WQ0015931_More Information (Requested)_20221104

November 4, 2022
BRANDON LONG – ORC
TNGC CHARLOTTE LLC
5600 LAKEVIEW ROAD
CHARLOTTE, NORTH CAROLINA 28269
Subject: Application No. WQ0015931
Additional Information Request
Trump National Golf Club Charlotte
WWTP
Reclaimed Water System
Iredell County
Dear Mr. Long:
Division of Water Resources’ Central and Regional staff has reviewed the application package
received August 10, 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 December
5, 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: Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Donald L. Munday, PE – Piedmont Design Associates, P.A. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Brandon Long
November 4, 2022
Page 2 of 6
A. Overall:
1. The application form for modifications to a Wastewater Irrigation System (Form: WWIS 06-16)
was submitted with the application package. Unfortunately, the facility described in Permit No.
WQ0015931 is a Reclaimed Water Generation and Dedicated Reclaimed Water Utilization System
which is not covered under WWIS 06-16 and 15A NCAC 02T .0500. Please submit the appropriate
application forms for modifications to the Reclaimed Water Generation facilities (i.e., Form RWPI
06-16 and Form RWG 06-16) and provide any attachments/enclosures required by these forms that
were not previously submitted. Please note that modifications to the Dedicated Reclaimed Water
Utilization facilities require an additional form (i.e., Form RWNC 06-16).
B. Cover Letter:
1. No comment.
C. Application Fee:
1. No comment.
D. Application:
1. The provided application was signed by Mr. Brandon Long, who is described as the facility’s
Operator in Responsible Charge (ORC). Our office could not find documentation that the current
ORC has delegated signature authority. Please provide the signature delegation authority letter
(i.e., Form NDSDAL 01-20 attached) for Mr. Brandon Long. Please note that the individual
delegating authority must meet the requirements of 15A NCAC 02T .0106(b) and .0106(c).
2. Please confirm that Mr. Brandon Long (ORC) is the individual listed as Mr. Charles B. Long (WW-
2 1000788; SI 991385).
3. Section IV.7 of the application indicates that a flow reduction has been approved under 15A NCAC
02T .0114(f). Please submit a copy of the flow reduction approval letter.
4. Section V.4 lists an overflow from the 5-day upset pond to the wet weather storage pond. Water
held within the 5-day upset pond is considered off-specification and this overflow would result in
partially treated water being introduced to the finished reclaimed water stored in the wet weather
pond. Pursuant to 15A NCAC 02U .0402(g), by-pass and overflow lines shall be prohibited. Please
provide additional information regarding the overflow identified in the application.
5. The response to Section V.8 discussing the number days of residual storage provided in the design
was left blank. Pursuant to 15A NCAC 02U .0402(j), 30 days of residual storage shall be provided.
Please provide additional information indicating the number of days of storage incorporated into
the design and how the requirements of 02U .0402(j) are to be met.
6. Within Section V.11., and the included engineering documents, the proposed treatment appear to
comprise a single treatment train. Pursuant to 15A NCAC 02U .0402(c), dual facilities are to be
provided for all essential treatment units. Additionally, the 5-day upset pond must have the ability
to return effluent to the head of the treatment facility in accordance with 15A NCAC 02U .0402(d).
Please review and revise as needed.
Mr. Brandon Long
November 4, 2022
Page 3 of 6
7. Section V.11.e. lists the facility design criteria for pumps. The proposed grinder pumps to handle
waste flow from the existing office restroom (as depicted on Sheet U-1) are not included in this
table. This permit includes the wastewater collection system for the Trump National Golf Club
Charlotte WWTP, and any modifications to the wastewater collection system should be included
herein. Please note that modifications to the collection system must meet the requirements of 15A
NCAC 02T .0300, the North Carolina’s Minimum Design Criteria for the Permitting of Gravity
Sewers, and the Minimum Design Criteria for the Permitting of Pump Stations and Force Mains.
Please review and revise as needed.
8. The permitted dedicated reclaimed water utilization system employs both spray irrigation and drip
irrigation equipment. Within Section VII.8. only the drip irrigation design elements were provided.
Please provide information on both the spray irrigation design elements and drip irrigation design
elements.
E. Property Ownership Documentation:
1. No comment.
F. Soil Evaluation:
1. Not applicable.
G. Agronomist Evaluation:
1. Not applicable.
H. Hydrogeologic Report:
1. Not applicable.
I. Water Balance:
1. Not applicable.
J. Engineering Plans:
1. The resolution on the provided plan sheets is limited and many of the line-weights and hatches are
distorted and illegible. In addition to uploading a copy of the revised plans with the response
submittal, please provide an electronic copy of the plan sheets in a separate email for our review.
2. Within the Engineering Plans, the existing facility is only referred to in a call-out on Sheet U-1.
Please provide a Demolition sheet identifying existing structures/units and piping to be removed
and/or abandoned in place for our consideration. Please clarify what “to be abandoned” entails.
3. “Future” Flow Equalization (EQ) Basin and Textile Filter units are called out on Sheet U-1. Are
these units for a planned capacity expansion? Please note that the 02U rules require all essential
treatment units be provided in duplicate prior to start-up and operation. Please provide clarification
and revise as needed to meet the requirements of 15A NCAC 02U .0402(c).
Mr. Brandon Long
November 4, 2022
Page 4 of 6
4. Proposed piping between the new treatment facility and the existing storage facilities (i.e., the 5-
day Lined Upset Pond and the Wet Weather Lined Storage Pond) was not depicted on the plan
sheets. Please review and revise the plan sheets as needed.
5. A profile was not provided for the proposed collection serving the office restroom. Please provide
a profile and the necessary detail drawings, notes, and call-outs required by North Carolina’s
Minimum Design Criteria for the Permitting of Gravity Sewers and the Minimum Design Criteria
for the Permitting of Pump Stations and Force Mains.
6. Using the provided graphic scale, only 5 feet of separation exists between the proposed Flow EQ
Basin #1 and the existing 5-day Lined Upset Pond. It is unclear what protections are going to be
in place, and whether any additional considerations are needed for the proposed construction.
Please provide additional information regarding the installation of this unit.
7. Per Sheet U-1, is the manhole receiving waste flow from the office restroom an existing or new
structure? Please provide additional information.
8. The provided hydraulic profile on Sheet U-2 does not depict the 5-day upset pond and the wet
weather storage pond. Please include these features and their associated elevations in the profile.
9. Sheet U-3 depicts an alkalinity feed line with a note stating, “If needed”. A project narrative for
the proposed treatment process and engineering calculations were not included in the submittal,
and it is unclear whether the alkalinity feed line is being proposed for installation. Please review
and revise.
10. The trenching detail provided does not specify minimum cover, please revise the plan sheets to
indicate a minimum cover for all influent and reclaimed water piping.
11. The plan sheets show that the proposed flow equalization basin is to be installed above-grade. Will
above-grade piping and associated appurtenances be insulated to protect against freezing? Please
provide a call-out, notes, or detail drawings related to above-grade piping.
12. Within the turbidity basin detail drawing, the piping depicted is generic and does not depict separate
piping for the 5-day upset pond and the wet weather storage pond. Please review and revise the
plan sheets as needed to show that the requirements of 15A NCAC 02U .0402(d) are being met.
K. Specifications:
1. The specification package states that the system is designed to comply with North Carolina
Administrative Code 15A NCAC 02H .0200 on Pages 1 and 2. These rules were repealed in place
of the new 15A NCAC 02T rules in 2006. However, the facilities in this permit are regulated as a
reclaimed water system under the 15A NCAC 02U rules. Please amend these sections to reference
the applicable administrative code.
2. Within the Scope of the Project on Page 1, it is noted that during the construction process, the
Owner is prepared to shut down all flow for a period to allow for the change to occur. However, it
was not clarified how this will be accomplished. Please provide a construction sequence for this
project that addresses how wastewater service will be handled during installation activities that
interrupt the treatment facilities.
3. The Basis of Design in Section 3 of the specifications appears to have some inconsistencies with
the engineering plans and application. The primary treatment units specify two AX-MAX units on
Page 3, whereas only one unit is depicted on Sheet U-1 of the plans, with a second to be included
Mr. Brandon Long
November 4, 2022
Page 5 of 6
in the future. Similarly, there are only two ultraviolet (UV) units listed on Sheet U-1 of the plans
and Page 3 of the specifications, but four are specified in parallel on Page 1 of the specifications.
Please provide a clarification on how many units of each type are being proposed in this
modification.
4. Of Page 3, the effluent sampling is mentioned as being a brass sillcock “Located at Headworks”.
Please clarify where the representative effluent sample is to be collected.
5. On page 11 of the specifications, the panel operations mention that once the daily volume is reached
for irrigation Fields A, B, and C, all effluent shall be sent to the offsite remote dosing tank. The
fields in this permit do not include Fields A through C, nor is there an offsite remote dosing tank
in the facility description. Similarly on Page 12, there is a reference to Sheet U-17 for details for a
freestanding shelter for the control panel, but U-17 and the detail are not included in this application
package. Please correct these sections.
6. See Item D.6. The System Controller section of the Control Panels and Electrical specifications
shall include panel operation conditions to direct flow to the 5-Day Upset Pond if either turbidity
or permitted pathogen levels cannot be met in accordance with 15A NCAC 02U .0402(d).
7. See Item D.7. Any specifications regarding the installation of the grinder pump shall be included
in an updated specifications package if it is a part of the modification. This should include the
manufacturer’s information for the unit, methods of installation, and any water level float
controls/alarms that would be associated with this unit.
8. See Item J.2. Please provide specifications detailing demolition procedures to be used for the
removal/abandonment of any existing facilities.
9. See Item J.4. Please provide specifications for the installation of new piping, such as trenching and
backfilling.
10. Specifications shall be provided detailing any provisions or considerations that are to be used
protect the integrity of the existing facility. This should include protections such as
stormwater/sediment control and construction techniques to preserve the integrity of the liner for
the existing 5-Day Upset Pond during construction activities (mentioned in Item J.6).
11. See Item J.11. Specifications shall be provided detailing any provisions or considerations to be
used to protect against freezing of pipes and associated appurtenances.
L. Engineering Calculations:
1. The Engineering Calculations were not included within the provided application submittal. Please
provide calculations – including hydraulic and pollutant loading for each treatment unit, treatment
unit sizing criteria, total dynamic head and system curve analysis for each pump, and buoyancy
calculations – as required by 15A NCAC 02U .0201(c)(3).
M. Site Map:
1. A complete site map depicting the treatment, storage, and utilization facilities was not provided in
the application package. Please submit a site map meeting the requirements of 15A NCAC 02U
.0201(d).
Mr. Brandon Long
November 4, 2022
Page 6 of 6
N. Power Reliability Plan:
1. No comment.
O. Operation & Maintenance Plan:
1. Within the Operation & Maintenance (O&M) Plan, descriptions of surge tanks and the Creek Stone
wastewater treatment facility are included in the plan. These are not associated with this permit.
Please review the O&M Plan and revise it as needed to reflect the treatment, storage, and utilization
facilities permitted to TNGC Charlotte, LLC. Please include O&M requirements for spray
irrigation systems in addition to drip field irrigation systems due to the presence of both
technologies at the utilization sites.
2. Pursuant to 15A NCAC 02U .0801(a)(6), 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. A Residuals Management Plan was not included in the submittal. The Residuals Management Plan
is required for all application packages with new, expanding, or replacement wastewater treatment
systems. Pursuant to 15A NCAC 02U .0802(a), 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.
d. If oil, grease, grit, or screenings removal and collection is a designed process unit,
an explanation as to how these materials will be collected, handled, processed,
stored, and disposed.