NC0089940_Return Application_20211214

CERTIFIED MAIL 7018 1830 0001 8036 9315
RETURN RECEIPT REQUESTED

Malinda A. & Jason A. Duvall, MD
c/o Margaret Hankins
Joses Hideaway Restaurant
217 Liberty Rd
Reidsville, NC 27320

Subject: NPDES application return (#2322)
NPDES Permit Application NC0089940
Joses Hideaway Restaurant
Rockingham County

Dear Mrs. Duvall:

In accordance with 15A NCAC 2H.0107(b), we must hereby return the attached permit application
received on January 20, 2021. After a preliminary review, in accordance with N.C.G.S. 143-215.1, and
15A NCAC 2H.0105, the Division has determined that the application package lacks the following items:
1. An EPA Application Form. please complete Modified EPA Form 2A for privately owned,
100% domestic facilities with design flow <1.0 MGD.
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 BOD5= 5 mg/l, NH3-N = 2 mg/l and DO = 6 mg/l. Based on review of historic data reported
under the previous NPDES NC0085189, the current sand filter treatment system would have
issues meeting the required limits for BOD and Ammonia. Therefore, the Division is requesting
a redesign of the treatment system in order to meet the above limits.
You must obtain an Authorization to Construct (ATC) permit from the Division prior to
construction for modification or expansion of wastewater treatment facilities.
3. Additional Information requested for the Engineering Alternatives Analysis (EAA). The EAA
was incomplete for the following items. Also please refer to the EAA Guidance Document.
a. Please provide discussion of the following items for STEP 1 of the EAA Guidance:
• Basin wide Water Quality Plans.
• Impaired waters and TMDLs.
• Presence of Endangered Species.
b. Non-Municipal Flow Projections (STEP 2 EAA Guidance). Please justify the design flow
projection. Flow may be justified in accordance with 15A NCAC 02T .0114 for various
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12/14/2021

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 facility design flows are also referenced in 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 it is cost effective for the project size.
• 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 that they will
not accept the wastewater.
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.
• 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
alternative 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/l, NH3-N= 1 mg/l] 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
indicating the location of outfall line.
• 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.
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• Please note that the current sand filter design may not provide adequate 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 alternative by considering a new system design
that can meet these limits.
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.
d. Evaluate economic feasibility of alternatives (STEP 4 EAA Guidance).
Evaluate the economic feasibility of alternatives using the method described in the 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 the
alternatives including Alternative D for a direct discharge.

If you wish to reapply for an individual NPDES permit, please correct these items before resubmitting the
application. Please note that permit fees are nonrefundable [15A NCAC 02H .0105 (b)(1)]. If you have
any questions, please contact Derek Denard at 919-707-3618 or email at [e-mail].

Sincerely,

S. Daniel Smith
Director, Division of Water Resources

ec: NPDES File [Laserfiche]
Margaret Hankins [[e-mail]]; Malinda A. Duvall [[e-mail]];
Jason Duvall [[e-mail]]
WSRO / Jenny Graznak [[e-mail]]; Ron Boone [[e-mail]]

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