EPA 904/9-77-037
FINAL
ENVIRONMENTAL IMPACT
STATEMENT
GREENSBORO - GUILFORD COUNTY, NORTH CAROLINA
201 WASTEWATER TREATMENT SYSTEM
PROJECT NUMBERS C37037601
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA 30308
IN COOPERATION WITH
THE STATE OF NORTH CAROLINA
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEICI1, NX. 27611
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ERRATA SHEET
p. ii Last line should read: station and force main back t.o
new plant.
p.II-1 The first two sentences in the second paragraph should
read: Since many comments were made regarding upgrading
existing facilities an extensive cost analysis was con-
ducted of the feasibility of upgrading existing facilities
(see Section VIII). As a result of this more detailed
analysis the cost for Alternatives 1, 2 and 6 have been
shown to be substantially more expensive.
p.II-2 The first sentence should read: The environmental ranking
of system alternatives presented in the DEIS ranks Alterna-
tive 6 first environmentally, Alternatives 1, 2 and 3 tied
for second, and Alternatives 4, 5 and 7 following in that
order.
p.II-3 The last sentence in Section C should read: However, it was
not deemed necessary to pursue the allegations further since
the alternative selection was based upon the other factors
described in this chapter.
p.IV-1 The last line in the description of Alternative 2 should
read: pump station and force main back to new plant site.
p. X—46 The first sentence should read: Speaker Mr. Jesse Brown:
I am here because I will refuse to dodge my responsibility
to be a part of the future.
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FINAL ENVIRONMENTAL IMPACT STATEMENT
Greensboro-Guilford County,
North Carolina
201 Wastewater Treatment System
Project No. C-37037601
iIV
l'":> iftrsiectsoa Agency
r/;'- '"v ..
v..-' j :.yW?;:vl
AfcLala, ui'Scrgia 3'0365
Prepared by:
Environmental Protection Agency
Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Approved:
John C. White
Regional Administrator
In Cooperation With:
The State of North Carolina
Department of Natural Resources and Community Development
Raleigh, North Carolina 27611
Approved:
Howard Lee
Secretary
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SUMMARY SHEET FOR ENVIRONMENTAL IMPACT STATEMENT
Greensboro-Guilford County, North Carolina
201 Wastewater Treatment Facilities
Project No. C-37037601
Draft
Final
( )
(X)
Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30308
1. Tvpe of Action: Administrative Action
Legislative Action
(X)
( )
2. Brief Description of Proposed Action:
This Environmental Impact Statement was prepared in response
to the action of awarding grant funds to the City of Greensboro,
North Carolina for the purpose of developing a wastewater treat-
ment system to service the Greensboro-Guilford County area. The
project consists of the necessary facilities to process and treat
approximately 36 million gallons per day (MOD) of wastewater.
The proposed action consists of upgrading the existing
North Buffalo Creek Treatment Plant (NBP) to tertiary treatment
at 16 MGD, abandoning the South Buffalo Creek Treatment Plant (SBP),
constructing a 60-inch diameter outfall from that plant location
to a new 20 MGD plant with tertiary treatment located 26,000 feet
downstream on South Buffalo Creek.
The proposed action will provide for:
^ dischar2ed°intnrNnn^iy inadequately treated wastewater
rth a5d South Buffalo Creeks to
meet water quality standards
(2) wastewater treatment fad n *--.•«<, «- j ^
and future sources of wasjevater accommodate ««£»>S
(3) Countynarea°r °rderly «ro"th in Greensboro-Guilford
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3. Summary of Major Environmental Impacts
Direct adverse impacts associated with the proposed action are
minor. Sewer construction and construction activity at the new
plant site will cause short-term, minor stream siltation and in-
creased air-borne particulates. Some natural vegetation will also
be destroyed, continuing a trend to habitat fragmentation. Some
human inhabitants will be subjected to temporary noise levels
that exceed acceptable thresholds. Water quality will be improved
in the lower stream reaches, but stream quality will remain stressed
in the immediate Greensboro vicinity due to industrial discharges
and urban runoff. A 26,000-foot segment of South Buffalo Creek
below the existing facility will undergo a substantial decrease in
flow. Abandonment of the existing South Buffalo plant may cause
a requirement for vector control downstream of the existing muni-
cipal outfall for several years. The proposed action is well-matched
to projected growth patterns, accommodating desired growth while
discouraging urban sprawl and other unplanned growth
Potential adverse secondary impacts include increased flooding
and the necessity for implementing flood control and erosion con-
trol measures, an increase m urban runoff of poor quality that
degrades streams and reduces aquatic habitat quality, continued
terrestrial habitat attrition through residential and industrial
growth, and increased air pollution through population growth.
Major beneficial impacts are improvements in the treated waste-
water discharges to North and South Buffalo Creeks to meet effluent
limits for these creeks eg elimination of the nuLance odor
source of the South Buffalo Creek plant, and the allowance for
i^"associated 2ffJ«s.S U minimizing urban sprawl and
4. Summary of Alternatives Considered
The EIS process identified design flows that were at signifi-
cant variance with those used for alternatives development in the
201 Facilities Plan. Using the EIS design flows 124 dossible al-
ternatives were identified as candidates . From low and medium
level screening analyses, these were reduced to 46 then to 11
and finally to seven which are presented in this Final EIS
expand^SBp6to NB? t0 16 MGD; uPSrade and
SBP to Highway 70 pti<-1 ^0nstruct a gravity sewer from
back ?o tfe SilwnfpL^ and force maln
SBP*
station and force mam back to the existing plant.
'Disease carrying or transmitting insects, e.g., flies, mosquitos
ii
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Alternative 3 - Upgrade NBP to 16 MGD; abandon SBP; con-
struct new 2(j MGD plant 26,000 feet downstream; construct
outfall from SBP to new plant.
Alternative 4 - Upgrade NBP to 16 MGD; abandon SBP; con-
struct new pTant 46,500 feet downstream on Buffalo Creek;
construct outfall from SBP to new plant.
Alternative 5 - Upgrade NBP to 16 MGD; abandon SBP; con-
struct new plant 66,500 feet downstream on Buffalo Creek;
construct outfall from SBP to new plant; construct out-
fall from new plant to Reedy Fork Creek.
Alternative 6 - Upgrade NBP to 16 MGD; expand NBP to 25
MGD in 1987; upgrade SBP to 11 MGD; construct force main
from SBP to NBP; construct gravity sewer SBP to Highway
70 and a pump station and force main back to the existing
plant.
Alternative 7 - Upgrade NBP at existing capacity; upgrade
SBP to existing capacity.
5. Comments on the Draft Statement were received from the following:
Federal Agencies
U.S. Department of Agriculture, Soil Conservation Service
U.S. Department of Health, Education and Welfare
U.S. Department of Housing and Urban Development
U.S. Department of the Interior
Members of Congress
Honorable Richardson Preyer, U.S. House of Representatives
Honorable Robert Morgan, U.S. Senate
Honorable Jesse Helms, U.S. Senate
State
Ms. Mary Seymour, Representative, North Carolina
General Assembly
North Carolina Department of Natural Resources and
Community Development, Air Quality Section
North Carolina Department of Human Resources,
Division of Health Services
North Carolina Department of Cultural Resources
iii
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Local
Mr. Jim Melvin, Mayor, City of Greensboro, North Carolina
Mr. Forrest Campbell, Vice-Chairman, Guilford County Commission
Greensboro Department of Planning and Community Development
Guilford County Administrative Offices
City of Greensboro, North Carolina
Citizens for the Accountability of Public Officials, Inc.
Concerned Citizens of McLeansville
Greensboro Jaycees
Greensboro Citizens Association
NAACP
Greensboro Youth Council
McLeansville Community Council
Greensboro Homebuilders
McLeansville Athletic Association
A & T State University
Greensboro Motel Association
Guilford County Advisory Board for Environmental Quality
National Audubon Society, T. Gilbert Pierson Chapter
Interested Groups
Individuals
W. H. Ashworth
John G. Newsome, Sr.
Thomas & Sally Isley
Hal B. Lewis
George Mason
Joe Dillon
McNair Family
Wilbur D. Roush
Kenneth A. Watkins
Lola Ward
Clinton E. Gravely
N. Carlton Tilley, Jr.
H. A. Collins
Marquis D. Street
James R. Rees
Edna Isley
R. H. Souther
R. L. Thomas
James C. Johnson
Eula K. Vereen
Dan Fetzer
Henry T. Rosser
Brenda Hodge
John B. Ervin
S. T. Hoffman
Jon Wimbish
J. A. Avent, Jr.
Cora Robinson
Alfred Butler, Jr.
Charles Weill
Fred Clapp
Allen Holt
Dwig'nt Sharpe
Ken Smith
John Michael
Ralph Lewis
E. H. Greene
Dennis Harrell
Harold Haskine
Wade Payne
Florintine Sewell
Melvin S. Payne
Robert Mays
Jim Valentine
John G. Clapp, Jr.
Robert Elzy
Sara Newsome
Jim Rosenberg
iv
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A. W. Ray, Jr.
Gladys Graves
Charles E. Melvin, Jr.
Bill Anderson
Hermon F. Fox
David M. Dansby, Jr.
Dan Kerns
Lillian M. Harley
D. C. Frate
Elizabeth Cone
Larry Watson
Odell Payne
6. Date made available to CEQ and the Public:
The Final Statement was made available to the Council on
Environmental Quality and the Public on December 9, 1977.
W. A. White
Gregory Boyle
Caneron Cooke
Allen Andrew
Burleigh C. Webb
Art Flynn
Phillip J. Bissesi
Al Lineberry, Jr.
George Carr
Rosie Carr
Dan Kerns
v
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TABLE OF CONTENTS
Page
I. INTRODUCTION 1-1
II. AGENCY DECISION 11-1
A. Cost Analysis II-l
B. Environmental Analysis
C. Social Considerations II-3
D. Implementability II-3
E. Conclusion II-4-
F. Grant Condition II-5
III. BACKGROUND III-l
A. Natural Environment III-l
B. Man-Made Environment III-6
IV. ALTERNATIVES CONSIDERED IV-1
V. DESCRIPTION OF PROPOSED ACTION V-l
A. Description of Proposed Facilities V-l
1. Existing North Buffalo Facility V-l
2. New South Buffalo Facility V-10
3. Collection and Sewer System V-17
VI. ENVIRONMENTAL EFFECTS OF THE PROPOSED ACTION ... VI-1
A. Natural Environment VI-1
B. Man-Made Environment VI-5
VII. UNAVOIDABLE ADVERSE IMPACTS AND MITIGATING
MEASURES VII-1
A. Natural Environment VII-1
B. Man-Made Environment VII-3
VIII. REVISIONS AND ADDITIONAL INFORMATION VIII-1
A. Requirements for Upgrading South Buffalo
Plant VIII-1
B. Changes to Other Alternatives.Resulting.from .VIII-12
Additional Studies . .• .VIII-12
C. Recommended New. Site VIII-12
D. Errata . ... .VIII-14
vi
1,
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TABLE OF CONTENTS (Cont.)
Page
IX. RESPONSES TO COMMENTS RECEIVED IX-1
A. Alternatives Selection IX-5
B. Social Issues IX-18
C. Water IX-21
D. Air Quality and Odor IX-23
E. Urbanization IX-27
F. Engineering IX-32
G. Economic Factors IX-42
X. TRANSCRIPT OF PUBLIC HEARING HELD ON SEPTEMBER 1,
1977 AND WRITTEN COMMENTS RECEIVED BY THE AGENCIES
APPENDIX A - INDUSTRIAL COST RECOVERY METHODOLOGY
APPENDIX B - GREENSBORO LAND USE PLANS FOR CIBA-GEIGY SITE
APPENDIX C - SOIL CONSERVATION SERVICE CRITERIA FOR PRIME
AGRICULTURAL LANDS
APPENDIX D - CIVIL RIGHTS INVESTIGATION
APPENDIX E - LAND USE RESOLUTION
vii
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I. INTRODUCTION
This Final Environmental Impact Statement (FEIS) for
Greensboro, North Carolina, Wastewater Treatment Improvements
supplements the Draft EIS issued in July, 1977. The EIS has been
prepared in accordance with the Council on Environmental Quality
(CEQ) Guidelines, at 40 CFR 1500, and with EPA's 40 CFR 6 and
requirements of the North Carolina Department of Natural Resources
and Community Development (DNRCD). The FEIS fulfills the Agencies'
responsibilities under the National Environmental Policy Act
(PL 91-190) and the North Carolina Environmental Policy Act of
1972 and EPA's regulations for environmental review Section 306 of
construction grant applications. While this summary document is
intended to be comprehensive, the supporting information furnished
with the Draft EIS and its Technical Reference Document should be
reviewed and is incorporated here by reference.
This FEIS contains four major items of information.
The first is Chapter II, describing *~he final decis ion and its
rationale. Chapters III through VIII comprise the second
ma ir ser
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In accordance with the regulations, a thirty-day
review and comment period will exist after publication of this
Final EIS and its filing with the CEQ. A conditional construc-
tion grant offer to the City of Greensboro for funding Step 2
(detailed engineering) of the proposed action described below is
intended after this public review period. This FEIS does not
cover the Horsepen Creek service area. The 201 Project Number
C-37036901 issues will be covered by a separate EIS. The decision
made in this FEIS will not foreclose any options now available
nor affect any of the alternatives under consideration for pro-
viding service to Horsepen Creek. Anyone receiving this document
who has not received a copy of the Draft may request one from:
Mr. John E. Hagan, Chief
Environmental Impact Statement Branch
Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30308
1-2
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II.
AGENCY DECISION
The Environmental Protection Agency and the North Carol-
ina Department of Natural Resources and Community Development
have chosen Alternative 3 as the selected action. This alterna-
tive involves the upgrading of the existing North Buffalo Creek
treatment plant at 16 MGD, the abandonment of the existing South
Buffalo Creek treatment plant, the construction of a 60-inch diam-
eter outfall from that plant location to a new 20 MGD plant located
26,000 feet downstream on South Buffalo Creek. The following major
factors were considered in making this decision:
Since many comments were made regarding upgrading
existing facilities and extensive cost analysis was conducted
of the feasibility of upgrading existing facilities (see Section
VIII). As a result of this more detailed analysis the cost for
Alternatives 1, 2 and 6 have been shown to be substantially ex-
pensive. Alternatives 2, 3 and 6 now have essentially the same
cost. Alternative 4 is estimated to cost approximately $2,000,000
more than Alternatives 2, 3 and 6 because of an additional three
miles of interceptor line. The complete cost summary is presented
in Table VIII-6. The revised Present Worth costs of the system
alternatives are as follows:
A. Cost Analysis
Present Worth
Alternative
($xlQ6)
1
2
3
4
5
6
7
59.731
57.453
57.207
59.223
65.431
57.781
53.407
II-l
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B. Environmental Analysis
_ The environmental ranking of system alternatives pre-
sented m teh DEIS ranks Alternative 6 number 1 environmentally
A1 ernatives 1, 2, 3 tied for second, with Alternatives 4, 5, »d
owing m that order. The major factors making Alternative
6 rank^ first are lack of disturbance of new ground for the con-
struction of new site and not reducing the flow in South Buffalo
Creek during dry periods for several mlles downstream. The Agencies
believe that the removal of water from i-ho e«- •
e stream is not a maior
environmental, consideration (see response to Cogent C.l ) U
is also not felt that disturbance of land at sites 3 andYis of
signlfican concern It is, however, felt that disturbance of
nd at site would be a major adverse imapct since this site
is located on a highly productive farm.
The major environmental factors r. • -l.
j• -p-c j • for which significant
differences do exist were given specif ™ • j
• , , . s special consideration by the
Agencies xn the decision making process m, . ,
. * These include the pri-
mary impacts associated with pnns^nof ,
odor and noise) and the secondary implts 1
-Li v • associated with growth
supportable by the various systems.
The relative impact of construet-i™-. a a
various alternatives was considered to be H 0peratl0n of the
tion density surrounding the proposed facilities'1 P°PUla"
density of the area surrounding the exist--? c ' 8 proximate
Plant is much higher than the density surr^ BUffal° Creek
native sites under consideration (see DEIS ^ ^ ^ °ther alter"
deemed to be a negative factor ev n h ' ^ ^
stantially reduced if the facility wel ^ ^ ^
is available for use as buffer zones surr^I-^ Suitable land
native sites. The purchase of such land ^the^ty ofT ^T"
would prevent the encroachment of confi-? Greensboro
c mg land uses in years
II-2
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to come as well as allow flexibility for future additions or modi-
fications to the plant.
All alternatives considered provide sewer service to the
projected 20-year population except Alternative 7 (No Action).
Alternatives 4 and 5, however, provide service well beyond the
projected 20-year growth areas (see pages 11-99 and 11-111 in
the DEIS). The Agencies believe that this additional service
area would encourage urban sprawl and related adverse secondary
impacts.
C. Social Considerations
Serious allegations have been raised by residents of
southeast Greensboro that the continued operation of the South
Buffalo Creek Plant would constitute a continuation of past dis-
criminatory practices in violation of Title VI of the Civil Rights
Act of 1964. A review was conducted by EPA Region IV, Office of
Civil Rights (see Appendix D). However, it was not deemed necessary
further since the alternatives selection was based upon the other
factors described in this chapter.
D. Imp1ementabi1i ty
All six alternatives under investigation can be imple-
mented based solely on the consideration of engineering and con-
struction factors. However, other factors are involved in the
implementation of a proposed project. These factors include the
desires of local officials, the ability to acquire necessary
property, time constraints, and public acceptability.
Both the City of Greensboro and Guilford County favor
the implementation of either Alternative 3 or 4. The City and
County believe that these alternatives will better satisfy the
long term needs of the area.
II-3
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The North Carolina Council of State has not allowed the
sale of land necessary for the implementation of Alternative 1.
Landowners affected by Alternatives 2 and 4 have expressed an
unwillingness to sell. The selection of land involving unwilling
owners may require time-consuming condemnation procedures.
The selection of Alternative 6 may require the Agencies
to pursue further the allegations of discrimination.
Opposition has been expressed by a variety of interest
groups to each alternative under consideration
E. Conclusion
The decision made by the Agencies to select Alternative
3 was made after careful consideration of all of the factors dis-
cussed above. The revised cost analysis shows Alternatives 2, 3,
and 6 to be essentially equal with the lowest present worth cost.
The environmental analysis shows Alternative 3 to be
the only alternative without significant environmental reserva-
tions. Construction at alternative site 2 would directly impact
a highly productive family farm. Construction of of Alternatives
4 and 5 would encourage urban sprawl by providing service beyond
the projected 20 year growth area. Construction of Alternatives
1, 6, and 7 would continue the operation of the existing South
Buffalo Creek Plant in a densely populated residential community.
All alternatives are implementable from a technical
standpoint. Alternate 1, however, cannot be implemented because
of the lack of approval by the North Carolina Council of State.
Delays caused by allegations of discriminary practices and un-
willingness of landowners to sell may cause delays if Alternatives
2, 4 or 6 were selected.
II-4
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The alternative selected in the ongoing Horsepen Creek
study will not affect the alternative selected for the plant site
location. The service area in the South Buffalo basin will remain
the same under all Horsepen Creek alternatives.
F- Grant Conditions
To ensure that certain safeguards are adopted the
disbursement of grant funds will be subject to the following
conditions.
1. Potentially affected areas will be surveyed to
determine the presence of possible archaeological
resources. This survey will be accomplished
during the Step 2 process and the survey plan will
be subject to aDproval by the North Carolina
State Historic Preservation Officer and State
Archaeologis t.
2. If possible and complying with good engineering
practices, interceptor lines should be constructed
completely out of or on the edges of the flood-
plain. This condition should be evaluated during
Step 2.
3. An effective vector control program should be de-
veloped by the Guilford County Health Department
in conjunction with the City of Greensboro and to
be approved by the North Carolina Health Department.
4. The proposed buffer zone around the Ciba-Geigy
site must be purchased by the City of Greensboro.
II-5
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5. Following completion of the new South Buffalo
treatment plant, the existing South Buffalo plant
should be dismantled.
6. During the Step 2 process, the possible need for
pro-treatment (possibly pre-chlorination and/or
aer;.i ion) should be investigated and recoirmier: lat
made for location of such facilities if they are
deemed necessary. Any such recommendations are
subject to approval by the State and EPA.
7. Development of an effective industrial pretreatmer
program must be initiated during the Step 2. The
program must be approved by DNRCD and EPA during
Step 3 as a part of the industrial cost recovery
program.
8. Measures must be developed during the Step 2 pro-
cess so all existing and potential sources of odor
at the existing Horth Buffalo Creek plant and the
new South Buffalo Creek plant will be mitigated.
9. Approval of proposed landfill sites for ash dis-
posal by DNRCD must be documented.
10. An erosion and sedimentation control plan must be
submitted to DNRCD and EPA for approval of its
acceptability.
II-6
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III. BACKGROUND
This Final Environmental Impact Statement was prepared
jointly by the State of North Carolina Department of Natural
Resources and Community Development and the Environmental Pro-
tection Agency, Region IV, in response to legal requirements of
the State of North Carolina and the United States. It addresses
those areas stipulated by the National Environmental Policy Act
of 1969, the North Carolina Environmental Policy Act of 1971, and
the Council on Environmental Quality Guidelines of August, 1973.
For the purposes of this Environmental Impact Statement
(EIS) the study area includes most of Guilford County as shown in
Figure III-l. The total environment is divided into natural and
man-made aspects and each, while interactive, are discussed sep-
arately. Figure III-l also shows the designated 201 area and
existing wastewater treatment facilities of Greensboro, North
Carolina. Supporting documentation is provided in the Technical
Reference Document (RA-R-406) for the DEIS.
A. Natural Environment
Greensboro has a humid, temperate climate characterized
by relatively short, mild winters and long, hot summers. Preci-
pitation is abundant. North-northeasterly and south-southeasterly
winds prevail during the year as a result of high pressure systems
which progress across the eastern United States.
Presently, the general air quality of the study area is
good with respect to the criteria pollutants. Guilford County
is designated an Air Quality Maintenance Area for suspended parti-
culates. This designation has implications regarding the future
growth of suspended particulate levels. Air pollutant emissions
in the study area are typical of a moderately industrialized urban
III-l
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ROCKINGHAM CO.
AND EXISTING WASTEWATER TREATMENT FACILITIES
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region. The North Buffalo sludge incinerator is the only signifi-
cant source of air pollutants at the treatment plants, but its
impact is mitigated by extremely efficient wet scrubbers.
The existing wastewater treatment plants, especially
South Buffalo, are recognized as sources of odor nuisance to
areas surrounding the plants.
The Greensboro area has a noise climate typical of simi-
lar metropolitan areas in the United States. Residential areas
are characterized by low to moderate levels permitting, in most
areas, pursuit of outdoor activities without interference from in-
truding noise. Zones of higher noise level are near major traffic
arteries and the airport. Noise radiated from existing wastewater
treatment plants is of a level too low to be detectable by people
living around the plants.
The topography of Guilford County is typical of the
Piedmont Plateau pnysiographic province in that it is gently rol-
ling in the uplands and somewhat more rugged near the major streams.
The bedrock of the county consists of igneous and metamorphic rocks
that are also typical of the Piedmont province. The bedrock is
overlain by a thick mantle of saprolite (soft, weathered bedrock)
in most of the county. The most important geologic processes are
ground-water recharge and flooding.
The soils of Guilford County comprise deep, well-horizon-
ated acid soils on the uplands and poorly-horizonated alluvial soils
along creek bottoms. A total of seven soils associations have been
recognized and mapped in the county. Nearly all of the soils are
poorly suited for septic tank use, primarily because of low permea-
bility in the subsoil horizon. All of the soils except those along
bottomlands are also poorly suited for land application of sewage
effluent.
III-3
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Streams of the study area are numerous and rather small,
especially tiiose reaches draining the immediate area of metropoli-
tan Greensboro. The 7-day, 10-year low flows for these streams
are only a tew cfs or less, although average discharges are con-
siderably larger. Two streams, Worth and South Buffalo Creeks,
are significantly degraded in quality by municipal and industrial
outfalls and, increasingly, non-point source pollutants in urban
land runoff. Host industrial wastewater is discharged directly
or indirectly to South Buffalo Creek. Malfunctioning septic tanks
have caused locally poor bacteriological quality in streams through-
out tae area. The water supply for Greensboro is provided by a
system of small reservoirs no-ri-h • +. i . •,
' llortn of tae city, upon which urban-
ization is now encroaching.
Because of tile geologic setting of Guilford County, major
regional aquifers do not exist. Shallow, low-productivity water-
table aquifers are present now^or
1 nowever, and serve as important water
sources in rural areas. The e-rrmnri ,
ground water of these aquifers occurs
in pore spaces in the saprolitp .
/ r pruiire and m fractures in the underlying
bedrock. Recharge to the aauifor-o
„ aquifers occurs in the uplands, and dis-
charge is to wells or as basef1nT7
. , Dase^ow to the streams. The total ground
water available m the countv is pQHn,9). . ,
7 13 estimated to be about 150 MGD, but
only approximately 11 MGD is nre^nt-i,, u •
' Presently being used. Ground-water
quality is generally good, except for » i
„ , p a nig« iron content m some
areas. Ground-water quality nroh1B«,o t
. . Problems from septic tanks have been
reported m tne county.
The potential natural vei>Pt^,'ft •
is a climax hardwood forest Man'! „ f Greensb°r° «««
in the establishment of a mixed oak-nick ^ haS reSUlt6d
is now fragmented by cultivated fields t7Pe whlch
ji j . ias> °ld fields, and urban areas
No virgin woodlands remain. About saif * i areas.
in the study area is forested ^ ^ ^ ^ ^
aa p o • second growtn woodlands in var-
ious stages of succession.
III-4
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Because man's use of the study area has fragmented the
natural vegetation, forest species nave decreased while species
preferring brushy habitats have increased. Small game animals
and game birds have benefitted from fragmentation of the wood-
lands. Other game animals such as whitetail deer and wild turkey
have been practically eliminated. Species tolerant of or espec-
ially adapted to man's alterations in natural conditions are gen-
erally characteristic of the area's fauna.
Aquatic plants in the Greensboro area are almost entirely
restricted to streams and lakes above the existing sewage treatment
plants. Small, localized colonies of green and blue-green algae
may be found in North and South Buffalo Creeks below the treatment
plants where suitable, stable substrates exist. Bentnic inverte-
brates are most numerous and diverse in Horsepen Creek, Alamance
Creek, and Reedy Fork. Most sport fishing is restricted to Alamance
Creek, Reedy Fork, Lake Brandt, and small farm ponds. Both North
and South Buffalo Creeks contain benthic invertebrates tolerant
of heavy pollution and very few, if any, game fish.
No virgin woodland stands remain in the study area.
Three plant species are listed as "threatened througnout" their
range in North Carolina. The southern rain orchid (Habenaria
flava), Nestronia (Nestronia umbellula), and ginseng are all moist
lowland species. None of the mammals of Guilford County are con-
sidered endangered. The Bald Eagle once nested in the area and the
Peregrine falcon migrates through the region. Both are considered
endangered by the U.S. Fish and Wildlife Service. The sharp-shinned
hawk is considered threatened and is reported to nest near Lake
Brandt. Species which are sensitive in the area because they are
relictual populations or occur at the edge of their range include
the white-crowned sparrow, crescent shiner, and an unidentified
species of freshwater clam.
III-5
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B, Man-Made Environment
The EIS Study Area had 196,617 people in 1975 and will
grow to 287,200 by the year 2000. This population is clustered
in Greensboro itself with a few small high-density settlements
on the periphery along transportation arteries. Racially the
area is 25 percent black with 64 percent of the blacks in'the
South Buffalo subbasin and 28 percent in the North Buffalo subbasin
ine age of the population is young (median age of 27.0) relative
to the U.S. (28.1). Median income in 1970 was high relative to
both the state and the U.S.
on nnn • Gree"Sb°r° 3rea eco™my has grown since 1970 with
20,000 jobs created in Guilford County from 1970 to 1974. Unem-
ployment ftas Deen low in recent vpat-q it
. years (normally under 4 percent)
Manufacturing dominates the
ne emPl°yment structure witn textile
employment being conspicuously important- p i
_ _ . ^ y important. Employment in manu-
facturing sectors such as wholesalP/^^-i
wuuiesaie/retail trade and services
has grown m recent years.
As one would expect -roo-;^ • 1
.. r , . , ' idential land predominates
within Greensboro witn commercial l
uerciai land uses interspersed pcnPP
ially in the CBD and along maior i-hr> i * '
i i - J thoroughfares. Industry is
closely lined to transportation j
. j rcation and dominates areas along high-
ways, near railroads, and close to t-h« a,-
. 1+. , . e co the airport. Forests and
agriculture predominate in the peripherv of ^
. . •> , pnery of the study area vith
residential areas along highways and at int-«
i j m f intersections. Future
land use will feature growth all a™, A ^
rectional bias being dominant Hiehw reensb°ro with no di-
tant determinant of growth patter^ aCC*SS ^ ^ lmP°r-
Greensboro and Guilfnr-ri
fire protection, health care, education7 Pr°Vlding P°llce and
ies, and other public services to th • WaSte dlsPosal> librar-
to the citizens of the 201 area.
III-6
-------
Wastewater treatment is inadequate and should be corrected by this
proposed action. Public water supply and treatment capacity
should be adequate throughout the design period of the project.
Additional capacity will be required early in the next century.
Greensboro and Guilford County are financially sound
governments paying for their needs with very little bonding
required.
The Guilford County area has a rich cultural heritage
which is being enhanced and protected. National Register histor-
ic sites are located in Greensboro and many buildings and areas
of historic value have been identified. Also, the area may have
archaeological resources, but they are not well known at this
time. Recreational resources are scattered tnroughout the city
and county.
As a focal point of North Carolina highways, Greens-
boro's major thoroughfares are heavily used. Thoroughfares are
planned to relieve excess traffic loads as they develop, espec-
ially in peripheral areas.
Duke Power Company will be able to meet the area's
energy requirements through the year 2000 as long as coal and
nuclear power are available. No major natural resources are
being extracted in the study area other than rock and gravel.
III-7
-------
IV. ALTERNATIVES CONSIDERED
To satisfy a 20-year growth projection requiring 36
million gallons per day (MGD) of treated wastewater 124 alterna-
tives entailing consideration of 14 different treatment plant sites
located in five major watersheds were identified. These alterna-
tives were tested in a multilevel screening process involving
environmental, engineering, legal, and cost constraints, and inputs
from the Greensboro EIS Advisory Committee. With this process,
the alternatives were reduced to a total number of seven, includ-
ing No Action, for evaluation in the Draft EIS. All alternatives
considered require the upgrading of the existing North Buffalo
treatment plant (NBP) to provide a tertiary level of treatment
at 16.0 MGD. All alternatives, except Mo Action and Alternative
6, call for a 20 MGD plant with tertiary treatment on either South
Buffalo or Buffalo Creeks. The alternatives receiving detailed
environmental, cost, and engineering analysis are summarized be-
low. The alternatives are depicted graphically in Figures IV-1
and IV-2.
" NBP plus upgrading the expanding exist-
ing South Buffalo Plant (SBP); construction of a gravity sewer
from existing SBP to Highway 70 and a pump station and force main
back to the existing plant.
Alternative 2 - NBP plus abandonment of SBP and construc-
tion of a new plant 14,000 feet downstream from the SBP; construc-
tion of an outfall sewer from SBP to the new plant location; con-
struct gravity sewer from the new plant site to Highway 70 and a
pump station and force main back to the existing plant.
Alternative 3 - NBP plus abandonment of SBP; construction
of a new plant 26,000 feet downstream of SBP; construct an outfall
sewer from SBP to new plant site.
IV-1
-------
I
FIGURE IV-1
-------
<
I
FIGURE IV-2
-------
Alternative 4 - NBP plus abandonment of SBP; construction
of a new plant on Buffalo Creek 46,500 feet downstream of SBP; con-
struction of an outfall sewer from SBP to new site.
Alternative 5 - NBP plus abandonment of SBP; construction
of a new plant 66,500 feet downstream on Buffalo Greek; construction
of an outfall sewer from SBP to new site; construction of an outfall
sewer from new site to Reedy Fork Creek.
Alternative 6 - NBP plus expand NBP to 25 MGD in 1987;
upgrading SBP to tertiary level of treatment at 11 0 MGD; construc-
tion of a pump station and force main from SBP to NBP to transfer
9.0 MGD; construction of a gravity sewer from SBP to Highway 70
and a pump station and force main back to the existing plant.
Alternative 7 - No Action; upgrade NBP and SBP to terti-
ary level of treatment at existing capacity; provide septic tanks
to additional households not provided sewer service.
IV-4
-------
V.
DESCRIPTION OF PROPOSED ACTION
The proposed action for wastewater treatment facil-
ities 1 improvements for the City of Greensboro includes main-
taining and upgrading the existing North Buffalo treatment plant
at 16.0 MGD and construction of a new 20.0 MGD facility approxi-
mately 26,000 lineal feet downstream of the existing South
Buffalo Creek facility. A new sixty-inch, 26,000-foot outfall
from the existing South Buffalo to the new facility will also
be constructed. The South Buffalo Creek plant will be abandoned
and dismantled and the existing city-owned site will become
available for other desired uses. Figure V-l shows the location
and size of the proposed facilities with respect to the City of
Greensboro.
^• Description of Proposed Facilities
Both the existing North Buffalo plant and the new South
Buffalo plant are required to meet the Reliability Class II
criteria as outlined in EPA-430-99-29-001 (EN-610). The effluent
limits which must be met at the proposed facilities are shown on
Table III-3 of the DEIS. Dissolved oxygen limits which must be
met are 5 mg/1 at the South Buffalo Creek plant and h m*./l at the
North Buffalo Creek plant, respectively.
1- Masting North Buffalo Facility
The existing North Buffalo treatment plant provides
facilities for preliminary treatment, primary treatment, second-
ary treatment, and chlorination. Primary and waste-activated
sludge is thickened and dewatered with vacuum filters before
incineration and ultimate disposal in the nearby landfill site.
To meet the imposed stringent effluent limitations,
this facility can be upgraded by improving or modifying selected
V-l
-------
ROCKINGHAM CO.
<
I
ho
FIGURE V-l
PROPOSED ACTION
-------
existing unit processes as well as constructing new additional
processes. The following description of possible improvements
and additions includes a brief inventory of existing unit
processes. This approach will place the recommended proposed
action into perspective for reviewing purposes.
The existing preliminary treatment facilities include
a bar rack and screen, grit collector, and flow meter. These
facilities were originally designed for a capacity of 18.0 MGD
and should be sufficient for the proposed 16.0 MGD design
capacity.
The existing primary treatment facilities include four
identical rectangular clarifiers. Each clarifier is 80 feet
long, 40 feet wide, and 15 feet deep. With a total surface area
of 12,800 square feet, the design overflow rate at 16.0 MGD
would be approximately 1,250 gpd/ft2. This overflow rate is
slightly higher than the state recommended rate of 1,000 gpd/ft2,
but can be considered marginal if the overall necessary level of
treatment can be attained.
Effluent from the primary clarifiers is lifted to
trickling filters. The existing lift station has a pumping
capacity of 18.0 MGD (average) and should be sufficient for the
proposed 16.0 MGD facility. Therefore, no additional inter-
mediate pumping facilities are recommended.
The existing trickling filter facilities include two
identical units with diameters of 200 feet and depths of 4 feet.
These facilities have a total surface area of 62,800 square feet
(1.44 acres) and a total volume of 251,200 cubic feet, and are
operated with 100 percent recirculation. Assuming a B0D5 re-
moval efficiency of 20 percent, and continued 100 percent recir-
culation, the total organic loading on the trickling filters at
V-3
-------
16.0 MGD is 8,330 pounds/acre-feet/day. This loading is ex-
tremely high and modifications are necessary if these facilities
are to continue being used as roughing filters. Possible modi-
fications can include increasing the filter depth and volume,
replacement of the existing media with a plastic media, and re-
duction in recirculation.
The existing aeration tank facilities include four
identical rectangular units each with a length of 261 feet,
width of 42 feet, and a depth of 13 feet. With a total volume
of 570,000 cubic feet, these facilities will provide a detention
time of approximately 6.4 hours at 16.0 MGD. This detention
time should be sufficient to provide nitrification if adequate
aeration is provided without excess mixing.
The existing aeration facilities provide a blower
capacity of approximately 14,000 cfm. Assuming an oxygen re-
quirement of 1.5 pounds per pound of BOD5 removed and 4.6 pounds
per pound of ammonia-nitrogen (NH3-N) removed, additional blower
capacity of 7,000 cfm for a total of 21,000 cfm is necessary to
satisfy the effluent limitations. This aeration will provide a
mixing capability of 37 cfm per 1,000 cubic feet of aeration
basins which is slightly high but marginally acceptable.
Existing final clarifiers include five circular tanks;
two with diameters of 75 feet and depths of 16 feet, two with
diameters of 90 feet and depths of 15 feet, and one with a di-
ameter of 75 feet and depth of 13 feet. At a design flow of
16.0 MGD, the total surface area of 25,960 square feet will pro-
vide an overflow rate of 620 gpd/ft2. With a total volume of
389,460 cubic feet, the average hydraulic detention time will
be approximately 4.4 hours. These parameters are well within
the acceptable limits and no additional final clarifiers are
required.
V-4
-------
The North Buffalo Creek facility does not have facili-
ties providing multimedia filtration. To achieve and maintain
the BOD5 limitation of 6 mg/, it is necessary that additional
treatment be provided. The use of multimedia filters after ni-
trification would represent a cost-effective maximum attempt for
achieving the stringent limitations. As recommended by the
State of Uorth Carolina, municipal multimedia filters should
have a design hydraulic loading of no more than 3 gpm/ft2.
This loading rate will require a total surface area of approxi-
mately 3,700 square feet.
In addition to the multimedia filters, an intermediate
lift station will probably be necessary for loading the filters.
This pump station should have a capacity to lift the design flow
_ r 1 /" r\
For adequate disinfection, the State of North Carolina
requires a minimum detention time of 30 minutes for average flow
conditions. To provide this detention time for 16.0 MGD, a tank
size of approximately 44,560 cubic feet is required. The exist-
ing contact chamber has a volume of 35,625 cubic feet and an ad-
ditional volume of approximately 9,000 cubic feet must be pro-
vided to satisfy regulations. However, if the new multimedia
filters are placed downstream of the chlorination facilities,
additional chlorine contact time in the filters may be sufficient
for adequate disinfection. This proposed action is not neces-
sarily recommended but only suggested for consideration. Any
such variance will require the review and approval of both state
and federal agencies.
With the existing North Buffalo facilities and possible
modifications discussed herein, the North Buffalo Creek plant
should provide adequate treatment for 16.0 MGD and produce a
water quality acceptable for discharge into North Buffalo Creek.
V-5
-------
However, presently unforeseen problems may exist, and additional
treatment may become necessary once this facility is on-line and
operating properly.
Primary and waste-activated sludge at the North Buffalo
Creek plant is thickened, dewatered with vacuum filters, and in-
cinerated. Ash is disposed of at the nearby landfill site. Ad-
ditionally, a two-stage anaerobic digestion facility is available
but is used only as a backup to the sludge handling facilities
described. Stabilized sludge is dewatered with the vacuum fil-
ters and disposed of at the existing landfill site.
The existing primary sludge thickener has a diameter
of 60 feet and a depth of 8 feet providing a surface area of
2,830 square feet and a volume of 22,640 cubic feet. Based on
a solids loading rate of 10 pounds/square foot/day, the primary
sludge thickener has the capacity to process approximately 14.2
tons of sludge/day. With an estimated primary sludge production
of only 3.5 tons/day at 16.0 MGD, the existing primary sludge
thickener should be sufficient.
The existing waste-activated sludge floatation thicken-
er has a total surface area of 100 square feet. Based on a
solids loading rate of 30 pounds/square foot/day, the flotation
thickener can process approximatley 1.5 tons of sludge/day.
With an estimated waste-activated sludge production of approxi-
mately 6 tons/day, an additional surface area of approximately
300 square feet is necessary.
The existing vacuum filters include two identical
units with a surface area of 360 square feet each. Assuming
a filter yield of 3.5 pounds/square foot/hour and 56 hours of
operation per week, the existing facilities have adequate
capacity. However, it is recommended that an additional identi-
cal (360 square foot) unit be provided to allow for inevitable
downtime.
V-6
-------
The existing sludge incinerator has a capacity of two
to three tons per hour and need only operate four hours per day
to process all of the sludge produced. Therefore, no additional
incineration capacity is necessary. This incinerator is currently
fueled with natural gas and no associated air pollution has been
observed. However, with dwindling supplies of natural gas, it
may become more economical to switch to fuel oil at a later date.
Electrical costs to operate the improved North Buffalo
facility will approach approximately $300,000 per year at 16.0
MGD. This cost represents an equivalent electrical annual con-
sumption of approximately 8,500 megawatt hours, less than 0.5
percent of the electrical consumption of Greensboro.
With the exception of a masking agent for odor control,
the only chemicals used at the North Buffalo Creek plant is chlor-
ine for disinfection. At the design flow of 16.0 MGD, approximately
200 tons of chlorine will be required annually at a cost of approx-
imately $36,000
Construction of the North Buffalo Creek facility improve-
ments will be limited to the present site boundaries and no addi-
tional land should be required. Future expansion or improvements
will be difficult owing to the limited acreage and, if required,
will necessarily be provided across the North Buffalo Creek. All
proposed improvements and construction should be complete within
12 to 18 months after construction begins but may vary depending
on available materials and time required for deliveries.
A schematic of the proposed North Buffalo Creek plant
and improvements and the projected pollutant removal or mass bal-
ance for each level of treatment is shown in Figure V-2. Figure
V-3 shows a possible layout of the actual proposed facilities.
However, other possibilities exist and this proposed layout and
improvements should in no way constrain the design engineers.
V-7
-------
TWO-8TAQE ANAEROBIC
DIGESTION (BACKUP)
EXISTING FACILITIES
PROPOSED FACII ITIES
ASH TO LANDFILL
INFLUENT
FLOW MOMTOfitMG
COMMWUTOR
QUIT COLLECTOR
BAR RACKS
AND
BAR SCREENS
PRELIMINARY
TREATMENT
NORTH BUFFALO CREEK
Influent
BOm : 260 «g/»
TbS ISO agIt
KH. h ZC «g/.•
Mssuned Equal to Measured TKN
Preliminary Treatment
BOD-
Ti>S
^ Primary Treatment
2S0 »g/c BOf),
ISO mg/t
NHj-N = 20 mqft
^-Tricklmcj filters ^-Aitivaled bludcje
.'00 i s in le< li o»i - -
U0l> '¦ m<|/ •
' v I '.L> - 115 my / •
Nil ,-N 4 my/.
Feial Colifonn )UdO/tiii'
-55
FIGURE V-2 SCHEMATIC OF PROPOSED NORTH BUFFALO CREEK FACILITY WITH IMPROVEMENTS
-------
<
I
v£>
-------
The North Buffalo Creek facility currently employs 24
personnel for operation and maintenance. With the recommended
improvements, an additional 16 employees will be necessary to
properly operate this plant in an attempt to meet effluent limi-
tations. This facility should be staffed with approximately twenty-
five personnel on weekdays, five on weeknights, and ten on week-
ends. The complete staff of forty personnel should include two
for supervisory, one for clerical, twenty-one for operations, ten
for maintenance, three for laboratory, and three for yardwork.
2. New South Buffalo Facility
The proposed new 20.0 MGD South Buffalo Creek facility
will provide raw waste pumping, preliminary treatment, primary
treatment, two-stage aeration for nitrification, multimedia fil-
tration, and chlorination. Primary and waste-activated sludge
will be thickened, dewatered, and incinerated before ultimate
disposal in the existing landfill site. This existing landfill
site has a design life of approximately 12 years, but with the
addition of a proposed pulverizer, the life will be extended to
approximately 20 years. Therefore, this existing site should be
sufficient throughout the design period.
Because this new facility will be located above the
one-hundred year floodplain, a raw waste pumping station will be
required to lift the raw waste from the end of the proposed new
sixty-inch outfall. This pump station will be located in the
floodplain and will require flood protection. The pump should
be designed for peak pumping capacity of approximately 40 MGD.
The preliminary treatment facilities will include bar
racks and screens, a coraminutor, grit collector, and flow measur-
ing device. These facilities will also be designed for a peak
capacity of 40 MGD.
V-10
-------
Primary clarifiers will be constructed to provide an
overflow rate of 1,000 gpd/ft2 at 20.0 MGD. This design criteria
will require a total primary clarifier surface area of 20,000
square feet. These facilities may be either circular or rectan-
gular in shape. A minimum of three parallel facilities should be
provided in the design.
Primary sedimentation will be followed by two-stage
biological oxidation with clarification following each stage.
The first stage will satisfy the carbonaceous biochemical oxygen
demand (CBOD), while the second stage should satisfy the nitro-
genous biochemical oxygen demand (NBOD). A minimum hydraulic de-
tention time of four hours in the first stage and five hours in
the second stage will be necessary. Clarifiers following the first
stage should provide a maximum overflow rate of 800 gpd/ft2 at
20.0 MGD, while clarifiers following the second stage should pro-
vide a maximum overflow rate of 600 gPd/ft2. The aeration basins
as well as the clarifiers should be designed for parallel construc-
tion with a minimum of three basins or tanks for each process
This type of design will allow for increased flexibility and per-
formance during operation. Each tank should be sized for only
the portion of total flow that it will treat.
Assuming an oxygen requirement of 1.5 pounds per pound
of BODs removed and 4.6 pounds per pound of HH,-N removed the
blower capacity required is approximately 45,000 cfm. This blower
capacity can be provided with a different aeration system A
sufficient number of blowers should be provided to enable the de-
sign oxygen transfer to be maintained with the layout capacity
unit out of service.
Multimedia filters are necessary for attaining the strin-
gent effluent limitations and will be designed for a hydraulic
loading of 3 gpm/ft2. The existing movable tertiary filters at
V-ll
-------
the South Buffalo Creek plant should be salvaged and installed
with this new facility. However, these existing filters are de-
signed for only 6 MGD and additional facilities for the remaining
14 MGD must be constructed.
Disinfection will be provided with chloriantion facil-
ities including a contact basin and a chlorine feed system. To
provide the required contact time of 30 minutes, a minimum cham-
ber volume of 55,700 cubic feet is necessary.
Approximately 20 tons/day of primary and waste-activated
sludge will be removed for processing and ultimate disposal. As-
suming a solids loading rate of 10 pounds/square foot/day, approx-
imately 4,000 square feet of flotation-thickened surface area will
be required. The thickened sludge can be dewatered with vacuum
filters before incineration. These vacuum filters will require
a minimum surface area of 1,400 square feet assuming a filter
yield of 3.5 pounds/square foot/hour and 56 hours of operation
per week. A two to three ton/day capacity incineration should
be sufficient for this new facility and will probably require fuel
oil for operation. Scrubbers or other air pollution control equip-
ment must be installed and will be required to comply with new
source performance standards.
Electrical costs to operate the new facility will approx-
imate $400,000 per year at 20.0 MGD. This cost represents an equi-
valent electrical annual consumption of approximately 11,500 mega-
watt-hours, about 0.5 percent of the total electrical consumption
in Greensboro.
The only chemical which will be used at the site is
chlorine for disinfection. At the design flow of 20.0 MGD, approx-
imately 250 tons of chlorine will be required annually at a cost
of approximately $45,000.
V-12
-------
Construction of the new facility will require approxi-
maLely 40 acres of land out of approximately 400 acres which are
available to the city. This proposed site will offer little con-
straint to future expansion and improvements. Construction of
this facility should be complete within 24 to 30 months after
construction begins but may vary depending on available materials
and time required for deliveries
A schematic of the proposed new facility and projected
pollutant removal or mass balance for each level of treatment is
shown in Figure V-4. Figure V-5 shows a possible layout of the
actual proposed facilities; however, other possibilities exist and
this proposed layout should in no way constrain the design engineers
Figure V-6 is an artist's conception of the proposed new facility.
A true or useful hydraulic profile through this facility
can not be completed until the ^ ¦ j
, J detailed drawings and specifications
included m the 201 Step II „
activities are completed. The selec-
tion, arrangement, and placemen!- nf ^ ., . .
raent ot necessary facilities will de-
pend on a detailed site survev innli^in^ «. •, -
eluding topographical features
and engineering geologic character! qm* „a u • .
• However, it is estimated
Chat incoming wastewater win be llfted approximatfily „ fMt from
the outfall elevation of approximately 675 feet to the preliminary
treatment facilities located at an elevation of 730 feet The
profile through the plant wlU be dependent on the arrangement and
particular design of the unit processes -
.1,,,., , , . F ocesses. The treated wastewater
will be discharged back to the
, . 6 bouth ^ffalo Creek at a stream
surface elevation of approximately 690 feet
The existing South Buffalo r->-Q ^ c
ploys 17 personnel for operation and fa"lity currently e,-
ity should be staffed with " "JlThis new facil-
weekdays, eight on weeknights and twe^ tMenty"flve Pers°nnel on
employment of forty-five. Ih ^^ /
complete staff should include three7
V-13
-------
SLUOGE RETURN
9LUOGE RETURN
-0h
<3:
PRIMARY TREATMENT 1ST STAGE AERATION WITH CLARIFICATION 2ND STAGE AERATION WITH CLARIFICATION
<
I
DIFFUSEO AERATION
FILTER BACKWASH
RAW SEWAGE UFT STATION
CONTROL atNLOING AND LABORATORY
SOUTH BUFFALO CREEK
CHLORINE CONTACT
j±rii~j±
r
IT I
MULTIMEDIA FILTERS
lnflu«rnt 1
BODv
NH . -N
I I mj/
.uj oki/
b imj/ >
;J5
le
jI foil fan
1000/fct
FIGURE V-4 SCHEMATIC OF PROPOSED NEW SOUTH BUFFALO CREEK FACILITY
-------
c
h->
Ln
-------
S-"=5*g^ ^ssgim^SSP' ¦t,
----- , . , \..fo
i ri in ns-sPj
J-.-JitulJ -U '-» A-/^*pA ^
- .,-*1 " r , 1
--jl*
i^Vvsw:< ^ -^\ ,
4. ^^%4yf
b
FIGURE V-6
ARTIST'S CONCEPTION OF PROPOSED NEW SOUTH BUFFALO PLANT
-------
for supervisory, one for clerical, twenty-five for operations,
ten for maintenance, three for laboratory, and three for yardwork.
3. Collection and Sewer System
No specific collection/interceptor system expansion is
included with this proposed action. However, as the city con-
tinues to grow, additional sewer service and collection system
will be provided as demands for such service warrants.
To transfer the raw wastewater from the existing South
Buffalo plant to the new facility, a new 26,000-foot, 60-inch
outfall sewer will be constructed along South Buffalo Creek. This
outfall will be located away from the stream as much as possible
to minimize adverse impacts. The location of this outfall is
shown with the proposed action in Figure V-l.
V-17
-------
VI.
ENVIRONMENTAL EFFECTS OF THE PROPOSED ACTION
A. Natural Environment
Direct air quality impacts of the proposed action will
occur during the construction and operation phases. During con-
struction at the new South Buffalo site, appreciable fugitive
dust may be generated. These emissions should have a localized
impact. Operational impacts include combustion products from
gas and diesel-fueled engines used to produce power and also from
the sludge incinerator. The incinerator emissions will be minor
because of adequate control equipment. Secondary impacts will
occur due to growth patterns in the study area. More human activ-
ity will bring about more air pollutant emissions. It is not
known whether this will cause any future violations of air quality
standards.
Significant beneficial impacts for the existing odor
problem will occur as a result of the proposed action. The
elimination of existing and potential sources of odor will be of
prime consideration in design of the upgrading oi the existing
North Buffalo plant as well as the new facility (see Grant Condi-
tions of Section II).
Previous odor problems caused by industrial influent
under the existing treatment plants will be evaluated through the
initiation of an industrial pretreatment program. This program
must be developed and approved during the Step 3 process. The
program must include an identification of necessary pretreatment
locations and processes and a continuing monitoring program to
be conducted by the City of Greensboro. Step 3 construction grant
will be limited to eighty percent payment until this program
has been approved by The Stare of North Carolina and EPA (see Grant
Conditions of Section II) .
VI-1
-------
Potential problems resulting from sewage becoming septic
before it reaches the treatment plant must also be addressed.
During the Step 2 process, the possible need for pretreatment
(possibly prechlorination and/or aeration) should be investi-
gated by the 201 consultant and recommendations made for location
of such facilities as they are deemed necessary. Any recommenda-
tions will be subject to approval by our DNRCD and EPA.
Noise generated by construction of the South Buffalo
interceptor may cause disturbance to outdoor activities for per-
sons living or active within 2000 feet of the construction activ-
ity. Any one area is not expected to be affected for a period of
more than one month. Construction and upgrading of the treat-
ment plants is not expected to generate adverse reaction to noise.
Noise from operation of the new South Buffalo plant will not
cause an adverse impact on area residents. Operation of the
North Buffalo plant may cause slight annoyance to people engaged
in outdoor activities especially during nighttime hours.
The primary geology-related environmental effect will
be the blasting that will likely be necessary both for the new
sewage treatment plant and for the new pipeline that will connect
the new plant with the existing south Buffalo plant.
Two soils-related impacts will result from the proposed
action. Approximately 40 acres of moderately productive soil
will be permanently removed from cultivation by the new treatment
plant, and the moderately high erosion susceptibility of the soil
will probably result in considerable erosion at the site during
construction.
Despite the significant improvement in the discharge
of water quality from the new treatment plants, the direct effects
VI-2
-------
of the proposed action on the water regime are small. Streamflow,
especially dry weather flows, will gradually increase below the
outfalls as a result of increased municipal wastewater and will
promote a small incremental amount of continuing streambank ero-
sion and siltation. Sewer emplacement is likely to be more con-
sequential for stream siltation, but this impact will be temporary
and minor. Removal of the existing municipal wastewater discharge
for five miles of South Buffalo Creek will significantly improve
water quality in that reach only if upstream industrial discharges
are removed or undergo better treatment. Enforcement procedures
are available and in effect at both state and federal levels to
ensure that unacceptable discharges will be eliminated. The oxy-
gen-demanding pollutant loads to North and South Buffalo Creeks
will be substantially reduced, by 45 and 34 percent respectively,
and the times that these streams experience poor quality conditions
will be decreased. However, the water quality of the hydrologic
system will remain in a rather highly stressed state, due to the
influence of municipal wastewater, industry and urban land runoff.
Perhaps only in Reedy Fork and more downstream areas will the
stream health show substantial improvement as a result of the
proposed wastewater treatment facilities. Increased assimilative
capacity provided by the design wastewater discharge in these
lower stream reaches should be beneficial to water quality during
lower flows. No downstream water supply will depend upon disin-
fection at the proposed treatment plant sites for bacteriological
quality. Malfunctioning septic tanks in these watersheds are
expected to continue in the long term surviving possible public
health hazards. Discharge of nutrients and residual chlorine
should not impose an ecological burden. The chlorination process,
however, could conceivably create very low concentrations of car-
cinogenic, mutagenic or otherwise toxic compounds in the effluent
as a result of chemical reactions with the variety of organics
in these municipal wastewaters. This is not a certain effect and
has not been documented at the existing plants, but should be
considered as a possible direct impact.
VI-3
-------
The indirect effects of increased urbanization on water
quantity and quality are likely to be more significant than the
direct effects of wastewater discharge. The major hydraulic
effects that are likely to be experienced are higher peak flows
on the streams draining the urbanized area and concomitant more
frequent flooding in areas downstream. An indirect result of
this increased flooding is likely to be increased amounts of
channelization and other hydrographic modifications. The continued
urbanization of the region may cause a continuing poor quality
water in the streams of the Greensboro area without attention
being given to this pollution source. The point-source discharges
apparently are not capable, within the existing technological and
regulatory framework, of creating a sufficiently large buffer in
stream quality to accommodate the adverse effects of urban non-
point source pollutants without experiencing water quality de-
gradation.
ac
s
The most important environmental effect of the proposed
tion on ground water will be the very remote hazard posed for
hallow ground water at the site of the new treatment plant.
Leakage and seepage from the ponds and other facilities may reach
the water table without the benefit of natural renovation,
particularly where the facilities are excavated below the soil
zone.
The environmental effects of the proposed action on
terrestrial flora and fauna will be largely temporary. Distur-
bance of plant and animal communities by construction and opera-
tion of the proposed facilities will not destroy critical habitat
or deleterious numbers of wildlife. No endangered terrestrial
species are known to inhabit the proposed construction sites.
Indirect effects of the proposed action will reSult in an increase
of the habitat fragmentation already observed in the area
VI-4
-------
The effect of the construction and operation of the
new facilities on aquatic plants and animals will be minimal.
Existing aquatic habitat quality in North and South Buffalo
Creeks is marginal. Therefore, the proposed action will have
essentially no adverse impact and may produce some beneficial
effects . Increases in flow will be similar to historical in-
creases and should not produce any adverse effects not already
observed. Secondary effects on the aquatic environment will
stem from increases in urban runoff to both streams. No endan-
gered aquatic species are known to inhabit affected stream seg-
ments .
B. Man-Made Environment
Very minimal changes in population size, characteristics,
or distribution in the area will occur as a direct result of the
proposed action. The economy will benefit by approximately $33
million as a result of construction costs. As an indirect result,
the EIS study area will be able to accommodate projected population,
industrial, and commercial expansion without the environmental
and economic costs associated with sprawl.
The land lost to its existing use as a direct result of
the proposed action is relatively unproductive in economic terms.
The effect on neighboring land use will be minimal due to the
buffer to be established. Beneficial effects are related to the
closing of the existing South Buffalo plant, the cessation of low
density sprawl based upon the use of package plants and septic
tanks, and the implementation of controlled growth east of Greens-
boro .
The direct impact of the proposed action on community
facilities is anticipated to be very small. Indirect impacts
will occur as a result of population growth within the study area
VI-5
-------
but will be spread over the planning period. Proper planning and
zoning by the city and county will help provide additional
community facilities and services as needs for them increase
during the planning period.
Sewage treatment costs will increase to pay for the pro-
posed action. The increase will be small and dispersed throughout
the community. The increase should not cause undue hardship for
residential customers.
Direct effects on historical or archaeological resources
may exist. No presently known historical or archaeological re-
sources will be affected by the project. An archaeological survey
will be performed prior to implementation of construction to
determine the presence or absence of any unknown resources which
might be affected. The results of this survey must be approved
by the North Carolina State Historic Preservation Officer and
the North Carolina State Archaeologist. Indirect adverse effects
are limited to an eventual need for expanded recreational resources
as the growing population overuses those which now exist.
Huffine Mill Road will experience significantly heavier
traffic during construction. The entire ground transportation
system in the 201 study area will have to expand peripherally to
accommodate projected growth. No major adverse impacts, either
direct or indirect, have been identified.
Neither direct nor indirect adverse effects on resource
use or supply can be attributed to the proposed action.
VI-6
-------
VII. UNAVOIDABLE ADVERSE IMPACTS AND MITIGATING MEASURES
A. Natural Environment
To reduce the amount of dust generated from construction
at the new South Buffalo plant site, water or oil may be applied to
unpaved access roads and other potential areas of dust generation.
These measures can reduce dust approximately 50 percent.
Approved pre-treatment of sewage and proper operation
and maintenance of equipment at both facilities can mitigate odor
impacts. At both the North Buffalo Creek facility and the new
South Buffalo plant, covers and gas scrubbers on the primary sedi-
mentation tanks and sludge thickeners and gas scrubbers on the
vacuum filters and anaerobic digesters, as appropriate, can be used
to minimize odors.
Measures designed to mitigate adverse noise impacts in-
clude properly maintaining and efficiently muffling dozers, back-
hoes, and cranes and reducing rock drill noise by acoustic mufflers,
as well as enclosure of motors, pumps, and control valves and acous-
tical lagging of aboveground high pressure piping.
The blasting that will be required for construction of
some of the facilities will be of short duration, so no mitigating
measures will be required. The geology of the area is generally
conducive to urbanization, so no mitigative measures are recommended.
Preventive measures for soil erosion and the resulting
sediment generation at construction sites must comply with North
Carolina Sedimentation and Eroison Control Law.
The secondary effects of increased flooding as a result
of urbanization can be appreciably reduced by adopting a comprehensive
VII-1
-------
storm water management program that is integrated with community
land use planning and engineering constraints. Reduction of im-
pervious areas through lot size control and use of permeable pave-
ments and structural measures to offset decreased lag times, such
as detention ponds, natural and artificial depression storage,
and effective routing of storm water should "be considered in var-
ious critical areas.
All construction sites will be required to implement ero-
sion and sediment control plans to mitigate or eliminate stream
siltation. Other direct and indirect water quality effects can be
mitigated by implementing a timely, adequate monitoring program
for both effluents and receiving streams, in order to identify
areas requiring preventive measures. Such measures are likely
to include actions to reduce the amount and variety of contamin-
ants accumulated on impervious surfaces, to reduce overland and
channel flow velocities, and to encourage proper septic tank sit-
ing and maintenance.
A mitigative measure for the potential reduction of
ground-water quality would be to ensure prevention of leakage
from any of the new treatment plant facilities or the associated
pipeline. Monitor wells, particularly between the new treatment
plant and South Buffalo Creek, could be installed to detect ground-
water pollution, if it occurs, at an early stage
Because of the historical use by man of both terrestrial
and aquatic communities in the Greensboro area, no lasting adverse
impacts on area biota are anticipated. Secondary environmental
effects caused by urbanization would occur with or without the
proposed action.
VII-2
-------
B. Man-Made Environment
Adverse impacts directly related to the proposed action
are limited to traffic increases on Huffine Mill Road and minor
land use conflicts at the new South Buffalo plant. The former
problem is relieved by adequate scheduling while the latter is
diminished by a large buffer zone.
Indirect adverse effects related to population growth
may be discernible in undesirable spatial patterns of residential
development or in overburdened community services and facilities.
For both potentialities, farsighted planning by the county and
city governments will minimize the effects.
VII-3
-------
VIII. REVISIONS AND ADDITIONAL INFORMATION
Since July 1977, when the DEIS was distributed, addi-
tional investigations have been performed that have a bearing on
the decision-making process. The studies consisted of a detailed
examination of the requirements for upgrading the South Buffalo
plant, for upgrading and expanding the North Buffalo plant, and
an examination of an additional site proposed during the comment
period. Additionally, from comments on the DEIS, several errors
or inaccuracies were corrected.
A. Requirements for Upgrading South and North
Buffalo Plants
The assumption was made in the DEIS that both the
North and South Buffalo Plants would be upgraded and expanded by
utilizing existing facilities to their full capacity with some
modifications and additional capacity on a unit-by-unit basis
as necessary.
The discussion that follows first describes the history
and development of the South Buffalo plant. This is followed by
a detailed description of the upgrading and cost requirements
for Alternative 6.
The original South Buffalo plant was constructed in
1931 as a low rate fixed nozzle trickling filter plant. Subse-
quent additions and modifications to the plant in the mid 1950's,
mid I960'., and early 1970's converted the plant to a two-stage
biological system (roughing filters followed by activated sludge)
with tertiary filtration. Because nf •
dUSe ot the piecemeal manner in
which the plant evolved, it does nnt-
. l aoes not take advantage of the natural
VIIl-i
-------
slope of the plant site, resulting in the need for two inter-
mediate pump stations. The following is a brief description of
the units comprising the plant.
1. The influent pump station is in good condition and
of adequate capacity, due to relatively recent upgrading. With
additional flood protection, the station could be expected to
serve throughout the 20 year planning period.
2. There are two primary clarifiers. One is 70'
square, constructed in 1930. The other is a conventional round
clarifier, 80' diameter constructed in 1957. Both are covered
to reduce odors. The gases above the surface of the clarifiers
are used as feed gas for the preaeration unit. The square
clarifier is in poor condition and of poor design, and would re-
quire replacement should the plant be upgraded.
3. The preaeration basin is in good condition, and
could be expected to serve another 20 years.
4. The roughing filters, constructed in 1957 are in
good structural condition, although the distribution arms should
be replaced. The filters are capable of approximately 407o B0D5
removal at current loading of approximately 10 mgd and 260 mg/1
B0D5.
5. In the mid 1960's, the low rate trickling filters
(vintage 1930) and the final clarifiers (vintage 1975) were con-
verted to a conventional activated sludge system. The filter
media was discarded, surface aerators added, and appropriate
return sludge pumps and piping, etc., were added. An inter-
mediate pump station was needed to lift the trickling filter
effluent to the aeration basins.
VIII-2
-------
The basins appear to be in very poor condition. Visible
portions of the basins display general spilling and numerous
cracks, although no active leaks were observed. However, a
perennial boggy area down-slope from the basins could be evidence
of subsurface leaking.
Half of the aerators (200 horsepower) are platform
mounted, and were installed in the early 1960's. They are in
poor condition The other half (360 horsepower) are float
mounted, were installed in the late 1960's, and are in good con-
dition .
The final clarifiers were designed to serve the trick-
ling filters, and are not properly designed to function as final
clarifiers in an activated sludge system designed for nitrifica-
tion. They are too shallow (9 ft.) to allow for necessary
flexibility in sludge inventory control, and the overflow rate
is too high (640 gpd at 11 mgd) for a nitrifying sludge.
6. The tertiary filters, constructed in 1974, were
designed for an average flow of 6 MGD. An intermediate pump
station is used to lift the final clarifier effluent onto the
filters.
7. Waste activated sludge is thickened in an air flo-
tation thickener (1974) dewatered on a vacuum filter (1930) and
trucked to the North Buffalo plant for incineration or landfill.
Primary sludge is dewatered on the same vacuum filter (though
the sludges are not combined) and is also trucked to North
Buffalo. The thickener is in good condition-, however the filter
is in poor condition and would require replacement. Neither
unit has a back-up. The old anaerobic digesters are used for
sludge storage during down times. The digesters are in good
structural condition, though they would have to be renovated.
VIII-3
-------
The plant could be upgraded in two basic ways, each
with its own draw-backs. One method would be to demolish the
existing aeration basins, constructing new basins in their
place. This would require bypassing of partially treated
wastewater (primary clarification, roughing filter, final
clarification and tertiary filtration) during demolition and
construction. The other method would be to construct the new
aeration basins while maintaining operation of the existing
basins. This would require an additional pump station. Because
the second method would be somewhat costly, and would have the
O&M burden of an additional pump station, the first method was
included in the cost analysis of Alternative 6. However, if it
were determined that the bypassing of partially treated waste-
water was not acceptable, substitution of the second method
would result in only a slight increase in the cost of Alternative
6.
Costs were developed using the Stanley Cost Curves
whenever possible. The costs of items not included in the curves,
such as flood protection, trickling filter distributor arms,
demolition of existing structures, etc., were estimated from past
experience. The following is a summary of the capital cost
analysis performed on the South Buffalo plant upgrading. A
tabulation of O&M costs is included with the capital costs in
Table VIII-1.
1. The existing 80' diameter clarifier has a surface
area of 5000 ft2. At 1000 gpd/ft2, its capacity is 5 mgd. The
additional capacity required is 6 mgd. From the Stanley Curves,
the cost is $330,000.1
1 Curve values have been updated by a factor of 1.5.
VIII-4
-------
TABLE VIII-1
COMPONENT 3
SOUTH BUFFALO TREATMENT PLANT AT
11.0 MGD
Capital Cost O&M
Component ($ Millions) $/MG
Preliminary Treatment — 7.95
Preaeration — 21.35
Intermediate Pumping — 6.00
Primary Clarifiers 0.330 6.75
New Distributor Arms 0.150 12.00
Intermediate Clarifiers — 9.00
Intermediate Pumping — 6.00
Aeration Basins 1.230 —
Diffused Air 0.960 49.14
Final Clarifiers 1.125 9.00
Intermediate Pumping 0.135 6.00
Multimedia Filters 0.930 42.00
Chlorination 0.075 13.13
Sludge Thickeners 0.173 1.56
Sludge Holding Tank 0.100
Aerobic Digesters 0.100
Vacuum Filters 0.780 22.22
Truck Hauling — 9.08
Landfill — 16.82
6.088 $238/MG
Site Work & Piping (25%) 1.522
7.610 $955,570/YR
VIII-5
-------
The existing clarifier will be demolished at an esti-
mated cost of $15,000.1
2. The distributor arms on the existing roughing
filters need replacement. Estimated cost = $150,000.1
3. The existing aeration basins will be demolished
at an estimated cost of $85,000. The new basins will utilize
diffused aeration (30 CFM/1000 ft3) and have a detention time
of 10 hours. Estimated basin cost, $1,230,000.2 Estimated
diffused air system cost, $960,000.2
4. The existing final clarifiers will be converted to
intermediate clarifiers following the roughing filters. New
final clarifiers with a design overflow rate of 600 gpd/ft2 will
be constructed. Estimated cost, $1,125,000.2'3
5. The existing intermediate pumps to the tertiary
filters have a capacity of 6 mgd (avg). An additional 5 mgd
(avg) is required. It is assumed that 1/2 of the curve cost is
building and structural. Estimated cost, $135,000.2
6. The existing multimedia filters have a design
capacity of 6 mgd. An additional 5 mgd is required, at a design
loading of 3 gpm/ft3. Estimated cost, $930,000.2
7. Additional chlorination facilities are required
to arrive at a 30 minute contact time. Estimated cost, $75,000.
8. An additional sludge thickener will be installed
to handle primary sludge. Estimate cost, $137,000.2
Radian estimates
2 Stanley Curves
3To approximate the cost of two basins, the curve was entered
with 1/2 of the design flow and cost multiplied by 2.
VIII-6
-------
9. An aerated sludge holding tank will be provided
for emergency situations. Estimated cost, $100,000.1
10. The existing anaerobic digesters will be converted
to aerobic digesters. Estimated cost, $100,000.1
11. The existing vacuum filter will be replaced.
Estimated cost, $780,000.2,3
Because of site restrictions, the North Buffalo plant
expansion was assumed to occur across the creek. For the pur-
poses of this estimate, the proposed expansion of 9 mgd was de-
signed as a two-stage activated sludge system, with the same
design criteria as the new South Buffalo 20 mgd plant Costs
were estimated using the Stanley Curves in exactly the same
manner as for the other alternatives. A summary of both capital
and O&M costs is included in Table VIIl-2
The cost for upgrading the existing North Buffalo
plant to a capacity of 16 mgd was not changed. It was assumed
that the existing incinerator has adpmi^.
adequate capacity for pro-
cessing the sludge from the total 25 ,
in Table VIII-3. g ' C°StS are
Alternative 6 costs are summarized in Table VIII-4
and the present worth analysis is presented in Table VIII-5.'
Radian estimates
2Stanley Curves
3Assuming 50% back-up capacity
week. '
and operating 56 hours per
VIII-7
-------
TABLE VIII-2
COMPONENT 2
NORTH BUFFALO TREATMENT PLANT EXPANSION AT 9 MGD
Construction O&M
Component ($ x 106) ($/MG)
Preliminary Treatment 0.180 5.60
Primary Clarifiers 0.420 7.50
First Stage Aeration 0.930
Intermediate Clarification 0.800 9.90
Intermediate Pumping 0.390 6.75
Second Stage Aeration 1.050
Final Clarifiers 0.990 9.90
Diffused Aeration 1.200 24.00
Intermediate Pumping 0.390 6.75
Multimedia Filters 1.200 45.00
Chlorination 0.156 13.65
Sludge Thickeners 0.180 1.73
Vacuum Filters 0.900 32.00
Incineration — 8.57
Truck Hauling — 0.36
Landfill — 0.99
8.786
Site Work & Piping (15%) 1.318 $172.70/MG
10.104 $567,320/YR
VIII-8
-------
TABLE VIII-3
COMPONENT 1
NORTH BUFFALO TREATMENT PLANT AT 16 MGD
Capital Cost
Component ($ Millions)
Preliminary Treatment
Primary Treatment
Intermediate Lift to
Trickling Filters
Trickling Filters
Aeration Tanks
Diffused Aeration 0.405
Final Clarifiers
Multimedia Filters
(includes lift station) 2.575
Chlorination Facilities 0.108
Sludge Thickeners 0.151
Anaerobic Digestion
Vacuum Filters
Incineration
Truck Hauling
Sanitary Landfill
3.239
Site Work & Piping (20%) 0.648
3.887
O&M
$/MG
7.50
5.70
5.25
11.70
26.25
7.80
42.75
12.08
1.03
4.38
16.71
7.88
2.03
5.63
$156.69/MG
$915,070/YR
VIII-9
-------
TABLE VIII-4
ALTERNATIVE 6 COST SUMMARY
INCLUDES COMPONENTS 1, 2, 3, & 11
Capital O&M
Phase I ($ Million) $/YR
North Buffalo @ 16 mgd 3.887 915,070
South Buffalo @ 11 mgd 7.610 955,570
Administration & Lab 0.465 355,070
Force Main from South
Buffalo to North Buffalo 4.000 1,200
Pump Station 1.000 95,000
Interceptor, Pump Station &
Force Main Down South
Buffalo 1.799 12,600
Flood Protection 0.360
Land and ROW 0.052
10.304
Engr. & Legal (15%) 1.546
11.850
Land 0.063
11.913
19.121 2,314,510
Engineering & Legal (15%) 2.868
22.041
North Buffalo 9 mgd exp. 10.104 567,320
Flood Protection Allowance 0.200
VIII-10
-------
TABLE VIII-5
ALTERNATIVE 6 PRESENT WORTH
Total Project Cost (1980) = 22.041
0&M (1980 - 2000) = 32.072 (2,314,510 + 467,320) 11.129
Total Project Cost (1987) = 7.732 (11.913 x 0.649)
Salvage
N.B. @16 = 3.887 x 1/3 x 1.15 = 1.490
N.B. @9 = 10.304 x 30-13 x 1.15 = 6.715
30
S.B. @11 = 7.610 x 1/3 x 1.15 = 2.917
Admin & Lab = 0.465 x 1/3 x 1.15 = 0.178
Force Mains
& Interceptors = 4.436 x 1/2 x 1.15 = 2.550
Land (No Depreciation) = 0.115
13.965
Present Worth Salvage Value = 13.965 x 0.291 = 4.064
Present Worth = 61.845 - 4.064 = 57.781
VIII-U
-------
Cost estimates for all alternatives considered in the
DEIS are tabulated in Table VIII-6 for reference.
B. Changes to Other Alternatives Resulting from
Additional Studies
1. The cost of Alternative 1, which includes upgrading
and expanding the South Buffalo plant to 20 mg/1, was increased
for the same reasons that the cost for Alternative 6 was increased.
First, many of the existing facilities would have to be replaced
instead of incorporated into the plant as assumed in the Draft.
Second, the cost for the interceptor, force main and pump station
to Highway 70 were inadvertently omitted in the Draft..
2. The cost of Alternative 2 was increased because
costs for the interceptor, force main and pump station to Highway
70 was inadvertently omitted in the Draft.
C. Recommended New Site
Since publication of the DEIS, an additional site was
recommended as a possible candidate location for the new South
Buffalo plant. An area northeast of Lee Street, North of 1-85
and downstream of the existing South Buffalo plant was recommended
for consideration.
The site was investigated and evaluated on the same
basis as all other candidate treatment sites. Adequate area
does exist for installation of a treatment plant of 20 mgd
capacity. However, most of the area is in South Buffalo Creek
flood plain and extensive flood control measures would have to
be adopted to protect a treatment plant. Also, the location is
proximal to high density residential areas and inadequate land
is available to provide a suitable buffer. For these reasons,
it was concluded that the site did not justify further
investigation.
VIII-12
-------
TABLE VIII-6
COST SUMMARY AND COMPARISON OF SYSTEM ALTERNATIVES
AMORTIZED1
SYSTEM CAPITAL CAPITAL COSTS O&M COST2 TOTAL ANNUAL TOTAL TREATMENT
ALTERNATIVES COSTS ($)(106) ($/YR)(L06) ($/YR)(106) COST ($/YR)(106) COST ($/MG)
1
28.409
2.553
3.012
6.565
420
2
32.174
2.891
2.448
5.339
410
3
33.345
2.996
2.447
5.443
410
4
36.215
3.254
2.437
5.691
430
5
43.705
3.927
2.439
6.366
480
6
29.763
2.674
2.883
5.557
420
No Action
26.902
2.384
2.450
4.834
370
u>
*Based on 20 years @ 6-3/8% interest for WWTP's adn 30 Years @ 8% for septic tanks.
2Based on design flow of 36.0 mgd.
PRESENT
WORTH
($ x 106)
59.731
57.453
57.207
59.223
65.431
57.781
53.407
-------
D. Errata
Comments reviewed on the draft revealed some corrections
that are appropriate in the DEIS. Code for the commenter is des-
cribed in Section IX.
Commenter
p. ii Change last paragraph to read: W-26
"?4ajor beneficial impacts are improvements
in the treated wastewater discharges to
North and South Buffalo Creeks, elimination
of the notorious odor source of the South
Buffalo Creek plant and the possibility for
planning orderly urban growth without en-
vironmentally unsound sprawl or other effects."
p. 10 Change first sentence of 3rd paragraph to W-26
read:
"Despite the significant improvement in the
discharge of water quality from the new
treatment plants, the direct effects..."
p. 11 1st paragraph, third sentence: W— 26
"...degrade water quality by increased
turbidity and sediment loads, and destroy..."
p 11. Remove last part of last sentence of 1st W-26
paragraph.
p.13 Keep first sentence of 5th paragraph and W-26
add:
"Preventative measures for soil erosion and
the resulting sediment generation at con-
struction sites must comply with North
Carolina Sedimentation and Erosion Control
Law."
Eliminate remainder of paragraph
VIII-14
-------
ERRATA (Cont.)
Commenter
p. 1-2 Delete phrase of 1st sentence: W-26
"...as a result of a legal agreement..
p. 111-34 Change third line of subsection b from W-26
"...a supplementary cost document to this
EIS." to "...Technical Reference Document."
p. IV-1 (Correction to be provided by Ray Shaw, W-26
Don Knibb)
p. IV-7 (Correction to be provided by Raw Shaw, W-26
Don Knibb)
p. II-l Change third sentence of l.a. to read: W-14
"Worth-northeasterly and south-southwesterly...
p. II-2 After the first sentence insert: W-14
"None of the measures are included in
the cost presented in Chapter III."
p. 11-30 Insert at the beginning of the last sentence: W-14
"At the scale of mapping used as a basis for
evaluating widespread septic tank suitabil-
ity, most of the county... from septic tanks
from a given intensity of septic tank usage."
p 11-94 Add on * to the end of the 1st sentence of W-14
subsection C and add a footnote:
"*0BERS population projections consider the
effects of birth, death, and migration rates."
VIII-15
-------
ERRATA (Cont.)
Commenter
p. 11-110 Change title of table to read: W-14
"Partial Listing of Guilford County Land
Use Goals and Policies"
p. 11-124 Second paragraph, next to last sentence W-14
insert:
"In particular, English Quakers settled
the western portion of Guilford County and
founded Jamestown and Guilford College."
p. 11-124 Change spelling of Randolf and Nathaniel W-14
to "Randolph" and "Nathanael"
p. 11-125 Change first sentence of Subsection 2 to W-14
read:
"Currently, there are three National Regis-
ter sites, Blandwood, the Jefferson building,
and Bumpass-Troy House in the study area."
p. 11-125 Add at the end of second paragraph in W-14
Subsection 2:
"The Bumpass-Troy House was built for
Reverend Sidney Bumpass, founder of the
Methodist newspaper, The Weekly Message.
The structure is 2-story, brick, Greek
Revival style and is one of only 16 pre-
1879 buildings remaining in Greensboro."
p. 11-125 Change in last paragraph: W-14
"24" to "47"
VIII-16
-------
ERRATA (Cont.)
Comme titer
p H-125 Change last sentence to read: W-14
"Also, three areas of Greensboro are being
considered for Historic District Status,
the Southern Railway Complex, the South Elm
Street area, and the Summerfield Historic
Dis trict."
B-5 Change reference GU-106 to read: W-14
"Tax Department" instead of "Finance Department"
B-6 Author of NA-337 should read "Narkunas" W-14
VHl-17
-------
IX. RESPONSES TO COMMENTS RECEIVED
Due to the large number of individuals commenting on
the Draft EIS and the considerable overlapping of their concerns,
the Agency has responded to these comments generally according
to 53 identified categories of concern. The oral and written
comments from all commenters were assigned to one or more of
these categories. However, much of the material presented in
the comments was a restatement of information presented in the
Draft EIS or only a preference for or against a certain alterna-
tive, and no Agency response to that material is explicitly made.
To identify commenters with the various concerns expressed, each
commenter has been assigned an alpha-numerical designation as
follows:
Written
Commenters
A-l
W. H. Ashworth
A-2
John G. Newsome, Sr.
A-3
Thomas L. and Sally B. Is ley
A-4
Hal B. Lewis
A-5
Charles E. Mortimore
A-6
Joe Dillon
A-7
The McNair Family
A-8
U.S. Department of Agriculture, Soil
Conservation Service
A-9
Wilbur Roush (letter dated 8/24/77)
A-10
Kenneth A. Watkins
A-ll
Miss Lola Ward
A-12
Clinton E. Gravely
A-13
Osteen, Adams .**= Tilley (letter dated 9/14/77)
A-14
Guilford County
A-15
Department of Health, Education and Welfare
A-16
H. A. Collins
IX-1
-------
Written Commenters (Cont.)
A-17 Congressman Richardson Preyer
A-18 City of Greensboro (Cofer, Beauchamp & Hawes
letter dated 9/15/77)
A-19 North Carolina Department of Natural Resources
and Community Development, Air Quality Section
A-20 U.S. Department of Housing and Urban Development
A-21 State of North Carolina Department of Human
Resources, Divsision of Health Services
A-22 U.S. Department of the Interior
A-23 Marquis D. Street
A-24 North Carolina Department of Cultural Resources
A-25 James R. Rees
A-26 City of Greensboro (Cofer, Beaucham & Hawes
letter dated 8/29/77)
A-27 Edna L. Isley
A-28 Wilbur Roush (letter dated 9/15/77)
A-29 Osteen, Adams & Tilley (letter dated 8/31/77)
A-30 R. Odell Payne
A-31 R. H. Souther
A-32 R. L. Thomas
A-33 Hazen & Sawyer
Public Hearing Commenters
B-l Mary Seymour
B-2 Forrest Campbell
B-3 Henry A. Collins
B-4 James C. Johnson
B-5 Eula K. Vereen
B-6 Dan Fetzer
B-7 Henry T. R.osser
B-8 Brenda Hodge
B-9 John B. Ervin
IX-2
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Public Hearing Commenters (Cont.)
B-10 A. W. Ray, Jr.
B-ll Gladys Graves
B-12 Charles E. Melvin, Jr.
B-13 Bill Anderson
B-14 Edna Isley
B-15 Hermon F. Fox
B-16 David M. Dansby, Jr.
B-17 Dan Kerns
B-18 Lillian M. Harley
B-19 Robert Elzy
B-20 Sara Newsome
B-21 Jim Rosenberg
B-22 S. T. Hoffman
B-23 Jon Wimbish
B-24 J. A. Avent, Jr.
B-25 Cora Robinson
B-26 Alfred Butler, Jr.
B-27 Charles Weill
B-28 Fred Clapp
B-29 Allen Holt
B-30 Dwight Sharpe
B-31 Ken Smith
B-32 John Michael
B-33 Ralph Lewis
B-34 E. H. Greene
B-35 Dennis Harrell
B-36 Harold Haskins
B-37 Wade Payne
B-38 Florintine Sewell
B-39 Melvin S. Payne
B-40 Robert Mays
B-41 Jim Valentine
IX-3
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Public Hearing Coromenters (Cont.)
B-42
John G. Clapp, Jr.
B-43
W. A. White
B-44
Gregory Boyle
B-45
Cameron Cooke
B-46
Allen Andrew
B-47
W. H. Ashworth
B-48
Burleigh C. Webb
3-49
Art Flynn
B -50
Odell Payne
B-51
Phillip J. Bissesi
S-52
A1 Lineberry, Jr.
B-53
D. C. Frate
B-54
Elizabeth Cone
B-55
R. H. Soutner
B-56
Larry Watson
B-57
George Carr
B-58
Rosie Carr
B-59
Dan Kerns
B-60
Jesse Brown
IX-4
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A. Alternatives Selection
Commenters: A-l, A-2, A-3, A-9, A-10, A-ll, A-25, A-27,
A-28, A-32; B-4, B-5, B-7, B-8, B-9, B-10,
B-ll, B-13, B-14, B-18, B-19, B-22, B-24,
B-26, B-27, B-29, B-34, B-35, B-36, B-38,
B-39, B-44, B-47, B-50, B-55, B-57, B-58
Comment: Although the DEIS indicates that Alternatives 1
and 6 are the least expensive and most environmen-
tally acceptable, these two alternatives were
eliminated in the selection process.
Response: The rationale and basis for selecting Alternative 3
as the proposed action is fully explained in
Section II, Agency Decision in this final EIS.
Comment: In considering a location for a new plant, only
four potential sites were evaluated when other
areas are available both within the City of Greens-
boro and in Guilford County, particularly if the
400-acre requirement is eliminated.
Response: An extensive investigation of sites that were poten-
tially suitable for treatment plant locations was
conducted in the EIS process. On November 10, 1976,
at the public meeting at the municipal auditorium
which 986 people attended, a solicitation for recom-
mended treatment sites was made. Prior to that
meeting in the 201 Facilities Plan effort, inten-
sive investigations were conducted to identify
potentially suitable treatment plant sites that
would satisfy the Greensboro wastewater management
objectives. At each meeting of the Greensboro
IX-5
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Advisory Council (January 17, 1977, March 16, 1977,
May 2, 1977, May 19, 1977, July 12, 1977), treatment
plant sites were discussed and requests were made
for recommendations for additional possibilities.
Beyond these scheduled sessions, the EIS development
in potential treatment plant sites was covered in
the Greensboro local newspapers.
As stated in the EIS, fourteen candidate treatment
sites were identified for further evaluation to
determine their applicability for satisfying the
201 wastewater management requirements. From these
sites, 124 alternatives were identified and evaluated
accordingly.
The area requirement in identifying sites and
evaluating their suitability was not based upon
a 400-acre requirement, but rather on an approximate
50-acre requirement that would accommodate a 20 MGD
facility. The Agencies do however favor the practice
of acquiring buffer zones where feasible. This helps
to alleviate future problems with conflicting land
uses. One additional site since the public hearing
on September 1, 1977 was recommended. This site
lies across the creek from the existing South Buffalo
treatment plant. This site was investigated and
considered to be unacceptable because large numbers
of people lived within the area and because of the
extensive flood protection that would be required for
this site.
Criteria for evaluation of potential treatment plant
s was based upon engineering and environmental
considerations. Engineering considerations re-
quired that the site be located in an area which
IX-6
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would be amenable to construction and wastewater
treatment system needs. These factors essentially
entail the limitations that a wastewater treatment
site be located outside of in, jor floodplains , away
from steep slopes, and b- an enable to construction
practices not requiring excessive costs, i.e., dril-
ling, blasting, and rock removal.
The Agencies believe that all reasonable efforts
have been expended in identifying and evaluating pro-
mising candidate treatment sites that would satisfy
the Greensboro wastewater management needs and
obj ectives.
Comment Although fewer people will be affected by construc-
tion and operation of a new plant in Alternatives
4 and 5, the Ciba-Geigy site was selected.
Response: The number of inhabitants within a potentially
affected area of a wastewater treatment plant is
a prime consideration in selection as part of the
proposed action; however, it is just one factor
that goes into t.hf. selpc^ion process as described
in the EIS. Other environmental social, and eco-
nomic issues were considered to be of overriding
importance compared to the small differences in
the number of people affected by the sites of Alter-
natives 4 and 5 as compared to the proposed action.
IX-7
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4. Comment:
Alternative 2 was rejected because the site in-
volved a highly-productive, family farm; yet the
DEIS designates that area as one in transition
from rural, agricultural to commercial, industrial,
and residential and the construction of an outfall
sewer on part of the Clapp farm in implementing
Alternative 3 will encourage that transition.
Response:
5, Comment:
The DEIS, exclusive of siting factors, evaluated
those areas which are considered to be transitional
with respect to the growth of Greensboro. Refer-
ence to page 11-111 in the DEIS illustrates that the
future land use of the Clapp farm site and surround-
ing areas will continue within the 20-year timeframe
as it currently exists. Prediminate growth is ex-
pected to occur west and northwest of South Buffalo
Creek (in South Buffalo Creek basin) under any
alternatives selected, not just Alternative 3.
The implementation of the outfall sewer from the
existing South Buffalo plant to the new plant site
will not jeopardize the agricultural productivity
of agricultural plans of the Clapp farm site.
Government planning and zoning policies can control
or prevent any undesirable "leapfrogging" develop-
ment encouraged by the implementation of Alterna-
tive 4.
Response: The Agencies recognize the adverse environmental
consequences of "leapfrogging" and sprawl in
urbanizing an area.
IX-8
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The future land use and population forecasts as
depicted in the EIS indicate that population will
extend to below Highway 70 about one mile by the
year 2000. The proposed action places a gravity
interceptor along the South Buffalo Creek at a
distance that will just accommodate this growth.
The new South Buffalo plant is sited at the fringe
of the forecasted growth and will accommodate
South Buffalo Basin wastewater needs at least
until the year 2000.
In Alternative 4, the South Buffalo plant will be
located some 3 miles below the Alternative 3 site.
It will also accommodate the forecasted growth
but locating the plant an additional 3 miles
below maximum expected growth area is considered
by the Agencies to be excessive in meeting the
2000 growth needs and would contribute to the
development of urban sprawl.
6. Comment: The presence of a wastewater treatment plant depresses
land values; by keeping the existing facilities, no
new land values will be affected.
Response: The value of land as affected by the installation
of wastewater treatment plants is a function of the
land use planned around the plant. It is agreed
that if the land use is residential and is within
an affected zone of the plant, that the property
values will probably be less than if the plant
were not in the area. However, if the area surround-
ing the treatment plant is to be used by the indus-
trial or commercial sector, no appreciable decrease
IX-9
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in property values is expected. Because the pro-
posed action provides for a large buffer around
the treatment plant, the area is considered to be
suitable for residential development.
In essence, the value of property around the exist-
ing South Buffalo plant is expected to be increased
while property values around the Ciba-Geigy site
will not be adversely affected.
Comment: Alternative 3 will cause increased "dispersion" of
flora and faunal habitats.
Response: The installation of the outfall sewer and construc-
tion of the treatment plant per se is not considered
to be a significant adverse impact upon the vegeta-
tional and wildlife habitat environment. Any of
the alternatives will accommodate increased urban-
ization which will occur in the area as described
in the EIS. By its very nature, urbanization will
remove habitat for wildlife and change the vegeta-
tional structure within an area. This will result
from implementation of any of the alternat ives ,
not just Alternative 3.
Existing aquatic habitat quality in North and South
Buffalo Creeks is marginal and consequently, the
proposed action will have essentially no adverse
impact and in time will produce beneficial effects.
Effects of the proposed action on terrestrial flora
and fauna will be largely temporary. Disturbance
f p ant and animal communities by construction and
operation of the proposed facilities will not des-
IX-10
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troy critical habitat or deleterious numbers of
wildlife. No endangered terrestrial species are
known to inhabit the proposed construction sites.
Indirect effects of the proposed action (and all
alternatives) will result in an increase of the
iabitat fragmentation already observed in the area.
8- Comment: The South Buffalo plant should be abandoned
because of the odor problems.
Response: As described in Section VIII, additional studies
were conducted to assess the modifications that
would be required to upgrade the South Buffalo
plant. Results of this investigation concluded
that extensive and costly rehabilitation will be
required.
The proposed action includes abandonment of the
South Buffalo plant and consequently relief of
of the odor problem as it now exists.
9. Comment: Will implementation of the proposed action involve
acquisition of any currently productive farm
land?
Response: No, the farm land on the Ciba Geigy site that
will be removed by the treatment plant is not
currently being worked.
IX-11
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10. Comment: The principal
plant and the
South Buffalo
problem is siting a new treatment
EIS should confine itself to the
basin.
Response: The Agencies do not agree with this allegation.
In fact, the Agencies are legally constrained to
consider an area at least as large as the 201
Facilities Planning Area. The "problem" is
not merely one of site selection; rather, the
Agencies must consider direct and indirect effects
on the natural and cultural environment of the
construction and operation of the proposed waste-
water treatment facilities. This includes by
necessity the effects of the facilities in
accommodating, stimulating, or modifying popula-
tion growth trends, land use patterns, and other
socio-economic characteristics throughout the ser-
vice area, regardless of the treatment plant(s)
location.
11. Comment: The criteria by which the alternative site #2
was judged "prime agricultural land" (and there-
by eliminated from consideration) should be set
forth.
Response: Since publication of the Draft EIS, the Soil
Conservation Service has promulgated specific,
material criteria for assessing whether soils
should be considered "prime agricultural land"
(42 Federal Register No. 163). These criteria are
presented in the Appendix. Investigation and
IX-12
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comparison characteristics of soils in the
Greensboro area and these criteria indicate
that virtually any upland area of a size and
configuration necessary for a treatment plant
in eastern Guilford County will comprise in part
soils that are prime agricultural land. In
particular, the sites proposed in Alternatives
2, 3, 4, and 5 are considered in part prime
agricultural land with respect to their soil
physiochemistry. Of these, however, only the
new site of the proposed action is not in
agricultural production. Moreover, the Clapp
farm site of Alternative 2 is comprised of the
most prime agricultural land, and it would be
virtually impossible to avoid disrupting such
soils in constructing a treatment plant at this
site.
Beyond these considerations, the Agencies
believe that the Clapp farm is very definitely
of considerable agronomic importance historically
and is recognized by local agronomists and
soil scientists as a valuable regional resource.
(See material submitted by Commenter P-42 in
Chapter IX.) For these reasons, the Agencies
are not persuaded to commit this land resource
to a treatment plant locale.
Comment: The Citizens Advisory Group was not offered an
opportunity to provide input into final site
selection, a "breach of responsibility" on the
part of EPA.
IX-13
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Response: While the Agencies value highly public participa-
tion in the NEPA process, the purpose of the
Citizens Advisory Group (CAO) is not to delegate
EPA and DNRCD1s responsibility for decision-making
Input from the CAG was applied to all alternatives
through the weighting factors used to calibrate
the evaluation to the socio-cultural characteris-
tics of Greensboro. A meeting was held following
the preliminary decision to select the Ciba-Geigy
site. At that meeting the impacts of this alter-
native were discussed. This preliminary decision
was included in the DEIS. Committee members as
well as the public at large were given the oppor-
tunity to comment on this selection prior to the
final decision which is included in the FEIS.
13. Comment; It was made public at one time, that Alternative 2
was selected as the proposed action and shortly
thereafter Alternative 3 was announced as the
proposed action. How was the site for Alternative
3 identified and selected?
Response: On May 20, 1977, a meeting was held in Atlanta
with EPA and Radian to discuss selection of pre-
ferred alternatives for the DEIS. A1 ter...; r i vt- ?
w s tentatively selected and Radian performed an
intensive investigation to determine the accep-
bility of the site for location of a wastewater
treatment plant.
IX-1L
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Following the May 20 meeting, the State and City
requested a meeting to discuss this preliminary
decision. This meeting was held May 26 with
EPA, State, and City officials and Radian represen-
tatives. At this meeting, Radian presented a
detailed analysis of Alternative 2 revealing that
the candidate site was occupied by a highly pro-
ductive farm and was inconsistent with national
and regional policy.
A new site (incorporated in Alternative 3) was re-
commended for consideration by the State. Radian
was instructed to investigate this site in detail
After this investigation, another meeting was held
June 15 to discuss the findings. Representatives
of federal, state, and local governments were in
attendance.
At this meeting, Alternative 3 was selected as
the preferred alternative as the proposed action
for the DEIS.
Comment: The location of a plant for the city is in the
county rather than the city.
Response: County commissioners support implementation of
either alternative 3 or 4 and the plant is de-
signed to serve portions of the county as well
as the city of Greensboro.
IX-15
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15. Comment: Why were no capacity alternates considered, parti-
cularly in view of the wide variation of projected
flows, from 29 to 48 MGD, which have been estimated
for this project? The 2 MGD flow downstream of
South Buffalo provides an apparent capacity alter-
nate. What is the environmental impact of not
providing service to this flow for a reduction in
total capacity requirements?
Response: Population forecasts were developed and established
as tne basis for computation of an areawide design
flow. Alternatives were identified and sized to
accommodate this design flow. Capacity alterna-
tives were considered but abandoned because the
area is generally not suitable for septic tank
service and wastewater reuse/recycle is currently
not economically attractive. The environmental
impact of not providing service was assessed under
the No Action alternative and was found to be
unacceptable.
In the flow resolution calculations, what is the
assumed percentage of population served in what
service area, and what is the cost of providing
sewer service to the growth? Can that service
be reasonably expected to be provided within the
20-year period?
See the Technical Reference Document of the DEIS
for flow calculations. The user charge for imple-
menting the proposed action which will accommodate
projected growth will be $36.60 per household per
16. Comment:
Response:
IX-16
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year. User's cost is based on the total local
capital costs arid municipal operation and main-
tenance cost for a sewered population of 255,000.
17. Comment: Why was the site in the general area of Northeast of
Lee Street, North of 1-85 and just downstream of
the South Buffalo plant discarded? Note this site
would be bounded partially by the A&T farm which
would provide a buffer zone for the plant and that
substantial acreage, topographically suitable for
a new plant, is vacant and available.
Response: See Section VIII
IX-17
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B. Social Issues
Commenters: A-l, A-2, A-4, A-7, A-13 , A-15, A-18, A-29,
A-32; B - 7 , B-9, B-15, B-16, B-47
1. Comment: The continued existence of the present South
Buffalo plant essentially prohibits Blacks living
in the area of the plant from selling their homes
and re-locating, thereby perpetuating discrimina-
tory housing patterns in the City of Greensboro
and constituting a violation of the Civil Rights
Act. Although the DEIS contains no factual data
to support the conclusions stated in the Robbins
memorandum (e.g., investigation of past housing
practices or current housing availability), this
memorandum was apparently accepted as an authori-
tative interpretation of Title VI of the Civil
Rights Act and further as a basis for rejecting
Alternatives 1 and 6.
Response: Serious allegations have been made from residents
of the southeast Greensboro community that the con-
tinued existence of the present South Buffalo plant
constitutes a continuation of past discriminatory
practices in violation of the Civil Rights Act of
1964. A review was conducted by the EPA Region IV
Office of Civil Rights (see Appendix D). Since the
construction of a new plant is preferable for other
reasons, as presented in Section II, a detailed in-
vestigation was not conducted in conjunction with
the EIS.
IX-18
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2. Comment If upgrading of the South Buffalo plant is deter-
mined to be "socially unacceptable" because of the
discriminatory situation the plant's existence
encourages, why is the same standard of "accepta-
bility" not applied in considering the upgrading
of the North Buffalo plant where a substantial
minority population is also located in the area
adjacent to that plant?
Response •. There has not been a final determination that either
the North or South Buffalo plant is "socially unac-
ceptable" and contributes to a discriminatory sit-
uation. The DEIS states that some 878 people live
within 2000' and some 2,273 live within 3009' of
the North Buffalo treatment plant. Most of these
people live north of the treatment plant in multi-
family housing units. These housing units are pre-
dominately occupied by non-minority members. From
the Public Hearings and in odor complaint records,
no appreciable concern has been voiced about the
North Buffalo plant having an adverse impact on
residential living. Some complaints have been ex-
pressed by commercial establishments across the
North Buffalo Creek from the plant. However, when
compared to South Buffalo as a source of potential
health hazards and annoyance, factual complaint
data do not substantiate that the North Buffalo
plant is a major concern to neighboring residential
areas. In any case, the odor problem that does exist
should be significantly reduced by the proposed up-
grading of the North Buffalo facility.
3. Comment: The impact of the treatment plant on other than
residential areas (i.e., industries, schools, etc.)
should be addressed.
IX-19
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Response: No other areas, including industries, schools,
churches, etc., will be directly affected by in-
stallation and operation of the new South Buffalo
outfall and treatment plant.
4. Comment: Is it not EPA policy to provide funding to build
wastewater treatment plants that do not smell and
wouldn't this upgrading relieve the "social effects"
around the existing South Buffalo Plant?
Response: It is EPA's policy to provide funding for design
and construction of wastewater treatment plants
that do not emit undesirable odors. Upgrading
would significantly reduce the frequency and potency
of odors emanating from South Buffalo plant. A
final determination concerning allegations of
discrimination at the South Buffalo plant cannot
be made without further investigation.
IX-20
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C. Water
Commenters: A-9, A-14, A-15, A-28
1. Comment: Building a new plant downstream will eliminate
8 miles of good stream for fish, wildlife, and
irrigation.
Response: For the proposed action, it is acknowledged that for
approximately 5 miles, approximately 11 MGD, of
streamflow will be removed from that segment. How-
ever , existing water quality is not suitable for
fish and wildlife in the upper reaches and only
marginally suitable in the lower reaches of South
Buffalo Creek. With the proposed action, the
natural streamflow will return to the low flow
condition of approximately 1 cfs. If the South
Buffalo treatment plant were upgraded, the improve-
ment in the aquatic habitat of South Buffalo Creek
would be marginal because of its channelized char-
acter and the influence of non-point sources on
stream quality.
Although it is acknowledged that a reduction in
streamflow that now exists will occur in this 5-
mile segment, the water of South Buffalo Creek
in this segment is not currently used as a source
of irrigation water, nor is it anticipated to be
used for irrigation in the future.
Comment: If water downstream, of the new plant is to be used
as a potable water resource, what are the impacts
to that resource of increased urban runoff?
IX-21
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Response
Whether the proposed action or one o~ the other
alternatives were selected, the urbanization is
expected to be the same. Consequently, any impact
downstream from urban runoff will be common for
aay of the alternatives.
Comment:
Response
No known drinking water supply downstream of the
proposed South Buffalo plant will be affected
by installation or operation of that plant or
urbanization of the South Buffalo basin. It is
recognized that increased urbanization will cause
increased pollutant loadings from land runoff.
At distances where any drinking water is withdrawn
from the drainage area, the pollutants from Greens-
boro runoff are not likely to translate into any
appreciable effects on stream quality.
The estimates of ground water availability in the
DEIS are considered to be extremely high.
The Agencies consider that the most recent study
of the Ground Water Section of North Carolina De-
partment of Natural Resources and Community Develop-
ment more accurately reflects the true ground water
availability in the county. This study was speci-
fically designed to obtain such an estimate. This
report will be available from DNRCD in the near
future.
IX-22
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D. Air Quality and Odor
Commenters: A-2, A-14, A-19, A-25; B-3, B-7, B-29
Comment: Air Quality Maintenance Area (AQMA) regulations
cannot be considered an automatic control on air
quality standards or ensure compliance. For each
alternative, increases in air pollutants should
be analyzed with respect to possible additional
regulatory action required.
Response: The Agencies recognize that AQMA regulations are
not considered to be an automatic control over
air quality standards or ensure compliance with
those standards. The alternatives were developed
in the EIS on the premise that urbanization of the
study area will occur in response to patterns that
do 1101 consider sewerage service a constraint. All
of the alternatives closely accommodate such a
pattern. Consequently, increases from air pollu-
tants for any alternative, except No Action, will
be essentially the same. Differences in secondary
air quality effects among the alternatives will be
negligibly small.
It is not expected that any one alternative will
significantly affect AQMA planning over any other
alternative. With respect to urbanization and past
suspended particulate violations in the study area,
the selected alternative may contribute to future
localized increases in TSP levels. These increases
may necessitate additional emission controls.
IX-2 3
-------
2. Comment: With regard to the first paragraph on page V-4,
non-significant deterioration regulations will have
little effect in preventing increases in pollutants
because of the limited nature of the state's
regulatory authority; hence, the statement in the
DEIS that secondary impacts will not be significant
may not be true.
Response: Currently, state statutes only contain a general
reference to prevention of significant deteriora-
tion of air quality in clean areas (15 NCAC 2D .0401)
Under the federal prevention of significant deteri-
oration regulations (40 CFR 52.21), the state has
been delegated administrative and technical review
powers by EPA. But these PSD regulations regulate
only TSP and sulfur dioxide levels. PSD regula-
tions governing levels of other air pollutants will
be promulgated in 1979.
3. Comment: Is the DEIS correct in stating that no significant
improvement of air quality will be accomplished in
upgrading the North Buffalo plant?
Response: Yes. The Agencies do not consider the North Buffalo
treatment plant as a source of air pollution to be
appreciable. Upgrading and improving the North
Buffalo plant will have an insignificant contribu-
tion to reduction of the air pollutants in the
Greensboro area.
IX-24
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4. Comment:
The DEIS did not include air quality and odor im-
pacts .
Response: The DEIS discusses impacts of air quality and odor
under Section V.B.
5. Comment:
Response
No comparison of the odor impacts of Alternatives
1, 3, and 6 were made in the DEIS.
The impacts of air quality and odor for all alter-
natives are addressed in the DEIS and Technical
Reference Document
6. Comment:
Response
7. Comment:
The two statements in the DEIS that recorded overt
odor complaints are minimal and that no records of
such complaints are kept are contradictory.
It is not standard policy for the City of Greensboro
to record all of the odor complaints as received.
The complaint records in the Guilford County Health
Department show that very few complaints have been
received regarding the odor from the existing waste-
water treatment plants. At the public hearing of
September 1, 1977, several hundred complaints of
odor from the South Buffalo plant were received.
An explanation should be given as to how the 3000
radial foot limitation for considering odor impacts
was determined.
Response: No widely accepted criteria or guidelines have
been developed to specify zones of odor effect as
related to wastewater treatment plants. Such fac-
tors as odor types, wind, temperatures, humidity,
IX-2 5
-------
etc. , vary widely from area to area. Tine 3000'
radius was chosen from past experience on the basis
of studies of odor impacts from wastewater treat-
ment facilities including odor surveys of neighbor-
ing residents.
8. Comment: If odor is a concern with upgrading of the South
Buffalo plant, why is it not a concern at the
proposed new plant?
Response The new treatment plant site will provide a buffer
of approximately 3000 feet to the nearest human
inhabitants and a distance of 2 miles to McLeans -
ville, whereas some 3,192 people live within 3000
feet of the existing South Buffalo site. Signifi-
cant offensive odors from either of the candidate
alternative treatment plants is not expected be-
cause state-of-the-art design of unit processes
will be implemented.
IX-26
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E. Urbanization
Commenters: A-3, A-14, A-16, A-18, A-27; B-16, B-27,
B-29 , B-33, B-34, B-41, B-56
Comment: McLeansville residents oppose the increased urban-
ization that the proposed new South Buffalo plant
will encourage.
Response:
Comment:
The population and land use forecasts presented
in the DEIS were based upon the premise that all
growth in the Greensboro area would be accommodated
by sewerage service. Consequently, all alternatives
under consideration would, by definition, be re-
quired to service those areas that were forecast
as being growth areas in the DEIS. A review of
the DEIS shows that growth in the South Buffalo
basin in the next twenty years will occur downstream
from the existing South Buffalo plant, approximately
5 miles. This growth is projected to occur under
any alternative.
It is tne view of the Agencies that the location of
the new South Buffalo plant will not encourage nor
stimulate growth beyond that forecast in the DEIS land
use projections for the year 2000.
Local residents will be subjected to increased fre-
quency of flooding and power failure if the new
plant is located in McLeansville.
IX-27
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Response: Increased runoff caused by urbanization will occur
under any alternative regardless of the new plant
site. The alternatives development was based on
an urbanization scenario that is forecast for
Greensboro by the year 2000 and is independent of
treatment plant location.
As presented in the DEIS, the secondary effects of
increased flooding as a result of urbanization can
be appreciably reduced by adopting a comprehensive
storrnwater management program. Tnis program should
be integrated with community land use planning
and engineering constraints. Other mitigative mea-
sures will include the reduction of impervious
areas through lot size control and use of permeable
pavements and structural measures to offset decreased
lag times. Detention ponds, natural and artificial
depression storage, and effective routing of storm-
water will be considered in the critical areas.
The City Council of Greensboro has adopted a resolu-
tion "that the Mitigative Measures set forth in the
State/Federal EIS are found acceptable and will be
implemented provided that either Alternative No.
3 or 4 is constructed with Federal funds." Guilford
County Commissioners are encouraged to adopt policies
and programs consistent with those of the City Council
concerning this issue. (See Appendix E.)
3. Comment: What will be tne effect of increased development of
the McLeansville area on agricultural productivity?
Response: As described in Figure 11-21 of the DEIS, those
areas identified as agricultural which occupy the
IX-2 8
-------
^ones of transition will be removed from productivity
These areas were surveyed during the development of
the DEIS. Most are either pastureland or marginally
productive row crop. This area is typical of much
of the Piedmont region of North Carolina where
areas suitable for agricultural development are
also those areas which are amenable to residential
development. In the South Buffalo basin, approxi-
mately 2,800 acres is in agricultural use. Of this,
an estimated 25%, or 700-1,000 acres, will be re-
moved by urbanization by the year 2000. In the
North Buffalo basin, about 2,400 acres is allocated
ro agricultural use. It is estimated that about
20%, or 500-700 acres, will be urbanized by the
year 2000. In the Reedy Fork basin, about 8,400
acres is designated for agricultural use, of which
about 800-1,000 acres will be urbanized. In Alamance
Creek, approximately 15,000 acres is currently under
agricultural use. By the year 2000, about 200-500
if res will be her -4uf:c r -i -barti zaHon
Comment: More than a 20-year growth period should be
considered in selecting the proposed action;
in this regard, Alternative 4 is preferable.
Response: The Agencies are charged with equitably, dispen-
sing public funds to assist in the construction
of publicly-owned treatment works. As a public
trustee, the agencies must assure that the
capacity of the works related directly to the
needs of a designated area, as specified by a
systematic apportionment of projected conditions.
EPA's policy is that twenty years is a cost-
effective design period for these wastewater
IX-29
-------
treatment facilities, and the flow is determined
from regional population projections, disaggre-
gated (i.e., subdivided) to the local designated
planning area. EPA can not participate in funding
facilities to serve growth beyond that projected
or committed within the design period.
The proposed action is designed to serve adequate-
ly the Greensboro area until the year 2000, at
which time conditions may be substantially
different from those existing now. Development
patterns may change. Waste treatment technology
may be more advanced and less costly. The pre-
sent proposed action does not prohibit the re-
consideration of Greensboro's wastewater treat-
ment requirements in a timeframe beyond the
design period. The provision for wastewater
treatment at that time will require a thorough
evaluation of available options considering these
future conditions.
5. Comment: The DEIS does not present data concerning degradation
of water quality from urbanization.
Response: It has been demonstrated from many studies (such
as North Carolina Triangle J Area Council of Govern-
ments, Section 208 investigation, and U.S. Geological
surveys in several urban watersheds of the Piedmont
Region) that urban runoff is a prime source of streafl
water quality pollution. The Horsepen Creek monitor-
ing and modelling program will provide technical
data for determining the degree of water quality
degradation that may occur under different urbani-
zation scenarios. This information will be docu-
mented in the Horsepen Creek EIS to be filed with
CEQ in early 1978.
TX-30
-------
The lack of these data during development of the
Greensboro EIS did not influence in any way the
alternatives selection process nor the selection of
the proposed action.
6. Comment: Alternative methods of servicing the area between
the existing South Buffalo plant and the proposed
new South Buffalo plant should be investigated.
ResponsePopulation projections indicate sufficient popula-
tion in that portion of the basin to justify sewer-
age service. Soils in this area not suitable for
septic tank use on a large scale.
IX-31
-------
F. Engineering
Commenters: A-3, A-li, A-21, A-26, A-31, A-32, A-33 ;
B-3, B-7, B-14, B-29, B-30, B-32, B-37,
3-41, B-51, B-55, B-59
1. Comment: Recycle/reuse operations were not adequately ad-
dressed, nor were water conservation methods, in
homes and industry, considered, particularly inso-
far as such methods could have reduced trie projected
design capacity.
Response The Agencies recognize the potential to be gained
from considering wastewater recycle/reuse alterna-
tives and as national policy, EPA encourages and
even specifies that wastewater reuse and recycle
options be carefully considered on a co.-t effect ive
basis. The trade-offs require an assessment of
the economic gains and/or penalties afforded by
recycle-reuse options on an area-specific basis.
For the Greensboro 201 study area, various approaches
to wastewater reuse/recycle were investigated and
reported in the EIS and are reiterated below.
Land application of pretreated wastewaters can be
an economically attractive alternative because a
lesser degree of treatment may be required and
valuable nutrients, including nitrogen and phos-
phorus, can be recycled onto cropland. Crops grown
by land application of treated municipal wastewaters
are presently limited to those crops which do not
directly enter the food chain. According to the
Soil Conservation Service surveys as reported in
the EIS (with the exception of only a few locations)>
IX-32
-------
soils in the Greensboro area are generally not suit-
able for land application practices. It was reported
that an application rate of 0.25 inches per day (aver-
age infiltration capacity) would require about 10
square miles of disposal field. An area above the
headwaters of Lake Brandt was investigated as a po-
tential site for land application of pretreated
wastewater with the intent of recycling the land-
applied wastewater through Greensboro's water system.
It is doubtful that the soils in the Greensboro water
supply watershed area are suitable for renovation
of the wastewater to an acceptable level. Costs
for pumping the wastewater to the areas above the
water supply were also investigated and were con-
cluded to be prohibitive.
Direct recycle for industrial requirements can also
offer potential for reuse of treated wastewater.
The level or degree of treatment required is con-
tingent on the specific use intended for the re-
cycled wastewater as reported in the DEIS. Indus-
trial concerns have available the options of treat-
ing their plant wastewaters for either discharge
into municipal wastewater treatment systems, dis-
charge into area streams, or treatment and recycle
of water. The option chosen depends upon the eco-
nomic gain that an industry considers to be in its
best interest. It is unknown at this time whether
Greensboro area industry plans to initiate waste-
water recycle programs, but such a possibility
exists with industrial cost recovery requirements
and potentially more stringent discharge standards
that may come into force in the next two decades.
IX-33
-------
As demonstrated in the DEIS, Greensboro is approach-
ing a period in which existing water supply sources
will be inadequate. Current investigations are
underway to identify additional sources. Should
future water supply demands begin to exceed the
quantity available, then Greensboro officials
may wish to consider the option of recycling treated
wastewater. Additional treatment measures can be
incorporated into the proposed treatment system
such that it will allow municipal recycle for
drinking water. Public approval will have to be
obtained for this option. Additional measures
available to Greensboro for reduction of water
usage are detailed in various publications from
EPA and other sources.
2. Comment: The purposes of the existing South Buffalo plant
as it relates to implementation of Alternative 3
should be explained further.
Response: Alternative 3 calls for the abandonment of the
South Buffalo plant as a treatment center for the
proposed action. The process by which the South
Buffalo plant will be abandoned will be described
in detail in Step 2 of the 201 grant process.
It is now envisioned that all existing structures
will be demolished, removed, and the area rehabil'
itated to satisfy a land use as dictated by city
planning officials. A gravity interceptor will
tied to the headworks of the South Buffalo plant
and will couple to the outfall sewer leading to
the Ciba-Geigy site.
IX-34
-------
3. Comment: Industrial cost recovery (ICR) methodology was
not adequately addressed in the EIS.
Response: Attached as Appendix A is EPA's description of
the methodology used in determining industrial
cost recovery. The specific formula to be used
will be determined during the Step 2 process by
the applicant with the approval of EPA and the
State of North Carolina.
4-. Comment: Background and approaches to determining the 20-
year design flow needs should be explained in more
detail in the EIS.
ResponseSee the Technical Reference Document for an explan-
ation of the 20-year design flow determination. As
presented in the TRD, the EPA computed the design
flow to be 36 MGD. By an independent method (the
OBERS plus 10 percent method), the State of North
Carolina determined the design flow to be 36 MGD.
Comment: The discussion on reliability of a single stage sys-
tem is misleading and not valid in view of current
research.
Response: The Agencies do not agree that the conclusions on
reliability as stated in the EIS are inaccurate.
A single-stage system (one aeration basin with a
long detention time) is not sufficient for treat-
ment of Greensboro's wastewater. The State of
North Carolina does not intend to permit single-
stage systems because of their susceptibility to
IX-3 5
-------
upset. Two-stage systems (two aeration tanks with
clarifiers off of each stage) are more reliable
and less susceptible to failure caused by toxic
loads. The first tank will absorb the "shock" and
act as a buffer for the second tank to provide at
least some aeration. The DEIS reports that the
reliability comparison is that of a trickling fil-
ter, not a single-stage process.
6. Comment: The statements that textile wastes at South Buffalo
are toxic and contribute to odor formation is in
error and should be corrected.
Response: The Agencies do not believe that the implication
that textile and other industrial wastes contribute
to occasional upset conditions in the biological
treatment systems and reduce treatment efficiency
is in error. "Heavy metals may enter the waste
effluent of textile plants from mordants, metallized
dyes, and dye oxidants (dichromate, copper), cata-
lysts for resin treatment and acid fulling (zinc,
sizing preservatives) , and impurities found in com©01
chemicals used in large quantities such as mercury
from the caustic soda used in the mercerization
process.nl
According to the American Textile Manufacturers
Institute survey, "toxicity of synthetic fiber dye
wastes can retard or prevent biological waste
treatment when concentrations are significant. In
1 Industrial Wastes, March-April 1977, Page 32.
IX-36
-------
^• Comment:
Response:
8. Comment:
Response:
such cases, chemical pre-treatment will be required
prior to biological treatment or discharge to muni-
ii 2
cipal sewers."" In addition, color will sometimes
be toxic if it prevents light penetration at the
plant and it sometimes does.
The proposed new treatment plant will be able to
accommodate occasional shock loadings with less
adverse effects than those caused in the existing
South Buffalo plant.
The statement that trickling filters are temperature-
dependent and will provide little treatment in cool
weather is in error and should be corrected.
The existing tricking filters are not as reliable
as the two-stage aeration system and they are more
temperature-sensitive. This fact is well established
by treatment plant design practices. The treatment
efficiency of 87% is not good enough to meet the
proposed standards and nitrification is not accom-
plished. One of the most notorious problems with
trickling filters is that they are temperature-
susceptible and efficiency drops off with tempera-
ture decrease.
If the plant itself requires only about 50 acres,
what is the intended use of the additional land
included in the 400-acre site?
From EPA's Municipal Wastewater Treatment Works
(January. 1976):
>„ _ _ " II S Department of the Interior Federal
The Cost of Clean Water, u.j- w no^
Water Pollution Control Administration, 111, No. fy, 29 U9t>7) .
IX-37
-------
"In the past, environmental factors have created
public doubts and uneasiness about nearby municipal
treatment works... it has been the practice to
surround wastewater treatment plants with open
ground and natural barriers as forests, rivers,
major highways, etc."
The additional land is intended to provide a buffet
to eliminate aesthetic impacts to local residents
that could occur otherwise. The plant will be
visually and acoustically isolated.
The Agencies encourage multiple use of buffer areas
such as parks or recreation use. No plans are
intended to use any of the area for solid waste
disposal (refer to Appendix B for documentation).
9. Comment: Abandonment of the existing South Buffalo plant
may require implementation of a vector control
program.
Response: Because of the poor quality bottom sediments that
will remain for several seasons in the stream
segment from the existing South Buffalo plant
to the new site, the support of vectors is con-
sidered likely. As recommended in the DEIS, a
vector control program should be implemented as a
mitigative measure. Also, the agencies have
identified this action as a grant condition for
disbursement of funds as described in Section II.
10. Comment: Can odors associated with wastewater treatment
plants be eliminated and will such odors be
eliminated or significantly reduced by the pro-
posed action?
IX-3 8
-------
Response:
The odors now associated with the existing facility
will be significantly reduced by the proposed
action. See Section II.
The proposed action will include mitigating
measures such as buffer zone and covers for the
primary clarifiers, sludge thickeners, and gas
scrubbers for vacuum filters at the new plant.
In addition, pre-aeration and pre-chlorination
facilities will be located upstream to offset
septic influent wastewater to the new plant (see
Section II !
At the North Buffalo plant, covers will be pro-
vided for the sludge thickeners.
11. Comment: Waste removal efficiencies reported in the EIS
are not consistent with current state-of-the-art
wastewater treatment practices.
Response: The wastewater treatment design removal efficiencies
were estimated from EPA's standard design manuals.
Removal efficiencies at these plants are considered
reasonable if the wastewater treatment system is
properly operated.
EPA should fund a demonstration grant at South
Buffalo treatment plant to show that the South
Buffalo plant can be upgraded to meet applicable
effluent limitations.
Response: Only the City of Greensboro can request a demon-
stration grant for this purpose and no such re-
quest has been submitted
•*¦2. Comment:
IX-39
-------
13. Comment:
Exfiltration from gravity sewers and force mains
will contribute to ground water pollution.
Response: Wastewater collection
will be designed and constructed according to
best engineering practices to minimize this po-
tential. The saprolite in which these facilities
will be constructed will generally retard the flow
of any pollutants. Additionally, the clay substrata
will offer significant attenuation of these pollu-
tants before they reach the ground-water system.
In the Agencies' opinion, these collection systems
do not present an appreciable hazard to the ground' ,
water system.
14. Comment:
Response:
Greensboro's 20-year sewage treatment needs can
be met with an expenditure of $12,000,000 or less
in upgrading both plants.
The EPA and State do not agree, based upon detail®^
analysis of existing sites (reference Section VIll)'
15. Comment:
Specific suggestions were made to improve the
accuracy of the cost calculations for the alterna-
tives .
Response: Most of these suggestions were considered appro-
priate and costs were modified to reflect them
in this Final EIS. Refer to Section VIII for the
revised cost estimates.
16. Comment
The EIS does not present detailed supporting
facts regarding recommending size and design of
wastewater treatment system components.
IX-40
-------
Response: The Technical Reference Document contains detailed
costing and engineering data supporting conclusions
of the EIS. Additional engineering documentation
will be supplied in the 201 Facilities Plan.
IX-41
-------
RADIAN
CORPORATION
G. Economic
Commenter: A-32
1. Comment: Per the Council on Environmental Quality's guide-
lines for EIS's, who stands to make windfall
profits from the proposed action? Who are the
individual property owners affected, or corporation
owners if held by a corporation, and to what exteflc
have they been instrumental in selecting the
proposed action?
Response: The following people have property at the
proposed site:
Name
Paul B. Phillips
Sandra D. Kerns
George Denny
Daniel Kerns
Carl Hamilton
Virginia Hamilton
William Buder
Dwight Green
Northeast Baptist Church
H. D. Rhew
Fay Newman
Charlie Stewart
Sarah Stewart
John Broadway
Tabernacle Farm Co.
W. V. Maness
A. L. Meyland (trustee)
*Less than 5 acres
Acreage
5
76
145
*
*
49
4
5
50
*
*
*
*
7
133
65
86
IX-42
-------
Name
I. T. Cohen
Ciba-Geigy Corporation
Robert Fryar
Vannie Fryar
Christine Glass
Marvin May
Mary Anderson
Acreage
45
74
75
150
30
80
18
The Agencies do not believe that anyone stands
to make a windfall profit from implementation of
any alternative. The proposed action was selected
because it is felt to best serve the needs of the
20-year growth projection and is a cost-effective
solution to the 201 grant objectives. However
individuals who own tracts of land that will
have sewers made available by the proposed pro-
ject may realize an eventual increase in property
values. Specific propertv owners who might eventually
benefit can not be identified until the location of
the collector system is known.
IX-43
-------
x. TRANSCRIPT OF PUBLIC HEARING HELD ON SEPTEMBER 1, 1977
AND WRITTEN COMMENTS RECEIVED BY THE AGENCY
-------
THE
U. S.
ENVIRONMENTAL PROTECTION AGENCY PUBLIC
THE GREENSBORO/GUILFORD COUNTY
WASTEWATER TREATMENT SYSTEM
Greensboro, North Carolina
Thursday, September I, 1977
Fran Phillips, Moderator
This is to certify that the attached Proceedings were held as
inis is to certiiy rranscript was prepared verbation fr ;>m
herein appears. Thi meeting The scheduled Court Reporter
a tape "corjwj of the »eet«.. was
iLf" files °£ the u-s-
Environmental Protection Agency, Region IV.
- SERV.
HEARING
TRANSCRIPT
on
-------
List of Speakers for the Sept. 1, 1977 Public Hearing
Greensboro, N. C.
Jim Melvin, Mayor, Greensbor
Mary Seymour, N. C. Representative, Gen. Assembly
Forest Campbell
Henry A. Collins
James C. Johnson
Eula Vereen
Dan Fetzer
Henry T. Rosser, Attorney
Brenda Hodge
John B. Ervin
A. W. Ray, Jr.
Gladys Graves
Charles Melvin
Bill Anderson
Edna Isley
Jesse Brown
Hermon F. Fox
David M. Dansby, Jr.
Dan Kerns
Lillian M. Harley
Robert Elzy
Debra R. Alton
Sara Newsome
Mr. § Mrs. Julius Alston
Jim Rosenberg
Pearlie C. Alston
S. T. Hoffman
Jon Wimbish
W. A. Ward, Jr.
Lola Ward
James A. Avent, Jr.
Herman Lewis
Cora Robinson
Rosalia Cummings
Alfred Butler, Jr.
Charles Weill
Fred Clapp
Allen Holt
Dwight Sharpe
Ken Smith
John Michael
Thomas Nettles
Leonard" V. Lassiter
Harry Pilce
J. Ralph Lewis
E. H. Greene
Dennis C. HarTell
Harold Haskins
Wade Payne
Dr. Dlorentine V. Sowell
Mrs. Margaret Snow
-------
Speaker's List Page 2
Harvey Moses
Vance H. Chauis
Melvin S. Payne
M. F. Shute
Robert IV. Mays
Johnny Hodge
Walter Reynolds
Luevenia C. Milling
Joseph A. Bennett
Lydia Wallington
William J. Murphy
Jin-Valentine
Fred L. Clapp, Jr.
Bob She1ton
Charles L. Thompson, Jr.
A. Harrell
John G. Clapp, Jr.
W. A. White
Gregory A. Boyle
Caraeraon Cooke
Allen Andrew
Dr. Willie T. Ellis
W. H. Asjworth
Jon Wimbish
Richard T. Evans
Burleigh C. Webb
Ruby Garranaif
W. C. Parker, Jr.
Art Flynn
James C. Banks
R. Ode11 Payne
Phillip J. Bissesi, PE
Mrs. Earline H. Clarke
A1 Lineberry, Jr.
Maurice Fishman
Ben Matkins
Felicia F. Holley
Mrs. Hattie L. Slalom
Wilhelmina Foy
John Kavanagh
D. C. Frate
Mrs. Goodsby
Elizabth W. Cone
Mrs. Dorothy S. Cameron
Marquis D. Street
R. H. Souther
Gerard Gray
Mr. § Mrs. Norman L. Humphrey
C. W. Harshaw
E. Vitcor Pruitt
Mrs. Doris H. Harshaw
James S..McInler
Mrs. W. M. Black
Norma Westmoreland
Larry Watson
Mr. Stephens
Thomas Is ley
Mr. W. McLoyd
Phillips McAlpin
Merritt A. Donnell
Marie Evans
Mrs. C. Moore
Cjarles Robinson
W. T. Gibbs, Jr.
George E. Carr, Jr.
Mrs. Ruth V. Lemmon
Rosie Carr
Dan Kerns
-------
THE PROCEEDING
Moderator: May I call the meeting to order, please. Good evening
and welcome to this Public Hearing on the Draft Environmental
Impact Statement for the Greensboro, Guilford County Wastewater
Treatment System. The National Environmental Policy Act of 1969
requires an agency of the Federal Government to prepare an environ'
mental impact statement whenever that agency proposes to take a
federal action significantly affecting the quality of the human
environment. In addition, the North Carolina Environmental Poll#
Act of 1971 requires an agency of the State government to prepare
an environmental impact statement whenever that agency proposes to
take a State action significantly affecting the quality of the
human environment. The City of Greensboro, North Carolina appli^
for a grant from the United States Environmental Protection Agentf
and the North Carolina Department of Natural Resources and Commit
Development to develop a wastavater treatment system to service #
Greensboro/Guilford County area. EPA and the State responding to
the mandate of their respective national environmental policy act*
determined that the issuance of funds for the proposed Greensboro/
Guilford County Wastewater Treatment System was a major federal
and state action significantly affecting the quality of the envi*0*'
ment. Accordingly, on April 5th, 1976 EPA and North Carolina DN*cP
issued a notice of intent to prepare a joint environmental impact
statement. On November 10th, 1976 the governmental agencies joi^
held a public meeting to discuss the objectives of the EIS and
public involvement program. Pursuant to the Guidelines of the
-------
2
Council of Environmental Quality and the rules and regulations
of the Environmental Protection Agency and the North Carolina
Department of Natural Resources and Community Development with
regard to the preparation of environmental impact statements,
this Public Hearing is being held to receive comments from the
publ-ic on the Draft Environmental Impact Statement. This Draft
is being discussed in a public forum to encourage full partici-
pation of the public in the decision-making process, to develop
greater responsiveness of Governmental action to the gov... to
the public concerns and priorities, and to develop improved
public understanding of projects funded with federal and state
funds. An official report of these proceedings will be made and
become a part of the record. Notice of the public hearing was
published in the Greensboro Daily News on August 7th and
August 2 8th, 19 77. The Draft Environmental Impact Statement was
submitted to the Council of Environmental Quality and made avail-
able to the public on July 29th, 1977. I would now like to
introduce the Hearing Panel. To my right and your left, Mr. Page
Benton, Jr., who is Chief of the Water Quality Section, Division
of Environmental Management, State of North Carolina; Mr. Everett
Knight, Director, Division of Environmental Management State of
North Carolina; Mr. John A. Little, Acting Regional Administrator,
U. S. Environmental Protection Agency, Region IV; Mr. Joe
F anzmathis, Director, Water Division, Environmental Protection
Agency, Region IV; Mr. James Finger, Director, Surveillance
and Analysis Division, EPA, Region IV, and,
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3
I am Fran Phillips, Regional Counsel for EPA, Region IV. People
I would like to introduce who are not part of the Hearing Panel
are: Mr. Jim Melvin, Mayor, would you please stand Mr. Melvin?
(Applause); Mr. Forest Campbell, Vice Chairman Guilford County
Commission, (Applause); Mrs. Mary Seymour, State Representative,
Guilford County, (Applause), Is there any other elected officii
\
that I have overlooked, I would like to recognize you' at this ti®6'
(Pause). Before we begin citizen testimony, Mr. Bob Cooper of ^6
Environmental Impact Statement Preparation Section will give us a
brief summary of the project.
Speaker Mr. Bob Cooper: Thank you, Fran. This Draft Environment
Impact Statement addresses the provision of wastewater trans'
mission, treatment and disposal facilities for the greater Gree^3'
boro Area. The Horsepen Creek portion of the study is not covef^
in this Draft EIS, because water quality monitoring and modeling
studies essential to that part of the project were not completed
soon enough to be included. A supplement to the Draft will be
issued later this Fall to cover the Horsepen Creek issue. Any
decision made regarding the Horsepen Creek area will not affect
the suitability of any plant site location considered in this
Draft EIS. The objectives of constructing wastewater treatment
facilities in the Greensboro area are the attainment and preser-
vation of high quality waters for fish and wildlife, and recreat*
ional and esthetic uses, and a provision of treatment facilities
to adequately service existing and future sources of wastewater*
-------
4
A 201 Facilities Plan to achieve these objectives was prepared
by the firm of Hazen and Sawyer for the City of Greensboro. The
plan recommended the construction of a new twenty-one (21) million
gallon per date wastewater treatment plant at the confluence of
the North and South Buffalo Creeks; the upgrading of the existing
wastewater treatment plant on North Buffalo Creek at twenty-one
(21) million gallons per day, and the upgrading of the existing
South Buffalo Creek Plant at six (6) million gallons per day.
This proposal stimulated considerable controversy among citizens
in this area. The major concerns expressed included the adequacy
of the evaluation of alternative treatment plant sites, the ade-
quacy of the wastewater flow projections, and the primary and
secondary effects of the proposed new plant on land use patterns.
Based upon these concerns expressed by citizens, the Environmental
Protection Agency and the North Carolina Department of Natural
Resources and Community Development issued a notice of intent to
prepare the EIS April 5th, 1976. The objectives of the HIS pro-
cess were to adequately establish existing conditions in the Greens-
boro area, to independently evaluate alternatives for wastewater
transmission, treatment and disposal, and to assess in detail the
environmental effects of the proposed action. This Draft Impact
Statement was filed with the Council of Fnvironmental Quality and
made available to the public on July 29, 1977. An important part,
of the preparation of the EIS has been the input of the EIS
Advisory Committee. This group consists of representatives of
local governmental bodies and citizen interest groups. This
Committee has reviewed and commented on all portions... on all
-------
5
EIS outputs, has provided guidance on the relative value of
identified natural and man-made resources to residents of the
area, and has suggested alternatives to be evaluated. In the
Draft EIS, a Year 2000 design flow of thirty-six (36) million
gallons per day was agreed upon and seven (7) alternatives were
selected for detailed evaluation. The economic costs and envir°n'
mental acceptability of each of these seven (7) alternatives are
presented in the Draft Statement. In the Draft Statement Alter-
native Three (3) is chosen as the proposed action. This alter-
native consists of upgrading the North Buffalo Creek Plant at
sixteen (16) million gallons per day and the construction of a
new twenty (20) million gallons per day treatment plant at the
Ciba Geigy Site, which is just north of the intersection of South
Buffalo Creek and U. S. Highway 70. This alternative was chcsefl
because it was found by EPA and the State to be the most cost
effective alternative which was environmentally and socially
acceptable, and which met the projected twenty (20) year needs
for the provision of wastewater treatment in the Greensboro are*'
The final decision on the selected alternative will be made based
upon the material presented in the Draft EIS and upon the record
of this Hearing and all written comments received. The desires ^
and concerns of the citizens of the Greensboro area will be givefl
serious consideration in determining this recommended alternative'
I would now like to introduce Mr. Lee Wilson, who is the EIS Pro-
ject Manager for Radian Corporation, and he will give a descripti0,1l
of the seven (7) alternatives and present the economic costs and
environmental inpacts associated with each.
-------
6
Speaker Mr. Lee Wilson: Madam Chairman, members of the Hearing
Panel, ladies and gentlemen, X personally consider it to be a
distinct pleasure and privilege to participate in this Public
Hearing. I consider such public hearings to be a crucial factor
in the execution of the National Environmental Policy Act, and
also-a very crucial factor in the decision-making process as... as
Promulgated by that Act. I'd like to briefly cover five (S)
areas, some of which, hopefully, will give you visability into
the EIS development process that does not become apparent from
the EIS. Because of some confusion concerning Radian's role in
this... this ah- EIS development, I'd like to tell you a little
bit about what our purpose and function is as related to the
decision-making process. Ah- I want to give you a brief hand-
guided tour through the alternatives development, synopsize for
you the major environmental impacts of the proposed action,
briefly describe where we are Horsepen Creek study, and recognize
certain participants that were involved in this process that with-
out thair participation we wouldn't be here tonight. First of all,
Radian Corporation is an environmental study firm based in Austin,
Texas. Our total business is derived strictly from environmental
studies, and we were selected to conduct or assist EPA and the.
State of North Carolina in the development of this Environmental
Impact Statement through a competitive bidding process against
other firms similar to ours. Our contractual and designated
responsibility has been and continues to be to'conduct scientific
research to develop information that will serve to assist the
decision-makers in the various decisions that have to be made
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7
along... along the ah- course. I want to emphasize that our
responsibility is not to make decisions. We simply develop
information that can be used in the decision-making role, that
is EPA and the State of North Carolina. It may also be of
interest to... to you to know the kinds of disciplines that go
into,the preparation and research that is required in EIS develop"
ment. From Radian alone, there was some twenty (20) team-members
that were involved in the backgrounds and disciplines of various
ah- areas of social sciences,. physical sciences and life sciences,
and these were supplemented, of course, with the members of EPA,
members from the City, the County, the State. Now one of the
purposes as Mr. Cooper so well has pointed out of the EIS process
is to investigate the validity of those studies that have been
conducted in supporting a particular decision. Now, in our exami11'
ation of studies that were made available to support the EIS there
was considerable variance associated with the design flows that
were used as a critical factor in selecting the alternatives that
were previously evaluated. Because of this, it was necessary for
us to go back and re-initiate the alternatives evaluation process-
This was conducted through close interface with the citizen adviso?l
group, the City, EPA, the Sta^e, and as a result we beganned with
some fourteen (14) different sites that were candidate sites for
alternative treatment plants. And, using the population forecast
that had been developed, we began with a hundred arid twenty-fou*
(124) different alternatives that were subjected to a systematic,
multi-level screening involving economic, environmental and regul^'
tory constraints. From this screening process the one hundred and
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8
twenty-four (124) alternatives were reduced over a period of
months to forty-six (46), then to eleven (11), then finally to
the seven (7) alternatives that ah- were presented in the
Environmental Impact Statement. In your hand-out you have a
summary description of those seven (7) alternatives, and I'm
simply going to try to summarize the summary, but you can follow
along with me, if you will. First of all there's certain common
features in all seven (7) of the alternatives. One feature is
the upgrading of North Buffalo at sixteen (16) million gallons
per day. Another common feature is the ancillary facilities
that will support the population forecast. And these facilities
may even be interceptors, they may be force mains and so forth.
So, I won't mention any of those. The main differences in the
alternatives have to do with the proposed South Buffalo Plant.
Alternative Number One (1), and I won't mention the North Buffalo
Plant or the other facilities, is to upgrade and expand the South
Buffalo Plant at its current location to twenty (20) million gal-
lons per day. This alternative cost in present worth terms, about
fifty-three ($53) million dollars. The next four (4) alternatives
have to do with locational considerations for the South Buffalo
Plant. And again, design level for the South Buffalo Plant for
each of these alternatives is twenty (20) million gallons per day.
Alternatives Two (2), Three (3), Four (4) and Five (5) have to do
with locating the plant at various sites downstream. Each site,
respectively, at approximately three (3), five (5), nine (9) and
thirteen (13) miles downstream. Alternative 2, 3, 4 and 5 cost
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9
approximately fifty-six C$56), fifty-seven ($57), fifty-nine
($59) and sixty-five ($65) million dollars. Alternative Six
(6) calls for something a little different. It has to do with
the immediate upgrading of the North Buffalo Plant at sixteen
(16) million gallons, and then, at a time in the future in 1987
when it is forecasted that additional capacity would be needed
it would up... ah- be expanded to twenty-five (25) million
gallons per day. The South Buffalo Plant will be maintained at
its ah- at the capacity of eleven (11) million gallons per day
and upgraded. Alternative Seven (7) is a no-action alternative
that's required by the development of any environmental impact-
statement. Again in your hand-out, the summary is a major
environmental trade-off associated with each of these alterna-
tives is.... (The tape went blank at this point in the record-
ing. The following represents a reconstruction of the Hearing
from the registration record, actual written statements, or the
best recollection by the participant of their comments.):
A summary of the environmental, impact trade-offs associated with
each of the alternatives are presented in the hand-out. These
are as follows: Alternative 7 (the No Action Alternative) was
eliminated because it was deemed environmentally unsatisfactory•
If this alternative was implemented, a large part of the area's
projected growth could not be served by the municipal system.
This would make large numbers of people dependent upon septic
tanks in areas with soils unsuitable for septic tank use. The
alternatives involving the continued use of the existing South
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10
Buffalo Creek Plant (Alternatives 1 and 6) were eliminated
because they were deemed socially unacceptable and because
of their lack of flexibility. The area surrounding the existing
South Buffalo Creek Plant is heavily populated. Over 3,000
people live within 3,000 feet of the existing South Buffalo
Creek Plant. These residents have been subjected to periodic
episodes of highly undesirable odors for several years. For
this reason, the continued operation of the existing South
Buffalo Creek Plant was deemed to be socially undesirable. Also,
these alternatives do not provide for service of twenty-year
growth projections by gravity flow. Alternative 2 (The Clapp
Farm Site) was eliminated because it contains a century old
highly productive family farm on the site. EPA and CEQ guide-
lines discourage removing prime agricultural land from product-
ivity. Alternative 4 and 5 (the confluence site and the Reedy
Fork discharge site) were eliminated since the costs associated
with these alternatives are high, the environmental suitability
rankings are relatively low, and service would extend beyond
areas forecast for growth in the EIS land use projections.
After careful consideration of all factors involved in the
selection process, Alternative 3 (the Ciba-Geigy Site) was
chosen as the proposed action in the Draft EIS. This alternative
offers the greatest flexibility for the long-term provision of
wastewater treatment in the Greensboro area witnout encouraging
excessive urban sprawl. EIS future land use projections show
that the proposed site will allow almost all existing and pro-
jected population to the year 2000 to be served by gravity flow
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11
rather than by pumping stations and force mains. The proposed
site will also provide enough land for a buffer zone. While
the purchase of land for buffer zones is not a requirement,
EPA does encourage this practice when feasible. This helps to
alleviate future problems with conflicting land uses similar
to the existing situation surrounding South Buffalo Creek. Pro-
posed Action. Direct adverse impacts associated with the pro-
posed action are minor. Sewer construction and construction
activity at the new plant site will cause short-term, minor
stream siltation and increased air-borne particulates. Some
natural vegetation will also be destroyed, continuing a trend
to habitat fragmentation. Some human inhabitants will be sub-
jected to temporary noise levels that exceed acceptable thresholds-
Water quality will be improved in the lower stream reaches, but
stream quality will remain stressed in the immediate Greensboro
vicinity. A 5-mile segment of South Buffalo Creek below the
South Buffalo treatment plant will undergo a substantial decrease
in flow. Abandonment of the existing South Buffalo plant will
likely cause a requirement for vector control downstream of the
existing municipal outfall for several years. Important adverse
secondary impacts include increased flooding and the necessity
for flood control measures, an increase in urban runoff of poor
quality that degrades streams and reduces aquatic habitat quality>
continued terrestrial habitat attrition through residential and
industrial growth, and increased air pollution through population
growth. Major beneficial impacts beyond any water quality im-
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12
provements include elimination of the notorious odor source
of the old South Buffalo plant which adversely affects several
hundred people and the potential for planning orderly urban
growth without environmentally unsound sprawl or other effects.
The proposed action is well-matched to projected growth patterns,
accommodating desired growth while discouraging urban sprawl
and other unplanned growth. Horsepen Creek. Numerous technical
tools are available to the investigator for forecasting impacts
of various alternative actions. One category of tools are
proven mathematical simulation models which are capable of
efficiently revealing to the analyst probable effects, both
adverse and beneficial of certain a-: tivities. For the Horsepen
Creek basin, we are collecting data to calibrate such a model to
determine the impact of various development patterns on the
water quality of Lake Brandt. This study is proceeding and we
are expecting to complete the analysis in early October. The
results wil3 become an amendment to the published EIS and
another publich hearing will be conducted to enable your inputs
concerning this question into the Final EIS. Coordination. To
successfully complete an EIS study requires the coordination and
cooperation of a broad spectrum of individuals including back-
grounds in the natural, physical, and engineering sciences. Ar.
an unbiased participant in this program, I believe it appropriate
that you should know of the participation of your citizens and
public administrators in this program. I have had the privilege
of working on several studies of this type--yours has been parti-
cularly unusual because of the unselfish participation and coop-
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13
eration of so many individuals who contributed many hours of
their time to insure that your community's interest was repre-
sented throughout the development of the EIS. The members of
the Citizens Advisory Group whose names are presented in
Chapter VII of the EIS are to be particularly commended. Your
city officials and representatives from surrounding communities
were extremely helpful in making available information needed
for the study and working with Radian, the State, and EPA
staff members. You also neud to know that the City published
the EIS. I also believe that the EPA and the State participants
should be recognised for their dedication in guiding the develop-
ment of this EIS through a very difficult preparation time-frame-
This effort.has represented an extraordinary example of cooper-
ation between citizens, industry, local, state, and federal
governments and that's what i;he spirit and intent of NEPA i.s
all about. Your presence here toright keenly demonstrates
your interest in the welfare of your community's future and that
NEPA is alive ?;nd well-
Speaker E. S. Melvin: First, I would like to thank you and the
other members of the staff of EPA and the Department of Economic
and Natural Resources for your patience and understanding on this
most important project. I sincerely hope we are drawing close to
the hours of decision. I would like to take the liberty of tell-
ing you a little bit about our community because I think it is
pertinent to the subject that we are here tonight to discuss. I
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also hope that while you have been visiting here examing this
Project, you have had an opportunity to observe-first-hand
our very unusual community. Greensboro is, indeed,, an unusual
community and it is, indeed, an outstanding place to live.
These qualities that we all enjoy and covet so much did not
just, happen. Our forefathers of this community in general have
a long track record of facing up to our problems--facing up to
unusual problems of all types. We stand here tonight in a
community that has been judged by lots of people as really one
of the finest in this Country in which to live. Now, I know it
is easy to make that claim about being one of the finest, but
we have substantiating evidence recently published by an outside
agency. I would like to enter into the official record tonight
a copy of a survey just completed and just published nationally
by the University of Nebraska. This survey was financed by the
federal government and conducted by the University. It surveyed
more than eighty different categories which affect the quality
of life in a community like Greensboro. Our score was so high
that we finished number S in the 100 cities tested. I would like
to point out that not only did we finish number S, but if you
will carefully review all of the categories tested, you will see
that Greensboro consistently finished in the top 10% in all
qualities of life. This substantiates our claim that we are not
a good community by accident. The project that we are here to-
night to propose and speak in favor of is the very foundation of
our community. Over eight years ago, this community, without
undue outside infludence recognized that we had an environmental
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problem. As a local community, we decided to resolve those
local environmental problems. At the time this"project was
started, projects of this type could be resolved in small
meetings under semi-private circumstances. Greensboro, in
no way, ever tried to fast-ball this project by our neighbors
to the east. Ifi 1970, we conducted a very public campaign
through a bond issue which plainly explained that the proceeds
would be used to ultimately build this plant so that Metropolitan
Guilford County wastewater treatment problems could be resolved.
That issue received a 3-1 vote of approval from the voters of
Greensboro. In 1972, at the time of the State's Clean Water
Bond Referendum, our project was given the number 1 priority
by the State. We stand, before you tonight with either unanimous
or overwhelming majority positive votes from every local govern-'
ment agency pertaining to this project. The Greensboro City
Council is and has been unanimous in its support, and yet we
are little or no further along tonight than we were in 1968.
We plead with you to digest the comments, the facts, and the
figures that you hear here tonight. But we also plead with you
and even beg of you to let this community face up to its own
local environmental problems by giving us a decision and allow-;
ing us to build this project somewhere - but quick! Further
delays are going to cost these taxpayers - our taxpayers - sign-
ificantly more tax dollars. We feel that this community has
done its homework. We have stated from the very beginning and
very publicly that we expect our proposal to stand every test;
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we feel that our proposal has met those challenges. We feel
that the facts - and I must emphasize facts - point out clearly
that the plant should be located at the confluence of North and
South Buffalo Creeks. We feel that the facts recommend this
site for the residents in and around the McLeansville area, as
well, as those in Greensboro and rural Guilford. We, however,
quickly must state that if in your opinion Alternate 3 is the
location, we can accept that premise. We again want to point
put, however, that the North-and South Buffalo confluence site
is the best and most desirable. In closing, I would just like
to say that I think our wastewater treatment plan has been a
good example of democracy at work. Everyone, both pro and con,
has had his opportunity to speak. I think it is now time, how-
ever, for the speaking to cease and for the acting to start. I
would like those in the audience who join with me in favoring
either Alternate 3 or Alternate 4 to please show their support
by standing. Thank you.
Speaker Ms. Marv Seymour: I am Mary Seymour, 110S Pender Lane,
Greensboro. From 1967 thru 1975 I served as a member of the
Greensboro City Council and was Mayor Pro Tem from 1973-1975.
Last November I was elected a State Representative from Guil-
ford County to the North Carolina General Assembly. I am a
member of the House of Representatives' Natural and Economic
Resources Committee. Soon after the General Assembly convened,
I had several conferences with Secretary of Natural and Eco-
nomic Resources, Howard Lee, regarding the urgency of proceeding
with site selection and implementation of the Metro Wastewater
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Treatment Plant and the impact it would have not just for
Greensboro and Guilford County but for the State of North
Carolina. Governor Hunt's platform for economic and .quality
gTowth development mandates industrial expansion. Because
of inadequate treatment facilities, Greensboro and High Point
are under a moritorium for industrial expansion which has
severely restricted economic recovery in a section of the
State possessing a mobile and effective labor market. As I
have listened tonight to the presentations of the consultants
for Radian Corporation another consultant study has come to
mind. In attempting to meet the challenge to clean up our air
someone recommended the catalytic converter be developed to
eliminate air .pollution from automobile exhaust. But today
scientists tell us that the catalytic converter is dripping
toxic waste into our water sheds poluting another valuable
resource. How do you balance clean air against clean water?
From all the studies the majority agree on the need for improved
waste treatment. It appears to me we are talking about balancing
the interests of the 150-160 thousand people of Greensboro and
the other people of Guilford County who will use this facility
against those people who for one reason or another, do not want
the facility. When the project was first planned in the late
60's or.early 70's, it was estimated to cost approximately 13
million dollars. When I duscussed this matter with Secretary Les
in February of this year, it was estimated at approximately 45
million. Tonight we have heard the estimate of 57+ million for
the Radian recommended site, or 59+ million for the City's pre-
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ferred site at the confluence of North and South Buffalo. It
would appear that the people of Greensboro have ..lost approximately
45 million dollars in the projected increase in costs, but the
people downstream have lost in the quality of their water and
their environment and this includes the people in McLeansville.
The longer the Metro System is delayed, the longer it is inade-
quate, we are just postponing with more cost and more damage
to our environment. Time is a natural resource that is not
recoverable.
Speaker Mr. Forrest Campbell: I come to you representing the
voice of the majority of our County Commissioners on the issue
of the proposed Metro Site. Guilford County government, as
well as all other officially sanctioned agencies, has repeatedly
endorsed the Metro Project and the confluence site. This in-
cludes the positive sentiments of our Environmental Committee."
The plans for this 465-acTe site present in our minds the least
expensive plan which most fully accomplishes the objectives and
goals established for wastewater management for the Greensboro-
Guilford area. It also poses the least permanent effects on
people, plant, and animal life. We.continue to express the
urgency of the project, not only in view of the growth designs
of the City of Greensboro, but those county areas that will be
developing under a planned program. From the standpoint of
both local government, growth can be more efficiently directed by
our policies including land-use plans and water and sewer service
areas. Most of Greensboro's industrial development land is
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located in the South Buffalo drainage basin. The new Metro
plant would provide capacity service for present and future
industries, as well as the residential population. The Metro
plan would also make gravity service available to an addition-
al 35 square miles in northeast Guilford County. Planning and
cooperation on a fully regional basis has been formalized
between the County and City since the 1965 Water and Sewer
Agreement, which, by the way, was the first of its kind in
North Carolina. Looking at the whole of our area, we are in
further agreement with the City of Greensboro that the Ciba-
Geigy site would be an operable location. While, it does not
meet our needs as completely as the confluence site, we could
accomplish most ends within its confines. The number of people
adversely affected is approximately the same number in both the
confluence and Ciba-Geigy sites. The confluence site has approxi'
mately 1,800 persons living within two miles of the proposed site'
You can compare this with the South Buffalo site which has
approximately 25,000 persons living within two miles of the
plant, or 3,200 living within 3,000 feet of the plant. The Ciba'
Geigy site would serve about 27 more square miles and would pro-
vide adequate land for future expansion plus providing a buffer
area. On behalf of the majority of the Board of County Commiss-
ioners, I would like to urge that the decision-making on this
project be expedited, not only because of the pressing area needs
but because of the rapidly escalating project costs.
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Speaker Mr. Henry A. Collins: Members of this Hearing Committee
and those gathered here, my name is Henry A. Collins. I reside
at 3904 Hickory Tree Lane, Greensboro, North Carolina. Hickory
Tree Lane is located southeast of Greensboro. It is immediately
south of Interstate 8S in the vicinity of Young's Mill Road. For
those of you not familiar with Young's Mill Road, it crosses 1-85
at the overpass just east of the southbound rest stop near to and
east of Greensboro on Interstate 1-85. At this point in time, I
w in favor of Alternative No. 3 proposed by Region IV of the
Environmental Protection Agency in cooperation with the State of
North Carolina Department of Natural and Economica Resources.
This Alternative proposes construction of a wastewater treatment
facility 26,000 feet downstream of the South Buffalo Creek
facility with capacity to provide tertiary treatment at 20 million
gallons per day. It further proposes upgrading of the North
Buffalo Creek facility to provide tertiary treatment of 16 million
gallons per day, the abandonment of the South Buffalo Creek
facility and construction of a sixty-inch outfall sewer from the
South Buffalo Creek facility to the new sewage facility which is
proposed. Although I have several concerns about the present
sewer system, my major concern is that of aerial pollution in
the form of odor which is all too common from the South Buffalo
Creek facility. A'more recent example of this was. Saturday
evening, August 27, 1977. Approximately 8:00 p.m., the odor
was of choking proportions. The recent odor is not new. As a
point of information, I wrote to the Guilford County Board of
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Commissioners on about the odor frequently
emanating from the South Buffalo Treatment facility. I will not
read this letter, but here is a copy of it. Based on. the Envir°n'
mental Impact Statement prepared, the City of Greensboro nor Guil'
ford County maintains a record of the number of complaints recei^
relative to sewage odor. I am certain that there have been man/
relative to the South Buffalo Creek facility. If this has not
been the case, its not because the many residents of the area
surrounding the facility have not detected odors on many instance5'
but rather because they have not taken it upon themselves to issUe
official complaints. To those of you here who would say you do
not make a point, for why move the odor from one point and locate
it at another point. I would say to you that I am convinced
that with modern technology in design and treatment, chances of
odor from the proposed new facility should be quite rare. In
the South Buffalo Creek facility area, I feel that the frequency
of detection of limited to severe odor is the rule rather than
the exception. I honestly believe that it approaches a 50:50
proposition as compared to odor free conditions. You may ask,
why do you feel that the proposed new wastewater treatment
facility will be essentially free of odor? One reason is the
requirement of the Environmental Protection Agency. Many of you
are undoubtedly familiar with the organization which is Federal
in nature. Even though many of us have been unhappy at times
with decisions of this organization (for example the banning of
chlorinated hydrocarbons for certain agricultural uses), we would
dare say that it seeks to improve the quality of the environment.
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This includes air quality. I feel that the Federal, State and
Local governments will set standards for the proposed new
facility that will cause the design and operation to keep air
quality problems to a minimum in terms of odor. I am certain
that opponents of this plan who are opposed to the proposed
new treatment facility have been in contact with Federal and
State officials to use their influence in opposing the plan.
I am not certain that it serves a useful purpose to turn this
local wastewater treatment plan into a political issue. Rather,
I feel that our action should be based upon a critical analysis
of the possible alternatives and the adoption of a solution
that will have the lesser if not the least impact on the areas
of concern. I think it is one matter to fight the construction
of a facility because we feel that it will be too close to our
neighborhood. And that this, in turn, may possibly affect air
quality or may lead to an increase in the population density in
our area. This is mere speculation and cannot be based on tacts,
since it has never happened. Again I would say that the perceived
odor problem can be handled by design and operation. We all know
that population density within a given area can be controlled by
zoning ordinances. It appears to be an entirely different matter
when residents of an area that has been continually subjected to
sewage treatment odors for years express the desire to have some
relief. Here is not expressed from a perceived or anticipated
belief, but rather from daily or weekly experiences. The quest-
ion arises what about the North Buffalo Creek facility. It is my
understanding that although odors from that wastewater treatment
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facility are sometimes detected by residents and businesses in
the vicinity of it, the frequency of detection is not nearly as
often as that from the South Buffalo Creek facility. In addition*
the population in the immediate vicinity of the North Buffalo
Creek facility is less than that in the immediate vicinity of
South Buffalo Creek's treatment facility. I, like others I am
certain, had assumed that expansion of the North Buffalo Creek
facility would reduce its incidence of offensive odor due to
the waste having more time to be acted upon. I was surprised
to read in the Draft Environmental Impact Statement that no
significant improvement is expected in air quality in the
vicinity of the North Buffalo Creek facility if it is upgraded
to provide tertiary treatment of 16 million gallons per day of
wastewater. I have empathy for the residents in the area of
the North Buffalo Creek facility. It's difficult to endorse a
plan such as this which while upgrading the facility does not
improve air quality unless there are other advantages derived.
Personally I am not convinced that the air quality in the North
Buffalo Creek facility cannot be improved if this is adopted as
a goal at the time the facility is upgraded. I recommend that
the goal be adopted to improve aerial emission in the North
Buffalo Creek Wastewater Treatment Facility as the facility is
upgraded. Finally, there are those here who will have thought
of all possibilities to impede or defeat this plan. Non the
least of which will be comparative costs of Alternative 3 versus
upgrading the existing wastewater treatment facilities. I think
that most of us are cost conscious not necessarily because we
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wish to be, but rather because we have no alternative. I do
not feel that we should let cost be the sole deterrent and
over-rule what is the best plan for all of us in so many ways.
Speaker Mr. -Tames C. Johnson: I am a living witness of the exist-
ing problem at the South Buffalo Creek Treatment Plant. More than
fifteen years have passed while we, as residents, have petitioned
for relief. It was more than five years before we could convince
the City that a problem existed. The City then assured us that
the problem would be cured. Curing consisted of the spraying of
perfume and the purchase of areators. These new devices only pro-
vided new inertia in the spreading of the mixture of perfume and
the fumes from the fermented residue of the plant. I have spent
more than one third of my life under these conditions. At the
time we purchased our home in this community, it was the only
area open to the upper lower income residents who were not
appraised of the location of the plant. According to the zoning,
non-existence of the Fair Housing Act and the availability o£
limited financial resources Blacks were forced to take up their
habitat in this locale. This community soon became the pride of
the City. They, the residents, had the best groomed lawns, the
least amount of crime and the best voting- record of any precinct
in the State of North Carolina. We were proud. As soon as
Spring emerged, the obnoxious odors began to evade our homes,
Settle in our clothing and making us the talk of the City as
the place not to visit. Many residents moved, others were not
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able to do so because they had invested their life savings to
this point and mortgaged any future potential savings for the
next thirty.years. So we had to bear it and hope that the
promised relief would be forthcoming. Over the years we have
seen our hopes for relief dwindle and residents of the Southeast
no longer view the South Buffalo Treatment Plant as a treatment
center, but rather as a distribution center for the disbursements
of foul odors. Therefore, anything short of the total abandon-
ment of the South Buffalo Plant is unacceptable to us. We support
the location of the new Metro System being located at the conflueflcS
of North and South Buffalo Creeks. We believe that this location
would better serve the interest of Metropolitan Greensboro where
we live, earn our livelihood or depend on it for resources and
support. The population of Southeast Greensboro affected by the
plant numbers serve 26,000 persons. An even larger number of
persons nearer the center of the City which includes some of the
oldest most "prestigious" neighborhoods of Blacks in the City.
Southeastern residents represents nearly 19% of the City's entire
population. It represents approximately 12% of the County's
population. The proposed new location of the plant would only
affect around 1,800 residents of the McLeansville area which
represents around .00095% of the population. These persons also
work in the City or rely on it for support. Therefore, we in
Southeastern Greensboro are having a difficult time understanding
the rationale or any agreement in terms of expanding existing
facilities at South Buffalo. Now any decision other than to
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abandon the South Buffalo plan is unacceptable and unjust to
a large segment of Greensboro's population. We recommend the
location of the new site where North and South Buffalo Creeks
join, but can live with alternatives three and four. The Bible
states that "A tree is known by the fruit it bears," let us not
be known by the odors we bear. Let us petition for a decision
from the Board favorable to the wishes of the Southeast quadrant
residents because it is right and just.
Speaker Ms. Eula K. Vereen: I have several concerns to present
to you tonight which disturb most of us because of the odor from
the Metro Sewer System, known as Buffalo Creek. I had guests in
my home on yesterday as each one of them entered the odor seemed
more fowl than ever, even though I had cleaned thoroughly, I
still had to apologize to them for the unpleasantness. Our pro-
perty values have gone down from 1/3 to 1/2 in value because of
this Metro Sewer System. Some of us have our life's earnings
invested in our homes. Our children leave home clean, going to
school, before they get there, they gather a fowl odor, after-
which they are set aside from other children and their friends.
The upkeep on our homes are greater. If we paint them one summer,
the paint turns opposite colors which means there's another paint
bill the following summer which most of us cannot afford. We
cannot eat on the outside, or have cook-outs on our patios be-
cause of the flies and other insects who have swam down in our
yards from Buffalo Creek. I am a nutritionist and I know the
value of good food and good health, but because of the fowl odors
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we are not able to eat at all because at times when the odor is
unbearable, we really don't know what we are eating. Our electric
bill has more than doubled during these Spring and Summer months
because the odor is too fowl to open our doors or our windows.
But yet, our air conditioners are going at full blast. Thus,
our electric .bill sky-rockets to a price we are unable to pay,
easily. On rainy days the creek overflows, sending the debris
in many of our yards. Thus causing fowl odors, flies and insects-
Often we accidentally step in this debris, bringing it into our
homes, then we are in for expensive rug cleaning and expenses
which we cannot afford. Riding in our cars, we find ourselves
with our windows closed even if we don't have air conditioners
in our cars, we just have to "sweat it out" because of the fowl
odor. One of the most important concerns is that of industries*
Industries refuse to come to the City of Greensboro because of
the poor Metro Sewer System. These industries will continue to
go elsewhere unless our sewer system is corrected. This again,
affects our people in the community. Since job opportunities
are not as great for Blacks as they are for Whites, everyone
should have an opportunity to be employed. I highly recommend
that something is done now, immediately, to eliminate the Old
Metro Sewer System and begin working 'on the site of the conflue^c®
of South and North Buffalo Creeks.
Speaker Mr. Dan Fetzer: I represent a group of over 400 conceme^
young businessmen in this community, in the form of the Greensbo1"0
Jaycees. We are concerned about a multitude of situations, but
certainly one of our greatest concerns is the situation we face
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here tonight. It is a situation that has cost the tax payers
literally millions of dollarsj a situation that has caused vital
new industry to pass this area by, taking with it hundred, per-
haps thousands of jobs; a situation that has become a albatross
upon the economic development of our City. And I guess the only
question I have is why---why when study after study has resulted
in the same basic general recommendation, and that being to build
a new wastewater treatment facility on the South Buffalo Creek at
or just south of the convergence of the North and South Buffalo
Creeks—why after all these years has nothing been done! If you
were trying to. piease everybody, forget it. You could build this
plant on the moon and someone would still complain about it! I
believe that all the people of Greensboro are asking is that you
make a decision, and base that decision on the technical inform-
ation and surveys that you have at your disposal. It is time to
end this travesty.
Speaker Mr Hanry T. Rosser: Ladies and Gentlemen, my name is
Henry T. Rosser, and I am an attorney from Raleigh, North Carolina.
I appear here tonight on behalf of the Concerned Citizens of
McLeansville to oppose the site proposed in the Draft Environmental
Impact Statement for the location of the new Greensboro-Guilford
County Wastewater Treatment System. The United States Environment-
al Protection Agency and the North Carolina Department of Natural
and Economic Resources have previously stepped to the forefront
in this matter and retained an independent consultant, the Radian
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29
Corporation, to collect and compile the data necessary for pre-
paration of an environmental impact statement. We have no
quarrel with the work performed by Radian, which we.consider
to be a careful and factual study. We also believe, however,
that the conclusions of EPA set forth in the Draft Environmental
Impact- Statement represent a distortion and subversion of the
objective facts and recommendations of the Radian Corporation.
After reviewing more than 100 possible alternatives, Radian
^selected six as being the most feasible. These six alternatives
were subjected to intense and careful scrutiny and analysis by
the Radian Corporation. Based upon the vast amount of data
collected, Radian concluded from its analysis that all six of
the alternatives were feasible from an engineering and construct-
ion standpoint, but they determined also that there was a very
large disparity in the costs and environmental impact of the
various alternatives. Alternatives 1 and 6 were, by a very wide
margin, the least expensive to construct and were also the most
environmentally acceptable. The third most acceptable alternative,
both from the standpoint of. costs and environmental impact, was
Alternative 2. Alternatives 1 and 6 both provide for upgrading
the existing waste treatment facilities located on North Buffalo
and South Buffalo Creeks. Alternative 2 provides for the upgrad-
ing of the existing North Buffalo facility, abandonment of the
existing South Buffalo facility, and the construction of a new
wastewater treatment plant about 14,000 feet downstream on South
Buffalo Creek from the existing South Buffalo plant. In spite of
the clear superiority of these three alternatives from both a
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30
cost and environmental standpoint, the Draft Environmental
Impact Statement designates Alternative 3 as that for proposed
action. That alternative proposes upgrading the existing North
Buffalo plant, construction of a new plant some 26,000 feet (or
5 miles) downstream on South Buffalo Creek from the old plant,
and the construction of an outfall sewer from the old plant to
the proposed new plant. Alternative 2 was rejected in the Draft
Environmental Impact Statement, however, because the proposed
¦site of the new plant would require the acquisition of a century-
old highly productive family farm. In rejecting Alternative 2
in favor of Alternative 3, EPA has approved an alternative that
is less environmentally acceptable and which will cost the tax-
payers an estimated $1,680,000 more to construct. It is very
difficult to understand the rationale behind this decision since
the farm in question lies within three miles of the City of
Greensboro in an area which the Draft Environmental Impact State-
ment designates as one in transition from rural, agricultural
uses to industrial, commercial, and residential uses. What makes
EPA's decision even more difficult to understand is the fact that
the Environmental Impact Statement recognizes that the sewer out-
fall which will be built across the farm under Alternative 3 will-
have the effect of further accelerating the change in use of this
farm from agricultural purposes to industrial, commercial, or
residential. Further comparison of the six alternatives indicates
that Alternatives 1 and 6 are more environmentally acceptable and
far less costly than either Alternative 2 or Alternative 3. In
fact, the estimated costs of construction set forth in the Draft
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Environmental Impact Statement reveal that the construction of
either Alternative 1 or Alternative 6 will be approximately $12
million less than the construction of Alternative 3 and will be
about $10 million less than the construction of Alternative 2.
In spite of the fact that all of the available facts and compar1'
sons show that Alternatives 1 and 6 are the most cost-effective
and least environmentally harmful, the Administrator of EPA
Region IV in Atlanta determined that the continued existence
of the South Buffalo plant was not socially acceptable in any
alternative because of the history of odor problems with that
plant. This determination by the Regional Administrator appeal"5
to be totally subjective, because there are no objective facts
or data in the Draft Environmental Impact Statement which will
support that decision. For this reason we contend that the
rejection of Alternatives 1 and 6 by the Regional Administrator
is arbitrary, capricious, and totally unsupportable. The Impact
Statement contains no findings as to the frequency or extent of
past occurrences of the odor problem; contains no findings as
the frequency, extent, or nature of any future odor problem if
the South Buffalo plant is upgraded; and contains nothing con-
cerning the environmental or economic impact of the odor prob-le®
as it now exists or with regard to comparisons of the relative
anticipated environmental and economic impacts of Alternatives
1, 3 and 6. What the Impact Statement does reveal is that EPA
does not know how much of the odor emanating from South Buffalo
Creek results from the improperly treated discharge of the South
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32
Buffalo plant and how much is attributable to numerous other
point and non-point sources of pollution being -discharged
into the Creek. In other words, there is no guarantee that
if the South Buffalo plant is demolished, there will be any
substantial reduction of odors. The Impact Statement also
reveals that under both Alternative 1 and Alternative 6, the
upgrading of the existing plants at North Buffalo and South
Buffalo will permit them to properly treat the quantity of
wastes being discharged to them and will also provide the
appropriate treatment for the quality of the wastes they
receive. The Impact Statement further recommends odor control
technology that may be employed at both plants. The results
of this upgrading would be a substantial reduction in the odors
produced by these plants. One noted authority has advised both-
EPA and the North Carolina Department of Natural and Economic
Resources that the odor problem is primarily the result of the
lack of dissolved oxygen in the streams. It is his expert
opinion that the use of available technology to increase the
amount of the dissolved oxygen in these streams'will substantially
reduce, if not entirely eliminate, the odor problems which are
being experienced. The only material support for the Regional
Administrator's decision to reject Alternatives 1 and 6 appears
in a memorandum dated July 12, 1977, appended at the end of the
Technical Reference Document, from Matthew J. Robbins, Regional
Director, Office of Civil Rights and Urban Affairs, to John
Hagan, which states that Mr. Robbins finds that upgrading the
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33
existing South Buffalo plant will be in violation of the
Civil Rights Act of 1964 in that Federal financial assistance
will be used to support an existing discriminatory.situation,
will perpetuate discrimination, and will cause direct conflict
with Title VI of the Civil Rights Act. Mr. Robbins appears to
feel that there is and has been unlawful discrimination in the
City of Greensboro with regard to availability of housing.
Assuming, for sake of argument, that this is true, Mr. Robbins
.totally fails to explain how"upgrading the South Buffalo plant
to properly treat sewage and reduce odors constitutes perpetuat-
ing housing discrimination or how elimination of the South
Buffalo plant would make adequate housing available to the
black residents of the City of Greensboro. Since Mr. Robbins ccfl
elusions appear to be illogical and irrational in the extreme,
and since there are no factual data in the Impact Statement to
support those conclusions, we contend that his assertion that
Federal financial assistance to upgrade the South Buffalo plant
would be in violation of the Civil Rights Act, is arbitrary,
capricious, and totally without supporting facts. Since the
Draft Environmental Impact Statement candidly reveals that any
sewage treatment plant, whether new or old, will produce offensive
odors from time to time, it is difficult to understand why the
Regional Administrator did not find the proposals to upgrade
the North Buffalo plant and to build a new plant to be socially ufl'
acceptable, or why Mr. Robbins did not find upgrading the North
Buffalo plant to be in violation of the Civil Rights Act. The
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Impact Statement also reveals that the greater the length of a
sewer line, the greater the chance that sewage will become
septic and.will release obnoxious odors at the plant outfall 01.
at the intermittant manholes along its length. Since the sewer
outfall proposed to be constructed under Alternative 3 from the
existing South Buffalo plant to the proposed new plant will be
five miles long, it would appear that EPA is recommending an
alternative which will have a good chance of smelling up at
"least an additional five miles of the County. It should be
pointed out that the Impact Statement contains no studies
relative to the social and economic impact that construction
of the five mile sewer and the new plant will have on the areas
of Guilford County in -which they are to be located. Common sense
and experience dictate that the impact will be adverse and th~t
property values will decline throughout the area impacted by the
new construction. We submit that this effect must be taken into
consideration before the overall social and economic impact of
the proposed action can be properly evaluated, and that EPA
should conduct studies to this end. Basic equity and fair play
dictate that those who have created and are responsible for a
problem should be the ones who bear the brunt of correcting it.
Since the residents of the City of Greensboro generate the sew-
age which has created the present problem, and since the techno-
logy and methodology to correct that problem where it' exists are
available, it is not only right, fitting, and proper that Greens-
boro should be not only allowed, but required, to employ the
alternative that will result in the least economic and environ-
jjjqn"t31 detriment to the other citizens of this State and Nation.
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It is totally unfair to not only allow, but to require, the
City of Greensboro to flush its problems five miles out into
the County to the specific detriment of citizens who are not
residents of Greensboro and to the general detriment of us all.
For the reasons that we have enumerated here, we submit that
the selection of Alternative 3 is based upon a decision which
is arbitrary, capricious, and without support in fact or logic.
We also submit that not only basic fairness, equity, and common
sense, but also law and regulation, mandate that the Regional
Administrator's decision be set aside and that Alternative 1
or Alternative 6 be designated the plan for further action.
Thank you.
Speaker Ms. Brenda Hodge: My name is Brenda Hodge... I was among'
the hundreds of Warnersville residents in Greensboro who was
forced, by a redevelopment commission, to relocate in the early
1960's. At that time "colored property" was limited in the area.
My family and I were shown only those lots in the southeastern
section of the City. We chose to build on Dans Road. We were
unaware, then, that the South Buffalo Creek Treatment Plant was
located only a block away from our property. As the neighbor-
hood grew, the odors from the plant worsened. Foul scents began
to fill the air and lessen our chances of enjoying meal times,
play times, and rest periods. We knew by now that these repulsive
odors were coming from one of the City's major sewage plants.
Thus, we were told that the place for concerned citizens to take
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36
their grievances was to the City Council. Continuously, over
the years we have gone to the City Council Members, to the
Mayor, and to the City Managers to find redress to.our problems.
Now we come again at a time when the odors and the mosquitos,
nats, etc., in Southeast Greensboro are a disgrace to the City
of Greensboro. I question the continued existence of the sew-
age treatment plant in an area where some 25,000 Black citizens
live. Moreover, to even have considered the expansion of this
¦plant on that particular site is just another indication to me
that this City and this State are being run by some white people
who just .don't care. We want you, the officials who will make
the final decision, to clearly understand that as far as the
people in our community are concerned, your energies should have
been spent in locating another site for the Metro Sewage rather
than in expanding the present site. Your energies could have
been spent by enforcing the health code that you already have.
If you'd enforce that code, then the Buffalo Creek would not
plague the lives of so many Blacks today. We don't need the EPA
or any other agency to tell us that the scent from the Buffalo
Creek is hazardous to our health... we know that it is. We
didn't come to beg for a change, and we didn't come with "hat-
in hand" we've done that too much already*. We've come because
we're sick and tired of the City, the State and other representat-
ives "bumfuzzling" around and skirting over the Buffalo Creek
issue. We're tired of signing petitions, calling on council
members, attending meetings, and talking with the Mayor. And,
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37
we're tired o£ reading this and that in the newspaper. We're
tired from years long past of seeing the City Planning Commissi*"15
and Urban Renewal Commissions fail to speak to the needs of
Blacks in a meaningful way. It's past time for you people who
are in leadership positions to wake up to what's happening in
our Black community. You would be wise to listen because we
are the people you have pushed across those railroad tracks
out of urban renewal areas. Lean back in those chairs, Mr. City
Manager, Mr. Mayor, and Mr. Environmental Protection Man and
Mr. City Councilman, and listen to what we are talking about.
It's time for you to do something to benefit us. We want reli®^
from those odors... NOW! We are tired, we are frustrated and i11
a sense, we feel betrayed and when people get tired and frustrat^
and feel betrayed, they do things that they wouldn't ordinarily
do.
Speaker Mr. John B. Ervin: GCA § NAACP are making this stateme^
on behalf of the approximately 41,500 Blacks living in the North
and South Buffalo Creek sub basins.' It is- our position that
environmental considerations are important only because environ-
mental factors affect the quality of life of human beings living
within the environment. For that reason we feel that one of th®
most important considerations is the number of people who will be
directly affected by the placement of the wastewater treatment
plant. There are at least 25,000 people living within 2 miles
of the South Buffalo Plant, all of whom have been adversely
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38
under normal atmospheric conditions due to the conditions under
which the plant has been operated. The wastewater treatment
plant should be placed at the confluence of the North and South
Buffalo Creeks because: Population. At the McLeansville-con-
fluence site only 1,800 people live within two miles of the pro-
posed site. While almost 26,000 people live within two miles of'
the existing South Buffalo Plant. Three Thousand Two Hundred
(3,200) of these people live within 3,000 feet of the existing
South Buffalo Treatment Plant. The population at the confluence
of North and South Buffalo is only expected to increase 49 7
people by the year 2,000. The population at the E.I.S. site is
expected to increase to 2,000 people per square mile by the year
2,000. (E.I.S. P.II 100). Racial Impact. The Black population
of Greensboro is concentrated within two miles of the existing
North and South Buffalo Plants. Because of the refusal to sell
to Blacks in other parts of the City, Blacks desiring to purchase
homes, could only buy in the areas of South Buffalo Creek until
the mid 1960 when the area near the North Buffalo Treatment Plant
was opened to Blacks. It was not until long after the effective
date of the Fair Housing Act in 1970, that Blacks were free to
buy homes in other areas. Many of the residents living near
the plants cannot sell out and move because prospective buyers
are unwilling to buy because of their knowledge of the odor pro-
blem in the areas. Schools. There are six schools within a mile
and a half of the existing South Buffalo site. Four of these
schools are elementary schools. One elementary school is located
within 3,000 feet of the existing site. Students and teachers
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39
from all over the City are therefore affected by the odors
and emissions from the existing site. Advantages to McLeans-
ville Residents. Guilford County soil is* not well suited to
use of septic tanks and some areas are already over saturated
with septic tanks (E.I.S. P.II 3 § II 30). Possibly well be-
fore the year 2,000 County residents including McLeansville
residents may be expected to experience well water contaminat-
ion from septic tanks in the absence of a central sewage system.
Also, because of the low permeability of the soil, sewage may
be expected to seap to the surface in existing septic tank
systems causing odors and disease. The confluence site is down-
stream from McLeansville and would provide gravity flow access
to the treatment plant. The South Buffalo, North Buffalo and
the E.I.S. sites are upstream from McLeansville and would require
expensive construction, replacement, maintenance, fuel cost and
pumping stations. Advantages to East Guilford County. There
have been numerous complaints from residents of east Guilford
County concerning the rapid growth and land value increases in
western Guilford County while little growth and land value
increases have occurred in east Guilford County. One of the
important impediments to growth in east Guilford is the lack of-
sewage disposal facilities. West Guilford County is upstream
from the South Buffalo Plant and gravity flow to the plant is
economical. East Guilford County is downstream from both the
North and South Buffalo plants and therefore not easily accessible
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If the plant is built at the confluence site, vast new areas
of East Guilford County will be .easily developed, clearing the
way for new residential areas as well as industrial areas.
Such development will create new jobs and improved living
standards for all of Guilford County as well as increase pro-
perty values in east Guilford. If the plant is built at the
E.I.S. site, an important part of Guilford County (McLeansville)
will still experience slow growth due to the lack of economical
sewage disposal facilities since McLeansville will be downstream
from that site. Summary. The Black residents of South East
Greensboro have been plagued with the offensive odors of the
South Buffalo Plant for a quarter of a century. It is unfair
for the residents of Southeast Greensboro to shoulder this burden
alone. Now is the time to build a new plant at the confluence
and give the residents of Southeast Greensboro relief, allow
Greensboro to expand east, and allow east Guilford County to
grow and prosper.
Speaker Mr. A. W. Ray, Jr.; Members of the Committee, distin-
guished public officials, and friends. I'm A. W. Ray of 2301
East Florida Street, which.is about two blocks from the South
Buffalo Plant. Others haye been yery eloquent in describing
the conditions in the area. I cannot find words to fully express
my feelings about it, so if you will excuse me, I will say that
it "Just Plain Stinks." Much has been said about the cost of
relocating the plant, but the thing that concerns me is the health
factor. Being an asthmatic sufferer, I find it hard to breath at
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41
times. When Buffalo is raging, my problems are compounded.
Another interesting point is that it has been said that about
751 of the people that live in McLeansville work in Greensboro.
Therefore, they too add to our problem. I trust that the
Committee will see fit to relocate the plant so that we can go
on to cleaner air and healthier lives.
Speaker Ms. Gladys Graves: As an educator in the public schools
of Guilford County, as well as a resident of Southeast Greensbol"0'
I'd like to say that when the thrust for environmental educatio11
began, our school curriculum began to reflect this need. But,
how can we justify teaching our children about their role in
helping to preserve clean air, clean water, plant life, etc.
when thsy look to the adults and the system as they continue to-
perpetuate a facility such as that which now exists at North
and especially the South Buffalo Sewage Treatment Centers. Si»ce
I have seen the alternatives presented in the E.I.S. study, Sit®
#3 offers absolutely no advantage over the site at the intersect'
ion of North and South Buffalo Creeks (Alternative #4) except
that it was chosen for political reasons. As most decisions
generally affecting human needs take on a political tone, I
stand before you tonight asking you to look beyond politics and
look instead to the needs of 26,000 Guilford County residents
who have had to smell the odorous fumes of Buffalo Creek for as
many years as the system has seen fit to direct our living locat*
ions. As I close, I'll tell you something that is not arbitrary'
not capricious, and can be supported by facts and that is
Buffalo Creek STINKS!
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Speaker Mr. Charles E. Melvin, Jr..* I'm Charles £. Melvin, Jr.,
President-Elect of the Greensboro Chamber of Commerce. The
Chamber has been closely involved with the effort to construct
a Metro Wastewater Treatment Plant since it was first proposed
in 1971. There has been substantial agreement concerning the
need for this plant since it was first proposed. Only the
degree of need has changed as the years have gone by. The streng-
thening and diversification of our local economy is one of the
.highest priorities in our Chamber program. To accomplish this,
we must be able to attract quality industry to our community and
this requires ample sewage treatment capacity. In recent years
the capacity simply has not been available resulting in the
restriction of our economic growth possibilities. Earlier this
year, the Chamber made a very careful analysis of the Greensboro
economy's recovery from the recent national recession compared
to that of other major North Carolina cities. We were distressed
to learn that our local economy is substantially lagging in its
recovery when compared to Wins ton-Salem, Raleigh and Charlotte.
Current economic data continues to emphasize the large number
of our citizens who are still unemployed in the manufacturing
job categories. It is vital that we replace these lot jobs. We
urge you to complete this study process and approve the construct-
ion of this plant so that we might again be able to compete for
the full-range of quality industries. We have carefully studied
the information developed by the Radian Corporation. When con-
sidering the long-term needs of our community, we still feel the
greatest advantages are offered at the Buffalo confluence locat-
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43
ion. However, it appears that most of the community's object-
ives can also be met at the recommended site jcrst downstream
from U. S. 70. We believe two of these objectives to be most
important. The site must be selected where adequate land can
be acquired to provide for future treatment expansion while
maintaining a sufficient buffer to protect the adjacent pro-
perties. Secondly, the site should be located so that it will
open up sewer service on our eastern side where development has
-been stymied for decades. Neither of these key objectives
could be met at the existing South Buffalo Treatment Plant site-
Considering our critical treatment capacity problem, we believe
the single most important concern is that we choose an accept-
able site so that we might move this project forward. We were
extremely encouraged by the statement made by Tom Rosser,
Attorney for the Concerned Citizens of McLeansville, at the
November 1976 public hearing when he indicated that the McLean*'
ville group would abide by the outcome of this environmental
impact statement. We now are disappointed to hear him indicate
at this meeting that there has been a change of mind in this
regard. We find ourselves tonight in the situation where we
do not fully agree with the consultant's findings and recommended
site. We do, however, accept this environmental impact statement
as an objective effort based solely on facts obtained over an
eight month period. Again, believing that it is most important
that we move this project forward, we urge that the community
get behind this decision and expedite the construction process-
Thank you.
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(NOTE: To-the-Record - Mr. Bill Anderson was registered to
speak at this time, however, he did not make an oral present-
ation but submitted his written statement for the record as
follows:) As a tax paying citizen of this Country, I think it
is way past time for all levels of government to pay particular
attention to all tax money being spent. As an example, the
Metro site which was last picked for the construction site is a
waste of our tax money. This site will be outdated in less
than twenty years and this waste of land and money will have to
be done over. As a practical solution to Greensboro's needs
now and in the future, I think the two.present sites should be
updated and expanded. The citizens of McLeansville, both black
and white, did not cause this problem. It has been a disgrace
to our community for over forty years as the City of Greensboro
did not try to correct this problem. They still think you can
treat sewage with concrete and steel. Greensboro is facing, a
water shortage and this can be partially solved by reprocessing.
It is stupid to put their sewage eight miles out of town and
then have to pump it back for their use. Since the citizens
who live around the South Buffalo Treatment plant are most vocal
in their complaints, I suggest that the City of Greensboro buy
back their homes so they may settle elsewhere. The City has for
years received taxes from these people. It is their responsibili
to treat their citizens in a fair and decent manner. I want to
see the two present plants updated and improved. Let us save
eight to twelve million dollars by this action. If the plant can
be built so as to not smell in McLeansville, then it can be built
so as not to smell at the present sites.
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45
Speaker Mrs. Edna Isley; In regards to that sewer plant that
Greensboro wants to put down here is not in McLeansville, it
is on the forks of South and North Buffalo Creek. Right on
my best crop land. I am not in favor of Greensboro taking any
farm land to put a sewer plant on, when there is other places
and iess costly. I still think that they could upgrade what
they already have. I understand that there is plenty of land
close by to expand their present plant. I know what those
people are going through with up there. But, we down here on
Buffalo have smelt that awful odor for 25 or 30 years or more
and it still stinks right here under our nose. If they can
build plants in other places without odor, why can't Greensboro
do something about what they already have? I have just got
35 acres of open land that we have been farming for 53 years.
We have never worked at public work,we have always farmed. We
have raised four sons and three of them still lives on the
plantation. With a small lot if they take my farm land, how
do they think my children feels about it? They would like a
little expansion too. I am a widow, 72 years old, and still
depend on my farm for a living. This land has been in our
family for 6 generations and I don't want to see it put under
a sewer plant, dumping ground or a part either. We just don't
want it right in my front door, please. It seems.like Greens-
boro officials have got a spite at us down here. They have
never come to us asking about our land. They act like it all
belong to them. I feel like it belong to us, we have paid taxes
on it and kept it.for our living purpose. I can't see what they
want with 400 acres.
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I am here because I will refuse to dodge my responsibility to be a part
of the future. I am that future!
I would hate the thought of inviting the heads of state to my presential
palace here in Greensboro to talk about improvements in their own countries
then to try to explain the "honey pot" we cannot seem to be able to eliminate.
On a more serious note, the question that we should address ourselves with
is not a technological one, because the technological machinery that we will be
constructing is one of highest efficiency in the world. So the question is not
of technological efficiency, but of social feasibility and social desirability..
In the course of my investigation it was evident to me that the site that
would and have suffered the greatest amount of social impact is the South Buf-
falo Creek site. (Alternatives 1 and 6)
You are talking about a site that will affect 25,000 or more people. You
are talking about a site that has no potential for expanding. You are talking
about a site that cannot provide an adequate buffer zone.
You are talking about taking our technologically efficient machine and
Placing it in a socially insufficient area.
I would hope that you who carry the responsibility of making the final
decision will do so with expediency. Because of the slowness of your decision,
Greenboro citizens have lost favorable consideration by major industries to use
Greensboro as its place of business. This is turn has supplemented Greenboro's
^employment rate, and in the long run will stifle growth in one of America's
"¦ost desirable cities.
So your concern with the quality of human life can be as greatly affected
by your slowness of decision as well as the decision itself.
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(NOTE: To-the-record - The verbation transcript from the tape
recording begins again at this point.)
Moderator: .... Thank you. Would somebody see about changing
this tape so we can begin again? Thank you. (Pause). Mr. Fox.
Mr. Fox. Thank you.
Speaker Mr. Hermon F. Fox: Ah- I'm Hermon Fox, I live at 1714
Eastwood Avenue. I'm going to read a joint statement of the
NAACP and the Greensboro Citizens Association, and if I do not
finish this statement, Attorney David Dansby will finish it,
who comes after me. The Greensboro Citizens Association and the
NAACP are making this statement on behalf of the approximately
forty-one thousand five hundred (41,500) blacks living in the
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North and South Buffalo Creek sub-basins. It is our position
that environmental considerations are important only because
environmental factors affect the quality of life of.human beings
living within the environment# For that reason we feel that one
of the most important considerations in the number... is the
numbe-r of people who will be directly affected by the placement
of the waste treatment plant. There are at least twenty-five
thousand (25,000) people living within two (2) miles of the
South Buffalo Plant, all of whom have been adversely affected
under normal atmospheric conditions due to the conditions under
which the plant has been operated. The wastewater treatment
plant should be placed at the Confluence of the North and South
Buffalo Creeks because; Population. At the iMcLeansville Con-
fluence Site only eighteen (1,500) hundred people live within
two (2) miles of the proposed site. While almost twenty-six
thousand (26,000) people live within two (2) miles of the exist-
ing South Buffalo Plant. Three thousand two hundred (3,200) of
these people live within three thousand (3,000) feet of the
existing South Buffalo Treatment Plant. The population at the
Confluence of North and South Buffalo is only expected to
increase four hundred and ninety-seven (497) people by the
Year 2000. The population at the EIS site xs expected to
increase to two thousand (2,000) people per square mile by
the Year 2000. Racial Impact. The black population of Greens-
boro is concentrated within two (2) miles of the existing North
and South Buffalo Plants. Because of the refusal to sell to
blacks in other parts of the City, blacks desiring to purchase
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homes could only buy in the areas of South Buffalo Creek until
the mid-1960s when the area near the North Buffalo Treatment
Plant was opened to blacks. It was not until long after the
effective date of the Fair Housing Act in 1970, that blacks were
free to buy homes in other areas. Many of the residents living
near"the plants cannot sell out and move because prospective
buyers are unwilling to buy because of their knowledge of the
odor problem in the areas. There are six (6) schools within a
mile and a half of the existing South Buffalo site. Four (4)
of these schools are elementary schools. One elementary school
is located within three thousand (3,000) feet of the existing
site. Students and teachers from all over the City are there-
fore affected by the odors and emissions from the existing site.
Advantages to the McLeansville Residents. Guilford County soil
is not well suited to use of septic tanks and some areas are
already over saturated with septic tanks. This is supported by
the EIS Study. Possibly well before the Year 2000 county
residents, including McLeansville residents, may be expected to
experience well-water contamination from septic tanks in the
absence of a central sewage system. Also, because of the low
permeability of the soil, sewage may be expected to seep to the
surface in existing septic tank systems causing odors and disease*
The Confluence site is downstream from McLeansville and will pro-
vide gravity flow access to the treatment plant. The South
Buffalo, North Buffalo and the EIS sites are upstream from
McLeansville and would require expensive construction, replace-
ment, maintenance, fuel cost and pumping stations. Advantages
to East Guilford County. There have been numerous compliants
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from residents of East Guilford County concerning... concerning
the rapid growth and land value .increases in Western Guilford
County, while low growth and land value increases have occurred
in East Guilford County. One of the important impediments to
growth in East Guilford is the lack of sewage disposal facilities.
West Guilford County is upstream from the South Buffalo Plant
and gravity flow to the plant is economical. East Guilford County
is downstream from both the North and South Buffalo Plants and
therefore not easily accessible If the plant is built at the
Confluence site, vast new areas of East Guilford County will be
easily developed, clearing the way for new residential areas as
well as industrial areas. Such development will create new jobs
and improved living standards for all of Guilford County, as well
as increase properly values in East Guilford. Ij. the plant is
built at the EIS site, an important part of Guilford County,
McLeansville, will still experience slow growth due to the lack
of economical sewage disposal facilities, since McLeansville will
be downstream from that site. I leave only the summary for
Attorney Dansby.
Moderator: Thank you. (Applause).
Speaker Mr. David M. Dansby, Jr.: I'd like to say I appreciate
those remarks by Mr. Fox, and I'd like to keep my comments, brief.
I would like to say that ah- to the members of the panel that ah-
the purpose of environmental impact statement to me is not to
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determine, solely, the affect of a proposed course of action
on certain natural parts of our environment such as lakes,
streams, wildlife and vegetation. It would seem to. me that a
good portion of the impact statement was concerned about the
effect of the proposed course of action on these things. The
effect... the importance of an environmental impact statment
and the importance of considering the environment in the first
place is the effect of the environment on people. And, what we're
talking about when we're talking about the people that live in
South Greensboro is some twenty-six thousand (26,000] people.
But we're not only talking and we're not only concerned about
those twenty-six thousand (26,000) people that live in Southeast
Greensboro, we're also concerned about those people that also
live in the area that's effected by the North of Buffalo Creek
ah- Treatment Facility. And there's some concern even in this
last alternative ah- that's proposed alternative four (4) about
upgrading North Buffalo... the North Buffalo Treatment Facility.
I wouldn't have a quarrel with that if we, in fact, did upgrade
that facility. But, when we say upgrade we're engaging in some...
in ah- exercise and summatics. What we're talking about is
enlarging, ratheT than upgrading. Now we can deal with some up- "
grading, but when you start talking about enlarging the plant
you're talking about large numbers of people, mostly black people,
that are going to be effected by that plant. And, I think that ah
even though nothing has been said about it, that the people in the
Northeast part of Greensboro, and I live in Southeast Greensboro,
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are entitled to some relief. In terms of the ah- proposed
-proposal to upgrade South Buffalo Creek, I'd like to point out
that ah- and reiterate what some of the previous speakers have
said, that the black people that are living there in Southeast
Greensboro are living there not because they chose to. I'm sure
that-if you go back through your Tecords and if you look at some
of the testimony that was taken in the previous Hearing ah- a
lot of people... and you might hear some speakers say later on
that the people in South Greensboro... Southeast Greensboro ah-
shouldn't even be complaining because they knew the plant was
there and they moved there. I'd like to reiterate that we moved
there simply because that was the only place we could go. That
was because of the segregated housing factors that were existing
in Greensboro at that time. The people in Northeast Greensboro
are still suffering from these segregated housing ah- facilities.
And the best course of action would be to eliminate both the
existing plants in North and South Buffalo and build a plant large
enough down there at the Confluence site to accommodate growth,
not only for twenty (20),years, because in twenty years we're not...
we're still going to have a sewage problem. And it's very short-
sighted to say that we're going to get something that's going to
last us just ah- twenty (20) years, but we've got to be concerned
about these kids that's going to be coming up ah- will be coming
into adulthood in the Year 2000 and the years afterwards. I'd
also like to point out that if we choose or if the course of action
is chosen to upgrade the existing South Buffalo Plant not only are
the people in Southeast Greensboro going to suffer. Mr. Fox has
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indicated that there are about six (6) schools in that area. Ah"
that's the (this name was indistinguishable)
School, the (this name was indistinguishable)
School, the Lincoln School and the Dudley High School which are
all within five thousand (5,000) feet or so of that existing
plant. Now, if it's upgraded to or enlarged to twice the size,
we can expect that people twice as far are going to be suffering
from the ill-effects of that plant. And ah- school kids from all
over the community are coming to Southeast Greensboro to go to sch°0^
I think we should certainly take that into consideration. So ah-
in summary, I think that what we should take into consideration
is not lakes, streams, trees, but we should take into considerate011
the very important and vital human factor that ah- is going to be
effected by any course of action we take. And I'd also like to
that even though some of the representatives from the McLeansville
area ah- have ah- talked about the best course... said the best
course of action would be to enlarge South Buffalo Creek, I'd li^8
to point out that in the Environmental Impact Statement on page3
three (3) and thirty (30) there is considerable discussion about
the nature of the soil in Guilford County. It says that this soil
has low permeability, and what that means is that when people- have
or use insanitary septic tanks that this water will not absorb that
sewage. Well, it's got to go somewhere and if it doesn't go down
it's going to gum up, which means that you're going to have some
considerable problems out there in McLeansville, and I want those
folks to be aware of that, and I certainly would like to see the
Environmental Protection Agency take that into consideration. NoW>
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if the plant is placed at the confluence which is downhill, the
Buffalo Creek,., the North and South Buffalo Creek is the best
example of gravity flow, because water will flow downhill. And,
if the people in McLeansville are concerned about their .future
I think that some consideration should be given to the type of
facility that they can tap on to at some later date. Because in
the Year 2000, I'm sure you're going to go and look for some of
your leaders and some of these people who... who come in here
tonight and made representations ah- that ah- that some site
other than the confluence site or the Ciba Geigy Site will be
in the interest of the people in McLeansville. Now, I think
that ah- it's incumbent upon the Agency to take that into con-
sideration. Thank you. .
Moderator: Thank you. (Applause). Kerns. Kerns. Lillian Harley,
Miss Debra Alston and Robert Elzy. Mr. Kerns.
Speaker Mr. Dan Kerns: I'm Dan Kerns McLeansville, and I
live on the banks of the Buffalo Creek. Some concerned citizens
of McLeansville have helped me in raising...in getting a petition
of over one thousand (1,000) names. This petition was collected
on a personal... many of these names were collected on a person-
to-person basis. They were ah- informed of the situation and all
of them realize that the only decision that is economically feasi-
ble and environmentally sound for a new, modern site is at the
existing South Buffalo Plant. I would like to present this petition
to this Board, now. (Applause).
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Moderator: Miss Harley..
Speaker Ms. Lillian M. Harley: Madam Chairman, members of the
panel, friends, Mayor, and everybody, I'm not going to stand here
three (3) minutes or five (5) minutes. I just have a few state-
ments I'd like to make. But my first statement is... I would
like to ask the panel if you all have had the opportunity to get
a whift of Buffalo Creek?
Moderator: Yes we have. (Applause).
Speaker Ms. L. M. Harley: Well, I'm sure all these statements
that people have made tonight you can go along with what they're
saying.
Moderator: Yes Mam.
Speaker Ms. L. M. Harley: I ah- know McLeansville, I feel like
those residents have an opportunity and should speak for themselves*
But, Buffalo Creek's been down there about fifty (50) years, and ah*
I was chastised for saying last Sunday that I've smelled it for
forty-one (41) years and I think it's time for something to be done*
Relocate it, don't expand it. It's overflowing, now. And I think
that you all should find, in your own meetings and whatever ah- to
move it somewhere else. Because I think it's been down there on the
southside long enough. (Applause).
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Moderator: Thank you. Miss Alston.
Speaker Mr. Robert Elzy: Ah- I'm Robert Elzy of 2118 Veal Place.
1 live not far from this Buffalo Creek and ah- I in very upset.
Now, I'm not saying that we're going to move this plant out of
our doorsteps and put it in somebody else's. But I would say,
move it. Pick it up and move it. Now, as the lady just said,
now I've been smelling it tor twenty (20) years, myself, and ah-
for the last three (3) years I have moved closer to it because I
didn't have no where else to move. And, I think that ah- in fact
I was listening to a lady not long ago in her speech about the
land. Now, we have plenty of land in this County and which I
have information, that xe could put this plant other than where
it is. But it's so many people they have the land and the don't
want it there. Now, I believe... I'm not being prejudice, if I
Had land and if the City wanted it, if the County wanted it, if
the State wanted it they wouldn't do but one thing, and that's
condemn it. And, I wouldn't have no alternative. I couldn't do
a thing about it. (Applause). So, I'm going to make a long story
short, in other words, the people that we have put in office I
want to remind them, 'course I hope some of them are here tonight,
to help us move that plant. Now you know it's election time coming
up again. (Applause). 'Course I... I have talked with ah- some
of the politicians and they agreed with me. But, they haven't
seemed to do anything about it. But, let us do something about it
in the next election. Thank you. (Applause).
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Moderator: Thank you. Miss Debra Alston, then Sara... Miss Sat*
Newsome, then Mr. and Mrs. Julius Alston and then Jim Rosenberg-
Miss Alston... Debra Alston. (Pause). Sara Newsome.
Speaker Ms. Sara Newsome: Madam Chairman, distinguished panel
and Guilford County citizens my name is Sara Newsome, I'm a life'
long resident of McLeansville and I do live on the banks of the
South Buffalo Creek. We want it known that we who live downstream
of the South Buffalo Plant have suffered from the plant, also.
odor problems have not been confiru d just to the people who live
around the plant, but we have smelled this creek for at least
thirty (30) years. In the late 1960s the stream at ah- U. S. 70>
which is in the County/ was declared a health hazard by Dr. Sara
Marr (this name may be spelled incorrectly) of the Guilford County
Health Department. The odors turned the paint on our homes blackf
it peeled the paint from one of our churches, our property has
been devalued due to the stinch from the creek. We believe that
it's long past time for this problem to be corrected within the
City. Thank you. (Applause).
Moderator: Thank you. Julius Alston... Julius Alston. Jim Ro"se&
berg, ana arter Mr. Rosenberg, Pearlie Alston.
Speaker Mr. Jim Rosenberg: Madam Chairman, I am Jim Rosenberg
representing the Greensboro Youth Council. You will find a written
statement of our views, I will not make my remarks long. On behalf
of the Greensboro Youth Council I would like to address the membe*5
of the EPA concerning the youth point of view on the Metro Sewage
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Plant. There has been no youth point of view presented so far,
so I'd like to feel that this is an issue, it should be said, now.
GYC is Greensboro's only city-wide youth organization and we repre-
sent over seven thousand (7,000) high school youth age students.
Please do not dismiss us as merely kids, for we are not. The
Youth Council consist of a hundred and forty (140) members selected
by their student body, all of whom are concerned leaders. We take
the time and effort to supply Greensboro's youth point of view as
we feel it is crucial to matters such as this. We realize that
twenty (20) years from now, it will be us who are directly affected
by the site of this plant. We will be the adults at that time-,
and we will have to face these problems. Therefore, at a recent
meeting of the Council we addressed ourselves to this issue. Each
proposed site was discussed, debated and eventually voted on. Tha
Youth Council, representing Greensboro's youth voted to endorse
the confluence site of North and South Buffalo Creek. This is our
formal endorsement because of population effected, future expansion
and environmental impact we chose this particular location. But,
most important is that the action take place, soon. It should not
be prolonged until it is we who actually decide the issue. It
should be decided on now and soon. The contra... the confluence
site on North and South Buffalo Creek we' feel affords the best
location, possible, and we feel it should be done, now. We are
grateful for this opportunity to be heard, and hopeful-that our
views will be taken into serious consideration. GYC realize the
importance of the metro issue and also the controversy surround-
ing it. We feel that we have no regional or personal biases
that would discredit out recommendations , and we feel they were
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made in the best interest of all those involved in all areas.
As the Mayor mentioned, Greensboro is an unusual community. We
are proud of our progress, and as youth looking forward we are
hopeful for the future. Thank you.
Moderator: Thank you. (Applause). Pearlie... Pearlie Alston,
S. T. Hoffman, Jon Wimbish, W. A. Ward. Miss Alston. (Pause).
S. T. Hoffman. Mr. S. T. Hoffman, Jon Wimbish... Mr. Hoffman?
Speaker Mr. S.T. Hoffman: Yes.
Moderator: Okay.
Speaker Mr. S. T. Hoffman: Madam Chairman and gentlemen, my name
is S. T. Hoffman and I represent the McLeansville Community Council
on the Citizens Advisoiy Committee during the ah- environmental
. t
impact study. Ah- to begin with, I'd like to respond to Mr. Melvi11
remarks about Mr. Rosser's statement, because at the last public
hearing ah- Mayor • (this name was indistinguishable)
proclaimed at the end of his ah- annual eloquent, political speech
that if you people will tell us where to locate the Metro Plant
we will bargain or comply with that decision. Well, a decision was
reached and Mayor Melvin caught the first plane to Atlanta, not to
comply as stated but to apply pressure to change the decision that
was based on the data from the Environmental Impact Study. The
site location was changed, and the basis for that decision, as we
contend, was political. Now, there are two (2) points or issues
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that I would like to provoke pursuit on, the first ah- on who
would benefit from locating the Metro Plant north of Highway 70;
and secondly, the issue of minorities as it relates to ah-
McLeansville's citizens. Now, in first point we must realize
that the location of the Metro Plant downstream will open up
vast areas in the South Buffalo Basin for development. With
this potential, the banks will be ready to deal and the developers
to develop and the realtors to trade, and the Chamber of Commerce
will be in a better position to sell the region to industrialization.
Now, foregoing groups have been silent partners with the City leader-
ship from the very beginning, and stand to benefit, financially.
Some more than others, to be sure. Now, we still need to know
what individuals and/or. businesses now that stand to benefit from
the location of the plant north of Highway 70, and I would present
the question, is this not one of the functions or purposes of the
EIS. And, if not, shouldn't the public have the right to know.
And, in addition, have any of the individuals been in contact...
direct contact with'EPA while serving as elected officials on
official business. Do any of these individuals own substantial
amounts of land in the area that will be opened up for development.
Do any of these represent banking, real estate, building and
industries. In short, has it been a conflict of interest on the
part of some lucky public official. Now, with a word about those
who will not benefit from this development. Who will pay for the
re-directing of transportation to serve this area, such as street
and readability. Who will pay to extend water and sewer. Who
will pay for solid waste management and other services. The people
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will pay for this development are the middle-class taxpayers
in Greensboro, principally; and, in Guilford County, in general.
Now, it cost money to expand and the taxpayers foot the bill.
will be created, but in-migration job-seekers will take up
many of these newly created jobs. More services will be needed.
Government will grow larger, and so will the tax bill. Must we.-'
must we re-live the experiences of New York City and other blight
urban areas that are development and growth oriented. Does Greens
Soro and Guilford County want quality, or does it want quantity-
And finally, the minority rights issue. Do the people of NortheaSt
Guilford County not constitute a minority. A small group of pe°P^
that must ah- contend with an olfactory, objectionable sewage
plant, and that means i-t stinks, because a larger, more powerful
group didn't want it in their community. And, why has the City'5
leadership permitted the re-location or movement of the black
community around ah- to the North Buffalo Plant, while shedding
these giant, crocodile tears over the residents around Buffalo
South. These people have been crying for years, so can we expect
the same relief. Further, if the Metro Plant is built in the
McLeansville ah- community, and there are complaints about the
odor and land de... de-evaluation, who do we petition. The Coufltf
Commissioners state that their hands are tied, the City has a
legal right to build the plant outside the City limits. Why can
city officials... ah- why can city officials exercise influence
and affect our lives, but ah- in the same token, why can we not
vote for these same officials. So, I ask the question ah- what
are our rights, and as a post-note, I'd like to say if the odor
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will not be or should not be a consideration in McLeansville
with the new plant, why should it be a problem in the City.
Thank you. (Applause).
Moderator: Mr. Wimbish. After Mr. Ivimbish, Mr. W. A. Ward.
Speaker Mr. Jon Wimbish: My name is Jon Wimbish, I represent
Cone Mills Corporation....
Unidentified Speaker: Yes sir.
Speaker Mr. J. Wimbish: .... Cone is *1" largest employer in
Greensboro and Guilford County. It takes pride in its record
of civic involvement. We've watched closely the development of
the sewage system controversy, and have weighed various advantages
and disadvantages as set forth in each of the seven (7) alternatives
There is a great deal of concern by all parties involved, and not
must we make a decision, but the right decision in agreeing on a
long-range solution to the present sewer dilemma. It's been a long
and difficult process to determine the correct, long-term answer
to our sewer problem. Originally, in order to satisfy the twenty
(20) year growth projection requiring thirty-six (36) million
gallons per day of treated wastewater a hundred and twenty-four
(124) alternatives entailed consideration of of fourteen (14)
different treatment plant sites, including five (S) major water
sheds were identified. Certainly with a study of this magnitude
.. ail alternatives... or combination of
justice has been given to all anem*"*
w#» feel a decision must be made, and
alternatives. Therefore, we reej.
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made soon to proceed with an alternative that will provide the
greatest long-term benefit to'the most people at the most nominal
cost. This alternative appears to be Alternative Four (4), as
outlined by the Environmental Impact Statement. The advantages
provided by Alternative 4 out-weigh any disadvantages as compart1
the six (6) other alternatives outlined. Alternative... Altera*1
Number 4 would consist of the upgrading of the North Buffalo PlaIlt
to sixteen (16) million gallons per day, the abandonment of ths
South Buffalo Plant, constructing the new plant approximately
eight point eight (8.8) miles downstream from the... on Buffalo
Creek, and constructing the outfall from the South Buffalo Creek
to the new plant. This provides a combination of advantages.
Certainly the alleviation of offensive odor of the South Buffa^0.
Plant is a major consideration, but in addition, City disposal
problems will be solved as well as expansion problems. Growth
on the south end of town can proceed by adding sewer lines and
sewer capacity, which should relieve pressure for growth in the
northwest end of town. County property will be able to tie int0
the sewer system, which is more environmentally desirable than
present septic tanks they now use. In general, Guilford County
poor soil permeability in comparison to' other areas of the St*te
locating the new plant down Buffalo Creek will allow gravity &0*
and reducing pumping cost. Industrial growth will also be enhanC
by the new sewage facility provided under Alternative 4. Based 0,1
(3)
the cost factors of the service area, Alternative Number Three *•
could provide an acceptable, though not as desirable alternati^0'
to four (4). Number 3 provides advantages similar to number 4,
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except of course the plant would not be located as far down
Buffalo Creek. Cone Mills has no business interest in any of
the sewer proposals being considered. Our concern is one of
improving the economy and continuing to provide a favorable
living environment to residents of Greensboro and Guilford
County. Thank you. (Applause).
Moderator: Mr. Ward. Mr.'W. A. Ward. (Pause). Lola Ward.
(Pause). James Avent, (Pause). Herman Lewis. Have any of the
people I called... is anyone here? Yes?
Speaker Mr. James A. Avent, Jr.: I'm James Avent.
Modt! rator: Alright.
Speaker Mr. .»¦ »¦ Avent. Jr.: Madam Chairman and ah- members of
the panel, ladies and gentlemen, I'm James Avent of 2021 East
Florida Street. I've been living on Florida Street approximately
three and a half (3%) y«r«. I'™- liTed in Greensboro for all of
my life. I've lived in the southeastern section of Greensboro
for twenty-one and ahalf C21« of my twenty-three (23) years. ¦
Since this issue is factual as well as emotional, I want to
talk about a few facts, first. First of all the approximate
twenty-five thousand (2S.000) people living within two (2) miles
of the present plant, which means more of our tax money will go
towards building the new plant. As I understand it, the plant...
the present plant is at least fifty CSO) years of age. Therefore
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expansion of it would be fool-hearted and would be a fiasco,
since it has already outlived it's usefulness. Also, as I
understand it, the present plant is overloaded as to capacity
of wastewater it can treat daily. So expanding it would
bring it to a level of minimum capacity, which would in term
mean it would have to be expanded again. Even if the present
plant is expanded it is expected to be useful for an additional
twenty (20) years, while a new facility is expected to b.e useful
for a hundred (100) years. Also, I understand that there is no
available land in this section for expansion after twenty years.
Now, some emotional issues. Since my family-moved here in 1950
from Thomasville, they were forced to move to the southeast
section. This was quite normal because blacks had no other place
to go. This was also true for my father's people who moved here
from Halifax County in 1952. Although both of my parents were
college educated, they were more economically and socially
deprived than myself for obvious reasons. As a small boy I too
had to smell the hideous odors that imminated from the South
Buffalo Plant. I now have a son of my own that I would not
like to have subjected to this type of odor. On some Summer
nights the odor is so rancid that I cannot turn my air conditro^e*
on because the odor is blown into my house. My wife and I have
spent many a nights sick to our stomachs because of the odor, and
I invite anyone in this room that doesn't believe me to my house
for a sample. Some others may say that I had some knowledge of
the sewer plant when I moved into the community. This is true,
however, as I stated previously all I have known as home for the
-------
Majority of my life is southeast Greensboro, End if it offsets
that section of the City, regardless if I lived in the north
section, it affects me. Also, the contractors when building
the homes in my section had knowledge of the sewage plant. This
did not deter him from selling the real estate in the area. You
must keep in mind that during the 1950s the destiny of blacks
was solely determined by whites. This might be a purely subjective
statement, but I strongly oppose the South Buffalo Plant expansion
due to inhumane and unjust living conditions that the black resi-
dents have had to be subjected for the past twenty (20) to twenty-
five (25) years. It is high time that something be done about
that obsolete and malfunctioning cesspool. And Madam Chairman,
if I may comment about the odor further, you and the panel nor
anyone else that does not live in my area can't possibly begin to
realize how bad it is. Thank you.
Moderator: Thank you. (Applause). Mr. Herman Lewis and Cora
Robinson and Rosalia Cummings. Mr. Lewis, are you here? Please
raise your hand. I see. Mr. Lewis. (Pause). Cora Robinson.
(Pause). Rosalia Cummings. If you're here and you're trying to
get to the microphone, please raise your hand so I don't overlook
you. Thank you.
SpeaK,,- M,. rora Robinson: I •» Cora Robinson. X have been a
resident of the southeast section of Greensboro for almost sixteen
(16) years, and I will not go into all the facts of... the people
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before me have stated them. But I am opposed to upgrading the
South Buffalo Creek. Thank you.
Moderator: Thank you very much. (Applause). Rosalia Cummings.
(Pause). Alfred Butler. (Pause). Mr. Butler. Charles Weill.
(Pause). Mr. Butler.
Speaker Mr. Alfred Butler, Jr.: I'm Alfred Butler and I live at
1S07 Hilliard Street in southeastern Greensboro. And, I propose
that we will not upgrade the disposal plant, that we will build
another some other place. I'm not... I'm not for throwing it
off down on McLeansville, because I know they don't want to conteI1<*
with the same odor that we are having. But, we can move it so®e"
where, just since we ah- get it out from the Buffalo Creek, 'cause
it is really just a terrible odor. Thank you.
Moderator: Thank you. (Appause). Mr. Weill. After Mr. Weill,
Mr. Fred Clapp, and then Allen Holt.
Speaker Mr. Charles Weill: Madam Chairman, I am Charles Weill of
307 Sunset Drive. My concern is the economic development of our
community and the longer range planning for the growth that we can
logically expect. , The population in Greensboro has grown over the
past several decades at a rate of approximately two (2%) percent a
year. At this rate, our population has doubled every thirty-five
(35) years. Whether this rate continues, we don't know. There's
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been a great many projections, certainly we know the southeastern
part of the Country and the Piedmont, in general, has been very
attractive. We can logically expect more people. These people
will need employment opportunities. The various points concerning
the making of opportunities availables through industrial expansion
has been adequately stated by both Mr. Fetzer of the County
Chamber of Commerce and Mr. Charlie Melvin of the Chamber of
Commerce. Little more needs to be said, but I would like to
endorse their comments. But, with respect to longer range planning,
I'd like to point out to the panel that the Piedmont Council of
Government, which"is a rather extensive planning organization sup-
ported through contributions of eleven (11) county governments
has developed what they term their regional development guide.
This information has generally been distributed throughout the
community. The concepts in that guide ah- shown in this little
brochure, I'm sure this is available and has been inspected by
the ah- various investigators in the preparation of your report.
The basic concept suggest that if we don't direct our planning
we're liable to end up with a megopolis between the Greensboro,
Winston-Salem and High Point. These towns, perhaps, will grow
together. This is not desirable. That concept of... of avoid-
ing a megapolis such as we have in the northeast has generally
been accepted. To avoid that direction of growth, has been
suggested that Greensboro to the north and east. In order to
accomplish this, waste treatment... waste collection systems will
need to be installed. I think it's not a question of whether we
need additional waste treatment, that's been demonstrated adequately
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tonight, the question is when and where. The when has pretty
well been spoken and ah- the point has been proven, well demon-
irated, and I think we all know that we need it now. The questi"11
then remains, where. I suggest to you that Alternate Plan Numbs*
is by far the best one to provide for the growth in the north and
east, which we would expect through the direction of ah- the
various governmental agencies. The representative from Radian
Associates said that Alternate No. 4 perhaps would allow a link
for development, I would assume that he meant by this, fragment^
development. We need not be concerned with that particular all6'
gation, because we have adequate boards, councils and represent^
to ah- direct our growth. Such as zoning commissions, sub-divis^
control, and etcetera. It's been pretty orderly to date, and
appears it will continue. I suggest that if the new plant is
4
constructed, I certainly hope it will be, that it be at Site No-
where gravity flow of the collection system can adequately serve
the greatest amount for our County and provide for the longest
possible growth. You're concerned with twenty (20) years, I
believe we in Greensboro who have to finance this project
are concnered with as much longer period that this facility will
possibly last. South Buffalo has lasted fifty (50) years. If v,e
put this at the right place, it will last longer. I heartily
recommend that you ah- endorse Alternate No. 4.
Moderator: Thank you. (Applause). After Mr. Holt, will Mr. Sh^
and then Ken Smith proceed to the microphone? Mr. Holt.
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Speaker Mr. Fred Clapp: Madam Chairman and members of the panel,
my name is Fred Clapp. I'm the president of the Greensboro Board
of Realtors. The Board of Realtors is already on the record with
you in supporting Number One (1)» the immediate implimentation of
an adequate regional wastewater treatment plant, and Number Two
(2), supporting the plan previously approved by the City of Greens-
boro, County of Guilford and the North Carolina Department of
Natural and Economic Resources known as the Confluence Plan and
Alternative Number Four (4) in your study. A special sub-committee
of our legislative committee has been tracking the progress of
Metro and has served as our representative on your EIS Advisory...
Advisory Committee. The committee has recommended to our Board
of Directors, and the directors, representing almost six hundred
(600) members of our community who daily face this problem in the
course of their business, have authorized me to present to you
the following statement. The conclusions presented in your Environ-
mental Impact Statement fail to provide sufficient argument to
persuade us to change our previous opinion that the so-called Con-
fluence Site, Alternative Number 4 is still the most effective,
prudent and economical plan from a long-range point of view. We
believe any plan involving continued use of the South Buffalo
Plant, your Alternative 1, 6 and 7, would prove to be not only
improbable to impliment, but would be unacceptable for a number
of reasons. It is, however, our opinion that the urgent need to
proceed with a regional waste-water treatment facility at this
time is our number one concern and therefore we hereby go on
record in support of your proposed action, Alternative Three (3),
provided you can proceed to immediately impliment the proposed
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action. Ladies and gentlemen, the time is now. Your report li$tS
three and a half (3%) pages of major events, hearings, meetings
and approval of this project and assuming a plant coming on-str®*1"
in 1980, this is a time-span of eleven (11) years. We fi*1^
further delay unacceptable. The people of Greensboro have alr®a<^
put up their money, so to speak, almost seven (7) years ago, and
we still stand ready, willing and able to proceed with the pro*
ject. We understand of course that no project of this magnitude
can meet with everyone's approval, but we do believe that the
is now for this community to close its ranks and support a plan
that will more greatly benefit the entire community. If you
fund Alternative 4, we urge you to proceed with your proposs<^
action, now. Thank you.
Moderator: Thank you, Mr. Holt. (Applause).
Speaker Mr. Allen Holt: Madam Chairman, panel members, my name
is Allen Holt, I'm a resident and a property-owner in McLeansvil^3
After looking over the Draft Environmental Impact Statement, there
axe several factors of Alternate 3 that have not been addressed*
adequately. Number one, much of the dis... or discussion in the
Environmental Impact Statement was centered on the short-term
effect of the construction of the sewer treatment facility. A
more important focus would be the analysis of the long-term envi*0
mental effects of the:existence of a treatment facility at Site
Number two, the Environmental Impact Statement states that overt
complaints are minimal. Yet, it also states that no records at0
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kept of such overt complaints. How can this be. Number three,
the residents of eastern Guilford County have been assured by
Greensboro's decision-makers that there would be no odor problem
with the new Metro Treatment Facility. However, the Environmental
Impact Study again states that the technology is not available to
prevent odor pollution. If Greensboro continues to assure us that
there will be no odor problem, then the EPA should require a
performance bond so that owners can be compensated for the devaluat-
ion of their property by over-pollution. Number four, the Environ-
mental Impact Study includes the possibility that the South Buffalo
Treatment Plant will remain in-operation so that it can serve as a
(this word was inaudible) facility to reduce the odor
potential from septic conditions at the outfall . Nevertheless the
document was vague as to whether this would in fact be a realistic
possibility. It should be made clear to the citizens as to whether
this will in fact be a part of the anticipated treatment operation.
Number five, the development of Site 3 versus the upgrading of
North and South Buffalo Treatment Plants has the added liability of
dispersing the flora and faunal habitats along South Buffalo Creek.
In urbanizing areas, the streams.and flood plans are critically
important in the maintenance of a diversity of flora and fauna.
Number six, and the final one, the social impact of the present
South Buffalo Treatment Facility is significant only because the
the perimeter area around the treatment facility was encroached
by sub-divisions. The facility was there, first. The residential
use followed. The community of McLeansville and the residents of
eastern Guilford County established their homes in an area that
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would afford the social and environmental conditions that would
be conductive to rearing families. Now, the City of Greensboro
propose to come, after the fact of our existence as.a- community*
after the fact of the construction of our homes and the establi5'1
ment of our families and to evade our rural, suburban-like li^e
with'a sewer treatment facility. Just because this facility wil*
only dislocate three (3) families is no reason to minimize its
significance on a cooperative population of eastern Guilford
It will adversely affect us on anyone's standards.
Moderator: Will you please summarize, Mr. Holt?
Speaker Mr. Allen Holt: This is my last statement. The Envito11'
mental Impact Statement Study shows clearly that the most cost-
effective and best environmental solution is to upgrade existing
facilities.
Moderator: Thank you. (Applause). Dwight Sharpe. (Pause).
Dwight Sharpe. (Pause). Ken Smith, John Michael, and then
Thomas Nettles. (Pause). Dwight Sharpe.
Speaker Mr. Dwight Sharpe: Yes mam, I'm Dwight Sharpe. I'm
from the McLeansville community, and I just want to make a short
statement or two concerning ah- to get your sympathy to look at
this project in a moral ah- and ethical point of view. I think
that ah- the moral aspect of the ah- sewer treatment plant being
relocated from a community that gets the benefit, and it entirely
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benefits this community... relocating this sewer plant to a
community that doesn't get any benefit from it just doesn't
seem morally fair to me, and ah- you people, I think ah- if
you would think morally and religiously, in fact I think it
is to the point of being a sin to ah- indulge this type thing
upon someone that ah- is not getting any benefit from it. If
it's so bad why... why does it have to be put on some ah-....
We have the minority race out there, plus we have white race
there, yet we are the minority in this situation. So, ah-
it seems to be ah- a few laws ah- new laws within the Consti-
tution or within the ah- laws of the federal government that
ah- protects the minority. So, let's kind of review this. Ah-
this is... the facts that most of these South Greensboro people
have brought forth are well taken. The points are very good,
but it seems that ah- their point of view is when it concerns
South Greensboro residents a sewer plant smells too bad for
them, but concerning a sewer plant in downstream neighborhood,
we have been assured that a sewer plant will not smell bad to
us. Ah- how is it going to be that way. (Applause). The last
point I would like to make and bring out, I have been concerned
with this thing ever since it started. In fact, my name was
smeared in the paper when we had a meet... the very first meeting
that ever caused this to start was held at Mount Pleasant Church
on Sunday before Labor Day, I don't even remember the year, but
it's been about ten (10) /ears aS°- Ah" 1 come t0 church with
my wife and family, and the church had just been painted. And ah-
I drove up and the paint on the church had turned black. And I
said, I'm not going to put up with this. Ah- I left my wife and
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family in Sunday School and didn't even stay for the church service'
I went to see Representative Odell Payne and he and I got a meeti^
together the next day, which was ah- Labor Day, and ah- and trie<*
to get the City and County officials out there to do something
about it then. We have had problems. These people in South Green5
boro,' I can sympathize with them. But ah- the lady a few minutes
ago from McLeansville stated the facts about the paint peeling
of the buildings out there.' I... I won't go into that, because
that's too old a thing to talk about. It's just like the civil
rights issue though. It's just... the civil rights issue for
people in Greensboro is just like fighting the Civil War over
again, as far as I'm concerned. And that's ridiculous. The ci^
rights issue is out of it, as far as I'm concerned. And, one fliore
point I would like to make. I think it is time to stop spending
wasting all this money for studies and you people to sit up there
and make a big salary and not make any decisions. One year ago
I think that... I think the tax money was something like two hun^1"6
thousand ($200,000) dollars was allocated to these people to make
this study. They made the study and made the recommendations an<*
nothing was done about it. That's a waste of the taxpayers' mone/
already. No wonder it's going to cost fifty-nine ($59) million
dollars. Thank, you. (Applause).
Moderator: Mr. Smith.
Speaker Mr. Ken Smith: Madam Chairman, my name is Ken Smith. I
speak in behalf of the home-builders of Greensboro. We the home*
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builders of Greensboro are very concerned about our City. We
feel it is a must that a new waste-treatment plant be built,
now. Our constructing industry employs some seven to ten
thousand (7,000 - 10,000) people, directly. Also, several
thousand, indirectly. We are the second largest industry in
the Country, the economy depends on construction, greatly.
Therefore, we UTge your speedy approval of a new site, now.
We are concerned about the cost of homes. We build... have
built here good houses for our people, and in the future. The
cost of land and the availability of it is getting worse
day-by-day. We are concerned about the growth of Greensboro,
the jobs of our people. We have had a very limited growth'for
several years because our present treatment plant is not suffi-
cient to take care of our needs. Therefore, good industry is
passing us by. With Greensboro being one of the best places
in the Country to live, help us to keep this name and build
a better City. We must have your help, now. So, please give
us a prompt answer. Thank you.
Moderator: Thank you. (Applause). Mr. Michael, then Mr. Nettles,
and then Leonard Lassiter. • Mr. Michael.
Speaker Mr. John Michael: My name is John Michael, and I've been
a citizen of Greensboro for eight (8) years. And ah- after hearing
all of the political rhetoric, I just wanted to ask a few questions,
not to the panel but to pose them to the people here, tonight. And
ah- my main concern was in the looking over the ah- book prepared
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by the Environmental Protection ah- people, why the ah- re-cycle>
re-use type of operation was not considered as the only alter-
native, no matter what the site was. No one has dealt with this
subject, tonight. And, I think, especially after the failure of
the Chapel Hill ah- folks to have any water at all to use this
Summer and the problem with the sabotage contamination in
• (this name was inaudible), North Carolina and
the problems in the other sections of the Country, I can't see
why it wouldn't be feasible before the year twenty thousand and
ten (2010) for it would be economically competitive to re-cycl®'
Why this wasn't considered, no matter were the site might be.
I'm in complete empathy with the citizens of McLeansville. But
ah- when... if we wait .too long, then it'll be economically
impossible to have a re-cycle, re-use type of operation, and we
won't be able to turn it over where we will be able to have water
at all. And ah- I... i wondered why this wasn't considered when
this impact study was made. Thank you.
Moderator: Mr. Thomas Nettles, 1302 Moody Street. I may have
pronounced that incorrectly. (Pause). Mr. Leonard Lassiter,
then Mr. Harry Pike, then Ralph Lewis. Mr. Leonard Lassiter.
(Pause). Mr. Harry Pike. (Pause). Mr. Ralph Lewis. (Pause)*
Espanella (this name may be spelled incorrectly) Greene-
Speaker Mr. Ralph Lewis: Madam Chairman and members of the pan®*'
my name is Ralph Lewis, and I represent the McLeansville Athiet^5
Association. We ah- have athletic programs involving about two
hundred and fifty (250) people in three (3) programs, and we're
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opposed to the Greensboro... to Greensboro putting the waste
treatment plant in our neighborhood. We're a rural community,
and we want-it that way. Many families have been here for
generations, and we do not want the city problems such as con-
gestion, pollution, industrial emission and the squalor which
a treatment plant will eventually bring. To avoid these problems
is the reason we live there. The City should have some rural,
green space around it, and we're that green space. And, our
end of the County grows agriculatural products and these are
nec... necessities. And, we do not... we don't need the sewer
service, and we don't want it. (Applause).
Moderator: Miss Green, then Mr. Dennis Harrell, and then Harold
Haskins. Miss Greene.
Speaker Ms. E. H. Greene: Madam Chairman and members of the
Environmental Protection Agency, my name is Espanella Greene.
I live at 1602 Lincoln Street, within smelling distance of Buffalo
Creek. The central issue here tonight seems to be what is the
greatest good for the greatest number for the longest period of
time. And to that question I can only say the Confluence Site
of North and South Buffalo Creeks. In addition to all of the
reasons you have heard, already, I shall attempt to summarize
just a few. The Confluence Site provides ample space for future
expansion, it affects a relatively smaller number of people. Your
recommendation of Alternative Three (3) will only last us for
twenty (20) years, and I would hate to go through this all over
-------
again in the next twenty (20) years. Your objection to the
Confluence Site seems to be the cost factor. Hopefully many
of us will be around twenty years from now. And, I think all
of us will agree at that time that that was by far the cheapest
location. Thank you.
Moderator: Thank you. (Applause). Mr. Harrell. Dennis Harrell'
After Mr. Harrell will be Mr. Harold Haskins, and then Mr. Wade
Payne.
Speaker Mr. Dennis Harrell: Madam Chairman, I'm Dennis Harrell*
and I speak as the chairman of the Concerned Citizens of McLeans'
ville. We are opposed to ^Greensboro putting their waste treatment
plant in McLeansville. We want to know why Greensboro wants five
hundred (500) acres, while all they need is forty (40) or fifty
(50) acres. A buffer area could be zoned around their plant.
We want to know when additional sites downstream were looked at.
Was Radian looking for five hundred acres, or forty to fifty acres-
How could there by only three (3) places to put a plant in nearly
eight (8) miles of stream. Why was the so-called preferred site
never mentioned or discussed until it was proposed in the May 26th
fleeting in Atlanta with EPA and the City. How many other as yet
under-discovered sites might be available up-stream at a savings
of nearly a million ($1,000,000) dollars a mile, particularly if
your consultants would look for fifty acres or so. Why does EPA
and the State want to spend so much of our money on a project that
does so little when better and cheaper alternates are available.
I would like the record to show that we oppose Greensboro's waste-
-------
water treatment plant being located anywhere in the McLeansville
area. In summarizing, the Environmental Protection Agency, the
Department of Natural and Economic Resource and their consultants
the Radian Corporation have found Alternates Six (6) and One (1)
to be the most environmentally acceptable. They have also found
Alternate 6 and 1 to be by far the big... the least expensive to
construct, as well as the most cost-effective. We recommend that
you follow your findings. Thank you. (Applause).
Moderator: Mr. Haskins.
Speaker Mr Harold Haskins: Madam Chairman and the panel members,
I am Harold Haskins from McLeansville and I represent a
majority group of the land-owners of the Confluence Site. We feel
it would be most uneconomical for the Metro Sewage Treatment Plant
to be constructed in the McLeansville area. By upgrading and
expanding the present North and South Buffalo Treatment Plants,
there would be a savings of twelve (-$12,000,000) dollars to us
taxpayers. If other Cities in North Carolina can treat sewage
waste without odors, why can't the City of Greensboro. With
these facts in mind, we support one hundred (100%) percent
Alternate Site Six (6) described in the Environmental Impact
Statement. Thank you. (Applause).
Moderator; Mr. Payne. After Mr. Payne, Miss Margaret Snow,
and then Haley Moses. Mr. Payne.
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Speaker Mr. Wade Payne: Madam Chairman, I am Wade Payne. I
represent the people close to the proposed site. We object to
Greensboro puttan'g" their sewer plant in our community. We
believe that the odor problems and the discharge of poorly
treated sewer should be stopped and the State and EPA have
the authority and the knowledge to stop these problems. Greens*
boro should never have had their permit to discharge improperly
treated sewer renewed a while bacl< by the State and EPA. Greens'
boro should never be allowed to move their problems downrtr«ii®
to McLeansville. In 1969 my home and others in my community
were turned brown by odors and fumes from the South Buffalo
Plant or South Buffalo Creek. We had to pay to paint our homes»
and we would like to know who will be able to do the repaying
for flirt he j- re-pairs and problems if this plant is put downstres®'
Thank you. (Applause).
Moderator: Thank you. Mrs. Snow. (Pause). Mrs. Snow. Mr.
Is Mrs. Snow coming to the podium? Are you Mrs. Snow? Mr. ah"
Haley Moses, and then Vance- Chauis... Chauis. Yes Mam.
Speaker Ms. Florintine Sewell: Ah- I'm Flor:'m... I'm Morintii'0
Sewell, 1413 Dans Road. The same street on which the South Buf^a^
Plant is located.- I come not '.o speak about where, the plant sUo!i*
be located. But rather I want to strongly speak about where the
plant should not be located. As a resident of Dans Road, a home"
owner, I am a victim of fifty-four thousand (54,000) households
in the City c£ Greensboro flushing in the wake of my living room*
There are also another twenty-six thousand (26,000) residents who
-------
are also victims of the fifty-four thousand (54,000) occupied
homes flushing their many toilets into their living rooms. I'd
like to comment that as we talk about the location we think about
in this area that there are recreation areas located on this con-
taminated Creek, that in our neighborhood, on the same street as
I've mentioned my dog fell into something. We're not quite sure
what it was, but it was unbearable to live with him for a few
days. I want to also comment that as we think about this south-
east portion of Greensboro, and as we talk about the problem, we
recognize that it is a Guilford County problem, that it is a
Greensboro problem, and that we as citizens certainly ought to
now think in terms of as I heard the statement a few minutes ago,
the quality of human environment. I'd like to also comment about
the economics of the location, mainly to locate.the plant where
it should be cheaper to recognize some opportunity cost, some
hidden cost that have not been discussed here tonight. To recognize
that it will indeed be an expensive venture to come within a highly
indensely populated area of our City to locate a disposal plant.
I'd like to also mention as we talk about the cost that we recognize
the health problems. The health problems ah- to which I've heard
no comment as to the extent of deterance and the difficulties that
must because... because of the unsanitary conditions that are caused
by the odor pollutions which have been discussed quite often here.
And, as I summarize, I'd like to mention that I've brought along
a yellow bucket with a sample of what the odor is like along the
South Buffalo Creek. And, if you'd like to have a smell, be sure
to come by my yellow bucket and you'll have that opportunity.
Thank you.
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Moderator: Thank you. That was Dr. Florintine Sewell, while
either Mrs. Margaret Snow, Haley Moses or Mr. Vance Chauis is
coming to the podium, I would like to say that we have now
completed speaker number fifty (50) of a hundred and fifteen (1*^
registered to speak. Therefore, if any of... anyone has prep3re<*
comments or you've written them out that would rather submit th°se
comments than make an oral presentation, we will answer anythi11?
in writing also in the final EIS. Also, if someone has esseixti3,11'
expressed your own personal concerns and you wish merely to give
us your preferred alternative, we would accept that, also.
Mrs. Margaret Snow, Mr. Moses, Mr. Vance Chauis from the Greens^0*
Men's Club. (Pause). Melvin Payne, M. F. Shute or Robert Mays*
Speaker Mr. Melvin 5. Payne: Madam Chairman and panel members,
I'm Melvin Payne from McLeansville. The opposition of the McLe^5
ville people has already reduced the size of the Greensboro Waste
Treatment System from forty-eight (48) to thirty-six (36) mill*011
gallons per day for a potential savings of up to twelve million
($12,000,000) dollars. By building a new plant at the present
site in size and quality to make it acceptable, and not moving ^
plant downstream and in so doing completely damaging the qualify
of the stream along the way, another ten or more million dollars
can be saved. That's a total savings of approximately twenty-
two million ($22,000,000) dollars. I would like to know how muck
longer the people of McLeansville will have to spend their time
and money to get the State and federal agency to make the right
decision in this plant. Thank you.
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Moderator: Thank you. (Applause). M. F. Shute. Thank you.
Speaker Mr. Robert Mays; Madam Chairman, I'm Bob Mays, I reside
on Benjamin Parkway. I think it's rather a sad thing as we sat
here tonight to see so many different opinions from three (3)
different identifiable groups. The problem is not just one that
can go with just one group. I think we're all fooling ourselves
if we think that. The problem is one that everyone faces here,
and it's rather ah- a view of tunnel vision to think that every-
one here is not affected by the problem. This problem is not a
McLeansville problem, nor a South Buffalo problem or a Greensboro
problem, but a Guilford County problem. And, I feel very ashamed
that we're not be-fore you as a unified group. Because you're the
people that need to make the decision, now. And I'm afraid thaf
we've damaged our chances of you making a prompt decision by
dividing our force. So, I reiterate to you that we need this
decision, now. We don't need any more studies, we need it now.
Guilford County's waiting. (Applause).
Moderator: Thank you. Johnny Hodge, Walter Reynolds and then
next Mrs. Milling. (Pause). Hodge, Reynolds, Milling. (Pause).
Joseph Bennett. Please raise your hand if I call your name, so
I'll know you're coming toward the podium. Come ahead at the back.
Were you raising your hand? Did I call your name, sir? (Pause).
Okay. Joseph Bennett. (Pause). Lydia Wallington. (Pause).
William Murphy. (Pause). Jim Valentine.
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Speaker Mr. Jim Valentine: Madam Chairman, I'm Jim Valentine,
a resident and land-owner in McLeansville. I just have a few
things here. My concern ah- especially on our property is I've
got four (4) free-flowing springs. I've got a good well in order*
and I've got a good septic tank system. And, the soil on our
property was exception for septic tank use, as stated by you
Guilford County folks. Ah- in this draft is stated the possibili^
of flood problems and seepage from the new plant which might seep
into the acquifer and pollute wells within the area of where this
proposed plant will be. This is of great concern to me, and I1®
sure it's of concern to residents in the area. Another thing is
I'm from... I'm basically from New York City. I've lived in the
big city, I was born and raised there. Moved to New Jersey and
moved to Greensboro. It was the best thing that ever happened to
me. Living in Greensboro was almost similar to living In Newark,
and if you've ever been in Jersey where I'm from, but when I
bought property in the County, it was the happiest day of my life*
It's quiet out there, I've got plenty of acreage and plenty of
land. I don't have a lot of traffic and a' lot of pollution. And,
I sure don't want the city coming back on me again, after it took
all of my twenty-eight (28). years to get out. Thank you. (AppluaS
Moderator: Thank you. Bob Shelton. Bob Shelton. (Pause).
Charley Thompson. (Pause). A. N. Harrell and John G. Clapp, Jr.
Are any of those people present? (Pause).
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Speaker Mr. Tnhn fl. Clapp, Jr.: Madam Chairman, members of the
panel, I'm John Clapp representing Clapp Farms. I'd just like
to ah- re-state some of the decisions that the Environmental
Protection Agency considered in eliminating Alternate Site Two
(2), which involves ah- our farming property. There are people
thati of course, live on that land that have been engaged in
farming and they depend upon agricultural production as their main
source of income. There are three (3) families that have retired
from farming and, of course, are supplementing their social
security pension from agricultural production and then there are
others of us that have a heavy investment ah- in this business'-
Now, the history of this land goes back to quite a ways. Ah-
to 1845 and has been farmed, continuously, since that time. Now,
we've made major improvements in trying to increase the efficiency
of production, such things as irrigation ponds and enlarging fields,
ah- elliminating hay-droves, ah- establishing side-waterways and
etcetera. Ah- if there's some question ah- about the term century
old farm, ah- I have here a copy of the original deed that my
grand-father signed on August the 19th, 1845, I'd like to present
that to you folks that are in the decision-making process, and
some other information.
Moderator: Thank you. W. A. White, Gregory Boyle, Cameroon
Cooker. Mr. White.
Speaker Mr w. A. White: Yes Mam. I'm... Madam Chairman, I'm
William White of McLeansville, and ah- most of what I've got to
say has been said. So, I support Alternate Number Six (6).
-------
Moderator: Thank you.
Speaker Mr. W. A. White: Thank you. (Applause).
Moderator: Gregory Boyle.
Speaker Mr. Gregory Boyle: Madam Chairman, members of the panel,
ladies and gentlemen. We've heard a lot of rhetoric tonight about
the citizens of Greensboro whose obvious thrust is to get something
done and get it done, now, and for heaven's sake, get it out of
Greensboro. We are... I represent the ah- McLeansville Wildlife
Club. I'm the president of that club, and I do endorse what
Mr. Rosser and some others in the McLeansville said tonight, that we
don't want the sewage plant from Greensboro in McLeansville. We
feel a far more environmentally sound decision is to, you know,
leave it in South Buffalo Creek or the South Buffalo Plant. Up-
grade that plant, but do it in a manner which will eliminate
odors and that it will improve the waters coming downstream to
benefit the wildlife and the agriculture in that... that area.
Thank you.
Moderator: Thank you. (Applause). Cameraon Cookie.
Sneaker Mr. r.n.raon Cooke : Madam Chairman, and friends, my
name is Caineraon Cooke...*
Moderator: Excuse me.
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Speaker Mr. Cameraon Cooke: .... I live at 2707 Lake Forrest
Drive, here in Greensboro. I'm an attorney and I don't represent
anyone, yet. Ah-... (Laughter). I appreciate the opportunity
to make a few comments ah- as a private citizen. The City's
early planning efforts in this area are very commendable and
I think it's clear the forbid hope of most people in the area
is that these will lead to some fruition, shortly. I've been
impressed with the range of comments, tonight. A lot of business
people, Chamber of Commerce, technical people, all sorts of skills
and tech... ah- technology represented, and not one has complained
about the size, the sufficiency, the technical ah- proficiency of
the plant or anything else. The whole issue here is the adequacy
of treatment and where "the facility will be located. I personally
came to the meeting tonight without having seen a copy of the draft
statement. I heard some comments earlier about how they... nobody
could understand it. To me it's very simple. All of the graphs
and charts in here represent, to me, the fact that the facility
will cost approximately ah- thirty some million dollars, this is
a mid-range figure of all of the facilities studied. The environ-
mental assessment is a mid-range item. This... the proposed
facility three (3), the City's preference four (4) are essentially
the same on that. The operating cost are similar. I really don't
see what the problem is. Ah- frankly, I'm beginning to believe
that it's arbitrary and capricious not to make a decision. And
I certainly urge that you make a decision shortly. Thank you very
much.
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Moderator: Thank you. (Applause). Allen Andrew, Dr. Ellis,
W. H. Ashworth. Mr. Andrew.
Speaker Mr. Allen Andrew: Madam Chairman, I'm Allen Andrew from
Greensboro. We are fortunate to have dedicated, elected officials
and I think very competent City and County employees. They have
suggested a very positive plan for treating our wastewater. The
citizens of Greensboro on a whole have certainly supported this,
and we urge you to give us your decision so we can move ahead. I
support Alternate Four (4). But, if not that, certainly the
recommended Alternative Three (3).
Moderator: Thank you. (Applause). Dr. Ellis, W. H. Ashworth,
and after Mr. Ashworth, Jon Wimbish, but he has spoken. Yes sir.
Speaker Mr. W. H. Ashworth: Madam Chair-person, ladies and gentle-
men, my name is William H. Ashworth, I'm a member of the Concerned
Citizens of McLeansville, but expressing my personal views because
my involvement with the Metro planning extends well beyond the
formation of our citizen's group. My first look at the Metro
plant came during the early 19 70s, or approximately even before,
at least well before the 1970 Census figures were available. At
that time, we all thought our cities and towns had had tremendous
growth in the 1960s, and that our population explosion was still
going strong. The long-range planning at that point in time was
for large regional systems to provide for the anticipated, con-
tinued rapid growth. Therefore, based on what seemed to be taking
-------
place at that time, I strong supported a regional Metro System,
with a treatment plant located at Reedy Fork Creek. As the true
facts and figures of the 1970 Census became available, we all
learned, much to our surprise that our cities had not grown nearly
as much as we had previously thought, and further, our birth rate
was rapidly declining. The Gladstone Report had been completed,
and indicated sufficient land already available within the city
limits to provide for future growth. Further, we were rapidly
moving in a... into a disastrous inflationery period. Mr. R. A.
Thomas, consulting engineer who joined our efforts about this
time convinced me of the accuracy of the above mentioned, but
yet to be recognized facts. Even though the Reedy Fork system
would help provide more available, low-cost building lots for our
young people... our young couples, the plan was strongly opposed
by the City. We could further find little hope that P.L. 92-500
or the new P. L. being able...or to take into account the major
social considerations necessary to finance anything other than
the most cost-effective alternate. Faced with these fact, I
was forced to agree, reluctantly, to withdraw my support of the
Reedy Fork Plan, and to go strictly by the law. We began our
further review of the original 201 Facility Study in an effort
to determine the most cost-effective alternate, and to reconcile
our figures and calculations with the study. This we were never
able to do. And, Mr. Thomas presented these major differences
during the public hearing that the City held. These differences
were substantial, and if our calculations were correct, would
represent potential savings of several million of dollars. It
-------
should be clearly stated for the record that these cost
differences are a major factor in the desire of the McLeansville
community for the Environmental Impact Study. We met in this
same location here a year ago and started the Environmental
Impact.Study. That night, two (2) general feelings were expressed.
Number one, we said give us a fair and impartial study that proves
us wrong, and we'll give you full cooperation in the construction
of the plant. Two, the City said, just tell us where to build it.
In early July of this year, EPA, in fact told the City where to
build it. Within one week, the City and County officials descended
upon Atlanta, and had a new site chosen. The first site selected
was Alternate Two (2), or what is called the Clapp Farm Site. One
week later, Alternate Three (3), the Ciba Giegy Site became the
preferred plan. We have extreme difficulty in understanding this
action by EPA. We find no major fault with Radian Corporation's
study. It would be extremely hard for us to do so, since it has
proven our position to be ninety-nine and forty-four, one hundred
(99.44/1001) percent correct, and that, in fact, many millions of
dollars can be saved by going with the more cost-effective alter-
nate. Time will not permit me to read into the record a single
letter from Mr. J. Matthew Robins, Regional Director, Office of
Civil Rights and Urban Affairs, that attempts to negate this entire
Environmental Study. If all here tonight are truly interested
in a fair solution to our mutual problem, I ask that you take the
time to read Mr. Robins' letter. There has been a long and costly
struggle for us, but we feel our efforts have been in the interest
of all people, whether in McLeansville, Greensboro or elsewhere in
-------
this Country. In conclusion, we trust that the facts of the Environ*
mental Impact Study will not be altered by fiction. Thank you.
Moderator: Thank you. (Applause). Jon Wimbish. Mr. Wimbish
hadn't registered for rebuttal. Okay. Mr. Richard Evans, I would
assume you had... I called on you, previously. Mr. Richard Evans,
Mr. Webb, and Ruby Garraway, are any of those people here? (Pause)*
Speaker Mr. Burleigh C. Webb: Madam Chairman, members of the panel*
citizens of Greensboro and McLeansville, my name name is Burleigh
C. Webb and" I'm here representing A§T State University. This
university being located in the proximity of the South Buffalo
Creek ah- Treatment Facility, and the other ideas that this univer-
sity, through the State of North Carolina, owns land that abuts
Buffalo Creek at the point where the present site stops and A§T
land begins. I want to bring to your attention a problem that
would be caused for A§T State University by an enlargement of
South Buffalo Creek to the twenty (20) MGD capacity. However, I
quickly add that the university also truly endorses those state-
ments already put forth here tonight which direct attention to the
general welfare of those persons who live at the threshhold of the
present site. Now, specifically, if the South Buffalo Creek Treat-
ment Plant present existing were to be enlarged to twenty million
gallons per day capacity, a particular, and we consider, a unique
educational facility at this university would be lost. Now, we
are talking about the land that abuts, directly, the present site
of South Buffalo Creek. And on this site, I'm not talking about
-------
farm land in this case, at all, for some people get that confused
with the AST Farm, this is a ah- a site that is designed for passage
recreation and a botannical arboretum. Therefore, we don't see
that there is any remedy by a simple land-swope with some land
existing some place else, or a simple land ah- purchase for new
lands from any effort to relocate this resource. This recreational
facility and arboretum presently contains a bog situation with all
the unique-type... not alii but the kinds of unique plants that
would normally be found in a bog situation and should, therefore,
be protected as that. That it has certain species of hard-woods
already there; that it has some reasonable amount of open-space
there; in fact it has just about an ideal laboratory, educational
situation, except for the presence of the proximity, anyway, of-
the South Buffalo Treatment Plant. Now, this area is already
detached from the main farm-land owned by A§T by the intervention
of Highway 6, about fifteen (15] years ago. This turned out not
to be a problem at all, that is the intervention of Highway 6
through a major part of the immediate A§T farm-land, but the...
it's rather ah- it provided an improved access by students and
by citizens ah- citizens-at-large who would use this recreational,
arboretom resource that I referred to. Now, I want to say that
though the site I'm talking about abuts the present South Buffalo
Creek Facility, the university, through the State, has expressed
its willingness to provide, without any question, whatever right-
of-ways would be necessary to convey and deter (this
word was indistinguishable) further somewhere downstream. Now, in
part, because of this educational and community ah- facility that
I referred to... or resource that I referred to, finally I want to
-------
say to you that I've been advised and I have copies of the letter
that does advise me this way, that the State of North Carolina
and certainly A$T State University have shown no interest in sell-
ing the A§T land which, as I understand it from the ah- engineer's
drawings, that land which would need to be provided or would have
to be provided in order to expand Buffalo Creek to a twenty (20)
million gallons per day capacity, the only other alternative in
this absolute space, as I understand it, is to move some people
from v/here they live, because it would have to include their home
site as of now. The only other direction with the highway on
one side, I don't believe we're going to tear-up eighty-five (I-85)}
and the other side is the land that the State is not willing to
sell... .
Moderator: Please summarize, Dean.
Speaker Mr. B. C. Webb: .... The other side is the land owned by
A§T State through the State of North Carolina to which there is
no willingness to sell. Therefore, AST State University proposes
complete abandonment of the South Buffalo Facility. Thank you.
Moderator: Thank you, Dean. (Applause). Ruby Garraway, W. C.
Parker, Jr., Art flynn, James Banks. If I have called your name...
yes sir.
kker Mr. Art Flynn: I am Art Flynn, representing the Greensboro
Motel Association. The Greensboro Motel Association comprises
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about four thousand (4,000) rooms that serve the. population, the
industries and families of Guilford County in total. Within the
past four (4) years over a thousand rooms that were not necessary
were built in the anticipation of industrial growth and expansion.
This.wonderful community of ours that we love so much has led a
lot of people to invest in its future. The fact that today industry
can chose, finds an indecision in handling a waste treatment is
detering the arrival of these people, affecting the amount of jobs,
and has twenty-five (251) of the rooms in Greensboro in bankruptcy.
We have full confidence in the leaders and planners of our County,
and we ask that you respect these people who have given their lives
to the offices and expedite either Plan Four (4) or Plan Three (3)
as soon as possible. Thank you.
Moderator: Thank you. (Appluase). W. C. Parker, James Banks,
Odell Payne, Phillip J- Bissesi.
Speaker Mr- nrtell Payne: Madam Chair-person, I'm Odell Payne from
McLeansville, and a lot has been said here tonight and for the sake
of time, I will not go in and reiterate and be repetitious. But I
think it is worthwhile to note in 1969 this problem did exist, I
was elected to the general assembly, and at that time I got to meet
some of the members on the panel here tonight to try to help us to
resolve the terrible problem that has been spoken to. This problem
is bad, the people in McLeansville does not oppose the building of
the waste treatment plant. While we have suffered as others have
around South Buffalo Plant. And I think it's been adequately spoken
-------
to here tonight. My concern here is ah- a lot of comments have
been expressed, a lot of persona! feelings have been expressed,
ah- I respect the opinions of all that have spoken, but I think
we've come down to the facts of the matter. I believe ah- Mr.
Rosser who spoke earlier for Concerned Citizens of McLeansville
spoke as factual and as accurate as any speaker here tonight.
And, I'd like to reiterate again for the panel and members of
the EPA and the State of North Carolina to review the statement
that he presented to you in detail and provide us with some of the
questions raised within that statement and give that careful...
that statement careful evaluation, because it is concerning
millions of dollars in savings. It also concerns the environment.
We would like to see the project move on, quickly, and a decision
be made. We would like to see the right decision be made, and we
would like to see our tax dollars be saved. One other point has
been raised on a number of occasions, tonight, I think the City
Council should be aware of it, the County Commissioners I think
said a majority of those people supporting the decision of the Ciba
Giegy Site, but a majority of the County Commissioners do not live
in the eastern sector of Greensboro, as well as the members of the
City Council. In addition, we talked about sewer service being pr°'
vided in that particular area and the needs for it. Ah- that's a
question to be debated. But, at the same time, if there was a
need I don't see how the people of Guilford County or in the eastern
part of Guilford County could afford the tax on it. I don't think
the double-standard is right when you charge people outside the
corporate limits twice the sewer service, when eighty-seven and
-------
one half (87ig%} percent of this bill is being paid for by all
of the citizens in this Country and this State. So, therefore,
that's another reason that a lot of people are not interested
in this sewer service, because they couldn't afford if it was
available. On the news tonight we talked about the County
Commissioners ah- building a water supply line to... to build
lab facilities out there. But, only two (2) people have attached
to that line. Can they afford to. I think the economics are
important. And to keep from having a delay and so we could end
this matter here in a short period of time, and not have to go
further steps ah- down the line to get the correct answers, I
would ah- ask you to review the statement that was presented.
And, I think, very factual and accurate by Mr. Rosser, and make
a sound decision on the facts that was presented by Radian Corp-
oration. Thank you.
Moderator: Thank you, Mr. Payne. Phillip J. Bissesi.
Speaker Mr. Phillip J. Bissesi: Madam Chairman, gentlemen, I
am an independent consultant engineer, I practice in the fields
water use. Ah- my opinions deal with the volume of sewage
going into the plant, and this is directly related to water
usage by our citizens in their homes and in the industrial pro-
cesses. The water use can be cut by fifty (50$) percent, without,
any change in our life-style. Specifically, I refer to the water
that eventually goes into a sanitary sewer system as wastewater
flow. Water use in homes can be cut fifty percent, t^o (2) simple
-------
remedies of showers and faucets. There are heads on the market
that cost no more than conventional heads, do a good job with
half the water. Toilets can be reduced from six (6) gallons to
three (3) gallons and still flush sanitary. Water use in industry
can be cut drastically. Engineers have changed processes to reduce
wastewater flow by ninety (901) percent, and at the same time,
reducing the flow of floatness and the load on the sewage treatment
plant, accordingly. A case in point, I reduced the wastewater
in a chrome-plating plant from eleven thousand (11,000) gallons a
day to three hundred (300) gallons a day, and did away with
(this word was indistinguishable) chrome and the
discharge. The technology is available to reduce sewage flow,
and thus, save tax dollars. I urge the City of Greensboro to set
up a more equitable sewer rate structure that will contribute tc
water conservation and re-use. I also want the best possible
sewage treatment system for our City, and wholesome drinking water
for us and our neighbors, both up-stream and downstream. Tonight
I spoke with the man from Radian, and he told me that in their
report they concluded that it is feasible to upgrade the South
Buffalo Plant. It can be made odorless. Now, by upgrading, we
mean using tertiary treatment and making it to the same standards
as a brand new plant. In other words, there is no reason why the
existing plant can't smell exactly the same as the new plant put
somewhere else. Therefore, there's no excuse to move it what-so-
ever. In realization, the tertiary treatment will solve the
pollution and odor problems, and water conservation and re-use
will solve the capacity problems. Thank you.
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Moderator: Thank you. (Applause). Mrs. Earline Clarke, A1
Lineberry. Earline Clarke, A1 Lineberry.
Speaker Mr. A1 Lineborry, Jr.: Madam Chairman, panel, I'm A1
Lineberry, Jr., I've been in Greensboro, virtually, all my life.
I have been involved with community work now for... I guess,
since I graduated from college about eight (8) years ago, and
this is the very first topic that I remember being involved
with. It's kind of appalling that we can end a war that last...
but involve the entire world, I mean World War II, in less time
than it takes us to build a metro system. We ended the largest
conflict this Country's ever seen in the Viet Nam War, and we
still can't build a metro system. I think the problem has been
pointed out to everybody here, has been pointed out tim
-------
Moderator: Thank you. (Applause). Maurice Fishman has sub-
mitted his statement for the record. Ben Matkins, Felicia
Holley, Mrs. Hattie Slalom, Mrs. Foy, John Kavanagh, D. C.
Frate (Moderator spelled this last name). After this speaker,
Mrs. Goodsby, Elizabeth Cone, and Mrs. Cameron.
Unidentified Speaker: I was wondering if I could get clarification
on ah- some figures presented by the EPA on ah- page nine (9)?
Okay. We received a letter, August 23rd, 1977, and I noticed
that was an error that should be corrected on page nine. The
figure should be thirty-three (33) million. Is that a good
figure, or is it now fifty-seven (57)? On page nine it's ah- in
the summary of the EIS Draft, or page seven (7) in the summary
sheet ve received tonight.
Unidentified Panel Speaker: We'll attempt to answer that now....
Moderator: Yeah.
Unidentified Panel Speaker: Which chapter?
Unidentified Speaker: Okay. In the beginning of the EIS
you have a summary.. On the ninth page, you have a list of ah-
descriptions of proposed actions. The third point is construction
of the new one million ($1,000,000) dollars plant. Okay. That
JEgure you stated in your letter dated August 23rd, 1977 should
be thirty-three million, three hundred and forty-five thousand
-------
($33,345,000), is that correct? Is that a good figure now, or
should it be ah- fifty-seven million ($57,000,000)?
Moderator: Okay. Mr. Howard?
Speaker Mr. Howard: Yes. I would... let me respond to that.
The thirty-three million is capital cost.
Unidentified Speaker: Okay.
Speaker Mr. Howard: The fifty-seven million is the present-
worth cost for the entire twenty (20) year period.
Unj dent ifled Speaker: Okay. Then all... then ah- taking that
figure back to Chapter Five (5), page fifty-nine (59), Taxes and
Budgeting, Direct Affects, go down to paragraph three (3).
Facilities described in the proposed action will provide suffi-
cient wastewater treatment at a cost of approximately .41* per
thousand gallons. Now, did that figure enter into this figure?
Is that where this figure came from, .41*
Speaker Mr. Howard: What page now are you talking about?
Unidentified Speaker: Okay. Chapter five, page fifty-nine,
under Taxes and Budgeting, Roman Numeral Five.
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Speaker Mr. Howard: As I understand, that involves the present-
worth cost.
Moderator: But we will clarify that in the final EIS, in case
Mr. Howard is incorrect on that. Do you have any other questions
about specific points in the EIS, sir?
Unidentified Speaker: Ah- I was just wondering what happens in
1985 or the Year 2000 or the Year 2010. It seems that ah- we're
planning for twenty (20) years, and that brings us up to 1997,
and ah- the Year 2000, the Year 2010 ah- they say the re-cycle,
re-use will economically feasible. That's only three (3) to
ten (10) years away from that design period. I don't see why
we can't spend a little more time, and we should have done this
in the past, the EPA should have stressed this, perhaps, for
this area that ah- perhaps we ought to be thinking seriously
about re-cycle, re-use, now, and not twenty years down the road.
Thank you.
Moderator: Thank you, and your name, sir, was D. C. Frate?
Is that correct? Thank you. Mrs. Goodsby, Elizabeth Cone,
and Mrs. Cameron. (Pause). R. H. Souther. Excuse me.
Speaker Ms. Elizabeth Cone: I'm Elizabeth Cone, and I live at
1901 Lafayette Avenue in Greensboro. The Guilford County Advisory
Board for Environmental Quality wishes to reaffirm its endorse-
ment of the construction of an additional waste-water treatment
-------
facility to serve Greensboro. The Board feels that Alternative
Number Three (3) is a sound Alternative. It poses no measurate
environmental or operational hazards. And would appear to serve
the projected twenty (20} year needs, adequately. Alternative
Number Four (4) would be acceptable it appears with the Board
should site reconsiderations be made. Seveial members of the
Board still consider Alternative No. 4 as the better site for
a new plant. The Board does urge that the project be undertaken
as quickly as firms and construction will allow. We are attaching
to our statement a list of errors and observations on the Draft
HIS compiled by Dr. Douglas Carroll, who is secretary for the
Board. The Board, with regard to the Draft EIS Statement was
concerned that much of the discussion was very general, and that
the attention given to the long-term impact of the new treatment
Plant seems inpropcrtionate to the lengthy attention given to
the construction phase impact. Speaking personally, I would
suggest that in the future as Alternatives are given arbitrary
identification by the number when first named, that that identi-
fication be carried throughout the entire process. And that
related drawings and tables carry the same identifier with the
suffix. I find that the great frustration not to be able to handle
and compare data on the various alternatives with the way it was
written up in detail, and it equally frustrating to make compari-
sons in the elimination alternatives process. It would seem that
if laymen are to have an effective role in the decision-making
Process that the data must be available to them xn an organized
and understandable format. The Advisory Board of Environmental
-------
Quality looks forward to seeing the completed and corrected
Environmental Impact Statement, and to action the project.
Moderator: Thank you, Ms. Cone. (Applause). We now need to
change the tapes. If you'd like to stand-up and stretch while
we change the tape. (Pause). While we're doing... I can't even
tell you anything, yet. They can't... cut me off. (End of Tape
Number One). We're ready to begin. I'm ready to begin, if I
can get a mike, upstairs. Okay. Our next speaker will be R. H.
Souther, and after Mr. Souther, Gerard Gray, Norman Humphrey,
and C. W. Harshaw. Mr. Souther.
Speaker Mr. R. H. Souther: Madam Chairman, ladies and gentlemen,
I appear as a member... here as a member of the T. Gilbert Pierson
Chapter of the National Audabon Society, which is interested in
protecting the turbulent environment and in good government; to
conserve all resources, including money by using integrity and
common sense in money spending. For the City's got to show better
physical responsibility. If it tried to save twelve ($12) to
twenty million ($20,000,000) dollars in money spending and complying
with a mandate of Congress. We are interested in more scientific
approach to abate pollution more effectively at lower cost. The
treatment of wastewater is very similar. It's based on a princi-
pal established by that eminent chemist, Louis Pasteur. It
involves three (3) things, interim mixing of food with micro-
organisms; two, supplying plenty of air; three, giving time enough
for the micros to digest the food. That principal has not been
-------
carried out at South Buffalo. And, it burns me up to hear all
these good people here tonight coining up and telling what. .. how
much they're suffered motives. I did the research on the North
Buffalo Plant at the request of the State ah- Director, who ah-
was the first State Director, has (this name was
indistinguishable), and we did a project to show that how the
effluent waste could be treated down that stream without... without
ah- pre-treatment. But, about ninety-three (93%) percent of re-
moval of effleunt. And later, twenty-one (21) month study Radian
shows ninety-three percent. What I want to say is I favor Alter-
nate Six (6), use the existing plants as the best plan as pro...
as ah- approved by Radian. But, at the same time, EPA is respect-
fully urged to arrange'for a full-scale plant demonstration grant
study to show that the South Buffalo Plant can be upgraded, while
applying the latest innovative technology, using the simple prin-
cipals of Pasteur development. That is, you've got to have plenty
of air, well mixing, and re-circulation of such. To show that the
South Buffalo Plant can be upgraded for about Wo million ($2,000,000)
dollars to treat, at an advance level, at ninety-seven (97) to
ninety-nine (995) percent efficiency, with odor problems corrected
and meet EPA and States limits, which is even better than tertiary
treatment in the proposed metro plant. The BOD was five (5) ah-...
the BOD was two (2) milligrams per liter, ammonia nitrate was
one and a half C1W. in the neK ms"° plant' the *h" Un,itS
are about eleven (11) BOD, and five (S) ammonia nitrate. This
ah- benefit from these grants
-------
could be to stop the ah- offensive odors now which are apparently
worse after the EPA and State gave the City a permit to discharge
raw sewage into the creek. This had never been done. Where did...
why didn't our State and EPA enforce the law and make the City
stop those odors. I feel really embarrassed. There's been more
research conducted in Greensboro than any city in the entire world.
Of course you know this may include the work under Dr. H. J. Batty
at Chapel Hill, but I do feel that the State and EPA should enforce
the law, and ah- stop these odors, right now. And that's why I'm
asking for an EPA grant to ah- show that it can be stopped.
Moderator: Mr. Souther, we'll have to ask you to summarize, please
sir.
Speaker Mr. R. H. Souther: Alright. I thank you. If it's
possible to save up to twenty million ($20,000,000) dollars by
further study which would amount to eighty million ($80,000,000)
dollars at (this word was indistinguishable) city
interest in twenty (20) years, or fifteen hundred ($1,500) dollar5
per family, is it not the best way to proceed with this group's
responsibility in reflecting great credit to City, State and EPA*
If a new aggregate secondary treatment plant can be upgraded to
treat at an advanced level, ah- would this not be more cost-
effectively, and would not this ah- information be of great value
to EPA technology manuals and set an example for other areas to
achieve advance treatment at such low cost. It's a challenge to
EPA to enforce the mandate of Congress to provide the Nation wit'1
the highest quality of water at the lowest cost. Thank you.
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Moderator: Thank you so much, sir. (Applause). Mr. Gray,
Mr. or Mrs. Norman Humphrey, E. Victor Pruitt, James Mclnler,
Mrs. W. M. Black. Stop me, please, if I call your name, come
forward. Norma Westmoreland, Larry Watson. After Mr. Watson,
we have Mr. Stephens, Thomas Isley, and William McLoyd. Yes
sir.
Sn.»w Mr. I.arrv Watson: My name is Larry Watson, I'm a resi-
dent of McLeansville, have been for approximately eighteen (18)
months. I moved to McLeansville from the City of Greensboro,
and I like to consider it the happiest day of my life. I got
, . nT,,:Hnns I ®ot out of a high rate of crime,
out of overcrowded conditions, a a
... _j t dnn't ever want back in them. If
I got out o£ high taxeb, and I
, . • «.u-j e Krtnk wes political motivate*-!
I could think that nothing m this oook was p
it I would like to think that the
I might take time to read it.
• -»e much as they like to talk. There's
City Fathers like to listen as much as tn y
erases any County resident, and
one word, or one sentence that enrag
tu , • * ritv Limits to take in his land that he works,
that's expansion of City Limits
in the Citv. I would like to
that he pays for, just like peop
think that the relocation and the construction of metro sewage
would not prompt the City of Greensboro to creep, Irte a cancer,
^ • r-itv taxes, to bring City slums, to
into McLeansville to bring City
bring City sewage, to bring what I personally fled from a year
and a half ago. I. personally, wouZd fight to go into the law
t t little five (5) acres, I don't have a lg
to keep my property, my little
o I wort in the City.... (Laughter),
farm, I don't even have a farm,
a t finure I'm smarter than some. I think
®ut I live in the County, 1 fx8
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I made a good move going to the County. I cut my tax rate by
seventy-five (75%) percent. I live in a fifty thousand ($50,000)
dollar home, and I pay one-fourth (J$) the taxes I did in a twenty-
five thousand ($25,000) dollar home in the City. I want to keep
it that way. I don't want the City to take McLeansville and turn
it into what many parts of Greensboro are now. I sympathize
strongly with the residents of eastern Greensboro. Buffalo Creek
stinks. I pass it every morning going to work. My wife and I
have to roll-up the windows. It stinks, bad. But, would a City
fire truck come to the County and fight a fire. No. They'd
stop at i_he city limits and let it burn. Would a City policeman
come to the County. Ah- he'd stop at the city limits and let
what happened, happen. I say let the City keep their problems
within the City, because ic s been proven they're more, economically'
but they can take care of their sewage problems by expansion and
by re-building present sites. Thank you.
Moderator: Thank you. (Applause). Mr. Stephens, Thomas Isley,
W. McLoyd who lives on Mapp Street, Phillip McAlpin, Merritt A.
Donn.ll, Marie Evans, Mrs. Moore, Cjarles Robinson, W. T. Gibbs,
Jr., George E. Carr, Jr., Mrs. Ruth V. Lemmon. Excuse oe, I'm
sorry, sir. Would you identify yourself.
Speaker Mr, George Carr: T'm T .. .
-c a i in George Larr, I live m Greensboro
at 1810 Huntington Road. I believe in The Bm(j ^ ^ the
last shall be £irst and the firs(. ^ ^ ^ ^ ^ ^
very little what to all that's been said, as your... as your
hundred and fifteenth (115th) speaker it's awfully hard to ask
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t0 (this word was indistinguishable). But I
would like to reiterate that the conditions decaying stagnation
(this portion was inaudible as speaker was standing too close
to the microphone and words were jumbled together) by a sizable
number of Greensboro's population, and being comparative the
construction of a now waste treatment facility. Ah- my personal
preferance would be Plan Four (4), although ah- I can see some
validity and merit to the adoption of Plan Three (3). I ah-
would like to suggest, most importantly, that a decision be
made and that it be made, expeditiously. Ah- above all, please
do not give us years more of study. I think that a decision
must be made, and it must be made, soon. With your help we can
ah- assist in helping Greensboro to get moving, again. And I
thank you for your patience in listening to all of us, tonight.
Moderator: Thank you Mr. Carr for your patience. (Applause).
Mrs. Ruth Lemmon, Frenchie Lee Lemmon. That concludes the list
°f registered speakers. Is there anyone else who is not... who
lid not register to speak that wishes to speak at this time?
(Pause). Thank you all for your testimony this evening.
you wish to speak, please mam?
^identified Speaker: Yes mam.
Aerator: Alright.
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Unidentified Speaker: Members of the ah-
Moderator: Would you identify yourself, please?
Speaker Ms. Rosie Carr: I'm Rosie Carr, and I live in... on
Blueberry Lane. That's down there at South... you know, close
to the exposure plant. This was the first house built down
there on Blueberry Lane. We were brought down there to pick-
out a lot. And I know it use to be a golf course down there,
and I asked about the odor, because it was an odor, then. And
they told us it was no odor. And the houses were built. We had...
we picked the lot, picked the house we wanted built. The house
was built. And we were so tickled because we had never had a
house before of our own. And I was running down there early in
the morning, in the evenings and all times of day. And, no odor.
But, time the houses were built and the people nioved in, the odor
started back up. So, I would like to know why the City sold
these lots to the real estate people, and it was sold to the people*
They put them down there . They knew all the time that stuff was
down there, but we did not. (Applause). We did not know it was
down there. Because I know the odor use to be down there when it
was a golf course, but I didn't even know the reason the odor was
there to start with. But, I asked the man, and he said it was no
odor. And, I'm telling you, I am sixty-seven (67) years old, and
I can not be running from pillar to post, and I don't have no money
no more, because you never was paid but so much to start with. It'®
just a shame before God the way you people treat us. It's just &
shame before God. And I don't know whether you know it, but I'm
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gonna tell you, if you don't change your way of living, you're
not gonna make it in. You'll make it in, but it won't be where
God is. Thank you.
Moderator: Thank you, mam. (Applause). Yes sir. Is this in
rebuttal, sir? It's hard for me to see if you've spoken before,
would you identify yourself?
Speaker Mr. Dan Kerns: I am Dan Kerns, of'Route #1, McLeansville.
I have spoken, but I have one short question, for the record.
Moderator: Yes sir.
Speaker Mr. Dan Kerns: I would like a clarification on the pre-
treatment site at the South Buffalo Plant, to be constructed when
aplant in McLeansville is built. Thank you.
Moderator: Thank you. I want to thank you all for your testimony
this evening. These comments will be carefully considered and
responded.to in the Final Environmental Impact Statement. The
comments received tonight should be a major determining factor, in
the project alternative to be recommended for funding, as the EPA
and the State place great importance on the desires of the community.
Let me remind you that the record will remain open for an additional
fifteen (15) days, if you wish to submit further written comment.
The Final EIS will take a minimum of sixty (60) days to complete.
Upon completion, the document will be filed with the Council on
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Environmental Quality and made available to the public. Those
of you who have commented tonight or submit comments, will
receive a copy of the Final Environmental Impact Statement.
The U. S. Environmental Protection Agency and the State of North
Carolina wish to thank you for attending this Public Hearing
and participating in this process. Good evening.
The Environmental Protection Agency Public Hearing Transcript
on the Greensboro/Guilford County Wastewater Treatment System,
Greensboro, North.Carolina, Thursday, September 1, 1977, closed
Friday, September 16, 1977. Total number of Transcript pages, 74;
total number of attachments submitted, 66.
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ATTACHMENTS
GREENSBORO/GUILFORD COUNTY
WASTE-WATER TREATMENT SYSTEM
September 1, 1977
Greensboro, North Carolina
Total Number of Pages - 66^
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3
September 1, 1977
Statement for "Metro" Public Hearing, Greensboro, North Carolina
Approved by Guilford County Advisory Board for Environmental Quality
on August 31, 1977
The Guilford County Advisory Board for Environmental Quality wishes to
reaffirm its endorsement of the construction of an additional wastev/ater
treatment facility to serve Greensboro.
The Board feels that Alternative Number 3 is a sound alternative. It
poses no major environmental or operational hazards and would appear to
serve the projected 20-year needs adequately.
Alternative No. 4 would be acceptable in the opinion of the Board,
should site reconsiderations be made. Several members of the Board
still consider Alternative No. 4 as the better site for a new plant.
The Board does urge that the project be undertaken as quickly as
funds and construction will allow.
>i I attaching to our statement a list of errors and observations
on theiE. I. S. compiled by Or. Douglas Carroll, Secretary tc the Boird,
for you>* records. r
A
The Board with regard to theAE. I. S. statement was concerned that
n,uch of the discussion is very general and that the attention given to
the 1 ong term impact of the new' treatment plant seems proportionate
to the lengthy attention given to the construction phaseimpccT
Speaking personally, I would suggest that in ^future,
given arbitrary identification by number when first JJawinqs
identification be Carried throughout the entire process and re ated drawings
and tables carry that same identifier with a suffix. 4JJ"Jattves
frustration not to be able to handily compare data on the jarious alternatives
^th the one which was written up in detail - and JJJ JJ It would
comparisons during the elimination of alteraat1V®* p. • ,' m^ina
seem that if laymen are to have an effectlve,fole.inaJh^ JIS and
Process, that the data must be available to them in an organized and
understandable format.
+u The Advisory Board of Environmental Quality looks forward to seeing
^e completed and corrected Environmental Impact Statement
n the project.
Elizabeth Cone
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4
AFFILIATED CONSULTANTS, ENGINEERS
915 WINTERLOCHEN DRIVE, GREENSBORO, NC 27410 919/294-1610
METRO WASTEWATER TREATMENT PLANT
Opinion Statement - September 1, 1977
by Philip J. Bisesi, P. E.
As an engineer engaged in water use system design, my opinions deal with
the volume of sewage going into the plant; this'is directly related to the
water "usage by our citizens in their homes and in industrial processes.
Water use can be cut by 50% without any change in our lifestyles. Specifi-
caly, I refer to the water rhat eventually goes into our sanitary sewer
system as "wastewater flow". Water use in homes can be cut by 50%. Two
simple remedies are in showers and faucets. (There are heads on the market
that do a better job with half the water normally used and cost little, if
any extra), and in toilets("Water-Saver" toilets cut the water use from six
gallons to three gallons, cost no more, and are just as sanitary).
Water use in industry can be cut drastically. Engineers have chanaed proces-
ses to reduce waste water flow by 90% and at the same time reduced'the flow
of pollutants and the load on the sewage treatment plant accordingly.
The technology is available to reduce sewage flow and thus save tax dollars.
I urge the city of Greensboro to set up a more equitable sewer rate structure
that will contribute to water conservation and reuse. I also want the best
possible sewage treatment system for our city and 'wholesome drinking water
for us and our neighbors both upstream and downstream.
HANICAl / ELECTRICAL ENGINEERING • ENERGY Awn
tlNlKUT AND RtSOURCES USE AND CONSERVATION
>IES • DESICN • TESTINC • LITE CYCLE COSTING . „
(-usriNo • 01 CRATING AND MAINTFN vsrr rn\.ci hw'
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5
¦' '' ' ¦ 1 1 •¦'j'-.C 'i ' M Al. 11| y
MEMORANDU H
TO: Metro E.I.S. Subcommittee
FROM: G. Douglas Carroll, Secretary
RE: Metro E.I.S. Review
DATE: August 25, 1977
Attached are the comments of the Planning Department on the
Metro E.I.S. The inclusion of data for only one MeUo site
makes evaluation of this proposed treatment facility diffi-
cult. A preferable alternative would be to present data on
all sites to facilitate comparative analysis. With the
present E.I.S. document, the staff can only respond to minor
errors; whereas, in an analysis of all the sites long-range
development patterns and trends could be predicted and com-
pared to County growth management policies. Additionally,
much of the discussion is general and not substantive. The
attached comments list errors and observations on the E.I.S.
GDC/lte
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6
P. l(l-a): The predominant winds in Greensboro are southwesterly
and northeasterly (See Annual Wind Rose, p. II-5).
P. II-7: Records relating to odor complaints generated by South
Oil Company. In 1975, the Health Department was
actively involved in correcting odor emissions and il-
legal stream discharge.
P. II-7: For greater accuracy the sentence should read: "The
South Buffalo Plant was built prior to the residential
subdivisions which exist adjacent to it today."
P. 11-17: Maximum and minimum elevations are respectively, +/-
1,000 feet, and +/- 414 feet.
Pp. 11-20-25: Soils - The soils section contains statements that are
so general that they have little or no value. The
statements are accurate but only because they are so
vague.
P. 11-29: Hydrology - On page 11-29 the report states "it was
estimated that about 33 million gallons per day (MGD)
of groundwater may be available. This estimate is
probably conservative." This estimate is probably not
conservative which means that the estimate of 145 MGD
and 160 to ]95 MGD are extremely high. Th^ou^h July
of 1977 Guilford County had only recorded 12 inches of
rainfall so that we were not even getting 33 million
gallons per day MGD of groundwater.
P. 11-30: On page 11-30 - "Where septic tank density is not too
great, the thick soils and saprolite in most areas
should serve to renovate the septic tank effluent quite
well before it reaches any aquifer systems."
This statement is not true because the saprolite is
cracked which would serve not to renovate the septic
tank effluent.
P. 11-30 "Most of the County is considered to have about the same
potential for site specific'problems and ground-water
degradation from septic tanks."
This statement is not accurate.
P. 11-94:
There is no mention of what assumptions were made in the
population projections concerning birth, death, and mi-
gration rates. These are important determinants in future
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7
population growth. For example, the Creensboro Depart-
ment of Planning and Community Development prefers to
use population projections based on a 1960-1970 migration
rate whereas the Guilford County Planning Department uses
a 1970-1974 migration rate. The resulting projections
differ greatly. Section II. B. l.a. DEM0GRAP5TY ANT) rrn-
NOMICS TECHNICAL REFERENCE DOCUMENT. A statement is made
that a 1975 breakdown by census tract, which was used to
prepare 1975 population within the study area by subbasin
was prepared by the National Planning Data Corporation.
The 1975 total County estimate computed by NPDC was ap-
proximately 8000 persons higher than the current N. C.
Office of State Planning and U. S. Bureau of the Census
Guilford County estimate available. Efforts should be
made to use the latest "official" figures while keeping
the percentage distribution by census tract available
from NPDC.
11-110: The title should read: Partial Listing of Guilford Country
Land Use Goals and Policies.
11-111: Figures 11-21 - Future land use is accurate. However, the
transition area off 220 around Lake Higgins as developing
by 2000 and the area between 1-85 and Forest Oaks is
questionable. It depends on whether these areas will be
classified as' developed according to the proposed State
Land Classification system or by another guideline.
P TT
• H-124: The discussion of migrants entering Guilford County and
the Carolina Piedmont should mention the English Quakers
by name. The early Quakers settled in the western portion
of the County and are known mainly for the founding of
Jamestown and Guilford College.
P T
II-124: In the last paragraph, should read: "Randolph" and "Nathanael."
*1-125: There are three National Register sites in the study area:
Blandwood, the Jefferson Standard Building, and the Bura-
pass-Troy House.
Description of Bumpass-Troy House taken from the publication
An Inventory of Historic Architecture: Greensboro, N. C.
Built for the Reverend Sidney Bumpass, founder of the
Methodist newspaper, "The Weekly Message.". Publication
was continued in the house, by his wife, until 1872.
The 2-story brick Greek Revival style house is one of. the
only 16 prc-1879 buildings remaining in Greensboro.
(Sec attached lists and map.)
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8
NATIONAL REGISTER STUDY LIST PROPERTIES
(Within Study Area)
DATE APPROVER
PROPERTY AND LOCATION FOR STUDY*
1. Charles Benbow House, Oak Ridge (B-3) 3-17-76
2. Low House, Whitsett vicinity (L-7) 3-17-76
3. Oak Ridge Institute, Oak Ridge (B-3) 3-17-76
4. "Old Mill of GuilfordOak Ridge (B-4) 3-17-76
5. Thomas Scott House, N. Greensboro vicinity (F-3) 3-17-76
6. Isaac Thacker House, Browns Summit vicinity (H-2) 3-17-76
7. Robert Thompson House, N. Greensboro vicinity (G-3) 3-17-76
8. West House, N. Greensboro vicinity (F-3) 3-17-76
9. Colson-Shaw Log House, Summerfield vicinity (E-3) 5-12-77
10. Reuban Starbuck House, Colfax vicinity (A-5) 5-12-77
11. Jesse Benbow House, Oak Ridge vicinity (B-3) 5-12-77
12. SummerfieId Historic District (D-2) 5-12-77
13. Ingles-Kraus-Hodge House, Whitsett vicinity (L-7) 5-12-77
14. Ward House, E. Greensboro vicinity (G-6) 5-12-77
15. W. H. Paisley House, E. Greensboro vicinity (G-6) 5-12-77
16. Midway Diner, Sedalia vicinity (K-7) 5-12-77
17. Lewis Lyndon Hobbs House, Guilford College vie. (D-6) 5-12-77
18. Palmer Memorial Institute, Sedalia (K-7) 5-12-77
The Historic Sites Inventory of Guilford County was completed in June,
1977. Over 400 sites were listed as "historically or architecturally
significant."
Approximately 200 inventoried sites are in the study area in addition
Co the ones listed above.
~North Carolina Department of Cultural Resources.
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9
GREENSBORO NATIONAL REGISTER STUDY LIST PROPERTIES
PROPERTY
1. Buffalo Presbyterian Church
2. Caldwell Log College Sice
3. Carnegie Negro Library
4. William Fields House
5. Foust Building, UNC-G
-6. - Green Hill Cemetery Office
7. Greensboro College Main Building
8.. Greensboro Motor Co. and Buick Motor Co. Showrooms
9. Greensboro Passenger Depot (Railroad)
10. Guilford Courthouse National Military Park
11. Iceland House
12. S. H. Kress Building
13. 195-201 Lyndon Street Townshouse
14. McNairy House
15. Murphy House
16. Pomona Terra Cotta Manufacturing Company
17. Proximity Cotton Mill
18- Sherwood House
19. South Elm'Street Historic District
United Methodist Church
*1. Wafco Mills
22' N.H.D. Wilson House
21. F. W. Woolworth Building
22* Guilford County Government Complex
DATE APPROVED
FOR STUDY*
3-17-76
3-17-76
3-17-76
3-17-76
3-17-76
3-17-76
5-6-75
3-17-76
9-30-75
Pending
3-17-76
9-30-75
3-17-76
9-19-69
3-17-76
9-30-75
9-19-74
3-17-76
3-17-76
3-17-76
3-17-76
3-17-76
3-17-76
5-12-77
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FIGURE 11-22
MAJOR HISTORICAL SITES IN THE STUDY AREA
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11
P. II-125
P. 11-125
P. 11-127
P. H-127
129:
P. V-4 - 7:
P- V-5:
P. V-5:
P. V-50:
P. V-54-57:
V-62,63:
Paragraph four should read: "Nathanael Greene's."
Last paragraph should read: "Ac least 47 structures..."
Discussion of proposed Historic Districts should include
the Summerfield Historic District.
6. Transportation - In the transportation section the
consequences of a new wastewater treatment or the growth
that would occur due to the plant is not considered.
Would locating the plant in McLeansv.ille increase the
attractiveness of a beltline 'in that section of the
County?
Concerning the discussion of ocio-r,..what population and
other land uses are within tn.e. impacted area near Mc-
Leans ville?
There is no quantification "hcxe.
impacted?
How people- will be
No mention or evaluation is. made* of people who do not
identify the plant as a major p.dor sfcurce but would
identify it as significant nevetrth-eless.
All through this study, little 3""oo merit ion is made of
the impacts on senior citizens in genira1, and the
Evergreens Nursing Home (and PtJrer' nursing'homes ?)
particular
in
Indirect Effects-"on Demography and Economics
Ascribes'to thecalternatiVe-the ability to open up area
east of Greensboro to .development and to take develop-
ment pressures off of north and northwest. Not true!
Only the sewer line extension policies of Guilford County
and Greensboro can do this*. Ii one examines the current
situation, it can be seen 'tnat cwo STF in eastern Greens-
boro did nothing to lessefv development pressures in the
north and northw^Sjt and encourage ¦'development east of
Greensboro.
2. If ttfe. Soyffh Buffalo plant' 'c'feaSes - operation the zon-
ing of that land may or may ndt ciiAnze. from industrial.
Given past trends, leapfrogging .olopment will occur
in eastern Guilford'County unless there is a lessening
of the stigma attached to black-occupied areas.
6. Transportation - The plant will attract population
growth into the South Buffalo area which will increase
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12
the attractiveness of Hufftne Mill Road as a major
connector.
The South Buffalo site will make the proposed beltline
more attractive as growth becomes a reality.
p. VI-2: The statement that odor complaints are minimal is
grossly inaccurate.
P. VI-5: "July, 1976" is the correct date of adoption of the
Land Use Goals and Policies.
P. B-5: Bibliography footnote should read "Tax Department" in-
stead of "Finance Department," (GU-106).
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13
/<^d^
Cn/
METRO PLANT
After careful consideration of all fvarious methods, alternatives
and social aspects available to th
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& pac-ZcYS
There are environmental ^jimifiiratians. relating to Alternate 3
which have not been addressed adequately in the draft Environ-
ment Impact Statement:
#1. Much of the discussion in the E.I.S. was centered on the
short-term effect of the construction of the sewer treat-
ment facility. A more important focus would be the analy-
sis of the long-term environmental effects of the existence
of a treatment facility at site 3.
#2. The E.I.S. states that odor complaints are minimal; yet, it
also states that no records are kept of odor complaints.
How can this be?
#3. The residents of .eastern Guilford County have been assured
by Greensboro's decision-makers that there would be no odor
problem with the new Metro Treatment facility. However, the
E.I.S. again states that the technology is not available to
prevent odor pollution. If Greensboro continues to assure
us that there will be no odor problems, then the E.P.A.
should require a performance bond so that owners can be com-
pensated for the devaluation of their property by odor pol-
lution.
#4. The E.I.S. included the possibility that the South Buffalo
treatment plant will remain in operation so that it can
serve as a preclorification facility to reduce the odor po-
tential from septic conditions at the outfall. Nevertheless,
the document was vague about whether this would in fact be a
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IS
realistic possibility. It should be made clear to the
citizens as to whether this will in fact be part of the
anticipated treatment operatidn.
#5. The development of site 3 versus the upgrading of North and
South Buffalo treatment plants^has the added liability of
disrupting the flora and fauna habitats along South Buffalo
Creek. In an urbanizing area the streams and flood plains
are critically important in the maintenance of a diversity
of flora and fauna.
#6. The social impact of the present South Buffalo treatment
facility is significant only because the perimeter area
around the treatment facility was encroached by subdivisions.
The facility was there first; the residential use followed.
The community of McLeansville and the residents of eastern
Guilford County established their homes in an area that would
afford the social and environmental that would be
conducive to rearing families. Now, the City of Greensboro
proposed to come after the fact of our existence as a com-
munity, after the fact of the construction of our homes and
the establishment of our families and to invade our rural-
suburban way of life with a sewer treatment facility. Just
because the facility will only d.islocate three families is
no reason to minimize its significance on the corporate
populqHon of eastern Guilford County. It will adversely af-
fect us on anyone's standards.
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16
RFD 6
l6l(.-20 Selkirk Drive
Greensboro, North Carolina 271;05
May 1+, 1976
Mr. G. Paiaon, Chairman
Guilford County- Board of Comrairjclonorc,
Guilford'County'Offico Building'
Groon^boro 9 Carolina
Doar Mr. Faiaon:
For nearly three-years I have lived at the abovo
address, uhich ia near Younsa Mill Road and Interstate
Highway 05. During this-time, I havo frequently been
sub joctod to an unpleasant odor apparently omanatinr
fros Buffalo Creek. ¦ 7hia. odor in'ofton readily-discer-
nible as one drives clonr; Interstate Highway 85 in the
vicinity of Loa Street. It in also diacerniblo in
much of the residential area fioutheaat of Greonrboro.
I an certain that boniplaints have boon voiced ovan
tho years concerning this matter. I do not know what
action if any feae been taken, to rectify; the situation.
It-appears--that tho aewago treatment facility hoar
hact Leo Street is die charging effluent into Buffalo
J0*?11* °f adoquatoly-. degraded. I aw
cei—in that Buffalo Creek j.a- a'-breeding place-for-somo
undorsira lo orsanisna. I ©von question' whother :ho air
In Uno area la healthy
as a. resident and' taxpayer.-or'Guilford' County, I
desire to learn tho-true situation and what action ia
in progress->to correcti.Mt,
sSinceroly#
H.. A. Collins
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17
STATEMENT OF: Forrest E. Campbell
Vice Chairman
Board of County Commissioners
September 1, 1977
I come to you representing the voice of the majority of our
County Commissioners on the issue of the proposed Metro Site.
Guilford County government, as well as other officially
sanctioned agencies, has repeatedly endorsed the Metro Project
and its location at the confluence site. This includes the
Positive sentiments of our "Environmental Committee." The plans
f°r this 465-acre site present in our minds the least expensive
Plan which most fully accomplishes the objectives and goals estab-
lished for wastewater management for the Greensboro-Guilford area.
also poses the least permanent affects on people, plant, and
ajUmal life.
We continue to express the urgency of the project. ihis
UrSency is net only in view of the growth designes of the City of
^se.nsboro, but those county areas that will be developing under
a Planned program. From the standpoint of county government,
8l,°wth can be more efficiently directed by our policies which
delude land-use plans, as well as water and sewer service areas.
M°st of Greensboro's industrial development land is located in the
S°"th Buffalo drainage basin. The new Metro plant would provide
opacity service for present and future industries, as well as
the Residential population. The Metro plan would also make gravity
Service available to an additional 35 square miles in northeast
^Iford County.
Planning and cooperation on a fully regional basis has been
^aiised between the county and city since the 1965 Water and
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18
- 2 -
Sewer agreement, which, by the way, was the first of its kind
in North Carolina. Looking at the whole of our area, we are in
further agreement with the City of Greensboro that the Ciba-Geigy
site would be an operable location. While it does not meet our
needs as completely as the confluence site, we could accomplish
most ends within its confines.
We regret that any persons may be adversely affected by the
Metro Plan. The delays already experienced has had overwhelming
adverse effects on all citizens of Guilford County - not only
those in need of the service, but the increased costs must also
be considered. The number of people adversely affected is approx-
imately the same number in both the confluence and Ciba-Geigy sites.
The confluence site has approximately 1,800 persons living within
two miles of the proposed site, while the Ciba-Geigy site has 90
persons living within 3,000 feet of the proposed site. You can
compare this with the South Buffalo site which has approximately
25>000 persons living within two miles of the plant, or 3>200
living within 3>000 feet of the plant. The Ciba-Geigy site would
serve about 27 more square miles and would provide adequate land
for future expansion, plus providing a buffer area.
On behalf of the majority of the Board of County Commissioners,
I would like to urge that the decision-making on this project be
expedited, not only because of the pressing area needs, but because
of the rapidly escalating project costs.
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19
Statement by
Senator Robert Morgan
Thursday, September 1, 1977
Opinions that differ are part of the American way. In the
course of debate, some such differences lead to sharp dis-
agreement and controversy.
At the end of this process, however, after a full hearing
and redress of grievances, our system calls for a resolution.
In the case at hand, it seems that we must very soon reach a
decision, and move forward with this project.
Some eight years ago, the City of Greensboro launched an
effort to improve its waste treatment facilities. More than
100 wastewater treatment alternatives have been considered
and a number of Public Hearings have been held. In June of
this year a proposed action was selected.
On July 12, 1977, I directed a letter to Mr. Douglas M.
Costle, Administrator of the Environmental Protection Agency,
in which I asked several questions about this proposal focus-
ing on my concerns for the most "cost effective" plan to
solve the problem. (I might add that I often direct such
questions to a number of our Federal agencies. I believe
this to be a proper excercise of my responsibilities to our
taxpayers and also an appropriate way to gain the background
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20
Page 2
Senator Morgan's Statement
information which I need.)
In a letter to me, dated August 10, 1977, Mr. Costle answer-
ed my questions in a way to suggest support of the proposed
action. I also received a letter, dated August 9, 1977, from
the Honorable E. S. Mclvin, Mayor of the City of Greensboro
in which further explanation was given.
In addition to these letters, I have received a great num-
ber of letters from interested citizens in the Greensboro and
Guilford County area. These ietters oppress both favorable
and unfavorable viev/s. I respect the views expressed and
also the citizens' desire to be heard.
This is a big project, expected to cost some $33 Million. I
can appreciate the efforts of all concerned in studying the
matter fully and in giving all interested citizens an oppor'
tunity to be heard,
At the end of this Public Hearing, a further period will be
open for additional comments. Then, the Final Environmental
Impact Statement will be prepared.
It is my hope that all parties involved and concerned will
then work together to move this project along to completion
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21
Page 3
Senator Morgan's Statement
September 1, 1977
without further delay. In view of the fact that it is number
one on the. priority list in North Carolina, I believe it de-c
serves the full and continuing effort of everyone.
In addition to my concern for this particular project, I want
to express my concern for the entire 201 Facilities Plan pro-
9ram in North Carolina. Public Law 92-500 is a complex piece
of legislation and requires thorough planning and deliberate
review of all actions. However, some projects
*5=31 are experiencing long and frustrating delays in getting
Step Three, which is the Construction Phase. In-this fis-
C^1 year, which ends on September 30, we are dangerously close
losing construction funds allocated to North Carolina be-
°ause we may be unable to move projects into Step Three".
April of this year, North Carolina had $69.6 Million in
such. funds to be obligated before September 30. My office was
a^vised a few days ago that $5 Million to $6 Million remain
^ this fund with only one month left in this fiscal year.
money not obligated by September 30 will.be lost for pro-
jects in our state.
points up the overall urgency to get on with our 201
acilities Plan program in North Carolina,
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22
JOINT STATEMENT OF THE N.A.A.C.P. £> G.C.A.
TO THE E.P.A.
ON THE
GREENSBORO, GUILFORD COUNTY, NORTH CAROLINA
201 WASTEWATER TREATMENT SYSTEM PROJECT
NUMBERS C37037601 & C37036901
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23
GCA. &- NAACP are making this statement on behalf of the approximately
41,500 Blacks living in the North and South Buffalo Creek sub basins.
It is our position that environmental considerations are important only
becguse environmental factors affect the quality of life of human beings living
(he environment. For th at. reason we feel that one of the most important
Cor>siderations is the number of people who. will be directly affected by the place-
^6rit of {he wastewater treatment plant. There are at least 25,000 people
',Vln9 within 2 miles of the south buffalo plant, all of whom have been adversely
c,ed under normal atmospheric conditions due to the conditions under which
!he
P»ant has been operated.
The wastewater treatment plant should be placed at the confluence of the
and South Buffalo Creeks .because:
k*
s*^5H!ation
the McLeansville-confluence site only 1,800 people live within two miles
0/
ne Proposed site. While almost 26,000 people ffve within two miles of the
Slir>3 South Buffalo Plant. Three Thousand i wo Hundred(3,200) of these
p,e live within 3,000 feet of the existing South Buffalo Treatment Plant. The
°Pu|3tion at the confluence or North and South Buffalo is only expected to in-
Sa
5e 497 people by the year 2,000. The population at the E.I.S. site.is
V
®ctecJ to increase to 2,000 people per square mile by the year 2,000. (E.I .S.
* .
'00).
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24
Racial Impact
The Black population ol Greensboro is concentrated within two miles of the
existing North and South Buffalo Plants. Because of the refusal to sell to
Blacks in other parts of the City, Blacks desiring to purchase homes, could
only buy in the areas of South Buffalo Creek until the mid 1960 when the area
near the North Buffalo Treatment Plant was opened to Blacks.
It was not until long after the effective date of the Fair Housing -A-ct in
1970, that Blacks were free to buy homes in other areas, Many of the residents
living near the plants cannot sell out and move because prospective buyers are
unwilling to ouy Because of their knowledge of the odor problem in the areas.
Schools
There are six schools within a mile and a half of the existing South
Buffalo site. Four of these schools are elementary schools. One elementary
school is located within 3,000 feet of the existing site.
Students and teachers from all over the city are therefore affected by the
odors and emissions from the existing site.
.Advantages to McL-eansville Residents.
Guilford County soil is not well suited to use of septic tanks and some
areas are already over saturated with septic tanks(E.).S. P. 11 3 & II 30/.
Possibly well before the year 2,000 county residents including McLeansville
residents may be expected to experience well water contamination from septic
tanks in the absence of a central sewage system. AJso, because of the low
permeability of the soil, sewage may be expected to seap to the surface in existing
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25
s®P*ic tank systems causing odors and disease.
The confluence site is downstream from McLeansville and would provide
Cavity fiow access to the treatment plant. The South Buffalo, North Buffalo
9r)d the E.I.S. sites are upstream from McLeansville and would require
e*PGncive construction, replacement, maintenance, fuel cost and pumping stations.
^^Sntages to East Guilford County.
There have been numerous complaints from residents of east Guilford
£
0uhty concerning the rapid growth and land value increases - in western Guilford
C°unty while little growth and land value increases have occurred in east
Gilford County. One of the important impediments to growth in east Guilford
'® 'he lack of sewage disposal facilities. West Guilford Oounty is upstream from
south buffalo plant and gravity flow to the plant is economical. East Guilford
Is downstream from bctn the 1*4Oi hi aiiCi *-^ouln Buuctlo plsnls and there—
'0r>e not easily accessible.
If the plant', is built at the confluence site, vast new areas of East Guilford
^ounty will be easily developed, clearing the way for new residential areas as
as industrial.areas. Such development will create nevy, jobs and improved
'iv>ng standards for ail of Guilford County as well as increase property values in
•**st Guilford.
e.i;s.
If the plant is built at the/site, an important part of Guilford County
v(.McL.eansv|||ej Wjjj still experience slow growth due to the lack of economical
SeWage disposal facilities since McL-eansvilte will be down stream from that site,
^irnmary
The Black! residents of South East Greensboro have been plagued with the
0ffensive odors of the South Buffalo Plant for a quarter of a century. it is unfa;r
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26
for the residents of Southeast Greensboro u«
. , . , . ... sholdor this burden alone. 1
,s the time to build a new plant at the COnfI
Southeast Greensboro reliet, a||ow Gr^ 9'VC lhe resid
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27
WIfY TliS GREENSBORO METRO WATER TREATMENT
PUNT SHOULD NOT BE LOCATED AT CLAPP FARM SITE
A. History of Site
Current Land Use
C. Family Dependence on Agriculture
D. Landowners Opposition
Prepared by*
John G. Clapp, Jr.
fioute 6, Bex k6$B
Qremeboro, N, C,
August 15, 1977
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28
History of Site
The Clapp Farm Site (Alternative 2 in EPA Environmental
Impact Statement 904/9-77-018) contains land purchased on August
19, 18^5 by Peter Clapp, great-grandfather of John, Marvin, and
David, current land owners of property at this site location.
A copy of the original deed is attached.
The land v/as purchased for farming in 18^5 and has been
farmed continuously by the Clapp family. Tlt'tha *time of pur-
chase the City of Greensboro consisted of only one square rnile^^".
In fact, Greensboro didn't even have a water system until 1887 >
forty-two years after the .Clapp land was purchased.
In 19751 J- Garland Clapp, grzndson cf Peter Clapp, v/as
honored by the State of North Carolina as one of 13 Guilford
County owners for having i'arm land that has been in the same
family for over one hundred years. Documentation of this
recognition follows.
(l) Arnett, E. S. 1955» Greensboro, North Carolina.
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'29 (bj
PJ& £&?/> ~ /S>lJ:>
ry%L<, y^/^lc^puj /???/a>L
^ ytfri%xyvtj
<£&/u^t-t/?/sZtof do ^ts**K. Cyi. .£{ js&/&C*y££~~
'trf o*7 / yry^ : j
„ ' > y' ^, s&Ar^J~i*s OcA^'p /te* Aoc?,?#*xAC~ i
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^CjtrA^j/*&> * /&cJm/o «. -^k> ss&y&u.ij.
—Xtsu~^"%* A ^C0? '(WtA! yfy^:t^O '••\> u •
u*st **< -A ™/£?4£#'*:'u
^ /0//j[js£t ~7%~ 0 a*u.*,• ,•i0/sfr S'f rftJf&y /07(st'i*J & estij /W^c.
-------
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'9-'-- -<1:5}^
tell
'-$¦'1*.- * £i >K
A
4« V i.
•%%. V-5
v%^ hl$
r&p a\><
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jrf |iadl) Caralma
the State Department of Agriculture and the State Fair
take great pleasure in presenting this certificate to
John Gaftfand Ctapp
as the owner/owners of a farm which has remained in his or her family for one hundred
years or more, lending to the ficp heritage of this great State.
(&£ntur]i 3Ftirm ©toaersinn Certificate
M 1
¦'1 -¥M
• if-' +. .
0i\ £? m
''M
J# J If
' '^.'7
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-4
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Ul
LIImQ |% . V *
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32
Sunday, September 21,1975
Governor W. Kerr Scott Building
Registrciicn
Lunc! lees"!
Master of Ceremonies
WallyAusley,
Vice President-General Manager and Farm Director
WPTF
Invocation
Dr. Albert Edvyards, Pastor
First Presbyterian Church
Recognition of Guests
WallyAusley
Special Guosl
The Honorable Doyle Connor
Florida Commissioner of Agriculture
Recognition of Century Farm F utiniliwS
The Honorable James A. Graham
North Carolina Commissioner of Agriculture
Entertainment
Jerry Clower, Humorist
Adjourn
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33
In Honor of
North Carolina's
Century Farmers
Since statehood in 1789 North Carolina has been
transformed from an unharnessed wilderness into
a land ol abundance. A great deal of this progress
and vitality must be attributed lo those pioneers
who settled here, endowing (his State with a heri-
tage of wisdom and courage.
The families listed in this booklet, along with the
hundreds ol which we were unable to locate,
represent the kind of traditional spirit that assures
North Carolina a promising future. The work and
dedication of such families has helped lead us to
the forefront in the field of agriculture—most vital
for the welfare ot this growing nation.
This is the program by which the State Fair can
honor the families of these oarly settlers with a
special recognition day. Those who have main-
tained homesteads for a century or more are
saluted for their countless contributions to our
State. This program will be repeated every five
years.
With a deep sense of gratitude, the Stale De-
partment of Agriculture, the North Carolina State
Fair and the State of North Carolina and its people
thank you.
Owners are listed under the county where the
property is located.
Illutl.at.ont courtesy ol tlx N. C. 0«P»r«"e
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34
GRANVILLE COUNTY
Fred Blnckwell
Mrs. Alclla Usry Bruedlove Eslalo
W B Crews
Mrs. E. G. Fraiier
Mrs. M. T. Greer
Mr. & Mrs. James B Hancy
Waller H, Harris
Richard W. Harris, Jr.
Ben L. Husketh
Ed.vard T. Huskoth. Jr.
Mrs. Mary I. Parham
Claude A. Renn
Mrs. Emma M Summers
Mrs. Corrina S. Sutton
William A Terry
Thomas William Winston
Mrs. Elizabeth Moss Woltz
Route 2 Box 93
Roulo 1
317 Williamsboro
Si.
Route 4 Box 157
2614 Fayctieville
St.
114 Military St.
501 Country
Club Or.
Route 3
Route 1
Route 1 Sox 198
Box 224
Route 1
3940 Bristol Rd.
4108 W. Galax Dr.
443 Oak SI.
Route 2
Qox 012
Virgilina. Va. 24593
Franklinton 27525
Ox lord 27565
Oxford 27565
Durham 27707
Oxford 27565
Oxford 2 7565
Oxford 27565
Crccdmoor 27522
Crocdmoor 27522
Oxlord 27565
Oxford 27565
Durham 27707
Raleigh 27612
Henderson 27536
Virgilina, Va. 24590
Oxford 27565
GREENE COUNTY
Henry C. Dixon
James W. Herring
James A. Rouse
Chiiici F. Sugg, Jr.
GUILFORO COUNTY
Mrs. W. T. Ballinger, Miss
Emily Ballinger I Max D. Ballinger
John Garland Clapp, Sr.
'Mr. £ Mrs. Leonard Fields
William W. Greeson
Holly L. Johnson
Robert W. McNairy
George R. Osborne
Mrs. Eula R. Osborne, Thomas
V. Osborne, Jr.. & George R.
Osborne
Mr. & Mrs. Hubert Rumley
John Henry Stewart
Mr. & Mrs. Franklin J. Toaguo
Mrs. Jew Irvin Wagoner
Mr. & Mis. John B. Wagoner
HALIFAX COUNTY
Robert B. Fleming
Miss Annio R. Hockaday
Raymond F. Shear in
HARNETT COUNTY
Mr. & Mrs. John 0. Champion, Jr.
Mr. & Mis. F. Junius Denning
Betty M. Johnson
Mr. & Mrs. Luther G. Partin
Mrs. Joseph H. Williams, Jr.
Routo 4 Box 106
Roulo 3
100 Wollihavon Dr.
112 W. Grear.j SI.
5926 Ballinger Rd.
Route 6 Sox 463
Routo 2 Box 172
Route 1
Routo 2
Route 2 Box 626
Route 7 Box 608
2615 David Clad-
woll Or.
Route 1
Route 2 Box 190
Route 1
Route 1
Route 1 Box 55-8
408 Church St.
Route 1 Box 114
5501 North Blvd.
Routo 1
Route 2 Box 84
Route 3
Routo 2
Route 1
Snow Hill 28430
Snow Hill 28490
Hubert 2853S
Snow Hill 28480
Guilford College Z7410
Greensboro 27405
Stokcsdale 27357
Julian 27283
Stokcsdale 273S7
Greensboro 27405
Greensboro 27407
Greensboro 27408
Brown Summit 27214
McLeansville 27301
Elon College 27244
Gibsonvillo 27249
Gibsonvillo 27249
Louisburg 27549
Roanoke Rapids 27870
Raleigh 27604
Fuqu.ly Varina 27526
Angier 27501
Dunn 26334
Willow Springs 2*592
Etwin 28333
«
HAYWOOD COUt
Millard H. & Dais;
Mattie M. Garrett
G. C. Palmer, jr. i
V/. Riley Palmer |
Mr. & Mrs. John (I
Mr. & Mrs. Way M
Mr. 4 Mrs. Hugh t
I
HENDERSON CO
Mr. & Mrs. Carl Lj
HERTFORD COUl
Mrs. Henry Thoml
Louis W. Snipes ,
William A. Thoma-
Thomas A Ruth M,
I
HOKE COUNTY i
Delia Raynor j
IREDELL COUNT'
Mrs. Rose H. Albd
Thomas A. Allisor^
Mrs. R3chcl P...-
L. M. Beaver
Mrs. Emma K. Be
William Kerr Qra-
Mrs. Stella Prove
Miss Elma Oowei
Lewis Clayton Oc •'
Miss Mary Rebecc
Thomas Leland PC
Melmoth W. Hill j
John Atwoll Hoiiui;
Julius Walter HoMt
Jamas C. Holmes |
N. P. Holmos .-j
John Shelton Kins
Roy S. McNoely j
Mrs. Mary Dowoli I
Henry P. Mullis j
Harry Prcvctto
Mrs. Jamea Burlie
Moblo Daxtor Prev
C. K. Sharpe
M. A. Sh.lrpe
Mrs. John D. Stevr
Mr. & Mrs. Fred L.
& Nora Mae Yates
Robert S. Thomas
Mrs. Mary D. WarN
Mrs. Irene Prcvflt"1
I
l
I
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35
Current Land Uae
All property located at the Clapp Farm Site is being
actively used for agricultural production with the exception
of a few old houses which are no longer needed for tenant
families and are rented. No houses have been abandoned.
Since these lands have been farmed continuously for over
100 years, it is an indication of their productivity. Most
soil is classified as 50&B -,Enon fine sandy loam, 0 to 6 %
slope,'Which is considered as agricultural important soil type
by the Soil Conservation 'Service.
Improvements are being made continuously tc increase tha
agricultural production of these farms. Good agricultural
practices such as proper linujgand fertilization, weed, disease
and insect control, irrigation, no-tillage planting and sod
waterways are standard procedure.
The operation of these farms require many long range
capital improvments. Grain storage facilities, machinery
buildings, fences, irrigation ponds, sod waterways, all require
a major investment that have a useful life for several generations,
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36
Family Dependence on Agriculture
Currently there are three fammlies living on the Clapp
Farm Site land that depend almost entirely on farming for a
living. These include Marvin Clapp, David Clapp, and Charlie
Daye. Three additional families have some income from Social
Security, but are still actively engaged in farming in order to
support their Social Security income. These include J. Garland
Clapp, Charlie Clapp, and John Moorefield. In addition to the
above families John Eowman, Norman Bowman, and John Clapp are
actively engaged in farming on a part-time basis with land,
storage byildings and machinery investments.
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37
Landovmers Opposition
For the above reasons» the property owners and other
people currently living on these properties are opposed to
the location of a Waste• Treatment Plant at the Clapp Farm
Site. Please note copy of signed document dated July 1, l977.
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38
July 1, 1977
Mr. Jim Melvin, Mayor
City of Greensboro
Greensboro, N. G. 27402
Mr. Lee Wilson
Radian Corp.
P. 0. Box 9948
Austin, Texas 78766
Mr. W. E. Knight
N. C. Department of Natural
Mr. John Hagan
Environmental Protection
and Economic Resources
P. 0. Box 27687
Raleigh N. C. 27611
Agency
1421 Peachtree St. N. E.
Atlanta, Georgia 30309
Gentlemen:
We submit the following data to you in regards to the South
Buffalo Creek site between I-85 and Highway 70 currently listed
as a possible location for Greensboro's Metro Wastes Treatment Plant.
Since these lands are the only source of"income for some of
us and have been farmed by some of our families continuously since
1845 involving 5 generations and with a life investment, we encour-
age you to select a less important agricultural area.
Approximate -acreage of crops either grown on our land or
managed 'uy us on surrounding rented land:
Crop
Acreage
Corn
Soybeans
Tobacco
Wheat
Barley
Milo
Pasture
69
199
69
70
30
100
24
Type and number of structures on bur property used for
agriculture production:
Grain storage facilities with concrete foundations
Conventional tobacco curing barns
Bulk tobacco curing barns
Tobacco storage barns
Livestock barns in use
Swine farrowing facility
Machinery storage sheds
7
12
4
4
3
1
5
Number of farm ponds on Qur property constructed and used for
irrigation purposes 5
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39
Property owners and acreage«
—(l&wf9 /?-
/rjp/t
Ay (\J.
'^Wx-
J/%u4r\;f ^//Z-
1] U/iJ, »¦ n, d-eJjJif-
firnrtz¦
yi'&isu.
C&yzs*
y<£~C^ C^-C'-rfxA
77
Si, ,A *--^ • A /g-^
,z
_John G. Clapp, Jr.
Gladys C. Clapp
John B. .Bowman
_A. Norman Bowman _y
_J. Garland Clapp
, Sr^
_Edna R. Clapp
_Charlie G. Clapp""^
_Cora M. Clapp J
_C. Marvin Clapp
jSylvia F. Clapp I
_David R. Clapp /
JSmily H. Clapp ^_J
102
89
236
190
Additional families or Jivine •
property and currently depend upon farming for a living.
John Moorefield & wife
'if/y
^(J_
Charlie Day. wife & 6 chidren
rWMf<
tiUiktn..
_Harry Davis
Reggie Herbin
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41
MAJOR CROPS CURRENTLY BEING PRODUCED
Small Grain - double-cropped
with no-tilled soybeans
-------
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43
EXAMPLE OF FARM PONDS USED FOR RECREATION AND IRRIGATION
EXAMPLE OF LAND IMPROVEMENTS MADE IN 1977
Field Enlargement
Construction & Establishment
of Sod Waterway
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44
PRESENTATION AT HEARING BY
UKITr.n STATES KKVIKOtr-lKNTAL PROTECTION ACD.'CY
ON PROPOSED GREENSBORO WASTE TRKATMFNT FACILITY
September 1, 1977
Ladles and gentlemen, my name is Henry T. Rosser, and X am
on attorney from Raleigh, North Carolina. X appear here tonight on behalf
of the Concerned Citizens of Mcl.eansville to oppose the site proposed
in the Draft Eiwironnental Impact Statement for the location o£ the new
Greensboro - Guilford County Wastewater Treatment System.
The history of the so-called Metro wastewater treatment
facility is both long and involved. The Concerned Citizens of
McLeansvllle, among others, have opposed the previous proposals and
recommendations of the City of Creensboro. They have contended that
those proposals and recommendations exceeded the needs of the City, that
they were environaantaily unsound, and that chey ueru not the most cost-
effective.
*ftor years of acrimonious debate and vrangling among various
groups concerning the proposed facility, the United States Environnental
Protection Agency and the North Carolina Department of Natural and Economic
Resources stepped to the forefront and retained an independent consultant,
the Radian Corporation, to review the entire probleta aud to collect and
compile the data necessary for the preparation of an environnental impact
statement. This brought a sigh of relief from many, for they felt that
a truly objective and factual study would be undertaken which, at long
last, would lay the problem to rest.
The Radian Corporation conducted its study and prepared its
findings In a thoroughly competent, objective, and professional manner!
and we hove no quarrel with it. In fact, it continued most of the things
McLeansvllle residents have been saying for years. The study and finding*
of Radian were subsequently reviewed by EPA and the Department of Natural
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45
and Kconomic Resources. The conclusions of the Draft Environmental Impact
Statement produced as a result of that review totally distort# and subverts
the objective findings of the Radian Corporation. It is this, subversion
and distortion to which we most vehemently object.
After reviewing well more than 100 possible alternatives for
action on the pare of the City of Greensboro, Radian eventually was able
to reduce the total number of alternatives for serious ard intensive
consideration to six, disregard^ the "So Action" alternative.
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46
South Buffalo plant, as tfi.it Cor proposed action. This slcc was selected
despite Che face that it was not the most environmentally acceptable
and was far from being the lea3t costly to construct, operate, or maintain.
Scrutiny of the Draft Environmental Impact Statement reveals
that Alternative 3 wa3 not, in fact, selected, but became the recommended
alternative by default when Alternatives, 1, 2, and 6 were rejected by
the EPA Administrator of Region IV. We contend and submit that the rejection
of Alternatives 1, 2, and 6 by Che Regional Administrator was without
foundation in fact or law and was totally unreasonable, arbitrary, and
capricious.
Since Alternatives 1 and 6 both contemplate upgrading the existing
waste treatment facilities, while Alternative 2 proposes construction
of a new plant, we will consider Alternatives 1 and 6 together and
Alternative 2 separately.
The Draft Environmental Impact Statement indicates Chat Alternative
2 was rejected bacause construction of that alternative would require
the acquisition of a "century-old highly productive family farm" as a
portion of the site for the construction of the alternative. It is further
stated that: "Guidelines from the President'3 Council on Environmental
Quality discourage removing prime agricultural land from productivity
if other alternatives will provide accommodation of the project needs."
(EIS, 111-32)
Assuming that the site location of Alternative 2 is so critical
that acquisition of the farm could not be avoided,.it is still highly
questionable whether Alternative 2 should be disqualified on this basis.
The above-quoted language contains the word "discourage", which indicates
that the guideline is not mandatory but is discretionary. In other words,
it vould appear that if all other factors are equal, agricultural land
should not bo removed from productivity, but if other factors are not
equal, then It is permissible to acquire agricultural lands.
-3-
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47
Acquisition of the farm would not have a perceptible effect
either on national agricultural output or on the economy of the region
in which the farm is located. Statistics compiled by the North Carolina
Department of Agriculture reveal that over the past several years there
has been an accelerating decline in smaller farm units. The reasons
for this decline are many, but perhaps the most important is that present
day economics of farm operation and production are against smaller family
farm units and are in favor of large ones. As a result, hundreds of
small farms in this State are annually converted to other uses or combined
in to larger agricultural units.
Since the sewer outfall proposed to be constructed froa the
South Buffalo plant to the new plant site under Alternative 3 will cross
the farm, it is very likely that the construction of Alternative 3 will
in fact cause the faro to be far more valuable for other purposes, and
will accomplish indirectly what the Regional Administrator claims he
wishes to avoid - conversion of the family farm to other uses. The T)rrf*»
EIS implicitly recognizes this, stating that:. "However, the proposed
action fi.e., Alternative 3J does provide a more positive prospect of
development occurring east of the present city limits. The new treatment
facility will easily provide the South Buffalo (east) subbasin with sewer
service. . . . 'Uap-froggine' is not expected to happen on an appreciable
scale for three major reasons. First, there is ample land for residential,
commercial, and industrial development near Creensboro in the transition
zones. Since the supply is available, the demand should not push the
cost of land to * level where people will have to seek cheaper rural
land for their housing needj. .. . • .The proposed action will change land
ownership patterns in the study area, particularly cast of the city lizit*.
Residential, commercial, and industrial uses will replace some of the
agricultural land." (EIS, V-56) It should be noted that the farm in
question lies in the transition area identified in Figure 21—21.
(EIS, 11-111)
-4-
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48
Although it is impossible Co say that the particular farm under
consideration here will became one of those converted or combined into
other osns in either the near or distant future, it is possible to say
that both the economics of farm operations and the location of the farm
in the. vicinity of an expanding metropolitan area crenta a high statistical
probability that this fana will cease to operate in its present manner
within the next few years.
Since there appear to be no larger social or economic conse-
quences involved with the removal of thi3 farts from agricultural
production, then we must focus on the particular farm and Che consequences
of its acquisition upon the present ouners. It is a sad fact, of course,
that acquisition of the farm would have a disruptive effect upon the
lives of the owners and may sever deep emotional ties with the homeplace.
While we cannot but view such a situation with sympathy, it
must, nevertheless, be viewed objectively and in context. First, it
vould be literally inpossible to construct most large-scale public, works
projects without acquiring agricultural lands. Public reservoirs, lakes,
highways, aquaducts, military and public defense facilities, and the
like have required and will continue Co require the acquisition cf agricultural
lands.
Second, acquisition of these lands for public use imposes a
concomitant legal requirement that the owners of the land be paid full,
fair, and Just compensation for their property, and that they be put,
monetarily, in cha sane position after the lands are t-tV.cn as chay were
In prior to the taking. If Che farm is acquired for the facilities site,
Che owners will have the choice of continuing in agriculture on another
farm acquired with the monies paid for their old farm or of investing
the proceeds and going into other lines of work. In any event, the owners
should not suffer any economic loss by reason of the acquisition of their
lands.
While It is true that the ovners of the fans vould be Impacted
by this project and would undoubtedly suffer some degree of disruption
-5-
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49
In their lives, it i8 also equally true tlmt others will be impacted
and will suffer a greater or lesser degree of disruption if the site
proposed under Alternative 3 is acquired. In both instances, lands acquired
for the project will lose both their present and future potential and,
for all practical purposes, will forevermore be devoted to waste treatment
purposes.
The most immediate and practical effect of selecting Alternative
2 over Alternative 3, insofar as the public is concerned, is that
Alternative 2 will sav6 the public $1,680,000 in construction costs.
(ETS, Table III-9) I*16 environmental detriment of Alternative 3 as opposed
to Alternative 2 will also be somewhat greater, since sewer lines will
have to be extended some two stiles further downstream under Alternative
3, with accompanying destruction, of vegetation and ecological disturbance.
A future and somewhat more disturbing prospect is that of precipitating
or contributing to urban sprawl along the additional extension.
Viewed objectively, then, there seems to be excellent rcison
to select Alternative 2 over Alternative 3. To summarize, the farm in
question is a small agricultural unit located within three miles of a
Urge and growing metropolitan district. Under such circumstances, there
is a high degree of statistical possibility that the farm will be converted
into other uses within the foreseeable future. Additional lands must
b. acquired for the construction of all of the presented alternatives
except Alternative 7, the "No Action" Alternative. Thus, present owners
of lands which will be acquired will be impacted when those lands are
taken. The public body acquiring those lands (in this case, the City
o£ Greensboro) is mandated by law to pay the owners, including the owners
of the farm under consideration, full, fair, and Just compensation for
the land, taken. On the other hand, selection of Alternative 3 will
have greater adverse environmental i*P*« than the selection of Alternative
2 and the construction of Alternative 3 will cost approximately $1,680,000
Of Alternative 2, which is a direct detriment
more than construction or Aiternai
to the public.
-6-
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50
From all that has been seated previously, It might be assumed
that we are urping that Alternative 2 be constructed rather than
Alternative 3. Such, In fact, is not the case. What wo arc attempting
here is a logical, rational, and dispassionate analysis of the data set
forth In the EIS and related documents.
That analysis leads to the conclusion that construction of
Alternative 2 is more beneficial to the public weal than the construction
of Alternative 3. Further analysis leads to the Inescapable conclusion,
however, that construction of either Alternative 1 or Alternative 6,
involving the upgrading of the existing North Buffalo and South Buffalo
plants, is the enly truly acceptable alternative.
the text, of the Environmental Impact Statement and Table 1II-7
(EIS, 111-29, 111-32) show that of the six alternatives, Alternative
6 ranks aa the most environmentally acceptable, while Alternative 1 ranks
as the second most acceptable.
Reference to Table III-9 (EIS, 111-35) shows that, respectively,
Alternatives 6 and 1 will be the least expensive to construct. The
projected costs of $21,226,000 for construction of Alternative 6 is
$12,11&,000 less than the projected cost of construction of Alternative
3, which occupies Che fourth ranking in projected construction coses.
Construction of Alternative 1 would cost only about $460,000 more than
construction of Alternative 6.
Tabic 111-10 (EIS, 111-36), which contains projected user's
costs, shows that of the six alternatives, Alternative 2 will be the
least expensive, Alternatives 3 and 6 are tied for second least expensive,
while Alternative 1 will be. the most expensive.
Based upon the factors of environmental acceptability and cost
effectiveness, then, Alternative 6 is overwhelmingly the alternative
of choice, with Alternative 1 running a very close second. Alternative
2 runs a somewhat distant third.
The only reason eiven in the Draft Environmental Impact
Statement for rejection of Alternatives 1 and 6 is that: "After careful
-7-
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51
considcmtion of all factors involved in the selection process (cost,
environmental, engineering, and implcaentability) tlws EFA Administrator
of Region IV determined that the continued existence of the South Buffalo
plant was not socially acceptable in any alternative. THi3 decision
was based upon the history of odor problems with the plant and the large
nuaber of people that had been adversely affected by this pollutant
(RA-R-406)." (EIS, 111-32-33)
It is submitted that there is a substantial question whether
the Regional Administrator has the right or authority to dctemlne that
the continued existence of the South Buffalo plane is not acceptable.
The South Buffalo plant exists, and has for nany years. The Regional
Administrator is not in a position to banish that facility. The Regional
Administrator and EPA are in a position to Impose sanctions against the
City of Greensboro and its officials for failing to meat water quality
standards, and they are in a .position to withhold Federal funding, but
only the duly constituted public officials of the City of Greensboro
are in a position to eliminate the plane. The Regional Administrator
cannot force abandonment of the plant simply because he does not
personally find the plant socially acceptable.
Insofar as appears from anything in the Draft Environmental
Impact Statement, this determination of the Regional Administrator is
entirely a subjective one. There are no findings as to the frequency
or extent of past occurrences of the odor problem. There are no findings
ss to the frequency, extent, or nature of the problem as it may occur
In the future if the South Buffalo plant is upgraded pursuant to Alternative
6 or Alternative 1- So data is presented concerning the environmental
or economic impact of the odor problem as it now exists or with regard
to comparisons of the relative anticipated environmental and economic
lapacte of Alternatives 1, 3, and 6.
Indeed, there appears to be no objective or factual data to
support the determination of the Regional Administrator. It is submitted
-------
52
that only a qualitative and quantitative analysis will answer the questions
of the nature and extent of the odor problem as it now exists in connection
with the South Buffalo plant and questions of the nature and extent of
the odor problem as it will exist after upgrading the Sovith Buffalo plane
as proposed in Alternatives 6 and 1, or construction of a new plant as
proposed in Alternative 3.
The only scintilla of support for the Regional Administrator's
determination appears in that memorandum dated July 12, 1977, from Matthew
J. Robbins, Regional Director, Office of Civil Rights and Urban Affairs,
to John llagan, which is reproduced at the end of the Technical Reference
Document. In that memorandum, Mr. Robbins states: "Title VI provides
that, 'No person in the United States shall be excluded from participation
In, be denied the benefits of, or be subjected to discrimination in . . .
programs or activities [receiving federal financial assistance].'" Mr.
Robbins goes on to say that from information received by hia from the
National Association for the Advancement of Colored People and fron tKa"
Greensboro Citizens' Association, it is his evaluation that EPA will
be supporting an existing discriminatory situation if it provides financial
assistance for upgrading the South Buffalo plant; and that upgrading
the South Buffalo plant will perpetuate discrimination and cause direct
conflict with Title VI of the Civil Rights Act of 1964.
To say that the reasoning behind the conclusions of this
seaorandua is not only tortuous in the extreme, but is also fallacious,
la to utter a gross understatement. Mr'. Robbins appears to proceed upon
the following presuppositions: (a) construction of a wastewater treatment
plant In an area occupied predominantly by a racial minority Is per sa
discriminatory; (b) upgrading an existing wastewater plant located in
an area occupied predominantly by a racial minority is per se discriminatory;
and (c) obversely, relocation of a wastewater treatment plant presently
existing in an area occupied predominantly by a racial minority to an
area occupied predominantly by a racial majority is per se nondiscriminatory.
-9-
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53
Mr. Robbins does not dollacate for us the area Impacted by
the odor problem, nor does he toll us the composition, by r.icc and nuober,
of tho persons living within that area. By his illogic, lie implicitly
and simplistically asserts that the only acceptable site for a wastewater
treatment plant is in an area predominantly occupied by a racial majority.
To say that that is the meaning and intent of the Civil Rights Act of
1964 as applied to such a situation is a gross distortion and misconstruction
of that Act.
It would seen that the problem to which Mr. Robbins is actually
addressing himself is that a black ghetto area has been created in the
South Buffalo area because of alleged past discriminatory housing practices
in Greensboro, and that, except for one other area of the City, acceptable
housing is not available to blacl: residents of Greensboro. Thac may
be the case, but the existence of the South Buffalo plant has nothing
to do with housing discriuination or the lack of acceptable housing
elsewhere. Upgrading C-V;C existing plant has nothing to do with continued
discrimination in housing, if such discrimination exists. Nothing
indicates that removal of the plant to another site would convert the
South Buffalo area into an interracial neighborhood, create new housing
opportunities for blacks, or otherwise eliminate any racial discrimination
that may exist. The remedy for the housing discrimination that Mr. Robbins
decries does not lie with relocation of the South Buffalo plant.
There is no question but that odors have been a consistent
problem. In the case of the South Buffalo plant, the reason is obvious.
k» U stated in tho Draft Environmental Impact Statement, concerning
both Horth and South Buffalo plants.' "Odors at these plants are typical
0[ inadequate treatment plants." (EIS, II-8) It also states; "Tho
lower quality effluent at the South Buffalo Plant probably is a result
of the larger portion of industrial wastewater discharged to that plant
«nd the lack of sufficient oxygen transfer facilities. Additionally,
the South Buffalo Plant is operating near its peak hydraulic
capacity ..." (SIS, 11-140).
>10-
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54
Despite the face than odors exist, the Draft Environmental
Impact Statement reveals: "In U>e Greensboro study area, no quantitative
odor data were available ... Ho existing studies, such as a comnunity
odor survey, were located for the Creensboro study area . . . According
to the Greensboro Public Works Department, no odor complaint records
are kept by the City." (EIS, II-7) Thus, although EPA knows that an
odor problem exists, and apparently knows why an odor problem exists,
it has collected no data and presents no substantive conclusions, as
to the past, present,' and future nature of the problem and of its impact.
Despite this paucity of facts, however, Mr. Robbins is willing,
upon hearsay, to misconstrue the Civil Rights Act of 1964 to prohibit
upgrading of the South Buffalo plant; and the Regional Administrator -
is willing to accept that evaluation and decide "the continued existence
of the South Buffalo plant was not socially acceptable, in any alternative."
The facts of the situation are that the North Buffalo plant
uaells, the South Euffalo pltiit sr.e?ls, and any new plant constructed
by the City of Greensboro will smell. (EIS, VI-1) In addition, it vaa
found: "Tor new plant sites an adverse ixpar.t is indicated. This is
due to a new odor source being superimposed on the area surrounding the
plant site." (Technical Reference Document) The Draft Environmental
Impact Statement also states: "Wastewaters which travel significant
distances before reaching the treatment facility often become septic
and release obnoxious odors at the plant outfall or wall or. at the inter-
mittant manholes." (EIS, VI-1) Alternative 3,'of course, proposes the
construction of a sewer extending 26,000 feet from the existing South ¦
Buffalo plant to the proposed site of the new plane. This will present
tha opportunity for a new source of stench to permeate an additional five
miles of the county.
Despite all of this data which la present in the EPA documents,
the Regional Administrator did not find that continued existence of the
North Buffalo plant or construction of the new plant "was not socially
-11-
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55
acceptable In any alternative". Nor did Mr. Kobbino find that continued
existence of the North Buffalo plant or construction of the new plant
would be in violation of the Civil Rights Act of 1964.
Alternative 1, among other things, proposes that the existing
South Buffalo plant facility be upgraded to provide tertiary level
treatment with a capacity of 20 million gallons per day. Alternative 6
proposes, among other things, that the South Buffalo plant be upgraded
to provide tertiary treatment with a capacity of 11 million gallons per
day, with an additional 9 million gallons pet day to bo transferred to
the Worth Buffalo plant whan that facility is upgraded to 25 million
gallons per day capacity in 1987. (EIS, XXX-17 through 21).
Under both of the alternatives, the hydraulic overloading of
the South Buffalo plant would be eliminated and the nature of the treatment
provided would be capable of treating both household and industrial waste,
a capacity which the South Buffalo plant presently does not have. (EIS
11-139 through 140) A natural result of providing adequate tTe.itr.eat
for the waste discharged to the South Buffalo plant will ba the reduction
in odors produced. This would certainly be true if the methodology
proposed by the Draft Environmental Impact Statement for the N'orth Buffalo
plant and the proposed new plant were employed in upgrading the existing
South Buffalo plant. (CIS, VI-2 through 3).
The Draft Environmental Impact Statement recognizes South Buffalo
Creek as a very heavily polluted stream. (EIS, 11-43, 74) It further
recognises that the inadequately treated discharge front the South Buffalo
plane is only a part of the problem, inasauch as there are also nuneroas
point and non-point discharges to the stream. (EIS, 11-39-40; 11-43;
Figure 11-10, 11-44; 111-12) Despite these findings, the Draft Environmental
Impact Statement states: "However, the effects of other discharges to
the stream were not explicitly incorporated in the modal and no true
waste load allocations were decerained. Therefore, the effluent limitations
to South Buffalo Crook arc based on the projected discharge from the
municipal treatment facility alone and the observed capacity of the Creek
to assimilate that sole discharge." (EIS, 111-22 through 23)
¦12-
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56
The foregoing paragraph, together with the paucity of studies
and data concerning odors previously referred to, makes it abundantly
clear that no determination lias been made as to what portion of the odors
associated with the South Buffalo plant emanate from the plant itself,
and what portion is created by the other point and non-point discharges
to that stream. Until such a determination has been made, it is impossible
to say that removal of the South Buffalo plant will materially improve
the odors ar.sociatcd with South Buffalo Creek.
Since there nas been no quantification of the source of odors
emanating from South Buffalo Creek, and since no information is provided
with regard to the reduction of odors if the South Buffalo plant is up-
graded in conformity with Alternative 1 or Alternative 6 and there is
applied to it the methodology reconnended on Pages VI-2 through 3, it
is submitted that the Regional Administrator has no basis upon which
to make the determination that the continued existence of Ilia South 5"f"alo
plant is socially unacceptable because of odor problems. In the absence
of studios and facts upon which rational conclusions can be reached,
the Regional Administrator's decision Is completely subjective, arbitrary,
a manifest abuse of discretion, and totally unsupported. Under such
circumstances, the Regional Administrator's determination must be reversed.
The Draft Environmental Inpact Statement states, with commendable
candor, that:
"Municipal wastewater treatment facilities have
been odor sources and it is doubtful whether such
odors can ever be completely eliminated at all
times . . . Wastewaters which travel significant
distances before reaching the treatment facility
often become septic and release obnoxious odors at
the plant outfall or well or at the intermittant
manholes. . . . Almost all facilities associated
with sludge handling and processing will at times be
characterized as an odor nuisance, especially In
summer conditions." (SIS, VI-1)
-13-
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57
Figure V-l (EXS,' V-5) indicates that some portion of the people
living within 1,000 feet of a waste treatment facility would identify
that facility as a major odor source. Tabic V-9 (EIS, V-51) indicates
that at present, approximately 2,000 people live within 3,000 feet of
tha North Buffalo plant. In addition, odor complaints have been received
from a shopping center located to tha northwest of the North Buffalo
plant. Despite these findings, it is again noted that the Regional
Administrator did not find the North Buffalo plant to be socially
unacceptable, nor did Mr. P.obbins find its upgrading to constitute a
violation of tha Civil Rights Act.
The Environmental Impact Statement also indicates that the
new plant proposed under Alternative 3 will be a source of odors which
will affect the surrounding area. An attempt is wade to Justify the
plant on the grounds that fewer persons will bo affected. (EIS, IV-
6) The Statement further notes: "Obviously, if population densities
surrounding the proposed site increase dutinK this planning period, a
greater impact could be expected." (EIS, V-6)
The result of the decision to select Alternative 3 will be
to ccmtinue to impact the area surrounding the Korth Buffalo plant and
to Impact an entirely nev area in the vicinity of tha proposed new plant.
This action will be taken despite the fact that there is no guarantee
that thera will be any substantial reduction in odors in the vicinity
of the existing South Buffalo plant upon its abandonment so long as the
numerous other point and non-point sources exist.
Whatever adverse social impact the South Buffalo plant may
have, that Impact has long since occurred. To the extent that the plant
contributes to the odor problem, its impact would undoubtedly be substantially
reduced if the plant were upgraded and the suggested technology applied.
Under theae circumstances, it is extremely difficult to understand ho*
the Korth Buffalo plant and the new plant can be found to be socially
acceptable under similar circumstances. In both cases, persons living
-14-
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58
in the vicinity of those planes, now and in the future, will be adversely
affected by any asnociated odor problems. In the case of the proposed
new plant, the problem will simply have been transferred five miles
downstream to impact and adversely affect an entirely new group of
people. The effect of the new plant may be to substantially impede or
destroy the development potential of between one and two square miles
of land in the vicinity of the new plant. If the odor problem is not
socially acceptable in the community in which the old plant presently
exists, and within which the sewngc producing the odor is generated,
why should it be any more socially acceptable to the new community upon
which the odor problem will be imposed?
Despite the fact that EPA recognizes that the proposed plane
will adversely affect the area in which it is located, no studies appear
to have, been made concerning either the nature or extent of the inpact
on present and prospective prr.ncrty values in that area. It car. rcsssnabl?
be expected that both Ions and short term values will decline. We submit
that this effect must be taken into consideration before overall social
and economic impact of the proposed action can be properly evaluated,
and that EPA should conduct studies to this end.
As a matter of equity and basic fairness, it should be observed
that the odor problem connected with the South Buffalo plant has persisted
for many years and that many of the persons affected by that probleo
undoubtedly chose to move into their present neighborhood after the problem
was in existence. The persons affected are residents of the City of
Greensboro and it is their-and their city's wastes that are being treated
and froia which the odor problem derives. Since odors can undoubtedly
be substantially reduced by reconstruction of the South Buffalo plant,
It is totally inequitable to require the citizens of this Nation to pay
an additional $12 million to construct a new plant, admittedly having
o substantially greater adverse environmental effect, five miles downstream.
-15-
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59
Civen that any wastewater treatment plant will emit odors, it is toally
inequitable to impose those odors upon people who are not residents of
the City of Creensboro, who have not participated in the creation of
the problem, and who receive no benefits from the City's waste treatment
facilities.
of Natural and Economic Resources, and their consultant, the Radian
Corporation, have found Alternatives 6 and 1 to be the most environmentally
acceptable. They have- also found Alternatives 6 and 1 to be by far the
least expensive to construct, as well as the most cost effective.
Alternative 2 is in a somewhat distant third place in these various
categories. Yet, by the arbitrary, capricious, and unsupported decision
of the Regional Administrator, and by misconstruction and misapplication
of the Civil Rights Act of 1964, the most acceptable alternatives have
bean eliminated. The very agencies of State and Federal Government which
have been charged with protecting the environment of this Scate and Macinn
havo violated their public trust and have further acted contrary to the
directives of the State and Federal Executive Offices that fiscal waste
eliminated and the public purse b« protected. It is clear that the
only acceptable alternatives are Nos. 6 and 1. It is equally clear that
the decision of the Regional Administrator must be overturned.
In summary, the Environmental Protection Agency, the Department
Thank you.
-16-
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60
UiluM "
may CONCERN:
WE, THE UNDERSIGNED CITIZENS AND RESIDENTS AM-i.t I t .
INDIHKCTLY. BY THE PROPOSED METRO SEWAGE TREATMENT |Va.\': ' • ','V,
CREENSUORO, NORTH CAROLINA, DO HEREBY ENTER OUU PlWl'lV''
THAT WE OI'PGSE THE LOCATION OF SUCH PLANT IN THE McLEANSVli |
IN VIEW OF THE STUDIES CONTRACTED I3Y THE ENVIRONMENTAL IKou t ; ¦ '
SHOWING THAT UPGRADINC GREENSBORO' S PRESENT TREATMENT EAUi.l! I s
MOST ENVIRONMENTALLY SOUND PLAN, AND THAT IT WILL SAVE APi*l\';Xl.v\ ;
TEN MILLION ($10,000,000.00) IN TAX DOLLARS. , /
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«*« iii&tiCilUs
lit. 2f Box 40-11
j>iCLca)isTilles , »*. 27301
July 29, 1977
'ir» tiotiii Ail i/1i.i."fc©
director> Region IV iSPA
345 Oonrfcland street
'•tlaata, Ga.
Be&r j in
. . _ | ¦» i« T ntri COflCflr**6d about tilt? —oi
a citiaeri of ilcLeams vilJM*» tv,«ir sev/a/o ireat»seat = Plant
Greensboro insisting oilJjj^!L coet, or aiivij^/vserr&al
ueor HcLeancville, regardless of ti* cost,
ejects.
v „*«+ tttudv ftas been made by iiaU:Uu
} uiideruUund t^t » J0*? £a t^Lyera of some 3 250,0i;O, GO
Corporation at a coat to we taxp y overruled at Vi* awo^e
to bou,000.00 and the Wjults were ewgj^ ^ 16
°* a pert, Itadian Corporatio ^ than building a aearage
alternatives* that are 1#b« cosw v»<~
Plant in fteLeaniwill**
I would certainly BpPr.ci*te your r.vi.Ki>c tki» i^ue.
Touro very truly,
i.enneth A, v-'atkina
{.'jr. Bob Cooper $ Region I'/ SPA
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V
John E. Hagan, III
AUGUST 8. 1077
Chief, EIS Branca
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia ..0308
Dear Mr. Hagan:
Enclosed rlease find my published letter to the Editor, Mr. William Cheshire,
of the Editorial Page of The Greensboro Record.
I would like to have it included in the records pertaining to the EIS of the
Metro Sewage Treatment riant proposed for Greensboro.
As you may note, the criticism of the DRAFT ENVIRONMENTAL IMPACT STATEMENT,
GP.EENSBOP.O-GUILFORD COUNTY. NORTH CAROLINA 201 WASTEWATER TREATMENT SYSTEM
which I received focuses upon "methodology" used in all scientific enquiries,
referenced specifically to the investigation for a location for the proposed
treatment riant.
It is important that this letter get into the record because it relates to
3 previous communications I have mailed the EPA Region IV offices in Atlanta.
These communications are:
(1) Letter of September 21, 1976 to Asa B. Foster, Jr., Acting Regional
Administrator - no response
(2) Statement of November 9. 197b addressed to EPA and Radian officials
concerning the insufficient period of time for a reliable study for
an EIS statement (period limited to NINE MONTHS in Contract WA 76-B445)>
no response
(3) Letter of July 15. 1977 addressed to Mr. Bob Cooper of EPA concerning
criteria used as the reason to change the location of the proposed Metro
plant 1rum "Site 2" to "Site 2A" (now identified as Site 3) ~ response'
I am sure that you are aware, as we are, that it is important to retain these
communications from citizens as part of the record to show government's responsive-
ness. I believe that everyone realizes that the final determination of the im-
plementation of the proposed Metro plant and Horsepen Creek basin sewer line
extension will be made through court action and that complete records will be
necessary for trial exhibits.
If the newspaper letter cannot be included in the records for some technical
reason, I would appreciate it if you would so advise me so that I may rewrite
to EPA.
On a related matter, reference is made in the above-identified report to a
Technical Reference Document (RA-R-406) prepared by Radian Corporation. I would
like to have this document. If there are costs entailed, please advise.
James R. Rees,y Soil Scientist
2224 Walker Avenue
Greensboro, North Carolina 27403
-------
Mr. Bob Cooper JULY 15, 1977
Environmental Protection Agency, Region IV Greensboro. N.C.
345 Courtland Street
Atlanta, Georgia 3030$
Dear Mr. Coor>er:
I wish to hpvfi +Ms letter and your response to it included in the records
°f the proceedings relative to the proposed Horsepen Creek basin sewer line
extension/Metro Treatment Plant EIS study conducted by Radian consultants
(Contract: WA 76-B445).
The subject of this letter centers upon the meeting on July 12, 1977 of
members of the Citizens Input Advisory Group, yourself representing SPA,
the Radian spokesman, the representative of the North Carolina Environment-
al Management Department and other citizens; this meeting convened in the
Grand Jury Room of the Guilford County Court House.
As an interested citizen, I attended this meeting but became somewhat con-
ned by the explanations given by yourself, the Radian employee, and the
State official as to the purpose end business of the meeting. To be more
exact, I was unable to fully comprehend why the citizens of the Input Ad-
visory Group were called to this meeting. My confusion stemmed in part from
^ foreknowled- -bout particular events that took place before this July 12
®eeting date. Let me recount these events in the order they occurred.
One: On Thursday, May 19, 1977, in th. sa»e location and largely with the
s«»e participants as the July 12, 1977
-------
-2- Letter to Bob Cooper from James R. Rees (JULY 15, 1977) -2-
The significant point to recognize about this series of actions i» that
selection of Site #2 was based upon a long investigation by Radian specialists
AS WELL AS sufficient opportunity for the input of the Citizens Advisory Group.
Members of this group, and including other citizens, took advantage of this op-
portunity before as well as during the May 19th meeting.
Two: On June 15, 1977, the following public officials met in the EPA offices,
345 Courtland Street in Atlanta:
W.E. Knight, N.C. Department of Environmental Management
Jim Melvin, Greensboro Mayor
Tom Osborne, Greensboro City Manager
Jesse L. Warren, Greensboro City Attorney
Ray E. Shaw, Jr., Greensboro Sewer & Water
Ogden Deal, Guilford County Commissioner
Bob Landreth, Guilford County Commissioner
John V. Witherspoon, Guilford County Manager
Larry Karvell, Guilford County Environmental Services
Bob Cooper, EPA
Bob Mitchell, EPA
Alec Little, EPA
Paul L. Hatchett, EPA
Sheppard Moore, EPA
Tom Ries, Attorney - EPA
Lee Wilson, Radian Corporation
Berry A. Williams, N.C. Department of Natural & Economic Resources
Although the 17 persons present at this meeting agreed to relocate the site
of the proposed Metro treatment plant, no citizen member of the Input Advisory
Group was in attendance to present views, as a non-elected or hired public off-
icial, on behalf of the general public.
Three: At the meeting of July 12, 1977, the audience was Informed that EPA
had changed the proposed site of the Metro plant from Site #2 to a location
identified as Site #2A which is downstream from Site #2, along South Buffalo
creek, within a lineal distance of 2 miles from McLeansville.
This sequence of events and actions, I believe, raises a very important question
about how EPA perceives the value of the contributions of the Citizens Input
-------
Letter to Bob Cooper from James R. Rees (JJLY 15, I977) _3_
Advisory Group to aid in decisionmaking. To be concise, the citizens did
not have the opportunity to contribute information in the deliberations made
in Atlanta to change the site from Site #2 (which they generally accepted) to
°ite #2A. Site ,#2 vas selected by 3PA after the opportunity for innut by cit-
izens; Site #2A vas selected v/ithcut this opportunity.
I consider this to be a serious oversight in the selection and SIS formulation
process. I am uncertain about its legal ramifications, but it ia a breach of
responsibility to recognize citizens' interests. The deliberations by govern-
ment officials in a meeting prior to the July 12, I077 meeting in Greensboro
excluded views of the citizens' Advisory Group. The decision reached in this
Prior meeting, therefore, did not represent a corporate agreement cf all parties
involved in resolving the sewage treatment problem affecting the Greerisboro/Guil-
ford County communities. In short, although a citizens' advisory group was formed
for the expressed purpose of contributing advice about public concerns, their
role, when it appeared convenient to do so, was abruptly excised.
The meeting of July 12 seemed to be convened solely to inform the citizens of
a decision taken by their government representatives; a decision in which the
Citizen Input Advisory Group had no part. It occurs to me that much expenditure
°f public money, citizens' time, and general energy could have been prevented
were written communications concerning this official decision to have been mailed
the members of the Advisory Board. Since no vote was taken at the July 12
feting to note the citizens' agreement with this official decision, mailed an-
nouncements would have been just as, or more, effective.
To compound the seriousness of this inequity in representation, i.e., denying
the citizens the opportunity to express their thoughts and views, the explan-
ationa of the "reasons" for this changed EPA decision were not convincing. This
-------
-U- Leotar to Bob Cooper from James R, Rees (JULY 15, 1977) -k-
is to say that the necessity to select the new 2A site was not adequately
substantiated either by yourself as the SPA representative, the Radian employee,
or the State Environmental Management man.
According to the rather superficial explanations (verbal and transparency pre-
sentations without sufficient reference to fundamental data which should have
been put into the hands of the audience) at the July 12 meeting, this is my
understanding of the overriding reasons for the reselection of the site:
1. The first site, Site #2, was "prime" agricultural land, and there were
objections to taking this land out of production by using it for the
Metro treatment facilities;
2. More people within a 3.000 foot radius of the plant established on
Site #2 might be subjected to odors than would be the case were it
constructed and operated on Site #2A.
I must assume that these were the decisive reasons for the change in the EPA
selection because the first selection, Site #2, was made after a prolonged study
of most other i*iraiueters affecting plant construction, operation, and consequent
effects upon the environment and human inhabitants.
If my understanding is correct, then, for the sake of objectivity, I must ask
a series of questions about these reasons (items 1 and 2 above). In so doing,
I hope that you understand that I realize that time limitations, possibly, did
not permit a more thorough presentation at the July 12 meeting. This is always
a problem in making presentations to groups. However, since you undoubtedly had
fundamental data available for the consideration of the officials at the Atlanta
meeting of June 15, 1977, I surmise that you have it readily available to supply
the answers to my questions.
With regards to Item §1 of my understanding, would you please forward to me the
data and/or explanations (or both) about how EPA/Radian determined Site ^2 to
be "prime" agricultural land? Of course, I expect that the same method used to
-------
¦5-
Letter to Bob Cooper from James R. Rees (JULY 15, 1977)
-5-
this determination for Site #2 weald also apply to Site MZk to enable
coinnarison. As an Agronomist, I have found that any reliable evaluation and
rating of agricultural land must be founded upon the answers to the following
questions. I exrect that the Radian consultants have these answers.
1- What percent, of the site, Site *2, is cleared and in agricultural us*
(for row crops, pasture, hay, ensilage)?
2. What are the mapping units (types of soil and respective slones
elineated on soil maps) of Site #2, and what percent of the tn+ai
area dc they occupy, respectively?
3. What is the crcp production history of Site *2 for the preceding 3 years-
(a) crops grown and (b) yields for each year? * years.
U. What is the level of the landowner's or tenant's farming skills anrf
agement capabilities and how was this determined? man-
*>• What was the cash income to the landowner for whatever products vere
raised on Site 02; for each year of the previous 3 years (actual not
estimated)?
6. What is the projected income (for the following 3 years only) fr0m the
products grown on Site #2? Please consider the possibility that tobacco
as one crop grown in this area, may suffer a declining market. (Assume '
the same level of management as currently found).
7. How does this past and projected income from products grovn on Site #2
compare wjth the past and future returns of an equally-sized cropping
area on farms located in the northern section of Guilford County? This
section would be determined by a line roughly following the I-AO/Huffine
Mill roadways across the county. (A random selection of 25 farms) This
generally, will compare areas of Cecil, Appling, Lloyd and Davidson soils
with an area of Iredell, Enon, Wilkes, Helena and Vance soils.
V/ith reference to Item #2 of ray understanding, i.e., the 3,000 foot radius limit
^favn for possible odor transmission, I would like the following question (s)
answered, together with corroborating data:
!• How was the 3,000 foot radial limit determined?
I assume that the Radian specialists resorted to analogs in setting this
limit. If so, would you please specify these analogous locations/condit-
ions and supply me with the pertinent meteorological data that supports
Radian interpretations?
I was particularly interested in the conclusion expressed by the Radian
consultant that "still air, less than 2-3 raph" seems to be the atmospheric
condition when odors around sewage treatment plants are most noticeable.
-------
-6-
Letter to Bob Cooper from James R. Rees (JULY 15, 1977) -6-
I drew an inference from this; that is, the sensors of odors checked
around treatment plants in other cities were inconsistent humans rather
than instruments.
Further, I should like to know more about general meteorological conditions
prevailing at the times of the measurement of odors (or better, the surveys
of human sensors) in other locations. I am wondering if rather uncommon at-
mospheric conditions existed at the time of the surveys in these other loc-
ations air inversions, extreme radiation cooling, conditions accompanying
"stationary fronts," and so forth.
Of course, density and humidity also affect the capability of the air medium
to transport odore, and diurnal changes usually affect these characteristics
of the air. Therefore, would you please supply me with the temperature and
humidity data of the air at the times of the odor surveys, and hours the sur-
veys were taken.
Topogranhy altso aifects the transmission of odors and air pollutants, that is,
the relative elevational positions of the source of odors and the sensors. Would
you please send me appropriate data showing or indicating these positions at the
locations and times odor surveys were taken?
Finally, before reliable conclusions can be made about a 3»000 foot limit, the
conditions of the treatment plants surveyed and the degree to which sewage has
been treated should be known. Please include this information.
It is rather obvious to persons knowledgeable in meteorology and micrometeorology
that "analogous conditions" upon which to base odor limits are very difficult
to find. When all of the variables are considered, not the least of which is
the variable reactions of humans to odors (or scents), it seems that long-terra
FIELD measurements of any specific situation are required to arrive at dependable
conclusions. The 3,000 foot radius limit is highly arbitrary even as an estimate.
This stated limitation could be overlooked were it not for the fact that it is
a spatial relationship that was used as a major criterium in the site selection
I await your answers and supportive data. Please understand that this request
is made as a positive effort; we need to examine the environmental/social problem
affecting the people of this area in as objective a manner as possible to gain
ultimate results beneficial to all.
process.
2224 talker Avenue
Greensboro, N.C. 27403
-------
»H(js -'«»aiunuai lniorma-
co"se1ue"ces
Wisrsu-u1 ?r 11 confuses deci-
Ite, disr.1-,0 nd to re'y on false
It'as fart «d 'n handsome re-
E'feareiii„ ually> unreliable
e WorSe than none. As one
•Wf,
ers to the editor ¦
Metro report rambles, distorts
^ord
^6 Af i
OrteiK). nsuhstantial informa-
nt of this P°int'
ikN'int had t0 disprove
lS sha* that the lenticu-
r uetDf. ye was necessary for
Kd reigning the successful
MeS, A person trying to
Wht 01 a river surely 1S
\ (l„' someone who roils and
'ilt? ater'
. tenoVt8 brou«ht t(> mind by the
[lew .Qn the Greensboro-Guil-
Pfc ' metlt system.
TOtu ""Wiry is not a magical,
CSlytvu88, a rite performed
WbiS.8 chosen breed of men
w Si^?|8' To the contrary, it is
i laiv# i jexercise guided by a
i,,'8?8. reasonableness.
K idea out, try it on a
r«atfr'^onable to attempt to
»n!e,m through the follow-
JS fj,, Make sure what the
i.e., "define" the
!?%<%» • a crucial step; it is
< Nv.Kl.to go chasing after a
lyfc a" at one time. (2)
v® each one and all of
if^A'Parameters," if you
lute to the specific
>««... 'First-hand on-site
li^te in-Lbest and the use of
(3) rLur?ents reduces hu-
0 obLr°uble-check recheck,
K °bsetv® l0ns- (4) Quadru'
Kf'lse Mpatl°ns reported by
[S°f othPf°rrelate" (compare)
K? 'lew lnvestigations and
Sit *virifnexPeriences. Collect
E^fc(incaseofdoubt-
©J* them i!°Ur "data" in or"
1 reiatf^ in a manner that
Cation i^P5' Patterns of
'• (6) <;ln'eraction between
' back, contemplate
your work critically, then propose
"Passible" solutions based upon rea-
sonable estimates derived from your
own "verified" data. (7) Finally, re-
port your wotk as precisely, orderly,
understandably as possible, revealing
not only the results of observations,
but also, the methods used to obtain
them, times they were made, etc., in
detail. Above all, describe things and
events accurately and identify them
correctly—compatible with the de-
fined problem (step 1).
The "Draft Environmental Impact
Statement; Greensboro-Guilford
County, North Carolina 201 Wastewa-
ter Treatment System" is misnamed.
A jury of scientists, given the oppor-
tunity. would come down hard on this
report on the method of compiling
the information, the pertinence of the
information, and its presentation.
The specific problem before the
Radian investigators was to deter-
mine a "tentative" location for the
proposed Metro treatment plant in
order to delineate the territoiy which
would be affected by its construction
and operation. A subsequent environ-
mental impact study was then to de-
termine whether this tentative site
was suitable for such a facility; that
is, would it, on balance, be ecological-
ly safe and acceptable.
In their hurry, Radian consultants
took too big a big bite, and over-
stepped the defined problem. Conse-
quently, the data compiled from a
variety of others reports (second-hand
information) rambles and distorts.
The confusion cannot be corrected by
entitling the published report inap-
propriately. Calling a rock a "rose"
does not alter its composition and at-
tract bees or sweethearts.
I would like to try for a more defin-
itive name, something like "An As-
sessment of a Tentative Location for
a Proposed Metro Sewage Treatment
Plant." And instead of running bun-
nies all over Guilford County, I would
confine my observations to the South
Buffalo Creek watershed, primarily,
and let the wintering "whitecrowned
sparrow," mentioned in the report,
"utilize" the waste grain around ths
regional airport (in the Horspen
Creek basin) in peace, his presence
and eating habits to be reported an-
other day in another, more fitting,
impact statement.
JAMES REES
Greensboro.
Tickets and fines
for dirty litterers
Editor. The Record:
I think Greensboro is a beautiful
city and I know the city government
and most of its citizens work to main-
tain its appearance of cleanliness. I've
seen the litter patrols along Wendov-
er and Market streets, and I've seen
private citizens picking up litter along
their streets.
This past weekend I had to drive
north on Holden Road from High
Point to Market, and it seemed that
the median was "literally" sprinkled
with beer and soft drink cans. I real-
ize this kind of environmental van-
dalism is perpetuated by a relatively
few drivers, and I'm sure the police
have enough to do, but wouldn't it be
worthwhile if the officers concentrat-
ed just a couple of hours a week in
citing litterers?
With a combination of stiff fines
and some prominent publictiy given
to the offenders. I suspect there'd be
a substantial reduction in the number
of bottles and cans and cigarettes and
fast food containers that come flying
out of car windows to dirty our com-
munity.
JOHN G. HILL
Greensboro.
The Record welcomes letters to the
editor. Lett*rs should be signed and
should include the writer's signatory od-
ditis, ond telephone number. TUIMpi
in to verify the letter and enables im to
cheek wkh the author should any question
tins*. Address your letters to Editorial
Page Editor, The Record, Box 20148,
Greensboro 27<2C.
@be (Breensboro
WILLIAM 0. SNIDER • •
WILLIAM P. CHESHIRE
JUANITA N. WEiKLEY
Greensboro, N. C. 27420
Established 1890
PETER B. BUSH, President
Editor PORTER L CRISP P—cmiu. ...
... editorial Page Editor WIUIAM T. SAUNDERS Adv.. '
«*«»,««.... ":::.S32!ES:
Thursday, Aupsst i, 1877
-------
NOR1H
G1ROLINK
DETRIMENT
OF
CULTURAL
RESOURCES
Raleigh,
North Carolina
27611
August 10, 1977
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
We have reviewed the draft environmental impact statement on the GreenS"
boro-Guilford County Wastewater Treatment Facilities, Project Numbers
37037601 and 37036901.
Division of
Archives and History
Larry E Tise Director
The draft environmental impact statement contains a statement to the
ed
effect that an archaeological survey will be performed by an experie^c
professional archaeologist prior to construction activities. Conse-
quently, we are confident that adequate efforts are being undertaken t0
comply with the mandatory procedures and legislation relating to the
protection of cultural resources.
However, we would like to point out that while the location of the PrC*\tfal'
new South Buffalo Creek Treatment Plant and the route of the proposed
line will require archaeological investigation, as the construction
upgrading of the existing North Buffalo Creek Treatment Plant will tafce
place within the plant boundaries, no investigation of this portion o£
the project will be necessary.
Thank you for your cooperation and consideration. If you have any
concerning the above comment, please contact Ms. Kathleen F. Pepi/ ®nV
mental Review Supervisor, at 919/733-4763.
Sara W. Hodgkins.
Secretary
James B. Hunt, Jr.
Governor
Sincerely,
Brent D. Glass, Deputy State
Historic Preservation Officer
BDG:sw
cc: Berry Williams, DNER
Epf..|\«:>Hr CT MOMENTS
j , - > '
i I i I
Jib'. JlJhti U
HUjIu.i i v, .ii -
-------
JAMt8
!»K,
'ah t.
B. HUNT. JR.
8°Virnoi,
morrow, m.d.. m.p.h.
"CRITARY
STATE OF NORTH CAROLINA
DEPARTMENT OF HUMAN RESOURCES
Division of Health Services
P. 0. Box 2091 Raleigh 27602
August 22, 1977
JACOB KOOMEN, M.D., M.R
Director
~ 1877 y
One Hundred Years
of Public Health
in North Carolina
v 1977 '
John E. Hagan, III
£hief, EIS Branch
environmental Protection Agency
345 Courtland Street, N.E.
^lanta, Georgia 30308
Res Greensboro-Guilford County, N. C.
201 Facility Plan
Draft EIS
Dear Mr. Hagan:
We have received copies of the above referenced plan from both your office
2nd the State Clearinghouse. Our review finds nothing objectionable.
However, we have forwarded the following comment to the State Clearinghouses
A statement was made on page ii of the summary sheet for the
Environmental Impact Statement that the abandonment of South
Buffalo Creek (SBP) Plant may cause a requxrement for vector
control downstream from the existing municipal outfall for
several years. The existing SBP contains some ® .
if not filled in may hold water after a heavy f^^eate
a potential mosquito breeding habitat and a possible infes
tation of rats and flies. Some form of vector ^ontrol program
should be considered for the area due
within the site area. Some plan of ac.^"^^woSd be
actual abandonment ^ and dismantl^gof d method for
desirable. There is no objection to P P
sludge disposal.
Sincerely,
C.Z* * *"
CCs Mr. W. J. Stevenson
Mr. Jerry C. Perkins
—«- •
/times F. Stmey
Assistant Chief
Sanitary Engineering Section
\ci stAll
¦W/V/i;
-------
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-------
Hazen § Sawyer Corny its
1. Operating costs were apparently tnVor -c
data and assume the same operation purl iL -+ cost curve
habilitated South Buffalo 1 f Jf""" cost for rc-
plant. (Some portions of both North BuffPlai}ts as for a new
Plants are more than 50 years old- «»ff»ii* South Buffalo
both plants probably approaches 20 year?tlv® ayerage life at
0 S M costs estimates for the uo^r-irWi li- I- 13 believed that
and South Buffalo Plants as presents * if North Buffalo
as much as 25 - 30% low. PTesented ln the draft BIS may be
2. Capital costs for alternative 7 ^
for several items which would be rpmn'r i 2 n0t include costs
9 MGD plant on the north side of LJ! ?J?r addition of a
from the existing North Buffalo Plant ¦ ° Creei: across
nti These include:
a. Flood protection diking or • •
property to permit location above 100 v1Sl£1011 o£ sufficient
year flood levels,
b. Vehicle access bridge ir-r^o «
"new" and "old" plant sites.° Cross North Buffalo Creel: between
c. Cost for upgrading the exi^t-in o
11 MGD capacity assume solids disposal £ Vth Bu£fa3-° Plant to
no capital investment required to eqSin L ^ge di8estion with
tion. This digestor has not been usedJ 1-gestor foT opera-
least 5 years and it is questionable wWi gestor for at
m operation with no additional cap ^ " Xt could be replaced
p ai ^vestment.
d. Cost for additional aerati™
Bu"J1'? ™?;eofa^d °n.8'; "W tra™fe?P!f^y.Iec « f«t) tMs
3. In estimating capital costc fnv <,i*. ^ .
indicated that the existing South Buffalo Plan^TOld hf equipped
to meet proposed effluent standards over the 5L5 ?n !t ii
MGD hydraulic capacity for a capital expenditure of ? 17 millioi
dollars. It is extremely doubtful if this > i • „°L
the age and condition of many of the niant possible given
equipment. The City has minimized capiS and P™CeSS
plant for several years on the basis that ?*pe*dltures at
equipped on terms of process capabilities wPf*nt V/as, Poorl>\
condition to continue in operation beyondan age na + 1
future waste loads and discharge requirements given expected
4. Operation costs for the Nnrn w *r
tive 7 do riot appear to reflect the fart*^!0 ?lant under alterna-
efforts would approach the levels Plant operation
9 MGD plants since the major tirorpec ^ separate 16 MGD and
arated by North Buffalo Creek. units would be on sites sep-
5. For the
reasons stated above, the
T>~rriT "n m ¦» ^ - > LI16
presented in the preliminary dr^•f^^V^, Xne econ°mic comparisons
the capital and 0 § M cost which wmnl b^ieved to truly ref.lect
ticularly those for alternative 7 C actuaHy be incurred par-
-------
Mr. John Hagan
EPA Region XV
345 Courtland St.
Atlanta, Georgia 30308
Dear Mr. Hagan:
. ,fer
-------
Citizens fox the.
c^/facoun tafcility oj ,® citY of Greensboro has allocated $900,000 from Federal Revenue
-------
Rev, Graves Finally Locates
Home For Housing Project
BY STEVE BERRY
Daily Mmn Staff Wrlftr
~The Rev. Prince Graves has finally found
a home for his federally assisted housing proj-
ect for the elderly and handicapped.
About a month after refusing to let him put
the project in the Rotherwood Community,
the Greensboro Housing Development Clear-
inghouse Commission Thursday spproved a
new site beside K-Mart and next to the Caroli-
na Circle Mall in the northeastern quadrant
of the city.
The $2.1 million project, which involves a
loan from the federal government and help
for its tenants in paying the rent, will consist
of 100 apartment units. The project is spon-
sored by St. James Home, Inc., a non-profit
organization under the auspices Gf Graves's
church, St. James Baptist Church.
The nart step for Graves Is to obtain ap-
proval from the U.S. Department of Housing
and Urban Development Start of construc-
tion is about four to six months in the future.
When Graves bled to locate the project in
the Rotherwood Community, he ran into a
storm of opposition from members of the
Rotherwood Community Organization. One of
the majoi arguments against the project, was
tteft entrap&oa&t& ^roiects tot Vow-income
i Viatel V& fc* aa. <
l
Rev. Prince Graves
the Greensboro City Council approved a re-
zoning request that was necessary for the
project in the Rotherwood Community, but
the Greensboro Clearinghouse Commission
denial the request largely on grounds that it
would constitute undue concentration of fed-
erally assisted low-income housing projects in
a single area.
The same issue came up briefly Thursday
•when commission chairman Tim Burnett not-
ed five federally assisted projects are already
Vacated ta tSbe DRtftaart. aua&rani \he
Ste te \neift«A."Tam»8B. said ttam
are only three such projects in the southeast
quadrant where the Rotherwood site is locat-
ed. There are several federal projects in the
- southwest quadrant, but none in the north-
west.
George Carr, director of the Greensboro
Housing Foundation, told Burnett the pro-
posed site is some distance away from the
other five sites. He also pointed out U".e ad-
vantage of nearby shopping facilities for el-
derly and handicapped tenants. Can's
comments apparently satisfied the commis-
sion.
Unlike the public reaction to the Rother-
wood site, there was no opposition to the site
proposed Thursday. There aren't very many
single-family homes in the area, but there is a
large apartmant complex about 300 yards
awav on Utah Place.
Police Plan Arrest
Of School Bus Driver
Police will arrest a Greensboro school bus
driver today, and several other arrests r"
possible, in connection with the va*"*
25 ot 30 buses outside Pa-
Stfhool .
-------
CLtlzzns. fox tim
cy^fccoun tabitity of u(j[ic tcLa Ci, Cine.
Post Office Box 6660, Summit Station
GREENSBORO, NORTH CAROLINA 27405 July 29, 1977
Director of the Office of Revenue Sharing
Treasury Department
Washington, D. C. 20226
Attn: Jeana D. Tully
Qear Ms. Tully:
We are enclosing the following.
„+¦ fnr information from the City of Greensboro.
Exhibit A - Our request for in^ ^ ^ request]
Exhibit B - The rep y Financial report City of Greensboro.
Exhibit C - Accountant s
We offer the following comments:
nn(.p that as of 6-1-77, 68% of Revenue Funds
Exhibit B - Please:n th Carolina National Bank.
Were located in the N
, y.-. iq employed by this bank in the capacity
The Mayor of Greensboro is emPx *
of Vice-President.
Ao-oosxt. in minority owned banks, although
S^e £ JocJrSno?iWPownea banKs in Greensboro.
ml accountants summary report of Oct. 25, 1976
Exhibit C - The acco inadequacy of assurance in the validity
addresses itself to tn
of internal control.
m 61 copy attached, we are making a request
Therefore, under 51. / made as Exhibit B indicates noncompliance
that an investigation that a line audit be conducted on
with 51.52, copy atta ' Funds by the City of Greensboro, as per
the use of Revenue Shari g
51.200.
31.^uu.
the Freedom of Information Act, we wish to r«
In addition, under responaence regarding this matter, to
ceive copies of aix G vernmental offices, federal, state, ai
include copies of inter
city.
•« furnished to use in the public interest and
This information is rt of public servants is alleged or
wrong doing on the pari, of
imnl i .
ormation is _ > «
^ doing on the part of public servants is alleged or
impliedT
Ypurs truly
'/ '
' ''.'C - y
George Mason
Communications Officer
cc: Congressman Jack Brooks;
nffino of Mi moritv Affairs
-------
Exhibit A
C.iUx zn\ fox tL'H.
cj/fccoiintiiC'iUtij oj ii-ubtic , One.
Post Office Box 1:660, -Summit Station
GREENSBORO, NORTH CAROUWA 27405
Jane '10, J ? 7 7
MA. Tom OdboAne, City Uanaqcx
City 0& Gizznibcio, Noith Cxiotina
Cl-tij Hall - South Ghzznti 5 it tut
GA(L&n&bo>io, NoAth Carolina
Vtati M*. OiboKne.:
Undzn the. FA.ec.dcm o)$ In^oima.tcon Act m\. * » / • i J( - »- „
intimation: the. rfuW.tutfoig
/. r/te name the bank and the amm,*,1- t ¦ ^
and 6-1-77] o< ,«* Ftrfe-Ut KevewtJ S^uST#!.;!!
2. The (i the v l-'cufL r ekzvenue $ha>'i Mruon
Conmuuiic.c.t.ion* 0 (face.*
-------
aiOLUT/0/V
%./K;miTS3»3Sae.
A,
S'^-1916
(II Y OF (iK'lil-A'SliOL'O
noim'H < viioi.i :; \
June 24, 1977
Mr. George Mason
Communications Officer
P. 0. Box 6660, Summit Station
Greensboro, North Carolina 27405
Dear Mr. Mason:
Mr. Osborne has asked me to reply to your request of
June 20, 1977 concerning General Revenue Sharing. The
following is the information you requested:
1. 12-31-76
North Carolina National Bank $1,800,748
First Union National Bank 80,000
Northwestern Bank 800,000
6-1-77
North Carolina National Bank $2,258,736
First Union National Bank 200,000
Wachovia Bank & Trust Company 400,000
Northwestern Bank 20,000
2 Interest is credited to the Revenue Sharing
* Trust Fund to the appropriated Revenue Account.
TMq is used as an anticipated source of revenue
each year in adopting the budget.
cmc.: fd
enc.
Sincerely,
C. M. Conway
Finance Director
hkawkk w-2 ««'•
'¦ r'-ssKxr, vamzmm
SffSBEMf
fc'V.SHOHO, < . -1'? !tn<
-------
C 0 NT E NTS
June 30, 1976
-L
PAGES
-ART I - FINANCIAL:
ACCOUNTANTS' REPORT ON FINANCIAL AUDIT 2
EXHIBITS:
"A" Statement of Changes in Available Funds 3
"B" Statement of Obligations Incurred 4
Summary of Data Submitted to Bureau of the
Census, for the Year Ended June 30, 1976
Note to Financial Statements
-art xi _ COMPLIANCE:
ACCOUNTANTS' REPORT ON INTERNAL ACCOUNTING CONTROT
AND COMPLIANCE MATTERS 7 _ 8
5
o
-------
ESTABLISHED 1908
=0
-PULLlgN- .^fe-1 COMPANY i
CERTIFIED PUBLIC ACCOUNTANTS
EDGEWORTH BUILDING - P.O. DRAWER G-2
GREENSBORO, N. G. 27402
liD
ACCOUNTANTS' REPORT ON FINANCIAL AUDIT
The City Council
City of Greensboro
North Carolina
Tte havP examined the Revenue Sharing Fund Statements of
• f Tinhi'e Funds and Obligations Incurred and have compared
Change.- in_Availau.^ , ded on Bureau of Census Form RS-9 with audited
the financial a&c, f Qreensboro, North Carolina for the year ended
records of the ox y x ination was made in accordance with generally
June 30, 19(O. oflndards, and the "Audit Guide and Standards for
accepted auditmg ^ . ,Rr i_SPUad by the Office of Revenue Sharing,
Revenue Sharing R- t-- Treasury and, accordingly, included such
U. o. Department 0 . J- ' records' and such other auditing procedures as
terto of the accounting lecoia ^
we considered necessary in
..ilon the Statement of Changes in Available Funds
In our op •- obligations Incurred present fairly the revenue,
and the Statement_ o g j_ncurred and status of revenue sharing
expenditures, obHt'-.a GreenSbor0} North Carolina for the year ended
funds of the City o mi'ty wit'n generally accepted accounting
June 30, 197o> basis consistent with that of the preceding
principles appliea J , the adjustments as shown in Exhibit "C!1,
year. Further, wn on the Bureau of Census Form RS-9 for the
the financial data. agreement with audited records of the
year ended J™® JO, 1976, lna.
City of Greensboro, n"1"
(yC - 971 ^ f
October 23, 197^
-------
3
CITY OF GREENSBORO, NORTH CAROLINA
REVENUE SHARING FUNDS
STATEMENT OF CHANGES IN AVAILABLE FUNDS
„. n
Year Ended June 30, 1976 EXHIBIT
Available funds, beginning of year-
Unappropriated
Unencumbered appropriations
Total
Add revenue:
Entitlement payments
Interest
Funds released from obligations
Total
Less unappropriated, end of year
Available for Obligation
During Year
Less :
Expenditures
Encumbrances (net)
Total Obligations Incurred
Unencumbered balance, end of year
Unappropriated, end of year
Available funds, end of year
See Note to Financial Statements.
Per
Bookt
Adj ustments Adjusted
$2 209 173 $ $2 209 1S
2 186 m
2 1B6JI64
^ 395 637
3 154 351
371 304
59
.87 539
8 008 831
2 506 535
... 5 502 296
2 893 622 (
1.50 150 (
3 0^3 772 (_
2 458 524
2 506 535
4 395
63?
3 154 'ill
371
87
8 008 B31
,06
2 5
5 502
296
oQ
9 593) 2 884 Of
11 500) 138 6^
>1 093) 3 022
11 093 2 479 61?
2 506
-.965 059 $ 21. 093 $4 986_Jl|§
-------
CTTY OP GREENSBORO} NORTH CAROLINA ,i|.
REVENUE SHARING FUNDS
STATEMENT OF OBLIGATIONS INCURRED
Year Ended June 30, 1976 EXHIBIT "13"
per Questioned
Books Adjustments Adjusted Costs
Or> era ting/maintenance
*egp«nd«ure»: * 657 136 # 5 21»)» 651 922 $
Public safety -1 9
Environmental protection - ^ _
Recreation ^ qq2
Libraries ^ '
Social services lor e ^ ^
iCLS administration £*& I 5-229) SL§25
Total Operating/
ExpendTT? 188 ( 10J311+) 76a 274
Capital expenditures:
Environmental ^ ^ ^
protection ^ 22q ^ 8 2n ^Qg
Public transpor - Q g g
Recreation
Mgene?aIPgove?ment 1IL£J2 ( a 583)__m_032
27 819
4 7 002
Total Capital
Expenditures 2 271_m L_10^79)__2^60 405
Total Obligations
Incurred ogg 679 ^
See Note to Financial Statements.
-------
CITY OP GREENSBORO, NORTH CAROLINA
REVENUE SHARING FUNDS
SUMMARY OF DATA SUBMITTED TO BUREAU OF THE CENSUS
Year Ended June 30, 1976 EXHIBIT
"C'
PART I:
1. Property taxes
2. Sales taxes:
General sales tax
Gasoline tax
Liquor tax
Cigarette and tobacco
taxes
(e} Public utilities tax
(f) Other
3. Licenses, permits and
other taxes:
(a) Income, payroll or
earnings tax,
local
(b) Motor vehicle
licenses, local
(c) Fees retained frorri
tax collections by
officials of your
local government
(d) Other
4. Taxes for education
PART IX:
From State:
1. General support:
(a) Property tax
relief
(b) All other
2. Streets and highways
3. Education
4. Public welfare
5. Health and hospitals
6. All other
From other local governments
From Federal Government
(directly)
Reported Audit .
to Census Ad.justments Ad,jusjfcgS-
$18 944 539 $
3 676 936
71 335
I89
660 366
4 222 484
1 811 367
314 9?7
1 179 041
9 259 395
$18 944 539
2 676 936
71 335
lSJ
660 3$
1 000)* 4 221 m
1 811 3&
314 9f
1 179 o^L
259 30
To correct compilation error.
See Note to Financial Statements.
-------
CITY OF GREENSBORO, NORTH CAROLINA
REVENUE SHARING FUNDS
NOTE TO FINANCIAL .STATEMENTS J
June 30, 197& y ^
Significant Accounting Policies.
rrhe accounting records of the Revenue Sharing Funds are
. f-hp modified accrual basis whereby revenues are
maintained on ^ caghi Expenditures are recorded as
recorded ao ruct-j-vc
incurred.
-------
ESTABLISHED IOOQ
CERTIFIED PUBLIC ACCOUNTANTS
EOGEWORTK BUILDING - P O. DRAWER G Z
GREENSBORO, N. G. 27402
ACCOUNTANTS 1
CONTROL"
'ET'OPT ON INTERNAL ACCOUNTING
AND COMPLIANCE MATTERS
The City Council
City of Greensboro
North, Carolina
. We have examined the Revenue Sharing Fund Statements of
^hai.^es Available Fi.ndo and Obligations Incurred, and have compared
the : mancial data included on the Bureau of the Corpus Form ES Q with
the v udited records of the City of Greensboro, Sorth 'Carolina fo? the
year ended June 30 1976. Our report thereon! which appears on
, M®?"11 1!" U Pertai"s to Exhibit c for the reason set
fot ..h tne.ein. Our exdroindtion was made in accordance with generally
accepted auditing standards and the "Audit Guide and Standard- for
Revenue Sharing Recipients" (Guide) issued by the Office of RevenL
Sharing U S Department of-the Treasury ."Sa
such tests of the accounting records and such other auditing
procedures as we considered necessary in the circumstances. As part
of our examination, we made a study of those internal accounting ™d
administrative control procedures and compliance matter- 'that C?
centered relevant to the criteria estabUshed by th SlT^e of
Kevenue Sharing as set forth in Section V.D. of its "Guide"?
^mable^^f^ofa^^tefls^rancra'fiS^r"^?1 iS £ pr0Vide
e-,3 against loss from unauthorized use or di-«osi ti nSgthf
lability of financial records for prm?inf??n 'at"? \
naintaining accountability for afLto rj lt}a-^oial statements
j * „ ,, , . -LXiUJ- assets. we understand that -t-ho
u'ance as to compliance with its related reqS?™entf'^The concept
reasonable assurance recoenl?pq that- - ine concept
.-•ml control should Sceld the benef??^0'PT ?f
agnizes that the evaluation of the-e f,AtA derived and also
imates and judgments by management" 2'S necessarlly requires
rea
arts
rel
and
obj
the
a s s
of
i n t
rec
est
There are inherent limitations
considering the potential effectiveness
cor,"., -ol. In the performance of most con
result from misunderstanding of instruct
carelessness or other personal factors,
effectiveness depends upon segregation o
by collusion. Similarly, control proced
intentionally by management with respect
that should be recognized in
of any system of internal
trol procedures, errors cart
ions, mistakes of judgment,
Control procedures whose
f duties can be circumvented
ures can be cire urnvented
either to the execution and
-------
8
recording of transactions or with respect to the
Judgments required in the preparation of financial
-------
(DUES AMD SmJUTHXMS
request of the OfTlce of Revenue' Slurring,
any State or local utrency which bn.i
been legally authorised to monitor lti
civil rights compliance activities.
§ 51.60 Compliance r*vUrw» rimI affirm-
ative action.
fa) Compliance reviews. Tht Director
shall monitor and determine compliance
ot recipient governments wltti the re-
quirements of this subpart ar/d ot the
Act. Compliance reviews will tis under-
taken from time t» time, as appropriate
and, feasible, at the discretion of the
Director. Such reviews shall be com-
pleted within 180 days of initiation by
the Director.
(b) Affirmative action. Any recipient
government which has been determined
to be in violation of any provisions of
this subpart shall take such notion as
approved by the Director in order to
remove or overcome the constqaences of
such discrimination.
(c) Equal Employment Opportunity
Coordinating Council Policy Statement
on A formative Action Programs lor State
aid Local Government Agencies. The
Equal Employment Opportunity Co-
ordinating Council has Issued a policy
statement on Affirmative Action Pro-
grams for State and Local Government
Agencies. This Statement which has
boon adopted by the Department of the
Treasury (41 FR 38814) provides addi-
tional guidance to States and local
governments In meeting their affirmative
action requirements. The EEOCC policy
statement is as follows:
Equal Employment Opportomtv
COORDINATING COUNCIL
AFFIRMATIVE ACTIOM PROGRAMS FOIl MTATK AND
LOCAL GOVERNMENT ACLNC'.T.'J POM.:* 8TATK-
MFNT
The Equal Employment Opportunity Co-
ordinating Council wan established by Act
of Congress In 1972, and charged with ro-
aponnlhlllty for developing and Implementing
agreements and pollcleu designed, among
other things, to eliminate conflict »nd In-
consistency among the agencies of the Fed-
eral government responsible for adminis-
tering Federal law prohibiting discrimina-
tion on grounds of nice, color, sex, religion,
and national origin. ThU statement la issued
as an Initial response to the requests of n
number of State and local officials for clari-
fication of the Government's policies con-
cerning the role of affirmative action In the
overall Equal Employment Opportunity pro-
gram While the Coordinating Council's
adoption ol this statement expresses only the
views of the signatory agencies concerning
this Important subject, the principles set
forth below should serve as policy guidance
for other Federal apencles oh well.
1. Kqunl employment opportunity Is the
law of the land. In the public sector of our
society this means that all persons, reixard-
lesa ot race, color, religion, sex, or national
origin shall nave equal access to positions in
the public service limited only by tlr.eir abil-
ity to do the Job. There Is ample evidence In
all sectors of our society that such equal Ac-
cess frequently haa been denied to members
of certain groups because of their .ie it, racial,
or ethnic characteristics. The renpedy for
such past iud present dlscrlmin ition Is
twofold.
On the one hand, vigorous etiforciment of
the laws against discrimination It essential.
But equally, and perhaps even more Impor-
tnt are afflrmattva, yiw art4rr» eCI'w 1 * aa rtlo
part of public eoiplcr.ners to BQBnt* t.lf»t jkmI«
tlons la :he public fK-rv **> are .U : riy cn-,1
equally x.&:o«slble to qualified pnrtixi*, with-
out regard to their sax. racial, nr e U:j!c
charactorl&tlai. Without nuch uflortj nqual
employment opportunity hi no morn than r
wish. The importance of voltin'wy alflrma-
tlve action on the part of empUyww* is un-
derscore; by Title VII of the Civil rilnht«
Act of 14164, Executive Order 112'-8, and re-
lated laws and regulations—Ml of i».Mch «m-
phaalae voluntary action tc achieve equsvl em -
ployment opportunity.
As with most rm.iviKoniout ob|wLlv«n, a
systematl1: plan bLie<( on sound organisa-
tional analysis and problem Identification is
crucial t:> the accomplishment t.f nfilrnm-
tlve action objoctivea. .P'oi' this r<->a.ion, the
Council ur^ea all State a.id local f;o-r .¦ :1 rr-enl.'.
to develop and Implement result* oriented
affirmative action plans which d'-a ¦ Lth the
problems so Identified.
Tho following purugrtphii are invmled to
assist 8tate and local governments 1>./ Illus-
trating tho kinds of rinolj-ses and activities
which miy be appropriate for a puli'.le em-
ployer's voluntary affirmative ecfior. plan.
This statement does not address reraodtaii
Impound after a finding ol unlawful
discrimination.
2. Voluntary affirmative action tr.- unsure
equal employment opportunity Is appropri-
ate at any stage of the ompSoymsnt process.
The first step In tho construction ot any
afflrmatlvn action plan should be an analysis
of the employer's wort rohjo to le (.ermine
whether percentage? of acrt, racn or ethnic
groups in Individual Job clanHflculm arc
substaotittlly similar to the per-enures of
those groups available ti the work; force In
the relevant Job market who ponsc.se Die basic
Job related qualifications.
When liUbstantlal disparities nro found
through such analyses, each clement of tlic
overall selection proems should bo examined
to determine which elrrments opnr, tin
¦selection, hiring, promotion, etc, 'H-.r exami-
nation of each clement of the selection proc-
ess should at a minimum Include u deter-
mination of Its validity In predlc'lni; tob
performance.
3. When an employer has reason to believe
that Its selection procedures have toe ex<-lu-
lilonary effect described In paragraph '.! above.
It should Initiate a/Hrmi.'ivc steps to rrnu'd.v
the situation, Such r.topn. which i.i 'lc;lf;n
and execution may be rare, color, w? ut-
nlc "conscious" include, hut arc uei 'linlfrd
to, the followlnf::
'1'hc establishment of « long term t:< »1. mid
short range, interim goal-; aiid.llnrrtiiiUcs lor
tile specific Joh clasrlllt'iu If.iis. nil ol which
should take Into account the uvallnU li(v of
basically riinllfted per-'.-nn in ll'.e r'.c\a:it
Job. marHc::
A reenntment prurra n desli;i ei| to m •
tract qua:iilcd iiii'iiiIwi- of tin- »rn.ip m
r,:nnIze v(ns;
The Initiation of mew.ures deslf^ed to »n-
sure that members ol' the affected group
who are qualified to petturm U r J b ure
Included within thr pi».1 of pcr«>;i:, from
wJi.lcb tlie Hil*cUag oiQckol mrtfVei tb*
aeloctlon;
A jysttmall: effort to provide career *d-
va iremrnt training, both clnsnroom mid on-
thT-job, 'n muplojwes locKed Into dead end
Jobs; Hid
The octstll'd' meat ot fciryiteiii for rAgularll
monitoring un eUeettveneM of the particu-
lar afttcTuittv s acUfiri jwrogrim, atul ptooe-
dur<", for malt.,' jg tliaey ikdjustments In this
proftr&m »!)».-( ereetlveaess Is not diauon*
strand.
<: The gcol uf any afflrmatlvs action plan
»hould be u- ilevarnent of genuine equal
isniployrnorrt c iprirtunity for all qualt^ed
persons. 3c!ei tmn under such plua chould
be haaed upon the ability of tbe applicant!*)
ui do the wcr . Such plaae siould liot re»
quire Uie selooilou of Ute utiquiLlUled. or the
unnended, rioi- wliould they requlro ttvfi selec-
tion of per io u on the bo sis of nice, color,
Bffx. reHglon r: • national origin. MoreOTiT,
while the Coindl belierei. that this utnte-
ment ehould mrvo to assist £ttate wad local
employe™, qa msll as Todoral agencies, K
rci ':vnlKe; t!i»i ofnrmatlve action cannot be
vlewol us a stw»l!i avithorttU'S, Btute and local
employers have QuHblllty to formulate s.f-
flrmnf lve actfori plaas that are beat suited to
their particular situations. In ttols manner,
the Council UeJluvca that afllrKiatlve action
prci,runis w:il >i«et serve the goal of equal
employment opi«rtunlty (41 PR. 38814).
§51.61 Atliniiiiiitralive complaint" a"1'
iyn I iunn.
'tv1 Administrative cumplainU. Any
person who believes anyone has been
subjected tc discrimination prohibited
by this iiibpai t. may personally or by 3
rop/encntattvft flic with the Director of
the Office o! H-:vc/iue Sharing (Treasury
Den.-irtrmTit, Washington, D.C. 2022C) a
written staootnent setting forth the
nnture oi tlic olsciiminutlon uDeged an*1
the Tact;! upon which the allegation i?
based. No representative of a recip'""'"
rovernmen! ri<:r any ot its agencies shall
intimidaM, threaten, coerce, or discrimi-
nato fkp\inst any person or class of per-
son < botT..i';i,' ol tc;;timony, asi.lstaucc, or
liatUetpatiou in an investigation, pro-
rceillnp, or '.ica-ini; under tills subpart.
il)) truest! jiUiona. ill The Director
••iliaII advise tlir chief executive officer of
the roiiiuotiL % ivernnient oi' any admin-
• >tr.-.tivc coiiii liint received pursuant to
pariuuaph 'a) witliln 30 davs ot the
rcccip', of such complaint.
i") II the Director has reason to be-
lieve that Lie administrative complaint
shotvLi that a iccipient Bovernment has
fat lid to coiv.ily with tho provisions oi
this subpnri. u.i investigation will be
mime by tin c rite of Revenue Sharing,
or other apivopriate I-'edcral or State
n.< y. of Die arugram or activity con-
cerned within OP days of receipt of such
complainl alleging noncompliance by the
recli lent provernmtnt with the provisions^
of Uils subpiiri.
<3> The ItirC'"tor shall make a finding
within 90 d,tys from the time of fllinB
of i compliii'.t aliening noncompliance
by a recipient i overnmcnt with the pro-
F60JRAI REGISTER, VOt, 43, NO. S.S—WEONSSOAY, APRIi. t, 1977
-------
Subpart Nondiscrimination by Rocfpfent
C»ovornmon'.» Receiving Entitlement Fund;*
Sec.
61.50 Purpose.
^161 EVUiiltWma.
61.63 Discrimination prchU'lU'd.
61.63 Employment dlscrln.nft: ion.
61 64 Dlixrlmtofition on th'i basin of box.
61.55 Rep-ervcd.
61.50 Discrimination on the .basis ol na-
tional origin.
61.67 Discrimination on the bfiMs of r» ¦
ll-jlcn.
61.50 Asnurimees required
6) 6d Compliance Information and ivp»>ri»»-
61.60 Compiianco reviews and ftfNrmaUv»
action,
81.01 Administrative coMplfunts nntrativc reme-
dies.
5106 Proccdu/c for effect: rg romplWJioe.
M.Cfl Hcf.riinj* before a.liiilrlstniWve l*M-
61.07 Holding by a court. >n FWlnrul K'.»vp* P
ment-ii m:t»ncy-
61 On Procedure for effect Ii.k .jomplift'io* m
ca«?e of holdfn#.
60 Initial decision of it.'.mlnl'rtraMve
JpurHiiant r* -967.
61 70 Resumption of *;w ponded coilm-
incut payment*.
61 71 Cnmphaiure ar;rcen>»uit«.
M 7.: H»'r.rini; procedures.
' M Jurhultrt ton over pr i'iny
«f'i 71 Ai rcchii i\t butvrMi ,n;cnruv;.
61.7* Authority of the Attorney ar«<-r;«: <•
it.e rr.ited Stutos.
A"1'intuiTv : .State and Ia**! As;lslai"'f A section 122 of tl •! Act to the en"
no pri'j.i n in the Umt/d States r.h.i
<«i I In? of run;, color, national (in-
'-'In. or m>x. v.< excluded -Vow pat U«'.l!i8"
f>on in, b" (!';>i<.'d the benefits of or t><
"ibjeetPd to ilisnirninsilijn under mi>
|lr''i:i';iin or activity of i- recipient- |!'n'
'•I'iini.-'nt, v.'hi.'li iiovci iiiiH'iit f - •' ^'
'''i'f.:¦ imi'lc im-iltibl' un.ii'i- siil>' art-
Any prohibition acai'i-'-t, li: Timim'1'"1
'•"i the basis ot age undor the Ai-.e »"•-
!'i-lmiaat.ie -"'i 1
'« »ii otherwise quulifl'<. hawhcm-'l'^
inf!ivif;• j.• i n: provicii in ocction
1'i'h..lji!iti'.tion Act of 137.**. «
•b ¦ Civil llii.hts Act of IOCS, sh0'' ?t
I'hply in iin.-' :Mch projru.n or
. •*' 1 ..7 I 1
I'rjithe context rcrpihTS ot-h'!r>'-1 P.
u (-(l iii this subpart, ti.e term:
.1 ¦ 'Amp m,-.crimination" refers t
• ' .rrii:i:11i(iiI on Ulfi bfW.ls of !,KC
KULES AMt) REGULATIONS
•lie \| P Discrimination Act ol 1975.
' . t i ""ompliaiicc review means j. re-
,,' .J"recipient's selected employment
' Si;S, or delivery of serv-
low for comiiliiuice with the provisions
includes all or any part
r -Lructures, er mean-
1 U'Tnvesmn Mon" inciades both
. , .. rijnu efrr.r'Ji iind attempts to se-
whmt^y resolutlcn or com-
'•¦i.rogn.m or activity" uienns Wi'
ggZilmSU M* ,l;' "TiP""
^ ^ jiMriiuiiiaLi(>n" refi'rs
' ' n?-nhibitkini affixinst ctsrriniUia-
-
the Civil ltiulHs Act of J9b».
s " I 7,2 Di^rbuii'"*'"" proiiil.iKHl.
s »ii»i*/71 No Dcrson Hi vHo Uuitcd
1; '?» W theVround of ir.ee, c^lor,
.'jliiL'.s m.U. on tl f bc rJtr„uicd from
iiaLii'ii;-! CMC1IV - (ioniotl t» 10 bcnelHs
p;irti' ii,:,L'011. (Uscrinii'iation un-
!.f. or bc M,t.ject^ ^ rL,n,jlent
,i..r ii. I.v l,roB"! r;„ , VovernmPdt receives
Kovrn.n-int ft hi ¦ <• ndl;1. St|btiUe A
i»"SiiWUon ai:ain,t ¦dw-
dl I in- Aot. Any I Js of a„c under
rr.minHton on - Uon Acfc of i81»
the ->«®,.^.Vrrcd to as cimcnmina-
iluM-iuii.tei Jp'( 1( or v.-itli respect
t ;on on I ie bn^ jwinbcapi>ci i»-
"•ll" ""U'rVV J i" wctior, :>04 of the
v„| I. wprovwi «'»'»•„ .n, .hereinafter
U..-hi.t>'U"'t''^j^'^mination ou the ba^w
relen*«'-l 10 M.,u,o or m'.v prohib -
«f '|i:'»,;1^c-!^ntion oi: the bosi.s
lion u;;anw>t d..» • 8ny exemption
ol rcli:.i«m. „ provcied in the
iron miic-J ]"0 or j304 or the C"»v"
ri'"" S of Ul ¦.hewlnafU-r rererwl
1;ii:1',1 / m i ati' m onthebaUsofreh-
|!JVi,n or ac^ily'n (rivlinatoty actions
>¦»-. tvXml e'vemmmit
£V n,^ on thr ui«?«» of '
jii<1I ;,riKin;/'s',,^,e or oil er benefit
tn iy my V
l"'in • i„ "vice or o'.her bene-
r/^inVh,VAff«';n'-?r iHP'-ovuled In
a different form from that provided to
others.
i ii>) subject ftny person to sefrregated
or sep irate tref.tmont in any facility or
in any matter or process related to re-
ceipt c f any service or benefit.
lit) Restrict In any way the enjoy-
ment of any advantage or privilege en-
joyed by others receiving any service or
bene ill.
(v) Treat an Individual differently
from ethers In determining whether the
Individual satisfies any admisnlon,. en-
rolhrevt, eligibility, membershlpi or
other requirement or condition whlcli
individuals muut meet In order to br;
provided any service or other benefit.
<2> A recipient government shall not
on r.'ii ground of race, color, national
origin, sex. handicapped status, ago or
reilfiion:
Ui Deny any person an opportunity to
participate in a program or activity as
an cm! loyee.
(ii1 Deny any person an equal oppor-
tunity to participate as appointed mem-
bers Oi planning or advisory bodies In
connection with the disposition of en-,
titlemcnt funds,
<31 !n areas of employment, a recipi-
ent government may not utilize criteria
or methods of administration which have
the elTect of:
U) Subjecting Individuals to discrimi-
nation on the basis of race, color, na-
tional origin, sex, age, handicapped
status, or religion.
a recipient government may not
on the ground ol race, color, national
origin, or sex make selections of site or
location of facilities which have the
effect cl':
including individuals from such
facilitii'S.
i ii-> Oenying the individuals the bene-
fits of such facilities.
i iii i Subjecting individuals using vhe
facilities to discrimination.
ifn Recipient governments are en-
l ourat'.i'd to take action with entitlement
liinil-i u> ameliorate an imbalance In
.serviiT! or facilities provided to any
fieoKi apiiic area or specific group in order
io over 'oine the effects of prior discrim-
inatory practice or usage. If a recipient
vnvptnuwnt funds a program or activity
whii'h is found to provide an Imbalance
of set* ens ,or facilities to persons pro-
tected by this subpart, then such im-
balance shall be ameliorated. f
• C) The enumeration of specific forms
of prohibited discrimination tn this par--
seraph does not limit the generality of
the pro ilbition in paragraph (a> of this
section. " '
itn i.temptions. The provisions of
piiragrcphs ia) and ib) shall not apply:
ill H'nere a recipient government
rkinon: I rates by clear and convincing
Fnutr-A
hloi> in
, VOL. 42, f W-WStiMlSOAr, AMU *.
-------
•2m
Title 31—Money and Finance: Treasury
CrJAPTER I—MONETARY OFiK.TS,
DEPARTMENT OF THE TREASURY
I'ART 51—FISCAL ASSISTANCE TO STATE
AND LOCAL GOVERNMENTS
Fiscal Procedures and Auditing; Interim
Regulations
Notice Is hereby given that pursuant
'to the authority vested in the Secretary
of the ^Treasury by the State and Local
jjlscal Assistance Act of 1972 (the Reve-
vue Sharing Act) as amended by the
Rrtato and Local Fiscal Assistance
Amendments of 1913 (31 U.S.C. 1221 et
jeq.) the Department of the Treasury
hereby adopts the following interim reg-
ulations In Part 51 of Subpart Is1 of Title
31, Code of Federal Regulation*, which
became effective November 18, 1976 (40
BR 53355). Additional regulation will
be issued at a future date to conform the
remaining subparts in port 51 of Title
31, Code of Federal Regulations, to the
1 State and Local Fiscal Assistance
Vmendmenta of IS78. •
Regulations appearing in Subpart a,
¦roceedlnas for Reduction Enfciulement,
Ylthholding or Repayment of Funds,
lumbered 8S 51.80 to 51.105 are redesig-
nated §} 51.200 to 51.225.
Present 8 51.70 of the regulations is
¦^designated as 8 51.100 and paragraph
[to) of that section is amended to provide
,hat a use, obligation, or appropriation
)f entitlement funds shall be consistent
/tith the State or local law requiring a
tfgislative enactment in ordinance or
•esplution form. Present 8 51.70(d) (3) is
•edesignated as 8 51.100(d)(2) and is
amended to elaborate upon the extent to
which fiscal accounts must be main-
lined to permit tracing of entitlement
funds to a level of expenditure adequate
;,o establish compliance with the pro-
visions of the Act and regulations. A re-
Mpiont ^government jshtill eithej- njftia-
netrt'S separpesefc ofira3"acco'iiiii&J sep-
irate"bank account, or a ,memorandum
Mirtord of voucher numbers ancl J ,mparts
CSrmtIf3^^t"fuiu<^£xSen(Je(l, Present
5 51.70(d) (2) is rescinded.
Present 8 51.71 is redesignated as
8 51.101. Section 51.101(a) provides, In
cfi&eraL thaLwh .recipient, gemsmmunt
a'aaU. have.an. independent audit of its
financial statements^conducted in uc-
corflance jKl^ieneraH^' icceptefi audit,
ing standards at least once eve.-v three
years~for the entire'ttftee" years,'
""Section 51.101 (b)^deffies "independ-
ent audit" as an audit conducte.1 by in-
dependent public accountants, or quali-
fied accountants or examiners from a
State agency, who have no Interest in
the financial affairs of the government
being audited. Where the audit of a local
government, under State or looal law is
made by a State official, or where the
local government maintains a perma-
.nent auditing office responsible directly
to the legislative branch, such audit
Khali be considered an independent audit
Section 51.101(c) (1) defines "gener-
ally accepted auditing standards" as
those auditing standards pronounced by
the American Instttute ot Certified Pub-
lic Accountants and Incorporated In iti
RULES AND REGULATiOMS
Statements on Audit p-.-occdom- and
tn summary t(rm ir
"lf Standards for Audit of o( v,.r.-»ner,-
tai Organizations, Programs Actlvltl*'!
and hmrfton, as i*.issued in 'l wjth
StatM r °eneral of
Sectjon 51.101 (di and (e) u.k,
ta m,,kinir'^
i. rvvuw»w» tut v
™.:s"cl1 government i*
stantlal nrofjreps towards miM, r "i. """
counts auditable. Iltnic4^ h'; lta.nr-
i e„ notification to the Dire -t^/ tT3 lvel'-
accounts are unaiirMMhirt thu,t J^i
by the bo
March 31, 197a. utnt on. or before
Sectloa 51.10*3 tu ,
r may rely Unr.» that tne Direc-
Departii'ien Written comment? may be
iubrnitteo, in triplicate, on or before
l"ebru;iry A, if»77 to the following ftrf-
(iresd:
Iiirepto:-, O'Nco of Revenue Sharing (Symbols
iO'V'Q8 W»»hI''gton. P'O-
n. Pomirie ':5ukmltted tn rc5por1.se to
this solicr .ii tloa arc available to the pub-
Ac ujon v/i-lttcn request pursuant to the
I'reeuom of Information Act and the
rcculatioria proriuiliiated thereunder l>."
l!io Depart-nent, HI CFIt l.l ct. seq.
Dtuwi: January,), 1977.
JeannaI). Tui.ly,
Director,
O ffice of Revenue Sharing.
Approved:
.Tbi'r-,' Thomas,
Vn l;r Secretary
ct the Treasury.
Part 61 of 21 CFR Chapter I is amencl-^
od asfollwfi:
1. The re :titms in Subpart O. currenH}'
liumbered !i5 ni.80-51.103, are renum-
Oered 11,3 8;¦51.200-51.225 respectively.
2. Subpa't 1;| ia revised to read as
lows:
S.:c.
• «rt F-—fiscal Procedures and AuditlHj5
of
Sectioa 61.104 Sf12fnte.',f *
dered with respect to audit? t-1?"3 mi"
a iJim Of the audit n-n^rr 11 "
With opinions in genial Jl'".I?'r',?;*dj
to financial statements
nnvo
IwSnl te amended
the scop? of each audit^l!?, that
separate fund matatiinl^int;iurif-
ent government anri v^n -V fl rfclpi-
nscal data as report of iUi
reau ot the Cemus rti ly tlle &*•
audits are the Stan-ioSi ^'s :or Slu'h
Governmental Orpar^itf ' Au,lit °f
Activities, and^ST'1 Pro^nW,
'"Ons is:>nri1 ht» 41. _
VU163, and I^Liiotirvn. ; ' 1
Comptroller Genera^'of hL t-1';0;'1 by tJ p
'icl the
Sharing RecJplSto ^wflf lov R''ven».o
fice of Revejiue Sharing tl,e °''"
Because the purposp n
regulations is tn nr2,?f tlu:S( interim
«»ce to the Statos '^r^61,1 Ue >
ments in order Unit ih<> l(' covem-
of the Act, as amene'ed h«
it is hereby found imiirT°H1r'!,>'Iei:1
such regulations with to ls,M::e
Public procedure 1 "we a art
853(b) or subjMt trs th1 Undej' 5 TJ.S.C.
limitations of 5 U.S.C. 553fef>T< ,VC
.tall b,„
1977. It Is expected thnt r ,,fu:"ar,v t,
illations will be isruiMnn1f£riIUnent
and for this rcasot v", ^ "!' ir
e solicitPd fot'
HOERAl REOISTCR, vot. 42, N0
Ijl.lOO Pr'Kijrkires ani:llcal)lo to thr uso
pj.101. i\iid tl>i[; mid ci-Blunt.lon.
la 10:! Wrlvcr of aurtlcliir; pro'/lfilonn
r nimn -ini nccowatii ma •jmiucUtttt'"';
''1.10,1 Itp.lxnc.a \ipon othur Federal nut"'
at tmcten.
Avirtlt opiutor.'i.
101;. OT audit!!.
¦U.tflii Rat 'iitlou of audit work papers.
Ji.lJT Up a ,;Ir1-100 I V< ii|'plic"
couni", mr.y be established.
(b) \Ts'», obligate, or appropriate su"j
limd.s ¦witliiu :>4 months from the end 0'
•he entitle nent period to which the W»"
u clement payment is applicable. S"fJ
i.u:e, obligation or appropriation of
Utlement funds shall be consistent wt"
•state or lonul law requiring a
enactment in ordinance or resoiuti01.
form. Any in|j?rest earned on such fun"'
while i:i trta trust fund shall be used, °''.'
iicated or appropriated within >
month!, iiv.m the mid of the entitlpio^.
period duiing which the interest w f
received or credited. An extension 01
tune in w/iicit to act on the funds, or i1'!
tores'; earned thereon, shall be obtain^.
!,y Hpplir.r t,ion to t.He Director. Su^j
appltcatior v, ill set forth the facts
eircunvitfu.ce? supporting the need *"
more tune and the amount o( iiddi"0' v
time, riiqucsted. The Director
¦Tuesday, januass- jj, ,977
-------
LAW OFFICES
COFER, BEAUCHAMP & HAWES
SUITE 200.PEACHTREE & BROAD BUILDING TELEPHONE:
404/577-6200
Th ATLANTA, GEORGIA 30303 TELEX:
0HAS H. RIES 54 2326
August 29, 1977 coS™-^
John E. Hagan, III,
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30308
RE: Pre-Public Hearing Comments by City of Greensboro
Draft Environmental Impact Statement
Greensboro - Guilford County, North Carolina
201 Wastewater Treatment System
Project Nos. C37037601 & C37036901
Dear Mr. Hagan,
Pursuant to EPA's notice of July 29, 1977 respecting the
above referenced, we submit the following comments on behalf of
the City of Greensboro.
These comments are based upon our review of the DEIS and are
presented in summary form for your convenience. We would be happy
to further discuss our views with you or your staff. The City
of Greensboro expects to make a short presentation at the public
hearing scheduled for September 1, 1977, and it is expected we
will prepare and file additional written commentary for the Record
after the Hearing and before the close of the Administrative Re-
cord on this matter, September 15, 1977.
The subject Projects under study are of substantial size and
complexity. While the City's preference is for implementation of
Alternative 4 (the confluence site), the EPA environmental re-
view to date represents a very impressive data collection effort.
-------
LAW OFFICES
COFER, BEAUCHAMP & HAWES
John E. Hagan, III
Page Two
August 29, 1977
Our comments are filed in a constructive vein, intended to
clarify certain information presented in the DEIS. With a project
of this magnitude, assuring public understanding is a herculean
task. Further, the choices which must be made in the selection
of an Alternative will stimulate public concern. Our overriding
objective is to secure the broadest possible public understanding
of the Project and to select an option which will cure the City's
critical, current wastewater treatment needs and provide for
orderly, future development.
Our observations and comments regarding the content of the
DEIS are as follows:
DEIS "SUMMARY SHEET" (Pages
DEIS "SUMMARY" (Pages 1-14)
A more detailed history of
rmal and formal notices and
the City, DNER and/or EPA;
-pass resulting in severe
-------
LAW OFFICES
COFER, BEAUCHAMP & HAWES
John E. Hagan, III
Page Three
August 29, 1977
these problems should be set forth in the Statement's full text
(see our comment regarding page 11-140, infra.)
Page 9 - Text at this point or elsewhere (e.g., page 111-32)
should reflect substantial record of community opposition to
maintenance of South Buffalo Plant and EPA's findings of July
12, 19 77 regarding implications of Title VI of the Civil Rights
Act of 1964 (42 USC §2000(d) et. seq.).
Page 10 - comment in major paragraph regarding water quality
presumes continued stress; this comment confusing in light of
previous statement in same paragraph noting that episodes of poor
quality would be decreased and in light of mitigative measures
set forth at pages VI-6 through 9.
Page 11 - comment in first full paragraph regarding chan-
nelization as degrading water quality should reflect parameters
used to make this determination; data regarding dissolved oxygen
at South Buffalo before, during, and after dredging (1970-1977)
appears to undermine conclusion in Statement regarding channeli-
zation.
Page 11 - Discussion of the affects of "urbanization" should
include the adverse environmental impacts which would occur ab-
sent implementation of the preferred alternative; this analysis
could rely in part upon the previous history of septic tank
failures and ground water pollution. "Benefits" of proposed action
and other alternatives should be noted.
Paqe 13 - discussion of preventive measures for soil erosion;
measures are not summarized at water quality section, as noted
in the paragraph. Why mention a mitigative measure found to be
"unnecessary"?
CH. I, "INTRODUCTION" (pages 1-1 through 1-7)
Page 1-1 - discussion of decision to prepare EIS should in-
clude a description of Radian Corporation's involvement and
Radian's contract should be exhibited among the Technical Docu-
ments .
-------
LAW OFFICEG
CO FER, BEAUCHAMP & HAWES
John E. Hagan, III
Page Four
August 29, 1977
Page 1-2 - comment at this point in text and throughout the
Statement regarding hydraulic capacity of South Buffalo Plant are
not accurate. These comments suggest SBP is not hydraulically
S™ conflicts with an EPA directed study
of December, 1976, which was presented in a report prepared March
1*7 / / •
Page 1-2 - mention of "legal agreement" at top of page con-
fusing; if this is a reference to disposition of a previous law
suit involving Horsepen Creek, the characterization isirong.
ITs ^"consentLc^Infn^T* t0 EPA'S and the?4
Ihl "severabilitv of 5 ntlnuin3 Jurisdiction. If appropriate-
could ^ d^scusSd. ^ H°rSePen ^om the Metro pSj-St
forth^fer^procedurerpSrfMnt3^™??350^^11 "D" settin?
elude this information in the discussion o? ™CA'
Page 1-1. These procedures include nn+-i Aspects at
for September 1st, availability of * ? 9 he Publlc hearing set
comments, projected timetable for a f^i^o °pex± "jord for
of Step 2 and 3 procedures under Title n. ^CA? 3 SU
Ch. II, "DESCRIPTION OP RYTRrnrwo
11-140) ~~ — G ENVIRONMENT (pages II-l through
Page 11-35 - First four lineq rvF +.1.
underlying quantitative and email tat.- ^ page should include
elusion; this matter relates V f a in suPP°rt of con-
reservoirs. ectly to the safe yield of the
Page 11-94 & 96 - Comments reaara-
tion give rise to a negative iirmi • • 9 sewer service assump-
methodology; should note that ^.iLcatlon regarding projection
preferred alternative, assuming the s*te location of the
is reasonable. g acc®ssability to sewer services
Page 11-140 - Discussion of ftffi
mention of history regarding o & m ent quality should include
recommended, supra, for Page 5 Problems and other matters
-------
LAW OFFICES
COFER, BEAUCHAMP & HAWES
John E. Hagan, III
Page Five
August 29, 1977
Ch. Ill, "SYSTEM ALTERNATIVES" (pages III-l through 111-38)
Page 111-15 - It is understood that the costs associated
with the many alternatives could, at this point, only be "rough"
estimates; however, further, available details regarding cost
should be presented. Attached please find observations prepared
by Hazen & Sawyer, the Grantee's consulting engineering firm;
these observations were taken down by telephone dictation last
week and may reflect errors in transcription. Below follow ad-
ditional comments regarding cost prepared by City staff.
Page 111-34 - "Cost Rankings" - This section should be re-
vis ed"Toihow^the elements of costing; more refined description
of system components should be included and their underlying
cost figures should be presented.
Pacre III-34 - "Supplementary cost document" noted in first
Paragraph missing; need to review for adequacy.
Paqe 111-38 - "Conclusions" - Judgment presented is far
too qeneral; the comparative and relative merits of the seven
intensively studied alternatives should be summarized at this
section to support the judgment.
Ski IV, "DESCRIPTION OF PROPOSED ACTION" (pages IV-1 through IV-171
u -Page IV-1 - More refined description of the proposed facili-
ties should be presented at this section. In particular, the
assumed facts regarding loadings and unit removals are not in-
cluded and the design removals should be compared to actual ex-
perience based upon existing plant records.
Page IV-7 - the first full paragraph's description of in-
cinerator capacity is inaccurate; the calculations regarding
®J-2e are wrong, but the source of the error cannot be determined
®ihce the underlying data is not presented. We believe the error
sizing occurred because the calculation was based upon in-
cineration of dry solids rather than wet solids.
Paqe IV-11 - the system components noted at this page need
-------
L.AW OFFICES
COFER, BEAUCHAMP & HAWES
John E. Hagan, III
Page Six
August 29, 1977
to be accompanied by the supporting facts regarding recommended
size and aesign for each; this information could be provided
in the text or by clear reference to the "Technical Reference
Document".
Page IV-12 — discussion of incinerator sizing at second
full paragraph needs to be supported by display of data and cal-
culations; again, we believe an error was made regarding the size,
as noted above with respect to Page IV-7.
Page IV-12 - discussion of electrical costs at third full
paragraph fails to present details of assumptions (demand charge
and energy charge).
* 11 ^aC*e,rya^i2Qhndil?C^SSi'0£ re9<*rding flocculant usage at fourth
full paragraph should include underlying documentation.
Ch. Vf—"ENVIRONMENTAL EFFECTS OF THE PROPOSED ACTton" (pages V-l
through V-64) —
discussion at second full para-
graph is not accurate; the primary purpose for the channelization
WaS cyability of the creeks. Accomodat-
ing higher flows was a secondary reason for channelization.
Page V-31 & 33 - discussion of water quality is very am-
¦"* iSh regard to bLefits
Of D.bfShould Wi? dis°ussi??
zation should be data supported! COInment regarding channeli-
project^deci sion an^wheSer o^no^s^udy needs*^? ^V^d
before making a final selection of an alternative? finalized
shoulH^bl~^pportedSbySavailableedata?t^0n flowing from runoff
-------
LAW OFFICES
CO FER, BEAUCH AM P & HAWES
John E. Hagan, III
Page Seven
August 29, 1977
Ch. "T, "TiwavnTnABLE ADVERSE IMPACTS AND MITIGATING MEASURES"
(pagesfVI-1 through VI
p VI_2 & 3 - unclear whether or not expense for suggested
mitigative measures reflected in current cost estimates for pre-
ferred alternative.
We also have some comments regarding the style, content and
use of the "Technical Reference Document" as follow:
DEIS citations to the "Technical Reference Document"
(and to other sources) noted parenthetically in the text are very
unclear.
, The Technical Reference Document, itself, should be
2-, ; of its contents prepared,
indexed and a table o
be a written introduction to the "Technical
3. There sho aining the reason why documents are in-
Reference Document expxaxny^ ^
eluded and their relat
very much for your kind attention, and please know
/. the continuing NEPA proceedings,
we look forward to tne
Respectfully submitted,
cc: North Carolina Department of
Natural and Economic Resources
Division of Environmental Management
Attn: Mark Oakman
-------
OSTEEN, ADAMS 8t TlLLEY
ATTORNEYS AT LAW
POST OFFICE BOX 2480
GREENSBORO, NORTH CAROLINA 27402
WILLAM L. OSTEEN
J. PATRICK ADAMS
N. CARLTON TlLLEY, JR.
GATE CITY SAVINGS ft LOAN BUILDING. SUITE 304
August 31, 1977
Area Codk 019
telephone 274-2®*®
The Honorable Frances Phillips
Office of the Regional Counsel
U. S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
REGIONAL
COUNSEL
fj]E®.r?nn nrq
W SEP 21977
Jlkisi£DirEl
EPA-REGION IV
ATLANTA, OA.
Re: Project Nos. C37037601
C37036901
Dear Mr. Phillips:
Greensboro - Guilford County, N. C.
201 Wastewater Treatment System
This law firm has been retained to represent the Concerned
Citizens of McLeansville in their strong opposition to the pro-
posed action espoused in the Draft Environmental Impact State-
ment relating to the above mentioned sewerage treatment project.
As classified in the Draft EIS, alternative #6 (providing for
upgrading of the existing South Buffalo facility) rated substantial-
iot onlvrtheV^atmn J Ltha" 911 °thers' Further, it proved to be
million to S12 min°S ? ecfcive, but will cost the taxpayers $8
million to yl2 million less fViaM f i, , ,
a. • my- x-,, ^nan the alternative proposed,, Alter-
native ^£6 was fotzncl fov ths ppn^ r\r\^ i *^3 * *
socially acceptable..! based upon Lfh'T f "[Nl0t -,h
the plant ana the large number of ~ ^ ° Problems wlth
affected by this pollutant * ^ had bC6n
ient
We feel that the factual data regarding origins both of pres
and projected odor is insufficient to warrant that determination
which consequently is arbitrary and capricious* This is especially
apparent when it is understood, by EPS's own study, that the saiu®
situation will exist at the upgraded North Buffalo facility and
similarly affect an equal number of people.
We shall attend a public hearing on the Draft EIS Thursday*
September 1, 1977. Mindful that there is some authority regarding
-------
Mr. Phillips Pa9e 2
exhaustion of administrative procedures, we would very much appre-
ciate vour informing us what further administrative steps might be
taken to secure a review of the Regional Administrator's decisions.
Your cooperation will *e very muoh appreciated.
Yours very truly,
N. Carlton Tilley, Jr.
NCT:ld
cc; The Honorable John A. Little
Mr. John E. Hag an# HI
General Counsel , . ^
U. S. Environmental protectio g
-------
U].02 Blueberry Lano
Grcenob'-ro, .1. C. 27/fOl
August 30, 1977
Mr. John A. Little, Regional Administrator
Region IV SPA
3*f5 Courtland Street
Atlanta, Ga. 3'^3-S
Deer Mr. Little:
We are speaking as concerned citizens who have made an invest-
ment in a home in Southeast Greensboro; for a number of years we
h.7ve had to live and endure the stench of Buffalo Creek, with no
consideration given to our protest ana complaints. V/e feel that the
new facility should be built at McLeansville as originally proposed.
V/ith the continued growth of Greensboro it does not take a pro-
fessional environmentalist to resize that the present facility is
inadequate; neither does it take a genius to realise that housing
patterns being: as they are in lihis city, it i-s the Black minority
that has to suffer the indignity of living in fcis area.
I arc sure I speak for the majority of Hie early home buyers,
that had we known the situation v/e would not hove made our invest-
ments here.
V/e are in no position to move nor should we have to suffer any
further indignities because of Buffalo Creek. 0
Are we as citizens of this city not to be given any consideration
IVe feel that any expansion of Buffalo Creek Treatment Plant is a
gross violation of our rights.
V/e t ;ink that it is aypoor reflection to welcome travelers to
our city with the stench of Buffalo Creek, since we call ourselves
The Gate CiJ# and The Capital Of The Piedmont Cresent.
It is our hope that you will use the influence of your office
to help correct this gross injustice.
Yours truly,
n
)
\
fPVlMP'T "'AVEIJfcNTS
r-o -.'Pr.n nrp
StP ,1
I
uia
ftttluN XV, AtLANTA, GA.
-------
SlCS"
*°MINISTRATIVE
offices
Greensboro, N. C.
27-402
September 6, 1977
Mr. Bob Cooper
EIS Preparation Branch, Region IV
U. S. Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Re: Greensboro Metro Treatment Plant —
Environmental Impact Statement
Dear Bob,
Besides the comments offered by Mr. Forrest Campbell Vice-
Chairman, Board of County Commissioners at the Hearing of September 1,
1977, Guilford County staff would like to have the attached comments
entered into the record.
Thank you.
Jim Rickards
Assistant to Manager/Operations
JR:lfm
Attachment
cc: John V. Witherspoon, County Manager
-------
MEMORANDUM
TO: Metro E.I.S. Subcommittee
FROM: G. Douglas Carroll, Secretary
RE: Metro E.I.S. Review
DATE: August 25, 1977
Attached are the comments of the Planning Department on the
Metro E.I.S. The inclusion of data for only one Metro site
makes evaluation of this proposed treatment facility diffi-
cult. A preferable alternative would be to present data on
all sites to facilitate comparative analysis. With the
present E.I.S. document, the staff can only respond to minor
errors; whereas, in an analysis of all the sites long-range
development patterns and trends could be predicted and com-
pared to County growth management policies. Additionally,
much of the discussion is general and not substantive. The
attached comments list errors and observations on the E.I.S.
GDC/lte
G. jll, Secretary
/
/
-------
P. l(l-a):
P. 11-7 :
P. 11-7 :
P. 11-17 :
Pp. II-
20-25 :
P, 11-29 :
P. 11-30 :
P. 11-30 :
P. 11-94 :
The predominant winds in Greensboro are southwesterly
and northeasterly (See Annual.Wind Rose, p. H-5)
Records relating to odor complaints generated bv Snnfh
Oil Company. In 1975, the Health Department wa£ "
actively involved in correcting odor emissions and
illegal stream discharge. na
For greater accuracy the sentence should read- "Thp
South Buffalo Plant was built prior to the residential
subdivisions which exist adjacent to it today."
Maximum and minimum elevations are respectively +/-
1,000 feet, and +/- 414 feet. '
soils The soils section contains statements that are
so general that they have little or no value. The
statements are accurate but only because they are
so vague.
Hvdroloqy - On page 11-29 the report states "it was
estimated that about 33 million gallons per day MGD)
of groundwater may be available. This estimate is
k,Mw rnncprvative." This estimate is not conser-
vative but is accurate which means the estimates of
¦Mmpr and 160 to 195 MGD are extremely high. See
ptnyj rt • Population and Urban Growth..., 1975.
11-30 - "Where septic tank density is not too
*\L thirk soils and saprolite in most areas
S i v h r novate the septic tank effluent
quite well before it reaches any aquifer systems."
•ru- c+;,tPmPnt is not true because the saprolite is
lackedwhich would serve not to renovate the septic
tank effluent.
1 l^SrSSd-
waterPdegradation from septic tanks.
This statement is not accurate.
manti on of wba t a s sufliptions we re made in
There is no meiRejections concerning birth, death,
the population pr j Tuese are important determinants
-------
P. 11-94
continued-
For example, the Greensboro Department of Planning
and Community Development prefers to use population
projections based on a 1960-1970 migration rate
whereas the Guilford County Planning Department
uses a 1970-1974 migration rate. The resulting
projections differ greatly. Section II. B. l.a.
DEMOGRAPHY AND ECONOMICS TECHNICAL REFERENCE DOCUMENT.
A statement is made that a 1975 breakdown by census
tract, which was used to prepare 1975 population with-
in the study area by subbasin was prepared by the
National Planning Data Corporation. The 1975 total
County estimate computed by NPDC was approximately
8000 persons higher than the current N. C. Office
of State Planning and U. S. Bureau of the Census
Guilford County estimate available. Efforts should
be made to use the latest "official" figures while
keeping the percentage distribution by census tract
available from NPDC.
P. 11-110: The title should read: Partial Listing of Guilford
County Land Use Goals and Policies.
P. 11-111: Staff would like to know on what basis the land use
categories were determined particularly the tran-
sition zones. In several cases, the transition zones
overlap residential areas.
P. 11-124: The discussion of migrants entering Guilford County
and Carolina Piedmont should mention the English
Quakers by name. The early Quakers settled in the
western portion of the County and are known mainly
for the founding of Jamestown and Guilford College.
P. 11-124: In the last paragraph, should read: "Randolph" and
"Nathanael."
P. 11-125: There are three National Register sites in the study
area: Blandwood, the Jefferson Standard Building, and
the Bumpass-Troy House.
Description of Bumpass-Troy House taken from the publi-
cation An Inventory of Historic Architecture: Greens-
boro, North Carolina.
Built for the Reverend Sidney Bumpass, founder
of the Methodist newspaper. "The Weekly Message."
Publication was continued in the house, by his
wife, until 1872. The 2-story brick Greek Re-
vival style house is one of the only 16 pre-1879
buildings remaining in Greensboro.
(See attached lists and maps.)
-------
NATIONAL REGISTER STUDY LIST PROPERTIES
(Within Study Area)
PROPERTY AND LOCATION ^TE ^PROVED
— FOR STUDY*
1. Charles Benbow House, Oak Ridge (B-3) «
J-17-76
2. Low House, Whitsett vicinity (L-7) ^ ^
3. Oak Ridge Institute, Oak Ridge (B-3) - ,
3-17-76
"Old Mill of GuilfordOak Ridge (B-4) 3-17 76
Thomas Scott House, N. Greensboro vicinity (F-3) 3.^7 7g
Isaac Thacker House, Browns Summit vicinity (H-2) 3_17 76
Robert Thompson House, N. Greensboro vicinity (G-3) 3-17 75
West House, N. Greensboro vicinity (F-3) 3-17-76
Colson-Shaw Log House, Summerfield vicinity (E-3) 5-12-7
Reuban Starbuck House, Colfax vicinity (A-5) 5-12-7
Jesse Benbow House, Oak Ridge vicinity (B-3) 5-12-7
Summerfield Historic District (D-2) 5-12-7
Ingles-Kraus-Hodge House, Whitsett vicinity (L-7)
Ward House, E. Greensboro vicinity (G-6)
W. H. Paisley House, E. Greensboro vicinity (G-6)
Midway Diner, Sedslis vicinity (K-7)
Lyndon Ilobbs House, Guilford College vie.(D-6)
^8. palmer Memorial Institute, Sedalta (K-7)
4.
5.
6.
7.
8.
9.
10
11
12
13
14
15
16
17. Lewis
5-12-7
5-12-7
5-12-7
5-12-7
5-12-7
5-12-7
nf ruilford County was completed in June,
The Historic Sites Inventory
nc^d as "historically or architecturally .
1977. Over 400 sites were
significant."
, a are in the study area in addition
Approximately 200 Invented
to the ones listed above.
™.t of cultural Re.ources.
*North Carolina Departme
-------
GREENSBORO NATIONAL REGISTER STUDY LIST PROPERTIES
DATE APPROVED
PROPERTY FOR STUDY*
1. Buffalo Presbyterian Church 3-17-76
2. Caldwell Log College Site 3-17-76
3. Carnegie Negro Library 3-17-76
4. William Fields House 3-17-76
5. Foust Building, IJNC-G 3-17-76
6. Green Hill Cemetery Office 3-17-76
7. Greensboro College Main Building 5-6-75
8. Greensboro Motor Co. and Buick Motor Co. Showrooms 3-17-76
,9. Greensboro Passenger Depot (Railroad) 9-30-75
10. Guilford Courthouse National Military Park Pending
11. Ireland House 3-17-76
12. S. II. Kress Building 9-30-75
13. 195-201 Lyndon Street Townshouse 3-17-76
14. McNairy House 9-19-69
15. Murphy House 3-17-76
16. Pomona Terra Cotta Manufacturing Company 9-30-75
17. Proximity Cotton Mill 9-19-74
18. Sherwood House 3-17-76
19. South Elm Street Historic District 3-17-76
20. United Methodist Church 3-17-76
21. Wnfco Mills 3-17-76
22. N.H.D. Wilson House. 3-17-76
21. F. W. Woolworth Building 3-17-76
22. Guilford County Government Complex 5-12-77
-------
K>
O
FIGURE 11-22
MAJOR HISTORICAL SITES IN THE STUDY AREA
-------
P. 11-125: Paragraph four should read: "Nathanael Greene's."
P. 11-125: Last paragraph should read: "At least 47 structures..."
P. 11-127: Discussion of proposed Historic Districts should include
the Summerfield Historic District.
P. 11-127- 6. Transportation - In the transportation section the
129: consequences of a new wastewater treatment plant or the
growth that would occur due to the plant is not con-
sidered. Would locating the plant in McLeansville
increase the attractiveness of a beltline in that
section of the County?
P. V-4-7 : Concerning the discussion of odor, what population and
other land uses are within the impacted area near
McLeansville?
P. V-5 : There is no quantification here. How people will
be impacted?
P. V-5 : No mention or evaluation is made of people who do
not identify the plant as a major odor source but
would identify it as significant nevertheless.
P. V-54- 2. If the South Buffalo plant ceases operation the
57 : zoning of that land may or may not change from
industrial.
Given past trends, leapfrogging development will
occur in eastern Guilford County unless there is
a lessening of the stigma attached to black-occupied
areas.
6. Transportation - The plant will attract population
growth into the South Buffalo area which will increase
the attractiveness of Huffine Mill Road as a major
connector.
The South Buffalo site will make the proposed belt-
line more attractive as growth becomes a reality.
P. VI-2 : Since no records are kept, how can one ascertain
that the number is minimal?
P. VI-5 : "July, 1976" is the correct date of adoption of the
Land Use Goals and Policies.
P. V-62,
63 :
P. B-5 : Bibliography footnote should read "Tax Department"
instead of "Finance Department," (GU-106).
-------
Macfield
September 6, 1977
Mr. John White, Administrator
Region IV
EPA
345 Courtland, St., N.E.
Atlanta, Ga. 30308
Dear Mr. White:
Re: 201 Greensboro-Guilford EIS
In regard to the 201 Greensboro-Guilford EIS Study, we would like
to state we prefer Alternative 6, using the existing plants costing $21
million, which is far more cost effective than using the proposed new
expensive Metro Plant system costing $33 million.
We also favor a plan for immediate research in a full-scale plant
demonstration study on aeration tank » VUnt can
be upgraded for $2 million to treat textile wastewater as well, or better,
without offensive odor problems, tJlan ±" a new
Metro Plant costing $20 million. We do not think this delay in decision
would affect growth, since city has 8 MGB spare capacity to serve growth
for ten (10) years or more.
We feel if public money ba«»v»d 1° applying Best Practicable
Technology Economically Achievable (BPTEA) this is^best way to proceed
in complying with the intent of Congress in PL 92-500 to meet cost effective,
environmental, and social concerns.
EPA ¦ HPr j STATEMENTS
Hi
1 St? J W7 //•;
iu..
a.
I1EGMN TV. AT!ANYA. GA.
Yours very sincerely,
MACFIELD TEXTURING, INC.
Mir* Joe Dillon
Vice-President/Engineering
JD/d
Macfield Texturing
, Inc., Madison, North Carolina 27026, Teh (9?9)42?-025f
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
P. 0. Box 27307, Raleigh, North Carolina 27611
Telephone FTS 672-4210
September 8, 1977
Mr. John E. Hagan, III
Chief, EXS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr, Hagan:
We have reviewed the draft environmental impact statement for Greensboro,
Guilford County Wastewater Treatment Facilities and offer the following
comments.
The environmental statement adequately addresses the project's impact on
water quality sedimentation and changes in land use. Much of the analysis
is directed toward temporary effects on the environment during the
construction phases of the project. Erosion control specifications and
standards are to meet requirements of the North Carolina Sedimentation
Pollution Control Act of 1973.
The Soil Conservation Service assists soil and water conservation districts
in technical phases of their program. Consultive services consistent with
work priorities established by the districts are available from the Service
in reviewing and developing plans for erosion control.
We appreciate the opportunity to review and comment on the draft EIS.
Sincerely,
State Conservationist
cc: Council on Environmental Quality, Attn: General Counsel, 722 Jackson
Place, N.W., Washington, D.C. 20006 (5 copies)
USDA Coordinator of Environmental Quality Activities, Office of the
Secretary, U.S. Department of Agriculture, Washington, D. C. 20250
R. M. Davis, Administrator, SCS, Washington, D.C.
J. V. Martin, Director, STSC, SCS, Fort Worth, Texas
S. G. Lane, State Soil & Water Conservation Commission, Raleigh, N.C»
R. W. Giessler, SCS, Salisbury, N.C.
H. W. Robertson, SCS, Greensboro, N.C.
-------
CITY OF GREENSBORO
NORTH CAROLINA
September 8,1977
Mr. John A. Little
Acting Regional Administrator
EPA, Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Dear Mr. Little:
Transmitted herewith are two copies of a statement prepared by the
Greensboro Department of Planning and Community Development for
inclusion in the official record of the September 1, 1977 public hearing on
the draft EIS for the Metro Wastewater Treatment Plant. Your consideration
of this statement in your deliberations will be appreciated.
Sincerely,
Charles E. Mortimore
Director of Planning and
Community Development
CEM/gw
cc: City Manager
-------
Statement on Metro Plant
Effects on City Development
Department of Planning and Community Development
City of Greensboro, North Carolina
September 1977
The location of the existing wastewater treatment facilities
has had a major influence on the development pattern within the Greens-
boro Urban Area for over forty years. During the early part of the
century, Greensboro's development was marked by a balanced growth pat-
tern centered around downtown. This pattern was altered as vacant
land in the eastern section of the City capable of being served by the
existing treatment facilities was depleted. Since the late 1950s the
majority of Greensboro's growth has moved in a westward direction,
since the extension of gravity flow sewer was more cost effective than
the installation of lift stations and force mains required in the
east. This growth pattern has affected residents of all sections of
the City.
In the east land was being depleted at the same time out-
lying shopping centers were coming onto the market. Since shopping
centers are more profitable in locations that can capture new popula-
tion growth, few located in the southeast section of the City. This
meant residents of the southeast had to rely on retail facilities in
the downtown. Since the decline of retail activities in the down-
town—partly caused by past development patterns--close~by shopping
facilities are not as plentiful in the east and southeast.
The absence of new development activity in the southeast
has also affected the market desirability of this area. New residential
-------
- 2 -
development in the western section located close tn
i-Luse to new outlying
shopping facilities „as considered -ore desirable, and „any d„e1U„gs
in the southeast were acquired as income producing rental property.
This has resulted in declining housing conditions and further lessen
ing of the market image. The absence of large vacant tracts capable
of being served by sewer service has also affected the ability of th
eastern section to attract new industrial development. Prior to th
mid 1960s, the eastern section attracted considerable industrial
development. However, with the increased importance placed on high
way transportation and the desire of many firms to locate on large
tracts with quick and easy access to the interstate system, much of
the new industrial development has located in the western section
The result is the southeast, with many lower income persons, is even
further from employment opportunities.
In the western section of the City development boomed since
sewer service could be provided relatively cheaply and vacant land
was not available in the east. In response to this development the
capacity of the major street system was increased and other public
and private facilities constructed, which in turn increased the at-
tractiveness of this area for further development.
A continuation of this development trend is assured unless
sewer service is made available to the east of the City. The conse-
quence of forcing new development to the west can be severe:
1. Concentrations of minority population living in the east will
be further separated from community and economic life.
-------
- 3 -
2. Congestion is sure to increase in the western section of the
City leading to increased road construction.
3. Intensive development will be forced into the City's watershed.
4. Residential development will be forced into areas close to the
regional airport resulting in noise problems for residents and
possible demands for changes in flight patterns or curtailment
of operations.
The wastewater treatment plants operated by the City of
Greensboro have been improved many times over the years. However,
these improvements have taken place on sites that were originally
placed into operation over forty years ago, and the service area has
not been expanded to the east since that time. Since the plant site
has a much greater functional life than the treatment equipment,
choosing a site that will insure the community's ability to develop
in the most desirable pattern is of prime importance.
The studies conducted concerning the design and location
of the proposed metro plant have covered a time span to the year
2000. This is adequate for the actual physical plant; however, it
must be understood that the site chosen will affect the growth pat-
tern for the City well into the next century. While projections for
this expanded time period cannot be developed with any reliability,
the past influence of the existing plant sites should provide insight
into possible future consequences.
In recent years the desire to control urban sprawl has in-
fluenced the location of wastewater facilities. Although the effects
-------
of urban sprawl are well documented and the need for adequate controls
is evident, locating major facilities such as wastewater treatment
plants for the purpose of controlling short term growth is question-
able unless a community is prepared to abandon and relocate such ex-
pensive capital facilities on a short term basis. A more logical and
cost effective means of managing urban growth exists. Wastewater
treatment facilities can be located to provide for optimum long term
growth while the timing of growth can be controlled by restrictions
on sewer tap-ons to major lines. Such an approach to facilities
planning offers many benefits since growth can be monitored and new
areas opened to development as the need arises.
From the standpoint of land use and the development of the
City, the confluence site offers the following advantages:
1. The shutdown of waste treatment facilities in the southeast
will increase the livability and desirability of that area,
to the substantial benefit of the minority and lower income
population.
2. The opening up of land for residential development will bene-
fit low to moderate income people because of lower land costs
in that area.
3. The opening up of land for industrial development will provide
employment opportunities for the minority and lower income
population in the southeast, reduce travel time to employment,
and more equally distribute employment centers serving the
City.
-------
- 5 -
4. Development to the east will favorably affect downtown by
making it a geographic center again.
5. The opening up of a substantial land area to the east will
relieve development pressures in the west, reduce the pressure
for watershed development, reduce the chances of Greensboro
and Winston-Salem growing together, and provide more geographic
balance to the City, with concomitant benefits and savings in
public service costs.
Expansion of the South Buffalo plant would reverse the fore-
going effects and have long term unfavorable consequences on the de-
velopment of the City.
The confluence site presents an opportunity for the City
to meet its land use and development needs, as well as serve those
other Guilford County residents who are dependent on the City as an
activity and employment center.
-------
3ept, 9, 1977
rfr, John E, i-"q„ar. > IIC
Chief, "13 Branch Re. r)raft SIS Oreensboro-Guilford County
iipvironmental Protection Ag -n-y Wastewater Treatment Facilities
31ir' Courtland Street,
Atlanta, GA 30308
Boar Mr. Hfi^'ru
, , ^nrletv we ar«5 1sterested In protecting the
A3 a. .nember o" the Auoudotj conserve sll resources, including
total environment and ir good g - pf'sense ^ vise spending. Our interest is
mono;*, by using integrity aR p .joientific rather th?.n political approach
in greater research and velvet lower costs us keynotad by the late
to ab*ta pollution not* etz v • » C|^yf 3re*nsboro cr.naave fro;u !i>12-?0
Sen. Kerr0 Vhat is the lnter®!\ _ current research techniques such as used at
million in public funds by app^» s lejj manual) to upgrade existing
Kebane and Jackson, Mich. ' t this bhe best way to proceed with project?
Plants and correct oaor problems. 13
-j. ftxine to read in news media that so many have
Therefore, it is most perpj- » fi^t, which apparently ignores intent
been milled into endorsing propose effect that coat effectiveness must be
of Congress in PL 92-£00, which say ^ concerns. If serious efforts to
applied, including environmental. BPA, State, and City as mandated by
save $12-20 million are not appix / ^ ^ Carter to taUnce the budget,
PL 92-500 there will be no neea iw fffllo# If city had tried as hard to
which might also be acrapp® residents as to spend $33 million (cut from
stop odors and complaints would be no problem with social concern today,
$U3 million by SIS study) there wou applylug research techniques as propose
for odors could have been co.reo
in demonstration grant-
son, Mich.; , Buffalo at 20 MOD and S. Buffa
Sw and better aiwrn«;^ reSpectfully urged that EPA delay
at 16 MOD can save up to $20an* * Mllm9e&U plantdemonstration study to
decision In Draft SB®«. »««£ usinglmovatlT. UWMite
•Via« ivai, c Buffalo CW . ¦feptsfltii 12m1^ MOD S« 41) ImTWOCw 1.6V6*
about£2millicn for all lmproT«»n*»ttt, d m eTM better than
Itthodo/»£jM» KffitoSo »•>» «"•"«>• T°W
in proposed.?? to 333 »llHo» In proposed Metro
l^Jr«£~Z* ^t^O^iuonTTotal
tertjtffi i»X®3l2JT«ES- 40 •H£^VST&"£S
aystes; would cost about ^ant on aeration tanks to «eet B0D and
aystem, with a coat for about $200,000.
NH3-N limits and control oao
I here, because present- spare
A delay would not ftin^ ZmUtlov and industrial growth for next 20
11 fo mn would serve P°P^X_", gm^h aa now used), which correct3
capacity of 9'MB eW ind^trfc urgency to attract new industry,
years (iaotatog3»D » MW »d Cb«Wr « £*. to com her. «hen the, a.
misleading statements ^ -j n« JwlaaW ^ capital c08t# for its ahare
(Reft Radian Oorpw $l0l4 "J;111?,, v(urs for using using 2 MID capacity
f or^out $a6,000 for 30ior s ^ ^ ^
11 LlTieLo raSn?? Sid Oity ?££ «>inflation- >»t»nual piping
in new HetMPlan consumers, .n pallons, coopered to annual interest
must be passed on bout $30,OCO/mil^.® leading statements about
opS^12-20 million Sver $800,000, mailable at both plants to double
»vLif £,"SiiSr*«>¦ ^20 yws i!rwrth'w "•of
capacity to last for 7^ V
only a small part now.
-------
Ilr. Hagan
Page ?
Sept. 9, 1977
Benefits from thio proposed grant would oe r.s follows:
1. Immediate correction of odors which have b,i-tr> Intensified with even more
complaints v.h-ivr odors over
the yearn instead of correcting as required by law, resulting in
Congressmen and others being Miuled by such misleading statements that
textile wastes were the cyutio of odoiv: and then being ajkod to ignore
PL >2-50'". ?:;/ endorsing the building of --.n otmeedod new expensive plant
coating h-20 million Juf?t to stop odors at minting plant. Why didn't
City correct odor3 like other cities.! by upgrading existing plants,
including K, Buffalo with bad odore at Carolina Circle flail and
surrounding area? (la thiu discrimination":1)
2. Other important benefits would be:
a. To correct the statements in "Reliability" and "Conclusion'' sections of
Draft SIS, most of which are not valid in view of current research
findings and should be definitely corrected by demonstration study.
1) Including misleading statement that textile waster, may need pre-
treatment and that a difficult-to-operate two-stage Metro Plant
would treat more reliably. H0w can this be true if data from EPA
manuals and current research show otherwise at 97*99% efficiencies
in advanced level treatment in a more cost effective single-stage
process without odor problems. (Jee EFA manual on nitrogen
control, data attached, Jackson, Mich.)
b. The implication that textile wastes at 3„ Buffalo are toxic and should
be pretreated and are the cause of odors would be devastating to textile
industry in future guidelineo and should be corrected as a moral
obligation to the Industry in the proposed demonstration study.
c. The temperature-dependent statement that trickling filers would provide
little treatment in cool weather should be corrected because F.PA records
for Dec, 197? and 1976 show 9k$ and 91% efficiencies.
d. Research conducted by Greensboro industry merited the Industrial Waste
Award from WPCF in 19£0, which showed trickling filters could be used
for roughing treatment as at N. and S. Buffalo with efficiencies in
cool weather ranging at 3Q# at 12 C, which current research shows is
enough for effectively upgrading 3. Buffalo flant to treat at 16 MGu
without aeration tank enlargement» (Ref: Sewage and Industrial. Pastes,
August 1958, p, 1003.) *
-------
Mr, Hagan ^a6e 3 Sept. 9, 1977
Radian Corp. first approved in EIS studythe use of existing plants &s best
plant cost effectively and environmentally and stated odors could be corrected
by upgrading, but the next day EPA Administrator said area residents have
suffered long enough to scrap S, Buffalo Plant and to prepare a new study. Why?
This shocking decision to scrap such an excellent plant is not covered by
law and ignores the mandate of Congress and should be investigated. Radian did
not make decision,as was iaiplied in news media, and to let stand with no
corrections is not good government.
This is a dangerous precedent because in effect it says if a city is not
capable of operating a waste treatment plant properly, the plant wast be moved
to another site and impose odors on others, which is apparently morally and
lepallv wrone. This has refer been heard of before in meetings attended at a
national level as well as international pollution control conferences in
London and Munich where 38 nations were represented. But there should not
have been a single period of offensive odors if research used by plants
without odors applied, with high regard for the biochemistry of the process
and functions of the microbes.
example, a process developed in local studies used these techniques
for Canton, Georgia to treat textile, poultry, and sewage waste at 98% effioiencv
in a plant (better than any in Atlanta), which is located only 800 feet from a
3000 pupil school with no odor problems. A population density of 30,000 would
make no difference. Town M-NC Bant designed in similar researoh treats textile,
electroplating, and sewage wast eatan advanced level.(B0D, J4 mgA| ammonia N,
^ , nig A; BODuit^lO mg/i) ^th best in ftate "lth n° odor problems,
•and suitable for recycling to water auPP^. ®mil1¦ "*th a plant
using innovative techniques to treat «ly textile wastewater meets SPA limits
and is located about 200 feet from mill with no odor Problems. All asked say
lunch may be eaten at these plants with no pother from offensive odors in
c™tr.?t to the many statements at hearing that lunch could not be eaten half
a mile away from S. Bui&lo Plan •
a <.«ks why can we fly to the moon and City oannot correct odor
problems at S Buffalo Plant. Current researoh on S. Buffalo Plant wastewater,
fArthniaues, shows plant can be upgraded for about $2 million to
?« £ ! ,o ^ ^n ?n existing single-stage tanks for 6-8 hours at 97-09*
X advanced level, which Is even better than tertiary treatment
»«-*•«• «r. pm , ojs.ssr*
million.
Tf state funds of $ii million for Metro Plant are lost. City might still
If State junaa building a new Metro Plant, arid using the oronosftd
o«r *1 »iUi« Jyw* »»Jrt ?,mir0h findings In domon.trftion £2? 4
^Her altMnrtim TUet at 20 MID and 3. Buffalo FlSt'ItW mo
""l100 ""5 J,ltLfS'lng "J1? *3 -rtthout '
sSteltnS!) 8o rush to spend » ™<1 *>Prln mil totms of
. — -• - « «... . J_fl
needed funds?
EPA is respectfully urged aeaonatration
. tanks can develop another reasHfl.fi alternative and correot th.
grant on aoratlon taw ™u->1Ilty. „d "Conclusion" saotion. .Moh I~ *
misleading atateraont In aitarnatlt» 3 and bawd on oonvantlonal Hladam
SZ5£ o^lll £ /•« mltUdlllon dollar on S^SISSt
-------
" , '{agftn
Mge )i
'ept, o, ir-77
protection, a part of which indij-.U-* t-vsre ;(uy be a lack of technic*!
knowledge en use uf such innov-.tiv: techniques In ?01 ^ltern.: tivos ;:t the
decision-sn^k i v:?, level, sr.d ^slc finds "that Z?k does not sy vte'mati.ially
or comprehensively consider all f*;-a!sibl e site mat. Ives in its 3 •ioisioL—
making process.(Kefs j'invironmcntal faciei; --g c.r.u i'schr jlog., '.Jzy !T?7>
T. U33.) For this reason, the'd-iai:.siou "ourht to be ^e"W?.d because snothnr
feasible alternative which could elimi^atfe social concern should o<"- ft a inly
be considered in a further Dep;onatrr.tion Sb'idy prcf :jrab?,.j- r>y Radian who
knows the process,
.' farther study to find c
better altemctJvn, which'would swiounb to $90 million at 7% interest ir
20 years, or $l60C per foully, 1* r.oi tfcl.? !'.he best w-v to irocrod wit!',
fiscal rosf en nihility, reflect inf. ;?ro*t credit to ;'ity, r.tr.tf;, ?nd Sl;.'?
Wry the hurry to or? up litat*. w>. •« 1t)i 1 •-;*'.*••• none to r>thers if bond
.?. If * Demonstration nr^nt will show th„t an in-^Uquabe secondary treatment
plant can by upgraded for $? million to bre,..b
-------
iir o Hagan
Page $
Sept. 9, 1977
, , contributions in research with background information
These rtat«nt. »4 oortr^ tW ^ ^
are being submitted as a ci i ' spen(jing because funds are available,
stop Inflationary trends in aoncemed citizens as well as FPA.
which should be the goal
+„ FPi to use a scientific rather than political
It is a challenge to tr Congress to provide the nation with
approach to enforce the nanoa
highest quality «*« >' l0,K
-------
Sept. 12, 1977
Mr. John White, Administrator (or Acting Administrator)
Region IV
EPA
3U5 Courtland Stree, NE Re: Draft EIS Greensboro-£uilford County
Atlanta, GA 30308 Wastewater Treatment Facilities
Dear Mr. White:
In regard to Draft EIS, Alternative 6 is favored, but in view of recent
findings (attache.!) that a new and better alternative (N. Bufi'&lc at 20 I ED
and 5. Buffalo at 16 MOD) can save up to $20 million, it is respectfully
urged that EPA delay decision in Draft EIS and arrange for a full-scale plant
demonstration study to show that S. Buffalo Plant can be upgraded using
innovative techniques for about $2 million for all improvementv, to treat up
to 12-16 MGD at an advanced level with odor problems corrected, and meet State
and EPA limits as well as or even better than tertiary treatment in proposed
20 MID Metro Plant costing $20 million. Total system would cost about $12
million, compared to $33 million in Metro system, with a cost for demonstration
grait on aeration tanks to meet BOD and NH3-N limits and control cdora about
5200,000.
EPA is respectfully urged to delay decision until a full-scale demonstration
grant on aeration tanks can develop another feasible alternative and correct the
misleading statements in "Reliability" and "Conclusion" sections which are
apparently made to justify Alternative 3 and based on conventional wisdom,
not Best Practicable Technology Economically Achievable (BPTEA). The National
Research Council is making a 2\s year multimillion dollar study on environmental
protection, a part of which indicates there may be a lack of technical knowledge
on use of such innovative techniques in 201 alternatives at the decifion-rcakirg
level, and also finds "that EPA does not systematically or comprehensively
consider all feasible alternatives in its decision-making process." (Ref:
Environmental Science and Technology, May 1977, p. U33.) For this reason,
the decision ought to be delayed because another feasible alternative which
could eliminate social concern should certainly be considered in a further
demonstration study preferably by Radian who knows the process.
This delay is urged for the following reasons:
1. EPA N Control Manual and other researches (including current researches
attached) show a new alternative system, N, Buffalo at 20 MGD and S.
Buffalo at 16 M3D, costing about $12 million can treat as reliably or
even more effectively than a proposed Metro Plant system costing about
$33 million.
a. Odors can be controlled as well as at Metro Plant.
b. Data shows aeration tank large enough, at 6 hrs. detention with
100# recirculation, to treat 16 MGD at advanced or tertiary level.
(Statement in EPA 11-16-76 survey, p. 36, that hydraulic detention
time is 6 hrs. at 12 MGD flow is based on including recirculation
of 37?S in detention time and should be corrected.)
c. Very little land would be required for upgrading facilities, mostly
for solids handling.
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Mr. White
Page 2
s^t. 12, 1977
3.
and eliminate social concern.
2. Correct odor problems anu
.x x i?Pfl «av are cause of offensive odors?
a. What do State and EPA say are
, ,, shows it is lack of dissolved oxygen in
b. Research ^finitely ^ odorg# {Cd0rs usually worse in periods
aeration tanks, causing
involving Federal funding.;
q+a+ifi reports have shown zero DO in effluent and at
c. Over the years,:3trt e reP«^ ^
various stations in *
. ,, ,^76. ghows aero DO at 7 stations of lit tested
d. SPA survey report, U-l >ators not working (80 HP of 560 HP).
in aeration tank, wi™" ? effluent, or stream, impossible not to
(If no D0 with degrees from Harvard cannot stop them.)
have odors, and operator
rnrrect odor problems at aeration tank by
e. Demonstration Grant can oo ^ ralse D0 lr aeration tank to h
applying more air ] &t Xo$ instead of \M and changing flow
^ssrss1^^- Mrte° ^
. , "Reliability" and "Conclusion" sections
Correct misleading statements x more reliably than upgraded
that State proposed Metro rj.an
existing S, Buffalo *
, . ^_nn mch. and current research data attached
a. EPA N Control treat won reliably than upgraded
n Plant - 98$ efficiency compared to 96% Metro,
b Uorraded S, Buffalo Plant -
b. upgraoeo ^ . not true m view of published research
than enough. oretreatment in proposed innovative
. . «a*tes will not require P_. ^ n0 toxicity has been found
tor "»e 1» or in ll-W-76 aurrey by m on
process z --searches over the y jmT,lication stand would be
I" St«a«r. (To W* }"^S>etr.at»eDt fMrtta. and
to ^'."fSa^and IM* obligation to the tadnatry.)
needs to be correc ^.4nBWt of atringent effluent limitations
e. Possibilities for^onsist^ t J® ^^e^MceM^n^^S^nSSwt
&rj/sss y«s?s as*? *•
carbonaceous oxygj Mich, report.)
(See attached Jackson, to disoharge untreated waste.
.m on{j EPA -g,. mre complaints when EPA
Correct error in ^!n intensifi«d 2T«nd gave City a permit to discharge
Odors which enforce its <*» ^paiation of 36,000 people dischaglng
surprisingly ^aileo t punting to * State grant this permit,
up to 6,000 tea. OT/yjJJiu tf«rt BM aa) imj-» 1M»«
raw sewage into®®®® eftSily been i®P^ $200,000 by applying research
when plant could h^ :for 1®SS tbm ** '
(as at Winston, $k00'0au;
techniques#
-------
Mr. White
Page 3
yept. 12, 1977
l3. A decision to delay would not hinder new industry coming here, because
present spare capacity of 9 HHD »Jould serve population and industrial
growth for next twenty years (including 3 M»D for new industry, as
much as now used) which corrects misleading statements by City and
Chamber that additional capacity is needed to attract new industry.
(Ref: Radian.)
a0 Annual puraping cost from suburbs would be low, about $30,000/MGD
compared to annual interest on wasteful $12 million over $800,000/
yr,, which will correct misleading statements about savings in
gravity flow.
b. Plenty of land is available at both plants to double capacity
to last for 70 years.
6. If it is possible to save up to $20 million by further study to find a
better alternative, which would amount to $80 million at 1% interest in
20 years, or $1600 per family, is not this the best way to proceed with
fiscal responsibility, reflecting great credit to City, State, and EPA?
Why the hurry to use up State money and leave none to other* If bond
fails?
a. Winston plans to upgrade it?plant for $U00,000 to stop odors and
fish kills in Yadkin, and meet State and EPA limits, which have been
in violation over past $ years.
7. If a Demonstration Grant will show that an inadequate secondary treatment
plant can be upgraded for $ 2 million to treat at an advanced level without
odor problems, would not this information be of inmense value to EPA
technology manuals in setting an example for other areas to achieve advanced
treatment in upgrading existing plants or in building new ones at such
extremely low costs? Would not this save hundreds of millions in public
funding nationwide?
The proposed innovative techniques for S. Buffalo Plant are largely
based on research findings published nationally in studies for Cluett, Peabody
& Co., Troy, N.Y., which received commendations from State Engineers and Gov.
Rockefeller. Results showed 98$ efficiency in 6 hrs. aeration time in treatment
of 100$ textile waste, with aeration tank DO at h mgA and recirculation at
200$ required by State to level out high surges in flows from mill waste. The
S. Buffalo Plant shows about 87$ efficiency (Radian) with DO from 0 to 1 mgA
average and with conventional recirculation at U0$, which will not level out
flows (Ref: EPA Survey Team 11-16-76) causing misleading statements in news
madia that plant is overloaded. The Demonstration Grant is needed to show
designers over the nation that textile waste and sewage can be treated at
advanced or tertiary level more cost effectively in a single-stage nitrification
process now used all over England, than in a two-stage process. Recent
published researches indicate the Metro two-stage process may be outmoded in
the next decade. One small town in state amendeded 201 plant from a 2-stage
to single-stage process to save about one-half of proposed 201 funding of
$575,000 and cut water costs for consumers from about to 270/gal.
-------
Page k Sept. 12, 1977
Mr. White
_ .-ibutions in research with background information
These statements ana conw ^ public service to aid in efforts to
are being submitted as a civic s gpending because funds are available,
stop inflationary trends in concerned citizens as well as EPA to help
which should be the goal rf ui
President Carter balance the wage
.. city want to spend only 12 to 21 million to
The question is, cleaner water at lower cost, or spend $33
provide citizens and i^stry wi ^ piPA State money($2.5 million) to
million, and waste up to J20 m-J developers, and other spenders, as well as
satisfy demands of
City, because funds ar
. e a scientific rather than a political
It is a challenge to ^ w Congress to provide the nation with highest
approach to enforce the ^ateResearch needs to be applied to abate pollution
quality water at lowest cost. ^ %o be successful, it must be applied,
more effectively at lower cos , .
more effectively ai>
roval of this better alternative to meet cost
Your consideration and app ^ concerna wiU be appreciated.
effective, environmental, ana
Yours very sincerely,
-> & a (1
R. H. Soutlier
3116 Summit Ave.
Greensboro, N. C. 27U0S>
-------
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DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE SECRETARY
WASHINGTON. D.C. 20201
SEP 1 2 '977
John E. Hagari, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, GA 30308
Dear Sir:
Thank you for the opportunity to review the draft
Environmental Impact Statement for the Greensboro-
Guilford County, North Carolina Wastewater Treatment
System C 37034601 and C37036901. We find that the
statement does not adequately address potential impacts
Sd/SrStlgating actions. Specific comments are as
follows:
1 Some passing reference is made to the potential
&ome pas y stewater for irrigation purposes,
use of the treated wastewauox --.--if- n£
Analvsis of the wastewater and a profile or its
Analysis or cne reference to potential uptake by
contaminants with entry to the food chain should
plants, e.g. corn, h _ program is initiated,
be addressed before such a progxcu
. i land disposal of sludge, either
2. Similarly, any la tilizer or as soil conditioner
for immediate use as agricultural use should
for land intended for entrance into the food
be in context of potential
chain.
3.
It is noted that, while '£ihalo-
methanes as a re«»° is^econmended as the remedy,
recognized, monitor g rather recognition of
This is not ^figating t^l0lination shluM be
a hazard - aIter: JrfX be especially important if
considered. T^IS *IrSjm aS a potable water resource
water is used down stream as a w
which is, in itself, not addressed.
i.e. downstream water use,
4. For the same reas°"' rimoff during storms because
the problem of increase attributable to population
of additional potential use of the stream
growth and its impact on p -^dressed,
for potable water should be addresse
-------
5. The residential area surrounding the sewage treat-
ment plant is identified and the impact assessed. Is
there any other facility within the impacted area, such
as an industrial plant - food processing plant, school,
etc?
Sincerely,
Charles Custard
Director
Office of Environmental Affairs
-------
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AiARQUhS D. 5TRE ET
ATTORNEY AND COUNSELLOR AT LAW
SUITE 533
SOUTHEASTERN BUILDING
J02 N. ELM STREET
CREEN5B0R0, NORTH CAROLINA 27401
t{ SEP 19 1977
jiit
l_i Li t~_. — j i J i 1
SPA-FuSXOH IV
ATLANTA, C^iREA Code
275-078W
September 14, 1977
The United States Enviornmental Protection Agency
on IV
*itlanta, Georgia
Re: Public Hearing
201 Waste Treatment System
Greensboro-Guilford County, North Carolina
°ear Madam Chairman:
I attended the above referenced public hearing on September 1 1077
* had originally registered to speak (#95) but, due to another appointment-
1 had to leave before being heard. I understood at that time that the '
would remain open for a period of fifteen (15) days after the hearing dat*30^
in order that written statements might be included. e
I am a thirty-one (31) year old attorney, and have lived in Southeastern
Greensboro since birth. The South Buffalo Creek sewage treatment plant has
been a part of my life. I will always remember it in terms of the foul odor
°n a day to day and year to year basis. On humid summer nights the odor
*as worse than at other times and we were forced to swelter inside of our
houses rather than enjoy the outdoors. Such was the quality of the air
breathed by the residents of Southeastern Greensboro. The situation has
Progressively worsened as the South Buffalo Treatment Plant has been loaded
capacity.
1 am in total support with those who are advancing the Confluence site
°n the North and South Buffalo Creek as the site upon which a new sewage
treatment facility should be constructed. The reason for my support is not
80 much the foul odor of the South Buffalo Creek Treatment Plant; but rather,
interest in the continuing growth of the city of Greensboro and the county
of Guilford, if the Confluence site is approved, it wall enable the city
an3 county to handle a much greater waste water load than under the current
p. This in my mind would attract industry to the areajhach would,
hopefully, locate in the eastern part of the city. As the matter now stands,
interstate 85 runs along the eastern border of Greensboro; however, there is
n° significant industry in the eastern part of Greensboro, When one thinks
in tenrc u * /JJL, has not seen fit to locate in eastern Greensboro,
it is i f • i ? t-hat industry is not interested in investing dollars
land „ T Y t« foul *>• has
acre- w^lch xs subject Interstate 85 due primarily to the inadequacy
•XL'ZiXZeZLTS T«anLnTp!.nt to hanau the
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September 14, 1977
Page 2
With the unemployment situation being what it is in this city, we can
not long afford to ignore means of attracting industry to this area. The
South is on the rise. Residents once settled in the industrialized north-
east are returning to the south. It is only logical to assume that the
next step in the growth pattern of the South will be industrial development.
I for one, and I am sure thousands of others who reside in this city, would
like to see industry, which we know will ultimately develop somewhere in
the South, (Miller Brewery, Eden, North Carolina) locate in Greensboro,
North Carolina.
I feel, and others back me in this point of view, that the matter has
been studied and re-studied, recommended and re-recommended, and red-taped
to death at this point in time. I believe, as an attorney, that the decision
of tha Enviornmental Protection Agency to locate the new sewage treatment
facility at the Confluence site is justifiable, both from a legal, moral,
social, and economic point of view. It would distress me if EPA chose to
locate the site of the new sewage treatment facility at any place other than
the Confluence site due to minor opposition by one tiny Guilford County
community. The waste needs of this city and county are on the increase.
I would urge that the best possible site for construction of the new sewage
treatment facility is the Confluence site due to the abundant availability
of water in that area. Further more, it is the only viable means of attractin
industry to this area, which is so solely needed.
This position statement is supported by the Greensboro Young Men's Club
of Greensboro, North Carolina. This group is made up of young Black professic
nal men who live in Greensboro and who are very concerned about the controlled
growth of the community.
Respectfully submitted
Secretary, Greensboro Young
Men's Club
-------
CLINTON E. GRAVELY, A.I.A.
ARCHITECT and ASSOCIATES
Member of the American Institute of Architects
"""ORAVm .„1LWNC CREINSBORO.N.C.
September 14, 1977
Mr. John A. Little
Regional Administrator
Region IV EPA
345 Courtland Street
Atlanta, Georgia 30308
Re: Proposed Metro Sewer Plant
Greensboro, North Carolina
Dear Sir:
-t-hc ronfluence Site, Alternate No.4, as the
We urge the selection lant. We feel that a new plant
site for the proposed ^ew , built to take in consideration mc
should be located, designe ^ period ^ indicated for the CJ
than an annroximate 20 y g Confluence site also offers the ad\
rted'dSn s;rean fro. the intersection of North Buffalo
ffalo Creeks.
^ rmne be provided, preferable thru the purchase
We urcrp al<5o that a buffer zone cb » r
we urge also tnay «« -)tljre land use problems.
of land, to eliminate future
°r being locareu
and South Buffalo Creeks.
^Cts
d,»raffenriedt, jr.
fr»nce» tt> Unrit
PLANNERS
fc tymMU gravely
-------
M
3 *
J^nll n
[
~ s
REGION IV
Pershing Point Plaza
1371 Peachtree Street, N.E.
Atlanta, Georgia 30309
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
AREA OFFICE
415 NORTH EDGEWORTH STREET
GREENSBORO, NORTH CAROLINA 27401
September 15, 1977
IN REPLY REFER t<"
4.4SS
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Subject: Draft Environmental Impact Statement
Greensboro - Guilford County, North Carolina
201 Wastewater Treatment System
Project Numbers C37037601 & C37036901
Dear Mr. Hagan:
Thank you for the opportunity of reviewing the proposal.
We have no substantive comments to make at this time.
Sincerely,
Sabella
Area Director
cc: Regional Environmental Standards Officer
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3901}. Hickory Tree Lane
Gre og8ibl« that Alternative Xunbar If. b«
atances ahould w*k« it Alternative Huiaber 3 outlined In
tsrw** b:°»dopt.a.
Ky r.cc^.nd.tion 1. >«•* on th. follow!,*:
*> t-hm t»ropoaed wastewater facility near the
I. Construction of* /SoUth Buffalo Crfaka ahould provide
confluence of JoW a for long Um nt#da and expansion
th. no.t f'"1"' Gilford County.
in Greensboro an«
i. 4y, the best interest of Greensboro and Gull-
Notes I wastewater treatment plan be based on
?ord Oj^^SfdiMWoSI. ™tb,r th>" *
solution. reslij«nt« of MoL8*n«vlll« of th«
p The bl ^Lblers emanating from the proposed new
ootintul f°r oi°/ Sdf r technology «i«t» to d.aign
?££& i. «r'S2tfin» SwiU** ttmt will «..* stringent
a ^4,m«a#d frore this is a statement in the
*«<-«• ffut totally aivoi _ dtglgtt atid con struct ton of
%7^,'rhich acknowla^S" t f.ctliti«s which ineorporata recent
'Shod. Kill offwinor. reliability
technology •°VthI?W*0Tiwt,Bt w
-------
Furthornore, it can be proven both sci en hif icr;lly *nd statis-
tically tii. in South "uff'-lo Ore -k undoubtedly accountj r^r t
portion of th •> odor ~bout which 3 ore TTcLeansville v. a 1. d<¦-.rix
currently complain.
5. Construct} on of a nau wastewater trcati. rot facility down-
stream r.t th*; confluence of Kort'n and South 3uff..lo Gr; ¦1:,°
would necessitate the r-ilocation of an '.nai.^nifleant number
of houacholda ?nd businesses,
Note: Sizeable buffor zones are possible in th" vicinity
of th'* proposed wastewater treatment oit'-s in Alternatives
L| and 3. This should help ritignte any possible odor detection*
6. Upgrading or expansion of th« North Buffalo Creek T./aste-
vater Treatment Facility should be poaaibl* without hsvin.q
to relocate any, or at least any significant nurber of residefl^2
or buainas2es.
Net?: I sincerely believci that a Ion;* with the upgrading of
tha North Buffalo Trantment Facility"a goal can ba 3at to
improve aerial aruiasion. If this ia dona, irnrovad aerial
amission and hance air auallty can be accomplished.
7. The environment-»1 impact has alr eady been completed
regarding locating the proposed new wastewater tr*~twent
facility at the confluence of North and South Buffalo
Cracks. Accordingly, no additional tir» would be needed
to assaas the cnvironri:ent'il irnonct .
Kota •. It ray understanding that tha topography in this area
Ta conducive to the wastewater tr'-atiiant facility proposed
It is obvious that no one solution will receive unaniri:ou3 approval
of all the citizens who either will bo or perceive that they will
be affected. This Qotuinitfcee will do justice to the rajority of
the citiz^n3^ of ureensboro and Cmilford County if it adopts
Alternative :io, Ij. or 3 aa ezpaditlously as poamible. Thanlc You,'.
Sincerely,
-H a.CciA.^
H. A, Collins, Resident
Guilford County, NC
-------
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-------
United States Department of the Interior
OFFICE OF THE SECRETARY
Southeast Region / 148 International Blvd., N.K / Atlanta, Ga 30303
ER-77/819
Mr. John E. Hagan, III
Chief, EIS Branch #
Environmental Protection Agency
345 Court!and Street, N.t.
Atlanta, Georgia 30308
Dear Mr. Hagan:
thP reauest to the Director, Office of Environ-
This is in response to we /J. on the
for a wastewater treatmeiit y ^ statement and find that it appears
North Carolina. we have revi effects on cultural resources,
to be adequate in addressing h fgj and hydr0]0gic resources,
outdoor recreation, fish
to review this statement.
Thank you for the opportunity to review
Sincerely yours
// Regional Environmental Officer
/
-------
September 7, 1977
Environmental Protection Agency
345 Courtland Street N.E.
Atlanta, Georgia 30308
Attn: Mr. John E. Hagan, III
Chief, EIS Branch
Dear Mr. Hagan:
Enclosed are some questions I feel should be more
adequately addressed in the Environmental Impact
Statement for the Greensboro-Guilford County, North
Carolina 201 Wastewater Treatment System.
Please consider these comments as part of the record
of the September 1, 1977 public hearing.
Sincerely
Robert L. Thomas
Route 2 Box 368D
Gibsonville, N. C. 27249
Enclosure
-------
COMMENTS FOR
THE SEPTEMBER 1, 197 7 PUBLIC HEARING
GREENSBORO 201 PLAN
ENVIRONMENTAL IMPACT STATEMENT
Several additional questions need answering in the Environmental
Impact Statement.
1. Is it not stated EPA policy to provide funding to build
waste treatment plants that do not smell and would that
not relieve the "social effects" around the existing
South Buffalo plant?
2. Per the Council on Environmental Quality's guidelines for
EIS's, who stands to make windfall profits from the proposed
action? Who are the individual property owners affected,
or corporation owners if held by a corporation, and to what
extent have they been instrumental in selecting the proposed
action?
3. Provide data showing what waste treatment sites are suitable
along the length of South Buffalo and how the current sites
were selected. To what extent does the city's desire for
400-500 acres affect site selection? Why not site the plant
on the 50 or so acres that are needed and zone or otherwise
restrict development around the plant in the future?
4. How severe are the effects on agricultural production of
accelerated development due to sewer availability in this
"prime agricultural area?"
5. The projected flow downstream of the existing South Buffalo
plant is only 2 MGD, assuming sewer is no constraint. Explain
in detail the economic justification, if any, for moving the
entire plant with its attendant large diameter outfall to
accommodate this growth rather than serving the same area with
a pump station and force main.
6. Why was the site in the general area Northeast of Lee Street,
North of 1-85 and just downstream of the South Buffalo plant
discarded? Note this site would be bounded partially by the
A&T farm which would provide a buffer zone for the plant and
that substantial acreage, topographically suitable for a new
plant, is vacant and available.
7. Provide details of the flow resolution meeting. Where was Lhe
meeting, who attended, and how is the 36 MGD justified by EPA
procedures?.
8. Explain how, after EPA's aborted first decision for Site 2, a
new site suddenly appeared which had never been mentioned in
any of the previous studies or Advisory Committee meetings,
and then became the "preferred site." Who attended this
meeting and how was this decision made?
-------
-2
9. What is the industrial cost recovery formula and how much
will the proposed action cost local industry? How are
industrial pre-treatment costs credited in this calculation?
10. In the flow resulution calculations, what is the assumed
percentage of population served in what service area, and
what is the cost of providing sewer service to that growth?
Can that service be reasonably expected to be provided
within the 20 year period?
11. Why were no capacity alternates considered particularly in
view of the wide variation of projected flows, from 29 to 48
MGD, which have been estimated for this project? The 2 MGD
flow downstream of South Buffalo provides an apparent capacity
alternate. What is the environmental impact of not providing
service to this flow for a reduction in total capacity
requirements ?
Robert L. Thomas
Route 2 Box 368D
Gibsonville, N. C. 27249
cc: Mr. Bob Cooper
-------
%riDSUPPLYING
W. H. ASHWORTH & ASSOCIATES "a "»8
products
PRODUCTS^'nr. 1 M Mc«-EANSVa«. N C
INCORPORATED (9l9)6ai-4M,
September 10, 1977
.1 protection Agendy
Environmental Protec
345 Courtland Street N.e.
Atlanta, Georgia 30JUS
Attn: Mr. John E. "JgJ* 111
Chief, £IS Branch
Dear Mr. Hagan:
» find mv presentation at the public
Attached, please 1977 £n reference to the City of
hearing on
5e?^fcomlty, wastewater Tre.t.ent Project.
Greensboro-Guilt ^
forwarded to you is altered slightly,
The paper being gnd of the presentation, so that
to include the notes at be required to further 'clutter'
additional letters will no
this file. .ftted With the water and wastewater
Having been century, I feel I understand some
business for over » q»»Jj£ f?ces in raakl„g their final decision
of the problems your on
that we might visit you in Atlanta, to
I would hope that we j costly project to a successful
assist in bringing tfti. 1«"«
conclusion. ^ ^ tnrned into a
I sincerely regrv
Civil Rights issue. ^ ^
William H. Ashworth
WHAshs
r . , .
Enclosure
-------
SUPPLYING |) o BOX 8
MUNICIPAL & INDUSTRIAL ^ASHWORTH & ASSOC! ATFS M.I I ANSVII 1.1., N. i'- 2
WATER & WASTEWATER ill Ol /liJijWvjliA 1 ILO (910) 621-4221
PRODUCTS INCOIU'OKAH:!>
September 1, 1977
Madam Chairperson, Ladies & Gentlemen:
My name is u'illiam H. Ashworth, a member of the Concerned Citizens
of McLeansvilief but expressing my personal views because my
involvement in the MSTRO planning extends well beyond the formation
of our citizen's group.
My first look at Metro planning came during the early 1970's, or
possibly even before. At least well before the 1970 Census figures
were available.
At that time, we all thought our cities and towns had had tremendous
growth in the 1960*s, and that our population explosion was still
'going strong'.
The long range planning, at that point in time, was for large, regional
systems to provide for the anticipated, continued rapid growth.
Therefore, based on what seemed to be taking place at that time, I
strongly supported a REGIONAL METRO system with the treatment plant
located at Reedy Fork Creek.
As the true facts and figures of the 1970 Census became available,
we all learned, much to our surprise, that our city had not grown
nearly as much as we had previously thought, and further, our birth
rate was rapidly declining.
The "Gladstone" report had been completed and indicated sufficient
land already available within the city limits to provide for future
growth.
Further, we were rapidly moving into a disasterous inflationary period.
Mr. R. L. Thomas, Consulting Engineer, who joined our efforts about
that time, convinced me of the accuracy of the above mentioned, but
-------
P. O BOX 8
„ SUPPLYING «r O A CUWORTH & ASSOCIATES McLEANSVILLE.N.C. 27301
'CIPAL & INDUSTRIAL W. H. A^WUIHO tx tX INCORPORATED (9.0)62,-422,
11ER & WASTEWATER
PRODUCTS
(2)
yet to be recopnizes facts.
t, cnrk svstem would help provide more available,
Even though the Reedy ForK sys
1«+C for our young couples, the plan was strongly
low cost, building lots tor o y
ritv We could further find little hope of PL 92-500
opposed by the City.
* to account the major social consideration necessary
being able to take mi
.. *u... f-hP most cost effective alternate,
to finance anything other than
r facts. I was forced to agree, reluctantly, to
Paced with all of these facts,
* the Reedy Fork plan, and to go strictly by
withdraw my support
the law. ... .
„{ew of the original 201 Facilities Study in
We began our further
+ hi» most cost effective alternative, and to
an effort to determine the mo
. calculations with that Study. This, we were
reconcile our figures a
Mr Thomas presented those major differences
never able to t Hall. Those differences were
during the public hearmg at the y ^
„ calculations were correct, would represent
substantial, and i °
of several millions of dollars.
potential savings uted f0r the record that those cost differences
It should be clea y . _ire of the McLeansville community for
vere a major factor i°
1 Tmoact Study.
the Environmental w t -tart th*
i^ation nearly a year ago to start the BIS.
We met in this same loc.ti MoresSed.
r*l feelings were expressed.
That night, two gene st,
two
' f*4r and impartial study that proves us
«• '^vner3»/^itr;ii:°^uU.cooperation for the
c?^stftjyst°te 11 us where to build it",
2. The City sai » ^ ^ city whefe to bU£ld it.
r EPA, in Ia 1
In July of this ye » officials descended upon Atlanta and
i r4tv and County
Within one week, ^
had a new site chosen.
-------
I1. O. BOX 8
W. H. ASHWORTH & ASSOCIATES
INCOKl'ORA 11.0
(3
The first site selected was Alternative # 2, Clapp Farm Site. One week
later Alternative # 3, Ciba Geigy Site, became the preferred plan.
We have extreme difficulty understanding this action by BPA.
We find no major fault with the Radian Corporation study (See Note 1)>
it would be extremely hard to do so since it has proven our position t0
be 99.44% correct, and that in fact, many millions of dollars can be
saved by going with their most cost effective alternate.
Time will not permit me to read int6 the record the 'single letter'
from Mr. Matthew J. Robbins, Regional Director, Office of Civil Rights
& Urban Affairs, that attempts to negate the findings of the
Environmental Impact Study.
If all here tonight are truly interested in a fair and impartial
solution to our mutual problem, I ask you to take the time to read
Mr. Robbins' letter, checking for completeness and accuracy.
It has been a long and costly struggle for us, but we feel our efforts
have been in the interest of all people, whether in McLeansville,
Greensboro or elsewhere in this Country.
In conclusion, we trust that the FACTS of the ENVIRONMENTAL IMPACT
STUDY will not be altered by FICTION.
Thank you,
William H. Ashworth
Note 1: It would appear that Radian accepted, from other sources, the
following date which we challange:
1. The TOTAL CAPACITY required to meet projected needs.
2. The PRESENT CAPACITY of the North Buffalo Plant.
3. The GROWTH PATTERN as projected in the 201 Study.
SUPPLYING
MUNICIPAL & INDUSTRIAL
WATER & WASTEWATER
PRODUCTS
-------
September 10, 1977
Mr. John Hagan, III, Chief. EIS Branch
Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
Dear Mr. Hagan:
a annreciate, Mr. David A. Adams' letter
we have received, ana py final comments we may have
of September 6th conce g Greensboro metro sewer plant.
concerning the Ions which I want to submit for the record
I do have several questions wni answers on.
and am looking forward to having
nicked by the EPA (between Highways 70 and
(1) Why was a site picice y d after a visit to Atlanta by
1-85), announced, ancJ.„ M*lvin and Ray Shaw? Was there political
Greensboro's Mayor, people feel?
pressure applied, as several peop
in the EPA impact not given the intent
(2) Why were other sites were given?
study that the McLeansville sites
r-reensboro feel it necessary to imply
(3) Why did the City of W heing televised and taking the
and make this a racialissue £heir support in Greensboro?
issue to the minority to g«* station WEAL several times before
Mayor Melvin was also on *3 , rity for their support.
the hearing, "begging" the minor ,
¦ ^ nver upgrading which would have been
(4) Why were sites P1Cke(\.hp most cost-effective action not
ttost economical? Why was the mos
taken?
¦kt t-j-ViAw J Robbins, dated July 12, 1977,
(5) Your letter from Mattne • ^ ^ uged tQ upgra
-------
Mr. John Hagan
Page 2
September 10, 1977
(8) Why was all our money spent for an Impact Statement which
did not include air quality or smell of the metro plant?
(9) Why, approximately three weeks before the September 1st
hearing, did the City of Greensboro dump an extra amount of raw
sewage Into South Buffalo Creek? Was this to gain The suddo«
of those living near the creek in the Citv t-r. uo suPP°rt
of us who live in its banks in tL County?'
I am enclosing a copy of a letter to me from Senator Robert
Morgan with a copy of his letter to Mr. Douplas Costle FPA
me^pUnt01' C°nVSylnB his ques^ons on Jhe proposed
favorable°decision. t*lese -l-o. and eagerly await a
Thank you for your time and help.
Yours truly,
JGN/n
Enclosures
cc: Mr. David A. Adams
Mr. Howard N. Lee
hn G. NewsomV^- Sr
Route 1, Box 459
McLeansville, N. C. 27301
-------
OSTEEN, ADAMS 8c TlLLEY
ATTORNEYS AT LAW
POST OFFICE BOX 2489
GREENSBORO. NORTH CAROLINA 27402
GATE CITY SAVINGS ft LOAN BUILDING, SUITE 304
WlLLAM L. OSTEEN AREA CODE 019
J. PATRICK ADAMS TELEPHONE 274-2949
N. CARLTON TlLLEY, JR.
September 14, 1977
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
The Concerned Citizens of McLeansville wish to bring to your
attention several important questions which we feel should be
thoroughly considered by the Regional Administrator in reviewing
the proposals advanced in the Draft Environmental Impact Statement.
We also feel the final EIS should address itself to these points.
Reprinted on the last page of the Technical Reference Document
is a memorandum from Matthew J. Robbins, Regional Director, Office
of civil Rights and Urban Affairs to John Hagan. That memo states
certain interpretations of 42 USC § 2000 d to d-4 as applied to the
upgrading of the present South Buffalo facility. Our research
fails to disclose any authority supporting an interpretation that
the upgrading of a sewerage treatment facility already located in an
area inhabited predominately by a racial minority is discriminatory.
Our questions relate to that memorandum and are as follows:
(1) Does EPA accept as authoritative Mr. Robbins interpretation
of 42 USC § 2000 d to d-4 as it relates to this project?
(2) Did EPA accept as factual the assertions regarding past
unlawful housing practices and present availability of
housing in the City of Greensboro?
(3) Did EPA make any study regarding residential property
availability in Guilford County outside of the Greensboro
City limits?
(4) Did EPA use this memorandum or its contents as a con-
sideration for rejecting alternative sites #1 and/or #6?
-------
Mr. John E. Hagan, III
Page 2
(5) If the Robbins' memo was not a factor in EPA's rejecting
alternative sites #1 and/or #6, why is it "socially un-
acceptable" to upgrade and enlarge a facility at the
South Buffalo site while at the same time it is socially
acceptable to upgrade and enlarge the existing North
Buffalo facility?
We would appreciate your attention to these questions.
N. Carlton Tilley, Jr
NCT:Id
cc: The Honorable Prances Phillips
The Honorable John A. Little
General Counsel
-------
RICHARDSON PREYER
6th District, North Carolina
103 Federal. Buiudino
Buwunoton, N>C. 27219
2344 Rayumn House Office Bvildinq
WA8HINQTON, D.C. 20519
Congress of tfie IHm'tcb States
249 Federal. Buildinq
Gminsmno, N C. 27401
COMMITTEES;
INTERSTATE AND
FOREIGN COMMERCE
House of HepreaentatitoeiS
iM)in0ton, 3&.C. 20515
409 Law Building
Him Point* N.C. 27290
GOVERNMENT OPERATIONS
SELECT COMMITTEE ON
ASSASSIN AT IONS
CHAIRMAN: KENNEDY SUBCOMMITTEE
ROCKINGHAM
County
September 14, 1977
Mr. John E. Hagan
Chief EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30308
Dear Mr. Hagan:
1 am submitting herewith a written statement which X would like to
request be made a part of the written public record of the September 1st,
1977, hearing on the Greensboro Metropolitan Wastewater Treatment Facility
Project.
It is my understanding that the closing date for written, statements
is a postmarked receipt of September 15th. X hope very much that
my statement can be included in the record.
Cordially
<1
Richardson Preyer
KP:bjb
EPA • IMPACT STATEMENTS
THIS STATIONERY PRINTED ON PAPER MADE WITH RECYCLED FIBERS
-------
September 14, 1977
STATEMENT FOR THE PUBLIC RECORD - EPA
GREENSBORO METROPOLITAN WASTEWATER TREATMENT FACILITY
RICHARDSON PREYER, MEMBER OF CONGRESS
The proposed Greensboro Metropolitan Wastewater Treatment facility
has been under review by the Environmental Protection Agency for a
perzod of five years. Many negotiations have been held between local
officials and engineers, the State of North Carolina officials on
the water programs and the Environmental Protection Agency officials.
Misunderstandings have ensued from time to time but in the final analysis
all of those concerned have been able to reach a decision on the approach
to take in order to provide the City of Greensboro with adequate waste-
water treatment facilities. Public hearings have been held, environmental
assessments conducted and finally a full Environmental Impact Statement
has been done by an outside contracting firm.
The project has grown from one which was to have cost $17 million
to one which will now cost in excess of $30 million. Greensboro
was instrumental in approving a State referendum for the issuance of
water bonds to aid in the development- nf x. , , ,
uevexopment of wastewater treatment facilities.
Yet, because of the delays i„ the project, Greensboro has not
been the recipient of such bond monies and stands to lose its last
opportunity for use of the funds unle** pd» ^
unxess EPA grants prompt approval of
the project before us.
-------
RICHARDSON PREYER STATEMENT
September 14, 1977
Page Two
The recommendations of the draft EIS submitted by the Radian
Corporation as to plant size and location have taken into consideration
the various objections, cost effectiveness, and long range needs of
the area. It is my conviction that the project should now finally
be approved. It is my earnest hope that the new Regional Administrator
will make a prompt decision approving the project as recommended in
the EIS.
-------
LAW OFFICES
COFER, BEAUCHAMP & HAWES
SUITE. 200, PEACHTREE
-------
LAW OFFICES
CO FER, BEAUC HAMP & HAWES
City of Greensboro EIS Comments
Page Two
September 15, 19 7 7
In our view sufficient data justifies selection of Alterna-
tive 4, the "confluence site". The existing needs respecting
water quality, adequacy of wastewater treatment, environmental
and land use concerns, and social and economic factors, all sup-
port selection of Alternative 4. The confluence site is also
fully justifiable given the documented projections of these needs
through the twenty year planning period.
One factor regarding Alternatives 1, 6 and 7 is not suffi-
ciently discussed by the DEIS. All three Alternatives call
for upgrading the South Buffalo Plant. In our judgment, imple-
mentation of any would result in a close down and sewage bypass
of these facilities during construction. Simply put, given the
antiquated plant, the substantial reconstruction effort required
by these Alternatives, and the insufficiency of land available
for construction activity, SBP would be closed down for a sub-
stantial period of time. Accordingly, the SBP wastewater would
have to be bypassed, a situation which is environmentally intol-
erable. This matter should be reconsidered and discussed in the
Final E.I.S.
There are significant economic, land use planning, and
social factors which bear upon the site selected and which per-
sist beyond the twenty year planning period. EPA is authorized,
-------
LAW OFFICE S
COFER, BEAUCHAMP & HAWES
City of Greensboro EIS Comments
Page Three
September 15, 19 7 7
both under the Grant Regulations (40 CFR Part 35) and NEPA Re-
gulations (40 CFR 1500), to consider these compelling matters.
While planning for purposes of identifying Alternatives is con-
fined by policy to a twenty year period, selection of a final
Alternative must take into account any overriding, longer range
factors. These factors and their consequences are amply de-
scribed in the Greensboro Department of Planning and Community
Development statement of September 8th. The history of Greens-
boro development, the City's current demography, and the fixed
pattern of future development clearly foreclose as a viable op-
tion upgrading existing facilities. Further, the report demon-
strates the compelling reasons for locating new facilities at
the confluence site.
Review of the social implications inherent in EPA's final
selection of an Alternative are not only required by the Grant
and NEPA regulations, but are also compelled pursuant to Title
VI of the 19 64 Civil Rights Act and EPA's implementing regula-
tions at 40 CFR 7.1-7.13. In public discussion of Title VI,
certain questions have been raised regarding the applicability
of this Statute to the Metro Project, the remedies provided by
Title VI, and the sufficiency of evidence developed to date.
Title VI imposes obligations on both EPA, as Grantor, and
-------
LAW OFFICES
COFER.BEAUCHAMP & HAWES
City of Greensboro EIS Comments
Page Four
September 15, 19 7 7
the City of Greensboro, as a Grantee of Federal funds. While
there are no cases applying Title VI to EPA activities, analog-
ous case law is pertinent. It requires not only the avoidance
of perpetuating past discriminatory actions, but also affirma-
tively curing the effects of past, discriminatory patterns and
practices. These obligations obtain, notwithstanding the fact
that discriminatory housing, in its origin, may be unrelated to
the site selection and operation of the South Buffalo Plant.
Proof that maintaining South Buffalo operations would per-
petuate isolation of the black community is sufficient cause
to require "affirmative action". The Administrative Record is re
Plete with evidence sustaining the conclusions reached in the
determinations made by EPA's Office of Civil Rights and Urban
Affairs dated July 12, 19 77. The EPA findings record any num-
ber of contacts with leaders and organizations in the Greensboro
minority community. Federal case law applying Title VI find, as
probative evidence, facts and views solicited from minority com-
munity leaders and residents. These views are buttressed by
written submissions of the Greensboro N.A.A.C.P. and G.C.A. at
the public hearing, and in their correspondence to EPA dated
May 10, 1977 and May 25, 1977. The data is confirmed by the
information supplied in the Planning Department Statement of
-------
LAW OFFICES
GOFER, BEAUCHAMP & HAWES
City of Greensboro EIS Comments
Page Five
September 15, 19 77
September 8th. The demographic material prepared by the EIS con-
sultant also clearly reflects the concentrations of minority
housing, economic disparity in land values, and the probability
of continued minority isolation should the South Buffalo Plant be
maintained.
The question then becomes, "how much is enough affirmative
action". The duty goes beyond simply identifying alternatives
to maintaining SBP. It creates an inducement to spend more money
for the Project if an alternative is otherwise (apart from civil
rights implications) justifiable under the site selection criteria.
As noted above, this rationale is also supported by Title II
provisions of the FWPCA and its implementing regulations at 40
CFR Parts 35[Grants Regulations] and 1500[NEPA Regulations];
both authorize recommendation of an alternative on the basis of
overriding social considerations.
Pursuant to your obligations at 40 CFR 1500, et. seq., the
DEIS includes recommended, mitigative measures which address ad-
verse environmental impacts of the Preferred Alternative. Be-
cause of their proximity, the mitigative measures suggested at
Chapter VI of the DEIS would also apply should Alternative 4 be
finally selected. We believe it is important to your decision
making that the City respond to these recommendations.
-------
LAW OKFICES
COFER, BEAUCHAMP & HAWES
City of Greensboro EIS Comments
Page Six
September 15, 19 77
Court interpretations of the National Environmental Policy
Act of 1969 tell us that an EIS review must identify all fore-
seeable environmental consequences of a proposed federal action.
They also teach that the duty to identify impacts and to miti-
gate potential, adverse impacts is a continuing obligation, i.e.,
the grantor and the grantee must commit themselves to avoiding
environmental damage as a project moves forward, through imple-
mentation. I am authorized to represent the City's intent to
satisfy these obligations as they apply to the measures set out
at Chapter VI of the DEIS as well as any which become apparent
in the future.
We have closely reviewed the controls specified in the DEIS.
We believe the recommendations are well founded, and we commit
to implementation of these measures as indicated and as appropriate.
In particular you should know we will encourage further develop-
ment and enforcement of the Guilford County Land Management Policy
adopted January, 1977 (DEIS p. VI-5). Additionally, we find the
table of lot sizes and impervious surface areas (at p. VI-5) ac-
curate, and we fully adopt the recommendation regarding lot sizes
(p. VI-6). Those mitigative measures regarding "Water Quality"
-------
LAW OFFICES
COFER, BEAUCHAMP & HAWES
City of Greensboro EIS Comments
Page Seven
September 15, 19 77
(pp. VI-6 through VI-9) will be undertaken. The remaining sug-
gestions respecting both the Natural Environment and the Man-Made
Environment are oonsistant with our land use planning authority
and will be implemented.
Thank you very much for your kind attention.
Respectfully submitted
THR:sgb
cc: Bob Cooper
-------
J iidc : B Mi mi, !i.. Governor
North Carolina Department of Natural
Resources &Community Development
Howard N. Lee, Secretary
September 19, 1977
Mr. John E„ Hagan, III
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E,
Atlanta, Georgia 30308
Dear Mr„ Hagan:
This letter contains the comments of the Air Quality Section on the draft
environmental impact statement on the Greensboro 201 system (EPA 904/9-77-018),
On page II-9 the sentence "The results were inconsistent." should be deleted.
The results (projections) were not inconsistent with each other. The projections*
were different from (inconsistent with?) values actually observed, which is what
the next sentence states. The sentence is thus either incorrect or redundant,
depending on interpretation, '
On pages II-9, II-12, and 11-13, the (EN-485)reference (bibliography entry)
is incorrect. The volume cited is only one of four in a series, and reference
to all four is necessary to fully document statements in the DEIS. Engineering-
Science is the author of only Volume I, the Air Quality Section of the Division
of Environmental Management of the N, C, Department of Natural and Economic Re-
sources (now N. C„ Department of Natural Resources and Community Development)
is the author of Volumes II and IV, and the Research Triangle Institute is the
author of Volume III,
On page 11-10 Annual Average N02 values should also be indicated as arith-
metic means.
We are unable to comment on the "red flag" on the air quality aspects of
the no action alternative as noted on page 111-33 due to lack of information on
the red flagging procedure.
On page V-4, first paragraph, it is stated that, since Guilford County is
an Air Quality Maintenance Area for TSP, governmental agencies should prevctu
violations of air quality standards. That AQMA regulations should prevent future
TSP (total suspended particulate) violations is not a cost-frce side-effect
benefit of some other purpose. The purpose of the AQMA regulations is by defini-
tion to prevent future TSP and all other pollutant violations. If there can be
increases in pollutants as is likely due to the secondary impact of the proposed
P. O. Box 27687 Raleigh, North Carolina 27611
An f. gun/ Opportunity Affirmative Action Employer
-------
Mr. John E. Hagan, III
September 19, 1977
Page 2
action and if these increases might necessitate additional air quality regula-
tory actions due to probable violations of ambient air quality standards, then
the environmental impact statement should evaluate each alternative as to its
probable future impact in terms of the additional air quality regulations, if
any, that the growth associated with the alternative would cause to be imposed.
However, resources required to carry out this evaluation would be considerable.
On page V-4, first paragraph, it is stated that non-significant deterioration
regulations control other pollutants. Actually, other than a generalized reference
to prevention of significant deterioration in 15 NCAC 2D ,0401, the Prevention of
Significant Deterioration Regulations (40 CFR 52.21), for which the State has been
delegated administrative and technical review by EPA, regulate only TSP and sulfur
dioxide and only from a limited list of types of large industrial sources. There-
fore, non-significant deterioration regulations will have little, if any, effect
m preventing increases of pollutants associated with the secondary impact of the
proposed action. r
the con?lde*ations in the two Paragraphs above, the statement, on
page V-4 first paragraph that the deleterious secondary impacts will not be
significant may very well not be true.
On page VI-1 include a statement on adverse implications for air quality
and/or cost to prevent air quality violations due to secondary air quality
impacts of growth permitted or encouraged by the proposed action. (See three
previous paragraphs.) r
NCDNER address on page VII-2 is an incorrect hybrid of two separate
agencies. ' r
i-h-c C0"Tact Dr' Russell Hageman or Mr. Brock Nicholson of
this office for any explanation or expansion of these comments at 733-5188.
Sincerely yours,
' s ..
McColman, Chief
Air Quality Section
JAMc:RH/am
cc: Mr. Brock Nicholson
Dr. Russell Hageman
Mr, David Ligon
Mr. Mark Oakman
-------
Post Office Box 6
McLeansville, North Carolina 27301
September 22, 1977
Mr. Bob Cooper
Environmental Protection Agency-
Region IV
3^5 Courtland Street, N. a.
Atlanta , Georgia. 30308
Dear Bobi
Enclosed is the article that I mentioned to you by telephone.
I believe there is good reason to think that other situations
such as this might exist concerning this project. I believe
you know as well as others on the staff there know that
political involvement has over-ridden facts and good judgment
in this situation to date. I have served in public office
for three terms and I believe I have some understanding of
how things like this work.
Please remember the points I made to you about the smell of
South Buffalo. The smell was terrible about two weeks before
the Public Hearing and two days after the Public Hearing there
was no smell. The temperature and weather conditions did not
change during this time.
Please notice the inaccuracy and unfactual statements that
were made by elected officials at the public hearing as well
as on other occasions.
My last point is I believe that the cost and environmental
concerns are far greater and should over ride any social concerns
that EPA has in regards to this project. If EPA feels that they
must move the plant, I don't believe they could find 333 acres
any more isolated and desirable for this facility than the one
mentioned in the paper.
Sincerelv. .
REi Greensboro-Guilford County
201 Waste Treatment System
R. Odell Payne
ROPj Imp
Enclosure
-------
Greensboro Daily News, Sat., Sept. 17,1977
Landreth Pushed
'Personal Case'
In Washington
BY STEVE BEERY
Dally News stiff Writer
Guilford County Commissioner Bob Landreth
months ago traveled to Washington at taxpayers' ex£>nse and
lobbied against a proposed site for Greensboro's Metro sewaS
reatement plant in part because he said the site would advme
ly effect his nearby 333-acre farm and home.
Landreth_s actions in Washington are at odds with state
ments he made last week to the Daily News The VL
had opposed, at that time, had been selected' tentative!? a/th
federal Environmental Protection Agency's favored ate
' over
Landreth said, in a written memo last week, hand-delivered
to the Daily News that his involvement in the controvert7
where the plant should be located wasn't
motivated by a desire for personal gain
because regardless of where it was locat-
ed, his property would have access to the
plant's sewer facilities.
But in Washington, Landreth met
with 6th Congressional District Congress-
man Richardson Preyer and talked about
how the site, commonly referred to as the
Clapp Farm site, was located very close
to his home and farmland and would ad-
versely affect it.
Landreth said Friday that at the time
of the Washington trip he was concerned
• adverse effects on his property be-
ano m ....
cause he wasn't sure of the exact proposed location of the plant
Landreth said he later learned the more precise location and
"now 1 don't think it will adversely affect my property."
Landreth said that he want to Washington to present the
county's and city's concerns about the Clapp farm site and that
he also expressed his "personal case." "I'm going to argue my
personal case whenever I can," he said.
He said he discussed making the trip with city and county
officials before departing "to see if they thought it would be
a benefit for me to go to Washington." Landreth said they
agreed the trip would be beneficial, he said. Landreth expressed
the county and city opposition to the Clapp farm site and sup-
port of a site near McLeansville where north and south Buffalo
creeks come together.
Preyer confirmed Landreth talked to him about the adverse
effects putting the plant on Clapp Farm would have on Lan-
dreth's property. Preyer said, however, he had talked with Lan-
dreth on a number of occasions about Metro before the Clapp
Farm site was proposed and considered Landreth's visit just an-
other contact. "But he did have more emotional steam this
time in his conversation because he said it would cut across his
land or take some of it and so on," Preyer explained.
Preyer conceded this was the first time Landreth had ever
made a personal visit to Washington to talk about Metro. He
said Landreth expressed his support, as he had in the past, of
sites further downstream, and didn't dominate the conversation
with his concerns over how the Clapp Farm site would affect
his property.
"1 didn't at all get the feeling he was doing anything sneaky
or underhanded. Me didn't ask me to not tell anybody about
the meeting,'' I'reyer .viid.
-------
APPENDIX A
INDUSTRIAL COST RECOVERY METHODOLOGY
-------
APPENDIX A
FEDERAL GUIDELINES
INDUSTRIAL COST RECOVERY SYSTEMS
Municipal Construction Division
Office of Water Program Operations
Environmental Protection Agency
Washington, D. C. 20460
February 1976
-------
TABLE OF CONTENTS
PAGE
Foreword i i i
1. Introduction 1
2. Purpose and Scope 1
3. General Requirements for Step 2 and 1
Step 3 Grant Applications
4. Step 3 Grants -- Required Documentation 2
for Approval of Proposed ICR Systems
5. Appeal Procedure 3
6. Computation of ICR Payments 3
7. Reserved Capacity 4
8. Exclusions from Application of ICR System 5
9. Industrial Cost Recovery Examples 6
A. Construction of a New Wastewater
Treatment Plant 6
B. Expansion of an Existing Wastewater
Treatment Plant 13
C. Construction of Sanitary Sewers 13
10. New Industry 13
11. Monitoring 14
12. Discontinuance of Use by Industrial User 14
13. Lump Sum Industrial Cost Recovery Payments 14
14. State Agency Reviews 15
15. Conflict Between Local Laws or Agreements
and Federal ICR Requirements 15
i
-------
PAGE
16. Implementation of Approved ICR Systems 15
A. Notification of Implementation 15
B. Deposit of Recovered Funds 16
C. Annual Payment to EPA 16
D. Use of Retained Funds 16
E. Reduction of Allowable Costs for Future
Grants 17
F. Audits 17
G. Record Keeping 19
H. Penalties for Non-Compliance 20
Appendices
Appendix A - Description of Industrial Cost
Recovery System A-l
Appendix B - Opinion of Legal Counsel B-l
ii
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FOREWORD
Section 204(b)(1)(B) of the Federal Water Pollution Control Act
Amendments of 1972 (PL 92-500) requires that industrial users of the
treatment works make payments for that portion of the cost of constr-
uction of such treatment works (as determined by the Administrator)
which is allocable to the treatment of such industrial wastes.
The congressional intent of this provision is that "it is
inappropriate in a larqe Federal grant program providing a high
percentage of construction funds to subsidize industrial users from
funds provided by taxpayers at large" (legislative history).
This provision was implemented in the Code of Federal Regulations
at 40 CFR Part 35, Subpart E, promulgated by the Environmental Protection
Agency on February 11, 1974. Specifically, 40 CFR 35.928 and 35.935-13
state the industrial cost recovery system shall be prepared by the
grantee, approved by the Regional Administrator, and implemented and
maintained by the grantee in accordance with those regulations.
These guidelines are published to establish general minimum
guidance and to inform industrial users, grantees, Regional
Administrators, and the Dublic concerning industrial cost recovery.
The purpose of the guidelines is to increase understanding, assist
preparation, simplify evaluation, and accelerate approval,
implementation and maintenance of industrial cost recovery systems.
Andrew W. Breidenbach
Assistant Administrator
for Water and Hazardous Materials (WH-556)
iii
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1. INTRODUCTION
On October 18, 1972, the Federal Water Pollution Control Act
Amendments of 1972 (Public Law 92-500} (the "Act") were enacted,
extendinq the construction arants program and imDOsinq new requirements
on grant applicants. Section 204(b)(1)(B) of the Act prohibits
the Environmental Protection Aqency from approving a construction
grant after March 1, 1973, unless the qrant applicant has made provision
for repayment by the industrial users of the treatment works, of
that portion of the Federal grant which is allocable to the construction
of facilities for treatment of wastes from those users.
Pursuant to the mentioned above legislation, rules and
regulations covering industrial cost recovery (ICR) were codified in
40 CFR Part 35 and are referenced in these Guidelines and in Appendices
A and B. It should be noted that the appendices are part of these
guidelines and must be followed to the same extent as these
guidelines.
2. PURPOSE AND SCOPE
These Guidelines and Appendices are intended to implement the
industrial cost recovery regulations and to assist State and local
officials and their representatives in the establishment of ICR systems
which conform to the statute and EPA regulations. Guidance is
provided on only the minimum Federal requirements. The resolution
of other issues and the selection of alternative methods of meeting
the ICR requirements have been left to the discretion of grantees.
The examples in Section 9 of these Guidelines should not be
considered as inflexible or complete solutions for all municipalities
seeking Federal grants. In particular, it should be recognized that
the numerical fiqures in the examples are to be regarded as hypothetical.
3. GENERAL REQUIREMENTS FOR STEP 2 AND STEP 3 GRANT APPLICATIONS
Applicants for Step 2 (preparation of construction drawings
and specifications) and Step 3 (fabrication and building of a treatment
works) grants must furnish letters of intent from prospective industrial
users pursuant to 40 CFR 35.925-12. All Step 2 and Step 3 grants will
be made on the condition that the grantee will comply with Federal ICR
requirements unless the project will not initially serve industrial
users (see Section 8).
1
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4. STEP 3 GRANTS REQUIRED DOCUMENTATION FOR APPROVAL OF PROPOSED
ICR SYSTEMS
A. Prior to requesting payment of more than fifty percent of the
Step 3 grant, the grantee must furnish evidence to the Regional Administrator
which demonstrates that it has made timely progress in development of an
approvable ICR system. Such evidence shall include, but is not limited to,
the following:
(1) The identity of grantee personnel, consultants, and grantee's
legal counsel, whose responsibility it is to develop the industrial
cost recovery system.
(2) A detailed schedule for completion of all significant
portions of the ICR system (e.g., ordinances, identification
of industrial users, etc.).
B. Prior to requesting payment of more than 80 percent of
the Step 3 grant, or the event or schedule determined by the
Regional Administrator to be applicable as described below, the
grantee shall submit the following additional documentation:
(1) A completed statement in the form shown in
Appendix A, which describes pertinent features of the ICR
system;
(2) A resolution passed by the grantee or a written agreement
executed by the grantee's representative who is authorized
to execute the grant documents that it will properly and
lawfully implement all the provisions of its ICR system;
(3) An opinion of the grantee's legal counsel, in the form
shown in Appendix B, that the grantee's ICR system meets the
requirements of Section 204(b) of the statute and applicable
EPA regulations, and is in conformance with the general
principles set forth in these Guidelines.
Generally, the requirement for submission of an ICR system at
the 80 percent payment level of a Step 3 grant is approDriate when
the treatment works to be constructed under the grant consists of
a single treatment facility which will be operable when construction
is completed. The two most frequent cases where the operation
of a treatment works or operation of elements of a treatment works
does not coincide with complete payment of the Step 3 grant are:
the segmented project -- a project is segmented by the grantee
and several Step 3 grants are necessary to complete construction
2
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of the treatment works before it can be placed in operation; and the
multiple facility project -- a project in which the treatment facilities
or elements will be constructed and placed in operation by the qrantee
at different times and before the completion of all oayments under
the Step 3 grant.
In projects where segmenting of an operable treatment works
has occurred, payment of more than 80 percent of the total of all Step 3
segments is not permitted unless the ICR system proposed by the grantee
is approved by the Regional Administrator.
In projects where an element or elements of the treatment works
have been completely constructed and placed in operation by the grantee,
additional payment on a Step 3 grant is not permitted unless the ICR
system (or that portion of the ICR system associated with the operating
elements of the treatment works) proposed by the grantee is approved
by the Regional Administrator.
In approving an ICR system, the Regional Administrator may
require additional documentation and assurances if he requires revisions
to the grantee's proposed system, or otherwise deems it appropriate.
5. APPEAL PROCEDURE
The grantee's ICR system and plans must provide for an administrative
appeal procedure by which individual industrial users will have an
opportunity to be heard regarding the reasonableness of the allocations
and ICR assessments imposed upon them. It must also provide a
method whereby others affected by the ICR system may obtain local
review of the grantee's administration of the ICR system.
6. COMPUTATION OF ICR PAYMENTS
It is the grantee's responsibility to insure that the proper amount
of Federal funds are recovered from industrial users and that each
industrial user is treated fairly and consistently and assessed ICR
payments in accordance with applicable law and generally accepted
accounting principles.
ICR payments must be in proportion to those industrial wastewater
characteristics which influence the cost of construction of the
treatment works. These characteristics may include strength, volume,
and delivery flow rate characteristics.
The following must be taken into consideration relative to
the computation of the individual industrial user's ICR payment:
3
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A. If an industrial user's maximum flow (hourly, daily,
monthly, seasonally, etc.) contributes to the cost of
construction of a treatment works, it should be the basis
for that user's ICR payment. No credit shall be given
to the industrial user for the time period when the user
is not operating and not discharging wastewater.
B. Industrial users often discharge uncontaminated cooling
waters into municipal treatment facilities. Such cooling water
is considered process waste and must be included in the
ICR computation.
C. Wastewater collection and treatment facilities are normally
designed with unreserved excess capacity for expanded
future use. The cost of building such unreserved excess
capacity into a facility need not be recovered from existing
users under these Guidelines.
D. Industrial cost recovery must be based on Step 3 construction
and administrative costs, plus related Step 1 and Step 2 costs.
Step 1 or Step 2 grant costs which do not result in actual Step 3
construction are not allocable to individual industrial users,
and consequently need not be recovered.
E. Industrial users discharging pretreated process wastes
into the municipal treatment facilities must pay industrial
cost recovery based on the characteristics of the pretreated
process wastes.
Those industrial wastewater characteristics included in the ICR
system shall be monitored as required under Section 11 of these Guidelines.
7. RESERVED CAPACITY
Grantees may permit industrial users to reserve capacity
in the treatment works (including used and unused capacity). Such
capacity reserved through formal, written agreement is subject to
industrial cost recovery as set forth below.
In such cases, the industrial user shall be required to pay the
full ICR allocable to the capacity reserved. In the event that the
industrial user exceeds its reserved capacity, it shall be required
to pay ICR calculated on the full reserved capacity plus additional
ICR for use above the limits of the reserved capacity or any element
thereof.
4
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In the event the treatment works are expanded in the future
with PL 92-500 grant assistance, an industrial user who has executed
a reserved capacity agreement and has made ICR payments based upon
full reserved capacity will not incur additional ICR charges
associated with the cost of expansion until the industrial user's
actual use of the treatment works exceeds its reserved capacity.
Industrial users with reserved capacity contracts will, of course,
be required to pay any additional ICR charges associated with the
cost of upgrading a treatment works.
8. EXCLUSIONS FROM APPLICATION OF ICR SYSTEMS
A. ICR is not required for the following grant costs:
(1) Infiltration/Inflow correction or treatment;
(2) Correction of combined sewer overflows and collection
or treatment of stormwaters;
(3) Grants for projects which will not initially serve
industrial users. In such cases, the grantee must provide
evidence that industrial users will not be initially
served and must agree to a special condition to the
grant agreement or grant amendment which will provide
that the grantee will submit for approval by the Regional
Administrator an ICR system in full compliance with EPA
requirements, and that the system will be placed in
operation at the time the first industrial user introduces
industrial wastes into the grant-assisted facilities.
B. Certain industrial users may be excluded, at the grantee's option,
from the application of the industrial cost recovery system if they
fall within the following categories:
(1) Industrial users (as defined in 40 CFR 35.905-8(a), (b),
(c), (d) and (e)) which discharge only non-process,
segregated domestic wastes, or wastes from sanitary
conveniences (for example, the so called "dry" industries)
which are not significant industrial users under the
Regulations (40 CFR 35.925-12);
(2) Industrial users that have reserved a portion of an
existing treatment works under contract or agreement
existing as of March 1, 1973, and who have paid a reasonable
portion of the capital costs associated with that reserved
capacity as determined by the Regional Administrator.
This exemption applies only to grants for treatment works
5
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expansions and only then if the industrial user has not
exceeded his reserved capacity and will not require a
portion of the expanded capacity. Any capacity reserved
after March 1, 1973 is subject to ICR in accordance with
the regulations.
9. INDUSTRIAL COST RECOVERY EXAMPLES
A. Construction of a New Wastewater Treatment Plant
The first step in developing an ICR system is to determine the share
of capital construction costs of each component of the treatment
works in relation to the principal parameters -- volume of flow, (Q),
biochemical oxygen demand (BOD), suspended solids (SS), and any other
design parameter which influences the cost of construction. General
agreement regarding cost allocation can be easily obtained for some
plant components; for example, costs associated with raw wastewater
pumping are almost wholly a function of flow. The cost of such pumping
equipment would, therefore, be assigned to the flow parameter (Q).
Allocation of costs for other plant components is not so obvious and
less precise methods of estimating must be employed. The allocations made
in Table 1 are for illustrative purposes only and should not be construed
as definitive for all types of treatment.
Costs associated with some of the components in Table 1 are not
allocated across Q, BOD, and SS because these particular cost items
(for example, control building or design costs) are not clearly linked
to the wastewater treatment parameters under consideration. Instead
a weighted average allocation may be made based on the costs attributed
to those other components which are allocable.
It should be noted that any Step 1, 2 or 3 grant cost associated
with infiltration/inflow correction or treatment of stormwater is not
allocable ^industrial users, and should be deducted from total costs
of construction for the treatment works prior to calculating industrial
cost recovery payments. In Table 1, for example, Step 2 and Step 3
costs were reduced by the ratio of the volume of nonexcessive
infiltration/inflow (100,000 gal/day from Table 2) to the total
volume (1,900,000 gal/day). Since I/I contributes only to the
volume (Q) parameter, only the cost of facilities for that
parameter was affected by the reduction. Step 1 costs were reduced
by the costs incurred in removing excessive I/I from the system.
In the event the Step 1 grant or Step 2 grant had covered more than
one Step 3 grant, a deduction from total Step 1 and total Step 2 costs
would also be appropriate to reflect the amount of such costs allocable
to other Step 3 grants.
6
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The percentage cost allocations shown in Table 1 should not be
considered mandatory nor should they be considered uniformly applicable
to all locations. They are presented to illustrate a reasonable approach
to carrying out this cost allocation analysis and serve only as the
basis for the examples. Grantees may allocate costs associated with
flow, BOD, suspended solids, etc., to the treatment facility as a
whole, without resorting to the component-by-component analysis
shown in Table 1.
Since it is often impractical to develop a monitoring program to
measure wasteload discharges from each minor industrial user (See Section 11)
such industries may be initially assessed cost recovery payments on the
basis of estimated discharges. In such cases, a flat rate may be charged
each industry provided that the grantee has documented that it would be
administratively impractical to monitor each of the industries separately,
and that all such industries discharge a waste that is compatible with
the municipal treatment process.
Table 2 lists the flows and strength of sewage from a sample
community. The Federal grant allocable to per unit of capacity of flow, BOD,
and suspended solids, based on the costs given in Table 1, are:
Flow = $529.08/1,000 gals/day
BOD = $75.15/1b/day
Suspended Solids = $25.62/1b/day
The calculations in the example were based on design flows
and do not include flows attributable to nonexcessive infiltration/inflow
which are not subject to ICR. (Guidelines, Section 8). Thus, although
the treatment plant's design capacity is 1,900,000 gals/day, an adjusted
capacity (total capacity less infiltration/inflow) of 1,800,000 gals/day
was utilized in calculating ICR allocations to industrial users.
7
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TABLE 1
Component
Total
Cost
%*
$_
BOD
SS
Pump Station $150,000
Grit Chamber 45,000
Primary Clarifier 325,000
Aeration Basin 400,000
Secondary Clarifier 325,000
Chlorine Contact 50,000
Flow Measurement 30,000
Sludge Digester 250,000
Sludge Dewatering 80,000
1 ,655,000
Control Building 150,000
Step 3 Admin. Costs 50,000
1 ,855,000
Deduct, for Non-
Excess. I/I (1/19 of
Q, See Table 2) - 64,000
Total Step 3 Cost
for ICR Purposes 1,791,000
Step 1 Costs 50,000
Less Sewer Rehab.
Costs - 10,000
Total Step 1 Costs
for ICR Purposes 40,000
Step 2 Costs 150,000
Less Deduct, for
I/I (1/19) - 5,200
Total Step 2 Costs
for ICR Purposes 144,800
Total of All Grants
(1-3) for ICR Purposes 1,975,800
Federal Grant
1,481,850
100 $150,000 0
45,000 0
325,000 0
160,000 60
325,000 0
50,000 0
30,000 0
0 50
0 50
100
100
40
100
100
100
0
0
66 1,085,000 24
66 99,000 24
66 33,000 24
1,217,000
- 64,000
1,153,000
66 33,000 24
- 10,000
23,000
66 99,000 24
~ 5.200
93,800
1,269,800
952,350
$ 0
0
0 0
0 0
240,000 0
0 0
0 0
0 0
125,000 50
40,000 50
405,000 10 165,000
36,000 in
12,000 10
453,000
- o_
453,000
12,000 10
0
12,000
36,000 10
0
36 ,000
501,000
375,750
*Cost allocations for individual plant components are not definitive for
all types of treatment, and may be varied as necessary
0
0
0
0
0
0
0
125,000
40,000
15,000
5,000
185,000'
; 0_
185,00C
5,000
o_
5,000
15,000
0_
15,000
205,000
153,750
8
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Table 2
Design Raw Wastewater Flows and Strengths in Sample Community
Q BOD SS
Type of
Account
No. of
Accounts
gals/day
% of
Total
Ib^day
% of
Total
lbs/day
% of
Total
Industrial*
8
450,000
25
2,300
46
2,800
47
Commercial**
10
50,000
3
150
3
200
3
Residential
3,000
1,000,000
55
1,700
34
2,000
33
Sub-Total
1,500,000
4,150
5,000
Unreserved
Excess Capacity
Total Design Capacity
Less Nonexcessive I/I
+ 400,000
1,900,000
- 100,000
__
850
5,000
1,000
6,000
Design Capacity
for ICR Purposes
1 ,800,000
100
5,000
100
6,000
100
Capital Costs Per Unit of Treatment Capacity
Flow: Federal grant allocable to flow = $952,350 (from Table 1)
Design Flow (1,900,000-100,000) = 1,800,000 gals/day
Cost per unit of = $952,350
flow capacity HOT = $529.08/1000 gals/day
BOD: Federal grant allocable to BOD = $375,750 (from Table 1)
Design BOD = 5,000 lbs/day
Cost perunit of BOD = $375 , 7 50
capacity §7® = 75.15/1 b/day
SS: Federal grant allocable to SS = $153,750 (from Table 1)
Design SS = 5,000 lbs/day
Cost per unit of = $153,750
SS capacity 6,000 = $25.62/1b/day
industries are defined as any establishment listed in Divisions A, B, D, E
and I of the SIC Manual.
**Some commercial establishments are included in Division I, and as such,,
have an ICR obligation.
9
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TABLE 3
Daily Industrial Discharge in Sample Community
No. of Type of
Industry Employees Waste Q(gal s/da.y) #B0D/day #SS/day
1 200 Process waste 150,000 600 1,000
2 200 Process waste &
reserved capacity 200,000 1,200 1,000
3 300 Pretreated process
waste 70,000 350 590
4 500 Sanitary waste 15,000 30 30
5-8 Varies Process waste 15,000 120 180
450,000 2,300 2,800
Table 3 lists the community's eight industrial accounts. The
procedures followed in calculating each industry's cost recovery
obligation are as follows.
Industry No. 1 Q = 150,000 gal/day
BOD * 600#/day
SS ^ 1,000 #/day
Assumptions: Process wastes discharged to municipal sewerage system.
Total Cost Recovery Payment = 150,000 gals/day-($529.00/1 ,000 gal/day)
(over the useful life)
+ 600#/day-($75.15/#B0D/day)
+ 1 ,000#/day-($25.62/#SS/day)
= $79,362.00 + $45,090.00 + $25,620.00
= $150,072.00
Annual payment = $150,072.00
30 years - $5,002.40/year
(Based on a 30 year useful life)
10
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Industry No. 2 Initial Q = 100,000 gals/day
Ultimate Q = 200,000 gals/day
Initial BOD = 600#/day; ultimate BOD = l,200#/day
Initial SS = 500#/day; ultimate SS = 1,000#/day
Assumptions: This industry olans on riouMinn its output so^etine
during the useful life of the facility, and has entered a biniinq
agreement reserving treatment plant capacity for ultimate usage.
Total Cost Recovery = 200,000 gatyday ($529.08/1,000 gal/day)
(over the useful life) + 1 ,200 #B0D/day ($75.1'5/#B0D/day)
+ 1,000 #SS/day ($25.62/#SS/day)
= $105,816.00 + $90,180.00 + $25,620.00
= $221,616.00
Annual payment
Industry No. 3
= $221 616.00
dU years = $7,387.20/year
(Based on a 30 year useful life)
Q = 70,000 gals/day
BOD = 350 #/day
SS = 590#/day
Volume and strength of pretreated
waste
Assumptions: Process wastes discharged to municipal sewerage
system following pretreatment.
Total Cost Recovery = 70,000 gals/day($529,08/1 ,000 gal/day)
(over the useful life) + 350 #B0D/day ($75.15/#B0D/day)
+ 590 #SS/day ($25.62/#ss/day)
= $37,035.60 + $26,302.50 + $15,115.80
= $78,453.90
Annual payment
¦ $78,453.90
30 years = $2,615.13/year
(Based on a 30 year useful life)
11
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Industry No. 4 Q = 15,000 gals/day
BOD = 30 #/day
SS = 30 #/day
Assumptions: The only type of waste discharged by this industry
originates in sanitary conveniences. In the event the grantee exercises
the option to exclude this and other "dry" industries (Guidelines
Section 8) no cost recovery would be required. Otherwise the ICR
would be calculated in the same manner as for other industries in this
example.
Industries 5-8 Total Q = 15,000 gals/day
Total BOD = 120 #/day
Total SS = 180 #/day
Assumptions: The process wastes discharged by the four industries
in this group are not large enough to justify constant monitoring. The
grantee will have the choice of either calculating ctfst recovery payments
from these industries on the same basis as for Industries 1 through 4
or determining the cost recovery payments required from these industries
as a group, and dividing the resultant liability equally among the four.
Cost recovery calculations for the latter case would be made as follows:
Total Cost Recovery Payment = 15,000 gals/day($529.08/1,000 gal/day)
(Over the useful life)
f 120 #B0D/day ($75.l5/#B0D/day)
+ 180 #SS/day ($25.62/#SS/day)
Total Cost Recovery Payment = $7,936.20 + $9,018.00 + $4,611.60
c $21,565.80
Cost Recovered from each industry = $21,565.80
(over the useful life) $ = $5,391.45
Annual payment from each industry = $5,391.45
30 years = $179.72/year
(Based on a 30 year useful life)
12
p. U.S. Government Printing Office: 1976-679'919/500 Region 8
-------
It should be noted that industrial cost recovery payments are required
from industrial users which pretreat their wastes (Industry No. 3 in
the example), but the amount of such payments will be determined by the
wastewater characteristics following the pretreatment process.
In the event the grantee exercises its option to exclude "dry"
industries from industrial cost recovery (Guidelines, Section 8),
the grantee should also deduct the estimated sanitary wastewater from the
total discharge of industrial users which discharge a combination of
process wastewater and wastewaters from sanitary conveniences, prior to
computing the industrial cost recovery payments of such industrial users.
B. Expansion of an Existing Wastewater Treatment Plant
Capital costs for treatment plant expansion projects will be
determined in the manner outlined in the preceeding example. Allocation
of costs to industrial users will be based on the total expanded capacity
of that facility. For example, if industrial users will utilize
50 percent of the total capacity of the treatment works as expanded,
ICR payments adequate to recover 50 percent of the Federal grant will
normally be required, unless any industrial users qualify for the exclusions
from ICR described in Section 8 of these Guidelines.
C. Construction of Sanitary Sewers
Allocation of sewer construction costs to industrial users must be
based on the design discharge from such users as a percentage of the
design flow in the sewer. Industrial allocations may be based on
(a) the total cost of the sewer without regard to the point of an
industrial discharge, or (b) the cost of the portion of the sewer
downstream from the industrial discharge.
10. NEW INDUSTRY
A "new" industry is one which connects to a treatment works after
such treatment works has been put into service. ICR payments by a new
industry shall begin on the date use is initiated and shall continue
for the unexpired portion of the ICR period or until the industry
ceases use of the facility, whichever occurs first (see Section 12).
Total ICR recovered from a new industry shall be the Federal cost of
the capacity used multiplied by the ratio of its period of use to
the ICR period.
13
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11. MONITORING
In developing the ICR system, the wastewater characteristics of
each industrial user shall be determined. Normally this id done by
monitoring. However, where monitoring is not feasible, wastewater
characteristics may be estimated using historical records, data from
similar industrial users, etc. After the ICR system is put into operation,
major industrial users must be monitored on a regular basis, not less
often than annually. Monitoring for minor industries may be done on a
random basis. The grantee shall propose a definition of major and minor
industry and a monitoring program for each which reflects its relative
impact on the cost of construction of the treatment works (see Appendix A).
Monitoring must be conducted during periods of normal discharge.
12. DISCONTINUANCE OF USE BY INDUSTRIAL USERS
If an industrial user discontinues use of the treatment works
(including termination of any agreement for reserve capacity),
its payment for industrial cost recovery will cease. There is no
requirement for other industries presently using the treatment works to
assume the portion of the ICR payment which is unrecovered due to the
departure of an industrial user. Total ICR recovered from an industry
which discontinues use during the ICR period shall be the Federal cost
of the capacity used multiplied by the ratio of its period of use to the
ICR period. A significant industry planning to discontinue its use
of the treatment facility during the ICR period must make its intention
known in the letter of intent required under 40 CFR 35.925-12. The
grantee must consider the cost-effectiveness of providing capacity for
that industry in its facility plan (Step 1).
13. LUMP SUM INDUSTRIAL COST RECOVERY PAYMENTS
An industrial user may wish to fulfill its industrial cost recovery
obligation by making a lump sum payment for its entire share of the cost
of construction of the treatment works. Such payments may be accepted
by the grantee and either processed as a normal ICR payment or set
aside in a separate account to be drawn on annually for the remainder
of the industrial cost recovery period. Lump sum payments will not relieve
an industrial user from the obligation of making additional future payments
should its wastewater flow or load increase. Discounts from the total
industrial cost recovery requirement will not be given to industrial
users making advanced ICR payments. Any interest earned by the grantee
on ICR payments set aside will be recoverable in the same manner as if the
ICR payments were made as due (40 CFR 35.928-2(a)).
14
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14. STATE AGENCY REVIEWS
Federal review functions including review of the original ICR system,
approval of the use of retained funds, and the conduct of necessary audits
can be delegated to State water pollution control agencies.
15. CONFLICT BETWEEN LOCAL LAWS OR AGREEMENTS AND FEDERAL ICR REQUIREMENTS
Section 204(b)(1)(B) of the Act supersedes and nullifies any and
all State or local laws and ordinances and orders in conflict therewith.
Any agreement between the grantee and any industry, or between the grantee
and any other political jurisdiction, or other party, which purports to
relieve any industry from payment of the Federal share of the grant,
or which purports to limit the power of a grantee to demand collection
of the Federal share of the cost of construction from each industrial
user will not be grounds to circumvent or avoid the requirements
of Section 204(b)(1)(B), EPA regulations and these Guidelines. Prospective
grantees shall promptly notify EPA of such laws or agreements and take all
steps necessary to remedy the defect in their ability to fully comply
with EPA requirements. Until such restrictions are completely removed,
whether by court order or otherwise, the grantee shall be ineligible for
Federal funding.
16. IMPLEMENTATION OF APPROVED ICR SYSTEMS
A. Notification of Implementation
In general, the industrial cost recovery period will commence when
Step 3 construction is complete. However, at the time any element of a
treatment works funded by the Federal construction grant becomes operable,
it must be placed in the ICR system and the ICR period will begin from
the date of beneficial use by the first industrial user.
Immediately after the ICR period begins, the grantee will establish
the accounting period for the ICR system, which may be based on the
grantee's fiscal year or any other appropriate annual period and need
not coincide with the ICR period for any particular treatment works.
Adjustment for a particular treatment works or individual industrial
users should be made where appropriate and necessary to maintain
administrative integrity and simplicity.
Not later than 30 days after the ICR period begins, the grantee
will establish the accounting period for the ICR system and will notify
the Regional Administrator, in writing, of the date of this implementation
of the ICR system. The first payment to the grantee by the industrial
users shall be made not later than one year after the beginning of the
ICR period.
15
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Although the ICR assessment imposed on industrial users is based
upon an annual allocation of the Federal costs of construction of the treatment
works, the grantee may require or accept partial payments of an industrial
user's ICR assessment on a monthly, quarterly or semi-annual basis.
The grantee shall not provide industrial user's with an interest type
credit for such periodic payments and the payments must be associated
with the assessment of ICR charges for the year in which they are paid.
B. Deposit of Recovered Funds
All funds recovered during the annual accounting period (with the
exception of the discretionary portion of the grantee's share) shall be
deposited in interest-bearing accounts which are fully collateralized by
obligations of the U.S. Government or by obligations fully guaranteed as
to principal and interest by the U.S. Government or any agency thereof.
Uncollected ICR charges which mature into bad debts as a result
of bankruptcy of any industrial users should be identified, but
are not to be recovered from other industrial users or
other sources, and the Federal share of such charges need not be paid to the
U.S. Government as long as they remain uncollected. The funds recovered
in ICR payments are not to be decreased by the grantee's costs of collection
and administration of the ICR, since those expenses should be paid as
part of the operation and maintenance expenses associated with the treatment
works. EPA reserves the right to withhold future grants or grant
payments from any grantee who is not operating its ICR system
in accordance with EPA regulations or enforcing its system to
recover ICR payments.
C.' Annual Payment to EPA
At no less than annual intervals, no later than four (4) months
after the end of the grantee's annual accounting period, the grantee
shall submit to the Regional Administrator's Financial Management Office
a check for the annual ICR payment to the Federal Government, made
payable to the Environmental Protection Agency. This payment must
include any interest earned on the Federal portion of recovered funds
during the preceeding annual accounting period.
D. Use of Retained Funds
(1) The grantee must obtain the written approval of the Regional
Administrator (or the State agency when it is certified by the EPA to
do so) prior to committing any of the funds retained for the construction
of treatment works, pursuant to 40 CFR 35.928-2. Since retained funds
belong to the grantee, approval of their use is not a separate grant
16
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and need not be applied for through the State priority system. Only
the approval of the Regional Administrator is necessary and it will be
based upon a determination that the prooosed use of the funds would be
for costs for expansion and reconstruction of treatment works
within the applicant's jurisdiction which would be eliqible for
a grant.
In order to make such a determination, the Reqional Administrator
will require the following:
(a) a preliminary engineering report sufficiently detailed
so as to permit a determination of eligible costs;
(b) an estimate of eligible costs (see 40 CFR 35.940).
The grantee should not contract for, or proceed with the
expenditure of such funds until the Regional Administrator's
approval has been obtained. No more than actual costs
may be withdrawn.
(2) Discretionary funds retained by the qrantee (20 percent of
the retained funds (See 40 CFR 35.928-2(b)) may be used for any purpose
except for construction of industrial pretreatment facilities or rebates
to industrial user(s) for costs incurred by such users in complying with
Federal user charge or industrial cost recovery requirements.
E. Reduction of Allowable Costs for Future Grants
Allowable costs for future grants will be reduced by an amount equal
to the unexpended balance of the amounts retained by the grantee for future
expansion and reconstruction together with interest earned thereon
(40 CFR 35.925-17).
F. Audits
(1) It will be the practice of EPA to make a preliminary audit of the
qrantee1s industrial cost recovery system at the time of, and as an
extension to, the final construction audit. The scope of this preliminary
audit will generally encompass:
(a) a verification that the grantee's approved industrial cost
recovery system as described in its submission pursuant to paragraph
4Bn) and (3) of these Guidelines fully complies with the Act,
EPA regulations concerning ICR and these Guidelines;
17
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(b) a determination that the grantee has an adequate accounting
system and other administrative procedures and systems, including waste
monitoring systems where these are required to effectively implement
the approved industrial cost recovery system.
Where deficiencies are identified, EPA will so advise the grantee
and recommend appropriate corrections. The purpose of these preliminary
audits is to identify deficiencies and seek their correction. When
the final construction audit occurs after the first full year of operation
of the industrial cost recovery system, or in some cases, after several
months of operation, the preliminary audit will take the form of the
regular audit described below.
(2) EPA will schedule audits of industrial cost recovery systems when
determined to be necessary and requested by the Regional Administrator.
Unrequested, random audits will also be made to assess general performance
of grantees and identify potential problem areas. These audits will
normally encompass the following:
(a) a determination of whether allocable industrial costs have
been properly computed, assessed and collected pursuant to the approved
industrial cost recovery system or approved revisions thereto:
(b) a determination of whether collected amounts have been
properly accounted for and have been deposited in accounts or invested
in obligations prescribed by 40 CFR 35.928-2, and a determination of
whether the interest earned on collected amounts has been fully and
properly accrued;
(c) a determination of whether the grantee has made all annual
submission and payments to EPA and whether these have been complete and
correct;
(d) a determination of the effectiveness of actions being taken
by the grantee to collect oroper amounts, if any, which have not been
paid by industrial users;
(e) a determination of the adequacy of wastewater monitoring and
reporting by the grantee and/or the industrial users, to the extent
that such monitoring is required by the approved industrial cost
recovery system or approved revisions thereto; and
(f) a determination of whether any and all uses of retained
funds have been approved by the Regional Administrator (or the State
agency when it has been certified to grant such approval), and have
been actually applied to eligible project costs.
18
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If there is any reason to suspect non-compliance with the approved
ICR system, Federal laws, EPA regulations, or these Guidelines, an
audit of the grantee's system will be made. Examples of non-compliance
are: inequitable proration of the ICR charges among industrial users,
failure to charge all ICR amounts, failure to account for and invest
collected and retained amounts, failure to pay the share due the
Federal Government, and use of the grantee's 80 percent portion of
retained amounts without the prior approval of the Regional Administrator.
G. Record Keeping
40 CFR 935.13(d) requires that the grantee maintain, for the
duration of the cost recovery period, such records as are necessary to
document compliance with the grant requirements. These will generally
include the following:
(1) documentation of the final grant amount;
(2) the originally approved industrial cost recovery system
and all documentation related thereto;
(3) all subsequent revisions to the industrial cost recovery
system and all documentation related thereto;
(4) a list of contributing industries and their wastewater loads
to the system;
(5) information on the total wastewater loading of the system;
(6) the grantee's notification to EPA of initiation of operation
of the industrial cost recovery system;
(7) all approval(s) of the use of retained funds;
(8) the record of the grantee's annual payments to EPA and
documentation related thereto;
(9) records relating to retention and investment of those
funds set aside for future expansion and reconstruction.
These materials are necessary for all audits and must be made
available to representatives of EPA or the State upon request.
19
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H. Penalties for Non-Compliance
Compliance with the approved system of industrial cost recovery is
a fundamental condition of the grant. If the grantee fails to
implement and maintain the approved system, the Regional Administrator
will take appropriate action, which may include (1) withholding of
grant funds for current projects, (2) determination of non-responsibility
for purposes of future grants, and (3) seeking a judicial remedy such
as a suit for recovery of funds already granted, criminal prosecution,
or other appropriate action.
20
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APPENDIX A
DESCRIPTION OF INDUSTRIAL COST RECOVERY SYSTEM
EPA Grant Identification Number
Name of Grantee:
Grantee's Legal Address:
Name of Facility (if applicable):
Brief Description of the Project:
(a) Total Design Capacity:
Flow =
BOD =
SS =
Other (Itemize) =
Total Initial Industrial Contribution:
Flow =
BOD =
SS =
Other (Itemize) =
(b) Total cost of construction of the treatment works based upon the
best available data or estimates including Step 1 and Step 2 costs,
and the total amount of construction grants to be received based
upon such estimates.
Total Cost $
as of (date)
Total grant funds
as of (date)
A-l
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(c) Furnish industrial user cost allocations similar to Table 1 and
Table 2 of Section 9 of these Guidelines (40 CFR 35.928-1(d),
40 CFR 35.925-12).
(d) Industrial Cost Recovery Period (40 CFR 35.905-7): Years
Initial date:
Useful life: Years (if different from ICR period)
Did the grant fund the construction of elements of the total treatment
works which will be placed in operation at different times? yes no
If "yes", attach a listing of the industrial cost recovery period
for each element so constructed and placed in operation.
(e) Cite the ordinances, authorities or contractual agreements which
establish the basis for the ICR system (40 CFR 35.928).
(f) Describe the method used for defining industrial users for the
purpose of allocating costs (40 CFR 35.905-8).
(g) Does the proposed ICR system make provision for an appeal procedure
in accordance with Section 5 of these Guidelines? yes no
Briefly describe the appeal procedure and cite legal authorities.
(h) Does the proposed ICR system make provision for adding new industrial
users to the system in accordance with Section 10 of these Guidelines?
yes no
(i) Were any grant costs excluded from the ICR system? yes no
If "yes", attach a description of the excluded portion and give the
basis for such exclusion (Guidelines Section 8).
(j) Were any industrial users excluded from the industrial cost recovery
system? yes no
If "yes", attach a list of the industrial users so excluded and the
basis for each such exclusion (40 CFR 35.905-8(e), Guidelines Section 8).
A-2
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(k) Has any portion of the treatment works' reserve capacity been
set aside for use by specific industrial users through formal
written agreements? yes no
Informal agreements? yes no
If "yes", attach a list of such agreements (formal and informal)
and the capacity reserved for each industrial user (40 CFR 35.928-1(g),
Guidelines Section 7).
(1) Will industrial users be required to begin paying ICR within one
year of the date of initiation of service of the grant-assisted
facility (40 CFR 35.928-1(c), Guidelines Section 16)? yes no
If "no", attach explanation.
(m) Will the proposed ICR system affect any ICR system developed under
a previous grant? yes no
If "yes", attach explanation.
(n) Describe the method to be used in classifying industries into major
and minor categories for monitoring purposes. Include, in the
description, the nature and level of monitoring to be required and
the manner in which monitoring will be conducted and reported.
Describe the method by which an industrial users ICR payment will
be adjusted with changes in wastewater characteristics (40 CFR 35.928-1(e),
Guidelines Section 11).
(o) Describe the method by which an industrial user's ICR payment
be adjusted if the treatment works is upgraded or expanded
in the future (40 CFR 35.928-1(f)).
(p) Describe proposed procedures for funds management and investment.
Prepared by:
Name (Typed)
Title (Title)
Telephone Number
(Signature)
(Date)
A-3
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APPENDIX B
OPINION OF LEGAL COUNSEL
I, , an Attorney-at-Law, authorized to practice law
in the State of , and employed as legal counsel for (the
grantee) have reviewed the industrial cost recovery (ICR) plans and
system proposed for implementation by the grantee, which has obtained a
Federal grant under Environmental Protection Agency (EPA) Grant Identification
Number pursuant to Title II of the Federal Water Pollution
Control Act Amendments of 1972 (Public Law 92-500) (the "Act"). A brief
description of the proposed ICR system and plans, is attached hereto
(Appendix A). I have reviewed Appendix A and its supporting documents,
and assuming that the engineering basis for the cost allocations is
correct, I am of the opinion that the grantee's ICR system as described
therein will meet the requirements of Section 204(b)(1)(B) of the Act,
will comply with EPA's rules and regulations, and will conform with
EPA1s ICR Guidelines. Furthermore, it is my opinion that the grantee
has the legal authority to implement the ICR system and plans, and to
fully enforce its provisions requiring ICR payments by industrial users.
Date: Name: (Typed)
Telephone: . (Signature)
Title: (Typed)
B-l
*U.S. Government Printing Office: 1976 -6 77-8 78/301 Region 8
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APPENDIX B
GREENSBORO LAND USE PLANS FOR CIBA-GIEGY SITE
-------
GITV OF (iUEENSBORO
NORTH C.AKOLINA
19 October 1977
OFFICE OF
THE CITY MANAGER
!«()B
Mr. Robert Cooper
Envirnomental Protection Agency,
Region IV
345 Courtland Street
Atlanta, Georgia 30308
Dear Mr. Cooper:
It is my understanding that you have had some questions
raised concerning the City's plans to purchase approximately
450 acres of property for the site of the proposed Metro
Waste Water Treatment Plant. It is also my understanding
that certain allegations have been made that the City proposes
to use the portion of this property not presently needed for
waste water treatment purposes for a landfill. This question
has been answered several times at public meetings.
Specifically, we have said that we do desire to control
the property in the vicinity of the Waste Water Treatment
facility so that private construction would not be made in
the immediate vicinity. It is obvious, in viewing our North
Buffalo and South Buffalo Treatment Facilities, that a mistake
was made in not doing the same thing at these two locations.
We have said publicly, and this letter is to confirm to
you, that we would be willing to make the following conditions
a part of the purchase of this land. The conditions would be
that for any portion of the property not being used for waste
water treatment purposes we would agree to:
1. Allow the present property owners to
lease the property back, at a nominal
fee, for a period of up to ten years
with the condition that the land be
used for agricultural purposes if that
is the purpose for which it is now used.
We would also propose that these leases
may be renewed at the end of ten years
by mutual agreement provided the same
owner is the lessee.
-------
Mr. Robert Cooper
Page 2
19 October 1977
2. In the event that the present owner does
not want to lease the land back, or at
the end of the lease period as outlined
above, the City would designate the land
for Park and/or Open Space purposes.
As I said this commitment has been made in several public
meetings and I don't believe there can be any misunderstanding
of the City's intent in this matter. Of course this commitment
was made in relation to the confluence site (Alternate 4 in the
preliminary EIS). The use to be made of fringe property at any
other site would have to be determined based on location, zon-
ing, accessability, and present use I can, however, assure
you that under no circumstances will the site be used for a
landfill.
If any additional information is needed, I would be very
glad to furnish it.
'City Manager
TZO/sc
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APPENDIX C
SOIL CONSERVATION SERVICE CRITERIA
FOR PRIME AGRICULTURAL LANDS
-------
42359
proposed rules
Th » setiori of tha FEDERAL REGISTER contain* notleas to tha public of wo propoaad issuance of rtilw and regulations. The purposa of
MeJ notice* la to giva IntarasUd partem an opportunity to participate in tha nil. making prior to tha adoption of tha final rules.
u
DEPARTMENT OF AGRICULTURE
Soil Conservation Service
I7CFR Part 657 ]
PRIME AND UNIQUE FARMLANDS
important Farmland inventory
AGENCY: - U.S. Department of-Agricul-
ture, 'Soil Conservation Service.
ACTION: Proposed rule
SUMMARY: TTiis rule prescribes gen-
eral guidelines'for'a-national program
of inventorying: prime and.unique farm-
land, as.well aa other farmlands of state-
wide or»local importance. It includes
specific criteria lor the definition of
prime farmlana.
OATE: Commwits must be received on
or befope October 7, 1977,
POP. FURTHER INFORMATION CON-
TACT:
R. M.. Da vis,. Administrator, Soil Con-
servation Service, U.S. Department of
Agriculture. P.O. Box. 2890, Washing-
ton, D.C. 20013.
¦SUPPLEMENTARY INFORMATION:
3n OcViber 15, 1975, the Soil Conserva-
'oti Service (SCS") issued Land Inven-
oi-y and Monitoring (LIM) Memoran-
ium-3, to establish SCS policy regarcl-
!Vi a national program for inventorying
^nportsmt farmlands. For purposes of
etermtning applicability,- "ihventory-
'>?" means to identify, locate, classify,
measure. LIM Memorandum-3 was
eveloped in response to growing con-
6m over the continuing reduction of
le nation's supply of prime and unique
lrmland and Initiated a standard pro-
cure for showing the kind, extent; and
cation of these Important farmlands.
Prime and unique farmlands are im-
¦>rtant to the Nation as the base of high
iality land that can provide present and
iure food and fiber supplies with the
Mt use of energy, capital, and labor and
th minimal environmental impact.
Prime farmland is the only category
the important farmland Inventory
ftt is defined, on the basis of national
-teria, These criteria are based, on soil,
»ter, and climatic factors which are
«>i!y available in soil surveys and other
itid resource Information. AppUca-
" of these criteria assure that the
'd3 classified as prime farmland will
similar criteria lb all parts of the
tion. This la essential to provide uni-
"silfcy of Interpretation and establish
*uis for National policy and program
"ba affecting those lands that have
•• be.il physical and chemical qualities
for the production -oi food, feed, forage,
fiber; and oilseed-crops. The definition
of prime farmland Is published here to
fulfill the requirements or section
701(20), Pub.- L. -9S-8T, and. for other
purposes..
Unique farmlands and larmiands -of
statewide importance are Identified by
representatives of the Governor's office,
agencies of the State .Government; and
others in cooperation with the SCS..
Farmlands of local Importance are iden-.
tifled if it has been determined by local
agencies that this information is needed..
LIM Memorandum-3 is hereby revised
to indicate new procedural responsible
Itlea^in making -and publishing inven-
tories^ of important, farmlands. These
new responsibilities provide SCS State
Conservationists additional opportuni-
ties and -flexibility to develop inventories
more rapidly. There-is no change in the
specific criteria for prime farmland, but
both the general definition and the spe-
cific criteria have been edited to--pro-
vide a more clearly understandable defi-
nition for lay people and technical spe-
cialists.
The SCS plans to' issue these regula-
tions to provide information on the im-
portant farmland inventory and to serve
as a standard reference for the defini-
tion and specific criteria for prime farm-
land. This 13 necessitated by the growing
number ol legislative and regulatory ref-
erences to the term "prime farmland"
and the need to provide a uniformly ac-
cepted definition.-
Concern for the continuing loss of
these lands to non-agricultural uses has
resulted in legislative and regulatory
efforts by different levels of Government
attempting to reduce-these losses. SCS
policy and programs support these ef-
forts in several ways. Making and peep -
ing current an Inventory of the Import-
ant farmlands is one such way. other.
SCS efforts Include special evaluation of
the impact of major Federal actions on
prime farmlands- (See 7 CFR 650.8.)
As other SCS policies or programs to
protect prime and unique farmlands are
developed, they will be published .ln this
part .
Interested persons-are invited to sub-
mit written comments, suggestions, data,
or arguments as they desire.. Comments
should be submitted to:
Administrator. Soil Conservation Service,
U.& Department of Agriculture.vR.O. Bo*
2860, Washington,. P.C. 20013,
Written comments received on or be-
fore October 7, X977, .-will be considered
before any-action Is taken on this pro-
posed rule.
, comments received before the closing
date will be made available for exami-
nation by interested persons.
Dated: August 18,1877.
Wiujaji M. Johnson,
Deputy Administrator for Tech-
nical Services, SoflOonserva-
tion Service.
(CatalogofJederal Domestic.-Assistance pro-
grama numbered 10.900 (Great Plaln»),lO.0Ol.
(Resource Conserratloa and Development);
10.903 (Soil and -Water Conservation). 10.904
("Watershed- Protection and Flood Preven-
tion v..and 10.900 (Plant Materials).)
PART 657—PRIME AND UNIQUE-
FARMLANDS
Subpart-A—Important Farmland Inventory
Sec,
657,1 Purpose. -
667.3 Policy.
087.3 Applicability.
657.1 SCS Responsibilities.
657.5 Identification ot vmvort&nt larm-
iands.
AuTHoBirr:. 18 TJS.C. 59Cwv-f, q; 7 CFS
2.63; Pub. L, 95-87; 42 U.3.C. 4321 et seq.
Subpart A—Imoortant Farmland Inventory
§657.1 Purpose.
The Soil Conservation Service is coij-
cerned about any action that tends to
impair the productive capacity of Amer-
ican agriculture. The Nation needs to
know the extent and location of the best
land for producing food, feed, fiber, for-
age, and oilseed crops. Farmlands, in ad-
dition to prime and unique farmlands,
that are of statewide and local impor-
tance for producing, these crops need to
be identified.
§657.2 Policy.
It is SCS policy to make and keep cur-
rent an inventory of the prime farmland
and unique farmland of the Nation. This
Inventory Is to be carried out In coopera-
tion with other Interested agencies at
the national. State, and local levels of
Government. The objective of the inven-
tory Is to identify the extent and location
of important rural lands needed to pro-
duce food, feed, fiber, forage/and oilseed
crops,
g 657.3 Applicability.
Inventories made under this memoran-
dum do not-constitute aideaignation of
any land area to a specific land use. Such,
designations are the responsibility of ap-
propriate local and State officials:
g <574 SCS ReajKHwHjOittea.
(a) State Conservationists. Each State
Conservationist is to:
«Dt*AL UOtSUt, VQl^4VNO 163-TUISDAV; AUCUjrM.'PIWX
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42360
PROPOSED RULES
(1) Provide leadership for Inventories
of Important farmlands for the State,
county, or other subdivision of the State.
Each Is to work with appropriate agen-
cies of State Government and others to
establish priorities for making these In-
ventories.
(2) Identify the soil mapping units
within the State that qualify as prime
farmland. Each is to invite representa-
tives of the Governor's Office,.agencies-of
the . State Government, and others to
Identify farmlands of statewide impor-
tance and unique farmlands that are to
be inventoried within the framework, of
this memorandum.
(3) Prepare a statewide list of
(i) Soil mapping units that meet the
criteria for prime farmland.
(il> Soil mapping units that are farm-
lands of statewide importance if the cri-
teria used were baaed on soil information.
(ill) Specific high-value food and fiber
crops that are grown and, when com-
bined with other favorable factors, qual-
ify lands to meet the criteria for unique
farmlands! Copies are to be furnished to
Field Offices and to the Technical Service
Centers (TSC's). (See- 7 CFR * 600.3,
600.0.)
(4) Coordinate soil mapping units that
qualify as prime farmlands with adjacent
States, including the States responsible
for the soil series. Since.farmlands of
statewide Importance and unique farm-
lands are designated by others at. the
State level, the soil mapping units and
areas identified need not be coordinated
among States.
(3) Instruct .District Conservationists
to arrange local review of lands identi-
fied as prime,. unique, and additional
farmlands of statewide Importance by
Conservation Districts and representa-
tives of local agencies. This review is to
determine il additional farmland should
be identified to meet local decisionmak-
ing needs.
(6) Make and publish each Important
farmland inventory on a base map of
national map accuracy at an Interme-
diate scale- of 1:50,000 or 1:100,000.
State Conservationists who need base
maps of other scales are to submit their
requests with, justification to the Ad-
ministrator for consideration.
(b> Technical Service Centers. Field
Representatives (see 7 CFR 600.2(f)) are
to provide requested technical assist-
ance to State Conservationists in Inven-
torying prima- and unique farmlands.
This includes reviewing, statewide, lists
of soil mapping units that meet the cri-
.terja for prime farmlands and resolving
coordination problems that may occur
among States for specific soil series .or
soil mapping units,
(c) National OMce,- The Assistant
Administrator for Field Services (see 7;
CPS 600.2) is; to provide national lead-
ership to preparing guidelines for inven-
torying prime farmlands and for na-
tional statistics and reports of prime
farmlands.
§ 657.5. Identification of important farm-
lands.
(a) Prime farmland—(1) General.
Prime farmland is land that has the best
combination of physical and chemical
characteristics for producing food, feed,
forage, fiber, and oilseed crops, and also
available for these uses (the-land could,
be cropland, pastureland, rangeland,
forest land, or other land, but not urban
built-up land or water). It has the soil
quality, growing season, and moisture"
supply needed to economically produce
sustained high yields of crops when
treated, and managed, including water
management, according to modern farm-
ing, methods. In general, prime farm-
lands have an adequate and dependable
moisture supply from precipitation., or
irrigation, a favorable temperature and
growing season, acceptable acidity or al-
kalinity, acceptable salt and sodium
content, and few or no rocks. They are
permeable to water and air. Prime farm-
lands , are not excessively erodible or
saturated with water for a long period
of-time,-and they either do, not flood or
are protected from flooding. Examples of
soils that qualify as prime farmland are
Palouse silt ,'oam, 0 to 7 percent slopes;
Brooks ton- stlty clay loam, drained;, and
Tama silty clay loam, 0 to- 5 percent
slopes.
(2; Specific criterial. Prime farm-
lands meet the following criterial. Terms
used in this section are defined in USDA
publications: Soil Taxonomy, Agricul-
ture Handbook 436: Soil Survey Manual,
Agriculture Handbook 18; Rainfall-Ero-
sion .Losses fropi Cropland, Agriculture
Handbook 282; and Saline and Alkali
Soils,'Agriculture Handbook 60.
(I) The soils have: (A) Aquic, udic,
ustic, or xeric moisture regimes and
sufficient available water capacity within
a depth of 40 inches (1 meter), or in the
root zone If the root zone is less than 40
baches deep to produce the commonly
grown crops in 7 or more years out of 10;
or;
(B) iXeric or ustic moisture regimes in
which the available water capacity is
limited, but the area has developed irri-
gation water supply that is dependable
(a dependable water supply is one in
which enough water is available for irri-
gation in- 8 out of 10 years for the crops
commonly grown) and of adequate qual-
ity; or,
(C) Arldic or torric moisture-regimes
and the area has a developed Irrigation
water supply that is dependable and of
adequate quality; and,
(II) The soils have a temperature re-
gime that is frigid, mesic, thermic, or
hyperthermic (pergelic and cryic regimes
are excluded). These are soils that, at a
depth of 20 Inches (50 cm)have a mean
annual temperature higher than 32° F
(0• C). In addition, the mean summer
temperature at this depth in soils with
an O horizon is higher than 47° F. (8° C);
in soils that have no O horizon, the mean
summer temperature 1s higher than 59? P
(15° C) i and,
(ill) -The soils have a pH between 4.5
and 8.4 in all horizons within a depth of
40 inches (1 meter) or in the root zone
if the root zone is less than 40 inches
deep; and,
(iv) The soils either have no water
table or have a water table that is main-
tained at a sufficient depth during the
cropping season to allow food, feed, fiber,
forage, and oilseed crops common to the
area to be grown; and,
(v) The soils can be managed so that,
in all horizons within a depth of 40
inches (1 meter) or in the root zone if the
root zone Is less than 40 inches deep,
during part of. each year the conductivity
of the saturation extract is less than 4
mmhos/cm and the exchangeable so-
dium percentage. (ESP) is less than 15;
and,
(vi) xns sous, are not flooded fre-
quently during the growing season (less
often than, once in 2 years); and,
(vil) The product of K (erodibility fac-
tor) x percent slope Is less than 2.0, and
the product of I (soil erodibility) X C
(climatic factor) does- not exceed 60:
and,
(viii) The soils have a permeability
rate of at least 0.06 inch (0.15 era) per
hour in the upper 20 inches (50 cm) and
the mean annual soil temperature at a
depth of 20 inches (50 cm) Is less than
59° F (15° C); the permeability rate Is
not a limiting factor if the mean annual
soil temperature is 59° F (15° C). or
higher; and,
¦ (ix) Less than 10 percent of the sur-
face layer (upper 6 inches) in these soils
consists of rock fragments coarser than 3
inches (7.6 cm).
(b) Unique, farmland—(1) General.
Unique farmland is land other • than
prime farmland that is used for the pro-
duction of specific high value food and
fiber crops. It has the special combina-
tion of soil quality, location, growing sea-
son, and moisture supply needed to eco-
nomically produce sustained high quality
and/or high yields of a specific crop
when treated and managed according to
modern farming methods. Examples of
such crops are citrus, treenuts, olives-,
cranberries, fruit, and vegetables.
(2) Specific characteristics of unique
farmland, (i) Is used for a specific high-
value food or fiber crop.
(ii) Has a moisture supply that is ade-
quate for the specific crop. The. supply
is from stored moisture, precipitation, or
a developed Irrigation systems
(iii) Combines favorable factors of
soil quality, growing season, temperas
ture, humidity, air drainage, elevation;
aspect, or other conditions, such as near-
ness to market, that favor the growth.of
a specific food or fiber crop.
. (c) Additional farmland of Statewide
importance; This is land, in addition to
prime and unique farmlands, that is of
statewide importance for the production
of food, feed, fiber, forage, and oilseed
crops. Criteria for defining and delineat-
ing this land are to be determined by the
appropriate State agency or agencies.
Generally, additional farmlands of state-
fCDCRAI REGISTER, VOL *2, NO. 163^—TUESDAY,' AUGUST 23, 1977
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PROPOSED RULES
42361
wide importance Include those that are
nearly prime farmland and that eco-
nomically produce high yields of crops
when treated and managed according to
modern farming methods. Some may
produce as high a yield as prime farm-
lands if conditions are favorable. In some
States, additional farmlands of state-
wide importance may include tracts of
land that have been designated for agri-
culture by State law.-
(d) Additional farmland of local im-
portance. tn some • local areas there is
concern for certain additional farmlands
for the production of food, feed, fiber,
forage, and oilseed crops, even though
tiies* lands are not identified as having
national or statewide importance. Where
appropriate, these lands are to be identi-
fied by the local agency or agencies con-
cerned. In places, additional farmlands
of local importance may include tracts
of land that have been- designated for
agriculture by local ordinance.
IFB Doc.77-24189 Piled ^-22-77:8:43 &mj
FEDERAL ENERGY
ADMINISTRATION
£'lO*!FR Part 430 ]
ENERGY CONSERVATION PROGRAM FOR
APPLIANCES
Proposed Energy Efficiency Improvement
Target for Home Heating Equipment, Not
Including Furnac«s; Further Opportunity
for Comment
AGENCY!* Federal Energy Administra-
tion.
ACTION: Notice of further opportunity
for public comment.
SUMMARY: The Federal Energy Ad-
ministration gives notice of an extension
of the deadline for submission of written
comments concerning the proposed
energy efficiency improvement target Tor
home heating equipment, not including
iurnacea, which appeared, at 38648 of the
July IS, Federal Register. The new
deadline ts October 25, 1977. A second,
public hearing 'will be held concerning
this proposed target, at the time of the
hearing on test procedures for vented
home heating equipment, -which will .be,
proposed shortly.
DATES: Comments by October 25, 1977:
hearing to be held on .November 2, 1977.
PGR FURTHER INFORMATION CON-
TACT:
James A. Smith, office 01 conserva-
tion, Room 307—Old Post Office Build-
ing,, 12th & Pennsylvania Ave., N.W.,
Washington, DC. 20461, (202) 566-
4*35.
William J. Denmson, or. Laurence J.
Tiyman,-Office of, the General Counsel,
Room *7348—Federal Building, 12th &
Pennsylvania Ave., N.W.; Washington,
D.C. 20481, ,(20a> 566-9750.
i>UPPLEMSNTARY - INFORMATION:
Tho Federal Energy Administration
previously r proposed an energy
¦JUIc'ency Improvement target for home
heating. «iulpiaenfc*jnot including fur-
naces, and scheduled a public hearing
concerning this target, to be held on
August 19, 1977 (42 PR 36648. July 15,
1977). FEA Intends to publish shortly
proposed test procedures for vented home
heating equipment. Publication of- pro-
posed test procedures for other types of
appliances has preceded the proposal of
targets for those appliances. PEA be-
lieves that reference to the test proce-
dures for vented home heating equip-,
ment would permit more effective public,
comment on the proposed energy effi-
ciency improvement target for home
heating equipment. Therefore. PEA has
extended the period for written comment
concerning the target to October. 25*
-1977. Comments-should continue to be
sent to the address specified in the July
15,1977, Federal Register notice. A pub-
lic hearing concerning both the proposed
test procedures and the proposed: target'
will be held on November 2, 1977;- The!
exact time and place of this hearing, and
procedures for requesting an opportuni-
ty to speak, will be announced when the
test procedures for vented home heating
equipment are proposed. The August 19,
1977; hearing will be held as scheduled.
Issued tn Washington, D.C. August
17,1977.
Eric J. Fygi,
Acting General Counsel,
FederalJSnerair Administration.
[PR Doc.77-24269filed &-22-77;8:45 ami
DEPARTMENT OF HEALTH,
EDUCATION, AND WELFARE
Food and Drug Administration
[ 21 CFR Parts 431 and 514 ]
[Docket No. 77N-0U7]
CERTIFICATION OF ANTIBIOTIC DRUGS
Revised Requirements for Submission of
Requests for Batch Certification
Correction
In FR Doc. 77-20306, appearing at page
36492 in the Issue of Friday, July 15,
1977, make the following changes:
1. Hie second line of the fourth full!
paragraph on page 36493 should read,
"(c) (4) to require submission , of the
date".
2. The fourth complete word in the-
ninth line of the fifth full paragraph on
pag* 36493 should read "test".
3. The eleventh to last line of the fifth
full paragraph on page 36493 should be
omitted:"
PENSION BENEFIT GUARANTY
CORPORATION
[ 29 CFR Part 2610 ]
VALUATION OF PLAN BENEFITS
Interim Regulation; Proposed Amendment
AGENCY:.-Pension Benefit.' Guaranty
Corporation.
ACTION: Proposed Amendment to the
Interim Regulation.
SUMMARY: This proposed Ttfle pre-
scribes the rates and factors.to lie used
.for valuing plan benefits under Title IV
of the Employee Retirement Income Se-
-curity Act of 1974 for plans that ter-
minated on or after March 1, 1977, but
before June 1, 1977. It is necessary be-
cause the PBGC has not yet published
valuation rates and factors for plans
th$t terminated during the period cov-
ered, by the proposed amendment. The:
proposed amendment's effect is to, pro-
vide notice of the rates and factors that
wlil be used to value benefits provided
under such plans.
DATES: Comments should be submit-
ted on or before September 22,1977.
ADDRESSES: Comments should be sent
to:. Office of the General Counsel, Pen-
sion Benefit Guaranty • Corporation,
Suite 7200, 2030 K Street NW., Wash-
ington, D.C. 20006. Copies of written
comments will be available for exami-
nation, in: Office of Communications,
Pension Benefit Guaranty Corporation,
Suite 7100, 2020 K Street NW., Wash-
ington; D.C.. between the hours of .9
a.m. and 4 pan.
FOR' "FURTHER INFORMATION CON-
TACT:
William E. Seals, Staff Attorney, Office
of the General Counsel, Pension Beiie-
"fit . Guaranty Corporation, 2020 K
Street NW., Washington, D.C. 20006
'202-254-4895
SUPPLEMENTARY INFORMATION:
Oh November 3, 1976 the Pension
Benefit Guaranty Corporation .(the
"PBGC") issued an interim regulation
.establishing the methods for valuing plan
benefits under Title IV of the Employee
Retirement Income Security Act of 1974
(the -"Act"). <41 FR 48484 et seq.). The
regulation included an appendix con-
taining rates and factors to be used to
value benefits in plans that terminated
on or-after September 2,1974, but before
October 1,1975. Subsequently, the PBGC
adopted additional rates and factors for
valuing benefits tn plans that termi-
nated on or after October 1, 1975, but
before December 1, 197a <42 FR 2678
et.seq., .42 PR 32777 et seq.). On June 8,
1977, .The PBGC published for comment
in the Federal Rioisteh additional rates
and factors for valuing-beneflts in plans
that, terminate on or after December 1,
1976, but before March 1, 1977 (42 FR
29318 et
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APPENDIX D
CIVIL RIGHTS RESOLUTION
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE-.
SUBJECT:
FROM:
TO:
November 17, 1977
Final Environmental Impact Statement on the
Greensboro 2 01 Plan
Matthew Robbins
Office of Civil Rights ^
John Hagan, Chief
Environmental Impact Statement Branch
This office has received several complaints concerning
alleged past discriminatory housing practices in the
Greensboro, North Carolina area near the South and North
Buffalo Creek wastewater treatment plants. The complaints
said that since the alternatives in the Draft Environmental
Impact Statement ("Draft EIS") on the Greensboro 201 Plan
would allow federal money to be made available for improve-
ments to the South Buffalo and North Buffalo facilities,
this office should review the allegations pursuant to its
responsibilities under Title VI of the Civil Rights Act
of 1964. Such a review was undertaken by this office.
The review included an on-site inspection of
both treatment facilities and their surrounding areas,
meetings with the National Association for the Advancement
of Colored People and Greensboro Citizens Association
representatives, consideration of the testimony and record
from the September 1, 1977 public hearing, a review of the
correspondence constituting the complaints, and a review
of the Draft EIS.
Our preliminary review indicated that the South Buffalo
Creek facility is located in a densely-populated minority
area that has had a long history of racial isolation.
It is located in 1970 Census Tract 128.02 and has a 94.9%
black population as compared to a city average of 2 8.2%
black population. According to the statements of minority
representatives, the Draft EIS and the hearing testimony,
the plant is old, inadequate, poorly-operated, and malodorous.
On the other hand, the North Buffalo Creek plant is
located in an area that contains less than the average
population of minorities. The facility is located in
1970 Census Tract 101, with the exception of one tank
which is in Tract 119.02. Tract 101 is comprised of
approximately 16.9% black population with the racial
characteristics of Tract 119.02 being 4.9% black within
the city limits and 12.4% black within the total tract.
E PA For," ) 320-6 (Rev. 3 7A1
-------
- 2 -
Adjacent to the facility is 1970 Census Tract 127.02 with
a 50.8% black population. The census statistics as well
as the history of these three tracts exhibit a much better
racial balance than southeastern Greensboro. There was
no significant evidence presented at the public hearing or
during the public involvement period on the Draft EIS to
indicate that the North Buffalo facility was being operated
to the detriment of the residential community.
Consequently, if the Final EIS recommends that federal
money be offered to upgrade or expand the South Buffalo
facility, it may be necessary for this office to recommend
forwarding the allegations of discrimination to Headquarters
for further consideration.
Our review did not find sufficient evidence to warrant
further consideration of the discriminatory allegations
at the North Buffalo plant.
-------
APPENDIX E
LAND USE RESOLUTION
-------
APPENDIX E
LAND USE RESOLUTION
RESOLUTION OF COMMITMENT TO IMPLEMENT SOUND LAND USE
POLICIES TO ENHANCE THE ENVIRONMENT AND TO ENSURE
COORDINATED DEVELOPMENT FOR THE CITY OF GREENSBORO
AND GUILFORD COUNTY
WHEREAS, the City of Greensboro is developing a comprehensive
plan supported by funding from the United States Department of
Housing and Urban Development to establish land use, transportation,
and public facilities needs and plans throughout metropolitan
Greensboro;
WHEREAS, the City of Greensboro has concluded a Facilities
Plan in conjunction with the United States Environmental Protection
Agency and the State of North Carolina Department of Natural
and Environmental Resources to determine wastewater treatment
needs throughout metropolitan Greensboro;
WHEREAS, said Facilities Plan and the recommendations contained
therein are currently undergoing a review pursuant to the National
Environmental Policy Act of 1969 and the North Carolina Environmental
Policy Act of 1971;
WHEREAS, the United States Environmental Protection Agency
and the North Carolina Department of Natural and Environmental
Resources issued a Draft EIS on July 18, 1977 and conducted Public
Hearings on same September 1, 1977, jointly proposing funding and
construction of a Metro Wastewater Treatment'Facility to be located
at a point 26,000 feet downstream of South Buffalo Plant ("Alter-
native No. 3");
WHEREAS, the proposed construction of the Metro Wastewater
Treatment Facility has been found sufficient under Federal and
State Environmental Laws and is proposed for construction in
accordance with certain Mitigative Measures set forth in the
aforesaid Draft EIS;
WHEREAS, the City of Greensboro prefers construction of the
Metro Wastewater Treatment Facility at the confluence of the
North Buffalo and South Buffalo Creeks ("Alternative Mo. 4")?
-------
WHEREAS, both the City and Guilford County recognize the need
to assure and provide for a comprehensive, controlled, orderly,
coordinated and environmentally sound system of community develop-
ment throughout the regional area;
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE
CITY OF GREENSBORO:
1. That the land use plan for Greensboro and Guilford
County shall be jointly reviewed and updated from time to time
with Guilford County for the purpose, goal and objective of
continuing an orderly and sound comprehensive land use plan con-
sistent with the enhancement of the quality of life and environmental
well-being of the citizens of Greensboro and Guilford County.
2. That the Mitigative Measures set forth in the State/
Federal Draft EIS are found acceptable and will be implemented,
provided that either Alternative No. 3 or No. 4 is constructed
with Federal funds.
3'. That the Guilford County land use regulations, including
zoning and subdivision regulations, applicable to all areas of
unincorporated Guilford County within the Facilities Planning
Area are found acceptable and, to the extent allowed by law, will
be implemented and enforced provided that either Alternative No. 3
or No. 4 is constructed with Federal funds.
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