percina
evides), and mottled sculpin (Cottus bairdi), based on Menhinick (1991). At least eight species of
native river mussels are extant in the French Broad River, and six species are apparently
extirpated (Bogan, 2002).
14

Small tributaries in the Rosman service area support few fish species, due to their small
size, steep gradients, and/or degradation from urban impacts. The more pristine segments may
support brook trout, dace, chubs, and sculpin. Small headwater streams are also important to
downstream aquatic communities for their contribution to flow stabilization, thermal regulation,
water quality protection, nutrient processing, and benthic macroinvertebrate production.
Headwater stream segments too small, shallow, or steep for fishes provide habitat for
semi -aquatic invertebrates and salamanders that require streams or seeps with limited competition
and predation from fishes. Typical salamanders in seeps and headwater streams in Transylvania
County include dusky salamanders (Desmognathus spp.), spring salamanders (Gyrinophilus spp.),
brook salamanders (Eurycea spp), and red salamanders (Pseudotriton spp.) Southwestern NC
contains the highest diversity of salamanders in the world, including several endemic species.
4.9.2. Wildlife and Terrestrial Habitats
The proposed WWTP site and spray field site contain active or fallow agricultural land
containing forage crops and weedy herbaceous plants, especially grasses (Poaceae), goldenrods
(Solidago spp.), ground cherry (Solanum carolinense), and wild carrot (Daucus carota).
Bordering the French Broad River is a narrow buffer of levee/floodplain forest dominated by
sycamore (Platanus occidentalis), tulip poplar (Liriodendron tulipifera), sweetgum (Liquidambar
styraciflua), river birch (Betula nigra), silver maple (Acer saccharinum), and black cherry (Prunus
serotina). The proposed sewerline corridors along roadsides border a mix of urban, agricultural,
and forest land. The off -road sewerline segments traverse lawn and agricultural land.
Typical wildlife on the floodplain fields and roadside woodlands in the project
construction areas includes the northern brown snake (Storeria dekayi), five -lined skink (Eumeces
fasciatus), Fowler's toad (Bufo woodhousei), cardinal (Cardinalis cardinalis), robin (Turdus
migratorius), bluebird (Sialia skills), Carolina wren (Thryothorus ludovicianus), mourning dove
(Zenaida macroura), mockingbird (Mimus polyglottos), gray squirrel (Sciurus carolinensis - often
white in the Rosman area), raccoon (Procyon lotor), opossum (Didelphis virginiana), and big
brown bat (Eptesicus fuscus). Non-native wildlife are also abundant in developed and
agricultural areas. These include the house sparrow (Passer domesticus), starling (Sturnus
vulgaris), pigeon (Columba livia), house mouse (Mus musculus), and Norway rat (Rattus
norvegicus).
4.9.3. Fish and Wildlife Habitat Impacts and Mitigation
Impacts to aquatic habitats are discussed in section 4.7.2. Sewerlines crossing streams
will be buried below the stream bed and will not pose a barrier to movement of aquatic animals
after construction is complete. The new WWTP will provide more advanced treatment and
employ UV disinfection rather than chlorine, which should benefit fish populations and other
aquatic life.
The proposed conversion of two acres of agricultural land to WWTP use is unlikley to
affect local wildlife populations. The old WWTP will be removed and the site revegetated, which
will restore approximately one-half acre of wildlife habitat. The spray field will remain in
agricultural use and its wildlife habitat value will not change substantially after construction.
Existing riparian buffers along the French Broad River adjacent to the new WWTP and spray
field will not be disturbed except for the effluent outfall corridor perpendicular to the buffer. The
15

sewerline corridors have been designed to follow existing roadsides or cross previously cleared
land (lawn and pasture) where habitat impacts will be minimal.
The project may indirectly affect fish and wildlife habitats by accommodating future
development in Rosman's expanded wastewater service area. However, these impacts will likely
be minor for several reasons: 1) The magnitude of expected urban growth is small (section 2.0);
2) new development served by the project will be adjacent to existing developed areas; and 3)
there are vast areas of National Forest and other lands near Rosman that are unlikely to be
developed.
4.10. State and Federal Protected Species
4.10.1. Existing Environment
Tne N.C. Natural Heritage Program (NHP) reports 140 rare animal and plant species known
from Transylvania County, of which seven species are federally protected as endangered (E) or
threatened (T) and another 37 species are state protected as endangered, threatened, or special
concern (SC). The remaining 96 species are designated significantly rare (SR) or candidate (C)
species that are not formally protected. This report primarily addresses the 44 federal and state
protected species known from Transylvania County. Unprotected rare species are excluded from this
report unless NHP has records near the project area or if encountered by RJG&A during the field
reconaissance.
Diagnostic features, habitat requirements, life history information, and distributional records
for each protected species were compiled from LeGrand and Hall (2001), Radford et al. (1968),
Amoroso (2001), Bogan (2002), Schafale and Weakley (1990), Menhinick and Braswell (1997),
NHP and WRC records, and personal communication with agency biologists. Potentially suitable
habitats for protected species were identified from soil maps, topographic maps, and field inspection.
Field surveys of the project corridors were conducted during October 2002. Protection status, habitat
requirements, and likelihood of occurrence in the project area for each species are documented in
Table 2.
Of the 44 protected species known from the county, only three have been reported on the
Rosman USGS quadrangle: timber rattlesnake (Crotalus horridus), hellbender (Cryptobranchus
alleganiensis), and Fraser's loosestrife (Lysimachia fraseri). There is no recent record within the
past 20 years for any of these species on the Rosman quadrangle, and none of the old site records
is within one mile of the project area. Potential habitat for a fourth species, the bog turtle
(Clemmys muhlenbergii), has been identified on the Rosman quadrangle but no bog turtle has yet
been reported. All other known protected species occurrences in Transylvania County are on
other USGS quadrangles, three miles or farther from Rosman.
The field survey by RJG&A revealed apparently suitable habitat in the French Broad
River for the hellbender, mudpuppy, and four river mussel species. In -stream surveys for these
species were not conducted, as in -stream construction will be minor (new effluent outfall pipe
only) and the effluent is unlikely to have adverse impacts on aquatic life. The numerous small
streams in the Rosman area are not suitable habitat for these aquatic animals.
The only terrestrial protected species for which apparently suitable habitat was found in
the proposed construction areas are the loggerhead shrike (Lanius ludovicianus) and Fraser's
loosestrife (Lysimachia fraseri). The loggerhead shrike may occur intermittently on floodplain
fields, including the WWTP site and spray field site, but this habitat type is abundant in the
Rosman area and the project should have little if any impact on shrikes. No shrike was seen
16

during the field reconaissance. RJG&A surveyed for Fraser's loosestrife on the forested slopes
adjacent to SR 1371, SR 1385, and the west side of SR 1388 in the proposed sewerline corridors.
We found the common species L. quadrifolia on roadside slopes in these areas, but L. fraseri was
not found, and based on this survey it is unlikley to occur here. Suitable habitat for several of
Transylvania County's terrestrial protected plants and animals may occur in rocky woodlands,
rich mesic slopes, and seeps in the wastewater service area beyond the proposed construction
areas (Table 2).
4.10.2. Protected Species Impacts and Mitigation
Aquatic protected species known from the French Broad River (hellbender, mudpuppy,
and river mussels) might be present near the Rosman WWTP, but are unlikely to be adversely
affected by project construction or operation, as instream construction will be minor and effluent
quality will be better than that from the existing WWTP.
Suitable habitat for the loggerhead shrike will be affected, but there is no record of the
shrike near Rosman and no shrike was seen during the field survey. Approximately two acres of
potentially suitable shrike habitat will be used for the new WWTP. Disturbance to shrike habitat
on the spray field site will be temporary; after installation of the spray distribution piping this site
will be similar to its pre -construction condition. Suitable shrike habitat is abundant along the
French Broad River floodplain from Rosman to Brevard, and the rarity of this bird is apparently
due to unknown factors other than habitat loss.
No protected species is likely to occur in the proposed sewerline construction corridors,
based on RJG&A field surveys. Provided that the roadside sewerlines corridors along SR 1371,
SR 1385, and the west side of SR 1388 are installed in the existing road rights -of -way, no direct
impacts to terrestrial protected species are likely. Forested slopes beyond the road rights -of -way
were not surveyed and might contain protected species.
Future development in the expanded wastewater service area may affect presently
unknown populations of protected species and their habitats. Such impacts, if any, will likely be
minor for several reasons: 1) The magnitude of expected urban growth is small (section 2.0); 2)
new development served by the project will be adjacent to existing developed areas; and 3) there
are vast areas of National Forest and other lands near Rosman that are unlikely to be developed,
and that provide better habitat for protected species than lands in the Rosman service area.
4.11. Air Quality
4.11.1. Existing Environment
Air pollutants routinely monitored by the N.C. Division of Air Quality (DAQ) include total
suspended particulates (TSP), fine particulates (PM10), sulfur oxides (SO)), nitrogen oxides (NO.),
volatile organic compounds (VOCs), carbon monoxide (CO), lead (Pb), and ozone (03). The major
sources of most of these pollutants are emissions from fuel combustion (vehicles, heating, and power
generation), industrial processes, non -industrial solvent use, solid waste incineration, open burning,
and land disturbance (U.S. Environmental Protection Agency, 1990; N.C. Division of Air Quality,
1998). Direct emissions of ozone are minor; this toxic and reactive gas is mostly created by the
photochemical reaction of emitted air pollutants (primarily nitrogen oxides) with ultraviolet sunlight.
Ambient air quality data from two DAQ monitoring stations in Haywood and Swain
counties during 1998 and 1999 are presented in Table 1 (N.C. Division of Air Quality, 2001). No
17

exceedances of DAQ standards are reported, and Transylvania County has never been designated an
EPA non -attainment area. Automobile emission testing is not required in Transylvania County and
is not scheduled to be required.
4.11.2. Air Quality Impacts and Mitigation
An increase in airborne particulates from land disturbing activities and exhaust emissions
from construction vehicles will occur during construction, but public health impacts should be
negligible. Proper vehicle maintenance, frequent wetting of exposed soil, and prompt soil
stabilization will minimize impacts. Because no forest clearing is required for construction, there
will be no air quality impacts from burning woody debris.
The WWTP and pump stations may emit odors produced by bacterial metabolism, but odor
control mechanisms will be incorporated into design and odors will be similar to those emitted by the
existing facility. Airborne particulates may temporarily increase near the WWTP when emergency
generators are used during power outages. These brief episodes will not significantly affect air
quality.
Future urban growth in the service area may cause an increase in air pollutant emissions
from vehicles and construction, but these impacts are expected to be minor based on the small
amount of new development projected. Particulate matter interferes with human and animal
respiration and plant photosynthesis (N.C. Division of Air Quality, 2000). Carbon monoxide
interferes with blood oxygen uptake. Sulfur oxides and nitrogen oxides are corrosive, damage crops,
forests, and structural materials, and may aggravate respiratory and cardiovascular problems.
Nitrogen oxides exposed to sunlight also cause ground -level ozone formation. DAQ considers ozone
the most serious air pollutant in North Carolina, particularly during warm weather, with a wide range
of adverse impacts on human health, wildlife, crops, forests, and materials.
4.12. Noise
Nuisance noise associated with project construction in residential areas will be limited to
daylight hours in accordance with local noise ordinances. Once built, operational noise from the
WWTP and pump stations will be insignificant. Occasional operation of the emergency back-up
generators during testing or power failures may pose a minor source of nuisance noise, but these
facilitities are remote from existing residences.
4.13. Transporation
Several of the proposed sewerline construction corridors are alongside public roads, and
the road shoulder in many areas is steep. It may be necessary to temporaily close one lane on
short segments of these roads during sewerline installation, and then alternating traffic flow
direction through the remaining open lane using people with hand-held stop signs. The project
contractor will be responsible for safely managing traffic on public roads during construction.
After sewerline installation is complete there will be no long-term impacts on traffic flow.
4.14. Socio-Economics & Environmental Justice
The project is intended to serve all remaining Rosman residents that do not currently have
sewer service. The majority of new service will be in low-income neighborhoods.
18

4.15. Introduction of Toxic Substances
Other than a minor temporary increase in emissions from construction vehicles, the
project is not expected to release hazardous substances in quantities that could cause toxicity to
humans, wildlife, or aquatic life. No underground fuel storage tanks or contaminated sites are
known in the proposed construction areas. All treatment chemicals and potentially hazardous
materials at the existing WWTP will be removed and properly disposed of when that facility is
decomissioned. The majority of wastewater treated by the new WWTP will be domestic. The
town will require that any industrial wastewater customers pre treat their wastewater stream if
necessary to ensure that the influent to the WWTP does not pose a threat to WWTP workers or
impede the biological treatment process, and that the WWTP effluent is not acutely toxic. DWQ
may require Rosman to conduct quarterly whole -effluent toxicity testing.
5.0. Summary of Mitigation
Measures for mitigating indirect and cumulative adverse impacts of future urban growth in
the project service area were summarized from ordinances and land use planning documents
provided by the Town of Rosman and Transylvania County.
5.1 Transylvania County.
5.1.1. Watershed Protection Ordinance.
The Transylvania County Watershed Protection Ordinance (WPO) was enacted
December 13, 1993, and contains amendments through November 24, 1997. The WPO applies
only to Water Supply Watersheds, as defined by the NC Environmental Management
Commission (EMC). Transylvania County has one Water Supply Watershed (WS-II), divided
into two areas, the Critical Area (WS-II CA), and the Balance of the watershed (WS-II BW).
Neither WS-II area occurs in the Rosman WWTP project or service areas, and the WPO does not
apply.
5.1.2. Flood Damage Control Ordinance.
All areas of special flood hazard within the county's jurisdiction are subject to the Flood
Damage Control Ordinance. Flood elevations recognized by the county are those identified by
the Federal Emergency Management Commission (FEMA), in its September 29, 1978 report,
"The Flood Insurance Study for Transylvania County" and accompanying Flood Insurance Rate
Maps (FIRM). Development permit applications are required to provide a site map, illustrating
the floodway and base flood (100-year flood) elevation, or a statement that the entire property is
within an area of special flood hazard. The statement must be certified by a professional engineer
or registered land surveyor.
Where base flood elevations are provided, the application must include elevations of the
lowest floor of all new or substantially improved structures, or the elevation to which non-
residential structures will be floodproofed. Where no base flood elevation is provided, the
application must show the lowest floor elevations, or non-residential floodproofing elevation, at
least two feet above the highest adjacent grade. Where alterations to any watercourse are
proposed, the application must contain a description and map illustrating the alterations, and an
engineering report summarizing the effects of the project on properties both upstream and down.
19

All new or substantially improved structures located in areas of special flood hazard must
be constructed with materials and equipment resistant to flood damage, and be anchored to
prevent floatation, collapse, or lateral movement during periods of flooding. Service facilities,
such as heating/air conditioning, plumbing, electrical, etc. shall be designed and constructed to
prevent the infiltration of flood waters. New water and sewer lines constructed in areas of special
flood hazard must be designed and constructed to the standards established by the NC DENR.
Where base flood elevations are provided, new or substantially improved structures must
be elevated to at least one foot above the base flood elevation. Elevated structures must be
designed and constructed to immediately equalize hydrostatic forces on exterior walls, and
preclude finished living space below the base flood elevation. Minimum standards for meeting
this criterion are established in §4-2 (a)-(c). All new, or substantially improved Residential
structures, including basements, must be elevated to at least one foot above base flood elevation.
Where solid foundation perimeter walls are used to satisfy this requirement, they must allow for
the unimpeded movement of floodwaters. Non-residential structures located in areas of special
flood hazard should be floodproofed to at least one foot above base flood elevation. A registered
professional engineer or architect must certify that the structure is designed to resist floatation, is
watertight, and is capable of resisting the hydrostatic and hydrodynamic loads of floodwaters.
Floodway encroachment is strictly prohibited, unless a registered professional engineer certifies,
through standard engineering practices, that the encroachment will not result in any rise in base
flood elevation.
Where no base flood elevation is available, floodway encroachments are prohibited
within 20 feet of the top of the bank, unless a registered professional engineer certifies, through
standard engineering practices, that the encroachment will not result in any rise in base flood
elevation.
5.1.3. Subdivision Control Ordinance.
Transylvania County enacted its Subdivision Control Ordinance on February 25, 1991.
The existing ordinance contains amendments through July 26, 1999. The county's planning
department is responsible for reviewing all proposals for new subdivisions and insuring
compliance with all applicable local, state, and federal requirements.
Preliminary plats submitted for approval must contain maps illustrating the name and
location of all watercourses identified on the most recent version of the USGS 7.5 min.
topographic maps. Any and all natural features affecting the site, and the location of the
floodway and flood hazard areas (where applicable) must also be identified. Preliminary plat
submissions must also include statements from NC DENR, approving proposed water and sewer
improvements, and erosion control plans for the proposed development. Article VII, § 10.6
requires all new and proposed subdivisions to comply with the county's Flood Damage Control
Ordinance (Section 6.2.1.2).
Developers are required to provide stormwater drainage for proposed developments
meeting the standards established in the NC DOT, in its document, "Handbook for the Design of
Highway Surface Drainage Structures", dated 1973. Surface water shall not be diverted into any
sanitary sewer. Wherever possible, developers are required to connect to existing storm drainage
systems. Subdivisions proposed in the county's jurisdiction must provide sufficient drainage to
protect the development from flood damage.
20

5.1.4. Manufactured Home Park Ordinance.
On October 23, 1995, Transylvania County passed its Manufactured Home Park
Ordinance, which today contains amendments through February 26, 2001. Each application
submitted for manufactured home parks must contain maps illustrating the name and location of
all watercourses identified on the most recent version of the USGS 7.5 min. topographic maps.
Any and all natural features affecting the site, and the location of the floodway and flood hazard
areas (where applicable) must also be identified. Preliminary plat submissions must also include
statements from NC DENR, approving proposed water and sewer improvements, and erosion
control plans for the proposed development. Manufactured home spaces must be at least 5,000 ft2
in size.
No roads proposed in areas subject to flooding, whose elevation is lower than two feet
below the base flood elevation, will be approved. Each road must be designed to accommodate
the 10-year stormwater runoff either naturally, or artificially.
5.2. Town of Rosman.
5.2.1. Watershed Protection Ordinance.
The Town of Rosman, on April 23, 2001, adopted the Watershed Protection Ordinance of
Transylvania County. The ordinance addresses activities in Water Supply Watersheds, as
identified by the NC EMC, none of which occur in the town.
5.2.2. Stream Bank Buffer Zone.
On April 23, 2001, the Town of Rosman passed an amendment to the town's building
setback ordinance establishing a 35-foot protected buffer zone along the French Broad River
within the town's jurisdiction. The French Broad River is the only surface water within the
town's jurisdiction this mandatory buffer requirement applies to.
5.2.3. Wastewater Connection Ordinance.
The Town of Rosman requires of all owners of pretreatment or holding facilities to
maintain said facilities by and at the expense of the owner of said facilities. Persons discharging
industrial waste into public sewers may be required to provide access manholes for inspection.
Within 30 days of the completion of any sewer line in the Town of Rosman, all owners of
improved property within 300 feet of the sewer shall cause said property to become connected to
the public collection system.
21

6.0. LITERATURE CITED
Adams, W.F., J.M. Alderman, R.G. Biggins, A.G. Gerberisch, E.P. Keferl, H.J. Porter, and
A.S. VanDevender. 1990. A report on the conservation status of North Carolina's freshwater and
terrestrial molluscan fauna. The Scientific Council on Freshwater and Terrestrial Mollusks,
Raleigh, N.C. 246 pp.
Amoroso, J.L. 2001. Natural Heritage Program List of the Rare Plant Species of North
Carolina. North Carolina Natural Heritage Program, Division of Parks and Recreation. N.C.
Department of Environment, Health, and Natural Resources. 85 pp.
Bogan, A.E. 2002. Workbook and key to the freshwater bivalves of North Carolina. N.C.
Museum of Natural Sciences, Raleigh, NC. 101 pp.
Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual,
Technical Report Y-87-1. U.S. Army Engineer Waterways Experiment Station, Vicksburg, Miss.
100 pp. + appendices.
King, J.M., J.W.Turpin, and D.D.Bacon. 1974. Soil survey of Transylvania County, North
Carolina. U.S. Department of Agriculture Soil Conservation Service, Brevard, N.C. 71 pp. + maps.
Lee, D.S., J.B. Funderburg, Jr., and M.K. Clark. 1982. A distributional survey of North
Carolina mammals. Occasional Papers of the North Carolina Biological Survey, 1982-10. 70 pp.
LeGrand, H.E. Jr. and S.P. Hall, 2001. Natural Heritage Program list of the rare animal
species of North Carolina. N.C. Natural Heritage Program, Division of Parks and Recreation,
Raleigh. 91 pp.
Martof, B.S., W.M. Palmer, J.R. Bailey, and J.R. Harrison III, 1980. Amphibians and
reptiles of the Carolinas and Virginia. University of North Carolina Press, Chapel Hill, N.C. 264
PP.
Menhinick, E.F. and A.L. Braswell. 1997. Endangered, Threatened, and Rare Fauna of
North Carolina, Part IV: A Re-evaluation of the Freshwater Fishes. N.C. Museum of Natural
Sciences, Raleigh, N.C. 106 pp.
N.C. Division of Air Quality. 2001. 1999 Ambient Air Quality Report. Department of
Environment and Natural Resources, Raleigh. 76 pp.
N.C. Division of Land Resources. 1985. Geologic map of North Carolina. N.C.
Department of Natural Resources and Community Development - Geological Survey, Raleigh. 1 p.
N.C. Division of Water Quality. 1999. French Broad River Basinwide Water Quality
Management Plan, December 1999. Department of Environment and Natural Resources, Raleigh,
N.C. 266 pp + appendices.
Palmer, W.E. and A.L. Braswell. 1995. The Reptiles of North Carolina. University of
North Carolina Press, Chapel Hill. 412 pp.
Potter, E.F., J.F. Parnell, and R.P. Teulings. 1980. Birds of the Carolinas. University of
North Carolina Press. Chapel Hill, N.C. 408 pp.
22

Radford, A.E., H.E. Ahles, and C.R. Bell, 1968. Manual of the Vascular Flora of the
Carolinas. University of North Carolina Press, Chapel Hill, N.C. 1,183 pp.
Schafale, M.P. and A.S. Weakley. 1990. Classification of the Natural Communities of
North Carolina - Third Approximation. North Carolina Natural Heritage Program, Division of
Parks and Recreation, Raleigh, N.C. 325 pp.
Webster, W.D., J.F. Parnell, and W.C. Biggs, Jr. 1985. Mammals of the Carolinas,
Virginia, and Maryland. University of North Carolina Press, Chapel Hill, N.C. 255 pp.
W.K. Dickson & Company. 2001. Town of Rosman Preliminary Engineering Report &
Environmental Assessment for Wastewater System Improvements, amended October 5, 2001.
Asheville, N.C.
W.K. Dickson & Company. 2002. Town of Rosman WWTP - Engineering Alternatives
Analysis (EAA) for NPDES Permit Application, amended May 16, 2002. Columbia, S.C.
23

TABLES, FIGURES, and APPENDICES
24

Table 1. DAQ Ambient Air Quality Monitoring near Transylvania County, 1998 —1999.
Air Pollutant
Total Suspended Particulates
(TSP = 0 to 45 microns)
Particulate Matter -10
(PM-10 = 0 to 10 microns)
Nitrogen Dioxide (NO2)
Sulfur Dioxide (SO2)
Carbon Monoxide (CO)
Ozone (03)
Site: Number
of Samples
N.C. Air Quality Standard
(and Period of Average)
none annual geom. mean
24-hr 2nd maximum
A: 53 annual arith. mean
24-hr 99th percentile
none annual arith. mean
A : 7,869
annual arith. mean
24-hr 2nd maximum
3-hr 2nd maximum
none 8-hr 2nd maximum
1-hr 2nd maximum
B : 5,064
: 211
1-hr expect 2nd max
8-hr mean 4th max
75 ug/m3
150 ug/m3
50 ug/m3
150 ug/m3
0.053 ppm
0.03 ppm
0.14 ppm
0.5 ppm
9 ppm
35 ppm
0.124 ppm
0.08 ppm
Observed Maximum Value Observed
Value (and Period of Average)
22
41*
0.005
0.008
0.018
0.107
0.096**
44 (24-hr)
0.008 (24-hr)
0.028 (3-hr)
0.110 (1-hr)
0.098 (8-hr)
Site A = Site number 37-173-0002. Center Street, Parks 7 Rec. Facility, Swain County.
Site B = Site number 37-087-0035. Blue Ridge Parkway tower, mile marker 410. Haywood County.
* 24-hr 99 percentile data not tabulated by DAQ; approximated using 24-hr 2nd maximum.

Table 2. Protected Animal and Plant Species known from Transylvania County, NC. See code explanations at end of table.
Scientific name
Common name
Habitat in Transylvania County
State
Protect
Status
Federal
Protect
Status
Report
History
Co / Quad
Likely to Occur in
Construc Area / or
Service Area
MAMMALS
Corynorhinus
rafinesquii
Rafinesque's big -eared bat
Old buildings, hollow trees, caves, mines, under
bridges, usually near water
T
FSC
H / N
0 / 2
Glaucomys sabrinus
coloratus
Carolina northern flying
squirrel
High elevation forests, mainly Spruce -Fir
E
E
C / N
0 / 0
Myotis
septentrionalis
northern Tong -eared bat
Warm weather: hollow trees and buildings
Cold weather. caves and mines
SC
C / N
0 / 2
Neotoma floridana
haematoreia
eastern woodrat
rocky deciduous or mixed forests
SC
FSC
C / N
0 / 2
Sorex dispar
long-tailed shrew
High elevation forests with talus or rocky slopes
SC
H / N
0 / 2
BIRDS
Aegolius acadicus
southern Appalachian
northern saw -whet owl
spruce -fir forests or mixed hardwood/spruce forests
SC
FSC
C / N
0 / 0
Certhia americana
brown creeper
High elevation forests, usually spruce -fir mixed with
hardwoods
SC
C / N
0 / 0
Falco peregrinus
peregrine falcon
Nests on cliffs, hunts over fields & water
E
C / N
0 / 2
Lanius /udovicianus
ludovicianus
loggerhead shrike
Fields and pastures
SC
0 / N
2 / 2
Loxia curvirostra
pop 1
southern Appalachian red
crossbill
Coniferous forests, especially spruce -fir stands
SC
FSC
C / N
0 / 0
Poodle atricapilla
practica
southern Appalachian
black -capped chickadee
High elevation forests, especially spruce -fir.
SC
FSC
C / N
0 / 0
Thryomanes
bewickii altus
Appalachian Bewick's
wren
Woodland borders, clearings, rural land at high
elevations.
E
FSC
H / N
0 / 2
AMPHIBIANS +
REPTILES
Ambystoma
talpoideum
mole salamander
Fish -free flooplain pools or upland pool in
woodlands
SC
H / N
0 / 2
Aneides aeneus
green salamander
Moist rock outcrops in woodlands
E
FSC
C / N
0 / 2
Clemmys
muhlenbergii
bog turtle
Bogs, wet pastures
T
TSA
C / P
0 / 2
Crotalus horridus
timber rattlesnake
Rocky upland forests
SC'
H / H
0 / 2

Scientific name
Common name
Habitat in Transylvania County
State
Protect
Status
Federal
Protect
Status
Report
History
Co / Quad
Likely to Occur in
Construc Area / or
Service Area
Cryptobranchus
alleganiensis
hellbender
large, clear fast flowing rocky streams
SC
FSC
C / O
2 / 2 (FB River)
Necturus maculosus
common mudpuppy
large, clear fast flowing rocky streams
SC
H / N
2 / 2 (FB River)
FISHES
_
_
Etheostoma
inscriptum
turquoise darter
cobble/gravel riffles in perennial streams, in
Savannah River basin only
SC
C / N
0 / 0
_
Hybopsis rubrifrons
rosyface chub
runs & pools below riffles in perennial streams, in
Savannah River basin only
T
C / N
0 / 0
Notropis lutipinnis
yellowfin shiner
runs & pools below riffles in perennial streams, in
Savannah River basin only
SC
C / N
0 / 0
MOLLUSKS AND
CRUSTACEANS
_
Alasmidonta
raveneliana
Appalachian elktoe
med-large streams with coarse sand, gravel and
cobble
E
E
C / N
2 / 2 (FB River)
Fusconaia
subrotunda
long -solid
med-large streams with coarse sand, gravel and
cobble
SC
C / N
2 / 2 (FB River)
Pleurobema
oviforme
Tennessee clubshell
med-large streams with coarse sand, gravel and
cobble
E
FSC
C / N
2 / 2 (FB River)
Strophitus undulatus
squawfoot
med-large streams with coarse sand, gravel and
cobble
T
C / N
2 / 2 (FB River)
Cambarus
chaugaensis
Oconee stream crayfish
rocky perennial streams, in Savannah River basin
only
SC
C / N
0 / 0
NON -VASCULAR
PLANTS
Gymnoderma
lineare
rock gnome lichen
above 5,000 feet or in deep gorges, rock surfaces
with high humidity
T
E
C / N
0 / 0
Cheilolejeunea
evansii
liverwort
bark of hardwoods in humid gorges
E
H / N
0 / 2
Plagiochila
caduciloba
liverwort
rocks and streambanks in humid gorges, waterfall
spray zones
E
C / N
0 / 2
Bryocrumia vivicolor
gorge moss
rocks and streambanks in humid gorges, waterfall
spray zones
E
FSC
H / N
0 / 2
Schlotheimia
lancifolia
highland moss
Bark of hardwoods in cove forests
T
H / N
0 / 2

Scientific name
Common name
Habitat in Transylvania County
State
Protect
Status
Federal
Protect
Status
Report
History
Co / Quad
Likely to Occur in
Construc Area / or
Service Area
VASCULAR
PLANTS
Arethusa bulbosa
bog rose
bogs, seeps, upland wet depressions
E
C / N
0 / 2
Asplenium
monanthes
single-sorus spleenwort
wet rock outcrops near waterfalls
E
C / N
0 / 2
Dalibarda repens
robin runaway
bogs, moist woods under Rhododendron
E
FSC
C / N
0 / 2
Geum radiatum
spreading evens
high elevation rocky outcrops
E-SC
E
C / N
0 / 0
Glyceria nubigena
smoky mountain
mannagrass
high elevation seeps
T
FSC
C / N
0 / 0
Helonias bullata
swamp pink
bogs, seeps, upland wet depressions
T-SC
T
C / N
0 / 2
Isotria medeoloides
small whorled pogonia
mesic to dry pine/hardwood forests
E
T
C / N
0 / 2
Lysmachia fraseri
Fraser's Ioosestrife
moist woodland edges, roadsides
E
FSC
C / H
1 / 2
Parnassia
grandifolia
large -leaved grass -of-
Parnassus
fens, seeps over calcareous or mafic rocks
T
C / N
0 / 2
Sarracenia jonesii
mountain sweet pitcher
mountain bogs
E-SC
E
C / N
0 / 2
Shortie galacifolia
var galacifolia
southern Oconee bells
streambanks, moist slopes, outcrops in humid
gorges
E-SC
FSC
C / N
0 / 2
Trichomanes
petersii
dwarf filmy -fern
moist rocks and humid gorges
T
C / N
0 / 2
Trillium discolor
mottled trillium
basic to circumneutral soils in rich coves and on
forested slopes
T
C / N
0 / 2
State and Federal Protection Status: E = endangered; T = threatened; SC = special concern; FSC = federal species of concern; PE, PT = proposed E or T; TSA =
threatened by similarity of appearance
NHP Report History by County and USGS Quadrangle: C = current within past 20 years; H = historic, more than 20 years ago; 0 = obscure, date and location
uncertain; N = not reported on Rosman quadrangle; P = potential habitat exists, but no specimen found (applies to bog turtle and other difficult to detect species)
Likelihood of Occurrence in Construction or Service Area:
0 = suitable habitat is not present and species is unlikely to occur
1 = suitable habitat may be present, but species apparently does not occur based on surveys by RJGA or others
2 = suitable habitat may be present, but not surveyed or surveys inconclusive; species might be present
3 = suitable habitat is present and species occurrence has been documented by RJGA or others

LIST OF FIGURES
Figure la-b. Rosman WWTP and Sewer System Improvements, Transylvania County, NC
Figure 2. Rosman Existing and Proposed WWTP Site Layout
Figure 3. Rosman Proposed Spray Irrigation Field Site Layout
Figure 4a-c. Locations of Jurisdictional Wetlands and Streams in the Project Construction Areas
Figure 5a-e. Digital Aerial Photos of Wetlands and Streams in the Proposed Rosman WWTP/Sewer
Construction Areas

•
• •
PROPOSED GRAVITY
SEWER REHABILITATION'
OR REPLACEMENT
(GRAVITY UNE •
• •
. . ... .... .......
':•s. A.- .4;3.
..s,s, -PROPOSED ROSMAN*.
,i,e4i7:i:io:....p•.!
0.25 MOD W.W.T.P
UPGRADE (SEE 1,i• ._
s.,..
• SCHEMATIC no. 9) 1.
VI' fk• eistr.;.'"
i••••••111%...
VVK
II DICKSON
Enginces 14t0 PATION AVt
Psorenos
Sufv*yors
aSitVALLE. N C
virtD 8 90:03
• " " • 7::,"*.'"*.t ••:•t .
• • • • • -. ; • .:••• 7‘.1 •
. • . . .:s : • •
• .•
PROPOSED
SPRAYFIELD
FORCE MAIN
N.41E;
THE INFORMAPON SHOWN C
OBTAINED FROM MAPS PRO\
FOR CONCEPTUAL PLANNING
i"= Doe
. •;.• . : .
5.1
Figure la. Rosman WWTP and Sewer System Improvements,
Transylvania County, NC. Southern Portion of Project Area.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616

f
**: LEGEND
Ii$R
r,-.,-.--,5
CLOUDED AREAS DENOTE A
( 1..................P-P REQUIRE • ARCHEOLOGICAL 5.
NOTE 1 BELOW.
•
,.x:'1...1.,:::::::',::.:;.;:i.;.,,`":. •:•!.•••!::. ....;.
••.• ..f .. . : .. .. t'*."•'!".!..
..„, .A14.4si...-pg,•;.4,..:,z, . ,..
A VW'
,,,,,, 4 ..,
•0`.. ef * ,,, - -,,
-,<- . •or:. ' •
.
•••—..".:,st..- • %<. •
• • ---4:2•44'"x,„
• .....r.).pp.,,.* !••
r . ' .,, * ,,, ). .N ws,,,,...
.... •'''''''''.4.:?;7%
A.::', •-..._
--• •••••NY,....
ke 41 ,,,..
PRODUCTS
/ • •,... -s,
,..
N / .... .:, . ,
It ' '.:,
\ ::
,:. 1:. e.... A ...:,<,
1 i
i i
4
4,.41.**„
f. , -..3:Efikg::::
:•Atik. * SANITARY SEWER
.
SPRAY IRRIGATION PIPING
ik *A '
• ,44-4. %.,111.1f: "-.0 •,,,.,
... . K • • >A.
Z
44 . .1%. 4, 7 v -,
'1. — — ... FirCE MAIN
k -, ,,--- ' \.: ''''''''',,, •••4,X 11
• , .. WASTEWATER LIFT STATION
',...t• .4.„ Ni..
- 1 ,.,„......,-. k..
N .4. :., • ' 4
.-- .::-.
.ia. - 4f.
% ''• 'i•• '-
..... c TABLE1
ADOTIONAL CALVERT ROAD N". %,<„.
r GRAVITY SEWER LINES 1
'' 3 ...: A Rd NO, DESCRIPTION
500 LF. 25' WIDE CORRIC
tt. '., - GRAVITY SEWER
P .. • -,
.'#1 '''
.C) 75o. IF. 30' WIDE CORRIC
1
':`r ....
-' :.. • rft'''''
• ! ..-- e./GRAVITY SEWER AND 4" I
..lp .i...,
jr•••• %., i '•
0 :
io
•*,
41*
•
Figure lb. Rosman WWTP and Sewer System Improvements,
Transylvania County, NC. Northern Portion of Project Area,
Including Calvert Road Service Area.
2 ACRES FOR WASTEWATE
PLANT
1600 IF, 25' WIDE CORR
FORCE MAIN
16.5 ACRES FOR SPRAY
APPLICATION OF WASTEW,
PLANT EFFLUENT
800 LF, 25' WIDE CORM(
FORCE MAIN
1500 LF, 25' WIDE CORR
GRAVITY SEWER
s4
• f;
. A..... ‘ s:"....i.t
le,) 1 41 ,
.i:
:,
a' I - •
gaZt MEM IVISTPIIIIIIIIVICIESH
• MR 212Er
•••.• 1000
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
• • • .
S V A \
N; • •••
r-1; /-1 N
c:.
—) •

EXISTING GRAVITY
SEWER
EXISTING TOWN OR ROSMAN
WELL #2 LOCATION
50' BUFFER
FROM RIVER,
TYPICAL
D ICK80N
THE SHOWN ON THIS MAP IS APPROXIMATE AND WAS
OBTAINED FROM MAPS PROVIDED BY ROSMAN. THIS MAP I5 INTENDED
FOR CONCEPTUAL PLANNING PURPOSES ONLY. FINAL CONFIGURATION
OF PLANT EXPANSION lc TREATMENT METHOD SUBJECT TO CHANGE
DURING FINAL DESIGN. PRELIMINARY —DO NOT USE FOR CONSTRUCTION.
REFERENCE SHEET 9 FOR PROPOSED
SPRAY IRRIGATION FIELD LOCATION
S t/lyG G AVj
ABA gNooN foB£
I .
50' BUFFER FROM PROPERTY
PROPOSED ENTRANCE
ROAD & PARKING
PROPOSED SEQUENCING
BATCH REACTORS
UNE, TYP.
11
PROPOSED
INFLUENT
SCREEN
/ PROPOSED
INFLUENT
PUMP
STATION
FUTURE
EXPANSION
AREA
UV OR CHLORINE
INFECTION
DIS
i-4101.
�.
PROPOSED POST
AERATION CASCADE
City U�
%%b.
APPROXIMATE DISCHARGE
LOCATION
PROPOSED
BLOWERS
PROPOSED
.EFEI DENT — PROPOSED BACK—UP CHLORINATION/
FLOW Mil'Er'"'" —CHLORINATION "STRUCTURE
60
PROPOSED POST
EQUAUZATION TANK
PROPOSED SLUDGE
DUMPSTER PAD
FUTURE VACUUM SLUDGE
DRYING BED
0
60
120
PROPOSED VACUUM SLUDGE
DRYING BED
PROPOSED
STAND—BY
GENERATOR
SCALE: 1' - 60'
PROPOSED SLUDGE CONDITIONING
AND MAINTENANCE BUILDING
EXISTING 90,000 GPD WWTP
TO BE ABANDONED AND
DEMOLISHED
~ ci�irs
—x—x—x—x—x—x�
'PROPOSED DIGESTER
PROPOSED 4" SPRAY
IRRIGATION _PUMP UNE,
-APPROX= . 2850 LF. (t)
t
joe
L EXISTING
DISCHARGE
FUTURE .QIGES1 ER
(PROPOSED SPRAYS / \v1'1‘
FR /
RIGATIGN
PUMP STATIO�t _.
PROPOSED TERTIARY FILTERS
Figure 2. Rosman Existing and Proposed WWTP Site Layout.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
TOWN OF ROSMAN
PRELIMINARY ENGINEERING REPORT
OPTION #2 - IMPROVE ROSMAN WWTP
SCHEMATIC OF PROPOSED 0.25 MGD WWTP
.r
UPDATED
ANRJ$T 2C01
FIGVR( NO.
10

Fields R4 + R5 Combined
Spray Loading Schedule
Month Million Gal/Month
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
0.00
0.00
0.00
0.78
0.54
0.83
0.72
0.35
0.74
0.41
0.34
0.00
TAO °• 1•
4 - t NcH ♦
FORGE MAIN •
FROM WWTP
FIELD No.
R-2
R-3
rR-4
R-5
R.6
TOTAL
1i%%//4
BM+1,ER MAP/PRELIMINARY SPRAY HEAD LAYOUT
W.K. Dickson Prelininary Soil Evaluation
Rosman, North Carolina
SCALE:
As Shown
J08 NO.
1588-01.044
DRAWN BY:
DATE:
RDM
January,2002
FIGURE NO.
CHECKED BY:
CSC
1
SBME
ENVIRONMENTAL SERVICES
ENGINEERING • TESTING
USEABLE BUFFER TOTAL
ACREAGE ZONE ACREAGE
4.22 5.58 9.80
4.91 4.95__
7.20 3.97
10.40 9.20
0.57 8.30
28.06 31.30
A
9.92 . R-'{ + R•S
11.17
1.9.60r 1'J.6 acres
8.87 usable
59.36
LEGEND
• 100' BUFFER ZONE FOR STREAMS CLASSIFIED AS WS
EME - 150' BUFFER ZONE FOR PROPERTY BOUNDARY
• HOUSE
A - STRUCTURE
- - - - • PROPERTY LINE
- - • DRAINAGE WAY
_ • UNPAVED ROAD
• - SPRAY HEAD
♦
(
MAIN LINE
r,�' H BROAD RIVER
Figure 3. Rosman Proposed Spray Irrigation Field Site Layout.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
LATERAL LINE (TYP.)
GRAPHIC SCALE -_
300 150 0
300

1
ee •
r"""
PROPOSED GRAVITY
SEWER REHABIUTATION
OR REPLACEMENT
(GRAVITY UNE A
•
. • f ria4""6'cl "<;:// ee1.-
;
Figure 4a. Locations of Jurisdictional Wetlands in Streams
(GA- GD) in the Proposed Construction Areas.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
,f

78
•
6;
. ........:...:.::.:
PROPOSED GRAVITY
SEWER REHABIUTA
OR REPLACEMENT
(GRAVITY UNE 8)
f
ADDITIONAL 8' GRAVITY
SEWER FROM ABANDONED
PUMP STATION TO PROPOSED
WWTP PUMP STATION
Figure 4b. Locations of Jurisdictional Wetlands in Streams
(GE) in the Proposed Construction Areas.
a
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
/1ff

I
it
jr
�r..d
ti`k` jt j
is NI,, �
, ,
.
!f'
►'r� s
,.i ��•�''
N - ------ -..— ?"7
t �
N,1
1!s
�l •
Figure 4c. Locations of Jurisdictional Wetlands in Streams
(GF- GG) in the Proposed Construction Areas.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
•
1'

TerraServer Image Courtesy of the USGS
Page 1 of 2
Send To Printer Back To TerraServer 11 x 17 Print Size
MUMS 1 km N of Rosman, North Carolina, United States 25 Mar 1995
Figure 5a. Digital Aerial Photo of Wetland/Stream GB in
the Proposed Rosman WWTP/Sewer Construction Areas.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
Image courtesy of the U.S. Geological Survey
© 2002 Microsoft Corporation. All rights reserved. Terms of Use
.../printimage. aspx?T=1 &S=10&X=1669&Y=19454 R' 7=17& W=2&P=1+km+N++of+Rosman%2c+North+Caroli na%10/03

TerraServer Image Courtesy of the USGS
Page 1 of 2
Send To Printer Back To TerraServer 11 x 17 Print Size
MEN Rosman North Carolina, United States 25 Mar 1995
0'
Figure 5b. Digital Aerial Photo of Wetland/Stream GC-GD
in the Proposed Rosman WWTP/Sewer Construction Areas.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
'100M
rye.; ; : ir.� •; ...3 �
,.. .. '. C+xi ....:r+.: :.:,tit' F:G r:.;i.'•;'-.
0' 1100yd
Image courtesy of the U.S. Geological Survey
© 2002 Microsoft Corporation. All rights reserved. Terms of Use
.../printimage.aspx?T=1 &S=10&X=1670&Y=19451 &Z=17&W=2&P=Rosman%2c+North+Carolina%2c+United+St/10/03

TerraServer Image Courtesy of the USGS
Page 1 of 2
Send To Printer Back To TerraServer 11 x 17 Print Size
MUSCS Rosman North Carolina United States 25 Mar 1995
o'
1100M
Figure 5c. Digital Aerial Photo of Wetland/Stream GE in
the Proposed Rosman WWTP/Sewer Construction Areas.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
0'
�100yd
Image courtesy of the U.S. Geological Survey
© 2002 Microsoft Corporation. All rights reserved. Terms of Use
.../printimage.aspx?T=1 &S=10&X=1671&Y=19448&Z=17&W=2&P=Rosman%2c+North+Carolina%2c+United+S11/10/03

TerraServer Image Courtesy of the USGS
•
Page 1 of 2
Send To Printer Back To TerraServer 11 x 17 Print Size
MUMS 2 km NE of Rosman, North Carolina United States 25 Mar 1995
Figure 5d. Digital Aerial Photo of Wetland/Stream GF-GG
in the Proposed Rosman WWTP/Sewer Construction Areas.
Robert.J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
Image courtesy of the U.S. Geological Survey
© 2002 Microsoft Corporation. All rights reserved. Terms of Use
,,./printimage.aspx?T=1&S=10&X=1676&Y=19456&Z=17&W=2&P=2+km+NE+of+Rosman%2c+North+Carolina 1/10/03

raScrvcr Image Courtesy of the USGS
:rver Image Courtesy of the USGS
Send To Printer Back To TerraServer
:WKS 2 km NE of Rosman, North Carolin
•
0
11 x 17 !
r__ a_ J 4-
Send To Printer
Back To TerraServer
Figure 5e. Digital Aerial Photo of Wetland/Stream GG and
the Proposed Calvert Road Wastewater Service Area.
vi: � tee:\•'i
Image courtesy of the U.S. Geological St
© 2002 Microsoft Corporation. All rights reserved.
Robert J. Goldstein & Associates, Inc
ENVIRONMENTAL CONSULTANTS
8480 Garvey Drive, Raleigh NC 27616
Image courtesy of the U.S. Geolo
© 2002 Microsoft Corporation. All rights rese
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4.17 iv-wt Ei/

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Gregory J. Thorpe, Ph. D, Acting Director
Mayor Johnny Rogers
Town of Rosman
P.O. Box 636
Rosman, North Carolina 28772
April 16, 2002
LerA
NCDENR
Subject: Comments on Engineering Alternatives Analysis
Permit No. NC0021946
Rosman WWTP
Transylvania County
Dear Mayor Rogers:
The NPDES Unit has completed its review of the Engineering Alternatives Analysis (EAA)
submitted for expansion of the Rosman WWTP from 0.090 MGD to 0.250 MGD and submits the
following comments.
Flow Justification
The major issue of concern with the EAA is clear justification for an increase in flow to 250,000
GPD. From review of Figure 1., the projected increase in population from year 2002 to year 2022 is 570
persons to approximately 660 persons. An increase of less than 100 people over a twenty-year period
does not clearly justify an increase in flow of 160,000 GPD. There was no mention of potential
industrial flows due to businesses that would contribute to the need for this amount of flow. While the
Rosman plant currently has inflow and infiltration (I&I) problems, there should be a reduction of I&I
flow with the addition of new sewerlines. With a projected improvement in the excessive flows to the
system and the minimal yearly increase in population in Rosman, a more thorough explanation and
justification of the request for expansion is required before a permit modification can be issued.
Costs
Sources of costs and the derivative of the discount rate should be documented. It is also
recommended that a summary table of discharge options and the costs be presented. It is recommended
that land costs for the adjacent acres that are proposed for land application be provided. Further
explanation of the unavailability of land surrounding the Rosman WWTP is also needed. Were actual
inquiries made to landowners? What was the average cost of an acre of land in that area?
Loading Rates
For the non -discharge alternatives, the derivation of loading rates should be provided.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Permit, No. NC0021946
Rosman WWTP
April 16, 2002
Page 2
Proposed Treatment System
It appears that the design of the proposed facility with the sequential batch reactors, the tertiary
treatment multidisk cloth filtering system and ultraviolet disinfection will adequately treat Rosman's
domestic strength effluent. The speculative limits recommended by DWQ should be achieved with this
type of treatment system. In addition, the option of land application of a portion of the effluent was
evaluated as a viable option for the proposed expansion.
We are returning the application for expansion and a copy of the engineering alternatives
analysis. Please resubmit your application and provide the requested information by May 16, 2002. If
you have any questions or need additional information, please contact me at telephone number (919)
733-5083, extension 512.
Sierely,
lyn M. Nowell
NPDES Unit
cc: Central Files
Asheville Regional Office
Bobby Blowe/Construction Grants & Loans
WK Dickson, 501 Commerce Drive, Columbia. S.C. 29223
NPDES Unit

Iv,n..l'del r . cdsley, t,uvei l iui
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
,pjQ — C6L
March 1, 2002
Honorable Johnny H. Rogers, Mayor
Town of Rosman
P.O. Box636
Rosman, North Carolina 28772-0636
SUBJECT: Environmental Comments
Preliminary Engineering Report &
Environmental Assessment
Project No. E-SRG-T-02-0131
Dear Mayor Rogers:
The Construction Grants & Loans Section has completed the environmental review of
Rosman's Preliminary Engineering Report and Environmental Assessment, and the
environmental comments are attached. The technical review has not been completed, and
comments will be submitted when it is completed.
If you have any questions concerning this matter, please contact me at [phone].
Sincerely,
Reginald R. Sutton, Ph.D.
Environmental Assessment Coordinator
RRS/dr
Attachments: (all cc's)
cc: W. K. Dickson - Robert D. Wilroy, P.E.
DWQ Asheville Regional Office
Daniel Blaisdell, P.E.
Larry Horton, P.E.
SRG
R C C E
iii is 1 s' 23 :.
.:. DtO?-(SC' ,', CO.
Construction Grants and Loans Section 1633 Mail Service Center Raleigh, NC 1 its-1 b33.3 (91 J) /'Ss-
E-Mail Address wwnr.nccgl.net FAX [phone]
4...
4.4n
L17,:.
1ustomer berme
1 800 623-7748

CGL
TOWN OF ROSMAN
Environmental Review Comments
Project No. E-SRG-T-02-0131
February 28, 2002
General
1. All of the proposed wastewater collection, transport, reuse, and treatment plant facilities for
the selected alternative must be identified on an 8/2 x 11 topographical map. The length
and size of all replacement/rehabilitation/extension sewer lines must also be provided on a
topographical map.
2. A public hearing needs to be advertised and held. The advertisement must be documented
with an affidavit of publication, and a record of the public hearing presentation must be
provided.
Section I - Existing Environment
1. A specific discussion of topography, soils, surface waters, groundwater, and geology must
be included for the service area. A quality map should be provided showing the location of
streams in and adjacent to the service area.
Section II - Need
1. Additional information needs to be provided about the "multiple private point source
wastewater discharges in the vicinity."
Section IV - Environmental Consequences
1. Identify the source of Rosman's potable water, and indicate if the supply is
adequate to serve future needs.
2. The existing habitat type should be specifically described for all areas in which construction
is proposed.
3. How many stream crossings will be required to construct the proposed transport facilities,
and have steps been taken to minimize adverse impacts?
4. The Corps of Engineers should evaluate the proposed project sites to determine if
jurisdictional wetlands will be impacted. A letter of confirmation should be provided from
the Corps. The report needs to indicate that steps will be taken to avoid construction in
wetlands and/or appropriate mitigative measures will be implemented to minimize adverse
impacts.
5. How much clearing of forested areas will be required to construct the proposed facilities?
6. Has the potential for recreational and open space been evaluated?

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D.
Acting Director
Division of Water Quality
January 15, 2002
MEMORANDUM
TO: Melba McGee
Department of Environment and Natural Resources
FROM: Milt Rhodes i
Division ofWater Quality
SUBJECT: SEPA Review of Town of Rosman, NC, Wastewater System Improvements
Environmental Assessment, DENR # 1155
The Division of Water Quality (Division) has reviewed the proposal for the Town of Rosman.
This project has been reviewed by staff in the NPDES Unit, the Regional Office, and Local
Government Assistance Unit.
In the recent "speculative limits" letter sent to the Town of Rosman, it was indicated that the
Town should more closely evaluate the option of connecting to the Brevard WWTP.
Regionalization of wastewater treatment facilities remains a primary goal of DWQ and it appears
that connecting to the Brevard system is a viable alternative. The Division would like to the
Town to reconsider the preferred alternative and re-examine connecting to the Brevard WWTP
prior to pursuing an upgrade of the magnitude discussed in the environmental document.
Thank you for the opportunity to comment. If there are any questions, please contact Milt Rhodes
at [phone] x366 for further information.
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1517 [phone]
Customer Service
1 800 623-7748

7. Executive Order 1 1988: Floodplain Management - requires an action or project to avoid, to
the extent possible, the long and short-term adverse impacts associated with the direct and
indirect occupancy and modification of floodplains. The environmental assessment needs to
demonstrate that steps have been taken to avoid the construction of a new wastewater
treatment plant and transport facilities in the 100-year floodplain. The report needs to
document that there are no other feasible sites, which are not in the 100-year floodplain,
available for constructing the wastewater treatment plant.
8. What policies and regulatory measures (e.g., floodplain protection, wetland preservation,
greenway conservation, stormwater runoff, riparian buffers, etc.) are available to protect
water quality from secondary growth and development?
Agency Reviews
I. Several agencies reviewed the report. The attached comments from the NPDES Unit, the
Local Government Assistance Unit, the NC Wildlife Resources Commission, the US Fish
and Wildlife Service, and the Department of Cultural Resources must be addressed.
Comments from the Division of Air Quality are provided for information and planning
purposes.

QG +..
NCDENR
Mayor Johnny Rogers
Town of Rosman
P.O. Box 636
Rosman, North Carolina 28772
Dear Mayor Rogers:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
December 20, 2001
Subject: Modification of NPDES Permit NC0021946
Rosman WWTP
Transylvania County
The Division received your permit application request and fee payment of $215.00 (paid by check #
1728) on December 17, 2001. Ms. Jacquelyn Nowell of the NPDES Unit staff will review the application.
Ms. Nowell will contact your Authorized Representative (Robert D. Wilroy of W.K. Dickson & Company) if
further information is needed about this project.
Please note that the NPDES Unit has consistently had at least 2 (and as many as 5) vacant positions
since mid-1998. Our remaining permit writers are currently carrying extremely heavy workloads. While we
do not expect severe delays in handling your request, be aware that your application' is one of many that Ms.
Nowell is currently reviewing.
If you have any additional questions concerning the subject application, please contact Ms. Nowell at
[phone], extension 512.
cc: Asheville Regional Office / Water Quality Section
Central Files
N'PDES Unit
Robert D. Wilroy
N. C. Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Sincerely,
1/407,
Charles H. Weaver, Jr.
NPDES Unit
Phone: [phone], extension 511
Fax: [phone]
e-mail: [e-mail]

WK
Ili DICKSON
Engineers • Planners • Surveyors
Landscape Architects
December 11, 2001
Mr. Dave Goodrich
NC DENR-DWQ-NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
RE:
Town of Rosman, North Carolina
NPDES Permit Application
EAA Submittal
Dear Mr. Goodrich:
Ai'COC 2/90
#-• /iZir
Vwx-74_
Enclosed are three copies of the NPDES permit application form and Engineering
Alternatives Assessment (EAA), a check for $215 for a major modification of an existing
NPDES Permit made payable to NC DENR, and a letter from the Town of Rosman
Council giving the Mayor permission to sign the permit application.
The above referenced documents are being submitted in conjuction with a proposed
new wastewater treatment facility for the Town of Rosman. We are requesting an
increase in the discharge limit for the permit from 0.09 MGD to 0.25 MGD. The
proposed new facility is replacing the existing treatment plant, which is undersized and
outdated. Since this permit application is for an increase in flow for a new proposed
facility that is less than 0.5 MGD, no Environmenal Assessment (EA) was required for
submittal.
If you have any questions, please feel free to contact me at [phone].
Sincerely yours,
W. K. Dickson, Inc.
Robert D. Wilroy, P.E.
Project Engineer
cc: Dan Blaisdell, NCDENR
file
Enclosure
501 Commerce Drive, NE
Columbia, South Carolina 29223
803.786.4261
Fax [phone]
www.wkdickson.com
Other Offices:
Asheville, NC
Atlanta, GA
Charlotte, NC
Hickory, NC
Raleigh, NC
Wilmington, NC

Rosman - Spec/EAA Review
_ Must show justification for need of the project
• Population projections, trends
• I & I —expansion
• Did they follow our alternatives analysis guidance - table of contents
Look hard at population projections
1/ flow justification
1/ for connection with nearby or regional facility, check with RO for land
• Rule of thumb if >5 miles away, they don't have to consider
Spray irrigation — check loading rate numbers. What is it based on? 1/ with RO or soil scientist in the area.
1/ w/ JR for info on loading rates
• Need to look at adjacent parcels of land, not just land they own
• Soil scientist , out of Black and Veech, DEH employee
Look at adjacent land, what is the best soil, tell how many acres are needed
1/ to see hd uniform the soils are, Are there better soils in the area
1/ land is available, check cost
*Cost out the cost of the land
Call realtor
Cost of land per acre
WW Reuse?
What efforts did they go through to 1/ reuse?
Can reuse on their own grounds
Effluent will not be reuse quality. 30/30 limits required. How much do you go into?
**Comment on UV, filters, using SBRsV
Present value analysis
Discount rate? Loan rate? V w/ Construction Grants
Missing : Need Summary table
Complete spray irrigation system
Soil loading rates
Land costs, if Rosman should purchase
Projected population growth - 1/ flow justification
570 in 2002
750 in 2039
an increase of 180 people
**increase in population VS. flow justification,
Do you expect any reduction in I& ?
Does not appear to be justified for 250,000 GPD
@600 people, the WWTP is 0.075 MGD + 100 people .012 MGD = 0.087 MGD
80% of 0.090 = 0.072 MGD
Can get grant money to fight I&I
• Need to provide the source of their costs --3 equipment items (Means manual)
If costs of alternatives are close, look at the big -ticket items. Compare the two recurring.costs.

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December 7, 2001
Mr. Reginald R. Sutton
North Carolina Department of Environment and Natural Resources
Division of Water Quality .
Construction Grants & Loans Section
1633 Mail Service Center
Raleigh, North Carolina 27699-1633
Dear Mr. Sutton:
U�-r+WS
Subject: Town of Rosman, Wastewater System Improvements, Transylvania County, North
Carolina
On October 22, 2001, we received a copy of the Preliminary Engineering Report and
Environmental Assessment (Report/EA) for the subject improvements. We have reviewed the
Report/EA and provide the following comments in accordance with the provisions of the Fish
and Wildlife Coordination Act,.as amended (16 U.S.C. 661-667e), and Section 7 of the
Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act).
The Town of Rosman proposes to improve their wastewater system by eliminating failing
wastewater system components, expanding a currently inadequate treatment works capacity, and
providing sanitary sewer service to unserviced areas of the town. Two alternatives are
considered for upgrading the wastewater treatment facilities --improving and expanding the
current system or tying into the Town of Brevard's municipal sewage system.
We have no major objections to the proposed project (either alternative) because the results will
ultimately mean better water quality in the French Broad River. Though Alternative 1 (tying into
the Brevard municipal sewage system) is more expensive, environmentally it appears more
desirable because it would minimize potential flooding of the system and avoid fill and
construction in the 100-year floodplain. Executive Order 11988 requires Federal agencies to
consider and protect floodplain functions. We believe the recent examples of flooding in eastern
North Carolina highlight the importance of avoiding the "... long- and short-term impacts
associated with the occupancy and modification of floodplains . • ." and that we should "avoid

direct ano inairect support or tioodpiain development ...." We encourage you to review the
enclosed copy of Executive Order 11988.
The Report/EA notes potential wetland impacts. Measures to avoid or minimize impacts to
sensitive resources, including wetlands, should be implemented during construction. Where
impacts to wetlands are unavoidable, we recommend mitigation of the losses. In addition to
providing wildlife habitat, wetland areas perform important functions of flood control and water
quality protection. Disturbed wetland areas should be returned to their original soils and
contours. Plant communities should be reestablished that would result in wetland plant
community succession into habitat of equal or greater value than the habitat that was destroyed.
Temporarily disturbed wetlands should be reseeded with annual small grains appropriate for the
season (e.g., oat, millet, rye, wheat, or rye grass) and be allowed to revert to natural wetland
vegetation. The crossing of wetlands and streams should be minimized, located at narrow areas,
and made perpendicular to the stream.
,lough the Report/EA states that there are no known threatened or endangered species in the
project area, it does not mention any surveys for such. We recommend that appropriate habitat in
the project area be surveyed for federally listed endangered and threatened species to ensure that
these rare resources are not inadvertently lost. We have enclosed a list of federally endangered
and threatened species and Federal species of concern for Transylvania County. In accordance
with the Act it is the responsibility of the appropriate Federal agency to review its activities or
programs and to identify any such activities or programs that may affect endangered or threatened
species or their habitats. If it is determined that these proposed activities may adversely affect any
species federally listed as endangered or threatened, formal consultation with this office must be
initiated. Please note that Federal species of concern are not legally protected under the Act and
are not subject to any of its provisions, including Section 7, unless they are formally proposed or
listed as endangered or threatened. We are including these species in our response to give you
advance notification and to request your assistance in protecting them.
We appreciate the opportunity to provide these comments. If we can be of any assistance or if
you have any questions, please do not hesitate to contact Mr. Alien Ratzlaff of our staff at
828/258-3939, Ext. 229. In any future correspondence concerning this project, please reference
our Log Number 4-2-02-084.
Sincerely,
. 7
Brian P. Cole
State Supervisor
Enclosures

NC- Wier
North Carolina Wildlife Resources Commission g
Charles R. Fullwood. Executive Direm.)r
MEMORANDUM
TO. Melba McGee, Environmental Coordinator
Office of Legislativ d Il tg4v mental airs
FROM. Owen F. Anderson, u tain Region Coordinator
Habitat Conservation Program
DATE: November 28, 2001
SUBJECT: Preliminary Engineering Report & Environmental Assessment for Wastewater
Facilities, Town of Rosman, Transylvania County, NC, DENR Project No. 1155
Biologists with the North Carolina Wildlife Resources Commission have reviewed the
subject project. Our comments are provided in accordance with provisions of the Fish and
Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S C. 661-667d.) and the North
Carolina Environmental Policy Act (G.S. 113A-1 et seq , as amended; 1 NCAC 25).
The Town of Rosman is evaluating alternatives for wastewater collection and treatment.
The current collection system is old and failing and the wastewater treatment facility is
exceeding 80% of capacity. Excessive infiltration and inflow are resulting from the failing
collecting system and are causing problems with treatment at the plant.
The Town is evaluating repairing the collection system and constructing a new treatment
plant and providing sewer lines to areas with failing septic systems. A second alternative is
connecting to the Town of Brevard's wastewater system via a force main. The cost of the two
alternatives does not appear to be significantly different. The Town's preferred alternative is to
construct a new wastewater treatment plant.
The plant that is proposed would increase the current capacity of 90, 000 gallons per day
to 250,000 gallons per day and would provide for the Town's wastewater needs for 20 years.
The proposed plant would be a tertiary treatment facility and use ultraviolet disinfection with
which we are pleased.
We concur with the need to replace the failing wastewater treatment plant and Collection
system. Due to the excessive infiltration and inflow, rehabilitation of the collection system
should be given top priority The collection system would need to be repaired regardless of what
treatment alternative is used
This project is limited in scope rel2tive to m1'. c`st waste'..'ate treatment plant upgrades.
Therefore, we. do no believe adverse impacts to ash and wildlife should he significant. However,
due to the good quality streams in the area. there are several lss',:es that teed to be addressed
Mailing Address: 'i• i .. n r'r ai^ - . `.'. ' C . . „ ' P. 1h, NC 27699-17221
>✓ .�. ., r..a,� l li.._: if i • i . ai 'i t--. li_'
Tei:nhnnr, _i: • Fax: y••. n4..

Town of Rosman WWTP & Lines
Transylvania County. French Broad River
Many of the streams in the area are classified as trout waters by the Division of Water
Quality and/or designated as trout waters by the NCWRC. The protection of these streams is
most important to fish and wildlife resources and to public recreation and tourism.
Our major concern with this project is the secondary impacts associated with
development that could be facilitated by the improved infrastructure. Much of the Rosman area
is within the 100-year floodplain of the French Broad River. Unless there are ordinances that
prohibit filling and/or providing sewer service to new construction within the l00 ye
floodplain, we believe there is potential for significant adverse impacts associated with the
improved infrastructure.
We are also concerned about the secondary and cumulative impacts of stormwater runoff
and loss of riparian buffers. The loss of forested riparian areas will leave streams vulnerable to
bank erosion and water temperature increases. Sedimentation and elevated water temperature
could adversely impact the important trout resource in this area.
Overall we believe this project can have benefits to fish and wildlife due to improved
water quality from tertiary treatment and ultraviolet disinfection; therefore, we anticipate
concurring with the EA. However, there are several issues listed below that need greater
discussion and/or clarification.
1. Much of Rosman is within the 100-year floodplain. What assurances (e.g., ordinances or
conditions of loans or state regulations) will be in place to prevent development within
the 100-year floodplain, filling'of the 100-year floodplain and to prohibit sewer service to
such development in these areas?
Discuss the secondary and cumulative impacts associated with development that may be
promoted by the improved infrastructure and what measures (e.g., local ordinances or
Initiatives) will be put in place to mitigate the impacts. The discussion should focus on
stormwater management measures, forested riparian buffer protection and floodplain and
wetland protection.
3. Wastewater treatment plants should have emergency generators of sufficient size to
provide power during power outages to operate all essential treatment works. Please
clarify if emergency generators to supply such power are included in this project.
4. There is no comparison of impacts for the two alternatives although the cost is essentially
the same. What are the differences in environmental impacts for the two alternatives?
The impacts to wetlands and streams and the improvement to water quality in the French
Broad River between Rosman and Brevard due to the removal of the Rosman discharge
are of particular interest.
5. What mechanisms are in place that would require the connection of existing residences
that are on septic systems, especially those that are malfunctioning or are in poor soils?
Thank you for the opportunity to provide input during the planning stages of this project.
If we can provide further assistance or clarification of these comments, please contact me at
[phone].
cc: Dave Goodrich, Division of Water Quality, NPDES Section
Steve Hall, Zoologist, Natural Heritage Program
Mark Cantrell, Biologist, USFWS, Asheville
'7.
November 28, 2001

,Nov 14 01 03:21p
WKD Registered User
828 251-1611
p.1
FAX TRANSMITTAL
1419 Patton Avenue • Asheville, North Carolina 28806 • 828-251-1610 • 828-251-1611 (fax)
To: Jackie Nowell Fax [phone]
From: Jody Lowe
CC: File
Date: November 14, 2001
Re: 10583.40 Town of Rosman VVWTP Expansion —Waste-load Allocation Request
00744.40 Town of Highlands WWTP Expansion — Waste -load Allocation Request
Ms. Nowell:
Attached is a copy of the original requests for the above mentioned projects from July 20, 2001
that was sent to Forest Westall, as well as the follow-up request I sent to Charles Weaver on
September 21, 2001. If you have any questions, please call me at [phone].
Thank you.
L:lProjects\RoSMA1902031Qocuments1Cover-DENR-Wasts Load Allocation Request to Nowetl.doc 11/14/01 3:15 PM

Nov 14 01 03:21p WKD Registered User
828 251-1611
p.2
TRANSMITTAL
WK
DICKSON
Ertyuuxra • Pfaaura • Swvcvors
I 419 Patton Avenue • Asheville, North Carolina 28806 • 828-251-1610 • 828-251-1611 (fax)
To: Charles Weaver [phone] From: Jody Lowe
Company: NCDENR
Date: September 21, 2001
Reference: Preliminary Waste -Load Allocation Requests
0 Urgent ❑ For Review ❑ Please Comment ❑ Please Reply ❑ Please Recycle
CC: Towns of Rosman and Highlands
Attached are copies of the original requests sent to Forest Westall of NCDENR in Asheville on July
20, 2001 requesting preliminary waste -load allocations for the expansions of theTowns of Rosman
and Highlands wastewater treatment facilities. Included is a copy of the original cover letter and
map for each project. Please call if you have any questions regarding this matter.
Total## ofpages: 5
If you do not receive all pages or If the transmission is not legible please call our receptionist at [phone].
The information in this fax transmittal is privileged and confidential. If you are not the intended recipient any
distribution or copying hereof is strictly prohibited. If you have received this fax transmittal in error, please call our
receptionist and return this fax transmittal to W.K. Dickson & Co. by mail. Thank you.
-1 -

Ploy 14 01 03:21p WKD Registered User
828 251-1611 p.3
S
�;'
K.
July 20, 2001
Mr, Forest \Vestal!, PE
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville, North Carolina 28801
RE: Waste -Load Allocation Request
for the Town of Rosman
Wastewater Treatment Plant Expansion
WKD #90203.40
Transylvania, North Carolina
Dear Mr. Westall:
F COPY
We are working with the Town of Rosman to expand their existing wastewater
treatment plant capacity to 0.25 MGD. The existing treatment plant has a
capacity of 0.09 MGD. The effluent is discharged into the French Broad River,
south of Rosman, as shown in the attached figure. The facility operates under
the NPDES permit number NC0021946.
We are requesting a preliminary waste -load allocation, effluent limitations and
monitoring requirements for the expansion so that we may complete the
alternatives analysis for this project. Currently, the wastewater is primarily
domestic in nature and is not likely to change in the future.
If you have any questions, or require additional information, do not hesitate to
call.
Sincerely,
W. K. Dickson & Company, Inc.
. / •-
,
Victor Lofquist, lP
Enclosures
cc: File, Town of Rosman

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July 20, 2001
Mr. Forest Westal!, PE
North Carolina Department of Environment
and Natural Resources
59 Woodfin Place
Asheville, North Carolina 28801
RE: Waste -Load Allocation Request
for the Town of Highlands
Wastewater Treatment Plant Expansion
WKD #00774.40
Macon, North Carolina
Dear Mr. Westall:
F1L Ccpj'
We are working with the Town of Highlands to expand their existing wastewater
treatment plant capacity to 1.5 MGD. The existing plant has a capacity of 0.5
MGD. The effluent is discharged into the Cullasaja River immediately below the
Lake Sequoyah Dam, as shown in the attached figure. The facility operates
under the NPDES permit number NC0021407.
We are requesting a preliminary waste -load allocation, effluent limitations and
monitoring requirements for the expansion so that we may complete the
alternatives analysis for th;s project. The wastewater is primarily domestic in
nature and will remain so.
If you have any questions, or require additional information, do not hesitate to
call.
Sincerely,
W. K. Dickson & Company, Inc.
r
• f r
Victor Lofquisf• PE
Enclosures
cc: File, Richard Betz, Town Administrator

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