NC0037371_Regional Office Historical File Pre 2018

Michael F. Easle , Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
June 23, 2008
Mr. Stephen A. Mauney, Director of Operations
Mooresville Graded School District
305 North Main Street
Mooresville, North Carolina 28115
Subject: Pump and Haul Permit Request
Coddle Creek Elementary School
Iredell County
Dear Mr. Mauney:
Coleen H. Sullins, Director
Division of Water Quality
This Office is in receipt of permit applications and supporting information dated June 18,
2008 for a pump and haul (P&H) permit to, serve the subject school. In your request, you stated that
a P&H permit was needed to allow up to 15 staff members to begin set-up of the school prior to
permanent sewer service becoming available. Staff with this Office has completed a preliminary
review of this application and our comments are listed below.
1 Pursuant to 15A NCAC 02T .0204(a), P&H permits are only to be issued to facilities in the
case of environmental emergencies, nuisance conditions (odors, vectors), health problems,
and/or for unavoidable delays in construction of systems previously permitted under this
Section. The failure of the local municipality to provide sewer service by a predetermined
date, which may ultimately result in occupancy delays is an example of a unique situation,
and would also be of sufficient merit to warrant issuance of a P&H permit. P&H Permits,
however, are not intended to allow the use of wastewater collection/disposal facilities or
commercial/residential development prior to the date that sewer service is to be available to
serve the project or the date by which permanent wastewater disposal facilities are expected
to be operational.
Based on our review of the information supplied in your application, sufficient justification
as to why this Office should issue a P&H permit has not been provided. If the subject school were
scheduled to open in August 2008, proper planning would have ascertained the need to have
permanent sewer service available prior to the opening date so staff could begin school preparation.
Furthermore, there is no mention in your request as to any unavoidable delays experienced by the
Town in the construction of the permanent sewer line or why portable toilet facilities cannot be used
until such time as the construction of the sewer line to serve this facility is completed and
operational.
e;1.4
NCDENR
NorthCarolina
Naturally
Mooresville Regional Office Division of Water Quality Phone [phone] Customer Service
Internet: www.ncwaterguality.org 610 East Center Ave, Suite 301 Mooresville, NC 28115 Fax [phone]
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Mr. Stephen Mauney
June 23, 2008
Page Two
If you have any additional information that you feel would provide the necessary
justification for P&H permit issuance, please submit same to this Office by no later than July 3,
2008 so that it can be reviewed in conjunction with your application. If, in the absence of additional
information, you no longer desire the issuance of a P&H permit, you may request that your
application package (along with the processing fee) be returned.
If you have any questions regarding this matter, please contact Mr. Michael L. Parker or me
[phone].
Sincerely,
Robert B. Krebs
Regional Supervisor
Surface Water Protection
cc: J. Michael Frye, P.E.
/mlp

Michael F. Easley, Governor
a
�OF W A 11z9Q
O G
Dr. Kenny Miller, Ed. D.
Iredell-Statesville Schools
P.O. Box 911
Statesville, NC 28687-0911
Dear Dr. Miller:
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources .
Coleeor
c
RIPM
ivis' `f W r lity
January 18, 2008
J A N 2 4 2008
NC DENR MRO
DWQ jA rface eater Protection
Subject: Speculative Limits for Coddle Creek Elementary School
Iredell County
This letter is in response to the request for speculative effluent limits for the proposed
Coddle Creek Elementary School WWTP. The proposed design flow is 0.0.13 MGD with the
potential for expansion to 0.026 MGD. Mr. Greg J. Wells of Willis Engineers submitted this
request to our office on behalf of Iredell-Statesville Schools.
Receiving Stream. The Coddle Creek Elementary School WWTP proposes to discharge
domestic wastewater into West Branch Rocky River. It is classified as a C waterbody in the
Yadkin River Basin. The best usage of these waters includes aquatic life propagation and
maintenance of biological integrity, wildlife, _ secondary recreation and agriculture. The
WWTP discharge point has an estimated drainage area of 7.2 square miles, with an average
flow of 7.6 cfs; a summer 7Q 10 flow of 0.7 cfs and a winter 7Q 10 flow of 1.4 cfs.
The West Branch Rocky River is a tributary stream in the Upper Rocky River watershed. The
current water quality management strategy for new and expanding dischargers requires
meeting the best available technology "limits for BOD5'and ammonia.
Speculative Limits. Based on available information, speculative effluent limits for the
proposed wasteflows of ,0.013 and 0.026 MGD to West Branch Rocky River are presented in
Table 1. A complete evaluation of these limits and monitoring frequencies will be addressed
upon receipt of a formal NPDES permit request.,
Enoineerin;� Alternatives Analysis (EM. Please note that the Division cannot guarantee that
an NPDES permit will be issued with these speculative limits. Final decisions can only be
made after the Division receives and evaluates a formal permit application for the' Coddle
Creek Elementary School's proposed discharge. In accordance with the North Carolina.
General Statutes, the practicable wastewater treatment and disposal alternative with the
least adverse impact on the environment is required to be implemented. Therefore, as a
component of all NPDES permit applications for new or expanding flow, a detailed
engineering alternatives analysis (EAA) must be prepared. 'The EAA must justify requested
flows, and provide an analysis of potential wastewater treatment alternatives. Alternatives to
NpaCarolina
Natur,74
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet: www.ncwaterquality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax [phone]
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Letter to Dr. Kenny Miller
Page 2
a surface water discharge, such as spray/drip irrigation,: wastewater reuse, or
-inflow/infiltration reduction, are considered to be environmentally preferable. A copy of the
EAA,guidance document is attached to this letter. Permit, applications for new or
expanding flow will be returned as incomplete if all EAA requirements are not
adequately addressed. If you have any questions regarding these requirements, please
contact the DWQ NPDES Program at 919-733-5083.
The fee schedule for NPDES permits has changed as of September 1, 2007.. Application fees
for a minor individual NPDES permit will be $860 should the Iredell-Statesville Schools
pursue this discharge. If you have any questions about. these speculative limits or NPDES
permitting requirements, please feel free to contact Jackie Nowell at (919) - 733-5083,
extension 512.
Respectfully,
Zuk(�.A. Wilson, P.E.
Supervisor, Western 'NPDES Program
Attachments
cc: Gene J. Wells; P.E./Willis Engineers, 1520 South Boulevard, Charlotte, N.C. 28203
Mooresville Regional Q /Surface Water Protection Supervisor
Central Files

Letter to Dr. Kenny Miller
-Page 3
Table 1. Speculative Limitations for Coddle Creek Elementary School WWTp

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 919-733-5083. Application forms,
applicable fees, and guidance documents are available on the NPDES website at
httn:/AZo.enr.state nc us/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 FAA 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 FAA 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 FAA submission
lacks any of these basic elements, .the NPDES application will be returned as incomplete.
EAA Guidance Document Version: October 14, 2004
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 class waters have various
discharge restrictions or require stricter treatment standards]. Stream classifications are available on the
DWQ website and from the DWQ Standards & Classifications Unit at 919-733-5083, 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 919-733-5083.
■ Impaired waters and TAMLs. 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 919-733-5083.
■ 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 byth.e
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. 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: October 14, 2004
Page 2 of 8

All applicants.
If you conclude that the proposed discharge will pass, the "allowable discharge" criteria, then begin the FAA
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://u'v'u'.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 clearly 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 htip://www.nccgI-net/fal2/cwsrfZ20lgLij.htm. Exceptions to these flow criteria
may be approved on a case -by -case basis provided adequate justification is supplied.
■ Current Flow- Provide current flows including 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 clearly 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: October 14, 2004
Page 3 of 8

treatment plant filter backwash, industrial facilities), the flow projections will be based on engineering design
considerations and/or production projections rattier 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, infiltration galleries (for groundwater remediation discharges)
• 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 WrPs 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, and infiltration galleries 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
EAA Guidance Document Version: October 14, 2004
Page 4 of 8

that have accepted this wastestream in the past. If the municipality will not accept the wastestream, the
connection alternative is also considered technologically infeasible.
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 S stem.
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 WWTPs
under consideration for connection. If a municipal or private V W\ P cannot accept the wastewater,
include 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.
Include 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 be used by a third party.
5. Conduct a Present Value Cost Analysis per STEP 4. For the reclaimed water system include the
potential revenue generated by selling the water.
6. Provide all calculations, documentation and maps as necessary to support assumptions and conclusions..
7. Note: The design of land application systems must meet the treatment and design requirements specified
in 15A NCAC 211.0219 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: October 14, 2004
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 213.0206(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 included 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/l, NH3-N= 1 mg/1] 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: October 14, 2004
Page 6 of $

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:
PV = C + Y Ct
0
Where: t=1 (1 + r)t
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:
PV=C + (I+r)"-11
r(l+ ry 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
PV $2,000,000 + $40,000 X
PV= $2,000,000 + $471,428
PV=_ $2,471,428
PVCA Summary Table.
[(1+0.05625)20-1] / [0.05625(1+0.05625)20]
[1.98/0.168]
The EAA must include a Summary Cost Table, which summarizes present worth costs developed for -all technologically
feasible wastewater. alternatives. The'summary should include 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: October 14, 2004
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. Themnitten 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) fails) 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/CountyManager)
S tate
County of
On this day of , , personally appeared before me, the said
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: October 14, 2004
Page 8of8

Speculative Limits request
Iredell-Statesville Schools - Coddle Creek Elementary School (proposed)
mn
West Branch -Rocky River C
030711 (HUC 03040105)
Iredell County
Iredell-Statesville Schools is requesting spec limits for a proposed elementary
school that will discharge into West Branch Rocky River. The proposed design
flow is 0.013 MGD with the possibility of future expansion to 0.026 MGD.
Wastewater will be 100% domestic.
Receiving Stream
The proposed discharge point in the West Branch Rocky River is just below
where State Road 1138 crosses the stream. The Basinwide Assessment Report of
the Yadkin -Pee Dee River"Basin, indicated that the stream is not impaired. It was
sampled upsteam at SR1136 in May 2002.
Nearby dischargers: NCO079774 - Davidson Downes Subdivision. Facility not
yet built. Qw= 0.060 MGD. Permitted limits 5/2/5 (summer) and 10/4/5
(winter). Letter in file dated March 2000 - Town of Mooresville in unwilling to
accept ww from Davidson Downes Subdivision. Therefore permit was renewed
in April 200O and April 2004.
The Coddle Creek School would discharge about 200 feet downstream of the
proposed Davidson Downes Subdivision.
Note: Another nearby discharger on West Branch Rocky River, River Run
Country Club WWTP (Mecklenburg County)(, rescinded its permit in 2005 and
connected to CMUD. -per BIMS review 1 /4/2008
Will use the DA and flows from Davidson Downes for the Coddle Creek School.
Estimated drainage area = 7.2 square miles,
Average flow of 7.6 cfs;
Summer 7Q1O flow of 0.7 cfs
Winter 7Q10 flow of 1.4 cfs.
Recommended Effluent Limits
Based on previous DWQ recommendations for the Upper Rocky River
watershed, best available technology limits have been given to new and
expanding dischargers. Limits of 5/2/5 and 10/4/5 were given to Davidson
Downes and should be given to Coddle Creek Elementary. It is recommended
that Iredell-Statesville School look at connection to City of Mooresville. Last

correspondence from Mooresville in 2000 indicated that they would riot accept
wastewater from this part of the county, however City is looking at new WWTP
and may now be willing to -accept the ww. CMU did accept ww from River Run
CC located on this stream, However River Run was located in Mecklenburg Co.
J

O�O� W AT FRQG
7
� r
o �
5439
Mr. Dennis Gryder
Iredell Statesville Schools
1147 Salisbury Rd.
Statesville, NC 28625-
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
December 15, 2006
SUBJECT: Wastewater/Groundwater Laboratory Certification Renewal
Field Parameters Only
Dear Mr. Gryder:
Alan W. K��1gqrMek-R.E,Directok I-v&4*o
19I�a Wateerr Quality�4 CES
AL OFFICE
0�
DEC 1 9 200'
The Department of Environment and Natural Resources, in accordance. with the
provisions of NC GS 143-215-.3 (a) (10), 15 NCAC 2H .0800, is pleased to renew
certification for your laboratory to perform specified environmental analyses required by
EMC monitoring and reporting regulations 15 NCAC 2B .0500, 2H .0900 and 2L .0100,
.0200, .0300, and 2N .0100 through .0800.
Enclosed for your use is a certificate describing the requirements and limits of your
certification. Please review this certificate to insure that your laboratory is certified for all
parameters required to properly meet your certification needs.
Please contact us at 919-733-3908 if you have questions or need additional
information.
Sincerely,
Pat Donnelly
Branch Manager
Enclosure
cc: Chet Whiting
Mooresville Regional Office
Nort hCarolina
latura!!il
Laboratory Section 1623 Mail Service Center Raleigh, NC 27699-1623 Phone [phone] Customer Service
Internet: w%vW.dwolab.or5 Location: 4405 Reedy Creak Road Raleigh. NC 27607 Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

STATE OF NORTH CAROLINA DEPARTMENT OF THE
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
LABORATORY CERTIFICATION PROGRAM
In accordance with the provisions of N.C.G.S. 143-215.3 (a) (1), 143-215.3 (a)(10) and NCAC 2H.0800:
Field Parameter Only
J
M^Y 10 r7is
LLJ
~I C
�PttL I2
.171
'
QL1AM
IREDELL STATESVILLE SCHOOLS
Is hereby certified to perform environmental analysis as listed on Attachment I and report monitoring data to DWQ for
compliance with NPDES effluent surface water, groundwater, and pretreatment regulations.
By reference 15A NCAC 2H .0800 is made a part of this certificate.
This certificate does not guarantee validity of data generated, but indicates the methodology, equipment, quality control procedures,
records, and proficiency of the laboratory have been examined and found to be acceptable.
This certificate shall be valid until December 31, 2007
Certificate No. 5439
�LZ
Pat Donnelly

•
Attachment
North Carolina Wastewater/Groundwater Laboratory Certification
Certified Parameters Listing
FIELD PARAMETERS ONLY
.ab Name: Iredell Statesville Schools Certificate Number: 5439
address: 1147 Salisbury Rd. Effective Date: 01/01/2007
Statesville, NC 28625- Expiration Date: 12/31/2007
Date of Last Amendment:
he above named laboratory, having duly met the requirements of 15A NCAC 21-1.0800, is hereby certified for the measurement of the parameters listed below
CERTIFIED PARAMETERS I
NORGANICS
ZESIDUAL CHLORINE
Sid Method 4500 Cl G
iH
Std Method 4500 H B
his certification requires maintance of an acceptable quality assurance program, use of approved methodology, and satisfactory performance on evaluation samples. Laboratories are
ubject to civil penalties and/or decertification for infractions as set forth in 15A NCAC 21-1.0807.

;sac EP7
WIIIISENGINEERS
November 15, 2001
NOV 1 6 2001
Ms. Kristin Miguez
NCDENR — Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699
912.101 (34)
Subject: Permit Number WQ0018831
Town of Mooresville
Lake Norman High School Wastewater collection System Extension
Iredell County
Dear Ms. Miguez:
As requested, we are resubmitting our certification and documentation for the subject
project in accordance with the requirements set forth in the new "fast track" permit
process. Please find attached the last page of the Permit executed by Charles A. Willis,
one copy of the Design Calculations and Construction Record, and one set of sealed
Record Drawings. If you have any questions or need any additional information, please
feel free to call me at 704.338.4668.
Yours very truly,
WILLIS ENGINEERS
Charles A. Willis, Jr., P.E.
CAWjr/kcl
cc: Mr. Richard A. McLean, Town Manager
Mr. H. Carson Fisher, P.E., Town Engineer
Mr. Glenn A. Shuler, Director of Utilities
Iredell County Health Department
Aooresville Regional Office, Water Quality Section
1520 South Boulevard
Charlotte, North Carolina 28203
704/377-9844 • FAX [phone]

r
Iredell-Statesville Schools
Maintenance Department
1147 Salisbury Road, Statesville, NC 28677, Phone [phone], Fax: [phone]
Date: July 30, 2001
Dear Permit Issuing Authority,
I, Harold D. Beaver do hereby give signature authority to Dent Gryder, Waste Water
Treatment Plant Supervisor. Mr Gryder will be offically named by the Board of Education
at the August, 2001 Board meeting and will continue in that capacity while employed by
the Iredell-Statesville Schools.
NC DEPT. . OF 7-y -: '" ", NT
AND tiwjnj 'ES
AUG 1 3 2001
Sincerely
Harold D. Beaver
N
® 4$ - SM

State of North Carolina'
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T.- Stevens, Director
Don Atkinson
Construction Manager
Iredell-Statesville Schools
P.O. Box 911
Statesville, NC 28677
Dear Mr. Atkinson:
J„
f�
NCDENR
August 19, 1999
. D
+`n58
Subject: Authorization to Construct
Permit No. NCO037371
ATC No. 037371ACB
North High School WWTP
Iredell County
The Division received a letter of request for an Authorization to Construct (ATC) June 25, 1999 and final
plans and specifications for this project have been reviewed and found to be satisfactory. Authorization is hereby
granted for the construction/ alteration of the wastewater treatment facility discharging into Patterson Creek in
the Yadkin -Pee Dee River Basin. The wastewater treatment plant serves the North High School and is permitted
at a flow of 0.0125 MGD (monthly average); this authorization to construct permit does not alter the currently
permitted flow of 0.0125 MGD., The permit allows the following:
alterations to the existing flow distribution box in the equalization basin;
• installation of new return activated sludge pumps (2, '/2 Hp submersible pumps at 9-10 gpm) along with
piping modifications,
• installation of a tertiary filtration system (2 cells at 16 x 16" each, with 2 feed pumps and 1 backup rated
at 7.3 gpm each),
and all associated piping and appurtenances.
After completion of construction, access to the treatment site and equipment must be restricted (via a fence
or other means, ref. 15A NCAC 2H .0219).
Once construction under this ATC has been completed and an Engineer's Certificate has-been submitted,
the permittee is authorized to operate with the above approved -design components. At no time shall flow exceed
the permit limit of 0.0125 MGD (unless approved by the Division).
This Authorization to Construct is issued in accordance with Part III, Paragraph A of. NPDES Permit No.
NCO037371 issued August 31; 1994, and shall be subject to revocation unless the wastewater treatment facilities
are constructed in accordance with the conditions and limitations specified in the permit.
1617 Mail Service Center, Raleigh, North -Car olina 27699-1617 Telephone [phone]/FAX [phone]
An Equal Opportunity Affirmative Action Employer susan_wilson®h2o.enr.state.nc.us

Permit No. NC0037371
ATC No. 037371ACB
North Iredell High School WWTP
i The sludge generated from the treatment facility must be disposed of in accordance with G.S. 143-215.1
and in a manner approved by the North Carolina Division of Water Quality.
In the event that the facility fails to perform satisfactorily, including the creation of nuisance conditions,
the Permittee shall take immediate corrective action, including those as may be required by this Division, such as
the construction of additional or replacement wastewater treatment or disposal facilities.
The Mooresville Regional Office, telephone number (704) 663 - 1699, shall be notified at least forty-
eight (48) hours in advance of operation of the installed facilities so that an in -place inspection can be made.
Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m. until
5:00 p.m. on Monday through Friday, excluding State Holidays.
Upon classification of the facility by the Certification Commission, the Permittee shall employ a certified
water pollution control treatment system operator to be in responsible charge (ORC) of the water pollution
control treatment system. The operator must hold a certificate of the type and grade at least equivalent to or
greater than the classification assigned to the water pollution control treatment system by the Certification
Commission. The Permittee must also employ a certified back-up operator of the appropriate type and grade to
comply with the conditions of.Title 15A, Chapter 8G, .0202. The ORC of the facility must visit each Class I
facility at least weekly and each Class II, III, and.IV facility at least daily, excluding weekends and holidays, and
must properly manage and document daily operation and maintenance of the facility and must comply with all
other conditions outlined in Title 15A, Chapter 8G, .0204. Once the facility is classified, the Permittee must
submit a letter to the Certification Commission which designates the operator in responsible charge within: (A)
Sixty calendar days prior to wastewater being introduced into a new system or (B) within 120 calendar days of
the following, (i) after receiving notification' of a change in the classification of the system requiring the
designation of a new ORC and back-up ORC or (ii) a vacancy in the position of ORC or back-up ORC.
A copy of the approved plans and specifications shall be maintained on file by the Permittee for the life
of the facility.
The Operational Agreement between the Permittee and the Environmental Management Commission is
incorporated herein by reference and is a condition of this Permit. Noncompliance with the terms of the
Operational Agreement shall subject the Permittee to all sanctions provided by G. S. 143-215.6 for violation of or
failure to act in accordance with the terms and conditions of this Permit.
Failure to abide by the requirements contained in this Authorization to Construct may subject the
Permittee to an enforcement action by the Division of Water Quality in accordance with North Carolina General
Statute 143-215.6A to 143-215.6C.
The issuance of this Authorization to Construct does not preclude the Permittee from complying with any
and all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local,
state, and federal) which have jurisdiction.
Upon completion of construction and prior to operation of this permitted facility, a certification must be
received from a professional engineer certifying that the permitted facility has been installed in accordance with
the NNPDES Permit, this Authorization to Construct and the approved plans and specifications. Mail the
Certification to the NPDES Unit, 1617 Mail Service Center, Raleigh, NC 27699-1617.

Permit No. NC0037371
ATC No. 037371ACB
North Iredell High School WWTP
One (1) set of approved plans and specifications is being forwarded to you. If you have any questions or
need additional information, please contact Ms. Susan A. Wilson, telephone number [phone], extension
510.
Sincerely,
Kerr T. Stevens
cc: Central Files
NPDES Unit, Permit File
TechnicalAssistance and Certification Unit
Mooresville Regional Office, Water.Quality/ Rex Gle_ aso_ i i
Ivan Cooper, P.E. Cooper Environmental, Inc.
2300 Sardis.Road North, Suite Q
Charlotte, NC 28227

i
RECEIVE`
rdhW!QN DE ENVIRONMENTAL MAIL uV L 111 � . ^ ^"
4y
State of North Carolina
OR SVILLE
Department dal Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
S. Thomas Rhodes, Secretary July 13, 1.988
Mr. Franklin D. Ivey, Associate Superintendent
Iredell County Board of Education
P.O. Box 709
Statesville, NC 28677
SUBJECT: Permit No. 16509
Iredell County Schools
Mount Mourne Elementary School
Sewer Extension
Iredell County
Dear Mr.. Ivey:
R. Paul Wilms
Director
In accordance with your application received June 13, 1988, forwarding
herewith Permit- No. 16509, dated July 13, 1988, to Iredell. County Schools for the
cons t.ructi.on. and operation of the subject wastewat.e.r col.leclJon. system extensions.
This permit shall. be effective from the date of issuance rrn:t:i.l resc:i_n.ded., and
:,hall_ be subject to the conditions and limitations as specified therein.
If any part-s, requirements, or limitations contained in this- permit are
unacceptable to you, you have the right to request: an a.djud.icato.ry hearing upon
w.ritt:en .re -quest within 30 days following receipt of this pe.rrni.L. This reqi-lest: must
be in the form of a written petition, conforming to Chapter 1.50B of North Carolina
General Statutes, and filed with the Office of Administrative Hearings, Post Office
Drawer 1.1666, 'Raleigh, North Carolina. 27604. Unless stich demands are. made th:ts
permit sh.a.11. be final and binding.
One (1) set of approved plans and Sp(cif-:i.cations is being Forwarded to you. If:
you need.addittional information concerning this matter., please contact Ms. Rosanne
Baron.a, telephone No. 919/733-5083, ext. 545.
Sinc're.y,
Pau . ms 7
cc: Iredell Coi.inty Health Depa.rt:ment / ^
Mooresville Regional Supervisor. ✓
Willis Engineers
Dennis R. Ramsey
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT
RALEIGH
PERM I
For the.discharge of Sewage, Industrial Wastes, or Other Wastes
In accordance with the provisions of Article 21 of Chapter. 143, General Statutes
of North Carolina. as amended, and other applicable Laws, Rules, Gild Regulations
PERMISSION IS HEREBY GRANTED TO
Iredell County Schools
Iredell County
FOR THE
construction and operation of approximately 1,004 linear feet of 9--inch and 8,294
li.nea.r feet- of 12-inch gravity sewers to serve Mount Mourne Elemel.ita.xy? School and the
discharge of the collected domestic wastewater into the Town of Mooresvi.11e's
existing sewerage system, pursuant to the application received June 13, 1988, and in
conformity with the project p1.an, specifications, and other supporting data
subsequently filed and approved by the Department of Natur_a.1. Resources and. Community
Development and considered a part of this permit.
This permit shall be effective from the date of issuance until. rescinded, and
shall be subject to the following specified conditions and limitations:
1.. This permit shall become voidable unless the facilities are constructed in
accordance with the approved plans, specifications and other supporting data.
2. This permit is effective only with respect to the nature .and volume of wastes
described in the application and other supporting data.
3. The .facilities shall be properly maintained and operated at all times.
4. The sewage and wastewater collected by this system shall be treated in the Rocky
River Wastewater Treatment Plant prior to being discharged into the receiving
stream.
5. This permit is not transferable.
6. Construction of the sewers_ shall be so scheduled so as not: to interrupt service
by the existing utilities nor result in an overflow or bypass discharge of
wastewater to the surface waters of the State.

s
' 7. Upon completion of construction and prior to operation of this permitted
facility, a certification must be received. from a professional engineer
certifying that the permitted facility has been installed -in accordance with the
approved plans and specifications. Mail. the certification to the Permits and
Engineering Unit, P.O. Box 27687, Raleigh, N.C. 27611-7687.
8. A copy of the approved plans and specifications shall be. maintained on file by
the pe.rmi_ttee for a. minimum of five years from the date of issuance.
9. This permit shall become voidable unless the agreement between Town of
Mooresville and Iredell County Schools for the collection and final. treatment of
wastewater is in full. force and effect.
Permit issued this the 13th day of July, 1988.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
. Paul Wilms, Director
Division of Environmental. Management
By Authority of the Environmental Management Commission
Permit No. 16509
Engineer's Certification
I , as a duly registered Professional., Engineer in the
State of North Carolina, hereby certify that constructionof these permitted
facilities has been completed in accordance with the approved plans and
speci f ications .
Signature Registration Number__ Date