WQ0007569_More Information (Requested)_20200406

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
April 6, 2020
J. BRYCE MENDENHALL — VICE PRESIDENT OF OPERATIONS
CAROLINA WATER SERVICE, INC. OF NORTH CAROLINA
4944 PARKWAY PLAZA BLVD, SUITE 325
CHARLOTTE, NORTH CAROLINA 28217
Subject: Application No. WQ0007569
Additional Information Request
Brandywine Bay WWTF
High -Rate Infiltration System
Carteret County
Dear Mr. Mendenhall:
Division of Water Resources' Central and Regional staff has reviewed the application package
received January 23, 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 May 6,
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
in Sections A through P, 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), with two paper
copies and one electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3658 or [e-mail]. Thank you for your cooperation.
Sincerely,
Ashley Kabat, Environmental Engineer
Division of Water Resources
cc: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Linwood E. Stroud, PE — Stroud Engineering, PA (Electronic Copy)
Permit Application File WQ0007569
D E 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
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Mr. J. Bryce Mendenhall
April 6, 2020
Page 2 of 5
A. Cover Letter:
1. Due to the operational issues at the current facility including storage ponds that are infiltrating, lack
of an agreement to operate the spray irrigation system located on the golf course, and deteriorating
equipment, please provide a schedule for completion of the proposed modifications.
B. Application Fee:
1. No Comments
C. Application:
1. In application item IV.10., every monitoring well is labeled outside of the compliance boundary.
Monitoring wells should be located on the review boundary so the Permittee can take corrective
action before groundwater contamination reaches the compliance boundary. Propose a monitoring
well network that has at least three downgradient wells located on the review boundary for the
proposed high -rate infiltration system. [ 15A NCAC 02L .0106]
2. In application item V. L, fill out the estimated influent and designed effluent concentrations for
Nitrate Nitrogen, Nitrite Nitrogen, and Total Kjeldahl Nitrogen. [15A NCAC 02T .0705(b)]
3. In application item V.B., respond with how the Applicant proposes to prohibit public access to the
wastewater treatment and storage facilities (ex. fence, gate, locks, etc.). [ 15A NCAC 02T .0705(p)]
4. In application item V.1 l.c., provide the capacity information for the groundwater lowering pumps.
5. In application item VII.2., respond by saying the artificial drainage or water movement structures
will be maintained or they will be modified. [15A NCAC 02T .0706]
6. Application item VIII.2. was left blank. Identify if setback waivers have been obtained for this
facility. If setback waivers are not required, mark "no."
7. Application section X states there is a 691,200 GPD groundwater lowering system that discharges
water to a golf course irrigation pond. More details on this pond or series of interconnected ponds
will need to be provided to determine if the ponds have the capacity for this flowrate and to verify
the ponds are not connected to any surface waters, wetlands, and/or storm water structures. [15A
NCAC 02T .0704(c)]
D. Pronerty Ownership Documentation:
1. The proposed system pumps groundwater from the groundwater lowering system to ponds located
on a nearby golf course. The parcel of land these ponds are located on is owned by Jassa Group,
LLC. Provide an agreement between Jassa Group, LLC and Carolina Water Service, Inc. of North
Carolina allowing the use of these ponds as groundwater lowering discharge disposal and agreeing
to accept up to 691,200 GPD of groundwater from this system. [15A NCAC 02T .0704(f)]
2. The parcel containing the proposed wastewater treatment and disposal system is not adjacent to the
parcel of land accepting the groundwater lowering discharge. Provide easement agreements for the
pipe conveying the groundwater to the golf course ponds. [15A NCAC 02T .0704(fl]

Mr. J. Bryce Mendenhall
April 6, 2020
Page 3 of 5
E. Soil Evaluation:
1. No Comments
F. Agronomist Evaluation:
1. N/A
G. Hydrouologic Report:
1. No Comments
H. Water Balance:
1. No Comments
I. Engineering Plans:
1. On sheet C3, the review boundary and compliance boundary are drawn incorrectly. In the bottom
right corner, the compliance boundary has a gap — please make this continuous. In the center
between the two high -rate infiltration basins, the compliance and review boundaries cross over the
groundwater lowering drain which is not allowed. Please draw separate boundaries for each high -
rate infiltration basin. [15A NCAC 02L .0107, .0108, 15A NCAC 02T .0705(y)]
2. Well names MW-9 and MW-10 are currently being used for monitoring wells located on the golf
course. Please use new nomenclature so these wells are not confused.
3. On sheet C3, correct the label that says "300,000 GPS SBR WWTP."
4. Provide details on the pipes that convey groundwater lowering discharge to the golf course ponds
and show which pond(s) the water will be stored in. [15A NCAC 02T .0704(c)]
5. Provide a plan and profile detail on the influent pump station. [ 15A NCAC 02T .0704(c)]
6. Confer with the Wilmington Regional Office on where to properly place monitoring wells. [15A
NCAC 02L .01061
7. Specify who did the wetlands delineation shown in the Engineering Plans.
8. Provide duality for the post-EQ blower and the digester blower or explain how duality is already
being achieved with the current configuration. [15A NCAC 02T .0705(v)]
9. Provide pump duality for the digester jet motive pump or explain how duality is already being
achieved. [15A NCAC 02T .0705(i)]
10. On sheet C10, the dewater well section view depicts a PVC cap on the wellhead. How will this
provide a vacuum tight connection and prevent pressure losses?

Mr. J. Bryce Mendenhall
April 6, 2020
Page 4 of 5
11. On sheet CIO, the well details do not depict a 2-foot concrete pad around the perimeter of the well,
an outer casing, a permanently affixed registration plate, and a locking well cap which are required
by NCAC 02C .0108. Please depict these requirements. [ 15A NCAC 02C .0108]
12. On sheet C10, the cross -hatched area shown on the infiltration basin section views is labeled "low
permeability material depth" which implies that the area will be filled with fill material. This will
cause lateral movement of the treated wastewater directly into the groundwater lowering pipe that
will discharge into a pond. All area containing fill (non-native) material will be considered part of
the disposal area unless the design complies with § 143-215.1. According to a memo from the
EPA, if a preferential pathway from the infiltration basin to the groundwater lowering pipe through
non-native soil is provided, the effluent from the groundwater lowering system will be considered
wastewater and the discharge, storage, or irrigation of that wastewater will require an applicable
permit. In order to dispose of this water as groundwater and not treated wastewater, native soil
(100 feet) must be provided between the infiltrative area and the groundwater lowering pipe. [
143-215.1]
13. Provide detail drawings on the groundwater lowering pipe. [I 5A NCAC 02T .0704(c)]
14. Provide a detail drawing on the ultraviolet disinfection system. [15A NCAC 02T .0704(c)]
15. Provide a construction sequence drawing or notes showing in what order each component will be
constructed in order to allow operation of the WWTP and disposal system during construction.
[ 15A NCAC 02T .0704(c)]
16. Disposal areas shall be designed to maintain a one -foot vertical separation between the seasonal
high water table and the ground surface. Show that this design meets this separation, or apply for
Alternative Design Criteria to waive this requirement. [15A NCAC 02T .0705(o)]
J. Specifications:
1. Provide a closure plan for the 1.25 MG and 7.5 MG ponds incorporating the required items from
the Guidelines for the Closure of Permitted Wastewater Ponds and Lagoons memo issued June 22,
2012. [15A NCAC 02T .0704(c)]
2. The Engineering specifications mention that essential treatment units of the existing WWTP will
be kept in operation until the new WWTP is operational, but does not specify how treated
wastewater will be disposed of during active site construction. Please specify where the treated
wastewater stored in the 1.25 MG and 7.5 MG ponds will be disposed of when pumped out, and
where the treated effluent to the existing WWTP will be stored and disposed of during construction
of the high -rate infiltration basins. [ 15A NCAC 02T .0704(c)]
K. Engineering Calculations:
1. Provide pollutant loading calculations for reduction of fecal coliforms from UV disinfection. [ 15A
NCAC 02T .0704(c)]
L. Site Map:
1. Incorporate applicable comments from section 1. [15A NCAC 02T .0704(d)]

Mr. J. Bryce Mendenhall
April 6, 2020
Page 5 of 5
M. Power Reliability Plan:
1. No Comments
N. Operation & Maintenance Plan:
1. Add information in the operation and maintenance plan on how to properly maintain the high -rate
infiltration basins to prevent the infiltrative surface from clogging. [ 15A NCAC 02T .07071
2. Add information to the operation and maintenance plan on how to properly operate and maintain
the groundwater lowering system. [ 15A NCAC 02T .07071
O. Residuals Management Plan:
1. Submit a formal residuals management plan that specifies where residuals will be generated in the
treatment and disposal works, how they will be collected, processed, stored, treated, and disposed.
Also provide an evaluation of the facility's residuals storage capacity and provide an estimated
schedule of how often residuals will need to be removed from the facility. [ 15A NCAC 02T .07041
P. Additional Documentation:
➢ Certificate of Public Convenience and Necessity:
1. No Comments
➢ Existing Permit:
1. No Comments
➢ Final Environmental Document:
1. N/A
➢ Floodway Regulation Compliance:
1. N/A
➢ Operational Agreements:
1. N/A
➢ Threatened or Endangered Aquatic Species Documentation:
1. Submit the Threatened or Endangered Species report ordered from the Natural Heritage
Program on January 14, 2020. [15A NCAC 02T .0105(c)]
➢ Wastewater Chemical Analysis:
1. N/A