Loading...
HomeMy WebLinkAboutNC0089737_Renewal Application_20180202E McGill A S S O C I A T E S April 2, 2018 Ms. Bnanna Young Environmental Senior Specialist Department of Environmental Quality Division of Water Resources Compliance and Expedited Permitting Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Dear Ms. Young: RECO !EMENR/DWR APR m 9 2098 Water Resources Permitting Section RE: Water Treatment Plant Upgrade Town of Franklin NPDES Application Permit # NCO089737 Macon County This letter provides responses and additional information as requested in the letter from John Hennessy to Ms. Summer Woodard at the Town of Franklin dated January 12, 2018. This additional information is provided in response to the NPDES permit application for Town of Franklin Water Treatment Plant which was submitted for review and approval. The permit application review letter notes that this is for a NPDES Renewal application. It should be noted that the Town of Franklin does not have an active NPDES permit for the water treatment plant (WTP). While the plant has been in operation at the current location since its original construction in 1975 there has been no NPDES permit in place for discharge of treated effluent from the alum sludge lagoons. All wash water/wastewater effluent has either evaporated and/or infiltrated through the bottom of the sludge holding lagoons. Page 1 of the review letter, item #1 request a more detailed solids handling plan. This additional description is as follows: WTP Solids Handling Plan Solids from the water treatment plant (WTP) process are generated from three (3) potential sources. Raw water is withdrawn from Cartoogechaye Creek and pumped to the WTP for treatment. Chemical addition occurs in the raw water pump line to the treatment process to enhance coagulation the raw water in the ballasted setting pre-treatment unit (Actiflo Process by Kruger). A large percentage of the solids in the raw water coagulate with a ballast sand and settle in the Actiflo process. The settled solids are pumped from the unit and conditioned through a cyclone 55 Broad Street P O Boa 2259 ph 828.252 0575 Asheville, North Carolina 28801 Asheville, North Carolina 28802 f 828 252 2518 Nv%%,Nti mcgillengmeers coni process which separates the solids from the ballast sand. Solids flow by gravity to an existing circular flow equalization tank and then to the first of two alum sludge lagoons. The two alum sludge lagoons are interconnected. The ballast sand is returned to the Actiflo process tank for reuse in the process. Water from the Actiflo process then flows by gravity to two sedimentation basins where a large portion of the remaining solids are separated by gravity settling prior to final filtration. Any solids accumulated in the settling basins are removed approximately once every three (3) months by washing out the basins. The wash water carrying the removed solids accumulated within the settling basins flows by gravity to an existing circular flow equalization tank and then to the first of two alum sludge lagoons. All remaining solids in the raw water are removed through the mixed media filter process. To keep the filters clean and operating at peak performance the filters are backwashed and cleaned approximately once every 72 hours of services. The filter wash water carrying the remaining removed solids flows by gravity to an existing circular flow equalization tank and then to the first of two alum sludge lagoons. The water treatment solids remain in the two alum sludge lagoons for storage and thickening. Once the NPDES permit is approved water will be removed from the top of the second lagoon and discharged to Cartoogechaye Creek to make room for additional wastewater and sludge storage. The two alum sludge lagoons are interconnected with a pipe which allows water to flow form basin 1 to basin 2 prior to decant and discharge from the second lagoon. Approximately every two to three years the solids in the basin have thickened a level where it is advantageous for the town to dispose of the solids. The water plant residuals are land applied onto local farm land as a beneficial soil amendment and as a Class A product. The town of Franklin contracts with a licensed residuals/sludge hauler who secures the permits for the farm land and application sites and manages the beneficial reuse program for the town. Page 1 of the review letter, item #2 request that the WTP schematic should be modified to show the proposed sampling point and the flow pattern. The schematic has been revised as requested. Page 1 of the review letter, item #3 request a copy of the analysis of the raw water. This data is collected daily and shown on the WTP DMR monthly report. A copy of two months of data from these reports are attached. More months can be provided if needed upon request. Page 1 of the review letter, item 94 request five (5) days of Total Hardness data for the water plant effluent and raw water data. As previously mentioned there is no discharge point currently in place at the WTP. In follow-up to your email of March 7th which provided concurrence for the testing of effluent hardness from the second alum sludge lagoon near the location of the proposed discharge point sampling for a five (5) period was completed. The results of these five (5) days of test are: Date Influent Hardness (m 1) Effluent Hardness (m I) 3/12/18 10 15 3.13/18 10 14 3/14/18 10 14 3/15/18 10 13 3/16.18 12 15 • Note that effluent sample taken from second alum sludge lagoon near the location of the proposed discharge point. Page 2 of the letter has additional comments which are addressed as follows: Comment #5: Determination if facility is subject to zero flow restrictions: An evaluation of flow in Cartoogechaye Creek was performed in accordance with, and using data from, USGS Water Supply Paper 2403 (flow data pg. 28). Flow data in the WSP-2403 is from USGS Gage# 0350024000 (period of record 1963-1988), which is located approximately 3.7 stream miles downstream from the Franklin WTP lagoon discharge point. The drainage areas at the gage is 57.1 sq. miles and the drainage area at the WTP is 46.1 sq. miles or 80.7% of that at the gage. The table below shows the flow estimates requested in the January 12, 2018 letter to Summer Woodard. Flow estimates are provided for both the gage and outfall locations correlated by drainage area ratio. Comment #6: Required stream and basin information: a) Receiving Stream Classification: Cartoogechaye Creek from Town of Franklin water supply intake to Little Tennessee River (index 2-19-(10.5) is classified as Class C, Trout. b) Basinwide Plan Review: The most recent Basinwide Plan for the Little Tennessee River Basin is dated 2012. Cartoogechaye Creek is located in the Headwaters Little Tennessee River Basin (HUC 0601020201). The watershed consists of mostly undeveloped public lands in the headwaters. Below the headwaters the creek flows through mostly agricultural valleys with tributaries draining side valleys and wooded coves and slopes. In the lower reaches of the creek, below the discharge point from the WTP, there is more residential development and some light industrial and commercial development. According to the ambient monitoring data collected by NCDWR all sections of Cartoogechaye Creek support designated uses. Sampling in 2011 at the WTP site found elevated levels of bacterial contamination that was attributed to upstream livestock farming without BMP's. In 2008 the Little Tennessee Watershed Association monitored fish communities and found high incidence of a parasitic infection called blackspot that has been associated with organic enrichment but can occur in healthy streams as well. Water quality concerns in the basin are primarily focused on livestock access to streams and other riparian disturbance. There are no listed limitations for NPDES permits and no recommended NPDES permitting strategies noted in the 2012 Plan. c) Assessment of impairment and 303(d) listing: With the exception of the statewide Category 5 listing for Mercury, there are no impaired waters listed in the Cartoogechaye Creek watershed. This determination is based on review of 2016 303(d) reports and maps. Comment #7: Endangered Species Evaluation: A scoping letter was sent to the US Fish and Wildlife Service (FWS) explaining the proposed activity and requesting comments regarding listed species. The FWS responded by letter dated March 2, 2018 and noted two federally listed species in the project vicinity. These are the federally threatened northern long-eared bat (Myotis septentraonalis) and the federally threatened spotfin chub (Cyprinella monacha). The FWS letter states that any incidental take of the northern long-eared bat that may result from project activities would be exempt under the 4(d) rule. The FWS letter also states that, due to the distance of the proposed discharge to the spotfin chub habitat (5.7 river miles) and the large amount of dilution that would occur to the proposed discharge, the FWS is "...not opposed to the proposed project based on the apparently low probability for impacts to this species and its downstream habitats." Comment #8: Population Projections: The Engineering Alternatives Analysis submitted with the original submittal contained population projections for the Town of Franklin Water system which were generated in a system wide water study prepared by W.K. Dickson. The appropriate sections of that report will be forwarded under separate cover. Comment #9: Flow Projections: The above referenced system wide water study prepared by W.K. Dickson contains projections of future water system demands. The appropriate sections of that report will be forwarded under separate cover. Comment #10, 11, 12: The Engineering Alternatives Analysis submitted with the original submittal has been updated to include the requested additional information related to cost for each of the proposed alternatives. The requested Attachment A is also being completed and signed by the Town. The revised Engineering Alternatives Analysis report will be forwarded under separate cover. Should you have any questions please let me know. Sincerely, McGILL ASSOCIATES, P.A. IN k" V (sw M. KE H WEBB, P.E. Vice President - Principal Attachments 15.00359/Franklin WTP/letters by 2apn118-npdes response CC; Summer Woodard — Town of Franklin Nathanael Moore — Town of Franklin Tim Heim- DEQ Regional office Franklin Water Treatment Plant 440 AIL - Ail ^Y � � � � � � � � 0 � -U U�..3JUv..Y.w.r�u LV.Lu'-1�'\��Ju � C � � C C ju barl..- Kim 2 LU 2 U 0 Z Q cn I— W H J Q U_ N 2 n. _ CD W y > Z c w CO O W N U � � z a_ > r O (fine) o N N O 0 6 '- O co M N O r- M M N (N N O IT co 0) JaleM paysiuid E r o 0 0 (6ne)JaleM a 66 0 0 0 0 0 o r- - a o 0 0 0 o a D o a o - o 0 0 �o pajallid-aid Q �o (fine) ry o O m O '- 0 0 0 N N N N O N N M N N N— N M jaleM Mea c o 77 = (fine) N o ZD CO r m oO m O N 66 0 0-- M N O— N V M N N M M M M V N N � V E JaleM paysiuid ND "00 (fine) jaleM O N O m N V— N N N N V co M M M co V V co M V V V V M M N V ° pajaiLl-aid - — — — — f- — � — — — — — — — — — — — — c 0 0 (fine). . v o rp m r OO 00 O O N O O O M N N NM V M M V M V V N U JWAA Mea (O Un (D Un In (0 (D r UD (D In (D Un Un r Un1 r W LO (D r (D Un c0 Un V «� (D In r r UP (fine) rrrrrrrrrrrrrrrrrrrrrrrrrrrrrr li In r- 31 JoleM paysiuid V LO V M m C' V M co Un -'T Lf) LI? (9 N V 10 V CO V M V In M O 10 (uiw) rrrrrrrrrrrrrrrrrrrrrrrrr(flrrrr rr JaleM paysiuid 7 r (O (O co r N M r D (D 0O O�� V m-7— CO r 00 r N a) V (xew) 0Oro;rrrroD(ocorcorrODrcoODrrror(o00rrrrr r� JaleM paysiuid CO CO r r 00 co CO CO V (D w r r r r r co of co (O rn O Un ID O Un O 10 r CO T-(uiw) JoleM D fl fl o o D o D o m o o D D D D o co D o 0 o D c o D o co co co m co co a i a� PaJell.d- d m m m O m m m CO O m of M W m m m m m CO O N M N r r D r DJ O) CO (xew)jaleM r cfl r (o (o (o 6 (D co co co 0 0 0 0 0 o m fl o fl fl r fl o D o o m o o r paaalpd-aid m mo 10 (uiw) rrrrrrrr ;rrrrrrrrrrrrrrr �rrrrr rr JaleM Mea N N M N M N N 7 N N N M M M V M (f) V N '7 V V N Un Un ul M U[') (xew) rrrrrrrrrrrrrrrrrrrrrrrrrrrrrr rr jaleM Mea (xew) JaleM paysiuid 0 C) (xew) U jaleM Mea N co co co co r c0 c0 co 00 Co CO CO co OO r oO M CO R CO N O CO CO CO CO 00 c0 N jaleM paysiuid ico sisal to jagwnN Uf) (f) m (D m V OO Cl) M r CO CD CO e r r V c0 V O Z O M M r N 0) m m (D (D (D In N V Un V c0 m V V co CO CO V O 0) m O V r m (xew) V V V C �7 M N M (D 'C M M N N M V M M M N N Uf Uf) Lo (D M Un Un r (D V cD jaleMpaellas o0060000 o 060066660000000000CD0 o— ID 7 m Un M (D V M r CO (D N r Un W V (D O V m O (xew) Un M r m r In V O m (D O V r N In r N '- r m U) m M m (() m m r Un m r . u) r m (D (D r CO r m M O (D Un to (D r to Un N Un U) U() V r D V Un r JaleM Mea N Un N co r Un M M m N V r M (D LO M r r N V V M r m V V N c0 Un (D U() LO co 10 r v m m N r m m r O m m O O O N C'," N N V M N M M M N O O O O� N N N N N N N N N N N N N N N N N N N N N N N tO 3 v 0 CL E d F- aleQ N co V Uf) (D r M m n DroOmO�NMcliNCNrmmo N N N M N N N N N N N M H > Q x x z _ CD W y > Z c w CO O W N U � � z a_ > U - a W w CO U) } J Q Z Q J U_ Z. W U Z Q N H N W F- J Q U_ } a s 2 6 0� E- W z Fn O 3r.Q 2 a 3 (xew) J o JaleM pagsiui=� E (xew) 0 — JaleM Mea (fine) (-l/6w) wrnolep Ja1eM pagsiu'J (fine) (s Oeep) M C, N N V V M N N N N V V V N N V M V u7 V M V V V V l(7 L(7 V M M V M ([) JeleM pagsiwd J 0 N 0 (fine) (£Opep) N V V V N V N V V V M M U) M (n (n V M� V V (n (n M V V M V M (n JaleM Mea It CD (fine) o ` O (") O o N M U') -t -t M N M N M N V N M M 44 N (n 0) JaleM pagsluid E yD �O E (6ne)JaleM . . v o N N6 w O O (N O r N O O O O N O M N" M M M N N- N M m V V cz o(fine) M o 0' N M N N N M N N U7 M m V M R M R O N U o N N O O Ja1CM Mea D o �3 D 0 C) N N V V-4 N N V (n M N M -'t M N (n V M M -t V V V V co V O N co n M (!') m JaleM pagsiwd E o0 (6ne)JaleM Co) paJall!-�-aJd o 0 — o cz (fine) co CD 0 m M N M V M N co V M V U) (n V V U V M (D V V M V V V M N M M M M M U JaleM Mea w www w u D w rn w w D w n n rn w V) rn (fine) r� r Ja1eM pagsiwD r- M co N V M V M M M cn (D O r N V O V rn V CD V r- V Lo N N L V U7=1V ti (ulw) JoleM pagsiuid CO w O w w .- w w .-- f` O w r-- .- N O O O O V 0) v (xew) c6���t-�00�r-CoC6�cooor cd r--�r--co00rl-rl-r--r,ODwww rl-00 JaleM pagsiuid w O In (oil- r- r- (D t` (D f- w ((') CD r� r� f� f� r� r r� r� r� N V (D (D f� (D w 2 (ulw) JaleM D D o r o 61,6 o 0 o D o w o 0 o D m o 0 o m o co (D o (6 w w w(D 0 o a paJa111A-aJd Ico 1"- o, rn (n (r (D ,- oo (xew)JaleM cc co (D (o (D (D (D o (D o 0 0 0 0 0 o co 0 (D D (o coo r-_ co (D o (0(o 0 o r paJal1id-aJd wr-, rn w rn rnrn m Oo (ulw) r-oo(Dr-r-(or-r--cDr--�r-- r-- ��r-- r-- r--r--(o(or;r=r- r- r- JoleM Mea U) N N N N M V M M N N M M V M N M co. M M M N M M M m (xew) �r ��� r ����� r r �� r ��� JaleM Mea (xew) (3 JaleM pagsiuid 0 0 (xew) JaleM Mea w�wwwwwwwwwwrnwr- wwwwcowwr- wwwwwww corn Ja1eM paysiui-� sisal ;o JagwnN F o� Dw n_��N (nrnr nn�w M Orn n nM r www wvo Z w N V O n r V n N[zl" U) 0) w C N CD N rn U� w N N O M N N (xew) U) LO. (D co m w rl- (f) U) U) '7 V D V n r.- U) V U) r-- In to cn (D V N w 0) (n w U) M w N JaleMpaplaS 000000000000000000 00 ooC, 0000 or 0 -2 o rn o :3 D (Dvw nvco aw r Nr LO "I co r rno (xew) n (nv�o(o(O fl ���00 fl r- U, 0'1 Ivo? vvo M cn (o V O co w (D (D C V V V V .rl- (D V V V V C V M w M rn U) rn (D V N r . (D . JaleM Mea CO M N- V N co V M JaleM cq w LL7 (fl 7 V N 7 r- (D CO V to N w N 0) (On V (n -' w O w O 117 O rn 1 rn I rn O 11)? O N N N N N I N jr- N N Ic? N M N N N 1(,� M N N M M M Z N M Mea p,, -dual N N .- .- N N N N N N N N N N N N N N N N N N N N N N N N N N N aleQ N M V n U) r w rn O .- N M S (n w r: w 0) O - N M '7 U) O N 1- N loo w N rn N O M H> Q Q Z r N N N N N N �O z Lo 0 w CN E2 > C) E2 U a) z a > Hardness Tests Town Of Franklin DATE TIME INFLUENT (RAW WATER) EFFLUENT (FAR END OF LAGOONS) 3/12/18 8:00am 10mg/1 15mg/1 3/13/18 8:00am 10mg/t 14mg/t 3/14/18 8:00am 10mg/l 14mg/t 3/15/18 8:00am 10mg/1 13mg/1 3/16/18 8:00am 12mg/1 15mg/l McGill A S S O C I A T E S February 2, 2018 Mr. Byron Hamstead United States Fish & Wildlife Service Asheville Ecological Services Field Office 160 Zillicoa Street Asheville, North Carolina 28801-1082 RE: NPDES Renewal Application Town of Franklin WTP NPDES permit NCO089737 Macon County, North Carolina Scoping Request Dear Mr. Hamstead: The Town of Franklin has submitted an application for a NPDES pen -nit for a discharge to Cartoogechaye Creek from an existing alum sludge lagoon associated with the Town's existing water treatment plant (WTP). The WTP and sludge lagoons are existing but planned upgrades to the WTP will increase the volume of flow from the pretreatment unit and the amount of filter backwash flow that will be discharged to the lagoons. Please find enclosed figures identifying the referenced project location and supporting documentation. McGill Associates, P.A. is requesting comments from your office regarding potential threatened and endangered species issues or other concerns relating to this project. Probable state and/or federal actions that may be needed to develop the project to include but are not limited to, the following: • NPDES Permit • Clean Water Act Section 401 Permit • Clean Water Act Section 404 Permit • Floodplain Permits The proposed discharge from the Town of Franklin WTP is 0.085 MGD or 0.13 cfs. The discharge will consist of wastewater generated from the pretreatment unit (Actiflo), filter backwash, periodic cleaning of the sedimentation basins and process instrument wastewater. All wastewater flows to an existing 136,700 -gallon flow equalization tank, then to two existing, unlined alum sludge lagoons, functioning in series, with a combined volume of 1.8 MG. The discharge will be from the second alum sludge lagoon. The discharge water is the same water withdrawn from Cartoogechaye Creek just upstream of the WTP but it has run through the treatment process and may contain trace amounts of the following substances: E n v i r o n m e n t a l • P l a n n i n g F i n a n c e 11rGill, lscnciatc s. P.,1 • 468NewIfarketBlyd. Ste. B, Boone. North Carolina N60? OJiire: (828) 3x6-19-10 • Fax: r8281386-1923 Mr. Byron Hamstead USFWS Page 2 • Zinc -orthophosphate (Sweetwater CP 1236): a water softener • Ployaluminum chlorosulfate (PAC — cederclear-757): coagulant • Sodium Hydroxide (caustic soda): for pH adjustment • Sodium hypochlorite (bleach): for disinfection The receiving stream is Cartoogechaye Creek, with a drainage area of about 46 square miles at the discharge point. There is a USGS gage downstream from the WTP on Cartoogechaye Creek, the drainage area at the gage is 57.1 square miles and the dates of record for the gage are 1963 to 1988. Using the published data from the gage, corrected for the WTP site using a drainage area ratio, the average discharge at the WTP site is 96.6 cfs, the 7Q10 and 30Q2 at this site respectively are 24.2 cfs and 41.2 cfs. The WTP site is approximately 11 stream miles upstream of the confluence with the Little Tennessee River. Please provide any comments regarding threatened and endangered species concerns or other issues of significance that may affect this project. We look forward to your comments on this matter. If you have any questions, please free to contact me at our office phone number of (828) 386-1920 or my email address john.vilas@mcgillengineers.com. Sincerely, MCGILL ASSOCIATES, P.A. YHNC.LAS Environmental Program Manager Cc: Mr. Keith Webb, P.E., McGill Associates, P.A. List of attachments: 1. LOCATION MAP AERIAL 2. USGS TOPOGRAPHIC MAP 3. DRAINAGE AREA MAP E n v i r o n m e n t a l 0 P l a n n i n g • F i n a n c e McGiIVIs,swiates. P.A • 468,Vei+'MarketBlvd. Sie. B. Boone. North Caro lip? a2x60' 01firi+ (82.0386-1920 • Fav,i82Ni 3X6-1923 t� United States Department of the Interior V. "�"w"��` �� FISH AND WILDLIFE SERVICE Asheville Field Office ° 9s 160 Zillicoa Street • Till, Asheville, North Carolina 28801 March 2, 2018 Mr. John Vilas McGill Associates 468 New Market Boulevard Boone, North Carolina 28607 Dear Mr. Vilas: Subject: Town of Franklin Water Treatment Plant NPDES Permit (NC0089737); Macon County, North Carolina Log No. 4-2-18-150 The U.S. Fish and Wildlife Service (Service) has reviewed the information provided in your correspondence dated February 2, 2018 wherein you request our scoping comments regarding potential impacts to federally protected species that may result from the proposed project. We submit the following comments in accordance with the provisions of the Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); the National Environmental Policy Act (42 U.S.C. §4321 et seq.); and section 7 of the Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act). Project Description According to the information provided, you on behalf of the Town of Franklin are seeking a National Pollutant Discharge Elimination System (NPDES) permit associated with modifications to an existing Water Treatment Plant west of Franklin, NC. Specifically, the proposed upgrades would increase the volume of flow from the pretreatment unit and filter backwash into the two existing unlined sludge lagoons. You indicated that the plant would discharge 0.085 MGD (0.13 cfs) of wastewater from the final lagoon in the series into the Cartoogechaye Creek. Wastewater would contain trace amounts of zinc -orthophosphate (water softener), polyaluminum chlorosulfate (coagulant), sodium hydroxide (pH control), and sodium hypochlorite (disinfection) generated from the pretreatment unit, filter backwash, and periodic cleaning of the sediment basins. The plant modifications may require some ground disturbance associated with the installation of new equipment and an outfall structure. Federally Listed Endangered and Threatened Species According to Service records, suitable summer roosting habitat may be present in the project area for the federally threatened northern long-eared bat (Myotis septentrionalis). However, the final 4(d) rule (effective as of February 16, 2016), exempts incidental take of northern long-eared bat associated with activities that occur greater than 0.25 miles from a known hibernation site, and greater than 150 feet from a known, occupied maternity roost during the pup season (June 1 — July 31). Based on the information provided, the project (which may or may not require tree clearing) would occur at a location where any incidental take that may result from associated activities is exempt under the 4(d) rule. The proposed project would occur approximately 5.3 river -miles upstream from designated critical habitat for the federally threatened spotfm chub (Cyprinella monacha) in the Little Tennessee River. We do not have concerns for project -mediated impacts to this species provided that the proposed NPDES permit would require monitoring and compliance standards for applicable toxicants or parameters, (which may include zinc, chloride, and pH) for the purpose of protecting water quality and natural resources. Moreover, you indicated that the 7Q10 at the proposed discharge site is approximately 24.2cfs, which is more than two orders of magnitude greater than the proposed maximum discharge of 0.13cfs. Before it enters the Little Tennessee River and critical habitat, Cartoogechaye creek drains numerous tributaries that would further dilute upstream inputs from the proposed discharge. We are not opposed to the proposed project based on the apparently low probability for impacts to this species and its downstream habitats. Based on the information provided and Service records, no other federally protected species or their habitats occur in the project vicinity. Please be aware that in accordance with the Act, it is the responsibility of the appropriate federal agency or its designated representative to review its activities or programs and to identify any such activities or programs that may affect endangered or threatened species or their habitats. The Act does not require written concurrence with the Service for "no effect" determinations from the Action agency. If it is determined that the proposed activity may adversely affect any species federally listed as endangered or threatened, formal consultation with this office must be initiated. Several federal species of concern' occur in Cartoogechaye creek downstream from the proposed discharge location. They include: Little Tennessee River crayfish (Cambarus georgiae), olive darter (Percina squamata), smoky dace (Clinostomus sp. 1), and hellbender (Cryptobranchus alleganiensis). These aquatic species are sensitive to perturbations in water quality and physical habitat conditions. In addition to monitoring for compliance with water quality standards, we offer the following recommendations in the interest of protecting these, and other fish and wildlife resources: Riparian Buffers Natural, forested riparian buffers are critical to the health of aquatic ecosystems. They accomplish the following: 1. catch and filter runoff, ereby helping to prevent nonpoint-source pollutants from reaching streams; 2. enhance the in -stream p ocessing of both point- and nonpoint-source pollutants; 3. act as "sponges" by abs rbing runoff (which reduces the severity of floods) and by allowing runoff t infiltrate and recharge groundwater levels (which maintains stream flows uring dry periods); I ' Federal species of concern are not currently afforded legal protection under the Act. However, proactive conservation measures on behalf of these species may preclude the need to list them in the future. 2 4. catch and help prevent excess woody debris from entering the stream and creating logjams; 5. stabilize stream banks and maintain natural channel morphology; 6. provide coarse woody debris for habitat structure and most of the dissolved organic carbon and other nutrients necessary for the aquatic food web; and 7. maintain air and water temperatures around the stream. To the extent that is feasible, we recommend establishing/maintaining a forested riparian buffer (100 feet wide [or the full extent of the 100 -year floodplain, whichever is greater]) along Cartoogechaye Creek. Erosion and Sediment Control Measures to control sediment and erosion should be installed before any ground -disturbing activities occur. Grading and backfilling should be minimized, and existing native vegetation should be retained (if possible) to maintain riparian cover for fish and wildlife. Disturbed areas should be revegetated with native grass and tree species as soon as the project is completed. Ground disturbance should be limited to what will be stabilized quickly, preferably by the end of the workday. Natural fiber matting (coir) should be used for erosion control as synthetic netting can trap animals and persist in the environment beyond its intended purpose. The Service appreciates the opportunity to provide these comments. Please contact Mr. Byron Hamstead of our staff at 828/258-3939, Ext. 225, if you have any questions. In any future correspondence concerning this project, please reference our Log Number 4-2-18-150. Sincerely, - - original signed - - Janet Mizzi Field Supervisor PLAN yliR4M11( st'\I! ! IWU s j1Im FEE'1 - 4 Franklin Glbsal � ,j 43� � '' �,� -. - vn 14 Hill 64 ­0_��NPDES DISCHARGE POINT • ` - -�_ s " 1 t,FRANKLIN WATER \\ r �' �- /Coaad$- _ TREATMENT PLANT f MW BloMomtown ' 1 f ' /; f t_ l �:.�•- \�� � � � \\fes � " f- nmc-Gm WATER TREATMENT PLANT l ' �m ; FIGURE BAG(WASN / WASTEWATER NPDES PEwurt TOWN OF FRANKLIN `'" LOCATION MAP wrt~ MACON COUNTY NORTH CAROLINA .. __. ro c .o _c O T U C C m = o Q CL -0 U v H c > c ar O eo E ace v c a c +• 0! « — E v c r C `! E lL N N 6/ F y O 0J W m 3 t; w 3 eco r 0 'Eg11� GLLx �rJ Y ,7thf;99a �,� FAAC Y "� !al,• ws�".d: MACONCONCO UNTY y 600iHVUEaI EFdJ COMMUNITY COLLEGE r `lI•'f674437ae7•' r �•"f •,—��' Ytl 66744,3808 j MAt✓ON'(:(xINTY t ' 'STAMEY;f)ENNIS N : 1=10� •' ti .� � ^-+1�, p� : s' C"2921'48s 74337 ti 1k, .v ►yrr,. N 74 ,4432201 WN OF FRANIq II, 10129-31 'I 1/ ,_a :rjr- INTi11S tTtd4L f'Akk 1.O(JP acv . � �~ STATE OF NORTH CAROLINE 074.1;754, F-13178 1 I-RO ikA ()N COUNTY , 6574533485p'�c. •;c 'ii10 MERCIALwP.ROPERTICA, , r,, � w . " +- 6t;74639237 dES A , 74435094 INDUSTRIAL PARK PROPS LL v. - J��" .. IY�712405', rrr .• , '6574521279 SOUTHWESTERN COMMUNITY 1-22AS93 65 nu 6674425 � �~ � 1i 444621un", AP4INHOLDIN LLC r 74621279' r S'OUTHWES'TERN COMMUNITY CO( IT 07 '1159- Macon County WTP S� w�W 6&fP"y d�cA.Ic- 16c.,4,^ Disclaimer: The information contained on this page is taken from aerial mapping, tax mapping, and public records and is NOT to be construed or used as a survey or'legal description'. Only a licensed professional land surveyor can legally determine precise locations, elevations, length and direction of a line, and areas. J- APAC'TENNESSEE M-2 011 55 61 55 8 65745 ;8123 L,1(APAC TENNESSEE INC j6574528904 ,1f >' E'APAC-ATLANTIC,, INC. N 35-1102 n"Es IARD+WAYN' 5674629777 7651 APA+CATLANTIC�II �'``'�G35J1164 IARD WAYNE le 2 `1 66 7 452 9 620 4N TIC INCAPACATLANTIC INC ti -3&1496 I 65745218, HESTON WR6'iTOPHER E ;(1.,2097 " 1:3,272 0 0.0275 0.055 0.11 mi 0 0.0425 0.085 0.17 km February 2, 2018 coK CO& FSt. 1141! 212/2018 StreamSlats Cartoogechaye Creek Drainage Area Region ID: NC Workspace ID: NC20180202193043378000 Clicked Point (Latitude, Longitude): 35.15625, -83.38082 Time: 2018-02-02 14:31:00 -0500 co Airport Franklin 4 410 UNZAIN ` U u N T `� 2 c? ` ,,A0 1 { 1676 in t � z Proposed NPDES discharge point at Franklin WTP is marked on map with circled red x. Drainage area to discharge point is approximately 46 square miles and this point is approximately 11 stream miles upstream of the confluence with the Little Tennessee River. The entire drainage area for Cartoogechaye Creek is 57.4 square miles. �4� {rSS�I https:/Istreamstats.usgs.gov/ss/ 112 ENGINEERING ALTERNATIVES ANALYSIS WATER TREATMENT PLANT UPGRADE and TREATMENT PLANT RESIDUALS TOWN OF FRANKLIN MACON COUNTY, NORTH CAROLINA M. KEITH WEBB, P.E. OMcGM ASSOCIATE S Engineering • Planning • Finance Asheville, North Carolina OCTOBER, 2017 PROJECT #15.00359 TABLE OF CONTENTS A. SUMMARY, CONCLUSION & RECOMMENDATION .....................1 B. CURRENT SITUATION..........................................................................2 C. ALTERNATIVES ANALYSIS...............................................................11 A. SUMMARY, CONCLUSION AND RECOMMENDATION The Town of Franklin owns and operates a water treatment plant (WTP) which has a design capacity of 2 0 MGD and is located west of downtown in the Franklin Industrial Park off of US 64. The WTP was constructed in 1975 and last upgraded in 1997. Recent studies identified the need to expand the WTP to a capacity of 3.0 MGD to 4.0 MGD to meet the long term projected future water demands. Average daily water demands have been projected to increase of 1.90 MGD by year 2060 with peak day demands of 3 0 MGD. As a part of the WTP expansion phase I improvements have been designed and permitted and construction is beginning on these first phase improvements which consist of the construction of an Actiflo@ treatment process to address the need for either mechanical pretreatment of the raw water or off -stream storage associated with the future expansion of the WTP as required by the North Carolina Administrative Codes Title 15A, Subchapter 18C entitled "Rules Governing Public Water Systems". The Actiflo@ system utilizes a micro -sand particle which is blended into the raw water stream along with coagulant chemicals to provide a ballasted settling environment The proposed new pretreatment unit is situated so as flow is pumped to the unit from the raw water pump station and then flows by gravity to the existing sedimentation basins and filters. The proposed Actiflo@ system will result in a continuous flow of wastewater from the pretreatment unit when the WTP is in operation This flow is estimated to be in the range of 40 gallons per minute (gpm) to 55 gpm The WTP currently operates on average approximately 14 to 16 hours per day to meet current system demands. Therefore, once the pretreatment unit is in place and operational the facility will generate approximately 52,800 gpd of wastewater that must be properly handled. In addition to the wastewater generated as a part of the new pretreatment process there will continue to be wastewater generated as a part of the normal plant operation Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 Page 1 of xiv associated with the required routine filter backwash which occurs approximately every 72 hours of filter run. On average the filter backwash is 30,000 gpd. In addition to filter backwash water and flow form the Actiflo unit the sedimentation basins require at least semi-annual cleaning, if not quarterly. This activity typically generates an additional 150,000 gpd of wastewater. Modifications to the WTP wastewater collection system are being made. Once completed the WTP backwash flow will be handled and treated utilizing an existing 136,700 gallon capacity backwash water flow equalization tank and then the two alum sludge lagoons. In order to provide maximum flexibility in the operation of the current WTP residuals handling system it is proposed to secure an NPDES permit for the residuals (alum sludge) lagoons to allow for the discharge of clear water from the top of the lagoons back into Cartoogechaye Creek. The town will continue to maintain the WTP wastewater system and will schedule the removal of water treatment plant residuals from the lagoons on a routine basis. B. CURRENT SITUATION 1) Existing Water Treatment Plant The Town of Franklin owns and operates a water treatment plant (WTP) which has a design capacity of 2 0 MGD and is located in the Franklin Industrial Park west of downtown and off of US 64. The WTP was constructed in 1975 and last upgraded in 1997. Therefore, most of the facility is greater than 40 years old. However, despite its age for the most part the WTP is in good condition. The WTP provides treated finished water for the Franklin distribution system and the approximately 3,350 customers within the town and a small portion of Macon County with water service outside the corporate limits. Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 GA NS"0f:1 k I GS Page 2 of xro The WTP utilizes a conventional treatment process with raw water withdrawn from Cartoogechaye Creek, a tributary of the Little Tennessee River. Raw water is pumped to a flashmix basin where polyaluminum chlorosulfate (PAC — (cedarclear-757)) is added to enhance coagulation and sodium hydroxide (caustic soda) is added for pH adjustment. Raw water flow then enters two flocculation basins, each equipped with two vertical flocculators which slowly mix the water to build a floc of the sediment in the raw water. Coagulated water flows to two sediment basins where heavier sediments are removed by gravity settling. These heavier sediments are removed on a routine basis, typically every three (3) months to the alum sludge lagoons. Clarified water is then filtered by two mixed media gravity filters prior to the addition of chlorine gas for disinfection. Finished water is stored in a clearwell at the plant prior to being pumped into the distribution system. Cartoogechaye Creek has an estimated "safe yield" of 4.0 MGD and based upon previous approved studies the Town of Franklin may expand the WTP up to a capacity of 4.0 MGD to meet future demands for the water system. The current average daily demands average 1.10 million gallons per day (MGD) with peak day demands of 1.70 MGD Projected future demands have been estimated to be 1.90 MGD by year 2060 with peak day demands of 3.0 MGD. 2) Population and Demographics The foundation of any water plant evaluation is the projection of future demands for the water system. Future demand projections establish the framework of the WTP upgrade/expansion by establishing an agreed upon planning horizon and corresponding system demand. As part of a previous evaluation of the Town of Franklin water system conducted by WK Dickson (WKD), a detailed evaluation of the Town's water system demands was conducted. The results of this evaluation are summarized in Figure B.1 Engineering Alternatives Analysis �I�� IT Water Treatment Plant Upgrade 11 ll and Treatment Plant Residuals' Town of Franklin, Macon County, North Carolina August 2017 Page 3 of xiv below Town staff reviewed these projections and have concluded that they are reasonable and acceptable for use in future planning of the water system 3) Figure B.1— Water System Demand Projections 35 3 25 in 2 £ 15 a O 1 0.5 0 4) Water System Demand Projections Town of Franklin 2010 2015 2020 2030 2040 2050 2055 —A --Estimated Average Dally Usage (MGD) -Estimated Max Dally Usage (MGD) SOURCE: COMPREHENSIVE WATER MODEL AND MASTER PLAN, WKDICKSON, 2013 Engineering Alternatives Analysis Water Treatment Plant Upgrade t' and Treatment Plant Residuals ` `� 4 i) C 1 1 I [ 5 Town of Franklin, Macon County, North Carolina August 2017 Page 4 of xiv - �--- r-- --1 -- — - --C -- - — - -- -_ ----' -- f __-__--_-__-- _-___ _______ �_------ _-+ — —_—f—_—r---�--- --_;-- - --4— --- + — —I— 4-----r--a _-- _� — ----1--- - -- ----' ----- -- ---- — ----i---J i 2010 2015 2020 2030 2040 2050 2055 —A --Estimated Average Dally Usage (MGD) -Estimated Max Dally Usage (MGD) SOURCE: COMPREHENSIVE WATER MODEL AND MASTER PLAN, WKDICKSON, 2013 Engineering Alternatives Analysis Water Treatment Plant Upgrade t' and Treatment Plant Residuals ` `� 4 i) C 1 1 I [ 5 Town of Franklin, Macon County, North Carolina August 2017 Page 4 of xiv The Town of Franklin has identified the need to expand the capacity of the water treatment plant to 3 0 MGD or even 4.0 MGD to meet these projected future demands. An interim first phase of this project has been designed, permitted and is scheduled to begin construction This interim phase consists of the addition and construction of an Actiflo® treatment process to address the need for either mechanical pretreatment of the raw water or off -stream storage The previous engineering report prepared as a part of the WTP upgrade evaluated the alternatives for mechanical pre-treatment or off -stream storage and recommended the construction of the Actiflo® system The Actiflo® system utilizes a micro- sand particle which is blended into the raw water stream along with coagulant chemicals to provide a ballasted settling environment The proposed new pretreatment unit is situated so as flow is pumped to the unit from the raw water pump station and then flows by gravity to the existing sedimentation basins and filters. Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 Page 5 of xiv Engineering Alternatives Analysis OMcGill Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 Page 6 of xiv Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 �McGill ASS0('IA 1 E:4 Page 7 of xiv Proposed Improvements As described above the current project scheduled to begin construction includes the construction of an Actiflo@ treatment process for the pretreatment of the raw water prior to sedimentation and filtration. Unlike the current WTP process the new proposed Actiflo® system will result in a continuous flow of wastewater from the pretreatment unit when the WTP is in operation. This flow is estimated to be in the range of 40 gallons per minute (gpm) to 55 gpm. The WTP currently operates on average approximately 14 to 16 hours per day. Therefore, once the in pretreatment unit is in place and operational the facility will generate approximately 52,800 gpd of wastewater that must be handled. In addition to the wastewater generated as a part of the pretreatment process there is also wastewater associated with the required routine filter backwash which occurs approximately every 72 hours of filter run. On average the filter backwash is 30,000 gpd. Semi-annual cleaning, if not quarterly cleaning of the sedimentation basins is also required. This activity typically generates an additional 150,000 gpd of wastewater. Modifications to the WTP wastewater collection system are being made and the backwash flow will be handled and treated utilizing the existing 136,700 gallon capacity backwash water flow equalization tank and then the two alum sludge lagoons. Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 oMcGill Page 8 of xiv __VVR%r Figure 1- WTP and Sludge Lagoon Location Map Currently all non -sanitary wastewater from the WTP facility, primarily filter backwash water and sediment basin drains flows to a pair of WTP residuals (alum sludge) lagoons located below the WTP along the banks of Cartoogechaye Creek. Filter backwash water flows from the WTP through a 24 -inch sewer line to a 136,700 gallon capacity concrete sludge thickening tank prior to then flowing to the two alum sludge lagoons. This tank basically serves as a flow equalization tank with the filter backwash water flowing though the tank to the alum sludge lagoons. As a part of the WTP improvements the WTP wastewater piping is being modified so that all backwash water (filter backwash, sediment basin cleaning and the Actiflo system) will first flow to the existing 136,700 gallon circular concrete tank. This tank will function as a flow equalization tank and modulated flows will then exit the tank and to the lagoons. Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 __.._ OMcGill Page 9 of xiv The two existing alum sludge lagoons are both unlined with an approximate combined volume of 1.8 MG and were built in 1975 as a part of the original WTP construction. These lagoons have been in service at this facility since it first went on-line and the residuals in the lagoons was recently (2011) removed and land applied on local farm land for beneficial use. These lagoons and the residuals handling system are typical for WTP facilities with a high quality water source similar to the Town of Franklin. While the alum sludge lagoons have functioned adequately, there is a concern on the part of the WTP operation staff that with the daily flow of wastewater associated with the Actiflo® pretreatment process removal of clear water from the lagoons on a routine basis will be required to provide adequate volume for wastewater from the WTP. Historically the water treatment plant operators have relied on evaporation and/or infiltration of the clear water from the lagoons to provide the hydraulic capacity required. The existing alum sludge lagoons along with the 136,700 gallon capacity flow equalization tank should provide adequate hydraulic capacity for the WTP and the pretreatment unit. With the two lagoons relationship adjacent to Cartoogechaye Creek, and no additional undeveloped space on the plant site options for the expansion and construction of additional lagoons is limited. Increasing the depth of the lagoons is not a feasible option as they are currently located above the water surface of the creek and lowering of the lagoons would drop them below the water table. In order to provide maximum flexibility in the operation of the current alum sludge system it is proposed to secure an NPDES permit for the lagoons to allow for the discharge of clear water from the top of the lagoons into Cartoogechaye Creek. Clarified Engineering Alternatives Analysis 'McGill Water Treatment Plant Upgrade and Treatment Plant Residuals 4 h O t { E S Town of Franklin, Macon County, North Carolina August 2017 Page 10 of xiv water will be decanted and removed from the top of the lagoons and returned to Cartoogechaye Creek. This water should be of very good quality and is essentially the water previously removed from the stream with trace amounts of treatment chemicals (polyaluminum chlorosulfate (PAC — (cedarclear-757)), sodium hydroxide (caustic soda), and Sodium hypochlorite (bleach). The town will continue to maintain the wastewater system and will schedule the removal of water treatment plant residuals from the lagoons on a routine basis. C. ALTERNATIVES ANALYSIS Four alternatives have been identified for the Franklin WTP upgrade to provide the operational flexibility needed for the WTP residuals generated as a part of the enhanced treatment process. These are: 1. No Action 2. Construction of additional Residual Storage Lagoons. 3. Secure an NPDES permit to allow decant and discharge from the Existing Lagoons. 4. Connection to public sewer collection system ALTERNATIVE # 1 — NO ACTION This alternative consists of taking no action to make improvements to the existing residual system (alum sludge) at the Franklin WTP. The existing system has a combined volume of approximately 1,936,000 gallons in the backwash tank and the two lagoons, provided the two lagoons are cleaned of residuals (sludge). However, over time the lagoons will capture residuals (alum sludge) and will fill -up, reducing the capacity. Currently there is no method to remove or decant clear water from the lagoons. Water must either evaporate and/or infiltrate through the residuals in the lagoon into the groundwater system. Depending upon this type of system for the Engineering Alternatives Analysis OlMcGill Water Treatment Plant Upgrade and Treatment Plant Residuals 1 S S 0 4' 11 T k: S Town of Franklin, Macon County, North Carolina August 2017 Page 11 of xiv removal of water necessary to provide adequate volume for additional backwash water is not reliable, especially during the winter months and periods of heavy rainfall. While the two lagoons and the backwash tank can provide as much as 23 days of theoretical storage for the Actiflo and filter backwash water this volume is only available when the system is 100% cleaned of residuals. Operation of the WTP results in the generation of residuals which must be stored in the two lagoons, therefore continuously reducing the capacity. Continued operation of the system with no increased ability to decant and remove clear water meeting typical parameters for discharge back to Cartoogechaye Creek is not feasible and is not recommended as it subjects the WTP to potential violations for system overflows. ALTERNATIVE # 2 — BUILD ADDITIONAL LAGOONS This alternative consists of building an additional residuals storage lagoon to provide additional wastewater storage volume. A lagoon with a capacity equal to the two current lagoons is recommended. Land owned by the Town of Franklin at the WTP is limited and there are no locations on the current site available to build a new lagoon. Property adjacent to the WTP is also not available for purchase to build a third lagoon. Of even more concern is that the construction of a third larger lagoon which would provide additional residual storage volume, the removal of clarified water would still be through either evaporation and/or infiltration and would be very weather dependent and not reliable. This option is therefore not recommended. ALTERNATIVE # 3 — NPDES PERMIT FOR THE EXISTING LAGOONS Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 -'McGill Page 12 of xiv This alternative will require the construction of no new lagoons or other residual treatment facilities. Minor improvements to the current wastewater discharge piping will be made to allow for the optimization of the current facilities. The existing system has a combined volume of approximately 1,936,000 gallons in the backwash tank and the two lagoons, provided the two lagoons are cleaned of residuals. This provides as much as 23 days of storage for the Actiflo and filter backwash volume when the system is 100% cleaned. There is adequate volume to allow the residuals to settle by gravity in the two lagoons with the clear water discharged to Cartoogechaye Creek, under the provisions of a new NPDES permit. The ability to decant and remove clear water from the surface of the lagoons will provide the needed flexibility the WTP operation staff require. Typical effluent parameters for discharge of the treated wastewater from water treatment facilities and in this case back to Cartoogechaye Creek appears to be the most feasible alternative. Similar operations and systems are common at other WTP utilizing similar high quality raw water sources. The clarified water to be decanted and removed from the lagoons and returned to Cartoogechaye Creek should be of very good quality and is essentially the water previously removed from the stream with trace amounts of treatment chemicals (polyaluminum chlorosulfate (PAC — (cedarclear-757)), sodium hydroxide (caustic soda), and Sodium hypochlorite (bleach). The town will continue to maintain the wastewater system and will schedule the removal of water treatment plant residuals from the lagoons on a routine basis. ALTERNATIVE # 4 — CONNECTION TO A PUBLIC SEWER SYSTEM This alternative would consist of connecting the wastewater system at the WTP to the existing Town of Franklin sewer collection and treatment system. The town does have an 8 -inch gravity sewer line located approximately 250 feet from the alum sludge lagoons. Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 OMcGill 0( 1.1 ( E,S Page 13 of xiv Figure 2- Alum Sludge Lagoons and Gravity Sewer Line This sewer has a capacity of 255 gpm and provides service to the Franklin/Macon County Industrial Park. There is limited capacity to accept flow from the Franklin WTP in this sewer line. In addition to the limited capacity of the sewer line near the WTP the gravity sewer line conveys flow to a sewer pump station which then pumps the flow through a force main to another gravity sewer line. This sewer line then conveys flow to a second sewer pump station which pumps wastewater to the wastewater treatment plant (WWTP). Like most sewer collection systems inflow and infiltration (1/I) is a problem for the Town of Franklin. The age of the majority of the sewer collection system and the materials of construction present an ongoing challenge for the town. The higher sewer flows especially during periods of excessive overflow subject the sewer Engineering Alternatives Analysis � McG Water Treatment Plant Upgrade and Treatment Plant Residualsil Town of Franklin, Macon County, North Carolina August 2017 Page 14 of xiv collection system to potential sewer overflows and stress the WWTP at these higher flows to operate within limits. The Town of Franklin has an ongoing 1/I abatement program and continues to set aside funds on an annual basis to address the I/I flow situation. Water to be decanted and removed from the WTP residual (alum) storage lagoons is expected to be of a quality that will allow the water to be discharged back to Cartoogechaye Creek with no negative environmental issues. Discharge of this water to the public sewer system will present continued I/1 problems for the town's sewer system and will potentially require the upgrade and expansion of a number of the wastewater collection and pumping system components. Due to the potential negative impacts on the town's sewer collection and wastewater treatment system the connection to the public sewer system is not recommended. Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 OMcGillTIF S Page 15 of xiv Engineering Alternatives Analysis Water Treatment Plant Upgrade and Treatment Plant Residuals Town of Franklin, Macon County, North Carolina August 2017 MGillOcM1:11 E Page 16 of xiv