Final EIS Supplemental Information
Wastewater Treatment Facilities
For Henrico County, Virginia
U.S. Environmental Protection Agency
Region III • Philadelphia, Pa.
March 20, 1978
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IV. Description of the Applicant's
Proposed Wastewater
Treatment Facilities
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IV. DESCRIPTION OF THE APPLICANT'S PROPOSED WASTEWATER TREAT-
MENT FACILITIES (Deep Bottom West)
A. DESIGN SEWAGE FLOWS
In keeping with a directive from the Governor of Virginia,
population projections developed by the Office of Planning
and Budget (OPB) must be used as the basis for projecting
future sewage flows. Population projections for Goochland and
Henrico Counties are reviewed in the Draft EIS, Section V-A.
Projections for the Mechanicsville area of Hanover County are
based on assumptions in the Hanover County 201 Facilities
Plan and on data from the Hanover County Department of Public
Utilities.
Projection of future sewage flows is necessary to select
appropriate treatment plant and transportation system capaci-
ties. A design period of 25 years (2005) was selected for the
treatment plant; design periods of both 25 years and 50 years
(2030) were compared to select the most cost-effective waste-
water transportation system.
Sewage flow consists of four basic components: domestic
contributions, industrial flows, commercial flows, and that
volume of water associated with infiltration and inflow (I/I)
to sewer lines. Domestic flows are projected on the basis of
service populations: the number of individuals receiving
sewer service. Therefore, projected populations must first
be modified to reflect the percentage expected to receive ser-
vice in the projection year. Following this, a per capita
flow allowance, measured in gallons per capita per day (gcd)
is applied to these service populations. Industrial, commer-
cial, and I/I flows can be estimated in many different ways.
Often, industrial and sometimes commercial flows are estimated
separately, then converted to "equivalent populations."
These equivalent populations are then added to service popula-
tions and a per capita flow allowance is applied to the total.
I/I may be based on per capita flow allowances, the size of
the sewerage system, or measured directly in an I/I study.
1. Engineer's Projections
For the purpose of this project, Wiley & Wilson and
Royer (1977) based predictions of flow on two approaches:
one for sizing the treatment plant for 2005; and another
for sizing the transport system for 2005 and 2030. The
projections and flows that resulted are summarized in
Table IV-1. The methodologies used are given below.
In order to calculate wastewater flows in relation to
individual drainage areas, total Henrico County projected
populations for 2005 and 2030, generated from OPB esti-
mates were distributed over the County by census tract
by Wiley & Wilson and Royer (1977) . The distributions
used were previously developed by the Henrico County
IV-1
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Table IV-1. Equivalent Populations and Flows used in Plant and Transport System Design.
Design Year
Estimated Populations Service Population
Equivalent Commercial Pop.
Equivalent Industrial Pop.
Plant Design Total Equivalent Population
(Service & Industrial)
Projected Flows (@ 100 gcd)
(mgd)
H
(Service, Commercial and
Industrial)
Project Flows (@ 100 gcd
x 2.5) (mgd)
Design Year
Estimated Populations Service Population
Equivalent Commercial Pop.
Equivalent Industrial Pop.
Transport System Design Total Equivalent Population
(Service, Commercial and
Industrial)
Projected Flows (@ 100 gcd
x 2.5) (mgd)
Henri co Hanover
2005
230,138 36,875
30,170
13,698
243,846 35,875
24.4 3.7
274,006 36,875
68.5 9.3
2030
292,919 54,000
39,481
18,336
350,736 54,000
87.8 13.5
Total
Service
Goochland Area
5,510 272,523
-
- -
5,510 286,231
.6 28.7
5,510 316,391
1.5 79.3
6,800 353,799
-
— —
6,800 411,616
1.8 103.1
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Planning Office, based on the adopted Land Use Plan and
Phasing Plan. Distributions developed in relation to the
county's 1995 and 2020 projections were used as fitting
most closely to the 2005 and 2030 projections, based on
OPB's work. In all cases, totals of the resulting figures
corresponded to within three percent of the OPB-based
projections. Residential densities were determined for
each census tract by dividing the total projected popula-
tion by the total amount of residential land on the adopted
Land Use Plan. Drainage area maps were then placed over
the census tracts. Adjustments were made and projections
developed for future residential populations within each
drainage area. These populations were then adjusted to
reflect percent sewered, to yield projected service popu-
lations. This was done on the basis of discussions with
the Henrico County Planning Office. Judgments were based
on current development patterns and future trends.
Projections of service populations for Hanover County's
service area were based on growth assumptions in Hanover's
201 Facilities Plan and on a base population and predic-
tions of percent-connected provided by the Hanover Depart-
ment of Public Utilities.
Projections of service populations for Goochland
County's service area were based on the assumption that
all development will be connected as it occurs. This is
because Goochland soils are largely inappropriate for
leaching fields.
To obtain projections of the industrial equivalent
population for Henrico County, existing industrial flows
were related to existing industrial acres to obtain a
measure of existing industrial flow per acre. Wiley
& Wilson and Royer (1977) then related existing indus-
trial acres to total existing population. These relation-
ships were assumed to remain constant and, on the basis
of total project populations, industrial flows were pro-
jected for 2005 and 2030. These flows were then divided
by per capita water usage to yield projections of equi-
valent industrial populations.
Using this same methodology, commercial flows were
estimated for each drainage basin. This operation was
performed to insure that proposed pipe sizes were large
enough to handle additional flows from areas of concen-
trated commercial development. These additional com-
mercial flows were not included in the determination of
sewage treatment plant capacity.
A preliminary I/I analysis by Wiley & Wilson and
Royer concluded that excessive I/I was not present. This
conclusion was based on the fact that average sewage flows
were 99.7 gcd (Siegrist, 1975). Virginia State Water
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Control Board regulations prohibit designing a plant with
a capacity of less than 100 gcd. The engineer reasoned
that it would not be cost-effective to reduce the flows
since the plant would be designed for 100 gcd regardless.
No I/I component was added to the flow projections since
it was assumed to be included in the 100 gcd.
The total equivalent population was based on the sum
of the projected sewered population and the industrial
equivalent population. A flow allowance of 100 gcd was
used for calculating plant capacity- In estimating flows
for the transport system design, a peaking factor of 2.5
was used.
B. WASTEWATER TRANSPORTATION SYSTEMS
1. Western Henrico County
The transportation system for Western Henrico County
is presented in Figure IV-1.
Wastewater will be pumped from an expanded Tuckahoe
Creek pumping station to the Gambles Mill pumping station.
Force mains will be routed south along the old railroad
bed to the Chesapeake and Ohio Railroad Tracks. The route
will follow the north side of the railroad tracks and
cross under the Kanawha canal in the vicinity of Bosher's
Dam. It will continue between the railroad and the canal
and cross the canal a second time below the Huguenot
Bridge. From this point, it will follow the south side of
Huguenot Road to the Gambles Mill pumping station.
Additional flow from the remainder of western Henrico
County will be served by the Gambles Mill pumping station.
A new force main will be constructed from this station to
Patterson Avenue where gravity sewers will take the
pumped flow along Horsepen Branch to intercept flow from
Upham Brook at Staples Mill Road.
2. Mid-eastern Henrico County
The proposed transportation system for mid-eastern
Henrico County is presented in Figure IV-2 and is divided
into four segments. A force main will be routed from the
Beulah Road pumping station through the Richmond Municipal
Airport and then along the Chesapeake and Ohio Railroad
to the Fort Lee area. A second segment will be routed
from the Gillie Creek pumping station across Zanes Lane to
Brittles Lane. This route will follow Brittles Lane south
to Charles City Road and then follow Charles City Road east
to Fort Lee. A third segment is to serve the Highland
Springs area; it will extend approximately two miles east
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XS Existing Wattewater Pumping
v Station
Q Existing Wastewater Pumping
Station to be Abandoned
^. Existing Wastewater Pumping
^^ Station to b* Expanded
im Proposed Wotttwaltr Pumping
Station
+ + Existing Gravity S«w*r
44 Existing Fore* Main
— Proposed Gravity S«w»r
. ,, Proposed Force Main
FIGURE IV-1*. WESTERN HENRICO COUNTY WASTEWATER
TRANSPORTATION.
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Existing Wostewotsr Pumpin9
Station
Q Existing Wastewater Pumping
Station to be Abandoned
^^ Existing Wastewater Pumping
^^ Station to bs Expanded
mm Proposed Wastewater Pumping
Station
• • • Existing Gravity Sewer
+ + Existing Force Main
—— Proposed Gravity Sewer
Proposed Force Main
MID-EASTERN HENRICO COUNTY WASTEWATER
TRANSPORTATION.
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of the hills bordering the southern flood plain of the
Chickahominy River, picking up effluent from four existing
pump stations. The gravity line ends at Broadwater Creek,
where a pump station will be constructed to force main
the flow approximately one mile south, up the valley of
Broadwater Creek to an existing sewage treatment facility
and pump station. Existing force mains will then connect
this segment to the Strawberry Hill pumping station. From
here the route follows a power-line right-of-way to the
1-64 interchange. The line then follows the western side
of South Laburnum Avenue to Charles City Road.
3. South-eastern Henrico County
Most of the proposed south-eastern Henrico County
transportation system varies with the choice of the
treatment facilities site. For this reason, these systems
and their impacts are examined in Section II, Proposed
Treatment Plant Site Profiles. Only that portion of the
proposed south-eastern transportation system which is
common to all sites is described here. For a diagram of
this line segment, refer to site-transportation figures
in Section II. This common segment is to service two
existing schools, Baker Elementary School and Varina High
School, as well as a third school under consideration nearby
for the eastern side of Laburnum Avenue. A gravity sewer
will extend south from Baker School, across Wilson Road,
where it will follow Cornelius Creek to cross under Labur-
num Avenue, until it crosses under Virginia Route 5. A
short spur from Varina High School will enter approximately
midway along this segment. The line will leave Laburnum
Avenue, turning south along Cornelius Creek for approxi-
mately two thousand feet until it meets a pump station.
This pump station will be constructed on the flood plain
at a point where an unnamed tributary enters Cornelius
Creek from the west. From this point, a force main is to
extend one thousand feet up-this tributary to Route 5
where various site-related transport alternatives begin.
4. Goochland County
The wastewater transportation system for Goochland
County is presented in Figure IV-3, and has three segments.
One segment of interceptor originates immediately south
of the James River Estates at a pumping station and con-
nects to a private drive leading to Cherotuck Nursery.
The next segment runs from this private drive south of
the pond and along the tributary to Tuckahoe Creek to
the pumping station on Tuckahoe Creek and then into the
Henrico County line. In the third segment, a gravity
sewer will originate in the vicinity of Pagebrook and
follow an unnamed tributary north-northeast to Tuckahoe
Creek, cross Tuckahoe Creek and connect to an existing
gravity sewer in Henrico County.
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(
••
/'\ "? —>*-i -^^-^^^/^«^r{
i ) i / ( o / \ / A ^ \ \
^ ^ x-^ ' i •/ ' V ' ^
) •*""' Ji A ^
Existing Woft«v«at«r Pumping j^ \ ^*f \ *^^^ V-, ^
$,„!.„ , r^\/ /"\—v i \
Proposed Wai>*war«r Pumping J \. Vuf I \ ^^ ^ ^^
Srorion * \ ^"--v \ \ \
Proposed Gravity S*v*«r
Propo*#d Fore* Main
Existing Gravity 5*w*r
•.
1
x/
J
FIGURE IV-3. GOOCHLAND COUNTY WASTEWATER TRANSPORTATION.
IV-8
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5. Hanover County
The Strawberry Hill Pumping Station will provide ser-
vice to Hanover County. This portion of the system was
evaluated as part of Hanover County's Facilities Planning
Process.
C. TREATMENT PLANT SITE
The final choice of a treatment plant site remains the
major unresolved issue related to the proposed action. Although
the Cornelius Creek site has been identified in the EIS as the most en-
vironmentally desirable site, the applicant's proposed site; Deep Bottom
West, has also been determined to be environmentally acceptable. For this
reason, profiles of all five sites are given in Section II. As
noted in Section III, the selection of the Deep Bottom West site
is subject to a thirty day public comment period and subsequent
Virginia State Water Control Board and EPA approval.
D. WASTEWATER TREATMENT PROCESS
The preliminary designs for the final treatment alterna-
tives are as follows:
1. Preliminary and Primary Treatment will consist
of course screening, fine screening, comminution
and flow measurement. Primary treatment will
consist of two grit removal units, four 110 foot
diameter primary clarifiers and a primary sludge
pump station.
2. Secondary Treatment by air activated sludge. This
system will consist of two 155 ft. square aeration
basins, each equipped with six 125 HP aerators, four
135 ft. diameter secondary clarifiers and a return
sludge and waste sludge pump station. The system will
be the same for aerobic or anaerobic digestion.
3. Sludge Conditioning and Dewatering. Air activated
sludge with aerobic digestion will be used for sludge
conditioning. This system requires two aerobic
digesters that are 155 ft. by 155 ft. and are equipped
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with four 125 HP aer.ators, and will produce approxi-
mately 54,000 Ibs. per day of dewatered solids at a
concentration of approximately 20% dry solids for
disposal. Vacuum filters will be utilized for de-
watering the sludges.
E. DISINFECTION
Virginia regulations (SWCB, 1975, Section 27.02) require
that all sewage treatment plant effluents be adequately dis-
infected prior to discharge. Chlorination was chosen for
disinfection.
Chlorination equipment would be required to have suf-
ficient capacity to maintain a chlorine residual of 2.0 mg/1
in the final effluent at peak flows; a capacity of 8 mg/1,
based on design average flow, is recommended for activated
sludge plants (SWCB, 1975, Section 27.03.01). A conservative
design capacity of 10 mg/1 at an average daily flow of 29 mgd,
or about 2400 Ib/day was selected for evaluation. A system
of dechlorination with SC>2 followed by aeration, proposed
for this method, will be highly effective in preventing
acute chlorine toxicity in the James River.
F. EFFLUENT DISPOSAL
The effluent will be discharged into the James River.
The quantity and quality of effluent which can be discharged
is regulated by the State Water Control Board. A mathematical
model of the James River is used to predict the effects of
discharges on water quality, and limitations are established
that will not cause water quality standards to be violated.
A description of this model is beyond the source of this re-
port, but can be found in Special Report No. 41 (SWCB).
An outfall located in Segment 16 (mile 93.0 to 94.4)
would be allowed to discharge 5,000 Ibs/day or BODs. The
James River in this segment follows a straight channel with no
cutoffs or major backwaters, and is not expected to present
problems in mixing the effluent. The 201 Facilities Plan
recommends Segment 16 as the discharge point. However, the
mathematical model used to estimate the assimilative capacity
of the James River has changed and new river segment numbers
have been assigned. For this reason, Old Segment 16 now cor-
responds to New Segment 24.
G. RESIDUALS DISPOSAL
The proposed facility will produce 23,000 to 54,000 Ibs.
of dewatered sludge per day at 20% concentration. Sludge
will be transported by truck from the facility to a 300 acre
site east of Deep Bottom Road where standard sanitary land-
fill operations will be employed.
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Measures will be taken to prevent groundwater contamina-
tion. Operating in an area of about one acre at a time, the
site will be cleared and soil removed to a depth of about
8 feet. An impermeable layer of soil cement, impacted clay
or other appropriate material will be installed and the area
will be drained by a small pump station and system of pipes
laid on porous material, over the impermeable barrier. Layers
of soil and sludge material will be placed on top of the
drainage network and, when filled, the area will be covered
with fill which will be compacted to avoid percolation
through the landfill. Grass species or fast growing pines
will be planted on completed sections. Any leachate drained
from the land fill will be transported to the wastewater
treatment facility and reprocessed. Monitoring of groundwater
will be conducted to detect contamination as a safety measure.
Although landfill of sludge has been the proposed method
of final disposal by the applicant, recent advances in tech-
nology require a reconsideration of raw sludge composting
as a viable alternative. This issue is discussed in more
detail in Section III, EIS Recommendations and Conclusions, and
required for consideration during Step Two of facilities planning.
IV-11
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V. Environmental Evaluation
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V. ENVIRONMENTAL EVALUATION
A. ENVIRONMENTAL IMPACTS AND MITIGATING MEASURES OF THE
APPLICANT'S PROPOSED PROJECT
Environmental impacts identified as associated with the
construction and use of the Deep Bottom West treatment
facility, landfill and transportation corridors are identified
below. In each case impacts are listed under the appropriate
subcategory and are followed by mitigating measures.
1. Surface Water and Erosion
a. Impacts:
• removal of two package wastewater treatment
plants from operation and associated improve-
ment in treatment reliability;
• the new facility will bring Henrico County's
wastewater discharges into compliance with
effluent limitations designed to protect water
quality in the James River;
• accelerated erosion and sedimentation of Roundabout
Creek from clear-cutting and construction activi-
ties, particularly on the central and southern
portions of the site;
• potential erosion and subsequent sedimentation
in numerous intermittent and permanent streams
from sewer line construction. These will include:
Tuckahoe Creek, Deep Run, Oldhouse Branch, Cabin
Branch, Upham Brook, Turner Run, Horse Swamp
Creek, Cornelius Creek, Fourmile Creek,
Roundabout Creek, and Gillie Creek;
• somewhat accelerated erosion and sedimentation
of Fourmile Creek from landfilling operations
east of Deep Bottom Road; and
• clearing of steep slopes adjacent to the Chespeake
and Ohio right-of-way will cause severe erosion.
b. Mitigating Measures
Local erosion and sedimentation controls are
authorized by Title 21, Chapter 1, Article 6.1, Sections
21-89.1 et. seq. of the Code of Virginia. Ordinances
to controT erosion and sedimentation under this enabling
law have been adopted by Henrico County; these became
applicable to public utility construction on July 1,
1977. An erosion and sedimentation control plan will be
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submitted to the Henrico County Department of Public
Works for approval prior to construction. Numerous con-
ventional erosion and sedimentation control techniques
will be applied, including but not limited to:
• siltation check-dams in stream beds;
• buffer zones between stream beds and floodplain
sewer routes;
• berms and filtering devices such as hay bales
and netting between sewer routes and streams;
and
• perimeter dikes and sediment retention basins
to intercept runoff from site and corridor
construction areas allowing sediment to settle
out before entering surface waters.
These mitigating measures are appropriate to all
construction sites and sewer corridors. Actual design
requirements for stream crossings by sewer lines are
given in the February, 1977, Virginia Sewerage Regula-
tions, including minimum rock cover, pipe seals, and
so forth. In addition, the section of gravity sewer
extending parallel between Laburnum Avenue and Cornelius
Creek should stay as close to the shoulder of Laburnum
Avenue as topography will allow, to avoid impacts on
stream quality in Cornelius Creek.
2. Groundwater
a. Impacts:
• potential contamination of groundwater due to
landfilling operations.
b. Mitigating Measures:
• appropriate techniques for lining landfill
areas and draining leachate for retreatment will
be utilized to avoid contamination of ground-
water and Fourmile Creek (refer to Section IV-G,
Residuals Disposal).
3. Natural Resources (wetlands, agriculture, vegetation
and wildlife)
a. Impacts:
• increase in siltation of a large area of wetland
below the landfill site;
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• short-term increased erosion and sedimentation
to three ponds adjacent to the pipeline corri-
dor;
• disturbance of a beaver community and possible
disruption of feeding waterfowl adjacent to the
area;
• disturbance of approximately 6 to 6.5 miles of
stream valley vegetation by sewer corridor
construction including removal of both stream-
bank and mature hardwood vegetation;
• clearing of vegetation types ranging from young
successional woodlots to more mature upland and
bottomland forests along transmission corridors;
• removal of 150 to 170 acres of young pine/
hardwood vegetation and subsequent loss of
suitable wildlife habitat;
• disruption to heavily vegetated, steep slopes
along the north bank of Kanawha Canal;
• occupation of 455 acres of land designated
'prime agriculture1 by the county, 40 of which
are now in active cultivation; and
• occupation of 160 acres of soils designated by
the U.S. Soil Conservation Service (SCS) as
prime agricultural. Unlike Henrico County's
Future Land Use Plan category 'prime agriculture1
which defines the intent of the County but not
necessarily the capability of soils, this SCS
category is based on soil quality. Primary
factors considered are the soil's limitations
for crops, the risk of these uses damaging the
soils, and the way soils respond to management
and treatment. In this case, on a 455 acre site
in an area intended by planning for use as prime
agriculture, 160 acres are actually prime agri-
cultural soils as defined by the SCS.
b. Mitigating Measures:
• landfill operations should be restricted to areas
above the thirty-foot contour as indicated in
preliminary plans to maintain the integrity of
bottomland hardwood and marsh communities and to
avoid floodplain areas; the boundaries of the
"Special Flood Hazard Area" extend above the
thirty-foot contour at one point (see Figure II-2)
This boundary, established by HUD under the
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National Flood Insurance Program, should be
investigated during Step II as it applies to this
point; if this boundary proves to be accurate
where it extends above the thirty-foot contour,
landfill areas should remain outside of this
area ;
• in order to preserve the wildlife corridor
function of the unnamed tributary of Fourmile
Creek which borders the southern edge of the
landfill, all operations should be confined to
the area north of this stream;
• removal of large hardwood trees along the banks
of Roundabout Creek should be avoided wherever
possible;
• whenever possible during vegetation removal for
interceptor construction, larger pines should be
cut, in lieu of mature, vigorous hardwoods;
• in order to avoid disturbance of beaver habitat
and to minimize removal of larger hardwood
specimens, a qualified biologist should be in-
cluded in interceptor survey operations on the
section from Varina Road north three-quarters
of a mile.
Aesthetics, Public Health and Safety
Impacts:
• construction in residential areas will have
short-term impacts upon local traffic and result
in noise, dust and potential safety hazards;
• temporary disruption of ingress and egress to
business along Charles City Road during con-
struction;
• disruption of traffic and access to commercial
properties along Laburnum Avenue;
• disruption of parking, traffic and landscaping
at the Henrico Arms Townhouses;
» negative visual impact on users of Kingsland
Road and Deep Bottom Road; and
• negative visual impact at two points on Segment
13 (Engineer's Selected Plan) where the gravity
inflow sewer to the plant will utilize short
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portions of aerial sewer to maintain grade while
crossing streams. One crossing occurs over an
unnamed stream tributary to Fourmile Creek approxi-
mately 1/3 mile north of the sewer's crossing of
Route 5; this portion will not be visible from
the highway. The second crossing occurs over
another unnamed tributary of Fourmile Creek near
the stream's crossing of Buffin Road one mile
south of Route 5; this portion may be visible
from Buffin Road, especially during winter
months.
b. Mitigating Meaures:
• damage to existing landscaping will be minimized
by laying sewer pipe in the road, or as close to
the paved right-of-way as possible;
• maintenance of a 200 foot wooded buffer strip
along Deep Bottom, Kingsland Roads, using existing
planted trees.
5. Recreation
a. Impacts:
• potential short-term disruption of the Oak Hill
Country Club Golf Courses during construction;
• foreclosure of recreational uses of 455 acres of
currently open space;
• potential disruption of C. F. Baker Nature Trail
behind Baker School;
• temporary disruption .of the Guthrie Street Trail
will result in loss of established ground cover;
• crossing of the historic Tuckahoe Creek Canal Bed
has the potential for foreclosing future passage
of recreational boats;
• negative impact on users of Deep Bottom Boat
Landing due to simultaneous use of Deep Bottom
Road by car-towed boat trailers and trucks trans-
porting sludge to the landfill site. In addition,
Deep Bottom Boat Landing may be expanded by the
county. Although this possible expansion is not
in conflict with the proposed landfill site
(LaVecchia, 1977), increased future use may
exacerbate any traffic problem on Deep Bottom
Road; and
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• if soils are left bare of vegetation for a lengthy
period of time, erosion and nutrient loss may en-
courage regeneration in brushy/hardwood vegetation.
On some sections of the construction corridor this
effect may be incompatible with future recreational
use as a hiking trail.
b. Mitigating Measures:
• locate the beginning of the gravity sewer ser-
vicing Baker School along the edge of the open
field to avoid the nature trail behind the school;
• pursue multiple-use concepts in planning for the
treatment plant site and sewer corridors (refer
to Section III);
• accomplish construction of a landfill access road
from the treatment facility perpendicular to Deep
Bottom Road as soon as possible to avoid use of
Kingsland or Deep Bottom Road by these vehicles;
• curtail use of Deep Bottom Road by construction
vehicles and sludge trucks on weekends during
warm-weather months; and
• limit exposure of bare soils to a minimum amount of
time on each section of transportation corridor
construction.
6. Historic and Archeological Resources
a. Impacts:
• occupies a battlefield where black soldiers fought
during the Civil War. The site has been suggested
for the National Register of Historic Places by
a local citizen; however, the Virginia Historic
Landmarks Commission (VHLC) has determined that
the site is not eligible (1978). For this deter-
mination, see Appendix D;
• destruction of breastworks surviving from the
Civil War period at the landfill site;
• potential odor and visual conflicts due to con-
struction and operation of the facilities near
the historic Yarborough House. The VHLC has
determined that, while the house has architec-
tural significance and should be preserved, it
is not eligible for the National Register of
Historic Places (1978) ;
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• excavation and construction on a site with known
archeological sites of undetermined significance;
• potential disruption of three archeological sites
by sewer corridor construction:
- Indian site HE 17 at River Road
- Lorraine railroad station at Route 157
- Westham railroad station at Route 147 and
Huguenot Memorial Bridge;
• possible damage to unprotected historic breast-
works by sewer corridor construction at four
points; and
• disruption of the historic Tuckahoe Creek Navi-
gation Canal where the route of a force main is
to cross the canal.
b. Mitigating Measures
In order to comply with Section 106 of the Historic
Preservation Act of 1966, the comments of the office of
the Virginia State Historic Preservation Officer have
been included in Appendix D. The following measures
have been initiated to mitigate possible adverse impacts
of the project:
• a Stage 1 archeological survey of the Deep Bottom
West Site is now underway, and should be completed
by late February, 1978. Subsurface testing and
surface reconnaissance will identify potentially
significant archeological sites;
• when the above mentioned study is completed, the
State Historic Preservation Officer will utilize
its findings and existing information to recom-
mend any necessary actions; these could include
mapping and/or excavation of artifacts of his-
toric or archeologic significance prior to project
construction and landfill excavation. Certain
areas of on-site breastworks may also be recom-
mended for restoration following initial con-
struction. Such excavations and restoration are
eligible for 75% EPA funding up to 1% of the
total project cost;
• the transmission force main will be placed under
Tuckahoe Canal by tunneling procedures;
• breastworks disturbed by sewer corridor con-
struction will be restored following construction
operations;
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• standard procedures using wooded buffers and
noise and odor controls will mitigate all signi-
ficant impacts on the Yarborough House; and
• recommendations of citizens and the VHLC con-
cerning the historical significance of the Deep
Bottom West site will be forwarded to the Advisory
Council on Historic Preservation for final
review.
7. Flooding
a. Impacts:
• "Special Flood Hazard Areas" (identified by HUD
under the National Flood Insurance Program) are
located in the eastern portion of the proposed
landfill site (see Figure II-3). In the event a
flood should occur while active landfilling is
underway in this portion of the landfill site,
disruption of operations and surface water con-
tamination could occur;
• the interceptor corridor will also fall in a
"Special Flood Hazard Area" just north of its
discharge point on the James River; this is not
anticipated to cause adverse effects.
b. Mitigating Measures:
• landfill areas should be maintained above the
30 foot contour as preliminary plans indicate;
if the boundaries of the "Special Flood Hazard
Area" prove to be accurate where they extend
above this contour, landfill areas should also
remain outside of this area (see Section II-A-2).
8. Social Environment
a. Impacts:
• potential stress and social disorientation of
those more-vulnerable low-income residents, who
desire relocation; and
• potential noise and odor effects upon remaining
adjacent property owners.
b. Mitigating Measures:
• in order that adjacent residents desiring relo-
cation are promptly and efficiently relocated to
adequate replacement housing, EPA guidelines for
relocation under the Uniform Relocation Assistance
-------
and Real Property Acquisition Policies Act of
1970 will be utilized;
• proper operation and maintenance of the facilities
to eliminate possible plant operation malfunctions
would effectively eliminate any possible odor
problems from reaching areas outside of the
facilities boundaries.
9. Growth and Future Development
The purpose of applicant's proposed project is to
provide sewage treatment capacity for future development
planned by the County to occur within their 1995 Phasing
Line. Investments in wastewater treatment and conveyance
facilities have been identified by EPA as having poten-
tial impacts on the location, rate, and character of
local growth. When these facilities indirectly provide
stimulus for growth and development which will, in turn,
cause physical impacts contravening environmental regu-
lations, these secondary impacts should be assessed as
part of the decision-process for federal funding of
these facilities.
At this time it is EPA's position to fund facilities
for existing need plus adequate reserve to maintain the
integrity of the future environment. This necessitates
utilization of accepted local projections and land use
plans to determine appropriate sewer service areas and
treatment capacities.
Possible secondary impacts from accommodated and
induced land development are numerous. These can
include:
accelerated development
increased housing cost
windfall land profits
unanticipated pressures on local public services,
often causing
increased local taxes, especially for schools
fiscal instability
threatened and diminished water supply
disappearance of prime farm land
air pollution
increased surface run-off and flooding
sedimentation and erosion
non-point runoff pollution
Population growth in an economic region such as the
Richmond metropolitan area occurs as a result of the
balance of births, deaths, and migration. Current
theories estimate population increases either directly
V-9
-------
or indirectly through a projection of regional economic
growth. A given county or city's previously projected
share of regional growth may be accommodated by new
wastewater facilities; inducement of growth in excess
of this previously projected share can occur when sewer
service makes one area (such as eastern Henrico County)
more attractive to developers than competing areas
(such as western Henrico or Richmond). This growth in-
ducement is a short-term land market effect, fueled by
large areas becoming sewered and developing before their
prices can rise to reflect increases in value due to
public infrastructure investments.
Highway-access can also make part of a region rela-
tively more attractive to developers, especially when
existing levels of access are low. In general, "it is
large and dramatic shifts in accessibility or [in]
sewered vacant land that create the potential for signi-
ficant secondary effects." (EPA, 1975). Research by
EPA has identified four factors as important in housing
location: the availability of sewer service, the proxi-
mity to major highways, the amount of vacant land, and
the residential vacancy rate.
Sewers have their greatest influence on single-
family detached homes; multi-family housing is not as
responsive to new sewer service (1) because demand for
single-family homes is high in the suburbs where new
sewers are usually placed and (2) because highway access
and nearness to existing development is more critical.
New highway access can stimulate development, especially
where existing levels of access are low. However,
single-family housing is not clearly tied to highway
access in the way that multi-family and commercial
growth are.
Properly analyzing the influence of highway access
or sewer service on growth would require extensive for-
mulation of utility functions, supply and demand curves,
and market clearing processes for use in a mathematical
model. EPA (1975) has determined that by focusing on
the influence of public investments on urban growth,
economic analyses can be restricted to the actions of
developers as producers of new structures.
The potential gravity-sewer service areas related to
each of the five alternative plant sites as well as the
County's 1995 Phasing Line are shown in Figures II-3,
7, 11, 15 and 19. These areas are not sewered by the
proposed project but are those areas which could be
served by new gravity sewers without construction of a
costly pump station and force main. Figures II-3 and
II-7 also illustrate an additional potential gravity
V-10
-------
sewer service area which could be made available by con-
structing an additional pump station. While this pump
station is not suggested as part of the proposed facili-
ties plan, its use was extensively discussed during the
public information meeting on October 25, 1977. This
station would therefore require new formal action by
the County if it were to be constructed in the future.
The acreages of potential gravity-sewer service
associated with site-related interceptors are shown
below in Table V-l. Areas outside the phasing line
opened to potential gravity sewers are also shown.
Table V-l. Potential Gravity Sewer Service Areas of Proposed
Plant Sites
Potential Gravity Area Outside 1995
Service Area (acres) Phasing Line (acres)
Deep Bottom West 8,600 500
Upper Cornelius Creek 4,600 0
Varina Farms 9,100 700
Darbytown 4,500 0
Deep Bottom 12,800 3,800
These figures indicate that most areas opened to
potential gravity sewer service are within the County's
phasing line. Utilizing any of the alternative plant
sites except the original Deep Bottom therefore accommo-
dates rather than induces growth.
Henrico County has various policies and controls,
supplemented by the state and federal governments, which
will aid in controlling the effects of projected growth
and development. These include erosion and sedimentation
controls, a comprehensive land use plan with phasing,
flood plain regulations, zoning and subdivision ordinances,
and federal controls on historic sites and air and water
pollution. These controls are discussed in detail in
Sections V-B-2, 3 and 4 on Pages V-16 to 27 of the Draft
EIS. Specifically, non-point pollution control is being
addressed by the local Areawide Wastewater Management
Planning effort under Section 208 of PL-92-500.
V-ll
-------
In order to assess the potenrial for impacts on residential
growtn from these areas a preliminary evaluation was
performed. Among the factors considered were:
local vacancy rates, past building rates and patterns,
County policies toward the sizing the funding of sewers,
past adherence to land use plans, and opinions of local
assessors, developers, residents, and County officials.
The conclusion of this investigation was that poten-
tial for growth inducement was low. Several factors
contributed to this conclusion:
• The high cost of building pumping facilities
(which would enable a developer to cross out of
one watershed to reach an existing interceptor
within another warershed) effectively constrains
sewered development to areas within watersheds
above existing interceptors;
• Henrico County's policy requires a developer
which installs an interceptor between his sub-
division and County interceptors to size his
interceptor to service the entire watershed up-
stream of the subdivision. Since the only compen-
sation offered to the developer by the County
for such construction is a credit on his lot-
related tap-in fees, the policy essentially
restricts sewered development to relatively short
distances (1,000 to 2,000 feet) from existing
interceptors;
• Growth trends and interviews indicate a long-
standing community bias against locating in the
'east end1 as opposed to the comparatively
fashionable 'west end1. While this situation is
changing, its market effects should be felt for
some time.
• The phasing plan and other County land use control
devices have operated effectively over their first
few years and this compliance seems likely to
continue.
Therefore, it was determined that the growth effects
of the various site-specific interceptors would be
localized and minimal. The only potential difficulty
may be in some scattered pressure to develop flood plains
where interceptors are routed. County controls mentioned
previously, and citizen pressure appear capable of con-
trolling these effects if conscientiously pursued.
V-12
-------
A reevaluation of the potential for growth induce-
ment was conducted during preparation of Addendum Number
One utilizing updated market indicators. This analysis
concluded that potentials for induced secondary growth
continue to be low to moderate. However, the recent
strong recuperation of the local housing market, illus-
trated by falling vacancy rates and a climbing rate of
construction, indicated that adherence to planning con-
trols and strict application of land use plans to
utility extensions continue to be necessary.
The current Henrico County Future Land Use Plan
utilizes the proposed route of 1-95 through the eastern
County as a 1995 phasing line; development is planned
to remain within this line prior to 1995 (refer to
Draft EIS, Section V-B). Planning conducted since publi-
cation of the Draft EIS and the County's Plan has intro-
duced four additional routings through the eastern
county, most with additional variations south of the
James River, in Chesterfield County. All of these
alternatives shift the route of 1-95 to the west of
the previously considered eastern County route, toward
the center rather than the perimeter of the area pro-
posed for development prior to 1995 (see Appendix E).
Therefore, none of these new alternatives will have the
effect of extending the phasing line further east. The
effect of shifting the highway route to the west of the
existing phasing line would be to further reduce pressures
for induced growth from potential gravity service areas
which occur east of the phasing line. Therefore, none of
the new alternative routes through eastern Henrico County
is anticipated to increase the potential for violation of
this line. In fact, a shift toward Richmond would serve to
reinforce the County's intended pattern of development.
If this shift occurs, it is likely that the 'interchange
impact area1 and associated development currently shown on
the Future Land Use Plan at the intersection of Route 5 and
1-95 will be eliminated from the plan (LaVecchia, 1978).
In order to maintain the character of Route 5 which led to
its designation as a Scenic By-way, the County is currently
in the process of amending their zoning ordinance to incor-
porate additional height, setback, and landscaping controls
on the route. EPA supports this change as a reinforcement
of the Land Use Plan and the Route's scenic character.
The cumulative effect of 1-95 and the potential
service areas discussed above may be greater than either
action separately; however, this conclusion cannot be
made without extensive analysis. Existing levels of
access in the area may be great enough for this cumula-
tive effect not to occur. EPA has recommended previously
that one of the western alternatives should be chosen
due to wetlands impacts by the highway's eastern route
V-13
-------
(this recommendation is reprinted in Appendix E).
Therefore, in order to reinforce the County's intended
development pattern, reduce potential for a cumulative
effect on growth from the proposed highway and sewer
routes, and to minimize impacts on wetlands, one of these
western alternates is recommended.
To summarize, the proposed facility will accommodate
previously projected population growth largely within
the County's 1995 Phasing Line. The County Land Use
Plan projects primarily low density residential growth
with appropriate levels of commercial and multi-family
development. Potential for growth inducement beyond
County projections is low—however, choice of a western
alternate for 1-95 would help insure that inducement
effects will be controlled.
Secondary air quality impacts from the proposed pro-
ject will not be significant. As previously discussed,
induced growth is expected to be only minimal as a
result of construction of sewerage facilities. Develop-
ment will not be extensive or wide ranging. The growth
plans of the AQMA are being reviewed by the Virginia
State Air Quality Control Board (VSAQCB) to insure
compliance with the National Ambient Air Quality Stan-
dards. The VSAQCB (1976) has found that the "State
Implementation Plan contains adequate control strate-
gies to attain the National Ambient Air Quality
Standards for Total Suspended Particulates in the State
Capital Region (AQCR 225)." Other pollutants are still
under review.
B. ADVERSE IMPACTS WHICH CANNOT BE AVOIDED
Construction and operation of the proposed wastewater
facilities will produce many adverse environmental impacts.
Most of these impacts cannot be avoided but can be reduced
in magnitude through the implementation of appropriate environ-
mental protection measures. The magnitude of a few adverse
impacts cannot be reduced. Adverse impacts resulting from
the proposed project and appropriate mitigating measures
are summarized in Section V. In the following discussion
both primary and secondary impacts are discussed.
Primary Adverse Impacts
Commitment of Land. If the proposed project is imple-
mented, the treatment plant will be built on a site of
between 260 and 455 acres, depending on the site chosen.
During construction the fauna and flora of the site will
be destroyed or displaced. The recreational potential
and aesthetic quality of the site will also be destroyed.
Any archeological remains on the site will be permanently
disturbed or destroyed, although some may be mapped or
excavated.
V-14
-------
A total of 7 sites throughout the Service Area are re-
quired to accommodate new pumping stations. The sites
committed to this purpose will not be available for
other human activities.
Private land will also be acquired for construction and
operating the collection system. After compensating the
owner of private lands crossed by the sewer, Henrico
County will own the sewer right-of-way. This will reduce
the previous owner's use of that portion of his property,
although some of these routes may be used for trails.
Construction Impacts. Excavations for sewers will re-
sult in some soil erosion, siltation of streams, safety
hazards, inconveniences, and loss or damage to private
and public property. Strict adherence to county erosion
and sedimentation control laws will minimize the effects
of construction upon water quality. Trench sections will
be left open for limited lengths to reduce damage from
runoff and to minimize safety hazards. Dust will be
controlled in areas where it would create a nuisance
or a hazard. Construction designs and controls will be
planned to minimize the removal of trees and expensive
stream crossings. Project construction will result in
temporary alterations to existing land and streams. All
disturbed areas will be rehabilitated.
Operation Impacts. With efficient operation, most adverse
environmental impacts resulting from the operation of
the proposed project can be minimized. The most signi-
ficant continuous operational noise will be generated
at the sewage treatment plant, and the highest noise
levels will be in the buildings. Near the boundary of
the treatment plant property noise levels will not be
significant. Pumping stations will generate little
sound. Odors generated by sewage treatment processes
are not expected to be significant. A continuous main-
tenance program and alarm systems will minimize failures
that would create significant environmental impacts.
Continuous analytical testing in the plant laboratory
and on-line analytical monitors will provide the data
necessary to maintain the plant's effluent at the
quality required by state and federal regulations.
Secondary Adverse Impacts
The mitigation of secondary impacts resulting from the
proposed project requires planning and legislation. The
proposed project will accommodate planned development
in areas where new service is provided. The potential
for significant adverse impacts occurring as a result
of intensive development made possible by the proposed
project is projected to be low to moderate. The proposed
V-15
-------
project is consistent with the Henrico County Future Land
Use Plan. Development according to the land-use plan
will reduce the intensity of many secondary, adverse
impacts, including flooding and nonpoint pollution from
developed areas and disruption of environmentally sensitive
areas.
C. RELATIONSHIP BETWEEN LOCAL SHORT-TERM USE OF MAN'S EN-
VIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-
TERM PRODUCTIVITY
Construction and use of the proposed wastewater facili-
ties will bring Henrico County's wastewater discharges into
compliance with effluent limitations designed to protect
water quality in the James River and provide facilities for
the enhancement of the long-term growth and productivity of
the county. The costs of the project, short-term environmental
disruption and long-term commitment of some resources, are
justified by its beneficial impacts.
Henrico is a suburban but predominantly rural county and
is experiencing pressure for future development. The pro-
posed project is consistent with the Henrico County Land Use
Plan. Completion of the project will provide local officials
with a facility which will create conditions favorable to
development in accordance with the land-use plan. Without
the proposed project, development might occur in many areas
which could not support septic tanks and in areas outside the
1995 Phasing Line.
The capacity of the sewage treatment plant and its sup-
porting facilities has been designed to accommodate projected
growth in the service area. However, the proposed expansion
of the plant may maximize the cost to the current population.
The proposed facilities will have life spans equal to or
greater than their financing period. Operation and main-
tenance of the facilities will be required but these costs
will be supported by annual user charges.
Short-term adverse environmental impacts of the proposed
project will be offset by long-term beneficial impacts:
The quality of surface water and ground water in
Henrico County will be enhanced over the life
of the project by the elimination of septic tanks and
the potential for package sewage treatment plants.
The treatment plant and its accompanying collection
network will reinforce the proposed land-use plan for
Henrico County by accommodating projected growth within
the 1995 Phasing Line.
V-16
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D. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES
WHICH WOULD BE INVOLVED IN THE APPLICANT'S PROPOSED
PROJECT SHOULD IT BE IMPLEMENTED
The following discussion summarizes the adverse effects
that the proposed project will have on the beneficial use of
the environment by permanently committing land, construction
materials, and biological, human, economic and aesthetic re-
sources. These resource commitments have been separated
into primary and secondary commitments.
Primary Resource Commitments
Land necessary for the treatment plant and pumping station
sites cannot be used for other purposes during the life
of the treatment system. Rights-of-way which are not
located along highways will restrict land use across
them to agricultural, recreational, or open space.
Labor will be irreversibly committed to the construction
and operation of the system.
Materials and natural resources required will include
rock, concrete, steel, glass, wood, clay and asbestos
compounds for the construction of the system's components.
Seeds and plants will be required for landscaping dis-
turbed areas.
Operation of the system will require chlorine for eff-
luent disinfection, polyelectrolyte, sand for filters,
fuel oil for heat and air conditioning, and fossil fuels
to generate the electricity required by the system.
Aesthetics and recreational potential of the plant site
and any aerial portions of sewer lines will be irrever-
sibly committed to these facilities.
Secondary Resource Commitments
Secondary irreversible and irretrievable resource commit-
ments are generated by new development accommodated by new
sewers and increased treatment capacity.
Land within the County's 1995 Phasing Line will be com-
mitted to increased development. This area of land repre-
sents a significant resource commitment.
Materials and natural resources will also be committed
to development. Because secondary development will be
significantly more extensive than the proposed project,
the commitment of resources will also be significantly
greater.
V-17
-------
Air quality may be degraded by increased loads of indus-
trial and automotive pollutants, although this is under
examination.
Ground water levels may be lowered through the loss of
aquifer recharge areas to development. Ground water
quality may be degraded by urban runoff, although this
is under examination.
Surface water flows may be altered with more frequent
flooding and longer periods of low flow. These flow
variations will result from increased areas of impervious
surface and reduced stream recharge from ground water.
However, the relief of existing treatment facilities
and septic tanks will increase water quality. The bene-
ficial impacts resulting from improved water quality
will offset the adverse impacts resulting from increased
flow variations and increased urban runoff.
Recreational and open space areas will be irretrievably
lost as development continues throughout the county.
Areas of valuable open space were defined in the Future
Land Use Plan.
V-18
-------
. Public Participation
-------
A. Chronology
and
B. Public Hearings
-------
VI. PUBLIC PARTICIPATION
A. CHRONOLOGY
As part of the joint Facilities Plan/EIS process, a
series of public meetings were held by the County to receive
public comment on the various phases of the plan. The
meetings were of two basic types: public information
and public comment. Information meetings were sche-
duled for the purpose of reporting the findings of a par-
ticular phase of study. Following each information session,
a public comment meeting was held for the purpose of
receiving comments concerning the previously disseminated
information. In addition, Public Hearings where transcripts
were maintained were held by EPA on two occasions: fol-
lowing publication of the Draft EIS and of Addendum Number
One. These meetings and hearings as well as other events
in the Facilities Plan/EIS process are chronologically listed
below:
Date
August 1, 1975
December 3, 1975
January 14, 1976
March 2, 1976
March 9, 1976
March 23, 1976
April 4, 1976
Event
EcolSciences, inc. (environmental EIS
consultant) meets with EPA to discuss
potential impacts associated with the
proposed project.
Wiley & Wilson and Royer (engineering
Facilities Plan consultant) meets with
EPA to discuss need to prepare EIS.
EPA, Virginia State Water Control Board
(SWCB), Environmental and Engineering
Consultants and the County meet to discuss
issues associated with the proposed
project.
"Notice of Intent" to prepare an EIS is
officially released by EPA.
First Public Information Meeting dis-
cussing project goals, environmental
inventory and wastewater transportation
alternatives.
Joint Public Comment meeting on March 9
information and Public Information Meeting
discussing treatment process alternatives.
"Memorandum of Understanding" signed by
Henrico County and EPA to prepare a
"piggy-back" EIS.
VI-1
-------
Date
Event
May 10, 1976
May 18, 1976
May 27, 1976
July 1, 1976
October 14, 1976
November 15, 1976
January 4, 1977
January 11, 1977
January 18, 1977
March 28, 1977
May 18, 1977
June 21, 1977
Environmental Consultant meets with EPA
to discuss alternatives.
Third Public Comment Meeting (on infor-
mation presented March 23) and Public
Information Meeting to discuss final
wastewater transportation alternatives.
EPA, SWCB, Environmental and Engineering
Consultants and Henrico County meet at
EPA to discuss wastewater discharge
criteria and plant location alternatives,
EPA, Environmental and Engineering Con-
sultants and Henrico County meet to dis-
cuss wastewater discharge criteria,
plant site alternatives, including land
application, and level of detail in
Facilities Plan.
EPA, SWCB, Environmental and Engineering
Consultants and Henrico County meet to
resolve alternatives and wastewater dis-
charge requirements. These two issues
are acknowledged major set-backs in EIS
preparation progress.
EPA, Environmental and Engineering Con-
sultants and Corps of Engineers inspect
alternative plant sites.
EPA, SWCB, Engineering Consultant, De-
partment of Health, and Henrico County
meet to discuss recommendations of pro-
posed Facilities Plan, financing and pre-
c©nstruction bioassay and pilot study
requirements.
Public Information Meeting on recommen-v
dations of proposed Facilities Plan.
Public Comment Meeting on proposed
Facilities Plan recommendations.
EPA, SWCB, Environmental and Engineering
Consultants and Henrico County meeting
to discuss presentation of alternatives
in Facilities Plan/Draft EIS.
Release of Draft EIS and Facilities Plan.
Public Hearing on Facilities Plan and
Draft EIS.
VI-2
-------
Date
July 13, 1977
July 20, 1977
August 3, 1977
August 10, 1977
August 21, 1977
November 25, 1977
December 13, 1977
Event
Regularly scheduled Board of Supervisors
meeting. Agenda included discussion of
201 Facilities Plan.
Scheduled public work session for Board
of Supervisors to discuss wastewater
treatment plant sites. No action on
acceptance of plant site and meeting was
moved to August 3, 1977 for special
session.
Special public session, Board of Super-
visors, to discuss alternate treatment
plant sites.
Regularly scheduled Board of Supervisors
meeting. Agenda included discussion of
alternate treatment plant sites.
Scheduled public meeting. Board of Super-
visors to discuss plant site location.
Board of Supervisors adopted 201 Facili-
ties Plan with Deep Bottom West plant
site.
Release of Draft EIS Addendum Number One.
Public Hearing on Draft EIS Addendum
Number One.
B. PUBLIC HEARINGS
1. Draft EIS Public Hearing
Pursuant to EPA's Final Regulations for Facilities
Planning, published February 11, 1974, in the Federal
Register, and EPA's Final Regulations for Environmental
Impact Statements, published April 14, 1975, a joint pub-
lic hearing was held on behalf of EPA and Henrico County
at 7:30 p.m., Tuesday, June 21, 1977, in the Hermitage
High School Auditorium, in Henrico County, Virginia. The
attendance list was signed by 177 persons, and 30 per-
sons presented testimony. A transcript of the hearing
is available from EPA, Region III. The following persons
spoke at the hearing:
• Mr. George D. Pence, Jr., Chief of EIS Branch,
EPA, Region III
• Mr. William S. Dewhirst, Acting County Manager,
Henrico County
• Mr. Patrick J. Brady, Director of Public Utilities,
Henrico County
VI-3
-------
• Mr. Steven A. Torok, Chief of the EIS Preparation
Section, EPA, Region III
• Mr. Robert Pickett, Project Manager for the Henrico
Grant Application, EPA, Region III
• Mrs. Dolly Rankin
• Mr. William H. Walton, Jr.
• Mr. Newton H. Ancarrow
• Mr. Thomas W. Evans, Virginia B.A.S.S. State
Federation
• Mr. Morris Pence
• Mr. Jeffrey T. Miller, Professional Engineer,
NABISCO, Inc.
• Mr. Watson M. Marshall
• Mr. H. L. Nelson, Varina Homeowners Association
• Mr. Ed Winks
• Mr. J. R. Berlinghoff
• Ms. Jean N. Gibbons
* Mrs. W. T. Pryor
• Mr. John F. Deal
* Mrs. Helen S. M. Blackwood, Richmond Metropolitan
Area, League of Women Voters
• Mr. Chris R. Ragland
• Mr. J. D. Kitchen, Acting Regional Engineer,
Bureau of Sanitary Engineering, Virginia Depart-
ment of Health
Mr. John Murdock
Mr. J. D. Adams
Mr. F. S. Fisher
Ms. Dorothy Johnson
Mrs. George Brydon
Mrs. M. Wilcos
Mrs. Walker
Mr. Morris Moore
Mr. E. W. Nash
The primary issues discussed by the various speakers
related to the choice of a treatment plant site and the
quality of the proposed discharge. Pertinent comments
regarding these issues are summarized in the sections
which follow. The responses of EPA to these issues can
be found in Section E, along with responses to the
written comments on this EIS. The Richmond Metropolitan
Region League of Women Voters, the Varina Homeowners
Association, and the Virginia B.A.S.S. State Federation
opposed the Varina Farms site. NABISCO, Inc. opposed
the Upper Cornelius Creek site.
a. Choice of a Treatment Plant Site
Many of the speakers expressed objections to any
treatment plant site located in the eastern end of Hen-
rico County, on the grounds that the plant's service
area would be primarily the western end of the county,
VI-4
-------
and that a plant in the eastern end would tend to cause
development in the eastern end.
There was considerable debate among the speakers re-
garding the desirability of the four alternative treat-
ment sites proposed in the Draft EIS. Advantages and
disadvantages raised for each site are tabulated in
Table VI-1.
b. Degree of Treatment Required
Several speakers stated that the proposed treatment
plant, which is designed for secondary treatment, will
not produce an effluent of acceptable quality, and that
land application or reuse of wastewater is required.
Some suggested that a higher degree of treatment was
necessary and the county should build the best plant
possible; others claimed that only "zero discharge" was
acceptable.
A representative of the State Health Department ex-
pressed the Department's concern over the effects of the
discharge on the Hopewell water intakes.
2. Draft EIS Addendum Number One Public Hearing
Following the introduction of a fifth site, Deep
Bottom West, to the EIS process Addendum Number One to
the Draft EIS was published. Pursuant to EPA regulations
a joint public hearing was held on behalf of EPA and
Henrico County at 7:30 p.m., Tuesday, December 13, 1977
in the Varina High School Auditorium in Henrico County,
Virginia. The attendance list was signed by 71 persons,
and 14 of these presented testimony. A transcript of
the hearing is available from EPA, Region III. The
following persons spoke at the hearing:
• Mr. George D. Pence, Jr., Chief of the EIS
Branch of EPA, Region III
• Mr. Robert Pickett, Project Manager for the
Henrico Grant Application, EPA, Region III
Mrs. Dolly Walker Rankin
Mr. Robert P. Geary, Varina Homeowners Association
Mr. Morris Moore, Co-Chairman, Deep Bottom
Homeowners Committee
Mrs. Lois J. Pryor
Mr. Watson Marshall
Mr. John Murdock
Mr. Tom Wilkerson
Mrs. Walter A. Lemon
Mr. Alex B. Moody
VI-5
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Table VI-1.
Summary of Public Comments at the June 21, 1977 Public Hearing Regarding Advantages and
Disadvantages of the Four Proposed Treatment Plant Sites. These comments do not
necessarily reflect the viewpoint of EPA.
Site
Cornelius Creek
H
I
Advantages
NABISCO is already near a dump and creosote
plant
Less costly than Deep Bottom
Little relocation necessary
Compatible with neighboring land use
Can handle designated growth
Waste land unsuitable for any other function
Allows larger buffers to residential area
Rail service adjacent for sludge disposal,
if desired
Will not cause induced growth
Not agricultural land
Deep Bottom
Varina Farms
Disadvantages
Not most cost-effective
Serves smallest area
Interference with NABISCO expansion
and operations
Wells in area went dry when site was
originally excavated
Leaks will drain to river
If plant is built, industry can't use
If area is "ruined" industry will
want to locate in residential areas
Groundwater problems
• Only spot with public access to river
• Residents are black, poor and can't
afford to move
• Trucks will disturb neighborhood
• Discharge pipeline would interfere
with WRVA antenna system
• Riverfront land
• Archeologic site
• Will induce growth
• Trucks will disturb neighborhood
• Will induce growth
• Riverfront land
-------
Table VI-1 (cont.
Site
Darbytown Road
Advantages
Disadvantages
• Interference with, aircraft
• Impacts to nearby churches
• Destruction of historic boarded-up
springs
• Not in area it services
• Nearby homes have shallow wells
• Planned for regional park
• Will induce growth
<
H
I
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• Mrs. Helen Blackwood, Richmond Metropolitan
Area, League of Women Voters
• Mr. Edward Winks, Varina Homeowners Association
• Ms. Margaret Wilcox
The issue most extensively addressed by the speakers
was the choice of a treatment plant site, primarily the
relative merits of the proposed Upper Cornelius Creek
site versus the proposed Deep Bottom West site. These
comments are summarized in Table VI-2. The degree of
treatment proposed was questioned in relation to water-
quality in the James River and downstream withdrawals of
raw water for municipal water supplies.
The Richmond metropolitan area League of Women Voters,
the Deep Bottom Homeowners Committee, and the Varina
Homeowners Association all supported the proposed Upper
Cornelius Creek Site, and the latter two opposed the
proposed Deep Bottom Site.
vi -
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Table VI-2.
Summary of Public Comments at the December 13, 1977 Public Hearing Regarding Advantages
and Disadvantages of Two of the Proposed Treatment Plant Sites. These comments do not
necessarily reflect the viewpoint of EPA.
Site
Deep Bottom West
Advantages
<
H
I
Cornelius Creek
• Site is 'industrial1 in
Land Use Plan
• Less overall environmental
impacts
Disadvantages
Historic Civil War battlefield with special signifi-
cance to black history
Landfill and facilities surround and affect a large
number of nearby residents
Residents nearby are low-income and minorities;
site chosen due to their inability to effectively
oppose
Will induce growth
Growth will conflict with Land Use Plan for 'low
density' in Eastern Henrico
Site conflicts with Land Use Plan for 'prime
agriculture'
Site will occupy currently productive farmland
Site operations conflict with Deep Bottom Road
traffic using County boat ramp
Site will cause groundwater contamination in
domestic wells
-------
C. Written Public Comments
on the Draft EIS and
Addendum Number One
-------
C. WRITTEN PUBLIC COMMENTS ON THE DRAFT EIS AND ADDENDUM
NUMBER ONE
This section contains reprinted comments received by
EPA from members of the public. Some specific comments on
major issues are reprinted in Appendices C, D, E, and F.
The following other comments were received:
-------
February 7, 1977
Mr. Patrick J. Brady
Director of Public Utilities
County of Henrico
P. 0. Box 27032
Richmond, Virginia 23273
Dear Mr. Brady:
Please find enclosed, information presented by the Varina
Homeowners, Inc. pertaining to the proposed 201
faci Titles.
Best regards,
VARINA HOMEOWNERS, INC.
Edward H. Winks, Jr.
EHWJr/clf
Enclosure(s)
vi-10
-------
At this point, a petition with 593 signatures was
attached. This petition is on file with EPA, Region III
The text of the petition was as follows:
The Varina Homeowners Association, Inc. is on re-
cord as opposing the location of a sewage treatment
plant in the Varina District located in eastern
Henrico County. We have petitioned the county
to study other alternatives for plant and discharge
sites.
If, in the final analysis, the studies indicate
the Varina District to be the only feasible loca-
tion for the sewage treatment plant, we, the
undersigned after extensive research, do hereby
recomment [sic] the following site for the loca-
tion of the proposed sewage treatment plant:
The property located within the area bounded
generally by Darbytown Road on the south
and west and by Charles City Road on the
north. The property is further identified
as the former gravel dig site mined and
operated by Commonwealth Sand and Gravel
Company.
VI-11
-------
Route 1, Box 336
Richmond, Va.
February 21, 197?
Victor W. Kreiter, Chairman
Henrico County Board of Supervisors
110 Early Avenue
Sandston, Va. 23150
Dear Mr. Kreiter:
We would appreciate an opportunity to express some thoughts
and comments regarding the waste treatment system proposed for in-
stallation in the Varina District.
As concerned citizens we are opposed to this type of in-
stallation anywhere wilshin the Varina area, however, we realize there
comes a time when existing facilities are no longer adequate and that
preparation must be made for future needs.
We are especially opposed to some citizens' recommendation
to install the system in an area bounded by the Charles City Road,
Darbytown Road and Laburnum Avenue. We believe the Board of Super-
visors will not consider this location due to the substantial addi-
tional cost to the citizens and based on other information and
recommendations submitted by Wiley Wilson & Royer. Also, near this
site is a heavy concentration of homes.
We believe the Board should be aware that approximately 15
years ago, when mining operations were in progress at this location,
many wells surrounding the gravel pit site went dry. We believe this
was caused by the interruption of the water veins, and the water
drained from these wells into the excavation site. Naturally it was
necessary to have new and deeper wells dug. With a sewerage dis-
posal facility at this location, there is real danger of our wells
becoming contaminated due to seepage into existing water veins.
In view of the above, we believe the Board should proceed
with this facility atNVarina Farms as recommended by Wiley Wilson &
Royer.
We realize the decisions to be reached in this matter will
not be easy for the Board of Supervisors, and we thank you for this
opportunity to express our opinion.
Sincerely yours,
Charles L. Holmes,I'Jr.
VI-12
-------
Richmond, Virginia, March 15, 1977
Mr. V. W. Kreiter, Sr., Chairman
Board of Supervisors
Henrico County
110 Early Avenue
Richmond, Virginia 23231
Dear Vick:
As one of your constituents I am writing in regard to the
proposed Waste Water Treatment Plant Site fo-r Henrico County. It is
with strong feelings that I request this site to be located in an area
other than the Gravel Pit area. After reviewing the cost figures for
the various sites, it is apparent that other sites would be less expen-
sive to the taxpayer. To me this in itself is a big point. It seems
unwise to pay for a detailed present worth cost study, if not used.
It was my understanding that the section between Charles City
Road, Laburnum Avenue, and Darby town Road was to be used for medium and
heavy industry; and to me, it is an ideal location for this purpose and
would in the long run keep industry from intermingling with areas that
are proposed for residential growth.
As you know, good examples of industrial growth already in this
area are Nabisco Biscuit Company, A. H. Robins, along with others. To
me, this is a good area for an industrial nucleus and I feel sure this
is why the county designated this land for industrial growth on the land
use map.
For many reasons, the Consulting Engineer stated in one of the
hearings that it would be practical and beneficial and less expensive to
locate this facility in one of the other areas.
I feel we should base our decisions on the detailed study rather
than the views from some of the political circles of our community. I
haven't had the opportunity to congratulate you since you became the
Chairman of the Board. I wish to take this opportunity to do that and to
say that I feel our District and Henrico County is in better hands than
ever before.
Sincerely,
VI-13
-------
April 5, 1977
The Honorable Board of Supervisors
of Henrico County, Virginia
P 0 Box 27032
Richmond, Virginia, 23273
Gentlemen:
I wish to address you concerning the location of the
proposed sewerage disposal plant for Henrico County.
I wish, first, to review some of the background of the
development of the sewerage system in Henrico County starting with
the creation of Sanitary District No. 1 many years ago for the
purpose of providing for the requirements of the Windsor Farms
subdivision and the adjoining territory. Collector lines were run
to the west of the Windsor Farms and the effluent was then "pumped
over the ridge" into the lines of the City of Richmond. As addition;
sanitary districts were formed, all in the western and northern
portions of the County, similar arrangements were made with the
City of Richmond. These arrangements, coupled with the objections
raised by the City against the location of any disposal plant west
of the City's Water System - and indeed against any plant in the
County, made the County dependent upon the City for sewerage disposa
Those of us in positions of responsibility at that time
and in succeeding years might have foreseen the extraordinary growth
that was to take place in the County and had built a plant in the
western sector and discharged the effluent downstream and had become
independent of the City's facility.
Be that as it may, the errors of judgment past live with
us and we can only hope that present judgment is based on recognitio;
of all values and under such considerations I believe that it would
be inconsistent to consider locating the new plant on Varina Farm.
This opinion is based on the following facts: Varina Farm is one of
the oldest landmarks in the State as well as in the Nation. It was
the home of John and Pocahontas Rolfe, the site of the first develop]
of the tobacco industry in America and within the area of the second
oldest settlement of the English people in America. It was the poin
of exchange of prisoners of war during the War Between the States.
It was the site of the first courthouse for the County. In addition
to these facts it has been the home of citizens down through the yea
who have, by their interest and efforts, contributed to the wellb ei
of the County and State. The present owner's husband was a member o
the County Board of Supervisors within the very recent past. These
facts, together with the opposition of the present owner to the loca
of the plant on this site, should eliminate any consideration of thi
site and I strongly urge that you not consider it for this facility.
Yours^ery -truly,
vi-i4 /<^'^' r^~':-'- '
s~ - T 7 -^ T T '' T"> j-~
'/-, W." H. Ferguson
-------
JHet Baptist QJ{]urcl|
CHARLES CITY ROAD
May ?, 1977
Victor W. Kreiter, Chairman
Henrico County Board of Supervisors
110 Early Avenue
Sandston, Virginia 2j5150
Dear Mr. Kreiter:
Reference is made to the 201 Facilities Plan for a proposed
sewage treatment plant in the Varina District of Henrico County.
While the consulting firm of Wiley and Wilson and Royer have
recommended a site for this installation, several other locations
have also been mentioned.
One location suggested is a area referred to as the "gravel
pit" which is bounded on the north by the Charles City Road, on
the south by the Darbytown Road and on the east by Laburnum
Avenue.
Due to the close proximity of the "gravel pit" to our
church facilities, the membership of Fort Lee Baptist Church
voted unanimously in its regular business meeting on April 6,
1977 to be in opposition to the 201 Facilities being installed
at the "gravel pit" location.
Sincerely,
Donald L. Matheny, pastor
fl/W&&('(£- fhfti-<£ij*t£/
Bessie Bowden, clerk
dm/dm
VI-15
-------
Varina Homeowners As so., Inc.
Route 5, Box 283 N
Richmond, Virginia 23231
May 16, 1977
Mr. Robert J. Blanco, P.E. Chief
Environmental Impact Branch
U.S. Environmental Protection Agency
Region III, 6th and Walnut Street
Philadelphia, Pennsylvania 19106
Attention: Mr. Fenton Roudabush
Dear Mr. Blanco:
Re: Proposed Sewage Facilities - Henrico County, Virginia
It has come to our attention that the sewage facilities as now planned
for lower Henrico County - to be located on the James River - could adversely
effect the following: historic sites, wildlife areas, agricultural lands,
conservation areas, parks, recreational areas, forest lands, residential
neighborhoods, ground water supply, land use plans, and phase growth plans.
The county concludes that gravity service and cost are the main reasons
for their selection of a river site. Because of the adverse effect of the
river front sites - the actual cost to the community and the state of leep-
frog development and non-renewable resources will be far greater than the
small amount of money expended for operational and construction costs. The
report that is enclosed is the result of months of work of our civic
organization. We want this report to be reviewed and entered as part
of the public record concerning the proposed facilities project. We have
used the county's own data but have reached a different conclusion as to
the best location. We hope that as you carefully review this report that
you will share our conviction and endorse our recommendation.
Please respond to the organization as to your remarks concerning the
enclosed study so that we may enter your comments in our records.
1
Yours truly.
enry L. Nelson
President
Varina Homeowners Association, Inc.
HLN/mew
Enclosure
VI-16
-------
THE COMMUNITY SPEAKS
The Varina Homeowners, Inc. has made every effort to encourage community
participation in the discussion and planning of the proposed 201 facili-
ties. Our organization has encouraged the community to attend public
meetings, research alternate sites, sign petitions, place phone calls,
and express themselves by letter concerning their viewpoints on the
sewage treatment plan location.
To date we have collected over 1,000 signatures on petitions favoring
the industrial park, gravel pit site, for the location of the sewage
treatment plant.
Many other citizens support this position and will be expressing them-
selves by letter and postcard to the appropriate county officials. We
hope the county will acknowledge citizen effort and positive partici-
pation in this municipal project and will act accordingly.
Sincerely,
FOR THE VARINA HOMEOWNERS ASSOCIATION, INC.
Edward H. Winks, Jr.
VI-17
-------
BACKGROUND INFORMATION:
The Varina Homeowners Association, Inc0 has attended each
public hearing regarding the Henrico County 201 Facilities Plan-
ning Study. We have viewed with interest the various informational
studies and hand-outs distributed and discussed at the public hear-
ings o We feel that a thorough study of the existing environmental
settings of the site proposals indicates that a river front location
for the 201 Facilities Plant should not be allowed in eastern Henrico
Countyo
In reaching this conclusion we have studied the various environ-
mental areas to be affected by the plant and have analized each aspect
on an individual basis as it relates to the specific site proposal.
The environmental aspects which were reviewed were as follows:
1o Natural Environment
Climate
Air Quality
Topography
Geology
Soils
Biolcgy
Historic Archeologic Resources
Asethetics
Noise
2. Man-made Environment
Existing Land Use
Current Status of Comprehensive Planning and Growth
Management Systems
VI-18
-------
Demographic Socioeconomic Characteristics
Future Population Projections
3. Environmentally Sensitive Areas
i.e0 - The area between historic Route 5 and the James
River in eastern Henrico County.
The study compiled by the Varina Homeowners Association
included much information on this particular area because
it contains significant natural and cultural resources„ We
feel that planning and subsequent development of this area
should be carefully measured, giving attention to the pre-
servation of the many resources contained in this historic
corridor.
Intensive development or disturbance of this sensitive area
may result in significant environmental, social and economic
costso Loss of the James River front and Four-mile Creek
drainage basin to leap-frog growth may result in the
irretrievable elimination of non-renewable resources„
Our study indicates that this area may also be important as
a primary recreational resource. The corridor (Route 5 to the
James River) is a natural, scenic and historic area which
merits the protection afforded through measured phase growth,,
In studying the proposed river front sewage plant locations
the Varina Homeowners Association, Inc. reviewed the following
categories as they related to environmentally sensitive areas:
Prime Agricultural Land
Flood Plains
Ground Water
Vl-19
-------
Forests and Woodlands
Fish and Wildlife Habitats
Endangered or Threatened Species
Steeply Sloping Land
Historic and Archeologic Resources
Recreational Resources
The following is a study of the proposed sewage treatment
plants—with attention given to areas which the Association feels
are pertinent.
VI-20
-------
A SUMMARY REPORT PREPARED BY
THE VARINA HOMEOWNERS ASSOC., INC.
ON THE
GENERAL CRITERIA FOR ENVIRONMENTAL
EVALUATION OF THE HENRICO COUNTY
201 SEWAGE TREATMENT FACILITIES PLAN
THE DEEP BOTTOM SITE:
1. Impacts Upon The Natural Environment
Henrico environmental studies indicate that extensive clearing of vege-
tation types ranging from young successional woodlots to more mature
upland and bottom land forests would be required. The project intrusion
would cause an increase in erosion and sedimentation because of required
clearing of the relatively steep slopes around the perimeter of the site.
The site represents a major disturbance to a significant wetland area along
the Four Mile Creek floor plain. (See Henrico open space plan - flood
plans map - Page 26.) The disturbance to the creek valley is further
complicated because of the reduction of wildlife habitat in a very
environmentally sensitive area. The Four Mile Creek stream bed contains
all fresh water fish species common to the area and serves as a spawning
ground for herring.
Another negative factor associated with the Deep Bottom site is the adverse
effects that will occur to the quality of both ground water and surface
water in the area. Due to the high ground water table; the potential
contamination of ground water caused by the proposed land filling opera-
tions could create a threat to public health through seepage into the
ground water u..d nearby water-wells.
The site suitability is very questionable due to the topography, geology,
and soil type surrounding the site. The site is located within the
nanjeomy and aquia formations. These formations consist of glauconite
clays and quartz glauconite sands with interbedded shells and limestone.
The aquia formations range in thickness from 0 to 100 feet. (See Henrico
open space appraisal plan map - Page 19.) A study conducted by Henrico
County indicates that the soil on the site is predominantely suited for
open space and(recreation use. (See Henrico open space appraisal plan
map - Page 18.) The natural drainage pattern is moderately well developed
to poorly developed in the site area. Part of the site is low-lying with
nearly level areas which are excessively wet in winter and spring. Springs
and seeps are present where the flood plain adjoins the slopes. A portion
of the nearby area is subject to flooding, particularly along the Four
Mile Creek.
VI-21
-------
-£.-
The Deep Bottom site may cause a degredation of air quality in the area
surrounding the proposed plant. The potential order problem may have an
adverse effect on nearby residential and recreational sites.
In summary, the Deep Bottom site is viewed as having a detrimental impact
upon the natural environment in the following areas:
a. Site clearance will create a potential for soil erosion and sedi-
mentation.
b. Loss of natural negetation will be extensive - young successional
woodlots and more mature upland and bottom land forest growth will
be lost.
c. The site will create a major disturbance to important wetlands and
stream valley of Four Mile Creek.
d. The site location will reduce the potential wildlife habitat of
eastern Henrico.
e. The effects on ground water and surface water quality may cause
public health problems and well-water contamination.
f. The site is poorly suited for a treatment plant because of topography,
geology and poor soil permability.
g. The site is on or near a flood plain - with a high ground water level.
h. The air quality may be damaged causing problems for nearby homes and
recreational sites.
i. The site is slated as an environmental protection area and best
suited for recreation. It was a proposed regional parkstrip in
1972.
2. Impacts Upon The Community
The site will displace five owner families - all of which are minority
group members. The loss of property, homes and relocation costs are
extensive and unnecessary.
The aesthetics of the plant represent a major intrusion into the local
low-density residential community.
The Deep Bottom site location also represents a disruption to existing
community facilities. In order to locate the plant in this area, Deep
Bottom Road will have to be relocated. This will not only be an incon-
venience to the remaining property owners but to the general public
seeking access to the river as well.
The location of the plant and the relocation of the road may have a
detrimental effect on the recreational area located at Deep Bottom.
This is the only public access to the James River in Henrico County.
Vl-22
-------
-3-
The disruption to historic and archaeologic sites are as follows:
The proposed plant location sits astride a stream bank area, rich
with Indian archaeologic possibilities. An Indian dig located at
the mouth of Four Mile Creek unearthed Indian artifacts thought to
be approximately 10,000 years old. The site is in an area which
has many Civil War breastworks nearby. Deep Bottom Road was used
during the Civil War as an access point to the James River. _A
pontoon bridge crossed the James at or near Deep Bottom landing.
Also nearby is Gregg's Pond believed to be a very old grist mill
site dating back to the 1700's. The pond appears on maps in the
book, "Families along the James." The pond is but a short distance
upstream from the proposed site location. A pumping station proposed
to lift the waste water up to enter the plant site would be located
near the headwaters of the pond. The pumping, station is near several
breastworks and the pipeline may traverse them in order to make
connection with the treatment plant. At the very least, the
noise and visual impact of the road site will be adverse. The
construction and location of the pumping station may also dislodge
and discourage wildlife in the pond area. Currently deer, beaver,
and other animals frequent the area.
The Deep Bottom site is in dire conflict with the land use plan for
me ueep Bottom site is in dire conrnct witn tne iana use pian tor
Henrico County and will greatly alter the 1995 phasing plan. The
secondary growth implications are plain. Leap frog development will
take place throughout the Four Mill Creek drainage basin. This growth
pattern will have an adverse economic impact on the county tax base
and cause a great deal of expenditure for unplanned growth in an area
unsuited for intensive development. The site is completely incompatible
with planned land uses in the area, i.e. low-density residential, con-
servation, agricultural, and recreational. The Deep Bottom area should
cease to be a site proposal.
In summary, the Deep Bottom site proposal for the 201 waste water facil-
ities will initiate the following adverse impacts upon the surrounding
community:
a. Displacement of structures and people. The site will displace five
owner families - all of which are minority group members.
b. The site will cause a disruption to community facilities.
1. Transportation - Deep Bottom Road must be relocated to accommodate
the plant site. This will cause a disruption to local residents
and to other residents seeking access to the only public boat
ramp in Henrico County.
2. Recreational areas. The site location may have an adverse effect
on the Deep Bottom park site located at the mouth of Four Mile
Creek. This is the only park site currently owned by the County
on the James River.
VI-23
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-4-
c. The plant construction may cause a disruption of sites containing
Indian artifacts. Archaeological sites have been located near the
proposed plant site. Also several Civil War breastworks may be
disturbed. A historic grist mill pond and wildlife area may also
receive adverse impact.
d. The site location will stimulate secondary growth patterns which
are incompatible with the county's 1995 phase growth plan and cause
adverse economic impact to the county tax base. Rapid growth which
is largely unplanned will place a strain on the county's ability
to provide the necessary services, i.e. schools, police, fire,
etc., to accommodate the increasing population.
e. The plant location site at Deep Bottom is completely incompatible
with planned land uses in the area, i.e. low-density residential,
conservation, recreational, and agriculture. The Deep Bottom site
should cease to be a site proposal.
VI-24
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THE VARINA FARM SITE:
1. Impacts Upon The Natural Environment
The site location has dense vegetation consisting of young successional
woodlots to more mature upland and bottom land forest wood. The plant
construction will require entensive clearing over fifty per cent of the
site. The loss of vegetation creates the potential for soil erosion
during the construction period. The area is rich in wildlife including
white-tail deer, wild turnkey, and other smaller species. The loss of
vegetation caused by plant construction coupled with the noise intrusion
of the plan operation will greatly reduce the wildlife habitation of
the area.
The soils of the area are recommended by a recent County study for open
space conservation, recreation or agriculture. The sludge storage may
cause contamination of the ground water due to the seasonal high water
table attributed to the site area.
The air quality of this low-density, agricultural area may be adversely
effected due to the odor out fall caused by the landfill slude treatment
method to be employed at the plant.
The loss of agricultural land will further contribute to the deficit
in productive farm lands currently being experienced by the State of
Virginia.
2. Impacts Upon The Community
Although the construction of the sewage treatment plan will not directly
displace any property owners; the site location is in close proximity to
an established residential community and the intrusion to the area by the
proposed plant may very well cause a reduction in property value. The
aesthetics of the treatment plant will not be in harmony with the rural
surroundings directly adjacent to the site.
The disruption to historic and archaeologic sites will be very severe if
the sewage treatment plan is located on Varina Farm.
The plant location will represent an irreversible invasion into an area
rich in history that dates to the early 1600's. The land along the banks
of the James River in eastern Henrico County is perhaps one of the most
significant historic areas in the United States.
vi-25
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-2-
Historic Background:
In August, 1611, Sir Thomas Dale sailed up the James River and founded a
new settlement which he called Henrico Towne, in honor of Prince Henry who
was at that time a favorite of the English people. The settlement was
described as "convenient, strong, healthie, and sweet seat," on the
penninsula formed by a great northward bend of the south shore of the
James River.
Across the river on Varina Plantation, John Rolfe grew the first crop of
tobacco in Virginia and thereby established the first successful commercial
plantation in the English colonies. Varina Plantation was thus named for
Varinas, the Spanish town from which tobacco was imported to mix with the
Indian weed which became America's first important money crop in 1612.
Princess Pocahontas, the daughter of the Indian King Powhatan was baptized
at Varina as Rebecca and became the first Indian convert to Christianity
recorded in the colony. In 1614 the Reverend Alexander Whittiker married
Rocahontas and John Rolfe in the Varina Parish. The Rolfe's lived at
Varina where the-ir son Thomas, was born in 1615. It was from there
that they set sail for England where Pocahontas died in 1616. John
Rolfe returned to Varina and became active in colonial affairs. He
served as Secretary and Recorder General of the Colony prior to his
death in 1622. After receiving his education in England, Thomas Rolfe
returned to Varina in 1640. The distinguished Randolph family of
Virginia included descendants from the Rolfe family. It should be
noted that William Randolph purchased Varina following Bacon's
Rebellion which took place in 1676. The last Randolph owner of
Varina became the fourteenth governor of Virginia. He received
Varina as a wedding gift from his father when he married Martha,
the daughter of Thomas Jefferson, in 1799. He lived at Varina for
six years and his will is recorded in the court records of Henrico
County.
Varina residents were among the most prominent persons residing in
Virginia during the early colonial period. James Blair (1655-1743)
was rector of the Henrico Parish, and lived in the Varina Glebe House.
The first attempt to establish a university in America at Henrico had
failed. This was due in part to the setback of the Indian Massacre
in 1622. Blair consumated the plans which led to the founding of the
college of William and Mary in 1693, and served as its first president.
In addition to this capacity he was minister of the church at Jamestown
(1694-1710), and served as rector of Bruton Parish in Wil1iamsburg.
Another distinguished person who lived in Colonial Henrico included
rector William Stith (1707-1755). In 1746 while residing in the
Glebe House at Varina he wrote a book entitled, "History of the
First Discovery and Settlement of Virginia." This book was published
in Williamsburg where Parson Stith was later to become the third
president of the College of William and Mary.
VI-26
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-3-
In 1680, Varina became the site of the Henrico Court House by a special
act of the General Assembly designed to promote industry in the colony.
Although Charles III suspended this act in 1681, Varina continued to
thrive and grow. In 1691 the General Assembly re-enacted the act of
1680 and Varina was made a port of entry.
By 1741 the center of affairs in Henrico had moved from Varina to the
Richmond area. The event was marked with the construction of St. Johns
Church that year. In 1752 the Henrico Court House was moved from Varina
to Richmond and located on half an acre of land at what is now 22nd and
Main Streets in Richmond.
On September 29, 1864 Fort Harrison in eastern Henrico was captured by
the Federal Army. General Benjamin F- Butler lived at Varina during the
period that his troops were cutting the canal through the James River
bend at Dutch Gap. The old military road crossed Varina to a pontoon
bridge which extended southward over the James. In addition to the
occupation by Union troops Varina plantation served as a point of
prisoner exchange for the Northern and Southern Armies.
Today, the 1854 structure at Varina Plantation is recognized as both a
State and National Landmark. The plantation contains approximately
2,000 acres of productive agrucultural land, marshland, water inlets,
forest and wildlife areas.
Other historic sites nearby: The farm is across the James River from
Henricopolis or Henrico Towne. It is located near Fort Brady which was
built in 1864 by Union Troops to extend their defenses to the river.
Nearby also is Sailors Tavern thought to be the site of one of the
first taversn in America. Across Varina Road on a northwest angle
from the plantation is "Farmers Rest." The house was built around
1790 by Henry Cox. The home was used as a Northern hospital during
the Civil War. When the house was under restoration wallpaper with
the names and addresses of Union soldiers from Coopentown, New York
were discovered. A second dwelling house located on the property was
also constructed in the late 1700's and has a very unique architecture.
The interior of the house is lined with brick while the exterior is
wooden clapboard. The construction technique is known as Noggins and
is found in very few locations in America.
Varina plantation agriculturally active since 1611 serves as a very
important link in a chain of Historic sites which exist along the
James River in eastern Henrico. These sites include: Malvern Hill,
Turnkey Island, Bremo, Curies Neck, Wilton Site, and Tree Hill. The
site is also an integral part of the corridor which exists between
Historic Route #5 and the James River between Richmond and Jamestown.
The location of a sewage treatment plant at Varina Farm is completely incom-
patible with planned land uses in the area. According to county land use
plans the land is most conducive to be used as either prime agricultural,
conservation, or recreational purposes. Adjacent land use includes
agriculture, forests, and low-density housing.
VI-27
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-4-
The plant location at Varina is incompatible with the growth plan of Henrico
and would destroy the 1995 service area as established. The economic impact
of leap frog development caused by the plan location would initiate havoc
on the county tax base. Such growth patterns would also lessen the quality
of development and life style of the Varina community.
VI-28
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THE DARBYTOWN ROAD SITE
We did not consider this site location viable in view of the fact that the
county has indicated that it should serve as a county park.
Vi-29
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THE UPPER CORNtLIUS CREEK - OR GRAVEL PIT SITE:
1. Impacts upon the Natural Environment
The site location has sparse vegetation and will not require extensive
clearing. The area is currently a wasteland created by open pit gravel
mining. Some grading and water drainage will be necessary; however, erosion
should not be a significant problem during the construction period.
The site does not contain any significant wildlife, nor does it provide
habitat for any endangered species. The soils in the area seem more suited
for industrial development than do the river front sites under consideration,
The air quality should not be significantly altered by location of a
sewage treatment plant in this area. There are several other industries
nearby which create odor sufficient to disguise any odor emission, i.e., a
creosote plant, a cookie factory, a cinderblock factory, a landfill, etc.
Location of the sewage plant at this location would create productive
utilization of a current wasteland area which is a liability to the county.
2. Impacts upon the Community
The construction of the plant at this location will not dislodge any
property owners. The location is compatible with the land use plan vhich
indicates that the site should be utilized for industrial development. The
site would not alter the 1995 phase growth plan adopted by the county.
The proposed plant site is surrounded by existing industries. The few
existing homes which are located near the site are situated on land slated
for future industrial use. The aesthetics of the treatmeant plant are in
harmony with the surrounding community and the size and location of the site
allows for sufficient buffer to screen the site from residential areas.
vi-30
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- 2 -
The plant will not disrupt any known historic or archaelogical sites.
The location will not encourage out-of-phase development and cause leap-frog
growth characteristic with the river front sites.
Rail service which is adjacent to the site may serve to encourage the
county to seek alternative uses for sludge disposal, such as fertilizer for
forest lands, etc. The industrial location may also encourage usage of the
waste in the creation of energy for a cheap power source.
The Upper Cornelius Creek site is the only site which has received any
favorable response from the Varina community. Approximately one thousand
Varlna citizens have signed petitions and letters supporting the gravel pit
site. These residents are to be the citizens most directly affected and
should have some influence in the final site selection. This particular
site location will service present and future sewage needs; is convenient
to existing and proposed trunk lines, can be connected to the river dis-
charge point by gravity, and affords the least disruption to the future
county growth plans.
The only disadvantage that county studies attribute to the Cornelius
Creek site is the possible need for a pumping station to be located some-
where within the Four Mile Creek drainage basin.
Since the location on the river, making gravity flow possible, would
cause out-of-phase growth and disrupt neighborhoods unsuited for the plant
location, one might argue that this gravity advantage is actually a disad-
vantage. Also, the additional cost variable listed in county studies which
would be caused by an upland site is not large enough nor accurate enough to
warrant location of the plant on the river. All other drainage basins will
be served by pumping stations; why not let Four Mile Creek drainage basin
be served by a pumping station if it means that phase growth and the quality
of life in the community can best be maintained in this manner?
vi-31
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The following maps are taken from the Henrico County Open
Space Appraisal Plan developed in April, 1976. The Association
feels that these maps illustrate graphically several reasons why
the river front sites should be rejected as potential sewage treat-
ment plant locationso
1. Flood Plains -p. 26.
The Deep Bottom site is directly adjacent to a
flood plain area. The plant site as proposed will con-
tain area within the flood plain.
The Varina Farms site is near a flood plain area;
however, the height of the actual plant site is
approximately ±00 feet8
The Darbytown site is near a flood plain, i.e.,
Four-Mile Creek.
The upper Cornelius site is not located on or near
a flood plain area.
2. Soil Suitability - p. 18.
According to county studies tne lower Four Mile
Creek valley and other areas adjacent to the James River
contain soils predominately suited for open space and
recreational use0
The Darbytown Road site appears on the land use map
as a recreational site and has been proposed as such by
the Henrico County Parks Commission,, The site is part of
a total recreational plan for the county.
The Deep Bottom site is part of a proposed regional
park outlined in a plan adopted by the Richmond Regional
Planning District in 19?20
VI-32
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The Varina Farm site is part of a historic plantation
and county seat dating to 1611. The area is surrounded by
historic sites, including the National Battlefield Park at
Fort Bradyo
The Upper Cornelius Creek site is not located on soil
suitable for recreation, nor is it near any park area..
The site is surrounded by and slated for industrial growth.
3o Conservation Areas - p. 37»
County studies indicate that there are certain areas
within the eastern Henrico area which should be preserved
"as much as possible" as conservation areas.
The Deep Bottom site is located along a major stream-
bed (Four Mile Creek) and contains much wildlife indicative
to the area. Vegetation, young woodlots, mature upland
and bottomland forests cover the area»
The Varina Farm site is located on prime agricultural
Iand0 The site is partially wooded and provides habitat
for a large wildlife population.
The Darbytown Road site is partially located in a
conservation area, is currently under agricultural pro-
duction and provides habitat for a small amount of
wildlife.
The Upper Cornelius Creek site is not located -in a
conservation area and does not contain natural habitat
suggested for preservation.
Vl-33
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^•- Historic and Archeological Sites - p. ^20
The Deep Bottom site sits astride an area which may
contain Indian artifacts„ Adjacent digs have yielded
items approximately 10,000 years old. The area is near
an old grist mill site and numerous breastworks from the
Civil War.
The Varina Farm site is a National Historic Landmark
and is surrounded on all sides by other historic properties,
The Darbytown Road site is near the outer-defense line
established for Richmond during the Civil War«
The Upper Cornelius Creek sites contain no known
historic significance or artifacts,,
5o Groundwater Resources - p. 3^«
Many residents of the Varina district in eastern Henrico
County depend on wells for their main water source. These
wells are supplied by the groundwater resources consisting
of underground water veins. There are also several water
companies located in the area who receive their supply from
underground springs.
The Deep Bottom site location has a seasonable
high water table and groundwater contamination from
sludge storage will be a danger.
The Varina Farm site also has a high water table
and shares the danger of the sludge contaminating the
groundwater supply.
There is little danger present at the Darbytown site.
The Upper Cornelius site should not present any danger
for groundwater contamination.
VI-34
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60 Urbanization (1985-99) - P° 39°
Henrico County had adopted a land use plan containing
phase growth development projection through the year 1999-
The plan indicates that the Varina area in eastern Henrico
County is to receive a slow progressive development, with
the area between Route 5 and the James River remaining a
low-density, conservation, and agricultural area through
1995.
The Deep Bottom site is in violation of the phase
growth plan and would stimulate leap-frog development.
The Varina Farm site is in violation of the phase
growth plan and would stimulate uncontrolled urban
sprawl..
The Darbytown Road site would not alter the phase
growth plan.
The Upper Cornelius Creek site is located within
the area expected to develop by 19850 The site location
is convenient to proposed industrial development and will
not alter the phase growth plan. The site would serve
the present and future needs of the county.
VI-35
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I
CO
CTl
SOIL PREDOMINATELY SUITED FOR
OPEN SPACE AND RECREATION USE
OPEN SPACE APPRAISAL
SOIL SUITABILITY
HENRICO COUNTY,VIRGINIA
APRIL 21,1976
HENRICO COUNTY PLANNING OFFICE
0 8000
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I
u>
-J
100 YEAR FLOOD PLAIN CONTOUR
OPEN SPACE APPRAISAL
FLOOD PLAINS
HENRICO COUNTY, VIRGINIA
APRIL 19, 1976
HENRICO COUNTY PLANNING OFFICE
-------
H
I
\
DRAINAGE BASINS
SURFACE WATER
SWAMPS AND MARSHES
TIDAL POINT
DIRECTION OF DRAINAGE FLOW
OPEN 3PACE APPRAISAL
SURFACE WATER AND
DRAINAGE BASINS
HENRICO COUNTY, VIRGINIA
APRIL 12,1976
HENRICO COUNTY PLANNING OFFICE
0 8OOO
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OJ
1 NANJEOMY 8 AQUIA FORMATIONS
] PATUXENT FORMATIONS
OPEN SPACE APPRAISAL
6ROUNDWATER RESOURCES
HENRICO COUNTY,VIRGINIA
APRIL 22,1976
HENRICO COUNTY PLANNING OFFICE
?
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H
I
OPEN SPACE APPRAISAL
CONSERVATION AREAS
HENRICO COUNTY,VIRGINIA
APRIL 9, 1976
HENRICO COUNTY PLANNING OFFICE
-------
<
H
I
CURRENTLY DEVELOPED
EXPECTED TO DEVELOP BY 1985
OPEN SPACE APPRAISAL
URBANIZATION (1985)
HENRICO COUNTY, VIRGINIA
APRIL 9,1976
HENRICO COUNTY PLANNING OFFICE
0 80OO'
-------
H
I
Isj
/ \
o
A
SITE
STRUCTURE
APPROXIMATE SITE LOCATION
LISTED ON NATIONAL REGISTER
OF HISTORIC PLACES
OPEN SPACE APPRAISAL
HISTORIC AND
ARCHAEOLOGICAL SITES
HENRICO COUNTY, VIRGINIA
APRIL 21.1976
HENRICO COUNTY PLANNING OFFICE
° 3>0-
-------
CONCLUSION!
In conclusion we feel that the results of our study are best
expressed in our position statement listed below:
PROPOSED SITE LOCATION FOR THE
HENRICO SEWAGE TREATMENT PLANT
The Varina Homeowners Association, Inc0 is on record as opposing
the location of a sewage treatment plant in the Varina district
located in Eastern Henrico County. We have petitioned the County
to study other alternatives for plant and discharge sites.
If in the final analysis the studies indicate the Varina district
to be the only feasible location for the sewage treatment plant,
we, the Varina Homeowners Association, Inc0 after extensive re-
search, do hereby recommend the following site for the location of
the proposed sewage treatment plant:
The property located within the area bounded generally by
Darbytown Road on the South and West and by Charles City
Road on the North. The property is further identified as
including the former gravel dig site mined and operated by
Commonwealth Sand and Gravel Company„ The site is slated
on the land use map as an industrial development area and
now includes a cinderblock plant to the West, a creosote
plant to the North, a cookie factory to the East, a landfill
and other industrial properties.
Vl-43
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SUMMARY
VARINA HOMEOWNER'S ASSOCIATION
POSITION STATEMENT ON PROPOSED SITES FOR
THE HENRICO SEWAGE TREATMENT PLANT
t The Varina Homeowner's Association is on record as opposing the
location of a sewaqe treatment plant in the Varina District.
However, if in the final analysis, it must be located in Varina,
we feel that we in Varina should say where the plant should be
located.
• The Varina Homeowner's Association supports the gravel pit plant site.
• There is greater support for the gravel pit site than for any other site.
t The Varina Homeowner's selection criteria:
1. Compatability with Henrico Land Use Plan.
2. Located to serve present and future needs and potentials.
3. Compatability with surroundinq neighborhood.
4. Situated to produce minimal environmental impact.
• Proposed site locations unacceptable to the Varina Homeowner's Association:
1. Varina Farm: A national historic landmark, adverse impact; Potential
hold-up of approval for years from: The Virginia Historic Landmark
Commission, the Department of the Interior, the President's Advisory
Commission, leqal challenges by local citizens. Adverse impace
on the evnironmentally sensitive James River Valley. Sludge
storage in close proximity to established residential community.
Possible loss of real estate tax income from decreased property
values from potential odor problem. Extensive clearing/erosion
problems, poor soil conditions.
2. Deep Bottom: Adverse environmental impact. Infringes on
environmental protection area. Extensive clearing/erosion
problems. Encouraqes extensive leapfrog development. Relocation
of several families.
3. Darbytown Road site: Adjacent residential community. Proposed
County park site. Airport flight path.
• Twelve Reasons for Supporting the gravel pit site
1. Compatible with Land Use Plan and adjacent uses.
2. Convenient to existing and proposed trunk lines.
3. Can service present and future sewaqe needs.
4. Utilization of a current wasteland area.
5. Possible stimulation of adjacent industrial area.
VI-44
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Page Two
Varina Homeowner's Association
6. Unusually larqe site area, allows for larger buffers and greater
distance to residential areas.
7. No relocation necessary.
8. Imaginative engineering - low invert high discharge can greatly
increase gravity sewage service area.
9. Strong support for the gravel pit site from Varina citizens.
10. The gravel pit site is compatible with the quality growth
standards of the Varina Homeowner's Association.
11. Rail service adjacent site allows for alternate uses of sludge.
12. Will not encourage out-of-phase development and expensive services
to outlying out-of-phase growth areas.
Analysis of gravel pit site versus the Varina Farm site:
1. Sewage treatment plant, an industrial use is allowed at Varina
Farm only by a zoning loophole.
2. Fewer environmental conflicts on gravel pit site.
3. Grading required both sites.
4. Good engineering requirements because of high water table both sites.
5. Less chance of serious erosion on gravel pit site.
6. Odor problem both sites. Greater distance to adjacent residential
areas at gravel pit site.
7- Consultant's claim of 3 million dollar savings for Varina Farm site.
We question this. The 3 million could be reduced by: low invert-
reduces pumping cost. Use road grading techniques to lower path of
trunk and cut cost of digging to depths of 35'.
8. Record on cost - We stated once before that an upper site would be
as economical as, i^ not cheaper than, a river location. The
consultant said an 8.5 million dollar pumping station was required.
We said it was not, and showed alternate routes to support our. position.
After months of analysis the consultants latei report shows our proposal
to be considerably less expensive.
9. We feel the gravel pit site can be as economically efficient as the
Varina Farm site.
10. Even if this time the consultants are correct, 3 million dollars comes
to only $30,000 per year as Henrico's portion. A small price when
compared to expensive new services synonymously with a Varina Farm site.
vi-45
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f*1 COK. \TC( CHUMMM
_
SSSr -
COMMONWEALTH of VIRGINIA
»r, , , *.. .
* - mm.«u*o P*y//f fa Historic Landmarks Commission
22, 1976
•r. Bobert J. BUoco, P.I.
Chief
Environmental Impact Branch
9. 3.. EnviroiOMtBtal Protection
teflon in
6th end Walnut Street*
fbiia2«lphla, Pennsylvania 19106
Attention: Mr. Fenton Roudabush
Dear Mr. Blanco: Re: Proposed Sewerage Facilities
Henrico County, Virginia
It ha* corn* to our attention that the facilities aa now planned for lover
Henrico County could adversely effect several historic places on the James
River. Presently being considered as the preferred location for a severag«
traataant plant is Deep Bottom across the river from Jones Neck. Deep
Bottoa was the site of an Indian village which was excavated by a tean of
archaeologists from Virginia Commonwealth University. I understand that a
park is being considered for the area.
One of the alternate locations for the plant is on Curies Neck Farm, di*
large, working farm is the descendant of a plantation established by a
seventeenth century land grant. Curies Neck may be eligible for the National
legiater of Historic Places. Another alternate for the sewerage plant i* cm
Varina Farm, which also dates from the seventeenth century. Varina was the
tyrst commercial plantation in the English colonies and was a home o£ >iohn
Bolfe end his wife, Pocahontas. A proposed sewerage discharge point ia Jush
upriver froo the antebellum plantation house. Papers are now being prepared
for Che nomination of Varina Farm to the National Register.
We would object to any encroachment upon any of these presently unspoiled his-
toric areas and hope that other suitable locations can be found for the
sewerage facilities. We appreciate your consideration.
Tours truly,
lobert E. Swisher cc: Mr. John Sebaka
Specialist Mr. Charles M. Johnson
Mr. Henry L. Nelson
K5S/bf Mr. Dick Gibbons
VI-46
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June 10, 1977
Mr. Patrick J. Brady, P.E.
Director Public Utilities
County of Henrico, Virginia
P. 0. Box 27032
Richmond, Virginia 23273
Re: County of Eenrico, Virginia
201 Facility Plan
Dear Mr. Brady,
Thank you for providing me with the several pages and map of the
proposed Deep Bottom Road Wastewater Treatment Plant today.
As we discussed on the telephone, WRVA is vitally concerned as to
the location of the Treatment Plant, and the location of the transportation
lines to and away from the Plant.
WRVA's concerns date back to May 19, 1976 and correspondence has
been exchanged between Mr. T. F. Turner, Jr. of the consulting firms of
Wiley, Wilson and Royer; Mr. E. A. Beck, Henrico County Manager; and Mr.
Frank Miller, Chief Engineer, Department of Public Utilities, Eenrico County.
Apparently, there is no official public record of WRVA 's concerns
about the possible location of the Sewage Treatment Plant and transportation
lines at the proposed Deep Bottom location in the vicinity of the WRVA property.
We respectfully request that this letter and the attached correspon-
dence be made a part of the official record regarding the Deep Bottom location.
Sincerely,
/rft
'John B. Tansey
President and
General Manager
BJT/dm
VI-47
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E. A. = ETC.-'
co'jsr-- v \^>.--.
COMMONWEALTH OF VIRGINIA
COUNTY OF HENRICO
September 15, 1976
Mr. John Tansey
President and General Manager
'.VRVA
Post Office Box 1516
Richmond, Virginia 23212
Dear Mr. Tansey:
1 am a\vare of the correspondence regarding the County's Wastewater
Treatment Plans and the concerns of WRVA for any pipe that might cross
vour property. This, of course, is primarily a technical matter and I
am sure that our engineers will keep your interests in mind as one of the
most well known radio stations in the United States. We, indeed, are
proud of WRVA and certainly do not want to have anything happen that
might cause damage to its reliability,,
We are now in the early planning stages and certainly the fact that your
concerns have been expressed will give us a better opportunity to make
adjustments that may seem necessary. Your support and assistance in
the betterment of our community is indeed appreciated.
With best wishes, I am
Very truly yours,
cc: Mr. Taylor Turner
Director of Public Utilities
VI-48
2 s- AN D MAIN STREETS/P O. BOX 27O32 RICH MONO. VIRGINIA 23273/S49-I46I AREA CODE SO 4
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1514 WILLOW LAWN DRIVE
RICHMOND. VIRGINIA 23226
A joint venture
between two consulting firms to provide
engineering, architectural, and planning
services for regional sewerage facilities.
POST OFFICE BOX 8687
TELEPHONE 804-282-9029
August 25, 1976
Mr. John B. Tansey
President and General Manager
WRVA
P. 0. Box 1516
Richmond, Virginia 23212
Re: County of Henrico, Virginia
201 Facility Plan
Dear Mr. Tansey:
I would like to 'thank you for your letter of August 24, 1976.
The information contained in this letter will be very helpful in
assessing the feasibility of the various routing alternatives being
considered for the proposed Henrico County sewerage facilities.
Sincerely,
WILEY 5 WILSON AND ROYER
TFTjnlu
cc: Mr. E. A. Beck
Mr. Frank Miller
VI-49
-------
August 24, 1976
Mr. Taylor Turner
Wiley, Wilson and Royer
Engineering Consultants
P. 0. Box 8687
Richmond, Virginia 23226
Re: County of Henrico, Virginia
201 Facility Plan
Dear Mr. Turner:
This letter is- in reply to yours to Mr. T. W. Chezik,
WRVA's Chief Engineer, dated July 12, 1976.
We regret very much your inability to provide us with
an exact location of your proposal to cross the WRVA
property. However, it appears that your proposal at
this time indicates that you would cross our property
at a point that would disrupt and drastically effect
WRVA's ground system.
I think that you should know that WRVA is one of only
52 fifty-thousand watt clear channel AM stations out of
four thousand four hundred sixty-three licensed AM
radio stations in the United States and the only such
facility in the Commonwealth of Virginia. As such, we
must maintain our operations within very rigid toler-
ances to maintain Federal Communications Commission
approval.
To begin with, this area is subject to more drastic
soil conductivity•changes than almost any other place
in the nation. Furthermore, because of seasonal changes,
high ground conductivity, which is essential to our
producing the necessary signal strength, make the whole
problem of transmission even more critical.
The two possibilities suggested in your letter would
not be at all satisfactory to WRVA in that they would
change the operation of the station in such a manner
that either possibility would effect the phasing and
tuning of the antenna system that maintains WRVA's cov-
erage pattern. We know from operating experience and
from studies by our consulting engineers that there will
be an adverse and perhaps illegal effect on our authori-
zed transmission strength and pattern.
VI-50
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Mr. Taylor Turner
August 24, 1976
Page 2
Early this year, prior to our knowledge of your proposal
to cross the WRVA property, WRVA had various computer runs
made by our consulting engineers to determine if we could
achieve better coverage of the area we are licensed to
serve by moving the WRVA transmitter facilities out of the
eastern part of Henrico County to some other location in
the metropolitan Richmond area and in every case we were
unable to improve our position and still maintain suffi-
cient signal strength over the City of Richmond as estab-
lished by the FCC.
It appears to us that re-locating your sewage disposal
lines outside the limits of the WRVA ground system to the
northeast would be the most logical solution to the pro-
blem.
A similar problem arose several years ago both with VEPCO
and the C & P Telephone Company with their underground
lines and they were able to satisfactorily locate their
lines so as not to interfere with the WRVA ground
Serious complications could arise also from the use of a
buried pipe line which would seem to us to drain addi-
tional moisture away from the ground system, since the
water in the ground would tend to follow the route of the
pipe line and be carried away from the ground system thus
making an already difficult situation even worse.
We at WRVA want to cooperate with the County of Henrico
in every possible way and we recognize the need for a
sewage disposal system for the County such as presented
by your firm at the public hearings conducted on this
issue to elicit response from property owners and others
who may be affected by such a proposal.
Since this project is still in the planning stage and we
feel certain that there is a less damaging method of rout
ing the sewage lines than through the WRVA property, we
urgently request that an alternative route be developed
as part of your proposal .
It is our considered judgment and that of our consul-ting
engineers that construction of the sewage disposal system
in .the area proposed would do irreparable damage to our
antenna ground system. This could result in a condemna-
tion award running into millions of dollars on account of
consequential damages to the residue of the property.
VI-51
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Mr. Taylor Turner
August 24, 1976
Page 3
If we may assist you in any way, please let us know
Sincerely,
'*^
-------
LO.1/' LAV.U DRIVE
O.VIRGINIA 2322S
A joint venture
between two consulting firms to provide
engineering, architectural, and planning
services for regional sewerage facilities.
POST OFFICE BOX 8687
TELEPHONE 804-282-9029
July 12, 1976
Mr. T. W. Chezik
Chief Engineer
WRVA
P. O. Box 1516
Richmond, Virginia 23212
Dear llr. Chezik:
Re: County of Henrico, Virginia
201 Facility Plan
Your letter of July 9, 1976, has been received, however,
we are still unable to provide an exact location and the
proposed construction details in relation to the WRVA property.
Based on the map furnished to our office, it appears that
the tentative location selected for the alternative crossing
the WRVA property v/ould place the pipe perhaps 6 ' - 8 ' below the
ground system and through the middle of the radial lines buried
under the ground.
At present two possibilities exist for constructing such a
line. The first method would involve installing a metal tunnel
liner under the ground system to carry the pipe. Such a tunnel
would be installed without disturbing the ground system. The
second method would be to lay the pipe from the surface. This
would require temporary disconnection of short segments of the
ground system during construction.
We thank you for your cooperation and hope the above generaJ
information will be of some assistance.
Sincerely,
WILEY & WILSON AND ROYER
'. F. Turner, Jr.
TFTjrrlu
c^: Mr. Frank Miller
VI-53
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July 9, 1976
Mr. Taylor Turner
Wiley, Wilson and Royer
Engineering Consultants
P. 0. Box 8687
Richmond, Virginia 23226
Re: County of Henrico, Virginia
201 Facility Plan
Dear Mr. Turner:
We are still waiting for your reply to our letter
of June 3, 1976, requesting the exact location and pro-
posed construction details of the 201 Facility Plan
Proposal in relation to the WRVA property.
We v/ish to cooperate with you but, until the re-
quested information is in hand, we are unable to proceed
with a study to determine the effects of the plan on the
WRVA broadcasting facilities.
Sincerely,
T. v," Chezik
Chief Engineer
cc: Mr. E. A. Beck
Mr. Frank Miller
bcc: Mr. James lloke
VI-54
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June 3, 1976
Mr. Taylor Turner
Wiley, Wilson and Royer
Engineering Consultants
P. O. Box 8687
Richmond, Virginia 23226
Re: County of Henrico, Virginia
201 Facility Plan
Dear Mr. Turner:
We have received your letter of May 28, 1976, requesting
information as to the possible effects your proposed
"Deep Bottom" and "Darbytown Road" sewage treatment plant
and the waste water transportation systems would have on
WRVA's ground transmission system.
While we realize that the County's proposed facilities
are not final and we wish to cooperate with you, it is
impossible for us to provide you with any information un-
til you supply us with the exact geographical location and
proposed construction details of the waste water transpor-
tation system, as proposed, in relation to the WRVA property
At this point, it is useless for us to pursue the matter of
underground conductors, at considerable time and expense to
us, unless we have, in hand, the information requested
above I'm sure you can understand that we must have such
information in order to expedite any accurate response to
your request.
Sincerely,
T. W. Chezik
Chief Engineer
TWC:aw
cc: Mr. E. A. Beck
Mr. Frank Miller
bcc: Mr. J. Hoke
VI-55
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151-". WILi.GW LAWN DRIVE
KICHMON'O, VIRGINIA 23226
A joint venture
between two consulting firms to provide
engineering, architectural, and planning
services for regional sewerage facilities.
POST OFFICE BOX 8587
TELEPHONE 804-282-9029
May 28, 1976
Mr. T. W. Chezik
c/o WRVA Radio, Inc.
Post Office Box 1516
Richmond, Virginia 23212
Re: County of Henrico, Virginia
201 Facility Plan
Dear Mr. Chezik:
We have received your letter of May 19, and appreciate
the information which was transmitted therein. As you know
from our telephone conversation on May 25, we are hoping that
you will be able to provide assistance to our office in deter-
mining the effect of installing conductors under your company's
grounding system. At the present time the County's proposed
facilities are not final in any sense of the word. The 201
Facility Plan is a planning document used to make basic decisions,
therefore, the exact location of the proposed facility is unknown.
However, should the final decision to construct facilities in the
vicinity of your company's grounding system be made, every effort
and consideration will be given to reduce any harmful effect to
the WRVA broadcasting facilities. x
If any information you will be able to furnish indicates
that installing a conductor will be harmful to the broadcasting
equipment, we would propose changes to the system as it is now
envisioned. therefore, any assistance you may be able to provide
to help in our decision-making process will be greatly appreciated,
Sincerely,
WILEY & WILSON AND ROYER
TFTjr:lu
cc: Mr. Frank Miller
T". F. Turneix^cTr
VI-56
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.
V// V/
May 19, 1976
Mr. Taylor Turner
Yi'iley, V.'ilson and Rover
Engineering Consult ants ^ 1,1
P. 0. Box 8637 ^-^01 /rW^- ^
Richmond, Virginia 23226 ^ '
Dear Mr. Turner:
I am enclosing t\ra copies of the V.RVA gound system
as per our conversation toclax . Indicate on one
•copy the rout.es of the V.'ast ev. :ir or- Tr t-nsnor T at ion
System and other pertinent i n ;.or:'i;j.". i en re;virding
the lines \v h o r e they' v/ i 11 c r o r. s t \\ e V:" 11V A p r o ] •> e r t y ,
if either the Deep UottGrn or L\irby i" ov/n. road site
is chosen as the treatment plant and return to roe.
The other copy is for your files.
Sincerely,
T. V;. Chezik
Chief Engineer
TV.'C: av.
Enc losures
VI-57
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BARR BUILDING
BIO SEVENTEENTH ST., N.W. 2C
TELEPHONE (202) 296--*222
June 15, 1977 F,LE NO
Henrico County Draft EIS
EIS Preparation Section - EPA
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Re: County of Henrico, Virginia
Wastewatex Facilities Planning Study
0-51G-511-01
Gentlemen:
This firm represents the owners of Varina Farm in
Henrico County, Virginia. Mrs. Irene S. Stoneman and Mr. and
Mrs. Wilmer N. Stoneman, Jr. have requested that I write to
you in order that they may go on record as to being strongly
opposed to the County of Henrico considering Varina Farm as
a possible site for the proposed wastewater treatment plant
described above.
You and the County of Henrico are well aware of the
very significant historical value of Varina Farm. In addition
to other objections to the site, the Stoneinans feel that plac-
ing such a plant on Varina Farm would have a serious adverse
affect on the historical value of the area.
Further, in light of the shortage of clean water in
various areas in the State of Virginia, the Stonemans have
asked that further consideration be given to the possibility
of a tertiary system for treating the water as opposed to the
secondary treatment system as proposed.
This letter is submitted pursuant to the Public Notice
dated May 20, 1977 in which the EPA requested written comments
from interested parties.
Very truly yours.
60/313 William G. Hancock
cc Mrs. Irene S. Stoneman
Mr. & Mrs. Wilmer N. Stoneman, Jr.
VI-58
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June 22, 1977
Gentlemen;
I am once again mailing these petitions against the Waste
Treatment Plant being built on the Dorey Earn located on Darby-
town and Doran Roads. In June of 1976 I Sailed these petitions to
Mr. Bradey of Henrico County and Mr. Kreiter, Board of Supervisors
member in the Varina District. The Virgini. State Water Control
Board also received copies.
The last three pages of this petitions on these copies are
not too readable and if they are not acceptable and you cannot
count them, please let me know and I will mail you the originals.
I would like to remind you that the Dorey Farm on Darbytwwn
and Doran Roads is a proposed Henrico County Park which passed
by vote in our recent election of June lltth. It is my understand-
ing that Henrico County Officials are negotiating with the owners
on this property now.
Very truly yours,
^4 U
(Mrs.) roward P. Rankin (Dolly)
I am also enclosing maps from the Battlefield Park of the Federal
Government of the troop movement and activity around this land
Curing the Civil War.
8,
VI-59
-------
June 15, 1976
Gentlemen:
Enclosed are petitions opposing the Wastewater Treatment Plant being
built in Varinf, Henrico County on the property known as the Dorey Farm,
owned by Mrs. Belle F. Dorey.
These petitions were signed by residents bordering on all four sides
surrounding this property. The property is bordered on all sides by re-
sidents and two new large developments. It is in front of one church,
Pioneer Baptist, and comes to the back door of another, Four Mile Creek
Baptist Church. Also, the property was once the site of a Union Camp
and a Confederate Cairp during the Civil War. The whole area is rich in
Civil War history.
Residents of this area deplore and strongly object to this Treat-
ment Plant being built in Varina. The feeling is that Henrico County
Officials are once more useing this area for everything undesirable.
We were informed that this site, tha Dorey Farm, was suggested as an
alternate site by the Varina Homeowners Association. The Varina Home-
owners Association has approximately eighty members. At their last
meeting in May only about twenty members attended their meeting with the
rest of the people being visitors as myself, Mrs. Lottie Rankin.
All residents of Varina are united against this plant being built
anywhere in Varina and if it is built anywhere in Henrico we would hope
that it would be an odorless system.
Mrs. Lottie W. Pankin
I Jr. W. H. Walton, Jr.
Mr.Ernest E. Griffey
!s > L — • ''-•- x '
VI-60
-------
At this point a petition with 973 signatures was attached.
This petition is one file with EPA, Region III. The text of
the petition was as follows:
May, 1976
We, the Residents of Varina District, Henrico
County, are opposed to the Wastewater Treatment
Plant being built on the property known as parcels
No. 31-A1-19 and 31-A2-31 owned by Mrs. Belle F.
Dorey. We are opposed to this Wastewater Plant
being built anywhere in Eastern Henrico.
VI-61
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VI-65
//
-------
c WHITES TAVE.RN
DUKEL
i,
-------
W. H. FERGUSON
MALVERN HILL FARM
ROUTE 5, RICHMOND, VIRGINIA 23231
June 25, 1977
Evirnomental Protection Agency
Region 3 Preparation Section
6th and Walnut Streets
Philadelphia, Pennsy.
Gentlemen:
Re: Henrico County, Va., EIS
Enclosed herewith please find a copy of a letter sent
recently to tHe Board of Supervisors of Henrico County, Virginia,
regarding theAlocation of the proposed sewerage disposal plant.
I wish to call your attention to the contents of this
letter and to state to you that this is a matter of tremendous
importance to this area and we respectfully request your most
serious consideration and your rejection of the Varina Farm
site for this facility.
Thank you for your consideration.
Yours very truly,
VI-67
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ESTABLISHED 1887
'
-'--•• /*:-'0/.' .-"^fr- \v.--
AMERICAN AND
EUROPEAN AWARDS
frAUlli.AljDRESS1'SAUER RICHMOND"
DUKE'S /.'.AYONNAISE PRODUCTS
RICHMOND, VA. 23220
June 29, 1977
IMPORTERS °r VANILLA DEAHi
ETC M-F-R'S or SPECIAL BRANDS "
EXTRACTS a DRUGS
^; ^^%*¥
SAUER'S SPICES
Mr. Patrick J. Brady, Director
Department of Public Utilities
Henrico County, Virginia 23273
Dear Sir:
Re: 201 Facilities Plan
As an interested citizen and property owner in Henrico County, we have been following
the progress of the implementation of the 201 Facilitiess have attended several in-
formation sessions and would like to go on record with the department and as part of
the public hearing record that we are in agreement with the plan as submitted by the
engineers and hope that you can expedite this project to an early completion.
Of the four plant site locations under study, it appears to us that the plant site of
Varina Farms would serve .the county best, since it is located at a point where future
distribution lines can be brought from the Eastern end of the County by gravity resulting
in an economical sewerage distribution.
We would hope that the County Officials would review this location as it affects the
total area and that the Board of Supervisors will approve the location in order that
construction can start within two years.
Yours very truly,
THE C. F. SAUER COMPANY
FFJ/jw
cc: Mr. Taylor F. Turner, Jr.
R. Stuart Royer & Associates
F.'-'T. Jewett-Vice President "
Manufacturing and Engineering
vi-68
-------
Routs 5, Box 320
Richmond, Virginia 23231
July 1, 1977
Kenrico County Draft BIS
EIS Preparation Section EPA
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Gentlemen: Re: County of Henrico, Virginia Waste Water Facilities Planning
Study No. C-510-511-02
The proposed Henrico County <=ewsr treatment facility is primarily the solution
of a County problem for area0 other than the Varina District of the County.
Varina IP the largest of the districts area wise and a majority of the homes
in this district could continue to be served by individual peptic systems
even if the proposed County sewer facility in built in the Varina vicinity.
I feel there should be a better way of ^olving the sewage problem?, of those
area? remote to Varina, other than pumping the great volume of tho sewage
generated in these areas some thirty-five mile." to Varina for treatment and
then discharging the effluent into the James River.
Some of my ancestors have lived in eastern Henrico County, Virginia since
1783 and have had a great interest in thip area. As long as I can remember,
pixty or more years, there hap been talk of curbing the polution of the river.
At that time, there was fishing and swimming in the river twelve miles down
ptream from the 'City of P.ichmond, Virginia. Since then, polution has increased
enormously and what should be a s;reat natural resource IP something of a
nuisance. I feel the time for a start on improving the quality of the James
River is long over due. Therefore, I am against effluent of this, proposed
sewage treatment facility going into the James River, and especially in the
Varina area.
Thank you for your kind consideration of this matter.
Sincerely,
Robert F. Nelson, Sr.
VI-69
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Route 1, Box 336
Richmond, Va.
July 12, 1977
Victor W. Kreiter, Chairman
Henrico County Board of Supervisors
110 Early Avenue
Sandston, Va. 23150
Dear tor. Kreitorj
With further reference to my letter of February 21, 1977
regarding the installation of a waste v/ater treatment plant in
the Varina District, 1 would like to add the following:
Based on the report submitted toy Wiley, Wilson & Royer, v/e
do net believe cea^iteration should "be given to any site other
than tlv3 Varina Farms. Many things have been said about the his-
torical valx.ie cf Varina Farms, hov/ever I sincerely wonder why a
"Wo 'Ire3passing" sign is posted at a so-called historical land-
mark. Perhaps your on-site inspection of Varina farms revealed
tho mining of gravel v/as underway for many years and in the past
nothing was said, oi' efforts made, to male Varina Farms a his-
torical site.
It j 3 noted in the various reports th.it have been available
to the public the gravel pit beivean Ja::byto.\-n o.r.d Charj.es City
Road,~ is a ponr .si to for sludge ianafiii, ani c>. faciJ.ity at thle
3,ocation significantly reduces tho service ar^c. and. v/ill req_uire
additiorxal purnin^; r, tat ion? if :jay area, couth ::J Vi-.i' C .?. 0 Rail-
road is to be so-.verod. Also, the installation ccst is considerably
higlior than tho other locations -uhat are mentioned.
Since tho draf'u.-j a:au oth^r irn'orniati^i ha'vo indica.tea Yarim
Farms v.;oulcl be tho most c;ci-;ir;iblo sit?., i tr-..,sr. you. arrd the o'i'.lior
raembers of the lioarrt ..rlj.,.1 fia:l it to thu o.'.lvajitajj'j of o~..r county
and cast your vote ir. fivor of p.l^cji-'/r thir fr.ciir.Ty r.t Varina
inoor^y y ro.rs,
Charles L. Holies, Jr.1-
VI-70
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VA&IXA HOMKOWIR3LS ASSOCIATION, !MC.
Maftiatioa «ss tb« HsB.rleo Ceanty 201 Sewage TrsseaMat Plant S*L«etioa
Vaffifts HasBeowfifcts Ass0c.I«tl,@sf Its,",., do b«teby petition the EPA
C®a»tj
-------
Mr. and Mrs. Charles E. Wright
Rt.5, Box 213 Kingsland Road
Richmond, Va. 23231
Mr. Robert Pickett
United States E. P. Agency
Region 3
6th and Walnut Sts.
Phil.fPerm. 19106
Dear Mr. Pickett: Aug. 29, 1977
We are enclosing a copy of a map showing the general location of the Deep-
Bottom-West (plan 201} wastewater treatment site. As you can see, it is
almost the same location. It doesn't displace any homeowners, however
they are expected to be surrounded by the plant and sludge areas.
Seme of the objections to the Deepbottom site.
1. The site has not been selected by any agencies such as the
a. Planning Commission-Cornelius Creek
b. E.P.A.- Cornelius Creek
c. Dept. of Public Utilities-Varina Farms
d. Consulting Firm-Varina Farms
2. Deepbottom is still more expensive than any other site,
3. It will leave more land open to developers-which will cost
the County if developed too quickly-(schools, fire and
police protection, etc.)
4. Deepbottom site is located closer to homeowners than any
Qther site and will affect property values more.
5. Owners" close to site are very concerned about it affect-
Ing their water, since they all have wells. ( Very high
water table) The county says precautions will have to be
made but too many mistakes can occur. Since most of the
homeowners land around--site is lower than the site and
if a mistake occures, wells will become contaminated.
We are also enclosing copies of newspaper articles appearing in the Richmond
News Leader and Richmond Times Dispatch, Aug. 25, 1977.
In view of the above we request that Federal Funds be withheld at this
location. We do appreciate your consideration in this matter.
Sincerely,
VI-72
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"''•"•;; I pKlch ,/
V, 11"i' ^
-------
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. ^ (^ '77
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VI-74
"fc
J? dJ-i ~U>
c (I '
4, (l^J^^Jl J!^<^^_ C^t^ &
I ^ I
-------
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71-15
-------
Beute 5, Bex 199B, Wall* Bd.
Mchmend, Virginia 23231
September 5. 1977
Mr. Rebert Pickett
Unite* States Bovirenmental Agoney
Regien 3
6th and Walnut Streets
Philadelphia, Pean. 10106
Dear Rr. Pieketti
Ve are very mueh displeased and eppesed te the "Sewage Treatment
Plant Site? te be Heated in the Varina District ef Henrioe Oeunty.
After taking twe years te purchase eur Ian* site en Wall* Read and anether
fetir years ef struggling te save a sufficient payment te censtruet eur
heme In the natural seenery an* beauty ef Varina, this kind ef aetien
really hurts te the heart*
T» further exemplify eur feelings, we qusstlen hew the prepesed
"Sewage Sites will affect the wild life in this area. Ale* what affects
will the dumping ef sewage inte the river affect the Hvelihee* ef; human
beings living in this area* net mentiening the air that all ef the
inhabitants are required te breathe.
Presently the area is zened as agriculture. Meet families have persenal
gardens whieh is a seuree ef employment* and a valuable means efsubsidising
their feed budget which mas already rea«h inflationary levels. fhi«are*
is knewn te have a high greufidwater table and these is the pateatial
centaminatien ef greund water by landfilllng eperatiens. Oar «nly se«rce
ef water is the supply ebtained by wells, till the people whe live in this
area be left with enly te drink sewage infested water ef ethmrs,
Is the taxpayers meney being wieftly used wnea it eneenrages prejects
that increase eresien and sedimentatien whieh will be required If this
plant is eeaetra«ted. The ^Sewage Treatment Site in Varina net enly displays
peer families that have lived here fr*m birth, it ferees th«a ts sell tteir
preperty at less than market values. The plant will alss daore*s4 the
value ef all residents ef the Varina Distriet,
Vlth the magnitude ef dlsruptien in the "Deep Bettem • Varina Katvral
Senery Site, and the abeve aentiened evaluatienst
VI-76
-------
Mr, Rebert Pickett
Pace 2
Zened - Agriculture
Wild Life Prtteotien
Greuniwatcr-wells Gentaainatien
Displacement ef Faailiea
Clearing ef weedlets and Ferests
Decreased in Property Values
Htman Preteotien - Fe«d, Shelter, ffiapleyment
We are anticipating year suppert te assist in the selectien ef a different
site er restering and widening the present sewage treatment facilities
threugheut Riehnend, Ranrice Gewranity.
Sincerely,
Th ~\ &S'
qfajA^
(Mr. & Mrs*) Rebert fi. Beeker
VI-77
-------
September 16, 197?
Mr. Robert Piekett
United States E.P. Agency
Region 3
6th and Walnut Sts.
Phil., Penn. 19106
Dear Sir,
As a homeowner, living in the area known as Deep Bottom
West, the selected site ef the sewage treatment plant fer
Henriee Ceunty, I am writing te express ay feelings that my
rights as a citizen, hare been violated.
The request f«r funds far this plant have been made by
the Henrlce Beard ef Supervlsers, witheut due consideration
te any ef the fellewing reasons listed*
1. The site was pieked in less than a twe week period
te meet the E.P.A. deadline fer funding.
2. The television and news media reported the selected
new site (Deep Bottom West) four days prior to the
supervisors vote, which twice h»d been hopelessly
deadlocked.
3. It is strletly against the land use growth plan,
whleh was made by the County of Henrlce.
^. It is an entirely new site from the ©rginal Deep
Bottom site.
5. No study made, no public meetings, and no citizens
input.
6. All this area is dependant en wells for their water
supply, and no guarantee can be made fer the safety
of these wells.
7. The decrease in property value for all land owners
in the area of this treatment plant.
8. Least opposition, because of lower income families.
9. No guarantee there will not be an «d®r. .
10. One of the most costly sites erglnally studied.
VI-7!
-------
11. Lass ©f »u©h land n*w used f®r farming,
These are only a few reasons aut ®f Many why I am ask
ing y®ti t« v»t« n« ®n the Enriranment Pr»t«etlon Ageney
funds f«r this plant.
Yeurs truly,
-"//--j
(Mrs.) 'James W. Yarbrough
VI-79
-------
September 16, 1977
Mr. Rebert Piekett
United States E.P. Agency
Beglea 3
6th and Walnut Sts.
Phil., Penn. 19106
Dear Sir,
I am writing te yen »s a concerned homeowner, regard-
ing the approval by the Environmental Protection Agency, f*r
funds fer a sewage treatment plant legated, en the site called
(D{ep Bottom West. )
I feel this site was selected, because it weuld meet
with less opposition. It alse was selected, wltheut regard,
te any ef the homeowners, that would h«ve te live in this
rery undesirable environment. I feel that my supervisor,
Mr Vtetor Krieter, has a conflict of interest, due to the
fa«t, that his wife has landholdings in the Cornelius Creek
site. This was the least eostly, and most desirable IB land
use with less environmental impaet. All other sites that
wvve selected, were studied, and input meetings w»»e held.
This site was selected in less than two weeks, without the
benefit ©f either. I feel this site, although net displac-
ing any families, would decrease the land value, and make a
very negative impact on all ©oneerned.
All this »rea is served by wells for their water supply,
and no ©no has guarenteed these weuld continue to be safe
for use.
The county als® has voted sgainst their land use reg»
ulatlons, that w*»e passed to protect the growth of our
county.
There are many more reasons, that I am sure the E.P.A.
Is aware ®f, so I urge you to vote against funding the
Deep Bottom West site for a sewage treatment plant*
Yours very truly,
(Mr. ) Jaaies W. Yarb rough
VI-80
-------
Route 1, Box 208, Strath Road
Richmond, Virginia 23231
November 28, 1977
United States Enviornmental Protection Agency
Region III, 6th & Walnut Streets
Philadephia, Pennsylvania 19106
Attention: Miss Alma Mullane, Mr. Robert Pickett, Mr. Penley
Dear Miss Mullane and Messers Pickett & Penley
I understand you will be holding your next community input meeuing on
the Wastewater Treatment Plant 201 Facility Plan on December 13th at the
Varina High School. I wish to speak at this meeting. I will be defending
the Darbytown and Doran Roads location as I have previously done.
If you will refer to my letters written over the past two years you
will know my feelings, and I speak for all the homeowners surrounding this
property. The following is a brief resume' of important facts concerning
this property:
1. It is a proposed Henrico County Park site and I believe the County
is in the process of a^tJrvffiLiag this land. I proposed this site
and the citizens voted on parks in Henrico County in June, 1977.
2. This property is a flight path for Byrd International Airport
radar use to be pn this land.
3. It is in the middle of the Varina area, surrounded by three new
housing developments, and surrounded on four sides by much traveled
roads.
4. Pioneer Baptist Church is across Darbytown Road from this property,
Four Mile Creek Church is on the back side. The total attendance
in these two churches is about eighteen hundred people.
5. On the Doran Road side of this property there are ten black famalies.
I do not believe this should be an issue on the location, but it has
been brought to the attention of Mrs. Fender of E.P.A's Human Rela-
tions section in connection with the Deepbottom Road site being
detrimental to the black families at that site. I wish to state
there are only about three families residing on Deepbottom Road, the
other houses are vacant, Mr. Williams' house is for sale since he
remarried and lives in town.
VI-81
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Page 2 U. S. Enviornmental Protection Agency. November 28, 1977
I cannot understand why the County of Henrico or E. P. A. could spend
over four hundred thousand dollars for the consulting firm of Wily, Wilson,
and Royer to make a recommendation and disregard their advice.
This letter is being mailed to the Third District Congressman, David
Satterfield, since this is his congressional district, and it is Federal
dollars that will be used for the greater portion of the cost for this project.
My husband is Congressman D. Kerrick Robinsons' brother-in-law and some
of eastern Hanover is his district. This area is involved in the sewage plan.
Varina Homeowners Association, who are for the Cornelius Creek location,
has forty families in attendance. I have attended their meetings, and few
of the people attend, few of the members attend even when Virginia delegate
Bill Axselle speaks. There are about ten people in that group doing all the
speaking and by no means do they represent the Varina voting district. If this
plant is located on either Darbytown and Doran Roads or Cornelius Creek sites,
the greatest part of the Varina District would be affected. This includes
Sandston- Highland Springs, Virginia two areas in the Varina district represented
by Mr. Kreiter. If a vote could be taken from these areas, I am sure they would
want this plant somewhere on the river.
Since the Varina Homeowners group formed nearly two years ago, they have
not had the best interest of the citizens of this area. It is felt that the
leader of this group has political ambitions. Many people in the area are
becoming highly resentful of this group. It is felt that they are trying to
take over the whole community and that is wrong.
Finally I would like to say that I have petitions with over a thousand
names opposing the Darbytown and Doran Road, and Cornelius Creek area has
petitions also. It has been brought to my attention that Mr. Pickett favors
Cornelius Creek because he feels the people want this location; but that is
not the true situation. A majority of the people in the area do not want the
plant in the Varina Magisterial District, they feel that it is an infringe-
ment on their human rights. The Carter Administration is supposed to be strong
on this subject, and I am mailing them a copy of this letter.
Hoping for the right decision, I remain,
Very truly yours,
Dolly Walker Rankin
cc Mr. Warren Carter, E. P. A.
The Honorable David Satterfield
President James E. Carter
Victor W. Kreiter, Chairman Henrico Board of Supervisors
VI-82
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u
Richmond, Virginia 23231
January 28, 1977
.*" * r -J_ f f W j«»
&
Miss Ellen R. Ramsey
The Advisory Council Historical Preservatory
1522 K Street N. ^., Room 430
Washington, D. C. 20005
Dear Miss Ramsey and Gentlemen:
We were advised that the Varina Farms, Henrico County, Virginia was under
consideration for the Virginia Landmark Registery. As you probably know this two
thousand acre tract of land is part of the parcel proposed for the Henrico County 201
Facilities Plan. We understand the parcel chosen for this facility is the parcel
with 867 acres, and it is not near the site where Pocohontas was supposed to have been
married or the old County Courthouse. Also, I would like to point out that gravel was
sold from this parcel by the owners and the land is an eyesore.
You have done much to preserve our history and I commend the Government for
founding your preservatory.
I would like to give you a few details concerning the involvement of our local
area regarding this farm.
1. There is an organization called Varina Homeowners Association consisting of
approximately eighty members (husband & wife and other relatives). Since
they do not want this plant in their area on the river, they suggested
first it be built on the Dorey Farm property on Darbytown and Doran Roads.
This is the parcel which most concerns us because it is in front of one
church and comes to the back door of another. It is in the heart of the
area and many houses border around it (three housing developments with septic
tanks). Petitions with six hundred signatures were collected from residents
whose property border this land protesting this as a site for the proposed
201 Facility.
2. The Varina Homeowners Association then suggested another site for the
facility, Charles City Road and Darbytown Road, known as the gravel pits.
Residents of that area initiated petitions and complaints.
The engineers have recommended Varina Farms sinje it is the least cost effective
and it is on the river. Many people in the Varina community feel that this plant should
go on the river if it has to be built in Varina.
Another site consideration was Deep Bottom Road, also on the river, and that too
has some history.
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WALTER LEMON
ROUTE 5 KQX 327A
RlCHhc^uj VA ^3231 ojEstem union
* ******
U-054021E012 01/12/78 ICS IPMMTZZ CSP PHAB
a MQM TDMT RICHMOND VA 100 01-12 0514P EST
HtNRICO COUNTY felS
TAL IMPACT bPANCH
TAL PROTECTION AGENCY
6 AND WALNUT ST
PHILADELPHIA PA 19106
BELIEVE DEEP BOTTOM SITE MEETS CRITERIA FOR LISTING ON THE NATIONAL
RtGISTtn AS A NATIONAL HISTORIC LANDMARK, HAVE NOTIFIED S.H.P.O.
VIRGINIA, NATIONAL REGISTER WASHINGTON DC, AND ADVISORY COUNCIL ON
HISTORIC PRESERVATION
MRS *ALU-R LEMUN
ROUTE b BOX 32 7 A
VA 23231
17: ib EST
M G H C 0 M P M C. M
VI-84
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RECEIVED
JAN2 4 1978
Eco! Sciences
VARINA HOMEOWNERS ASSOCIATION INC.
Route #5, Box 283-N
Richmond, Virginia 23231
TO ALL INTERESTED GOVERNMENT AGENCIES,
PUBLIC GROUPS AND CITIZENS:
Pursuant to Section 102(2)(C) of the National
Environmental Policy Act of 1969 and regulations
promulgated by the EPA {40 CFR 6; April"14, 1975),
the Varina Homeowners Association'is forwarding
for EPA review and comment this addendumn to our
previous drafts and letters concerning the proposed
Henrico County Wastewater Treatment facilities.
It is our understanding that the public transcript
record will be kept open for thirty days after the
Public Eiearing date. We are therefore, submitting
the attached comments to. be considered in the final
EIS.
Thany you for allowing us to participate in the EIS
process.
Sincerely yours,
Henry L. Nelson
President
Varina Homeowners Assoc- Inc
HLN:cnw
Enclosure
VI-85
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INTRODUCTION
Subsequent to the June 21, 1977, Public Hearing, the
Board of Supervisors of Henrico County met on July 13,
July 20, August 3, and August 10, 1977, to discuss the
***
facilities plan. At several of these meetings, concerned
citizens made presentations. The Varina Homeowners
Association with supporting signatures from approximately
1,000 citizens from eastern Henrico County, the League
of Women Voters, the Conservation Council of Virginia, the
State Landmark Commission and others, stated that any
river front site would be unacceptable to the citizens of
Henrico.
The Board of Supervisors asked the consultants to provide
another alternative for the location of the proposed waste-
water treatment plant site. The result was a site known
as "Deep Bottom West."
The site was to include three criterias:
1. Have minimal effect on the total, project costs.
2. Have minimal adverse impact on historic areas.
3. Minimize the displacement of persons.
VI-86
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After a review of the four orginial alternative sites,
the Varina Homeowners Association has found that the
Deep Bottom West site does not meet these three criterias
anymore than did the original Deep Bottom site.
COSTS
In actual construction costs the Deep Bottom West site,
although less expensive than the original Deep Bottom
site, costs about the same to construct as Upper Corneliu
Creek. However, the consultants have projected dollar
figures into the project which might be expended when
and if certain portions of the Pour Mile Creek Basin
would be served by sewage. These dollar amounts are
charged to the upper sites as construction costs, thus
inflating the total cost figures.
HISTORIC IMPACTS
The new site, "Deep Bottom West," was to be one which
would minimize adverse impacts on historic areas. This
is not the case. Our research indicates that the Deep
Bottom area has been continually occupied for approximately
10,000 years. Early records indicate that Indians
frequented the area and established villages in and around
the area.
The Powhatan Peace Tree was reported to have been located
in the area as a monument to early peace efforts between
VI-87
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the English and local Indians. (see appendix #1).
Land patents recorded in Henrico indicate that there
has been continually occupation of,the area since the
1600's. (see appendix #2).
During the Civil War the area was a part of entry dutf*
to the deep harbor area the mouth of Four Mile Creek.
Several battles were waged in the area during the summer
and fall of 1864. In July of 1864, four negro Union
regiments heroically withstood an emeny assault and
Sergeant Major Thomas Hawkins won the Medal of Honor for
rescuing the regimental flag in a battle at Deep Bottom.
(Note appendix - A Guide to Negro History in America)
page 215, NY, 1968 Philip T. Drotring.
Deep Bottom was the focal point for entry into the area by
detatchments of Grant's forces during the seige of Petersburg
in 1864. (see Battle Maps in appendix 4, 5, 6, 7 and 8,
see also 9-16)
In the past Deep^ Bottom was selected as a site for a
proposed regional park. Currently local black residents are
petitioning the local, state, and national Battlefield Park
Commission, to establish the area as part of the National
Battlefield Park System of Richmond. In addition to
pre-historic archaeologic discoveries it would appear that
insufficient dato has been researched to state that there is
no conflict with the establishment of a sewage treatment
VI-88
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plant at Deep Bottom West.
i.e. No mention is given to the existance of the pre-
Civil War structure known as the Yarborough House located
directly adjacent to the proposed Deep Bottom West site.
We have included a photocopy in the appendix to add to the
informational data of this site consideration (see appendix 17]
CONSLUSION
The Deep Bottom and Deep Bottom West site have adverse
impact on historical areas.
DISPLACEMENT OF PERSONS
Another point of contention with the original Deep Bottom site
was the displacement of persons. The new Deep Bottom West
site surrounds the previously displaced persons and causes
impact to far more people than before. Is this to be con-
sidered an improvement? How many people would realistically
seek to live in the very center of a sewage treatement plant?.
Conclusion: Deep Bottom West causes a greater impact on
the residential neighborhood than the original Deep Bottom
site. (see appendix 18).
VI-89
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ENVIRONMENTAL IMPACTS
Key issues which the Varina Homeowners Association have
identified through research and public participation are as
follows:
1. The degree of wastewater treatment required:
Although the consultants indicate that the County's
wastewater dishcarges will be brought into compliance
with effluent limitations designed to protect water
quality in the James River, we find this statement highly
questionable for two reasons:
A. The 1985 standards set by EPA concerning
discharge will be violated. The plant is not
designed to meet these standards.
B. There has been no statement expressed in any
of the EIS reports to date regarding the concerns of the
State Health Department about the danger of discharging
micro-pollutants into the river. The river is shared
by many downstream neighbors who are already having
water problems. We feel that it should be the
responsibility of the municipal government causing
the pollution to fund the treatment costs of the
discharge. We conclude that only safe drinking
water should be discharged into the river.
VI-90
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2. The Location of the treatment plant site:
The location of the sewage treatment plant in Eastern
Henrico County has drawn criticism from local residents.
The only site which has received any public support has
been "Upper Cornelius Creek." This site has been identified
as the site which is the most environmentally acceptable
site in Eastern Henrico County.
3. Secondary growth impact:
The Varina community is both the first and last frontier
area to be settled in Henrico County.
The adopted land use plan indicates that it should be
done in a careful, balanced manner; allowing for main-
tenance of argicultural areas, recreational lands, and
low density residential development.
The area is highlighted by original river plantations
dated to the early 1600's, Civil War battlefields, and a
state designated "scenic byway, (State Route 5).
The big question seems to be; how can you place a sewage
treatment plant in the midst of this environmentally sensitive,
cultural, historic area and imagine that it will not have
a growth inducement effect which will be irreversible and
adverse?
A sewacre treatment olant and the service it orovides .
allows, and encouracres develooment wherever its trunklines
VI-91
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and wipes reach. In fact, the sewaae treatment plant and its
services are orobably the largest growth catalyst yet to
be developed.
HIGHWAY INFLUENCE
When you combine the services provided by sewage plants
with undeveloped real estate and the proposed interstate
highways (#295, £1-95), the outfall could be overwhelming.
Such is the case in the Varina district located in Eastern
Henrico County. The EPA, Interior Department, and the
Varina Homeowners Association, Inc., all agree that a western
alignment of $295, #1-95, would be more compatable with the
land use plan and the environment of Eastern Henrico County-
We feel that if the sewage treatment plant is located in a
position east of the proposed highway, "along the river,"
that the plant location will cause pressure to locate the
interstate road in a easterly direction.
This is easy for anyone to understand. If the plant is
located along the river then gravity sewage service will be
available to most interchange points proposed for Eastern
flenrico along the #295 corridor. The further the location
to the east the larger the area slated for intensive growth,
(i.e. the state originally planned to four lane Route #5,
and other connector roads between the original corridor
proposed for #295, and Laburnum Avenue to the west.)
VI-92
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Interchanges, four lane roads, and available sewage
service all combine to form growth inducement ingredients
that are impossible to combat.
The real estate values will also change due to the
investment expectation and inflation brought about because
of available sewage and proposed highways. The higher the
cost of real estate the greater the pressure for intense
development to recoup the investment extended.
In order to protect the National Battlefield Park,
historic sites, and environmental areas, we must insist
that a western alignment be given to #295 and that the
sewage treatment plant be located in the industrial area
of upper Cornelius Creek. If this is not done, and the
sewage treatment plant is located on the river, it will
draw the highway to itself like a magnet, due to the
investment potential which could be realized by land
speculators and local real estate agents. In other words,
if the plant is located on the river, the Varina Historic .
District will be opened to development which cannot be
controlled and may resemble a modern version of the,
"Oklahoma Land Rush."
VI-93
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COURT CASES
Recent court decisions seem to indicate that where
services are available, local government are not able
to restrict growth or development. Developers have won
dicisions against municipal governments for trying to
maintain low density growth where services such as
sewage was available. Contractors have argued successfully
that they were being denied the highest potential for
their investments. If Henrico County is allowed to violate
its own land use map, the same conditions will prevail,
chaotic, uncontrolled growth. If the plant is located at
upper Cornelius Creek the county can add service as it is
needed, and maintain control of its growth in a orderly,
planned, progression.
THE FOUR MILE CREEK DRAINAGE BASIN
This area of real estate seems to be the area that the
county is so anxious to give immediate gravity sewage
service. Maps, provided by the County, suggest uses
such as agriculture, recreation, conservation and low
density residential. Of all the uses projected by the
county, non seem to suggest the immediate need for sewer
service.
VI-94
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If and when the county wishes to expound sewage
service to the Pour Mile Creek area, all consultants
agree that it could be accomplished with a small
pumping station. If, however, the plant is located on
the river the basin will be developed intensively du£
to the availability of sewage and the investment pentential
for developers. The uses which the county planners have
slated for the area will become an impossible dream.
The plant location on the river will also bring #295
through the Four Mile Creek drainage basin and cause
development in and around the proposed interchanges.
The Four Mile Creek Basin is the only area where Henrico
County can obtain a large unpolluted fresh water supply
for its future use. It is also the last free flowing
stream remaining in the county which supports a large
wildlife population.
Gravity sewage service will cause the end to this valuable
natural resource and environmental protection area.
In order to preserve balance in this drainage basin, it
would make more sense to add service only to the portions
of the basin where it was necessary. This can best be
controlled through force-mains and a pumping station. Both
of these have less impact on the environment than do a
gravity s.ewage transport system and treatment plant,
VI-95
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OTHER SECONDARY GROWTH IMPACTS
In areas where sewage service is available rapid and
unplanned growth may occur when such a large undeveloped
area of real estate is opened up at once. Services
such as schools, fire, police, garbage, transportation
and others may cause increased tax rates and strain the
county budget. Rapid growth also adds to inflation and
incresase tax costs due to the spiraling cost of building,
The short term benefits of increased growth activity are
soon worn thin with the increased cost of services. Ask
any big-city mayor!
WHAT ABOUT WATER?
Currently Henrico gets its fresh water from the City of
Richmond. The source of supply is the James River. This
river is very polluted and is getting worse each day. As
the county adds sewage service it makes the local citizen
give up water wells. Thus, the citizen is dependant on
the county to provide water services via the city.
Richmond's water treatment plant does not meet current
standards let alone future demands. This is yet another
factor which suggests that growth should be measured and
not left to providence. Norfolk is looking for water and
the cost projections, to provide adequate supply are about
two hundred million dollars.
VI-96
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EVALUATION OF THE DEEP BOTTOM WEST SITE
A. Adverse site impacts.
Adverse environmental impacts identified as associated
with the construction of the proposed treatment platn
and the use of the treatment facility and landfill
include the following:
1. Removal of 150 to 170 acres of young pine/
hardwood vegetation and subsequent loss of suit-
able wildlife habitat.
2. Accelerated erosion and sedimentation of Round-
About Creek from clear cutting and construction
activities, particularly on the central portion of
the site.
3. Accelerated erosion and sedimentation of Four
Mile Creek from landfilling operations east of
Deep Bottom Road.
4. Potential contamination of ground water due to
landfilling operations.
5. Occupation of 420 acres of land designated as
"prime agriculture" by the county.
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6. Occupation of 40 acres of land now in active
cultivation.
7. Negative visual impact on users of Kingsland
Road and Deep Bottom Road.
8. Negative impact on users of Deep Bottom
Boat Landing due to simultaneous use of Deep
Bottom Road by car-towed boat trailers and trucks
transporting sludge to the landfill site. In
addition. Deep Bottom Boat Landing may be expanded
by the county. The area was also slated as a
possible regional park site.
Recently local black citizens have petitioned the
Interior Department to include the site in the
Richmond Battlefield Park system. During the Civil
War Negro troops entered battle here, with one earning
the Medal of Honor.
9. Petential noise and odor effects upon remaining
adjacent property owners.
Vl-i
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10. Potential stress and social disorientation of
more vulnerable low income, minority race, residents
desiring relocation.
11. Flood prone areas identified by HUD under the National
Flood Insurance Program are nearby. The county intends
to purchase and add portions of the areas to its
property. It may be difficult to monitor the site
to prevent sludge, filling in the flood areas, in the
future expansion of the plants.
B. Adverse Transportation impacts.
Adverse impacts of the proposed transportation lines
include the following:
1. Disturbance to approximately 7 to 7.5 miles of
stream valley vegetation by sewer corridor construction
including removal of both streambank and mature
hardwood vegetation.
2. Subsequent erosion and sdeimentation in Four
Mile Creek and lower Round-About Creek and two un-
named intermittent streams, particularly in steeply
sloping areas.
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3. Distubrance of stream valley vegetation
from crossing two intermittent and six permanent
streams.
4. Disturbance of a bearer community and
possible disruption of feeding waterfowl adjacent
to the area.
5. If soils are left bare of vegetation for a
lengthly period of time, erosion and nutrient
lose may'discourage regeneration in bushy hardwood
vegetation.
6. The interceptor corridor will fall in a special
flood hazard area (identified by HUD under the
National Flood Insurance Program) just north of its
discharge point on the James.
7. The greatest impact is the opening of approxi-
mately 8,600 acres for immediate development on
gravity sewer, 500 of which falls outside Henrico
County's 1995 phasi.ng line.
Under normal conditions growth in this area would
develop gradually. This construction allows immediate
and uncontrolled growth; we cannot allow this to
happen .'
VI-100
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C. Mitigating Measures
The Varina Homeowners Association hereby petitions
the EPA to take the following mitigating measures:
I. Refuse to fund any river front site
(including Deep Bottom West).
2. Indicate that funding of the Upper Cornelius
Creek site would be immediately forthcoming.
3. Consider the realignment of the transport
system (if Upper Cornelius Creek is selected) to
follow the? proposed Laburnum Corridor.
4. Consider a new site for discharge into the James
River near the mouth of Cornelius Creek.
5. Insist that the discharge be treated and released
as safe drinking water into the James River.
6. Recompare the analysis of Deep Bottom West site
with the original four sites. Take careful note of
the relative acceptability of plant sites and
associated impacts. The only plus factors associated
with Deep Bottom West are questionable. (see p.20
Ecolscience addum #1)
VI-101
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Flood plains. The county intends to purchase
floodplain lands adjacent to the sludge land-
fill east of Deep Bottom Road. What assurance
do we have that sludge storage expansion will
not include the flood area?
Soil erosion and sedemintation; consultants
indicate that this is a problem with both sites,
while under construction, and with the trans-
portation line.
Odor and noise. The closeness of the plant to
residents who will be surrounded by the plant
does not present danger of odor and noise problems'.
Plant site. Related interceptor impacts, these are
to be considered negative not positive as outlined
previously the largest negative impact is the
immediate opening of 8600 acres to intensive development
potential.
Water Quality. There is a possibility of ground
water contamination. Also the loss of Four Mile
Creek to development which may cause Henrico problems
in the future due to its loss of fresh water.
Sensitive areas including flood plains and wetlands
are adversly affected by the plant sludge area and
by the proposed transportation route.
VI-102
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Residential displacement. Although not directly
a plant design such as Deep Bottom West
causes the property to lose value
without compensation
Plant site and transportation costs are not
sufficiently less to merit the selection of this
site ,
Conclusion: EPA should not fund any site except
the one which is the MOST environmentaly acceptable,
"Upper Cornelius Creef(. "
VI-103
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At this point, extensive appendices were attached to
the previous letter, composed primarily of supporting docu-
mentation of the historic significance of the Deep Bottom
West site. Several attachments are reprinted here, all of
the appendices are on file with EPA, Region III; some are re-
printed as attachments to a letter from Mrs. Walter Lemon,
dated January 10, 1977 which is included in Appendix D to
this FEIS.
VI-104
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YARBOROUGH HOUSE 43-290 (Dutch Gap Quad)
The Yarborough House is an excellent example of the type of two storey farm
dwelling popular after the Civil War. Although presently in decay, it stands
unaltered except for the addition of asphalt siding over the original poplar
weatherboards. Note that the house is set on brick piers rather than on an
English basement, as was usual for houses of this scale built prior to the
Civil War.
Center-hall plan; 3-bay; ell extension on rear; tall, narrow exterior end
chimneys of random American bond.
The family cemetery is located across the road o.n the north side of Kings -
land Road.
230
4
"" coxvi
VI-105
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VAR1HA HOiviJIOWNERS ASSOCIATION, INC.
Route 5, Box 233-r!
WHEREAS: The Environmental Protection Agency and various
state agencies mus'1; approve the final site location
and point of discharge for The proposed Henrico
County Sewage Treatment Plant, and
WHEREAS: Citizens of Varina have petitioned the County
to select a site compatible v/ith. the Land Use
Ivnd Regional Planning Commission's 20<
Study indicates that larger volumes of discharge
may be execute-.'! at many pclucs between the fall
line and the 13en;]amiu Harrison bridge on the James
River,
BE IT THEREFORE RECO.bVEl); That xhe federal Environmental
Protection Agency and other related state cigencies
should wi I'.hl'ol.1 f uridin^ for the proposed sewage
;)l---i!it i'oi' llc-MiL" 1 cu County unless, and until, the
following: Cf.-riditiona are met;
1. That the County select a site for the treatment plant
that wouLd be located within the designated industrial ,
area as shown on the adopted Land Use IV1 ap of Henrico
County Circa 19'/'4, and
2. That the Hounty address attention to the question of
possible eorrkamin.fi tioa of the Hopewell drinking water
in the Environmental Impact iJtudy avid in the design of
the treatment plant, and
'3» That tlie -County t:;oi/e tivo discharge point i'urtKer upstream
<;,}{ tf.i;v J'ines Kivi.'r i.r, order t.(u:t (a) the nol.lution
r.-..; L-1' i. i.l o/i the lie, .,-;\.'ell di-rrikuti. •; vvutc-r mi(.;i'i.t be reduced,
((•>) the discharge ()oint bo .looited in the: general
v Lcinlt;r ^f Corrioi J ius 'Crcsek, (c) th^ 'tx-ansport system
be co'n.s ti-;.ioted-- ' i >. ;ui o L l/'imient soii'iewh,..i t parallel to tlie
proposed Laburnum alignment for the purpose of serving
the treatment plairu when located within the identified
industria.] area.
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VARINA HOMEOWNERS ASSOC. INC.
"A SUMMARY REPORT OF THE 201 STUDY FOR
THE SITE SELECTION OF THE HENRICO
SEWAGE TREATMENT PLANT"
The Varina Homeowners Assoc, Inc-, is on record
as favoring quality growth standards for our community.
The Association feels that for the most part the adopted
county land use map, if maintained, will serve as an
effective guide to growth which will be controlled, balanced,
and take place over a timed cycle known as phasing. As
proposals and circumstances are presented which may adversely
affect the community, we respond and express our concerns, in
order that the decision-making process may be improved.
The Varina Homeowners Assoc. Inc., has made every effort
to encourage community participation in the discussion and
planning of the proposed 201 facilities. Our organization
has encourgaed the community to attend public meetings,
research alternative sites, sign petitions, place phone
calls, and express themselves by letter concerning their
viewpoints on the sewage treatment plant location.
To date, wo have collected approximately J.OOO signatures
on petitions favoring an industrial park location near the
upper regions of Cornelius Creek for the location of the
sewage treatment pJont.
VI-107
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Many other citizens support this position and
have expressed themselves by letter and other means
to the appropriate agencies. We hope the E.P.A. will
acknowledge citizen effort and positive participation
in this municipal project and will refuse to fund any
site which is not located wj thin the identified industrial
area on the adopted use map.
The association maintains that, if the sewage treat-
ment plant is located on the James River, the change which
will come about in Varina will be rapid, uncontrolled, and
detrimental to the quality qrowth so necessary if Eastern
Henrico is to remain an asset and not a liability to the
county.
Recent court case decisions indicate that where
municipal services such as sewage are available, local
governments cannot maintain restricted or low density
housing profiles. The adopted land use map suggested however,
that the corridor between the historic Route #5, and the
James River should be maintained as low density residential,
agricultural conservation and recreational area. If the
county is allowed to violate its own land use map in an
effort to promote clesnity and rapid growth; does this not
make a joke of the entire public process of land use planning?
VI-108
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Historically E.P.A. has not been an agency to be
used by local governments as a growth inducement catalyist,,
We demand that the E.P.A. help the responsible local citizens
maintain the integrity of the adopted land use plan and
the phase growth concept by refusing to fund a project which
violates municipal growth guidelines established and adopted
for 1995.
After making a careful review of the environmental
factor which have been presented in the E.I.S. and the
various supplements the Association is quite puzzled as to
why the industrial area near the upper regions of Cornelius
Creek was not selected. A comparison of the five sites
indicates that in considering the primary and secondary
impacts, Cornelius Creek is the most acceptable site.
A comparison of the social and economic impacts
indicates that Cornelius Creek is again the most acceptable
site. In fact, a site comparison prepared by the consultants
indicated that Cornelius Creek is the most acceptable site,
thus far studied, in Eastern Henrico County.
At this point we must ask an important question. Is
the environmental data which has been assembled into volumes
regarding this plant site location to be regarded as mere
page fillers in the final site selection? We feel that a
careful analysis of the consultants report emphasizes that
VI-109
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the E.P.A. should have little choice but to insist that
the treatment plant for Henrico County be constructed
in the environmentally compatable industrial area on the
upper regions of Cornelius Creek!
Another area of contention which we feel has no£ been
sufficiently treated or discussed is that of the treatment
of the discharge and its effect on the downstream communities.
The state health department has expressed a great deal of
concern regarding the effect that micro-pollutants may have
on the Hopewell drinking water. However, to date we cannot
find any information in the environmental impact statement
either acknowledging this problem or addressing any concern
as to its merit.
We feel that the discharge should be treated to a point
that it becomes safe drinking water suitable for human con-
sumption before being released into the river. It should
clearly be the responsibility of the municipal government
causing the source of pollution to treat the water to safe
levels and not the sole responsibility of the persons who
wit;hdarw the wat:or downsl-rf-am for public consumption.
To do less in our opinion is to commit criminal neglect
and constitutes a complete disregard for the safe drinking
water act.
VI-110
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In direct proportion to the method of discharge,
we find studies which suggest the point of discharge
which might be acceptable on the James River. The
county has selected the Varina Farm area, as a point of
discharge based on studies conducted by the state water
control board and others.
A recent #208 study conducted by the Richmond Regional
Planning Commission suggests that other points of discharge
might be utilized in volumes larger than originally antici-
pated in the. area between the fall line and the Benjamin
Harrison Bridge.
This imformation 'may suggest that other discharge
points might be utilized further upstream which are less
environmentally damaging than Historic Varina Plantation.
If an upstream discharge point could be established, this
may, in conjunction with a new alignment for the transport
system to the point of discharge, make it more cost effect
to construct a plant in the confines of the identified
industrial area of upper Cornelius Creek. Such a location
change would also .increase the distance betv/een the discharge
point and HopeweJL's raw water intake.
A careful look at the cost analysis makes one wonder
why such differences occur each time the material is
VI-111
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reviewed. It seems that the cost figures in the final
supplement are more of a defense for a decision which
was already made, rather than data which would assist
someone in making an objective decision.
In examining the various components which make up the
cost analysis it appears as if the consultants are projecting
new costs into the profile which inflate the end results.
It would appear that sites located in the upper regions of
Eastern Henrico County (Cornelius Creek and Darbytown) are
being charged with cost figures which might be expended if
they were to provide the same service area as Deep Bottom
West.
It would be a simple matter to locate the sewage
treatment plant in the industrial area near the upper
Cornelius "Creek and add future service to the lower area
with the strategic location of the County's proposed
pumping station, for the Four Mile Creek drainage basin.
This would allow for a more orderly progression of growth
and provide the County with a better argument for restricting
growth in accordance with the adopted land use map. In
any event, the cost varibJes do not justify the selection
of the Deep Bottom site.
VI-112
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In summary we feel that the E.P.A. should not
fund a site which would encourage out of phase develop-
ment.
The E.P.A. must consider the cost of selecting a
site which is not the most enviromentally acceptable
and reject it for one which is.
The E.P.A. must consider the question of the proper
treatment of discharge and insure that we do not add to the
pollution of a major water resource.
The Varina Community is expected to endure the plant,
the loss of its land use map, and chaotic growth. The cost
is too high! The E.P.A. must insist that the plant location
serve current needs and that the community not be molded to
feed its trunk line.
If Henrico is to receive funding for a site it should
be located in the industrial area so that the community
environment, identity, and destiny are assured.
VI-113
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D. Written Governmental
Comments on the Draft EIS and
Addendum Number One
-------
D. WRITTEN GOVERNMENTAL COMMENTS ON THE DRAFT EIS AND
ADDENDUM NUMBER ONE
This section contains reprinted comments received by EPA
from various levels of local, state, and federal government.
Some specific comments on major issues are reprinted in
Appendices C, D, E, and F. The following other comments
were received:
VI-114
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BOARD OF SUPERVISORS
COUNTY OF NEW
Office of County Administrator June. 27, 1977
WL. W. S. Vewhiut
Acting County Managed.
County o^ Hen^ico
P. 0. Box 27032
Richmond, V*AQ -in
the. HenAico Re.gtoncutL WaAtewateA. FacAJUtieA Planning Study and the.
fie.c.ommended ptan.
The. SupeAviAou noAhfaUvm tknAJt tnteAut -in the. County o& New; Kent' A
potential, ofi joking the. pfiopo&ed £y&tem at 4acfi time. ai> t& e.c.onomJ,caULy
ke.e.p CM •in&otume.d ofa the. pAogfLeAA o& tivit> matteA.
Royai E.
ChaiAman, BoaAd o& SupeAviAou
pbp
Vi-115
County Office Building
P O. Box 5O, New Kent. Virgi ma 23124 / 8O4 - 966 - 2764
-------
I^kould like to call your attention to Chapter 6, page 6-6
and to plate 6.1 on the opposite page. Here you find a brief
description of the Hanover County role in your plan. The
statement that construction of these facilities is now underway
with completion expected in 1978 is accurate. The first service
through the Strawberry Hills pumping station should take place
during the current calendar year. We look forward to working
in harmony with our neighbors to the southwest.
You will note in Chapter 7 on page 7-4 a statement that
Hanover County must negotiate a contract with Henrico County
to accept and treat wastewater from this area. There is some
concern that this negotiation has not been consummated. Hanover
County officials are assuming that our sister County will charge
us those amounts indicated in table 7-10 on page 7-23. Thes~e
figures have been utilized by Hanover County's consultants in
developing our bond programs. Changes made by Henrico County
at this late date resulting in an increased charge to Hanover
County would have a very negative affect on our proposed utility
rates which are already high in relation to our neighbors' rates.
I am thankful for this opportunity to make comments and
for the cooperation and assistance received from Henrico County
staff and officials in planning for our sewer program.
VI-116
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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
P.O. Box 10026 - Richmond, Virginia 23240
July 11, 1977
Mr. Alvin R. Morris
Acting Regional Administrator
U. S. Environmental Protection Agency
Region III - 6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Morris:
Re: EVT - Draft EIS - Wastewater Treatment Facilities
Henrico County, Virginia
U. S. Environmental Protection Agency
The subject document adequately addresses Soil Conservation Service
concerns.
Table IV-1, Soil Associations in the Henrico County 201 Study Area,
required some alterations. A hand corrected copy is enclosed for
your use in preparing the final EIS.
Sincerely,
'D. N. Grimwood
State Conservationist
Enclosure "
cc: Council on Environmental Quality (5 copies)
Office of the Coordinator of EQ Activities, USDA
Gerald R. Lowry, Acting Director, Env'l. Services Division, SCS,
Washington, D.C.
R. M. Davis, Administrator, SCS, Washington, D.C.
C. J. Gillman, Director, NETSC, Broomall, Pa.
William 0. Boothe, AC, Franklin, Va.
Wallace E. Cummins, DC, Richmond, Va.
VI-117
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COMMONWEALTH of VIRGINIA
Council on the Environment
July 15, 1977
Mr. Alvin R. Morris
Attention: Mr. Joe Piotrowski
EIS Preparation Section
U. S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
SUBJECT: Wastewater Treatment Facilities for Henrico County,
Virginia
Dear Mr. Morris:
The Council on the Environment has completed its review of
the subject Draft Environmental Impact Statement. The following
agencies participated in that review:
State Water Control Board
State Department of Health
Commission of Game and Inland Fisheries
Marine Resources Commission
Air Pollution Control Board
Virginia Institute of Marine Science
Soil and Water Conservation Commission
Commission of Outdoor Recreation
Historic Landmarks Commission
Department of Agriculture and Commerce
State Corporation Commission
Department of Conservation and Economic Development
Virginia Port Authority
Department of Highways and Transportation
Division of Industrial Development
Virginia Energy Office
Virginia Research Center for Archaeology
Coastal Zone Management Program
Office of Outer Continental Shelf Activities
Based upon our review of the document and the comments that
we have received, we would like to say that the EIS is in general
well written and comprehensive. We do have several specific ob-
servations that pertain to certain aspects of the report.
Vl-118
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•Mr. Alvin R. Morris
July 15, 1977
Page two
We are concerned over the failure of the report to adequately
address the impact, if any, on the downstream potable raw water
intakes, two of which are within eight miles of the projected point
of discharge. We support the discharge into River Section 16 in-
stead of Section 17 because of the ecologically sensitive and pro-
ductive oxbows in Section 17.
The State Water Control Board has noted that the Deep Bottom
site is the most environmentally sensitive as well as having the
potential for inducing the greatest development. There could be
severe siltation of wetlands below this site unless extra precau-
tions are taken, especially during construction. The EIS points
this out but leaves the impression that the four sites are equally
environmentally acceptable.
We noted that Hanover and New Kent Counties were not considered
in the impact statement study, although they are in the study area.
The Soil and Water Conservation Commission has commented that
the document properly addresses erosion and sediment control, and
pointed out that the erosion and sediment control plan can be sub-
mitted to the local plan approving authority or to the Commission
itself for review and approval.
We hope you will find these comments helpful in your further
considerations. If you have any questions, please do not hesitate
to call us.
Sincerely,
Susan T. Wilburn
Acting Administrator
STW:RFW:dja
cc: Honorable Earl J. Shiflet, Secretary of Commerce and Resources
Mr. J. L. Hamrick, State Water Control Board
Mr. 0. H. Adams, State Department of Health
VI-119
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= *
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
REGIONAL OFFICE
CURTIS BUILDING, SIXTH AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
REGION
August U, 1977
IN REPLY REFER TOt
3CE
Mr. Alvin R. Morris
Acting Regional Administrator
Environmental Protection Agency
Region III
Attention: EIS Preparation Section -
Environmental Impact Branch
6th & Walnut Street
Philadelphia, Pa. 19106
Dear Mr. Morris:
We have completed our review of the Draft Environmental Impact
Statements for Wastewater Treatment Facilities for the Counties
of Henrico and York. Our only comment with respect to these
statements is that the actual location of each plant in relation
to the 100 year flood plain is not clearly indicated. We feel
that an additional appendix, or at least more specific maps at
an appropriate scale, should be included to define this relation-
ship. There is a completed Flood Insurance Study for Henrico
County which should be of some use accomplishing this.
We would appreciate receiving copies of the final EISs upon their
completion. Thank you.
Sincerely,
R. Marcj^; Jr.
Assistant Regional Administrator
for Community Planning Development
VI-120
AREA OFFICES
BALTIMORE. MARYLAND - PHILADELPHIA. PENNSYLVANIA • PITTSBURGH, PENNSYLVANIA- RICHMOND, VIRGINIA -WASHINGTON, D.C.
Insuring Offices
Charleston, West Virginia . Wilmington, Delaware
-------
JAN 10 SECT
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
P.O. Box 10026 - Richmond, Virginia23240
January 6, 1978
Mr. Jack J. Schramm, Regional Administrator
U. S. Environmental Protection Agency
Attn: Environmental Impact Branch
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schramm:
Re: EVT - Addendum No. 1 to the Draft Environmental Impact
Statement for the Proposed Henrico County Wastewater
Treatment Facility
The subject document has been referred to me for comments.
Page 9, par. 3 of the Addendum indicates that the entire 155 acres
have been designated "prime agricultural land" by the Henrico County
Future Land Use Plan. This is true - the Henrico County Future Land
Use Plan does designate the area as prime agricultural land. However,
the Soil Conservation Service, as the recognized Federal authority,
does not class the total area as prime agricultural land. I have
enclosed a copy of the Henrico County Progressive Soil Survey sheet.
On this map we have outlined the approximate area of the Deep Bottom
Westside Site. Prime soils have been circled in green ink. From this
you can determine the percentage of the area that is prime agricultural
land.
Page 9, par. 4, last sentence, should be changed to read as follows:
On the central portion of the site, soils will be subject to moderate
to severe erosion hazard if vegetation is removed for construction.
Page 13, par. 3, item C - We would suggest that you delete the phrase
"seasonal flooding" and insert "seasonal high-water table".
Thank you for the opportunity to comment on this document.
Sincerely,
C ..-..
D. N. Grimwood
State Conservationist
Enclosure
cc: Council on Environmental Quality (5 copies)
Office of the Coordinator of EQ Activities, USDA
R. M. Davis, Administrator, SCS, Washington, D.C.
Neil Sampson, Acting Dir., Evt'l. Services, Wash. D.C.
C. J. Gillman, Director, NETSC, Broomall, Pa.
W. 0. Boothe, AC, Franklin, Va. VI-121
W. E. Cummins, DC, Richmond, Va.
_
VV
| J
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United States Department of the Interior
OFFICE OF THE SECRETARY
Northeast Region
15 State Street
ER-77/500 Boston, Massachusetts 02109
January 23, 1978
Henrico County EIS
Environmental Impact Branch
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Gentlemen:
The Department of the Interior has reviewed Addendum Number 1
to the draft environmental statement for wastewater treatment
facilities, Henrico County, Virginia.
Our concerns are chiefly related to potential impacts on out-
door recreation.
The text references several open space and recreation areas
that will be directly impacted by the construction and operation
of the proposed Deep Bottom West wastewater treatment plant and
its related facilities. These areas include: (1) approximately
300 acres of open space that will be lost for a sludge landfill
site; (2) approximately 7.5 miles of stream valley that will be
disturbed by construction of a sewer interceptor; (3) the
James River and its tributaries, whose water quality may be
adversely reduced by effluent discharge and erosion; and (4)
the Deep Bottom Boat Landing, whose access may be impaired by
use of the same road by construction and sludge trucks.
The text notes that designation of the proposed landfill site
as "prime agriculture" open space in the Henrico County Future
Land Use Plan will represent a conflict regarding its compat-
ibility with a sewage facility (p. 11). However, there is no
mention as to how this conflice and loss of open space relates
to and will impact the County's need for open space. This applies,
also, to the disturbance of approximately 7.5 miles of stream
valley during the construction of interceptor lines (p. 15). The
document should contain a discussion of the impact from the loss
of open space on the County and any mitigating measures that will
be taken to compensate for this loss such as opening the lands
surrounding the proposed treatment plant to public use and/or
providing recreational trail use along the interceptor lines
(as alluded to on page 15).
VI-122
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In the same context, we are concerned with the impact to water quality
caused by the effluent discharge and erosion due to the loss of vegata-
tion from construction of plant and interceptor facilities, poor soil
drainage conditions, steep slope contours, and seasonal flooding (all
discussed on pages 9, 11, 12, 13, and 15). Fourmile Creek, Roundabout
Creek, and their tributaries feed into the James River which has been
identified and evaluated for future study for possible inclusion as a
potential candidate into the National Wild and Scenic Rivers System. We
believe that the mitigating measures identified for erosion (p. 16) do
not begin to adequately and thoroughly address methods of lessening and
controlling this extensive erosion problem, i.e., "soil and erosion con-
trols involving best available techniques should be utilized as prescribed
by County ordinance, although these regulations do not currently apply
to public utility construction;" (p. 16).
The text states (p. 13):
"negative impact on users of Deep Bottom Boat Landing due to
simultaneous use of Deep Bottom Road by car-towed boat trailers and
trucks transporting sludge to the landfill site. In addition, Deep
Bottom Boat Landing may be expanded by the county. Although this
possible expansion is not in conflict with the proposed landfill
site (LaVecchia, 1977), increased future use may exacerbate any
traffic problem on Deep Bottom Road."
While the impact to the users of the boat landing is identified, there
should be discussion of any potential reduction in the use of this rec-
reation facility. This is of major importance since public access to
water for fishing, swimming, and boating had been identified as a high
priority need by the Commonwealth of Virginia's Commission of Outdoor
Recreation in their 1974 Virginia Outdoors Plan.
In addition, consideration should be given by the County to the multiple-
use of the existing wastewater treatment plants and pump stations to be
abandoned and those proposed for construction, along with their related
facilities (fig. III-2, p. 14) for the purposes of open space, recreation,
and environmental education, especially since construction and operation
of the proposed treatment plant will directly impact existing open space
and recreation lands. Multiple-use opportunities would be in accord
with the 1974 Virginia Outdoors Plan and the efforts of the Bureau of
Outdoor Recreation and the Environmental Protection Agency to promote
multiple-use in conjunction with water quality improvement facilities.
vi-123
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We recommend that all appropriate measures to safeguard cultural resources
be accomplished in consultation with the State Historic Preservation
Officer.
The newly proposed site could conflict with a producing sand and gravel
pit located 0.8 miles northwest. Although this pit will not conflict
with the buildings, it could interfere with sewerage pipeline placement.
The addendum should discuss possible impacts of the proposed landfill on
ground water and should indicate planned mitigation, including appropri-
ate design, operating procedures, and monitoring.
Sincerely yours,
X?
William Patterson
Regional Environmental Officer
Vl-124
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COMMONWEALTH of VIRGINIA
? Environment
January 30, 1978
_ ., .; r- f 903 NINTH STREET OFFICE BUILDING
SUSAN T.WILBURN CounCllOll tflC LH VU'Onment RICHMOND 23219
ACTING ADMINISTRATOR 804-786-4500
Mr. Jack J. Schramm
Henrico County EIS
Environmental Impact Branch
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
SUBJECT: Henrico County, Virginia Wastewater
Treatment Facilities
Dear Mr. Schramm:
The Council on the Environment has com-
pleted its review of the subject Addendum Number One
to the Draft Environmental Impact Statement. The
following State agencies participated in that review:
Commission of Game and Inland Fisheries
Commission of Outdoor Recreation
Department of Agriculture and Commerce
Department of Highways and Transportation
Division of Industrial Development
Marine Resources Commission
State Air Pollution Control Board
State Department of Health
State Water Control Board
Virginia Historic Landmarks Commission
Virginia Institute of Marine Science
Virginia Soil and Water Conservation
Commission
Virginia Research Center for Archaeology
Based upon our review of the document and
the comments that we received, we make certain recommen-
dations herein that we hope will be useful to the Environ-
mental Protection Agency in its consideration of this major
action.
The staff of the State Water Control Board has
commented that the statements concerning the effects of
the proposed project on the surrounding environment are too
general. A serious deficiency of the Addendum
VI-125
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Mr. Jack J. Schramm
January 27, 1978
Page two
is the absence of discussion of the possible impacts of
the project's effluent on the water quality of the James
River. The staff of the Water Board also commented that
every measure should be taken to prevent the possible
groundwater contamination from the landfill site.
The staffs of both the State Water Control
Board and the State Department of Health recommend that
the Environmental Protection Agency should address the
process of composting sludge as a feasible alternative
if the matter is to be further pursued. The Final En-
vironmental Impact Statement should provide a section to
address this.
The State Department of Health has no objec-
tion to the addition of the Deep Bottom West site as an
alternative for a treatment plant site but is still con-
cerned that the impact of the proposed sewage discharge
on the downstream raw water intakes for public water
supplies have not been adequately addressed. This weak-
ness was pointed out earlier in our letter of July 15,
1977, to Mr. Alvin R. Morris.
The Virginia Soil and Water Conservation Com-
mission has noted that due to the recent amendment to the
State Erosion and Sediment Control Law by the General
Assembly, the construction of water or sewage treatment
facilities is no longer exempt from the sediment and
erosion control plan requirements. Therefore, statement
two under Section F, Mitigating Measures, on page 16 is
incorrect, and an erosion and sediment control plan must
be submitted and approved prior to construction. For
further information, please contact:
Mr. Gerard Seeley, Jr.
Chief Engineer, Virginia Soil and Water
Conservation Commission
830 East Main Street, Suite 800
Richmond, Virginia 23219
(804) 786-2064
The Virginia Research Center for Archaeology
has determined that a field survey at the site is necessary
prior to disturbance of the site. Due to the potential
archaeological value of the site such a survey is necessary
to determine the extent and significance of archaeological
remains that would be disturbed by the project. The pipe-
line routes should also be surveyed.
VI-126
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Mr. Jack J. Schramm
January 27, 1978
Page three
The Virginia Department of Highways and Trans-
portation has determined that segments of the proposed
treatment system involve a number of secondary and primary
roads in the area. Standard crossings of Interstate
Routes 64 and 95 appear to be involved which will cause
disruption of traffic.
There are two areas of involvement within the
area of Route 295. One of these is in the interchange
north of Richmond and the other is in the Varina area.
Any part of installation that will occupy right-
of-way on roadways maintained by the Department of Highways
and Transportation must be covered by a permit. Information
regarding the proper procedures for obtaining such permits
should be requested from:
Mr. R. C. Hundley
Environmental Quality Engineer
Department of Highways and
Transportation
1221 East Broad Street, Room 1114
Richmond, Virginia 23219
Thank you for the opportunity to review and
comment on this document. If I can be of further assistance,
please let me know.
Sincerely,
Susan T. Wilburn
Acting Administrator
STW:RFW:jlp
CC: The Honorable Maurice B. Rowe, Secretary of Commerce
and Resources
Mr. Raymond E. Bowles, Director, Bureau of Surveillance
and Field Studies, State Water Control Board
Mr. Oscar H. Adams, Director, Division of Engineering,
State Department of Health
Mr. Gerard Seeley, Jr., Chief Engineer, Virginia Soil
and Water Conservation Commission
Dr. William M. Kelso, Commissioner, Virginia Research
Center for Archaeology
Mr. R. C. Hundley, Environmental Quality Engineer, De-
partment of Highways and Transportation
VI-127
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E. EPA Responses to Comments
on the Draft EIS and
Addendum Number One
-------
E. EPA RESPONSES TO PUBLIC COMMENTS ON THE DRAFT EIS AND
ADDENDUM NUMBER ONE
The following substantive issues were raised in comments
received from the public and governmental agencies:
1. Eastern Henrico Plant Site
The elimination of the alternative of a western
Henrico plant site has been questioned by a number of
commentors. The elimination of this alternative was
justified principally due to economic constraints. The
EPA "Cost-Effectiveness Analysis Guidelines" provide a
uniform method for calculating the costs of wastewater
treatment facilities, which have been followed in the
Draft EIS and Facilities Plan. The term "cost-effective-
ness" comprises three very important costs: monetary or
dollar costs, environmental costs, and social costs. For
this alternative one other equally important factor in
considering cost-effectiveness is that of complying with
State water quality standards. Recognizing the need to
preserve the integrity of the James River above Richmond
as a major water supply source, and noting the existing
discharges directly below the City, a plant located west
of the City of Richmond would be required by the State
of Virginia to discharge at the same point on the James
River as permitted for the recommended eastern discharge
site near Varina Farms. Ignoring various environmental
reservations, the associated construction costs of
transportation facilities necessary to pump raw sewage
flows from the eastern portion of Henrico County to
the western treatment site and then return them
to the required eastern discharge site would make this
alternative very roughly between 30 and 60 percent more
costly than the recommended alternatives. EPA has
assumed a 10 percent range of economic variance in its
consideration of'cost-effective alternatives, thereby
eliminating this alternative from further evaluation.
2. Degree of Treatment
All final alternatives, except for the "no-action"
alternative will bring Henrico County's wastewater dis-
charges into compliance with effluent limitations designed
to protect water quality in the James River. However,
there have been comments which question the elimination
of the alternative of providing advanced pollutant re-
moval capacities to meet the Clean Water Act's (Federal
Water Pollution Control Act Amendments of 1972) 1985
National goal of zero pollutant discharge into navigable
waters.
VI-128
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The 1972 Clean Water Act set forth a number of
national goals. Among these were two interim goals:
(1) wherever attainable, water quality which provided for
the protection and propagation of fish, shellfish and
wildlife and provided for recreation in and on the
water should be achieved by July 1, 1983, and (2) the
discharge of pollutants into navigable waters should be
eliminated by 1985. The current water quality standards
of the State of Virginia are intended to provide waters
of a quality required to meet the 1983 goal. There has
been much discussion of the so-called "zero-discharge"
goal. Many people have seen the statement of this goal
as providing assurance that all of our waters would be
returned to a nearly pristine state. Others contend
that the general definition of pollutants should be con-
sidered as any material in a discharge which adversely
affects the beneficial uses of the receiving water.
The major problem in achieving "zero-discharge" is,
not unexpectedly, the question of cost and the desirable
allocation of social resources among the great number
of competing social problems. In general, the technology
for achieving "zero-discharge" is available, but only
at a cost of perhaps five to ten times the current
levels of expenditure on water quality management. To
date, except for a few experimental research projects,
the apparent judgment has been that the benefits to be
obtained by the total elimination of pollutants have
not justified the costs. In fact, in many areas under
current programs of construction grants for wastewater
management facilities, insufficient money has been made
available to meet even the limited 1977 goal of secondary
treatment for municipal wastewaters. Whether Congress
will see fit to shift a major portion of its resources
from other problems to achievement of the 1985 "zero-
discharge" goal remains to be determined.
3. Raw Water Intakes Downstream
Raw water intakes for Allied Chemical Company and
the Virginia-American Water Company in the Hopewell,
Virginia area are located within eight miles of proposed
effluent discharge point. Various commentors including
the Virginia Department of Health have questioned the
effects of the effluent on downstream potable water
supplies. The discharge will meet all standards for a
Class II-B water segment as indicated in the "Water
Quality Standards" issued by the Virginia State Water
Control Board in November, 1974. Despite offers to meet
any special treatment requirements the Virginia Depart-
ment of Health might wish to invoke, no additional
standards have been advanced (see Appendix C). Should
new treatment processes be required in the future, all
proposed sites have sufficient room for expansion.
VI-129
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4. Groundwater Contamination
The adequacy of measures to prevent groundwater
contamination from sludge landfill operations was ques-
tioned. Standard methods including impervious liners
and leachate collection and retreatment should insure
adequate protection of groundwater supplies; these
methods are discussed in Section IV-G, Residuals Dis-
posal .
5. Treatment Plant Odors
The potential for odors during plant operation has
been questioned by residents near proposed plant sites
and by NABISCO, Inc. (see Appendix F).
The proposed facility is a new plant treating normal
domestic wastewater, adequately sized, properly funded,
and operated by a county with a good reputation for
maintaining public services. Under these circumstances,
there is no justification for concluding, in advance,
that odors will result from bad design or poor management.
The large buffer zone provides good protection against
any stray odors arising from normal operations.
The plant will be designed to deal with normal mechanical
failures, although more severe accidents are possible.
Because site drainage will be controlled, a spill of
sewage or sludge could be cleaned in a relatively short
time. Arrangements could be made to by-pass raw sewage
should the plant be severely damaged by an explosion or
other catastrophic event. Thus, the possibility of an
extended period of odor contamination due to an accident
is remote.
6. Proximity of Upper Cornelius Creek Site to Ft. Lee
Baptist Church
Ft. Lee Baptist Church is two-thirds of a mile from
the proposed facilities; an active railroad, a four-lane
highway and a light industrial plant occupy the inter-
vening distance. For this reason, impacts on the church
are not anticipated to be significant.
7. Aerosols
NABISCO, Inc. has suggested that pathogens aerosolized
during wastewater treatment at the Upper Cornelius Creek
Site will contaminate products stored or processed at
their nearby bakery (see Appendix F).
A number of studies have been made of the formation
and spread of aerosols at wastewater treatment plants.
VI-130
-------
Hickey and Reist have provided an excellent summary and
analysis of the literature in the Journal of the Water
Pollution Control Federation, December, 1975. Many of
the studies reported involved trickling filters or spray
irrigation, which are not proposed for Henrico, but a
sufficient amount of information on the activated
sludge process appears available to draw some conclusions,
The major source of aerosols at an activated sludge
plant is the aeration tank, due to the breaking of
bubbles at the liquid surface. Other treatment units,
such as clarifiers, have not been identified as signifi-
cant contributors to aerosols.
Concentrations of viable organisms have been reported
as far as 200 feet from aeration tanks. However, they
have been found 1000 feet from trickling filters, so
the possibility of further travel cannot be excluded.
The plant site, regardless of location, will have a
minimum buffer zone of 600 feet and the distance to the
aeration tanks could be even greater, depending upon
plant design. Adding 800 feet from the NABISCO property
line to the bakery gives a minimum distance of 1400
feet. This is further than any distance at which viable
organisms have been detected in studies reported in
the literature. Several mitigating measures for pro-
viding further protection from airborne pathogens could
be implemented at reasonable cost:
• Locate the aeration tanks at the opposite end of
the site from NABISCO;
• Enclose the aeration tanks with a cover, or choose
the pure oxygen or Bio-surf alternatives, which
are routinely covered;
• Install scrubbers in the vents from covered
tanks.
To determine if these mitigating measures are neces-
sary, the following program will be implemented:
• When the treatment process is selected after
pilot studies, conduct an aerosol sampling program
at a plant of similar design. This will deter-
mine if further protection is needed.
• Sample the Henrico facility after startup to
confirm effectiveness of protective measures.
8. Discrimination and Deep Bottom West
Residents near the proposed Deep Bottom West site
VI-131
-------
allege the site was selected by the applicant due to
the inability of nearby low-income minorities to
effectively oppose the proposed location. The Civil
Rights Enforcement Division of EPA has investigated the
situation and determined that there has been no violation
of the 1964 Civil Rights Act. A copy of the statement
with this determination can be obtained by contacting
the designated Project Monitor noted on the Title Page.
9. Relocation Assistance
Some residents bordering the proposed Deep Bottom
West facility have questioned the adequacy and avail-
ability of relocation assistance which was offered by
the County to those residents who would be required to
sell part of their property, but not their residence.
On January 4, 1978 the Board of County Supervisors of
Henrico County adopted a resolution confirming this
offer and the application of the procedures of the
Uniform Relocation Assistance and Real Property Acqui-
sition Act of 1970 (Public Law 91-646) in subsequent
relocation.
VI-132
-------
pendices
-------
APPENDIX A
Additional and Corrected Data
-------
Appendix A. Additional and Corrected Data
1- Threatened and Endangered Species in Virginia
Restrictions on the taking of threatened or endangered
species or the destruction of supporting habitat are con-
trolled by the U.S. Fish and Wildlife Service, Department
of Interior, in conjunction with the Smithsonian Institu-
tion and other federal agencies. Those species (or sub-
species) which are listed in Tables A-l through A-4, under
"federal authority", "final", are protected under the
authority contained in the Endangered Species Act of 1973
(16 U.S.C. 1531-1543; 87 Stat. 884). The list is con-
tained in: U.S. Department of Interior, Fish and Wildlife
Service, 1977, Endangered and Threatened Wildlife and
Plants, Republication List of Species, Federal Register,
Thursday, July 14, pp. 36420 to 36431.
Certain plant and animal species have been listed in
the Federal Register under a "notice of review." Other
species have appeared in the Federal Register as "pro-
posed" for protection under the Endangered Species Act.
This list was compiled from: (1) U.S. Department of
Interior, Fish and Wildlife Service, 1976, Endangered and
Threatened Species, Plants [50CFR Part 17], Federal
Register, Wednesday, June 16, pp. 24524-24572; (2) U.S.
Department of Interior, Fish and Wildlife Service, 1976,
Endangered and Threatened Wildlife and Plants, Federal
Register, October 27, pp. 47180-47198; (3) U.S. Depart-
ment of Interior, Fish and Wildlife Service, 1975, Threat-
ened or Endangered Fauna or Flora, Federal Register, July
1, pp. 27858-27884. Although technically not yet pro-
tected under law, these species are also listed in the
tables and marked in the appropriate column. It is in-
teresting to note that no plant species, identified in
Virginia, have been listed in the Federal Register as
"final" and are protected under law.
In addition, the Virginia Commission of Game and In-
land Fisheries maintains an official state list, generally
taken from the Federal Register. However, the Commission
has the authority to designate protected species on a
statewide basis even though they may not appear on a
federal list. Those species which appear on the State
list are cited in Tables A-l through A-4 under "Virginia
Authority." "Fish and Wildlife" which appear on the
Virginia State list are protected under Chapter 11,
Section 29-230 through 234 of the Virginia Game, Inland
Fish and Boat Laws, 1977.
No species identified as threatened or endangered by
either state or federal authority are known to exist in
A-l
-------
Table A-l. Endangered Flora.
Scientific Name
Common Name
Federal
Authority
: OJ =
•DOS
a) -H dJ
w -P -H
O 0 >
ft 2 (P
O = PJ
(-1
ft M M-4
= 00
Virginia
Authority
Sedge Family
Scirpus anoistrochaetus
Carex biltmoreana
Ehynohospora kneiskernii
Snapdragon Family
*Bacopa simulans
Bacopa stragula
Bulrush, (unnamed) X
Sedge, Biltmore X
Kneiskern's Beaked rush X
Water-hyssop
(unnamed) X
Water-hyssop
(unnamed) X
X
X
X
Chickweed Family
Cerastium awense
var.
Chickweed
(unnamed)
Buttercup Family
Clematis addisonii
Clematis vitioaulis
Grass Family
Paniaum mundum
Orchid Family
Isotria remota
Isotria medeoloides
Mallow Family
Iliamna remota
Lily Family
Uypoxis longii
Trillium pusillwn
var. virginianwn
Rockrose Family
Leohea maritima
var. virginioa
Birch Family
Betula uber
Birthwort Family
Hexastylis naniflora
Virgin's bower (unnamed) X
Virgin's bower (unnamed) X
Panic grass (unnamed)
Pogonia, small whorled X
Whorled Pogonia (unnamed) X
(n.c.n.'.
Stargrass (unnamed) X
Wake robin (unnamed) X
Pinweed, Virginian
Ashe's Birch X
Heartleaf, dwarf
flowered
X
X
X
X
X
X
X
* Believed to be extinct
n.c.n.-no common name
A-2
-------
Table A-l (cont.)
Endangered Flora
Scientific Name
Common Name
Federal
Authority
: 0)
T3 O
0) -H
(/) 4->
O O >
a
0)
a)
00
Virginia
Authority
Pixie Family
Shortia galaoifolia
var. galae-ifolia
Tape-Grass Family
Elodea schweinitsii
Oconee bells, milky
leaved
Waterweed (unnamed)
A-3
-------
Table A-2.
Endangered Fauna.
Scientific Name
Common Name
Federal
Authority
: 0) =
T) O 3
0) -H d>
(/) -P -H
O O
O,
O =
S-l
0)
Pd
O O
Virginia
Authority
Clams
Fusconaia edgarlana
Pleurobema plenum
Lampsillis orbiculata
orbiculata
Fuscona-ia cuneolus
Epioblasma walkerl
Epioblasma (=Dysnomi,a)
tovulosa gubernaoulum
Quadrula spars a
Conradi-lla oaelata
Quadrula intermedia
Dromus dramas
Fish
Aoipenser brevlrostvim
Birds
Dendre-ica kirtlandii
Faloo peregrinus anatum
Campephilus prlnc-Lpalis
Pelecanus occldentalis
Dondrocopos borealis
Haliaeatus leucocephalus
Vermivora baohmanii
Mammals
Sciurus niger ainerous
Fells concolor cougar
Myotls grlsescens
Myotls sodalls
Glaucomys sabrinus fuscus
Synaptomys cooperl
helaletes
Mussel, shiny pigtoe
pearly X X
Mussel, rough pigtoe
pearly X X
Mussel, pink mucket
pearly X
Mussel, fine-rayed
pigtoe pearly X X
Tan riffle shell mussel X X
Mussel, green-blossom
pearly X X
Mussel, Appalachian
monkeyface pearly X X
Mussel, birdwing pearly X X
Mussel, Cumberland
monkeyface pearly X X
Mussel, Dromedary
pearly X X
Sturgeon, shortnose X
Warbler, (wood)
kirtland's X
Peregrine falcon X X
Woodpecker, ivory-billed X
Brown pelican X X
Woodpecker, red-cockaded X X
Eagle, Southern bald X X
Warbler, Bachman's X
Squirrel, Delmarva Peninsula
fox x X
Cougar, eastern X' X
Bat, gray X
Bat, Indiana X x
Northern flying squirrel X
Dismal Swamp lemming
mouse X
A-4
-------
rable A-2 (cont.)
Endangered Fauna.
Scientific Name
Plecotus townsendii
virginianus
P.r. rafinesquii
Reptiles
Clemmys insoulpta
C. muhleribevgi
P-ituoph-is m.
melanoleucus
Lampropeltis doliata
doliata
Crotalus horr-idus
atr-icaudatus
Leptdochelys 'kemp'O-
Evetmochelijs -imbvLcata
Dermochelys cor-Lacea
Amphibians
fleotwcus m. maoulosus
N. P. punotatus
Siren lacerti-na
Rana wirgat-ipes
Common Name
Virginia big-eared
bat
Rafinesque's big-eared
bat
Wood turtle
Bog turtle
Northern pine snake
Scarlet king snake
Canebrake rattlesnake
Atlantic Ridley sea
turtle
Hawksbill sea turtle
Leatherback sea turtle
Mudpuppy
Dwarf waterdog
Greater siren
Carpenter frog
Federal
Authority
T 0) -
T3 O 3
0) -iH 0)
W -P -H
O O >
a z
O =
0)
-------
Table A-3.
Threatened Flora.
Federal
Authority
Scientific Name
Quillwort Family
Isoetes virg-in'ica
Walnut Family
Junaus caesariensis
Mint Family
Py cnanthemwn
monotvichwn
Synandra hispi-dula
Lily Family
Lil-Lwn grayii-
Orchid Family
Platanthera flava
Platanthera peramoena
Grass Family
Calamagrostis porteri
Calamovilfa bvevipilis
var. brevipilis
Calamovilfa brevipilis
var. oalvipes
Panicum aculeatum
Buttercup Family
Ci-mic'ifuga vubifolia
Anemone m-imima
Hydrastis oanadensis
Sandlewood Family
Buokleya distiahophylla
Nestronia wnbellula
Saxifrage Family
Heucheva hispida
Saxifraga oareyana
Saxifraga caroliniana
Common Name
Quillwort, Virginia
Bog rush, unnamed
Mountain mints, unnamed
n.c.n.
Lily, gray
Rein-orchid, unnamed
Rein-orchid, unnamed
Reed bent grass
Sand grass, unnamed
Sand grass, unnamed
Panic grass, unnamed
n.c.n.
n.c.n.
n.c.n.
n.c.n.
n.c.n.
Aluminum root, unnamed
n.c.n.
n.c.n.
: 0) :
T) O £
(U -H
a 2 QJ
O =
PL,
O O
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Virginia
Authority
X
X
X
X
X
X
X
X
X
X
X
X
X
n.c.n. - no common name
A-6
-------
Table A-3 (cont.)
Threatened Flora.
Scientific Name
Snapdragon Family
M-icTanthemum
micranthemoides
Common Name
Federal
Authority
: 0) -
T3 O 3
Q) -iH d)
(0 -P -rH
o o >
O, 2 0)
O=Ct;
J-l
rti
C
-H
Virginia
Authority
n.c.n.
Holly Family
Ilex amelanch'LeT
Acanthus Family
Justic-ia mortu-Lfluminis
Parsley Family
Lilaeops-is carolinensis
Oxypolis aaribyi
Ginseng Family
Panax qu'inquefolius
Birthwort Family
Hexastylis lewisii
Aster Family
Ech'inaoea laev-igata
Eupatori-um saltuense
Rudebeokia heliopsidis
Birch Family
Alnus mar-itima
Mustard Family
Cardamine longii
Sedge Family
Carex chapmanii
Cymophy I lus fr>as eri-
Scirpus flaecidifolius
Heath Family
Rhododendron bdkeT-i
Juneberry holly
Waterwillow (unnamed)
n.c.n.
Dropwort
Ginseng
Heartleaf, Lewis
Coneflower
Thorough wort
n.c.n.
Alder, seaside
Bittercress, long
n.c.n.
n.c.n.
n.c.n.
Rhododendron, Baker's
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Fern Family
Aspleniwn ebenoides
Asplenium kentuck'Lense
Scott's spleenwort
Kentucky spleenwort
X
X
X
X
n.c.n. - no common name
A-7
-------
Table A-4.
Threatened Fauna.
Scientific Name
Common Name
Federal
Authority
: 0) ;
T) O £
CU -iH Q)
0) 4J -iH
O O >
OH 2 0)
O = BJ
CU
M-l
nJ
c
•r-l
Virginia
' Authority
Mammals
Uvsus arctos
Fish
Hybopsis oahni
Hybopsis monacha
No tar as flav-ip-inni-s
Bear, brown
Chub, slender
Chub, spotfin
Madtom, yellowfin
X
X
X
X
X
A-i
-------
the study area. All tables apply to Virginia; Table A-l
lists endangered flora. Table A-2 lists endangered fauna,
Table A-3 lists threatened flora, and Table A-4 lists
threatened fauna.
2. Soil Associations in the Henrico County 201 Study Area
Table A-5 indicates the characteristics of soil associ
ations found in the 201 area. Comments on the Draft EIS
from the U.S. Soil Conservation Service indicated that
Table IV-1 (originally in the DEIS) was incorrect in some
ways. The revised version, Table A-5 reflects these
changes.
A-9
-------
Table A-5. Soil Associations in the Henrico County 201 Study Area [Source: USDA SCS (1975), RRPDC (1973a)
Corrected Utilizing SCS Comments on the Draft EIS.
Depth to (ftet)
I
M
O
2 Appling-Wedowee-State
Gently rolling up-
lands to steep slopes
3 Kempsvalle-Atlee-
Duplin. Nearly
level to gently
sloping uplands
4 Ochrepts-Udults
Norfolk-Caroline
Rolling to hilly
coastal uplands
5 Lynchburg-Rains-
Coxville
Upland flats
6 Angie-Pamunkey-
Lenoir. Flood-
plains and stream
terraces
Chewacla-Riverview-
Toccoa. James
River flood plain
Mayodan-Creedmor-
Crotan
Piedmont lowlands
Goochland County
Chesterfield-Appling
Piedmont uplands
in Goochland County
a .
b.
a.
b.
a.
b.
a.
b.
a.
b.
a.
b.
a.
b.
a.
b.
a.
b.
Texture
(a. Surface)
(b. Subsoil)
Fine sandy loam
Sandy clay loam-
clay
Fine sandy loam
Clay loam- clay
Very fine to
fine sandy loam
Sandy clay loam-
clay
Very fine sandy
loam to gravelly
C 1 ay 1 o am- c 1 ay
Silt loam-very
fine sandy loam
Clay loam-clay
Silt loam-fine
sandy loam
Silty clay-
sandy clay loam-
clay
Fine sandy loam-
silt loam
Silt loam- very
fine sandy loam
Medium- light
texture
Plastic clay
Fine sandy loam
Clay
Drainaqe
Poor to
moderately
well
Well
Moderately
well to
well
Well to
excessive
Poor
Poor to
well
Poor to
well
Poor to
well
Moderate
to well
Perme-
ability
Very slow
to s 1 ow
Moderate
Slow to
moderate
Moderately
slow to
moderately
rapid
Slow to
moderate
Slow to
moderate
Moderate
to moder-
ately
rapid
-
Moderate
Seasonal
Shrink- High
Swell Water
Potential Table
Low to 1-3
high
Low to >5
moderate
Low to 1.5->5
moderate
Low to Vari-
moderate able-
>5
Low to 0-1.5
moderate
Low to 1->B
high
Low to 1.5->5
moderate
-
Moderate >5
Limitations to
Bed- Flood- Fragi- Septic
Building
rock ing pan Tanks Construction
>4 Yes Yes Severe
>5 No No Moderate
to severe
>5 Yes Yes Moderate
to
severe
Vari- No - Moderate
able- to severe
>5
>5 Yes No Severe
>5 Yes No Low to
severe
>5 Yes No Severe
"Deep - No Severe to
to moderate
shallow"
"Deep" No No Moderate
Severe
Moderate
to severe
Low to
moderate
Low to
moderate
Severe
Low to
severe
Severe
Severe to
moderate
Moderate
Sanitary
Land-
fills
Severe
Low to
moderate
Low to
severe
Low to
severe
Severe
Mostly
severe
Severe
Severe
to
moderate
Slight
to
moderate
-------
APPENDIX B
Henrico County Position Statements
-------
Appendix B. Henrico County Position Statements
This section contains two reprinted statements and two
resolutions in chronological order, all expressing Henrico
County's position regarding the 201 process. The first is
a statement from Patrick J. Brady, Director of Public
Utilities for the County at a work session of the Board of
Supervisors on July 20, 1977. The second is a statement by
Supervisor V. Kreiter on August 24, 1977. The last items,
resolutions from the Board of Supervisors, were approved on
January 11, 1978, and February 8, 1977.
-------
BOARD OF SUPERVISORS' WORK SESSION
JULY 20, 1977
ON FEBRUARY 9, 1977, YOU RECEIVED A COPY OF THE FINAL DRAFT
OF THE HENRICO REGIONAL WASTEWATER FACILITIES PLANNING STUDY
PREPARED BY WlLEY & WlLSON AND ROYER. THE BOARD DIRECTED THE
COUNTY MANAGER TO HOLD THE REQUIRED PUBLIC HEARING AND TO PROVIDE
THE BOARD WITH A COPY OF THE TRANSCRIPT OF THE PUBLIC HEARING
PRIOR TO A DECISION BY THE BOARD TO APPROVE A FINAL PLAN, ON
MAY 18, 1977, EPA RELEASED THE FINAL DRAFT EIS AND COPIES WERE
FURNISHED TO THE BOARD OF SUPERVISORS,
ON JUNE 21, 1977, THE PUBLIC HEARING WAS HELD JOINTLY WITH
EPA ON THE FACILITIES PLAN AND EIS, THE PUBLIC COMMENT PERIOD
FOR THE FACILITIES PLAN ENDED 15 DAYS LATER OR JULY 6, 1977, COPIES
OF THE TRANSCRIPT OF THE PUBLIC HEARING AND SUBSEQUENT CORRESPONDENCE
CONCERNING THE FACILITIES PLAN WERE SENT TO THE BOARD ON JULY 13, 1977
THE PROPOSED PROJECT IS TO BE FUNDED BY A 75% FEDERAL GRANT
UNDER THE FEDERAL WATER POLLUTION CONTROL ACT AMENDMENTS OF 1972
WITH AN ESTIMATED TOTAL COST OF $69 MILLION AND APPROXIMATELY $22
MILLION IN LOCAL COSTS, HENRICO is ON THE FY '76-'77 PRIORITY LIST
OF THE STATE WATER CONTROL BOARD FOR A STEP II (DESIGN) GRANT OF
$1,854,000, THE SWCB HAS INDICATED THAT, SINCE HENRICO WILL NOT
BE ABLE TO RECEIVE THE GRANT FOR THESE FUNDS PRIOR TO THE SEPTEMBER
30TH ENDING OF THE EPA FISCAL YEAR, THESE FUNDS WILL BE REALLOCATED
TO OTHER VIRGINIA PROJECTS, THE SWCB HAS RECEIVED APPROXIMATELY
- 1 -
B-2
-------
$22 MILLION IN EMERGENCY '77-'78 FUNDS AND IF HENRICO HAS A
COMPLETED GRANT APPLICATION PENDING ON SEPTEMBER 30TH AT EPA,
WE HAVE A GOOD CHANCE TO RECEIVE A STEP II GRANT TO ALLOW OUR
PROJECT TO CONTINUE UNINTERRUPTED, To DO THIS, THE GRANT APPLICATION
MUST BE AT THE SWCB BY AUGUST 15TH AND, THEREFORE, ALL BOARD OF
SUPERVISORS' ACTION MUST BE COMPLETED BY AUGUST 10m SITE SELECTION
EARLIER WOULD BE DESIRABLE IF THE APPROVED FACILITIES PLAN IS TO
BE READY BY AUGUST 15TH, THE PROPOSED FACILITY IS SCHEDULED FOR
COMPLETION IN 1982 AND DELAYS COULD RESULT IN LACK OF NEEDED TREAT-
MENT FACILITIES IN 1983 AND RESULTANT DENIAL OF ADDITIONAL CONNECTIONS
TO THE COUNTY SEWER SYSTEMS, THE PRESENT CONTRACT EFFECTIVE
JULY 1, 1976, WITH RICHMOND EXPIRES JUNE 30, 1981 AND LIMITS FLOW
TO 23 MGD, RICHMOND is NOT PROVIDING FOR INCREASED HENRICO FLOWS
SINCE PLANS ARE FOR HENRICO TO BE SERVED BY THE NEW FACILITY,
AVERAGE DAILY FLOW IN JUNE, 1977 WAS 14.8 MGD, PROJECTED HENRICO
201 SERVICE AREA FLOWS IN 1982 TOTAL 22,5 MGD,
THE FINAL DRAFT FACILITIES PLAN ADDRESSES NUMEROUS ALTERNATIVE
TRANSPORT AND TREATMENT SYSTEMS TO SERVE THE STUDY AREA CONSISTENT
WITH THE WATER QUALITY MANAGEMENT PLAN FOR THE GREATER RICHMOND
METROPOLITAN AREA APPROVED BY THE SWCB ON AUGUST 24, 1974. DURING
THE 2-YEAR COURSE OF THIS STUDY, THERE HAS BEEN A COMMITMENT TO
PUBLIC PARTICIPATION AND INVOLVEMENT, FlVE PUBLIC MEETINGS WERE
HELD FOR PUBLIC INFORMATION AND INPUT, AND WERE WELL ATTENDED,
NUMEROUS MAILINGS WERE MADE TO INTERESTED PARTIES, AND PRESENTATIONS
MADE TO ALL WHO REQUESTED PROGRAMS ON THE FINAL DRAFT PLAN BETWEEN
FEBRUARY 9TH AND JUNE 21sT, 1977, ADDITIONALLY, BOARD MEMBERS
RECEIVED IN FEBRUARY THE FINAL DRAFT FACILITIES PLAN, AND IN MAY,
THE FINAL DRAFT EIS,
-------
THEREFORE, IT is NOT INTENDED TODAY TO REVIEW ALL DETAILS OF THE
STUDY,
THE FINAL DRAFT FACILITIES PLAN RECOMMENDS AS THE "LEAST
COST ALTERNATIVE" A TRANSPORT SYSTEM BEGINNING IN THE TUCKAHOE
CREEK AREA OF WESTERN HENRICO, PROCEEDING NORTH AND EAST AROUND
RICHMOND. AND TERMINATING AT A TREATMENT FACILITY IN EASTERN HENRICO,
TREATMENT is PROPOSED AS ACTIVATED SLUDGE SECONDARY TREATMENT WITH
DISCHARGE OF THE TREATED EFFLUENT TO THE JAMES RlVER IN THE VICINITY
OF VARINA FARMS, ALTERNATIVE SITES FOR THE TREATMENT FACILITY
WERE STUDIED AND IN THE FINAL DRAFT REPORT AND EIS, FOUR ALTERNATIVE
SITES ARE DISCUSSED, THESE ARE: VARINA FARMS, DARBYTOWN ROAD,
UPPER CORNELIOUS CREEK, AND DEEP BOTTOM, THE LEAST COST ALTERNATIVE
FOR THE SYSTEM INCLUDES THE VARINA FARMS SITE FOR THE TREATMENT
FACILITY, SINCE MOST OF THE PUBLIC PARTICIPATION HAS CENTERED
AROUND THE SELECTION OF THE TREATMENT PLANT SITE, I WILL DISCUSS THE
FOUR ALTERNATIVE SITES,
WE HAVE PREPARED A COMPARISON OF THESE FOUR SITES BASED ON (1)
PROPOSED LAND USE; (2) RELOCATION OF FAMILIES; (3) CITIZEN COMMENTS;
(4) ULTIMATE FUTURE SERVICE AREA BY GRAVITY FLOW; (5) PLANNING
COMMISSIONS' FINDING REGARDING SUBSTANTIAL CONFORMANCE WITH THE
LAND USE PLANJ (6) SITE SPECIFIC ENVIRONMENTAL IMPACTS NOT S.HARED
BY ALL SITES; AND (7) PRESENT WORTH ANALYSIS,
AFTER CAREFUL CONSIDERATION OF ALL FACTORS, IT is RECOMMENDED
THAT THE BOARD OF SUPERVISORS APPROVE THE FINAL DRAFT FACILITIES
PLAN WITH THE FOLLOWING SPECIFIC REQUIREMENTS:
B-4
-------
1. THE APPROVED TRANSPORT SYSTEM IS W~2~A, E~2, AND E~4-B,
2. THE VARINA FARMS SITE is APPROVED FOR THE TREATMENT PLANT
WITH THE RECOMMENDED OUTFALL TO THE JAMES RlVER,
3, PARTICULAR ATTENTION SHALL BE GIVEN TO PROTECTION OF THE
ENVIRONMENT DURING CONSTRUCTION,
4, A BUFFER OF 600 FEET OF WOODED AREA SHALL BE MAINTAINED
AROUND PERIMETER OF TREATMENT PLANT SITE,
5, MAXIMUM EFFORT SHALL BE MADE TO INSURE COMPATIBILITY OF
TREATMENT PLANT AND TRANSPORT SYSTEM WITH ADJACENT LAND USES
INCLUDING ARCHITECTURAL TREATMENT OF ABOVE GROUND FACILITIES,
6, MAXIMUM EFFORT WILL BE MADE TO INSURE THE ODOR-FREE OPERATION
OF FACILITIES,
7, THE NECESSARY FACILITIES WILL BE PROVIDED TO SERVE THE ALMOND
CREEK DRAINAGE BASIN INTO THE HENRICO FACILITIES,
IF THIS RECOMMENDED PLAN IS APPROVED, THE BOARD OF SUPERVISORS
SHALL DIRECT THAT THE PLANNING COMMISSION AMEND THE LAND USE PLAN
AS NECESSARY TO PLACE THIS PLAN IN "SUBSTANTIAL CONFORMANCE" WITH THE
LAND USE PLAN, A PROPOSED RESOLUTION is SUBMITTED HEREWITH TO
ACCOMPLISH THE RECOMMENDED APPROVAL IF THE BOARD CONCURS,
I REALIZE THAT THIS IS NOT AN EASY DECISION AND THAT THE IMPACT
ON THE FUTURE OF HENRICO COUNTY WILL BE SIGNIFICANT, I ALSO REALIZE
THAT THERE MAY BE CHOICES WHICH HAVE GREATER CITIZEN SUPPORT OR
OFFER LESS RESISTANCE FROM OTHER AGENCIES; HOWEVER, I BELIEVE THAT
OF THE FOUR ALTERNATIVE SITES STUDIED IN DETAIL, THE VARINA FARMS
SITE IS IN THE BEST INTEREST OF THE MAJORITY OF OUR CITIZENS,
B-5
-------
AFTER BOARD APPROVAL OF A FINAL FACILITIES PLAN, THE STEP II
GRANT APPLICATION WILL BE SUBMITTED TO THE STATE WATER CONTROL
BOARD AND EPA, THE FOLLOWING ADDITIONAL BOARD ACTIONS WILL BE
REQUIRED TO COMPLETE THE STEP II GRANT APPLICATION PACKAGE:
1, SIGNATORY AUTHORITY FOR STEP II AND III GRANT APPLICATIONS,
(RESOLUTION)
2. APPROVAL OF ENGINEERING AGREEMENTS FOR STEP II WORK,
3, AUTHORIZATION TO APPLY FOR NPDES PERMIT AS REQUIRED,
PROPOSED RESOLUTIONS FOR THESE ITEMS WILL BE PLACED ON THE
AGENDA FOR AUGUST 10, 1977, THE FIRST RESOLUTION WOULD AUTHORIZE
THE COUNTY MANAGER OR DIRECTOR OF PUBLIC UTILITIES TO EXECUTE THE
NECESSARY APPLICATION FORMS AND OTHER DOCUMENTS RELATED TO GRANT
APPLICATION, REQUESTS FOR PAYMENT, REPORTS, ETC, THE NEXT
RESOLUTION WOULD APPROVE A CONTRACT WITH WlLEY & WlLSON AND ROYER
TO PROVIDE GENERAL ENGINEERING SERVICES FOR STEPS II AND III TO
INCLUDE MANAGEMENT SERVICES, IN CONNECTION WITH IMPLEMENTATION OF
THE ENTIRE PROJECT AND DESIGN SERVICES IN CONNECTION WITH DESIGNATED
PORTIONS OF THE TRANSPORT SYSTEM, SPECIFICALLY THAT PORTION OF THE
TRANSPORT SYSTEM FROM THE TlJCKAHOE CREEK PUMP STATION TO THE END
OF THE STRAWBERRY HILL FORCE MAIN, THIS WILL ALLOW FOR DESIGN OF
THE "BACKBONE" OF THE SYSTEM CONCURRENT WITH PREPARATION OF SCOPE
OF WORK AND NEGOTIATION UNDER THE "RFP" PROCESS OF ADDITIONAL
DESIGN CONTRACTS FOR THE TREATMENT PLANT, AND REMAINDER OF THE
TRANSPORT SYSTEM,
- 5 -
B-6
-------
IT IS ANTICIPATED THAT THIS PROCEDURE WILL ALLOW FOR
THE DESIGN TO PROCEED IN A TIMELY MANNER. THE MANAGEMENT
SERVICES PORTION OF THE AGREEMENT WILL ALLOW MINIMUM INCREASE
IN THE DEPARTMENT OF PUBLIC UTILITIES STAFF TO ADMINISTER THIS
PROPOSED $69 MILLION PROJECT,
THE NPDES APPLICATION AUTHORIZATION WAS DEFERRED FROM
THE JULY 13TH MEETING OF THE BOARD,
- 6 -
B-7
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DARBYTOWN ROAD '"
With W-2-A, E-2 &/-E-5
DEEP BOTTOM ROAD
With W-2-A, E-2 & E-7
UPPER CORNELIUS CREEK
With W-2-A, E-2, & E-\8-A
VARINA FARMS
With W-2-A, E-2 & E-4-B
Proposed Land
Use
Active Recreation
Prime Agricultural
Light Industrial
Prime Agricultural
Relocation of
Families
Yes (3)
Yes (5)
No
Citizen
Comments
Opposed
Opposed
Opposed by adjacent Opposed except for limited
bakery, and residents. support from 3 respondents.
Support from Citizens I (Nabisco, Sauer, and Citizens
group (Varina Homeowners Asn at Hearing.)
Ultimate service
area by gravity
flow south of
C & 0 Railroad
64 acres immediately
adjacent to site, plus
4500 acres to a proposed
pump station to serve
Varina High School,
Baker Elem. & proposed
Middle School.
12,700 acres including
3600 outside 1995
phasing line. Includes
4500 acres to proposed
pump station to serve
Varina H. S., Baker
Elem. & proposed Middle
School.
4500 acres to proposed
station to serve Varina H.S.
Baker Elem. School and pro-
posed Middle School.
9,100 acres including 4,500
acres to proposed pump station
to serve Varina H.S., Baker
Elem. School and proposed
Middle School. (960 acres is
outside 1995 phasing line)
Planning
Commissions'
finding regarding
substantial con-
formance w/Land
Use Plan.
Site Specific
Environmental
Impacts not
shared by all
sites.
No' (by 6 to 0 Vote)
Yes,(by 3 to 3 Vote,
deemed no action, and
after 60 days consid-
ered approval)
Yes (4 to 2)
No (6 to 0)
None
Severe impact by P.S.,
Four Mile Creek, pos-
sible wetlands impact.
None
Possible Historic Impact.
(Site is not on portion of
Farm designated as Historic
Landmark)
7. Present worth
Analysis entire
Project using
this site.
$95,884,613
$107,760,020
$98,192,021
$96,081,013 - E-4-B Alternative.
$94,605,323 - E-4-A Alternative
-------
FELLOW MEMBERS OF THL BOAuu OF SUPERVISORS:
AT OUR MEETING ON AUGUST 3RD, I MADE A STATEMENT EXPRESSING MY
CONCERN FOR THE FUTURE OF OUR CITIZENS AS IT MAY BE AFFECTED BY OUR
DECISION ON THE PROPOSED REGIONAL V/ASTEWATER DISPOSAL FACILITIES,
I STATED MY SUPPORT FOR THE LOCATION OF THE K'ASTEWATER TREATMENT PLANT
AT DEEP BOTTOM AND GAVE MY REASONS, I STILL BELIEVE THE LOCATION OF
THE TREATMENT PLANT IN THE DEEP BOTTOM AREA IS IN THE BEST INTEREST
OF THE MAJORITY OF OUR CITIZENS,
AMONG MY REASONS FOR SUPPORT OF THE DEEP BOTTOM SITE WAS A DESIRE
TO AVOID THE POSSIBLE ADVERSE IMPACT ON HISTORIC VARINA FARMS, AND THE
BELIEF THAT THE LARGER POTENTIAL SERVICE AREA OF THE DEEP BOTTOM SITE
WOULD BENEFIT VARINA AND ALL COUNTY CITIZENS USING THIS SYSTEM, A
MAJORITY OF THIS BOARD DID NOT SUPPORT MY POSITION AND THE ADMINISTRA-
TION WAS INSTRUCTED TO PREPARE ALTERNATIVES WHICH ADDRESSED CONCERNS
EXPRESSED BY THIS BOARD THEY HAVE ATTEMPTED TO DO THIS AND TODAY
WE ARE PRESENTED THE "DEEP BOTTOM WEST" ALTERNATIVE. I BELIEVE THIS
ALTERNATIVE ADDRESSES MOST OF THE CONCERNS EXPRESSED BY THIS BOARD;
HOWEVER, IT PRESENTS A NEW QUESTION FOR ME, IN MODIFYING THE DEEP
BOTTOM ALTERNATIVE, THE COSTS HAVE BEEN REDUCED, FORCED RELOCATION
OF FAMILIES ELIMINATED, AND HISTORIC IMPACTS MITIGATED, THE REVISION,
HOWEVER,, ALSO RESULTS IN A REDUCTION OF THE POTENTIAL GRAVITY FLOW
SERVICE AREA BY 4100 ACRES, I REALIZE THAT 3600 ACRES OF THIS IS
OUTSIDE THE 1995 PHASING LINE OF OUR LAND USE PLAN; HOWEVER, IF THE
"DEEP BOTTOM WEST" SITE is APPROVED AND THE PROPOSED REGIONAL PLAN
PROCEEDS, I AM CONFIDENT THAT THERE WILL BE ADJUSTMENTS TO THE LAND
USE PLAN IN THE FUTURE,
B-9
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AUGUST 24, 1977
RECENTLY, (JUNE 8, 1977) THIS BOARD APPROVED A SUBDIVISION
IN ANOTHER DISTRICT WHICH WAS BEYOND THE PHASING LINE AND ADMITTED
THAT THE PHASING LINE IS A GUIDE AND IS ONLY ONE OF THE CONSIDERATIONS
IN SUCH APPROVAL.
CITIZENS OF VARINA HAVE OBJECTED TO LOCATION OF THE WASTEWATER
TREATMENT PLANT IN VARINA WHILE OFFERING ONLY LIMITED SERVICE POTENTIAL
TO VARINA, I BELIEVE IT is ESSENTIAL THAT ANY APPROVAL OF A TREAT-
MENT PLANT SITE IN VARINA OFFER THE MAXIMUM POTENTIAL FOR FUTURE
SERVICE, THEREFORE, I CAN ONLY SUPPORT THE "DEEP BOTTOM WEST"SITE
IF I BELIEVE THIS BOARD INTENDS TO FULFILL MY COMMITMENT TO PROVIDE
THE OPPORTUNITY FOR SERVICE TO THE AREA ORIGINALLY INCLUDED IN THE
DEEP BOTTOM SITE,
THE DIRECTOR OF PUBLIC UTILITIES AND THE CONSULTANT HAVE CONCLUDED
THAT A PUMP STATION IN THE FOUR MlLE CREEK AREA WITH THE RELATED INTER-
CEPTOR SEWER AND FORCE MAIN TO SERVE THE ADDITIONAL. AREA WOULD COST
APPROXIMATELY $2 MILLION. I REALIZE THAT THIS EXPENSE IS NOT JUSTIFIED
TO SERVE EXISTING NEEDS; HOWEVER, I WOULD LIKE TO HAVE SUCH A PROJECT
INCLUDED IN THE PUBLIC UTILITIES CAPITAL IMPROVEMENT PLAN, TO BE
REVIEWED ANNUALLY TO DETERMINE NEED AND PRIORITY, THIS WILL INSURE
THAT THE AREA IS NOT OVERLOOKED AND THAT IT WILL BE TREATED EQUALLY
WITH OTHER AREAS OF THE COUNTY WHEN REVIEWING THE PLAN EACH YEAR, I
HAVE REQUESTED THE VlCE CHAIRMAN TO MAKE SUCH A MOTION IF WE APPROVE
THE "DEEP BOTTOM WEST" SITE AND URGE ALL OF YOU TO SUPPORT SUCH A
MOTION,
THIS PROPOSED REGIONAL PROJECT is OF GREAT IMPORTANCE TO THE
COUNTY OF HENRICO AND THE REGION, I BELIEVE OUR STUDY AND DELIBERATION
OF THIS PROJECT REFLECTS THE BOARD'S CONCERN THAT IT SERVE THE BEST
INTEREST OF ALL OF OUR CITIZENS,
B-10
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COUNTY OF HENRICO, To-Wit:
At a regular meeting of the Board of County Supervisors of Henrico County,
held in the Board Room, Administration Building, Henrico Government Center,
Parham and Hungary Spring Roads, Richmond, Virginia, on Wednesday, the
llth day of January, 1978, at the hour of 2:00 o'clock p.m.
Present:
George W. Jinkins, Jr., Chairman
Charles M. Johnson, Vice-Chairman
Victor W. Kreiter, Sr.
Eugene T. Rilee, Jr.
Robert N. Johnson Members of the Board
n f. ft ff Tt7
46-78 On motion of Victor W. Kreiter, Sr., seconded by Eugene T.
Rilee, Jr., the following resolution was adopted:
WHEREAS, The Board of County Supervisors has approved the
Henrico Regional Wastewater Facilities Plan including the
proposed Deep Bottom West treatment plant site; and
WHEREAS, The site acquisition will require acquisition of
portions of parcels where the residual of the parcel con-
tains a residence; and
WHEREAS, The residents of such parcels may desire to sell
the entire parcel and relocate.
NOW, THEREFORE, BE IT RESOLVED, That the Board of Supervisors
confirms the policy that where portions of a parcel are to
be acquired and the owner desires to sell the entire parcel,
the entire parcel will be acquired; and
BE IT FURTHER RESOLVED, That where relocation results from
such acquisition of the entire parcel, the procedures of the
Uniform Relocation Assistance and Real Property Acquisition
Act of 1970, Public Law 91-646 will apply and relocation
assistance will be provided; and
BE IT FURTHER RESOLVED, That the Clerk forward a certified
copy of this resolution to Mr. George D. Pence, Jr. , Henrico
County EIS, Environmental Impact Branch, Environmental Pro-
tectional Agency, 6th and Walnut Streets, Philadelphia, Penn-
sylvania 19106, to be included in the record of the Public
Hearing held on December 13, 1977, by ^he U.S. Environmental
Protection Agency on the Environmental Impace Statement for
the Henrico County, Virginia Wastewater Treatment Facilities.
A Copy Teste:
—>
-/^
Clerk
5 \
B-ll
-------
COUNTY OF HENRICO, To-wit:
At a regular meeting of the Board of County Supervisors of Henrico County, held
in the Board Room, Administration Building, Henrico Government Center, Parham
and Hungary Spring Roads, Richmond, Virginia, on Wednesday, the 8th day of
February, 1978, at the hour of 2:00 o'clock p.m.
PRESENT:
George W. Jinkins, Jr., Chairman
Charles M. Johnson, Vice-chairman
Victor W. Kreiter, Sr.
Eugene T. Rilee, Jr.
Robert N. Johnson MEMBERS OF THE BOARD
**********
122-78 On motion of Victor W. KreJter, Sr., seconded by Charles M. Johnson,
the following resolution was adopted:
WHEREAS, The County of Henrico Board of Supervisors, on August 24,
1977, approved the Henrico Regional Wastewater Facilities Plan in-
cluding selection of the Deep Bottom West site for the proposed
wastewater treatment plant; and
WHEREAS, The final Environmental Impact Statement prepared by E.P.A.
evaluated five alternate sites for the proposed wastewater treatment
plant, and the Deep Bottom West site was found to be environmentally
acceptable; and
WHEREAS, The Facilities Plan approved by the County Board of Super-
visors is the most cost effective alternative and is environmentally
acceptable; and
WHEREAS, The Board of County Supervisors believes that selection of
a wastewater treatment plant site can best be decided by local elected officials
after consideration of all factors including environmental impacts.
NOW BE IT THEREFORE RESOLVED, That the Board of County Supervisors
affirms the decision of August 24, 1976 approving the Henrico Regional
Wastewater Facilities Plan including selection of the Deep Bottom West
treatment plant site; and
BE IT FURTHER RESOLVED, That a copy of this resolution be forwarded
to the Executive Secretary of the State Water Control Board, the
Regional Administrator Region III, U. S. Environmental Protection
Agency and members of the U. S. Congress representing Virginia; and
BE IT FURTHER RESOLVED, That the Chairman of the Board of County Super-
visors and County Manager are authorized to take action to insure that
this resolution is known to all concerned and to urge early approval of
the Henrico Regional Wastewater Facilities Plan by the State Water
Control Board and U. S. Environmental Protection Agency.
**********
B-12
A Copy -
Teste:
-------
APPENDIX C
Effluent Criteria Correspondence
-------
Appendix C. Effluent Criteria Correspondence
This section contains three letters in chronological
order regarding the water quality criteria applied to the
effluent from the proposed treatment facility. Two letters
from E. H. Bartsch, Director of the Virginia Department of
Health's Bureau of Sanitary Engineering are dated June 21
and August 17, 1977. A letter to Director Bartsch from
Greene A. Jones, Director of the Environmental Protection
Agency's Region III Water Division is dated July 12, 1977.
C-l
-------
'*}• ' f." >4'
'(' T'1 u
'. XV-^ >^ •>
COMMONWEALTH of VIRGINIA
Department of Health
Richmond, Va. 232)9
SUBJECT: HENRICO COUNTY
Sewerage - Draft Environmental Impact
Statement for 201 Facilities Plan
21 June 1977
Henrico County Draft EIS
EIS Preparation Section - EPA
6th and Walnut Streets
Philadelphia, Pa. 19106
Gentlemen:
This Bureau has reviewed the "Draft Environmental Impact Statement" as prepared
by Ecol Sciences, Inc. through the EPA, in conjunction with the Henri co County
201 Wastewater Facilities Planning Stiidies.
In addition to the comments which we have submitted to the Virginia State Water
Control Board by our letter of 20 April 1977 (a copy of which is attached) con-
cerning the Draft 201 Facilities Plan, we wJ.ll make comments below on the Draft
Environmental Impact Statement.
In past correspondence to all planning and regulatory agencies involved with this
project, we have expressed our concern for downstream potable raw water intakes
which may be affected by this project's discharge. There are two potable raw water
intakes located within eight (8) miles of the subject potential discharge. The
first of these intakes is the Allied Chemical Plant located in the Bermuda Hundred
area of Chesterfield County which uses water for both on—site domestic and industrial
purposes. The other intake located in this area is that of the Virginia-American
Water Company, Hopewell Plant. This intake, located on the Appomattox River, slightly
above it's confluence with the James River, eventually serves the City of Hopewell
domestic system, Fort Lee Domestic needs, Federal Reformatory (Prince George County)
domestic needs, and the domestic and industrial needs of industries located in the
Hopewell area.
Once again, we express our concern in the failure of either the Draft 201 Facilities
Plan or the Draft EIS to adequately address the impact, if any, on the potable raw
water intakes.
Sincerely,
E. H. Bartsch, P.E., Director
Bureau of Sanitary Engineering
r „
O • IAI • V— * • .o •
S.W.C.B. - Piedmont
Wiley, Wilson and Royer
Henrico County Department of Public Utilities
SHD-Norfolk C-2
-------
ML ia \
"""" "! UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 111
STH AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
JUL 1 * 1977
Mr. E. H. Bartsch, Director
Bureau of Sanitary Engineering
State Department of Health
927 James Madison Building
Richmond, Virginia 23219
Dear Mr. Bartsch:
During the preparation of the Henrico County, Virginia 201 Facilities
Plan and Environmental Impact Statement (EIS) , EPA, the State Water
Control Board (SWC3) , Henrico County (the applicant) , and his
As you are aware, the proposed Henrico Wastewater Treatment Facilities,
which would discharge into segment 17 of the James River, will meet
all standards for a class II B water segment as indicated in the "Water
Quality Standards" issued by the Virginia State Water Control Board
in November 1974. In addition, adequate room at all alternative
plant sites have been included to allow for any future plant upgrading
if future additional requirements are mandated. However, cognizant
of the potential health concerns of this discharge on the existing
downstream water supply intakes, Henrico County has in the past requested
and offered to meet any special treatment requirements the State
Department of Health may wish to invoke on all upstream wastewater
discharges .
To date, no directives have been received from the Department of Health,
nor has the proposed meeting with the SWCB, the County and EPA, mentioned
in your letter of July 20, 1976 to Mr. T. F. Turner, Jr., been scheduled
to discuss this important issue.
Currently, EPA is involved with the preparation of the Final EIS for
this project. Comments have been solicited from your Department as
well as from various other State and Federal agencies. In light of
your remaining concerns as expressed at the June 21 201 Facilities
C-3
-------
Plan/EIS Public Hearing (and in your letter dated June 21, 1977), I
am requesting your immediate response to the acceptability of the
proposed project and specific delineation of all special requirements
which your department deems necessary to insure the integrity of the
continued use of the James River as a potable water supply source.
Sincerely yours,
Greene A. Jones, Director
Water Division
cc: Wayne Burgess
Stu Kerzner (3WA12)
C-4
-------
COMMONWEALTH of VIRGI?
••; D(.']hirtnu}nt of Health
Rh'hmnnd. \'u. J.rV(>
SUBJECT: HENRIGO COUNTY
Sewerage - 201 Facilities Plan and E.I.S.
17 August 1977
Mr. Greene A. Jones
Director of Water Division
U.S. Environmental Protection Agency
Region III
6th and Walnut Street
Philadelphia, PA 19106
Dear Mr. Jones:
This letter is in reference to your letter of 12 July 1977 concerning the position
of the State Department of Health on the proposed Henrico County Wastewater Treat-
ment Facilities.
This is to advise that at no time have we made any comments regarding the disapproval
of this proposed project by the Department of Health. We have in fact stated in
past correspondence (letter dated 23 March 1976 from Mr. O. H. Adams to Mr. Daniel
Snyder III) and a statement made at the Public Information Meeting in Henrico County
on 23 March 1977 that we are in favor of a wastewater treatment plant to serve the
County of Henrico and parts of surrounding counties. We did state, in these two
instances and in other correspondence, our concern about any additional wastewater
discharges into the James River in the vicinity of the raw water intakes of the
Allied Chemical Company and the Virginia-American Water Company in the Hopewell
area. We have also expressed our concern with the present wastewater discharges
in the vicinity of these raw water intakes and any additional discharges in the
stretch of the James River between Richmond and Hopeweli. We also stated in the
referenced letter and statement above that if the proposed Henrico County discharge
point is the only point available, then the highest degree of plant reliability
should be incorporated into the system design.
In reference to the proposed meeting with all parties concerned as mentioned in our
letter of 20 July 1977 to Mr. Turner, it was decided that a meeting of this type
would probably not be productive. We now anticipate holding a Public Hearing to
request conment on the entire water quality problem for public water supplies
utilizing the James River from the City of Richmond to the Hopewell area. Upon
receiving approval from the Board of Health to hold the Public Hearing, formal
notice will 'be forthcoming.
AUG221977
C-5
EPA R3
-------
-2-
We believe that our records will show that we have processed all official
proposals to the proper authorities and in no way have we held up this proposed
Henrico County project. We have only pointed out our concern which we believe
is the concern of others involved in the regulation of the public water supplies
utilizing raw water sources which are receiving considerable industrial and
domestic wastes.
We will be happy to discuss this matter further with you or any other interested
parties if you so desire.
Sincerely,
E. H. Bartsch, P.E.
Director
Bureau of Sanitary Engineering
cc: Patrick J. Brady
Taylor Turner
Norfolk Regional Office
S.W.C.B.
C-6
-------
APPENDIX D
Historic and Archeologic
Resources Correspondence
-------
Appendix D. Historic and Archeologic Resources Correspon-
dence
This section reprints various correspondence in chronolo-
gical order related to historic and/or archeologic resources
affected by the planning process. Included are (1) two
memoranda dated February 16 and October 26, 1977 from Ms.
Martha McCartney, a researcher with the Virginia Historic
Landmarks Commission's (VHLC) Research Center for Archeology,
(2) a letter dated July 21, 1977 from Mr. William Patterson,
Environmental Officer for the Interior Department's North-
east Region, (3) a letter dated August 12, 1977 from Ms.
Myra Harrison, Acting Director of the Advisory Council on
Historic Preservation's Office of Review and Compliance,
(4) a letter dated January 10, 1978 with enclosures, from
Mrs. Walter Lemon, a citizen of Henrico County, (5) five
additional letters, two dated January 10 and three dated
January 27, 1978, from Mrs. Walter Lemon to various govern-
mental officials, (6) a letter to Mrs. Walter Lemon from
Mr. Tucker Hill, the State Historic Preservation Officer
and Executive Director of the VHLC, (7) a letter dated
January 20, 1978 to Mr. Tucker Hill from Ms. Helen Waldorf,
an ecologist with EcolSciences, inc., and (8) a letter
dated February 6, 1978 from Mr. Robert Swisher of the VHLC.
D-l
-------
\ ' ' "'*•"
COMMONWEALTH of VIRQIN1A
Virginia Historic Land marks Commission
Va. Research Center for Archaeology
Post Office Box 1204-
Williamsburg, Virginia 23185
February 16, 1977
MEMORANDUM
TO: Edward F. Wandelt
FROM: W. M. Kelso, Commissioner
SUBJECT: Henrico County Sewage Treatment facilities
COMMENTS:
[ j There are no known archaeological sites affected by this project.
I X j There are archaeological sites affected by this project.
m Survey is necessary for adequate evaluation of archaeological
resources affected by this project.
ADDITIONAL COMMENTS: Four known prehistoric sites lie within the study area,
44Hel2, 4-4Hel3, and 44Hel4, three of which are of the Archaic period. The projec
areas shown on your maps have both historic and prehistoric potential and therefore
should be surveyed.
For further information please contact: Martha W. McCartney Ph. 253-4.836
D-2
-------
ER77/500
United States Department of the Interior
OFFICE OF THE SECRETARY
Northeast Region
150 Causeway Street, Room 1304
Boston, Massachusetts 02114
July 20, 1977
Mr. Alvin R. Morris
Regional Administrator
U. S. Environmental Protection Agency
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Morris:
This is in response to your letter requesting the Department of the Interior's
comments on the draft environmental statement for the wastewater treatment
facilities in Henrico County, Virginia.
The location of the Varina Farms alternative does give us some concern
because of its potential for creating negative impacts on cultural resources
in the area. On page VII-39 of the statement there is the comment that,
"The projected plant would also fall within one-half mile of a part of
Richmond National Battlefield Park (Fort Brady). ..." The potential for
project created adverse effects on this National Register of Historic Places
site has been identified. Specifically, the selection of this alternative
presents a potential for adverse odors and visual intrusion. Under these
circumstances, we recommend that consultation with the Advisory Council on
Historic Preservation be initiated. This effort could produce an evalua-
tion of these impacts on Fort Brady, their severity and such measures as
might mitigate them. This information should be included in the final
environmental statement.
As documented in Table VII-4 (p. VII-64-65), conflicts are identified
with various other cultural resources. Other than noting the conflicts,
the statement contains little or no information as to the nature or extent
of the impacts. Similarly, it omits all discussion of possible mitigation
measures. We recommend that consultation with the State Historic Preserva-
tion Officer and Archeologist, as well as the Advisory Council on Historic
Preservation be initiated. The results of those actions should be included
in the final statement.
D-3
-------
Alternatives E4A and E8B will conflict with existing sand and gravel
operations. The final statement should discuss the impacts that the
loss of these resources will have.
As evidenced by the above comments, we have reservations regarding the
potentially significant., environmental impacts of this proposal as they
relate to the concerns and responsibilities of this Department. It Is
to be hoped that the final statement will more adequately"T'e~spond to
those concerns. That we may be assured of this, it is requested that
the final environmental impact statement be made available to the Depart-
ment of the Interior for its further review at the earliest possible
date. The adequacy of that document will determine if further comment
or statement of position by this Department will be necessary.
Sincerely,
/
-X1.
William Patterson
Regional Environmental Officer
D-4
-------
Advisory Council on
Historic Preservation
1522 K Street N.W.
Washington, D.C. 20005 August 12, 1977
Mr. Alvin R. Morris
Acting Regional Admin'istraor
Region III
U.S. Environmental Protection Agency
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Morris:
Thank you for your request of May 18, 1977, for comments on the draft
environmental impact statement for Wastewater Treatment Facilities in
Henrico County, Virginia. We have reviewed the statement, and find that
the responsibilities of E.P.A. to comply with Section 106 of the National
Historic Preservation Act of 1966 (16 U.S.C. 470f, as amended, 90 Stat.
1320) are recognized on Page V-24 of the report. The Council's "Procedures
for the Protection of Historic and Cultural Properties" (36 C.F.R. Part 800)
should be followed in evaluating the potential sewer project sites discussed
within the report.
The final environmental statement must demonstrate that either of the
following conditions exists:
1. No properties included in or that may be eligible for inclusion in the
National Register of Historic Places are located within the area of environ-
mental impact, and the undertaking will not affect any such property. In
making this determination, the Council requires:
—evidence that you have consulted the latest edition of the National Register
(Federal Register, February 1, 1977, and its monthly supplements);
—evidence of an effort to ensure the identification of properties eligible
for inclusion in the National Register, including evidence of contact with
the State Historic Preservation Officer, whose comments should be included
in the final environmental statement. The State Historic Preservation Officer
for Virginia is Mr. Tucker Hill (804-786-3143).
D-5
The Council is an independent unit of the Executive Branch of the Federal Government charged by the Act of
October 15, 1966 to advise the President and Congress in the field of Historic Preservation.
-------
Environmental Impact Statement
2. Properties included in or that may be eligible for inclusion in the
National Register of Historic Places are located within the area of
environmental impact, and the undertaking will or will not affect any
such property. In cases where there will be an effect, the final
environmental impact statement should contain evidence of compliance
with Section 106 of the National Historic Preservation Act through
the Council's "Procedures for the Protection of Historic and Cultural
Properties" (36 C.F.R. Part 800).
Should you have any questions, please call Amy P. Sch.lagel at 202-254-7788.
Sincerely yours ,
^ -JJLMAtffl^
Myra /. Harrison
Actiag Director
Office of Review
and Compliance
D-6
-------
f f
COMMONWEALTH o/ VIRGINIA
Virginia Historic Landmarks Commission
Virginia Research Center for Archaeology
Wren Kitchen
THE COLLEGE OF WILLIAM AND MARY
Williamsburg, Virginia 23186
October 26, 1977
MEMORANDUM
T0: T.F. Turner
FROM: W. M. Kelso, Commissioner
CT ID TPpT •
'Deep bottom 201 Facilities Plan
COMMENTS:
CD There are no known archaeological sites affected by this project.
rXl There are archaeological sites affected by this project.
fXl Survey is necessary for adequate evaluation of archaeological resources affected by this project.
ADDITIONAL COMMENTS: There ^rQ two known prehistoric archaeological sites located
adjacent 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
additional archaeological sites of the prehistoric and historic periods and there-
fore should be surveyed prior to submission of the preliminary engineering report.
(Map reference: J.F. Gilmer's "Richmond and Part of the Peninsula," 1864.) Please
find enclosed a list of educational institutions which have satisfactorily completed
surveys in the state.
Wayne E. Clark
Martha W. McCartney m 804-253-4836
For further information please contact: Ph.
cc: Wayne Burgess, State Water Control Board
D-7
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VIRGINIA RllSCARCH CLIITLR TOR ARCHAEOLOGY
The educational institutions .listed beJo-.v have satisfactorily completed
archaeological survey work for the state:
American University
Department of Anthropology
c/o Dr. Clvirles V.'. Mci.'ett, Or-
Washington, D C. 20016
Catholic University
Department of Anthropology
c/o Dr. Vii.iliam Gardner
Washington, D. C. 20064-
College of William and Mary
Department of Anthropology
c/o Dr. Norman Barka
Williamsburg, Virginia 23186
University of Virginia
Department of AnthropoJogy
c/o Dr- Michael Hoffman
Room 303 Crooks Hall
Charlottesvillc, Virginia 22901
Emory and Henry College
c/o Dr. Doug]as Boyce
Emory, Virginia 24-327
3ames Madison University
Department of Sociology, Anthropology,
and Social Work
c/o Dr. Clarence Geier
Harrisoriburg, Virginia 22801
Sweetbriar College
^Department of Anthropology
c/o Ms. Ann Ottescn
Sweet Briar, Virginia 24-595
Virginia Commonwealth University
Department of Sociology and Anthropology
820 West franklin Street
Richmond, Virginia 23220
Washington and Lee University
Department of Sociology and Anlhropology
c/o Mr. John McDanicl
Lexington, Virginia 24450
It should be noted that this list is not necessarily inclusive of all
organizations which may be able to do the work. Should none of the above
institutions be able to perform the necessary survey, please advise us
as soon as possible.
When the archaeological survey is completed, the VRCA should review the
resulting report in order to furnish necessary information to the State-
Historic Preservation officer for his evaluation.
D-8
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Rt. 5, Box 327A
Richmond, Virginia 23231
January 10, 1978
Henrico County EIS
Environmental Impact Branch
Environmental protection Agency
6th and Walnut Streets
Philadelphia, rA 19106
Gentlemen;
Thank you for the opportunity to submit additional testimony to
that given at the public Hearing December 13.
Copies of letters sent to various organizations and excerpts of
resource materials to support testimony pertaining to the histor-
ical value of Deep Bottom are attached.
Construction of a waste water treatment plant would cause ur-
banization of the last prime agricultural and an Environmental
Protection Area. Ironically, the very first area of settlement
in denrico will be destroyed as well as the last thread of our
County*s earliest visible history.
In 1975, our .board of oupervisors voted unanimously in favor of
the Menrico County rarm Bureau's request for participation and
compliance with Title 58 of the Code of Virginia. ihis action
gave tax relief to farmers and other participants because agricul-
ture and other land uses are important entities in the economic
make-up of our County.
xn addition to destroying valuable farm land, construction of a
waste water treatment plant in the j^eep Bottom area would destroy
the o_aljL wild life habitat in the bounty.
Our .band Use Plan has effectively controlled the growth of our
Bounty as planned. However, any deviation from this plan would
not only violate the <^ode of Virginia 1950—±itle 15.1, chapter
11, Article 4, but, become an open uncontrolled invitation to
wild cat growth of this area.
D-9
-------
Informational copies of this letter will be sent as shown on the
bottom of this letter.
lour favora.ble consideration of facts presented supporting our
request for locating this plant outside the Deep Bottom area is
solicited.
Sincerely yours,
\ * •
(MRS.) WALTER LEMON
Attachments: 5
"A Guide to Negro History In America"
"The Sable Arm"
Battle Map dated Sept. 28, 1864
Battle Map dated sept. 29, 1864 - 6:30 AM
Battle Map dated Sept. 2y, 1864 - Midnight to 6:30 AM
Copies: 3
Richmond National Battlefield Park
Henrico County Historical Society
Virginia Historic .Landmarks Commission
D-10
-------
Kt, 5, Box 327A
hicnmond, Virginia 23?31
January 5, 1978
Mr. Sylvester Puttaan, Superintendent
Richmond National Battlefield Park
National Park Service
3215 B Broad, Street
gichmond, Virginia 23223
Dear Mr. Putman:
Located in eastern Henrico County is a tract of land commonly
known as "Deep Bottom". This land is historically significant
because it was the scene of intensive military action by black
troops during the Civil War. Many citizens of Henrico County
strongly feel that Deep Bottom is worthy of consideration as a
National Historic Landmark or a unit of Richmond National
Battlefield Park. I concur with this thinking and represent a
group of concerned citizens who would like to preserve this
site for the enjoyment of the American people.
We are requesting your assistance in bringing to the attention
of your superiors the following information with regards to
the Beep Bottom site.
Wegro soldiers fought valiantly at Dee^ Bottom during the Civil
War. 1'neir dedication to duty and the contributions made by
these soldiers should be acknowledged as worthy of commendation,
This is a very important chapter in Black History and must be
recognized befor^ it is destroyed. I am attaching excerpts of
two books and portions of Battle Maps as initial resource
material.
Copies of this material and requests for assistance and recogni-
tion will be sent organisations listed on the bottom of this
letter.
There is some urgency to thia request as the Deep Bottom site
is in lamediate danger of being lost. A proposed waate water
treatment plant at this location would virtually deatroy this
historic yiece of ground. Citizens, at a December 13 Public
D-ll
-------
Hearing, were given until January 13, 1978 to forward additional
testimony to the Henrioo County £13, Environmental Protection
Agency in Philadelphia, Ihe Agency will review the additional
testimony and announce its decision whether or not t© fund the
Deep Bottom vest site on or about February 13*
Thanking you in advance, I am,
Sincerely yours,
(MSS.) VAMEH LENOX
Attachmantsj
"A Guide to Negro History In America1*
"The Sable Arm"
Battle Map dated sept. 28, 1364
Battle Map dated Sept. 29, 1364 ~ 6j30 AM
Battle Map dated Sept. 29, 1864 - Midnight to 6i30 AM
Copies* 3
Henrioo County HistoricalJ^eiety
Virginia Historic Land^kfks Commiaaion
Henrioo County MS ^
Environmental Impact Branch
Environiaental Protection Agency
6th and Walnut Streets
Philadelphia, PA 19106
D-12
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A GUIDE TO
NEGRO HISTORY
IN AMERICA
G
I
M
BY PHILLIP T. DROTNING
DOUBLEDAY &: COMPANY, INC.
GARDEN CITY, NEW YORK
1968
-------
214 !! A Guide to Negro History in America
gathered from the numerous battlefields of the year-long siege that
led to the_faii of Richmond in April 1865. Negro troops were with
General Ulysses S. Grant when he crossed the Rapidan River with
the Army of the Potomac. They were with Major General Benjamin
F. Butler and his Army of the Jarnes, and were the first Union sol-
diers to take the James River points of Fort Powhatan, Wilson's Wharf
Landing, and City Point.
Negro cavalrymen of the 5th Massachusetts Regiment were at the
head of the Union troops that poured into Richmond after it fell,
and members of the all-Negro XXV Army Corps were close behind.
City Point National Cemetery contains a white marble monument
erected in 186; by order of General Butler in memory of the dead
of the Army of the Janies.
Maggie L. Walker High School is named in honor ot
a community leader who also was the first Negro woman bank presi-
dent. Mrs. Walker organized the St Luke Penny Savings Bank in
1902. It is now the Consolidated Bank and Trust Company. She
died in 1934.
Monumental Church, E. Broad Street, stands on the site
of the old Richmond Theater, where Governor George William Smith
and many other leading citizens died in a fire on December 26, 1811.
Gilbert Hunt, a husky slave, saved the lives of about twenty women
and children by catching them as they leaped from the upper win-
dows,
Richmond National Battlefield Park includes the fortifi-
cations that constituted the outer defenses of Richmond during the
Civil War. The area around Richmond includes many historic sites
of Civil War engagements in which Union Negro forces were deeply
engaged. Fort Harrison is now a park headquarters and museum,
and Fort Harrison National Cemetery, nearby, is the burial place
of the Union troops who died when the fort was taken.
Among the sites marked are those of the bitter battles at Chaffin's
Farm and New Market Heights.
General Benjamin Butler was so pleased with the gallantry of
Negro troops in these actions that he had two hundred medals made
by Tiffany's, and presented them to the outstanding Negro soldiers.
He commented that as he "rode among the victorious, jubilant colored
troops at New Market Heights, I felt in my inmost heart that the
capacity of the Negro race for soldiers had then and there been fully
settled forever."
VIRGINIA I) 215
Secretary of War Stanton said of the final assault: "The hardest
fighting was done by the black troops. The parts they stormed were
the worst of all."
Also in this park is the site of the battle fought at Deep Bottom
in July 1864. Four Negro regiments heroically withstood an enemy
assault, and Sergeant Major Thomas Hawkins won the Medal of
Honor for rescuing the regimental flag. Of the action, in which about
three hundred Negroes died, Major General D. B. McBirney, the
X Corps commander, said: "It was one of the most stirring and
gallant affairs I have ever known/'
Sixth Mount Zion Baptist Church, Duval and St. John's
Streets, once enjoyed the sermons of the famous Negro preacher,
John Jasper. Jasper taught himself to read with the aid of a spelling
book when he was in his late twenties. He began preaching while
still a slave, usually at funerals, and his owner charged a dollar
for each workday he missed.
During the Civil War, Jasper preached in Confederate hospitals.
When the war ended he had his freedom and seventy-three cents.
He founded Mount Zion in a shanty, and it soon grew into a strong
and popular church.
His most famous sermon was delivered for the first time in 1879
and was titled, "The Sun Do Move and the Earth Am Square."
It captured attention in America and abroad with the theological
argument, based on Joshua's saving of the Gibbonites, that Joshua
could hardly have made the sun stand still if it wasn't moving in the
first place. The church displays a bust of Pastor Jasper, executed by
Edward V. Valentine. A memorial to him stands in Woodland Cem-
etery.
ROCKY MOUNT
Booker T. Washington National Monurnent. The park
grounds contain a replica of the slave cabin in which Washington
was born, in April 1856, to Jane Ferguson, a slave and cook on the
James Burroughs plantation. After emancipation, his family moved
to Maiden, West Virginia. He adopted the name Washington, \\hen
he entered school, and added the middle initial when he learned
that his mother had named him Taliaferro. The two-hundred-acre
monument includes the Burroughs plantation.
Franklin County Courthouse. Among the historical rec-
ords kept here is the inventory made in November 1861 of the
-------
u
Negro Troops in the Union Army, 1861-1865
By
DUDLEY TAYLOR CORNISH
And then there will be some black men who can remem-
ber that with silent tongue and clenched teeth and steady
eye and well-poised bayonet they have helped mankind on
D
I
to this great consummation.
—ABRAHAM LINCOLN
The Norton Library
W • W • NORTON & COMPANY • INC
NEW YORK
-------
278
THE SABLE ARM
". . . even the slave becomes a man . . .'
279
of the officers can best attest." How his men felt about their
day's work cannot be stated accurately. But Thomas noted that
they never sang their marching song again.26
Captain James A. Rickard, who was with Thomas's own regi-
ment, the 19th U.S. Colored Troops, argued that their crater
performance improved the status of Negro soldiers. "The charge
of Ferrero's division . . . through a broken and demoralized divi-
sion of white troops, then forming line inside the enemy's
works, and temporary capture of their interior works, with awful
losses in killed, wounded and murdered, is a record," Rickard
insisted, "to win back the previously prejudiced judgment of
the president, cabinet, generals, and officers of the Army of the
Potomac, who up to this time had thought negroes all right for
service in a menial capacity, but from henceforth to take respon-
sible places, like the right flank of the army at Deep Bottom,
Va., and the storming of strong works like Forts Alexander and
Gregg." 2r Rickard was not merely exercising his own obvious
prejudice in favor of colored troops. The facts of combat in the
remaining months of 1864 bear out his assertions. He might
have added New Market Heights and Fort Gilmer while he was
about it.
In the actions around Deep Bottom, August 13 through 20,
Brigadier General William Birney's colored brigade of Major
General David Birney's X Corps did soldiers' work. There, four
regiments of colored troops fought; their casualties were rela-
tively light as compared to those of the white brigades partici-
pating. But David Birney, the corps commander, reported that
they had "behaved handsomely" and were "in fine spirits." "In
front of one colored regiment," he wrote with evident satisfac-
tion, "eighty-two dead bodies of the enemy were counted." 2S
The battle of the crater convinced Benjamin F. Butler, but
not in the way suggested by Captain Rickard. Butler, command-
ing the Army of the James, saw the Petersburg action as further
evidence that "in the Army of the Potomac negro troops were
thought of no value . . ." With the qualified exception of Smith's
good use of Hinks' colored division in the assaults of June 15,
Butler felt that "negro troops had had no chance to show their
valor or staying qualities in action." His fertile mind grappled
with the problem and devised a plan of action. "I want to con-
vince myself," he told Grant in discussing this plan, "whether,
under my own eye, the negro troops will fight; and if I can take
with the negroes, a redoubt that turned [Winfield Scott] Han-
cock's corps on a former occasion, that will settle the question."
The redoubt was the strong Confederate position at New Market
Heights. On the night of September 28 the Army of the James,
consisting of Birney's X Corps and Ord's XVIII Corps, moved
to assault positions."9
Brigadier General Charles J. Paine's report of the actions of
his 3rd Division of Ord's Corps told the story:
September 29.—The entire division, with the exception of the Tenth
U.S. Colored Troops, moved from Deep Bottom, and was successfully
engaged in the assault on the enemy's works, losing heavily in officers
and men.
Birney's report for his colored brigade was only slightly
more detailed:
September 28.—Moved across the Appomattox and James Rivers to
Deep Bottom, Va.
September 29.—Moved out from Deep Bottom. In the afternoon par-
ticipated in an assault on Fort Gilmer, a rebel earthwork near Chaffin's
farm, which was unsuccessful.
September 30.—Took part in engagement at Fort Harrison. Chaffin's
farm, in which the enemy were repulsed, with loss. The loss of the brigade
in these two engagements amounted to 434 officers and men.30
The casualty reports were more extensive. The X Corps
suffered a total of 963 killed, wounded, or missing. The 1st and
2nd divisions lost 533, while Birney's colored brigade of five
regiments lost 430. The 7th U.S. Colored was the hardest hit:
20 killed, 76 wounded, and 129 captured or missing, a total of
235 casualties. Ord's XVIII Corps came through with 2,328
casualties, with General Paine's Negro 3rd Division suffering
1,302 of that total. The 5th U.S. Colored even exceeded the
terrible losses of the 7th, with 28 killed, 185 wounded, and 23
captured or missing, a total of 236.ol
What had happened in this two-day engagement or series of
engagements, called Chaffin's Farm in the records, was more
than the sum of the enormous Union casualties. Butler had his
proof.
-------
L EL G END
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-------
Ht. 5, Box 327A
Richmond, Virginia '-3231
January 5, 1978
Dr. Henry L. kelson, Jr., President
Henrico County Historical Society
Ht. 5, Box 283-N
Richmond, Virginia 23231
Dear Dr. Nelson:
Many citizens of the Varina area are very concerned and disturbed
about the probable lost of the hiatoric Deep Bottom battlefields
to a proposed waste water treatment plant. So very much Civil War
history of thie area has not been researched and documented,
particularly, "Black History1*.
Therefore, we are asking th© Henrico County Historical iiociety to
assist the Richmond National Battlefield Park in bringing to frui-
tion, the late but, deserving recognition to which this area and
the heroic Negro soldiers of the Civil War merited.
A copy of our letter to Richmond national Battlefield Park and
copiea of resource materials substantiating our request are
attached.
Informational copies of this request will be forwarded to the
organizations listed on the bottom of this letter.
Your immediate response will be greatly appreciated.
Sincerely yours,
(MRS.) WALTER LEMON
Attachments 5
Copies 3
Richmond National Battlefield park
Virginia Historic LandnupHKs Commission
Henrico County tIS ^
iinvironmente:! Impact Branch
environmental Protection Agency
6th and Walnut Streets
Philadelphia, PA 19106
D-23
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fit. 5, Box 327 A
Richmond, Virginia 23231
January 10, 197&
Tucker H. Hill> Executive Director
Virginia Historic Landmarks Commission
221 Governor Street
Richmond, Virginia 23219
Dear Mr. Hill:
We are concerned about tne preservation and recognition of an
historic area of eastern henrico County known as "Deep Bottoa".
This area was the scene of intensive military action by black
troops during the Civil War.
The outstanding performances by ftegroea as soldiers, the
initiative displayed on the battleground of Deep liottom, their
undaunted spirits and willingness to die for the principles in
which they believed, should be protected by appropriate designa-
tion and recognition. This is the opinion of many citizens and
I concur with their observation that Deep Bottom should be
preserved for enjoyment of the American people.
Moreover, this ie a very important chapter in Black History and
this site must be recognized before it is destroyed, citizens
of Varina face probable lost of the historic Deep Bottom battle-
ground to a proposed waste water treatment plaat.
We request the Commission to designate Deep Bottom a Virginia
Historic Landmark. We have petitioned th© Richmond National
Battlefield Park to declare th© site a Unit of the Park and the
Henrico County Historical Society for concurrence.
Copies of our letters to the above-named organisations and
excerpts of resource materials are attached. Informational
copies of this request will be sent as shown on the bottom of
this letter.
f4r. Hill, we fervently seek priority action on this request to
avoid the lost of thia phase of our American heritage.
Xhanking you in advance, 1 am,
Sincerely yours,
(MRS.) wALTEtf LfiMOM
D-24
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Attachments : 5
Copies : 3
Richmond National Battlefield Park
Henrico County Historical Society
Henrico County EIS
Environmental Impact Branch
Environmental Protection Agency
6th and Walnut streets
Philadelphia, PA 19106
D-25
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COMMONWEALTH of V1RQ1N1A
Historic /.
-------
January 20, 1978
Mr. Tucker Hill
State Historic Preservation Officer
Virginia Historic Landmarks Commission
221 Governor Street
Richmond, Virginia 23219
Dear Mr. Hill:
Re: ES Project I 02-14
In preparation of the final environmental impact statement
for wastewater treatment facilities in Henrico County, Vir-
ginia, we are required to comply with Section 106 of the
National Historic Preservation Act of 1966 (Enclosure t 1).
As explained in my October 24, 1977, letter to Mr. Swisher
(Enclosure f 2) , the proposed site has been moved to the west
of Deep Bottom Road. Its approximate location is shown in
red on the enclosed area map (Enclosure # 3) and the layout
of the facility is shown on the engineer's drawing (Enclosure
* 4).
There are three areas of concern related to possible impacts
of the proposed Deep Bottom West Sites
1. The location of battle sites in the area where black
soldiers fought during the Civil War (Enclosure f 5).
2. A possibility that the Yarborough House may be in sight
of the proposed facility, and may be a structure of his-
torical significance (Enclosure # 6).
3. The final results of an archeological survey of the
site being conducted by James Cleland.
On the basis of available information and the results of
the archeological survey to be reported to you by January 31,
1978, we request that you address a letter to the above
issues, to be included in the final EIS. In order to ade-
quately prepare a statement, we would like to receive such
a letter by February 6, 1978. Your comments should identify
any properties eligible for inclusion in the National Register
of Historic Places which are located on the proposed Deep
D-27
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Mr. Tucker Hill
January 20, 1978
Page 2
bottom West site, or which may be effected by the construction
and operation of the Wastewater Treatment Facility.
We appreciate your time and effort in an endeavor to locate
and protect areas of historical and cultural significance.
Thank you for your attention to this matter.
Sincerely yours,
Helen Waldorf
Ecologist
HWrmec
Encls. 6
D-28
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Enclosure # 2
October 24, 1977
Mr. Robert Svisher
Virginia Historic Landmarks Commission
221 Governor Street
Richmond, Virginia 23219
Dear Mr. Swisher:
Re: Project Number 02-14
In reference to our conversation this afternoon, I am en-
closing copies of the proposed 201 Facilities Plan map for
Ilenrico County's Deep Bottom Road Site. As I mentioned,
the proposed facility has been moved to the west of Deep
Bottom Road. This changes the plan slightly from the one
previously under consideration. In order to determine
the Environmental Impact of the proposed facility, we need
to determine if there are any known historical or archeological
resources on the Deep Bottom Road site. Of particular inter-
est are areas which are eligible for the National Register
of Historic Places. Your help in obtaining this informa-
tion would be greatly appreciated.
Thank you for your attention to this matter. Any comments
you may have on the proposed facility at Deep Bottom Road
would be welcome.
Sincerely,
Helen Waldorf
Ecologist
HW;ecb
Encls. 3
cc: Martha McCartney
D-29
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— \\
|V
,
I'M ^,01-'
ENCLOSURE #6
-J , ,^
rdi / <>/ the1 typo <>f iu(> storey farm
dwelling popular .ifd-r (ii«- (.nil Uar. AUIuni^h presently in -bay; ell i-xlension on rear; tall, narrow e\i<-rior end
chimneys ot random American bond.
The: family cemetery is lo< ated :i cross tin- road on the north side of Kings -
land Road.
730
V 7rV7 ?//•
o
D-30
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at. 5, itoJt 327A
Virgiaia ?3231
January 27, 1978
Mr. Tucker H. Hill, &x<»cutive Director
Virginia Historic Landmarke Commission
221 Governor Street
Richmond, Virginia 25219
Dear Mr. Hi Hi
Thank you for your prompt response to our letter dated
January 19, 1978.
we respect your comments with regards to our request for rec-
ognition of "Deep bottom" as an historic Virginia Landmark.
However, we would appreciate your presenting our request to
the Kegiater Committee of the Landmarks Commission for their
consideration.
We are extremely concerned about this particular site because
of its potential to identify an area where black troops were
heavily engaged in coabat. As you know historians have, for
whatever reason, tended to ignore or overlook the contribu-
tions of women and blacks during this turbulent period of
our nation's hietory.
informational copies of this letter will be sent as shown
we view this request as^ a last chance to save this historic
piece of land. Again, w© tnank you for your proapt reply
and assistance.
Sincerely yours,
(ftKS.) WALTER LEROS
D-31
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Copies: 5
Richmond National Battlefield Park
Henrico County Historical oociety
Henrico County KXS
Environmental Impact Branch
Environmental Protection Branch
6th and Walnut streets
Philadelphia, PA 19106
National Register of Historic Places
Advisory Council on Historic preservation
D-32
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fit. 5, Box 327A
Richmond, Virginia 23231
January 27, 1978
Keeper
National Register of Historic Places
Office of Archeology and Historic Preservation
National Park service
Washington, i). C. 20240
Dear Sir:
Many citizens of this area are concerned about the preservation and
recognition of "Deep Bottom" located in eastern Hsnrico. This area
was the scene of intensive military action by black troops during the
Civil War. It was at "Deep Bottom" that the Negro proved arid displayed
hie ability as a soldier rather than a Negro performing service in a
menial capacity* four Negro regiments heroically withstood an enemy
assault and Sergeant Major Thomas Hawkins was awarded the Medal of
Honor for rescuing the regimental flag. Also, other fiegro soldiers
were awarded medals for their feats of bravery.
Presently, this historic site is in immediate danger of being lost as
it hae been chosen for a proposed waste water treatment plant. It
is our understanding that large numbers of earthworks from the Civil
War remain in the area. This important chapter in Black History
chould be preserved. In addition to the aforementioned findings,
several prehistoric sites have been located and identified within the
bounds of the proposed waste water treatment location.
we are convinced that this site would be eligible for inclusion in the
National Register of historic Places according to i>ecti~>n 106 of the
National Historic ^reservation Act of 1966 and Executive Order 11593
dated, May 12, 1971.
A letter of notification will be sent to the Advisory Council on
Historic Preservation. Copies of letters &nd excerpts of resource
materials Bent various organizations are enclosed. Informational
copies of this letter will be sent as shown below.
We respectfully request assistance in this matter in order that this
eite and phase of American history may be preserved for future
generations.
D-33
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Thank you for your cooperation and immediate attention to this
most essential matter.
Sincerely youre,
WALTER LEMON
Copies: 5
fiichmond national Battlefield Park
Henrico County Historical Society
Virginia Historic Landmark s j2Qjaiai
Henrico County KIS
Environmental Impact Branch
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, PA 19106
Advisory Council on Historic Preservation
D-34
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at. 5, BOX 327.A
Richmond, Virginia 23231
January 27, 1978
Mr. Robert Garvey, Jr., Executive Director
Advisory Council on Historic Preservation
1522 K Street, M. W.
Washington, D. C. 20005
Dear Mr. Garveyj
Many citizens of this area are concerned about the preservation and
recognition of "Deep Bottom" located in eastern Henrico. This area
was the scene of intensive military action by black troops during the
Civil War. It was at "Deep Bottom" that the Negro proved and displayed
his ability as a soldier rather than a Negro performing service in a
menial capacity. Four Kegro regiments heroically withstood an enemy
assault and Sergeant Major Thomas Hawkins was awarded the Medal of
Honor for rescuing the regimental flag. Also, other Negro soldiers
were awarded medals for their feats of bravery.
Presently, this historic sit© is in immediate danger of being lost as
it has been chooen for a proposed waste water treatment plant. It
is our understanding that large numbers of earthworks from the Civil
War remain in th® area. This important chapter in tflack History
should be preserved. In addition to the aforementioned findings,
several prehistoric dites have been located and identified within
the bounds of the proposed waste water treatment location.
We are convinced that this site would be eligible for inclusion in
the National Register of Historic Places according to Section 106 of
the National Historic Preservation Act of 1966 and Executive Order
11593 dated, May 13, 1971.
A letter of notification will be-sent to the National Register of
Historic Places. Copies of letters and excerpts of resource mater-
ials sent various organizations are enclosed. Informational copies
of this letter will be sent as shown below.
We respectfully request assistance in this matter in order that this
site and phase of American history may be preserved for future
generations.
D-35
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Ihank you for your cooperation and immediate attention to this
most essential matter.
Sincerely yours.
(MRS.) WALIEK LEMON
Copiess 5
Richmond national iiattlefield Park
Henrico County Historical Society
Virginia Historic LaQdmarkg^Comaission
Henrico County £IS ^
Environmental Impact Branch
Environmental Protection Agency
6th and Walnut streets
Philadelphia, PA 19106
National Register of Historic Places
D-36
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MEMBERS
FREDERICK HERMAN, CHAIRMAN
JAMES R SHORT, VICE CHAIRMAN
A SMITH BOWMAN
MRS WILLIAM D BUNDY, JR
EEET11
FREDERICK D NICHOLS 221 GOVERNOR STREET
MARV,N M SUTHERLAND Virginia Historic Landmarks Commission
COMMONWEALTH of VIRGINIA
R'CHM
February 63 1978
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 County3 Virginia
Dear Miss Waldorf:
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 lines 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
suburbanizes3 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 contruotion, 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,
Robert E. Swisher
Environmental Officier
D-37
RES/cw
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APPENDIX E
1-95 Data and Correspondence
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Appendix E. 1-95 Data and Correspondence
This section reprints two letters chronologically as
well as an excerpt from the Supplemental DEIS on 1-95 near
Richmond. The first letter, dated July 14, 1977 is from
Franz K. Gimmler, Acting Regional Representative of the
Secretary of Transportation, US DOT. The second letter,
dated August 2, 1977, is to Mr. R. L. Hundley, an Environ-
mental Quality Engineer with the Virginia Department of
Highways and Transportation and is written by Mr. Nicholas
M. Ruha, Chief of the EIS and Wetlands Review Section
of the Environmental Protection Agency, Region III.
E-l
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U.S. DEPARTMENT OF TRANSPORTATION
REGIONAL REPRESENTATIVE OF THE SECRETARY
434 WALNUT STREET
PHILADELPHIA, PENNSYLVANIA
July 14, 1977
19106
MEMORANDUM TO:
U.S. Environmental
Region III
Protection Agency
SUBJECT: Draft Environmental Impact Statements
We have reviewed two EPA draft EIS's and offer the following comments:
Henrico County, Virginia, Wastewater Treatment Facilities
EIS doesn't truly reflect the amount of close coordination
with the Virginia Department of Highways and Transportation which
has taken place regarding the proposed location of 1-95. A DEIS
for 1-95 (FHWA-VA-EIS-76-05-D) was circulated in July 1976. Addi-
tional highway corridors are under review due to comments received
on the DEIS and to comply with FHWA Section 4(f) requirements.
FHWA foresees no significant conflicts at this time. A portion
of the Varina Farms is historically significant. This portion is
currently on the east side of 1-95 (see Plate 6-8). A selection of
this highway alignment and EPA's selection of the Varina Farm Site
will require continued close coordination.
York -River Hastewater Treatment Facility, York County, Virginia
No comment.
We thank you for the opportunity to comment.
Franz K. Gimmler
Acting Regional Representative
of the Secretary
E-2
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SP
T>
UN'TED STATES ENVIRONMENTAL PROTEC . ',ON AGENCY
REGION III
GTH AND WALNUT STREETS
PHILADELPHIA, PENNSYLVANIA 19106
August 2, 1977
Mr. R. L. Hundley
Environmental Quality Engineer
Virginia Department of Highways
and Transportation
1221 East Broad Street
Richmond, Virginia 23219
Re: Route 95, Counties of Prince George, Chesterfield, Henrico and
the City of Petersburg; and Route 85, City of Petersburg and
Dinwiddie County, Virginia
Dear Mr. Hundley:
We have reviewed the Supplement to the draft Environmental Impact
Statement for the above proposed project. Our comments on this
document remain basically the same as those made on the draft EIS
on August 23, 1976. We continue to be concerned with wetland crossings
and stream relocations, and in light of our Section 404 involvement
we suggest that they be avoided. In addition to the comments made un
the draft EIS, we have the following comments to offer. These comments
as well as those made on the draft EIS should be addressed in the final
statement.
1. The wetlands listed on Table V-15 of the Supplement as well as
those occurring in the total project area should be shown on a map in
the final EIS. We note that Exhibit III-9 shows the major wetlands in
the northern study ar^a, but it does not show several of the wetlands
indicated in Table V-15. The map in the final EIS should show all
wetland areas and have the preferred alignment superimposed on it.
Furthermore, the final EIS should include a table similar to Table V-15
indicating the acreage of wetlands expected to be impacted by the
preferred alignment. You should note that the filling of wetlands is
not in agreement with EPA policy. Therefore wetlands, insofar as practical,
should be either avoided or crossed on structure.
2. We would suggest that the alignments also be designed to avoid
stream relocations. A table similar to Table V-ll should be provided in
the final EIS indicating which streams are to be relocated and the extent
of the relocation. This should include all streams in the project area.
In addition, the existing characteristics of the streams should be given
E-3
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(depth, width, rate of flow, stream bank vegetation, aquatic life)
along with a discussion why the relocations cannot be avoided. Since
EPA does not favor stream relocations, it must be satisfactorily shown
that there is no feasible alternative. We should be contacted when a
more specific design is known, prior to the application for Section 404
permits. This would facilitate our review of the permit application and
would avoid delays resulting from unacceptable environmental design.
3. We note that on page B-8 and B-9 it is stated that the background
levels monitored in August 1974 were seasonally corrected since "winter
months generally have 50 percent higher CO concentrations," The final
EIS should substantiate this 50 percent figure with peak monitoring
data from prior experiences in the area.
4. From the discussion in the draft Supplement, the western alternates
appear to have the least ecological impact on the environment. These
also appear to be less expensive to construct, maintain, and operate than
the eastern alternates (Tables IV-1 and IV-2). Furthermore, these alternates
subject less land to noise in excess of the DNL. While the selection
of the final alignment is the Department's responsibility, we would recommend
that one of the western alignments be chosen. This would be compatible
with recommendations made in our revfew of the draft EIS. We note that
in terms of the total alignment, Table D-l shows the western alternatives
to have fewer overall impacts than the eastern alternates.
We hope that this review will assist you in the preparation of the final
Environmental Impact Statement. We appreciate that the final EIS will
incorporate emission factors from the latest Supplement to AP-42 in the
air analysis and that a site by site discussion of noise impacts and
possible abatement features will be included. However, since we continue
to be concerned with the identified water quality and wetland impacts,
we are rating this statement ER-2 in EPA's Reference Category. If you
have any questions concerning our comments, or if we can be of any further
assistance, you may wish to contact Mr. William Hoffman of my staff at
215-597-2650. Please send us five copies of the final EIS when it is filed
with the Council on Environmental Quality.
Sincerely yours,
Nicholas M. Ruha
Chief
EIS and Wetlands Review Section
E-4
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Exhibit IV-1
WEST ALTERNATES EXTENDED
AND WEST ALTERNATES REVISION 1
E-5
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Exhibit IV-2
EAST ALTERNATES EXTENDED
AND EAST ALTERNATES REVISED
E-6
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Each of the action alternates considered require varying lengths of travel
between the Richmond-Petersburg Turnpike in the vicinity of Proposed Route 288 and
Route 1-64 east of Richmond. A comparison between the East and West Alternates
Extended and the East and West Alternates Revision 1 shows the length of travel required
on the the Revision 1 Alternates to be approximately 2 miles farther. This additional
length would increase the amount of fuel used by these vehicles. This same traffic using
an East Revision 2 alignment would travel 4 miles farther than an East or West Alternate
Extended alignment with corresponding increases in fuel consumption. However, this
increase in travel distance and fuel consumtion on the Revision 2 alignment is offset by a
reduction in travel time and fuel consumption for traffic utilizing this alternate to travel
between the Hopewell-Fort Lee area and Richmond.
B. LAND USE PLANNING
1. IMPACT ON PHYSICAL FEATURES
In general, the alternates do not exert any specific detrimental impact due to
physical features in the northern part of the study area. All of the alternates would pass
through areas where soils are suitable for limited development. Such limitations as do
exist include poor drainage and high water tables, but these are soil characteristics
common throughout the Coastal Plain and would not result in any differentiation in
impact among the alternates. Only the circumferential segment of the East Alternates
Revision 2 would encounter a large area where steep slopes (along the bluffs on the
south shore of the James River just north of Route 10) would result in greater than
normal disruption of the surrounding terrain.
2. RELATIONSHIP TO PLANNING GOALS
The probable impacts of the alternates were defined in terms of whether a
particular alternate would enhance the expressed goals of various planning entities in
the study area, would have no direct relationship, or would conflict with these goals.
The West Alternates Extended and the East Alternates Extended would
generally enhance or have little effect on planning goals. The alternates extended would
follow the general boundary of Henrico's planned 1985 sewage services area and may
help achieve the goal of concentrating a mix of development types and influencing the
timing of development to occur only after the requisite public facilities are present.
Nothing in the location and design of these alternates would prevent the goals of
planning for open space and the protection of natural resources from being attained.
Since these alternates would be located in predominantly open areas and out of the path
of planned development, they would avoid conflict with the goal of locating limited
access highways so as not to disrupt neighborhoods, business centers, parks, and other
homogeneous areas.
Because the West Alternates Revision 1 and the East Alternates Revision 1 and
Revision 2 traverse areas planned for conservation, there is the potential for adversely
affecting the area's planning goals. The Revision 1 alternates may compromise
-------
environmental goals of planning for open space and protecting natural resources since
they would parallel Cornelius Creek in Henrico County which is planned as a protected
natural open space. In addition, the East Alternates Revision 2 would have a similar
impact on goals in the vicinity of the bluffs along the south shore of the James.
All alternates would promote the goal of providing accessibility to areas
consistent with the planned intensity of land use in that the placement of interchanges
would provide access to planned uses in the immediate vicinity. (This is especially the
case for commercial and industrial land uses on the eastern periphery of the Richmond
SMSA.)
3. IMPACT ON COMMUNITY FACILITIES
All of the alternates would generally aid police, fire, and rescue services by
improving high-speed access to areas near interchanges. From an overall standpoint, the
impact on police services would be relatively unimportant compared to fire and rescue
services. As fire and rescue service areas are revised, any of the alternates could be used
advantageously. Interjurisdictional cooperation regarding these emergency services
could have a notable beneficial impact in conjunction with any alternate's provision of
new highway linkages between Chesterfield and Henrico Counties across the James
River.
Of potentially greater importance is the impact of the alternates on water and
sewer service. Even though all alternates would create development pressures around
local access interchanges in Henrico County, the interchange locations are reasonably
close to the proposed sewer system or to existing service areas, thus minimizing the
anticipated costs to extend lines. It is not expected that any alternate would substantially
affect the provisions of water and sewer service. Under Revision 1 Alternates a portion of
Henrico County planned to receive sewer service between 1980 and 1990 would be
crossed. If one of these alternates were constructed before the area is sewered, the
potential exists for more difficulties and expense in placing gravity lines, lift stations, and
force mains. However, with proper coordination, the construction of these alternates
should not result in any significant impact on the future provision of sewer service.
4. IMPACT ON ACTIVITY CENTERS AND CLUSTERS
The impact of the alternates on existing activity centers and clusters is
considered to be of much more importance than the impact on planned clusters. With
respect to an activity cluster, the determination was made as to whether the clusters
would be served, not affected, or disrupted by the various alternatives.
a. Existing Activity Centers and Clusters
All alternates would have an overall neutral impact on existing activity
centers and clusters since their proposed interchanges do not interfere with or redirect
trends of development. For the most part, the interchanges would be supportive by
attracting growth to the East Henrico activity cluster and the Byrd International Airport
activity center. This phenomenon would be especially strong for the Revision 1
Alternates (either East or West).
-------
b. Planned Activity Clusters
All alternates would promote the development of mixed use activities
within the planned East Henrico cluster through the location of interchanges with
functional local access convenient to the cluster. Even though the alternates would cross
a port ion of this planned cluster (see Exhibit V-1), the land areas involved a re planned for
industrial uses which are generally not sensitive to highway intrusion so long as access is
retained. The East Alternates Revision 2 would create a barrier to expected expansion of
the Route 1-301/Turnpike corridor cluster northward to the James River (see Exhibit V-
1). The other alternates would absorb some land planned for industrial use in this same
cluster, but the effect is not considered significant.
5. IMPACT ON LAND USES
The impacts of the alternates on exist ing individual land uses were considered
apart from the conceptual clusters and this impact was deemed more important than any
impact on planned land use. The principal measure of impact was the extent of
elimination either through direct absortion for right-of-way or through secondary
pressures caused by new interchanges generating new land uses. Some of the potential
impacts of the alternates relative to existing and planned land use (both within and
without activity clusters) are summarized in Exhibit V-1.
a. Existing Land Uses
The East and West Alternates Extended would be located largely through
rural areas and thus would have relatively little impact on existing land use in terms of
occurrences, quantity, or intensity. The East and West Alternates Revision 1 would pass
through more developed portions of the study area and thus, would take some existing
residential land and improvements. The impact of the East Alternates Revision 2 would
be similar, but not of as great a magnitude since it would be largely limited tothetaking
of residential land in a mobile home subdivision just south of the James River.
b. Planned Land Use
The East Alternates Revision 1 and the West Alternates Revision 1 would
intrude into large areas of planned low density residential uses in Henrico County. They
would also cross planned industrial concentrations in Henrico County south of the
airport but the impact would be minimal since these industrial uses would not likely be
sensitive to highway intrusion. None of the other alternates is likely to significantly
impact planned residential uses. The location of all proposed interchanges appear to
support planned directions of growth.
6. SUMMARY OF PLANNING IMPACTS
A summary of the probable impacts from a planning perspective is tabulated
for the alternates in Table V-1.
E-9
V-6
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HENRI CO X* »
\
t ^—L/A INTERCHANGE
\ ^u"
\TE«0 TO EIPtKO ClllST£«
.1--,TO«4R5 '
^ .*/\ i /..;
.•;%'* K I 'A-/
PUNNED CLUSTER BOUNDARY
EXISTING CLUSTER BOUNDARY
WESTERN ALTERNATES
EASTERN ALTERNATES
NOTE: L/A INDICATES LIMITED ACCESS
(NO DIRECT ACCESS TO LOCAL ROADS)
Exhibit V-1
DEVELOPMENT PRESSURES
E-10
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APPENDIX F
Nabisco Correspondence
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Appendix F. NABISCO Correspondence
This section reprints six letters: (1) two letters
dated July 5 and July 14, 1977 from Mr. R. M. Schaeberle
and Mr. Robert L. Sanford of NABISCO, Inc., (2) one letter
dated July 29, 1977 from Mr. Kenneth E. Taylor, Director
of the Food and Drug Administration's Environmental Impact
Staff, (3) two letters dated July 25 and June 30, 1977
from Mr. Charles Custard, Director of the Office of En-
vironmental Affairs of the U.S. Department of Health,
Education and Welfare, and (4) one letter dated November 8, 1977
written to Dr. Taylor (FDA) from Mr. Jack J. Schramm,
Administrator of the Environmental Protection Agency's
Region III.
F-l
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East Hanover. New Jersey OVCOi
Olfico of Chairmnn of the Uonrd
July 5, 1977
Donald Kennedy, Ph.D.
Commissioner of Food and Drugs
Food and Drug Administration
200 C Street S.W.
Washington, D. C, 2020^
Dear Dr. Kennedy:
Nabisco owns an 820,000 square foot bakery in
Richmond, Virginia which produces over 500,000 pounds of
nationally distributed cooki.es, crackers and snack products
per day.
The county is seriously considering the construction
of a huge $70 million dollar sewage treatment plant at a site
directly adjacent to our bakery.
I have been advised by our technical people that
during waste treatment a great number and variety of pathogens,
such as salmonella and staphylococci, can be aerosolized.
Since the proposed sewage plant would be within
1200 feet of our bakery, we are gravely concerned that such
possible aerosolization raises serious questions regarding
the company's ability to meet its specific duties under the
good manufacturing practice regulations and its general
responsibility to provide a sanitary facility for the storage
and production of food products.
The United States Environmental Protection Agency's
draft environmental impact statement does not address itself
to the health and sanitation impacts of placing so -large a
treatment facility next to one of the country's largest
food producing plants.
We believe these impacts must be fully explored
before any responsible action can be taken regarding the
site selection for the sewage treatment plant.
Since FDA sets and administers the operative sanitary
standards for our facility and since the agency has the greatest
expertise in this field, we urge that FDA assess and evaluate
the potential health and sanitation problems which may arise-
F-2
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Our own review of these Issues strongly indicates
that a sewage treatment plant of the magnitude contemplated
should never be built alongside a food producing facility.
Nabisco, of course, stands ready to provide you
with any information or assistance you may require, and to
this end, I would suggest that any inquiries from the agency
in this regard be addressed to Mr. James Kirkman, who is
monitoring all developments on this matter for the company.
f\
»"-(-,
V&r> trjAly yours,
i\ / />
v,/,-/ /// . A./
.ft. M.JSchaeberle
RMS/ef
cc: Dr. Richard Bates
Associate Commissioner for Science
Mr. Joseph Hile
Associate Commissioner for Compliance
.Richard A. Merrill, Esq.
General Counsel
Howard R. Roberts, Ph.D.
Director, Bureau of Foods
F-3
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, INC.
East Hanover, New Jersey 07936 (201) 884-0500
Cable Address: NABISCO
July 14, 1977
Alvin R. Morris
Acting Regional Director
United States Environmental
Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Re: COMMENTS OP NABISCO, INC. ON THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR HENRICO COUNTY, VIRGINIA WASTEWATER
TREATMENT FACILITIES
Nabisco, Inc., East Hanover, New Jersey, is engaged
principally in the manufacture and sale throughout the United
States and abroad of various quality food products, including
cookies and crackers, pretzels and snack items.
One of the company's ten U.S. bakeries producing
such products is located In the eastern section of Henrico
County at 6002 South Laburnam Avenue.
This bakery is Nabisco's newest, having been completed
in late 1973, and is the most advanced facility of Its type in
the world. The bakery occupies 820,000 square feet and represents
an investment In excess of $60 million dollars. Currently, the
plant is producing at a rate of 500,000 pounds of product per
day.
We now employ approximately 800 people generating an
annual payroll of over $8 million dollars, and future expansion
plans could Increase the employment level to over 1200.
F-4
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- 2 -
Our Investment in the Richmond bakery and its vital
role in our business and the community clearly mandate that
the company take an active role in assessing the impact of the
various waste treatment site alternatives on its bakery operations
and the community at large.
To this end, we have carefully reviewed the Draft
Environmental Impact Statement dated May 18, 1977, [hereinafter
cited as EIS], and are of the opinion that the EIS's analysis
of the Upper Cornelius Creek site's potential impact on Nabisco's
adjacent bakery is incomplete and fails to address itself to the
potential hazards of placing a waste treatment facility within
1200 feet of a major food processing plant.
We also believe that the EIS's statement regarding the
Cornelius Creek site's compatibility with the county's Future Land
Use Plan's "light" industrial classification misapprehends the
nature and purpose of such classification and that placement of
a waste treatment facility within such a zone could seriously impact
the economic development of this area and the entire community.
Finally, as we shall discuss in detail, we feel the EIS
understates the Cornelias Creek site's unsuitability for sludge
land-fill handling and that this deficiency is sufficiently serious
to rule out the site as a viable alternative.
F-5
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POINT I
PLACEMENT OF A WASTE TREATMENT FACILITY ON
THE UPPER CORNELIUS CREEK SITE ADJACENT TO
A MAJOR FOOD PRODUCING PLANT CREATES THE
POTENTIAL FOR PRODUCT ADULTERATION, AND THUS
SUCH SITE CANNOT BE RECOMMENDED AS AN
ALTERNATIVE UNTIL THESE SANITATION AND PUBLIC
HEALTH IMPACTS ARE FULLY EXPLORED AND FOUND
NOT TO BE ADVERSE.
We are deeply concerned that the location of a sewage
treatment facility at the Cornelius Creek site, which is adjacent
to our bakery, may expose finished product and ingredients stored
on the premises to the risk of contamination from air-borne bacteria
of fecal origin.
A review of the literature indicates that during waste
treatment sewage organisms, including a great number and variety
of pathogens, such as E. Coll, salmonella, staphylococci,
mycobacterium and enteric viruses, can be aerosolized.*
*Goff, G.D., J. C. Spendlove, A. P. Adams and
P. S. NIcholes, "Emission of Microbial Aerosols
from Sewage Treatment Plants that Use Tricling
Filters." Health Services Reports Vol. 88,
pp. 640-652 (1973).
Adams, A. P. and J. C. Spendlove; "Coliform
Aerosols Emitted by Sewage Treatment Plants."
Science Vol. 1969, pp. 1218-1120 (1970).
Napolitano, P. J. and D. R. Rowe; "Microbial
Content of Air Near Sewage Treatment Plants."
Water Sewage Works Vol. 113, pp. 480-483 (1966).
Glaser, J. R. and J. 0. Ledbetter; "Sizes and
Numbers of Aerosols Generated by Activated Sludge
Aeration." Water Sewage Works, Vol. 114, pp.
219-221 (19F/T: F_6
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_ 4 -
Depending upon the prevailing meterological conditions,
these potentially dangerous organisms can be transmitted as far
as .8 miles.
Since it is only 800 feet from the bakery to our property
line and approximately an additional 400 feet from there to the
proposed location of the plant on the Cornelius Creek site, our
bakery would be well within striking range of these aerosolized
pathogens.
As opposed to, for example, canned products where
sterility is achieved in the packing process and the product is
rendered impervious to air-borne contamination at the point of
canning, baking temperatures are not sufficient to insure
destruction of many pathogens,and even if they were, our products
would still be subject to air-borne bacteria after they leave the
oven.
The EPA must realize that strict laws pertaining to
purity govern the manufacture of food products. For example,
under the Federal Food Drug and Cosmetic Act and Virginia Pure
Food laws, a food product will be deemed "adulterated" if it has
been "prepared, packed or held under unsanitary conditions whereby
it may have become contaminated with filth or whereby it may have
been rendered injurious to health [21 U.S. C §342(a) (4); Virginia
Food Act §3.1-3951,emphasis provided]."
Thus under this statute, a food product may be absolutely
pure but nevertheless adulterated if the conditions under which
it was manufactured were such as to create the possibility that
the product could have been contaminated.
F-7
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The FDA has promulgated Good Manufacturing Practice
(GMP) regulations [2 CFR §110.1 et. seq.] which set forth some
of the criteria used to evaluate compliance regarding the
maintenance of a sanitary food manufacturing facility.
Significantly, these regulations specifically state
that the grounds adjacent to a food plant "shall be free from
conditions which may result in the contamination of food..."
Moreover,this duty on the food processor applies whether the
immediate grounds are within his control or not.
Even prior to the enactment of the GMP regulations,
the PDA had always considered the plant environs as an important
element in its overall evaluation of a facility's sanitary
fitness.*
We wish to make it absolutely clear to the EPA that
Nabisco is not stating categorically herein that the operation
of the proposed plant at the Cornelius Creek site will render
its plant or products violative of applicable federal and state
pure food laws or regulations. What we are saying in these
comments is that the presence of such a large waste treatment
facility adjacent to our bakery raises serious and legitimate
questions concerning our ability to comply with statutorily
mandated standards of sanitation.
* e.g. see statement of former FDA
Commissioner citing waste disposal
"of the other buildings in immediate
surroundings" as a factor. (CCH Food,
Drug & Cosmetic Law Reporter, 1150,077)
F-8
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Further, we think it is patently clear that EPA
cannot responsibly proffer Cornelius Creek as an acceptable
alternative site until all aspects of these questions have
been thoroughly explored and the weight of probative scientific
evidence rules out any possibility that the treatment facility
could render our bakery products unfit.
Since the operative legal standard includes both
actual contamination of food and the maintenance and existence
of conditions which may cause contamination, the evaluation of
the treatment facility's impact on the bakery must include a
review of potential impacts which could arise if the facility
malfunctions or if conditions, such as weather, create additional
stresses on the system. Even the best designed and operated
waste treatment plant is going to have occasional breakdown.
As one commentator has succinctly stated: "Even under the best
of conditions, sewage is difficult to handle without a problem
[Cochran, D. M., "Nuisance Control, Odors, Insects, Frothing
and Other Nuisances," Manual of Wastewater Operations, p. 461,
Texas Water Utilities Association (1971)]."
It takes little Imagination to envision the horrendous
consequences which might attend a precipitous decision in favor
of the Cornelius Creek site without first conducting a full
exploration into the health and sanitation impacts of the treat-
ment facility vis-a-vis its food plant neighbor.
With bakery production at 500,000 pounds of nationally
distributed product per day, the potential scope and breadth of
any public health problem is self-explanatory.
F-9
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Given Nabisco's $60 million dollar investment in
the plant and its $8 million dollar payroll, even a temporary
shutdown caused by a malfunction in the sewage treatment system
could result in huge losses to Nabisco and to the community,
and under such a scenario, the ultimate liability for the injury
caused by the treatment facility would fall upon the county.
To assist EPA in its inquiry regarding the health-
sanitation issues, we have written the FDA (a copy of the letter
is attached hereto) advising it of the situation and requesting
it to review the possible adverse sanitation consequences
the treatment facility may have on our bakery. It is our under-
standing that PDA and EPA maintain an active liaison, and we
would suggest,since FDA has great experience and expertise in
the area of food manufacturing facility sanitation, that EPA
work closely with that agency in evaluating these health-
sanitation impacts.
F-10
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POINT II
PLACEMENT OF A WASTE TREATMENT FACILITY ON THE
UPPER CORNELIUS CREEK SITE ADJACENT TO A MAJOR
FOOD PRODUCING PLANT CREATES THE POTENTIAL FOR
ODOR CONTAMINATION OF PRODUCTS, AND THUS SUCH
SITE CANNOT BE RECOMMENDED AS AN ALTERNATIVE
UNTIL THIS ODOR IMPACT IS FULLY EXPLORED AND
FOUND NOT TO BE ADVERSE.
As every housewife knows who has put an uncovered onion
or some other pungent item in her refrigerator, that food's aroma
will migrate to the other foods in the refrigerator, often creating
some rather bizarre and unpleasant taste combinations.
There is no reason to believe that our products and
ingredients which are stored on the bakery premises would not also
be susceptible to impregnation by malodorous breezes generated by
a waste treatment facility.
We have documented claims against freight carriers for
merchandise rendered unsalable because residual odors in trailers
left from the prior transport of odoriferous substances permeated
our products causing off-taste conditions.
If obnoxious odors can penetrate finished product which
is already packaged and is contained in a heavy shipping carton,
then clearly the product in production and bulk-stored raw materials
at the Richmond bakery, which of course have no protective packaging,
appear particularly vulnerable to odor contamination from the
proposed treatment facility.
F-ll
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- 9 -
Despite all attempts to suppress them, it is acknowledged
by the experts that waste treatment plants of the type contemplated
here will periodically produce strong and unpleasant odors. Indeed
the EIS statement seems to acknowledge that such odor will be a
fact of life for the facility. For example, in describing the
impact of the facility on the Darbytown Road site, the EIS report
admits that "possible conflicts due to odor-.." will have to be
resolved (EIS, p VIII - 46). More significantly, the EIS report
specifically states, in its discussion of the Upper Cornelius
Creek site, that "effective odor control would still be important,
since some residences occur 3/4 of a mile to the north and one
mile to the southwest [EIS, p. VII - 57]."
As in the case of the sanitary-public health issues,
the EIS fails to address itself to the important question of
odor's effect on our bakery, which lies in the prevailing wind
pattern from Cornelius Creek and which, unlike the private
residents 3/4 to one mile away, is only 1200 feet from the pro-
posed site of the treatment facility.
Again, we submit that the EPA cannot recommend the
Cornelius Creek site as an alternative until it is completely
satisfied that our bakery will not be adversely affected by
odors emanating from a treatment facility at this location.
While odor contaminated product does not raise the public
health problems involved in the sanitary issues previously
discussed, it does contain all the potential economic impacts
of these issues, Including the county's liability for Injury
caused by the treatment facility.
F-12
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- 10 -
POINT III
THE CORNELIUS CREEK SITE APPEARS UNSUITED FOR
SLUDGE LANDFILL ACTIVITY AND THUS SUCH SITE
SHOULD NOT BE RECOMMENDED AS AN ALTERNATIVE
UNTIL FURTHER ANALYSIS OF THE SITE DEMONSTRATES
THAT IT CAN ACCOMMODATE SUCH LANDFILL WITHOUT
ADVERSE IMPACT ON THE AREA'S GROUNDWATER SUPPLY
AND QUALITY.
As the County's consulting engineers acknowledge,
sludge handling and sludge disposal are often the most difficult
and costly phase of wastewater treatment [Information Handout -
Henrico County 201 Facilities Plan, January 11, 1977; P. 3].
The treatment facility alternatives contemplated by the County
will produce from 23,000 to 54,000 pounds of sludge per day
[EIS, p. VIII-89].
Primarily for reasons of air quality, incineration of
the sludge has been ruled out, and it is assumed in the dis-
cussions concerning the four proposed sites that all sludge dis-
posal will be handled on an on-site landfill basis [EIS pp. VII-
75 - VIII-89; see also FPS, Appendix 10].
The other alternative method of sludge handling which
involves the transportation of sludge to other disposal sites
has been rejected as too costly and impractical. Thus, any site
selected must be able to accommodate substantial quantities of
sludge. In its summary of environmental.impacts [EIS pp. VII-64
and 65, Table VII-4 ] the EIS specifically identifies Cornelius
Creek as a "poor site for sludge landfill."
F-13
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- 11 -
The Cornelius site is characterized by numerous water
filled borrow pits which indicate a fairly high water table
[EIS, pp. VII-57-59]. The Facilities Planning Study, alluding
to this condition, states that a considerable amount of site
drainage will be required [FPS p. 6-29].
If this drainage is undertaken to accommodate the
borrow pits for sludge landfill, two possible consequences, both
of which would be seriously detrimental to the area, are possible
If the ponds are not completely drained and the water
table is not lowered sufficiently to prevent their refilling,
heavy metal contaminants and pathogenic organisms which remain
in dewatered sludge would come in contact with groundwater re-
entering the pits and could, given the quantities of sludge
involved, eventually contaminate the well systems which service
not only the Nabisco bakery but also many residents in this
section of the County.
The other possibility is that, if the ponds are in
fact completely drained and the water table lowered sufficiently
to prevent their refilling, the quantity of groundwater left
for community use could be greatly diminished.
In light of the fact that sludge disposal is one of
the most difficult and expensive aspects of wastewater treatment
and that Cornelius Creek is the only site where the landfill
method of disposal is clearly contraindicated, the selection of
this location should be ruled out unless further study by EPA
clearly demonstrates this site can support extensive landfill
activity.
F-14
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- 12 -
It must also be noted that dewatered sludge does
contain nutrients which can attract pests and vermin. Here
again, the proximity of the site to a major food producing
facility raises potential health issues in the event of
improper disposal.
POINT IV
PLACEMENT OP A WASTE TREATMENT PLANT ON THE
UPPER CORNELIUS CREEK SITE IS NOT COMPATIBLE
WITH THE COUNTY'S FUTURE LAND USE PLAN
DESIGNATION OF "LIGHT" INDUSTRY FOR SUCH
AREA AND THUS SUCH SITE CANNOT BE RECOMMENDED
AS AN ALTERNATIVE UNTIL THE ECONOMIC IMPACTS
OF PLACING SUCH A FACILITY WITHIN THIS AREA
ARE FULLY EXPLORED AND FOUND NOT TO BE ADVERSE.
One of the arguments advanced for the Cornelius Creek
site is that it currently is designated as "light industrial" on
the County's Future Land Use Plan and thus appropriate for a
waste treatment facility [EIS, p. VII-57].
We believe this argument has no merit. The purpose of
the "light industrial" classification is to designate an area,
compatible with overall community needs, which can accommodate
and stimulate Industrial development. Such development adds
ratables to the tax rolls and creates jobs and purchasing power
which in turn generate economic activity throughout the entire
community.
F-15
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- 13 -
The location of a waste treatment facility in such
an industrial designated zone is totally incompatible with
these goals. The facility Itself will contribute nothing to
the community's tax base. Moreover, despite its large capital
costs, the facility, once operational, will need only 30 to 40
employees.
Perhaps even more significantly, the location of a
treatment facility at Cornelius Creek, in addition to taking
260 acres of industrially zoned land out of circulation, could
seriously impact the commercial development of the entire area.
Nabisco is already on record at the June 21 hearing
that it would never have built its bakery at the present location
if the proposed treatment facility was on the Cornelius Creek
site. Furthermore, as we stated at the hearing, expansion plans,
which could add as many as 400 additional employees to our bakery
payroll and which were under active consideration by Nabisco,
have been placed in abeyance pending a final site selection decision
As the matter now stands, there would appear little chance of that
expansion going forward if the Cornelius Creek site is chosen.
As a food processor, our views concerning the placement
of a large sewage treatment facility adjacent to our plant are by
no means unique- Indeed, we feel safe in stating that no food
manufacturer would ever consider locating a plant in such an
environment.
While we cannot document it, we also believe that
others in nonfood "light" industries would be reluctant to
locate close to a large treatment facility.
F-16
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- 14 -
In essence, such a facility is not in harmony with
the spirit and. purpose of the "light industry" designation and
location of it at Cornelius Creek could impede the area's
future development.
Thus, we believe, EPA must assess more thoroughly
the actual economic impact on the community of placing a
waste treatment facility in such an area before it can
recommend the Cornelius Creek site as a viable alternative.
CONCLUSION
The factors we have considered herein concerning
Cornelius Creek's suitability as a waste treatment site raise,
In our opinion, serious questions concerning the feasibility and
advisability of this location.
Some of these questions, such as those Involving
sanitation and odor contamination, were not even addressed in
the EIS report. We feel strongly they are legitimate and
serious concerns which must be investigated thoroughly by EPA
before any conclusion concerning Cornelius Creek's fitness as
a waste treatment site can be properly drawn.
Similarly, the sludge and land use issues need to
be further explored along the lines suggested herein. Will
the Cornelius Creek site really be able to handle the projected
quantities of sludge on a landfill basis without adverse impact
on the area's groundwatersupply? We do not think the EIS draft
definitively answers this question. Nor do we believe the EIS
adequately assesses the potential adverse economic impact of
F-17
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- 15 -
placing a waste treatment facility in an area earmarked for
light industrial development.
Nabisco, of course, stands ready to provide whatever
assistance it can to EPA in resolving these important issues.
Respectfully submitted
NABISCO, INC.
Senior Vice"President
F-18
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
PUBLIC HEALTH SERVICE
FOOD AND DRUG ADMINISTRATION
ROCKVILLE, MARYLAND 20857
Mr. Alvin R. Morris
Acting Regional Administrator
Environmental Protection Agency, Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Morris:
This letter refers to the Draft Environmental Impact Statement
entitled, "Wastewater Treatment Facilities for Henrico County,
Virginia," and a related request to FDA from Nabisco.
Subsequent to the issuance of the draft EIS, Nabisco, Inc. asked the
Food and Drug Administration to assess any potential health and
sanitation problems which may arise at a large Nabisco bakery
adjacent to one of the four alternative sites for the proposed
wastewater treatment facilities. Potential contamination of bakery
products from aerosolized pathogens were cited as the source of
Nabisco's concern. If such food contamination occurred and could
not be prevented from recurring, then the bakery would be forced to
close since it could not meet FDA sanitation requirements.
We have reviewed the draft EIS and find that, while the document
mentions the presence of the Nabisco bakery at one of the sites
being considered, the potential public health and sanitation impacts
on products manufactured at this major food processing plant are not
discussed. Based on the literature immediately available to the
Agency, we believe that there is some evidence to support Nabisco's
concern. Adams and Spendlove (Science 169:1219-20, 1970) monitored
coliforms and the general microbial population aerosolized by two
sizes (6 and 25 mgd) of trickling filter wastewater treatment
plants. They detected aerosolized bacteria as far as 0.8 miles
downwind from these facilities. J. 0. Ledbetter (Water and Sewage
Works, February 1966) also discusses aerosolized bacteria resulting
from bubbling air through sewage (as in some activated sludge
plants) and mechanical aeration. These processes might also be
expected to strip from the sewage and release into the atmosphere
viruses and compounds of low water solubility such as aromatics,
PCB's, and mercury (Mackay and Wolkoff, Envir Sci and Tech
7_:611-6.13, July 1973). Of course, the wastewater treatment process
selected will affect the quantity of aerosolized pathogens and the
amounts of industrial wastes entering the facility will affect the
types and amounts of chemicals released into the atmosphere.
F-19
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Mr. Morris 2
We believe that these possible sources of contamination to the
Nabisco bakery, as well as any other food manufacturing or
handling facilities near the alternative treatment plant
sites, should be examined and weighed accordingly in choosing
the final site for the proposed wastewater treatment
facility. The final EIS should reflect these considerations.
Sincerely yours,
E, TayJo, D.V.M.
Director
Environmental Impact Staff
F-20
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20201
JUL 2 5 1977
United States Environmental Protection Agency
Region III
EIS Preparation Section
Environmental Impact Branch
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Sir:
In the light of recent information this department has to revise the
comments forwarded to your office June 30, 1977 regarding the draft
Environmental Impact Statement on Wastewater Treatment Facilities,
Henrico County, Virginia.
It has come to our attention that a food processing plant is under
construction adjacent to the proposed site for the Henrico County
Wastewater Treatment Facilities. Due to this omission, important
public health and environmental effects were not discussed in the
Statement. Therefore, this Department has concluded that the draft
Environmental Impact Statement is inadequate.
Sincerely yours,
Charles Custard
Director
Office of Environmental Affairs
F-21
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20201
June 30, 1977
United States Environmental Protection Agency
Region III
EIS Preparation Section
Environmental Impact Branch
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Sir:
Thank you for the opportunity to review the draft Environmental
Impact Statement on Wastewater Treatment Facilities, Henrico County,
Virginia.
The format, including presentation of alternatives, was well
organized. We have one comment dealing with the water quality of
the James River which is utilized as a municipal water source.
To assist in the selection of alternatives for effluent disposal,
an analysis of the nutrient and organic chemical loading of the
James River would be helpful. The analysis should compare projected
loadings with the state standard at various seasonal flows. The
effluent decisions would then be based on environmental as well as
economic factors.
Sincerely,
Charles Custard
Director
Office of Environmental Affairs
F-22
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UNITED STATES .ENVIRONMENTAL PROTECTION AGENCY
REGION III
6TH AND WALNUT STREETS
PHILAbELPHIA, PENNSYLVANIA 19106
NOV 8 1977
Dr. Kenneth E. Taylor, D.V.M. HFS30
Director, Environmental Impact. Staff
Food and Drug Administration
Office of Associate Commission for Science
5600 Fishers Lane
Rockville, MD 20857
Dear Dr. Taylor:
This letter refers to your July 29, 1977 letter to Dr. Alvin R. Morris
in which you raised some concerns regarding the potential health and
sanitation problems which may result from a proposed siting of the
Henrico County Sewage Treatment Plant (STP) next to an existing major
Nabisco bakery.
Although it was acknowledged that these concerns could be addressed
in the Final Environmental Impact Statement. (EIS) now under preparation,
I feel that it would be most advantageous co indicate our position on
these concerns as a result of an analysis of recent studies. The
attachment summarizes these findings as compiled by our EIS consultant.
EPA's general policy is to conform with the existing State standards.
The Commonwealth of Virginia Sewerage Regulations state that a minimum
of 600 feet must, exist between the sewerage facilities and any residential
or similar type structure (Part C, Part 2301, Draft, March 1975). The
attached comments support this minimum distance as being more than
adequate in assuring that any potential health or sanitation concerns
have been properly integrated into the Henrico STP planning process.
Let me assure you that the local Nabisco bakery will be kept informed
of our actions regarding this subject and their comments will be
solicited and carefully considered befoie any final administrative
action is made.
F-23
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For your review, a copy of the Final EIS will be sent to your office
as well as the Nabisco Bakery when it is complete.
Thank you for your interest.
Sincerely^yours,
Jack J. Schramm
Regional Administrator
Enclosure
cc: Pat Brady, Henrico Co. Public Utilities
Robert Sanford, Sr. Vice President, Nabisco, Inc.
F-24
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IMPACT SUMMARY
1. Aerosols.
A number of studies have .been made of the formation and spread of
aerosols at wastewater treatment plants. Rickey and Reist have
provided an excellent summary and analysis of the literature in the
Journal, WPCF, December 1975. Many of the studies reported involved
trickling filters or spray irrigation, which are not proposed for
Henrico, but a sufficient amount of information on the activated sludge
process appears available to draw some conclusions.
The major source of aerosols at an activated sludge plant is the aeration
tank, due to the breaking of bubbles at the liquid surface. Other
treatment units, such as clarifiers, have not been identified as signi-
ficant contributors to aerosols.
Concentrations of viable organisms have been reported as far as 200
feet from aeration tanks. However, they have been found 1000 feet
from trickling filters, so the possibility of further travel can not
be excluded. The plant site, regardless of location, will have a
minimum buffer zone of 600 feet and the distance to the aeration tanks
could be even greater, depending upon plant design. Adding 800 feet
from the Nabisco property line to the bakery gives a minimum distance
of 1400 feet. This is further than any distance at which viable
organisms have been detected in studies reported in the literature.
Several mitigating measures for providing further protection from
airborne pathogens could be implemented at reasonable cost:
Locate the aeration tanks at the opposite end of the site from
Nabisco.
Enclose the aeration tanks with a cover, or choose the pure
oxygen or Bio-surf alternatives, which are routinely covered.
Install scrubbers in the vents from covered tanks.
To determine if these mitigation measures are necessary, the following
program could be implemented:
When the treatment process is selected after pilot studies, conduct
an aerosol sampling program at a plant of similar design. This
will determine if further protection is needed.
Sample the Henrico facility after startup to confirm effectiveness
of protective measures.
F-25
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2. Odors
The proposed facility is a new plant treating normal domestic waste-
water, adequately sized, properly funded, and operated by a county
with a good reputation for maintaining public services. Under these
circumstances, there is no justification for concluding, in advance,
that odors will result from bad design or poor management. The
large buffer zone provides good protection against any stray odors
arising from normal operations.
The plant will be designed for normal mechanical failures, although
more severe accidents are possible. Because site drainage will be
controlled, a spill of sewage or sludge could be cleaned in a relatively
short time. Arrangements could be made to by-pass raw sewage chould
the plant be severely damaged by an explosion or other catastrophic
event. Thus, the possibility of an extended period of odor contamina-
tion due to an accident is remote.
3. Groundwater Contamination
From an engineering standpoint, the Upper Cornelius Creek site does
not have the most desirable properties for a sanitary landfill site;
however this simply means that more effort will be required to
properly construct a landfill, not.that one can not be constructed.
Primary control of landfill leachate is accomplished by compacted
cover material which minimizes percolation of water into the landfill.
An impermeable bottom liner provides additional protection by collecting
leachate which does occur. Monitoring will be required to detect any
contamination.
An additional protection is to provide at least 4 feet of separation
between the water table and the. bottom of the landfill. Thus, should
dewatering be necessary, groundwater would be lowered only 4 feet.
F-26
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References
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R-l
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Thurow, Charles, William Toner and Duncan Erly. 1975. Per-
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