WQ0044885_More Information (Requested)_20240123

January 23, 2024
WILLIAM G. ALLEN – MANAGER
EAST COAST INVESTORS, LLC
3129 SPRINGBANK LANE – SUITE 201
CHARLOTTE, NORTH CAROLINA 28226
Subject: Application No. WQ0044885
Additional Information Request #1
The Peninsula at Hyco Lake – Lot
50 SFR
Single-Family Residence
Wastewater Irrigation System
Person County
Dear Mr. Allen,
Division of Water Resources’ Central and Regional staff has reviewed the application package
received on November 1, 2023. However, the Division requires additional information before completing
our review. Please address the items on the attached pages no later than the close of business on February
22, 2024.
Please be aware that the Applicant is responsible for meeting all requirements set forth in North
Carolina rules and regulations. The Applicant is also responsible for any oversights that occur during the
review of the subject application package. The Division may return the application as incomplete pursuant
to 15A NCAC 02T .0107(e)(2) if any omissions are made when responding to the outstanding items in
Sections A through N or the Applicant fails to provide the additional information on or before the above-
requested date.
Please reference the subject application number when providing the requested information. The
Applicant shall sign, seal, and date (where applicable) all revised and/or additional documentation and
submit an electronic response to my attention via the Non-Discharge online portal.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Elton Luong, Engineer I
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
David C. Barcal, P.E. – MacConnell & Associates, P.C. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. William G. Allen
January 23, 2024
Page 2 of 5
A. Cover Letter:
1. No comment.
B. Application Fee:
1. No comment.
C. Application (Form: SFRWWIS 06-16):
1. Per Item V.3 of Form: SFRWWIS 06-16, the application does not indicate any excavation into
bedrock. The Engineering Plans D-103 Detail A “FIELD DOSING TANK SECTION” indicates a
maximum excavation depth of 114 inches, which exceeds one of the Soil Evaluation findings for
bedrock on all three KSAT Nests (CR horizon at 21-30 inches). Please verify and revise the
Engineering Plans, Specifications, and Form: SFRWWIS 06-16 per 15A NCAC 02T .02T .0605(d),
if necessary.
D. Property Ownership Documentation:
1. No comment.
E. Setback Waivers:
1. Per Item V.19 of Form: SFRWWIS 06-16:
a. Please provide the separation distances for any private or public water supply source and any
water line from a disposal system per 15A NCAC 02T .0606.
b. “N/A” is specified as the separation distance to any habitable residence or place of assembly
under separate ownership not to be maintained as part of the project site. There are adjacent
properties also with proposed non-discharge systems and accompanying habitable residences
within 500 feet of Lot 50. Please revise to include the separation distances from the irrigation
system and treatment/storage units to habitable residences under separate ownership per 15A
NCAC 02T .0606.
2. Per Item V.20 of Form: SFRWWIS 06-16, the property line separation distances provided in Item
V.19 do not meet the setback requirements of 50 feet for both irrigation sites and treatment/storage
units listed in 15A NCAC 02T .0606. It is noted that the parcel has not been subdivided and these
values are based on preliminary property lines. Please address how setback distances will be met
and verified prior to the operation of this facility.
F. Soil Evaluation:
1. Dorothy Robson of the Raleigh Regional Office has reviewed this application and provided the
following comments:
Mr. William G. Allen
January 23, 2024
Page 3 of 5
a. Per Item F of Form: SFRWWIS 06-16, reporting an Annual Hydrologic Loading Rate (AHLR)
based on the most restrictive horizon is a requirement. T he Soil Evaluation states the AHLR
justification based on the A horizon, whereas the KSAT tests and calucations were done for the
Bt horizon since this was stated as the most restrictive horizon. Please verify and revise.
b. The precipitation data and calculated potential evapotranspiration (PET) data used in the Single
Family Residence Loading Rate Worksheet (SFRLRW) were both provided using 58 years of
data from RDU International Airport between 1948 to 2006. This data is outdated and may not
be representative of current conditions. Precipitation data and PET data may have changed
since 2006. The SFRLRW shall be updated using precipitation and PET data that incorporates
the most recent data from RDU International Airport.
c. Per Item F of Application Form: SFRWWIS 06-16, it is not apparent that the KSAT tests were
run until steady-state equilibrium was achieved, as indicated in Attachment 3 – Geometric
Mean KSAT Data. Please verify and revise the KSAT data to provide more resolution.
i. KSAT Nest 1 has not reached steady state.
ii. KSAT 2 and KSAT 3 have insufficient readings to determine steady state.
iii. The reporting format for KSAT is inconsistent. Please report all future KSAT data within
the same report as the same format for clarity.
d. The Soil Evaluation does not discuss the existing cover crop at the site or if the cover crop of
the irrigation field will change. In accordance with the Soil Scientist Evaluation Policy, if the
proposed cover crop is not the existing cover crop and irrigation will take place to help establish
the crop, the precipitation rate shall consider the irrigation of bare soil. Please update the Soil
Evaluation to address existing cover crop conditions and address any changes that will be
proposed.
2. Per Item IV.5 of Application Form: SFRWWIS 06-16, please revise the SFR Loading Rate
Worksheet calculations to use the reduced daily flow of 270 GPD (90 GPD/BR), along with
subsequent affected values such as irrigation area.
G. Engineering Plans:
1. The proposed arrangement of the clean-outs are shown inconsistently between the plan and profile
views throughout the Engineering Plans (i.e., one on the influent side of the septic tank, one on the
effluent side of the septic tank, etc.). Please revise for clarity.
2. There are two different pages with the same label of C-103. Please verify and revise as appropriate.
3. The stone bedding depth specified for the field dosing tank in Section View A of D-103 is 12
inches, while the remainder of Details pages specify a 6” thickness of stone bedding depth. Please
verify if this is intentional.
H. Specifications:
1. No comment.
I. Engineering Calculations:
Mr. William G. Allen
January 23, 2024
Page 4 of 5
1. Per Item V.1 of Application Form: SFRWWIS 06-16, the reported Designed Effluent
Concentration for Total Suspended Solids (TSS) of 1.5 milligrams per liter (mg/l) does not match
the Engineering Calculations value of 4.50 mg/l. Please verify and revise.
2. Per Item VI.2.d of Application Form: SFRWWIS 06-16, the reported dimensions and volumes
(effective and total) of the septic tank, recirculation tank, EZ Treat, and PUMP/STORAGE TANK,
do not match Engineering Calculations. Please verify and revise.
J. Site Map:
1. No comment.
K. Operation & Maintenance Plan:
1. No comment.
L. Operation & Maintenance Agreement (Form: SFRWWIS-O&M 09-18):
1. No comment.
M. Additional Documentation:
 County Health Department Denial Letter:
1. In accordance with 15A NCAC 02T .0604(g), a letter from the local county health department
denying the site for all subsurface systems shall be submitted to the Division by the Applicant.
The Person County Health Department denial letter provided is not unique to Lot 50 that is
being proposed in this application. Each individual parcel shall have its own denial letter to
verify that the site cannot support a subsurface system.
The Person County Health Department shall investigate the proposed Lot 50 for suitability for
a subsurface system. This investigation shall include soil borings and a map identifying the
specific location of the lot.
 Floodway Regulation Compliance:
1. No comment.
 Threatened or Endangered Aquatic Species Documentation:
1. No comment.
N. Recommendations (Response not required):
1. Engineering Plans:
a. The Division recommends consistently labeling the “Finished Grade” across Detail sheets.
Mr. William G. Allen
January 23, 2024
Page 5 of 5
b. Per C-102, the Division recommends revising the sheet reference for “TREATMENT
SYSTEM SCHEMATIC / PROFILE” to C-102.
c. Per C-107, the Division recommends adjusting underline for “EFFLUENT LIMITS PER 15A
NCAC 02T .0605(b)” limits in Detail 1 for clarity of operator (e.g. ≤ 30).