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HomeMy WebLinkAboutNC0021547_Environmental Assessment_19910814NPDES DOCUHENT !iCANNIN` COVER !SHEET NC0021547 Franklin WWTP NPDES Permit: Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) Speculative Limits Instream Assessment (67b) Environmental Assessment (EA) Permit History Document Date: August 14, 1991 This document is printed on reuse paper - ignore any content on the reYerne side State of North Carolina Department of Environment, Health, and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27604 James G. Martin, Governor William W. Cobey, Jr., Secretary August 10, 1991 Mr. Terry G. Painter McGill Associates 206 Depot Street - Suite B Waynesville, NC 28786 Dear Mr. Painter: RF(RRF.111FD AUG 1 5 1991 _ BRANCH George T. Everett, Ph.D. Director This is in response to the submittal of a draft environmental assessment from McGill Associates for theTown of Franklin's proposed wastewater treatment plant expansion. The subject EA has been reviewed by the Department of Environment, Health and Natural Resources (EHNR) and comments are enclosed. It is requested that you review and respond to the enclosed comments in both a letter of response to me and through appropriate revisions in the EA as noted below. 1. Wildlife Resources Commission The Commission had three comments having to do with the description of the plant size and making sure that sediment and erosion control measures are effectively implemented. In response to the plant size comment, the size of the plant expansion should be put on the front page of the EA in the "Need for Project" section (I had read through five pages of the document before finding the figure). Your cover letter should provide assurances that sediment and erosion control will be appropriately addressed as required by the Division of Land Resources. 2. Division of Land Resources In light of Land Resources comment and Wildlife's, it is recommended that the language in section a.3) on page 8 of the EA be strengthened. As a minimum, it is recommended that it be revised to read "Design, implement and enforce an a State -approved erosion control plan." Please also respond to Asheville 704/251-6208 Fayetteville 919/486-1541 Mooresville 704/663-1699 Regional Offices Raleigh Washington 919/733-2314 919/946-6481 .Wilmington Winston-Salem 919/395-3900 919/761-2351 Pollution Prevention Pays P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer Terry J. Painter August 14, 1991 Page 2 the item checked off on the Land Resources project review sheet concerning high quality waters (the Little Tennessee between the Cullesaja and the Nantahala Rivers is classified as C Waters and not HQW). 3. Division of Water Resources Please answer the comments made by Mr. Sutherland. 4. DEM - Technical Support Branch (Rapid Assessment Group) Please make the revisions necessary in the EA to address this group's specific comments outlined in their memo dated July 29, 1991. Once the response letter and EA revisions have been made, please submit the letter and twelve copies of the revised EA to me for State Clearinghouse Review. I will prepare the Finding of No Significant Impact (FONSI) and handle submission to the Clearinghouse. Feel free to call me if you have any questions. Sincerely, Alan R. Clark Environmental Review Coordinator Enclosure: EHNR Comments FrankEA.Ltr/SEPA4 cc: Trevor Clements Don Safrit Melba McGee Forrest Westall North Carolina Division of Environmental Management Water Quality Section/Rapid Assessment Group July 29, 1991 MEMORANDUM To: Alan Clark Through: Ruth Swanek From: Dave, o 0 9 'eh V1 Subject: Review of Draft Environmental Assessment for the Town of Franklin WWTP NPDES #NC0021547 Macon County o'1oy'o I The environmental assessment for the proposed expansion of the Town of Franklin WWTP was reviewed by this office. Overall, the improvements in the treatment process should provide increased water quality. However, some concerns associated with water quality should be addressed in the final environmental assessment: 1) Eutrophication in the Little Tennessee River should be minimal as mentioned in the draft report. However, Lake Emory (located immediately downstream of the discharge) is considered a "significant" lake by NCDEM and results from samples collected in 1988 indicate it is eutrophic with elevated levels of phosphorus, nitrogen, chlorophyll -a, and solids. Although the cause(s) of these high concentrations are unknown, an increase in monitoring for nutrients would be warranted to determine the contribution from this WWTP. 2) Industrial wastestreams - including landfill leachate - are not well defined. A more detailed description of the types and amounts of industrial waste should be included in the final report. 3)_Although_the report_ mentions_dechlorination will occur, details are not_ iven. A brief explanation of the method chosen to dechlorinate should be provided in the final assessment. 4) During construction, erosion control measures should be taken to ensure the turbidity levels in the Little Tennessee River are kept below 25 NTU. This is especially important given the documented water quality problems in Lake Emory. cc: Central Files State of North Carolina Department of Environment, Health, and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27604 J G. Martin, Governor James July 16, 1 91 William W. Cobey, Jr., Secretary George T. Everett, Ph.D. Director 24,4111,, RECEIVED MEMORANDUM JUL 1 8 1991 TO: Melba McGee ,niviCRL SUPPORT BRANCH FROM: Alan Clark SUBJECT: Draft EA for Proposed Wastewater Treatment Plant Expansion in the Town of Franklin, Macon County The Town of Franklin proposes to expand its wastewater treatment plant from an existing capacity of 0.75 million gallons per day (MGD) to 1.65 MGD. Enclosed are ten copies of an environmental assessment for that proposed expansion. Please circulate the EAs to the appropriate agencies and provide me with their comments. Let me know if you need any additional information. Enclosures Franklin.Mem/SEPA4 cc: Terry Painter, McGill Associates Don Safrit Trevor Clements Forrest Westall Regional Offices Asheville Fayetteville Mooresville Raleigh Washington Wilmington Winston-Salem 704/251-6208 919/486-1541 704/663-1699 919/733-2314 919/946-6481 919/395-3900 919/761-2351 Pollution Prevention Pays P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer TOWN OF FRANKLIN, NORTH CAROLINA WASTEWATER TREATMENT PLANT EXPANSION ENVIRONMENTAL ASSESSMENT 1. Existing Environment. All construction activity related to the expansion of the Town of Franklin's Wastewater Treatment Plant will occur on property owned by the Town of Franklin. This property contains the existing 0.75 MGD wastewater treatment facility. The following maps show the general location of the existing wastewater treatment facility, existing plant location on the property and the expansion location in reference to the existing facility as well as the existing property. The topography of the site slopes moderately southeast to northwest, toward the Little Tennessee River. The average slope over the site is between two and three percent. Since this is an expansion to an existing plant, the land use in the immediate vicinity of the plant will not be affected. The land surrounding the plant is either wooded, used for agricultural purposes or is in the process of construction for the new Macon County landfill. The soil conditions have been altered by the grading operation for the construction of the existing plant and can be classified as Udorthents. The existing area is either grassed or is covered by stone paving. Any detrimental impact on surface water quality during construction should be eliminated due to the fact that all construction activity, with the exception ofthe 24-inch effluent line, will take place a minimum of 100feet from the Little Tennessee River. Within this 100-foot wide area there exists the present wastewater treatment plant as well as a minimum of a 40-foot wide vegetated buffer zone. No construction work will occur in wetland areas or within the 100-year flood elevation, with the exception of the 24-inch effluent line. No problem is expected with groundwater due to the fact that during soil boring operations at the site no groundwater was encountered as deep as 25 feet. 2. Need for the Proiect. The existing plant has a NPDES permit for 0.75 MGD. Maximum day flows are now and have in the past, periodically, exceeded this limit. In recognition of this, the Town of Franklin retained the services of McGill Associates, P.A. to perform a Preliminary Engineering Report to project the wastewater treatment plant design flow through the year 2010. The current facility presently treats wastewater that is produced by the existing sewer service area that generally covers the Town and some adjacent areas that are currently outside the Town limits. Population growth over the past 30 years as well as projected population growth to the year 2010 were acquired from the N.C. Office of Budget and Management and have been utilized asthe basis for predicting future wastewater flows. The figures are listed in TABLE - 1. 1 , - ... ..-,..., • '.Fi"› ) i 0‘.- ••••;% --..- \ /)‘\ • .. ...„..s,.,?„.• ,..\,..,,,-..,,,„:„Tis - _. •. p., .......,.4).. ,,.,.a.„......,..,,, ‘,„..,,,,...,,,.,,,,:........ )..,;„. •„, ... ik k 1.. i vl1" I •e, , \•„...„ . . ,.,...4 ...r, /--:st:.4...,-_;: ....::..... 11 i: hiilf :.- ,„..., ., ii • %., ,..i ..,....- . I : 1 r 4"se • kc.:•••;\ " • • t . • - \ \• • t t t: j*:./ • •••%!(II ntlis SInaeta • Chapel • . • ** „ • • :I.\ 01. • • e: 1 • 1 -2) ... ••••••.‘iv--.11), 1),--/ ... L./ ......,......., ,.: 1 • . • Y *. • '.„ . . :. ;...' i " 4 .. ‘ .... i • . c : l -,A - t A. ..". , . ..\ , (i I , • ... .1, \ i ./.", I % . .• • • :.\ ' • 1 i , •••1 • •.‚ .0'. 4. cul•o'' • r• ;,),, ... .•. , • ..! ., .. t Jk ..-- ..,..., „ J / .. ; ,-.. . ' , Gr.v. Ch ...,... ,.•-....A. .... 4. , • . 1 , • . •• •I• s • 1 ( . ..._ • . '• 1 . -a 'i 0% , •••• !I %. . i - • 1 I. 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(. .. . i t..4 .1 IP • ' . :::••••• • li. • % / LOCATION MAP TOWN OF FRANKLIN MACON COUNTY, NORTH CAROLINA HOUSE W N N Z Z W 1— I2' EFFLUENT i PUBLIC' WORKS MAINTENANCE BUILDING 6' WAT ER LINE WET WELL) TREATMENT PLANT (AERATION, SEDIMENTATION) -—.................... --"44F_--- ............. Q'BYPASS--...ss- _J EXISTING FENCE and PROPERTY LINE 6'wATER LINE ACCESS ROAD 1O-FORCE MAIN EXISTING TREATM TOWN OF MA' NOT EXISTING FENCE and PROPERTY LINE ABANDONED WELL J+ousE• ------------- PROPOSED OUTFALL SLUDGE IV EFFLUENT TO B_F I -�----- AlANDONETy' -- -- - - a'BYPAss _-I ► -� `--,___`� - _ ..---- ► ACLESS RCJ:.D 10'fCRCE ►a-,N PUBLIC WORKS MAINTENANCE BUILDING TO REMAIN NEW DRIVEWAY CONTROL ROOM .ref 1`_ DRAIN LINE SLUDGE PUMP STATION CLARIFIER r-1t AERATION BASIN AERATION BASIN ETURN • CHAMBER GRIT SLUDGE•• / •• i / wilt!- 10 SEPERATOR fD-_� 31-3 WET WELL IN TREATMENT PLANT FUTURE AEROBIC DIGESTER AND SLUDGE HOLDING BASIN 0i2 COMMINJTOR ABANDON ► BYPASS ABANDON CHLORINE CONTACT BASIN YARD HYDRANT MANHOLE(TYPICAL) 2'WATER UNE EXISTING FENCE and PROPERTY LINE YARD HYDRANT BAR SCREEN 2'WATER LINE 6-WATER LINE L PI E) PROPOSED TREATME TOWN OF MAY NOT T( TABLE - 1 MACON COUNTY POPULATION DATA YEAR ::•::::.:... ULA7:(ON i:GRQWTiffPERIQQ:i 1960 14,935 -- 1970 15,788 5.7 1980 20,178 27.0 1990 25,283 20.3 2000 27,944 15.1 2010 31,150 11.5 Source: North Carolina Office of Budget and Management In order to estimate future flows at the wastewater treatment facility, flow records for both the water treatment plant and the wastewater treatment plant along with water and sewer billing records were obtained from Town Officials. These historical records serve as the parameters for flow projections for future residential, commercial and industrial contributions. Residential, Commercial and Industrial Contributions Historical records show the following average daily flows: Residential 55.2% / (100) x 0.574 MGD = 0.317 MGD Com mercial 33.0% / (100) x 0.574 MGD = 0.189 MGD Industrial 11.8% / (100) x 0.574 MGD = 0.068 MGD Sincethe Town of Franklin provides water and sewer service to areas outside the Town limits, it was not possible to use Town population data to derive residential per capita flow. The February 1990 water bill was examined to determine the number of residential customers. The examination revealed that there are approximately 1,938 residential water customers. Based on an average of 2.5 persons per customer or household, the total number of people using Town water can be determined as follows: 1,938 Residential Customers x 2.5 Persons/Customer = 4,845 Residents The residential per capita water demand can then be derived as follows: 317,000 gpd / 4,845 residents = 65.4 gallons per person per day. 2 This number was considered reasonable since it compares favorably with other similar sized towns in the southeast. For the purposes of this assessment, 75 gpcd will be used for projecting future flows since it has been historically shown that per capita water usage is increasing. Although population projections have been estimated for both the Town and Macon County, there are no published projections for the number of residents that will require sewer service in the year 2010. In order to estimate the number of services that may be anticipated, the future service area was analyzed. EXHIBIT A illustrates the existing sewer service area and the projected sewer service area for the year 2010. Thetotal additional sewered service area for the year 2010 was estimated to be 10,100 acres. The approximate area that is sewered at present is estimated to be 2,170 acres. For the additional sewered area, it is anticipated that the population in this area in the year 2010 will be only one-half as dense as the present sewered area. The total "effective" additional sewered area can be considered to be 5,050 acres (one-half of the total additional area). If the same population density is then used for the additional "effective" area as exists for the Town, the resulting sewered population can be derived. It was also assumed that the entire Town population would be sewered in the year 2010. "Effective" Additional Sewered Area = 5,050 acres Town Sewered Area = 2,170 acres 1990 Sewer Population = 4,845 PROJECTED ADDITIONAL SEWERED Residents: 5,050 Acres / 2,170 Acres x 4,845 Residents = 11,275 Residents Total Projected Sewered Population in Year 2010 = 16,120 (11,275 + 4,845) Once the total sewered population was determined for the year 2010, the projected residential flow could then be determined. Average Daily Residential Flow (2010) 16,120 Residents x 75 gallons / resident -day x 0.90 (return flow factor) = 1,088,100 gallons per day. Known published values for return flow normally range from 70-90 percent. For the purpose of this assessment, 90 percent of the water consumption will be assumed to be returned to the sewage collection system. Conversations with Town and Macon County officials indicate there are no known "wet" industries that will move to the area and require sewer service. There are two (2) planned hotels for the area with 60 and 120 rooms respectively. The flow for these two hotels was computed as follows: 180 Rooms x 2 Persons Per Room x 50 Gallons per -Person -per -Day = 18,000 Gallons Per Day. (1:.;• ,- .. ....W:t .1. •• (,),.,: . . \cy • .• ' : ., 4. tea" r . .� .1.7.f..... -:-,_! ci • . r H tk\\,1/4\ �►+� Vt1\44 • • Obi 1\\\‘-‘40%,,, �r NN‘lekTk77 Att10.%.".. 7'4'4,;c ' <111. • 1/4%\\::: va.‘„‘•••*1‘,1\\ ;t4SN4 .\141t\.\ k / • IA IN. • 01 (,In 4. .M {.n� Vt/k },�a� t• tI l.t •� %'L` 7i if 1. '•+�\ ''' t.•t :.'i i •,. -; .^.i niter; " 'S • -'•�'. •i\ (1i7'V(.,\;r:' ;(\• i{ �;\1 ,:: .. .(1\Lliff:.:il::‘•-:::'...j.?.......:ff.);: ...;;.;--.:..'..'.1.(17.-1(1.i..i:'.:Iki_ti: , Ti.i.„. •-J (); u►� :��wa•ry!� RZ%'11?T/i.� SG, 8�•NE:tA •�.il�� "'�^�/'•. In order to calculate the commercial and industrial flows for the year 2010 a growth rate had to be established. As shown in Table - 1, the population for Macon County in the year 2010 is projected to be 31,350. This is approximately a 28% increase over the 1990 population. Although future commercial and industrial customers will be added as a result of increased service area, a smaller percentage increase was deemed appropriate. Without any firm future plans for commercial and industrial expansion (except for the two (2) hotels) an increase of 20% was used for commercial while 15% was used for industrial growth between the years 1990 and 2010. I nfiltration/Inflow Contribution The I & I was calculated from the same historical Town records that were utilized in obtaining current and future residential, commercial and industrial contributions. The Town currently is pursuing a sewer system rehabilitation program. It is uncertain at this time just how much reduction will be realized as a result of this program. For the purposes of this assessment, the I & I from the existing sewer service area will be assumed to remain. This is reasonable when one considers that although some corrections will be made to reduce leakage into the system, new leaks may develop due to the increasing age of the system. In order to properly project design flows for presently undeveloped areas and developed areas presently not sewered, design parameters must be established. Infiltration and inflow values found in older sewered areas were not considered appropriate for the areas yet unsewered. Much of the gravity sewer pipe used in the older areas is vitrified clay with bell and spigot mortared joints. As has been shown through recent years, PVC pipe with the rubber gasket push -on joints is better suited for use in sewage collection systems. Because of the Town's standards for construction of new gravity collection systems which Include the use of PVC pipe and inspection of same during construction, the amount of I & I should be kept within reasonable limits. For projecting 1 & I for the new service area in the year 2010, it was assumed that there would be approximately 40 linear feet of sewer line per customer. The approximate sewered population in the year 2010 is 16,120 residents. It is estimated that 4,845 residents will be serviced by the old system in the year 2010. Therefore, 11,275 residents will be serviced by the new system. It was assumed that there would be an average of 2.5 persons per household. Then the total of "new customers" or households could be determined. New Customers = 11,275 Residents / 2.5 Residents Per Household = 4,510 Households New Sewer Line = 4,510 Customers x 40 Linear Feet / Customer = 180,400 Linear Feet = 34.2 Miles Future I & I = 34.2 Miles x 175 GPD / Inch -Mile x 8-inches = 48,000 Gallons Per Day 4 Ct, 1*D°Ii‘r;').° \'°4 t/ As was discussed earlier, the Town of Franklin has agreed to collect and treat the leachate from the new Macon County landfill. Flow estimates furnished by Macon County presently indicate a maximum daily flow of approximately 50,000 gpd. It has been agreed that flow discharged to the wastewater treatment plant would be on a constant basis with the use of a lagoon for flow equalization at the landfill site. Table - 2 tabulates all contributions from residential, commercial, industrial, I & I and landfill flow. TABLE - 2 WASTEWATER TREATMENT PLANT 2010 DESIGN FLOW TOWN OF FRANKLIN SOURCE FLOW AVERAGE. DAILY FLOW:. (GPD) Residential 1,088,100 Commercial 226,800 Industrial 78,200 Existing Infiltration/Inflow 159 ,000 Future I & I 48,000 Landfill 50,000 TOTALS 1,650,100 As Table - 2 shows and has been previously stated the existing 0.75 MGD will soon be overloaded. 3. Alternative Analysis The only alternative is one of no action. This alternative is unacceptable due to the fact that the present day demands on the plant are periodically exceeding the design capacity. Also, several areas within close proximity of existing sewer infrastructure as well as future annexation areas are experiencing failure of septic tank systems and are requesting the Town provide sewer service. 4. Effluent Requirements Effluent requirements that are set for the existing plant will remain the same for the expansion. This is based on a letter received from DEHNR that was in response to a request for information in anticipation of compiling this environmental assessment. EXHIBIT B presents the existing requirements. In addition to these requirements, with the planned expansion the plant will be 5 Permit No. EXHIBIT B A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - FINAL Part I Page — of _ NC 0021547 During the period beginning on the effective of the permit and lasting unti expiration, the permittee is authorized to discharge from outfall(s) serial number(s 001. Such discharges shall be limited and monitored by the permittee as specifie. below: Effluent Characteristics Discharoe Limitations Monitoring Requirements Kb/day (Ibslday) Other Units (Specify) Measurement Sample * Sampl Monthly Avg. Weekly Avg. Monthly Avg. sleekly Avq, Frequency Type Locatio Flow SOD,5Day, 20°C " Total Suspended Residue °! NH3 as N 0.75 MGD 30.0 mgll 30.0 mgll 45.0 mgll 45.0 ngll Continuous Recording I or E 2/Month Composite E,I 2/Month Composite E,1 Monthly Composite E Temperature Weekly Grab E Total Nitrogen (NO2+ NO3 + TKN) Semi -Annually Composite E Total Phosphorus Semi -Annually Composite E * Sample Locations: E — Effluent, I — Influent ** The Monthly average effluent BOD, 5Day, 2O°C and Total Suspended Residue concentrations sha not exceed 15% of the respective influent values (85% removal). The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall b monitored 2/Month at the effluent by grab sample: There shall be no discharge of floating solids or visible foam in other than trace amounts. considered a major facility, i.e., wastewater flow greater than 1.0 MGD and thus will require whole effluent testing for chronic toxicity as well as annual priority pollutant monitoring. Also, chlorination and dechlorination to a maximum concentration of 0.028 mg/I will be required. Presently chlorination and hence dechlorination is not required. 5. Sludge Disposal Stabilized and dewatered sludge is presently disposed in the Macon County solid waste landfill. In the future, it is anticipated that sludge will continue to be disposed in the landfill. The sludge treatment process includes aerobic digestion of liquid waste activated sludge. Diffused air is utilized in the digester to provide oxygen for biological activity and to provide mixing to keep solids in suspension. Stabilized sludge from the digester is dewatered on a belt press and the resultant dewatered sludge is disposed in the landfill. 6. Environmental Consequences The preferred alternative for this project is to expand the existing plant at the existing site, utilizing similar treatment process technology. The following impacts have been considered: (a) Changes in Land Use There are development projects in progress as well as planned in areas that are anticipated for annexation. Also, several hotel/motel projects which will be within the existing service area are in the planning stages. (b) Wetlands All construction for this project will occur at upland areas at least 100 feet from the Little Tennessee River and will not affect any existing wetlands. (c) Prime Agricultural Land The improvements to the existing treatment plant will be made on land owned by the Town and adjacent to the existing facility. Therefore, the impact this addition will have on prime, unique or statewide important farmlands would be minimal to none. (d) Public Lands No public land will be affected since all construction will be confined to the existing site. The existing site is owned by the Town of Franklin. (e) Scenic & Recreational Areas The existing plant is slightly visible from the Little Tennessee River and the expansion will have the same visibility. (f) Areas of Archeological or Historic Value The North Carolina Department of Cultural Resources are aware of no properties of architectural, historic or archaeological significance which would be affected by this project. (g) Air Quality The treatment process presently used and to be used in the future expansion is completely aerobic. There will be a very small odor potential associated with the liquid treatment process. 6 (h) Groundwater Quality Groundwater quality will not be affected. All process basins are fully contained. Overall groundwater will improve due to the fact that future annexation areas that currently are experiencing septic system problems and/or failures will be served by the Town sewer system. (i) Noise Levels Noise levels will increase slightly due to aerators in the new aeration basins, however, no private property will be affected due to the Macon County Landfill being on adjacent property and encompassing the project property. (j) Water Supplies No water intakes for water supplies occur downstream in Macon County. (i) Fish According to the records of the U.S. Department of the Interior, Fish and Wildlife Service, there are no federally listed or proposed endangered or threatened species within the immediate impact area of the proposed project. Additionally, a letter from Brian Cole of the U.S. Department of the Interior, Fish and Wildlife Service states that two listed species do occur in the Little Tennessee River (the spotfin Chub and little -wing pearly mussel), the proposed treatment process and the buffer formed by Lake Emory make it unlikely that there would be any significant downstream effects. (I) Wildlife Habitats There will be minimal to no impact on wildlife and their habitats because the land use is not changing. (m) Plant Species No plant species will be affected due tothe fact that the expansion will take place completely within the existing wastewater treatment plant property which has been graded previously. (n) Forest Resources Forest resources will not be affected due to the fact that expansion will take place completely within the existing wastewater treatment plant property which has been graded previously. (o) Toxic Substances The only chemicals that will be in contact with the environment are chlorine and sulphur dioxide. Chlorine is used as a disinfecting agent and sulphur dioxide is used as a dechlorinating agent. Both chlorine and sulphur dioxide will be controlled as well as monitored by testing. (p) Eutrophication of Receiving Waters With low BOD effluent requirements and no apparent existing problems with dissolved oxygen, eutrophication of the Little Tennessee River will not be an impact of this project. Monitoring of NH3 as N, Total Nitrogen, and Total Phosphorus will continue to detect these nutrients. Eutrophication in the river such as the Little Tennessee is also limited by factors such as, limited sunlight penetration due to relatively high turbidity levels and constant mixing in the river. 7. Water Quality Development around the Little Tennessee River will grow due to this expansion and will increase nonpoint source pollution to a small degree. However, the benefit of eliminating faulty septic tank systems will offset the negative impacts of development. 8. Adverse Impacts and Mitigative Measures Construction of the proposed expansion will cause some minor adverse environmental impacts that can be mitigated through appropriate control measures, careful design and sound construction practices. Adverse impacts include: 7 a. During Construction Activity 1) Resources are consumed, including money, energy, land and construction materials. Mitigation: Public receives useful facility. 2) Air pollution occurs from windblown dust and engine exhaust. Mitigation: Enforce dust control measures during construction. 3) Soil erosion occurs. Mitigation: Design, implement and enforce an erosion control plan. b. Long -Term Impacts 1) In addition to those impacts normally associated with discharge of treated wastewater effluent, long-term impacts will consist of the continued and increasing expenditure of labor, chemicals and energy for operation and maintenance of the treatment facilities. Mitigation: Water quality of the Little Tennessee River and local groundwater is maintained. 2) Land use changesfrom agricultural to urban result in changes of nonpoint pollution loading pattern. Mitigation: Enforce zoning regulations and existing limitations of construction inside 100 year floodplain. Reduction of adverse impacts will be achieved by careful consideration during the design phase and enforcement of sound construction practices. All local, State and Federal regulations relating to environmental protection will be utilized in both the design and construction phases. 9. Secondary Impacts Current ongoing development as well as future development are the main reasons behind this project. This facility is an investment by the Town of Franklin to insure that any environmental impact will be held to a minimum. Secondary impacts will be held to a minimum by enforcement of federal, state and local ordinances for zoning, storm runoff, flood plain, erosion and sedimentation. The following summarized the secondary impacts and mitigation measures associated with the project. Secondary Impact Adverse Effect Mitigation Measure 1) None development Greater automobile emission load 2) Groundwater quality Enforce automobile emission standards if necessary Improvement likely Replace septic systems with sewer 3) Surface water quality Increased nonpoint runoff possible Enforce existing zoning and development ordinances References McGill Associates, P.A., "Preliminary Engineering Report", 1990. North Carolina Office of Budget and Management, "Population Records and Projected Population Growth" 1990. v United States Department of the Interior FISH AND WILDLIFE SERVICE ASHEVILLE FIELD OFFICE 100 OTIS STREET, ROOM 224 ASHEVILLE, NORTH CAROLINA 28801 June 26, 1991 Mr. Terry J. Painter, E.I.T. McGill Associates, P.A. Consulting Engineers 206 Depot Street, Suite B Waynesville, North Carolina 28786 Dear Mr. Painter: ■ T� ■ mainland= 11111111.11.11.1101 OM ■ o ■ RECEIVED JUN 2 7 1991 McGILL ASSOC., P.A. Subject: Preparation of environmental assessment for the proposed wastewater treatment plant improvementsfor the Town of Franklin, Macon County, North Carolina This responds to your letter of May 24, 1991 (received May 28, 1991), requesting our comments on the subject proposal. These comments are provided 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). The U.S.. Fish and Wildlife Service is particularly concerned about the potential impacts the proposed action may have on stream and wetland ecosystems within the project impact area. Preference should be given to alternative alignments, stream -crossing structures, and construction techniques that avoid and/or minimize encroachment and impacts to these resources. The Service's review of your environmental assessment on the subject project would be greatly enhanced if the document contained the following information: (1) A complete analysis and comparison of all available alternatives, including the no -action alternative. (2) A description of the fishery and wildlife resources within the project area that may be affected directly or indirectly by the proposed improvements. (3) Acreage and description of branches, creeks, streams, rivers, or wetlands that will be filled because of the proposed project. Wetlands affected by the proposed project should be mapped in accordance with the Federal Manual for Identifying and Delineating Jurisdictional Wetlands. (4) Linear feet of any water courses that will be relocated because of the proposed project. (5) Acreage of upland habitats, by cover type, that will be eliminated because of the proposed project. (6) Techniques that will be employed for designing and constructing any relocated stream channels or for creating replacement wetlands. (7) Description of all expected secondary and cumulative environmental impacts associated with this proposed work. (8) Mitigation measures that will be employed to avoid, eliminate, reduce, or compensate for habitat value losses associated with any of the proposed improvements. Based on our records there are no federally listed or proposed endangered or threatened species within the immediate impact area of the proposed action. Additionally, while two listed species do. occur in the Little Tennessee River (the spotfin chub and little -wing pearly mussel), the proposed treatment process and the buffer formed by Lake Emory make it unlikely that there would be any significant downstream effects. We appreciate the opportunity to provide these comments and request that you continue to keep us informed on the progress of this project. In any future correspondence concerning this project, please reference our log number 4-2-91-065. Sincerely, Brian P. Cole Field Supervisor cc: Program Manager, Division of Boating and Inland Fisheries, North Carolina Wildlife Resources Commission, 512 N. Salisbury Street, Raleigh, NC 27604-1188 Mr. Randall C. Wilson, Nongame Section Manager, Division of Wildlife Management, North Carolina Wildlife Resources Commission, 512 N. Salisbury Street, Raleigh, NC 27604-1188 Director, North Carolina Natural Heritage Program, P.O. Box 27687, Raleigh, NC 27611 Mr. Cecil Frost, North Carolina Department of Agriculture, Plant Conservation Program, P.O. Box 27647, Raleigh, NC 27611 Mr. Lee Pelage, Wetlands Regulatory Unit, Environmental Protection Agency, 345 Courtland Street, NE., Atlanta, GA 30365 Field Supervisor, FWS, Raleigh Field Office, Raleigh, NC RECEIVED FEB 1 1 1991 McGILL ASSOC., P.A. State of North Carolina Department of Environment, Health, and Natural Resources Division of Environmental Management 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor George T. Everett, Ph.D. William W. Cobey, Jr., Secretary Director February 6, 1991 Terry J. Painter McGill Associates 206 Depot Street, Suite B Waynesville, NC 28786 Subject: Town of Franklin WWTP NPDES No. NC0021547 Macon County Dear Mr. Painter: My staff has reviewed your request for comments regarding a proposed expansion of 0.9 MGD to the Franklin WWTP for a total flow of 1.65 MGD. Since your proposed expansion is greater than 0.5 MGD, an Environmental Assessment will be necessary. Please contact Mr. Alan Clark of the Water Quality Planning Branch at (919) 733-5083 for more information. The Division is initiating a basinwide management strategy for the state. All NPDES permits within a given basin will be renewed in the same year allowing the Division to examine interaction among all point and non -point sources of pollutants for that basin. The basin plan for the Little Tennessee River should be promulgated by 1997 and a draft version will hopefully be available to the public sometime in 1996. In the meantime, discharge limits will be based on existing procedures. Due to the dilution ratio of 62:1, the Town of Franklin's existing secondary limits for BOD5 and NH3-N should be sufficient to protect water quality. As a major facility, i.e., wasteflow greater than 1.0 MGD, quarterly whole effluent testing for chronic toxicity as well as annual priority pollutant monitoring will be required. The instream waste concentration (IWC) for the toxicity test will be 1.6%. In addition, dechlorination to 0.028 mg/1 or alternate disinfection will be required upon expansion. Metals limits and/or monitoring requirements will be determined based on the nature of the effluent. The above limits are speculative and are for use in an engineering review of discharge alternatives. Pollution Prevention Pays I'.O. Box 27687. Raleigh, North Carolina 2761 1.7687 Telephone 919.733.7015 An Equal Opp'rlunity Affirmative Action Employer -2- Final limits will be provided upon receipt of an application for permit modification. If you have any questions regarding the above issues, please contact Betsy Johnson or myself at (919) 733-5083. Sincerely, revor Clements s ;istant Chief, Water Quality Section JTC/eaj cc: Alan Clark Don Safrit Forrest Westall Central Files Pollution Prevention Pays P.U. Box 27687, Raleigh, North Carolina 2761 I -7687 Telephone 919-733-7015 An Equal Opportunity Affirmative Action Employer r State of North Carolina Department of Environment, Health, and Natural Resources Division of Soil and Water Conservation 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor David W. Sides William W. Cobey, Jr., Secretary Director January 25, 1991 MEMORANDUM TO: Terry J. Painter FROM: Larry T. Sink/r'S SUBJECT: Comments on Proposed Wastewater Treatment Plant Improvements - Town of Franklin, N. C. The improvements to the existing treatment plant will be made on land that is owned by the town and adjacent to the existing facility. Therefore, the impact this addition will have on prime, unique or statewide important farmlands would be none to minimal. Your letter also stated that this area had been graded or disturbed in the past. This would indicate that the natural soils conditions have been altered to some extent and the soils may now be classified as Udorthents. I am not sure of the actual size of this improvement site, but the possibility of wetland areas may exist due to this area being close to the river. An on -site evaluation should be made to determine any wetland areas that may exist. If there are wetlands, then the impact on these areas should be held to a minimum or no disturbance at all. If you need more soils information, please contact the Macon County Soil and Water Conservation District office. LTS/tl RECEIVED JAN 2 8 1991 McGILL ASSOC., P.A. I'( ). Box ?7(>.S7, ILtic'i� h. N� �rth Carl ilin,t ? 7 (iI t 7nt;7 .Icic•phi Stu• '1N) 7 i 1 2 302 :1n I clu,tl (>hlk)rtutnty I\fhritt,uive ,\cowl E mph .vcr North Carolina Department of Cultural Resources James G. Martin, Governor Division of Archives and History Patric Dorsey, Secretary William S. Price, jr., Director January 24, 1991 Terry J. Painter McGill Associates, P.A. 206 Depot Street, Suite B Waynesville, N.C. 28786 Re: Wastewater Treatment Plant Improvements, Franklin, Macon County, ER 91-7695 Dear Mr. Painter: Thank you for your letter of January 3, 1991, concerning the above project. We have conducted a review of the project and are aware of no properties of architectural, historic, or archaeological significance which would be affected by the project. Therefore, we have no comment on the project as currently proposed. The above comments are made pursuant to Section 106 of the National Historic Preservation Act of 1966 and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106, codified at 36 CFR Part 800. Thank you for your cooperation and consideration. If you have questions concerning the above comment, please contact Ms. Renee Gledhill -Earley, environmental review coordinator, at 919/733-4763. Sincerely, David Brook Deputy State Historic Preservation Officer DB:slw RECEIVED JAN 2 8 1991 McGILL ASSOC., P.A. 109 East Jones Street • Raleigh, North Carolina 27601-2807 RECEIVED JAN 3 1 1991 GILL ASSOC., P.A. North Carolina Wildlife Resources Commission 512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733-3391 Charles R. Fullwood, Executive Director January 25, 1991 Mr. Terry Painter McGill Associates, P.A. 206 Depot Street, Suite B Waynesville, N. C. 28786 Dear Mr. Painter: This correspondence responds to your letter of January 3, 1991 requesting our concerns and comments regarding preparation of an Environmental Assessment for the Proposed Wastewater Treatment Plant Improvements -.Town of Franklin, in Macon County. Due to priority projects with statutory comment deadlines, we regret that we were unable to respond sooner. Because we do not have enough staff biologists, we developed this standardized response to inquiries such as yours. Although some of the information requests and comments may not be applicable to your project, I am confident that you will find sufficient guidance for preparation of fisheries and wildlife impact assessments in the environmental document. To provide a meaningful review of proposed project impacts on fisheries and wildlife resources, the North Carolina Wildlife Resources Commission (NCWRC) requests that consultants, project sponsors, or permit applicants provide the following information: 1. A description of fishery and wildlife resources within the project area. Also, a listing of federally or state designated threatened, endangered, or special concern species should be included. A listing of designated plant species can be developed through consultation with Mr. Chuck Roe of the Natural Heritage Program, N.C. Mr. Terry Painter Page 2 January 25, 1991 Division of Parks and Recreation, P.O. Box 27687, Raleigh, N.C. 27611, (919) 733-7795 and Cecil C. Frost, Coordinator of the NCDA Plant Conservation Program, P. O. Box 27647, Raleigh, N.C. 27611, (919) 733-3610. In addition, the Wildlife Resource's Commission's Nongame and Endangered Species Section maintains databases for locations of vertebrate wildlife species. While there is no charge for the list, a service charge for computer time is involved. Additional information may be obtained from Mr. Randy Wilson, Manager, Nongame & Endangered Species Section, Division of Wildlife Management, N. C. • Wildlife Resources Commission, 512 N. Salisbury Street, Raleigh, N. C. 27604-1188, (919) 733-7291. 2. Description of any streams or wetlands affected by the project. 3. Project map identifying wetland areas. Identification of wetlands may be accomplished through coordination with the U.S. Army Corps of Engineers (COE). If the COE is not consulted, the person delineating wetlands should be identified and criteria listed. 4. Description of project activities that will occur within wetlands, such as fill or channel alteration. Acreages of wetlands impacted by alternative project designs should be listed. 5. Description of project site and non -wetland vegetative communities. 6. The extent to which the project will result in loss, degradation, or fragmentation of wildlife habitat. 7. Any measures proposed to avoid or reduce impacts of the project or to mitigate for unavoidable habitat losses. 8. A list of document preparers which shows each individual's professional background and qualifications. It is the policy of the NCWRC that impacts to wetlands be avoided. Wetlands are important to a wide variety of terrestrial, avian, and semi -aquatic wildlife species as nesting, feeding, and resting areas, as well as key travel corridors. Wetlands also act as a buffer between surface Mr. Terry Painter Page 3 January 25, 1991 waters and adjacent uplands and serve to filter sediment and other pollutants associated with runoff. Wetland and riparian areas are especially important in urban and developing areas as they often represent vestigial wildlife habitat. Non -wetland and non -riparian alternatives should be examined during project design. Where wetland losses are unavoidable, the NCWRC will recommend mitigation of the losses. To avoid wetland impacts the NCWRC recommends the following. Construction of sewage treatment plants and pump stations should be located in upland areas. Sewer lines should also be placed adjacent to upland areas. Crossings of wetlands and streams should be minimized and located at narrow areas and made perpendicular to the stream. Any disturbed wetland areas should be returned to original soils and contours. Plant communities should be re-established which would result in plant community succession into habitat of equal or greater value than that which was destroyed. For land application projects, the NCWRC is especially concerned about impacts to streams within and adjacent to the site. Sufficient buffer should be maintained between the site and surface waters. Provisions to monitor impacts to surface waters should be detailed. We are also concerned over the potential for bioaccumulation of heavy metals and toxics in animal tissue. Existing and future monitoring programs should incorporate this concern. We appreciate the opportunity to provide this information request in the early planning stages of this project. If we can be of further assistance, please let us know. Sincerely, /1( a Fred A. Harri , Chief Division of Boating and Inland Fisheries (919) 733-3633 FAH/lp cc: Micky Clemmons, District 9 Fisheries Biologist Joffery Brooks, District 9 Wildlife Biologist • DEPARTMENT OF THE ARMY WILMINGTON DISTRICT, CORPS OF ENGINEERS P.O. BOX 1890 WILMINGTON, NORTH CAROLINA 28402-1890 IN REPLY REFER TO Regulatory Branch January 16, 1991 SUBJECT: File No. CESAW-0091-0-057 McGill Associates, P.A. Terry J. Pointer 206 Depot Street, Suite B Waynesville, North Carolina Dear Mr. Pointer: 28786 Reference your January 3, proposed expansion of the Town located adjacent to Lake Emory proposal was discussed with Mr. on January 10, 1991. Upgrading of the facility is grounds with no further expansion outfall and associated riprap are with no material encroaching into permit will be required," provided manner. RECEIVED JAN 2 2 1991 McGILL ASSOC., P.A. 1991, letter requesting comments on the of Franklin Wastewater Treatment Plant in Macon County, North Carolina. The David Baker of my Asheville Regulatory staff to occur within the existing facility proposed. The new 24-inch effluent to be located outside the river channel Lake Emory. No Department of the Army that the expansion is accomplished in this We appreciate the opportunity to comment on the proposal. If you have any further questions, please contact Mr. David Baker at (704) 259-0856. Sincerely, • C1633".' ne Wrig t Chie , Regulatory Branch 1 State of North Carolina Department of Environment, Health, and Natural Resources Division of Forest Resources 512 North Salisbury Street • Raleigh, North Carolina 27611 James G. Martin, Governor William W. Cobey, Jr., Secretary Griffiths Forestry Center 2411 Garner Road Clayton, North Carolina 27520 January 8, 1991 Mr. Terry J. Painter, E.I.T. McGill Associates, P.A. 206 Depot Street, Suite B Waynesville, North Carolina 28786 RE: EA Scoping for the Proposed Wastewater. of Franklin Dear Mr. Painter: Reference is made to your letter to me above project. The comments in your forest resources will not be impacted however, woodland is involved or to be the following information: Harry F. Layman Director Treatment Plant for the Town dated January 3, 1991, concerning the letter give the impression that the as a result of the expansion. If, affected, then the EA should contain 1. The number of total woodland acres that would be taken out of timber production as a result of the expansion. 2. The acres breakdown of this woodland concerning present conditions and/or timber types such as clear-cut areas, young growing timber, and fully stocked stands of very productive timber within the project for disturbed and undisturbed portions. 3. The site indexes of the forest soils that would be involved within the proposed project, so as to be able to determine the productivity of these forest soils in the area. 4. The number of woodland acres that would affect any watersheds in the area, if the woodland was removed. I'.O. Box 27687, Raleigh, '4 tth (.rn.Iina 27011 7n87 icicph(m e 919-; 3a ?Ir,2 ECEIVED JAN 1 0 1991 McG'LL ASSOC., P.A. An Equal Opr orturnity :\Itirmativc A(.tir"n I mpl.vcr Page 2 5. The impact both present and future to any greenways within the area of the expansion. 6. If woodland is involved, it is hoped that the timber could be merchandised and sold to lessen .the need for piling and burning of debris during construction. Provisions should be indicated in the EA that the contractor will make all efforts to salvage any merchantable timber to permit construction, once the contractor takes charge of the project. 7. The provisions that the contractor will take during the construction phase to prevent erosion, sedimentation and construction damage to the remaining standing trees outside of construction limits. Trees outside of construction limits need to be protected from construction activities such as -- a. Skinning of tree trunks from heavy equipment operations. b. Exposure and injury to feeder roots from heavy equipment operations. c. Placing of fill dirt around the base of trees which would have a smothering affect which could eventually cause tree mortality. d. Accidentally spilling of petroleum products near the base of trees which could cause mortality. We would hope that the proposed project would not have any impact to the forest and related resources in the area of the expansion. Sincerely, J?(±th\ Don H. Robbins Staff Forester DHR:la pc: Warren Boyette - CO Macon County Ranger File ( A 1 NPDES WASTE LOAD ALLOCATION PERMIT NO.: NC0021547 PERMITTEE NAME: Town of Franklin / Franklin Wastewater T }R, Facility Status: Existing Permit Status: Renewal Major Minor Pipe No.: 001 Design Capacity: 0.750 MGD Domestic (% of Flow): 99.6 % 91.. 71 G Industrial (% of Flow): Comments: * Based on previous WLA, no SIU's listed on submitted application - PIRF submitted STREAM INDEX: 2-(20) o0,1 /o RECEIVING STREAM: Little Tennessee River Class: C Sub -Basin: 04-04-01 Reference USGS Quad: G5NW, Franklin (please attach) County: Macon Regional Office: Asheville Regional Office Previous Exp. Date: 7/31/91 Treatment Plant Class: III Classification changes within three miles: >15 mi. (to Nantahala River) Requested by: Jule Shanklin Date: 12/28/90 Prepared by: < < � � Date: //a S/?J Reviewed by: ,1„141.I(�i��J;T11►.�.. ate: 2' -goA 135 Modeler Date Rec. # EAS ‘24 %\ ero S1010 Drainage Area (mi2 ) a 9 °1 Avg. Streamflow (cfs): rv$� 7Q10 (cfs) 151 Winter 7Q10 (cfs) (gto 30Q2 (cfs) Toxicity Limits: IWC % Acute/Chronic Instream Monitoring: Parameters Upstream Location Downstream Location Effluent Characteristics BOD5 (mg/I) 3 Q NH3-N (mg/1) vin o vii ib2 D.O. (mg/1) tIo i .v,i -1-- TSS (mg/1) 3 0 F. Col. (/100 ml) / Wwtn�"Ca , pH (SU) tLUii L Comments: Request No.: 5980 WASTELOAD ALLOCATION APPROVAL FORM --R Vf Water Quality Section Facility Name: NPDES No.: Type of Waste: Status: Receiving Stream: Classification: Subbasin: County: Regional Office: Requestor: Date of Request: Quad: Town of Franklin NC0021547 Domestic Existing/Renewal Little Tennessee C 40401 Macon Asheville Jule Shanklin 7/31/90 G5NW WWTP River Drainage Summer Winter Average RECOMMENDED EFFLUENT LIMITS EXISTING Wasteflow (mgd) : 0.750 BOD5 (mg/1) : 30 TSS (mg/1) : 30 pH (su) : 6-9 Fecal Coliform (#/100 ml):no limit Toxicity Testing Req.: none MONITORING PARAMETERS: Fecal Coliform Upstream (Y/N): Y Location:100 Downstream (Y/N): Y Location:500 COMMENTS JA i'! Asheville Region ! Office Asheville, North Carolina area: 299 sq mi 7Q10: 157 cfs 7Q10: 186 cfs flow: 682 cfs 30Q2: cfs PROPOSED 0.750 30 30 6-9 monitor feet upstream feet downstream Facility meets existing limits; one TSS violation (53 mg/1) in 1990. Renew with existing limits. Dilution 136:1. Recommend fecal coliform monitoring. Mean: ny.fd( ST u e2A'l 11'1enu To•-.." woo(() ve yi've a 6 oa 7 . Td lr� j co%'Ja--H^ P/ellienfJ I,'l,t �1 Wvc'l) Le ffvo ,.; are . 96' 1'4 z P ,-o k ter,; Recommended by: Reviewed by Instream Assessment: Regional Supervisor: Permits & Engineering: ititLA1�. RETURN TO TECHNICAL SUPPORT BY: tiLL Date: Date: Date: Date: (Vt✓n GT r/4,11<t n (NL,)TP Ti4-J oy-oy-o/ 7Tc[ 7 r11 ec �3 CX.SF.;..14 ,.«i5 - bva TSS c i c It�f+'vh3r.)l ; / `� 7°- J 5 � / T. L.. 75 .. ,., / 3 c_= ' f c- c -- 1 (... w, , 4 el d ec-1 J .yyi OYuz egV u.s... -,`t- u 5 :/ ,[% QH'1ell O PI 0- /'.11, 75 ice%ePZ 1iracnriln P3.sc-k5 0000 Fsa PA a 9 7 ;z . 7447°5 ` / 5-7 ('Cs 7Q/0k, _ /(� (-T� EX/57-/tip c. /.n /7s F(0 7 S Mo-zD B oD5, 3 c7 +311 ?ss �oQ2 'Pi1J iT 1.0rc�.n�ct��'1 M61::+%1%'L. (.. f i LoN r'Pix pQK��G� -25- 4- . (o 5- IMGb sa-k.e...'4- r��o cst-� ---. w4-L s �.w�-t �t o �r s V 4,-,..- _ 6 a o t vio mo c\ d.¢d , e, s -\ �., — f rug8N tt -. bo E1J // /7( or-oY-vr p.k-reo -<- 1%- GLIA11._ j ,kt,LA-ci`u cx-t_ J� o Qvcd-oz- —".44—t • 7� `k lr'` � lac v `CC .16 McGILL ASSOCIATES, P.A. ioLsi CONSULTING ENGINEERS REPLY TO WAYNESVILLE OFFICE January 3, 1991 JAN091991 Mr. Trevor Clements N. C. Division of Environmental Management Water Quality Technical Support B ranch Post Office Box 27687 Raleigh, North Carolina 27611 Re: Proposed Wastewater Treatment Plant Improvements - Town of Franklin Dear Mr. Clements: This letter is in anticipation of producing an Environmental Assessment for a 0.90 MGD treatment plant expansion to the existing 0.75 MGD treatment plant. The improvements will be accomplished within the boundaries of the property already owned by the Town of Franklin, and adjacent to the existing wastewater treatment plant. The site has been graded previously during the construction of the existing plant and the expansion will utilize this area, so grading operations will be held to a minimum. I have enclosed the following maps for your use: 1) general area; 2) existing plant location, and; 3) expansion location. We would appreciate any input and/or questions your agency may have to assist us in the preparation of the Environmental Assessment. Your time and help will be greatly appreciated. If you have any questions, please feel free to contact me. Sincerely, McGILL ASSOCIATES, P.A. Ja 0 Term/ J. Painter, E.I.T. TJP:gs Enclosures 84182 206 DEPOT STREET, SUITE B WAYNESVILLE, NC 28786 704/456-4736 ASHEVILLE FAX 704/252-2518 / 38 ORANGE STREET ASHEVILLE, NC 28801 704/252-0575