NC0089761_More Information Received_20180228

Water Resources
ENVIRONMENTAL QUALITY
ROY COOPER
Goreinoi
MICHAEL S REGAN
Secretary
LINDA CULPEPPER
Interim Director
February 28, 2018
L. W. Nixon, Vice President
Murry L. Nixon, Fishery, Inc.
1141 Nixon Fishery Road
Edenton, North Carolina 27932
Subject: Additional Information Required
Engineering Alternatives Analysis (EAA)
NPDES Application NCO089761
Murry L. Nixon, Fishery, Inc.
1141 Nixon Fishery Road, Edenton
Chowan County
Dear Mrs. Nixon:
The Division of Water Resources (the Division) received your application for discharge from the subject site
dated January 5, 2018 via your authorized agent, Groundwater Management Associates (GMA), Inc. We have
subsequently reviewed your Engineering Alternatives Analysis (EAA) required for proposed new discharges.
We fmd your evaluation of the Surface Discharge alternative (EAA section 4.4) inadequate in that it does not
consider the degree of treatment required by the Chowan River Basin Plan. Please note that for classified
Nutnent Sensitive Waters (NSW), a surface -discharge cost analysis should likely include tertiary treatment
technology capable of attaining permit limits for Total Nitrogen (3.0 mg/L TN), and Total Phosphorus (1.0
mg/L TP), in accord with the basin plan (2007; see attached excerpt).
Your currently proposed septic system is likely inadequate to achieve the required permit limits for a surface
discharge Moreover, zero -flow receiving -stream conditions [7Q10 and 30Q2 = 0.0 cfs] prohibits any dilution
credit that would relax permit limits. Although some dilution is attainable by implementing an instream effluent
diffuser, any diffuser requires modeling by DWR-approved methods prior to installation.
In support of your application, we therefore request that you consider the potential need for tertiary wastewater
treatment, and reevaluate discharge alternative costs and priorities For questions regarding non-discharge/land-
application permitting, contact the Division's Nathamal Thornburg [nathamal [e-mail]], or call
his direct line, 919-807-6543.
Please respond to this request by May 31, 2018, — 90 days after receiving this letter After said date the
Division must return your application as incomplete. If you hav esti�on��' out this review, or if I can further
assist you, please email me at [toe corporon(a,ncdenr gov] o call y dir6cne [phone].
oe R Corpo on, L.G DES Permitting
Attachments: [portion of Chowan Basin Plan] Secti 5.1.3 Nut ne t Sens itiv Water Management
hc. Central Files
NPDES Program Files
David May
ec WaRO, David May, Robert Tankard
nathamal thornburg_na,ncdenr gov
lw mxonfisherom, john@gma-nc com
State of North Carolina I Division of Environmental Quality I Water Resources
Location 512 N Salisbury St 11611 Mall Service Center l Raleigh, 27699-1611
919-707-9000

[Portion of] Chowan River Basin Management Plan
5.1.3 Nutrient Sensitive Waters Management
Although there have been gains in nutrient reductions and associated benefits to water quality,
the Division recommends continued implementation of the nutrient reductions and conservation
measures. A Nutrient Sensitive Waters (NSW) strategy was initially adopted in 1982 and updated
in 1990. By year 1990, overall total nitrogen (TN) was reduced by 20 percent and total
phosphorus (TP) had been reduced by 29 percent (goal of 35 percent). Major points of the 1990
management strategy include:
• Reduction in phosphorus inputs from point and nonpoint sources by 35-40 percent
❑ Point Sources
♦ Land application systems for municipal wastewater treatment plants
♦ Phosphorus limits of 1.0 mg/1(TP) in the North Carolina portion of the basin
Nonpoint Sources
♦ Target funds from the Agriculture Cost Share Program to the Chowan River basin
• Reduction of nitrogen inputs from all sources by 20 percent
Point Sources
♦ Land application systems for municipal wastewater treatment plants
♦ Nitrogen limits of 3.0 mg/1(TN) in the North Carolina portion of the basin
Nonpoint Sources
♦ Target funds from the Agriculture Cost Share Program to the Chowan River basin
In response to the NSW strategy, many wastewater treatment plants, previously discharging to
Chowan Basin surface waters, converted their plants to land application. These non -discharge
systems treating domestic wastewater are required to meet total nitrogen (TN) and total
phosphorus (TP) limits.
The Division requires any new discharger to model nutrient impacts on water quality to ensure
that the Chlorophyll a standard is not exceeded. Also, Agricultural Cost Share Program monies
promote the application of best management practices (BMPs) in the basin (see Chapter 9), and
contribute to reducing over -enrichment conditions.
Such efforts should continue to improve the water quality of the Chowan River Basin.