WQ0043463_Additional Information Request_20220812

August 12, 2022
BARNES BOYKIN – MEMBER
CEDAR RUN CAPITAL, LLC
2405-F NASH STREET
WILSON, NORTH CAROLINA 27896
Subject: Application No. WQ0043463
Additional Information Request
Family Dollar – Currie WWTF
Wastewater Irrigation System
Pender County
Dear Mr. Boykin:
Division of Water Resources’ Central and Regional staff has reviewed the application package
received May 20, 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 September 12, 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 P, 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: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Jimmy Holland, PE – McKim & Creed, Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Barnes Boykin
August 12, 2022
Page 2 of 6
A. Cover Letter:
1. No comment.
B. Application Fee:
1. No comment.
C. Application:
1. In Section II, the provided address of 2844 Caratoke Highway and the provided facility coordinates
of 34.44º, -78.05º do not appear to correspond to the parcel referenced in the submittal documents.
Please revise the facility information to include the address associated with the proposed facility,
and please revise the coordinates to a higher level of accuracy (preferred accuracy is to the nearest
tenth of a second or six decimal points).
2. Item IV.7 lists that representative data and a flow reduction approval were used for the proposed
facility’s wastewater flow. A value of 260 gallons per day (GPD) was listed for the business;
however, it is unclear what data was used to determine this flow as this facility and the associated
business have not yet been constructed. Additionally, a copy of the flow reduction approval letter
was not included within the submittal package. Please provide additional information regarding
the daily design flow of the proposed wastewater facility that meets the requirements of 15A NCAC
02T .0114(c) and a copy of the flow reduction approval letter issued by the Municipal: NPDES,
Pretreatment and Collection Systems Unit.
3. Item IV.9 indicates that documentation of the presence or absence of threatened or endangered
aquatic species was provided. This documentation was not included in the submittal package.
Please provide the missing document.
4. Item IV.10 lists an active monitoring well (Monitoring Well 1). Please provide a copy of the Well
Construction Record (Form GW-1) so that we can add this well to the permit records. If the well
has not been constructed, then please revise the application to indicate that the monitoring well is
“proposed”.
5. Item V.1, the “Designed Effluent Concentrations” column lists values of less than the permit limits
outlined in 15A NCAC 02T .0505 for the designed effluent parameter rather than supplying values
representative of the proposed plant’s nutrient and constituent removal capacity. Please provide
either removal calculations that demonstrate what this treatment facility should be capable of
achieving or effluent study data from Advantex systems serving comparable influent waste streams.
Please revise the application as needed.
6. The response to Item V.5 states that an activated standby power supply will be made available
onsite to satisfy 15A NCAC 02T .0505(l). The response under Item IX.5 indicates that an
automatically activated standby power source will not be provided. Please address this discrepancy
and provide additional information regarding the Power Reliability Plan.
7. Earlier in the application, it was indicated that 15A NCAC 02T .0505(k), which requires multiple
pumps be provided wherever pumps are used, is being met. Section V.11.e indicates that only one
effluent pump is being installed in the pump tank. How is the applicant intending on complying
with .0505(k)?
Mr. Barnes Boykin
August 12, 2022
Page 3 of 6
8. Item VII.1 of the application states that the minimum depth to the Seasonal High Water Table
(SHWT) within the proposed irrigation area is 2.72 feet. This measurement does not appear to
agree with the Soil Evaluation report provided by Applied Resource Management, P.C. which
indicated that the water table may be within 12 inches of the surface. Please revise or explain the
discrepancy.
D. Property Ownership Documentation:
1. The submittal package included a document titled “Assignment of Rents” between Cedar Run
Capital, LLC (the applicant) and Truist Bank that refers to parcel 2285-63-0939-0000. The
"Assignment of Rents" document does not appear to meet the requirements of 15A NCAC 02T
.0504(f), and a review of the Pender County Register of Deeds GIS map shows that Parcel number
2285-63-0939-0000 is owned by Rudy Johnson. Additionally, Mr. Johnson does not appear to be
affiliated with Cedar Run Capital, LLC. Please demonstrate that the requirements of 15A NCAC
02T .0504(f) are being met by providing one of the following: a) Legal documentation of ownership
(i.e., GIS, deed or article of incorporation), b) Written notarized intent to purchase agreement
signed by both parties with a plat or survey map, or c) Written notarized lease agreement that
specifically indicates the intended use of the property and has been signed by both parties, as well
as a plat or survey map. Lease agreements shall adhere to the requirements of 15A NCAC 02L
.0107.
E. Soil Evaluation:
1. Saturated hydraulic conductivity (Ksat) values were only provided for depths of 22 to 40 inches and
66 to 84 inches. The Murville Muck series, as described in the “Soil Survey of Pender County,
North Carolina”, includes a mucky fine sand in the A horizon. The provided engineering design
indicates that the existing soils are to remain in situ, and hydraulic conductivities were not provided
for the full soil profile. Indications of a shallow groundwater table were noted throughout the Soil
Evaluation, and it is unclear whether the values depicted in Table 1 are representative of the most
restrictive soil horizon at the site. Please provide additional information regarding the saturated
hydraulic conductivity in the upper 22 inches of the soil profile.
2. Within the Soil Evaluation, a maximum daily design flow of 200 gallons per day (GPD) is provided
based on the preliminary water balance data with a note that the maximum daily design flow may
be limited by nutrient loading rather than hydraulic loading. The loading rate analysis section
indicates that phosphorus removal is the limiting design criteria and provides a maximum loading
rate of 70.8 inches per year. The loading rate of 70.8 inches per year for a 0.08-acre disposal area
appears to correspond to approximately 420 GPD – this is reflected in the Daily Design Flow
calculation in Appendix B. The engineering design for this application uses a daily design flow of
260 GPD. It is unclear what the basis is for the 200 GPD recommended in the Soil Evaluation, and
whether the proposed engineering design daily flow of 260 GPD is attainable for the current site
conditions. Please address the inconsistencies between the daily design flow requirements and
provide additional information as needed.
F. Agronomist Evaluation:
1. No comment.

Mr. Barnes Boykin
August 12, 2022
Page 4 of 6
G. Hydrogeologic Report:
1. Not applicable.
H. Water Balance:
1. The provided water balance was termed a “Quick Water Balance Assuming No Storage”. It is
unclear how nutrient management, required pursuant to 15A NCAC 02T .0504(k), has been
incorporated into the provided water balance. The maximum allowable irrigation depicted shows
considerably higher values than the 259 gallons per day listed in the Totals row. Please provide
additional information regarding the water balance.
I. Engineering Plans:
1. The provided Plan Set appears to have been resized during the submittal process rendering many
of the finer notes and features illegible. Please submit a copy of the revised Plan Set via email in
addition to your electronic submittal for the response to this letter so that our staff can confirm that
the depicted facility corresponds to the provided engineering calculations and design..
2. Several of the submitted documents indicated that Irrigation Field Notes 1 and 2 on Sheet G101
conflict with the Fill System Detail provided in the Soil Evaluation report. The Fill System Detail
calls for 24 inches of approved sand fill, while the Plan Note calls for 18 inches. Similarly, the Fill
System Detail states that fill material should be tapered from the top edge of the fill to the ground
surface 6 feet from the boundary area, while the Plan Note calls for 5 feet.
3. Sheet C101 depicts a pond and a temporary skimmer basin near the proposed treatment plant and
irrigation facility. The scale on the provided plan set is difficult to discern, but it appears that these
features are within the setback limits outlined in 15A NCAC 02T .0506. The Soil Evaluation
provided by Applied Resource Management, P.C., recommended reconstruction of the pond to
provide for the proper setback distance; however, this does not appear to be reflected in the
provided Plan Set (or other engineering documents). Additionally, it is unclear whether the
temporary skimmer basin will still be in operation at the time of facility start-up. Please provide
additional information regarding these structures including anticipated cease of operation,
reconstruction, and any additional actions necessary to meet the setback requirements.
4. A sufficiently detailed view of the pump tank was not provided within the submitted Plan Set.
Please include a detail that depicts the screened vent, as well as a depiction of the controls, alarms,
and proper signage.
5. Please provide a trench detail for piping installation and a detail for the compliance monitoring
well. Please note that monitoring wells are to be constructed in accordance with the 15A NCAC
02C rules.
J. Specifications:
1. The Engineering Plans and Soil Evaluation indicate that specialized earthwork is needed to
construct the drip irrigation area. Please provide specifications for the construction of the drip
irrigation mound area, including the type of soil to be used as backfill, methods used to place the
soil (e.g., tilling, discing, etc.), and any other necessary considerations.
Mr. Barnes Boykin
August 12, 2022
Page 5 of 6
2. On page TS-4, Subpart 1.09 Equipment states that the Contractor may use any type of earth-
moving, compaction, and watering equipment. Additional considerations are required for
earthwork and preparation activities in the proposed disposal area to preserve soil structure. Please
revise this section to adequately reflect separate requirements for earthwork activities within the
proposed disposal area.
3. Page TS-9 discusses fertilizer application in advance of seeding, but the specifications do not
appear to distinguish between the drip irrigation areas and the landscape areas of the property. The
proposed fertilizer is 8-8-8 which will result in further phosphorus loading to the proposed disposal
area and is not suitable for a site where phosphorus removal is the limiting design criteria. Please
revise this section to adequately reflect separate requirements for seeding and turfing the drip
irrigation areas. The Non-Discharge Branch also requests that the proposed seed mixtures for the
irrigation area cover crop be described therein.
4. TS-18 describes the high-head effluent pumps, but a few parameters were not included. Please
include the proposed pump operating point.
5. The specifications for the disinfection system list only that it is to be accomplished by ultraviolet
disinfection. Please provide details including the number of banks, the number of lamps per bank,
and the maximum disinfection capacity. Please also include product sheets of the selected system
or a list of acceptable manufacturers.
K. Engineering Calculations:
1. Several calculations were not included in the submittal. Pursuant to 15A NCAC 02T .0504(c)(3),
the engineering calculations should include hydraulic and pollutant loading for each treatment unit,
treatment unit sizing criteria, hydraulic profile of the treatment system, total dynamic head, and
system curve analysis for each pump, buoyancy calculations, and irrigation design. Please revise
the calculations to include the hydraulic and pollutant loading for each treatment unit, treatment
unit sizing criteria, the hydraulic profile of the treatment system, and the system curve analysis
depicting the pump curve and operating point.
L. Site Map:
1. It appears that Plan Sheet C101 is meant to serve as the Site Map for this permit application. This
sheet was missing several of the features required under 15A NCAC 02T .0504(d). Please include
the monitoring well (i.e., MW-1) and label the disposal zones (i.e., Zone 1 and Zone 2) so that the
Site map corresponds with the information provided in the application form. Please revise as
needed.
M. Power Reliability Plan:
1. A Power Reliability Plan was not included in the submittal. On the application checklist, the
checkbox for “Has sufficient storage capacity that no potential for overflow exists” is checked. A
storage calculation was not provided within the submittal package, and further information is
needed for approval from the Director. Please provide additional information within the Power
Reliability Plan document that meets the requirements of 15A NCAC 02T .0505(l).

Mr. Barnes Boykin
August 12, 2022
Page 6 of 6
N. Operation & Maintenance Plan:
1. Pursuant to 15A NCAC 02T .0507(a)(4), the Operation & Maintenance (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.
2. The Drip Irrigation System O&M Manual states "See the following pages for specific maintenance
tasks and troubleshooting guidelines". However, no additional pages were provided. Please review
and revise.
3. The ultraviolet (UV) disinfection system did not appear to be included within the provided product
manuals. Please provide the appropriate Operation & Maintenance information for the proposed
UV disinfection system.
O. Residuals Management Plan:
1. A Residuals Management Plan was not included in the submittal. Pursuant to 15A NCAC 02T
.0504(j) and .0508, submit a Residuals Management Plan that includes, at minimum:
a. A detailed explanation of how generated residuals (including trash, sediment and grit) will be
collected, handled, processed, stored, treated, and disposed.
b. An evaluation of the treatment facility’s residuals storage requirements based upon the
maximum anticipated residuals production rate and ability to remove residuals.
c. A permit for residuals utilization or 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.
P. Additional Documentation:
 Floodway Regulation Compliance:
1. Not applicable.
 Operational Agreements:
1. No comment.
 Threatened or Endangered Aquatic Species Documentation:
1. Appropriate documentation was not included in the submittal. Please provide documentation
meeting the requirements of 15A NCAC 02T .0105(c)(10).