HomeMy WebLinkAboutNCG551780_More Information (Requested)_20220121ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
January 21, 2022
CERTIFIED MAIL 7018 1830 0001 8036 9209
RETURN RECEIPT REQUESTED
Jennifer Ferrusi
5800 Wilma Street
Durham, NC 27712
Subject: Request for Additional Information
NPDES Permit Application NC551780
5800 Wilma St., Durham 27712
Durham County
Dear Ms. Ferrusi:
The Division of Water Resources (DWR) has reviewed your application, received on June 10, 2021, for a new
NPDES permit. To enable us to complete our review in accordance with N.C.G.S. 143-215.1 and 15A NCAC
02H .0105, DWR needs additional or revised information to address the following comments:
1. Plans and Specifications indicate the location of an off -site well on an adjacent property with a 50-foot
buffer and an on -site well indicated with a 50-foot buffer. In accordance with 15A NCAC 02T .1006,
the setback for treatment/storage units is 100-feet. Please indicate whether these wells are in use as
water supplies and whether both properties are severed by a public water supply. If possible, the
treatment units need to be placed at least 100-feet from any well. Please update plans and specifications
accordingly for a 100-foot well setback.
2. Please submit a final electronic copy of plans and specifications to derek.denard@ncdenr.gov.
3. Engineering Alternatives Analysis (EAA). The EAA was incomplete for the following items. Please
refer to the attached "Engineering Alternatives Analysis (EAA) Guidance Document" for the Present
Value of Costs Analysis (PVCA).
a) 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
(ex. include letters from adjacent property owners indicating no interest in selling property). Please
re-evaluate the following alternatives considering the cost of acquiring land:
i. Land Application — Assess the land application disposal alternatives such as spray irrigation,
drip irrigation, individual/ community onsite subsurface systems, and/ or innovative ground -
absorption.
ii. Wastewater Reuse — Wastewater Reuse Evaluate reusing all or a portion of the wastewater
generated, such as for golf course irrigation, crop irrigation (e.g., hardwood or pine plantation,
grasses), athletic field irrigation, landscape uses, and/ or commercial/ industrial uses.
£ D_E
NORTH CAROLINA
Department of Environmental Quality
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
b) Direct Discharge to Surface Waters. The EAA was missing a cost analysis for the discharge
alternative. Provide the PCVA for the discharge alternative with an itemized budget.
c) PVCA Summary Table. 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. Most importantly, all alternatives should be
included for the comparison to the Direct Discharge to Surface Waters.
Please submit the additional information requested by one of the following:
Electronically: derek.denard@ncdenr.gov
Address For USPS:
Attention: Derek Denard
Division of Water Resources
WQ Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address for parcel packages:
Attention: Wren Tredford
Division of Water Resources
WQ Permitting Section — NPDES
512 N. Salisbury Street
(9th Floor -Archdale Bldg)
Raleigh, NC 27604
Per 15A NCAC 2H.0107(b), if no response is received within 60 calendar days, the application will be returned to
the applicant. If you have questions concerning the additional information requested, please contact me at 919-
707-3618, or via e-mail at derek.denard@ncdenr.gov.
Sincerely,
Derek Denard, Environmental Specialist
NPDES Compliance and Expedited Permitting
Division of Water Resources, NCDEQ
Enclosure: Engineering Alternatives Analysis (EAA) Guidance Document
ec/cc: NPDES File [Laserfiche]
Jennifer Ferrusi [benjferl@gmail.com]
MacCONNELL & Associates, P.C.[gary.macconnell@macconnellandassoc.com]
[P.O. Box 129, Morrisville, NC 27560]
DWR RRO / Jane Bernard [jane.bemard@ncdenr.gov], Vanessa Manuel [vanessa.manuel@ncdenr.gov]