NC0089940_More Information (Requested)_20210629

ROY COOPER
Governor
JOHN NICHOLSON
Interim Secretary
S. DANIEL SMITH
Director
Malinda A. & Jason A. Duvall, MD
c/o Margaret Hankins
Joses Hideaway Restaurant
217 Liberty Rd
Reidsville, NC 27320
Dear Mrs. Duvall:
NORTH CAROLINA
Environmental Quality
June 29, 2021
Subject: Request for Additional Information
NPDES Permit Application NC0089940
Joses Hideaway Restaurant
Rockingham County
The Division has reviewed your application, received on January 20, 2021, for a new NPDES permit. The
Engineering Alternatives Analysis (EAA) was reviewed by our staff on July 18, 2021. To enable us to complete
our review in accordance with N.C.G.S. 143-215.1 and 15A NCAC 02H .0105, we need additional or revised
information to address the following comments:
1. An Updated EPA Application Form. Since this application is being updated, please complete Modified
EPA Form 2A (see attached) for privately owned, 100% domestic facilities with design flow <1.0
MGD. The application can also be downloaded from the following webpage:
https://deq.nc.gov/about/divisions/water-resource s/water-quality-permitting/npde s-wastewater/npdes-
permitting-process.
2. Treatment System Design. In accordance with 15A NCAC 2B .0206 (d)(1) for discharge to zero flow
streams (7Q10=0; 30Q2>0), if the 30Q2 flow is estimated to be greater than zero, effluent limitations
for new or expanded (additional) discharges of oxygen consuming waste shall be set at BODS= 5 mg/1,
NH3-N = 2 mg/1 and DO = 6 mg/1. Based on review of historic data reported under the previous NPDES
NC0085189, the current sand filter treatment system will have issues meeting the required limits for
BOD and Ammonia. Therefore, the Division is requesting a redesign of the treatment system.
Please note that an improved system will require an Authorization to Construct (ATC) permit. The
application and information for the ATC permitting process can be found at the following webpage:
https://deq.nc.gov/about/divisions/water-resource s/water-resources-permits/wastewater-branch/npdes-
wastewater/authorization-to-construct.
After an NPDES permit has been issued by the Division, you must obtain an ATC permit from the
Division prior to commencement of the construction of modifications or expansion of wastewater
treatment facilities. The draft NPDES permit will include language requiring an ATC permit before
construction and operation can begin, and an Engineer's Certification before discharging from the
treatment works.
The addition information needed for this NPDES application regarding the treatment system design is
the following:
D_E
NORTH CAROLINA
Department of Environmental Wali�
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

Mrs. Duvall
June 29, 2020
Page 2 of 4
a. The flow project information. See requested Item 3b below.
b. Information for EAA Alternative D for the direct discharge to surface waters. Which will also
include 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).
See requested Item 3c below.
c. Information included in the EAA cost analysis for a direct discharge. See requested Item 3d
below.
3. Additional Information requested for the EAA. The EAA was incomplete for items as outlined in the
attached EAA Guidance Document. Please note that some of the requested information below is taken
directly from the guidance document.
a. Please provide discussion of the following items for STEP 1 of the EAA Guidance:
• Basinwide Water Quality Plans.
• Impaired waters and TMDLs.
• Presence of Endangered Species.
You may want to also summarize the stream flow and stream classification information that was
provided in the original application as part of this this discussion. The EAA guidance outlines how
this information should be organized.
b. Non -Municipal Flow Projections (STEP 2 EAA Guidance). Flow may be justified in accordance
with 15A NCAC 02T .0114 for various activities. There are different minimum allowable design
daily flows listed for restaurants based on the type of service such as full service (40 gal/seat),
single service articles (20 gal/seat), drive-in (50 gal/car space), or carry out only (50 gal/100 sq ft
floor space). Other food and drink facilities are also reference in 02T .0114. Please note the 15A
NCAC 2H .0219(1) regulation cited in the guidance was removed to 02T .0114.
c. Evaluate Technology Feasible Alternatives (STEP 3 EAA Guidance). More detailed information is
needed for the following alternatives.
Alternative A. Connection to an Existing Wastewater Treatment System.
• Identify whether there are existing sewer lines within a five -mile radius or consider a
greater radius if cost effective for the project size. There are private WWTP within 5 miles.
The following GIS Online map may be helpful in locating facilities:
https://ncdenr.maps.arcgis.com/apps/webappviewer/index.html?id=4ca77e79b68e466cbcae
9713a28dde7d
• Provide a preliminary indication of flow acceptance from existing municipal or private
WWTPs under consideration for connection. If a municipal or private WWTP cannot
accept the wastewater, include a letter documenting such and consider this alternative
technologically infeasible.
Alternative B. Land Application. Land application disposal alternatives include
individual/community onsite subsurface systems, drip irrigation, and spray irrigation.
• 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.

Mrs. Duvall
June 29, 2020
Page 3 of 4
• 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).
• 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.
• Explain the proposed reuse plan if reclaimed water will be used by a third party.
• Conduct a Present Value Cost Analysis per STEP 4. For the reclaimed water system
include the potential revenue generated by selling the water.
• Provide all calculations, documentation and maps as necessary to support assumptions and
conclusions.
• Note: The design of land application systems must meet the treatment and design
requirements specified in 15A NCAC 02T .05 or 15A NCAC 18A.1900.
Alternative D. Direct Discharge to Surface Waters.
• All direct discharge systems of oxygen -consuming wastes should be evaluated both with
tertiary filtration [BOD5= 5 mg/1, NH3-N= 1 mg/11 and without, and assuming a weekly
sampling regime.
• 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).
• Conduct a Present Value Cost Analysis per STEP 4.
• Note: All direct discharge treatment systems must comply with Reliability Requirements
specified in 15A NCAC 2H.0124.
• Please note that the current sand filter design may not provide adequate enough treatment
for compliance with effluent limitations in accordance with 15A NCAC 2B .0206 (d)(1) for
discharge to zero flow streams (7Q10=0; 30Q2>0). Please reevaluate the direct discharge to
surface waters considering a new system design that can meet these limits. Please see
further discussion below about the system design and Authorization to Construct (ATC)
requirements.
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.
d. Evaluate economic feasibility of alternatives (STEP 4 EAA Guidance).
The evaluate the economic feasibility of alternatives using the method described in the attached
EAA Guidance. Please use the Present Value of Cost Analysis (PVCA) calculation method and
summarize the results for each alternative in one table. The table should compare all of the
alternatives include Alternative D for a direct discharge.

Mrs. Duvall
June 29, 2020
Page 4 of 4
If no response is received within 60 calendar days [per 15A NCAC 2H.0107(b)], the project will be deactivated
and withdrawn from our review process and the documents recycled. If you have questions concerning the
additional information requested, please contact me at 919-707-3618, or via e-mail at [e-mail].
Sincerely,
Derek Denard, Environmental Specialist
NPDES Compliance and Expedited Permitting
Division of Water Resources, NCDEQ
Enclosure: Engineering Alternatives Analysis (EAA) Guidance Document; Modified EPA Form 2A
ec: NPDES File [Laserfiche]
Margaret Hankins [[e-mail]]; Malinda A Duvall [malinda [e-mail]];
Jason Duvall [[e-mail]]; Stephen Buchanan [[e-mail]]
WSRO / Jenny Graznak [[e-mail]]; Lon Snider [[e-mail]];
Ron Boone [ron.boone@,ncdenr.gov]