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HomeMy WebLinkAboutWQ0029169_Additional Information Request_20230214ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality February 14, 2023 JAMMIE ROYALL — TOWN MANAGER TOWN OF MOUNT OLIVE 114 EAST JAMES STREET MOUNT OLIVE, NORTH CAROLINA 28365-1711 Subject: Application No. WQ0029169 Additional Information Request Town of Mount Olive WWTP Reclaimed Water Generation and Dedicated Utilization System Wayne County Dear Mr. Royall: Division of Water Resources' Central and Regional staff has reviewed the application package received November 22, 2022. However, additional information is required before the review may be completed. Please address the items on the attached pages no later than the close of business on March 16, 2023. Please be aware that you are responsible for meeting all requirements set forth in North Carolina rules and regulations. Any oversights that occurred in the review of the subject application package are still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items in Sections A through 0, or failure to provide the additional information on or before the above requested date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2). Please reference the subject application number when providing the requested information. All revised and/or additional documentation shall be signed, sealed and dated (where needed), with an electronic response submitted to my attention at: https://edocs.deq.nc.gov/Forms/NonDischarge-Branch- Submittal-Form-Ver2. If you have any questions regarding this request, please contact me at (919) 707-3659 or erickson.saunders@ncdenr.gov. Thank you for your cooperation. Sincerely, Erick Saunders, Engineer Division of Water Resources cc: Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy) J. Clark Maness, PE — WithersRavenel (Electronic Copy) Laserfiche File (Electronic Copy) =D.E NORTH CAROLINA Department of Environmental Duality 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 Mr. Jammie Royall February 14, 2023 Page 2 of 4 A. Cover Letter: 1. No comments. B. Application Fee: 1. No comments. C. Application: 1. In Item VI.6. of the Reclaimed Water Non -Conjunctive System Application form (FORM: RWNC 06-16), it asks for the equipment information for the spray utilization design element. Please provide this tabulated information for each different spray nozzle that is provided in this application. 2. The information in Item VI.8. of the RWNC form was not filled out to describe the new field configuration as described in this application's plans. This information shall be provided for each field in this section. 3. Item VIII.1. and 2. of the RWNC form states that the system will be used to irrigate food chain crops for human consumption and meet Type 2 reclaimed water standards for indirect contact irrigation. There are additional considerations for Type 2 reclaimed water facilities listed in 15A NCAC 02U .1400 that do not appear to be included in this application, and the cover crop listed in Item VI.9. of the RWNC form is Coastal Bermuda, indicating that this section may have been included by mistake. Please clarify whether this system will irrigate food chain crops as covered under 02U .1400. D. Property Ownership Documentation: 1. No comments. E. Soil Evaluation: 1. No comments. F. Agronomist Evaluation: 1. N/A. G. Hydrogeologic Report: 1. In accordance with 15A NCAC 02U .0202(c), any new and expanding dedicated reclaimed water facilities with a design flow over 25,000 gallons per day (GPD) shall have a hydrogeologic description of the surface prepared by a Licensed Geologist, Licensed Soil Scientist, or Professional Engineer which includes a mounding analysis to predict the level of the seasonal high water table after reclaimed water application. As this application proposes a permitted flow rate increase from Mr. Jammie Royall February 14, 2023 Page 3 of 4 560,893 GPD to 623,216 GPD, it would be considered an expanding dedicated reclaimed water facility. This proposed increase rate is based on the updated field areas and increasing the designed application rates to match the maximum soil scientist's recommendation. This proposal assumes that the hydraulic conductivity of the soil is the limiting factor for the disposal capacity of the facility. However, there is no analysis for how this flow increase would impact the groundwater flow regime at the site to verify that the groundwater mounding attributed to the operation of the facility does not violate the one -foot vertical separation between the season high water table and the ground surface as required by 15A NCAC 02U .0302(k). A hydrogeologic evaluation meeting the requirements of 15A NCAC 02U .0202(c) shall be submitted to verify that groundwater flow regime and mounding will not be a limiting factor if the permitted flow rate is increased from 560,893 GPD. H. Water Balance: 1. See Items I.1. and I.2. The water balance shall be performed using the acreages that only include the wetted areas of the specified sprayheads that are shown in the plans. 2. It is unclear how the "Total: Influent + Lagoon Gains & Losses" values were calculated in "Table 18. Water Balance for All Zones". It does not correspond to the monthly lagoon gains and losses added to the monthly design influent volume. Please clarify how these values were obtained. 3. The modification seeks to increase the permitted flow of this permit to 623,216 GPD. However, Table 18 of the Water Balance indicates that the design daily influent flow is 600,435 GPD, with the remaining flow coming from inputs and outputs from the storage lagoon. Please note based on this, a permitted rate would only be increased to 600,435 GPD. A response to this item is not required. I. Engineering Plans: 1. The Washington Regional Office noted in their site visit that the wetted areas of the installed spray heads did not overlap as they were indicated on the plan sheet for these fields. Currently configured, the sprayheads do not utilize the full extent of the field as depicted on the plans, and the reduced wetted area from these installed facilities reduces the disposal capacity of the system. The irrigation facilities shall be reevaluated to match the wetted area of the fields in the plans with their actual observed wetted area. This evaluation shall include a calibration of the system that tries to configure the actual observed wetted area with wetted areas in the current plans in order to maximize the disposal capacity. If what is observed does not match what is in the plans after this calibration, the plans shall be updated to depict the correct wetted acreage for each field, and the areas of each field shall be recalculated based on this change. 2. The acreages of the fields for the new subzones don't appear to correspond to the actual disposal areas irrigated by the new reduced sprayheads. For instance, on Sheet 2 of the plans, Field 3R is shown to only be dosed by a single SG Type 3 spray gun (a Nelson Big Gun 100 Series Ring Nozzle 0.89") while the listed/reported spray field area is 169,651 square feet (-3.9 acres). The Wetted Diameter of a full circle 0.89" 100 Ring Nozzle given in Table 2 of the Sprayfield Water Model Analysis provided in the application is around 270-290 feet when operated between 60 and 70 psi (65 psi is the calculated maximum pressure at this nozzle in Table 5). The wetted area of a 290 foot diameter circle is approximately 1.52 acres, which is a little more than half what is listed here. Mr. Jammie Royall February 14, 2023 Page 4 of 4 The 169,651 square foot area of Field 3R appears to come from to the Usable Area Calculation box shown on Attachment 2 of the November 15, 2022 "Land Application of Reclaimed Water — Soil Scientist Evaluation Report" performed by AWT. The Reduced Application Areas polygon shown on Sheet 2 of the plans seems to come from the field delineation on this Attachment 2, but not all the specified usable area is utilized and includes a sizable extent that would not receive any irrigation. This appears to also be the case of Field 4R, and to a lesser extent for Fields 7R and 9R. For the purposes of field delineations, water balance calculations, and design calculations, only the wetted area shall be included in this field sizing. The areas of each field shall be recalculated to correspond to the wetted acreage of the sprayheads, and the extent of each field shall be shown on an updated plan package. J. Specifications: 1. No comments. K. Engineering Calculations: 1. See Comments I.1 and I.2. The area of Field 3R on Table 3 of the Water Balance Calculation is 3.89 acres and the area on Table 4 of the Sprayfield Water Model Analysis is 172,788 square feet (3.97 acres). However, the wetted acreage is closer to 1.52 acres based on the spray diameters at the specified pressure. The application rates for all field shall be recalculated utilizing the wetted acreage of each fields to verify that there are not any violations of the instantaneous or annual hydraulic loading rates at the designed field run times. L. Site Map: 1. No comments. M. Power Reliability Plant: 1. N/A. N. Operation & Maintenance Plan: 1. Condition I.3. of the previous permit issued October 12, 2020 required that a Final Operation and Maintenance Plan be submitted for review. Condition I.6. of this permit stated operation of these facilities were contingent on the completion of the required documentation listed in Conditions 1.3., I.4., and I.S. Conditions I.4. and 1.5. have been received, but operation of this facility cannot be issued until documentation fulfilling Condition 1.3. has been received. O. Residuals Management Plan: 1. N/A