WQ0043463_Additional Information Request #2_20221115

November 15, 2022
BARNES BOYKIN – MEMBER
CEDAR RUN CAPITAL, LLC
2405-F NASH STREET
WILSON, NORTH CAROLINA 27896
Subject: Application No. WQ0043463
Additional Information Request #2
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 and subsequent response submittal received September 9, 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 15, 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 M, 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)
James W. Holland, PE – McKim & Creed, Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Barnes Boykin
November 15, 2022
Page 2 of 4
A. Response Letter:
1. In response to Comment C.2 of the Additional Information Request dated August 12, 2022, a flow
reduction document from the NC Department of Health and Human Services (NCDHHS) was
provided. Unfortunately, NCDHHS Flow Reductions are only valid for below-grade septic systems
permitted under 15A NCAC 18A. The provided approval does not satisfy the requirements of 15A
NCAC 02T .0114 that applies to Non-Discharge systems permitted under 15A NCAC 02T. Please
contact Mr. Charlie Miller with NPDES Municipal Permitting ([e-mail]) for
information regarding the appropriate flow reduction approval process.
2. The response from Applied Resource Management to Comment E.1 indicated that the unsuitable
A horizon soils are to be undercut which corresponds to an excavation depth of approximately 12-
14 inches below grade. Upon removal appropriate coarse-grained sand fill material is to be
incorporated into the Bh horizon and backfilled to the existing grade. An additional layer of
appropriate coarse-grained sand fill material is to be added to an elevation approximately 24 inches
above the existing soil surface to allow for positive drainage at the site and to satisfy the
requirements for the Seasonal High Water Table (SHWT). The soil scientist identified appropriate
coarse-grained sand fill material as a C-33 or 2S concrete sand backfill material having a saturated
conductivity equal to or greater than the Bh horizons measured in situ. Unfortunately, this design
requirement was not reflected in Sheet C103 of the Engineering Plans and Section 12000 of the
Specifications and is a key aspect of the proposed design. Please revise the engineering documents
to reflect the recommendations of the soil scientist.
B. Application (Form: WWIS 06-16):
1. No comment
C. Property Ownership Documentation:
1. No comment.
D. Soil Evaluation:
1. No comment.
E. Water Balance:
1. No comment.

Mr. Barnes Boykin
November 15, 2022
Page 3 of 4
F. Engineering Plans:
1. See Comment A.2 regarding the Sheet C103 profile view of the irrigation area and proposed fill
placement.
2. Revised Plan Sheet M100 does not depict a screened vent or proper emergency contact signage for
the pump tanks. Please revise the plans to include these items as either a detail drawing, note, or
call-out.
G. Specifications:
1. See Comment A.2 regarding the lack of specifications for the removal of A horizon soils within
the drip irrigation mound footprint described in Section 12000.
H. Engineering Calculations:
1. The provided calculations for the pollutant loading and removal were completed for a design flow
of 208 gallons per day (GPD). The proposed facility with a flow reduction approval will have a
permitted flow of 260 GPD. Please revise the pollutant loading and removal calculations to
correspond to the requested permitted flow (currently of 260 GPD).
2. The pollutant loading and removal calculations included two notes regarding the need for a
denitrification return line to the primary tank and a sodium aluminate chemical feed system. These
were not depicted on the Engineering Plans, nor were they mentioned within the Specifications.
Please provide additional information regarding these treatment components and revise the
engineering documents, as needed.
I. Site Map:
1. No comment.
J. Power Reliability Plan:
1. No comment.
K. Operation & Maintenance Plan:
1. The statement “Report any line breaks or spills to the proper authorities” does not satisfy the
requirements of 15A NCAC 02T .0507(a)(4). Please provide spill control provisions that include:
response to upsets and bypasses, including control, containment, and remediation; and contact
information for plant personnel, emergency responders, and regulatory agencies.

Mr. Barnes Boykin
November 15, 2022
Page 4 of 4
L. Residuals Management Plan:
1. The provided Residuals Management Plan does not meet the requirements of 15A NCAC 02T
.0508(a). Please address the following:
a. Please provide a detailed explanation as to how the residuals will be collected, handled,
processed, and stored prior to disposal, and include the evaluation of the residuals storage
requirements for the treatment facility based upon the maximum anticipated residuals
production rate to meet the requirements of 15A NCAC 02T .0508(a)(1) and .0508(a)(2).
b. The provided language indicates that the generated residuals will be disposed of using a
licensed sludge handler; however, a written commitment that satisfies 15A NCAC 02T
.0508(a)(3) was not provided. Please provide 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.
M. Threatened or End angered Aquatic Species Documentation:
1. The letter provided from the North Carolina Natural Heritage Program dated October 10, 2022,
identified a threatened species, Mabee’s Salamander (Ambystoma mabeei), within the one-mile
radius of the project area. Pursuant to 15A NCAC 02T .0105(i), Non-Discharge permits shall
provide specific conditions to address the protection of threatened or endangered aquatic species,
as provided in plans developed pursuant to 15A NCAC 02B .0110. Please determine whether the
construction and operation of the facility directly impacts the identified aquatic species and
identify site-specific strategies to maintain or recover the water quality conditions to meet the
requirements of 15A NCAC 02B .0110, if necessary.