NC0043532_Speculative Limits_20130517

NPDES DOCU BENT !;CANNING COVER :SHEET
NPDES Permit:
NC0043532
West Stanly / Oakboro WWTP
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
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Speculative Limits `''
Environmental Assessment (EA)
Document Date:
May 17, 2013
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North Carolina Department of Environment and Natural Resources
Division of Water Quality
Pat McCrory Charles Wakild, P. E. John E. Skvarla, III
Governor Director Secretary
The Honorable Joyce C. Little, Mayor
The Town of Oakboro
P.O. Box 610
Oakboro, North Carolina 28129
May 17, 2013
Subject: Speculative Effluent Limits
Oakboro WWTP
Permit No. NC0043532
Stanly County
Yadkin River Basin
Dear Mayor Little:
This letter confirms the speculative effluent limits provided by the Division in October
2005 for expanded wasteflows of 1.2 MGD and 3.0 MGD for the Oakboro WWTP are
still valid. (See attached) The Division received an email request for confirmation of
these limits on February 5, 2013 from the Wooten Company on your behalf. A review
of submitted data for, 2012 indicates that the Oakboro WWTP is currently at 40% of
current design capacity of 0.900 MGD. Please be advised that the Division requires that
flow justification must be provided and approved for expansion beyond design
capacity.
Receiving Stream. The Rocky River is currently listed as an impaired waterbody on
the 2012 North Carolina 303(d) Impaired Waters List. The problem parameters
listed are turbidity, copper and zinc.
The Town should be advised that as part of the implementation of the NC Statewide
Mercury TMDL (Total maximum daily load) approved by USEPA in January 2013, a
mercury minimization plan may be required to be developed and annual mercury
monitoring or effluent limitations may be included in the permit.
, 5 13° felititit-
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 i - r I
Location: 512 N. Salisbury St Raleigh, North Carolina 27604 ► "
Phone: [phone] FAX: [phone]
Internet: www.ncwateraualitv.orq
Noe Carolina
�tura!ly
An Equal Opportunity 1 Affirmative Action Employer

Mayor Joyce Little
May 17, 2013
Page 2 of 2
Should you have any questions about these speculative limits or NPDES permitting
requirements, please feel free to contact Jackie Nowell at [phone] or Tom
Belnick at [phone].
Respectfully,
om Belnick
Supervisor, NPDES Complex Permitting Unit
Attachments
Hardcopy:
Central Files
NPDES Permit File
Electronic Copy:
NC WRC, Inland Fisheries, [e-mail]
US Fish and Wildlife Service, [e-mail]
DWQ/SWPS Mooresville Regional Office
DWQ/SEPA, Hannah Headrick
DWQ/Modeling TMDL Unit, Kathy Stecker
DWQ/Basinwide Planning, Jeff Manning
NPDES Server>Specs

Michael F. Easley
Governor--r` "
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
February 10, 2005
The Honorable Joyce Little, Mayor
Town of Oakboro
P.O.Box610•
Oakboro, North Carolina 28129
Subject: Speculative Limits for Oakboro WWTP
NPDES Permit No. NC0043532
Stanly County
Dear Mayor Little:
This letter is in response to the request for speculative effluent limits for the expanded Oakboro
WWTP. Wastewater flows of 1.2 and 3.0 MGD were targeted for discharge from Outfall 002 into the
Rocky River in the Yadkin -Pee Dee River Basin.
Please be advised that response to this request does not guarantee that the Division will issue an
NPDES permit to discharge treated wastewater into these receiving waters. The Town of Oakboro will
be required to complete an Engineering Alternatives Analysis (EAA) that must be submitted with the
application for the NPDES permit. The EAA should contain a clear and strong justification for the
expanded facility and an analysis of potential alternatives, which should include a thorough evaluation
of non -discharge alternatives. Nondischarge alternatives, such as spray irrigation, water conservation, or
connection to a regional treatment and disposal system, are considered to be environmentally preferable
to a surface water discharge. In accordance with the North Carolina. General. Statutes, the most
practicable waste treatment and disposal alternative with the least adverse impact on the environment is
required to be implemented. (A copy of the EAA guidance is attached with this letter).
This segment of Rocky River has a stream classification of C. The best usage of these waters is
aquatic life propagation and maintenance of biological integrity (including fishing and fish), wildlife,
secondary recreation, and agriculture. Using available information, the discharge point has an estimated
drainage area of 965 square miles, with an average flow of 920 cfs, a summer 7Q10 of 29 cfs and a
winter 7Q10 of 51 cfs. Please be advised that these are historical flows, however it is preferable that the
Town of Oakboro request updated flow estimations from the United States Geological Survey (USGS)
to ensure accuracy. You may contact J. Curtis Weaver of USGS at 919-571-4043 concerning your
request.
The tentative effluent limits for oxygen -consuming constituents for the Oakboro WWTP
. discharge at the flows of 1.2 and 3.0 MGD are included on the attached effluent sheets. The speculative
limits are based on the results of a QUAL2E model application on the Rocky River and Mallard Creek
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
. ntaanei..b2&eor.state.nc.us _ ._.....____—DENELCustomer Service Center:-1 800-623=7748 --- -- --- - ------ ---

in the Yadkin River Basin. It is recommended that any new or expanding discharge in the lower
watersheds of the Rocky River should receive a total ultimate BOD limit of 32 mg/1 or less, equivalent
to 10 mg/1 BOD5 and 4 mg/1 NH3 for typical domestic discharges. This level of treatment will protect
the dissolved oxygen (DO) standard as well as preventing any one discharge from exhausting 100% of
the available assimilative capacity of the river. Please be advised that by the time of Oakboro's request
for expansion to 3.0 MGD, the Division may have made improvements to the model, and more stringent
limits than 10 mg/1 BOD5 and 4 mg/1 NH3 may apply. Should the Town ultimately decide to expand
above 1.2 MGD ( and flows above 1.2 MGD are justified), please contact this office prior to proceeding
forward with the EAA. Also, the Town should be aware that expansions greater than 0.5 MGD will
require an environmental assessment (EA).
The Division of Water Quality is requiring chlorine limits for all new or expanding dischargers
proposing the use of chlorine for disinfection. The process of chlorination/dechlorination or an alternate
form of disinfection, such as ultraviolet radiation, should allow the facility to comply with this
requirement. Additionally, upon formal permit application, if there are industrial wastewater
contributors to your plant, an evaluation of limits and monitoring requirements for metals and other
toxicants will be done.
Final NPDES effluent limitations will be determined if a permit application is submitted
to the Division. If there are any additional questions concerning this matter, please feel free to
contact Jackie Nowell of my staff at [phone] ext. 512.
Respectfully,
Susan A. Wilson, Acting Supervisor
NPDES Western Program
Attachments
cc: Larry Branch, Town of Oakboro P.O. Box 610 Oakboro NC 28219
Allen Wahab, The Wooten Company 120 North Boylan Avenue Raleigh NC 27603-1423
Mooresville Regional Office/Rex Gleason
MichelleWoolfolk/Modeling/TMDL Unit
Bobby Blowe, Construction Grants
Central Files
NPDES Permit File

A. SPECULATIVE EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS -
OAKBORO WWTP at 1.2 MGD
. During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge from outfall 002 (Rocky River). Such discharges shall be
limited and monitored by the Permittee as specified below:
EFFLUENT .
CHARACTERISTICS
LIMITS
MONITORING REQUhREMENTS
Monthly
Average
Weekly
Average
- Daily
Maximum
' Measurement
Frequency
Sample
Type
Sample Location.'
Flow
1.2 MGD
Continuous
Recording
Influent or Effluent
BOD, 5-day, 20°C2
10.0 mg/L
15.0 mg/L
3/Week
Composite
Influent, Effluent
Total Suspended Residue 2
30.0 mg/L
45.0 mg/L
3/Week •
Composite
Influent, Effluent
NH3 as N
4.0 mg/L
12.0 mg/L
3/Week
Composite
Effluent
Fecal Coliform •
(geometric mean)
200 / 100 ml
400 / 100 ml
-
3/Week
Grab
Effluent
Dissolved 0xygen3
3/Week
Grab
Effluent, Upstream,
Downstream
pH4
•
•
3/Week
Grab
Effluent
Total Residual Chlorine5
28 pg/L
3/Week
Grab
Effluent
Total Nitrogen
(NO2+NO3+TKN)
Monthly
Composite
Effluent
Total Phosphorus .
Monthly
Composite
Effluent
Temperature, °C
3/Week
Grab
Effluent , Upstream,
Downstream
Chronic Toxicity
Quarterly
Composite
. Effluent
Notes:
1. Influent, Effluent, Upstream, Downstream
•2. The monthly average effluent BOD5 and Total Suspended Residue concentrations shall not exceed 15% of the
respective influent value (85% removal).
3. The daily average effluent dissolved oxygen concentration shall not be less than 6.0 mg/L.
4. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
5. Monitoring requirement and limit applies only if chlorine is added for disinfection.
6. Chronic Toxicity (Ceriodaphnia) P/F at 6%; Months to be determined
There shall be no discharge of floating solids or visible foam in other than trace

Engineering Alternatives Analysis (EAA) Guidance Document
North Carolina Division of Water Quality / NPDES Unit
NOTE: The N.C. Division of Water Quality (DWQ) will not accept an NPDES application for a new or
expanding wastewater treatment plant discharge unless all the required application requirements are
submitted. A complete NPDES application will include the following items:
NPDES Application Form (in triplicate)
Application Fee
Engineering Alternatives Analysis (in triplicate)
Local Government Review Form (non -municipals only)
Failure to submit all of the required information will result in return of the incomplete package. If you have
any questions about these requirements, contact the NPDES Unit staff at 919-807-6300. Application forms,
applicable fees, and guidance documents are available on the NPDES website at
http://portal.ncdenr.org/web/wq/swp/ps/npdes. Completed applications should be mailed to:
NCDENR/DWQ/NPDES Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617.
Background
The NPDES permit program was enacted in 1972 as part of the Clean Water Act. The original goal of the program
was to eliminate all point source discharges to surface waters by 1985. Although this goal was not achieved, the
NPDES program continues to strive toward it. In that light, an Engineering Alternatives Analysis (EAA) is
required with any NPDES application for a new or expanding wastewater treatment plant discharge, in
accordance with 15A NCAC 2H.0105(c)(2). In order for an NPDES application to be approved, the EAA must
provide complete justification for a direct discharge to surface water alternative, and demonstrate that direct discharge
is the most environmentally sound alternative selected from all reasonably cost-effective options [per 15A NCAC
2H.0105(c)(2)].
The purpose of this EAA Guidance Document is to provide guidance to the regulated community for the evaluation of
wastewater disposal alternatives. The impetus behind this comprehensive guidance was based on the following 1) a
majority of new NPDES applications were being returned as incomplete due to inadequate EAA submissions; and 2) a
few recent court cases resulted in unfavorable rulings for the NPDES discharger due in part to inadequate EAAs.
DWQ most frequently returns EAAs as incomplete due to inadequate flow justification, inadequate alternatives
evaluations, and/or lack of documentation/references used to design and cost alternatives.
Please note that this guidance document is designed primarily for domestic wastewater discharges. For other proposed
discharges such as water treatment plant discharges from ion exchange and reverse osmosis units, some alternative
disposal options may not be technologically feasible. Within this guidance document, we have attempted to point out
where such technological limitations may exist. You are urged to review NPDES permitting guidance documents on
the NPDES website, which discuss some of the limited disposal options for some discharges.
Please note that if a proposed municipal expansion is subject to SEPA Environmental Assessment
(EA)/Environmental Impact Statement (EIS) requirements, the EAA requirements should be incorporated into the
SEPA document. In addition, the NPDES Unit cannot accept an application for a new/expanding NPDES discharge
until departmental review of the SEPA document is complete and a Finding of No Significant Impact (FONSI) has
been submitted to the State Clearinghouse for circulation.
The following step-by-step outline should be used for the preparation of all EAA submissions. If an EAA submission
lacks any of these basic elements, the NPDES application will be returned as incomplete.
EAA Guidance Document Version: June 23, 2005
Page 1 of 8

STEP 1. Determine if the proposed discharge will be allowed
Before beginning any engineering evaluation of alternatives, you must first determine if the proposed wastewater
discharge will be allowed. Otherwise, time and money may be spent needlessly for an EAA preparation that will
ultimately be rejected on the basis of existing water quality restrictions. There are several potential restrictions to a
wastewater discharge to surface waters, including.
• Zero flow stream restrictions [15A NCAC 2B.0206(d)(2)] apply to oxygen -consuming waste in zero -flow
streams. In order to determine streamflow at the proposed discharge location, contact the U.S.
Geological Survey at 919-571-4000.
• Receiving stream classification restrictions [e.g., ORW, WS, SA, NSW, and HQ lass waters have various
discharge restrictions or require stricter treatment standards]. Stream dassifications are available on the
DWQ website and from the DWQ Standards & Classifications Unit at 919-807-6300, while wastewater
discharge restrictions for various stream classifications are presented in state regulations [ 15A NCAC
2B.0200].
• Basinwide Water Quality Plans. These basin -specific plans list NPDES permitting strategies that may
limit wastewater discharges to particular streams within the basin due to lack of stream assimilative
capacity, etc. Basin plans are available on the DWQ website, or you may contact the DWQ Basinwide
Planning Unit at 919-807-6300.
• Impaired waters andTMDLs. Certain waterbodies listed as impaired on the 303(d) list and/or subject to
impending TMDLs may have wastewater discharge restrictions. The list of 303(d) impaired waters is
located on the DWQ website, or you may contact the DWQ Modeling/TMDL Unit at 919-807-6300.
• Presence of Endangered Species. If endangered species are present in the proposed discharge location,
there may be wastewater discharge restrictions. Endangered species information may be included in the
Basinwide Water Quality Plan, or you may contact the U.S. Fish and Wildlife Service (919-856-4520),
N.C. Wildlife Resources Commission (919-733-3633), or the N.C. Natural Heritage Program (919-733-
7701).
Municipal applicants.
As a public service, the NPDES Unit will evaluate whether a proposed municipal discharge is considered allowable.
The municipality needs to initiate this review by submitting a letter request for Speculative Effluent Limits to the
NPDES Unit. If the proposed discharge appears to be allowable, the NPDES Unit will prepare speculative effluent
limits for a maximum of 2 flows and 2 discharge locations using water quality models. The municipality can then use
the speculative limits to prepare preliminary engineering design and cost estimates for the direct discharge alternative
within the EAA. In limited instances where complex water quality models are necessary to develop speculative limits
and determine potential water quality impacts, some municipalities have undertaken the modeling effort (with DWQ
review) in order to expedite this portion of the NPDES permit review process.
Non -municipal applicants.
Due to staff constraints, the NPDES Unit cannot prepare speculative limits for non -municipal applicants. Thus, it is
your responsibility to make your own determination as to whether the proposed discharge might be allowed by the
Division, by evaluating the water quality factors listed above. It is highly recommended that you discuss the proposed
discharge with the applicable DWQ Regional Office and/or NPDES Unit staff, who may be able to provide input on
the likelihood of a new/expanding discharge. As a first step, you must obtain streamflow estimates for the proposed
discharge location to ensure that the receiving stream is not subject to zero flow restrictions. Low flow data
(specifically, the summer 7Q10 and 30Q2 flow statistics) can be obtained for a nominal fee from the U.S. Geological
Survey in Raleigh at 919-571-4000. The low flow data must be submitted with the EAA, and will be used by the permit
writer to develop permit limits. You must also verify that the proposed action (i.e., construction of a wastewater
treatment plant and its appurtenances) is consistent with local zoning and/or subdivision ordinances. You will need to
request the local government(s) to complete a Local Government Review Form (Attachment A), and include the
signed and notarized form with your NPDES application package.
EAA Guidance Document Version: June 23, 2005
Page2of8

All applicants.
If you conclude that the proposed discharge will pass the "allowable discharge" criteria, then begin the EAA
preparation by summarizing the following general information about the proposed project:
• Provide a description of the proposed project. If the project will be constructed in phases, provide a
schedule for constructing each additional phase, and provide the projected flow per phase (see STEP 2).
• Applicant name, mailing address, phone number, contact person
• Facility name, address, county, phone number, contact person
• EAA preparer's name, mailing address, phone number, contact person
STEP 2. Provide reasonable projections for population and flow
Residential Population Projections.
Facilities requesting an NPDES discharge permit for new or expanding domestic wastewater discharges must
document the population to be served within the service area over a 20-year planning period. The NC State
Demographics unit provides population data for each county and municipality and can be accessed on the Internet at
http://www.demog.state.nc.us. If 20-year population projections for specific areas are not available, a linear
extrapolation of population trends from the past decade should be used. Any deviation from a linear projection
method must be dearly justified. If population projections include future annexations, include a proposed annexation
schedule as well as any annexation requirements that must be met.
Municipal Flow Projections.
Justification of flow as well as a demonstration of need shall be provided. Mere speculation is not sufficient. Flow
projections should represent average anticipated flows, since permit flow limits are based on monthly averages.
Peaking factors used to design various components of the wastewater collection system (e.g., collector sewers,
interceptor sewers, pumping stations) should not be used in the justification of the average anticipated flow. For
municipal wastewater dischargers, flow must be justified using the Clean Water State Revolving Fund (CWSRF)
criteria available on the Internet at http://www.nccgl.net/fap/cwsrf/. Exceptions to these flow criteria may be
approved on a case -by -case basis provided adequate justification is supplied.
• Current Flow- Provide current flows induding residential, commercial, industrial, and non -excessive
infiltration/inflow (I/I) based on actual flow data or water billing records. Current residential flow and
current commercial flow may be based on water billing records minus a 10% consumptive loss. Current
industrial flow may be based on dual metering to determine consumptive losses. Current non -excessive
I/I should also be determined in accordance with CWSRF criteria. If I/I is demonstrated to be above
CWSRF criteria, that infrastructure contributing to excessive I&I must either be repaired or replaced
prior to any request for flow expansion.
• Future Residential Flow- Provide 20-year residential flows based on projected residential growth.
Multiply the projected growth in residential population by 70 gallons per day per capita.
• Future Commercial Flow- Provide 20-year commercial flows based on projected residential growth.
Multiply the projected growth in residential population by 15 gallons per day per capita.
• Future Industrial Flow- Provide flow for future documented industrial flow. A nominal allowance for
future unplanned industrial expansions may be considered by the Division, provided the basis is clearly
justified and current land -use plans and local zoning allow for such industrial growth.
• Future Non -excessive I/I- A nominal allowance for non -excessive I/I for new sewer lines may be
considered by the Division, provided the basis is dearly justified.
Non -Municipal Flow Projections.
Flow may be justified in accordance with 15A NCAC 2H .0219(1) for various activities (e.g., new subdivisions, new
schools, various commercial activities). For other proposed discharges (e.g., groundwater remediation, water
EAA Guidance Document Version: June 23, 2005
Page 3 of 8

treatment plant filter backwash, industrial facilities), the flow projections will be based on engineering design
considerations and/or production projections rather than population projections.
STEP 3. Evaluate technologically feasible alternatives
Since a goal of the Clean Water Act is to minimize or eliminate point source discharges to surface waters, any
proposal for a new or expanding wastewater discharge must include evaluation of wastewater disposal alternatives in
addition to direct discharge. Particularly for dischargers of domestic wastewater, this evaluation should investigate the
feasibility of the following wastewater disposal alternatives:
• Connection to an existing wastewater treatment plant (public or private)
• Land application alternatives, such as individual/community onsite subsurface systems, drip irrigation,
spray irrigation
• Wastewater reuse
• Surface water discharge through the NPDES program
• Combinations of the above
In order for the applicant to eliminate a wastewater disposal alternative, you must either show that the alternative is
technologically infeasible, or that it would be cost prohibitive to implement relative to a direct discharge alternative.
Please note that for some alternatives, it might be easier to prove an alternative is not viable based on high cost rather
than technological feasibility. For example, for a large municipal expansion that would require several hundred acres
for a land application alternative, it might be easier to simply assume that the required acreage could be purchased and
calculate the present value costs (including current market land costs) for this option, rather than evaluating whether
land application is technologically infeasible due to lack of available land and/or poor soil conditions. For those
alternatives identified as technologically feasible, you must develop and compare costs, based on a preliminary level
design effort (see STEP 4).
The Division recognizes that wastewater disposal alternatives may be limited for some non -domestic wastewater
scenarios, and a full alternatives evaluation may not be warranted. If there is some question as to whether an alternative
may be eliminated, contact the NPDES Unit staff. Some scenarios that might not require a full alternatives evaluation
include:
Water Treatment Plant Discharges. Discharges from water treatment plants (WTPs) that utilize a
membrane technology (e.g., reverse osmosis, nanofiltration) or ion exchange system tend to generate
highly concentrated wastestreams. These wastestreams are not amenable to land application and do not
have to be evaluated for this alternative. However, since these wastestreams can also have a toxic impact
on a receiving freshwater system, proposed new discharges from these WTPs to freshwaters will not be
considered for an NPDES permit unless you can demonstrate that the environmental impacts would be
minimal based on dilution modeling. You should investigate whether the wastewater can be piped to a
stream with sufficient dilution, or whether a local WWTP might accommodate this discharge. Please
note that discharges from WTPs that utilize greensand filtration or conventional technology produce a
wastestream that is not saline, therefore no disposal alternatives can be automatically ruled out as
infeasible for these other WTPs. Refer to the NPDES website for permitting strategies for reverse
osmosis, ion exchange, greensand filtration, and conventional WTPs.
• Groundwater Remediation System Discharges. You will need to evaluate whether WWTP connection,
land application, infiltration galleries, in -situ groundwater remediation wells, or closed -loop groundwater
remediation wells are viable disposal alternatives. While land application might be a feasible alternative in
rural areas, it would not be a feasible alternative in downtown Charlotte, where there is no land available
for wastewater application. In this instance, you may simply state that land application is infeasible based
on land constraints within the city. You will also need to evaluate connection to an existing WWTP (in
accordance with Alternative A), since there are some municipalities that have accepted this wastestream
EAA Guidance Document Version: June 23, 2005
Page 4 of 8

in the past. If the municipality will not accept the wastestream, the connection alternative is also
considered technologically infeasible. Please note that in -situ and dosed -loop groundwater remediation
wells are permittable well types and further guidance is available through the Aquifer Protection Section.
Aside from these exceptions, you should proceed with the alternatives evaluation in accordance with the following
requirements. If you have any questions about these requirements, contact the NPDES Unit staff.
Alternative A. Connection to an Existing Wastewater Treatment System.
You must evaluate the feasibility of connecting to an existing wastewater treatment system served by a municipality or
other entity holding a valid NPDES or Non -Discharge Permit. All connection options should include an evaluation
of a gravity line and/or force main with pump station(s).
1. Existing Sewerage System:
(a) Identify whether there are existing sewer lines within a five -mile radius, or consider a greater radius if
cost effective for the project size.
(b) Provide a preliminary indication of flow acceptance from existing municipal or private WW TPs
under consideration for connection. If a municipal or private WWTP cannot accept the wastewater,
indude a letter documenting such and consider this alternative technologically infeasible.
(c) If an existing sewerage system will accept the wastewater, evaluate the piping/pumps/resources
necessary to connect to the existing wastewater treatment plant. Attach a topographic map or a site
drawing showing the physical route of this alternative. Conduct a Present Value Cost Analysis per
STEP 4.
2. Planned Sewerage System: Determine if a regional sewerage system within a five mile radius is projected
to be available within the next five years to receive waste from the project site. If applicable, determine
availability date and flow acceptance projection from appropriate authority.
Alternative B. Land Application.
Land application disposal alternatives include individual/community onsite subsurface systems, drip irrigation, and
spray irrigation.
1. Provide an estimate of the best case hydraulic loading rate based on County Soil Surveys or from a soil
evaluation performed by a soil scientist. Include calculations showing the hydraulic loading rate
and the total area of land needed for the land disposal system, including buffers.
2. Assess the availability of land. If insufficient land is available onsite, assume that the necessary land can
be purchased and estimate the land purchase cost based on local real estate prices. Alternatively, provide
documentation to demonstrate that insufficient land is available for sale in the project area (include
letters from adjacent property owners indicating no interest in selling property).
3. Provide a description of the wastewater treatment system and the non -discharge application system.
Indude a site plan showing the proposed layout, the application area, any existing structures, proposed
structures, and other uses within the site.
4. Explain the proposed reuse plan if reclaimed water will he used by a third party.
5. Conduct a Present Value Cost Analysis per STEP 4. For the reclaimed water system indude the
potential revenue generated by selling the water.
6. Provide all calculations, documentation and maps as necessary to support assumptions and condusions.
7. Note: The design of land application systems must meet the treatment and design requirements specified
in 15A NCAC 2H.0219 or 15A NCAC 18A.1900.
8. Note: Proposed discharges from groundwater remediation systems must evaluate the potential for an
infiltration gallery treatment alternative.
Alternative C. Wastewater Reuse.
You must evaluate reusing all or a portion of the wastewater generated. Some municipalities are currently reusing
wastewater within the confines of their WWTP property for irrigation, toilet flushing, backwashing, etc., while other
municipalities have established progressive reuse programs for residential irrigation. Reuse applications might include
golf course irrigation, crop irrigation (e.g., hardwood or pine plantation, grasses), athletic field irrigation, landscape
uses, and commercial/industrial uses. Some of these reuse applications will be evaluated under Alternative B, Land
EAA Guidance Document Version: June 23, 2005
Page 5 of 8

Application. The design of reclaimed water systems must meet the treatment and design requirements specified in
15A NCAC 2H.0219.
Alternative D. Direct Discharge to Surface Waters.
1. No new or expanding (additional) discharge of oxygen -consuming waste will be allowed to surface waters
of North Carolina if both the summer 7Q10 and 30Q2 streamflows are estimated to be zero, in
accordance with 15A NCAC 2B.0206(d). Private applicants must contact the Federal USGS in Raleigh at
919-571-4000 and obtain (generally for a nominal fee), the receiving streamflow data (s7Q10, 30Q2,
annual average streamflow) at the proposed discharge location. This information must be induded in the
EAA, and will be used to develop permit limits.
2. All direct discharge systems of oxygen -consuming wastes should be evaluated both with tertiary filtration
[BODS= 5 mg/1, NH3-N=1 mg/I] and without, and assuming a weekly sampling regime.
3. Provide a description of the proposed wastewater treatment facilities, including a schematic diagram of
the major components and a site plan of the treatment facility with outfall line(s).
4. Provide documentation of the availability of required land and/or easement agreements.
5. Conduct a Present Value Cost Analysis per STEP 4.
6. Note: All direct discharge treatment systems must comply with Reliability Requirements specified in 15A
NCAC 2H.0124 as well as Minimum Design Requirements specified in 15A NCAC 2H.0219.
Alternative E. Combination of Alternatives.
You should evaluate the possibility of a combination of wastewater alternatives that would minimize or eliminate a
direct discharge alternative. For example, consider whether the facility can operate a land application system during
the dry season when streamflows are at their lowest and provide less dilution, and operate an NPDES discharge
system during the wet season when soils may not be as amenable to land application and the receiving stream
provides its greatest dilution.
STEP 4. Evaluate economic feasibility of alternatives
To provide valid cost comparisons among all technologically feasible wastewater alternatives identified in STEP 3, a 20-
year Present Value of Costs Analysis (PVCA) must be performed. A preliminary design level effort is considered
appropriate for comparing feasible options and their associated costs. For the PVCA cost comparison, all future
expenditures are converted to a present value cost at the beginning of the 20-year planning period. A discount rate is
used in the analysis and represents the time value of money (the ability of money to earn interest). Present value is also
referred to as "present discounted value" or "present worth".
The PVCA should include all monetary costs associated with construction, startup and annual operation and
maintenance of a facility. All unit cost information must be provided, and costs must be referenced. Costs can be
referenced in paragraph format by summarizing the sources utilized (e.g., vendor quotes, realtor land quotes, past
bids, Means Construction Index, etc). Vender quotes received for treatment units or other components, as well as
realtor land quotes, shall be included as well. For each treatment alternative identified as technologically feasible,
costs should include, but not be limited to, the following:
Capital Costs
■ Land acquisition costs
• Equipment costs
■ Labor costs
• Installation costs
• Design costs
EAA Guidance Document Version: June 23, 2005
Page 6 of 8

Recurring Costs
• Operation and maintenance costs (with replacement costs)
• Laboratory costs assuming a weekly monitoring regime for discharge systems and a monthly regime for
non -discharge systems
• Operator and support staff costs
• Residual disposal costs
• Connection fees and subsequent user fees
• Permit and compliance fees
• Utility costs (power, water, etc.)
Lost Opportunity Costs
PVCA Calculation Method
The following standard formula for computing the present value must be used in all cost estimates made under this
evaluation:
Where:
n C
PV=C +�
° r=1 (1 + r)`
PV = Present value of costs.
Co = Costs incurred in the present year.
Ct = Costs incurred in time t.
t = Time period after the present year (The present year is t = 0)
n = Ending year of the life of the facility.
r = Current EPA discount rate. EPA adjusts this rate annually on October 1, and it can be accessed from
the Internet at http:/www.nccgl.net/fap/cwsrf/201gui.html.
If recurring costs are the same in years 1 through 20, then Ct=C and the formula reduces to:
n
PY = C,,+ C - (1 + r) 1
_ r(1 + r) J
As an example, assuming capital costs (Co) of $2 million, annual recurring costs (C) of $40,000, and a discount rate (r)
of 5.625%, the 20-year (n=20) present value of costs would equal:
PV= capital costs + recurring costs X [(1+0.05625)20 — 1] / [0.05625(1+0.05625)2]
PV= $2,000,000 + $40,000 X [1.98/0.168]
PV= $2,000,000 + $471,428
PV= $2,471,428
PVCA Summary Table.
The EAA must indude a Summary Cost Table, which summarizes present worth costs developed for all technologically
feasible wastewater alternatives. The summary should indude a breakdown of capital costs and recurring costs. In
some situations, the Division may require the applicant to refine cost estimates for some alternatives, or possibly collect
actual soil data to better characterize the land application alternative. Ultimately, the final determination on cost
effectiveness is made by the Division with consideration of monetary costs as well as potential environmental impacts.
EAA Guidance Document Version: June 23, 2005
Page 7 of 8

Attachment A. Local Government Review Form
General Statute Overview: North Carolina General Statute 143-215.1 (c) (6) allows input from local governments in the issuance
of NPDES Permits for non -municipal domestic wastewater treatment facilities. Specifically, the Environmental Management
Commission (EMC) may not act on an application for a new non -municipal domestic wastewater discharge facility until it has
received a written statement from each city and county government having jurisdiction over any part of the lands on which the
proposed facility and its appurtenances are to be located. The written statement shall document whether the city or county has a
zoning or subdivision ordinance in effect and (if such an ordinance is in effect) whether the proposed facility is consistent with the
ordinance. The EMC shall not approve a permit application for any facility which a city or county has determined to be
inconsistent with zoning or subdivision ordinances unless the approval of such application is determined to have statewide
significance and is in the best interest of the State.
Instructions to the Applicant: Prior to submitting an application for a NPDES Permit for a proposed facility, the applicant
shall request that both the nearby city and county government complete this form. The applicant must:
• Submit a copy of the permit application (with a written request for this form to be completed) to the clerk of the city and
the county by certified mail, return receipt requested.
• If either (or both) local government(s) fail(s) to mail the completed form, as evidenced by the postmark on the certified
mail card(s), within 15 days after receiving and signing for the certified mail, the applicant may submit the application to
the NPDES Unit.
• As evidence to the Commission that the local government(s) failed to respond within 15 days, the applicant shall submit a
copy of the certified mail card along with a notarized letter stating that the local government(s) failed to respond within the
15-day period.
Instructions to the Local Government: The nearby city and/or county government which may have or has jurisdiction over
any part of the land on which the proposed facility or its appurtenances are to be located is required to complete and return this
form to the applicant within 15 days of receipt. The form must be signed and notarized.
Name of local government
(City/County)
Does the city/county have jurisdiction over any part of the land on which the proposed facility and its appurtenances are to be
located? Yes [ ] No [ ] If no, please sign this form, have it notarized, and return it to the applicant.
Does the city/county have in effect a zoning or subdivision ordinance? Yes [ ] No [ ]
If there is a zoning or subdivision ordinance in effect, is the plan for the proposed facility consistent with the ordinance? Yes [ ]
No [ ]
Date Signature
(City Manager/County Manager)
State of , County of
On this day of , personally appeared before me, the said
name to me known and known to me to be the person described in
and who executed the foregoing document and he (or she) acknowledged that he (or she) executed the same and being duly sworn
by me, made oath that the statements in the foregoing document are true.
My Commission expires .(Signature of Notary Public)
Notary Public (Official Seal)
EAA Guidance Document Version: June 23, 2005
Page8of8

Nowell, Jackie
From: Belnick, Tom
Sent: Friday, February 08, 2013 7:10 PM
To: Nowell, Jackie
Subject: RE: Request for Speculative Limits - Town of Oakboro NC0043532
Jackie- please check 1) 303d for any new impairment, 2) any anticipated nutrient requirements. If nothing new, please
draft short (1-page max) Cover Letter stating that 2005 specs still are good, and attach the 2005 specs to the cover
letter. Please reiterate my point that based on CY2012 data, the facility averaged 40% of permitted flow. Thanks.
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919-807-6390
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Crystal Penton [mailto:cpenton(athewootencompany.com]
Sent: Thursday, February 07, 2013 10:07 AM
To: Belnick, Tom
Cc: Nowell, Jackie
Subject: RE: Request for Speculative Limits - Town of Oakboro NC0043532
Tom —
We had previously discussed this matter with Jackie Nowell. Her recommendation was to send an email requesting
updated speculative limits to ensure that nothing has changed in the several years that have elapsed since the request in
2005. The area surrounding Oakboro is expected to experience growth in the future. As a result Oakboro is being
proactive at this time, taking steps to consider becoming a regional facility should the need arise.
Crystal Penton, PE
Project Engineer
The Wooten Company
120 North Boylan Avenue
Raleigh, NC 27603
919.828.0531
Fax [phone]
www.thewootencompany.com
TT
THE
WOOTEN
COMPANY
Original Message
From: Belnick, Tom [mailto:[e-mail]]
Sent: Wednesday, February 06, 2013 11:22 AM
To: Crystal Penton
Cc: Nowell, Jackie
Subject: RE: Request for Speculative Limits - Town of Oakboro NC0043532
1

Crystal- looks like DWQ issued specs for these flows back in 2005. Are you just seeking verification that the
previous specs are still valid? Is there any planned expansion in near future- looks like facility averaged 40% of
permitted flow for CY2012. Thanks.
Tom Belnick
Supervisor, NPDES Complex Permitting Unit
NCDENR/Division of Water Quality
919-807-6390
E-mail correspondence to and from this address may be subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: Crystal Penton[mailto:cpentonOthewootencompanv.com]
Sent: Tuesday, February 05, 2013 9:51 AM
To: Belnick, Tom
Cc: Charles Davis; Matt Echols; Nowell, Jackie
Subject: Request for Speculative Limits - Town of Oakboro NC0043532
Dear Mr. Belnick —
On behalf of the Town of Oakboro, we would like to request speculative effluent limits for expanding the Oakboro
Wastewater Treatment Plant which operates under NPDES permit No. NC0043532. Please provide speculative
effluent limits for flows of 1.2 MGD and 3.0 MGD discharged from Outfall 002 into the Rocky River in the Yadkin -
Pee Dee River Basin. If you should require any additional information from our office to complete this request,
please do not hesitate to contact us.
Sincerely,
Crystal Penton, PE
Project Engineer
The Wooten Company
120 North Boylan Avenue
Raleigh, NC 27603
919.828.0531
Fax [phone]
www.thewootencompany.com
y:y
THE
WOOTEN
COMPANY
2

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Nowell, Jackie
From: Belnick, Tom [[e-mail]]
Sent: Thursday, February 28, 2013 2:43 PM
To: NCDENR.denr.dwq.npdescomplex; NCDENR.denr.dwq.npdesexpedited
Cc: Templeton, Mike; Poupart, Jeff
Subject: NCDENR - NHP - Home
Neat easy tool to identify Federal Threatened/Endangered Species within 2 or 5 mile radius of
discharge, using link below:
http://portal.ncdenr.org/web/nhp/home
Developed by DENR Natural Heritage Program. Use "Map Viewer" and specify street address or
lat/long or just place pointer on map to generate list of Federal Threatened and Endangered
(T&E) species within 2 or 5 miles. We can use this tool when developing speculative limits,
and warn applicants in spec letter that if we find T&E species are nearby, they might want to
discuss proposed project with USFWS before proceeding too far down the road. Our focus would
be T&E fish/mussels/etc- aquatic life that might be impacted by a wastewater discharge. Per
our MOA with EPA, NPDES must attempt to resolve any T&E issues with USFWS, else EPA will
mediate.
Jackie/Ron/Teresa- please get familiar with this tool for use with future spec requests.
PS- Our lat/long (in degrees,minutes,seconds) will need to be converted to decimal degrees to
plug into this tool, if you use the lat/long option.
denr.dwq.npdescomplex mailing list
denr.dwq.npdescompiex(ail:ists.ncmail.net
1