NC0025534_Environmental Assessment_19940815

NPDES DOCUHENT SCANNING COVER SHEET
NPDES Permit:
NC0025534
Hendersonville WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
August 15, 1994
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content on the reverse side

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Nann B. Guthrie, Regional Manager
Asheville Regional Office WATER QUALITY SECTION
August 15, 1994
MEMORANDUM
EDEE 1- NI F
TO: Monica Swihart ^•
Planning Branch
1111
THROUGH: Forrest R. Westa
Water Quality Regi 4 Supervisor
II j)FROM: Paul R. White, P. E '�
Environmental Engineer
SUBJECT: Environmental Assessment
French Broad River Wastewater Treatment Plant
City of Hendersonville
NPDES Permit Number NC0025534
Henderson County
The following is in reference to your request for comments on
the Environmental Assessment for the City of Hendersonville's French
Broad River Wastewater Treatment Facility, dated April 1994. In
addition to the comments made on the June 23, 1994 staff report which
was based only on the application, the following comments are made
and information is requested to adequately evaluate the alternatives
analysis and potential environmental impacts of the project.
1. On page one, the proposed 30,000 feet of new sewer line
could be more correctly described as an interceptor rather than
an outfall.
2. Due to the fact that much of the projected tributary service
area lies outside the City, a letter from Henderson County is
needed outlining how this project will fit with their overall
plan for sewer service in the county.
3. A description of the proposed sludge disposal plan is
needed.
4. As mentioned in the staff report, the extent of the flood
plain as described conflicts with existing flood maps.
Interchange Building, 59 Woodfin Place, Asheville, N.C. 28801 Telephone [phone] FAX [phone]
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Monica Swihart
August 16, 1994
Page Two
5. Section II of the environmental assessment states that there
does not appear to be any wetlands. This conflicts with a site
visit made in conjunction with the staff report. It is not
clear whether the Corps of Engineers visited the site, or have
only been contacted.
Section V states that the sewer line route will be altered
to avoid impacts with wetlands. This insinuates that wetlands
have been delineated to the extent that it is possible to
completely avoid wetland areas by modifying the route. Again,
no mention was made of wetland delineation by the Corps of
Engineers. Clarification of the wetland status is needed.
6. Under EXISTING MUD CREEK BASIN WASTEWATER DISCHARGERS, the
report obtains information from Division miniature sub -basin
listings of dischargers. Unfortunately, this data is erroneous.
The assessment states that there are 39 discharge permits in the
Mud Creek drainage basin, 22 of which are not discharging. A
better approximation is 35 active dischargers, not including
single family residences.
7. The assessment erroneously lists NH3-N and D. O. as being
limited in the current Hendersonville permit. These two
parameters are monitored only. Also, the list of limited
parameters at 3.2 mgd omits fecal coliform, heavy metals,
cyanide, toxicity, and pH. Upon expansion to 6.0 mgd, the
permit also limits NH3-N and dissolved oxygen, as well as
reducing the BOD5 limit.
8. Flow projections include 64,000 gpd for infiltration and
inflow into future service lines. While it is recognized that
inflow and infiltration is a factor, especially in older
collection systems, it is recommended that funds be allocated to
maintain new lines rather than be allocated to additional plant
hydraulic capacity. New lines are required by regulation to be
designed to limit infiltration to 100 gpd per inch diameter per
mile of pipe. The basis for the 64,000 gpd allowance should be
included to indicate why design flows and design requirements
alone are not sufficient to project future flows. Although the
64,000 gpd is a very small percent of the total flow, its
inclusion indicates that adding hydraulic capacity is the
accepted method of handling inflow and infiltration.
9. Under Section III, reference is made to a letter advising
the City of Hendersonville of the requirement to submit plans
and specifications for increased capacity upon reaching 90% of
plant capacity to allow further sewer line extensions. This
requirement has been superseded by a change in this regulation
which bases this requirement on the flows for a calendar year
rather than on monthly flows for the previous three months. The
City was advised of this change and permit issuances for sewer
line extensions have resumed.

10. The alternatives analysis does not include a present worth
cost comparison. These figures and their basis should be
provided, especially for the connection to the Metropolitan
Sewerage District. A staged sequence of projects should be
considered, since this option would not necessarily have to
enable the ultimate flow to the existing MSD plant initially.
It is understood that a MSD plant south of Asheville might be
more advantageous than replacement of the sewer interceptors.
The feasibility of this option should be addressed as well, at
least to the extent that it has been investigated by MSD.
There has considerable information shared by the City of
Hendersonville, Henderson County, MSD, the Asheville Buncombe Water
Authority, and Buncombe County in ongoing discussions concerning a
regional approach to water and sewer needs. This environmental
Assessment for the City of Hendersonville's proposed wastewater
treatment plant expansion should include all the information
currently available so that an evaluation is made with the most up to
date information.
If you have any questions, please call.
copy = .Dana Eoiceep,

DIVISION OF ENVIRONMENTAL MANAGEMENT
Water Quality Section/Instream Assessment Unit
July 25, 1994
MEMORANDUM
TO: Monica Swihart
FROM: Betsy JohnsorK,�j
THROUGH: Steve Bevington f 8
Ruth Swanek k�
SUBJECT: Hendersonville Environmental Assessment
Hendersonville WWTP
NPDES No. NC0025534
Henderson County
The Instream Assessment Unit has reviewed the environmental assessment for the City of
Hendersonville's Waste Water Treatment Plant relocation dated April, 1994 (received July, 1994).
Section III, Need for the Project, should contain a list of facilities which will connect to the WWTP
upon its expansion.
A cost -benefit analysis of Alternative 3, relocation to the French Broad River vs. Alternative 4, tie -
on to Asheville's Buncombe MSD is needed. The EA includes limited cost estimates for tie -on
but no cost comparison. Over the long run what are the costs and benefits of each particularly
with respect to future expansions and water supply needs for Henderson and Buncombe
counties.
The March 1994 letter from the Division of Environmental Health indicates that the ultimate
source of drinking water for Buncombe County is the French Broad River at or above Brevard
Road. The letter also indicates that Hendersonville is interested in an intake in this area also.
The April 1994 memo from EHD indicates that the proposed discharge is of concern to the
proposed water intake site. These documents indicate that the French Broad as a drinking water
source is likely in the future with more studies warranted rather than that the source is suspect as
indicated in #10. Water Supplies on page 33.
On page 34, #13. Toxic Substances indicates that no toxic substances will be accepted at the
proposed WWTP. However, earlier in the EA, it is stated that General Electric's wastewater will
be accepted. Please clarify.
Of particular concern to Instream Assessment is that this EA does not address water quality
impacts. An effort should be made to characterize existing water quality conditions and evaluate
future impact. Ambient and facility self -monitoring data as well as citizen monitoring data are
available for review.
Thank you for this opportunity to review and comment. If you have questions or concerns,
please call.
cc: Don Safrit, Asst. Chief TSB
Dave Goodrich, P&E
Asheville Regional Office