WQ0041643_More Information (Requested)_20200710

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
July 10, 2020
STEVEN C. MAYNE — CHIEF FINANCIAL OFFICER
THE EAST COAST MIGRANT HEAD START PROJECT
2301 SUGAR BUSH ROAD, SUITE 400
RALEIGH, NORTH CAROLINA 27612
Subject: Application No. WQ0041643
Additional Information Request
East Coast at Montague WWTF
Wastewater Irrigation System
Pender County
Dear Mr. Mayne:
Division of Water Resources' Central and Regional staff has reviewed the application package
received April 28, 2020. 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 August 10, 2020.
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,
or failure to provide the additional information on or before the above requested date may result in your
application being returned as incomplete.
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), and submitted
electronically.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3660 or [e-mail]. Thank you for your cooperation.
Sincerely,
/CA4., -t �
Tessa Monday, Environmental Engineer
Division of Water Resources
cc: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
James Holland, PE — W.K. Dickson (Electronic Copy)
Permit Application File
DE Q�� North Carolina Department of Environmental Quality I Division of Water Resources
_ 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CARC CHINA
..,. am ofEnimnmenbia,afity /� 919.707.9000

Mr. Steven C. Mayne
July 10, 2020
Page 2 of 6
Division staff noted that the monitoring wells constructed on site do not meet the 15A NCAC 02C rules. They
do not have concrete well pads, well tags, or even well caps. This must immediately be resolved. Permits are
required to construct any monitoring wells constructed to assess hydrogeologic conditions on property not
owned by the well owner. All wells must be built to 2C Standards or properly abandoned.
A. Application (15A NCAC 02T .0105):
1. Provide the status on the Erosion & Sediment Control Plan.
2. The Applicant has selected yes for being a Developer. Clarify as it doesn't seem the Applicant is a
Developer.
3. Per 15A NCAC 02T .505(o), 30 days of residual storage is required. Explain where the residual solids
will be stored.
4. Verify that Application Item VII.2. is correctly answered. According to regional office staff, there are
constructed ditches in the vicinity. Ensure that there are no water movement structures within 200 feet of
the proposed irrigation area.
5. Due to the issues listed in the soil evaluation section below, groundwater monitoring wells will be
required. Provide a groundwater monitoring plan per 15A NCAC 02L .0110.
6. The compliance and review boundary are on the wetted perimeter of the proposed irrigation field on the
side next to Montague Road. The effluent will be required to meet groundwater standards due to there
being no distance to allow for natural treatment of the irrigated wastewater prior to reaching the
review/compliance boundary.
7. The data sheets included with the specifications indicate that the Bioclere Units are equipped with pumps
to recycle and dose the wastewater, but no mention is made of these pumps within the application.
Provide all necessary specifications and calculations. Include in the application form.
B. Soil Evaluation (15A NCAC 02T .0504(b)):
The following comments are from staff soil scientists Gary Kreiser and Patrick Mitchell:
1. Ensure the average conductivity measurement is the geometric mean of all measurements taken.
2. The soils profile descriptions provided do not match what was found during soils site visit. Of the three
soil profile descriptions, two only described two soil horizons and the third described three horizons.
Staff took four soil borings and found four to six horizons present between 1 to 40 inches. The site must
be re-evaluated by a Licensed Soil Scientist to provide accurate soils profile descriptions.
3. Provide a soils map meeting the requirements in the Division's Soil Scientist Evaluation Policy.
4. The report provided incomplete soils analysis results. Provide results for all required parameters.
5. Hydraulic conductivity measurements were not conducted in the limiting horizon (i.e., the Bh horizon)
observed between 15 and 25 inches deep in the borings done by staff soils scientists. Measurements in
this horizon are required. Address.

Mr. Steven C. Mayne
July 10, 2020
Page 3 of 6
6. Division staff think the proposed hourly rate of 1.25 inches is on the high side. A rate of 1 inch per hour
or less is recommended.
7. The soils report indicates 0.42 acres proposed for irrigation. The application indicates 0.578 acres.
Ensure the soils report covers all of the proposed irrigation area.
The site is artificially drained which makes the method used to measure saturated hydraulic conductivity
questionable in terms of accuracy and appropriateness for this site. The site is drained by a roadside ditch
that is greater than 36 inches deep and runs along the south and west borders of the parcel. Also, an
onsite borrow pit or pond that is greater than 4 feet deep to the water's surface. This can result in
artificially high conductivity measurements when using the pumped -borehole method. A method such as
the constant head may be more appropriate to measure conductivity. Both drainage features were found
to have standing water present in them at the time of the visit with reportedly no rainfall within 48 hours
prior to the visit.
9. Using the soil morphology described in the four soil borings conducted by the staff soil scientists, the
water table is at or near the ground surface for extended periods during a given year. This matches the
NRCS Soil Survey description for the soils at the site, with the water table being present at or near the
ground surface for four or greater months out of the given year. During the site visit, soils were found to
be physically saturated as shallow as two inches below the ground surface. Free water (i.e., apparent
water table) was observed to be present in our auger borings at approximately 10 to 12 inches deep.
These conditions were found to be present even during one of the dryer portions of the year, with artificial
drainage, and with no recent rainfall. This needs to be addressed in the soils report.
10. The soil wetness conditions described make this site an unsuitable candidate for a fill mound irrigation
area, as proposed with the proposed irrigation volume (2,000+ GPD), and the proposed sandy fill
materials. The proposed irrigation would likely result in lateral flow of wastewater, thus leading to
ponding and runoff. Perching or mounding would also likely result during extended periods of the year
resulting in system failure and overland flow discharges. A mounding analysis and more detail on the fill
material would be required to justify this would not happen.
11. The proposed fill material mound plan is unsuitable and does not provide details necessary for permitting
such a site. For example, the fill mound does not extend far enough beyond the wetted area to the north.
The wetted perimeter and mound soils edge are the same and located immediately adjacent to the parking
lot. The specific types of soils to be brought in are not adequate or appropriate for the proposed plan. See
comments below in the fill material section.
12. The proposed storage and treatment tanks and located immediately adjacent to the irrigation area, at the
edge of the fill system mound. The required setback for cuts 2 feet or greater is 15 feet. Address.
13. Address the proposed irrigation area directly adjacent to the parking lot. A greater distance would
provide more space for enough lateral water movement before reaching the compacted parking lot.
14. Verify the PAN calculations. It should be 104.7 pounds of phosphorus loaded onto the 0.42 acre area.
15. The proposed irrigation area is located within an area mapped by NCDCM as wetlands. The site has been
modified in the past with drainage features, but if an official determination has not been conducted, it is
necessary that a wetland determination (approved by the Army Corps of Engineers) be provided.
16. The proposed cover crop is unsuitable for a small mound system on a naturally saturated soil, and with
the proposed hydraulic loading. The heavy hydraulic load would result in poor growth or death of the
primary cover crop as Bermuda grass does not like saturated conditions. Furthermore, the vegetative

Mr. Steven C. Mayne
July 10, 2020
Page 4 of 6
cover rotation with annual winter crop over -seeding is not ideal. Equipment usage and the disturbance
necessary for annual crop over -seeding could potentially result in damage to the sand mound.
C. Fill Material (15A NCAC 02T .0504(b)):
1. The soil report needs to address the following:
i. Proposed fill material depth (including additional material to account for settling over the life of
the disposal field (2 additional inches is recommended).
ii. Type of fill material for the establishment of vegetative cover. Fill shall have no more than 10%
by volume of fibrous organics, building rubble, or other debris and shall not have discreet layers
containing greater than 35% of shell fragments.
iii. Identify areas of concern such as gullies, areas of ponding, unstable slopes, etc.
iv. Maximum slope of the site.
2. The specifications need to address the following:
i. Specifications need to be site specific (vegetation, topography, etc.).
ii. Fill material will have fertility analysis and recommend amendments for proposed cover crop
iii. Erosion and sediment control plan
iv. Clear and grub site by hand in such a manner as to minimize native soil loss and compaction.
V. The proposed irrigation area should be raked to remove all leaves, pine straw, and other debris.
vi. Remove vegetation less than 8 inches in diameter.
vii. Extend fill material at least 5 feet beyond the wetted area and blend into the natural contours.
viii. Incorporate the fill material with the top 3 to 6 inches of native soil to prevent capping and
preferential lateral flow.
ix. Lightly compact the fill material to achieve a bulk density similar to that of the naturally
occurring topsoil of similar soil texture and indicate what the desired bulk density should be.
X. Fill material should be tapered down to the surrounding ground surface with a side slope gradual
enough to not cause erosion.
3. The Operation and Maintenance Plans shall include the following:
i. All maintenance shall be done by hand
ii. Maintain vegetation
iii. Maintain the integrity of the fill
iv. Maintain the fill crown to have proper drainage
V. Maintain depth to the seasonal high-water table (may require additional fill over time)
vi. Grade rills and gullies
vii. Fill any low areas that are ponding water
4. The engineering plans shall include the following:
i. Show all stormwater management controls. Stormwater diversions and subsurface interceptor
drains or swales may be needed upslope of the system to diver runoff or lateral flow from passing
over or into the disposal field.
ii. Include the fill specifications to ensure proper construction.

Mr. Steven C. Mayne
July 10, 2020
Page 5 of 6
D. Water Balance (15A NCAC 02T .0504(k)):
1. The water balance calculations must be signed, sealed, and dated by a qualified professional.
2. Verify the precipitation is based on the 80t' percentile and a minimum of 30 years of observed data.
3. Address if wet weather storage will be needed during hurricane season. The proposed irrigation tank has
approximately 5 days of storage.
E. Engineering Plans (15A NCAC 02T .0504(c)(1)):
1. Ensure to show all stormwater structures and ditches on Sheet C.5.
2. Provide a process and instrumentation diagram showing all flow, recycle/return, aeration, chemical,
electrical, and wasting paths.
3. The units shown on Sheets C.7 and C.8. don't all correspond to the units listed in the application form.
There is a 1,000 gallon unknown unit (possibly the lift station) listed in the application, no sand filters are
shown, and there is a moving bed anoxic reactor not listed in the application. Clarify.
4. Ensure to show all pumps on Sheets C.7 and C.8.
5. Sheet C.8. references an alkalinity feed. This must be included in the application — pump and storage
tank. Provide all necessary specifications and calculations. Include in the application form.
6. Ensure that the plan and profile views of treatment and storage units includes all piping, valves, pumps,
blowers, mixers, flow meters, etc.
7. The plans identify chemical feeds at the moving bed anoxic reactor. Explain what this is and include in
the application. Provide all necessary specifications and calculations. Include in the application form.
8. The treatment system is proposed to have a parking lot built on top. Show the proposed parking lot and
access points to the treatment and storage units.
9. Plans shall represent a completed design and not be labeled with preliminary phrases that indicate they are
anything other than final specifications.
10. The capacity of the settling tank is different throughout the application. The application indicates 5,000
gallons, but the engineering plans indicate 1,257 gallons.
F. Specifications (15A NCAC 02T .0504(c)(2):
1. The allowable leakage, as indicated in Section 4.06 does not adhere to the Minimum Design Criteria per
15A NCAC 02T .305(b)(3).
2. Section 5.02 J indicates that the UV systems within the Granular Media Filter will be for open channel
gravity flow. However, the data sheets provided for this device indicate that the units are designed for
pressure applications. Revise or explain.

Mr. Steven C. Mayne
July 10, 2020
Page 6 of 6
G. Engineering Calculations (15A NCAC 02T .0504(c)(3)):
1. Provide pollutant loading calculations for each treatment unit demonstrating how the designed effluent
concentrations were determined.
2. The buoyancy calculations for the EQ tank are for a larger tank (5' vs. 9' height). Address.
3. The calculations indicate the EQ pumps have a TDH of 9.5 feet, but the specification indicate 9.4 feet.
Clarify.
4. The calculations indicate the lift station pumps have a TDH of 11.5 feet, but the specifications indicate
17.8 feet. Clarify.
5. The dosing pumps are indicated as 14 GPM, but 10 GPM in the specifications. Clarify.
H. Operation and Maintenance Plan (15A NCAC 02T .0507):
1. Provide contact information for plant personnel, emergency responders, and regulatory agencies.
L Power Reliability Plan (15A NCAC 02T .0505(1):
1. The following must be verified in order to waive the requirement of having activated standby power
supply:
i. Serves a private water distribution system that has automatic shut-off during power failures and
has no elevated water storage tanks;
ii. Has sufficient storage capacity that no potential for overflow exists; and
iii. Can tolerate septic wastewater due to prolonged detention.
J. Residuals Management Plan (15A NCAC 02T .0504(i)):
1. Provide an evaluation of the treatment facility's residuals storage requirements based upon the maximum
anticipated residuals production rate and ability to remove residuals.
2. Provide a written commitment to the Applicant from a Permittee of a Department approved residuals
disposal/utilization program that has adequate permitted capacity to accept the residuals or has submitted
a residuals/utilization program application.
3. If on -site food preparation is contributing wastewater to this system, an oil/grease disposal plan shall be
submitted.