WQ0043421_Additional Information Request #3_20230216

February 16, 2023
DAVID HUGHES – MANAGER
SHINNVILLE FARMS DEVELOPMENT PARTNERS, LLC
236 RACEWAY DRIVE – SUITE 7
MOORESVILLE, NORTH CAROLINA 28117
Subject: Application No. WQ0043421
Additional Information Request #3
Shinn Village WWTF
Reclaimed Water 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 packages received September 2, 2022 and December 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 March 20, 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 D, 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
February 16, 2023
Page 2 of 2
A. Response Letter:
1. The response to Item K.1. regarding access to Zones 1, 2, and 3 states that these zones are to be
used for natural walking trails and not for agricultural harvesting. Per the virtual meeting on Friday,
November 4, 2022, and subsequent phone conversation on Thursday, February 2, 2023, our office
has communicated that the proposed natural walking trail design is not considered beneficial reuse
under 15A NCAC 02U. Our office understands that as a result of this communication, the applicant
now intends to use all six dedicated utilization zones (Zones 1 through 6) for agricultural
harvesting. Please revise the engineering plans to include the appropriate call-outs, notes, or detail
drawings that denote the agricultural use, including the minimum width required to allow
agricultural harvesting equipment (e.g., tractor, mower, rake, baler) access for operation and
maintenance activities. Additional revisions to the specifications may be necessary to adequately
describe the proposed reclaimed water system.
2. The response to Item K.2. regarding site access to Zones 4, 5, and 6 indicates that Shinnville Farms
Development Partners, LLC has entered into an agreement with a neighboring property that allows
the property owner to use these zones for his farming purposes. A copy of this agreement was not
provided, and it is unclear whether access will be provided in perpetuity. Please provide additional
information regarding how access will be maintained if the neighboring property is sold, and please
also confirm whether the neighboring property referenced is Parcel No. 4669751962, currently
owned by Kevin and Theresa Atwell.
B. Engineering Plans:
1. The provided well detail on D-104 was unchanged from the previously submitted plans. Please
provide a detail drawing for the proposed compliance wells that depicts the construction standards
outlined in 15A NCAC 02C .0108. This drawing will need to depict more details related to the
above grade features, including the locking cap, well pad dimensions, identification plate, and any
additional wellhead protection, at minimum.
C. Operation and Maintenance (O&M) Plan:
1. Page 6 of the O&M Plan lists a single task related “Spray Field: Vegetation”. This activity calls
for the vegetative cover to be maintained to a minimum height of 4 inches and does not appear to
reflect the proposed agricultural non-food crop harvesting being proposed for the dedicated
utilization sites. Please revise the O&M Plan to reflect the proposed on-site agricultural harvesting
activities.
D. Education Program:
1. Please revise the Education Program documents as needed to reflect the proposed on-site
agricultural harvesting activities.