NC0078271_Speculative Limits_20010223

NPDES DOCUHENT :MCANNINO COVER SHEET
NPDES Permit:
NC0078271
Betsy -Jeff Penn 4-H Educational Center
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Site Plan
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
February 23, 2001
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content on the rezrerse side

•
�yq TF Michael F. Easley
�0 9Q ��A Governor
p G - .'�► William G. Ross, Jr., Secretary
r NCDENR North Carolina Department of Environment and Natural Resources
> -1 Kerr T. Stevens, Director
0 'C Division of Water Quality
February 23, 2001
Ms. Clare -Marie Hannon
Betsy Jeff -Penn 4-H Educational Center
804 Cedar Lane
Reidsville, North Carolina 27320
Subject: Speculative Effluent Limits for Betsy Jeff -
Penn 4-H Educational Center
NPDES Permit No. NCOO78271
Rockingham County
Dear Ms. Hannon:
This letter is in response to the request of Ms. Larissa M. Coles of Moretz Engineering
for speculative effluent limits for the wastewater treatment system at Betsy Jeff -Penn 4-H
Camp in Reidsville. The staff of the NPDES Unit of the Division of Water Quality (Division) has
prepared a response to your request for speculative limits for a proposed expansion to 15,000
gallons per day.
Please be advised that response to a speculative request does not guarantee that the
Division will issue an NPDES permit to discharge treated wastewater. In accordance with the
North Carolina General Statues, the practicable waste treatment and disposal alternative -with
the least adverse impact on the environment is required to be implemented. Non -discharge
alternatives, such as spray irrigation or connection to a regional treatment and disposal
system, are considered to be environmentally preferable to a discharge. Therefore, prior to
submittal of an NPDES application, a detailed alternatives analysis must be prepared to assure
that the environmentally sound alternative was selected from the reasonable cost effective
options. Attached is a guidance document that will assist you or your consultant in preparing
an engineering alternatives analysis.
Based on the available information, tentative limits for the proposed discharge to Carroll
Creek at 15,000 gpd are attached. The limits are based on streamflows calculated based upon
regional equations listed in the USGS document Low Flow Characteristics of Streams in North
Carolina. The following flow calculations were made:
Average Flow
3.59 cfs
Summer 7Qio
0.40 cfs
Winter 7Q io
0.55 cfs
This information was used in conjunction with the proposed effluent characteristics to
develop tentative limits. Please be advised that the limits and monitoring frequencies on the
following page were based on the information presented in the speculative limits request. A
complete evaluation of these limits and monitoring frequencies in addition to monitoring
requirements for metals and other toxicants will be addressed upon receipt of a formal NPDES
permit application.
A water quality model of the proposed discharge indicated that it would not cause a
violation of the instream dissolved oxygen standard of 5 mg/ L. Your facility has therefore been
given secondary treatment limits for BOD5 and Total Suspended Residue. Based upon the
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
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summer 7Q10 listed above, the instream waste concentration for this facility is 5.51. Effluent
limits are based upon this concentration; the only parameter whose limit was affected by this
change is ammonia nitrogen (NH3-N). Please note that the following are monthly average limits
for the effluent characteristics listed:
Summer
Winter
BODs
Total Suspended Residue
Dissolved Oxygen
NH3-N
Fecal Coliform
30 mg/L
30 mg/L
5.0 mg/L
14.4 mg/L
200/100 mL
30 mg/L
30 mg/L
5.0 mg/L
Monitor only
200/100 mL
When performing the Engineering Alternatives Analysis, you may contact Natalie Sierra
at [phone] for potential monitoring frequencies.
In response to your recent request to remove the Total Residual Chlorine limit from your
permit, we recommend that you first identify the source of the chlorine in your influent. From
the conditions that you describe, the effluent from your facility has the potential to violate the
instream chlorine standard for protection of aquatic life; the limit can therefore not be removed
from the permit at this time. Any questions or requests for additional information may also be
directed to Ms. Sierra.
Sincerely,
David A. Goodrich
Supervisor, NPDES Unit
Water Quality Section
cc: Winston-Salem Regional Office/Water Quality Section
Central Files
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GUIDANCE FOR EVALUATION OF WASTEWATER DISPOSAL ALTERNATIVES
Proposed Discharge
I. General Information
A. Provide the following:
• Facility name
• County
• Facility address
• Engineering Alternatives Analysis (EAA) preparer's name
• EAA preparer's North Carolina P.E. certification number
• EAA preparer's mailing address and telephone number
B. Provide a detailed description of the proposed discharge facilities (include a diagram
indicating the plant components and processes)
C. Describe the project served by the WWTP (i.e. school, subdivision, number of students
or households, total waste contribution calculated according to 15 NCAC 2H.0219 (1),
etc.)
D. Indicate if it is a phased development and provide the estimated wasteflow per phase
(indicate current phase status for existing facilities)
II. Evaluation of Environmental Feasibility of Discharge Alternatives
A. Evaluate the environmental feasibility of all three of the following non -discharge
alternatives.
1. Connection to Sewerage System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit).
a. Existing Sewerage System: Indicate distance to an existing.. sewer line within a
five -mile radius (radius extension should be considered if cost effective as it
relates to project size). If there are not available sewer lines in the vicinity note
this and proceed to entry 1(b) below.
(1) Provide description of sewer facilities necessary to connect to a wastewater treatment
plant (WWTP).
(2) Provide preliminary indication of flow acceptance from municipal or private WWTP
under consideration for connection (documentation should include NPDES permit
number and county of the accepting WWTP). If a municipal or private WWTP cannot
accept the wastewater, please explain.
(3) Indicate if third party agreements or easements would be necessary.
(4) Attach a topographic map and a site drawing showing the physical aspects of this
alternative (proximity to sewer system, route for sewer line, property difficulties, etc.)
(5) Proceed to Alternative II. A (2) - Subsurface Disposal Systems.
b. Planned Sewerage System: Determine if a regional sewerage system within a
five -mile radius is projected to be available within the next five years. Determine
availability date and flow acceptance projection with appropriate regulatory
authority. Identify the person at the public utility or private management group
that assisted you in this determination. If a sewer line will be available for
connection within the next five years, entry (1) (a) should be evaluated.
2. Subsurface Disposal System (Installation of nitrification systems, low pressure pipe
systems and mound systems)
Note: Subsurface disposal systems (low-pressure systems and nitrification systems) are
only permitted by DWQ for the following types of facilities: city -owned facilities, county -owned
facilities, public utility facilities and industrial facilities with an industrial wastewater
component. Other categories of facilities (including mobile home parks, homeowner
associations, nursing homes, industrial facilities with 100% domestic waste, etc.) are
permitted by county health departments. Any facility in the latter category must obtain a
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GUIDANCE FOR EVALUATION OF WASTEWATER DISPOSAL ALTERNATIVES
Proposed Discharge
statement from the relevant County Health Department concerning suitability/unsuitability
of soils for subsurface systems.
a. Determine if permittee currently owns land that is available and suitable for a
ground absorption system.
(1) Provide a preliminary report from a soil scientist with a loading rate recommendation
based on soil type.
(2) Provide calculations to determine land size requirements based on design and
loading rate characteristics. Note: Disposal systems require 100% reserve area.
(3) Indicate if all buffer zone requirements are met according to 15 NCAC 2H.0219 (j).
Provide a site plan indicating proposed layout of subsurface system.
(4) If there is sufficient usable land, consider the existing project development plan and
those modifications to the plan (reducing the number of units produced, reduction of
design flow, etc.) necessary to allow for adequate usable land on the site.
(5) If there is insufficient usable land on the project site, proceed to entry 2 (b) below, if
applicable. Otherwise, proceed to Alternative II A (3) - Spray Irrigation Systems.
b. Determine if adjacent land could be acquired through purchase or permanent
easement. Provide documentation of availability. If adjacent land could be
acquired, evaluate according to entry 2 (a).
3. Spray Irrigation System
a. Determine if permittee currently owns land that is available and suitable for a
spray irrigation system.
(1) Provide a preliminary report from a soil scientist with a loading rate recommendation
based on soil type.
(2) Provide calculations to determine land size requirements based on design and
loading rate characteristics.
(3) Indicate if all buffer zone requirements are met according to 15 NCAC 2H.0219 (j).
Provide a site plan indicating proposed layout of spray irrigation system.
(4) If there is sufficient usable land, consider the existing project development plan and
those modifications to the plan (reducing the number of units produced, reduction of
design flow, etc.) necessary to allow for adequate usable land on the site.
(5) If there is insufficient usable land on the project site, refer to entry 3 (b) if applicable.
Otherwise, proceed to Section II B.
b. Determine if adjacent land could be acquired through purchase or permanent
easement. Provide documentation of availability. If adjacent land could be
acquired, evaluate according to entry 3 (a) immediately above.
B. Review the data collected to this point before making further determinations.
1. If one or more of the non -discharge alternatives were found to be environmentally
feasible, select one and notify DWQ that the alternative will be undertaken in lieu of
submitting the NPDES application. If a non -discharge application is selected, the
rest of the EAA is not required.
2. If one or more of the non -discharge alternatives were found to be environmentally
feasible, but the permit applicant does not wish to select one because doing so
would be unreasonably costly, cost estimates prepared according to Section III of
this Guidance Document must be submitted to DWQ. Proceed to Section II.C.
3. If none of the non -discharge alternatives were found environmentally feasible,
proceed to Section II.C.
C. Evaluate the environmental feasibility of the discharge to a flowing stream (defined as a
stream with 7Q 10/ 30Q2>0 cfs flows).
NOTE: This section of the EAA is not necessary unless the non -discharge alternatives
evaluated in Section ILA. were found to be environmentally infeasible, or if one or more of the
alternatives were found environmentally feasible but the permit applicant claims that
selecting any of the environmentally feasible alternatives would be unreasonably costly.
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GUIDANCE FOR EVALUATION OF WASTEWATER DISPOSAL ALTERNATIVES
Proposed Discharge
1. Indicate distance to nearest stream with positive flow meeting the above criteria
(attach a topographic map indicating the current existing (or proposed) discharge
point and new/proposed location).
• 2. Provide documentation as to whether or not third parties agree to provide necessary
easements if applicable. Proceed to Section III.
III. COST ESTIMATION AND COMPARISON
NOTE: Section III must be completed only if one or more of Alternatives (1), (2), and (3) evaluated in
Section ILA. or if the proposed discharge evaluated in Section II.C. were found to be environmentally
feasible and the permit applicant claims that selecting the least costly of the feasible alternatives would be
unreasonably costly.
A. Prepare cost estimates in accordance with the following guidelines for each of
Alternatives 1, 2 and 3 that were found environmentally feasible in Section II. Be sure
to convert all costs to present value as described in Section III.E.
1. Connection to a Sewerage System (served by a municipality or other entity holding a
valid NPDES or Non -Discharge Permit.).
a. Provide detailed cost estimate of an installed sewer line interceptor and pump
station(s) if applicable (i.e. materials and labor).
b. Determine the operating expenses of the sewer extension (i.e. materials, utilities,
maintenance and operator costs) for the design period.
c. Indicate cost of easements if applicable (include documentation of offer to
provide easement with dollar amount from appropriate party).
d. Indicate the connection fees and/or surcharge required by the WWTP under
consideration.
Note: If a periodic surcharge is required, please consider cost in analysis.
2. Subsurface Disposal System (Installation of nitrification systems, low-pressure pipe
systems and mound systems).
A. Provide a detailed cost estimate for the installed cost (i.e. materials and labor) of
treatment facilities.
b. Determine the opportunity cost of any land under current ownership to be
utilized under this alternative.
c.Provide the cost of any land to be purchased and/or cost of the permanent
easement (include letter of offer to sell or provide permanent easement with
dollar amount from appropriate party) to be utilized under this alternative.
d. Determine the operating expenses of the subsurface disposal system (i.e.
materials, utilities, maintenance and operator costs) for the design period.
3. Spray Irrigation System
a. Provide a detailed cost estimate for the installed cost (i.e. materials and labor) of
treatment facilities.
b. Determine the opportunity cost of the land or portion thereof under current
ownership utilized under this alternative.
c.Provide the cost of any land to be purchased and/or cost of the permanent
easement (include letter of offer to sell or to provide permanent easement with
dollar amount from appropriate party).
d. Determine the operating expenses of the spray irrigation system (i.e. materials,
utilities, maintenance and operator costs) for the design period.
B. If discharge to a flowing stream was found to be environmentally feasible in Section II C,
prepare a cost estimate in accordance with the following guidelines. Convert all costs to
present value as described in Section III.E.
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GUIDANCE FOR EVALUATION OF WASTEWATER DISPOSAL ALTERNATIVES
Proposed Discharge
1. Provide detailed cost estimate of installed effluent line and pump station(s) if
applicable (i.e. materials and labor) to proposed discharge point.
2. Indicate cost of easements if applicable (include documentation of offer to provide
easement with dollar amount from appropriate party) .
3. Determine the operating expenses of the WWTP (i.e. materials, utilities, maintenance
and operator costs) for design period.
C. Cost Comparison: Title 15 NCAC 2H.0105(c)(2) requires that the most environmentally
sound wastewater disposal alternative be selected from the reasonably cost effective
options. The three non -discharge alternatives evaluated in Section IT.A. are assumed
roughly equivalent alternatives where they are found environmentally feasible, and
preferable to a proposed discharge. This section of the EAA must be completed when a
permit applicant has verified the environmental feasibility of one or more of the non -
discharge alternatives, but he claims the alternative(s), compared to a proposed
discharge, would be unreasonably costly. The EAA must present justification of the
applicant's claim based on the appropriate cost comparisons.
D. Present Value of Costs
Where:
1. Costs incurred in different time periods must be converted to a common time period
before they can be accurately combined or compared. Performing this calculation is
known as "computing the present value," or "discounting' the costs. Present value is
also sometimes called "present discounted value" or "present worth".
2. The following standard formula for computing the present value must be used in all
cost estimates made under this evaluation guidance.
n
C
t
PV = CO + 1 +r)
t=1
PV Present value of costs.
C0 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 Discount rate. For these calculations, use the rate that is required to be used by all
Federal agencies in the formulation and evaluation of water and related land
resources plans. The rate is computed annually in accordance with Sec. 80 (a)
Public Law 93-251 [88 Stat. 34) and 18 CFR 70439, and published in the Federal
Register. The current rate (for Federal Fiscal year 1993) is 8 1 /4%. Therefore in the
above formula for this year, r = .0825.
3. However, if the costs are the same in every time period from year one through year n
(i.e., Ct = C, a constant for t = 1,2, n), then the formula reduces to:
PV=Co+C (1+rin-1
r(1 + r)n
In this case, the present value may also be looked up in a table containing the present value
of annuities (an annuity is a constant amount payable in each year for a certain number of
years). Such tables are available from financial institutions.
NC DENR / DWQ / NPDES Unit
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