WQ0000798_Additional Information Request #2_20210903

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
September 3, 2021
JOHN NICHOLS, PE, CPESC — PUBLIC UTILITY DIRECTOR
BRUNSWICK COUNTY
POST OFFICE BOX 249
BOLIVIA, NORTH CAROLINA 28422
Subject: Application No. WQ0000798
Additional Information Request 92
Shallotte WWTF
Wastewater Irrigation System
Brunswick County
Dear Mr. Nichols:
Division of Water Resources' Central and Regional staff has reviewed the application package
received June 3, 2021 and the resubmittal received July 26, 2021. 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 October 4, 2021.
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 Q, 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 an
electronic copy submitted to my attention at the email address below or to our upload site (URL:
https://edocs.deg .nc.gov/Forms/NonDischarge-Branch-Submittal-Form-Ver2).
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3660 or Lauren.Plummer(ancdenr.gov. Thank you for your cooperation.
Sincerer
ZDSig d byAJW
�Q�'Iummer, Engineer III
Division of Water Resources
cc: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Ken Pohlig, PE, Division of Water Infrastructure (Electronic Copy)
Carter Hubbard, PE — WK Dickson & Co., Inc. (Electronic Copy)
Permit Application File WQ0000798
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
NORTH CAROHNA -
oeaa�entote.Wro,memsiQuality r 919.707.9000

Mr. John Nichols, PE, CPESC
September 3, 2021
Page 2 of 8
A. Cover Letter:
The submitted documents were overall organized to a more navigable format; however, there seems
to have been some confusion about separating the Mulberry Branch documentation from Shallotte.
This confusion has led to some additional questions in the following sections. For example, the
force mains affiliated with the Mulberry Branch plant were often difficult to parse out from the
force mains affiliated with the Shallotte plant because the plans were not separated into individual
files for the two permit applications. When revising the documents to address the following
comments, please also take care to make clear indications of where revisions have occurred.
2. Within the cover letter and unit process summary, the effluent pump station consisting of two (2)
820 GPM at 128 ft TDH pumps is not to be modified. Please address the following:
a. Is this configuration currently operating as one main pump and one backup pump, as required
by 15A NCAC 02T .0305(h)?
b. It is our understanding that with the proposed facility piping changes, that these pumps will be
used to irrigate all of the fields rather than just the fields originally associated with the 325,000
gpd plant upon decommissioning of the smaller pump station. No information was provided
to demonstrate the suitability of the turbine pumps for the additional spay fields. Has modeling
been performed to confirm that the pressure needs of the system will be met with the current
effluent pump station configuration?
B. Application Fee:
1. No comment.
C. Application:
1. Within Item IV.3, the applicant indicated that an Environmental Assessment (EA) was required
under 15A NCAC O1C; however, the EA was still under review at the time of the submittal. Has
a Finding of No Significant Impact or Record of Decision been issued to the applicant since the
last submission? Please provide an update on the status of the EA.
2. Portions of the proposed work appear to occur within designated wetlands areas per the plan sheets
(e.g. the crossing of Mulberry Branch depicted on Plan Sheet C44). Have Nationwide 12/Section
404 or Wetlands 401 permits been submitted and/or approved? Please update the Table in Item
IVA and provide additional information, as needed.
3. Within Item IV.7, the applicant indicated that a flow reduction has been approved under 15A
NCAC 02T .0114(f). Further information regarding the approved flow reduction was not provided.
Please provide additional information.
4. The mechanical bar screen listed in Item V.11.a. indicates a design volume of 3.125 gpd, should
the units be 3.125 MGD? Also, per the engineering calculations it appears that the manual bar
screen is designed for a peak flow of 12.5 MGD. Please confirm that the mechanical bar screen is
sized for 3.125 MGD and revise the application as necessary.
5. Item V.1 I.e lists a single equalization basin jet motive pump for solids handling. This pump appears
to be identified in the engineering plans on Sheet M8 as "Pump EQP-1" and is also identified as

Mr. John Nichols, PE, CPESC
September 3, 2021
Page 3 of 8
singular in the Specifications (22 13 29 - 7). Pursuant to 15A NCAC 02T .0505 multiple pumps
shall be provided wherever pumps are used. Please review and revise as needed.
6. Within the Setback table (Item VIIL3), it is indicated that there is a 0 foot setback with the irrigation
system and surface waters (streams — intermittent and perennial, perennial waterbodies, and
wetlands). Pursuant to 15A NCAC 02T .0506, the setbacks for spray irrigation sites and surface
waters is to be maintained at 100 feet. The Non -Discharge Branch does not waive this setback.
7. Page 13 of the application form (WWIS 06-16) was not signed by either the Professional Engineer
or the Signature Authority. Pursuant to 15A NCAC 02T .0106, permit applications must be signed
and certified by an appropriate signature authority. Submittal packages including engineering
documents must be signed, sealed, and dated by a North Carlina licensed professional engineer in
good standing.
D. Property Ownership Documentation:
1. No comment.
E. Soil Evaluation:
1. The provided documentation was extensive, and it appeared that data was included from previous
project work unrelated to this project which created some confusion. Additionally, some of the
prior project reports appeared to present conflicting information. Please provide the following, or
provide a written response to each item and clearly point us to where this information is located in
the existing application:
a. A written response that clearly indicates how many hydraulic conductivity measurements were
taken for each soil series present,
b. A map that clearly shows where all Ksat measurements were conducted within the proposed
irrigation area and their relation to the soils mapped in this area,
c. A compete soil profile description for each hydraulic conductivity measurement point,
d. A copy of the field measurements indicating that steady state was reached for each test
conducted within the restrictive horizon for each soil series, and
e. A summary table of the measurements for each soil series present in the proposed irrigation
area.
F. Agronomist Evaluation:
1. The Soils Report indicated that phosphorus is slightly limiting. It was unclear from the engineering
documents which crop has been selected, but has phosphorus accumulation been considered in the
selection of the final cover crop in Field 14? Please provide additional information regarding
proposed nutrient management.
G. Hydroaeoloaic Report:
1. The Soils and Hydrogeologic Reports were submitted as a combined document, please see Section
E for questions pertaining to the hydrogeologic report.

Mr. John Nichols, PE, CPESC
September 3, 2021
Page 4 of 8
H. Water Balance:
1. No comment.
I. Enaineerini! Plans:
1. The proposed equalization (EQ) tank does not appear to be depicted or referenced along the
hydraulic profile on Sheet G5. Please revise Sheet G5 to include the EQ tank.
Per Sheet C 16, the proposed piping configuration for Existing Upper Lagoon 1 depicts a drain line
to Existing Lower Lagoon 3 adjacent to the inlet line. While the notes on the application indicate
that this line will be used for maintenance purposes for Existing Upper Lagoon 2 (see WWIS 06-
16 Item V.3), its proximity to the inlet line poses a significant risk of short-circuiting during these
maintenance activities. Please review and revise the design accordingly and include a detail for the
proposed inlet and outlet structures.
3. In addition to concerns with short-circuiting, it is unclear how the facility will operate if Lagoon 1
or Lagoon 3 must be taken out of service for maintenance. For instance, how will flow get from
the influent pump station to Lagoon 2 if Lagoon 1 must be taken offline for solids removal? Please
provide additional information and clarification in the event any of the lagoons are needed to be
temporarily taken out of service for maintenance or other activities.
4. The plan set depicts influent force main from Ocean Highway West to the proposed headworks,
has this been permitted separately? Sheets C22-C25 were not provided, but a related permit was
not listed in the application to indicate whether this force main had previously been reviewed and
permitted by DEQ staff. Please provide additional information and revise the engineering
documents as necessary.
Multiple call -outs on Sheet C26 indicate that the headworks piping plan is depicted on Sheet C16.
Sheet C 16 is titled the "Lagoon Piping Plan" and includes a callout indicating proposed headworks
see "Sheet C14". Sheet C14 is the "Headworks Site Layout, Grading & Drainage Plan" and
predominantly depicts the control points for the proposed structures. Sheet C15 was not provided
but is listed in the table of contents as the "WWTP Piping Plan", and not the "Headworks Piping
Plan", and it is unclear if it is referencing the Mulberry Branch treatment facility or the shared
proposed headworks. Please review and revise the call -outs pertaining to the headworks and
provide the "Headworks Piping Plan" for our review.
The "Sewer Line - Shared Trench" detail depicted within the Plan Set indicates an 18-inch
horizontal separation between parallel pipes for the reclaimed water (Mulberry Branch) infiltration
basin force main and the wastewater effluent (Shallotte) spray field force main. Pursuant to 15A
NCAC 02T .0305, the separation between reclaimed water lines and sewer lines must be 18 inches
in the vertical with reclaimed over sewer, or 24 inches in the horizontal. Please review and revise
the detail and force main alignments as necessary.
7. Per Sheet C33, a call -out indicating the location of an endangered plant species is listed near Sta.
2+00 that refers to "Note 3" with a similar call -out near Sta. 9+00 that refers to "Note 2"; however,
the indicated notes do not appear applicable or are not provided on the plan sheet. This error
appears to occur without the plan set (i.e. Sheet C41). Please review and revise as needed.
8. Per Sheet C40, the minimum cover near Sta. 8+65 along the Spray Field Force Main appears to be
less than 36 inches with a proposed pipe material of 12-inch PVC at that location. Pursuant to 15A

Mr. John Nichols, PE, CPESC
September 3, 2021
Page 5 of 8
NCAC 02T .0305(g), for less than 36-inches from final earth grade, ductile iron pipe shall be
required in any alternative. Please review and revise as needed.
9. The Overall Plan Infiltration Basins & Spray Area drawing (Sheet C48) depicts two "Sheet C53"
blocks. Are both blocks depicted on Sheet C53, or is one of them labelled in error? The Attachment
I information sheet indicates that nozzle information and air releases/drains, and control valves are
presented on Sheet C53. The provided plan set did not include Sheet C53, and we were unable to
review this information. Please provide the missing sheet and review and revise Sheet C48, if
necessary.
10. Per Sheet C56, the depicted field is labelled as Field No. 14 Area (East Side), but based on the
provided north arrow and the overall map on Sheet C48 it appears to be the western portion of the
proposed field. Please review and revise.
11. Some of the field geometries depicted on Sheets C56 and C57 are not attainable with radial spray
heads, and it is unclear whether 3600 spray heads are the only type proposed. The permitted field
acreage is to be based on both the wetted area of soils suitable for irrigation and limits due to the
setbacks listed in 15A NCAC 02T .0506. Please revise the field acreage to account for the
achievable wetted area. Please review and revise the engineering documents accordingly.
12. Per the submitted Plan Sheets it appears that the proposed spray fields are to be automatically
activated. Has a rain or moisture sensor been included in the design to prevent irrigation during
precipitation events or wet conditions that would cause runoff, per 15A NCAC 02T .0505(x)?
13. Per Sheet M1, there are call -outs for the 12-inch by-pass lines located near the manual bar screen
and the rotary drum screen. Per Sheet M2, these by-pass lines appear to connect to the influent 12-
inch DIP force main refer to Sheet C15. Sheet C15 was not provided, and it is unclear where these
by-pass lines (not listed in the application form) are flowing to. Please note that pursuant to 15A
NCAC 02T .05050) by-pass and overflow lines shall be prohibited. Please provide additional
information and review and revise as needed.
14. Within the plan sheets the headworks have been routinely packaged as a singular unit (as shown
on the hydraulic profiles and within the C sheets). Due to the compact nature of the design, and
the numerous provided section views, it is a bit disorienting to follow the influent flow path through
the proposed system. A qualitative walkthrough was provided within the engineering calculations;
however, a visual of the flow path would be beneficial to our review. Please provide a linear flow
path that includes call -outs for the different treatment units to help clarify the proposed system
design.
15. Within Detail 3 on Sheet M3 a by-pass is identified in the vicinity of the jib crane within the section.
It is unclear where this by-pass is located as it does not appear to be called out on Sheets M1 or
M2. Please note that pursuant to 15A NCAC 02T .05050) by-pass and overflow lines shall be
prohibited. Please provide additional information and review and revise as needed.
16. The details depicted on Sheets M3 through M5 have numerous sections labelled "Headworks", but
they appear to be designed to highlight specific components of the proposed headworks. Please
consider adding clarification regarding the specific components presented. For example D6 on
Sheet M5 appears to be focused on the rotary drum screen.
17. Per Sheet D7, the monitoring well construction detail does not depict the permanently affixed
identification plate as required under 15A NCAC 02C .0108(p). Please review and revise as
needed.

Mr. John Nichols, PE, CPESC
September 3, 2021
Page 6 of 8
18. Per Sheet D7, detail drawings for the relation of water and sewer mains to storm sewer and the
relation of water mains to sewer mains was depicted; however, a similar detail drawing for the
relations of reclaimed water mains to potable water mains and sewer mains was not included.
Please provide a detail drawing for reclaimed water main separation requirements.
19. A portion of the proposed modification includes the removal of Fields IA and 113. The Plan Set
submitted did not appear to include demolition/decommissioning plans for these fields. Will
portions be capped and abandoned in place or will the existing infrastructure be removed? Please
provide additional information and a plan sheet depicting the extent of the proposed field removal
activities.
J. Specifications:
1. Specifications must be signed, sealed, and dated by a North Carolina licensed Professional Engineer
in good standing. Please provide a certified cover sheet for the Project Specifications.
2. Per 09 90 00 — 9 the color -coding requirements include finished water, but it was noted that the
colors called out for treated wastewater effluent to the sprayfields and treated reclaimed water to
the infiltration basins identified in the Plan Set were not included in this table. Please review and
revise.
3. Within Section 31 10 00, it appears that no reference is made regarding procedures for the
identification and relocation of endangered plant species within the limits of disturbance as
indicated within the Plan Sheets. Please review and revise as needed.
4. The Specifications regarding Seeding (32 92 19) only address final seeding, and the requirements
predominantly focus on the high -rate infiltration basins. Please provide seeding recommendations
for the spray irrigation field areas and include the temporary seeding requirements and riparian
seeding requirements outlined in the Plan Sheets. Please revise the engineering documents as
necessary.
5. Within the definitions of Section 33 1100, the utility company is listed as Lincoln County. Please
review and revise as needed.
Numerous sections of the Specifications reference Section 40 72 13 Ultrasonic Level Meters;
however, this section was not provided in the submitted Specifications set. Please review and
revise.
K. Engineering Calculations:
1. Within the basis of design section for the influent pump station it is unclear which pumps were
selected for the Shallotte plant. It appears that three (3) self -priming, 520 GPM variable frequency
drive, 20 HP pumps are proposed for the transfer to Mulberry Branch WWTP, but it is unclear
which pumps have been selected for the other three pumps. Please clarify and revise as needed.
2. Within the narrative for the System Head Curve of Grit PS, two separate scenarios involving usage
of the grit pump are provided (sump pump versus grit washer). The scenario labels on the next
page discuss new level pipe and old pipe. The narrative of the influent pumps similarly lists two
scenarios but identifies them as new versus old pipe. Are the Grit PS scenario labels in error?
Please provide additional information and revise as needed.

Mr. John Nichols, PE, CPESC
September 3, 2021
Page 7 of 8
3. The calculations for the Spray Irrigation system provide a precipitation rate of 0.13 in/hr; however,
the loading rate on the application (Item VIL3) lists a rate of 2 in/hr. Other provided documentation
indicates that application will be 0.2 in/dose (not to exceed 1 in/week). Pursuant to 15A NCAC
02T .0505(n), the irrigation system design shall not exceed the recommended precipitation rates
established in the soils report. Please review, revise, and provide additional information as needed.
4. Is total flow to spray irrigation 700 gpm (listed under site characteristics) or 1100 gpm (listed under
assumptions)? Please provide additional information and review and revise as necessary.
L. Site Map:
The Plan Sheets identified C3, C4, C7, C8 ,and C53 — which was missing from the provided
submittal — to be considered as the site maps. These sheets did not appear to include a map of the
existing spray fields. The site maps are used during permit writing and should encompass the entire
permitted facility. Please note that the final engineering plans will be approved separately, and
many applicants choose to create site maps separate from the plan set that utilize both topographic
contour base maps and aerial base maps to assist in pointing out key features such as lagoons, spray
fields, and property boundaries. For reference, the existing facility's site map is included as Figure
1 of the Existing Permit for WQ0000798. Please review and revise your site maps so that the entire
permitted facility is depicted.
M. Power Reliability Plan:
1. The documentation for the Power Reliability Plan was not included in the submittal (the pdf
"bookmarks" jump from Attachment L to Attachment P). Please provide documentation to indicate
that the requirements of 15A NCAC 02T .0505(1) are met for our review.
N. Operation & Maintenance Plan:
1. The Operation & Maintenance (O&M) Plan was not included in the submittal (the pdf "bookmarks'
jump from Attachment L to Attachment P). Please submit an O&M Plan meeting the requirements
of 15A NCAC 02T .0507 for our review.
O. Residuals Management Plan:
1. The submitted Residuals Management Plan was prepared for the Mulberry Branch WWTP and not
the Shallotte WWTF. Please provide the Residuals Management Plan pertinent to the Shallotte
facility (WQ0000798) that meets the requirements of 15A NCAC 02T .0508.
P. Additional Documentation:
➢ Certificate of Public Convenience and Necessity:
1. Not applicable.
➢ Existing Permit:
1. A copy of the Residuals Land Application Permit WQ0034513; however, the Shallotte facility
is not listed on the Attachment A in the provided document dated and certified September 27,

Mr. John Nichols, PE, CPESC
September 3, 2021
Page 8 of 8
2016. The most recent certified Attachment A is dated March 8, 2018. Please note that
Shallotte WWTF is currently permitted a total of 1,500 dry tons per year. Are the proposed
modifications anticipated to generate additional tonnage from the Shallotte facility's lagoons
and proposed headworks? An increase in dry tonnage will require modification to the existing
permit. Also, residuals generated by the Mulberry Branch facility will have to be added via
permit modification prior to disposal via land application under WQ0034513.
➢ Final Environmental Document:
1. The submittal indicated that an Engineering Report/Environmental Information Document was
submitted on December 17, 2020; however, a final ruling/response was not provided. Please
provide the Finding of No Significant Impact (FONSI) or the Record of Decision (ROD) for
our review.
2. Section 7.10 of the Environmental Information Document indicated that a Figure 7.10 depicting
endangered species was part of the report. Is this the map titled "Federally Protected Species"?
We were unable to locate this map within the submitted file.
➢ Floodway Regulation Compliance:
1. A portion of the proposed sprayfields are located within the 100-year floodplain. The
documentation of No Impact provided in the submittal appears to reference the proposed
culvert construction at Mulberry Branch and does not reference the potential impacts of the
proposed wastewater irrigation spray field. Within Chapter 143 Article 21 Part 6 of the
General Statutes, it is stated that a local government may adopt ordinances to regulate uses in
flood hazard areas and grant permits for the use of flood hazard areas that are consistent with
the requirements of this Part. Please provide written documentation from all local governing
entities that the proposed facility modifications are in compliance with all local ordinances
regarding construction or operation of wastewater treatment and/or disposal facilities within
the floodplain.
➢ Operational Agreements:
1. Not applicable.
➢ Threatened or Endangered Aquatic Species Documentation:
1. A map was provided labelled the "Federally Protected Species" document and it was indicated
that this project will not impact any endangered species. However, throughout the plan sheets
there are several call -outs indicating the location of endangered species along the force main
alignments. Please provide additional information regarding the referenced endangered plant
species and any pertinent documentation of these impacts.
➢ Wastewater Chemical Analysis:
1. Not applicable.
Q. Recommendations: (Response not required)
Within the submittal package and site visit, the applicant indicated that a portion of the
proposed spray irrigation area is located in a Zone A (100-year) flood plain. Although an
attempt was made by the applicant to justify the installation of spray heads in this area, our
staff would prefer the applicant find other suitable area(s) which are not within the flood plain.