WQ0043421_Additional Information Request #1_20220729

July 29, 2022
DAVID HUGHES – MANAGER
SHINNVILLE FARMS DEVELOPMENT PARTNERS, LLC
236 RACEWAY DRIVE – SUITE 7
MOORESVILLE, NORTH CAROLINA 28117
Subject: Application No. WQ0043421
Additional Information Request
Shinn Village WWTF
Wastewater Irrigation System
Iredell County
Dear Mr. Hughes:
Division of Water Resources’ Central and Regional staff has reviewed the application package
received May 6, 2022. 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 29, 2022.
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 R, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).

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 response submitted to my attention at: https://edocs.deq.nc.gov/Forms/NonDischarge-Branch-
Submittal-Form-Ver2.

If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Lauren Raup-Plummer, Engineer III
Division of Water Resources
cc: Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Gary S. MacConnell, PE – MacConnell & Associates, P.C. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. David Hughes
July 29, 2022
Page 2 of 7
A. Overall:
1. The Wastewater Irrigation System application (FORM: WWIS 06-16) form was submitted with the
application package; therefore, this system is to be classified as a wastewater irrigation system
regulated under the 15A NCAC 02T .0500 rules. Under the 15A NCAC 02T .0500 rules, treating
wastewater effluent to reclaimed water standards allows the reduced setback to property lines under
.0506(c); however, the public access requirements for the treatment, storage, and irrigation areas
are to be in accordance with the 02T rules.
During our review, the Non-Discharge Branch noticed several references to the “Shinn Village -
Reclaimed Water System” within the submitted documents. If the proposed facility was intended
to be submitted as a Reclaimed Water system governed under 15A NCAC 02U, then please submit
the Reclaimed Water Systems - Project Information (FORM: RWPI 06-16) application with the
appropriate additional forms (i.e., RWG 06-16 for Reclaimed Water Generation and RWNC 06-16
for Reclaimed Water Non-Conjunctive/Dedicated Utilization). Please note, in order for a facility
to be regulated under 15A NCAC 02U, it must meet the requirements outlined in 15A NCAC 02U
.0100.
Please confirm that the proposed facility was designed to meet the requirements of 15A NCAC 02T
.0500, or revise the submittal as needed.
B. Cover Letter:
1. No comment.
C. Application Fee:
1. No comment.
D. Application:
1. Mr. David Hughes signed the application as Manager of Shinnville Farms Development Partners,
LLC; however, the registered business documents filed with the NC Secretary of State’s office -
and provided with this application - do not list Mr. Hughes as a member or officer of the
organization. The only individual currently listed as being associated with Shinnville Farms
Development Partners, LLC is Mr. Todd Jason Farlow, the registered agent and organizer. Please
provide documentation showing that Mr. David Hughes has the signature authority required by
15A NCAC 02T .0106 for Shinnville Farms Development Partners, LLC. In the case of a
corporation, this shall mean a principal executive officer of at least the level of vice-president or
his authorized representative.
2. Section IV.7 indicates that a flow reduction has been approved under 15A NCAC 02T .0114(f).
Please submit a copy of the flow reduction request approval letter.
3. The response to Section V.8. indicates that 32.13 days of residuals storage are provided to meet the
requirements of 15A NCAC 02T .0505(o). Is this the effective storage time of the effluent storage
lagoon? Residuals refers to any waste product other than effluent as defined in 02T .0103(30).
Please provide clarification and information regarding residuals storage.
Mr. David Hughes
July 29, 2022
Page 3 of 7
4. Section VII.5. describes public access being provided to the irrigation system including walking
trails. Pursuant to 15A NCAC 02T .0505(q), the public shall be prohibited access to the treatment,
storage, and irrigation facilities. Additionally, irrigation areas shall have a year-round vegetative
cover pursuant to 15A NCAC 02T .0507(b), and it is unclear what “natural surface walking trail”
encompasses as a detail and further information were not provided.
5. Within Section VIII. Setbacks, several of the minimum field observed distances for the spray
irrigation system do not meet the requirements pursuant to 15A NCAC 02T .0506(a). Achieving
the reclaimed water effluent standards pursuant to 15A NCAC 02T .0506(c) permits the system to
use the setbacks in 15A NCAC 02U .0701(d) for property lines only. Was this system originally
designed as a reclaimed water system under 02U regulations? If the intent is to permit this facility
as a wastewater irrigation system, then please revise the design to meet the requirements in 15A
NCAC 02T .0506 and update Section VIII. Setbacks of the application, accordingly.
E. Property Ownership Documentation:
1. No comment.
F. Soil Evaluation:
1. No comment.
G. Agronomist Evaluation:
1. No comment.
H. Hydrogeologic Report:
1. The hydrogeologic report prepared by S&ME, Inc. recommends that the monitoring wells installed
as part of the assessment (i.e., MW2, MW3, MW4, MW7, and MW10) be properly abandoned.
The provided plan set and application did not indicate that these wells were to be abandoned;
however, several of these wells are located within the proposed wetted irrigation area and provide
a potential conduit to the groundwater table. Please confirm that the assessment wells are to be
permanently abandoned.
I. Water Balance:
1. No comment.
J. Engineering Plans:
1. The plan set included sheets for the septic tank effluent pump (STEP) system with the associated
force main design. The Non-Discharge Branch does not review collection systems. To permit the
alternative sewer collection system, please submit the appropriate engineering documents to the
Municipal Permitting Unit.
2. The soil scientist’s “Recommended Improvements” summary identifies a small rock outcrop within
the northeastern corner of the East Side field (Field 2). The recommendation proposes that this
Mr. David Hughes
July 29, 2022
Page 4 of 7
rock outcrop be removed and smoothed with clean soil material prior to surface irrigation. This
outcrop was also identified during the hydrogeologic report; however, this feature was not depicted
within the provided Engineering Plan Set. Please provide further information, including any
necessary drawings or details, regarding the proposed outcrop removal.
1. The plan sheets refer to Sheets C-101, WW-101, and D-101 for general notes. Sheet C-101 was
not provided, and there are no general notes listed on Sheets WW-101 or D-101. Please provide
the plan sheets with general notes.
2. The engineering documents depict six separate zone spray irrigation areas. For example, Sheet
WW-114 depicts three zones separated with zone valve connections. Based on the information
provided in the calculations on the “Summary of Zone Operating Conditions” page, these zones
are operated independently of each other using a prescribed dosing schedule. Independent zoning
configurations are considered separate spray irrigation fields by the Non-Discharge Branch, please
revise the submittal documents and application to provide individual field information, including
updated soils information, acreage, and loading rates for each of the individual fields.
3. The proposed irrigation layout on Sheet WW-114 includes wetted areas that appear to be less than
30 feet from proposed habitable areas based on the proposed grade elevations. Pursuant to 15A
NCAC 02T .0506(a), the setbacks for spray irrigation sites are 400 feet for each habitable residence
or place of assembly under separate ownership or not to be maintained as part of the project site.
Similarly, the existing dwellings located northeast of the East Side spray site also appear to be
located within the 400 ft setback. Please review the rule requirements and obtain setback waivers
meeting the requirements of 15A NCAC 02T .0506(d), as needed.
4. The rule reference on Sheet WW-116 for the West Side irrigation field compliance boundary cites
15A NCAC 02U .0107 which pertains to staff review and permit preparation. Was the intent to
reference 15A NCAC 02L .0107? Please note, wastewater irrigation systems achieving reclaimed
water effluent standards have a compliance boundary set at the irrigation boundary pursuant to 15A
NCAC 02T .0506(c). Please review and revise as needed.
5. Similar to Item I.3 above, the review boundary is not clearly defined on Sheet WW-116, and the
one call-out located near the middle of the page appears to run through the property lines of the
Shinn Village subdivision. For systems achieving reclaimed water effluent standards under 15A
NCAC 02T .0506(c), the compliance and review boundaries are established at the irrigation area
boundaries. Please revise the plan sheets to clearly depict the review boundary meeting the
requirements of 15A NCAC 02T .0506(c) and 15A NCAC 02L .0102(28).
6. Sheet WW-117 depicts the irrigation force main crossing South Fork Withrow Creek. Based on
the provided profile view, it appears that this installation is to be performed as an open-cut. Are
401/404 permits required and have they been obtained for the proposed stream crossing?
7. Sheet D-102 depicts an underdrain around the E-Z Treat filter pods that daylights at an unknown
location. This underdrain system wasn’t mentioned elsewhere, and the proposed groundwater
depths in the nearby monitoring well MW-4 was measured near 33 feet below top of casing
(BTOC). What purpose does the underdrain serve for the treatment facility? Please provide
additional information and a plan sheet depicting the daylight locations.
8. Sheet D-110 depicts the chlorine metering building with piping entering the building from the
pumps in the chlorine field dosing tank and exiting the building to the irrigation fields; however,
the chlorine feed line is not depicted. Please revise the chlorine/metering building to depict the
chlorine feed piping.
Mr. David Hughes
July 29, 2022
Page 5 of 7
9. Sheets D-112 and D-113 depict duplicate details for the chlorine/metering building. Several of the
details appear to conflict with each other (i.e., Detail 6 on both pages). Please review and clarify
which detail drawings are to be used for this structure and revise as needed.
10. Please provide a detail for the proposed compliance monitoring wells. Please note that monitoring
wells are to be constructed in accordance with the 15A NCAC 02C rules.
K. Specifications:
1. Section 2100 Site Preparation & Earthwork does not indicate the proposed method for removing
the rock outcrop located in the East Side wastewater disposal area. Please provide a section within
the specifications for the removal of rock outcrops from the wastewater disposal fields. This
specification should include, at minimum, the acceptable methods for rock removal, minimum rock
removal depths, the sourcing of suitable fill material for use within permitted wetted areas,
procedures for repairing any voids or uneven topography created during the rock removal, any other
requirements for repairs to the soil profile at the removal location, and soil evaluations to be
performed to certify that the repaired areas are capable of accepting the designed loading rate.
2. Section 02420 Fertilization, Seeding, & Mulching included language stating that “cover over the
drain field being left natural in forested areas…” The aerial maps in the soils report indicate that a
portion of the East Side spray irrigation area is currently forested. The application and other
submitted documents indicated that both irrigation fields were to be seeded for fescue hay; please
confirm that the proposed cover crop for both irrigation fields is fescue hay.
3. The language within Section 11715 Continuous Online Turbidimeter refers to disc filters and rapid
infiltration basins. Please revise this section to reflect the proposed design for the Shinn Village
WWTF.
4. The rain sensor product requirements and automatically-activated irrigation system control
parameters do not appear to be included within the specifications. Please provide further
information regarding this feature within the Specifications.
L. Engineering Calculations:
1. Please address the following regarding the “Summary of Zone Operating Conditions”:
a. The total daily dose per zone (gallons) is depicted as 70,470 gallons. The submittal documents,
including the Project Narrative, state that the spray irrigation system is designed to dispose of 52,830
GPD. Calculations are to be provided for the designed disposal capacity. Please address this
discrepancy, provide clarification regarding the irrigation capacity, and revise the calculations as
needed. Please also revise the irrigation field dosing schedule provided on Page 9 of Section 13300
within the Specifications.
b. The calculations use an instantaneous loading rate of 0.1 3-0.14 in/hr using two doses on a set schedule,
presumably barring inclement conditions detected by the facility’s rain sensor. The designed loading
rate provided in Section VII.8. of the WWIS 06-16 application is listed as 0.00478 in/hr. Using the
application values and the parameters for the selected spray nozzles, a total run time of approximately
2.5 minutes per dose or micro-dose would be prescribed which differs greatly from the values presented
in this calculation summary. Please confirm the designed loading rate and revise the application, if
necessary.
Mr. David Hughes
July 29, 2022
Page 6 of 7
2. Within the Engineering Calculations, pump sizing and curves were only provided for the 5-Day
Upset Pumps. However, this design also includes flow equalization pumps and irrigation field
dosing pumps. Pursuant to 15A NCAC 02T .0504(c)(3), system curve analyses with total dynamic
head calculations are to be provided for each pump. Please revise.
M. Site Map:
1. No comment.
N. Power Reliability Plan:
1. No comment.
O. Operation & Maintenance Plan:
1. Within the Operation & Maintenance Plan (O&M Plan), the “5-Day Upset Pond” section describes
overflow piping that will direct the wastewater from influent surge flows into the storage pond
dosing tank. It is not specified whether these flows represent untreated or partially-treated
wastewater; however, the storage pond dosing tank also serves the final effluent storage pond and
is located downstream of the ultraviolet disinfection treatment unit. Pursuant to 15A NCAC 02T
.0505(j), by-pass and overflow lines are prohibited. If the intent is for these surge flows to be
directed to the 5-day upset pond so that they can later be routed to the headworks for treatment,
then please reevaluate the design such that untreated water is not in contact with final treated
effluent. Please review and revise the submitted engineering plan sheets and O&M Plan, as
necessary.
2. Pursuant to 15A NCAC 02T .0507(a)(4), the O&M Plan shall include spill control provisions,
including (but not limited to): response to upsets and bypasses, including control, containment, and
remediation; and contact information for plant personnel, emergency responders, and regulatory
agencies. Please submit a revised O&M Plan that meets these requirements.
P. Residuals Management Plan:
1. The provided plan indicates that residuals are to be to be hauled to Rocky River Regional WWTP.
In accordance with15A NCAC 02T .0508(a)(3), the Residuals Management Plan shall include a
permit for residuals management, or a written commitment to the permittee of a Department-
approved residuals management program accepting the residuals that demonstrates that the
approved program has adequate capacity to accept the residuals or that an application for approval
has been submitted. Please provide one of these items.
2. Please include language within the Residuals Management Plan that addresses the record
requirements of 15A NCAC 02T .0508(b).
Q. Additional Documentation:
 Existing Permit:
1. Not applicable.
Mr. David Hughes
July 29, 2022
Page 7 of 7
 Final Environmental Document:
1. Not applicable.
 Floodway Regulation Compliance:
1. Not applicable.
 Operational Agreements:
1. Within the Developer’s Operational Agreement, there appears to be some confusion regarding
the fifth item. This entity is not to be Envirolink, Inc., but instead it is intended to be a non-
profit corporation organized and/or existing to handle the property, affairs, and business of the
development (including the Disposal System). Please revise as needed.
 Threatened or Endangered Aquatic Species Documentation:
1. No comment.
 Wastewater Chemical Analysis:
1. Not applicable.
R. Recommendations: (Response not required)
1. The proposed monitoring well network consists of one cross-gradient well located on the
compliance boundary adjacent to the West Side spray site and one downgradient well located on
the compliance boundary adjacent to the East Side spray site. Due to topography and anticipated
groundwater flow hydraulics, the Non-Discharge Branch suggests that an additional compliance
well be installed to the northwest of the West Side spray site at the compliance boundary.