NC0037001_Permit Issuance_20020408

NPDES DOCUMENT SCANNING COVER SHEET
NC0037001
Bethany Elementary School WWTP
NPDES Permit:
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Staff Report
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
April 8, 2002
This document is printed on reu11ae paper - igprzore any
content an the reverse side

WATF9
C. w
r NCDENR
a
r�
Mr. R.W. Holcomb
Rockingham County Schools
511 Harrington Highway
Eden, North Carolina 27288
Dear Mr. Holcomb:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
April 8, 2002
Subject: Issuance of NPDES Permit NC0037001
Bethany Elementary School WWTP
Rockingham County
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
There have been no significant changes from the draft permit previously sent to you on February 6, 2002.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required.
If you have any questions concerning this permit, please contact Charles Weaver at telephone number (919)
733-5083, extension 511.
cc: Central Files
Winston-Salem Regional Office/Water Quality Section
NPDES Unit
N. C. Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Sincerely,
ORIGINAL SIGNED BY
SUSAN A. WILSON
Gregory J. Thorpe, Ph.D.
Phone: [phone]
fax: [phone]
DENR Customer Service Center: 1 800 623-7748

Permit NC0037001
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended, the
Rockingham County Schools
are hereby authorized to discharge domestic wastewater from a facility located at the
Bethany Elementary School WWTP
NC Highway 65 at NCSR 2316
Bethany
Rockingham County
to receiving waters designated as Huffines Mill Creek in the Roanoke River Basin in accordance with
effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV
hereof.Lu,04- 7
�. �U''' ,
This permit shall become effective May 1, 2002 ;oil" V,a
This permit and authorization to discharge shall expire at midnight on April 30, 2007.
Signed this day April 8, 2002.
ORIGINAL SIGNED BY
SUSAN A. WILSON
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission
3Zo 17
, at'4

Permit NC0037001
SUPPLEMENT TO PERMIT COVER SHEET
The Rockingham County Schools are hereby authorized to:
1. Continue to operate an existing 0.01 MGD wastewater treatment facility with the
following components:
• Septic tank/pump tank
• Dual pump system with flow meters and zone control
• Recirculating sand filter system
• UV disinfection system
This facility is located off NC Highway 65 at NCSR 2316 in Bethany at the Bethany
Elementary School WWTP in Rockingham County.
2. Discharge from said treatment works at the location specified on the attached map into
Huffines Mill Creek, classified C waters in the Roanoke River Basin.

Quad: Bethany, N.C.
Latitude: 36°20'00"
Longitude: 79°51'27"
Stream CIass: C
Subbasin: 30203
Receiving Stream: Huffines Mill Creek
0
NC0037001
Rockingham County Schools
Bethany Elementary School
North
SCALE 1:24000

Permit NC0037001
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge from outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average.
Daily
Maximum
Measurement
Frequency
Sample Type
•
Sample Location
Flow
0.01 MGD
Weekly
Instantaneous
Influent or Effluent
BOD, 5-day (202C)
30.0 mg/L
45.0 mg/L
2/Month
Grab
Effluent
Total Suspended Residue
30.0 mg/L
45.0 me L--
2/Month
Grab
Effluent
NH3 as N
(April 1 — October 31)
14.0 mg/L
3S . I /
) -
`Monthly
_--
Grab
Effluent
NH3 as N
(November 1— March 31)
Monthly
Grab
Effluent
Dissolved Oxygen
Weekly
Grab
Effluent
Fecal Coliform (geometric mean)
200 / 100 ml
400 / 100 ml
2/Month
Grab
Effluent
Total Residual Chlorine1
28pg/L
2/Week
Grab
Effluent
Temperature (°C)
Weekly
Grab
Effluent
pH2
2/Month
Grab
Effluent
Footnotes:
1. Limits and monitoring are required only if chlorine is added to the treatment system.
2. The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
��--3/L ,
insvl-�.-,eot

Y.: PUBLIC NOTICE
STATE OF NORTH
CAROUNA
ENVIRONMENTAL
MANAGEMENT
COMMISSIOWNPDES
UNIT
1617 MAIL SERVICE
CENTER
RALEIGH, NC
27699-1617
NOTIFICATION OF
INTENT TO ISSUE A
NPDES WASTER
WATER PERMIT
On the basis of thorough
staff review end application
of NC General Stat413 14321,
Public law 92.500 and other
- lawful standards and
regulafiont, the North Canine
Environmental Management
Commission proposes to
issue a National Pdlutant
Discharge Eirina6m System
(NPDES) waste water
discharge permit to the
person(s) listed below
effective 45 days fro the
publish date of this notice.
Written cormhenls rogueing
the proposed permit wit be
accepted until 30 days after
the publish date of this notice.
Written comments reputing
~&tthrnrtLLr Lnifrm
1921 Vance Street • PO Box 2157 • Reidsville, NC 27320. 336-349;4331 i
meeting for the proposed
permit should the Division
receive a significant degree
o pubic interest.
Copies of the draft permit
and other supporting
Information on Tde used to
defamire o:raid s present
In the draft permit ars
evadable upon request and
payment of the costs of
repradcrcti ri. Mel comments
ander requests for tiommecri
to the NC Division of Water
Cuddly at the above address
weal I,4s. Christine Jackson
at 919-733.5083, extension
538. Please Include the
NPDES permit number
(attached) In any
oomxnunication. Interested
persons may also visit the
Division of Water Duality at
512 N. Salisbury Street,
Raleigh, NC 27604-1148
between the tours al 8:00
am. and 5:00 pm. lo review
iniarttation on Be.
NPDES Permit Number
NC0085022, Michael R.
Hodgin (U.S. 220 Trailer
Park), 4404 Caine= Dike,
Greensboro, NC 27406 has
applied for a permit renewal
for a facility located in
the proposed permit wdl be Rockingham County
'tweeted until 30days after discharging well -filter
the publish date d els notice. backwash waster water ido
Al comments nsceived pripr an unnamed tributary to
lirhatrefiltit a aXrSHetik* Creek in the
in the final determinations Roanoke River Basin.
regarding the proposed Curter* noparameters are
parr&The oiedoroMheNC water quality limited. This
13, 'sion of Water Quality discharging may affect
may a is allocations In this portion of ,
the receiving stream.
NPDES Permit Number
NC0077135, Fred D. Curl
(Hidden Valley Estates
WWTP), 707 North English
Street, Greensboro, NC
27405 has apded for a perm*
renewal for a facility located
'0 Rockingham County
discharging treated waste
water into an unnamed
tributary to Lick Fork Creek
n the Roanoke River Basin.
Currently ammonia nitrogen
and total residual chlorine
are water quality limited. This
discharge may affect future
allocations in this portion of
the receiving stream.
NPDES Permit Number
N00037001, Rockingham
County Schools (Bethany
Elementary School WWTP),
511 Harrington Highway,
Eden, NC 27288 has applied
for a permit renewal for a
freely braced n Rocking -a m
County discharged treated
waster water into Hullnes
Mil Creek in the Roanoke
River Basin. Currently
ammonia nitrogen and total
residential ddonie are water
quality lint tact. This discharge
may affect future allocations
n this portion dine receiving
stream.
February 8, 2002
Affidavit of Publication
North Carolina
Rockingham Coif ity v4, 4�0
<,
Before the undersigned, a Notary Public Said ounty and
State, duly commissioned, qualified, and authorized aw to admin-
ister oaths, personally appeared David Clevenger, who being first
dually sworn, deposes and says. That he is an official of Media
General of Reidsville, Inc. engaged in the publication of a newspaper
known as The Reidsville Review, published, issued and entered as sec-
ond class mail in the City of Reidsville, in said County and State; that
he is authorized to make this affidavit and sworn statement, that the
notice or other legal advertisement, a true copy of which is attached
hereto, was published in The Reidsville Review on the following
dates:
\w 5 Z r RMQ MAR 2 0 2002
Dm BUDGET OFFICE
and that the said newspaper in which such notice, paper document, or
legal advertisement was published, at the time of each and every such
publication, a newspaper meeting all the requirements and qualifica-
tions of Section I-597 of the General Statutes of North Carolina and
was qualified newspaper within the meaning of Section I-597 of theif�
General Statutes of North Carolina.
aECF1VFD
r (Affiant)
Sworn to and subscribed before me, this
day of t
r ' CER L.:.
R21c)(L/1--) t '
'ip
_ PaAI

Rockingham County Schools
Maintenance Office
391 County Home Road
Reidsville, NC 27320
October 16, 2001
Attention: Valery Stephens
NC Dept. of Environment & Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Dear Ms. Stephens:
Thomas D. Strader
Maintenance Director
[phone] / Fax [phone]
We received your letter dated October 12, 2001 requesting the sludge management plan for
Bethany Elementary School Permit NC0037001. This plant is a recirculating sand filter with
spray aeration. All sludge and solids are held in the head septic tanks. Sludge and solids are
pumped and removed annually by Billingsley Septic Tank Company. (Note: This is no longer a
dry -creek dumping plant.)
Please notify me if further information is needed. Thank you so much for your assistance.
Sincerely,
-J4477vt.1-1 • fdlY&,
Thomas D. Strader
Maintenance Director
ki
Teaching All Students to Become Productive Citizens and Lifelong Learners

NPDES PERMIT APPLICATION - SHORT FORM D
To be filed only by dischargers of 100% domestic wastewater (<1 MGD flow)
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
North Carolina NPDES Permit Number
(if known)
NCO() 37001
Please print or type
1. Mailing address of applicant/permittee:
Facility Name
Owner Name
Street Address
City
State
ZIP Code
Telephone Number
Fax Number
e-mail Address
Bethany Elementary School
Rockingham County Schools
511 Harrington Highway
Eden
NC
27288
( 336 ) 627-2611
( 336 ) b1/-ZbbU
2. Location of facility producing discharge:
Name (If different from above)
Facility Contact Person
Street Address or State Road
City / Zip Code
County
Telephone Number
Above
R. William Holcomb
Above
( 336 ) 627-2611
3. Reason for application:
Expansion/Modification * Existing Unpermitted Discharge
Renewal X New Facility
* Please provide a description of the expansion/modification:
NA
4. Description of the existing treatment facilities (list all installed components with
capacities):
Recirculating sandfilter system with UV disinfection.
Page 1 of 2 Version 11/2000

NPDES PERMIT APPLICATION - SHORT FORM D
To be filed only by dischargers of 100% domestic wastewater (<1 MGD flow)
5. Description of wastewater (check all that apply):
Type of Facility Generating Wastewater
Industrial Number of Employees
Commercial Number of Employees
Residential Number of Homes
School XX Number of Students/Staff
Other
Describe the source(s) of wastewater (example: subdivision, mobile home park, etc.):
Bethany Elementary School
6. Number of separate wastewater discharge pipes (wastewater outfalls):
One (1)
7. If the facility has multiple discharge outfalls, record the source(s) of wastewater for each
outfall:
NA
8. Name of receiving stream(s) (Provide a map showing the exact location of each outfall):
Huffines Mill Creek (Map Enclosed)
I certify that I am familiar with the information contained in the application and that to the,
best of my knowledge and belief such information is true, complete, and accurate.
R. William Holcomb
Printed Name of Person Signing
•
Associate Superintendent
Title
Signature of Applicant Date Signed
North Carolina General Statute 143-215.6E (i) provides that: Any person who knowingly makes any false statement representation, or
certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any
recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental
Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $10,000, or by
imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $10,000 or
imprisonment not more than 5 years, or both for a similar offense.)
Page 2 of 2
Version 11/2000

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. Daniel McCollum
1122 McCollum Road
Madison, North Carolina 27025
AVAI,
DENR
February 26, 1998
Subject: Permit No. NC0037001
Bethany School
Rockingham County
Dear Mr. McCollum:
Senator Virginia Foxx has asked me to write a letter in reference to the recommendation that was
made relative to the expansion request for the wastewater treatment facility at Bethany School. This letter
summarizes the key points addressed in the meeting between Senator Foxx and myself on Tuesday,
February 10, 1998. The meeting was scheduled to discuss the procedures that were followed prior to
issuing the expansion request for the wastewater treatment facility at Bethany School.
In order to accommodate the increasing student population at Bethany School, Rockingham County
Consolidated Schools requested an Authorization to Construct to expand the wastewater treatment facility
from 3,700 gallons per day to 10,000 gallons per day. The primary issue of concern with the expansion
request was the fact that the facility discharged into a zero flow stream.
In cases where the 30Q2 flow and the 7Q,o flow of the receiving stream are both estimated to be
zero, no new or expanded (additional) discharge of oxygen consuming waste is allowed. This prohibition
is specifically outlined in the North Carolina Administrative Code Section 15A NCAC 2B.0206 (d)(2). The
effective date of this prohibition was February 1, 1976. A copy of this language is attached to this letter for
your review.
When any facility requests an expansion, the Division requires the Permittee to prepare a detailed
engineering report that evaluates all wastewater disposal alternatives. The primary focus of this report is to
study all available discharge options and to prepare an economic analysis that compares the cost of
implementing each option. The results of this report are used to determine the most environmentally sound
of the reasonably cost effective alternatives for wastewater disposal at the subject facility. Tritech Civil
Environmental prepared the Engineering Alternatives Analysis report for Bethany School. The following is
a summary of the report conclusions:
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Bethany School
NC0037001
Page 2 of 2
Alternative
Description
Capital Cost
Present Worth Cost
1
Connection to municipal wastewater
system
$850,000
$873,300
Conventional subsurface disposal
$366,244
$411,062
3
Conventional spray irrigation
$739,620
$842,554
4
Relocate surface discharge
$273,831
$362,729
5
Subsurface drip irrigation
$541,272
$578,207
6
Low pressure pipe system
$533,900
$569,047
The Division recognizes that the expense to upgrade this facility and to relocate the discharge point
was substantial, but it was determined to be the most cost effective option available. Therefore, the school
moved forward and a permit authorizing construction was issued on December 22, 1997.
The Division would like to point out that Section 15A NCAC 2B.0206 (d)(2) of the North Carolina
Administrative Code applies to all discharges throughout the state. This requirement is applicable to all
Permittees who wish to expand to a stream with a 30Q2 flow and the 7Q10 estimated to be zero.
Should you need additional information or if you have any questions, please do not hesitate to
contact me at 919-733-5083, extension 597.
e f ey T. la, E.I.T.
Environmental Engineer
NPDES Unit
cc: Central Files
NPDES Unit

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 20, 1998
Senator Virginia A. Foxx
Legislative Office Building
Room 1120
Raleigh, North Carolina 27601-2808
A7A
ITT ITT
Subject: Permit No. NC0037001
Bethany School
Rockingham County
Dear Senator Foxx:
This letter was prepared to summarize the key points of our meeting that took place on Tuesday,
February 10, 1998. The meeting was scheduled to discuss the procedures that were followed prior to
issuing the expansion request for the wastewater treatment facility at Bethany School.
In order to accommodate the increasing student population at Bethany School, Rockingham County
Consolidated Schools requested an Authorization to Construct to expand the wastewater treatment facility
from 3,700 gallons per day to 10,000 gallons per day. The primary issue of concern with the expansion
request was the fact that the facility discharged into a zero flow stream.
In cases where the 30Q2 flow and the 7Q,o flow of the receiving stream are both estimated to be
zero, no new or expanded (additional) discharge of oxygen consuming waste is allowed. This prohibition
is specifically outlined in the North Carolina Administrative Code Section 15A NCAC 2B.0206 (d)(2). A
copy of this language is attached to this letter for your review.
When any facility requests an expansion, the Division requires the Permittee to prepare a detailed
engineering report that evaluates all wastewater disposal alternatives. The primary focus of this report is to
study all available discharge options and to prepare an economic analysis that compares the cost of
implementing each option. The results of this report are used to determine the most environmentally sound
of the reasonably cost effective alternatives for wastewater disposal at the subject facility. Tritech Civil
Environmental prepared the Engineering Alternatives Analysis report for Bethany School. The following is
a summary of the report conclusions:
Alternative
Description
Capital Cost
Present Worth Cost
1
Connection to municipal wastewater
system
$850,000
$873,300
2
Conventional subsurface disposal
$366,244
$411,062
3
Conventional spray irrigation
$739,620
$842,554
4
Relocate surface discharge
$ 2 7 3, 8 31
$ 3 6 2, 7 2 9
5
Subsurface drip irrigation
$541,272
$578,207
6
Low pressure pipe system
$533,900
$569,047
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Bethany School
NC0037001
Page 2 of 2
The Division recognizes that the expense to upgrade this facility and to relocate the discharge point
was substantial, but it was determined to be the most cost effective option available. Therefore, the school
moved forward and a permit authorizing construction was issued on December 22, 1997.
The Division would like to point out that Section 15A NCAC 2B.0206 (d)(2) of the North Carolina
Administrative Code applies to all discharges throughout the state. This requirement is applicable to all
Permittees who wish to expand to a stream with a 30Q2 flow and the 7Q10 estimated to be zero.
Should you need additional information or if you have any questions, please do not hesitate to
contact me at 919-733-5083, extension 597.
S
z
e ` ey T. fra, E.I.T.
Environmental Engineer
NPDES Unit
cc: Central Files
NPDES Unit

s.,
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Govemor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
December 2,1997
Representative Cary Allred
c/o EconoMed
4307 Sartin Road
Burlington, North Carolina 27217
A7A
DENR
Subject: Bethany School discharge
NPDES Permit No. NC0037001
Rockingham County
Representative Allred:
This letter is to follow up on our telephone conversation on November 13,1997. One of your
constituents, Mr. Daniel McCollum, requested a letter stating that the Division of Water Quality will
not close Bethany School. You forwarded his request to me and discussed the project with me via
telephone on November 13,1997. You requested a review of the Division's files and a written response
to Mr. McCollum's request.
I have reviewed the Division of Water Quality's files on Bethany School. I have also
discussed this matter with Mr. David Goodrich (NPDES Unit Supervisor) and Mr. Steven D. Pellei
(the engineer preparing the Authorization to Construct for Bethany School). Listed below are the
relevant points in the Division's interaction with Rockingham County Schools concerning Bethany
School.
1. It is not within the Division's power to order the closing of any school in North Carolina. The
Division's regulatory authority only governs the impact a school (or any other facility) may have
on water quality. It is within the Division's authority to set restrictions on where and how
Bethany School may treat and discharge its wastewater. Our contact with Rockingham County
Schools has been in that context only.
2. Rockingham County Schools was required to relocate the outfall from the Bethany School
treatment works from a zero -flow stream to a stream with positive flow. Bethany School currently
discharges into a zero -flow stream. At the time of the most recent permit renewal, Rockingham
County Schools requested that the Bethany School wastewater treatment plant be expanded to a
permitted flow of 10,000 gallons per day. Rockingham County Schools must relocate the outfall at
Bethany School because of the explicit rule concerning discharges to zero -flow streams. North
Carolina Administrative Code 15A: 02B.0206(d)(2) allows no new discharges to zero -flow streams,
and no expansion of existing discharges to zero -flow streams. .
3. Rockingham County Schools and the Division of Water Ouality are formulating a strategy for
removal or relocation of outfalls at nine schools in Rockingham County, Bethany School is one of
nine schools in Rockingham County which discharge to a zero -flow stream. The Division and
Rockingham County Schools are currently formulating a strategy to relocate these outfalls to
streams with positive flow. The zero -flow rule mentioned above has been consistently applied to
many school systems across North Carolina since the early 1990's, affecting approximately 200
schools.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 919 733-5083, extension 511 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer [e-mail]

While the Division is requiring the outfall at the school to be relocated, the Division has no
power to close any school in North Carolina. Furthermore, it was never the Division's intent to force
closure of the school or construction of a new school. Those decisions have been made by the
Rockingham County Board of Education.
A copy of the zero -flow rule is attached to this letter. I will send Mr. McCollum a copy of this
letter and its attachment. If you have any other questions about this project, call the NPDES Unit at
[phone] and ask for Mr. David Goodrich (extension 517) or Mr. Steven Pellei (extension 516).
Sincerely,
/ id,roq
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Winston-Salem Regional Office, Water Quality Section
NPDES Unit
Mr. Daniel McCollum

EHNR - ENVIRONMENTAL MANAGEMENT TI SA: 02B .0200
.0205 NATURAL CHARACTERISTICS OUTSIDE STANDARDS LIMITS
Natural waters may on occasion, or temporarily, have characteristics outside of the normal range established by
the standards. The adopted water quality standards relate to the condition of waters as affected by the discharge of
sewage, -industrial wastes or other wastes including those from nonpoint sources and other sources of water pollution.
Water quality standards will not be considered violated when values outside the normal range are caused by natural
conditions. Where wastes are discharged to such waters, the discharger will not be considered a contributor -to
substandard conditions provided maximum treatment in compliance with permit requirements is maintained and,
therefore, meeting the established limits is beyond the discharger's control.
History Note: Authority G.S. 143-214.1; 143 215.3(a)(1);
Eff. February 1, 1976;
Amended Eff. October 1,1989; January 1, 1985.
.0206 FLOW DESIGN CRITERIA FOR EFFLUENT LIMITATIONS
(a) Water quality based effluent limitations are developed to allow appropriate frequency and duration of deviations
from water quality standards so that the designated uses of receiving waters are protected. There are water quality
standards for a number of categories of pollutants and to protect a range of water uses. For this reason, the
appropriate frequency and duration of deviations from water quality standards is not the same for all categories of
standards. A flow design criterion is used in the development of water quality based effluent limitations as a
simplified means of estimating the acceptable frequency and duration of deviations. More complex modeling
techniques can also be used to set effluent limitations directly based on frequency and duration criteria published by
the U.S. Environmental Protection Agency pursuant to Section 304(a) of the Federal Clean Water Act as amended.
Use of more complex modeling techniques to set water quality based effluent limitations will be approved by the
Commission or its designee on a case -by -case basis. Flow design criteria to calculate water quality based effluent
limitations for categories of water quality standards are listed as follows:
(1) All standards except toxic substances and aesthetics will be protected using the minimum average flow for
a period of seven consecutive days that has an average recurrence of once in ten years (7Q10 flow). Other
governing flow strategies such as varying discharges with the receiving waters ability to assimilate wastes
*may be designated by the Commission or its designee on a case -by -case basis if the discharger or permit
applicant provide evidence which establishes to the satisfaction of the Director that the alternative flow
strategies will give equal or better protection for the water quality standards. Better protection for the
standards means that deviations from the standard would be expected less frequently than provided by using
the 7Q10 flow.
(2) Toxic substance standards to protect aquatic life from chronic toxicity will be protected using the 7Q10
flow.
(3) Toxic substance standards to protect human health will be:
(A) The 7Q10 flow for standards to protect human health through the consumption of water, fish and
shellfish from noncarcinogens;
(B) The mean annual flow to protect human health from carcinogens through the consumption of water,
fish and shellfish unless site specific fish contamination concerns necessitate the use of an alternative
design flow;
(4) Aesthetic quality will be protected using the minimum average flow for a period of 30 consecutive days that
has an average recurrence of once in two years (30Q2 flow).
(b) In cases where the stream flow is regulated, a minimum daily low flow may be used as a substitute for the 7Q10
flow except in cases where there are acute toxicity concerns for aquatic life. In the cases where there are acute
toxicity concerns, an alternative low flow such as the instantaneous minimum release may be used on a case -by -case
basis. • .
(c) Flow design criteria are used to develop water quality based effluent limitations and for the design of
wastewater treatment facilities. Deviations from a specific water quality standard resulting 'from discharges which
are affirmatively demonstrated to be in compliance with water quality based effluent limitations for that standard will
not be a violation pursuant to G.S. 143-215.6 when the actual flow is significantly less than the design flow.
(d) In cases where the 7Q10 flow of the receiving stream is estimated to be zero, water quality based effluent
limitations will be assigned as follows:
(1) Where the 30Q2 flow is estimated to be greater than zero, effluent limitations for new or expanded
(additional) discharges of oxygen consuming waste will be set at BOD5= 5 mg/1, NH3-N = 2 mg/1 and DO
= 6 mg/1, unless it is determined that these limitations will not protect water quality standards.
Requirements for existing discharges will be determined on a case -by -case basis by the Director. More
NORTH CAROLINA ADMINISTRATIVE CODE 05/01/97
Page 8

EHNR - ENVIRONMENTAL MANAGEMENT T15A: 02B .0200
stringent limits will be applied in cases where violations of water quality standards are predicted to occur
for a new or expanded discharge with the limits set pursuant to this Rule, or where existing limits are
determined to be inadequate to protect water quality standards_ ~�,
(2) If the 30Q2 and 7Q10 flows are both estimated to be zero, no new or expanded (additional) discharge of
oxygen consuming waste will be allowed. Requirements for existing discharges to streams where the 30Q2
and 7Q10 flows are both estimated to be zero will be determined on a case -by -case basis.
(3) Other water quality standards will be protected by requiring the discharge to meet the standards unless the
alternative limitations are determined by the Director to protect the classified water uses.
(e) Receiving water flow statistics will be estimated through consultation with the U.S. Geological Survey.
Estimates for any given location may be based on actual flow data, modeling analyses, or other methods determined
to be appropriate by the Commission or its designee. •
History Note: Authority G.S. 143-214.1; 143-215.3 (a) (1);
Ef. February 1, 1976; •
Amended Eff. February 1, 1993; October 1, 1989; August 1, 1985; January 1, 1985.
.0207 MINIMUM ACCEPTABLE DEGREE OF TREATMENT
History Note: Authority G.S. 143-214.1;
Eff. February 1, 1976;
Repealed Eff September 9, 1979.
.0208 STANDARDS FOR TOXIC SUBSTANCES AND TEMPERATURE
(a) Toxic Substances. The concentration of toxic substances, either alone or in combination with other wastes, in
surface waters will not render waters injurious to aquatic life or wildlife, recreational activities, public health, or
impair the waters for any designated uses. Specific standards for toxic substances to protect freshwater and tidal
saltwater uses are listed in Rules .0211 and .0212 of this Section, respectively. Procedures for interpreting the
narrative standard for toxic substances and numerical standards applicable to all waters are as follows:
(1) Aquatic life standards. The concentration of toxic substances will not result in chronic toxicity. Any levels
in excess of the chronic value will be considered to result in chronic toxicity. In the absence of direct
measurements of chronic toxicity, the concentration of toxic substances will not exceed the concentration
specified by the fraction of the lowest LC50 value which predicts a no effect chronic level (as determined
by the use of acceptable acute/chronic ratios). If an acceptable acute/chronic ratio is not available, then that
toxic substance will not exceed one -one hundredth (0.01) of the lowest LC50 or if it is affirmatively
demonstrated that a toxic substance has a half-life of less than 96 hours the maximum concentration will
not exceed one -twentieth (0.05) of the lowest LC50.
(2) Human health standards. The concentration of toxic substances will not exceed the level necessary to
protect human health through exposure routes of fish (or shellfish) tissue consumption, water consumption,
or other route identified as appropriate for the water body.
(A) For non -carcinogens, these concentrations will be determined using a Reference Dose (RfD) as
published by the U.S. Environmental Protection Agency pursuant to Section 304(a) of the Federal
Water Pollution Control Act as amended or a RfD issued by the U.S. Environmental Protection
Agency as listed in the Integrated Risk Information System (IRIS) file or a RfD approved by the
Director after consultation with the State Health director. Water quality standards or criteria used
to calculate water quality based effluent limitations to protect human health through the different
exposure routes are determined as follows:
(i) Fish tissue consumption:
WQS = (RfD-DT) x Body Weight / (FCRxBCF)
where:
WQS = water quality standard or criteria;
RfD = reference dose;
DT = estimated non -fish dietary intake (when available); •
FCR = fish consumption rate (assumed to be 6.5 gm/person-day);
BCF = bioconcentration factor, or bioaccumulation factor (BAF), as appropriate.
BCF or BAF values are based on U.S. Environmental Protection Agency publications pursuant to Section 304(a)
of the Federal Water Pollution Control Act as amended, literature values, or site specific bioconcentration data
approved by the Commission or its designee; FCR values are average consumption rates for a 70 Kg adult for the
NORTH CAROLINA ADMINISTRATIVE CODE 05/01/97 Page 9

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
A7A
DENR
Transmitted via fax - 4 pages total
November 13,1997
MEMORANDUM
TO: Representative Cary Allred
Alamance County
FROM: Charles H. Weaver, Jr.
NPDES Unit
SUBJECT: Daniel McCollum
Representative Allred:
• This memorandum is in response to your telephone call on November 12, 1997. You and I have not spoken
previously. It's likely that Mr. McCollum gave you my name and telephone number, as I have discussed the
Bethany School discharge with him on at least two occasions.
• Mr. McCollum originally called the NPDES Unit to ask why Bethany School was relocating the outfall for
their wastewater discharge, and why county tax money was being spent to fund the relocation. I took his
call and subsequently pursued the information he requested.
• The permit file (NC0037001) showed that Bethany School had previously discharged into a zero -flow
stream. At the time of the most recent permit renewal, Rockingham County Scools (RCS) requested
expansion of the wastewater treatment capacity at the school to 10,000 gallons per day. In order to expand
the discharge, RCS was required to relocate the outfall from the Bethany School treatment works from a
zero -flow stream to a stream with positive flow. The permit was renewed and issued on June 9,1997. RCS
recently submitted a request for an Authorization to Construct (AtC) for the new outfall. Those plans are
currently being reviewed by one of our senior engineers, Mr. Steven D. Pellei. Mr. Pellei was also the
engineer who renewed the permit.
• As I explained to Mr. McCollum, RCS was required to relocate the outfall because of the explicit rule
concerning discharges to zero -flow streams. NCAC 15A: 02B.0206(d)(2) allows no new discharges to zero -
flow streams, and no expansion of existing discharges to zero -flow streams. Mr. McCollum said he had
"walked behind the school" and had not seen "any environmental damage". While I sympathized with
his comments, I explained that the zero -flow rule is explicit and leaves no room for interpretation. Mr.
McCollum then asked me to send him a copy of the zero -flow rule. He later called me back and asked for a
copy of the rules governing interbasin transfer. I sent these items to him on September 24,1997. A copy of
my letter to Mr. McCollum is attached to this memo, as well as a copy of the zero -flow rule.
• I'm puzzled by Mr. McCollum's question about the Division's intention to "close" Bethany School. RCS
renewed the permit and requested the AtC in order to upgrade Bethany School's wastewater treatment
facilities. Any plans to close the school have not been forwarded to or offered by the Division.
• I will be in a training meeting given by Mr. Pellei for most of this morning, and will get an update on the
status of the Bethany School AtC as soon as I can speak with him. I have meeting with the NPDES Unit
Supervisor, Mr. David Goodrich, scheduled for 2 p.m. today. I will discuss this matter with him also.
• Once I have collected the most current information on this project, I will call you back. If you have
additional questions, you can contact me via telephone, fax or e-mail (see below).
P.O. Box 29535, Raleigh, North Carolina 27626-0535 919 733-5083, extension 511 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer [e-mail]

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
September 24,1997
Mr. Daniel McCollum
1122 McCollum Road
Madison, North Carolina 27025
.A7‘7VA
C)EHN1=3.
Subject: NPDES Permit Guidelines
Zero -flow discharge restrictions
Bethany Elementary School
Permit No. NC0037001
Dear Mr. McCollum:
This letter is to follow up on our telephone conversation from last Friday. You asked me to send you a
copy of the statute which prohibits new discharges or expansion of existing discharges into zero -flow
receiving streams. This restriction is cited in the North Carolina Administrative Code, Title 15A: 02B.0206
(d)(2). A copy of the regulation is enclosed.
The restriction of discharges into zero -flow streams is a state law. The Division must abide by the
statute. Zero -flow streams are most likely to become threats to public health if discharges of wastewater
are continually expanded into them. The aesthetic quality of the receiving stream and the downstream
threats to human & animal life were also considered when this policy was developed.
The site you discussed with me (Bethany Elementary School), while seemingly posing no risk to the
surrounding environment, must abide by the same rules as all other dischargers into zero -flow streams. The
outfall for Bethany Elementary had to be relocated to accomodate the expanded flow from the school's
wastewater treatment system. Title 15A: 02B.0206 (d)(2) allowed no other solution.
If you have any other questions concerning this matter, please contact me at telephone number (919)
733-5083, extension 511.
Sincerely,
Cory
Charles H. Weaver, Jr.
cc: NPDES Unit
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

Page 1
Note for Charles Weaver
From: Steve Pellei
Date: Wed, Oct 8, 1997 9:25 AM
Subject: Tritech...
To: Nancy Owens
Cc: Charles Weaver
submitted $400 when they only needed to submit $150 for Bethany School ATC. I called
and informed them that I will return their check but they need to send in a check for $150
along with a letter from the BOE authorizing Tritech to act as their agent. The date we recieve
this $ will be the application received date.
Do you have a return letter shell for something like this?
Charles - just FYI in case you seee their check come in.
Thanks, Steve

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Av"7A
EDBNJF{
February 5, 1997
Mr. Van Moore & Mr. R. William Holcomb
Rockingham County Schools
511 Harrington Highway
Eden, North Carolina 27288
Subject: Request for Additional Information
NPDES Nos. NC0037001 & NC0036994
Bethany and Monroeton Schools
Rockingham County
Dear Mr. Moore and Mr. Holcomb:
The Division received your Engineering Economic Analyses of Wastewater Disposal Options for
Bethany and Monroeton Schools on December 20, 1996. As discussed in conversations with Mr.
Jesse Wilson and Mr. Max Frazier, the Division will require additional information in order to complete
our review. Please provide clarification or additional information on the following items.
General Comments:
Comments included below pertain to both Bethany and Monroeton Schools.
Estimated Waste Flow:
For Bethany, justification for the estimated waste flow of 10,000 GPD should be made. State
guidelines1 stipulate a typical daily flow for day schools at 10-15 GPD/student. Past water use records
will provide a more accurate record of per capita daily use. If you elect to use values significantly
different from those mentioned above, adequate justification for your decision must be provided. Plans
for future class expansion should be outlined and an estimated time line for expansion should be
included. Consequently, any wastewater treatment disposal alternatives should be sized accordingly to
accommodate the flow.
Connection to Regional Sewer:
Although connection to regional systems seems costly, please provide a cost estimate to connect any
regional systems within a five mile radius. The analysis of this option should investigate the possibility
of cost sharing with other potential users. Maps of the proposed routes should be submitted.
Subsurface Disposal System:
A soil scientist report, a site plan, a letter from a land owner indicating land cost, and an 0 & M cost
estimate were referenced but not included. Please provide these items.
As outlined in the Division's "Guidance for Evaluation of Wastewater Disposal Alternatives", the
analysis of subsurface and irrigation disposal systems must include a preliminary report from a soil
scientist. To adequately evaluate subsurface and irrigation disposal systems, an on -site soils analysis
needs to be performed and submitted. This evaluation should include:
• a copy of field notes and boring log information,
1NCAC 2H 0.0219 (copy attached)
P.O. Box 29535, Raleigh, North Carolina 27626-0535
An Equal Opportunity Affirmative Action Employer
Telephone [phone] FAX [phone]
50% recycled/ 10% post -consumer paper

Request for Additional Information
Rockingham County Schools
• a soils site map overlain on a topographic map,
• a description of soil characteristics to include texture, structure, soil wetness and mineralogy,
• a characterization of the depth of soil to 48" or to a restrictive horizon, and
• ✓soil loading rate recommendations.
The on -site soil survey should include enough soil borings to adequately characterize the site.
Additionally, justification should be provided on the number and location of soil borings completed.
Generalized county soil survey maps are not adequate for the evaluation, but may be used as a reference
tool to plan the field work required for evaluation.
In addition, provide information as to the amount of land which is available on -site and the number of
students and staff which could be served by an on -site system. Conventional and low pressure
disposal systems should be investigated. The use of a low pressure system may reduce land
requirements.
Spray Irrigation:
The evaluation of a spray irrigation disposal option should include components capable of treatment to
secondary limits and disinfection. Areas dedicated for reserve or repair are not required.
Documentation of the non -availability of land should be included.
Existing Treatment System:
Discuss the inadequacies, if any, of the existing treatment system components. Can these components
be used for treatment, pumping or storage in the various disposal alternatives, thereby reducing costs?
Discharge to Surface Waters:
Any treatment system must meet the requirements for dual path treatment facilities and on -site standby
power as stipulated in 2H .0124 (copy attached). In addition, all treatment systems must meet
minimum design criteria as outlined in the attached document, "The Authorization to Construct
Process".
Costs:
Unit prices should be referenced and operation and maintenance costs should be included. Sources of
your estimated land costs should be documented. A present value of costs analysis should be
performed on these options as outlined in the document, "Guidance for the Evaluation of Wastewater
Disposal Alternatives". Costs should include recurring 0 & M costs, operator costs, annual fees, and
lab analysis costs.
Please submit all additional information no later than March 15, 1997. If you have questions regarding
this matter, please contact me at [phone], ext. 516.
Serely
Steven D. Pellei, P.E.
Environmental Engineer
Attachment
cc: Central Files
Winston-Salem Regional Office, Water Quality Unit
Mr. Jesse W. Wilson, P.E.
Tritech Environmental, PC
P.O. Box 4127
Asheboro, North Carolina 27204
Steven Pellei, Permits and Engineering