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U.S. EPA Region III
Regional Center for Environment;
I'lLppO^ T r ,.
Information
RegionaircntcrforFmironmen^Informahou ' 1650 Arch Str66t (3PM52)
"SSW Philadelphia, PA 19103
Philadelphia. P-\ 19103
PRELIMINARY CASE REPORT
For the
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IHenrico County, Virginia
Wastewater Treatment Facilities
DEEP BOTTOM WEST
July, 1978
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Table of Contents
Page
Introduction 1
I Background.
I A. NEPA Compliance 3
B. Description of the Proposed Action 4
C. Treatment Plant Site Selection Process 7
D. EIS Conclusions 8
II Description of the Effect Properties 9
III Determination of Effect 14
IV Avoidance of Adverse Effect 16
V Mitigation of Adverse Effect 18
APPENDIX 1 - Official Correspondence
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Introduction
The following report constitutes the Environmental Protection
| Agency's additional compliance with the National Historic Preser-
wm vation Act of 1966 and the associated regulations as established by
the Advisory Council on Historic Preservation (36 CFR 800). This
I preliminary case report will serve as the basis for the preparation
of the Memorandum of Agreement .
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An Environmental Impact Statement has been prepared for the
I proposed action with the Final EIS being released in March of 1978.
_ Most of the information found in this report has been taken from the
Final EIS. More detail can be found in the Final EIS, specifically
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Appendix D, "Historical and Archeological Resources".
An appendix is included with this case report which includes
the more important agency actions and position.
The County of Henrico, Virginia, acting as the grant applicant,
has proposed construction of a wastewater treatment plant at a site
identified as Deep Bottom West. As a result of the EIS Process, this
site has recently been identified by the Keeper of the Register as an
eligible site for inclusion in the National Register of Historic Sites.
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As required under 36 CFR 800.4(e), EPA has prepared this preliminary
case report for review and comment.
B The site is presently privately owned and afforded no protection
from private developmental interests. EPA feels strongly that a major
factor in determining the effect of the undertaking on the identified
site should be the consideration of alternative uses of this identified
historical resource if the proposed project is not implemented.
In accordance with the definition of adverse effects (36 CFR 800.9),
EPA has concluded that an adverse effect determination is necessary.
However, through consultation with the County of Henrico and the Virginia
State Historic Preservation Officer (Mr. Tucker Hill), a very definative
set of mitigative measures have been proposed which could not only allow
for the perpetual preservation of the identified Civil War related
I historic sites, but would culminate in the establishment of a County
Park, designed to make these sites and their educational resources readily
available and accessable to the general public. A unique nature of the
mitigative measures include the required review and approval of the
~ proposed park plan by the Advisory Council prior to the release of any
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EPA federal funds for any treatment plant site-specific work.
|| I. Background
A. NEPA Compliance
The National Environmental Policy Act of 1969 (NEPA) requires
the preparation of an EIS whenever federal funds or approval are
| considered for projects with potentially significant environmental
| impacts. Recognizing the potential air and water quality impacts
from the expected growth in the service area generated by the pro-
vision of sewer service and because of concerns and objections raised
by local citizens, EPA decided in the spring of 1976 that an EIS was
necessary for the proposed Henrico Regional Wastewater Facilities.
f The decision to prepare an EIS early in the planning process has
_ allowed it's preparation concurrently with the development of the
Facilities Plan. This permits a greater amount of environmental
V coordination and integration in the project's development than might
be normally anticipated from the preparation of the EIS subsequent to the
I completion of the Facilities Plan. It is for this reason that the reader
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will note that the applicant did not select a recommended plan
(including a recommended treatment plant site) until after the Draft
EIS was made available for their consideration. Under this process,
EPA would then address the applicant's recommended plan in the Final
EIS and make it's final recommendations and conclusions on the pro-
posed action.
The issue which this preliminary case report will discuss is the
£ archeologic impacts associated with the treatment plant site location.
_ Of the five treatment plant sites evaluated through the EIS Process,
only three were determined to be acceptable for EPA funding. The
I applicant's proposed site, Deep Bottom West, is one of these three
acceptable sites.
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B. Description of the Proposed Action
The proposed action involves seventy-five percent federal grant
A funding under Public Law 92-500, The Federal Water Pollution Control
Act Amendments of 1972, for the construction of a wastewater treatment
( plant and a system of interceptor sewers to serve Henrico County and
M parts of Goochland and Hanover Counties, Virginia.
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_ The Henrico County 201 Facilities Plan is an outgrowth of the
Richmond Regional Water Quality Management Plan which was approved
fl by the State Water Control Board in July, 1974. Briefly stated, this
plan called for an interceptor system which would begin in the far
j| west end of Henrico County and proceed in an easterly direction around
the City of Richmond and would terminate in the eastern portion of
the county at a new wastewater treatment plant. The treated effluent
M would then be discharged in the James River upstream from Jones Neck
Cutoff. The proposed circumferential interceptor system would serve
to prevent nearly all county wastewater from entering the City of
«| Richmond's collection system and eventually being disposed of through
their combined sewer system. The assumptions and cost analysis per-
taining to this plan were reviewed, and it was concluded that the
selected plan is the most cost-effective of the feasible alternatives.
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A large number of alternatives for wastewater transportation and
W treatment were considered in the 201 Facilities Plan/EIS process,
_ including:
- no action;
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- design flow - both "no growth" and water conservation
were considered;
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< - transportation - four (4) alternative interceptor
routings in the western end of Henrico County,
| three (3) in mid-eastern Henrico County, seven (7)
« in eastern Henrico County, and three (3) in
Goochland County were evaluated. In addition,
alternative routes to the various treatment plant
sites were evaluated;
4| - treatment plant sites - five (5) treatment plant
mt sites, all in eastern Henrico County, were evalu-
ated in detail. Four (4) of these sites were
evaluated in the Draft EIS and the fifth site
in Addendum Number One;
W - treatment process - over forty (40) treatment
r schemes were evaluated in detail;
- disinfection - alternatives using chlorine and
V ozone were evaluated;
- effluent disposal - two locations on the James
w River were considered;
m - land application - preliminary land requirements
and cost estimates were made for application
of effluent in Henrico County. Examination of
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M raw sludge composting and subsequent land application
will be reviewed in step two;
* - regional alternatives - the assumptions and cost
analysis pertaining to the selection of regional
water quality alternatives were reviewed.
The 201 Facilities Plan has recommended that a 28.6 mgd secondary
ff treatment plant be constructed at Deep Bottom West, with discharge to
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the James River at Segment 24.
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C. Treatment Plant Site Selection Process
The Draft EIS was released with the Facilities Plan on May 18,
I 1977. Four treatment plant sites were identified and evaluated:
V 1) Deep Bottom
2) Varina Farms
3) Darbytown Road
_ 4) Cornelius Creek
A joint public hearing was held on the Facilities Plan and the
Draft EIS on June 21, 1977. Following this hearing, the Board of
A Supervisors of Henrico County met on July 13, July 20, August 3, and
August 10, of 1977, to select a single treatment plant site to
complete the Facilities Plan and allow EPA to evaluate the appli-
cant's proposed action in the Final EIS. During these meetings,
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it became evident that even though the general consensus may had
favored the Deep Bottom Site, the displacement of homes and excessive
j| costs which would have had to be born by the local residents prompted
M the Board to reject this site. As a result of these considerations,
a fifth site was identified and approved by the Board which would not
require the displacement of families and would result in a substantial
monetary savings. This new site was identified as the Deep Bottom
V West Site.
W Since this was, in a sense, a new site, an addendum to the Draft
EIS was released in November of 1977 and both a public information
meeting was held on October 25, 1977 and a Public Hearing was held on
December 13, 1977 by EPA to allow public comment on the Deep Bottom
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* The 201 Facilities Planning/EIS process identified five alter-
W native sites for wastewater treatment facilities, all in eastern
Henrico County. After careful examination of all available information
and consideration of public input, the EIS concludes that two of the
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West Site.
D. EIS Conclusions
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alternative sites, Darbytown Road and Deep Bottom, are environmentally
M unacceptable. This determination is based on the social impacts which
would result from the relocation of local residents. It is EPA's
B position that because there are acceptable alternatives available, the
-_ relocation of residents is unnecessary. The other three sites, Deep
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Bottom West, Varina Farms, and Cornelius Creek, are environmentally
M acceptable.
A Although among these three sites there would, by necessity, be
a relative range of acceptability, it is the responsibility of the
M locally elected governing body to determine which of the acceptable
alternatives best meets the needs of the community. The Board of
Supervisors has reviewed the Final EIS and has resolved to maintain
jm their support for the Deep Bottom West Site. As this has been identified
as acceptable in the Final EIS, EPA is presently ready to approve federal
W funds for this site, pending resolution of this issue through the
development of a Memorandum of Agreement.
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II. Description of the Affected Properties
The proposed Deep Bottom West Wastewater Treatment Facility site
is located south of Kingsland Road, west of Fourmile Creek and east
and west of Deep Bottom Road in eastern Henrico County. Treatment Facil-
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ities are proposed for the 155 acre west of Deep Bottom Road; a sludge
fl landfill is proposed for the 300 acre area east of Deep Bottom Road.
The entire site is currently composed of twenty separate parcels and
^ is bordered by an additional fifty, fourteen of which are occupied by
« rural residences.
This proposed site is essentially the original proposed Deep
Bottom Wastewater Treatment Facility modified in order to avoid taking
residences along Deep Bottom Road, to avoid extensive areas of potential
gravity sewerage outside the County 1995 phasing line, and to avoid re-
I location of Deep Bottom Road. This was accomplished by splitting
the sites for treatment and landfill, locating the faciliites west
of the road and the landfill to the east.
B Approximately 50% of the facilities site is in agricultural use
«» and 50% is wooded. The entire 155 acres has been designated 'prime
agricultural' land by the Henrico County Future Land Use Plan, and
the western portion of the area is currently in agricultural pro-
duction (soybeans). The wooded or eastern portion of the facilities
area is in second and third growth pine/hardwood and young hardwood
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forest. It includes a patchwork of brushy hardwood and pioneer
species bordering the agricultural uses. This woodland habitat
supports a variety of animal species including game birds and
mammals. A man-made pond of approximately 1/8 acre is located
in the open field on the western portion of the facilities area
^ and is surrounded by brushy hardwood vegetation.
The presence of hardwood species such as sweet gum and sweet
| spices suggests soils on the plant site are poorly drained and
subject to flooding. Since older hardwoods on the plant site are
W characterized by slow growth and reduced vigor, soils in this area
may be nutrient deficient with respect to certain kinds of climax
vegetation. Slopes on the plant site range from zero to fifteen
percent and runoff is generally slow in the eastern and western
portions of the area. On the central portion of the site, soils
« may be subject to moderate or severe erosion hazard with rapid
runoff if vegetation is removed for construction.
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All of the 300 acre landfill area is wooded; vegetational types
J| range from successional woodlots to upland and bottomland forests.
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Most of the landfill area (above the thirty foot contour) has been
cleared at one or more times and is in various stages of recovery.
* An area to the east" of the landfill site consists of bottomland
fl forests bordered by a fresh water marsh in Fourmile Creek. This
portion of the site is within the Flood Prone Area identified by HUD
under the National Flood Insurance Program. The bottomland hardwood
_ forest is one of the most diverse terrestrial plant communities in the
Atlantic Coastal Plain. In addition to this diversity and the wild-
IB life population it supports, these areas act to control drainage to the
wetlands. The wetlands act as settling or filtering basins which collect
M sediments and other suspended material. Wetlands constitute a habitat
_ that is essential to waterfowl and numerous other aquatic and terrestrial
animals. Preliminary plans indicate this area, which falls below the
* 30 foot contour, will not be cleared or used.
Slopes in the area to be filled are shallow, ranging from 0-5%;
however, slopes below the 30 foot contour range from 10-20%. Existing
1 vegetation below the 30 foot contour should provide an adequate barrier
to construction-related erosion and siltation, if properly controlled.
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Erosion hazards from the landfill site appear slight to moderate unless
slopes below the 30 foot contour are cleared.
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Surrounding land uses include scattered rural residences, as
well as forested and agricultural lands. The projected facilities
and landfill will not be incompatible with forested or agricultural
M areas; compatibility with nearby rural residences will depend on
effective odor control and visual screening with vegetated buffers.
Henrico County has stated its willingness to relocate adjacent re-
fl sidents if they so desire. Responses at public meetings held by the
County indicate skepticism that adequate relocation assistance will
be made available. Fifteen to twenty residences occur directly or
_ nearly adjacent to the proposed site. Recent relocation studies con-
ducted in connection with the proposed routing of 1-95 through eastern
W Henrico County conclude that adequate local sale and rental properties
exist for necessary relocation (Federal Highway Administration and
J| Virginia Department of Highways and Transportation, 1977).
W Except for the slopes bordering Fourmile Creek to the east, the
site is designated as 'prime agriculture' by the Henrico County Future
Land Use Plan. This designation does not represent a violation of the
plan, but does represent a conflict regarding the compatibility of
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nearby land uses with a sewerage facility. The site's eastern slopes
I are designated as an 'environmental protection area' by the Plan;
use as a buffer would not conflict with this designation.
III. Determination of Effect
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The following determinations have been made utilizing the
Procedures For the Protection of Historic and Cultural Properties as
set forth by the Advisory Council on Historic Preservation (36 CFR 800).
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On May 11, 1978, EPA requested a determination of eligibility for
| inclusion in the National Register pursuant to the National Historic
m Preservation Act of 1966.
On July 14, 1978, the Keeper of the Register responded in two
parts:
J§ 1) The Deep Bottom West Site is eligible for inclusion in the
m National Register resulting from it's historic nature (site of a battle
fought during the Civil War) and identified historic archeologic
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features associated with the Civil War;
2) As requested by the State Historic Preservation Officer (SHPO),
a more detailed survey of certain prehistoric archeologic sites is
fl necessary prior to a determination of eligibility.
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As defined in 36 CFR 800.8, EPA has determined that the proposed
undertaking will have an effect on the property now eligible for in-
elusion in the National Register.
W In addition, the following has been established:
£ For Prehistoric Archeologic Resources; a determination of "No
» Adverse Effect" has been made based on the following grant conditions.
1 . A Phase II archeologic survey will be conducted on the five
sites as identified by the SHPO and the Keeper of the Register. On
4 completion of this work, all of the necessary information will be
forwarded to the SHPO and subsequently to the Keeper of the Register
for a determination of eligibility for inclusion on the National
Register.
2. No identified archeologic sites will be disturbed prior to a
determination of eligibility and the appropriate treatment of resources
*m has been made.
3. No identified archeologic sites will be disturbed for which
data retrieval or salvage is not an acceptable and appropriate treatment
of resources.
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For Historic Archeologic Resources (specifically, the Civil
War archeologic sites) : a determination of "Adverse Effect" has
been made. As will be discussed in Section V, EPA has proposed
certain specific grant conditions which it feels will satisfactorily
mitigate the adverse effect of the project and would permit the
£ execution of a Memorandum of Agreement.
IV, Avoidance of Adverse Effect
In the context of considering alternatives to the proposed action
which would avoid the adverse effect, the Final EIS identified two other
if acceptable alternatives; Varina Farms and Cornelius Creek.
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Varina Farms
As part of the Facilities Plan, a preliminary archaeologic survey
was conducted in June of 1977 to determine the existence and probable
9 significance of any prehistoric or historic artifacts. The conclusions
A of the survey included the discovery of three prehistoric sites; two
which were likely to be significant based on available data and location.
It was strongly recommended that a more detailed survey of the two sites
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be made.
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Based upon this information, it can be concluded that similar
coordination efforts would be necessary with the SHPO and Keeper
of the Register with no assurance that this site might be eventually
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determined to have any less adverse effect on historic or cultural
V resources than the Deep Bottom West Site.
Cornelius Creek i
Although this site offers some environmental advantages, the
location of a major Nabisco factory directly adjacent to this site
V significantly threatens the feasibility of this sites' implementation.
It is EPA's stated position in the EIS that certain special control
V measures could be introduced at the treatment plant which should prevent
m any anticipated adverse effects from effecting the operations of the
Nabisco bakery. However, noting the effect on the local economy and
employment should the factory be forced to relocate, and the most
probable prolonged negotiations and delays which would be anticipated
should this site be chosen, it would be highly advantageous for the
County to consider other, possibly more implementable, alternative
sites.
Thus, although certain alternatives to the proposed action are
available which would avoid the adverse impacts on the archeologic
resources of the Deep Bottom West Site, those sites similarly have
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serious obstacles associated with them which would, by necessity,
( consume substantial time commitments before they could be implemented.
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V. Mitigation of Adverse Effects
The proceeding mitigative measures have been developed in con-
sultations with the SHPO and the County of Henrico (the project
0 applicant). It is the opinion of these representatives and EPA
« that selection of the Deep Bottom Site for the treatment plant will
have two advantageous effects on the identified Civil War-related
archeologic sites:
fl 1. All but one of the sites will be located in the proposed
undisturbed buffer zone, thus afforded protection by their public
ownership and perpetual preservation, and;
2. The implementation of a park program which will make
publicly available a local educational resource.
As special mitigative measures, the following will be required
£ as grant conditions to the approval of the Facilities Plan and sub-
_ sequent Step II grant awards in addition to those grant conditions
previously mentioned in Section III (Prehistoric Archeologic Sites):
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_ 1. With the exception of Site Number 44 He 124, the sludge
disposal area will be restricted so that all of the identified
Civil War-related archeologic sites will remain in the undisturbed
buffer zone.
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2. Site Number 44 Hel24 will not be disturbed if data
retrieval or salvage is determined by the SHPO and Advisory Council
not to be an appropriate treatment of resources.
3. The southern boundary of the sludge disposal property shall
| be extended south to connect the sludge disposal property to the
M existing publicly owned boat launch with a minimum width of 40 feet.
4. The County shall prepare and implement a Park Plan to in-
' elude the following elements as a minimum:
I a. a graded path linking the identified Civil War-related
A archeologic sites with the existing boat launch on the James River.
b. four permanent trail markers at appropriate locations with
* narrative descriptions of the sites.
V c. a permanent marker at the path entrance from the boat
launch which in sufficient detail discussing the nature and significance
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of the area, persons associated with the area, and any other
appropriate information.
B d. a public information brochure describing the actions and
significance of the area, description of the path and other appro-
Q priate information suitable for distribution for local schools,
« libraries, tourist information centers, adjacent historical
parks, etc.
« 5. The County shall submit five copies of the Park Plan to EPA
within 120 days of the initial grant award. The Plan shall include
all of the information necessary for immediate implementation including
costs and time schedule for development.
EPA and the Advisory Council will review and comment on the Plan
within 15 working days from reception. Based upon the County's com-
plation of the preceding conditions, the Advisory Council and EPA will
A concur with the Plan. (It is understood that the County is responsible
for the development of, the Plan in accordance with these predetermined
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elements; thus, approval by EPA and the Advisory Council must be
based solely upon the satisfactory performance of these stated
elements. Conversely, the County must prepare the Plan in accord-
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ance with these elements in good faith; with the goal of developing
a viable, educational and implementable Plan). The concurrence of
the Plan by EPA and the Advisory Council will conclude the Memorandum
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of Agreement. Only after the conclusion of the Memorandum of Agree-
ment will EPA approve any Step II grant awards for any site-specific
contracts.
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APPENDIX ONE
OFFICIAL CORRESPONDENCE
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COMMONWEALTH of VIRGINIA
Virginia Historic Landmarks Commission
Virginia Research Center for Archaeology
Wren Kitchen
THE COLLEGE OF WILLIAM AND MARY
Wtlliamsburg, Virginia 23 1 86
October 26, 1977
MEMORANDUM
T0: T.F. Turner
FROM: W. M. Kelso, Commissioner
CT TT5 TpPT
Deep bottom 201 Facilities Plan
COMMENTS:
d There are no known archaeological sites affected by this project.
CS There are archaeological sues affected by this project.
CS Survey is necessary for adequate evaluation of archaeological resources affected by thii projec
& ADDITIONAL COMMENTS. T, +. L, < + ui-i-vi^.
There are two known premstoric archaeological sites located
jacent to the project area, as well a known sites of the Civil War period is located
within the project area. This location has excellent potential for the presence of
«ditional archaeological sites of the prehistoric and historic periods and there-
re should be surveyed prior to submission of the preliminary engineering report.
ap reference: J.F. Gilmer's "Richmond and Part of the Peninsula," 1364.) Please
fnd enclosed a list of educational institutions which have satisfactorily completed
rveys in the state.
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Wayne E. Clark
Martha W. M
c: Wayne Burgess, State Water Control Board
_ , , , Martha W. McCartney nu 804-253-4336
ror further information please contact rh.
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RICK HERMAN, CHAIRMAN
R DRT VICE CHAIRMAN
FH HvMAN
IILlBw 0 BUNQY JR
A HARRISON. Ill
.0 HAYNES
TH R HIGGINS
NICHOLS
N fUTHERLANO
COMMONWEALTH of VIRGINIA
Virginia Historic Landmarks Commission
February 6, 1978
TUCKER HILL
EXECUTIVE DIRECTOR
221 GOVERNOR STREET
RICHMOND, VIRGINIA 23219
TELEPHONE 786 3143
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Miss Helen Waldorf, Ecologist
Ecol Sciences, Inc.
127 Park Street, N.E.
Vienna, Virginia 22180
Re: Project #20-14
Sewerage treatment plant and attendant pipelines
Deep Bottom, Henrico County, Virginia
Dear Miss Waldorf:
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Mr. Tucker Hill has asked me to thank you for your inquiry of January 20. While
the Civil War associations of Deep Bottom may be of interest and some importance,
the staff of the Landmarks Commission believes that such associations would not
qualify Deep Bottom for the National Register of Historic Places. The Yarborough
House is of architectural significance to Henrico County and should be preserved
although our staff believes that it would, not be eligible for the National Register.
Because of its proximity to the proposed location of the sewerage plant, the
Yarborough House apparently would be affected by the facility, visually and other-
wise. Any pronouncements of possible National Register eligibility of archaeo-
logical sites at Deep Bottom must await our review of Mr. James Cleland's archaeo-
logical survey which should be available to us shortly.
I have discussed with you the Civil War breastworks at Deep Bottom and the
Tuckahoe Creek Canal in upper Henrico County as these would be affected by the
sewerage plant and a sewer line, respectively. A good many breastworks or earth-
works yet remain in lower Henrico County, but the number is dwindling as a result
of development. Ordinarily such structures would not qualify for the National
Register, unless associated with an important battle. We believe that the earth-
works at Deep Bottom would not qualify for the Register. Though, as the region
suburbanizes, hopefully as many Civil War earthworks as possible will be pre-
served concurrent with development. In that interest we would like to see the
breastworks at Deep 'Bottom either preserved or restored after contraction, where-
ever feasible. We have no immediate plan to nominate the Tuckahoe Creek Canal to
the National Register, but in order that the structure's integrity remain intact,
we would like to see the sewer line there buried beneath the canal bed,
I hope that I have adequately answered your questions.
Yours, * /
r>-^^^/ i^
Robert E. Swisher
Environmental Officier
RES/cw
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BeflS
ERH^HERMAN. CHA:PMAN
5 f»*ORT, VICE CHAIRMAN
4mflPbwMAN
VWUJAM D. BUNOY. JR.
) A. HARR5ON, III
R. HIGGINS
iRICX O. NICHOLS
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COMMONWEALTH o/ VIRGINIA
Virginia Historic Landmarks Commission
April 27, 1978
TUCKER HIU.
EXECUTIVE DIRECTOR
221 GOVERNOR STRECT
RICHMOND. VIRGINIA 23219
TELEPHONE 736-3143
Mr. E. R. Simmons, Director
Division of Construction Grants
P»t Office Box 11143
Richmond, Virginia 23230
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Re: Hsr.rico County 201 Facilities Plan.
Dear Mr. Sirninons:
Wwh regard to possible historical resources in the area of the proposed sewage treatment
plant at Deep Bottom in Henrico County, this office has completed its initial evaluation.
AM its meeting of February 21, 1978, the Register Committee of the Virginia Historic
L^dmarks Commission reaffirmed the Commission's long-standing policy of not registering
battlefields as landmarks, unless they are.the subject of on-site interpretation programs.
, archaeological resources would be the only basis for considering the area for land-
registration.
To determine the extent of the area's archaeological resources, a Phase I study (that is
aBreliminary assessment based on artifacts recovered from the ground surface and from
vBry small test pits) of the area was prepared by archaeologists at Virginia Commonwealth
University under contract with Henrico County. That study was submitted to the Landmarks
Cftmission for review. Because such a Phase I study is inherently an initial, cursory
sjfvey an^ not a definitive examination, this study should have been conducted in the
early planning stages for the treatment plant, so that any further testing or adjustment
oiconstruction plans could have been accommodated within the development of plans for
tB facility.
The Phase I report lists two archaeological sites that would be directly affected by
cBstruction of the sewage plant, eight sites adjacent to the construction area and
psibly affected, three sites within the proposed boundaries of the sludge dump area,
and thirty-five sites downhill from the sludge dump area and possibly by soil chemistry
cflln§es.~"~ Many sites date from the prehistoric period, many others from the eighteenth
aV nineteenth centuries.
Tjtt Phase I report, concurred in by the Landmarks Commission staff archaeologists, notes
tHt a number of the sites found may be eligible for the National Register of Historic
Places. The report and the Commission staff recommend Phase II testing of certain
within the area. Such testing through more extensive excavation work, will deter-
1. the extent and significance of the sites tested, 2. whether the sites are eligible
the National Register, and 3. necessary measures and costs for.mitigation of any
adverse effects from the proposed sewage treatment plant.
Csequently, upon recommendation of the Commission's archaeological staff, I request that
Phase II testing be conducted on the two sites directly affected by construction (sites
4fcte93 and 44H3102) and on the three sites within the proposed sludge dump area (sites
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>yr. E. R. Sinmons ,,-Director
April 27, 1978
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4tel23, 44Hel24, and 44Hel39). Upon completion of such testing, the final comments
of this office will be issued forthwith.
tker Hill
Executive Director
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EIS Preparation Section
EPA
The Honorable Clive L. Duval, 2d
Chairman, Henrico County Board of Supervisors
Mrs. Walter Lemon
Miss Helen Waldorf
Ecol Science, Inc.
Bill Kelso
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 111
6TH AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA 19106
In Reply Refer To (3IR60)
MAY 11 1978
Mr. William J. Murtagh
Keeper of the National Register
Heritage Conservation and Recreation Service
United States Department of the Interior
Washington, D.C. 20240
Dear Mr. Murtagh:
In accordance with the Advisory Council on Historic Preservation's
procedures (36 CFR 800), which implement the National Historic
Preservation Act of 1966, I am requesting that a determination of
eligibility for inclusion in the National Register be made by your
office regarding the following property. This site, being considered
for development by Federally-funded sewage treatment facilities, is
known as the Deep Bottom West Site.
The opinion of the Virginia State Historic Preservation Officer, Mr.
Tucker Hill, is enclosed. In addition, the archeological survey and
the Final Environmental Impact Statement (EIS) discussing this site
is Included. In the Final EIS, please note pages II-2 through II-4,
II-9, 11-10, III-4, V-6 through V-8, and Appendix d.
As you are aware, I am very concerned about any excessive delays which
could jeopardize the availability of State funds for this project.
I am aware of our responsibilities tc coordinate our project with the
Advisory Council on Historic Preservation (ACHP) should your office
make a positive determination of eligibility. In an effort to expedite
this total process, I am forwarding, the same enclosures to Amy Schlagel
(ACHP) for her information.
I understand Bob Pickett, of my staff, has been in contact with your
staff with regards to this issue already.
If you feel that a joint meeting of our respective offices could be
beneficial in defining the most expeditious roles in resolving this
issue, please contact Mr. Pickett by phorie (597-8337) and we will be
glad to set up the arrangements for a D.C. meeting.
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Sincerely yours,
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"George D. Pence, Jr.. Chief t^
Environmental Impact Branch
cc: Amy Schlagel, ACHF
Tucker Hill, SHPO
I Wayne Burgess, SWCB
Pat Brady, Henrico County
Taylor Turner, WWR
I Carl Mitchell, Ecol Sciences
James Cleland, UCU
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United States Department of the Interior
HERITAGE CONSERVATION AND RECREATION SERVICE
WASHINGTON, D.C. 20240
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IN REPLY REFER TO.
H32-NR
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George D. Pence Jr., Chief
Environmental Impact Branch
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Pence:
Thank you for your letter requesting a detsrmiration of eligibility
for inclusion in the National Register pursuant" to Executive Order
11593 or the National Historic Preservation Act of 1966, as amended.
Our determination appears on the enclosed material.
As you understand, your request for our professional judgment consti-
tutes a part of ths Federal planning process. We urge that this
information be integrated into the National Environmental Policy Act
analysis in order to bring about the best possible program decisions.
This determination does not serve in any manner as a veto to uses of
property, with or without Federal participation or assistance. Aay
decision on the property in question and che responsibility for
program planning concerning such properties lie with the agency oc
block grant recipient after the Advisory Council on Historic Preser-
vation has had an opportunity to comment,
We are pleased to be of assistance in the consideration of historic
resources in the planning process.
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Sincerely yours, /J /
William J. Murtagh V
Keeper of the National Register
Enclosure
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I B.
- DETERMINATION OF ELIGIBILITY NOTIFICATION
* NATIONAL REGISTER OF HISTORIC PLACES
OFFICE OF ARCHEOLOGY AND HISTORIC PRESERVATION
^HERITAGE CONSERVATION AND RECREATION SERVICE
St Submitted by: Mr. George P. Pence _ 'EPA _
ate request received: 5/16/78
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Of property:. Deep Bottom Site' State: Virginia
Hnn* Richmond vicinity
pjiion of the State historic Preservation Officer:
( ) Eligible { ) Not eligible ( ) No response
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h«Secretary of the Interior has determined that this property is:
( ) Eligible Applicable criteria:
mments:
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U) Not' eligible
CTmraents: "
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) Documentation insufficient (see accompanying sheet explaining
additional materials required)
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. Keeper of the National Register
Date: - WASO-m
9/75
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REQUEST FOR ADDITIONAL INFORMATION TO DETERMINE ELIGIBILITY
OF PROPERTY(S) FOR INCLUSION IN THE NATIONAL REGISTER
NAME OF PROPERTY DeeP Bottom West STATE Virginia
Description: Please locate and describe the sites (both historic and
archeological) in terms of their context in the local cultural-historical
framework and discuss the complete nature of the survey that identified
the properties. Please note, we are interested in the full range of historic
and archeological resources, including not only the prehistoric sites, but
also the 19th century historic sites. Appendix 3, which was left out of
the submission sent to us, may provide some of this information.
Statement of Significance: Please discuss the significance of the full range of
the resources in terms of specific research and interpretive potential for all
the sites, historical as well as archeological.
Bibliography: Please provide a bibliography that refers to all the disciplines
that are involved in the resource evaluations.
Geographical Data Acreage: Please provide for each of the sites and for the
entire complex.
UTM Reference(s):
Verbal Boundary Description: please provide for all the sites.
Photographic Coverage:
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Map Coverage: Please provide for all the sites and please provide an overall map
that shows the sites in regional context.
Other: 'We are concerned that the archeological and historic survey was not designed
to identify the full range of historic properties within the project area. It
must be recognized that the National Register considers not only unusual sites
but also sites representative of the history and development of an area. Hence,
"common sites" may also be considered eligible. Statements on pages 4 and 5 (con't)
Questions concerning additional information may be directed to Lucy Franklin or
Sarah Bridges
on the National Register staff, telephone 202-523-5483
Thank you for your attention to the above items.
Keeper of the Rational Reg/ister
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E.G. SHEET CONTINUED;
of the survey report and in the appended research proposal indicates a
possible bias in the approach against historic period sites, in particular,
the Black Civil War site. The Federal agency is responsible for the identi-
fication and evaluation of all historic and archeological resources, not
just those that are of interest to the individuals conducting the research
for the agency. Pursuant to our conversation of June 2 with Mr. Bob Pickett
of Region III, the National Register staff will continue to coordinate the
gathering of historical information with historians from a local university.
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In Reply Refer To (3IR60)
JUN
1978
Lucy Franklin
Office of the National Register
Heritage Conservation and Recreation Service
Department of the Interior
Washington, D.C. 20240
Dear Lucy:
In order to expedite the archeologic and historic review of the
"Deep Bottom West" sewage treatment plant site, I am forwarding
the Appendix 3 of the Archeological Survey to you. The author
has requested this not be released for public review due to
security purposes.
Sarah Bridges read your office's letter to me which requests
additional information from EPA. This Appendix 3 is all of the
additional information available to EPA at this time. In response
to certain specific requests, an aerial photo of the area is an
page II-5 of the Final EIS (which you have) and a bibliography
of references is on page 22 of the Phase I archeological survey
which you also have.
This document and my letter is our response to your office's
request. Therefore, I will assume that your review will continue
when this is received.
I do appreciate your involvement in this project. Understanding
that we both don't want to further delay this project, I urge
you to call me if you have any further needs.
Sincerely yours,
Robert W. Pickett
EIS Preparation Section
Enclosure
cc: Amy Schlagel, ACHP
Tucker Hill, S11PO
Wayne Burgess, SWCB
Pat Brady, Henrico County
James Cleland, VCU
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United States Department of the Interior
HERITAGE CONSERVATION AND RECREATION SERVICE
WASHINGTON, D.C 20240
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IN REPLY REFER TO.
H32-NR
ib/8
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Mr. George D. Pence Jr.
I' . Chief, Environmental Impact Branch
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Pence;
Thank you for your letcer requesting a determination of eligibility
for inclusion in the National Register pursuant to Executive Order
11593 or the National Historic Preservation Act of 1966, as amended.
Our determination appears on the enclosed material.
As you understand, your request for our professional judgment consti-
tutes 3. part of the Federal planning process. We urge that this
information oe integrated into the National Environmental Policy Act
analysis in order to bring about the best possible program decisions.
This determination doss net serve in any manne'r as a veto to uses'of
property, with or without Federal participation or assistance. Any
decision on the property in question and the responsibility for
program planning concerning such properties lie with the agency or
block grant recipient after the Advisory Council on Historic Preser-
vation has had an opportunity to comment.
We are pleased to be of assistance in the consideration of historic
resources in the planning process.
William J. Murtagh
Keeper of the National Register
Enclosure
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ITTTB /f^s -fl
E.O.I
| DETERMINATION OF ELIGIBILITY NOTIFICATION
- NATIONAL REGISTER OF HISTORIC PLACES
OFFICE OF ARCHEOLOGY AND HISTORIC PRESERVATION
I HERITAGE CONSERVATION AND RECREATION SERVICE
Request submitted by: Mr« George Pence _ EPA _
qu
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)ae request received: 5/16/78 additional information received 6/9/78, 6/20/78
laBe of property: Peep Bottom Site _ State -.Virginia
.OCati on : Richmond vicinity
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3pinion of the State I'istoric Preservation Officer:
| ) Eligible ( ) Not eligible ( ) No response
tOimnents: " (It is) the Conmiission's long-standing policy Of not registering
ex vation
The Secretary of the Interior has determined that this property is:
Eligible Applicable criteria: A, B, c, and D
omments:, Please see attached comments.
C
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) Not -l igibl e
ftomments:
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( ) Documentation insufficient (see accompanying sheet explaining
I additional materials required)
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m &-&££] Keeper of the National Register
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The Deep Bottom West site, made up of 106, 108, 110, 111, 112, 112a, 113,
114, 115, 116, 117, 124, 125, 126, 127, 128, 129, 130, approximately
500 acres in which is located the EPA sewage treatment plant site,
is the important historical site of a battle fought during the Civil
War in July 1864. Four Black regiments withstood an assault at this
site and Major Thomas Hawkins received the Medal of Honor for
rescuing the regimental flag during this campaign. Thus, because
of this site's association with important historical events, trends,
and individuals and because of the structural and archeological
remains of this site, it has been determined that it is eligible for
listing in the National Register under criteria A, B, C, and D.
This determination includes the entire historic site identified in
the documentary records and the archeological features associated
with this Civil War site located during the preliminary reconnaissance.
We note that Mr. Tucker Hill, Virginia State Historic Preservation Officer,
asks for additional information on archeological sites 44He98, 44Hel02,
44Hel23, 44Hel24, 44Hel39, because they are in the areas of direct
impact. Therefore, we ask that you provide the SHPO with the descrip-
tive and significance information that we outlined in our letter of
June 9, 1978, for those sites which may be affected after you have
conducted the more intensive survey recommended by Mr. Hill and request
Mr. Hill's opinion on the eligibility of these sites. Subsequent to
the receipt of Mr. Hill's opinion, please send us the full documen-
tation on this site, including the additional descriptive, contextual,
and significance data and the SHPO opinion letter so that we may give
you our determination of these sites' eligibility.
We understand from Mr. Robert Pickett of your office that the final
design of the facility has not been approved and that there is some
possibility the final design may avoid some or all of the 43 other
identified historic and prehistoric archeological sites. We await
your final decision and look forward to reviewing the complete docu-
mentation on those sites which may be within the area of probable
impact so that these properties may be afforded appropriate treatment
during the course of your project planning. If we may be of additional
assistance, please do not hesitate to call either Sarah Bridges or
Lucy Franklin of the National Register staff.
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