WQ0043421_Additional Information Request #2_20221201

December 1, 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 #2
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 and subsequent response package received September 2, 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 January 2, 2023.
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 T, 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
December 1, 2022
Page 2 of 5
A. Response Letter:
1. Please confirm whether Zones 4, 5, and 6 (which no longer have a proposed natural surface walking
trail), are to be regulated as reclaimed water utilization sites under 15A NCAC 02U. The alternative
would be that these spray irrigation areas are regulated as wastewater irrigation sites meeting the
requirements of 15A NCAC 02T .0506(c) which qualify for reduced setbacks to property lines.
Please note, should the adjacent parcels to Zones 4, 5, and 6 be developed in the future, a permit
condition requiring the installation of a fence to prevent public access would be required to ensure
the requirements of 15A NCAC 02T .0505(q) are met.
B. Application Fee:
1. No comments.
C. Application (Form RWPI 06-16):
1. No comments.
D. Application (Form RWG 06-16):
1. Within Item VIII. Design Information for Earthen Storage Impoundments, design information for
the treated effluent storage pond was provided; however, design information for the 5-day upset
pond was missing from the RWG 06-16 application form . Multiple copies of the questions on Item
VIII. are necessary for facilities with more than one impoundment. Please provide the design
information for the 5-day upset pond using a copy of the questions in Item VIII.
E. Application (Form RWNC 06-16):
1. Item II.6. refers to how reclaimed water utilization volume was calculated. The provided
calculation of 90 gallons/day/bedroom represents the wastewater volume requiring treatment rather
than the beneficial reuse of the reclaimed water. Please revise Item II.6 to show how the usage
volume (the 52,830 GPD quantity listed in Item II.4) for non-food crop irrigation was calculated.
2. Item VI.5 regarding the minimum depth to the seasonal high water table (SHWT) within the
irrigation area was left blank. Please revise to include the minimum depth to the SHWT or
otherwise indicate its absence during the site evaluation (i.e. > 29 feet below ground surface).
F. Property Ownership Documentation:
1. No comments.
G. Soil Evaluation:
1. No comments.

Mr. David Hughes
December 1, 2022
Page 3 of 5
H. Agronomist Evaluation:
1. No comments.
I. Hydrogeologic Report:
1. No comments.
J. Water Balance:
1. No comments.
K. Engineering Plans:
1. A review of Sheet WW-114 shows only one dedicated access point to Zones 1, 2, and 3, and it
appears to be an access for the Natural Surface Walking Trail along “Road E” based on the depicted
drawing. An access from the treatment facility to the utilization area was not indicated on the plans.
The provided plans include a detail for the Natural Surface Walking Trail on Sheet D-105 that
depicts a width of 3 feet 6 inches for the trail surface. Will this Natural Surface Walking Trail
access point be used for the proposed agricultural harvesting equipment (e.g., tractor, mower, rake,
baler)? It is unclear whether this access point is sufficiently designed to allow maintenance and
harvesting of the Zone 1, 2, and 3 utilization area. Please provide additional information and
indicate on the plans where the proposed operations and maintenance access point is for Zones 1,
2, and 3. Please indicate with a call-out, note, or detail drawing the minimum width required to
allow the proposed agricultural harvesting equipment to use the access point.
2. Similar to Comment K.1, and assuming that Zones 4, 5, and 6 are to be reclaimed water utilization
sites regulated under 15A NCAC 02U (see Comment A.1), it is unclear what access is available for
maintenance and agricultural harvesting equipment for Zones 4, 5, and 6 located across the South
Fork of Winthrow Creek based on the provided plan set. A path or road (including the Natural
Surface Walking Trail) is not depicted on the plan sheets that crosses the South Fork of Winthrow
Creek, and it is unclear whether an access agreement from an adjacent property has been obtained
to access those utilization sites without crossing the creek. Please provide additional information
and indicate on the plans where the proposed operations and maintenance access point is for Zones
4, 5, and 6. Please indicate with a call-out, note, or detail drawing the minimum width required to
allow the proposed agricultural harvesting equipment to use the access point.
3. The response to Comment J.10 in the Additional Information Response dated September 2, 2022
indicated that a monitoring well detail drawing was added to Sheet D-104. The provided drawing
appears to reference the test wells that are to be abandoned upon issuance of the permit (Wells
“MW” and “TW” in the provided documents). However, for the proposed compliance wells (CW-
1 and CW-2) please provide a detail drawing that depicts the construction standards outlined in
15A NCAC 02C .0108 including, but not limited to, features such as a locking cap, screening/casing
materials, well pad dimensions, identification plate, and wellhead protection.
L. Specifications:
1. No comments.
Mr. David Hughes
December 1, 2022
Page 4 of 5
M. Engineering Calculations:
1. Within the provided process calculations, a maximum turbidity value of 14 NTU is listed under
Design Effluent Characteristics. Pursuant to 15A NCAC 02U .0301(b), the reclaimed water
standard for maximum turbidity is 10 NTUs. A modelled value for final effluent turbidity was not
provided, and it is unclear based on the provided calculations whether this requirement can be met.
Please review and revise the Process Calculations as needed.
N. Site Map:
1. No comments.
O. Distribution System Monitoring Plan:
1. A distribution system monitoring plan was not included within the submitted documents. This plan
is required for verifying that reclaimed water effluent standards (15A NCAC 02U .0301) will be
met at the utilization sites. Please provide a copy of the distribution system monitoring plan for
review.
P. Education Program:
1. Documentation of a program of education and approval for all reclaimed water users was not
provided. Pursuant to 15A NCAC 02U .0501(a), a reclaimed water generator shall develop and
maintain an education and approval program for all use of reclaimed water. Please provide a copy
of the reclaimed water education program for review.
2. In addition to the education program for reclaimed water users requested in Comment P.1, please
provide an educational document to be distributed to property owners and the Homeowner’s
Association that defines reclaimed water, describes the on-site reclaimed water utilization
activities, provides information on the proper use of reclaimed water, and further clarifies that
reclaimed water is not intended for drinking. Please provide a copy of the educational document
to be distributed to property owners and the Homeowner’s Association for our review.
Q. Power Reliability Plan:
1. No comments.
R. Operation & Maintenance Plan:
1. No comments.
S. Residuals Management Plan:
1. No comments.

Mr. David Hughes
December 1, 2022
Page 5 of 5
T. Additional Documentation:
 Operational Agreements:
1. No comments.
 Threatened or Endangered Aquatic Species Documentation:
1. No comments.