WQ0015931_More Information (Requested)_20230303

March 3, 2023
CHARLES BRANDON LONG – BACK-UP OPERATOR IN RESPONSIBLE CHARGE
TNGC CHARLOTTE LLC
5600 LAKEVIEW ROAD
CHARLOTTE, NORTH CAROLINA 28269
Subject: Application No. WQ0015931
Additional Information Request #2
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 on August 10, 2022, and the subsequent response package received on December 28, 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 April 3, 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 O, 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. Charles Brandon Long
March 3, 2023
Page 2 of 6
A. Overall
1. The Applicant’s responses to the questions regarding dual facilities (i.e., Item D.6 in the Response
Letter dated December 21, 2022, and Item VI.8 of Application Form RWG 06-16) indicate that
mechanical redundancy is to be provided in lieu of dual facilities. Mechanical redundancy is
required under 15A NCAC 02U .0402(h) where “multiple pumps shall be provided wherever
pumps are used”. Pursuant to 15A NCAC 02U .0402(c), dual facilities shall be provided for all
essential treatment units. The intent of this rule is that reclaimed water facilities be designed with
dual treatment trains for all essential treatment units. The combined capacity of the dual treatment
trains must at least equal the proposed design treatment capacity of 25,000 gallons per day (GPD).
Please revise the proposed design to meet the requirements of 15A NCAC 02U .0402(c).
2. With regards to the permitted capacity of the TNGC Charlotte WWTP:
a. The RWG 06-16 application lists a daily design flow of 25,000 GPD under Item III.6. This
value corresponds with the previously permitted treatment facility design.
b. A review of the provided engineering calculations indicates that the current disposal capacity
is 20,000 GPD (12,500 GPD contributed via spray utilization areas and 7,500 GPD contributed
via drip utilization areas).
c. The response to Item J.3. in the Response Letter dated December 21, 2022, indicates that the
“future” treatment units depicted on the plans are necessary for the treatment facility to be rated
at 25,000 GPD. However, pending the response to Item A.1, we understand that these “future”
units are not proposed for construction at this time resulting in a design treatment capacity of
12,500 GPD.
Please note that the permit effluent flow limit is based on the most restrictive capacity (treatment
or disposal). If the proposed facility capacity (either treatment or disposal) is less than the minimum
allowable daily design flow under 15A NCAC 02T .0114(c), then a Flow Reduction Approval from
the Collections Group within the Municipal Permitting Unit may be necessary. Please contact the
Collections Group regarding the requirements of 15A NCAC 02T .0114(f) for an adjusted daily
sewage flow design rate. Please provide our office with a copy of the Flow Reduction Approval
or other documentation indicating that the requirements outlined in 15A NCAC 02T .0114 are being
met.
3. Within the Engineering Documents, Sheet U-3 depicts a single Flow EQ Tank, a Stage 1/Textile
Filter Tank, a Stage 2/Polishing Filter Tank, and a greyed-out “Future” Stage 1/Textile Tank to be
installed in parallel with the aforementioned Stage 1 Tank. On Page 4 of the Specifications, the
components of the system list one Flow EQ Tank, two Stage 1/Textile Filters, and one Stage
2/Polishing Filter. On Page 17 of the Specifications, the system components are listed as two Flow
EQ Tanks, two Stage 1/Textile Filter Tanks, and one Stage 2/Polishing Filter Tank. Are both Flow
EQ Tanks and Stage 1/Textile Filter Tanks being proposed for construction in this modification?
It is unclear whether the Applicant is seeking to have all the depicted units (including the greyed
out “Future” units) permitted as part of this modification request. Please provide clarification and
ensure that the Plan Set and the Specifications agree.

Mr. Charles Brandon Long
March 3, 2023
Page 3 of 6
B. Response/Cover Letter:
1. The response to Item J.6. in the Response Letter dated December 21, 2022, indicates that the
unit will be placed at grade; however, the response (and the specifications) was unclear on how
the proposed Flow EQ Basin #1 (which is not an Orenco Media Filter) is to be maneuvered
into place without damaging the liner of the 5-day upset pond. Additionally, it was noted that
the proposed location for the Flow EQ Basin #1 crosses the existing return pipe from the 5-day
upset pond to the treatment headworks. Will the existing return pipe be impaired by the
installation of Flow EQ Basin #1? Please provide additional information regarding the
installation method proposed for Flow EQ Basin #1 and any considerations being taken to
ensure that the existing infrastructure associated with the 5-day upset pond remains operational.
These considerations should be outlined within the Specifications.
2. The response to Item K.4 indicates that a sampling port is to be located at the back of the last
treatment unit before discharging to the turbidity basin. Sheet U-6 of the plans is referenced
as the noted location. A review of Sheet U-6 depicting the polishing filter does not show an
effluent sampling port. Please revise.
C. Application Fee:
1. No comments.
D. RWPI 06-16 Application:
1. No comments.
E. RWG 06-16 Application:
1. The values provided in the table for Item V.1. appear to be directly copied from the Type 1
reclaimed water effluent characteristics in 15A NCAC 02U .0301. These values should reflect
what the proposed treatment facility is capable of achieving based on the engineering calculations.
Please revise Item V.1.
2. Within Item VII.d. Residuals Treatment, an anaerobic digester is listed. An anaerobic digester is
not described within the remaining engineering documents. Please clarify why an anaerobic
digester is specified here.

Mr. Charles Brandon Long
March 3, 2023
Page 4 of 6
F. RWNC 06-16 Application:
1. Item I.4 of the lists a dedicated utilization capacity of 25,000 GPD for the TNGC Charlotte WWTP.
In Item II.6., the applicant indicated that this value is based on what was listed in the previous
permit. The engineering calculations provided in this submittal determined that 5,000 GPD of
capacity associated with drip zones D-4, D-5, D-6, and D-7 was removed from the permit in 2015.
The combined disposal capacity in the calculations lists 12,500 GPD attributed to the spray
utilization sites and 7,500 GPD attributed to the remaining drip utilization sites for a total disposal
capacity of 20,000 GPD. Additionally, a note within Section VI. Design Information for Non-
Conjunctive Irrigation Systems indicates that the spray system is not utilized. Is the active
dedicated utilization capacity currently 7,500 GPD? Please document the disposal capacity and
revise the application. Additionally, please explain why the spray utilization system is currently
not in use and if repairs are necessary to return the spray utilization sites to operational status.
Additional supporting documentation (i.e., soils report, agronomic evaluation, hydrogeologic
report) in favor of the 25,000 GPD disposal capacity for the remaining utilization sites may be
necessary.
G. Property Ownership Documentation:
1. No comments.
H. Engineering Plans:
1. Sheet DEMO-1 indicates the intent is to cut and cap the existing treated effluent piping to the old
plant; however, it is unclear what is being proposed for the abandonment/removal of the existing
return pipe from the 5-day upset pond to the old plant or the inlet piping from the old plant to the
5-day upset pond. The specifications within the Demolition section state that all underground
piping may remain at the discretion of the Owner. Please provide additional information.
2. Sheet U-6 depicts an AX-MAX 125-42 Denite Unit. This differs from what is listed on Sheet U-3
for Stage 2 (an AX-MAX 275-42 unit). Which AX-MAX unit is being proposed for Stage 2?
Please revise the Plan Sheets, as necessary.
3. Piping from the 5-day upset pond to the head of the treatment works was not depicted. Please
revise Sheet U-1 to depict all of the proposed piping and accompanying inlet/outlet structures. Will
the pond levels need to be lowered to complete this work?
4. The provided plan set dated April 12, 1999, depicts the discharge piping from the treatment facility
to the 5-day upset pond at the southern corner with a similar configuration at the southeastern corner
of the wet weather storage pond. The proposed treatment configuration depicts discharge piping
into the northern corner of the 5-day upset pond with a similar depiction at the southwestern corner
of the wet weather storage pond. Detail drawings for the discharge piping/structure were not
provided for the proposed treatment configuration.
5. The provided plan set dated April 12, 1999, depicts a 6-inch perforated PVC pond underdrain that
runs down the centerlines of the 5-day upset and wet weather storage ponds. Where does this
subsurface drain discharge?

Mr. Charles Brandon Long
March 3, 2023
Page 5 of 6
I. Specifications:
1. Page 1 of the specifications indicated that the 5-day upset pond and wet weather storage pond are
to be unchanged. Specifications were not provided regarding the installation of the revised piping
and inlet/outlet structures within the 5-day upset pond and wet weather storage pond. Means and
methods for ensuring that the integrity of the synthetic liner is not compromised should be
described.
J. Engineering Calculations:
1. The provided engineering calculations are considered incomplete. Pursuant to 15A NCAC 02U
.0201(c)(3), treatment unit sizing criteria (including UV disinfection systems), total dynamic head
and system curve analysis for each pump and buoyancy calculations are to be provided. Please
revise.
2. The facility capacity varies throughout the calculations package. The initial page of the Piedmont
Design Associates calculations shows a maximum daily flow of 12,500 GPD, and the second page
shows a maximum daily flow of 25,000 GPD. The first page of the AQWA calculations shows an
average flow of 9,500 GPD, and the second page shows 14,750 GPD. Please clarify the proposed
treatment capacity, and if construction is to be conducted in phases, then please clarify Phase 1, 2,
etc. within the calculations and the other engineering documents. Please also explain the
discrepancy between the Piedmont Design Associates design flows and the AQWA design flows.
3. The required textile area of 531 square feet (SF) at a flow of 9,500 GPD provided by AQWA does
not appear to correspond to the Piedmont Design Associates 12,500 GPD textile area calculation
which states that 250 SF of AX-MAX textile is required with an additional 65 SF of textile (having
a different textile per unit value of 75 SF) listed for polishing. Is the Piedmont Design Associates
calculation describing an AX-MAX 275-42 unit and an AX-MAX 125-42 Denite unit? Is the
proposed design of one AX-MAX 275-42 unit against the manufacturer’s specifications, and is the
single unit sufficient to meet the effluent treatment standards for 12,500 GPD?
4. Similarly, a large discrepancy between the required textile surface area is present between the
AQWA and Piedmont Design Associates calculations for the proposed permitted flow of 25,000
GPD. The AQWA calculation determined that 824 SF (equivalent to three AX-MAX 275-42 units)
is necessary for a lower design flow (14,750 GPD). The calculations provided by Piedmont Design
Associates showed that treatment is achieved with 500 SF of textile (two AX-MAX 275-42 units)
and an additional 125 SF of textile (possibly as one AX-MAX 125-42 Denite Unit). Please address
this discrepancy and clarify the design and unit selection. If the AX-MAX 125-42 unit is not being
proposed, then please revise the calculations from Piedmont Design Associates to reflect the
designed treatment facility.
5. Within the calculations for the high-water alarm elevation, a total dosage of 27,000 GPD is used.
Our understanding is that the applicant is proposing a facility capacity of 25,000 GPD, please
explain what the additional 2,000 GPD represents in this calculation.

Mr. Charles Brandon Long
March 3, 2023
Page 6 of 6
K. Site Map:
1. No comments.
L. Power Reliability Plant:
1. No comments.
M. Operation & Maintenance Plan:
1. No comments.
N. Residuals Management Plan:
1. No comments.
O. Recommendations:
1. Based on the submitted design, the turbidimeter and diversion to the 5-day upset pond occurs
downstream of the UV disinfection unit. The UV disinfection system experiences reduced efficacy
under increased turbidity conditions, and it is unclear how the proposed configuration will prevent
solids accumulation in the UV bank. Our office recommends the Engineer consider altering the
design such that the turbidimeter and diversion process occurs prior to the UV disinfection
chamber.