United States
         Environmental Protection
         Agency
           Region 3
           Sixth and Walnut Streets
           Philadelphia, PA 19106
&EPA
Final Environmental
Impact Statement
August 1981
            Wastewater Treatment
            Facilities for the
            Town of Ashland and
            Hanover County, Virginia

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         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                REGION III
                         6TH AND WALNUT STREETS
                     PHILADELPHIA, PENNSYLVANIA 19106
                                                             AUG 2 0 1981
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:

Enclosed is a copy of the Final Environmental Impact Statement (EIS)
prepared by the U.S. Environmental Protection Agency (EPA) in conjunction
with wastewater treatment Facilities Plans for the Town of Ashland and the
"Phase I Extended" area of Hanover County, Virginia.  This Final EIS has
been prepared pursuant to the National Environmental Policy Act (NEPA) of
1969, the Clean Water Act of 1977, and the corresponding regulations
promulgated by EPA (40 CFR Part 6, November 6, 1979; 40 CFR Part 35,
September 27, 1978).

Please note that since a Draft EIS was issued in 1979 covering the Phase II
area of Hanover County (which included Ashland), separate wastewater Plans
have been prepared by Ashland and the County.  This Final EIS addresses both
Plans in accordance with NEPA requirements.  It may be necessary for Hanover
County or the City of Ashland to furnish additional information or for EPA
to perform supplemental NEPA analyses prior to future Federal funding.

I wish to thank the local jurisdictions and participating government
agencies for their assistance during this EIS process.  In addition, I
especially wish to recognize and commend the strong environmental knowledge,
interest, and efforts of the area's citizenry.  Their participation
throughout the EIS process has had a profound influence on development of
wastewater treatment solutions which are responsive to the needs of the area.

EPA will not take any administrative action pending a 30-day review period
following public issuance of this FEIS.  A public meeting on the Final EIS
will be held on September 22, 1981 at 8:00 p.m. in the Wickham Building,
Hanover, VA.  The general public and representatives of organizations are
invited to attend and express their opinions about the Final EIS.  Any
comments or inquiries concerning this EIS should be raised to the attention
of Mr. Thomas Slenkamp of this Regional EPA office by September 28, 1981.

Sincerely yours,
Alvin R.ptorris
Deputy Regional Administrator

Enclosure

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                FINAL
  ENVIRONMENTAL IMPACT STATEMENT
   WASTEWATER TREATMENT FACILITIES
       FOR THE TOWN OF ASHLAND
                 AND
      HANOVER COUNTY, VIRGINIA
            August 1981
             Prepared for
U. S. Environmental Protection Agency
              Region III
      Philadelphia, Pennsylvania
                  By
         Engineering-Science
         7903 Westpark Drive
        McLean, Virginia 22102

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                                                        PREFACE

Purpose of the            This Final Environmental Impact Statement (EIS) has been
Final Els'prepared by the U.S. Environmental Protection Agency  (EPA) in
                          conjunction with wastewater treatment "Facilities Plans" for the
                          Town of Ashland and Hanover County, Virginia.

                          The National Environmental Policy Act (NEPA) requires every
                          Federal government agency to prepare an EIS before taking any
                          major Federal action which could significantly affect the quality
                          of the human environment.  In this case, EPA initiated an EIS
                          because of concerns over the proposed Federal funding for a
                          wastewater treatment project, termed "8-1",  serving an area
                          designated as "Phase II" in Hanover County  (including Ashland).
                          A Draft EIS covering the Phase II area was issued by EPA in early
                          1979 and a public hearing held on April 4, 1979.  Since that
                          time, several events have occurred which have altered the basic
                          circumstances and, therefore, assumptions involved in preparation
                          of the Draft EIS.  These include 1) efforts made by the Town of
                          Ashland to complete a separate Facilities Plan from that of
                          Hanover County, and 2)  the County's revision of previous waste-
                          water planning goals and objectives which has resulted in a
                          reduced service area-"Phase I Extended" - for future sewerage
                          facilities (See Figure 1).

                          The net effect of these changes has been to render as infeasible
                          the previously recommended Phase II solution ("8-1") which had
                          prompted EPA to initiate an EIS.  While the separate Facilities
                          Plans for Ashland and the County (Phase I Extended) would not
                          necessarily require EIS's in and of themselves, EPA believes it
                          is appropriate to provide guidance in this Final EIS concerning
                          environmental considerations which should be used by both local
                          jurisdictions when implementing wastewater treatment solutions.
                          However, the Final EIS in this instance does not cover both
                          Facilities Plans to a level of detail which would be expected in
                          a single-Plan EIS, partly because many of the previous environ-
                          mental concerns have been alleviated through development of the
                          new Plans.

                          In issuing this Final EIS, EPA will discuss only in a general
                          manner the rationale for selection of a Phase II alternative
                          concept, and, within that context, the alternative plans now
                          being considered for implementation by the separate jurisdic-
                          tions.  Somewhat more discussion is provided about the Ashland
                          alternatives, since the Ashland Facilities Plan had progressed
                          further at the time this Final EIS was started.

                          Although EPA is satisfied that the separate Facilities Plans
                          represent substantial improvement and have incorporated many
                          environmental concerns raised by the Draft EIS, this does not
                          preclude EPA from requesting additional information concerning
                          NEPA compliance from local jurisdictions in support of future
                          requests for grant assistance.  EPA reserves the right to modify
                          conclusions and recommendations expressed herein, and could issue
                          supplemental NEPA analyses on either Plan depending upon final
                          solutions and methods of implementation selected by Ashland and
                          Hanover County.

                          Following the close of the comment period on the Final EIS
                          (thirty days after issuance), EPA will prepare a Record of
                          Decision which will describe the conclusions of the EIS process,
                          the decisions reached by EPA as to Federal funding of alterna-
                          tives, and the actions to be undertaken by the grant  applicants.

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References                This Final EIS addresses all substantive comments received on the
                          "Draft EIS - wastewater Treatment Facilities Planning for Hanover
                          County, Virginia:  Phase II Area" including the testimony
                          received at the public hearings on 4 April 1979 and 20 January
                          1981.

                          Rather than repeat the entire Draft EIS here in the Final EIS,
                          the Draft EIS has been included by reference as Appendix A and
                          appropriate changes and additions made in the Final EIS.  All
                          environmental setting information used to evaluate Phase II
                          alternatives and sub-alternatives in this Final EIS was presented
                          in the Draft EIS except where specially noted otherwise.
                          Furthermore, detailed Facilities Planning information is drawn
                          from existing Phase II, Phase I extended, and Ashland Facilities
                          Plans.  The reader is referred to the following sources to obtain
                          this information:

                             For information on the Environmental Setting and on Phase II
                             Facilities Planning:

                                  "Draft EIS   Wastewater Treatment Facilities Planning for
                                  Hanover County, Virginia:  Phase II Area"
                                  (Draft EIS)
                                  Engineering-Science and EPA, January 1979

                             For information on the Phase II Facilities Planning:

                                  "Hanover County Facilities Plan, Phase II, Volumes I and
                                  II  (The Plan, Appendix)"
                                  (1975 Facilities Plan)
                                  Bremner, Youngblood & King, Inc., November 1975

                                  "Preliminary Draft - Expanded Scope and Investigation of
                                  Additional Alternatives for Facilities Planning in
                                  Hanover County, Virginia"
                                  (1978 Facilities Plan)
                                  Bremner, Youngblood & King, Inc., August 1978

                             For information on the Ashland Facilities Planning:

                                  "Preliminary Draft:  Town of Ashland Facilities Plan"
                                  (Ashland Draft Facilities Plan)
                                  Town of Ashland, February 1980)

                             For information on "Phase I Extended" Facilities Planning:

                                  "Draft Addendum - Water Pollution Control Facilities Plan
                                  - Phase I Extended, Hanover County, Virginia", April
                                  1981, Patton, Harris, Rust, and Guy
                                             ii

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LIST OF ACRONYMS
AND ABBREVIATIONS
BOD       Biochemical Oxygen Demand
BYK       Bremner, Youngblood & King, Inc.
CBOD5     5-day Carbonaceous Biochemical Oxygen Demand
cfs       cubic feet per second
EIS       Environmental Impact Statement
EPA       United States Environmental Protection Agency
ERA       Economics Research Associates
gpcd      gallons per capita per day
gpd       gallons per day
1-95      Interstate-95
I/I       Infiltration and Inflow
mgd       million gallons per day
mg/1      milligrams per liter
MPN       Most Probable Number
NEPA      National Environmental Policy Act
O&M       Operation and Maintenance
PL        Public Law (of the United States)
RBC's     Rotating Biological Contactors
RPCCA     Rural Point Concerned Citizens Association
SAPU      Service Area Planning Unit
SWCB      Virginia State Water Control Board
TSS       Total Suspended Solids
30/30     30 mg/1 for BOD and 30 mg/1 for TSS
                                                           iii

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LIST OF PREPARERS       U.  S.  Environmental Protection Agency

                        Thomas Slenkamp,  Project Monitor
                        Rosemarie Baldino,  Production Advisor
                        Karen  Risoli,  Support Services

                        Engineering-Science

                        Palma  Strand,  Project Manager
                        Philip Morris, Technical Director
                        Gregory Gibbons,  Project Engineer
                        Donald Gordon, Graphics
                        Nancy  Sanderoff,  Support Services
                        Mary Starrs,  Support Services

                        Economic Research Associates

                        Louise Root,  Project Manager
                        Jeffrey Jobe,  Economist

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                                                                                    Page
TABLE OF CONTENTS            Preface                                                   i
                             List of Acronyms and Abbreviations                      iii
                             List of Preparers                                        iv
                             Table of Contents                                         v
                             List of Tables                                           vi
                             List of Figures                                          vi
                             Executive Summary                                       vii

                       I.    Background                                                1
                                 Introduction                                          1
                                 History of the Project                                1
                                 Recent Developments                                   2
                                 Reassessment of the Planning Area                     2
                                 Organization of this EIS                              2

                       II.   Public Participation                                      5
                                 Introduction                                          5
                                 Chronology                                            5
                                 Public Hearings                                       6
                                 Written Comments                                      8
                                 EPA Responses to Issue-Oriented Public Comments       9
                                 Additional and Corrected Data                        13

                       III.  Phase II Alternatives                                    17
                                 Alternatives Recommended in 1978 Facilities Plan     18
                                 Alternatives Recommended in the Draft EIS            18
                                 Alternatives Evaluated in 1980 Ashland               19
                                   Facilities Plan
                                 Phase II Alternatives
                                 Environmental Impacts of Phase II Alternatives       22
                                 Summary of Environmental Impacts                     26
                                 Most Feasible Phase II Alternative                   26

                       IV.   Ashland Alternatives                                     27
                                 Separation of Ashland                                27
                                 Definition of Service Area                           27
                                 Population Projections                               27
                                 Wastewater Flow Projections                          29
                                 Existing Water Quality Problems                      30
                                 Ashland Alternatives                                 31
                                 Most Feasible Phase II Alternative                   40

                       V.    Recommended Ashland Alternative                          43
                                 Description                                          43
                                 Environmental Impacts and Mitigation Measures        46

                       VI.   Phase I Extended Alternatives                            51
                                 Revised Planning Area                                51
                                 Evaluation of Phase I Extended Alternatives          54
                                 Oak Hill Estates Alternatives                        77

                       Final EIS Mailing List                                         81

                       Appendix A - Draft EIS  (by Reference)

                       Appendix B - Public Comment Letters

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LIST OF FIGURES
LIST OF TABLES
1
2
3
4
5
6
7
8
9
10
11

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Original and Revised Service Areas
Flood Hazard Areas
Ashland Service Area
Flow Chart of Recommended Ashland Alternative
Site Plan:  Ashland Alternative
Phase I Extended Study Area
Existing Discharge Points
Base Sewer Network:  Upper Section
Hanover AWT Plant:  Alternative 2
Henrico Interconnecti Alternative 4
Oak Hill Estates - Recommended Alternative

Phase II Alternatives - Cost Comparison
Phase II Alternatives - Environmental Impact Comparison
Ashland Service Area Population Projections
Ashland Alternatives - Cost Comparison
Ashland Alternatives - Environmental Impact Comparison
Existing Facilities   Phase I Extended Area
Population Projections - Phase I Extended
                            Estimated Costs:
                            Effluent Limits
                            Estimated Costs:
                            Estimated Costs:
                            Estimated Costs:
                            Phase I Extended
                            Phase I Extended
                  Alternative 1

                  Alternative 2
                  Alternative 3
                  Alternative 4
                 - Environmental Impacts
                 - Cost Comparison
                            Oak Hill Estates - Cost Comparison
21
25
29
40
41
53
54
59
63
65
67
71
76
77
81
                                              VI

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Draft EIS
Public Input
Alternatives
Considered
                         EXECUTIVE  SUMMARY

This Final Environmental Impact Statement  (FEIS)  has  been prepared
by  the   U.S.   Environmental  Protection  Agency.    It  generally
addresses wastewater  treatment Facilities  Plans  prepared  for  the
Town of  Ashland and the Phase I  Extended  area of  Hanover  County,
VA.

A Draft  EIS  was previously prepared covering the Phase  II  area of
Hanover  County, including  the Town  of  Ashland.  The Draft  EIS
analyzed wastewater treatment  alternatives  developed  through Phase
II Facilities Plans,  and presented several others  in  addition  for
public   consideration.   The  Draft  EIS  also   outlined   several
preliminary  recommendations, chief  among them that the originally
recommended  Phase  II   areawide   solution  was   associated  with
numerous  adverse  impacts   which  cast  significant  doubt  on  its
feasibility.  Other alternatives were suggested for more favorable
consideration,   including   some   involving   a   separate   Ashland
treatment facility.

Partly based on  the Draft  EIS  recommendations, the  Town of  Ashland
and Hanover  County  subsequently  took  steps  to  prepare  separate
Facilities  Plans,   the  County's  being  for  a reduced  study  area
designated as  "Phase  I  Extended".  Although  Ashland's independent
Plan was completed  considerably  sooner  then  the  County's,  several
questions   remained  preventing   its   immediate   implementation,
including  those  concerning   the   interrelationship   of  the  two
Plans.   The  County recently  completed a  Draft Facilities Plan  for
Phase  I  Extended,   enabling  EPA  to  complete   this  Final  EIS
generally covering both jurisdictions'  Plans.

EPA received many  written comments on  the  Draft  EIS  during  and
after  a  formal  public  comment period  from  February  15,  1979  to
April  15,  1979.   In  addition, oral  testimony was received at  a
public hearing  conducted by  EPA on  April 4,  1979.   These and other
public   comments  were   instrumental   in   the   local  government
decisions to  prepare  separate  Ashland  and County  Facilities Plans
and  in  forcing  consideration  of  issues  of  concern  to  local
residents,  such as   the  environmental   value of  County  streams,
including Totopotomoy Creek and Chickahominy  River,   the need  for
balancing water  supply  and wastewater  treatment  needs,  the effect
growth will  have on  the County's  predominantly rural  way  of life,
and the  ability of  local residents to  pay  for  improved wastewater
treatment facilities.

During  and  after  the  separate  Facilities  Plans  were  prepared,
additional public  workshops, meetings,  and  hearings   were  held to
solicit  further  public  opinion.  A  public  hearing  was  conducted by
EPA on  January   20, 1981  in conjunction with  Ashland's Facilities
Plan.   The  County  held  a  public  hearing on  the  Phase  I  Extended
Plan  on  June  3, 1981.   EPA will  hold  a  public  meeting  on this
Final EIS approximately 30 days after public issuance.

The Final EIS addresses the alternatives developed through the
separate Town and County Plans.   Ashland's  Plan compared six basic
alternatives  for improving  the existing lagoon  system, including
two  land treatment  alternatives.   The  County  Plan  for  Phase  I
Extended  evaluated   four   primary   alternatives,   including  land
treatment and an alternative of improving  existing systems without
public sewering.   The level of detail  presented  in the Final  EIS
is  generally  less   than  in  the   Draft  EIS  since   the  separate
Facilities Plans have  alleviated  many  of  the  concerns  raised by
the Draft EIS.

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Final EIS
Recommended
Alternative
Recommendations and
Conclusions
EPA concurs with the recommended alternatives in the two Draft
Facilities Plans, which call  for  Ashland to upgrade  (by aeration)
and expand its existing facility  to  1.2  mgd, and  for  the County to
pursue  a  sewerage  interconnection  to  adjacent  Henrico  County's
treatment system.   EPA also  strongly recommends  that  the  County
consider phased  implementation  of the proposed sewer  network and
that  they  apply stringent  land use  controls  in conjunction  with
the wastewater  treatment  project.  Oak  Hill Estates  is recommnded
to be connected into the Ashland system  for treatment.

The following recommendations and conclusions are presented based
upon  information developed  and  analyzed  during  Facilities Planning
for Phase  II,  Ashland, and Phase I  Extended,  and  throughout the
EIS process.  Local jurisdictions  and  the  public  are  urged to take
these into  account  in determining a  final course  of  action.   EPA
will  prepare a  concise Record  of  Decision following  the  close of
the comment  period on this  Final EIS,  which  will  summarize the
findings of  the  EIS process  and  set forth  any  measures necessary
to make the recommended actions environmentally acceptable.

1.  The most cost-effective  alternative for the  entire  Phase II
area    is    Alternative    A-I:     Separation   of    Ashland   and
Interconnection  of  the  Industrial  Corridor  and  the  remaining
County  service area to Henrico  County.   This alternative minimizes
adverse environmental  impacts on the Totopotomoy Basin and allows
the Town of  Ashland to move immediately to  upgrade their facility
in order to  end  the moratorium on hookups imposed  by the Virginia
State Water Control Board.

2.    The  County,   the  Town,  the   SWCB,  and  EPA  have   taken
preliminary, although not irreversible,  steps to  implement the A-I
Alternative in concept.  These steps include:

   Approval by all parties of a separate Ashland facility;

   Preparation of a Draft Facilities Plan by the Town of Ashland;

   Reservation  by  the County of  3.7  mgd of treatment capacity in
the Henrico County  facility;

   Completion of a  Draft  Facilities Plan  for the Phase I Extended
area  by the County; and

   Separation of the  Phase  II EPA grant  funds  for Step  II  (design)
and Step III  (construction)  into  Ashland funds  and  County funds on
the State construction grant priority list.

3.  The Town  of Ashland's most feasible treatment  alternative for
upgrading  and  expanding   its  system   consists  of   aerating the
existing lagoon.   This option,  Alternative 1 in  the  Ashland  Draft
Facilities   Plan,    is   the   most   cost-effective    and    least
environmentally  impacting  alternative  for  the  Town.   It  has   a
construction cost estimated at $1,212,200.

4.  Growth  patterns in the  County since  issuance  of the original
Phase  II   Facilities   Plans    have   not   served    to    justify
implementation  of  a  maximum-growth  treatment  alternative.  In
response  to these  patterns,  and  to outspoken  recommendations by
the public,  the  County has minimized the  area  to receive  improved
wastewater   treatment  service.    The resulting  area,   "Phase   I
Extended",  is  significantly  smaller  than the  original  Phase II
Service Area.    The County's   Phase  I  Extended Draft Facilities
Plan  calls  for interconnection  to  Henrico  County as the most feasible
alternative, based  on most  recent  available cost estimates  and an
assumption that the planned Henrico system will be  fully implemented.
EPA endorses this recommended action  as  an acceptable  long-term
wastewater management  solution  for the needs of the Phase  I  Extended
area.   If has an estimated  construction  cost of $2,729,400.
                                              Vlll

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5.  Because of initially high projected growth  rates  for  the Phase
I  Extended area  and  financial  uncertainties   related  to  future
Federal  funding  and  costs  for  treatment  in  adjacent  Henrico
County, Hanover County  should  strongly consider  implementation  of
its recommended action  in  phases,  as .future development  occurs  in
a manner  sufficient to justify  construction  of  additional  system
components.   This  is  especially   relevant  to  construction  of
interceptor sewers.

6.  To ensure that  the  recommended  action  will  assist in  directinq
future  growth  into the  "urban"  service   areas outlined  in  the.
Facilities  Plan,  the   County  must  complement  the  project,  with
stringent application of land  use controls and  policies  which are
in  concert with  the  same  goal.   This  will  help  to  avoid  the
in-fill problems experienced with the Phase I  system.

7.   As an  additional  wastewater  project-related  growth  control,
the  County should  consider  construction  of   a forcemain  vs.   a
gravity sewer where  cost competitive.

8.   Continued use  of  on-site  systems,   including  upgrades  where
necessary   to  rectify  existing   problems,    and   provision   of
decentralized  off-site  systems  (cluster   systems)  are  acceptable
solutions  for  areas which may  not  warrant initial sewer  service.
EPA's  Contruction Grants Program provides  for  85%  Federal  funding
of these systems where certain conditions  are  met.

9.  Sewer  service should be restricted from the Totopotomoy River
Basin  (with the possible exception  of  three existing  subdivisions)
in the near term because of  unquantifiable  but  potentially  adverse
environmental  impacts.  Before  service can be  considered,   a  more
comprehensive  field survey should be  performed to more  precisely
define  the   sensitivity   of   the   Basin   and   its   value   as  an
environmental  resource.   EPA  will  arrange with   the  appropriate
government agencies  for this to be performed.

10.  EPA recommends that the Oak Hill  Estates pollution  problem  be
addressed   via   interconnection  with  the  Town   of   Ashland's
wastewater  treatment   system.   The   Town  should   modify   its
Facilities Plan to  incorporate this change.

To implement  solutions  to  the area's  wastewater management  needs,
it  is  recommended  that the  Town  of  Ashland  and  Hanover  County
finalize  Facilities Planning  efforts  consistent  with  the  above
recommendations and submit  formally  adopted  Plans  to  the  State
Water  Control Board along  with  Step II grant applications  as  soon
as possible.

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                                             SECTION I: BACKGROUND
INTRODUCTION
HISTORY OF THE
PROJECT
     Under the Clean Water Act of 1977, the U.S.  Environmental
Protection Agency  (EPA)   is  authorized  to administer  several
programs for  controlling  water  pollution.   Under  the  Section
201 program  "Grants  for  Construction  of  Treatment  Works", EPA
may provide  up to  75  percent  of  the  costs  for  the  planning
(Step 1),  design  (Step 2),  and  construction  (Step  3)  of con-
ventional publicly-owned  treatment  works  and up  to 85 percent
of the costs of "innovative or alternative" facilities.

     In addition, the  National  Environmental  Policy Act  (NEPA)
requires each Federal agency to prepare an Environmental Impact
Statement  (EIS) on  any of its actions  which  may  significantly
affect the quality  of the human environment.  EPA  funding  of
large construction projects  is,  in  some cases,  considered such
an action.  The EIS  process  is  designed to facilitate  informed
and responsible decision-making by all levels of government and
by the  public.   The  EIS  process  is  specifically  designed  to
ensure that environmental  as well  as  economic factors  are con-
sidered in decision-making and  that  the  environmental  conse-
quences of the options examined are disclosed.  The EIS process
also encourages public input into the decisions made.

     First a Draft  EIS is prepared and circulated  to  all con-
cerned parties.  Then  comments  are accepted  in writing  and  at
a mandatory  public  hearing.   Lastly  a Final EIS  is  prepared
which responds to comments on the  Draft EIS  and which presents
and evaluates  any  changes in the  proposed project  which have
occurred since the issuance of the Draft EIS.

     During the early and mid-1970's,  Hanover County, Virginia,
received Federal assistance from EPA for its plan to improve
the wastewater treatment  in  the  Mechanicsville  area (Phase I).
This plan  was  carried  to  fruition  and  facilities  are now being
constructed.   Additional parts  of  the  county north  and  north-
west of Mechanicsville  (designated  as the Phase  II  area) were
determined to  be  in need  of improved  wastewater  treatment  as
well, but  the  problems  in this area  were not  as  severe  and
were thus  postponed  until  after  Phase  I planning  was complete.

     In 1975, Hanover County applied to EPA  for a Step I grant
for Facilities Planning  in the  Phase  II  area.   The grant was
awarded, and a Facilities Plan was completed late  in 1975.  The
Plan presented a regional treatment scheme that would cover all
of the area identified as Phase II, but could not gain state or
local approval.  The Plan was not accepted because insufficient
information about the proposed project was presented, and inad-
equate investigation had  been done  of  additional  alternatives.

     To correct these  deficiencies, the County  requested addi-
tional Step  I  funds  to   study  other  treatment options.   EPA
granted these  funds  and  initiated  an  EIS on  the  Phase  II area
planning because of  the  significant controversy over the proj-
ect. The EIS was to be prepared concurrently  ("piggyback") with
the expanded  Facilities  Plan to expedite  the Step  I  process.

     A preliminary draft  Facilities Plan  was  completed in 1978
and a Draft  EIS  was  issued  in  1979.    Alternatives  beyond the
original options in  the  1975 Plan  were developed  in  the 1978
Plan and  additional  alternatives  were presented   in  the Draft
EIS. These alternatives included sub-regional treatment schemes
schemes and  limited  growth  options;  several options  provided

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RECENT DEVELOPMENTS
REASSESSMENT OF THE
PLANNING AREA
ORGANIZATION OF
THIS EIS
for a  separate  facility  for  the  Town  of Ashland.   A  public
hearing was held on the Draft EIS in April 1979.

     In April  1979,   the  Virginia  State  Water  Control  Board
(SWCB) issued  a  consent  order  to  the  Town  of  Ashland  which
stated that, because  it  was consistently  operating its  waste-
water treatment  system  above design capacity,  a moratorium  on
new sewer  connections  would  be  in   effect  until  a  plan  to
relieve this  condition  was  approved.   That  same month  the
Ashland Town Council  adopted  a resolution requesting that  EPA,
the SWCB,  and  the Hanover  County  Board  of  Supervisors  allow
the town  to proceed  with  development  of  its  own Facilities
Plan, separate  from  the  County's  Phase II efforts.   The  Town
indicated that  it  felt  that this  approach would  enable it  to
solve its  wastewater problem  most expeditiously.   Later  in
1979, the County, the SWCB,  and EPA approved Ashland's  request
to initiate planning  to  assess  overall Phase  II  alternatives
with respect to  the feasibility of  Ashland separating from the
County and  to  evaluate  options for  the  Town's  upgrading  and
expanding its existing treatment facility.

     In February 1980, the Town of Ashland completed a Sewer
System Evaluation  Survey  and  issued  a Draft  Facilities  Plan
which assessed the major  Phase II  alternatives and additional
wastewater treatment  alternatives  for  the Town only.    At  that
time, the  County expressed  its  intention  to  continue planning
efforts for the  remainder of the Phase  II service area.   How-
ever, as  the  County's planning has progressed, the portion  of
the Phase  II area  to  be  serviced has  diminished to the  extent
that it now includes only an area northwest of  the  Phase I  area
that extends  along the   1-95  Industrial  Corridor  only  about
halfway to  Ashland.   This  area has been  termed  "Phase I  Ex-
tended".  In January  1981,  EPA and the  Town  jointly sponsored
a public  hearing  to  receive  comments  on  the  Ashland  Draft
Facilities Plan and to present updates on  the County's planning
and on the status of the  EIS.

     Due to the changes  in the Facilities  Planning process
described above, the planning area covered by the  Facilities
Plans has  been altered  and  now consists of  an  Ashland  Service
area and  a Phase  I   Extended   area  (which  includes Oak  Hill
Estates).  The  original  Phase  II  study  area  and  the   revised
Facilities Planning  areas  are  shown  in  Figure  1.   Although
plans for  treating  wastewater  from the  entire Phase  II  area
as originally  designated  have  been   abandoned,   this   present
report continues to  assess  the  effects of the revised  alter-
natives on the  entire area.   These revised  study areas  simply
comprise a "limited-build"  alternative as  defined in the Draft
EIS.

     However, the  division  of  the  Phase  II  planning  area  be-
tween two planning authorities,  and the diminution of the  area
to be serviced,  render  inapplicable the Service Area Planning
Unit (SAPU) concept  that  was used  in  the  1978  Facilities  Plan
and in the Draft EIS.   The  seven SAPU's which were identified
and discussed  in  those  documents  are  therefore  not  used  in
this Final  EIS.    Instead,  the  Ashland Service  Area  and  the
Phase I  Extended  Service Areas are  the  sub-areas discussed.

     This Final EIS addresses comments  received on  the Draft
EIS and presents information on the selected  alternatives and
on sub-alternatives which have been developed  in detail  since

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the Draft EIS was prepared.  The  Final  EIS concentrates on the
Ashland Alternatives presented  in  the  Town's 1980 Draft Facil-
ities Plan.

     Section II of this  report  summarizes comments received by
EPA on  the  Draft EIS  and  responds to those  comments in light
of recent developments.  Section  III  briefly presents and dis-
cusses the main alternatives recommended  in the 1978  Facilities
Plan and  in  the Draft  EIS and  the  alternative  now  selected.
Section IV develops  the  Ashland portion  of the selected alter-
native in  terms  of  the  sub-alternatives  presented  in the 1980
Ashland Draft Facilities Plan.   Section  V describes  in detail
the selected  Ashland  sub-alternative  and  the  environmental
impacts of and  mitigative  measures for  that  alternative.  Sec-
tion VI  discusses   recent  County  progress  in  its   Facilities
Planning for  the Phase  I  Extended  Area  including  Oak  Hill
Estates.  Section  VII  summarizes  the   previous  Sections  and
makes recommendations to the local planning authorities.

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SPOTSYLVANIA
    COUNTY
                                                                                                     FIGURE 1
                                                                                       ORIGINAL AND REVISED SERVICE AREAS
                                                                                                      Phase I
                                                                                                      Phase II
                                                                                                      Phase I Extended
                                                                                                      Ashland
    GOOCHLAND COUNTY

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                                       SECTION II:  PUBLIC PARTICIPATION
INTRODUCTION
CHRONOLOGY
     Public involvement of the citizens of Hanover County and
the Town of Ashland  in the Phase II planning  process  has been
extensive.   The public has had a profound  influence  on many of
the major decisions:   the decision to develop alternatives in
addition to the originally-recommended 8-1 option; the decision
to prepare an  EIS  on  the Phase II Facilities Planning; the deci-
sion for Ashland  to  pursue  Facilities  Planning  individually;
and the  selection  of issues addressed in  the  Draft  EIS  and in
this Final EIS.   Public participation has taken the form of
testimony at  public  hearings; attendance  at  public meetings;
letters to the  various local,  state, and  Federal governmental
entities involved in the planning;  and preparation of citizens'
reports  (e.g.   "A  Closer   Look   at  Hanover  County's  Proposed
Facilities Plan, Phase 2"  by the Rural Point Concerned Citizens
Association, and  "A  Comparative Analysis  of  Sewerage  Program
Alternatives for  Hanover   County,  Virginia"  prepared  for  the
Public Facilities  and  Solid Waste Subcommittee  of  the Hanover
County Citizens Advisory  Committee by  Patton,  Harris,  Rust and
Guy).  In this  Section,  public  participation  relating  specif-
ically to the  Draft  EIS  and  this  Final  EIS is  identified and
discussed.

     As part of the extended Phase II Facilities Planning
process, a series  of public informational  meetings  and  public
hearings have  been  held   in Hanover  County over  the  past five
years.  Several of these meetings were held before the decision
was made to prepare  an Environmental  Impact  Statement  on the
Phase II project.  Indeed, public comments  received  at  some of
the earlier meetings  contributed to that  decision.   Since the
initiation of  the  EIS process,  two  public hearings have been
held to  officially  receive public comments  on the  EIS  and on
the status of  Phase  II Facilities  Planning in the County.  The
first public  hearing  was  held after distribution  of the Draft
EIS and  the second was held  after  publication of  the  Ashland
Draft Facilities  Plan, just  prior  to  issuance  of  this  Final
EIS.  Written comment  periods accompanied  each public hearing.
All public informational and comment meetings and hearings held
prior to  issuance  of  the Draft  EIS  are  included   with  other
major events  in the  Phase II  Facilities Plan/EIS process chro-
nology in the  Draft EIS (pp. 1-4 through 1-7).   Public meetings
and other events since the issuance of the Draft EIS are listed
below:
                          DATE
                                                          EVENT
                        February 1979  Distribution of Draft EIS.

                        March 1979     Public hearing held on Draft EIS.

                        April 1979     SWCB issued consent order to Town of Ashland
                                       stating that  it  was  operating  its  wastewater
                                       treatment system  above  capacity and that a mor-
                                       atorium on  new  sewer  connections  would  be   in
                                       effect until  a plan  to relieve  this  condition
                                       was approved.

                        April 1979     Ashland Town Council adopted resolution request-
                                       ing EPA, SWCB and County Board  of Supervisors  to
                                       allow the town to proceed with  its own facilities
                                       plan separately from the County.

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                            DATE
                                                    EVENT
                        May 1979




                        October 1979



                        January 1980


                        February  1980


                        March 1980



                        August 1980


                        January 1981
                Hanover County Board of Supervisors  adopted
                resolution approving Town of Ashland pursuing
                construction of its own wastewater treatment
                facility.

                Formal approval by SWCB and EPA  of Ashland's
                planning to upgrade and expand its own  waste-
                water treatment facility.

                Town of Ashland prepared a revised SSES for the
                Town only.

                Town of Ashland prepared a Draft Facilities Plan
                which included alternatives for  the  town only.

                SWCB revised FY '80 priority list.   The list
                included separate sums for Hanover County and
                the Town of Ashland.

                EIS contract modification approved by EPA to
                accommodate facilities planning.

                Public hearing held on Ashland Draft Facilities
                Plan and on updates to Hanover County facilities
                planning process.
PUBLIC HEARINGS
Draft Eis Public
Hearing
     To comply with EPA's regulations for public participation
in EIS preparation, a public hearing was held on 4 April  1979
at the Hanover County Courthouse at Hanover, Virginia. Seventy-
seven  people signed the  attendance  list, and 28 people gave
testimony.   A transcript of the hearing is available from EPA,
Region III.  The following persons spoke at the public hearing:

o  Steven A. Torok - Chief, EIS Preparation Section, U.S. Envi-
   ronmental Agency, Region III

o  Pettis Miller - Vice-Mayor of the Town of Ashland

o  Tom Slenkamp - Project Monitor for Hanover County Phase II
   EIS, U.S. EPA, Region III

o  James Bruce - Hanover County Public Utility Director

o  Robert Bremner - Bremner, Youngblood & King, Inc.

o  Tim Rohrmoser - Bremner, Youngblood & King, Inc.

o  T. A. Clark

o  Anne Smith - Rural Point Concerned Citizens Association

o  Donald Wiber - Rural Point Concerned Citizens Association

o  Tom Evans - Virginia B.A.S.S. State Federation, Inc.

o  Robert Phillips - Hanover County Citizens Federation

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Public Hearing on
Ashland Facilities
Plan
o  Gail  Enroughty  - President, Rural  Point  Concerned Citizens
   Association

o  Nina K. Peace - Member of the Hanover County Board of Super-
   visors from the Ashland District

o  Lou L. Hanks - South Anna Citizens' Council

o  E.C.C  Woods,  Jr. -  Member  of  the  Hanover County  Board of
   Supervisors from the Henry District

o  Margaret R. Miller - Citizens for Sensible Growth

o  Virginia Shaw English

o  Bruce V. English

o  Donald McDonald

o  John S. Graham - Hanover Properties, Inc.

o  Lois Wickham - Curator, Hanover Historical Society

o  Ron Jones

o  George Nester - Town Manager, Town of Ashland

o  John B. Steadman - Wiley & Wilson

o  Preston Wade - Wiley & Wilson

o  Bob Wilby - President Hickory Hill Farms

o  Bob Ostergren

     The majority  of  comments  at  the  hearing  dealt  with  the
question of  whether or  not a  regional  treatment  system  for
the Phase  II  area  was  justified.  A good  number  of  people
stated their support for dividing  the service area and allowing
Ashland to solve its treatment  problems individually.  Several
persons also  cited  lack  of  public support  in  the  County  and
inability or  unwillingness to  finance a  regional  project as
reasons for  abandoning  the  regional  treatment  concept.   The
growth-inducing effects of a regional facility were criticized;
several people stated  their desire to preserve  the rural qual-
ity of life  in the County.   The   justification of  the project
by failing septic systems  was  also questioned.   Several people
mentioned the  need  to  preserve the quality  of  the Totopotomoy
basin and  the  Pamunkey  River.    Some people  suggested   land
application of treated effluent as one way  to  attain this  ob-
jective.   One  industry  representative spoke  in  support  of the
facilities planned to  serve the  Industrial Corridor.  Finally,
a few people criticized the lack of public participation in the
planning process and the unavailability of the Facilities Plan.

     EPA responses  to  the issues  raised  appear  later in  this
Section.

     In response to the division of the Phase II study area for
Facilities Planning purposes, and  to elicit public reaction to
the split and to updated Facilities Planning efforts by the Town

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                        of  Ashland  and the County, EPA and  the  Town  of Ashland jointly
                        sponsored another  public  hearing  prior  to   issuance  of  this
                        Final  EIS.   The hearing  was  held  on  20 January  1981  at  the
                        Town of  Ashland Municipal Building.   The attendance  list  was
                        signed by  35 persons and  nine  of those  presented testimony.   A
                        transcript  of  the  hearing is  available  from EPA  Region  III.
                        The following  persons  spoke  at the public hearing:

                        o   Tom Slenkamp - Project Monitor for Hanover  County  Phase  II
                           EIS,  U.S.  Environmental Protection Agency, Region III

                        o   Douglas   C.   Cullinane  -  Town  Engineer,  Town  of  Ashland

                        o   John  Hodges  -  Planner,   Planning  Office,  Hanover  County

                        o   T.A.  Clark

                        o   Bruce V.  English

                        o   Gail  Enroughty  - President,  Rural Point  Concerned  Citizens
                           Association

                        o   Margaret Miller

                        o   Virginia Shaw English

                        o   Nina  K.  Peace - Member  of  the  Hanover County Board of Super-
                           visors  from the Ashland District

                            The  issues addressed most extensively at this meeting dealt
                        with the connection of Oak Hill Estates to the Town's treatment
                        system and  the effects of the  current drought  on the  planning
                        effort.   Several Ashland  residents  expressed  the  opinion  that
                        wastewater  management  in Oak  Hill Estates was not a problem that
                        the town should  be expected to assume (as proposed by Mr. Hodges
                        at the meeting).  Several  citizens also expressed their concern
                        that the present drought  situation may be relieving some of the
                        previously  acute problems  with Ashland's  lagoon and that plan-
                        ning for water  supply  and wastewater management  in the  County
                        should be  undertaken to avoid  shortages  during dry periods.   A
                        couple of  people  supported  the  proposed  Ashland project  as  a
                        necessary  cost-effective   solution to a  critical  problem,  but
                        one person  reiterated  his previous  support  for a land  applica-
                        tion solution.  One citizen  expressed  specific concern for the
                        protection  of  the  Upper Totopotomoy basin and  criticized lack
                        of public  participation,  also suggesting  that an  Addendum  to
                        the Draft  EIS be prepared in order  to  address the newly-devel-
                        oped alternatives   presented  in  the  Ashland  Draft  Facilities
                        Plan and the  County's  plans  regarding the  Phase  I  Extended
                        Service  Area.

                             EPA responses to  the  issues  raised at  this  hearing  also
                        appear later in this Section.

WRITTEN COMMENTS             In  addition to testimony given at the two public hearings,
                        one individual and several government  agencies submitted writ-
                        ten comments  to EPA  regarding  the Draft  EIS.   All  comments
                        received are reprinted in  Appendix B of this document.   Written
                        comments were  received from  the following persons:

                        o   Donald  Macdonald -  Hanover Citizens Federation

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                           Walter  P.  Pierson -  Regional Director,   Federal Insurance
                           Administration,  U.  S.   Department  of  Housing
                           Development
                                                     and   Urban
EPA RESPONSES TO
ISSUE-ORIENTED
PUBLIC COMMENTS
Separation of Ashland
o  William  Patterson  - Regional  Environmental  Officer, North-
   east Region, U.S. Department of the Interior

o  D. N.  Grimwood  -  State Conservationist (1979), Soil Conser-
   vation Service, U.S. Department of Agriculture

o  H.  McDonald Rimple,  M.D.  - Regional  Health Administrator,
   U.S. Department of Health, Education, and Welfare

o  Paul F.  Chamberlain  -  Division Administrator, Federal High-
   way Administration, U.S. Department of Transportation

o  J.D. Ruehrmund  -  Director,   Division  of Operations and Pro-
   cedures, Virginia State Air Pollution Control Board

o  R.  L.  Hundley  -  Environmental Quality  Engineer,   Virginia
   Department of Highways and Transportation

o  Leon  E.  App  - Virginia  Department  of  Conservation  and
   Economic Development

o  Berkwood M.  Farmer  - Virginia  Department of Agriculture and
   Consumer Services

o  Raymond  E.  Bowles,  P.E.  - Director, Bureau  of Surveillance
   and Field Studies, Virginia State Water Control Board

o  Ron R.  Blackmore -  Director, Virginia  Commission  of Outdoor
   Recreation

o  J.B.  Jackson,  Jr.  -  Virginia Council  on  the  Environment

o  Manly S. Wilder - State Conservationist  (1981), Soil Conser-
   vation Service, U.S. Department of Agriculture

    One commenter expressed support for a limited-growth option
(upgrading  the Ashland lagoon with land application of effluent
if feasible)  and  questioned  the  need  for a  growth-inducing
regional system for the Phase II area.

     The other  comments  comprised  factual correction of state-
ments in  the   Draft  EIS.   These  corrections  appear  later   in
this Section  II  are incorporated  into  later Sections  of this
Final EIS.

Issue:  Since the  initiation of Phase II Facilities Planning,
some citizens have opposed implementation of a regional solu-
tion and supported separation of the Phase  II area with accel-
eration of Ashland planning and deceleration of the planning
for the  "lower priority" parts  of the  study area.   With the
issuance of the consent order  to  Ashland  by the SWCB, the need
for Ashland to  separate  and  begin individual planning has been
more widely and vehemently expressed.

Response: In  response  to  the  critical nature  of the  Town   of
Ashland's current  wastewater treatment  problem and to the sig-
nificant support given  the division  of  the service area by the
public, the Town,  the  County,  and  the SWCB,  EPA has approved

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                        the separation of  Ashland  from the  remainder of  the  Phase II
                        study area.   Subsequent  to  this  approval, the Town  of Ashland
                        has pursued   individual  alternatives  to  correct  its situation
                        via its Draft Facilities Plan.

Growth in the           Issue:   Throughout the planning process, many citizens have
Phase II Area           questioned the need for a regional solution for the Phase II
                        area.  The  proposed   regional  solutions  have  been  viewed  as
                        growth-inducing,  and  the desirability  of  a  ''maximum-growth"
                        alternative  for the study  area has  been  questioned.  Citizens
                        have proposed  that  improved  wastewater  treatment be  provided
                        in certain priority areas  (e.g.  Ashland)  and that other, cur-
                        rently sparsely developed or  undeveloped  areas  in Phase  II be
                        left alone.

                              The concern regarding excess and unwanted  growth in the
                        County is manifested  in  corollary concerns as  well.  Interest
                        in controlling growth  in the County also appears as  interest in
                        preserving the rural quality  of  life in the  County,  preserving
                        prime agricultural land, land  use planning, and preserving his-
                        torical and  archaeological resources.

                              In the Draft EIS, several limited-growth alternatives for
                        the Phase II  area were developed  and evaluated  in  conjunction
                        with the regional  proposals.   A preliminary  conclusion in the
                        Draft EIS stated  that  the  sub-regional  alternatives  appeared
                        less environmentally  damaging  than   several  of   the  regional
                        options.

                        Response:  By approving the separation of  Ashland  from the rest
                        of the Phase II area,  EPA has  encouraged the speedy solution of
                        the major existing  wastewater treatment  problem  in the  study
                        area.  In addition, the planning for the remainder of the Phase
                        II area has  been  scaled  down  to the Phase I  Extended  area now
                        delineated by the County (Figure 1).   The  Phase I  Extended area
                        encompasses  the 1-95 Industrial Corridor from Mechanicsville to
                        Ashland and  several existing subdivisions  along the way.

                              This focussed planning on the part of the County reflects
                        a new, proposed growth-management  policy  which  has been devel-
                        oped by the  County Planning Department.   This policy,  "General
                        Policies Plan  -  An Element of  the  Comprehensive  Plan Update,
                        March 1981", emphasizes  differentiation  of existing rural and
                        urban areas. The  policy, when  adopted, will establish a general
                        planning approach  for  the  County:   the  County  should channel
                        future growth and development  into existing urban  areas such as
                        Phase I  and  Phase I  Extended,  as defined  by water and  sewer
                        service, and away  from rural  areas.   The plan  is designed to
                        accommodate  the  inevitable  growth for  the County while mini-
                        mizing adverse effects on the  natural  resources of the County.

                              Implementation of the proposed  growth  management policy,
                        as represented by  the  revised  Facilities  Planning, will maxim-
                        ize preservation   of  the  rural  character  of  the  County  and
                        minimize the  losses  of  prime   agricultural  and  forest  land
                        which would   have  occurred  if  the original  Phase II  area had
                        been developed.  Overall adverse  environmental  impacts related
                        to growth will be minimized by improvement of  the Ashland and
                        Phase I Extended  areas as currently planned.


                                                   10

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Preservation of the
Totopotomoy Basin
Effluent
Limitations
Issue;  Several citizens have opposed any treatment plant
construction, wastewater  discharge,  additional  residential  develop-
ment,  or  sewering  in  the  Totopotomoy  Creek  Basin.   They  have
maintained  that  the  Creek  is  an  area  of  diverse  and  sensitive
ecology and that  disturbances of  the natural  balance  by actions such
as those  listed  above  would irreversibly damage  the  Creek's natural
character.

Response:   The  County's  presently  recommended  Plan  for  Phase  1
Extended  does not  call  for  a  treatment  plant  in  the  Totopotomoy
Basin  nor  a discharge  to  the  Creek  (either  upper  or  lower reach) ,
although  an  alternative was evaluated  which  would discharge  to the
upper  Creek  above Route 301.  Additionally,  although  three  existing
subdivisions  located  within the  Totopotomoy  Basin  are  proposed for
initial service,  the  curtailment of  the Phase  II  area significantly
reduced  the  amount of  land  in  the  Basin  which  is  planned  for
service.   The County  has  formally  recognized  the  concern  for  the
Totopotomoy Basin by  eliminating it from  initial  service  considera-
tion  (except  for  the above  three  subdivisions)  and by  adopting goals
and objectives for  land  use  and  wastewater  facilities  planning which
restrain provision  of near  term  service  to  the  Totopotomoy Watershed
population  prior   to  fill-in  of  other  priority  "urban"   service
areas.   Thus, the  potential impacts  associated with the  "maximum
build"  alternatives developed  in  the  Phase  II  Facilities  Plan  and
evaluated in the  Draft EIS have been substantially reduced.

Regarding the sensitivity of the  Upper  Totopotomoy,  neither  Virginia
nor the Federal  Government  has officially  designated  any part  of the
Totoiiotomoy  as  a  natural  area  or  area of  sensitive  ecology.   The
designation  in  the Draft EIS of  the  Lower Totopotomoy  (below Route
643) as such an  area was  a  result of  a  field  survey  made by  Bremner,
Youngblood  &  King, Inc,  as  part of the  Phase  II planning  process.
To  determine  whether  or  not  this classification should be  extended
above  Route  643,  another field  survey  would  have to  be  undertaken.
EPA estimates  from aerial inventory analysis recently obtained from
the  U.S.  Fish  & Wildlife  Service  that a  minimum of 150  acres  of
wetlands  are  in  existence  along  the  Upper  Totopotomoy  streanibeds.
It  is  recommended that  a comprehensive  ground survey  be made  before
any  significant  actions are  taken in  the  Upper Totopotomoy  Basin.
EPA   will   arrange  with   appropriate   agencies  for  this   to  be
accomplished.

Whether or not the  Upper  Basin  is classified  as an  area of sensitive
ecology,  it  is   (see Figure  2) considered  a Flood Hazard  Area.  The
floodplain along  the  Creek,  as  delineated in the Draft EIS, stopped
at U.S. Route  201.   In the updated Flood  Hazard  map,  the  floodplain
extends  above U.S. Route 301.   Furthermore,  it  is  almost certain
that  point  or non-point  discharges  to  the  Upper Totopotomoy would
have  some impact  on  the  Lower   as  well.   The  extremely  low flows
characteristic of the  Totopotomoy Creek  (5.8 cfs  average  discharge,
with  a ten year  minimum average seven  consecutive  day flow  of. 0.0
cfs)   render  it  sensitive  to   relatively  small  changes  in  flow
quantity or characteristics.

Issue:  The effluent limitations  set by the SWCB for an ashland
discharge to  the  South  Anna River and for  a  County  discharge  to the
Pamunkey River at Nelson's  Bridge have  been uncertain throughout the
majority of the duration of the Phase II planning.

Response:  The SWCB has recently  set new effluent limitations  for
                         sp;
                          01
a  discharge at  Nelson's Bridge.   The new  limitations are  21 mg/1
BOD 5  and   1  reg/1   ammonia.    These   have  been  relaxed  from  the
previous limitations  of 11 mg/1  8005  for  a 3.0  mgd  discharge.  The
new limitations  are based  on stream  surveys  conducted by  the SWCB
for  the  purpose   of   ascertaining   whether   or  not  the  previous
allocations were valid.   It should be noted that this relaxation of
effluent   limitations   does   not   affect  the  cost-effectiveness
discussion  in Section III of  this Final EIS.   In
                                               11

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Public
Participation
Water Supply
Section III, it  is determined that  either  sub-regional alter-
native (R-I or A-I) is more cost-effective than the 8-1 region-
al alternative with  the previous effluent limitations  or with
30/30 requirements.

     The SWCB  has  not  yet finalized  revised  limitations for
Ashland1s South  Anna  River discharge.   However,  the  SWCB has
stated that  the  new limitations  will  be no  more  and possibly
less stringent than  the current  ones  (22 mg/1  BOD  for  a 1.2
mgd discharge).  Thus the Ashland alternatives' cost-effective-
ness will not be undermined by the new limitations and may well
be enhanced.

Issue:  At various times during the Phase II planning and EIS
process, several citizens have complained about the lack of
public participation.

Response:  As  noted  earlier  in  this Section,  public partici-
pation in the Hanover  County Phase II project  has been intensive
and has had a definite effect on several planning developments.
Most of  the  major  changes  of direction in  the  planning have
resulted, directly or  indirectly, from  public  comment.   These
changes have included  the  assessment of sub-regional alterna-
tives, the  separation  of  Ashland,  and  the  scale-down  of the
remaining Phase II study area.

     EPA, through  its  requirements  for  public  meetings,  hear-
ings, and distribution  of  documents, encourages  such partici-
pation.  EPA feels  that  the public  involvement in this project
has resulted and  will  result in  the  chosen  treatment alterna-
tive being most responsive to public need.  EPA recognizes that
public support  is  mandatory  for  sewage  and   water projects to
be implemented, since bond issues must be approved by the elec-
torate.  The  construction  grants public participation program
helps the planning  entities to  develop  projects which  will be
approved by  the  public and will  be  reflective of public need
and preference.

Issue; Several citizens have expressed concern over the need to
coordinate wastewater and water  supply  planning in the County.

Response:  Although there does  not  appear to  be  any threat to
the quality  or  quantity of water supply in  the County at this
time, it  is  well  to  consider the relationships  between water
supply and  wastewater  management.   There  are two  basic  water
supply considerations  to  be  included  when   making  wastewater
management decisions:

1.  If wastewater  treatment  is inadequate, water  supplies for
    the study  area or  for another  area may be  polluted and ,
    therefore threatened; and

2.  If water  supplies are limited and  water  conservation mea-
    sures are implemented, the reduction in wastewater flow may
    render a previously-sized treatment  facility over-designed.
    Conversely, concurrent planning  of  conservation and  treat-
    ment design can effect economies in  facility sizing.

Consideration of these two factors does  not significantly  alter
the Facilities Planning  accomplished either  by the  County or
by Ashland.
                                                     12

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ADDITIONAL AND          In response to specific comments received on the Draft EIS,  the
CORRECTED DATA          following errors have been noted and corrected:

                        Page Reference
                        in Draft EIS                   Correction

                           II-5          On Figure 11-2, Existing Land Use,the last
                                         entry should  read "Agricultural  and Forest".

                           11-34         The last sentence on the page should read
                                         "The impoundment  is  required  to discharge a
                                         minimum of  68 m^/minute  (40  cfs) year-round.

                           11-50         Figure II-8,  Flood Hazard Areas,  should be
                                         replaced with Figure 2 of this Section.

                        11-58 & 11-60    On Figure 11-12, Archaeological and Historical
                                         Sites in the  Phase II area, 7 (Rural Point) is
                                         located south rather than  north  of  Route 606.

                                         In addition,  The  Totomoi  historic site should
                                         be added  as  No. 11  to  Table  11-11, Historic
                                         Sites and Structures  in the Phase II  Service
                                         Area.The dateis early  1800's  andthe list-
                                         ing is  by  the State. No.  11  (Totomoi)  should
                                         be added to  Figure  11-12 (p.  11-58)  north of
                                         the Totopotomoy Creek,  south  of  Route 643  and
                                         west of Route 640.

                           11-59         Paragraph 4 should read as follows:  "...These
                                         are the  700-acre  Hanover  Wildlife and Recrea-
                                         tion Area on  the  Pamunkey River  just  east of
                                         Hanover, an 80-acre  park  (Patrick Henry Park)
                                         west of  Ashland,  the   115-acre   Little  River
                                         Falls Park, and  the  270-acre  Park  (Poor Farm
                                         Park) west of Ashland off Route 54"-

                                         An additional sentence should be  added to page
                                         11-59:  "In addition,  a transcontinental bike
                                         trail traverses Hanover County, although it is
                                         completely outside  of   the  Phase  II  service
                                         area."

                           V-5           The last paragraph should be replaced with  the
                                         following: "In Hanover County all streams have
                                         been classified  by  the SWCB  as  effluent lim-
                                         ited; however, for streams that are  water qual-
                                         ity limited,  implementation  of   the Virginia
                                         anti-degradation  policy requires   advanced
                                         waste treatment for all discharges  that cannot
                                         meet anti-degradation  standards   with  conven-
                                         tional treatment."

                        V-2 and V-3      Replace pages V-2 and V-3 with the  following:
                        "Pursuant to  the  requirements  of  the Federal  Water Pollution
                        Control Act Amendments of 1972 (PL 92-500), the SWCB  has estab-
                        lished receiving water quality standards for the surface waters
                        of Hanover  County.   In  general,  surface waters  in  the County
                        fall into two major classifications: estuarine waters  (Class  II)
                        or free flowing  streams (Class III)  (Ref.  28).   Water quality
                        stream standards  for  each of  these  classifications  are given
                        below.
                                                     13

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SPOTSYLVANIA
    COUNTY
                                                                                                        FIGURE 2
                                                                                                   FLOOD HAZARD AREAS
                                                                                                HANOVER COUNTY, VIRGINIA
                                                                                                    ( SOURCES: REFERENCES 1, 2, 6. 7 )

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      WATER QUALITY STANDARDS FOR PRIMARY CLASSIFICATIONS
                       IN HANOVER COUNTY

StandardEstuarineFree Flowing Streams
Parameter	Class II	Class III	

Dissolved Oxygen
   Minimum                   4.0                   4.0
   Daily Average             5.0                   5.0

pH                        6.0-8.5             6.0-8.5

Temperature (°F)
   Rise above natural   4.0 (Sept. - May)
                        1.5 (June - August)        5

Maximum                     —                 90

Maximum hourly change      2                    2


     An additional standard for  fecal  coliform for all surface
waters, except  those  where leased private  or  public shellfish
beds are present,  requires that: "the  fecal  coliform bacteria
shall not exceed a log mean (geometric mean) of 200 fecal coli-
form bacteria per  100  ml.   Evaluation  should  be  determined by
either the  multiple-tube  fermentation  for  marine  water  or the
membrane filter method  for fresh water and should be based on
not less than  ten samples  taken over  not  more than  a  30-day
period."
     All surface waters in  the County are assigned  a major class
(II or III)  as  described above.  In addition,  two stream seg-
ments are identified  as  sources  of public  water supply.  These
segments are:

o  The South  Anna River from Ashland's raw water intake to a
   point 5 miles upstream;  and

o  The North Anna  River and its tributaries from Hanover Coun-
   ty's raw water  intake  near  Doswell  (approximately 1/2 mile
   upstream from  State  Route  30)  to a  point  5 miles upstream.

The following standards apply to these  segments:

    CONSTITUENT                   CONCENTRATION (mg/1)

     Arsenic                                     0.05
     Barium                                      1.0
     Cadmium*                                    0.01
     Chloride                                   250
     Chromium (Total)                            0.05
     Copper*                                     1.0
     Foaming agents (measured as methylene       0.5
       blue active substances)
     Iron (soluble)                              0.3
     Lead                                        0.05
     Manganese  (soluble)                         0.05
     Mercury*                                    0.002
     Nitrate (as N)                             10
     Phenols                                     0.001
     Selenium*                                   0.01
                                15

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   CONSTITUENT

     Silver"
     Sulfate
     Total dissolved solids
     Zinc*
CONCENTRATION (mg/lj

            0.05
          250
          500
            5.0
     Chlorinated Hydrocarbon Insecticides:
        Endrin*                                  0.0002
        Lindane*                                 0.004
        Methoxychlor*                            0.1
        Toxaphene*                               0.005

     Chlorophenoxy Herbicides:
     2,4-D                                       0.1
     2,4,5-TP (Silvex)                           0.01

     Radioactivity:                        Picocurie/liter
        Combined radium-226 and radiura-228       5
        Gross Alpha particle activity           15
        (including radium-226 but excluding
         radon and uranium)
 * The  numeric  standards  for  the  chemicals  listed  above are
   designed to protect public water supplies for human consump-
   tion.  The  limits  established  for  those  chemicals  marked
   with an asterisk (*)  may not protect aquatic life. Therefore
   when a request to classify a stream as a public water supply
   is received, it will  be determined  if  more stringent limits
   are needed for those chemicals in order to insure protection
   of aquatic life.


     Furthermore, within Hanover County, the Chickahominy River
and its  tributaries,  and  the  tidal Pamunkey  River  and tidal
portions of  its  tributaries  have also  been  assigned   special
standards by the SWCB.   Effluents  discharged  to the Chickahom-
iny River or  its  tributaries must meet the  requirements given
in Table V-2  [of, the Draft EIS]  Additional  standards have been
promulgated for the tidal  portion of the Pamunkey  River which
has shellfish  beds.   For  these  areas,  the following   special
bacterial standards take  precedence over the  general coliform
standards:
     Coliform Organisms  -   The  median  MPN  shall  not  exceed
     70/100 ml and  not  more than  10  percent  of  the   samples
     ordinarily shall  exceed a  MPN  of  230/100 ml  for a 5-tube
     decimal dilution  test (or  330/100  ml  where  a 3-tube deci-
     mal dilution  is  used)  in those portions of  the area most
     probably exposed  to  fecal  contamination  during  the  most
     unfavorable  conditions.
                                16

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                                       SECTION III: PHASE II ALTERNATIVES
ALTERNATIVES
RECOMMENDED IN 1978
FACILITIES PLAN
Alternative 8-1
Alternative R-I
     The purpose of  this  Section is  to  evaluate  overall Phase
II alternatives.   The  political  feasibility  of  an  Ashland
split-off has already  been demonstrated, and  this feasibility
is extremely  important to  consider  in  the planning  process.
Also of  paramount  importance,  however,  is  the cost-effective-
ness of  this  politically desirable  option.    In  this  Section,
the cost-effectiveness  of  a separate Ashland  facility  within
the context of  the  entire Phase  II  area planning is assessed.

     Numerous alternatives and combinations of sub-alternatives
for the Phase II area were assessed in the Draft EIS.  To focus
attention on the most  feasible  of these  alternatives,  only the
two recommended alternatives from the 1978  Facilities  Plan and
the two from the Draft EIS are discussed in this Final EIS. All
costs presented in this Section are distributed over the entire
Phase II Service Area as originally delineated.

     Two basic alternatives were recommended in the 1978 Facil-
ities Plan.  The first consisted of a single treatment plant to
serve the entire Phase II area.  This option was the recom-
mended alternative in the original 1975  Facilities Plan for
Phase II and was known as Alternative 8-1.  The treatment plant
was to  be  located  in the Rural Point area  and would discharge
treated effluent to  the Pamunkey  River  near  Nelson's  Bridge.
The plant  would  be  designed to accommodate an average  flow of
3.0 mgd  using a  conventional  activated sludge process  followed
by physical-chemical  flocculation.  A detailed description  of
this alternative may be  found  in Section 5 of the 1978 Facil-
ities Plan or in Section III of the Draft EIS.

     The second alternative recommended  in the 1978 Facilities
Plan called  for  a  separate  Ashland   treatment  facility,  a
treatment plant  in  the Totopotomoy Basin to serve that Basin,
and interconnection  of  the  Industrial  Corridor  to  Henrico
County.

     This alternative was later identified as "R-I" in the Draft
EIS. Under  this  option,  an Ashland  treatment facility  would
serve the  Town  of  Ashland  and  those nearby areas which could
readily be  served  by  extending  existing  lines.    These  areas
included Oak Hill  Estates and  Hanover  Academy.  Two treatment
processes were proposed  as  feasible  for the  Ashland facility:
oxidation ditches with discharge to  the South Anna  River and
spray irrigation  of pretreated  effluent.   Both  alternatives
would be designed for a flow of 0.8 mgd.

     The Totopotomoy treatment plant  would  serve  areas in both
the Upper and Lower  Totopotomoy drainage basins.   The facility
would be  located  near  the  confluence  of  the  Totopotomoy and
Strawhorn Creeks and would  be  a larger version of the proposed
oxidation ditch at the Ashland  facility (design flow - 1.5 mgd).
The effluent would  be  chlorinated  and  discharged to the Toto-
potomoy Creek.

     The Industrial  Corridor,   under  this  scenario,  would  be
interconnected to  the   Henrico  County  system.    Treatment  of
sewage from  this area  at  either  the  Ashland or Totopotomoy
facility was  not  considered  feasible  due   to   the  relative
impracticality of  pumping  to  the  Totopotomoy Basin,   and the
lack of capacity at the Ashland plant.   Instead, an interceptor
sewer would  transmit the 1.29  mgd from this   area  along 1-95
to Henrico County.   Again,  a  more detailed description of this
                                                       17

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ALTERNATIVES
PRESENTED IN THE
DRAFT EIS
Alternative R-I
Alternative A-I
ALTERNTIVES
EVALUATED IN 1980
ASHLAND FACILITIES
PLAN
alternative may be  found in  Section  5 of  the  1978 Facilities
Plan or in Section III of the Draft EIS.

     The Draft EIS identified two environmentally and institu-
tionally desirable treatment option alternatives. These alter-
natives were very similar; both incorporated the concept of a
separate Ashland facility and the interconnection of the Indus-
trial Corridor  to Henrico  County.   However,  one  called  for
construction of a  Totopotomoy treatment  facility  to serve the
Totopotomoy basin service area  and  the other called for inter-
connection of  the  Totopotomoy  service area to  Henrico County
along with the Industrial Corridor.

     The Draft  EIS  concluded  that  Alternative  8-1 would  be
associated with numerous adverse environmental impacts relative
to the sensitive ecology of Totopotomoy Creek, the  use of prime
agricultural land in the  County,  and  the  opportunity for undi-
rected growth  that  was  presented  by the  proposed  regional
system.  Alternative 8-1  was  not recommended  for  further con-
sideration in the EIS because of  the  above impacts and because
of Ashland's expressed  and  increasing desire to continue oper-
ation of their existing facility.

     The first of these alternatives,  providing for a separate
Totopotomoy treatment  facility,  was  also  recommended   in  the
1978 Facilities Plan and was described previously.

     The second alternative recommended by the Draft EIS again
included a separate  Ashland  facility.   However,  under A-I, the
Totopotomoy basin and  the Industrial  Corridor  would intercon-
nect with Henrico County.   The  Industrial Corridor interceptor
would run along  1-95  as  in  Alternative  R-I.   In  addition,  a
trunk line serving the  Upper  Totopotomoy  would run along Toto-
potomoy Creek  and then  down  alongside  U.S.   Route 301  into
Henrico County.  A  third  sewer  would  follow the lower Totopo-
tomoy Creek and Strawhorn Creek and  then  be  diverted  south to
Henrico County  just  west of  State Route 643.  Each  of these
sewers would pass  into  Henrico  County at  a different point.  A
more detailed description of  this alternative may  be  found in
Section III of the Draft EIS.

     The 1980 Ashland Draft Facilities Plan evaluated three
basic Phase II alternatives: 8-1, R-I, and A-I.  These are
labelled Alternatives A, C,  and D in the Ashland Plan and were
chosen because they had been recommended  in either  the 1978
Facilities Plan or in  the Draft  EIS  as discussed above.  Under
the 8-1 alternative, two  sub-alternatives  were evaluated - one
under which  current  SWCB  effluent   limitations   at  Nelson's
Bridge would continue to  apply  (Alternative  A),  and one assum-
ing that  these  limitations  would be  relaxed to  30/30  for BOD
and TSS  (Alternative  B).   In this  EIS it  is  assumed that the
SWCB limitations would be met.

     The evaluation  of  these three Phase II  alternatives was
aimed at  assessing  the  cost-effectiveness  and  environmental
impacts of  a  separate  Ashland   facility  as  compared  to the
proposed regional  facility.   For  this   evaluation,  the  most
costeffective option  for an  individual  Ashland  facility was
assumed (see Section IV).
                                                        18

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PHASE II
ALTERNATIVES
Alternative 8-1
Description
Costs
Alternative R-I
Description
     For this Final EIS the comparison of the three Phase II
alternatives in the 1980 Ashland Facilities Plan has been
reviewed. A  summary  of  the  findings  from  that  review appear
in this Section.

     Alternative A in the Ashland Draft Facilities Plan is
essentially the same as the previously identified Alternative
8-1: construction of a  regional  treatment plant to service the
entire Phase II area.   This  alternative  was recommended in the
original 1975 Phase  II  Facilities Plan and  in  the  1978 Facil-
ities Plan as well.   It was not  recommended  in the Draft EIS.

     The treatment system  to be used at  the  Rural  Point Plant
is described fully  in  the 1975  Facilities  Plan.   In  the  Ash-
land plan, two  changes  have  been  made.   First,  the  design flow
has been  increased  to  4.0  mgd  to  accommodate  increased  pro-
jected flow  from  Ashland.   Second,  carbon  adsorption  columns
have been added to  the  effluent treatment.   The Ashland Facil-
ities Planner  determined  that  tertiary  treatment  would  be
required to meet stringent SWCB limitations on discharge to the
Pamunkey River.   Carbon adsorption columns were not included in
the original 8-1 cost estimates or treatment system, and it can
be argued that  the  original  8-1 could not  have met SWCB limi-
tations.  The recent relaxation in SWCB limitations means that,
although the  additional  processes   described   in   the  Ashland
Facilities Plan may  not  be  required,   some treatment  beyond
secondary would be necessary.

     The costs of this alternative were calculated as the sum
of an amortized  construction  cost  and  a yearly  operation  and
maintenance (O&M)  expense.   For ease in  comparison,  these  two
costs are  combined  and  reported  as single  treatment  expense.
This is then given as the unit cost  per  1000  gallons  of waste-
water treated and  also  as  a  total  equivalent  uniform annual
cost.  Figures are presented in October 1979 dollars.

     The unit cost  for  Alternative  8-1  (with  treatment facil-
ities capable of  meeting  stringent  SWCB  limitations)  is $2.14
per 1000 gallons of  wastewater treated,  which is an equivalent
uniform annual cost of $3,122,964.

     Alternative R-I was included as a recommended alternative
in both the 1978 Facilities Plan and in the Draft EIS.   This
alternative provides  for  continued  operation   of  a  separate
Ashland treatment plant,  construction  of  a  plant to  service
the Totopotomoy basin,  and  interconnection of  the Industrial
Corridor with Hanover County facilities.

     The proposed Ashland plant incorporated into this alterna-
tive in the Ashland  Facilities Plan  is  the  selected most feas-
ible Ashland sub-alternative in that Plan. This sub-alternative
consists of  upgrading   the   existing  lagoon  with  aeration,   a
detailed description of which  is  included  in  Section  V.   The
design flow  for the Ashland  Service  Area  has  been  increased
from the  0.77  MGD  used in  the  1978  Facilities Plan  and  the
Draft EIS  to 1.2  MGD  for  reasons  discussed  in  Section  IV.

     Two different treatment plants  are  proposed for the Toto-
potomoy Basin under  Alternative  C  -  both  with  discharges to
Totopotomoy Creek.   The  first  is similar to the plants previ-
ously proposed in the Phase  II planning:  a  1.5  mgd  conventional
                                                        19

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Costs
Alternative A-I
Description
Costs
Summary
conventional activated  sludge  process  with  effluent disinfec-
tion. The sludge process  train  would  include mechanical sludge
dewatering, anaerobic digestion,  sludge drying beds, and land-
filling of the stabilized  residue.   The other proposed Totopo-
tomoy plant is a physical/chemical facility.  The proposed flow
diagram would include screening,  an  aerated flow equalization,
flocculation, clarification, multimedia filtration, and carbon
adsorption.  Carbon  regeneration  facilities  are  included  in
the alternative.   The effluent  would  be  disinfected by chlor-
ination and  discharged.   Sludge  handling  facilities  for   the
physical/chemical plant would consist of aerobic digestion fol-
lowed by centrifuges.  The dewatered stabilized sludge would be
landfilled.

     The interconnection of the  Industrial  Corridor  with Henrico
County facilities has been discussed previously in this Section.
The costs of  this  alternative were merely updated  in the Ash-
land Plan.

     The unit cost for Alternative R-I  is  $1.77 per 1000 gal-
lons, and  the  equivalent  uniform annual  cost  is  $2,580,209.

     The final alternative included in  the Ashland  Facilities
Plan was developed in the Draft EIS.   Under this alternative
the Town of Ashland would continue to treat its wastewater, and
the rest of  the  Phase  II  Area  would  be  interconnected to the
Henrico County system.   The proposed  Ashland plant  was  again
the most  feasible  sub-alternative  of  the Ashland Facilities
Plan.

     Interconnection of  the Upper  and  Lower Totopotomoy basins
and of the  Industrial  Corridor  to Henrico County were assumed
to be as developed  in the  Phase  II planning efforts.  Only the
costs were updated.

     The costs of construction and operation of an  Ashland
facility along with  construction  and  maintenance  of transmis-
sion lines  to  Henrico  and  treatment  fees  for  the  Totopotomoy
basin and Industrial Corridor  would  result in a  unit cost for
the Phase  II  area  of   $1.63  per  1000  gallons  of  wastewater.
This equals  an  equivalent  uniform annual  cost  of  $2,386,198.

     Each of the  three Phase II  alternatives evaluated in the
1980 Ashland Facilities  Plan  would serve  all of the  Phase  II
area. However, a  regional treatment system is specified in only
one alternative;  an  independent Ashland  treatment  facility  is
specified in the other  two options.   The details of these lat-
ter alternatives  follow closely  the  details presented  in the
County's earlier  Phase  II 'planning.    However,  the  author  of
the Ashland  Facilities  Plan  has   evaluated  these  details  and
altered them  where  deemed  appropriate.  The  alterations  dis-
cussed in Section  IV appear reasonable,  especially in connec-
tion with the  Ashland  plant, where  more  accurate   information
was used than in  the previous Phase II  plans.

     The costs of  each  alternative are summarized  in Table 1.
This table demonstrates  that either R-I or  A-I  (the  options pro-
viding for a separate Ashland  facility) is more cost-effective
than 8-1 (in which  Ashland is  combined  with the County). Specif-
ically, Alternative A-I appears to be  the most cost-effective.
                                                       20

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                            TABLE 1

                     PHASE II ALTERNATIVES

                        COST COMPARISON
    ALTERNATIVE
    TOTAL       TOTAL    EQUIVALENT
   PRESENT    COST PER    UNIFORM     COST
    WORTH     1000 GAL   ANNUAL COST  RATING
8-1 - Phase II
Regional Plant
with Discharge at
Nelson's Bridge
$33,408,604
$2.14
$3,122,964
R-I - Ashland
Facility,*
Totopotomoy Facility,
Industrial Corridor
  Interconnect to
  Henrico County
$27 ,602,362
$1.77
$2,580,209
A-I - Ashland
Facility*, Rest
of Phase II
  Interconnect to
  Henrico County
$25,526,886
$1.63
$2,386,198
* Assuming Ashland Alternative #1 - Aerating existing iagoon
                                 21

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ENVIRONMENTAL
IMPACTS OF PHASE II
ALTERNATIVES
     The environmental impacts of each of the three Phase II
alternatives are summarized in this sub-section.  These sum-
maries are drawn from the Draft EIS and updated substantially
only where significant comments  were  received on the Draft EIS
and subsequent changes made  (see  Section  II of this Final EIS.
Alternative 8-1;
Socioeconomic
Water Quality
Biology
     The construction of a single treatment plant and sewer
for the entire Phase II area is identified as a project that
will allow  high  growth  for Hanover  County.   Residential and
commercial development  in  areas   currently  inaccessible  to
wastewater treatment would result.

     Construction of a regional treatment plant would be asso-
ciated with  both  beneficial and  potentially  adverse  impacts.
The most valuable  beneficial  impact would  be seen  in  the im-
provement to Falling  Creek and its small  unnamed tributary to
which the  Ashland  facility currently  discharges.  The  Ashland
lagoon has  been  cited  as  the  cause  of  degradation of   these
streams.  Elimination  of   the  discharge  would  allow  them  to
return to  their natural condition.  Another beneficiary of the
elimination of  the  currently   inconsistent  Ashland  discharge
would be the South Anna River.   A general improvement  in  water
quality could be expected.   A further benefit to surface waters
would come from the elimination of failing septic tank systems.
Currently failing systems  allow  unstabilized  leachate  to  enter
and degrade  small  streams in  the service  area.   In addition,
these failing  systems  have caused  seepage into  basements and
pose a threat  to local  groundwater  quality.  Connection to the
proposed sewer system  would eliminate  these  private  systems.

     The adverse impacts of the project on  surface water  qual-
ity could  include both  potential  serious  permanent impacts and
temporary construction  effects.   Possibly  the  worst potential
impact involves  the  effect of  the proposed  discharge  on the
Pamunkey River.  This,  as  included under Environmentally Sen-
sitive Areas is both  a  scenic  river  and  a  sensitive  ecology.
Therefore degradation of water quality would be critical.  Other
potential adverse impacts  on  the Pamunkey  include  raising BOD
and nitrate levels during  low  river flow periods  and  chlorine
toxicity problems from the disinfected effluent.

     Temporary adverse  construction impacts would be associatd
with the  sewer routing along  the stream  beds.   Sedimentation
from the construction could be  expected  in Stony Run,  Licking-
hole, Kersey,  and Totopotomoy Creeks  in  addition to the Chick-
ahominy River.

     Beneficial impacts on aquatic biota are expected espe-
cially in  Falling  Creek and its  small  tributary  to which the
effluent from  the  Ashland  facility is  discharged.   Beneficial
impacts could  also  occur  in  the small  streams  in the  area
degraded by the  failing septic  tank  systems.   Communities in
the watershed  of the  South Anna  River would  also benefit from
the general improvement in water quality.

     The potential  for  serious  damage  to  the sensitive ecology
of the Pamunkey bottomland is  again a  serious adverse impact.
In addition,  temporary  adverse   impacts  on  aquatic  organisms
could be  expected  from the  construction  of  sewers  in  stream
                                                          22

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Environmentally
Sensitive Areas
Summary
beds. As  before,  this  would  involve  Stony  Run,  Lickinghole,
Kersey, and  Totopotomoy  Creeks  and   the  Chickahominy  River.

     Terrestrial wildlife  living  along  Falling  Creek  and  its
small tributary to  which effluent  from the  Ashland  lagoon is
currently discharged  would  benefit  from  the cleaner  stream.
Adverse impacts  to  terrestrial  biota  would  include  animal
migration from  the  Rural Point  site   and  temporary disruption
of animals  by  gravity  sewer  and  force  main  construction.
Animals driven off  by  the  transmission line  construction could
be expected to return.

     Construction of a regional treatment plant poses a serious
potential threat to a sensitive ecology, the Pamunkey bottom-
lands. A  shock  pollutant loading, normal  discharge during low
flow, or  over-chlorination  of  effluent  could  result  in  per-
manent damage to this area.

     The proposed Rural Point plant would be located in another
area of  sensitive  ecology,  the  Totopotomoy  bottomlands.  Con-
struction would require  clearing  of some of  this area and  sub-
stantial sedimentation  from site  grading could be  expected.
Temporary sedimentation  from sewer construction could  also be
expected in the Chickahominy wetlands.

     The Pamunkey is also  a scenic river and the potential de-
gradation posed by Alternative 8-1 should be avoided.  However,
this alternative  would  have  beneficial impacts  on  the  South
Anna, also classified as a scenic river.

     Stony Run, Lickinghole, Kersey and  Totopotomoy Creeks and
the Chickahominy River  are  all  listed  as flood  hazard areas by
the National Flood Insurance Program (see Figure 2). Foundation
material under  the  sewer  could  be eroded  by turbulent  flood
flows without  proper  design precautions.   This  could  lead to
unsupported pipes which are susceptible to failure.

     No impacts  are  expected   on groundwater  recharge  areas
from any  of  the  alternatives.   Primary  impacts  on  prime agri-
cultural land  from  construction  of sewer and force  main  tra-
versing prime land  would be adverse.    In  addition, an adverse
secondary impact  would be  development of the  Phase  II  area,
much of which is prime agricultural land.

     Implementation of  Alternative 8-1  would not  be expected
to have  any  significant  impact  on historically  or archaeolo-
gically valuable  lands.   The proposed  sewer  routing does  pass
near seven identified historical sites (identified  in the Draft
EIS).

     The potential damage to the sensitive ecology of the Pamun-
key bottomlands and the  construction  of the plant  in the Toto-
potomoy bottomlands are  serious adverse environmental impacts.
Additional adverse  secondary impacts  associated with the  high
growth potential of the alternative would include loss of prime
agricultural land, some  degradation in air quality,  and poten-
tial socioeconomic stress on human services.

     Significant beneficial  impacts   would  include  removing   a
potential public  health  problem by eliminating  failing septic
tank systems  and   a dramatic   improvement  in  the   quality  of
Falling Creek and its small  tributary.
                                                         23

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Summary
Alternative A-I
Socioeconomic
Water Quality
Biology
Environmentally
Sensitive Areas
disrupt use ot prime agricultural land.  In addition, the
actual Totopotomoy plant would be built on prime agricultural
land causing its loss of use. The secondary impact of loss of
prime agricultral land due to growth would be lessened but not
substantially.

     Impacts on groundwater recharge areas and historically
or archaeologically valuable lands would be expected to be
minimal. As under Alternative 8-1, sewers would pass close to
seven identified historical sites.

     Alternative R-I, like the previous alternative, includes
a discharge into a sensitive ecology.  Potential damage to the
Totopotomoy bottomlands is a serious danger that must be taken
into account in alternative evaluation.  Secondary adverse
impacts would be much as those identified for 8-1, although
slightly smaller in magnitude.

     The beneficial effects are the same as under Alternative
8-1, the major impacts being water quality improvement in
Falling Creek and the removal of a potential public health
problem by elimination of failing septic tank systems.

     The construction of a separate Ashland facility has
already been noted as one of the alternatives leading to a
moderate growth scenario.

     Surface waters and groundwater in the county would bene-
fit from this alternative as from 8-1 and R-I.

     The South Anna River would be the only stream in the
County receiving effluent under this alternative.  The Ashland
discharge would be directly to the South Anna as under Alter-
native R-I.  General water quality in the County would improve
as discussed previously.

     Impacts to biota, both aquatic and terrestrial, can be
expected to be the same as listed under Alternative R-I.  The
biota of the South Anna is subject to the possible adverse
impacts of discharging to that stream.

     The greatest difference in environmental impacts of the
three alternatives concerns sensitive ecologies.  Alternative
A-I does not have a potential adverse impact on a sensitive
ecology. Under both Alternatives 8-1 and R-I, a discharge to
a critical bottomland was planned - the Pamunkey and Totopot-
omoy respectively.  The discharge from the Ashland facility
would be to the South Anna, well upstream of any sensitive
ecology.  In addition, this alternative is the only one of the
three that would not include plant construction in the Totopot-
omoy bottomlands.  Alternative A-I would include sewer routing
in the Totopotomoy and Chickahominy bottomlands as under the
previous two alternatives.

     Impacts to the South Anna, a scenic river, would be the
same as listed under Alternative R-I.

     Sewer lines would again traverse prime agricultural land
and adverse secondary impacts to prime agricultural land and
to air quality would be the same as those from Alternative R-I,

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                            TABLE 2

                     PHASE II ALTERNATIVES

                ENVIRONMENTAL IMPACT COMPARISON
IMPACTS 8-1 R-I
Surface Water Quality + +
Groundwater Quality ++ ++
Aquatic Biology + +
Terrestrial Biology - -
Scenic Rivers - 0
Flood Hazard Areas 0
Groundwater Recharge Areas 0 +
Prime Agricultural Land - —
Areas of Sensitive Ecology — —
Historical/Archaeological 0 -
Sites
Construction Impacts — —
Land Requirements — —
Land Use 0 0
Population Growth ++ ++
Implementability — —
NO
A-I ACTION
++
++
++
0 0
0 0
0 0
+
0
0 0
0 0
0
0
0 0
+
++
KEY:  ++ = Very beneficial impact
       + = Beneficial impact
       0 = Not impacted by the alternative/equal adverse and
           beneficial impacts
       - = Adverse impact
      — = Very adverse impact

NOTE:  These impacts have not been weighted in importance.
       Thus no quantitative evaluation is presented.
                                  25

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Summary
SUMMARY OF
ENVIRONMENTAL
IMPACTS
MOST FEASIBLE
PHASE II
ALTERNATIVES
Alternative  A-I  would  not  have  any  major  impacts  on  groundwater
recharge  areas  and/or  historically  or  archaeologically  valuable
land.   The  proposed sewer  routing  does come  near eight  identified
historical sites.

The  greatest difference  in  the  environmental  impacts  of  the  A-l
Alternative concerns areas of sensitive  ecology.   Of  the  three, only
Alternative A-I  does not  have a potential major adverse  impact on a
sensitive ecology associated  with  it.   This should be  given serious
consideration  in  alternative  evaluation.   The  other  adverse  and
beneficial impacts for this alternative  are very similar  to  those of
Alternatives 8-1  and R-I.

The individual descriptions above of each Phase II  alternative's
environmental impacts are summarized in Table 2.  Each environmental
factor  is  listed separately and the effects  of each  alternative on
that  environmental  quality  summarized  are  as very beneficial  (++) ,
beneficial   ( + ) ,   no  impact/equally   adverse   and  beneficial    (0),
adverse  (-) ,  and very  adverse  (--) .   No weighting of  these factors
has  been  established due  to  the  difficulty  of  prioritizing  them.
Thus  no  quantitative  evaluation or  summing of  all the  ratings  for
each  alternative is possible.   However, it  is  possible  to compare
the alternatives  on a more qualitative  basis.

Table  2  and  the  more  detailed descriptions  above   indicate  that
Alternative A-I  has fewer  adverse  impacts than  Alternatives 8-1  and
R-I.  It  appears  that  Alternative  A-I  would allow  Ashland and  other
portions  of  the  Phase  II  area to correct existing wastewater  treat-
ment problems while preserving  to a  large extent the  rural character
of  the  county and  its  pristine areas.   Alternative  A-I  would have
fewer and less extensive direct  impacts  on  environmentally sensitive
areas  and  would also  direct  and   control   growth  in  the  county.
Finally,  A-I  is  the  most   implementable  and  least  controversial
solution:   it allows Ashland to  resolve  its  needs   separately;  it
does  not  include  a treatment  plant  in the  County;  and  it  takes
advantage of  arrangements  that have already  been  made  with Henrico
County.

Of the assessed Phase II Alternatives,  Alternative  A-I, involving
the separation of Ashland and interconnection of the rest of the
Phase  II  area to Henrico  County,   has  been  shown to  be  the  most
feasible  Phase  II  alternative  from   economic   and  environmental
viewpoints.   This  feasibility  assumes availability  of  adequate
capacity  at  the Henrico  County  facility  and  continuing  relative
proportions of the costs of the various  option  components.  Although
A-I appears most  feasible,  the  evaluations  do show that  R-I is also
more  feasible than  the  regional 8-1 alternative.   Thus  it  is  clear
that  separation  of  Ashland,  with various  options   for  the remainder
of the Phase II area,  is feasible and cost-effective.

The A-I Alternative concept has been tentatively pursued  by  both the
Town  of  Ashland and  by  Hanover   County,  although  no   irrevocable
commitments have  been  made.   Asland has developed specific  alterna-
tives to  sole its problems  independent of the County's post-Phase II
planning  efforts.   The Town  has  prepared  its  own Draft Facilities
Plan  to assess  Ashland  alternatives.    Concurrently  the  County  has
reserved  capacity  in  the  planned  Henrico  County  facility.   In
addition,  however,  the County  has  initiated  assessment  of further
options for  a scaled  down service  area  extending   from Phase I in a
northwesterly direction towards Ashland  (Phase I Extended)

Both  the  Town's  and County's  recent actions are consistent  with the
A-I  concept  recommended  by  this  EIS  for   the   original  Phase   il
planning area.
                                                26

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SEPARATION OF
ASHLAND
DEFINITION OF
SERVICE AREA
POPULATION
PROJECTIONS
        SECTION IV: ASHLAND ALTERNATIVES

     As discussed in Section III of this Final EIS, the Town of
Ashland has been separated from the rest of the Phase II study
area as part of the selection of the A-I Alternative.  Pursuant
to this,  the  Town has prepared  its  own  updated  Sewer  System
Evaluation Survey and Draft  Facilities  Plan in order to deter-
mine which of  several options  is  best environmentally and eco-
nomically to  solve  the  Town's  current  acute problem  with its
wastewater treatment plant.   This  Section  discusses  and  pre-
sents information on each  of the  alternatives developed by the
Town.  All costs  in  this  section apply to  the  Ashland Service
Area only.

     The Town of Ashland is approximately eleven miles north of
Richmond adjacent to Interstate 95.  The Town limits encompass
an estimated 4.5 square  miles.

     The Ashland  treatment  facility is planned  to  service all
areas within the Town limits and nearby areas already served by
Ashland's water  system  and/or most readily  accessible to  con-
nections during  the planning period.  These  areas  are  shown on
Figure 3 and include:

     1)  The  area  adjoining U.S.   Route  1  from  the  North  Town
         limits to  the   junction  of  U.S.  Route  1  and  the
         R.F.&P. Railroad;

     2)  The  area surrounding  Hanover Academy  and the  State
         Route 54-Interstate 95 interchange;

     3)  The  area  adjacent to Ashcake  Road  (State  Route  657)
         from the  eastern  Town   limits  to  the  western  Town
         limits; and

     4)  The  residential  development  west  of  Stony  Run (west-
         ern Town limits)  near Woodland Cemetery.

     Population projections prepared for the Ashland Service
area by the Commonwealth of Virginia Department of Housing and
Community Development  and  by Bremner,  Youngblood  and  King,
Inc./Economics Research  Associates were  used  in  the  Ashland
Draft Facilities  Plan.  As shown  in  Table 3,  a  comparison of
these two  projections  revealed  almost  identical  projection
figures. These thus appeared  to  be reasonable projections, and
indicated an  average 2%  annual  growth rate  for  the Ashland
Service Area over  the planning  period.   Ashland's Draft Facil-
ities Plan used  the  Department  of Housing  and Community Devel-
opment projections  to  estimate wastewater flows  and  required
treatment capacity.

     Since the preparation of the  Ashland Draft Facilities  Plan,
however, new population figures have  been  issued - the prelim-
inary 1980 Census counts.   As shown in Table 3,  the preliminary
Census figures for the Town  of Ashland  Service Area indicate  a
significantly lower population than previously estimated,  about
1000 less people  in 1980  and about 2003 less in 2003  (assuming
the same growth  rate as that assumed  for the earlier  figures).
This population figure,  although preliminary, has not  been con-
tested by the Town, so  is probably close  to the actual number.
Thus the population projections used  in the Ashland Draft Fac-
ilities Plan appear to be about 20% higher than  they should be.
                                                           27

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ff/V
                              TOWN OF ASHLAND
                                       AREA

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TABLE 3                                       ASHLAND SERVICE AREA
                                             POPULATION PROJECTIONS

1980
1985
1990
1995
2000
2003
TOTAL
POPULATION1
6,331
7,112
7,893
8,549
9,222
9,647
TOTAL
POPULATION2
6,038
6,780
7,617
8,383
9,097
9,512
TOTAL
POPULATION3
4,982
5,566
6,151
6,643
7 ,142
7,461
                        1  Commonwealth of Virginia,  Department of Housing and Community
                           Development.
                        2  Bremner,  Youngblood  & King,  Inc., Economics  Research Asso-
                           ciates .

                        3  Developed by  Economics  Research  Associates from preliminary
                           1980 U. S.  Census  population  figure  for  the Town of Ashland
WASTEWATER FLOW              The per capita water consumption rate used in the Ashland
PROJECTIONSDraft Facilities Plan deviates significantly from previous
                        estimates.  In  the  Ashland  Draft Facilities Plan,  the  Town of
                        Ashland reports a 1979  water consumption of 137.3  gallons per
                        capita per  day  (gpcd).   However,  the  Draft  EIS  reported  an
                        average 1976  per capita water  consumption  of  105 gpcd  and
                        Bremner, Youngblood and  King,  Inc.  reported a  per capita water
                        consumption of  110  gpcd  for 1976 (Draft  EIS,  Section III). As
                        discussed below,  there  are  primarily  two   reasons  for  these
                        deviations.

                             The two low figures, 105  gpcd  and  110  gpcd,  were obtained
                        from the water  use  records  of  the  Town  of  Ashland.  However,
                        according to  the Director  of  Public  Works  for  the  Town  of
                        Ashland, there  exists  a  significant  amount  of  unmetered water
                        consumption within  the Service  Area  of  the  Town  of Ashland.
                        The amount  of  unmetered water  consumed daily  is estimated to
                        be 15.2 percent of  the  total  water produced or  an average of
                        112,660 gpd.   The  two  low  consumption  figures  do not  take
                        this factor into account.

                             Another factor contributing  to the variance in per capita
                        water consumption rates  is  time.   Again, the  two low  consump-
                        tion figures  were  calculated  from  1976  records,  whereas the
                        Town of Ashland's figure of  137.3  gpcd  was calculated  in 1979.
                        As noted  by Bremner,  Youngblood and King,  Inc.,  the  average
                        per capita  water  consumption rate  increased by approximately  5
                        gpcd from 1974  to 1976,  showing  that  variances  occur from year
                        to year.

                             To obtain  total wastewater  flow estimates,  the per capita
                        water consumption rate was multiplied by 80 percent  to  estimate
                        the actual wastewater generated from water consumption.  Finally,
                                                       29

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                        an  allowance  for infiltration  and  inflow was added  in  accord-
                        ance with  EPA  I/I  regulations.   This  procedure  provided  an
                        estimated  design  flow  amount  of 1.22  mgd.

                            The sewers  within  the  corporate  limits  of  the  Town  of
                        Ashland exhibit  excessive  inflow and  infiltration.   All  pro-
                        posed  Ashland  alternatives  would  include  an  extensive  sewer
                        rehabilitation program,  which  is detailed  in the  report  enti-
                        tled Addendum: Sewer System Evaluation  Survey,  Town of  Ashland,
                        January 1980.~ Although   current wastewater  flows  contain  an
                        excess of  I/I,   it  is  assumed  that  the  rehabilitation  program
                        would  reduce  I/I  to  allowable  levels.  Such  levels amount  to
                        552.8  gpd  per  inch-mile  of pipe and have been  used to  estimate
                        future .wastewater flows.

                            Although the methodology used to estimate future wastewater
                        flows  appears basically sound, one further step should be added.
                        Because the  future industrial  flows  were estimated  apart  from
                        domestic and  commercial  flows,  it seems  logical  that  current
                        commercial and  industrial  flows  should not have  been  included
                        in  the total flow  used  to  calculate  per capita flows.   Six
                        hotels (over  200 rooms each)  and one truck stop  currently are
                        served by  the  Ashland  water  system,  using  approximately 89,500
                        gallons of water  per day.   The  flow to  these  facilities will be
                        constant over  the planning period  and  should  be  separated  in
                        order  not  to bias  current per  capita  water consumption  esti-
                        mates. With the  exclusion of this  flow from  the  domestic water
                        consumption, per  capita  flows will  change.  True  domestic flows
                        may then be calculated for the remainder of  the  planning period,
                        based  on the population  projections.

                            Preliminary  calculations  indicate  that  incorporation  of
                        the revised  population  projections  based  on  the 1980  Census
                        figures into  a  revised methodolgy  allowing for  calculation  of
                        exclusively  domestic flows gives a  revised  design flow estimate
                        of  1.27  mgd for  the  year  2003.  Thus,  although  the Town  will
                        need to  reassess its design  flow in  light  of the  changes  dis-
                        cussed above,  it appears that the 1.22 mgd design  flow  used in
                        the Ashland  Draft Facilities  Plan  will  be  acceptable  with  no
                        significant  changes.

EXISTING WATER              The current  Ashland  situation  exhibits an  acute need for
QUALITY PROBLEMS        immediate  action to  upgrade wastewater  treatment.  The  Town
                        of  Ashland,  as  previously discussed,  was  issued  a notice  by
                        the State  Water  Control Board  (SWCB)  on  3  April  1979 to termi-
                        nate the   issuance of  building  permits until  such time  as the
                        critical condition  of overloading  at  the  treatment plant was
                        corrected.  The  consent  order  was  issued  because the  influent
                        flow exceeded  95  percent of  the plant's  design  capacity for
                        three  months  in  violation  of  the  SWCB's  Policy for  Sewage
                        Treatment  Plant  Loadings.  The  consent  order  has  slowed  both
                        commercial and residential growth in  Ashland.

                            Aside from   this  regulatory  constriction,    the   Ashland
                        plant  has  caused  real water quality problems.   Effluent  from
                        the Ashland  lagoon has been  cited  by the SWCB as  the  cause of
                        degradation  in  the  small unnamed tributary  of  Falling  Creek.
                        The lagoon,  although  overloaded, usually  meets   the  secondary
                        effluent limitations,  but the  flows  in  the  small  tributary
                        and in Falling  Creek are  at  times  so low that the BOD load in
                        the effluent  cannot be assimilated.  This  fact  is reflected in
                        in  the stringent limitations now placed  on effluent discharged



                                                        30

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                        to Falling Creek  (approximately  5 mg/1 BOD  and  TSS) .  In addi-
                        tion, the Ashland  facility  has  had  a number  of bypasses  of
                        untreated wastewater.

                             Although groundwater contamination has  not  been reported,
                        failing septic  tank  systems  pose a  potential  serious  public
                        health problem.  The Ashland  area has  been  identified as  a
                        poor soil  area   (Corville-Duplin-Marlboro)   for  septic  tank
                        systems and a  number of  failures  leading to  leachate  seeping
                        into drainage  ditches  and basements  have been  reported.   In-
                        creasing use of septic tank systems with corresponding failures
                        can be expected under an  extended sewer connection moratorium.
                        The potential  of groundwater  contamination and seepage of pol-
                        luted water into basements is a  serious public health problem.
                        Such failures  could  eventually affect  private water  wells  in
                        the Ashland area and potentially  some surface waters  as well.
                        Elimination of the failing systems by connection to the Ashland
                        facility is desirable.

ASHLAND                      Six alternatives for upgrading and expanding the Ashland
ALTERNATIVES            Treatment Plant were studied  in the Draft  Facilities Plan.
                        The six alternatives include  four conventional  treatment  pro-
                        cesses and two  land  application  systems.  The  six alternatives
                        are:

                            Alternative 1:    Aeration  of Existing Lagoon
                            Alternative 2:    Activated Sludge
                            Alternative 3:    Rotating  Biological Contactors
                            Alternative 4:   Oxidation Ditch
                            Alternative 5:    Land Application-Overland Flow
                            Alternative 6:    Land Application-Spray Irrigation

                        Each preliminary design used  for cost estimating and assessment
                        of environmental  impacts  makes  the  maximum  possible  use  of
                        existing facilities, but  some  alternatives were  able to employ
                        more of the existing plant than others.

                             The Town  of  Ashland  requested   the  Virginia State  Water
                        Quality Control Board to  set effluent limitations  for  a range
                        of flows  (volumes) that a separate  Ashland  facility might pro-
                        duce. Those temporary limitations  comprise the design criteria
                        for the six alternatives.  The SWCB limit for  a  design flow of
                        1.22 mgd  is  a  CBOD5 of 22.0  mg/1  (220  Ibs/day).   These  SWCB
                        limitations which  will   be  finalized  soon  will  not  be  more
                        stringent and may be relaxed  somewhat.

                             Along with selection of  one of these  six alternatives, the
                        Ashland Facilities Plan cites  the  immediate  need to  initiate a
                        sewer system  rehabilitation   program.  The  rehabilitation  is
                        detailed in  the  Addendum: Sewer System Evaluation Survey, Town
                        of Ashland, January, 1980.

                             Following is a  brief description of each of the six treat-
                        ment alternatives with probable environmental impacts included.
                        Since almost  identical   environmental  impacts  are  associated
                        with Alternatives 1-4 (the four  conventional treatment proces-
                        ses), they are discussed together.

                             A combined cost comparison  and  a chart  comparing environ-
                        mental impacts of all the alternatives is included in the Sum-
                        mary of this Section.
                                                         31

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Alternative 1;
Aerating Existing
Lagoon

Description
Costs
Alternative 2:
Activated Sludge

Description
     Ashland"s Alternative 1 consists of upgrading the existing
lagoon.  The upgrading would involve enlarging the lagoon to
allow a detention time of 31 days, dividing the lagoon into two
cells, and installing an  aeration system.   These modifications
would increase the capacity of the facility to the required
design flow of  1.22  mgd  and  would improve the  quality  of the
effluent from  the plant,  as  required  to meet the  effluent
limitations.

     The changes  to  the lagoon  would  require  construction  of
a earthen dike to divide it into a two cell reactor. The exist-
ing embankment would be raised  two feet to increase the volume
and therefore  the  detention time.  The  aeration  system would
require the installation  of blowers and air  piping.   The rest
of the  plant  would  be  upgraded  as  well; major improvements
would include upgrading  the pump station, changing the influent
pipe, constructing  an   Administration  and  Laboratory  Building
and increasing the capacity of the existing chlorination facil-
ity.  For this alternative, as for each of  the six alternatives,
it is  assumed  that  the existing  screening facility  would  be
adequate with  only minor  modifications.  Alternative  1 would
require the purchase  of no  additional  land.    Sludge  from the
treatment would remain in the lagoon without substantial build-
up; thus  no  sludge  handling  facilities   would  be  required.

     Alternative 1  (and  all others except  Alternative  6-Spray
Irrigation) would require construction of an effluent pipe with
discharge to the  South  Anna River.  A gravity  flow pipe would
run from the facility to  the discharge  point  at the confluence
of the South Anna River  and Falling Creek,  just downstream from
the U.S. Route 1 bridge  crossing.

     The costs of each Ashland alternative  are calculated as
a capital cost and as a yearly operation and maintenance (O&M)
expense.  For  ease  in  comparison, these are  combined  and pre-
sented in  terms  of  total present  worth,   unit   cost  per 1000
gallons of wastewater treated,  and as  a single equivalent uni-
form annual  cost.   All  costs   are  in  October  1979  dollars.

     For Alternative  1  (Aerating  Existing  Lagoon) ,   the  unit
cost is  $0.45  per  1000  gallon  of  wastewater  treated  or  an
equivalent annual cost of $201,580.

     A conventional activated sludge system is commonly  used
for facilities the size  of or larger than that proposed  for
Ashland. An  activated  sludge  system  provides  a  biomass  of
organisms and the oxygen required  by the organisms to consume
the organics  in  the  wastewater.   The  biomass,  unlike  the
organic material,  will  settle  out of  the water,  and  can  be
recycled and reused in the process.

     Alternative 2 consists  of this type  of  process.    As pro-
posed, the existing lagoon would be abandoned and new treatment
facilities constructed.   The activated sludge  plant  would incor-
porate the existing bar  racks and comminutors.   After screening,
the waste stream would pass through primary clarifiers and into
an aeration basin.  From here the  water would flow  to secondary
clarifiers from  which   the  settled biomass would  be  recycled
back to  the  aeration basin.   The water  would  then go  to the
chlorine contact  basins and  be discharged to   the  South Anna
River.  In  addition  to  the  wastewater  treatment  process,   a
sludge handling  system   would  be  required.   The  sludge from
                                                         32

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Costs
Alternative 3;
Rotating Biological
Contactors

Description
the clarifiers  would  undergo  aerobic  digestion   followed  by
sludge drying beds.   The  stabilized dewatered  sludge  would be
hauled to landfills.

     The physical  facilities  required  for  this  alternative
would include   primary  and  secondary  clarifier   tanks  with
sludge removal equipment, an  aeration  basin with the necessary
compressors, piping,  injectors  and  related  equipment.   The
sludge handling system would  include  the  aerobic digester tank
with mechanical  surface  aerators  and  the   sludge  drying beds.
Alternative 2  also  would   incorporate  the  existing  headworks
and, an  upgraded  pump station,  and would  require enlargement
of the  existing  chlorination  facilities.    An  Administration
and Laboratory Building which would also  house the compressors
is included in the cost estimate.

     Construction of  the activated  sludge  plant would necessi-
tate the purchase  of an  additional 36  acres  of land,  an aban-
doned quarry  north of the  present  site.   The  discharge  pipe
for this alternative  to  the  South  Anna would  be  identical to
the one previously discussed  under Alternative 1.

     The unit costs estimated for construction and operation
of this  activated  sludge plant  are $1.12  per  1000  gallons of
wastewater treated,  or  an   equivalent annual  cost  of $497,567.

     Using Rotating Biological Contactors (RBC's) as the
treatment process  is  the third alternative proposed in the
Ashland Facilities Plan.   RBC's, also called biodiscs, are
composed of a  series of  closely spaced plastic discs  to which
biological growth can attach.  The cylinders formed by the
stacked discs are  placed horizontally  in  a channel, partially
submerged in  the  wastewater.  As  the   wastewater  slowly flows
through the  wafered  cylinder,  the discs  rotate continuously,
exposing the  attached  biomass to the waste  stream and then to
the atmosphere.  The  organisms aerobically  consume  the organ-
ics in  the  wastewater;  adsorbing  oxygen  as they  contact  the
atmosphere.

     The existing lagoon  would be abandoned  in this alternative.
The influent would pass through the existing headworks and then
into a  primary  clarifier.    From  here  it  would   flow  slowly
through the RBC units and into a secondary clarifier. The final
step would again  be chlorination  followed  by discharge to the
South Anna.   The  sludge  handling  system  prepared  for  the  RBC
alternative is the  same  as  that  for Alternative 2; namely aer-
obic digestion followed  by  sludge  drying  beds with the  residue
being hauled to landfills.

     The proposed  construction  under  this  alternative would
include primary and  secondary settling tanks with sludge col-
lection equipment.  Also similar to the activated  sludge alter-
native would  be expanded   chlorine  contact  tanks  and  sludge
handling system.  The rotating biological contactors would con-
sist of  concrete  channels   with  the RBC units mounted in them.
The RBC  units would  also   require  the  equipment  necessary to
drive them. The estimate prepared for this alternative includes
an Administration  and Laboratory Building  and upgrading of the
influent pump station.

     Construction of this alternative would require the purchase
of 15 additional acres of   land north of  the present site.  The
                                                        33

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                        type of  construction  required  for   the
                        be the same as for Alternatives 1 and 2.
                                          effluent  pipe
                                                                                  would
Costs
Alternative 4;
Oxidation Ditch
Description
Costs
Alternatives 1-4
Environmental
Impacts
Land Use
Water Quality
     For Alternative 2 (Rotating Biological Contactors), the
unit cost is $0.74 per 1000  gallons  of wastewater.  The equiv-
alent uniform annual cost is $328,297.

     The fourth alternative proposed in the Ashland Facilities
Plan is an oxidation ditch to provide the secondary treatment
at the Ashland  facility.  The  oxidation ditch  is an extended
aeration type of activated sludge process, which consists of a
ring-shaped ditch with aeration  rotors placed to circulate and
aerate the wastewater.

     Use of  the  oxidation ditch  would eliminate  the  need for
primary clarification  tanks.   The  wastewater  would  flow  di-
rectly from  the  existing  screening   facilities  to  the  oxida-
tion ditch.  From the oxidation ditch the water would flow into
the secondary  clarifiers,  then  chlorinated  and  discharged  to
the South  Anna  River.   The  oxidation ditch  alternative would
have a sludge  handling  system similar to  those  for the activ-
ated sludge and RBC alternatives.

     The facilities required for this alternative would  include
the oxidation  ditch   channel  with  two  rotors,   including  the
driver and motors.  The  secondary clarifiers  would be concrete
tanks with sludge collection mechanisms. Once again, the chlor-
ine contact  facility  would  be enlarged  to  accommodate the 1.2
mgd design flow.  Sludge handling facilities would be the same:
an aerobic digestor  with mechanical  surface  aerators followed
by sludge drying beds.

     The additional  land required  by  this   alternative would
be 15  acres,  located  to the  north  of the  site.   The effluent
conduit to the  South  Anna  River  would  be  identical  to  that
proposed in the three previous alternatives.

     The unit cost for Alternative 4 (Oxidation Ditch) is $0.72
per 1000  gallon  of wastewater.   The  corresponding equivalent
uniform annual cost is $318,743.

     Implementation of any of the six alternatives  is not
expected to change the general trend in land use for the Town
of Ashland.  Growth would be stimulated temporarily by rescind-
ing the  sewer  connection moratorium.   Since  all  construction
for Alternative 1 would be on the present treatment site, the
relocation of  residents  or dedication  of additional  land  for
sewage treatment purposes would  not  be  required.  Alternatives
2, 3,  and  4  would  require  land  in  addition to  that  already
used for  sewage  treatment  (36 acres  for Alternative  2  and 15
acres for  Alternatives  3  and  4).   However,  this land  is  an
abandoned quarry  with  no   current  use  and  no  relocation  of
residents would be necessary.

     As discussed previously in this Section, elimination of
septic tank  systems  by  connection   to   the  Ashland  facility
under any  of the six  alternatives  would remove  the potential
serious threat  of  surface  or  groundwater  contamination  from
failing septic systems.

     In addition, all  of the alternatives would  cause  signif-
icant improvement  in  the water  quality  of  Falling  Creek and
                                                         34

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Biology.
Environmentally
Sensitive Areas
especially the  small  tributary  to  the   creek   to  which  the
effluent from  the  Ashland  facility  is presently  discharged.
The small  stream  is  presently  overloaded,   especially  during
periods of low  flow  or when  untreated  wastewater is bypassed.
Because of the proposed discharge location all the alternatives
would eliminate  any  discharge  to  Falling Creek;  Alternatives
1-4 call  for a  discharge directly  to  the  South Anna  River.

     The South Anna  River would also benefit from implementa-
tion of an upgrading  of the Ashland facility by  any  of Alter-
natives 1 to  4.  A potential adverse impact  to  the  South Anna
River would  be minor  degradation of water quality  at  the dis-
charge point  by  BOD  and  nitrates  in  the effluent  during  low
river flow periods.   The  South  Anna  River experiences  a  wide
variation in  flow  with  a  recorded ten  year minimum  average
seven consecutive day flow of only 14.1 cfs.   (Its average flow
is 362 cfs.)  At low  flow,  the  river  may  not be able to assim-
ilate even  the  secondary  effluent and  minor temporary  water
quality degradation at  the  discharge point  would  be possible.
During construction of  the  discharge pipe,  temporary  sedimen-
tation could  be  expected  in  the  South  Anna.   These  adverse
impacts are  associated with  all   alternatives  requiring  the
construction of a discharge pipe (Alternatives 1-4).

     No permanent adverse impact on terrestrial wildlife would
be expected  from implementation  of  Alternatives  1-4.   Alterna-
tive 1 would  require  no additional  land and  the  extra  land  for
Alternatives 2,  3,  and 4 has  already been  cleared.   The  con-
struction of the discharge pipe would temporarily drive animals
from the  immediate  area.   However,  these would  be  expected to
return once  the  work is  finished  and vegetative cover  is  re-
established.  Wildlife  communities  along  Falling Creek  would
benefit from the improved water in the stream.

     The improvement  to Falling  Creek would  benefit  the biota
of the  creek.   The  communities  in the  South Anna  watershed,
especially near the  confluence  with Falling  Creek,  would also
benefit from  implementation  of  any  of the alternatives. Chlor-
ination of  the  final effluent  must be  carefully  monitored to
avoid any problems with chlorine toxicity.

     The South Anna is classified as a scenic river.  As dis-
cussed above, implementation of any the six alternatives is
expected to  improve  the general  conditions  of  the  South Anna
River.

     A strip  of  land  along  the  South  Anna  is designated  as a
100-year flood  plain   by  the  U.S.  Department  of Housing  and
Urban Development's  National  Flood  Insurance  Program    (see
  Figure  2).   Additional  flow  from  an Ashlanddischarge  would
  minimally  augment  flood  waters.

       The  land  involved  in  the  conventional treatment  alterna-
  tives  is  not  classified  as  a  groundwater (artesian  aquifer)
  recharge  area.  Therefore  no impact  would be expected.

       Since  all  construction for Alternative 1  would be on  the
  existing  site,  no prime  agricultural land  would be  affected,
  nor  would  the discharge pipe  be  routed  across prime  agricul-
  tural  land.   The  additional land  required  for Alternatives  2,
  3, and  4  is not prime agricultural  land (nor  sensitive in  any
  other way).   Furthermore,  no secondary adverse  impacts on  prime
                                                         35

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Summary
Alternative 5;
Land Application
Overland Flow
Description
agricultural land would  be  initiated by any of  the  six alter-
natives, because growth  would be  accommodated  only  inside the
Ashland service area, which  includes  no prime agricultural land.

     None of the alternatives would have  an adverse impact on
an area  of  sensitive  ecology.   The  bottomlands  along  the
Pamunkey River  located  downstream of the  discharge  point, are
classified as  sensitive.  A  shock  load   passing  through  the
plant could conceivably reach this area, but with
considerable dilution.   Because  the  wastewater  is  domestic in
nature, the chance  of such  entering the  plant  is  minimal and
such a  loading  would  be unlikely  to  cause permanent damage.

     None of the six  alternatives involve  land that is consid-
ered historically or  archaeologically  valuable.   Therefore no
impact of this nature is expected.

     Beneficial impacts are expected from  implementation of the
conventional treatment  options:   Alternatives  1   through  4.
Improvement to  Falling  Creek and its small  tributary would be
of major  importance.   The  elimination of  the  potential public
health problems  associated   with  failing  septic tank systems
contaminating both groundwater and small  surface streams would
also be expected from  upgrading  the  Ashland  facility. Expected
adverse impacts would  be minor and  of  temporary duration only
(e.g. construction  impacts).   Alternatives  2,  3, and  4  would
require additional  land  aside  from  that   already  dedicated to
sewage treatment, but  that  land  is  not environmentally sensi-
tive nor would it interfere with existing land use.

     The major difference between the first four Ashland alter-
natives appears  to  be  cost.  Alternative  1  is  significantly
the least  expensive;  Alternative  2  is  significantly  the most
expensive; Alternatives 3 and 4 are  in the middle.

     The final two alternatives examined in the Ashland Draft
Facilities Plan are both land application processes. The first,
overland flow, is considered as Alternative 5.

     In an overland flow treatment system, the pretreated
wastewater is distributed  along  the  top  of a sloped  area of
relatively impermeable soil covered with vegetation.   The
wastewater flows in  a very  thin  layer  down the  slope through
the vegetation.  The  pollutants  in  the water are  removed by
physical, chemical  and  biological means.   The  purified  water
is collected  at the  bottom,  disinfected   and  then  discharged.

     The Ashland overland  flow  site was  selected from a list
of eight potential areas.   Two possible sites were  then
selected on  the  basis  of  amount  of land  available  and  soil
conditions. The  proposed  site  is  adjacent  to  the  existing
treatment site to the north and east.

     In this alternative the  existing lagoon would  be used for
pretreatment. Influent wastewater would flow through the exist-
ing screening facilities and  into the lagoon.   Lagoon effluent
would then be  chlorinated  and stored in  a reservoir. From the
reservoir it would  be pumped to  the application site and dis-
tributed over  the  top  of  the  slope.   After  flowing  down the
slope the water would  be collected,  chlorinated a second  time,
and discharged to the South Anna  River.
                                                        36

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Costs
Land Use
Water Quality
Biology
The overland flow alternative  would  require construction of an
asphalt-lined earth  basin  for  storage  of  pretreated effluent
and a pump station for the distribution system.  The  laboratory
facilities for  this  alternative would  be located  in the pump
house.  Additional  new  construction  would  be  required  for
expanded chlorination  tankage,  which would have to  be larger
than for the  four  previous alternatives  because  the  flow must
be chlorinated  twice  in  separate  basins  of  the  tankage.  The
influent pump station would  also  be  upgraded, but  the existing
screening facilities are assumed to be adequate.

     At the application  site  the  land would be levelled, grad-
ed, and  seeded  with reed  canary  grass.   This grass  would be
harvested and the profit used to  offset  operating  costs.  The
distribution piping  installed  at  the  site  would  be  another
major cost item.  The  runoff  from the slope  would  be captured
in a  series  of  ditches  excavated  at the  bottom  of the slope,
chlorinated, and discharged to  the South  Anna River via a pipe
similar to that in the previous alternatives.

 The land required  for the overland flow alternative would be
an additional 277  acres.  A final requirement  for  this alter-
native would be  construction  of a series of  groundwater moni-
toring wells around the  land application  site.

     A second overland flow  system,  Alternative 5A,  is includ-
ed in the Ashland Facilities  Plan.  This  is the  same  as Alter-
native 5 except for the application  rate used  in  the design.
Alternative 5A uses a lower application rate resulting in addi-
tional land being  required for application and  storage.   With
additional land, the total  area required  for  5A  is 350 acres.

     The unit treatment  cost for Alternative 5 is $0.90 per
1000 gallons of wastewater The equivalent  uniform  annual cost
is $400,860.  (The  unit  treatment cost   for  Alternative  5A is
$0.96 per 1000  gallons  of  wastewater  and  the  equivalent uni-
form annual cost is $427,584.) As a land  treatment  alternative,
this option would  be eligible  for 85%  Federal  funding  of  the
capital costs under  EPA's  innovative and alternative technol-
ogy program.

     Alternatives 5 and  5A would require  a commitment to limit
some land use along Route 1,  adjacent  to the land application
site, because of the proximity of this land to the  site.  Also,
some existing farmland would  be lost  and  relocation of several
residents would  be  necessary.   However,  the  overall  growth
trends and land use in Ashland would not  be affected.

     Impacts from implementation of the overland flow alterna-
tive would  be  similar to  those listed under Alternatives  1-4
for both  surface and  groundwater.   Additional  impacts  asso-
ciated with this  alternative would  include  temporary sedimen-
tation in  Falling  Creek  from the  levelling  and  grading  of
the application  site.    Some  percolation  of  pollutants  to  the
groundwater could  result from  improper  operation  of the land
application site.  However, monitoring  wells  would  be required
to ensure that such percolation would not occur.

     The impacts on aquatic organisms could be expected to be
as listed under Alternatives 1-4.  Impacts to terrestrial wild-
life would also be similar to those of the prevous  alternatives
but considerably more extensive because  some of the  additional
                                                         37

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Environmentally
Sensitive Areas
Summary
Alternative 6:
Land Application
Spray Irrigation

Description
277 acres required  for Alternative 5 have  not  been previously
cleared.  Some  wildlife  migration  would   likely  result  from
implementation of this alternative.

     Potential impacts on prime agricultural land, scenic
rivers, sensitive ecologies and historically or archaeologi-
cally valuable lands would be as listed under Alternatives 1-4.

     The overland flow site lies at the edge of the flood plain
along Falling Creek  (see  Figure 2).  In the event  of a flood,
the vegetation and  equipment at the  site  could  be  damaged  by
the high water  and  a  shock  load  of pollutants could  be swept
into the creek.

     A groundwater  recharge  area   could  be  affected  by  this
alternative. The  application site  borders  the  recharge  area
of the Pamunkey  Group  of the Aquia  Formation.  There  would  be
minimal risk  of  a badly  overloaded system allowing excessive
percolation to contaminate this groundwater.

     The environmental impacts expected from the overload
flow system are  similar to those  for  the  previously discussed
alternatives.  There  are  however   some  additional  adverse  or
potentially adverse  impacts,  involving  the  proximity  of  the
site to a flood  plain and a groundwater recharge area.

     Alternative 5A mentioned in the  review would have similar
impacts, although the additional land required would exacerbate
the adverse  impacts  mentioned  above.   Alternative  5  is  more
expensive than any  of  the  previous alternatives  except Alter
native 2.   Alternative  5A  is  slightly  more  expensive  than
Alternative 5.

     The second  land application alternative identified in the
Ashland Draft Facilities Plan is spray irrigation.  The major
advantage of a spray irrigation system is that no effluent dis-
charge is required.  Pretreated wastewater  is  distributed over
a vegetated area at a rate low enough to allow all the water to
be accounted  for  by  plant uptake,  evaporation  and percolation
to the soil.  Since  the  treatment  includes planned percolation
into the soil,  an extensive  groundwater monitoring program is
an integral part of any spray irrigation system.

     The land application  site  selection was made on the basis
of land availability and suitable soil conditions. The selected
area is located  south of the South Anna River, just east of its
confluence with  the  North  Anna.  This is a flood hazard area,
so construction  would have to include flood protection.

     As with  overland  flow,  the  spray  irrigation  alternative
would use the existing lagoon  for  pretreatment.   The influent
would pass though the existing screens and  comminutors and into
the lagoon.   Effluent  from  the  lagoon would be  chlorinated and
stored in a lined basin.   Effluent would  be drawn  from this
basin, chlorinated again and then pumped to  the  irrigation site.
The water would  be distributed over the site with spray irriga-
tors.  Any  runoff would be  caught  in a  series  of  collection
ditches, recycled to  the  distribution  system,  and  spray irri-
gated again.  The area would be planted with reed canary grass,
the harvest of which  would  be  used  to offset operating expenses.
                                                         38

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Costs
Land Use
Water Quality
Biology
     The new  facilities  required  by  this   alternative  would
include the  lined  storage  reservoir,   an  Administration   and
Laboratory Building  and  enlarged chlorine  contact  tanks.   A
pump station  and approximately  19,000   feet  of 14  inch  force
main would be necessary to pump the wastewater  to the
irrigation site.

     The irrigation  site  would   be  leveled   and  graded  and a
flood protective  dike  constructed.   Runoff  collection ditches
and a  small  pump  station to  recycle  the  runoff   to  the main
stream are also  included  in  the estimate.  The  total additional
land required  for this alternative would  be  approximately  543
acres.

     The unit cost for Alternative 6  is  an estimated $1.63
per 1000  gallons of wastewater.   This  converts  to  an equiv-
alent uniform  annual  cost of  $726,042.  As  with alternative 5,
this option  would  be  eligible for 85%   Federal funding of  the
capital costs under EPA's  innovative  and alternative technology
program.

     The land use trends  for the  Town of Ashland are not expect-
ed to  change with this  alternative.   However,  the  use of  the
selected land  application  site   would   require relocation  of
several residents.

     Improvements in Falling Creek and  the elimination  of poten-
tial groundwater  contamination would result.   The  South Anna
River would  benefit  more  from this  alternative than  the pre-
vious five since there would  be  no discharge  from  the system.

     There are, however,  adverse  or potentially adverse impacts
to water  quality associated  with the  spray  irrigation alter-
native.  Aerosols generated  by the spray  system  would require
a buffer  zone  for  containment.   There  may  be  a   rise  in  the
nitrate level  in  the South Anna   and Pamunkey river during per-
iods of  slow  nitrogen  uptake  by  plants.   A  third potential
adverse impact  on surface waters  would be the danger  of high
concentrations of  pollutants  from the  spray  irrigation  site
being washed  into the   South Anna  by heavy  rains  before per-
colation could  occur.    Finally,   the  extensive  site  grading
necessary for preparation of the   irrigation  field  would  cause
temporary heavy sedimentation  in  the  South Anna.

     Excessive percolation  of  the wastewater   into  the  soil
could possibly  contaminate  the   groundwater,   the  application
rate would have  to be carefully  controlled  to prevent  this.
As previously  mentioned,  a  system  of water quality monitoring
wells would  be  included to  check  for any  groundwater  contami-
nation.

     The biological communities in the  South Anna and Falling
Creek watersheds  would  benefit   from the  elimination  of dis-
charges. Potential adverse impacts to  the aquatic  biota  would
center on  the  potential  for  runoff  entering  surface  waters.

     Construction of the  spray irrigation  system would benefit
wildlife living  along   Falling  Creek  as  would  the   previous
alternatives.  Negative  impacts  to terrestrial  wildlife  would
include loss of  animal  habitat at the irrigation site  and tem-
porary migration  along  the force  main route  from the treatment
plant to the application  site.
                                                         39

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Environmentally
Sensitive Areas
Summary
SELECTION OF THE
MOST FEASIBLE
ALTERNATIVE
     Alternative 6 would affect environmentally sensitive areas
more significantly than Would the previous five. However no
historically or  archaeologically  valuable  lands  or  sensitive
ecologies would be impacted by this alternative.

     The irrigation  site  has  been classified  as  a flood plain
by the  National Flood  Insurance Program (see  Figure  2).   A
major flood could seriously damage or destroy equipment and  the
vegetation necessary  for  the  system  to  work.   A  flood would
also interrupt operation of the treatment plant.  High water or
heavy rains  could  also sweep  untreated wastes  into  the South
Anna and Pamunkey Rivers.  Both of  these  are considered scenic
rivers.  Construction (levelling and grading) at the site would
cause temporary sedimentation in the South Anna.

     The proposed  irrigation  site  lies  in  a  groundwater   re-
charge area known as the Pamunkey Group of the Aquia Formation.
As noted above,  overloading the  site could  lead  to excessive
percolation and contamination of the groundwater. Since this is
a recharge area,  serious  public health problems  could result.

     Finally, the proposed route  of  the transmission line from
the present  Ashland   facility  to  the  application  site  would
cross prime agricultural  land.  Use  of  this  land would be tem-
porarily disrupted during construction.

     The elimination of any discharge by means of spray irri-
gation would  seem  to make Alternative 6  superior  to  the other
alternatives.   However, there would be several offsetting
adverse and  potentially adverse  impacts  associated  with  this
alternative.  Prime  among  these  are the  irrigation site being
located in a  flood hazard area  and  on a  groundwater recharge
area.  Furthermore,  this  alternative  is  substantially  more
costly than any of the previous five.

     The selection of the most feasible Ashland alternative
takes into account economic, environmental and social impacts.
The selected plan represents the best alternative for meeting
these criteria.  Tables 4 and 5 summarize and compare the costs
and environmental impacts of the six alternatives identified in
the Ashland Facilities Plan.

                            TABLE 4

             ASHLAND ALTERNATIVES - COST COMPARISON
                            ALTERNATIVE
                         TOTAL      UNIT
                        PRESENT   COST PER
                         WORTH    1000 GAL
 EQUIVALENT
  UNIFORM     COST
ANNUAL COST  RATING
#l-Aerated Lagoon
#2-Activated Sludge
#3-Biological
Contactors
#4-Oxidation Ditch
#5-Overland Flow
#6-Spray Irrigation
$2,156,447
$5,332,834
$3,512,030

$3,409,824
$4,525,554
$7,766,996
$0.45
$1.12
$0.74

$0.72
$0.90
$1.63
$201,580
$497,567
$328,297

$318,743
$400,860
$726,042
1
5
3

2
4
6
                                                          40

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                                                TABLE  5
                                          ASHLAND ALTERNATIVES
                                    ENVIRONMENTAL IMPACTS  COMPARISON
#1 #2 #3
IMPACTS AERATED ACTIVATED BIOLOGICAL
LAGOON SLUDGE CONTACTORS
Surface Water Quality
Groundwater Quality
Aquatic Biology
Terrestrial Biology
Scenic Rivers
Flood Hazard Areas
Groundwater Recharge
Areas
Prime Agricultural
Land
Areas of Sensitive
Ecology
Historical/Archaeo-
logical Sites
Construction Impacts
Land Requirements
Land Use
Population Growth
Implement ability
++
++
0
+
0
0
0
0
0
-
0
0
+
+
KEY: ++ = Very beneficial impact
+ = Beneficial impact
+H
+H
0
+
0
0
0
0
0
-
-
0
+
0
0
h ++
h ++
0
+
0
0
0
0
0
-
-
0
+
0
= Not impacted
equal adverse
#4 #5
OXIDATION OVERLAND
DITCH FLOW
++ +
++ ++
0
+ +
0
0
0 0
0 0
0 0
_
-
0
+ +
0
by the alternative/
and beneficial impacts
#6
'SPRAY NO
IRRIGATION ACTION
"
+
0
++
0
0
0
0 0
0 0
0
0
0
+
0
- = Adverse impact
— = Very adverse impact
NOTE:  These impacts have not been weighted  in  importance.   Thus  no  quantitative  evaluation  is  presented,

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     The selected  plan  is  Alternative  1:   Aerating  Existing
Lagoon. Alternative  1  has  significantly  lower  costs  than  any
of the  other  alternatives  due  to  the   limited  construction
required.  It should be  noted  that although Alternatives  5  and
6 would  be  eligible  for  increased Federal  funding  of  the cap-
ital cost of  the  treatment facilities,  overall they  are  not
cost-effective compared  to  the  other  alternatives.   Further-
more, from  a  local  viewpoint,   even   with  increased  Federal
funding for Alternatives  5  and 6, Alternative  1 is  still most
economical.

     The only new facilities required under Alternative 1  would
be the  effluent  pipe  and  the  Administration  and  Laboratory
Building. The rest of the construction would consist of upgrad-
ing existing facilities.   No additional land would be required.
Another factor reflected  in the cost is the simplicity of  oper-
ation, with the  result that Alternative 1  has  the  lowest unit
cost.

     The comparison of environmental  impacts  for  the  six Ash-
land alternatives  shows  that the  first four  treatment  alter-
natives have almost identical impacts.  This is  expected,  since
all are conventional  treatment processes with the final product
being an effluent of  equal quality to be discharged at the same
point.  The  only difference  is  in the  land required  and imple-
mentability.  Implementability encompasses factors such as time
until completion and  ease  of approval of the plan.  Since Alter-
native 1  requires  the  least  construction, no  additional land
acquisition, or  relocation  of  residents and  is  a  widely  used,
easily operated  system,   it  is  more  implementable   than  the
others.

     The considerably lower unit  cost  and  the slight advantage
in environmental impacts  make  Alternative 1  the most  feasible
alternative.  A  detailed  description  of this  alternative,  its'
probable environmental  impacts,  and potential  mitigation mea-
sures appear in the next  Section.
                                  42

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                                 SECTION V:   RECOMMENDED ASHLAND ALTERNATIVE


DESCRIPTION                  The most feasible alternative identified in the Ashland
                        Facilities Plan  is Alternative  1,   which  combines  the lowest
                        unit cost with slightly better cumulative environmental  impacts
                        to outrank the other alternatives.

                            Under Alternative  1,  the existing lagoon would be  divided
                        into a  two-cell  reactor, the  volume increased  by  raising the
                        existing embankments,  and  aeration  equipment  installed.   In-
                        creasing the volume would increase the detention  time to  approx-
                        imately 31 days;   dividing  the lagoon into  a  two-cell  reactor
                        would  provide   the operational  control  needed to  produce  a
                        cleaner effluent on a reliable basis.

                             The major  improvement   in  the  treatment process  would be
                        afforded by  addition  of aeration   to  the  lagoon   system.   A
                        lagoon is  essentially  a large  reactor  vessel  in which the
                        organic material  (BOD)  is  consumed  by  organisms  (biomass) in
                        the water.  These  organisms  need  substantial amounts of oxygen
                        to convert  the  organic  material  into food.  In  an unaerated
                        lagoon, the  process  is  similar  to natural  purification  in
                        rivers and  lakes,  and  sufficient volume  must  be  provided to
                        avoid overloading  of  the  lagoon.  When  the  loading rate to the
                        lagoon increases beyond  the natural  reoxygenation  capacity of
                        the water, the  result is depletion   of the  dissolved oxygen in
                        the water.  The growth  and  activity  of  the  biomass are  limited
                        and the BOD oxidation stagnates. By  aerating the lagoon, oxygen
                        is re-supplied by  mechanical means,  and  the load-limiting  fac-
                        tor is shifted.  Besides  supplying the necessary oxygen  for the
                        process, aeration  mixes  the wastewater  in  the lagoon, ensuring
                        that the biomass will contact the organic matter present in the
                        water and also that the flow will be distributed throughout the
                        lagoon so  that  short-circuiting  of  the  intended  flow  pattern
                        will not occur.

                             The proposed  aeration  method for the   lagoon  is  known as
                        "tapered aeration."   Tapered aeration  involves  the  injection
                        of greater  quantities  of air at the  inlet  of  the  lagoon and
                        diminshing quantities  as one  moves  toward  the outlet.   The
                        rationale behind tapered  aeration is that  the  greatest demand
                        for oxygen is at  the  inlet  area where the  BOD  is highest.  As
                        the BOD  is  removed, the  oxygen demand lessens.   The objective
                        of tapered aeration  is to  match  the quantity of  air injected
                        to the  oxygen  demand  profile,  with  a  resulting   savings in
                        aeration cost.   Another  benefit  of  tapered aeration  is   that
                        the biomass in the system will settle as  the  mixing effect of
                        the aeration decreases with the tapering off of air injection.

                             A flow  chart   of  this   alternative  appears  in  Figure 4.
                        The influent  wastewater  is   screened with  the  existing facil-
                        ities and then pumped  to the south  end  of  the  modified lagoon
                        through a  new  influent   pipeline.   Effluent  from  the  lagoon
                        flows into the  upgraded  chlorine contact  tanks.   After chlor-
                        ination, the  effluent  is discharged to the South  Anna  River
                        through a new gravity flow discharge line.    The discharge  point
                        is at the confluence of  the South Anna and  Falling Creek,  just
                        downstream from the U.S.  Route  1  bridge  crossing.   A plan  view
                        of the proposed  facility and  the route  of  the  discharge  pipe
                        is shown in Figure 5.

                             Of the six  alternatives, Alternative 1 would  require the
                        least construction.   Existing  facilities  would  be  used   with
                        upgrading or addition.   Following is a  list of the major  items
                        required for construction of this alternative:



                                                        43

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                                               Figure 4
                                FLOW CHART OF ALTERNATIVE  1
                                                            TAPERED AERATION LAGOON
           BAR SCREEN   COMMINUTOR
                                      PUMP STATION
Q = 1.2 MGD,
  SCREENINGS TO  LANDFILL
                                                            CELL 1
             CELL 2
                                    ADMINISTRATION & LABORATORY
                                           BLDG + BLOWERS
                                         GRAVITY DISCHARGE
                                           TO SOUTH ANNA
                                                                Q = 1.2 MGD
BOD ^ 22  mg/1
                                                                            CHLORINE  CONTACT

-------
                                    DISCHARGE
                                       SOUTH
31  AERATED
V%)|  LAGOON
  \
} / •oj"ft---4^.;;""•"""- \ /'! .<-. j*»**4.-•
f A V^rv^^*"-'- i'^.-'"-' ,L   '" F'eld7SV" '
^  XS^\^H^ .., isw^:«vfevt
1 L^.^^^^--^~^^C..\s4^
""*"   \   /" ^s ; •""'S!^i"S":: "-^ ;''i \2-"- ''.' '^T^V^l
     j'  ..'-,• ji ^ fehflofrfllr^  r'T^T ^tii^'TT;^"-^-"^

!./ "•   *     . .Wum*f,L--  /
^BMSa*—--'   ,- . " ' ,^\  I /.  •;'/
                                                           Figure 5
                                                  TOWN OF ASHLAND
                                                        SITE PLAN:
                                                 Aerating Existing Lagoon
                                         45

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ENVIRONMENTAL IMPACTS
AND MITIGATION
MEASURES
Socioeconomic
        Influent pump station upgrading
        Influent pipe and structure modification
        Earthen dike for lagoon
        Intercell piping
        Raising of existing embankment
        Blower, air piping and associated equipment
        Effluent structure
        Administrative and laboratory building (will
        also house blower)
        Additional chlorine contact tank and chlorination
        equipment
        Discharge pipe to South Anna

     Of the above  items,  the discharge pipe  is  by far the most
expensive.  The pipe and  discharge  represent approximately 40'i
of the total  estimated  construction  cost.   All  of  the  alter-
natives, except spray irrigation,  require  construction of this
component.  As mentioned  in  Section  IV,  effluent from the Ash-
land facility  can  no longer be  discharged  to  Falling  Creek,
making the  long  effluent line  to  the South Anna a necessity.

     The preliminary design  assumes  that  the  existing facili-
ties can  be used  with  modification  or upgrading  and  can  be
operated during  construction.  The headworks (for  screens and
comminutors) are assumed  to  be adequate with  only  minor modi-
fication.  The  existing  pump  station  would  be   used  with new
pumps and  auxiliary  power equipment  installed.  The  capacity
of the chlorination facilities would be increased to the design
flow of 1.2 mgd.

     Besides upgrading the treatment  plant,  the Ashland Facil-
ities Plan  identifies as a second part of the wastewater treat-
ment plan  a  sewer  rehabilitation  program.   The Ashland collec-
tion system  suffers  from excessive   inflow and  infiltration
which must be reduced in order  to  be within required EPA levels.
The rehabilitation program  is  detailed  in  the Addendum:  Sower
System Evaluation, Town of Ashland, January  1980.

     The combination of  eliminating  the excessive  I/I and up-
grading the  treatment plant  will  enable  the  Town of Ashland to
meet the  BOD effluent  limitation of  22  mg/1 set by  the  SWCB.
In meeting  this limitation cost-effectively  and environmentally
for the design flow, Alternative 1 appears to be  the most  feas-
ible course of action for the Town of Ashland.

     The environmental impacts associated with Alternative 1
are almost  identical to those for the other  three conventional
treatment  alternatives,  as discussed in Section IV.  The major-
ity of  the impacts are  beneficial, expecially  with respect to
water quality and  aquatic biota.  There are, however,  some tem-
porary or  potentially adverse impacts inherent  in this project.
Probable or  potential environmental  impacts  from and  suggested
mitigation measures  for  Alternative  1   are  described  below.

     The unit cost of Alternative 1 is $0.45 per  1000  gallons
of wastewater  or  an  equivalent annual cost  of $201,580.  Fed-
eral funding  is  available for  75% of  the  construction cost of
wastewater  treatment  plants.  The  operation expenses  must be
borne solely  by  the  user of  the facility.   The total  construc-
tion cost  for  this  alternative  is  $1,212,200.    The  Federal
share (assuming  maximum  possible  funding)  would be  $909,150,
                                                      46

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Land Use
Water Quality
and the  local  share $303,050.   The  yearly  O&M   cost,  borne
solely by the  local  residents,  is estimated  at  $88,266.   On a
unit cost basis, these  costs  amount  to $0.19 Federal share and
$0.26 local share per 1000 gallons of wastewater treated. These
figures yield  equivalent  annual  costs of $84,986  for the Fed-
eral Government and $116,595 for the local residents.

     To acquire the  funds necessary  to support the local share
of the facility, two basic types of financing are possible: the
floating of revenue bonds and/or  the  creation of special assess-
ment districts.  Essentially, revenue  bonds  are  secured by the
revenues received  from  the operation  of the  facility.   Rates
for water usage would be established and users would be billed
according to  their consumption.  A  special  assessment district
would vary  from the  aforementioned  financing alternative  in
that a geographic  boundary would be drawn which  includes only
the beneficiaries of the project, and these residents and busi-
nesses would  be  taxed at a rate which produces  enough revenue
to pay the debt and operating costs of the facility.

     In the  Ashland  Draft  Facilities  Plan,  the  user  charges
necessary to  cover operation  and maintenance costs and to ser-
vice the  revenue  bonds have  been  estimated.   The  Facilities
Plan recommended  a  $600.00  connection  charge and  an  initial
bimonthly service  charge of $7.00,  with  increases  to $8.50  by
the year  2000.   These   user charges  would apply only to those
serviced by the Ashland  facility.

     The availability of wastewater treatment is not  expected
to change land use trends  for  the  Town  of  Ashland.  Removing
the sewer moratorium will allow temporarily restricted residen-
tial and  commercial  growth  to  resume.   Construction  of  the
upgraded facility will not require acquisition of any  more land,
and no residents will be  forced to relocate.

     The most  significant improvement  in surface water quality
will be  to  the  small,  unnamed tributary  of  Falling Creek  to
which the effluent from  the  lagoon  is discharged.   The SWCB
has cited the  Ashland facility  as  the  cause  of  degradation  of
water quality  in this small stream.   Once the discharge to the
creek is stopped, the natural  process of  purification can begin.
Significant improvement  will  also occur in  Falling  Creek.  The
present facility  has also  overloaded  this   creek,   especially
during periods of bypasses and of low stream  flows.  With  imple-
mentation of  the alternative, the presence of effluent in Fal-
ling Creek will be eliminated.

     The South Anna  River will  also  benefit  from the construc-
tion of  the  aerated lagoon.   Although  the  discharge  will  be
directly to the river,  the effluent will be consistently cleaner
than the water that  has been coming  from Falling  Creek, espe-
cially when  facility bypasses  have  occurred. Temporary water
quality degradation  near the  discharge  point  may  occur during
times of low  river  flow.   The  South  Anna  is subject  to wide
flow variations with a  reported  ten-year minimum average seven
consecutive day"  flow of  14.1  cfs.    (The  average   flow  is 362
cfs.) At extremely low  flows the river may  not be capable  of
immediately assimilating  the secondary effluent from  the  facil-
ity.  Minor  water  quality  degradation  from BOD  and nitrates
may occur  during  these  periods.    Another   potential  adverse
impact to the  South  Anna involves  effluent chlorination  before
discharge.  The chlorine dosage rates must be closely monitored
                                                        47

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Biology
Environmentally
Sensitive Areas
to prevent any chlorine  toxicity  problems.   Temporary sedimen-
tation at the discharge point can be expected from construction
of the effluent pipeline.

     Elimination of  failing  septic  tank systems  will benefit
the small streams  in  the area.   The leachate from these septic
tanks often  enters  and  degrades  these  streams  via  drainage
ditches.  Connection  of  these  sources  to the  upgraded collec-
tion system will eliminate this problem.

     An even  greater  benefit derived  from  the  elimination of
failing septic  tank  systems  will  occur with   respect  to the
quality of  local  groundwater.   Although contamination  of the
groundwater has not been reported, the possibility poses a dif-
ficult to correct problem once incurred.

     The potential  adverse  impacts  above  should  be minimized
by implementation of the following mitigation measures:

     o  Close monitoring of chlorine dosage rates;
     o  Careful operation of the facility, especially
        during periods of low flow;
     o  Use  of  sediment and  erosion  controls  during  stream
        corridor construction;
     o  Buffer  zones  between  sewer   lines  and  stream  beds
        incorporating riparian vegetation  when  available; and
     o  Berms  or  filtering  devices  such as hay bales between
        routes and streams.

     The terrestrial wildlife indigenous to Falling Creek would
benefit from  the  improved water  quality.  No permanent adverse
impact is  expected on  terrestrial  wildlife.   Construction of
the pipeline  will temporarily  drive off  animals.  After  con-
struction they can  be  expected to  return once  vegetative  cover
is reestablished.   The  construction  at  the plant  is  on the
present site.   Therefore no  permanent  animal  migration  from
construction of the facility is anticipated.

     Aquatic biota would benefit  from  construction of the aer-
ated lagoon.   The  major beneficiaries  would be  the flora and
fauna in Falling Creek and the small unnamed tributary to  which
the lagoon currently  discharges.   The  communities in the  South
Anna would also  benefit from the general  improvement  in  water
quality.  Again,  the  final  chlorination of  the  effluent  would
have to  be  closely monitored to prevent any chlorine toxicity
problem.

     Mitigating measures  recommended to alleviate  impacts on
biota are as follows:

     o  Stream  erosion  controls  previously  mentioned   under
        water quality - siltation dams,  buffer zones,
        filtering devices
     o  Revegetation of all cleared areas;
     o  Construction  of  stream  crossings   during  periods  of
        minimal biological activity  (winter months).

     The South Anna is classified as a  scenic river.   The
implementation of Alternative 1 will improve the water quality
of the  river.   A  detailed  description   of  probable  impacts  is
contained in the previous section.
                                                      48

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                             Land along the  South  Anna River  is  designated  as  a 100-
                        year flood hazard area  by  the  National Flood Insurance Program
                        (see Figure 2).  The additional flow  from the  Ashland facility
                        will minimally  augment  the  average  flow  of  362  cfs,  not  to
                        mention the flows expected at flood stage.

                             The land  involved  in this alternative is  not  considered
                        a groundwater recharge  area.   Therefore no impacts are expected.

                             Since all  construction   for  this  alternative  is   on  the
                        existing site,  no  prime  agricultural  land  is  involved.   The
                        proposed route  of  the  effluent pipe  does not cross  any prime
                        agricultural land,  nor  is any growth on prime agricultural land
                        expected to occur as a  result of this project.

                             Alternative 1   should  not.  affect  any areas  classified  as
                        ecologically sensitive.  Well downstream of  the discharge point,
                        the bottomlands of  the  Pamunkey River  are considered ecologic-
                        ally sensitive.

                             The land  involved  with  this alternative is  not  considered
                        historically or archaeologicaily valuable.

                             Since no  environmentally  sensitive areas  will  be affected
                        by Alternative 1,  no mitigation measures are required.

Summary                      The net results of the Alternative 1 environmental impacts
                        are beneficial.  Surface water quality would improve dramatic-
                        ally in Falling Creek  and the  small  tributary  into  which  the
                        lagoon now discharges,  improving  conditions for both  aquatic
                        and terrestrial  biota.   Equally   important  is   removing  the
                        potential public health danger of  failing septic tank systems.

                             No permanent adverse  impacts  are  anticipated  from  imple-
                        mentation of  the  proposed  project.   Mitigation measures  for
                        temporary construction   impacts on  water  quality and  aquatic
                        and terrestrial  biota   could  be  managed  as  outlined  above.
                        Additional mitigation  measures  to  minimize  adverse  noise  and
                        air quality  impacts during  construction  and  operation  could
                        include:

                            o   Muffling devices on pumps  and other treatment plant
                                equipment;
                             o  Appropriate design as well  as O&M procedures to
                                control odors;  and
                             o  Fugitive dust controls at  construction sites.

                             The results of the   total  project,   including  treatment
                        plant improvements  as well as the  sewer rehabilitation program,
                        will benefit the area  and solve the  Town of  Ashland's  sewage
                        treatment problem in the  most cost-effective  and environment-
                        ally sound manner possible.
                                                      49

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INTRODUCTION
PLANNING AREA
EXISTING NEEDS
            SECTION VI:  PHASE I EXTENDED ALTERNATIVES

With  the  separation  of the  Town  of Ashland  from  the Phase  II
planning area, Hanover  County  was faced with a question  of  how to
best  address  existing and expected  needs within  the  remainder  of
Phase  II  in a manner  which  would take  into account  the economic
and environmental  concerns raised during  the Phase  II  Facilities
Planning  effort.   After  months  of   local  study  and debate,  the
County  arranged  for   an   environmental  consulting  firm  (Patton,
Harris, Rust, and  Guy,  Inc.) to  complete  Facilities  Planning for a
reduced study area designated  as "Phase  I  Extended".   (See  Figure
1) •

Concurrent with this  Facilities  Planning,  the County embarked  on a
new growth  management  program to ensure that  future development
will  proceed  in  an  orderly,  planned  manner.   New  goals  and
objectives were adopted by the County for  land  use  management and
provision  of services,  which  specified  that  development   in  the
next  twenty  years should  be concentrated in four  "urban"  service
areas  :    Mechanicsville,   Ashland,   Hanover   Courthouse,   and
Doswell.  Once  development has materialized  in  those  areas, other
County  areas   would   then  be   serviced,   including   the   upper
Totopotomoy  River  Basin above  Route 643  and an  expanded  Doswell
service  area.   Public  utilities goals  and  objectives   were  also
outlined,  consistent  with the  above land  use  planning  goals  and
objectives,  from  which   Phase   I   Extended  Facilities  Planning
assumptions were derived.

As  directed by  the  Board of  Supervisors,  the  Phase  I  Extended
planning area represents  a significant reduction  in  size from the
previous  Phase  II  area  (even  without  Ashland).   The  revised
planning area reflects  a  desire  of  the County  government to solve
existing needs, to encourage  future  growth in  a  more  compact  area
that  is  readily   manageable,  and to allow  for  more financially
feasible alternatives  to  be  developed.   A  major  change  from Phase
II  has been the elimination of  the   Totopotomoy  River Basin {with
the exception of  two  existing  developments)  from the planning  area
due to environmental concerns.

The heart  of Phase I  Extended  lies  along  the  Route  1 -  Interstate
95 corridor  south  of  the  Town  of Ashland, encompassing land  as far
west  as the RF&P   railroad, and  includes  the  wedge of  land  east of
1-95  bordered  by  Routes   656  and   657.   Additionally,  Phase  I
Extended  includes  a  "connection" area  northwest  of  Phase  I along
the Chickahominy  River between  Routes  656  and 301,  and  south of
Route  637.   The  connection   area   includes  the  subdivisions  of
Totopotomoy  and   Kingswood  Court.    Oak  Hill  Estates,   located
directly   southwest   of  Ashland,   was   included   for  study  but
addressed separately because of  its  isolation from the above areas.

As  described in  the  Draft  Addendum Facilities  Plan for Phase I
Extended,  there  are  presently eleven wastewater  treatment  systems
in  the planning area,  operating  under a State Water Control Board,
Consent  Order  requiring  these systems to  upgrade  their  level of
treatment.   Table 6  lists these facilities.   Additionally, there
are   numerous   instances   of    septic   tank   failures   scattered
throughout  the  planning   area,   as  described  in  the  Draft  EIS.
Although  alternative  wastewater  treatment  solutions  are  geared
towards improving  or  eliminating the major discharges, some  or  all
of the on-lot system  failures  may be rectified via  the  alternative
solutions  described  later.  If  not,  they must be dealt  with  on  a
case-by-case basis by local and  State health  authorities.
                                                  51

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CAROLINE  COUNTY
         IGURE  6

_ Jtob^ AREA a :

^INITIAL SERVICE AREA
  ,;: HANOVER COUNTY . VIRGINJA
            DENOTES STUDY
            AREA
            DENOTES INITIAL
            SERVICE AREA
                                                UY
                                           .^vgwm-t
                          3

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co
    Name

1.  Chickahominy River Basin
      A.  Kosmos Village


      B.  Oak Hill Estates


      C.  Hanover House
          Restaurant § Motel

      D.  Colonial Estates


      E.  Stony Run Subd.

      F.  Lakeridge Ind'l. Pk.


      G.  Mobil

      H.  Hanover Air Ind'l.
          Park


      I.  Beechwood Farms
     II.   Totopotomoy Creek Basin
            A.  Kingswood Court


            B.  Totopotomoy Subd.
            C.  Blue Star Estates


    III.   Campbell River Basin
            A.  Speed and Briscoe
                Truck Plaza
                                                          TABLE  6
                                             Existing Sewage Treatment Facilities
                                      Type of Treatment
Single cell stabilization lagoon, chlorina-
tion, discharge to Stony Run.

Two single-cell stabilization lagoons,
chlorination, discharge to Stony Run.

Two single-cell stabilization lagoons,
chlorination,. discharge to Stony Run.

Single-cell stabilization lagoon, chlorina-
tion, discharge to Chickahominy River.

Individual septic tanks and drainfields for
each lot.
Individual septic tanks with a central
drainfield.

Individual septic tanks and drainfields.

Three single-cell stabilization lagoons
followed by land application sprinkler
system.

Two single-cell stabilization lagoons,
chlorination, discharge to Chickahominy
River.


Single-cell stabilization lagoon, chlorina-
tion, discharge to Totopotomoy Creek.

Single-cell aerated lagoon followed by clar-
ification and sludge holding tanks, chlori-
nation, discharge to Totopotomoy Creek.

Single-cell stabilization lagoon, chlorina-
tion, Totopotomoy discharge.


Two single-cell stabilization lagoons, chlor-
ination, discharge to Campbells Creek.
Est'd. Flows


 0.033 mgd


 0.04  mgd


 0.025 mgd


 0.033 mgd


 0.003 mgd

 0.02  mgd


 0.003 mgd

 0.03  mgd



 0.055 mgd




 0.02  mgd


 0.05  mgd



 0.015 mgd




 0.011 mgd
                                                                Comments
                                                                                                   111 trailer lots plus
                                                                                                   18 campsites.

                                                                                                   120 hook-ups


                                                                                                   Receives pumped effluent
                                                                                                   from Fleming's Truck Plaza

                                                                                                   122 trailer lots.
                                                                                                    27 lots.

                                                                                                    Light industrial area.
212 lots.




 67 hook-ups.


205 hook-ups.



 60 homes.

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POPULATION
PROJECTIONS
As part of updating the County Comprehensive Plan, the County
Planning Department  has  projected future  population and  land use
for   the   Phase   I   Extended   planning   area.    The   projection
methodology  uses   preliminary   1980   census  figures   and  data
developed by the State Department of  Planning and Budget.  Table 7
summarizes the population projections used by the County.

                              TABLE 7

                 Population Projections 1980-2002

                        Hanover County, VA
                           January 1981
YEAR

 1980
 1982
 1987
 1992
 1997
 2002
                                                    HANOVER COUNTY
                                                POPULATION GROWTH RATE
                                          YEAR

                                           1980
                                           1982
                                           1987
                                           1992
                                           1997
                                           2002
                   YEAR

                    1980
                    1982
                    1987
                    1992
                    1997
                    2002
                                                   50,219 (1)
                                                   53,000 (2)
                                                   60,500 (2)
                                                   67,300 (2)
                                                   73,400 (2)
                                                   79,900 (2)
                                           2.8%
                                           2.4%
                                           1.8%
                                           1.7%
                                           1.7%
                                                  PHASE I SERVICE AREA
                                                POPULATION GROWTH RATE
11,890 (3)
13,772 (4)
16,972 (4)
20,251 (4)
23,164 (4)
26,277 (4)

7.2%
4.3%
3.6%
2.7%
2.6%
                                                   PHASE I (EX) AREA
                                                POPULATION GROWTH RATE
3,578 (3)
3,804 (4)
6,084 (4)
7,703 (4)
9,109 (4)
10,617 (4)

3.1%
9.8%
4.8%
3.4%
3.1%
WASTEWATER FLOW
PROJECTION
As  can  be  seen,  roughly  a   tripling  of  growth  within  Phase  I
Extended  (from 3578  to  10,617)  is  expected within  the  next 20
years.   Although  this  may  appear  to  be  a  high  rate   it  is
consistent  with  the  County's  desire  to channel  growth  into the
"urban service areas,  and represents a  far  lower  number of  total
people  to  be  accommodated  than  under  the  Phase   II  plan without
Ashland  (10,617  vs.  approximately  20,000).   However,  because of
the  relatively  high growth  rate,  it appears that  phasing  of any
new  wastewater  treatment facilities  will  have  greater  than  usual
potential and should be seriously considered.

The wastewater flow generated by existing and future growth
was  calculated  by  the  County  based  on   the  above   population
projection and water  consumption records from Phase  I and Phase I
Extended customers.   The following  methodology  is  taken from the
County's April  1981  Draft Facilities Plan  and would  be  used as a
design flow for alternatives involving sewering.
                                                54

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EVALUATION OF PHASE I
EXTENDED ALTERNATIVES
                       The residential/commercial  use  of water  as  reviewed was  equal to
                       226 gallons  per connection  per  day, or  approximately  78  gallons
                       per  capita  per   day  (gpcd)  at   current   household  densities.
                       Assuming  that   only   80%  of  the   water   consumed  is  returned  as
                       wastewater, the  estimated  per capita wastewater  flow is:   0.08  x
                       78 gpcd - 62.4  gpcd.

                       It is estimated that  infiltration  from new sewer  line construction
                       will be held  to  the  required   (by  Virginia  State  Water  Control
                       Board)  200 gpd/inch-mile, and that future "non-excessive I/I" will
                       be held  at approximately this value through  a strict maintenance
                       program and  the benefits  derived  from improved sewer construction
                       materials.   At  the present time, the  Phase  I  sewage  collection
                       system  consists  of   930.42  inch-miles   of  sewer  pipe  which  is
                       presently  serving  approximately  5,000  people, but is  available to
                       service the existing  area  population of   11,980.   It  is  reasonable
                       to assume  that  the density  of development and related  sewer lines
                       in Phase I is representative  of future densities  to  be expected in
                       the total  area  within Phase I and Phase  I Extended.   The  ratio of
                       interceptor   collector   sewers   to   available    population   is
                       930.42/11,980 - 0.078  inch-miles  per  capita.  Use  of  this value
                       with  the  "non-excessive   I/I"  value  of  200  gpd/inch-mile  will
                       result  in  a  per capita non-excessive  I/I allowance  of  0.078 inch
                       miles/capita x 200 gpd/inch mile - 15.6 gpcd.

                       Current  industrial development  in  the  Study  Area   is  relatively
                       light,  but the  County expects this  to increase significantly with
                       sewer  availability in Phase  I  Extended.   To  provide  capacity for
                       this  expansion,  EPA   allows a  per-capita  allowance   for  future
                       nonspecified  industrial wastewater  flows   of  10%  of  the  total
                       design  flow  or  25%   of  the  total  industrial  flow,  whichever  is
                       greater.

                       The above  projected  per-capita wastewater  flow rates  and  volumes
                       result  in the following values:
                              Residential/Commercial
                              Industrial Allowance
                              Non-excessive I/I

                              Total:

                       Future wastewater flows  (2003)
                                            62.4 gpcd
                                             6.0 gpcd
                                            15.6 gpcd

                                            84.0 gpcd
                              Phase I           26,277 persons x 84 gpcd = 2,207,268 gpd
                              Phase I Extended  10,617 persons x 84 gpcd -   891,828 gpd
                              Total:
                         36,894 persons x 84 gpcd = 3,099,096 gpd

                            Say  3.1  MGD
Both  the  per  capita flow  figures  used and  the  overall projection
methodology  appear  to  be  sound  and  have  taken  into  account
suggestions made in  the  Draft  EIS.   The  estimated Phase I Extended
flow  of  approximately  900,000   gpd   is   less   than  half  of  the
previously estimated Phase II  flow  (minus  Ashland).   Assuming that
the  base  population  projections used are  supportable,  EPA will
accept as reasonable the above flow projections.

Combining the foregoing  information regarding updated
conditions   with   previous    Facilities    Planning   reports   and
suggestions made in  the  Draft EIS and by  interested  citizens, the
County  was  able   to   focus  on  four  possible  strategies  for
wastewater management for the Phase I  Extended area:
                                                55

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                       (1)   Upgrade/optimum  operation  of  existing  facilities  with  no
                       centralized  sewering

                       (2)   Collection and treatment (at a) within-County AWT  plant,  with
                       discharge  to either the  Totopotomoy or  Pamunkey River

                       (3)   Collection and  treatment at  a within  County  land  treatment
                       facility

                       (4)   Collection and transport to  Henrico County for treatment

                       (Treatment options for  Oak  Hill Estates  are  discussed  separately
                       in a later section of  this report.)

Service Area           The  initial  service   area  is seen as  the  "panhandle"  area  from
	~           Phase I to  1-95 along  the  Chickahominy and  below Route  637,  and
                       the Stony Run  and Lickinghole Creek  basins  as far  northwest  and
                       north  as   Kosmos  Village   and   the   Industrial   Air   Park,
                       respectively.   Also    included   is   limited   service   to   the
                       subdivisions  of  Totopotomoy and   Kingswood  Court  for  ultimate
                       development  of each subdivision only,  not beyond.

                       The initial  service area would   provide  wastewater  collection  and
                       treatment  for  ultimate  flows  to  the following  existing  wastewater
                       treatment  systems, judged to be  currenty inadequate  to  meet  the
                       levels  of treatment   required  for  discharge  to   the  Chickahominy
                       River Basin.

                            Kosmos  Village                         0.033  mgd
                            Colonial Estates                        0.033  mgd
                            Flemings Truck Plaza                   0.010  mgd
                            Hanover House                          0.015  mgd
                            Lakeridge Industrial Park              0.020  mgd
                            Industrial Air Park                    0.030  mgd
                            Totpotomoy Subdivision                 0.076  mgd
                            Kingswood Court  Subdivision             0.020  mgd
                            Beechwood Farms  Subdivision             0.055  mgd

                       With  the   exception  of  the  Totopotomoy   and   Kingswood  Court
                       subdivisions,  no   service  is  initially  anticipated  within  the
                       Totopotomoy River  Basin; however, pressures  do  exist for  including
                       additional  Totopotomoy   development,   as  evidenced  by   a  recent
                       request from Blue   Star  Estates to  be considered within  the Phase I
                       Extended solution.

                       The nature of  the  Phase  I Extended  area  is such that service could
                       be  phased  in  as  needs  materialize,   provided that  the current
                       "problem"  systems  are  improved immediately.

                       It  should be emphasized that these most  recent  alternatives  were
                       studied in  the context  of the Board  of Supervisor's desire  for a
                       reduced scope  service area,  recognizing the  separation  of Ashland
                       as  a fait accompli.   The solution  for Phase  I  Extended  may still,
                       however,   be  considered  "regional"  in  the   sense  that   it  will
                       address several existing problems  occurring  within a  broad area,
                       and be  flexible enough   to  accommodate anticipated  needs  over the
                       next twenty years.

                       The  following  descriptions  are  taken  from   the  April  1981 Draft
                       Facilities Plan for Phase I  Extended.   Further reference  should be
                       made   to    that   report    for    more   details.    Environmental
                       considerations  are discussed separately  for  Alternative  1,  then
                       collectively for Alternatives 2-4,  as  the  latter  three essentially
                       share a common sewer  network and  differ  only in their  method of
                       treatment.
                                                    56

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           FIGURE  7
     Existing    Sewerage
     Discharge     Points
     HANOVER COUNT Y.VIRGINIA
            SCALE   IN FEET
       0   400O  8000   12000  16000
    PATTON, HARRIS.  RUST AND  GUV  	  P.O.
CONSULTING ENGINEERING — LAND SURVEYING — PLANNING
                FAIRFAX , VIRGINIA

                                       3377

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Alternative 1 -        Alternative 1 consists of upgrading existing treatment systems
"Limited Build"        within the service  area  so that  they  will comply with  applicable
                       effluent limitations.   It is  the  only  of  the  four  alternatives
                       which does not involved  a centralized  sewer network.  However,  it
                       is not  in  EPA's view,  a  "no-action"  alternative,  as  it  would
                       provide   improved service  to  a  number  of  currently  inadequate
                       wastewater   treatment  systems.    It  is  also  not  a  "no-growth"
                       alternative?   future  growth would occur  without  the  provison  of
                       public  sewerage  through  the  continued  use  of  package  treatment
                       systems   for   individual  developments  or   by   individual   on-lot
                       treatment systems, primarily  septic tanks.

                       Costs for this alternative were  estimated  by assuming an  advanced
                       level of   treatment  would  be  applied  to  each  of  the  systems
                       requiring  an   upgrade.    The   construction  cost   estimate   of
                       $3,108,500  is  competitive with  the other  alternatives;  however,
                       operation and maintenance costs are the highest  of any  alternative
                       since no economy of  scale can be  realized,  making the  total  cost
                       over   the  entire planning period  relatively  unattractive.   (See
                       Table 8).
                                             58

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                                         TABLE 8

                     ESTIMATED COSTS - LIMITED BUILD ALTERNATIVE ONE


Treatment System
Kosmos Village
Colonial Estates
Hanover House
Laker idge Ind'l.
Park
Hanover Ind'l.
Air Park
Totopotomoy
Kingswood Court
Beechwood Farms
Total:
Average Cost
$/l,000 gals
Total
Construction
Cost*
$390,500
390,500
345,000

330,000

365,000
501,500
330,000
456,000
$3,108,500

"
Amortized
Cost
$/l,000 gals.
3.03
3.03
3.53

4.23

3.12
1.69
4.23
2.12
-

2.73

O & M Cost
$/l,000 ga-ls.
4.21
4.21
4.75

5.57

4.21
2.18
5.57
2.78
-

3.64
Total
Cost
$/l,000 gals.
7.24
7.24
8.28

9.80

7.33
3.87
9.80
4.90
-

6.37
* No allowance made for non-construction costs -- land acquisition,  site work,
  electricial, engineering,  legal and contingencies.

Source:   Draft Addendum - Facilities Plan - Phase I Extended, Patton,  Harris Rust & Guy
         - April 1981.
                                           59

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                       This alternative  was  determined not  to  be an  acceptable solution
                       by the  Facilities Planning consultants  because of high  costs and
                       the lack of growth control it provides.

Environmental          A number of impact categories may be affected by implementation of
Considerations         this alternative.   The discussion  will  focus  on  those  key areas
                       which involve the most  profound effects  and which  should be given
                       primary consideration in deciding which solution to pursue.

                       Primary, or direct,  impacts  occurring from actual  construction of
                       the  facilities'   improvements  will  be  minimal  and  acceptable,
                       assuming that  most  of the  upgrades  will  be  accomplished  on  or
                       adjacent   to   existing  treatment   sites.    No  construction   of
                       collector or interceptor  sewers is anticipated, thus  avoiding any-
                       direct disturbance of resources beyond the treatment plant sites.

                       The  water   quality   of   the   Stony   Run,    Lickinghole   Creek,
                       Totopotomoy, and Chickahominy Rivers will  be  enhanced  by improving
                       the quality of  effluent now  discharged  into those  water courses.
                       However, there  will  continue  to  be  numerous  effluent  discharges
                       into the  above  streams,  as  existing and  future  growth will  be
                       accommodated  by  a  number  of  separate  systems.    Additionally,
                       malfunctioning  or  marginally operating  individual  septic  systems
                       will not  be collectively addressed  under  this alternative,  but
                       handled on  a  case-by-case  basis  as  the  need  arises.   This will
                       mean a slower rectification of  those  problems with  a corresponding
                       strain on  local  government resources, and possibly on  surface  or
                       groundwater quality   in  the  short-term.   However,   this  does  not
                       imply that  properly  installed and operated on-site  systems cannot
                       be relied upon as a longer-term  solution  in  areas  with proper soil
                       conditions.

                       Indirect growth-related  impacts under this  alternative  appear  on
                       the  surface  to  be  negligible,  as  the  facilities  improvements  do
                       not  provide capacity  for  future  growth.   However,  by  forcing
                       future  development  to be  accommodated  via   on-site  or  package
                       treatment  systems,  the limited  build alternative  will  cause  the
                       pattern  of development  to  be  more  widely   dispersed  and  less
                       manageable   from  a  local  governmental  viewpoint.   Location  of
                       future  development will  be  more  dependent   on  suitable  soils,
                       possible effluent  discharge  points,  and  local  growth  controls
                        (e.g.   zoning,   subdivision   ordinances)   than  on   location   of
                       interceptor sewers.

                       Assuming similar growth attractiveness and pressure  in the  Phase  I
                       Extended area with  or without  the provision of  central  sewerage,
                       this alternative  will cause more  land area  to be  developed than
                       the others  because  population  density  will be less  than  under  a
                       sewered  alternative.    While  quantifying  indirect  impacts  under
                       this alternative is difficult,  it  is  reasonable to  assume that the
                       total amount of  land  disturbed, or  altered  from its  present use,
                       will  be at  least  as  much   as under  the  sewered  alternatives.
                       Although   termed   "limited   build",   this   alternative   could
                       conceivably  cause  the  loss   of   significant   amounts   of  prime
                       agricultural land,  woodlands,   and  wildlife  habitat.  Again, this
                       conclusion  is  based on an assumption  of  equal growth pressure with
                       or without  provision  of public  sewers.   The County  could  diffuse
                       these  negative  effects  with  an  agressive   program   of  land  use
                       management  and  control.
                                                   60

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Alternative 2
Hanover County
AWT Plant
Impacts  from  the  limited  build  alternative  on  the  sensitive
ecologies  of  streams  in  the  planning  area,  particularly  the
Chickahominy and Totopotomoy, will depend  on  the  control exercised
by local governments concerning location of  new development.   Some
direct  impact  on the  streams  will  occur,  although water  quality
will  be  improved,   as  effluent  discharges  continue  into  these
streams.  The  increased wastewater  load  generated by  a  projected
7,000 additional people in  Phase  I Extended area  by the  year 2002
can  be  absorbed without detriment  to these streams provided that
the systems sewage treatment are properly operated and  maintained.

A  more  subtle  but  significant  effect  is  likely to  occur  from
non-point source  runoff generated by the  roads,  driveways,  roofs,
parking   and   other   impervious   areas   associated   with   new
development.   As  noted  in  the  Draft  EIS,  regardless  of  the
alternative selected, non-point runoff will have  a great  effect on
water quality  of  County streams.   The  SWCB  estimates   that  97% of
the phosphorus  load  on  the  Chickahominy  River  comes from non-point
sources.  The  assimilative  capacity  of  the  streams and  filtering
action  of wetland  areas can buffer some of  this  runoff pollution;
however, it is  recommended  that the  County strictly enforce strict
sediment  and  erosion  control  ordinances,  or   like  measures  to
ensure  that  the carrying  capacity of these  streams is  not unduly
overburdened.   A  non-point source control  program should  also be
established  through  local-State cooperation to  protect especially
sensitive  watersheds,   such  as  the  Chickahominy  and  Totopotomoy.
The  rationale  for  such  a  program  was outlined  in  a SWCB memorandum
in December, 1980.

Alternative 2 consists  of collection  of all wastewater  flows
and  treatment by Hanover County in an advanced wastewater
treatment plant with effluent discharge to  either the Totopotomoy
or the  Pamunkey Rivers.

The  base  system  serving  the  Stony Run  and   Lickinghole  Creek
drainage basins in Phase  I Extended  is  shown in  Figure    .   This
system  is  presented  here  because it is an  element  of  the  total
wastewater  collection  system  common to  other  alternatives  to be
considered.     It   consists   of    the   following   sewer    lines:
approximately   1,400  feet  of  8"  diameter,  7,000  feet  of  10"
diameter,  3,700  feet  of  12"   diameter,  and  12,900   feet  of  15"
diameter; one  minor  pumping station  serving  Colonial  Estates and  a
larger  pumping station serving the  entire drainage basin  located
at  the  base  of Sliding  Hill.    Sewer  line  sizing  is approximate
only,  and  is  a  function   of  either the  projected 20-year  flows
within  the  drainage  area,  or  the  degree  to which limited  slopes
exist  in areas  where sewer  will be provided.   Pumping  stations are
sized  for  costing  purposes to  handle  year  2002  flows,  although
initial  design may  provide  for  lower initial  flows  to facilitate
proper  operation.

This  base  system provides  service  to  six  (6)   of   the  existing
wastewater  treatment   systems  and   additional   land   for  initial
growth   in  residential,  commercial  and  industrial   development.
Either  the  Lakeridge or Air Park  interceptors would be designed  to
allow   interceptor   extensions  up   Lickinghole   Creek  with  final
determination  of  the  most effective approach being  dependent  on
actual  on-site  surveys.
                                                  61

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       ewtetov
                     Campgroun
                                     Airport'
           iKEff
r\
         SEWEF
                           AVITY
                              ,'JJX
                         STATION
'/I
    STA.
                                \
                            \
                 FIGURE 8
           MAJOR SEWER ROUTES
               UPPER SECTION
         PHASE I EXTENDED AREA
                 (BASE SYSTEM)
             KXX)  O   KXX)  2OOO  3000
                  SCALE  IN FEET
 / fii 62
/ ^iHoll    PATTON,HARRIS, RUST AND GUY 	 p C.
 £>-4^. I CONSULTING ENGlNEEFdNG —LANOiSURVEYING —PLANNING

-------
Regardless  of  discharge  point, the  level  of  treatment  required
under  Alternative  2  will be  advanced  and  relatively  expensive.
The  State  Water  Control  Board  has determined  allowable discharge
limiations,  (wasteload allocations)  for  potential discharge points
on  the  Totopotomoy and  Pamunkey Rivers.   These are  presented in
Table  9.   The relatively expensive  consideration  of pumping  the
effluent to Nelsons Bridge on  the  Pamunkey  (61,600  ft.)  would have
to be evaluated  against  the  unquantifiable  impact  of  discharge to
the   Totopotomoy  and   its    critical,   environmentally-sensitive
areas.   For purposes  of initial  cost  comparison, discharge  has
been assumed to be to the Totopotomoy.

                              Table 9

                          Effluent  Limits

               Pamunkey  River  near Nelson's Bridge
                   Effluent Discharge =3.0 mgd


DO  (mg/1)                 CBOD5  (mo/1)            TKN  (mq/l>
  6.73                        21.0                       1.0
  6.73                        18.0                       2.0
  6.73                        15.0                       3.0
  6.73                         8.0                       5.0
                 Totopotomoy Creek  above Route  643

   Effluent
Discharge  (mgd)    DO  (mg/1)    CB055  (mg/1)    TKN  (mg/lj

      0.5              6.0           16.0             20
      1.5              6.0           11.0             20
      2.1              6.0             9.0             20
      2.7              6.0             7.0             20
      3.5              6.0             6.0             20

Source:  Virginia State Water Control  Board


The  treatment  plant   itself  is shown to  be  located   within  the
Chickahominy  River  basin  and the  County  Board-delineateed service
area, although  many  valid arguments do exist  for  placement within
the  Upper  Totopotomoy  drainage basin (above  Route 643).   It  is
recognized   that  many  problem   spots  and   areas  of  marginal
suitability   for  septic   systems   are   not   covered   by   this
more-limited  service  area.    Nonetheless,  it  is  the  Board  of
Supervisor's  and County  Staff's  determination  that   solution  of
these smaller problem  areas with a wastewater  collection system at
this   time   will   have    its   initial   benefits   significantly
overshadowed    by    the    adverse    environmental    impact    of
presently-unwanted    residential    and   commercial    development.
Initial limitations to the  service area were also deemed necessary
to  allow  development  of  a   solution  solving  the   areas  worst
problems, while  remaining affordable to the  ultimate users.

Estimates of  cost for  this  alternative, including  the  costs of the
"base system" are presented in  Table  10,  and will be compared with
other alternative costs in  a subsequent section.

Environmental   considerations   are   discussed  collectively   for
Alternatives  2-4.
                           63

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                                                           PUMP STATION
                                                               SEE  FIGURE,
                                                               FOR COMPLETE
                                                               VIEW OF SYSTEM
                                                               LAYOUr/
             Hermttige-Ethelwood
         /7> /-AS Country Club
                                                                     EX. SAN. SEW.
              FIGURE  9
TREATMENT AT 0.9mgd  AWTP
   IN  HANOVER   COUNTY
     ALTERNATIVE TWO
1000   0   1000  2000   3000
     ssssssssssssssss
      SCALE  Ik FEET
     RATION, HARRIS. RUST  AND GUY-	
CONSULTING ENGINEERING —LAND SURVEYING
            FAIRFAX , VIRGINIA
                      — P. C.   I
                      —PLANNING!

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                                         TABLE 10
                                     ALTERNATIVE TWO

                 ESTIMATED  COSTS  -  HANOVER COUNTY  0.9  MGD TREATMENT PLANT
Item
                               Construction
                                   Cost
                       O & M
                       Cost
Base Sytems:
  1,800 LF   4" forcemain
  1,700 LF -  8" san. sewer
  7,300 LF - 10" san. sewer
  3,800 LF - 12" san. sewer
 12,850 LF - 15" san. sewer
    300 LF Tunnel under Rte. 95
    Colonial Estates Pumping Station
    Sliding Hill Pumping Station
Subtotal:
  3,500 LF
  2,500 LF - 12'
  8,400 LF    8
  5,700 LF - 15'
  9.700 LF - 18
forcemain
forcemain
san. sewer
san. sewer
san. sewer
  Totopotomoy Pumping Station
Subtotal
  Pamunkey discharge:

  0.9 MGD
  Effluent Pumping Station
  61,600 LF 12" forcemain
Total Cost:
                                   Total:
$   21,600
    43,400
   227,200
   136,500
   539,700
   120,000
    64,800
   351,400
$1,504,600

$   52,500
    62,500
   235,200
   239,400
   455,900
   103,600
$1,224,800
                                $1,166,420
                                   334,500
                                 1,540,000
                                $5,694,620
                             =  532,320/year
                             =$1.62/1,000 gals
                              2.21/1,000 gals.
$    70
    160
    810
    410
  1,920

  7,080
 12,530
$22,980/year

 $   150
     160
     920
     930
   1,850
   8,180
$12,430/year
                       $130,860
                         23,920
                          3,970
                       $193,920/year

                        $0.59/l,000gals.
Totopotomoy Discharge:

  0.9 MGD AWTP
  Effluent Pumping Station
  9,500 LF 8" Forcemain
                                $1,827,200
                                   200,000
                                   171.000
                                $4,851,900
                                   435,545/yr.
                                  = $1.38/1,000 gals.
                          Total:    $2.17/1,000 gals.
                       $208,520
                         15,040
                       	630

                        259,360/year
                        $0.79/1,000 gals.
                                          65

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Alternative 3          Alternative 3 involves use of the "base11 collection system
Land Treatment         defined earlier.   All wastewater  flows  from this  area  would be
                       collected  and pumped  to  the  land application site via  the Sliding
                       Hill  Pump  Station.   The  panhandle   of   Phase   I   Extended  and
                       Totopotomoy and Kingswood Court subdivisions  would be  served by an
                       interceptor extended  along  the Chickahominy  from Phase  I  (Craney
                       Island) .

                       The treatment  system would  include primary  treatment  by aerated
                       lagoons,  chlorination,  minimum  60-day  storage capabiity, pumping
                       to distribution,  spray  irrigation and  collection and  recycle for
                       zero  discharge.    Overland   flow   and   infiltration/percolation
                       methods of  land  application were rejected in favor  of irrigation
                       based  on  effluent  quality,  land  requirements,   soils  limitations
                       with respect to  depth and  percolation  rate, and  potential impact
                       on groundwater  quality.

                       The land application  alternative was  reviewed extensively  in the
                       Preliminary Draft  Facilities  Plan,  the Expanded  Scope Facilities
                       Plan,   the   Draft  EIS  and  the  Ashland  Facilities  Plan.   Design
                       criteria  used herein  is  similar,  including applicable requirements
                       of the State Water Control Board.  Application sites,  as developed
                       and screened  in  these  documents,  were  evaluated  as  potential
                       sites.   The use of separate sites was ruled out due  to the expense
                       of duplicate facilities.  Site  #2 has  been used  in  this  report as
                       a potential site and serves  as the basis for cost  calculations.

                       Site #2  is the  one  closer  to Sliding  Hill Pump  Station  and is
                       characterized by  cleared  farmland,  thus  avoiding  some  of  the
                       environmental  and  cost  impacts  from   additional   clearing  and
                       grading.   The possibility  that  most sites  investigated  are  in  a
                       critical  groundwater recharge area may  require added protection by
                       the installation  of  an   underdrain collection system.   Total  area
                       requirements are  approximately  280  acres, including  the  required
                       400-ft.  buffer  zone on all  sides.   Crossing of the  site  by public
                       roads   would possibly require  additional  land  for  buffer  zone
                       requirements.

                       If land application becomes the selected alternative,  a first step
                       in the overall design procedure  would  be  the verification of site
                       suitability for  land  treatment,  including analysis of  floodplain
                       limits,  soil composition and  depth, and  groundwater  level,  flow
                       rate and direction of movement.

                       The costs  for this  alternative are  shown  on Table  11.   Costs for
                       transmission from  Sliding  Hill  Pumping Station  to the  treatment
                       site have  been  kept  separate  to allow  analysis  of  costs  for  land
                       application at  other potential sites.
                                             66

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                                        TABLE 11
                           ESTIMATED COSTS FOR LAND TREATMENT
                                    ALTERNATIVE  THREE
Item
I.
II.














III.


Base System
Land Treatment Components
A. Pre-Application
B. Pumping
C. Storage
D. Field Preparation
E. Distribution
(Center Pivot Spray)
F. Recovery
G. Administration & Lab
H. Monitoring Wells
I. Roads and Fencing
J. Chlorination
K. Plant/Cultivate/Harvest
L. Land
M. Transmission to Site 2
Sewering Lower Phase I
Extended Area
Totals:
Capital Costs
$1,504,600

83,700
188,400
429,700
49,500

163,700
255,500
96,300
7,300
131,000
62,800

843,000
1,518,000
935,200

$6,168,700
0 & M Costs
$22,980

22,000
7,340
2,600
-

29,370
9,900
14,130
4,000
3,420
5,570


12,350
52,070*


                                                     576,636/year
                                                     1.76/1,000 year
                   260,930/year
                   0.80/1,000 gals.
Total Cost:                                      $

* Includes costs for treatment in Henrico County.
2.56/1,000 gals.
                                          67

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Alternative 4
Hanover Collection,
Henrico Treatment
Alternative 4 consists of the collection and transport of all
wastewater flows in Phase I Extended to Henrico County for
treatment.  Use  would be made  of the  existing  Phase I  system
Beaverdam  Pumping  Station  and  Chickahominy  interceptor.   The
general  alternative  considered  involves   the  "base"  collection
system  reviewed  earlier,  the  Sliding  Hill  Pumping Station,  a
pumping  station  serving  the  Totopotomoy  and  Kingswood  Court
subdivisions, and approximately 18,500  lineal  feet of interceptor
sewer along  the  Chickahominy River  to  a connection  with  Phase I
at Craney  Island Estates.   See Figure    .   Minor  variations to
this  flow routing  have also  been  considered in  an attempt to
arrive at the minimal cost approach.

This alternative would  not  require any  upgrading  or expansion to
the  existing Phase  I  system  during  the   entire   20-year  study
period.  A review  of capacity  available  in the existing  Phase I
sewerage  system,  compared  to  existing  and projected  wastewater
flows  in both  Phase  I and  Phase  I  Extended,   indicates  that
adequate   capacity   exists   in   the   Chickahominy   (Phase   I)
interceptor  for  year  2002  flows  from  Phase  I  Extended  and  for
Phase  I  at  an  ultimate  capacity  of   10   persons  to  the   acre
(original  designs  planned  for  an  ultimate  density of  only  8
persons per acre).  As  reviewed earlier,  the projected wastewater
flows from both  Phase I and Phase I  Extended  have  been estimated
at 3.1 mgd.  Hanover  County currently has  a contract with Henrico
County for treatment  capacity of  3.0  mgd in their  existing sewage
treatment plant.  Henrico County,  through  the  EPA  grants process,
has initiated construction on  a system  of  new interceptors,   pump
stations  and  a  30  MGD  sewage  treatment  plant   (year  2005).
Because  of  funding uncertainties,  no fixed date  has  been  given
for  project  completion,  although  1988  has  been  cited  as  a
possible  completion time.    The design  for  these  facilities  has
included  3.7 MGD  capacity   for   Hanover  County   for  year   2005
wastewater flows.   The  plant will  be  expandable  and has indicated
potential Hanover Couny wastewater flows to  it of 5.4 MGD.

Thus, under  the current planning  assumptions  and  resultant   year
2002 flows of 3.1  MGD, it  is not  expected  that  any modifications
will be necessary to  the existing  and proposed Hanover facilities
or  to  the  Henrico  County Facilities,  until  after the  20-year
planning period.

It is  unrealistic  to  predict  future populations  and their  exact
locations  beyond   this  initial   planning   period,  although  it
appears  that a  significant  amount  of  capacity   will  still be
available  in  both  County  systems  at this  time.   Availability of
capacity and ease  of  expansion are two  positive elements  of  this
alternative.   It  is also apparent that  this alternative provides
additional flexibility to  Hanover  County.   If  at  some  point in
time  Hanover requires  capacity  beyond  what  Henrico County  can
provide,  or  if   Henrico treatment costs  become  too  expensive to
justify  contracting for additional  capacity,  Hanover  will  still
have  their backbone system of  interceptors  and  pumping stations,
and would  be able  to consider construction of their  own sewage
treatment plant  to  handle  part or all  of  their  wastewater flows.
The  existence  of  a  larger  service  population  at  this  point in
time  would  also  serve to   reinforce   the  feasibility  of   this
consideration.   The   County   of   Henrico  Wastewater  Facilities
Planning  Study,  January 1977,  with update  costs  in October 1977,
estimated  charges  to Hanover  County of  approximately  $0.50 per
thousand   gallons   for  transportation   and  treatment   of   its
wastwater.   Delays  in construction  funding, however, have pushed
back  the  project completion time  from  1982 to, at the earliest,
1988.   The many uncertainties' involved  in  financing this project
    unknown   grant   money    availability,   different   project
                                                  68

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construction times,  separate bond  programs and  related  interest
requirments     all  combine  to  make  it  extremely  difficult  to
estimate what  this final  cost  will  be.   The  Henrico  Facilities
Plan  (Appendix  15)  in its detailed  financial  analysis,  indicated
project 0 & M costs  (with  inflation  allowance)  to be at least 50%
of  the  total   cost  per  thousand  gallons.   Even   if  the  final
construction cost is  twice the  October 1977 estimate,  they would
only increase the total cost per  thousand gallons by 50%  (2 x 50%
+ 50%),  or  to  approximately  150% x  $.50   - $0.75/1,000  gallons.
Current estimates of  total construction costs  for  Henrico  County
are  now estimated  at $151  million,  a  98.7%  increase  from  the
original estimate.  To  be on the  conservative side, it has  been
assumed  that  the costs  to Hanover  County  will  be  approximately
$0.75/thousand  gallons.   This  value  has been combined with  the
costs for the Phase  I Exended facilities to provide a  total  cost
per  thousand gallons  for  service to Phase  I Extended -  See Table
12.
                        69

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                                        TABLE 12.
                      ESTIMATED COSTS - TREATMENT  BY HENRICO COUNTY
                                    ALTERNATIVE FOUR
Item
                                       Construction Costs
                                                               0 & M Costs
Basic System:

  1,800 LF -  7" forcemain
  1,450 LF -  8" san. sewer
  7,300 LF - 12" san. sewer
  3,800 LF - 12" san. sewer
 12,850 LF - 15" san. sewer
    300 LF tunnel under Rte. 95
    Colonial Estates Pumping Station
    Sliding Hill Pumping Station
Subtotal:
  3,500 LF
  2,500 LF
  5,900 LF
  5,700 LF
 12,800 LF
Subtotal:

Total:
   6" forcemain
- 12" forcemain
   8" san. sewer
- 15" san. sewer
- 18" san. sewer
   $21,600
    43,400
   227,200
   136,500
   539,700
   120,000
    64,770
   351,400
$1,504,600

    52,500
    62,500
   162,200
   239,400
   103,600
$1,224,800

$2,729,400

 0.78/1,000 gal.
   $70
   160
   810
   410
  1920

  7,080
 12,530
 $22,980/year

    150
    160
    600
    930
  8,180
$12,430/year

$35,410/year

 0.11/1,000 gal.
Treatment Costs at Henrico County = $0.75/1,000 gallons
Total Cost:
                         $1.64/1,000 gallons
                                            71

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Environmental
Considerations -
Alternatives 2, 3,
and 4
Primary Impacts
However, uncertainty exists  as  to the applicability  of this  rate
to  Hanover  County  exists  with   respect   to   the  use of   sewer
wholesale  rates  and  the  method  used  for offsetting Henrico's
capital  costs.   Thus,  for purposes  of  this  initial  comparison,
use  of  the  value of $0.75  per  thousand   gallons  appears  to be
reasonable.

As  a variation to  this alternative,  consideration was  given to
two  alternatives  4A and 4B which  allow  for transport  of  most of
Phase  I  Extended  wastewater   flows   to  Henrico   County  at the
Interstate 95 crossing  of  the Chickahominy  River in lieu of  using
the  Phase  I  Facilities.   (Figures   and    ).  While comparable in
total cost  to  Alternative 4, it  should  be noted  that:  1)   these
alternatives  do  not  allow  service  to  the  entire  panhandle of
Phase   I  Extended;  2)   they   limit  somehwhat   the  County's
flexibility  to  provide  their own  treatment plant  in the future;
and, 3)  Hanover rejected  the option  of utilizing Henrico's Turner
Run  interceptor before  it  started  construction and would now  have
to  negotiate  with  them  for  an  allocation   of  a   portion  of
Henrico's future capacity needs.

Based  on  this,  the   Facilities  Plan  rated   Alternative   4  as
preferable to 4A  or 4B, and utilized  this  in  the  cost comparison
with other alteratives.

Alternatives 2, 3, and  4 all share the common feature of a
sewer network, which with minor variations, serves  the  same
areas of Phase I Extended, follows similar  routing  patterns,
and will cause similar  environmental effects.

Primary  effects  from   construction  of  collector   or   interceptor
sewers along or across  stream beds  include increased erosion and
sedimentation deposits.   The proposed  sewer network avoids,   where
possible,  placement of  sewer  lines  directly  within  streambeds;
however,  the  significant  cost  savings   realized  from  use  of
gravity  sewers  vs. forced  flow sewers  dictates that  many   lines
follow  the  general contour  of  stream valleys.   The temporary
adverse  impacts  expected  from  these  sewer   placements  can  be
minimized  through  the   use of  standard engineering practices for
sedimentation   and   erosion   control.     The   adverse   impacts
associated with stream  crossings  are  potentially  significant and
should  be addressed  carefully prior  to  construction.   In   some
cases,  the effects  can be  minimized by  jacking   the  sewer   pipe
beneath  the  stream  bottom itself.   In  others,  installation via
cofferdams  may  be  appropriate.    Consultation   should  occur   with
local  or State soil  and  water conservation  agencies  to  ensure
that proper techniques  are employed.

Many of  the  sewer  lines will  lie  within  or  near floodplain areas,
as  delineated in  Figure 2.   While  this will not necessarily  cause
any  direct adverse  effects,  care  must be taken during  design and
construction  to  1)  avoid  location   in  floodplain  areas   where
possible  and  2)   to  ensure  sound  construction   techniques are
utilized  to  minimize  any potential damage  should   flooding occur.
Alternative  3  is  the most  susceptible to   direct  flood damage as
the  land application sites  themselves  lie within a  floodplain.
The   Federal   Emergency   Management   Agency   (FEMA)   now   has
responsibility  for  the  National  Flood   Insurance  Program and
Executive  Order No. 11988 on Floodplain Management.   They should
be   consulted   regarding   specific  mitigative   measures   for
construction of wastewater facilities within a  floodplain.
                                                72

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                       Other primary impacts which  can  be expected from  Alternatives  2,
                       3, and 4 are similar  to  those discussed in the Draft  EIS,  but  to
                       a  lesser  extent  since  the   service  area  has  been  considerably
                       reduced  in  scale.    Indeed,  the  direct  impacts   related   to
                       construction  in  the  Totopotomoy  River  Basin  will  be  all  but
                       eliminated since this area was  removed from consideration  (with
                       minor exceptions)  for service during the 20 year planning period.

Secondary Impacts      The  most  significant  potential  impacts  from   the  three  sewered
                       alternatives are those  secondary effects which could  result from
                       the development accommodated  by  the central wastewater  treatment
                       facilities.   Depending  on  its  location,  this  development  could
                       adversely   effect    such   environmental   resources    as   prime
                       agricultural lands,  wetlands, wildlife habitats,  and  terrestrial
                       and  aquatic  biota.   Hanover  County  has instituted a  new General
                       Policies  Plan  (GPP)  through a  Growth  Management  Program  which
                       provides the basic  framework  necessary to control growth  and  the
                       detrimental    environmental    effects    which    can    accompany
                       uncontrolled  growth.    The   effectiveness  of  this  program  will
                       depend on the degree to which the  County is willing  to strictly
                       adhere to the planning goals embodied in the Plan.

                       Alternatives  2-4   represent  potentially   both  promising   and
                       pessimistic   future   scenarios   for    the   County.    A   sewered
                       alternative   will greatly assist the  County in accomplishing  the
                       goal  of  locating  future  growth  in  the  "urban"  service  areas,
                       provided  that other  aspects  (of  the  GPP)  are  also  implemented.
                       However,  provision  of   a  sewer  network  for   Phase  I  Extended
                       without a strong  County commitment  to sound land use  management
                       could result in  significant negative consequences.

                       Among  the issues  of  greatest  public  concern are  those  potential
                       growth  impacts  on   the  Totopotomoy Creek  Basin wetlands,  future
                       water  supplies  (due  to  interbasin transfer) and  water/wastewater
                       relationships,  impacts  on  prime  agricultural  land,   and on  the
                       general rural character  of the area.   There will be  some  effect
                       on these  characteristics with or  without a sewered  alternative.
                       Under  the sewered  alternatives  (2,  3,  and 4),  the  environmental
                       effects will be generally  less  severe than if  the same  amount  of
                       growth were  handled  with  on-site or  package   systems,  primarily
                       because less total land area  would  be disturbed.  One  potential
                       negative  effect  of   the  sewered  alternatives  is  the  increased
                       pressure   to   connect   existing   and   future   systems,   and
                       subdivisions, lying outside  the  Phase I Extended area  but  within
                       the Totopotomoy River Basin.   This  pressure will be  strong along
                       Route  301   North,   and   eastward   along  Routes  643   and  606.
                       Connection   of   existing   subdivisions   would   eliminate   some
                       scattered pollution  problems,  but  the  presence of an  interceptor
                       sewer  would  tend  to  direct  growth   into  this  area  prematurely.
                       This action could strain the  carrying  capacity  of  the  Totopotomoy
                       Creek,  potentially  creating   an   even  larger   environmental
                       problem.  Measures  to minimize this effect  include  strict  County
                       application   of  available  growth  controls,  and careful  routing,
                       sizing, or phasing  of sewer lines.

                       Introduction of  public sewers into the  Phase I  Extended  area will
                       tend  to accelerate growth there  initially,  but long  term  demand
                       depends on  many other   growth  attractiveness   features, such  as
                       roads, schools,  taxes, and aesthetic  appeal.  That is,  sewer,  per
                       se, do not create a demand for growth;  rather  they can serve as a
                       catalyst,  or a tool for growth control.
                                                    73

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Treatment Method
Costs
In the  longer  term,  it  is probable  that equal  growth pressures
will  occur  with  or  without  public  sewers,  on  a  County-wide
basis.  Therefore, a key question becomes  whether it  is best, all
factors considered,  to  address  pollution  problems  and expected
growth in  the  Phase  I  Extended area via continued  use of on-site
and private package treatment  systems, a  central  sewer system, on
a combination  of the two,  where sewers  are phased-in  as growth
materializes sufficiently to enable citizens to afford them?

Under  the  sewered  Alternatives,  three  treatment  options  are
available:   advanced  wastewater  treatment  at  a  within-County
facility  with  stream discharge   (Alternative  2)  ,  land treatment
within  County  without   a  point  discharge   (Alternative  3),  or
transport  to  Henrico   County   for   treatment    (Alternative  4).
Environmentally, Alternative 4  is preferable as  it would address
needs  while  preserving  and  enhancing  water quality  in  Hanover
County  more  effectively  than  the  other  two alternatives.   One
negative environmental effect  of  Alternative 4  is  that  up to 1.0
mgd  of  water   will  be  diverted   from   the  Chickahominy   (and
minimally the Totopotomoy) to  the James River Basin.   This is not
expected to jeopardize future  water  supplies of  the County or the
Town of Ashland, based on projected  safe  yields  of the South Anna
and  Pamunkey  Rivers.   However,  the  County must  take  care  to
ensure that  adequate  water  supplies are  available  in conjunction
with any improvements made for  wastewater treatment facilities.

A  Hanover  County  AWT  plant   (Alternative 2)   is  technically
feasible,   but  less environmentally desireable  and a  more costly
option.    The  VA   SWCB   has  issued  effluent   limitations  for
discharge  into  either the  Totopotomoy or  Pamunkey  Rivers.   The
impacts  from  either  discharge  option  could be  significant  in
several categories, given present  environmental  conditions.   This
is  not a  recommended  alternative  now,   but  could  become  more
attractive  later  during  the  planning  period  depending  on  how
growth  occurs,  and  how  treatment  costs  compare  relative  to
Henrico County's treatment costs.

The land  treatment option  (Alternative 3) is desireable from the
standpoint of  requiring  no stream  discharge,  and  because  of its
feature of recycling  and  reuse of nutrients  and  other resources,
is  encouraged  by  the Federal Clean  Water  Act.   Its two  main
drawbacks here are high  initial  construction costs  and the  large
amount of  land required  for transportation,  treatment, and buffer
zones.   Additionally,  the  two  potential  treatment  sites  lie
within    groundwater     recharge    areas,    requiring    special
precautionary measures and monitoring.  The  land  treatment option
should not be  ruled  out totally,  however.   It could  be employed
for  a  portion  of  the Phase  I  Extended  area  or  for  individual
subdivision  or  commercial  treatment.   Land  treatment  remains  a
technology   which   is   supported   by   EPA   and  would  be   an
environmentally acceptable alternative for Hanover County.

Perhaps  the  most  determinative  factor  as   to   which  wastewater
treatment  solution  is chosen  will  be the  ability of  the County
government and  residents  to   afford  the  local   share  associated
with  each system.  The  existing  Phase  I system has  been  beset
with  financial  problems  requiring  supplemental   assistance  from
the  County's  general revenue  fund.   Many  County  residents have
voiced concern  over  embarking on  a new  financial program  for  a
Phase  I  Extended  wastewater  system  when   the  existing  Phase  I
financial situation has  not resolved.   In  addition, the future of
EPA's  Construction Grants  Program  is  uncertain  due  to  funding
cutbacks and policy changes.   Although the  Phase I Extended area
is on  the State priority list as  an EPA  fundable  project,  there
is some doubt as to whether Federal  money will  be available, even
at a reduced percentage rate, when the County is  ready  to proceed.
                                                      74

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Summary of Phase I
Extended
Alternatives
To assess this  situation,  the County recently  contracted  for the
preparation of  a  report entitled  "Financing  Alternatives  for the
Hanover County phase I  Extended Wastewater  System Project".  This
report  analyzes  various  financial  options   for   the  Phase  I
Extended alternative,  assuming that no  Federal  (EPA)  funds will
be available.   The report  concluded that  the  least  cost,  least
risk method of financing is to:

o   Fund the  residential  area  east  of  1-95   (Segment  1)  with
Farmers Home Administration low-interest,long-term loans.

o   Fund  the  commercial  area east  of  1-95   (Segment  2)  with
conventional  financing  of  lease/purchase  financing  or developer
pro rata share financing.

o  Fund costs  attributable to trailer parks  in the  area  west of
1-95  (Segment 1)  with  Housing  and  Urban Development Community
Block Grants.

o  Fund the balance with conventional or lease/purchase financing.

The  report  also  recommends  that  either  the areas  east  of 1-95
(Segments  1 and  2)  be funded  together or  the  entire Phase  I
Extended area be funded.

A wide  range  of  user  charges could be  applied depending  on the
method  of   financing  chosen,  and  whether  Phase  I   and  Phase  I
Extended customers are  combined   into  one  payment   system.   The
Draft Facilities  Plan  projects that  with a new  connection  fee of
$1500 and no  EPA  funding,  a typical Phase  I  Extended system user
could expect  to  pay roughly  between  $52-65 every two  months,  or
an annual charge  of  t312-#390.  EPA guidelines  suggest that user
charges should  not exceed  2.5%  of  median  household  income.   In
the case of Hanover County, this amounts to roughly $400/year.

If  EPA funding  is  available and  is  sought  by the  County,  a
detailed user charge system must be  developed and approved by EPA
prior to award of Federal funds for construction  (Step  3).

Selection of an alternative to serve the needs of the Phase  I
Extended area must take  into account a variety of cost,
environmental,  and social  factors.   Tables  13  and  14 summarize
and  compare  the   costs and  environmental  impacts   of the  four
alternatives  discussed  in  the Phase  I Extended  Draft Facilities
Plan.

Using   a   set  of  evaluative  criteria,   including   costs  and
environmental  effects,  the  Draft  Facilities  Plan  presented  a
preliminary ranking  of  the  four  alternatives,  recognizing that
public  hearing  testimony  and other public and  local government
opinions would  also  contribute  to  the  selection process.   The
ranking listed Alternative 4  as the  "best" alternative , followed
by Alternatives 2,  3,  and  1  in that order.   While the evaluative
criteria  were  not  individually  weighted   per   se,  they  were
averaged to derive a   final  numerical  ranking,  which  in   effect
assigned an equal weight  to  each criteria.   And while EPA does
not disagree with  the  preliminary  identification of  Alternative 4
as  the most  cost-effective  alternative,  the   public  and  local
decisionmakers  should  be aware that if  different weightings were
assigned and  public opinion  factored  in,  the  final  averages as
well  as ranking  order  beyond the  first  choice could  possibly
change.  Alternative  1  would  tend to  be  elevated  in rank  to a
point  where  it  could  compete with  Alternatives 2  and  3  as  a
viable alternative.
                                                    75

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            TABLE 13
        PHASE I EXTENDED
ENVIRONMENTAL IMPACTS COMPARISON
Impact
Area
           Alternative
       (1)
     Limited
      Build
                                                (2)
                                              Hanover
                                             AWT Plant
                                                                  (3)
                                                                Hanover
                                                             Land  Treatment
    (4)
  Henrico
Interconnect
Surface Water Quality

Groundwater Quality

Water Supply

Aquatic Biology

Terrestrial Biology

Population Growth

Land Use

Land Requirements

Construction Impacts

FLood Hazard Areas

Scenic Rivers

Prime Agricultural land

Historical/Archeological
  Sites

Groundwater Recharge
  Areas

Wetlands

Implementation

Key:
       o

       o
       o

       o

       o
       o

       o
                                                                                   o

                                                                                   +
      ++ = Very benefitical impact
       + = Beneficial impact
       0 = Not impacted by the alternative/equal adverse and beneficial  impacts
       - = Adverse impact
      -- = Very adverse impact

NOTE:  These  impact  categories  have   not   been   weighted  in  importance.
quantitative                                totals
                                                    Thus,  no
                                                      appear.
                76

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                                                          TABLE 14
                                                      PHASE I EXTENDED
                                                ALTERNATIVE  TREATMENT COSTS
Const. Amortized
Cost Const. Cost
Alternative $ $/Year
1.
2.


3.
4.

Limited Upgrade $3,108,500 $290,575
AWT Plant
a. Totopotomoy
Discharge 4,851,900 453,545
b. Pamunkey
Discharge 5,694,620 532,320
Land Treatment 6,168,700 576,636
Treatment in
Henrico 2,729,400 255,14
Cost. Cost
$/l,000 gals.
$2.73

1.38
1.62
1.76

0.78
Annual Total Cost $/l,000 gals.
O&M Cost O&M Costs 0% 50% 75%
$/Year $/l,000 gals. Grant Grant Grant
$388,600 $3.64 $6.37 $5.01 $4.32

259,360 0.79 2.17 1.48 1.14
193,920 0.59 2.21 1.40 1.00
257,850 0.80 2.56 1.68 1.18

281,790 0.86* 1.64 1.25 1.06
*Includes estimated treatment costs in Henrico County system.

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                       Because of the projected  initially high growth  rate,  the Federal
                       funding  uncertainties,   and   possible  fluctuation   in  Henrico
                       County's cost, phasing  or combinations  of the  four  alternatives
                       are also possible choices.  For  example, the County may elect to
                       initially construct  a  sewer  system  from Phase  I  as  far  west as
                       1-95 with treatment  in Henrico  County  (a portion  of  Alternative
                       4), while applying  the limited  build solution  to areas  west of
                       1-95.

                       However,  of  the  four   main  alternatives,  EPA   concurs  with
                       identification of Alternative  4  as most cost-effective  and, with
                       appropriate  preventive  measures  applied to  control  construction
                       impacts and  growth related secondary effects, believes  it can be
                       an environmentally acceptable  solution.

OAK HILL ESTATES       Alternatives for Oak Hill Estates   (located directly  southwest of
                       the Town  of  Ashland)  were examined  separately in  the  Phase  I
                       Extended Draft Facilities Plan because the  subdivision  is located
                       away from the Phase  I  Extended  initial  service area  and because
                       of public controversy.

                       The following  four options were evaluated for Oak Hill Estates:

                       1.   Interceptor  sewer  construction for  connection  into  the Phase
                       I Extended system (assumed to  include a sewer network)

                       2.   An advanced waste  treatment  plant on-site,  with  discharge to
                       Stony Run or Falling  Creek

                       3.   Connection to  the  Ashland system  via  pump  station  and force
                       main

                       4.   An individual land  treatment  system.

                       Table  15  taken  from  the  Draft  Facilities Plan presents  a cost
                       comparison  of these  four  options.   The  table  indicates  that
                       connection into  the Ashland system  (Alternative  3)  is  clearly the
                       least costly option.

                       From an  environmental  perspective,  Alternative  1 is  associated
                       with the most numerous adverse impacts due  to lengthy  interceptor
                       construction  and    corresponding    growth    impacts   which   are
                       inconsistent with County  planning  goals.  For this reason,  it is
                       not an  acceptable solution.   Alternatives  2,   3,  and   4  present
                       insignificant  and  roughly equal  overall  environmental  impacts.
                       Alternatives 2 and 4  do  not  involve construction of major sewer
                       lines outside  the general boundaries of  Oak Hill Estates and thus
                       avoid impacts associated  with  interceptor  construction.   However,
                       Alternative  2  would require construction of  an  effluent  discharge
                       line to  either  Stony Run or  Falling  Creek,  while Alternative  4
                       would require  pumping of  treated wastewater  to  a site outside of
                       the subdivision.  Alternative  3  involves construction of  a force
                       main to  the  existing  Ashland  sewerage  system.  Some  temporary
                       adverse impacts can  be  expected  from  this  alternative,  including
                       at  least  one  stream  crossing.   But  the  potential  for  induced
                       growth is not expected to be  strong because  the  force main would
                       technically  and economically  restrict additional  connections and
                       Ashland could  limit through agreement  the  amount of  flow it would
                       receive.
                                                    78

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It  is  recognized  that  many  residents,  and  the  Ashland  Town
Council object  to  resolution  of  a  "County  problem"  by  Ashland.
However,  given  the  overwhelming  cost  advantage  of  the  Ashland
interconnect option,  along  with  minimal environmental  impact,  it
is difficult to argue on a  cost-effective  basis  that any  but this
alternative  should  be   implemented.   Therefore,  unless  a  cost
competitive  technical alternative  can be  found  for  an  on-site
upgrade,  EPA must  support  the  Ashland interconnect  alternative
and recommends that the Town modify its plans accordingly.
                        79

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^ ''  S  • <•
:    -!'J*  •>•-
                   FIGURE 11 •

        OAK   HILL ESTATES
           STUDY
              ALTERNATIVE THREE

             ASHLAND  TREATMENT
                    1000  2000   3000
       PATTON.HARRIS, RUST  AND GUY
   CONSULTING ENGINEERING—LAND SURVEYING—PLANNING
               FAIRFAX . VIRGINIA

-------
                                                            TABLE 15
                                                        OAK HILL ESTATES
                                                  ALTERNATIVE TREATMENT COSTS
Const. Amortized
Cost Const. Cost Cost. Cost
Alternative $ $/Year $/l,000 gals.
1. Interceptor


2a.

2b.


3.


4.
Extens ion
Henrico
Treatment $672,000 $62,817 $4.30
AWT Plant -
To Stony Run 423,200 39560 2.71
AWT Plant -
rpj-i "F1?^ 1 "1 "i nrr
_L U JT a. ,L_L J, I ly
Creek 360,720 33,720 2.31
Puinp S ta t i on
to Ashland
System 177,910 16,630 1.14
Land Treatment 407,660 38,107 2.61
Annual
O&M Cost O&M Costs
$/Year $/l,000 gals


$ 1,287 $0.84*

51,560 3.53


42,970 2.94


7,942 1.02*
21,520 1.47
                                                                                                      U%        50%      75%
                                                                                                      Grant	Grant    Grant
                                                                                                     $5.14    $2.99    $1.91


                                                                                                      6-99     4.89     4.21



                                                                                                      6.00     4.10      3.52



                                                                                                     2-16     2.73      1.30

                                                                                                     4'09     2.78     1.86
"Include treatment costs of Henrico @ $0.75/1 000 Qaiirt     „   u
                                      »u./Vl,000 gallons and Ashland @  $0.48/1,000  gallons.

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                        HANOVER EIS MAILING LIST
FEDERAL AGENCIES
VIRGINIA STATE
AGENCIES
LOCAL AGENCIES
Council on Environmental Quality
U.S. Army Corps of Engineers, Norfolk District
Office of Economic Opportunity
U.S. Department of Agriculture
   Soil Conservation Service
U.S. Department of the Treasury
U.S. Department of Transportation
   Marine Environmental Protection Division
U.S. Department of Defense
U.S. Department of Health and Human Services
U.S. Department of the Interior
   Bureau of Outdoor Recreation
   Fish and Wildlife Services
   National Water Resource Analysis Group/Eastern
       Energy Land Use Team
   National Park Service
   Geological Survey
U.S. Department of Commerce
Advisory Council on Historic Preservation
Water Resources Council
U.S. Department of Housing and Urban Development
U.S. Department of Energy
   Office of the Secretary for the Environment
U.S. General Services Administration
National Agricultural Lands Study
U.S. Bureau of Prisons
Federal Emergency Management Agency

State Water Control Board
   Piedmont Regional Office
   Bureau of Enforcement
   Bureau of Water Control Management
State Health Department
   Bureau of Sanitary Engineering
   Bureau of Shellfish Sanitation
   Bureau of Occupational Health
   Bureau of Solid Waste and Vector Control
   Bureau of Environmental Health
Department of Highways and Transportation
Department of Housing
Commission of Game and Inland Fisheries
Council on the Environment
Air Pollution Control Board
Commission of Outdoor Recreation
Historic Landmarks Commission
Department of Agriculture and Commerce
State Energy Office
Department of Commerce and Resources
   Coastal Zone Management Program
Department of Intergovernmental Affairs
Marine Resources Commission
Virginia Park Authority
Office of the Governor
Soil and Water Conservation Commission
Department of Conservation and Economic Development

Richmond Regional Planning District Commission
Richmond National Battlefield Park
Hanover County
   Department of Public Utilities
   Planning Office
   Utilities Engineer
                                                83

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LOCAL AGENCIES
(cont)
ELECTED OFFICIALS
CITIZEN GROUPS
Henrico County
   Department of Public Utilities
Town of Ashland
   Water and Sewer Council
   Town Council

Honorable John N. Dalton
   Governor of Virginia
Honorable Harry F. Byrd, Jr.
   United States Senator
Honorable John Warner
   United States Senator
Honorable J. Kenneth Robinson
   United States House of Representatives
Honorable Tom Bliley
   United States House of Representatives

Honorable Elmo G. Cross, Jr.
Honorable James T. Edmunds
Honorable William E. Fears
Honorable E. T. Gray
Honorable J. Harry Michael, Jr.
Honorable William F. Parkerson, Jr.
Honorable Lawrence D. Wilder
Honorable Edward E. Willey

Honorable George E. Allen, Jr.
Honorable Ralph Axselle, Jr.
Honorable Richard M. Bagley
Honorable Robert B. Ball, Sr.
Honorable Gerald L. Baliles
Honorable James S. Christian, Jr.
Honorable John Warren Cooke
Honorable Alan A. Diamonstein
Honorable V. Earl Dickinson
Honorable Walter H. Emrock
Honorable Lewis P. Fickett, Jr.
Honorable John D. Gray
Honorable George W. Grayson
Honorable Franklin P. Hall
Honorable Robison B. James
Honorable George W. Jones
Honorable Benjamin J. Lambert, III
Honorable C. Hardaway Marks
Honorable Alexander B. McMurtrie, Jr.
Honorable Theodore V. Morrison, Jr.
Honorable D. Wayne 0'Bryan
Honorable Robert C. Scott
Honorable S. Wallace Stuffen

Virginia Farm Bureau Federation, Richmond, VA
Virginia Association of Counties, Charlottesville, VA
Izaak Walton League, Arlington, VA
Mechanicsville Civic Association, Mechanicsville, VA
Virginia Society of Ornithology, Richmond, VA
Virginia Research Center for Archaeology,
   Williamsburg, VA
Audubon Naturalist Society of the Central Atlantic
   States, Inc., Washington, D.C.
Virginia Wildlife Federation, Inc., Alexandria, VA
Virginia Historical Society,•Richmond, VA
                                                   84

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CITIZEN GROUPS
(cont)
LIBRARIES
CITIZENS
The Natural Conservancy - Virginia Division,
   Richmond, VA
Conservation Council of Virginia, Inc., Richmond, VA
Chesapeake Bay Foundation for Environmental Studies,
   Washington, D.C.
Sierra Club - Old Dominion Chapter, Midlothian, VA
League of Women Voters
   Bon Air, VA
   Waynesboro, VA
   Richmond, VA
Rural Point Concerned Citizens Association, Mechanicsville,  VA
Citizens for Sensible Growth, Ashland, VA
National Wildlife Federation, Washington, D.C.
Richmond Audubon Society, Glen Allen, VA
Virginia Bass State Federation, Roanoke, VA
Zero Population Growth, Richmond, VA
American Land Trust, Arlington, VA
Virginia Forests, Inc., Richmond, VA
Virginia Anglers Club, Richmond, VA
Reclaim-the-James,  Richmond, VA
Natural Resources Defense Council, Washington,  D.C.
American the Beautiful Fund, Washington, D.C.
Keep Virginia Beautiful, Richmond, VA
Environmental Policy Center, Washington, D.C.
National Parks and  Conservation Association, Washington,  D.C.
Rachel Carson Trust for the Living, Washington, D.C.
Water Pollution Control Association, Washington,  D.C.
Wilderness Society, Washington, D.C.
Piedmont Environmental Council. Warrenton, VA
The Wildlife Society, Washington, D.C.
Environmental Defense Fund, Washington, D.C.
Virginia Agribusiness Council, Richmond, VA
Hanover County Citizens Federation, Mechanicsville,  VA
Virginia Environmental Endowment, Richmond, VA

Ashland Branch Library
Mechanicsville Branch Library
Virginia State Library
Richmond Branch Library
Bon Air Branch Library
Henrico County Library

John B. Steadman
David S. Favre, Esq.
Sterling Anderson,  Mrs.
James A. Ayers
John H. Banks
R. Howell, Professor
D. Tilghman Broaddus
William Chamberlain
R. W. Darnell
Bruce V. English, Ph.D.
Lewis C. Gilbert, M.D.
Lynwood E. Hancock, Mrs.
Dale Hanks, Mrs.
Roscoe Hughes, Ph.D.
John A. Hugo, Mrs.
Sam Ketner
Donald MacDonald
W. Wallace Martin,  Ph.D.
James W. Midyette,  Jr.
Stuart B. Monroe, Mrs.
                                                  85

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CITIZENS                John Newell
(cont)A.  Preston Sale
                        Jane Ruffin
                        Dallas Smith
                        Charles Verdery,  Mrs.
                        Paul Von Mille
                        Melvin Wallinger, Mrs.
                        John Walton, Mrs.
                        Lois Wickham, Mrs.
                        Robert Weems
                        R.  V.  White
                        Dava R. Ambrosen
                        James W. Barber
                        Herbert C. Fearnow
                        James K. Cox, Jr.,  Mrs.
                        John C. Ekman
                        Peter H. Ring
                        J.  Westwood Smithers,  Jr.
                        Glenn Porter
                        Ken Williams
                        A.  Goodloe Sauners
                        Grafton Stephens
                        Dennis Tinsley
                        Robert Blevins
                        David Ryan
                        Henry J. Miller,  Jr.
                        Thomas P.  Krauth
                        Edward 0.  Dillon, III
                        Thomas W.  Evans
                        Fred S. Campbell
                        Ron Irons
                        J.  W.  Orange
                        George Bolton
                        Miles C. Johnston
                        I.  N.  Koontz
                        Mary B. Rice
                        Dan Smith, Mrs.
                        Donald Weber
                        T.  A.  Clarke
                        M.  Bordley, Jr.
                        Betsy J. Hale
                        John Maples, Mrs.
                        Ray E. Martin
                        Harvey F.  Ludwig
                        J.  Whiltoaker
                        K.  T.  Spear
                        William A. Beck
                        W.  A.  Phillips, Jr.
                        Patricia Borky
                        Rosemary O'Kelley
                        Helen Lahman
                        Colin Williamson
                        K.  Pea
                        John Fawborn
                        Peter P. Zubio
                        Robert Phillip
                        Robert N.  Pentar
                        L.  G.  Cox
                        E.  Casterline
                        Clyde L. Coff
                        Joseph C.  Douhe
                        Paul Mealow
                                                   86

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CITIZENS
(cont)
  OTHER
MEDIA
Newspapers
Television
      Radio
Eugene Taylor
T. A. Cole, Jr.
Ronald G. Jones
Barrett S. Hopkins
E. A. Beck
E. Contarlimt
William C. Wirkliar, Jr.
F. J. Brown
J. S. McClurkue, Jr.

Virginia Institute of Marine Science
Allen Transport
University of Pittsburgh
R. Stuart Royer & Associates
Patton, Harris, Rust & Guy
Little River Leisure Enterprises
Engineering-Science
Leadbottom Construction Co.
Bremner, Youngblood & King, Inc.
Clinton Bogert Association
Wiley & Wilson, Inc.
Mobil Chemical Co.
Hanover Properties, Inc.
Leadbetter Inc.

Times-Dispatch
News Leader
Gazette of Goochland-Powhatan
Herald-Progress
WCVE,
WCVW,
WTVR,
WWBT,
WXEX,
WVIR,
WHSV,
WAVY,
WHRO,
WTAR,
WVEC,

WHAP-
WBBL-
WANT-
WENZ-
WGOE-
WIKI-
WKDH-
WLEE-
WRFK-
WKIE-
WRNL-
WRVA-
WRVQ-
WTVR-
WXGI-
WTUR-
 Richmond, VA
 Richmond, VA
 Richmond, VA
 Richmond, VA
 Richmond, VA
 Charlottesville,  VA
 Harrisonburg, VA
 Portsmouth, VA
 Norfolk, VA
 Norfolk, VA
 Norfolk, VA
•AM,
•AM,
•AM,
•AM,
•AM,
•AM,
•AM,
•AM,
•AM,
•AM,
•AM,
•AM,
•FM,
•AM,
•AM,
•FM,
Hopewell
Richmond
Richmond
Richmond,
Richmond,
Richmond,
Ashland,
Richmond
Richmond
Richmond
Richmond
Richmond,
Richmond
Richmond,
Richmond,
Richmond,
 VA
 VA
 VA
 VA
 VA
 VA
VA
 VA
 VA
 VA
 VA
 VA
 VA
 VA
 VA
 VA
                                                87

-------

-------

-------
DRAFT EIS COMMENT LETTERS

-------
                            Rt. 1                    Tel:  (804) 227-3323
                            Doswell, Va.  23047
                            Mar.  30,  1979

EPA  Region III  Preparation Section
6th and Walnut Streets
Philadephia, Penn. 19106

             EPA EIS Summary- Wastewater Treatment Facilities Planning
                        For Hanover County, Virginia Phase II Area

We have three  areas of specific comment:

1.  We favor continued but limited growth, but want it contralled and phased.

2. -Waste Treatment facilities  are growing too expensive,  even with federal
aid, to make them generally acceptable for many citizens.  Therefore we look
for the lesser package where possible,  such as, upgrading existing facilities.
Ashland Lagoon would be an example.  The EIS outline of a proposed
improvement,  deepening, aeriation etc., with possible land application
looks to us as a good solution and a reasonable cost/benefit ratio.

3.  We generally approve Land Application for two reasons:
             a. It is less expensive
             b. It should not pollute the rivers if managed properly.

In a general comment, we approve your recognition of the importance of
preservation of our natural  and cultural resources, historic sites,  pre-
historic  sites,  prime farm land (very important), purity of the aquifer
recharge and ground water, and the guarding of citizen health.

In III - 15 EIS states: "Due to the increasing number of failing septic systems
and package facilities, and overall growth in Hanover County, adequate sewerage
service must be provided to the Phase II Service  Area. " We have doubt about
the urgency of the need of Phase II at this time.  There  is question about the
seriousness of the "failing systems" and their numbers  and the reasons for
failure.  The "growth" referred to will only be small unless Phase II is put
into effect.

                                Donald Macdonajd,  For
                                Hanover CitizenV Federation
                                            V

-------
                    COMMONWEALTH of VIRQINIA

J. B. JACKSON. JR.                     Council On the Environment         903 NINTH STREET OFFICE BUILDING
ADMINISTRATOR

                                        April  16,  1979
    Mr. Jack J. Schramm,  Regional Administrator                 £PA, Wi J" ' c,r'pTTlM
    U. S. Environmental Protection Agency                         ^RJatai" °
    .Region III                                                        	
    6th and Walnut Streets
    Philadelphia, Pennsylvania  19106

    SUBJECT:  Wastewater Treatment Facilities  Planning  for Hanover County,
              Virginia:  Phase II Area

    Dear Mr. Schramm:

          Thank you for the opportunity to review the  subject Draft Environmental
    Impact Statement.  It is a responsibility  of the  Council on the Environment
    to coordinate the State's review of Federal  environmental impact statements
    and to respond to the responsible federal  official  on behalf of the State.
    The State agencies which participated in the review of the subject document
    are listed below:

              Commission of Outdoor Recreation
              Department of Agriculture and Consumer  Services
              Department of Conservation and Economic Development
              Department of Highways and Transportation
              State Air Pollution Control Board
              State Water Control Board
              Virginia Soil and Water Conservation  Commission
              Virginia Research Center for Archaeology

          At this point the Commonwealth is not  opposed to any of the alternatives
    addressed in the document.  Without the information normally contained in a
    facility plan a comprehensive analysis of  the environmental impacts cannot be
    made.
                                   &-T.

-------
Mr. Jack J. Schramm
Page Two
April 16, 1979
                                            j
      The enclosed comments of State agencies should  be  addressed  in the Final
document.  If there are any questions,  please do not  hesitate to contact me.

                                     Sincerely,
/ J. 4>/J
                                                    Jr.
JBJr/gcj
cc:  The Honorable Maurice B.  Rowe,  Secretary of Commerce  and Resources
     Mr. Rob Blackmore, Commission of Outdoor Recreation
     Dr. Berkwood Farmer, Department of Agriculture  and Consumer Services
     Mr. Leon App, Department of Conservation and Economic Development
     Mr. R. L. Hundley, Department of Highways and Transportation
     Mr. James Ruehrmund, State Air Pollution Control  Board
     Mr. Raymond Bowles, State Water Control Board
                                a-s

-------
     R. V. Davis
  Executive Secretary

 Post Office Box 11143
Richmond, Virginia 23230
    (804) 257-0056
STATE WATER CONTROL BOARD
      2111 Hamilton Street
         April  3,  1979
          Mr.  Reginald F. Wallace
          Environmental Impact Statement Coordinator
          Governor's Council on the Environment
          Ninth Street Office Building
          Richmond, Virginia  23219
                                        v;\
                           ^J   .  .*"     V^S
                         /OL-T     '    '"     r:;A
                                Council on    !"^'
                         ICXT-,      the
                               Ehvironment
BOARD MEMBERS
Millard B. Rice, Jr.
    Chairman
 George M. Cornell
  Vice-Chairman

Col. J. Leo Bourassa
 Warren L. Braun
Kenneth B. Rollins
 William L. Tate
 R.Alton Wright
          Dear Reggie:

          RE:  DEIS - Hanover County Wastewater Treatment Facilities Planning

          The preface to the DEIS states  that the DEIS should be reviewed  concurrently
          with the 201 Facilities Plan.   However, information normally contained in a
          201 Facilities Plan was not  included in the DEIS, therefore, a comprehensive
          analysis of the environmental  impacts of the project cannot be made.

          We will assume that the Final  EIS  will contain the information contained in a
          facility plan or will  be  accompanied by the facility's plan.  Upon  receipt of
          the FEIS with other necessary  information, we will provide comprehensive comments.

          Our staff has reviewed the  DEIS in the context of the above, and we  have the
          following comments:

          1.  The DEIS makes several  references to data included in the facility plan
              which cannot be substantiated  without a copy of the facility plan.  It
              should be noted that  at  the present time there is still some question as
              to the waste load  allocation for the Nelson's Bridge Regional  Plant site,
              which will have a  major  effect on the results of the cost-effective analyses
              in the facility plan.   At  the  present time it is anticipated that an intensive
              stream survey will be undertaken to determine the actual effluent limtations
              to be imposed on both the  Ashland Sewage Treatment Plant and the proposed
              treatment plant at the  Nelson's Bridge site.  Such a survey  could add an
              additional year to the  planning process, and would also require some changes
              in the EIS.

          2.  The information concerning current flow levels at the Ashland Treatment
              Plant, on pages 2-20  and 21, are inaccurate in light of information gathered
              as a result of  recent enforcement actions.  Flow monitoring, currently at the
              Ashland Plant,  indicates that  average flows may be as htgh  as 1.2 MGD or
              double the flow levels  included in the EIS.

                                                                         Continued.  .  .

-------
April 3; 1979
                                 -2-
Mr. Reginald F. Wallace
o.

6.
On page 2-23, the statement is made that there is approximately 600,000
gallons/day of additional capacity existing at the Doswell  facility.
It should be noted that while flows resulting from industrial  activities
at the Bear Island Paper Company plant will not be going through the
Doswell Treatment Plant itself, sanitary sewage will, which will further
utilize the existing capacity.  The currently rated discharge  flow levels
from the Doswell Treatment Plant (including Bear Island) will  range up to
2.5 MGD depending on stream flow in the North Anna.

On page 2-34, the statement is made that VEPCO is required  to  discharge a
minimum of 40 cfs during the winter months and 120 cfs during  the summer
months from the Lake Anna Reservoir.  Our investigations, during the  pro-
cessing of the Doswell permit, indicates that there is a minimum discharge
requirement of 40 cfs year around.

Page V-3 needs to be updated to match current water quality standards.

The statement about anti-degradation in the last paragraph  of  page V-5 is
incorrect.  The anti-degradation policy holds true for plants  of all  sizes
and not just those above 1 MG.D.  If a plant can meet this criteria without
advanced treatment, then such treatment would not be mandatory.
Thank you for the opportunity to comment on this DEIS.   If you have any questions
concerning our comments, please do not hesitate to contact me.
                                      Since
                                      Raymond^.  Bowles, P.E.
                                      Di rector
                                      Bureau of Surveillance
                                        and Field Studies
/sec

cc:  John J. Cibulka-PRO
     Joyce Hoyle-PRO
     Sam Waldo-BAT
     Dale Wright-BSFS

-------
S. MASON CARBAUGH
  COMMISSIONER
DEPARTMENT OF AGRICUL TURE AND CONSUMER SERVICES
                Planning and Development
             P. O. Box 1 163, Richmond, Virginia 23209
                    March  28,  1979
                                                                        BERK WOOD M. FARMER, Ph.D
           Mr.  Reginald F. Wallace
           Environmental  Impact  Statement Coordinator
           Council  on  the Environment
           903  Ninth Street Office Building
           Richmond, Virginia  23219

                   Re:  DEIS - Wastewater Treatment Facilities Planning  for
                       Hanover  County, Virginia - Phase II Area

           Dear Reggie:

                   Sewerage collection and treatment facilities, per  se,  are
           not  solely  responsible for stimulating growth; however,  their size
           and  location influence the pattern and rate of growth within  the
           county.  Based on history, there is usually a direct relationship
           between  the location  of sewer lines and the pattern of development.

                   It  appears  that the planned location of the sewer  lines and
           wastewater  treatment  facilities coincides with the location of prime
           agricultural land in  the  southeastern half of the county.  Local
           decision makers and citizens should be knowledgeable of  the possible
           effects  on  removing prime agricultural lands.

                   This agency also  has responsibility in the application of sludge
           and  effluent to land.  Before a decision to go with land application
           of either effluent  or sludge is made, a detailed plan of application
           and  monitoring program will have to be prepared and submitted to the
           appropriate state agencies.

                                      Sincerely,
                                        /Ljju^
                                       Berkwood M.  Farmer

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8.   REVIEW INSTRUCTIONS:

    A)  Please review the document carefully.  If the proposal has been
       reviewed earlier (e.g.,  if the  current document is a FINAL EIS),
       please consider previous comments.

    B)  Prepare your agency's comments  in a form which would be acceptable
       for responding directly  to a project sponsoring agency.

    C)  Use the space below for  your comments.  If additional space is
       needed, please attach extra sheets.
        Return your comments to:

        Reginald F. Wallace,
        Environmental Impact Statement Coordinator
        Council on the Environment
        903 Ninth Street Office Building
        Richmond, Virginia   23219
                              COMMENTS
      In several places  (pp 11-54, 11-59,  Figure 11-10, pp. IV-31),  the  draft EIS
 refers to the North  Anna,  South Anna, Pamunkey and Chickahominy Rivers  as scenic
 rivers or scenic  river  areas.  Although  these rivers have been identified in the
 Virginia Outdoors Plan  as  potential components of the Virginia Scenic Rivers
 System and are in fact  significant natural  and scenic resources,  they have not
 been legislatively designated as components of the System.

      Because of their proximity to the Richmond area, all four of the rivers are
 frequently utilized  by  canoeists and  fishermen.  As residential development increases
 in Hanover and Henrico  Counties, and  as  canoeing continues to gain in popularity
 recreational boating use of area streams should continue to increase.  Alternatives
 for wastewater collection and treatment  which would result in numerous  pipeline
 crossings, substantial  streamside structures,  decreased water quality or other
 activities which  would  significantly  impact on these rivers would be  unacceptable.

      If facilities should be constructed in the vicinity of such  valuable river
 resources, mitigation methods will be necessary to maintain the scenic  character
 of these streams.

      Site planning should include wide,  vegetated buffer zones.   Effluent discharges
 should be minimized  in  order to maintain high water quality, and  stream crossings
 should be avoided.   Where such crossings are necessary, the stream banks should
 be revegetated, and  all structures left  above the ground should be set  back from
 the stream and painted  in a manner to blend with their surroundings.
    (SIGNED)

    (TITLE)

    (AGENCY)
Director
Commission  of  Outdoor Recreation

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FRED W WALKER
  Director
JERALD F. MOORE
  Deputy Director
    DIVISIONS
FORESTRY
LITTER CONTROL
MINED LAND RECLAMATION
MINERAL RESOURCES
PARKS
VIRGINIA STATE TRAVEL SERVICE
    PROGRAM
SALT WATER SPORT FISHING
DEPARTMENT OF CONSERVATION AND ECONOMIC DEVELOPMENT
                1100 STATE OFFICE BUILDING
                 RICHMOND, VIRGINIA 23219
                      (804) 786-2121
    BOARD
J. H. JOHNSON, West Point
  Chairman
D. HENRY ALMOND, Richmond
  Vice Chairman
A, R DUNNING, Millwood
MYRON P ERKILETIAN, Alnxandn.
ARTHUR P. FLIPPO, Doswi.>!l
HE1NRY T N. GRAVES. Luray
MILDRED LAYNE, Willidmsburg
FREDERIC S. REED. Manakm Saboi
GEORGE P SHAFRAN, Arlington
NICHOLAS D. STREET, Grundy
SHERMAN WALLACE, Cleveland
E FLOYD YATES, Powhatan
                                            April 4, 1979
               MEMORANDUM


               TO:        Mr. Reginald  F.  Wallacj

               FROM:     Leon E. App
                         This  is  in reference to the EPA Draft Environmental Impact
               Statement for the  Hanover County, Virginia,  Phase II Area,  Wastewater
               Treatment Facilities Plan.

                         This  report has been reviewed  by our Division  of  Forestry and
               their comments  are attached.

                         In general, Hanover County is  one of the State's  leading
               forest product  counties and forest management has been practiced by
               hundreds of Hanover landowners.  This fact has been ignored throughout
               the presentation,  and is especially obvious in the Biology  section on
               "Terrestrial/Ecosystems—Flora" on pages 11-43 and 44.   There are certainly
               more than five  vegetational types in Hanover County.  Those "types"
               described in the text are actually physiographic classes, not vegetational
               types.  Under "Disturbed Areas" on page  11-44 there is no indication
               that much of the forested disturbed area is a result of  management
               practices which include planting over one million tree seedlings each
               year by Hanoverians.

                         Further  information on Hanover's forest resources is available
               in the report,  Hanover County Agricultural Development Subcommittee,
               A Report to  the Hanover County Citizens  Advisory Board,  1978, published
               by Hanover County.  We feel these comments are important since historically
               the right-of-way for wastewater lines are impacted upon  the forest
               resource.

                         If we can be of further assistance, please let us know

               ec

               Attachments
               cc:  Mr. Wallace F. Custard

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             COMMONWEALTH of ViEGlN.

                  (jnt oj C(
                                  f fruif\i:>:
                          March 29,  1979
PLANS AND PROGRAMS
Environmental Impact Statement
Environmental Protection Agency

To:        Mr.  L.  E.  App

From:     M. J. Simons, Forester-Planner

Subject:  Hanover County Wastewater Treatment Facilities-Draft
          Environmental Impact Statement

     Gene Augsburger, District Forester, and I have  reviewed  the
Draft Environmental  Impact Statement for the Hanover County Waste-
water Treatment Facilities and have inspected particular  sites
of environmental importance in the county.   We 'wish  to  make the
following comments and recommendations concerning this  report:

   Figure II-2:  This map of existing land  use generalizes that
     all land that is not shaded in is considered agricultural.
     This is misleading to the public in that over 60%  of L'anover
     County's total  acreage is in commercial forest  land.  This  is
     stated in the text of the Impact Statement (11-55)  and is
     supported by data from the current U.S. Forest  Service Survey
     of Hanover County.

   Section II-C-6:  The major flaw in this  discussion of the  various
     physiographic classes is t''.at you assume, judging by your
     narratives of each, that these classes are in their climax
     sucessional stage.  In other words, you have assumed that
     each class of land described here is totally forested with
     climax tree species.  You have not taken into account that
     forest management has been practiced in Hanover County  for
     many years,  and that much climax forest type acreage has been
     cut and reforested with sub-climax species, such as loblolly
     pine.  These cutover areas, as well as old fields which  have

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PLANS AND PROGRAMS
Environmental Impact Statement
Environmental Protection Agency
                                 -2-
     been planted to pine, amount to a great deal of land,
     certainly enough to have them included in the discussion of
     physiographic classes.  By including pine acreages in your
     discussion of disturbed areas, you have implied that these
     acreages are random occurences, a part of natural succession/
     not, as is the case, an intentional, thoughtful process of
     managing forest lands for wood products and economic benefit.

   Section II-D-3:  After inspection of several areas along the
     Crump and Pollard Creeks, it was decided that few areas in
     each creek's bottomlands are undisturbed, rather than most
     areas, as was stated in the text  (11-53, last paragraph).
     These areas have been logged at one time or another, but
     have regenerated back to mature, bottomland hardwood species.

   Section II-D-7,8:  As in Figure II-2, forest lands have once
     again been glossed over, either unintentionally or becao.se txe
     importance of forest management has been taken for granted.
     In the Prime Agricultural Lands category, directly beneath
     Forest and Woodlands, the text goes into great detail as to
     where prime agricultural lands are located in the county and
     what the major crops are.  There is also a map delineating these
     prime agricultural areas (Figure 11-11).  Why then are the
     forest lands, which produce over five  (5) million board feet
     of wood per year, not given the same consideration?  A map
     delineating prime forest lands  (meaning those which have ^he
     greatest potential for producing wood fiber and those which
     are currently being managed; eg.-tree ^arms, forest industry
     land) should be essential to the decision-making process.
     Location of wastewater treatment facilities in or around prime
     forest lands will bring residential, commercial, or industrial
     development to these areas, and result in the  irretrievable
     loss of this forest resource.

   Section II-D-II:  There is one county park which is not mentioned
     in this text, and that is Poor Farm Park.  Containing two
     hundred seventy  (270) acres, this park is located west of
     Ashland off Route 54, and will be used for passive recreation.

     In conclusion, there is little consideration given to  the
 importance of Hanover County's forest lands in this text.  The
 Environmental and Economic benefits of the  forest resource have
 been glossed over.  The absence of accurate data, locations,  and
 description of the  forest resource in Hanover County can only lead
 to improper decision-making and poor location of wastewater treat-
 ment facilities; an error all environmental impact  statements are
 designed to avoid.

 cc:  Mr. Wallace F. Custard

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HAROLD C.. KING, COMMISSIONER

IEONAHD R. HALL. BRISTOL. BRISTOL DISTRICT

HORACE G. FRALIN, ROANOKE. SALEM DISTRICT

THOMAS R. GLASS, LYNCHBURG. L YNCHBURG DISTRICT

MQRR1LL M, CROWE. RICHMOND, RICHMOND DISTRICT

WILLIAM T. ROOS, YQRKTOWN. SUFFOLK DISTRICT


WILLIAM T. ROBINSON, WEST POINT, FREDERICKSBURG DISTRICT

WILLIAM B WRENCH, SPRINGFIELD, CULPEPER DISTRICT

ROBERT S. LANDES, STAUNTON, STAUNTON DISTRICT

T RAY HASSELL. Ill, CHESAPEAKE, AT LARGE-URBAN

CHARLES S, HOOPER, JR., CREWE., AT LARGE-RURAL
DEPARTMENT OF HIGHWAYS & TRANSPORTATION

           1221 EAST BROAD STREET
              RICHMOND, 23219
                                             March 29,  1979
                                                    LEO E. BUSSER, III
                                                     DEPUTY COMMISSIONER & CHIEF ENGINEER
                                                    T. ASHBY NEWBY
                                                     DIRECTOR OF ADMINISTRATION
                                                    J. M. WRAY, JR.
                                                     DIRECTOR OF OPERATIONS
                                                    H. R. PERKINSON, JR.
                                                     DIRECTOR OF PROGRAM MANAGEMENT
                                                    W. L. BRITTLE, JR.
                                                     DIRECTOR OF ENGINEERING
                                                    OSCAR K. MABRY
                                                     DIRECTOR OF PLANNING
                                                                                      IN REPLY PLEASE REFER TO
                                                      Wastewater  Treatment Facilities
                                                      Planning for Hanover County:
                                                      Phase II Area
                                                      (1)  Draft EIS
                                                      (2)  Summary Draft  EIS
                                                      Environmental Protection Agency
              Mr.  Reginald F.  Wallace
              EIS  Coordinator
              Council on the Environment
              Ninth Street Office Building
              Richmond,  Virginia  23219

              Dear Mr. Wallace:

                    Thank you for providing the Virginia Department  of Highways and
              Transportation with an opportunity to  review  the above  noted  proposal

                    After decisions on  facility locations are  made,  any proposed
              crossing of roadways by  sewer  lines should be coordinated with the
              appropriate highway resident engineer  with emphasis in  minimizing
              disruption to traffic flow and roadway continuity.

                    If we can be  of any further assistance,  please advise.

                                                      Since
                                                      R.'L.  Hundley                ff
                                                      Environmental Quality Engineer
                                    TRANSPORTATION - AMERICA'S LIFELINES

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AXEL T. MATTSON, CHAIRMAN
YORKTOWN

E. FOLGER TAYLOR, VICE CHAIRMAN
STAUNTON

EDGAR B. BOYNTON
RICHMOND

ELIZABETH H. HASKELL
MARTINSVILLE

CARLC. HEDINGER
ALEXANDRIA
COMMONWEALTH of VIRQINIA
        State Air Pollution Control Board
           ROOM 1106, NINTH STREET OFFICE BUILDING
                RICHMOND, VIRGINIA 23219
                TELEPHONE: (804) 786-2378

                        April  3,  1979
      W. R MEYER
EXECUTIVE DIRECTOR
             Mr.  Reginald F.  Wallace
             Council on the Environment
             903  Ninth  Street Office Building
             Richmond, Virginia  23219

             Dear Mr.  Wallace:
                   Since the proposed Hanover Wastewater Treatment Facility, does
             not plan to incinerate its waste there should be no direct effect on
             air quality.

                   However, there is most certainly an adverse impact on air quality
             as a result of the growth that the facility will encourage.  Thus the
             county should be forewarned of this indirect effect.  The county must be
             on guard to protect its air quality from unwanted growth and preserve it
             for the community's future use.

                                                Sincerely,
                                                J.  C.  Ruehrmund
                                                Director
                                                Division of Operations and Procedures
             JCR/WPP/pjg
                                  "An Equal Opportunity Employer"

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               DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
                                  REGION III
                              3535 MARKET STREET
                          PHILADELPHIA..PENNSYLVANIA
                                                             PUBLIC HEALTH SFRVICE
                                April 3, 1979            MAILING ADDRESS
                                                         P 0 BOX 13716
                                                         PHILADE LPHIA.
                                                         PENNSYLVANIA  19101
Mr. Jack J.  Schrairan
Regional Administrator
U. S. Environmental Protection
  Agency
6th & Walnut Streets
Philadelphia, Pennsylvania  19106

Attn:  Environmental Impact Branch
       EIS Preparation  Section
                                        Re:  Draft EIS, Hanover County, VA
                                             Phase II Area,
                                             Wastewater Treatment Plan
Dear Mr. Schrairan:
Thank you for the opportunity to review the draft EIS for the referenced
project.  I have already  forwarded a copy to the Regional Office for
Facilities Engineering  Construction (ROFEC) for a technical review
based on their expertise  in the field of engineering.  If they decide
to comment, they will write directly to you.

Your review of the  several  alternatives (14) is thorough.  Unfortunately,
the lack of information in  several instances, as acknowledged, leaves
the reader in a vacuum.

With the phasing out of the use of ground water to supply future water
demands in Hanover  County,  it is necessary to expedite the resolution
of the sewage treatment problems.   We hope that once you receive the
pending data, you will  complete your assessment and recommendations.
At this point in time,  we have no further comments to make.
                                        Sincerely you
                                        H.  McDonald Rimple, M.D.
                                        Assistant Surgeon General
                                        Regional Health Administrator
                           -1

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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE	
P.O. Box 10026 - Richmond, Virginia23240~

                                                    April 13, 1979
Mr. Jack J. Schramn
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia >  Pennsylvania  19106

Dear Mr. Schramn:

Re:  EV - Comments - Draft EIS - Wastewater Treatment Facilities
                     Planning for Hanover County,  Virginia:
                     Phase II Area (EPA)  and Summary

In comparing Figure 1-2, "Service Area Planning Units," and Figure 11-11,
"Prime Agricultural\Land, Hanover County, Virginia", we find considerable
overlap.  The EIS does not quantify the amount of  prime farmland that will
be lost due to project proposals.

Neither does the draft address the unique farmland found near Studley,
Virginia, along Routes 606 and 627.

No provisions are provided in the draft for conserving, stockpiling, or
proper disposition of topsoil.  This should be addressed since a considerable
amount of land-disturbing activities will occur when facilities are installed.

Thank you for the opportunity to comment.

Sincerely,
D. N. Grimwoo/1
State Conservationist

cc:  Office of Federal Activities, EPA, Washington, D.C. (5 copies)
     Administrator, SCS, Washington, D.C.
     Director, NETSC, SCS, Broomall, Pa.
     Area Conservationist, SCS, Culpeper, Va.
     District Conservationist, SCS, Ashland, Va.

-------
                  DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                          FEDERAL INSURANCE ADMINISTRATION
                       CURTIS BUILDING, SIXTH AND WALNUT STREETS
                           PHILADELPHIA, PENNSYLVANIA 19106

                               April 4, 1979


REGION III                                                       IN REPLY REFER TO:
                                                                 31
                                                                 FLO-1
  Mr.  Thomas Slenkamp
  U.S.  Environmental Protection
    Agency,  Region III
  EIS  Preparation Section
  6th  & Walnut Streets
  Philadelphia,  Pennsylvania  19106

  Dear Mr.  Slenkamp:

  We have recently reviewed the Draft EIS on Wastewater Treatment Facilities
  planning on Hanover County, Virginia:  Phase II area.  In our review, we
  have focused on compliance with the National Flood Insurance Program
  (NFIP), and Executive Order 11988, Floodplain Management dated May 24, 1977.
  Over the past year, the FIA has been especially active in the implementation
  of Executive Order 11988.  The FIA has a key role in its implementation.
  FIA's maps are its foundation and its  rgulations provide the Order's mini-
  mum  standards for Federal construction.  FIA's shared consultation role
  (pursuant to Section 2(d) of the Order) is the basis for a major inter-
  agency effort.   FIA has participated in the preparation of over thirty
  agencies'  procedures for implementing  the Order.  A major thrust of this
  activity has been clarifying the manner in which the Order applies to
  specific agency actions.

  Executive Order 11988 distinguishes between primary and secondary impacts
  on floodplains.   A primary impact would be one resulting directly from the
  siting of an action in a floodplain.  In the present case, examples of
  actions with primary impacts would be  the placing of treatment plants,
  collector systems or land application  sites in floodplains.  A secondary
  impact  would be one flowing from an action that was made possible by another
  action located either in or out of a floodplain.  An example, in this case,
  of an action with secondary impact would be the providing of infrastructure,
  i.e.  central sewerage facilities, that can help stimulate growth in flood-
  plains.   The DEIS summary recognizes the potential influence of this type
  of infrastructure on environmentally sensitive areas (pp 8,9).

  The  DEIS  addresses, at least preliminarily, the potential for adverse
  primary impacts of various alternatives.  Avoidance procedures (relocation
  of sites  and mitigating measures (floodproofing in plant design) are dis-
  cussed  (11-49  and IV-28).

-------
The potential for adverse secondary impacts of various alternatives does
not seem to have been addressed in sufficient detail.  Many of the pro-
posed sewer lines follow watercourses,  e.g. Stony Run, Lickinghole Creek,
the Chickahominy River, Totopotomy Creek.  Without contrary evidence, it
would seem that floodplain areas, being adjacent to sewer lines, would
thereby be made more developable.

A more detailed picture of existing and potential land use within the limits
of one hundred (100) year floodplains would facilitate an assessment of
probable impacts of the planning alternatives.  Figue II-3, the "General
Land Use Plan of Hanover County," is not of a large enough scale to support
such an assessment.

The floodplain information that is the basis for figure II-8, "Flood Hazard
Areas of Hanover County," has been superseded by a more recent Corps of
Engineers study.  Flood Hazard area maps accompanying the Flood Insurance
Study being prepared by the Corps of Engineers are now in draft form.  We
will be able to provide your office with access to these maps, which are
more detailed than those previously available.

In the event that further analysis indicates that floodplain development
would be supported by the various planning alternatives, strategies for
avoidance of these impacts should be discussed.  These strategies might in-
clude implementation of the zoning classifications such as those suggested
in the growth management plan for Eastern Hanover County (reference p. 11-10).

In summary, it is evident that the level of analysis of impacts relating to
NFIP regulations and E.G. 11988 has been in keeping with the preliminary
status of the DEIS.  However, subsequent documents should include sufficiently
detailed data to address the key requirements of the Executive Order:  the
identification of practicable alternatives that avoid floodplain impacts or
support floodplain development.  If it is found that there are no practicable
alternatives to primary impacts, the documents should fully address the
Order's provisions for minimization of harm to, or within, the floodplain
and restoration and preservation of floodplain values.  If secondary impacts
are inevitable, or probable, without intervention, strategies for avoidance
or minimization should be developed.

We are enclosing a copy of the U.S. Water Resources Council's Floodplain
Management Guidelines for Implementing Executive Order 11988. as well as a
summary, in the form of an eight-step process, of the Order's requirements
(attachment //I).  In considering indirect impacts on floodplains, steps 3,
4, and 5 are especially germane.

-------
Please contact Joseph Gavin of our office for any necessary clarifications
of our position.  We would be pleased to provide any possible assistance
in addressing the requirements of the National Flood Insurance Program or
the Executive Order.

Sincerely,

	)^ <:-U. i^4^ ^f ' -~-Se=-*£ -T^cfx-.-A, ZZZ

Walter P. Pierson
Regional Director
Federal Insurance Administration

Enclosure
cc:   Regional Director, CPD
      Asst.  Sec.,  CPD
                              6-17

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               United States Department of the Interior
                            OFFICE OF THE SECRETARY
                                Northeast Region
                                15 State Street
ER79/207                   Boston, Massachusetts  02109


                                                   April 27, 1979

       Mr,  Jack Schramm
       Regional Administrator, Region III
       Environmental Protection Agency
       Sixth & Walnut Streets
       Philadelphia, PA  19106

       Dear Mr. Sehramm:

       The Department of  the Interior has completed its review of the draft
       environmental impact statement for Wastewater Treatment Facilities
       Planning for Hanover County, Virginia:  Phase II area.  Our comments are
       listed below by our  areas of jurisdiction and special expertise.

       General Comments
       The proposed Phase II water treatment facilities for the Hanover County
       is part of the larger, more inclusive Greater Richmond Metropolitan Area
       Water Quality Management Plan.  The Phase III plan in conjunction with
       Phase I (which provides waste management facilities for the Mechanicsville-
       Beaverdam Creek drainage area of  the county), is intended to copy with
       waste management needs throughout the entire county.  The draft document,
       however, falls short in adequately reviewing the full range and scope
       of potential environmental impacts anticipated from this plan.

       Hanover County is  drained by two  major  stream basins, the Chickshominy
       and the Pamunkey.  Both streams,  particularly in the eastern portions of
       the county, are associated with high quality fish and wildlife resources.
       Extensive wetlands in the form of fresh water marshes and wooded swamps
       are present and critical spawning grounds for striped bass and other
       commercially and recreationally important fish species are located there.
       The proposed project plans, particularly those associated with aquatic
       habitat, could result in extensive  and  permanent losses to fish and wild-
       life resources in  the area.  The  draft  environmental  impact statement
       should provide a more thorough assessment of these impacts.

       Fish and Wildlife  Resources
       The statement is made in paragraph  3, page 11-36, that due to low flows
       during certain periods  of the  summer, the only flow in some streams will
       be treated effluent.  On page  IV-21, it is further stated in paragraph 1
       that under certain conditions  the entire Totopotomoy  Creek flow may consist

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                                -2-
of secondarily treated effluent.  Several alternative plans call for this
condition and it is indicated that significant adverse water quality
impacts can be expected.  The nature and degree of these impacts, however,
are not discussed.  Considering the potential significance of this con-
dition, a more thorough investigation is needed.  A determination should
be made of what pollutants would be present, in what quantify and their
ultimate impact on the ecosystem.

One of the more important impacts associated with high percentage effluent
flow in a stream is the toxic effect of chlorine residues left over from
waste treatment.  Chlorine can have detrimental effects on fish and
benthic populations.  A thorough investigation of potential impacts result-
ing from this condition should also be conducted.  A very brief but inade-
quate, discussion on this topic appears on page IV-25.

On page IV-21, a discussion of "construction impacts" is provided.  The
draft document states that "...construction of gravity sewers, inter-
ceptors, and force mains along stream beds will result in short term in-
creased erosion and sedimentation."  Depending on the specific alternative,
several miles of stream bed could be significantly impacted as a result
of streambed construction.  These impacts will not only be   short-term
but long-term and permanent as well.  Loss of vegetation, alteration of
streambed substrate and contour, and loss of channel stabilization are
potential permanent impacts.  Erosion and sedimentation, although temporary,
can have long-term impacts in terms of losses of aquatic invertebrate
populations.

On page IV-26, paragraph 1, it is stated that construction activities
within the lower Totopotomoy Creek Basin would result in severe impacts
on the varied marsh ecosystem.  If this is the case, and based on plan
summaries it appears certain it would be, a more detailed analysis of
impacts to the ecosystem should be done.  This type of analysis should
include a habitat survey with aquatic and terrestrial resources inven-
tories and a delineation of project associated losses.

In the same paragraph referenced above the statement is made that physical
stream conditions altered by construction activities "...would be restored
by the natural scouring and restoration effects of spring flows or seasonal
upstream flow increases."  This natural restoration process occurs only on
a limited scale.  It is highly doubtful that the type of streambed altera-
tion that is anticipated from installation of sewer lines would be repaired
by natural processes.  Alteration of stream substrate composition, pool and
riffle areas, and streambed contours cannot be repaired by natural scouring
and upstream flow increases.

Based on figures provided in the draft statement, extensive streambed areas
will be impacted by project construction.  Because of the quality and
quantity of habitat that could be impacted, alternative pipeline routes
should be proposed and investigated.  A route can parallel a stream, but

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                                -3-
should maintain a minimum of 150 feet offset from the center-line of
the stream.  The buffer between the pipeline and the stream allows the
stream and its riparian vegetation to remain intact.  Pipeline routes
which traverse wetland habitat should also be avoided.  Pipeline installa-
tion through marshes can result in loss of vegetation and alteration of
water circulation and drainage patterns.

The statement on page IV-5, paragraph 2, that full implementation of the
proposed sewer project would serve to reduce the current indiscriminate
scattering of various kinds of development is probably not an accurate
statement without the support of proper zoning laws, an adequate facilities
law, or the equivalent.

Outdoor Recreation
Units of the National Park System within the county are identified and
briefly described on page 11-59 under the heading of Public Outdoor
Recreational Areas.  These units are of historic significance and, thus,
we suggest in the final statement that they be described under the Historic
Sites heading (page 11-56).  These sites can be further identified by
location on Figure 11-12.

It is apparent that the Environmental Protection Agency (EPA) recognizes
its responsibility under the National Historic Preservation Act and 36
CFR 800 to have intensive archeological survey work done to identify
National Register' and eligible properties in the area of potential impact.
However, we do not agree that this should be done "once the final locations
of sewer lines, pumping stations, and land application sites have been
established" (page IV-32).  A staged plan of survey work and other
investigations should be implemented, so that results of archeological
and historic site identification studies can be used to narrow project
alternatives and make better decisions on facilities.  For example,
archeological survey  investigations could begin first at proposed treat-
ment plan alternate sites.  As information becomes available on the
relative acceptability of these sites, survey work could be expanded to
help analyse best locations of gravity sewers, force mains, pumping stations,
and other facilities.  In consultation with the Virginia SHPO, (Tucker H.
Hill, Virginia Historic Landmarks Commission, 221 Governor St., Richmond,
VA 23219) data should be assembled to help predict the most likely
archeological site locations from existing information.  Treatment
facilities and further survey work should be planned accordingly.

The final statement should include a full discussion of the methods and
results of survey work, as well as an assessment of expected impacts from
the various alternatives.  The views and recommendations of the Virginia
SHPO should be included, as well as evaluations of historic and archeo-
logical resources for possible inclusion in the National Register of
Historic Places.

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                                -4-
The Chickahominy River from the James River to U.S. Route 360 and the
Pamunkey River from Herrick Creek to Liberty Hall are included in the
final list of rivers or stream segments that have been identified in the
Wild and Scenic Rivers System Study conducted by the Heritage Conservation
and Recreation Service, Northeast Regional Office.  This study is an
inventory and evaluation of rivers in the northeast region and will be
used as one factor in determining suitability for, further study and/or
potential inclusion into the National Wild and Scenic Rivers System.

This list, which is part of the results of a 3-year effort, is a refine-
ment of the Preliminary Draft List which was issued in February 1978 and
the Second Preliminary Draft List which was issued in September 1978.
The Final List is the result of a detailed resource evaluation which
included site reconnaissance.  Rivers on the list have passed the final
system study evaluation phase.  They are generally 25 miles or more in
length (there are numerous exceptions) and are in a relatively undeveloped
or natural condition.  To be eligible under Public Law 90-542 the rivers
must meet the following criteria:

1.  Be a free-flowing river or stream

2.  Be free of certain types of alterations (i.e., impoundments, rip-
    rapping, channelization, etc.)

3.  Be largely undeveloped (rivers or sections of rivers with shorelines
    or watersheds essentially primitive or largely undeveloped)

4.  Be adjacent to or within a related land area that possesses an
    outstanding remarkable geologic, ecologic, cultural, historic,
    scenic, botanical, recreational or other similar value.  (Interpreted
    to mean an area of multi-state or national significance.)

This phase of the System Study is essentially the natural or wild component,
Rivers of urban, recreation and cultural value will be examined at a later
time.

It is important to note that the System Study is a survey of rivers and
should not be confused with the more detailed Congressionally mandated
studies under the National Wild and Scenic Rivers Act which are conducted
by the National Park Service.  The purpose of the System Study is to:

1.  Identify a balanced repreeentation, in terms of physiographic
    provinces and sections, of the most significant river segments in
    the nation.

2.  Identify for the President and Congress the parameters of a basic
    National Wild and Scenic Rivers System.
                                   2-1

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                                -5-
3.  Identify those rivers which may be considered under the provisions
    of Section 5(d) of P.L.  90-542, as amended.

This most recent list, although final, does not preclude the addition or
deletion of rivers or river  segments at a later time.

The Virginia State Comprehensive Outdoors Recreation Plan (SCORP) prepared
by the Commission of Outdoor Recreation (Revised Draft, August 1978) also
lists the Chickahominy River in Charles City,  New Kent, Henrico, and Hanover
Counties (in addition to those scenic river areas included in the draft
environmental statement) as  having potential for study and possible
inclusion in the Virginia Scenic Rivers System.

The Virginia Commission of Outdoor Recreation, in coordination with the
Department of Highways and Transportation, established the Virginia segment
of the Trans-Continental Bike Route which traverses Hanover County.  No
mention is made of the Hanover portion of this bicycle trail in the draft
environmental statement.

The final environmental statement should evaluate the impact of the proposed
project on these identified  river and trail segments.

Water Resources
Land application sites 1 and 2 proposed under alternatives A2, B2, and Al
are located within groutid water recharge areas.  On page IV-29, it is
stated that potential long-term impacts on artesian aquifers located in
the area may result from contamination by nitrates, heavy metals, phos-
phorous, and total dissolved solids.  Under measures designed to protect
ground-water recharge areas  and aquifers, a ground water monitoring
system should be proposed.

Mineral Resources
Bureau of Mines data lists mineral production of stone, aplite, and sand
and gravel in Hanover County, Virginia.  However, according to the Bureau
of Mines Mineral Industry Location System (MILS), current mineral pro-
duction does not occur in the immediate area of the proposed project.

In order for this draft environmental impact statement to be considered
an adequate assessment, mention should be made of the mineral resources
in the project area and the amount of those resources which will be fore-
gone  (preempted) if the plan is implemented, along with the commitment of
mineral resources for construction purposes.

Summary
The effort by Hanover County to upgrade and improve existing wastewater
treatment facilities in the area is heartily supported by the Department
of the Interior.  It is apparent, however, that several aspects of  this
facility plan require further study to assess more fully the impacts
that may result from implementation.  Also, other, loss impacting alterna-
tives must be developed that will protect fish and wildlife, recreational
and cultural resources in the area.

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                                -6-
The Department, under the provisions of the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U. S. C. 661 et seq.) will review and
comment on all work requiring Department of the Army authorization.
Several components of the facilities plan, such as activities impacting
streams and wetlands, will require permitting.  Based on the information
available to us at this time, our most probable position on the issuance
of permits needed for the construction of several of these alternative
plans would be one of opposition.  It is recommended that further
coordination with the U.S. Fish and Wildlife Service, Annapolis, be
initiated on this aspect of the project.

                                Sincerely yours,
                                William Patterson
                         Regional Environmental Officer
                           f'~^   —) •'->
                          AS -' Z^ 5

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                    U. S. DEPARTMENT OF TRANSPORTATION
                         FEDERAL HIGHWAY ADMINISTRATION
                                REGION THREE
                            Post Office  Box  10045
                         Richmond,  Virginia   23240
                                                      April  5, 1979
                                                      IN REPLY REFER TO:
                                   Subject:  Wastewater Treatment Facilities Planning
                                            Hanover County,  VA
                                            Phase II Area
                                            Draft Environmental Impact Statement

United States Environmental  Protection Agency
Region III
6th & Walnut Streets
Philadelphia, PA  19106

Attention:  EIS Preparation  Section

Dear Mr. Schramm:

We have reviewed the Draft EIS for the subject project, and would like to thank
you for the opportunity to comment on the proposed action.  Following are our
comments which have been arranged by subject area depending on priorities which
our agency uses in its overall functions.

Summary Comments

We fully agree with the statement that the EIS should be used as a  "decision
making tool" (pg. 1-3).  However, we doubt that this document gives the decision
maker all the information needed to objectively make the correct decision on
this important Hanover County issue.  We base our contention of this on state-
ments contained in the Draft EIS such as: (Underlining added for emphasis)-
Page x
     "Certain information normally contained in a wastewater facility  plan  has
     not been provided to the environmental consultant for incorporation  into
     this EIS, therefore, comprehensive environmental Impact analyses  cannot
     be undertaken at this time.  The following items must be  received from
     BYK in order to complete the Environmental Impact Statement:

     -Comprehensive discussion of the alternatives screening process  from
       local to subregional to regional alternatives  including  costs;

     -Consideration of phasing of sewerage facilities and details  of  Federal
       state/local financing  consideration;

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                                       -2-
     -Energy requirements for proposed facilities discussed in the recommended
      plan;

     -Facility Plan design flows by contributing component (i.e.,  residential,
      commercial, etc.) current and ten year incremental  increases;

     -Sludge management considerations for feasible alternatives.";

on Page 1-16

     "The issue of potential  impacts of wastewater treatment alternatives  (both
     primary and growth-induced) orTenvironmentany sensitive areas unsuitable
     for development is recognized as being necessary to  address  in the EIS.
     Hopefully, the joint EIS/Facilities Planning process will  develop  strategies
     to ensure that maximum protection will be given to areas identified as
     important.  This evaluation will include identifying impacts  on historic
     sites.";

on Page III-ll

     "Sites 1, 2, 15 and 16 were chosen for further study." without maps or  an
     adequate discussion of sites 15 & 16 being presented equal  to that presented
     on Sites 1 and 2.

on Page IV-18

     "Complete cost data for all alternatives has not yet been provided by the
     facility planning engineer."
     and
     "Data concerning phasing of treatment facilities has also not been provided
     by BYK, and consequently, specific phasing possibilities and  bond  require-
     ments cannot be discussed in this EIS."

on Page IV-23 Relative to Stream Crossings

     "No data available on Alternative 8-1" which was the recommended alternative
     in the '75 Facilities Plan

Therefore it is our recommendation, that when all the information  has been
developed to adequately address all impacts and alternatives, a supplemental
draft environmental impact statement be prepared.  We understand that many
delays have previously occurred in the preparation of the DEIS, but we
believe that the DEIS should not be sacrificed as a result of these delays
especially since one of the two "most significant delays" which you identified
is the result of your other consultant (BYK) on this project not supplying the
necessary alternative data in a timely manner.

In addition to the deficiencies which you yourself have noted in the DEIS, we
feel  the following areas need more information or clarification.
                              /

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                                       -3-


LAND USE

On page 1-4 the DEIS states that:

     "Phase II of the Hanover County wastewater management program, which is
     the subject of this joint Facilities Plan/EIS effort, is concerned with
     providing some form of sewage service to the remaining portions of the
     County where some type of non-rural, high density development currently
     exists and/or is planned to continue or occur."

However, when we compared the proposed Facilities Plan with the Hanover County
General Land Use Plan (Figure II-3), we noticed that large amounts of land
to the north of Mechanicsville, east of State Rte. 615, and west of Ashland
zoned low and low-medium density residential and some industrial land has
not been included in either the Phase I or Phase II Plan.  Since we are in
total agreement with your inference that construction of the proposed sewerage
facilities could serve as an important vehicle for implementing the Comprehensive
Land Use Plan, we feel that this document should address all of the county
that is planned to have a non-rural type of development.

On page IV-7 the DEIS states that because prime agricultural land is ideally
suited for septic systems, the risk of losing valuable agricultural land to
residential development is greatly enhanced.  Although we agree entirely with
this statement, we cannot believe that the potential for residential development
is as great on the agricultural land as it would be if Phase II was constructed
especially in the area known as the Lower Totopotomoy Basin (Planning Unit 5),
where approximately 60% of the area planned for sewers is zoned Agricultural,
Forest, Widely Scattered Residences, or Vacant Land in the County's Land Use Plan.

TRANSPORTATION

We realize that your document recognizes that their is an interrelationship
between transportation, land use, and sewerage facilities.  However, we feel that
the DEIS should place more emphasis on the impacts on the transportation system,
which will result from this project.

We believe that your document should address the additional vehicle trips which
will occur as a result of the more intense development, and assign these trips
to various highway facilities in the study area.  Once this data has been deve-
loped, it will be easy to compare this data to the carrying capacity of individual
facilities thereby identifying serious bottlenecks and areas where unacceptable
levels of service will result.

WATER QUALITY

As you stated both land application sites (1 & 2) are located in special flood
hazard areas.  One possible mitigation measure to impacting the floodplain
at either of these two sites would be to use either of the other two land
application sites (site 15 or 16) which are both mentioned as sites that are
still open for further study.

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                                       -4-


In addition to the major wetlands mentioned in your DEIS, there are several
other areas where wetlands are impacted by various alternatives, such as,
the Southern Corridor Interconnection (Figure III-6).  In the area east of 1-95
and north of State Rte. 656, -the proposed gravity sewer is located in a
wetland as identified on the USC&GS map.

GENERAL COMMENTS

Although the DEIS mentions a need for some additional public services (schools,
parks and retail services), it fails to discuss the need for additional emergency
services (fire, police, ambulance) as well as the possibility of the county
needing to construct some medical facilities (hospital) rather than rely on the
City of Richmond and Henrico County for these services.

Probably the need for these services can be rationalized as being a necessity
anyway relative to the projected population growth but as the DEIS states "In
absence of the proposed sewer facilities, current projections for the area's
2003 population would have to be revised downward.", and thereby population
projections could be classified as overly optimistic.

We hope that this review will assist you in processing the Environmental
Impact Statement.
                                        Sincerely yours,
                                        Paul F. Chamberlain
                                        Division Administrator

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  PUBLIC HEARING TESTIMONY




        APRIL 4, 1979




(Incorporated by Reference)

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            CRANE - SNEAD & ASSOCIATES, INC.
                    COURT REPORTERS
                  M08 EAST MAIN STREET
                    RICHMOND VIRGINIA
                     PHONE 548 - 2801
UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY

                   REGION III

          Philadelphia, Pennsylvania




        HANOVER COUNTY PUBLIC HEARING


                 April 4, 1979


                    8:00 p.m.
          Hanover  County Courthouse,
               Hanover,  Virginia
                     IN RE:
    HEARING FOR THE PURPOSES OF RECEIVING
      INPUT FOR THE FACILITIES  PLAN AND
   EPA'S FINAL REGULATIONS  FOR  ENVIRONMENTAL
               IMPACT STATEMENT

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                        CRANE - SNEAD & ASSOCIATES, INC.
                               COURT REPORTERS
                              1108 EAST MAIN STREET
                               RICHMOND, VIRGINIA
                                PHONE 648 - 280 I
       APPEARANCES:
 1
       STEVEN A. TOROK, Chief :of  the  Environmental Impact Statement
                        Preparation Section,  U. S. Environmental
                        Protection  Agency,  Region III, Philadelphia,
                        Pa0, Hearing  Officer
       TOM SLENKAMP, Project Monitor  representing the EIS Preparation
                     Section of the Environmental Protection Agency
                     Region III,  Philadlephia,  Pa
       ROSEMARIE BALDING, EPA, Region III,  Philadelphia, Pa.
       PAGE NUCKOLS, Chairman of  Hanover  County Board of Supervisor
 8      PETTIS MILLER, Vice Mayor, Town of Ashland, Virginia
 9      JOHN B. STEADMAN, Mayor of Ashland,  Virginia
 10
 11
 12
 13
 14
 15

 16

 17
 18
 19
20
21
99
                         £-30

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                 CRANE - SNEAD & ASSOCIATES, INC.
                        COURT REPORTERS
                       1108 EAST MAIN STREET

                        RICHMOND VIRGINIA
                         PHONE 649 - 2801
PERSONS GIVING TESTIMONY
Steven A. Torok, Chairman
Mrs. Pettis Miller
Mr. Tom Slenkamp
Mr. James Bruce
Mr. Robert Bremner
Mr. Tim Rohrmoser
Mr. T0 A. Clark
Mrs. Anne Smith
Mr. Donald Wiber
Mr. Tom Evans
Mr. Robert Phillips
Gail Enroughty
Nina Peace
Mrso Lou L. Hanks
Mr. E. C. C. Woods
Mrs. Margaret R. Miller
Mrs. Bruce V. English
Mr. Bruce V. English
Donald McDonald
John S. Graham
Lois Wickham
Ron Jones
Pettis Miller
George Nester
John B. Steadman
Preston Wade
Bob Wilby
Bob Ostergren

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                 CRANE - SNEAD & ASSOCIATES, INC.
                        COURT REPORTERS

                       1)08 EAST'MAIN STREET

                        RICHMOND. VIRGINIA

                          PHONE 648 -2801
APPEARANCES:

L.  Clark, Route  5,  Box  150, RPCCA
Barrett S. Hopkins, Route 5, Box 300, Glen Allen,  Virginia,
 Green Top Sporting Goods
John Cibulka, P. O. Box 6616, Richmond, Water  Control Board
E.  A. Beck, 1103 Ridgeriver Road
E.  F. Cartulin,  Route 2, Box 263, Mechanicsville,  Virginia,
 RPCCA
Mike Bagby, State Health Department, Richmond,  Virginia,
Kevin McCarthy,  333 G. Grace Street, Richmond,  Virginia,
 Richmond News Leader
T.  0. Leadbetter, 405-A Air Park Road, Ashland,  Virginia,
 Leadbetter Construction,
Peggy N. Allen,  2940 Atlee Road, Mechanicsville, Virginia,
 Allen Transport
A.  ,G. Allan, Jr. 2940 Atlee Road, Mechanicsville,  Virginia,
 Allen Transport
L.  P. Wade, 2310 Langhorn Road, Lynchburg, Virginia,  Wiley  &
 Wilson
Anne N. Smith, Route 5, Mechanicsville, Virginia,  Rural
 Point Concerned Citizens Association
Lois Wickham, Route 4, Ashland, Virginia, -land  owner,
Jerry Moore, P.  0.  Box 231, Ashland, Virginia,  Herald-
 Progress
William C. Wickham, Jr., Route 4, Box 182, Hickory Hill
 Farmsi
Thomas W. Evans, 1402 Pump House Drive, Richmond,  Virginia,
 Virginia Bass State Federation, Inc.
S.  N. Enroughty, Route 7, Box 21, Mechanicsville,  Virginia,
 RPCCA
Gail Enroughty, Route 7, Box 21, Mechanicsville, Virginia,
 RPCCA
Greg Swanson, 5710 Midlothian Turnpike, Channel  12, WWBT-TV
W.  K. Henberg, Jr., Ashland, Va., town council
E.  Taylor, Mechanicsville, Virginia, citizen
Howard Dickenson, WWBT-TV
George Nester, P. 0. 271, Ashland, Town of Ashland,
J.  S. Graham, III,  1200 Ross Building, Richmond, Virginia,
 Hanover Properties, Inc.
Mitam Gandhi, 1301 Roseneath Road, Richmond, Virginia,  State
 Health Department
Randy Morrissette,  1301 Roseneath Road, Richmond,  Virginia,
 State Health Department

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                 CRANE - SNEAD & ASSOCIATES, INC.

                        COURT REPORTERS

                       1108 EAST MAIN STREET

                        RICHMOND. VIRGINIA

                         PHONE 648 -2801
                                                         5.
APPEARANCES:   (Continued)
 Robert  M.  Ostergree,  P.  O.  Box  211,  Mechanicsville, Virginia
 T. A. Cole,  Jr.,  Route  6, Box 31, Mechanicsville, Virginia,
  landowner
 T. A. Cole,  Sr. Henrico, Virginia,  landowner
 Nancy Cole,  Route 6,  Box 37,  landowner
 Ronald  S.  Jones,  2110 Avondale  Dr,  citizen
 T. A. Clark,  Route 5, Box 150,  Mechanicsville, Va., RPCCA
 Pete P. Tubee,  6434 Penrith Drive,  Mechanicsville, Virginia
  County of Hanover
 Robert  Phillips,  Jr., 6410  Studley  Road, Mechanicsville,
  Virginia, homeowner
 Robert  N.  Pethlan, III,  Route 1,  Box 219, Doswell, Virginia
  homeowner
 K. C. Das, 4010 W. Broad Street,  Richmond, Virginia,
  State  Water Control Board
 B. P. Gayle,  4010 W.  Broad  Street,  Richmond, Virginia,
  State  Water Control Board
 L. G. Cox, 6824 Wheeling Road,  Mechanicsville, Virginia,
  business  and home owner
 Mrs. E. Casterlion,  Box  263, Route  2, Mechanicsville, Va.
  home owner
 Mr. E.  Caterlion,  Box 263,  Route  2,  Mechanicsville, Va.j
  homw owner
 Clyde L. Goff,  6001 Lakeside Avenue,  Richmond, Va.
  Beechwood Development Corporation
 Joseph  C.  Dowhe,  6400 Croftwood Dr.,  Mech., Va. Mech. Civic
  Association
 Pauline Meadow, 1110  Atlee  Road,  Mech., Va. Mech. Civic
  Association
 C. Fred Swats, Pembroke  Six, Suite  208, Virginia Beach,
  Virginia, Wiley  & Wilson,  Inc.
 Bruce V. English,  P.  O.  Box 267,  Ashland, Va.  land owner
Virginia English,  P.  O.  Box 267,  Ashland, Va.  citizen
 Lou L. Hanks, P.  0.  Box  1031, Glen  Allen, Virginia, South
 Anna Citizens Council
Joyce L. Hoyle, 6316  Morningside  Dr., Richmond, Virginia,
  SWCB
R. D. Weber,  Sr.,  Route  5,  Box  152,  Mech, Va., RPCCA
Nina K. Peace, Route  1,  Box 281,  Ashland, Virginia, Board -of
  Supervisors

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                       CRANE - SNEAD & ASSOCIATES, INC.
                              COURT REPORTERS
                             1108 EAST MAIN STREET
                              RICHMOND, VIRGINIA
                               PHONE 648 -2801
      APPEARANCES:   (Continued)

      Colin Williamson, Route 6, Box 671, Mech., Virginia
      John W. Fauborn, 307 Arlingston St., Apt. 56, Ashland,
       Virginia, Hanover County
      Tom O'Kelly, Sr. 6201 Delkin Circle, Mech., Va., Hanover
       County
      York Phillips, Planning Office, Hanover, Virginia, Hanover
       County
      Mrs. W. W. Bradley, Route 4, Box 184, Ashland,  landowner
      Bill Gulledge, McLean, Virginia, Engineering Science
      Frederick Kennedy, McLean, Virginia, Electronic Research
       Associates
      Ron C. Lyons, Mobil Chemical Co, Richmond, Virginia
      Louis L. Guy, 10523 Main St., Fairfax, Virginia, Patton,
      Harris, Rust & Guy
      Elaine G. Fenne, Route 2, Box 359, Mech., Virginia
 9      Utilities and Solid Waste
      Hank Lowry, 605 Maple St., Ashland, Virginia, Town Council
10     Rosemary O'Kelly, 6201 Delkin Circle, Mech., Virginia,
       resident
11     Helen M. Lachman, 1203 Boxlake, Mech., Virginia
      Ray E. Martin, 115 Henry Clay Road, Ashland, Virginia
      D. G. MacDonald, Route 1, Doswell, Virginia
      John Steadman, 2215 Falcon Hill Place,Lynchburg, Virginia
       Wiley & Wilson
      Diane Slusarski, P. 0. Box 231, Ashland, Virginia,
       Herald-Progress
      Shirley S. Mayer, Route 2, Box 143-E, Ruther Glen, Virginia
 0      Leadbetter Const. Co.
      Warfield Smith, Route 5, Box 165, Mech., Va.
lb     M. J. Whittaker, 2905 Waynedale Dr., Mech., Va.
      Margaret R. Miller, P. O. Box 202, Ashland, Va. Citizens for
       Sensible Growth
      M. M. Bordley, Jr., Box 182, Route 4, Ashland, Va.
18     K. T. Specer, 635 Mt. Herman Road, Ashland, Va.
      Mrs. John Maples, Route 1, Box 382, Mech., Va.
      E. C. C. Woods, Jr., Route 2, Box 8, Hanover, Virginia,
       Board of Supervisors,
20     Mr. and Mrs. William A. Bruce, 1207 Arnoka Road, Mech.,
       Virginia, land owner
      W. R. Phillips, Jr., 1203Barette Avenue, Mech., Va.,
24

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                 CRANE - SNEAD & ASSOCIATES, INC.
                         COURT REPORTERS
                        1 109 EAST MAIN STREET
                         RICHMOND VIRGINIA
                          PHONE s«9 - 230 i
                                                         7.
EXHIBITS
	.                                                      I
                                                              i
Flood Plain  Information  Totopotomoy Creek  Book,  Hanover      )
 County                                                       j

A closer Look  at Hanover County's  Proposed Facilities Plan,
 Phase II
Exhibit No.  1  - A  letter  from  Mr.  Robert  G.  Bremner,  Jr.
to Mr. Tom Slenkamp  dated April  3,  1979

Exhibit No.  2  - The  Confidential Survey of Hanover County
Residents

Exhibit No.  3  - A  group of correspondence submitted into the
record by Mr.  E. C.  C. Woods

Exhibit No.  4  - A  statement from Mr. Tom  Slenkamp, Project
Manager represeting  the EIS PREPARATION SECTION of the EPA

Exhibit No.  5  - A  statement from Thomas W. Evans of the
Virginia B.A.S.S.  State Federation,  Inc.

Exhibit No.  6  - A  statement from Gail  Enr.^ughty, President
of Rural Point Concerned  Citizens Association,  Inc.

Exhibit No.  7  - A  statement presented  by  Lou L.  Hanks
regarding the  Draft  Environmental  Impact  Statement for the
Hanover County Phase II Area and the Corresponding Facilities
Plan.

Exhibit No.  8  - A  statement presented  by  Margaret R.  Miller,
Co-Chairman, Citizens for Sensible Growth

Exhibit No.  9  - A  statement from Mrs.  Bruce  V.  English
dated April  4, 1979

Exhibit No.  10 - A statement from Mr.  Bruce  V.  English on
Hanover County Phase  II Facilities Planning.

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  PUBLIC HEARING TESTIMONY




     JANUARY 20, 1981




(Incorporated by Reference)

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                         UNITED STATES
               ENVIRONMENTAL PROTECTION AGENCY
                             and
                      TOWN OF ASHLAND
                  HANOVER COUNTY, VIRGINIA
In the Matter of:

WASTEWATER TREATMENT  ALTERNATIVES
FOR THE TOWN OF  ASHLAND AMD HANOVER
COUNTY(Phase II  area)

                 and

TOWN OF ASHLAND  "201"  FACILITY PLAN,
PRELIMINARY DRAFT.
JOINT HEARING
                                 Ashland Municipal Building
                                 Council Chambers
                                 Hanover Avenue and Thomnson Stree
                                 Ashland, Virginia 23005

                                 January 20, 1981
                                 8:03 o'clock, p,m.
Before
              THOMAS  SLENKAMP,  Project Monitor
              Environmental  Impact  Branch
              EIS Preparation Section

                           and

              RICHARD S.  GILLIS,  JR.,  Mayor
              PETTIS  FRAZI~R MILLER,  Vice Mayor
              BRUCE W. HAYNES,   Councilman
              LINWOOD HENDERSON,  JR.,  Councilman
              DONALD  P. ROBERTSON,  Councilman
                                           Daniel J. Siegel
                                            Court Reoorter
                              C.R.I. ASSOCIATES
                              Court & Cnnferpnct Reporters
                                905 World Building
                             •Silver Spr..-.«. Maryland 20910
                                 •J01 :--.--M-
     6-37

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ALSO PRESENT:
     DAVID REYNAL, Town Manager
     DOUGLAS CULLINANE, Director of Public  Works
     ELIZABETH C. KENNON,  Township Clerk

     JOHN HODGES,, Hanover  County Panning Department
     JERRY P. OWEN, Chairman,  Hanover Countv  Board of Supervis
     NINA K. PEACE, Supervisor, Ashland District

     ROSEMARIE 3ALDINO, Environmental Protection  Agency,
          and others.
                        I_ N_ D E_ X

Speakers                                           Page

Richard S. Gillis,  Jr.,  Mayor                        3

Thomas Slenkamp                                      4

Douglas Cullinane                                    9,  66

John Hodges                                        ,.23,  51,

Bruce English                                       36,  66

Gail Enroughty                                      ^5

Margaret Miller                                     53

Mr. T. A. Clark                                     63

Mrs. Bruce English                                   64

Nina K. Peace                                       69



                      ATTACHMENTS
ars
Letter read into record by  Mr.  Hodges,  from J.  W.  Fairburn,
Interim County Administrator,  dated January 20,  198l.

201 Facilities Planning Projections,  Hanover County,  Va.,
January, 1981, and attached memoranda.

SIS NEWS,  December 1930 Hanover County/Ashland,  VA Wastewater
Treatment  Planning.
                         £-3?

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  PUBLIC HEARING TESTIMONY




       JUNE 3,  1981




(Incorporated by Reference)

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                   Board Meeting June 3, 1981


 PUBLIC HEARING -  PAHSE I EXTENDED -  WATER POLLUTION CONTROL
 FACILITIES  PLAN 4/81

.Jim Popek - Chickahominy District

    1.  Has the  area  beyond Interstate 95 enough  density  to support
       the cost of extending  the pipe in that area.

    2.  Concern  as  to the cost the extension of Phase I area will
       create in other  services  required.

 T.  A.  Clark -  Henry District

    NO  QUESTIONS

 Nicholas  A.  Spinella - Henry District - Attorney  for Avondale  Corp.

    1.  Would welcome opportunity to have a meeting with  County
       representatives  in order  to work out a pro rata cost  of
       the extension so that  the developers of property  would
       be  paying their  fair share of  any extension.

       Supports  the  situation which must be corrected for  the
       residents of  Blue Star Estates.

Shirley Creasy  -  Chickahominy District  -  Blue Star  Civic  Association

    NO  QUESTIONS

    Stated residents of Blue  Star Estates  would  like the County
     to take over  the utilities  in Blue  Star  Estates at  no cost
     whatsoever  to the  residents.

Charles M.  Johnson, Manager  of  Public Affairs,  RFSP Railroad

    1. Would like  to see  Phase I  Extended  extend line to land
      already zoned industrial  up to  the  RFSP

    2. Need  to obtain additional  facts from the  County as  to what
      the cost  factors  would  be

Ann  Spain - Chickahominy District

   1. Ask that  Board seriously consider including Blue  Star Estates
      in Phase  I Extended

Margaret Miller - Beaverdam  District  -  Citizens for Sensitive Growth

   1. Cost for  sewage treatment  for Ashland

   2. Why land  treatment for Phase I  Extended is so much  less expensive
      than land treatment for Oak Hill Estates.

   3. Would  like to  know whether innovated procedures beyond land
      treatment were considered

   4. Would  increasing  the number of lagoons have any application
      in any of these  cases and have they been considered.

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                         OIHT  V^ ONCERJTED
           S3^a^£3M=?sa???,^J^aw»jli^-.^r.irffsrTF'r'T Vf.uama&pssssza- f^
           ROTFflT?  BOX 21   KECHA5ICS7ILLE,  71.  23111
 PUBLIC 'HEARING STATEMENT OF JUNE 3, 1981

 For the  record my name is Gail Enroughty, and I am represeint  Rural

 Point Concerned Citizens Association,  Inc.  As many of you are aware

 Rutal Point  has been following the Phase II, now Phase I Extension

 for a numer  of years with great interest and has had representation at

 the public hearings..  Our initial concern was and is. the Totopotomoy
         ^c_ AM > *.^ no^vA tWwx^ c_  o-v\i. oA^u_\j_>^ \M_vi ^M-l_£ uOc^AA^Ui c^
 Creek and possible discharge to this creekAand the Pamunkey River

 discharge.   We still have not seen answers to questions raised during

 the May, 1976  hearing and answers to the list submitted by the Town

 of  Ashland and others many years ago.   If my memory serves me  correctly,

 there were almost 100 questions submitted.




 Please refer to the  hearings held May,  1976; April, 1979 and January,

 1981 in  reference to the concerns and questions  expressed by Rural

 Point.   Also,   I  followed up on the statement given during the

 January. 1981  hearing with  a letter to  Mr. Thomas  Slenkamp dated

 March 6, 1981,  and as of this date still have not  received a reply.

,1 submit a copy of that  letter for the  recordT]  So again we ask:

 What evaluation has  been done on the upper portion 6f the creek

 and  what is  the outcome? What portions were found to be environmentally
                   oo-^ V1*- ^' £*-J ^ Von ck "Vvc Q_^- '-~±i—.
 sensitive if not  the whole-\creek,  and has the floodplain information

 been corrected}?^  In  my opinion there is absolutely no excuse for our

 questions pertaining to  the  sensitivity of the creek not being  officially

 answered before now.   Is this an example of the  bureacury fulfilling

 the  requirements  by  having  a public hearing and  not responding  to  the
                                     meetings
 concerns of  citizens? Also  how many XxxxiNgs have been held without
notification of  those  of  us  who  requested to be notified?  The

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 page Z



 Totopotomoy Creek  is  a  vital  portion  of  the  overall plans for some and

 we would appreciate an  answer tonight.



f The following are  some  of our other concerns which  we  at  least want

 included in this record and hopefully will be  addressed very  soon.   First

 we have previously questioned the issue  of interbasin  transfer.  With

 the inclusion of Blue Star Estates and the TSX2sS£Xo Totopotomoy Creek

 we are dealing with two watersheds.  Will this be allowed?



 Next the County recently contracted with an engineering firm  at a cost

 of approximately $10,000. to  study funding of alternatives.   How can
       a^r1'. ^jU^-Js^r^^c-^Y''^' C'°"V' " •Jl-^-->';  ~-<-~ \ V-c :v,-^,
 a final ElS^be prepared without the publicl  having  this information

 available for comment tonight?  So again we are having a  public hearing

 for public comment without all the information being available.  And

 speaking of funding, the information sent out by the County dated April,

 1981 on page 3 states "it is  estimated that this system will  actually

 allow a reduction in the Phase I user costs."  The propaganda dated

 July,  1977 made available by  the VPI Extension Service in cooperation

 with the Hanover Board  of Supervisors for the purpose of  trying to get

 the August,  1977 bond referendum passed was in the form of questions

 and answers.   # 14 states:   "Is there any possibility of reductions in

 the proposed SHwer user rate  schedule?  Yes.   .There is the potential

 for a  large industry to connect to the County's utility system that

 would  have  a substantial impact on USHT rates.   The industry proposed,

 a  newsprint mill (BATO), is equivalent to 1715 homes.  If this

 industry  comes  to the County it will  help support the utilities program."

 //  A states:  "Does this mean that every taxpayer will help pay for the

 sewer  facilities?  No.   It  is anticipated,  but not guaranteed, that the

 residential  and commercial  USHTS of  the sewer facilities will pay the

 full cost Of  ,-1-^ system."   And # 15  states:  "What effect will the passing

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 page 3
 of the bond referendum have on an individual's taxes in Hanover County?



 The intent is to make the County's utility program self-supporting



 through the connection fees and bimonthly sewer rate.   It is projected



 that those who use the system will pay and therefore an indifidual s



 taxes should not be affected."  The Herald-Progress recently reported



 that the deficit for the 81-82 budget  year will be $830,000; so these



 statements are history and today we are facing the reality and will do



 so in future years.  We predict that the deficit will  continue to be



 larger, user rates will have to be increased and all County taxpayers



 will have to pay through increased taxes unless money  is  received from



 the potential users up front.   Throwing good money after  bad is not the



 solution.   It is interesting to note that on page 4, section 9 of the



,, addendum dated March,  1981 prepared by Patton,  Harris,  Rust and Guy
 \


 under user charges and connections  the following statement is made:



 "Federal regulations require that  sewerage  systems  being  built with



 Federal grant money be self supporting."  Along this same line,  section



 6,  page 18,  Table 6-1  of the addendum,  the  limited  build  alternative



 gives costs  for upgrading.   First  question,  are these  figures  based on



 a sliding  scale without considering  portions  of the existing systems



 being used?   Has each  system been  individually  evaluated?   Has the



 SWCB developed allocations for each  of these  discharges?   Were costs



 based on degree of treatment required?   Kingswood Court and Totopotomoy



 ^states are  the only two County owned  systems on this  table.   The Cost



 given to upgrade these two is  $831,500.   Again,  is  this figure accurate?



 The others are privately owned commercial,  residential and industrial



 systems.  Are these owners  willing  to  pay up  front  the costs  associated



with  this proposal for their systems?  According  to this  table,  if  these



 systems were  individually upgraded  the  dollar amount to do so  would



be  $2,277,000.   Section 1,  page 3  states:   "The  combined  cost  for Oak



      Estates  and Phase I Extended  is as  follows:  Construction Cost

-------
  page 4
  $2,907, 310.."  If the previous dollar amount of $2,277,000 was collected

  from the private system owners and substracted from the estimated

  construction costs, this would leave  a maximum total, of $630,310    „  ,-_
                            (L.-. W"> 'V^ <*~i i &- clH^ vf  ,(7,o'n dk^cr
  without grant money for the County to"finance.\ Of course, grant money ^'i

  either at 507o or 7570 would substantially reduce the cost to the owners

  of the private system and to the County.



  The next concern is in reference to the planning area, what is the amount

  of area being studied and being considered for sewer service in square

  miles.  At one time it appeared that the 8-1 plan was being scaled down

  considerably, but it now appears that  the area is being increased back

  to the 8-1 plan size.^



  During the April 4, 1979 hearing Mr.  E.  C.  C.  Woods,  Jr.  entered a

  number of letters into the record.   On page 74 at line 17 of the

  transcript Mr.  Woods stated:   "And  to this  date an audit  has not been

  performed or started that I am aware of."   Has EPA completed or started

  an audit?  Also,  since Phase I rates  will  be included in  the rates  for

  the Phase I extension,  has an audi^beeji_c^m^l£X§.d__on__Phase^I by __

  EPA as was my understanding would be  done.   If so,  where  can a copy of

  the addit be obtained?



(In  closing I would like to point out  that numerous  hearings  have been

  held  for  the Phase II/Phase I extension.  The  citizens have  raised  many,

  many  questions  and points of concern.  Also citizens  have written letters

  to  EPA.   Will the issues be addressed in the Final  EIS or will the
 citizen participation for the  most part  end up being  ignored.  _When,
 we expect answer^?  J
                '

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        RESPONSE TO PUBLIC HEARING QUESTIONS JUNE 3, 1981
     Draft Addendum Water Pollution Control Facilities Plan
           Phase I Extended, Hanover County, Virginia
     The following is a list of questions raised by citizens at
the required public hearing held on the Draft Addendum, Water
Pollution Control Facilities Plan, Phase I Extended, April, 1981
(prepared by Patton, Harris, Rust & Guy) held by the Hanover
County Board of Supervisors during their June 3, 1981 meeting in
the Henry Taylor Wickham Building, Hanover Virginia.  The ques-
tions are followed by the best response the County can make at
this time to these questions as prepared by the Hanover County
Department of Planning.

     1.  Gail Enroughty, Rural Point Concerned Citizens Associ-
         ation, Inc . ("presented prepared statement, questions
         summarized below).

         a.   Question:   "We still have not seen answers to
             questions  raised during the May, 1976 hearing
             and answers to the list submitted by the Town
             of Ashland and others many years ago".

             Response:   Attached (Appendix B) is a September,
             1976 list  of 105 questions primarily concerned with
             land application of wastewater developed by cit-
             izens and  staff following the May, 1976 public
             hearing, .on Phase II.  The responses to most of
             the questions raised are included in the fol-
             lowing documents used in ^he preparation of the
             Draft Addendum for Phase I Extended:

             REFERENCES:

         1.   Expanded Scope and Invest Lgatlori of Additional
             Alternatives for Facilities Planning - Hanover
             County Virginia, preliminary draft, August 1978.,
             Bremner, Youngblood and King, Inc. (Sections
             4.6 - 4.8);

         2.   Draft Environmental Impact Statement - Waste-
             water Treatment  Facilities Planning for Hanover
             County,  Virginia"Phase II Area, January 1979,
             Engineering Science (Section III.c and IV);

         3.   Preliminary Draft:   Town of Ashland Facilities
             Plan, February  1980, Douglas Cullinane,  Town
             Engineer (Section  VI);   and

         4-   Draft Addendum,  Water  Pollution  Control  Facili-
             ties  Plan.  Phase 1  Extended,  April.  1981,  Patto-i
             Harris,  Rust  and Guv (Sections 6,7,8 and 10).    '

         5.   In  addition,  a review  of information regarding "Land
             Treatment  of  Wastewater  in  Hanover County"  is  included
             in  a  Memorandum  to  the  Board  of  Supervisors from the
             urowth  Management  Program  Manager (March 19,  1981).

-------
 After reviewing the  questions,  it  is  the  feeling
 of the County  Staff  that  the  oasic  questions asked
 in the September,  1976  list have either been an-
 swered (through the  documentation  indicated above)
 or have been rendered obsolete  by  the  subsequent
 significant revision and  scaling down  of  the May
 1976  Phase  II  proposals prepared by Bremner, Young-
 blood and Sharp, Inc.   (As represented by the June
 3,  1981 Phase  I Extended  proposal-).

 b.  Question:   "What evaluation has been  done on
    the upper  portion of  the  (Totopotomoy)  Creek
    and what is the  outcome?  What  portions were
    found to be environmentally sensitive if not
    the whole  upper  portion of  the  Creek, and has
    the flood  plain  information been corrected?"

    Response:   These questions  were directed to
    Mr.  Thomas  Slenkamp,  EIS  Preparation  Section,
    Environmental  Protection  Agency.   Mr.  Slenkamp
    has received a copy of your comments  from the
    June 3, 1981 public hearing and he has  indi-
    cated that  your  concerns  will be addressed in
    the Final  EIS.  Completion  and publication of  the
    Final EIS  has  been delayed  by Federal staff  and
    budgetary  cut-backs.  It  is anticipated  that
    the  Final  EIS will be available by the  end of
    July.

'c.  Quest ion:    "How  many meetings have been  held
    without notification of those of use  who  re-
    quested to  be notified?"

    Response:    It is assumed  that this question  is
    also directed to Mr. Slenkamp as the  County  has
    provided adequate notice,  as required for meet-
    ings in which the public  is invited.

d.  Question:    "First we have  previously  questioned
    the issue  of interbasin transfer.   With  the  in-
    clusion of  Blue Star Estates and the  Totopotomoy
    Creek we are dealing with  two watersheds.  Will
    this be allowed?"

    Response:    It is our understanding of the State
    law which  prevents  interbasin transfers  of water ..
    from one watershed  to  the  other (such as  from
    the York to the James  River Basin)  does  not  pre-
    vent transfer of water taken from deep wells
    (which represents water in unconsolidated sedi-
    ments not  related to surface water basins') •
    Therefore,  including Blue  Star  Estates, which  is •
    in the  York River Basin,  in the Phase  I Extended System
    which discharges  wastewater into the  James River
    Basin would not be prohibited  because  Blue Star
    Utility  users get their water  from deep wells.

-------
 Question:   "How  can  a  final  EIS  and a final
 201  Plan  be  prepared without  the public  having
 this  information?"   (Report  on  financing alter-
 natives for  Phase  I  Extended  to  be  presented
 by Peat,  Warwick,  Mitchell and  Company June 24,
 1981).

 Response:  The engineering consultants report
 (Patton,  Harris, Rust  and Guy) presented at the
 June  3, 1981  public  hearing  fulfils the  Envi-
 ronmental  Protection Agency's requirements for
 comparison of Alternate Wastewater  disposal
 systems within environmental, social  and cost
 constraints.  However, because the  County has
 been  advised  by  the  State Water  Control  Board
 that  Federal  funding of any Alternative  is
 highly uncertain at  this time and in  the near
 future, the  County has hired  a financial con-
 sultant (Peat, Marwick, Mitchell and  Co.) to
 assess the likelyhood  of building the  system
 with  local financial resources.  The  financing
 report will not  change the alternatives  reviewed
 in the engineering report, only  help  the Board
 determine  the most feasible way  to  finance the
 recommended alternative.  This may  alter the
 timing but not the environmental, social or
 cost  constraints which were discussed  in the
 engineering report.  Copies of the  financial
 consultant's report  have been available  since
 the Board's June 24, 1981 meeting for  review
 by the public.  Since the financing report is
 advisory only and does not affect the  Environ-
 mental Protection Agency's (EPA) requirements,
 the County Staff does not think  a public  hearing
 is necessary.  Should the Board  wish to  pursue
 a particular financing alternative  other  than
 EPA grants, then the Board may elect to  solicit
 public comments on the financing techniques.

 Question:   "...  the  limited build alternative
 gives costs for upgrading.   First question,
 are these  figures based on a sliding scale
 without considering portions of  the existing
 systems being used?"

Response:   The County's engineering consultant
 for Phase  I Extended advises that their  cost
estimates  did not allow for using individual
elements of the  existing treatment plants other
than  for flow equalization of influent or as
polishing  ponds  for the effluent.

-------
 g.   Question:   "Has each (existing)  system been
     individually evaluated?"

     Response:   The engineer Lnfr, consultant for
     Phase I Extended says that "yes"  the systems
     have been  individually evaluated  but not be-
     yond the general level considered appropriate
     to a 201 Facilities Plan.

 h.   Question:   "Were costs based on degree of
     treatment  required?  Kingswood Court and Toto-
     potomoy Estates are only  two County owned sys-
     tems in this table.   The  cost  given to upgrade
     these two  is $831,500.  Again  is  this figure
     accurate ?"

     Response:   The engineering consultant for Phase
     I  Extended  advises  that,  "yes", costs were based
     on expected advanced waste treatment require-
     ments.   Regarding Kingswood Court and Totopotomoy
     Estates, the consultant advises that costs were
     based on "typical"  costs  from  EPA publications
     and are considered  adequate for planning purposes.
     Further, the cost of Totopotomoy  subdivision is
     greater than the others because its  size is  also
     greater than all the other treatment systems.

 i.   Question:   "...privately  owned, commercial,  resi-
     dential, and industrial systems.   Are these-owners
     willing to  pay up front cost associated  with  this
     proposal for their  systems?"

     Response:   The firm  of Peat, Marwick,  Mitchell and
     Company recently reported  on the  financing alter-
     natives for Phase I  Extended  (June,  1981).   This
     report  included  a survey of major property owners
     and  developers in the  Phase  I  Extended study  Area.
     The  survey  indicated an interest  in  participating
     in  prepaid   connections or  the sale  of revenue
     bonds.   A similar but  independent  survey  conducted
     by  the  Hanover Association  of  Business found, how-
     ever, that  only  30%  of the  property  owners in the
     proposed Phase  I  Extended  Service  Area would  be
     interested  in  contributing  to  the  construction of
     the  Phase I  Extended  System.   The  Board  of Super-
    visors  will  consider  this  information in  making its
     final decision on financing for Phase  I  Extended.

j.  Question:   "What  is  the amount of  area being  studied
    and  being considered  for sewer service in square
    miles?"

    Response:  The Phase  I Extended "initial  service
    area" is approximately 8 square miles which  is
    55% of  the  total  Phase I Extended  "study  area"
     (1^-5 square miles).

-------
k.  Question:   "Hnu KI'A comp 1 ^jtr.-d or- utnrted an
    audit?"  Also ...hat; an audit been completed
    on Phase I by EPA...If so  where can a copy
    of the audit be obtained?

    Response:   Mr.  Slenkamp of EPA advises that
    an audit of EPA funds will not be conducted
    until all  Federal funds have been expended.
    As of this date, all EPA funds due the Phase
    I system have not been received.  The Corps
    of Engineers will conduct  a preliminary re-
    view of the County's files prior to release
    of final payment (the date has not yet been
    set for this review).   This review will be
    followed within three years by an audit by
    EPA.   (We  have  been advised that an EPA. audit
    is not a requirement and may not be conducted)

1.  Question:   "numerous hearings have been held
    ...When can we  expect  answers?"

    Response:   Attached (Appendices C and D),  is
    an extract of Ms.  Enroughty's comments from
    the two public  hearings held subsequent to the
    May 1976 meeting mentioned at the beginning
    of her prepared statement.   Responses are  as
    follows:

    1)  Public Hearing,  April  4, 1979,  Hanover
        Courthouse.   Comments  are addressed to~~
        the preparation of the  Final EIS  which
        has not been completed as of this date
        and is the  responsibility of 'the  U.  S.
        Environmental  Protection Agency.   Other
        comments  raised concerned the Bremner,
        Youngblood  and  King presentation  of a
        County facilities  plan  for Phase  II which
        has not been adopted by  the County and
        has been  made  obsolete  by the Patton,
        Harris,  Rust and Guy report on  Phase I
        Extended.   (April,  1981).

    2)   Public Hearing,  January  20, 1981  Ashland
       Municipal Building.  Comments are again
       addressed to the Environmental  Protection
       Agency and  the  Draft EIS.

    In regards  to Ms. Enroughty's  concern about
    pipe  sizing,  it  should  be pointed out that the
    Patton,  Harris,  Rust and Guy report projected
    design  flows  based  on  a twenty  year planning
    period  1982-2002.   Hanover  County does not an-
    ticipate requesting  a  larger pipe size corre-
    sponding to a longer staging period   such
    as  4.0  years.    While  not contradicting  the
    statement  quoted from  Mr. Cibulka's letter of
    March  5, 1980, the  State Water  Control Board,
    by  letter,  reaffirmed  the regulations  quoted
    by Ms.  Enroughty in  her  statement.

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Thom.-m Tuoh.y, Vice President, Mechanicsvil] e  Civic
Association  (presented prepared  statement,  ques-
tions summarized below).

a.  Question:  "Supposedly this  plan  will provide
    the sewer rate relief for the present Phase I
    Users that has been promised by members of the
    Board of Supervisors for many months.   But does
    it?   If we are reading the  table  (Table  9-3,
    page 9-9, Patton Harris, Rust and  Guy,  April,
    1981) correctly this represents an 81.5$  increase
    in present user costs."

    Response:  Table 9-3 was prepared  in April and
    presents existing Phase I rates if they were
    totally supported by user charges.  This  is not
    currently the case.  The table shows hypothet-
    ically how the addition of Phase I  Extended would
    benefit a total Mechanicsville Water system by
    lowering average user costs.

    Realizing the limitations pf this  type of financ-
    ial analysis, although sufficient  for Federal
    Grant purposes, the County hired the firm of
    Peat, Marwick, Mitchell and Company to conduct a
    detailed financial analysis of the  impact of con-
    structing Pahse I Extended.   This  report has been
    presented to the Board in draft form.  It shows
    that under certain financing conditions, the cost
    of construction to the users of the Phase I Ex-
    tenued system would be less than the current user
    costs of the Phase I system.  Therefore, this pre-
    liminary report supports the concept that if the
    Phase I and Phase I Extended systems were combined
    and all users paid the same user fee, then the
    users of the Phase I Extended system could help
    offset the costs of the Phase I user.

b.  Question:  "Page 4-10 of the Draft  Addendum lists
    different numbers  than Mr.  Bruce's memo (December
    22, 1980), as follows:  ...paid connection .fee, Bruce
    2241 (74.4$), Addendum 2709 (90%);  Actually con-
    nected, Bruce 1313 (43.6£, Addendum 1815  (60.2*)"

    Response:  The figures used by the  consultant in
    the Draft Addendum were provided by Mr.  Bruce, Di-
    rector of Public Utilities,  in an updated memo-
    randum of April 13, 1981.   Specifically, as of
    April 1981 there were 1815 physical connections
    to Phase I with 894 users  having paid the connec-
    tion fee but remaining unconnected.

-------
    c.  Question:  "Page 9-5 of tne addendum states that
        existing users would not ue assessed for con-
        nection...  Can someone explain either now or  in
        the near future the dissimilarity between the
        Phase I and Phase I 'Extended users?"

        Response:  The Draft Addendum as prepared by the
        consultant looks at the Phase I Extended Area
        separately from Phase I.  Therefore the discus-
        sion of "existing collections systems" is meant
        to cover only the Phase I Extended area.  The
        information presented in financial analysis of
        the Draft Addendum is used solely for illustrative
        purposes.Connection fees and charges for the
        Phase I Extended area as opposed to the Phase I area
        are a policy decisions which have not been made by the
        Board of Supervisors.

    d.  Question:  "The subdivision (Blue Star Estates)is
        T5years old.  Will an engineering survey be made
        of existing underground lines to determine condi-
        tion and adequacy to protect against future costs
        to the County?"

        Response:   This point is well taken.  Hidden costs
        could exist from collection systems pump stations
        and lagoons in a poor state of repair.   This level
        of analysis is beyond the scope of the  201 Facili-
        ties Plan.   These hidden costs would app-l-y to all
        alternatives  considered so they would not influ-
        ence the final recommended alternative..

3.   'Jim Popek, Chickahominy  District (no written statement
    submitted).

    a.  Question:   Has the  area beyond Interstate 1-95
        enough density to support  the  cost  of extending
        the pipe in that area.

        Response:   The Draft  Addendum  report prepared by
        Patton,  Harris,  Rust  and Guy did not address  the
        financial  self-sufficiency  of  the  Phase  I Extended
        system.   This  has  been  addressed by  the  prelimi-
        nary report of Peat,  Marwick,  Mitchell  and  Company.
        This report indicates that  the  segments  of  Phase I
        Extended west  of 1-95 are  not  likely to  be  self-
        sufficient  in  the  next  five  years.

    b.   Question:   Concern as to the other  costs  the  exten-
        sion of  Phase  I  area  will  create  in  other service
        areas.

        Response:   The Draft  Addendum  presents an analysis
        of  the costs associated  with different wastewater
        treatment solutions as  compared  to each  other.   The
        impact of Countywide  finances has been reviewed  by
        the  firm of Peat, Marwick. MitcheJ1  and  Companv  (pre-
        liminary report, June,  1981J.  The planning impacts
        will be  discussed in the Comprehensive Plan Update
        for  Phase I Extended which is being  developed by
        the  Planning Department  at this  time.    /O  c~r*

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 4.   T.  A.  Clark  -  comment,  no  questions.

 5.   Nicholas  A.  Spinella,  Henry  District,  Attorney  for
     Avondale  Corp.(no  written statement).

     a.   Question:   Would welcome an  opportunity  to  have
         a  meeting  with  County  representatives  in order
         to work  out  a pro  rata cost  of the  extension  (to
         Blue  Star  Estates)  so  that the developers of  pro-
         perty would  be  paying  their  fair share of any ex-
         tension .

         Response:   The  firm of Peat,  Marwick, Mitchell and
         Company  has  reviewed the impact of  pro rata share
         contributions to the Phase I  Extended system  which
         included comments  from developers regarding pro
         rata  share.  The County  would contact you if  ad-
         ditional information is  needed by the Board before
         making a final  decision  on the utility program in
         your  area.

 6.   Shirley Creasy - comment,  no questions.

 7.   Charles M. Johnson, Manager  of Public Affairs, R.F. & P
    ,Railroad(no written comments).

         Question:  Would like  to see  Phase  I Extended  ex-
         tend  line to land area already zoned industrial
         up to the R.F.  and  P.  Need to obtain additional
         facts from the  County  as  to what the cost factors
         would be.

         Response:  The  County has hired the firm of Peat,
         Marwick,  Mitchell and  Company  to review the finan-
         cial alternatives for Phase I  Extended.  The pre-
         liminary  report questions the  extension of a, line
         to the R.F. & P. property in  the next five years.
        The final report with  supporting documentation is
        expected  to be  available  in July,  1981.  When com-
        pleted we would be  glad  to send you this informa-
        tion .

8.  Ann Spain -  (comment, no questions).
    	                           r

9.  Margaret Miller, Beaverdam District, Citizens for Sen-
    sible Growth.

    a.   Question:  Cost  for  sewage treatment for Ashland.

        Response:  Hanover's Draft Addendum 201 Plan uses
        costs  used  by the Town of Ashland  in its own 201
        Facilities  Plan  for areas not  in the Town.

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     b.  Question:  Why is land treatment for Phase I Ex-
         tended so much less expensive than land treat-
         ment for Oak Hill Estates'/

         Response:  The lower costs are associated
         with the different economies of scale.   The
         Phase I Extended area would serve approximately
         1060 existing connections and an estimated 125
         new connections each year. 'The Oak Hill system
         would serve only about 100 .existing homes and
         would be designed to serve a limited number of
         new connections.  Because of the larger scale,
         the Phase I Extended system can be designed to be
         more efficient than Oak Hill.

     c.  Question:  Would like to know whether innovative
         procedures beyond land treatment were considered?

         Response:  Innovative alternatives for  wastewater
         treatment were considered but  were not  considered
         reasonable or practical for formal presentation
         in the report.

     d.  Question:  Would increasing the number  of lagoons
         have any application in any of these cases and
         have they been considered?

         Response:  Increasing the number of lagoons was
         considered but  were not seen as feasible'".''  As in
         the case of Oak Hill, increasing the number of
         lagoons would not be sufficient to meet the Chick-
         ahominy River discharge standards.

10.   Raphael Peters, President,  Blue Star Utility.

     a.  Question:  Please accept  Blue  Star Utility into
         Phase I.

         Response:  The  County staff has recommended the in-
         clusion of Blue Star Utility into  Phase I  Extended
         if the costs were borne by the  utility  users.   The
         County's financing consultant  has  advised  that  if
         the County pays the  construction costs, these addit-
         ional costs would not be  completely offset by the
         increase in the number  of users in the  Phase  I  Ex-
         tended system (See Draft  Report,  Peat,  Marwick  Mit-
         chell and Company,  June 1981 page  C-l).  The  treat-
         ment  of a private utility in the Totopotomoy  Water-
         shed  represents a planning precedent  which the  Board
         of Supervisors  and Planning Commission  will consider
         in the  Comprehensive  Plan Update  for  the Mechanicsville/
         Chickahominy Urban Area.

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11.  Blue Star Civics Association,  comment on household
     survey(Appendix H;,no question.

12.  Doran Woodson, letter submitted prior to the public
     hearing.

     Question:  If the price is right, I will be willing
     to pay my share.

     Response:  The County is preparing a financial anal-
     ysis which would indicate what the pro rata costs for
     developing properties would be in the Phase I Extended
     Area.  If you would like a copy of the report please
     contact the Growth Management Planning Office.

13-  Christopher J. Cullen, Executive Director, Hanover
     Association of Businesses letter submitted June 8,
     1981.

     Question:  Wish to include results of a survey of the
     Phase I Extended'.

     Response:  The results of the survey have been pro-
     vided the County's Consultant Peat, Marwick, Mitchell
     and Company, with the survey results for inclusion
     in their report on financing alternatives for Phase
     I Extended.

14.  W. Page Morris, Project Engineer, Johnson and Anderson
     of Virginia,Inc. representing Mr. Davide Mayers, Sr.
     letter submitted June 17, 1981.

     Question:  Request an expansion of the Phase I Initial
     Service Area to include approximately 351 Acres of Mr.
     Mayer's property which lies generally between and is
     contiguous to the subdivisions of Totopotomoy and
     Kingswood Court.

     Response:  Your request and the planning issues you
     raise will be considered and addressed by the staff
     in the Comprehensive Plan Update for the Mechanicsville/
     Chickahominy Urban Area.  The Planning Commission and
     the Board of Supervisors are anticipated to take action
     on the planning proposals in September, 1981.

15.  Gordon H. Lawhorn, correspondence received June 1, 1981.

     Question:  Is there a consideration of a water and
     sewer connection by the County of Hanover to Laurel
     Grove and north on U.  S. 301?  I would be interested
     to know more about the cost etc. and date of comple- .
     tion.

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     Response:  Hanover  County  is considering  extending
     ;i  sewer  lino  north  .-ilonr  II. f..  Houto  3n'l  from -At lee
     Squax-e to the  Blue  Star Instates Subdivision.  The
     cost to  the County  or  Blue Star Estates would be
     approximately  $120,000.   The County is considering
     several  separate  financing alternatives as  well as
     the planning  implications of extending a  sewer inter-
     ceptor into a  primarily  undeveloped  watershed
     (Totopotomoy  Creek).   The County staff is working
     on a planning  and financing recommendation  which
     will be  presented to the  Board, and Planning Com-
     mission  in September,  1981.

 ID.  David Mayers,  correspondence received June  1, 1981.

     Question:  The County  has proposed sewer  on property
     which he intends to develop.

     Response:  The planning implications of allowing
     Mr. Mayers property to be connected to Phase I Ex-
     tended is being studied by the staff and will be
     reviewed by the Planning Commission and Board in
     September, 1981,

 17-  R. P.  Peters, Jr.  , President, Sons, Inc., correspon-
     dence received June 1, 1981,  No question asked, in-
     dicates  interest in paying their.share of cost to
     serve Blue Star Utility.

 18.  Nicholas A.  Spinella,  Attorney-at-Law, representing
     Avondale Corporation,  correspondence received May  21,
     1981.

     Question:  Requests a meeting to discuss how Avondale
     Corporation and property  owners adjoining Blue Star
     Utility would share in the pro  rato cost of extending
     sewer service to Blue Star Utility.

     Response:  Correspondence  previously responded to
     by County Staff.   Mr.  Spinella  presented comments
     to Board at  June 3,  198l  Public Hearing.   Providing
     sewer  service to Blue Star and  adjoining properties
     has planning implications  which are being addressed
     by the  Planning Department in a report that  will be
     reviewed by  the Board and  Planning  Commission in
     September,  1981.

19.  W.  S. Heindl,  Jr. , President,  Heindl-Evans,  Inc.
     correspondence received May 26, 1981.

     Question:  Requests  to  be  informed  when sewer servic.e
     will be  provided to  certain properties owned by  Heindl-
     Evans,  Inc.   and Hanover Investments.

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     Response:   The County staff is preparing a report
     on the financing and planning implications of ex-
     tending the Phase I system.  This report is expected
     to be reviewed by the Planning Commission and Board
     in September, 1981.  The timing and service area of
     any sewer extension will be addressed at that time.

20.   Cecil R.  Hopkins, correspondence received May 1, 1981.

     Question:   Requests his property adjacent to Hanover
     Airpark be included in the proposed Phase I Extended
     service area.

     Response:   At this time the subject property is in-
     cluded in the proposed initial service area.   The
     Board and Planning Commission are expected to take
     action on the Phase I Extended proposals in September,
     1981.

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                                      Doran Wood son
                                      701 Brookhill
                                      Richmond.  VA 2322
                                      May 22.  1981      '
John I-Iodger, AICP
Growth Management Steering Committee
Hanover, Virginia 23069

Dear Sir:

     For the past 16 years, I have  owned  approximately
five acres facing Shannon Road.  Please include  this in
Phase I Extended.

     If the price is right, I will  be willing  to pay my
share.

                                     Sincerely,
D'v'/gr
cc:   Jerry P. Owen
     /,'illlam C. Frazier
     Terry Cook
     Joseph I;. Norman, Jr-
     A-  Pacre Nuckols
     Nina K. Peace
     E.C.C . Wood s,  Jr .
     Pet^r L. Trible
                                     Doran  Wood son

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 Jun«  3.  1981
 Mr.  Allan T. Williama
 County Attain La trator
 Hanover Courthouee
 Hanover, Virginia 23069

 Dear Mr. Willisiaaj

 Th«  Ranov*r Association of Buaineaaet Juat  completed a aurvey of the
 attitudes of selected user* la the proposed Phaee X fateoded
 entitled;
                      FUTURS USg^/BBMSyiCIASy STUDY 0?
                               i synsarap
                                  HAT 1981

 Tha Board of Directors pf th* Hanovar Asaociatioa of Suaincaaaa
 thia plan at their regular eoathly Meeting held June 2t 19S1 and unani-
 mously vocad to forward it to the County for loolajlan in the record of
 tha public haciriag held on June 3, 1981  oo the 201 Fe«ilitiaa Plaa.   Ple«e
 find a copy of tfa* iurvty eocloMNi*

 1 will ba happy to diacuaa thia curvey and it's find ins* with the Board
 and/or staff.  I aa adviaiog John Hodge*, aa well aa the Board of Suporviaori
 of thia matter by forwarding to the* a copy at thia letteir and *tudy»

 Should you hava any question* of coooeata, plaaaa feel free to call  ae at
 any tits.

 Eiacaruly,


                                                  RECEIVED
 Christopher J.  Cullea                          .                .
Sxacutiva Director                              f    JUN 0 8 1981

CJC :mc                                         v GMP-- Pt: --  . ' ? ^-osr
Enclosure                                      ' ""      hj.w,-cr County

ccj   John Kodgee
     aanover Couaty Board  of  Supervisor*

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 Johnson & Anderson of Virginia, Inc.
     4UN 1  7 1961
GMP - Planning C^-rl.
Consulting Engineers
Ashland-Hanover Office Bldg.
201 N. Washington Hwy
PO. Box 568
Ashland, Virginia 23005
Telephone: 804-798-1618


June  12,  1981
 County of Hanover
 Hanover Courthouse
 Hanover, Virginia 23069

 ATTN:  Mr. Allan T. Williams, County Administrator

 RE:    Wastewater Treatment Facilities Planning
       for Hanover County, Phase  I - Extended

 Dear Mr. Will iams:

      I hereby request that this letter, in its entirety, be entered  Into
 the minutes of the Public Hearing held June 3, 1981 by the Hanover County
 Board of Supervisors.   I have been advised by Mr. John Hodges of  the
 Hanover County Planning Staff that the above mentioned minutes have been
 held open to accept additional comments until June 19, 1981.  I am writing
 to you on behalf of Mr. David Mayers, Sr.  to request an expansion of  the
 Phase I Initial Service Area to include approximately 351 acres of Mr.
 Mayers' property which  lies generally between and is contiguous to the
 subdivisions of Totopotomoy and Kingswood  Court.                  *

     While the existing zoning of this property is agricultural,  there are
 many factors suggesting that there is a more appropriate use for  the  land
 (i.e. residential development).  To begin  with, as noted above, it is
 bordered to the north and south by existing residential subdivisions which,
 it should be noted, are included in the Phase I Initial Service Area.
 Located in the immediate proximity of the  property are .Hanover Industrial
 Air Park and Beechwood Farms Subdivision,  both of which are also  included
 in the Phase I Initial Service Area.

     These factors coupled with the fact that the property is readily
 accessible by State-maintained roads to Interstate 95 would appear to
 make this acreage a prime candidate for development in the near future.

     The inclusion of this property in the Phase I Initial Service Area,-
 and its subsequent development, would complement the existing, as well
 as the proposed,  utility systems in the area.  Proper location of central
wells and appropriate design of distribution systems could offer  some
 relief to the beleaguered water systems of  the surrounding subdivisions.
The proposed  sewerage facilities to accommodate Totopotomoy and Kingswood
Court are already shown on preliminary maps as located on and traversing

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 Mr. Allan T. Williams,  County Administrator
 Page  2 of 2
 June  12,  1981
across  the  Mayers'  tract.  Mr. Mayers has  Indicated a wll1tngness to
participate financially  in the project to  the extent that  the facili-
ties' design must be upgraded to accomn)odate future development of his
property.   In addition,  such development would greatly enhance the
County's  tax base and would add needed connections toward  the support
of County operated  utility systems.

     The  above  noted factors combine to provide a formidable case In
support of  our  request.  Development patterns of the surrounding geo-
graphical area  would seem to Indicate that the development of this
land is not only  imminent but also consistent with the principles of
sound land  planning.  The opportunity to achieve Integration of utility
systems in  the  area through advance planning Is uniquely consistent
with the  long-range goals of Hanover County and sound economic policy.
     Thank you
any assistance
to contact me.
for your consideration  of  this  request.   If  I may  be of
in the furtherance of  this matter  please  dont't  hesitate
Sincerely yours,

JOHNSON & ANDERSON
of VIrginia,  Inc.
W. PAGE(£0RRIS
Project Engineer
WPM/pws

cc:  Mr. A. Page Nuckols
     Ms. Nina K. Peace
     Mr. Jerry P. Owen, Chairman
     Mr. E. C. C. Wood,  Jr.
     Mr. Terry L. Cook
     Mr. Wi11iam C. Frazier
     Mr. Joseph H.  Norman, Jr.

     Mr, Richard F. E. Shirey
     Mr. Arthur P-  Flippo
     Mr. Robert S.  Cosby
     Mr. Fred  E.  Doggett
     Mr. James Winters
     Mrs.  Barbara D.  Jones
     Mr. James Brannan
                          Mr. York L. Phillips
                          Mr. Peter L. Trible
                          Mr. Randy D. Guill
                          Mr. James T. Bruce
                          Mr. John W. Falrburn
                          Mr. John Hodges

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May 28, 1981
Mr. Hodges
Water & Sewer Dept.
Hanover County
Hanover, VA  23069
Dear Sir:

Is there a consideration of a water and sewer connection
by the County of Hanover to Laurel Grove and north on
US 301?  I would be interested to know more about the
cost, etc, and date of completion.

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    P.O. BOX 9155      PHONE 730-9714      RICHMOND, VIRGINIA 23227
May 28, 1981
John Hodges
Program Manager
Hanover Court House
Hanover, Virginia  23069

Re: Sewer to Ex.  San.  Sew. System, Treatment
in Henrico County.,  Alternative Four.

Dear Mr. Hodges :

On receipt of your program paper "Future
Issues & Policies" I  notice the sewer will
go thru the center of  my property located
between Totopotomoy  Subdivision and Kingswood
Court Subdivision.

It is my intention to  develop this property
and hook up to the sewer as soon as practicable

I  submit this  letter  for input to your study.

Thank you.

Si nee rely,
                        RECEIVED
                           JUN 0 1

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                                   Sons, Ire.
                                   3010 :;. Cary Street
                                   r;ichr^.ond .  VA 23221
                                   ;:ay 22.
John K. Kod.fres,  AICP
Growth Management Steering  Committee
Hanover,  Virginia 23069

Dear Sir:

     Sons  Inc.  owns land adjoining Blue Star Utility Corp,
       d  like to be included in Phase I i
     Sons Inc.  Kill  be willing- to participate in paying
their share of  the cost  if the price is not too high.

                                  Sincerely .
cc:   Jerry  P.  Owen
     i'/illLa;n C.  Frazier
     Terry  Cook
     Joseph H. Norman, Jr
     A.  Pa?e Nuckols
     Xina K. Peace
     3.C.C. ",/oods, Jr-
     Peter  L.  Trible
                                  B.P. Oeters, Jr,
                                  President
         RECr:V~D
            JUN 0 1 198t
        GMP -
           Hanover County
                      .nent

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                                                                 i.' t ( '•
                              LAW OFFICES

                SIMNKI.LV. OWI.NGS, JACKSON & STKVKRSON
                            \ I'KiiJ K---ION u i iiHI'nK \ i (UN
                             lUCIIMdM). \Hii.IMA
Jo- >•-
 Yc,. ,-
                                                         \ ",-i
 Ml IIIH \~
 M HIVI) |.
 I.HtHI !• ;
 I. M-ll Ml-
 IIIIIN i. Ml
 IIIIHI (- I
Kl I JH.
I II \ > K
                      May 20, 1981
  w I- > I 111(11 \ll I'MIK
-•TL'II hMHII'lll^f I'tllKVO
    M I IK IM I
lll( IIMIIMI. \ IKI.IM V J.tlf-"'
I'KI t riinM- i HII i' r tT-ifijn
 Mr.  John H. Hodges
 Program Manager
 Growth Management Program
 Hanover Courthouse
 Hanover, VA  23069
                                            RECEIVED
                                               MAY 2 1 1981
          Re:
                                               • Planning Department
                                               Hanover County
         Proposed Plan for Extending Mechanicsville
         Waste Water System
 Dear Mr.  Hodges:

       I write on behalf of my  client,  Avondale Corporation,  to
 request that consideration be  given  in the  proposed plan for
 extending the Mechanicsville Waste Water  System to include
 neighboring property such as the  42.94 acres  owned by Avondale
 Corporation at the northeast quadrant  of  the  intersection of
 U.S.  Route 301 and State Route  640.

       We  would welcome the opportunity to have a meeting with
 you  as well as members of the  Board  of Supervisors regarding the
 details of how Avondale Corporation  -- and  perhaps other neigh-
 boring landowners as well — might share  in the pro rata cost
 of extending the Mechanicsville Waste  Water System to Blue Star
 estates and the area in the vacinity  of the  intersection of U.S.
 Route 301 and State Route 640.

       We  would appreciate a response to this  initiative, and we
 will  contact you again in the very near future to try to arrange
 a meeting.

       Please advise if you have any  questions.

                                   Yours truly,
                                  Nicholas A.  Spinella
NAS/vjs
cc:  Honorable  Jerry P.  Owen
     Honorable  William C.  Frazier
     Honorable  Nina K. Peace
     Honorable  E.C.C.  Woods, Jr.
                                   Honorable Page Nuckols
                                   Honorable Terry L. Cook
                                   Honorable Joseph H. Norman, Jr
                                   Mr.  Peter L. Trible
cc:  Mr. G.R.  Balducci

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              *_7n
NERAL CONTRACTORS
50 CHAMBERLAYNE  ROAD
iCHANICSVILLE, VIRGINIA 23111
LEPHONE 746-7851
 May  21,  1981
 Mr .  Jo hn  Hodges
 Hanover  Courthouse
 Hanover,  Virginia 23069

 Re:   Heindl-Evans ,  Inc. & Hanover Investments  Properties
      in  Hanover County needing sewage.

 Dear  Mr.  Hodges:

 I would  like  to express our company's extreme  need for
 sewers at  the below listed locations that  either  Heindl-
 Evans, Inc. or  Hanover Investments , both  a  Virginia
 corporation located in Hanover County owns.  Would you
 please informe  me at  your earliest convenience as  to when
 sewerage  will  be  extended to these locations:
Owned by Heindl-Evans,  Inc.:
See attached  copies  of  plats.

Owned By Hanover  Investments:
See attached  copies  of  plats.
If you have any  questions,  please contact me.

Thank you for your  consideration.

Very truly yours,
                                                      ECEIVED
                                                       MAY 2 6
                                                       - Pir-nnir.s Cepartment
                                                       Hanover
W. S. Heindl, Jr.
Pre s iden t

wshj r/ah

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                                    April 29,  1981
Mr. John H. Hodges, Program Manager
Growth Management Office
Hanover Court House
Hanover, Virginia 23069
                         RE: Parcel of Land ?/72 B  (1),
                             48.907 seres, Lots 5,6,7 & 8
Dear Mr. Hodges:
     To confirm our phone conversation of April 27, 1981
concerning the above plot of land situated on the south end
of the Hanover Industrial Air Park and the north side of
Route 656.

     I wish to subu.ic the following facts:

       1. This land has a state road No. 813 which is known
          as Air Park road running through approximately the
          center of it.

       2.  I donated this 60 ft. right of way to the County
           when this road was built with the anticipation
           that the land would be used commercially whenever
           sewer becomes available.

     The Board of Supervisors passed a resolution stating the
county would provide water and sewer lines under this road at
two locations plus some other conditions as you will see in the
attached copy of the resolution dated September 9,  1970.
         RECL
            MAY 0 1 1981

        GMP P-nningDc'u
            I'ii.icverCoor.ty

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      I  furthermore have an agreement with Mr. Troy  Leadbetter,
 developer of  the Hanover  Industrial Air  Park, that  whenever  his
 capacity of water and sewer become available  that I may  attach
 on  to his system.  You may verify this by contacting Mr.  Leadbetter,

      In consideration of  the  land location and  the  above  pertinent
 data, I feel  that this land should definitely be placed  in the
 urb:::n growth  area rather  than the study  area  as I suspect it is
 now.

     The reason I have made no effort to rezone or  use this
 property has been due to  the  lack of sewerage in this area.
                                    Respectfully yours,
                                    C, „:   A      -,
                                    Cecil R. Hopkins
                                    Rt. 5, Box 300
                                    Glen Allen, Va. 23060
CC :  Jerry Owens

    Troy Leadbetter

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