WQ0044604_Additional Information Request #2_20240311

March 11, 2024
ANDREW ROSS – MANAGER
THE CONSERVANCY REAL ESTATE GROUP, LLC
4201 TAYLOR HALL PLACE
CHAPEL HILL, NORTH CAROLINA 27517
Subject: Application No. WQ0044604
Additional Information Request #2
The Conservancy at Jordan Lake
WWTP
Reclaimed Water Generation and
Dedicated Utilization System
Chatham County
Dear Mr. Ross,
Division of Water Resources’ Central and Regional staff have reviewed the application package
received on July 24, 2023, and subsequent additional information received on December 15, 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 April 10, 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 W 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,
Zachary J. Mega, Engineer III
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Mark P. Ashness, PE – CE Group, Inc. (Electronic Copy)
John F. Phillips, PE – Diehl & Phillips, P.A. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Andrew Ross
March 11, 2024
Page 2 of 8
A. Overall:
1. The comments from Ms. Leah H. W. Parente and Mr. Michael Hall’s review of the revised
Hydrogeologic Report are listed in Section J. Both have continued concerns about the overall data
resolution of the conceptual groundwater model and its applicability to the proposed site.
To satisfy their specific concerns related to accurately modeling the seasonal high water table
(SHWT), groundwater mounding, and the potential for irrigation runoff, please complete one of
the following options:
 Provide a more detailed groundwater model based on empirical data from the project site that
takes an individualized approach to each proposed irrigation zone while satisfying the
requirements of Instructions E and F of Form: RWNC 06-16, 15A NCAC 02U .0202(c), 02U
.0202(e), and the Hydrogeologic Investigation and Reporting Policy. The Division included
this as Comments I.2.a and I.2.d in the Additional Information Request #1 sent on
October 5, 2023.
 Revise the application contents to provide soil moisture sensors for each irrigation zone linked
to the proposed weather station to prevent irrigation during wet conditions. The Permittee shall
install the soil moisture sensors at a consistent depth that is shallow enough to accurately reflect
the moisture level of the ground surface without normal operations disturbing them (i.e.,
mowing, soil aeration, etc.) This real-world approach is based on the Raleigh Regional Office’s
(RRO’s) observation of irrigation system performance at comparable existing facilities.
[15A NCAC 02T .0108(c), 02U .0108]
B. Cover Letter:
1. No comment.
C. Application Fee:
1. No comment.
D. Application (Form: RWPI 06-16):
1. No comment.
E. Application (Form: RWG 06-16):
1. No comment.

Mr. Andrew Ross
March 11, 2024
Page 3 of 8
F. Application (Form: RWNC 06-16):
1. Item VI.8 –
a. The response to Comment E.5.d says that CE Group, Inc. included supporting calculations to
clarify the designed hourly loading (precipitation) rates for the proposed irrigation zones. The
Engineering Calculations do not show how CE Group, Inc. obtained the values listed under
Item VI.8. Per Instruction I of Form: RWNC 06-16 and 15A NCAC 02U .0201(c)(3), please
revise the Engineering Calculations to show how CE Group, Inc. obtained the designed hourly
loading rates for each proposed irrigation zone. The Division included this as Comment
E.5.d in the Additional Information Request #1 sent on October 5, 2023.
b. The response to Comment E.5.e from CE Group, Inc. explains that the Operator in Responsible
Charge (ORC) will have the ability to match the recommended annual loading rates when
possible and the proposed design matches these recommended rates. The reviewer has
determined that the designed annual loading rates exceed the recommended rates for many of
the irrigation zones based on the information provided in the Engineering Calculations. Per
Instruction I of Form: RWNC 06-16 and 15A NCAC 02U .0201(c)(3), please revise the
Engineering Calculations to show how CE Group, Inc. obtained the designed annual loading
rates for each proposed irrigation zone and ensure that they are equal to or less than the
recommended rates in the Soil Evaluation. The Division included this as Comment E.5.e in
the Additional Information Request #1 sent on October 5, 2023.
G. Property Ownership Documentation:
1. No comment.
H. Soil Evaluation:
1. Ms. Dorothy Robson of the Raleigh Regional Office (RRO) reviewed the revised Soil Evaluation
and provided the following comments:
a. The review of the KSAT data indicates that Mr. Murray only modified some tests to be
satisfactory. The Division considers the following KSAT data acceptable:
 High-Rate (Mayodan): HR 2(Bt) & HR 3(C)
 Intermediate-Rate (Brickhaven/Carbonton): IR 1, IR 2, IR 3, IR 4 & IR 5
 Low-Rate (Creedmoor/White Store): LR 1(Bt), LR 2(BC), LR 3(Bt), LR 4(Bt) & LR 5(Bt)
Based on the acceptable KSAT data, the Soil Evaluation does not sufficiently evaluate the
Mayodan soil series. Per Section 1.c.v of the Soil Scientist Evaluation Policy, there must be a
minimum of three (3) valid KSAT data points conducted in the most restrictive horizon for each
soil series. Please revise the Soil Evaluation to ensure the Mayodan soil series meets this
requirement.
b. Some of the calculated averages for individual KSAT tests are incorrect. Please revise.

Mr. Andrew Ross
March 11, 2024
Page 4 of 8
c. The summary of geometric means indicates that the C horizon of the Brickhaven/Carbonton
soil series is more restrictive than the Bt horizon of the Creedmoor/White Store soil series. The
Soil Evaluation does not include an evaluation of the C horizon for the Creedmoor/White Store
soil series for comparison. However, based on the values for the most restrictive horizon in
each soil series, the Brickhaven/Carbonton soil series appear s to be the low-rate soil and the
Creedmoor/White Store soil series appears to be the intermediate-rate soil. Please explain the
reasoning for each determination.
d. Please explain, in detail, the areas that would require additional fill material (locations, acreage,
depths, etc.) and add this to the approved procedures listed in the Soil Evaluation.
e. Page 3 of the Soil Evaluation under “Hydraulic Conductivity Analysis”, states that “A
maximum dosing rate of 0.3 inches per dose is recommended for the soil zones of this project
with a minimum 2 hour ‘soak period’ between irrigation events.” Please explain, in detail, how
Mr. Murray determined that two hours is sufficient between irrigation events. Although there
is a weather station proposed at the wet weather storage pond, the winter months do not allow
as much evapotranspiration compared to the summer months. Will the ORC adjust the “soak
period” based on the season? This also differs from the Engineering Calculations, which show
a dose of 0.2 inches, instead of 0.3. Please verify and revise, if necessary.
f. The soil boring log is incomplete and hard to follow. Please explain what “Depth of Usable”
means. What do the dashes represent? Please provide a definition/legend to explain the soil
boring log.
g. Some of the soil profiles for the KSAT nest locations are missing the depth to the SHWT but
indicate each layer as moist. Please provide reasoning and/or details for determining the
SHWT.
h. Based on the figures in the Hydrogeologic Report, the proposed irrigation zones also overlap
the Chewacla/Wehadkee (ChA) soil series. The Soil Evaluation does not include any KSAT
data, soil borings, or soil profiles for this soil series. Please provide data for all soil series
located within and adjacent to the proposed irrigation zones or an explanation per Section 1.b.ii
of the Soil Scientist Evaluation Policy for why the Soil Evaluation excludes the ChA soil series.
i. The Soil Evaluation states that there are different loading rates for each soil series, however, it
is unclear whether there are different-sized spray nozzles or irrigation frequencies based on the
soil series. Please provide details on how the ORC will manage the irrigation for each zone.
[15A NCAC 02U .0202(b)]

Mr. Andrew Ross
March 11, 2024
Page 5 of 8
I. Agronomist Evaluation:
1. Ms. Dorothy Robson of the RRO reviewed the revised Agronomist Evaluation and provided the
following comments:
a. The Realistic Yield Expectation (RYE) values in the North Carolina Realistic Yield Database
differ based on the soil series and slope the cover crop is planted in. Although the high-rate
soil will have the most conservative nutrient uptake rate, the Agronomist Evaluation must
evaluate all combinations of soil series, slopes, and proposed cover crops per Instruction D of
Form: RWNC 06-16. Please provide RYE and nutrient uptake analyses (nitrogen and
phosphorous) for the intermediate-rate and low-rate soil using their respective annual loading
rates to provide a comprehensive evaluation of the site agronomy.
b. The provided soil fertility analyses indicate areas with higher levels of iron (Fe) and manganese
(Mn). Please provide details on how the facility will compensate for and manage these
parameters. For example, high iron levels in soil can be detrimental to plant growth leading to
nutrient deficiency, stunted growth, and chlorosis.
[15A NCAC 02U .0201(h)]
J. Hydrogeologic Report:
1. The Hydrogeologic Report is unclear about the mounding analysis results. On Page 19 below Table
5, there are contradicting statements concerning water table depths within one foot of the irrigation
surface. The Hydrogeologic Report states that “No areas within the boundaries of the modeled
sprayfields have a depth to watertable of less than 1 foot for any month of the year” and “The
mounding analysis also determined that no irri[g]ation should occur during the [month of] January
to avoid the development areas within the sprayfields where the modeled depth to the watertable
was less than one foot during that month.”
The Hydrogeologic Report also states in the “Conclusion” section on Page 43 that “The mounding
analysis shows that irrigation should not occur during November, December, and January.” This
is inconsistent with the data presented in the Hydrogeologic Report and the associated Water
Balance. There is no mention of this in the Soil Evaluation, Agronomist Evaluation, or Engineering
Calculations. It is also unlikely that a proposed facility this size will be able to stop irrigation for
three months.
Please clarify this statement and provide details on how the proposed facility will address this. The
Permittee and their consultants will need to revise the remainder of the application to reflect this
statement, if necessary. Please also revise the Hydrogeologic Report for clarity and consistency in
interpreting the mounding analysis results.
2. Ms. Leah H. W. Parente, the Geologist/Hydrogeologist for the Non-Discharge Branch, reviewed
the revised Hydrogeologic Report and provided the following comment:
a. Mr. Lappala’s response to Comment I.1.c states that “Slug tests were conducted where
sufficient saturated thickness of the surficial material is present for the tests to be meaningful
and deep KSAT tests will be conducted in borings where this is not the case.” The revised
Hydrogeologic Report does not include a sampling plan for additional KSAT tests. Please
provide details for when and at what locations this sampling will occur. The Division included
this as Comment I.1.c in the Additional Information Request #1 sent on October 5, 2023.

Mr. Andrew Ross
March 11, 2024
Page 6 of 8
3. Mr. Michael Hall, the Regional Supervisor for the RRO, reviewed the revised Hydrogeologic
Report and provided the following comments in response to Mr. Lappala:
a. The Hydrogeologic Report still does not contain the information required by Instruction E of
Form: RWNC 06-16 and does not meet the requirements of the Hydrogeologic Investigation
and Reporting Policy (HIRP) insofar as “All hydrogeological investigation data should be
clearly documented.” Therefore, it is difficult to review the Hydrogeologic Report and assess
whether the site is capable, from a hydrogeologic perspective, of assimilating the irrigation.
The conceptual groundwater model provided is too general and does not meet the purpose
stated in the HIRP to “…consolidate site and regional hydrogeologic and hydrologic data into
a set of assumptions and concepts that can be evaluated quantitatively.” The proposed spray
area consists of dozens of individual irrigation zones spread out over several square miles. The
twenty-two (22) borings and seven (7) piezometers/wells are insufficient to adequately
characterize the range of hydrogeologic conditions present in an area this size. The limited
information provided indicates significant topographic variation, faults, diabase dikes, and
numerous stream crossings. The conceptual groundwater model does not address these items
sufficiently, nor does it describe how hydrogeologic conditions vary across the project site or
temporally. There are no hydrogeologic cross-sections or potentiometric surface maps
provided. There is no discussion of vertical and horizontal hydraulic gradients, or how the
groundwater interacts with the surface water features that are present. There are no slug or
pump tests, or other measurements of hydraulic conductivity in the overburden, which is the
primary aquifer of interest for this site.
The HIRP indicates that (emphasis added) “The hydrogeological conceptual model should lead
the investigator into selecting an appropriate groundwater flow and/or transport model for
demonstrating (through model prediction) compliance with the seasonal high water table
separation rules..." Given the amount of data at this site, a more appropriate modeling approach
would be to provide a simple mathematical model to represent and predict the expected
mounding for the range of conditions that exist across the study area. Instead, a three -
dimensional model was built for approximately five square miles surrounding the study area.
Because of this limited data, the conceptual model is too simple and generalized to predict
conditions in specific areas of this complex hydrogeologic system. Furthermore, there are no
actual hydraulic conductivity measurements used in the model, nor is the model adequately
calibrated to actual water level measurements. See Comment A.1. The Division included this
as Comment I.2.a in the Additional Information Request #1 sent on October 5, 2023.
b. As stated in Comment J.3.a above, there are still insufficient data points for the scale of the
conceptual groundwater model. The limited amount of data available would be better used to
characterize conditions on an area-by-area basis and to support area-specific calculations of
groundwater mounding. It is not possible to assess the mounding analysis or the hydrogeologic
capacity of the proposed irrigation zones. See Comment A.1. The Division included this as
Comment I.2.b in the Additional Information Request #1 sent on October 5, 2023.
c. The Hydrogeologic Report indicates that the bedrock layer uses this hydraulic conductivity in
the conceptual groundwater model. The report does not indicate the hydraulic conductivity
used in the overburden, which is the primary concern for the mounding analysis. Please provide
a detailed characterization of the hydraulic conditions in the overburden, along with the specific
hydraulic conductivities used in the model, how they were distributed, and where they came
from. See Comment A.1. The Division included this as Comment I.2.c in the Additional
Information Request #1 sent on October 5, 2023.

Mr. Andrew Ross
March 11, 2024
Page 7 of 8
d. The Hydrogeologic Report has not addressed this comment. It is still not easy to identify
critical measurements and calculations for specific areas. The Hydrogeologic Report shall
include all the required information needed and present this information in a manner that makes
it easy to find and evaluate. See Comment A.1. The Division included this as Comment
I.2.d in the Additional Information Request #1 sent on October 5, 2023.
[15A NCAC 02U .0202(c), 02U .0202(e)]
K. Water Balance:
1. Please revise the Water Balance, if necessary, based on Comment A.1 and the comments in Section
J – Hydrogeologic Report.
L. Geotechnical Engineering Evaluation:
1. No comment.
M. Engineering Plans (Diehl & Phillips, P.A.):
1. No comment.
N. Engineering Plans (CE Group, Inc.):
1. No comment.
O. Specifications (Diehl & Phillips, P.A.):
1. No comment.
P. Specifications (CE Group, Inc.):
1. No comment.
Q. Engineering Calculations (Diehl & Phillips, P.A.):
1. No comment.

Mr. Andrew Ross
March 11, 2024
Page 8 of 8
R. Engineering Calculations (CE Group, Inc.):
1. See Comments F.1.a and F.1.b. Please revise the Engineering Calculations to (1) clearly show how
the designed annual and hourly loading rates were obtained, (2) specify the number of spray heads
in each irrigation zone and the assumed flow for each spray head model, and (3) annotate the
included manufacturer information to explain how the spray head flow was determined for each
model (nozzle type, operating pressure, etc.) [15A NCAC 02U .0201(c)(3)]
2. It is unclear why CE Group, Inc. specifies a 0.2 in/hr dosing rate and two (2) hour soak time
throughout the Engineering Calculations despite the Soil Evaluation stating the recommended
hourly loading rate is 0.4 in/hr (and the maximum dosing rate is 0.3 inches). The reviewer has
determined that the designed hourly loading rates exceed the specified 0.2 in/hr dosing rate for
many of the irrigation zones. Please clarify and revise.
S. Site Map:
1. No comment.
T. Operation & Maintenance Plan:
1. No comment.
U. Residuals Management Plan:
1. No comment.
V. Education Program:
1. No comment.
W. Additional Documentation:
 Operational Agreement (Form: DEV 03-19):
1. No comment.
 Threatened or Endangered Aquatic Species Documentation:
1. No comment.