NC0043974_approval_19960226

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
February 26, 1996
Cleveland M. Hawkins, Superintendent
Public Schools of Gates County
P.O. Box 123
Gatesville, North Carolina 27938
7:15.4A
LDF-1NI IR,
A)(G4e
02b
UJJ
Subject: Nutrient Variance Request
Buckland Elementary NPDES NC0043974
TS Cooper Elementary NPDES NC0033804
Sunbury Elementary NPDES NC0033791
Gatesville Elementary NPDES NC0033782
Gates County
Dear Mr. Hawkins:
Your request for a variance from the total phosphorous and nitrogen requirements of the Chowan
River Nutrient Sensitive Water (NSW) strategy adopted by the Environmental Management
Commission in December 1982 has been evaluated. In order to grant such a request, two
determinations must be made [per Chapter 15A North Carolina Administrative Code, Subchapter
2B, Section .0214(f)(2)]:
• that the waiver will not endanger human health, safety or welfare, and
• that preventing the waiver would cause a serious economic hardship without equal or greater
benefit to the public.
As per letter dated November 3, 1989, I concur that the volume of the discharge may be considered
deminimus. The mass of nutrient loading to the Chowan system from the schools on a yearly basis
also does not appear to be significant (approximately 100-200 pounds per year phosphorous and
1200-1800 pounds per year of nitrogen). Another mitigating factor is that these facilities typically
only discharge for eight months of the year and do not discharge during the summer months. Per
your letter, I also understand that the Gates County School System plans to install recirculating
sandfilter systems capable of achieving advanced pollutant removal for TS Cooper, Sunbury and
Gatesville Elementary schools. Given the above information, the determination that the discharges
will not endanger human health, safety or welfare is hereby made.
Staff have also reviewed the nondischarge evaluations performed by the Gates County School
System for the subject facilities and concurred that no economically practicable nondischarge
alternative was identified. Furthermore, per information you provided, the additional cost to
achieve the limits established in the NSW strategy would be as high as two to three times the capital
cost of installation of the recirculation sandfilter technology being proposed. Increased operation
costs would also be incurred. Therefore, after reviewing the information you have submitted, I
conclude that requiring compliance at the Gates County Buckland, TS cooper, Sunbury and
Gatesville Elementary School wastewater treatment systems with the Chowan River NSW strategy
requirements (1 mg/1 total phosphorous, 3 mg/1 total nitrogen) would cause a serious economic
hardship without an equal or greater benefit to the public.
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

I hereby grant to the Gates County School System for the wastewater treatment facilities for
Buckland, TS Cooper, Sunbury, and Galesville Elementary Schools a waiver of the total nitrogen
and phosphorous requirements as established in the Chowan River NSW strategy. Modifications to
the individual NPDES permits shall follow this letter.
In order to ensure that no increased nutrient input to the Chowan River from the Gates County
School wastewater treatment systems occurs, the school system must continually evaluate all
cleaning materials (detergents, cleaners, etc.) that end up in the wastewater treatment system. Only
those cleaning materials with no or very low concentrations of phosphorous and nitrogen should be
used.
If you have any questions, please contact Coleen H. Sullins at 919/733-5083, extension 550.
Sinceyely, 1
� Q
A. Preston Ho r .E.
cc: Roger Thorpe, Washington Regional Office
Facility Assessment Unit
Greg Thorpe
Ruth Swanek
Dave Goodrich
Central Files