NC0021849_Staff Comments_19971121

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary 1� F= F=1
A. Preston Howard, Jr., P.E., Director
November 21, 1997
MEMORANDUM
TO: Melba McGee
FROM: Michelle Suverkrubbe
RE: Comments on DEHNR #98-0314; DWQ#1 1857
Town of Hertford - Water and Sewer Improvements - NOI
Hertford, Perquimans County
The proposed project consists of several water system and wastewater collection
and treatment components designed to "expand the capacities of the facilities to meet the
needs generated by residential and commercial growth." The application for financial
assistance does not contain adequate information to determine potential environmental
impacts from the proposed utilities.
The Division has reviewed the above document and has the following comments on
the proposed project:
a. The document states that the "Town proposes to construct a 750,000 gallon per day
(i.e. 0.75 million gallons per day (mgd)) biological nutrient removal wastewater
treatment system." This statement is unclear. If this proposal is intended to expand
the existing Hertford Wastewater Treatment Plant (currently permitted to discharge 0.4
mgd) to 0.75 mgd, the Town should contact the NPDES Unit within DWQ to
determine appropriate expansion application needs, including requesting a speculative
waste load allocation analysis. Dave Goodrich is the contact for this Unit and his
number is 919-733-5083, ext. 517.
If the Town intends to construct a new treatment plant / system to either land apply or
discharge the 0.75 mgd of wastewater, this new system would require the preparation
of an Environmental Assessment (EA) under the North Carolina State Environmental
Policy Act (SEPA).
Expansion of the existing system from 0.4 to 0.75 may also require the preparation of
an EA under SEPA if it is determined that the new discharge would produce an
instrearn waste concentration of more than 33 percent during the 7-day 10-year low
flow conditions. If an EA is required for the project under SEPA, the applicant should
contact my office to determine specific guidelines for preparing an adequate SEPA
document.
b. The proposed sewer lines for the project do not meet the minimum criteria for
requiring an EA under SEPA. However, the applicant must still receive a sewer
extension permit from our Local Government Assistance Unit prior to beginning
construction. Please contact Farrell Keough at [phone], ext. 5 10 for more
information. ,
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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DEHNR 98-0314
11/21/97
Page 2
c. The project area for water and sewer improvements must be professionally delineated
for wetlands prior to any construction activities. Reliance upon National Wetland
Inventory maps is not a sufficient method to ensure valid wetland identification. The
applicant should be made aware of the necessity to follow the requirements for the
general certification for Nationwide Permit 12 - Utility Lines by the Army Corps of
Engineers when disturbing wetlands for water or sewer utility line construction
activities. Deviations from the General Certification will require a formal application
for a Section 401 Water Quality Certification from our Division. See attached
handout for more information. Please direct the applicant to John Dorney, 401/
Wetlands Unit, for further information on wetlands and 401 compliance. His number
is 919-733-1786.
The project applicant can reach me at 919-733-5083, ext. 567 if they have any
further questions.
mls:\980314 Hertford W&S
enclosed wetland handout
cc: Dave Goodrich - NPDES Unit
Ruth Swanek - Modeling Unit