WQ0004972_Staff Report_20230602

June 2, 2023
To: DWR Central Office — WQ, Non -Discharge
Attn: Zachary Mega
From: Caitlin Caudle
Winston-Salem Regional Office
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
Application No.: W00004972
Facility name: Forest Lakes WWI
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 5/30/2023
b. Site visit conducted by: C. Caudle & P. Mitchell
c. Inspection report attached? ® Yes or ❑ No
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ® No ❑ N/A
ORC: Amanda Grenier Certificate #: 100089 Backup ORC: Patrick Mays Certificate #: 1010112
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ❑ Yes or ® No
If no, please explain: See summary.
Proposed flow: 49,000 GPD
Current permitted flow: 24,400 GPD
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) See summary.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
See summary regarding proposed application rates.
7. Is the existing groundwater monitoring program adequate? ® Yes ❑ No ❑ N/A
See summary regarding monitoring well program.
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: A new grinder pump station was installed, the number of stations should be clarified. A new
permit description will also be needed for the proposed package plant and irrigation fields.
10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
FORM: WQROSSR 04-14 Page 1 of 2

11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
12. Has a review of all self -monitoring data been conducted (e.g., AR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: Nitrate in MW3 has been elevated since at least
November 2020, and exceeded the limit of 10mg/L in March 2022.
13. Has a review of source facilities compliance history been completed (e.g., CEIs and DMRs)? ® Yes or ❑ No
14. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
15. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
® Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
Applicable NODs, NOVs, and other correspondence can be found in LF.
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? The management of the package plant has
caused some solids issues that have not been resolved, to Staff knowledge.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: There may be issues associated with storage if f the permit is issued with no increase in
storaize.
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request: See summary.
3. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Compliance schedules should be included for start-up inspections, engineer certification dates, and
monitoring well installation dates.
4. Recommendation: ® Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Deny (Please state reasons: )
5. Signature of report preparer:
Signature of regional supervisor:
Date: 6/6/202 3 �--145ME225C94EA...
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See attached site visit summary, site maps, and additional information.
FORM: WQROSSR 04-14 Page 2 of 2

5/30/2023 Site Visit Summary
On May 30, 2023, Division of Water Resources staff Caitlin Caudle and Division of Soil and Water
Resources staff Patrick Mitchell completed a soils review of the proposed spray irrigation fields.
CLC1 (35.864491,-80.394880)
0-1"
A
Sandy loam, 10YR 2/2, granular, organic
matter present
1-3"
E
Sandy loam, 10YR 5/8, subangular
blocky, almost sandy clay loam
3-15"
Bt
Clay loam, 2.5YR 4/8, subangular blocky,
clay increase
15-38+
BC
Clay loam, 2.5YR 4/8, saprolite inclusions
of yellow/brown colors, massive, mica
increase
CLC2 (35.864360,-80.394148)
0-5"
A and E
Sandy loam, granular
5-12"
Bt
Clay loam, few saprolite inclusions
CLC3 (35.864639,-80.393401)
0-6" 1 Samy loam, may have lumped A and E
6-12+" Saprolite inclusions increase with depth
CLC4 35.865882,-80.395953)
0-5"
A
Sandy loam, granular
5-16+'
BT
More clay content in Bt, coarser
CLCS (35.86.5753,-80.398103)
0-16"
Bt
Higher clay content than other borings
16+"
BC/C
Saprolite inclusions increase with
depth, high clay content

Based on field observations and additional borings, Staff agree that the predominant soil series is
Pacolet, with slopes ranging from 5-20%. Clarification of loading rates will be needed before an accurate
assessment of the irrigation design can be made.
Items of Concern:
Cover Letter
No cover letter was included in the application
package.
Geologist Information
111.3 lists the geologist and the information is
incorrect. Eric Lapalla and Eagle Resources
provided the hydrogeological report.
Public monies (pg 13)
Item IV.3 is answered yes and no. This needs to
be clarified or the additional information
provided.
Flow calculation (pg 13, IV.7)
Flow needs to be recalculated. Per the most
recent permit and the resort map, there are 18
cabins, two pools, multiple bath houses, multiple
laundry facilities, a grill, and an office building.
Natural Heritage Info (pg 14)
IV.9 is answered no, natural heritage
documentation was provided in the application
package. Pg 1865-1868
New MW and unknown well at the toe slope of
A new MW will be needed downslope of ZB and
storage pond (pg 14)
ZC. This was not discussed in the hydro report.
Where does the facility propose to put a new
downgradient MW?
There is also a well visible at the toe slope of the
storage pond, close to the access gate for the
irrigation fields. Information needs to be provided
about this well. If it is a MW why was it not
properly abandoned. Or does it need to be added
to the permit? Why was it installed?
Clarification of bypass/discharge lines (pg 15, V.3)
This question is checked yes and no, needs to be
clarified
Residual storage volume (pg 15 V.7, pg 16 V.11.d.,
Residual storage is proposed in the application is
pg 106, pg 1845-1846)
6,700 gallons. The engineer plans and residuals
management plan show that there will be 7,770
gallons of storage between the sludge chamber
and the external storage tank, with a maximum
storage of 8,020 gallons. But the proposed sludge
generation is 272 gpd. 272 gpd x 30 days = 8,160
gallons. Based on this, there is not enough
residuals storage volume. The residuals
management plan mentioned a 2% decanted
solids rate, but does not provide any calculations
to show that the required volume will be less.
8,160 gallons x 2% = 163.2 gallons. 8,160 gallons
— 163.2 gallons = 7,996.8 gallons. Okay?

Public access (pg 15, 20)
V.8 and W11.4 state a fence and gate will be used
to restrict public access to the treatment plant
and irrigation fields. There are several well used
golf cart trails visible through ZB and ZC. Better
site restriction will be needed.
An ORC and BUORC must be designated for all
ORC and BUORC have been designated for 51, but
classifications for the system
not WW2.
Will the same grade be kept for the WWTP?
Currently, bot ORC and BUORC have WW2
certification.
Lift stations (pg 15, V.9)
The old lift stations were included in the most
recent permit description. The collection system
was expanded with a fast -track sewer permit. The
permit description needs to be updated to 8 lift
stations. This may need to be verified by the
facility.
Clarification of multiple pumps (pg 15, V.4)
The multiple pumps questions is checked no, but
there is no explanation of how compliance will
still be maintained
Clarify volume of each treatment unit (pg 16, 104,
The volumes listed in V.11 do not match what is
106)
listed on engineer plan page C-5. This needs to be
clarified.
The number of treatment units
More information is needed about chlorination
Currently, there is a baffled chlorine contact
(pg 16 V.11.c., pg 1785)
chamber with tablets used for disinfection at the
end of the package plant. The proposed
disinfection method is introducing liquid chlorine
to the influent pipe to the storage pond. The
storage pond is 408,000 gallons, not 200,000
gallons. I do not believe that this is an acceptable
disinfection method. There is no guarantee of
prolonged contact with chlorine, and the storage
pond will not be empty when the new plant is
installed. There will be a significant dilution of
chlorine as it enters the storage pond. Where will
effluent samples be taken to prove proper
disinfection and treatment? What is the irrigation
schedule with the retention time is 525 minutes
(8.75hrs)?
Will UV disinfection be used? There is a manual
for a UV unit included in the application package.
Will the old package plant be removed?
It is unclear how the old plant will be
decommissioned and what treatment units will
still be in use with the new package plant. It

appears that the old EQ basin will remain and
continue to serve as an EQ basin, but there is also
discussion of using the aeration basin as an EQ
basin while the EQ basin is being repaired. This
needs to be clarified. Engineer plans also show
that the old sludge basin will be used as an
aeration basin.
Clarification of artificial drainage or water
VII.2 is answered as no. Based on field
movement structures (pg 20, 36, 107)
observations there are several ditches within the
irrigation area and next to the irrigation area. The
soil map and engineer plans do not show any
ditches. See attached map for the approximate
location of the ditches within ZB and ZC.
Clarification of recommended loading rates (pg
VI1.3 lists both soil series within the proposed
20,33)
application fields. The Soil Report does not
separate the soil series and only lists 0.3 in/hr as
the loading rate and 36.82 in/yr. The
recommended loading rates based on soil
evaluation should be clarified.
Agronomist Report (pg 55)
The agronomist report listed in the application is
from Waypoint Analytical. The report provided in
the application was completed by Piedmont
Environmental. Is this the correct report? Should
another report be provided?
This report also refers to reclaimed wastewater.
Should there be reclaimed wastewater?
Where did the sqft come from? The minimum
irrigation area for nitrogen and phosphorus are
less than an acre and the minimum irrigation area
for water balance is about two acres.
The cover crops listed are not accurate. ZB and ZC
are more accurately described as mixed
hardwood, and ZD and ZE are pine. The soil series
listed is not Pacolet. Was this from another
agronomist report? The slopes observed in the
field are better described as 5-20%. A slope of
0.5% is not accurate.
Clarify irrigation zone names (pg 21, pg 107)
The application lists B, C, D, and E while the
engineer plans list B, C, D, and F. There are also
differences in the zone names of highest
elevation irrigation head labels.
Correct coordinates for zones (pg 21)
The coordinates for Zone D are incorrect, and
Zone E needs to be verified.

Clarify acreage and include decreased acreage of
The hydro report lists the new irrigation area as
Zone A (pg 21, pg 107)
9.6 ac, and the application lists 11.17, and the
engineer plans list 10.44 ac. Which is right?
Zone B and C have different acreage in the
application compared to the design plans.
The existing irrigation field was not included as
there is a decrease in acreage. The hydro report
lists 4.55 ac, the engineer plans list 5.26 ac.
Which is correct?
Clarify the in/hr amount and designed loading
The in/hr loading rate in the design plans is 0.939
rate (pg 21, pg 107)
in/hr but the application lists 0.078 in/hr.
0.939 in/hr exceeds the maximum dosing rate of
0.3 in/hr in the Soil Report (pg 33).
It should also be noted that the overall volume
that can be irrigated on the existing irrigation
field will decrease as the acreage has decreased.
Clarification of lack of storage volume increase
The permit application has no new proposed
storage unit. Based on pg 107, the existing
irrigation field has a new acreage of 5.26 acres.
With no change to the permitted yearly max,
6,684,516 gallons can be irrigated in a year. If
each irrigation event is 20,333 gallons as
proposed, that field can be irrigated up to 328
days in a year. Based on the designed yearly max
for the new fields, 1,702,555 gallons can be
irrigated in a year. If each irrigation event is
39,667 gallons as proposed, those fields can be
irrigated only 42 days in a year. These calculations
are based on a peak flow design of 60,000 GPD. A
total of 8.4MG can be irrigated on the irrigation
fields.
If permitted for 49,000 GPD, there should be
enough capacity to irrigate 17.9 MG gallons,
correct? The storage pond is only 408,000
gallons.
Will be reclaimed quality? (pg 22)
VIIIA is answered yes. Will this system be
reclaimed quality effluent? If so there needs to be
a 5 day upset storage unit and a turbidimeter.
There was no indication of these items in the
application.
Soil Report (pg 32)
The soil analysis provided was completed in 2021.
The application guidance states that a soil
analysis must be conducted no more than one

year prior to the permit application. Will a new
soil analysis be needed?
The soil report states that ksats and other field
work was completed in June and October 2021.
The dates on the ksat forms are 2022. When were
the ksats done? If > 1yr ago will another
statement be needed stating that no changes
have been made.
The field logs were not included in this report.
These need to be provided.
The recommended loading rate in the report is
0.3 in/dose, but what was considered a dose in
this report was not defined. The recommended
instantaneous application rate is 0.4 in/hr. The
recommended loading rate is 36.82 in/yr. In VI1.3
of the application (pg 22) the maximum loading
rates are 1.27 in/hr and 15.64 in/yr for PcB2, and
1.27 in/hr and 12.24 in/yr for PcC2. Why are
these rates different? What is the recommended
in/hr from the soil scientist?
The loading rates were not described based on
map unit. The ksats were not divided by map
unit. Map unit loading rates should be provided
as slopes within the map units ranged from 5-
20%. The hourly and yearly loading rates will be
impacted by the higher slopes.
I also have some concerns about the ksat
measurements. Some did not appear to be at a
steady state when the test was ended, and
consecutive measurements were not used to
calculate an average in some tests.
Hydro Report (starts pg. 63)
The Approach lists 3 borings in the areas
identified as new irrigation fields. There was no
data for the borings included. The field
investigation section does not include the
borings. Were these completed?
There is no description of the site. There is a large
lake on the property with a stream that flows
from it. There are four groundwater monitoring
wells associated with the facility that are not
discussed in detail. One of the MWs is within an
irrigation field, and there is no discussion of

where the new downgradient MW should be
located. There is also no discussion of the 100 yr
flood plain, which the existing irrigation field and
ZB and C are next to. There are also agricultural
fields less than a mile from the irrigation area.
The area is described as the Carolina Slate Belt
(pg 75), which it is not. The area is in the
Charlotte and Milton Belts. Clarification is needed
if this will impact the hydrogeological report.
The maximum wastewater flow was calculated
assuming there is no water in the storage pond.
This is an incorrect assumption as the storage
pond will contain effluent when the new package
plant is installed. The storage pond cannot be
completely drained because a minimum liquid
level will always be maintained to protect the
irrigation pumps.
There are also no water supply wells in the area
as the campground is served by public water. In
the Conclusion, water supply well information is
listed. This needs to be clarified.
There is no discussion of the groundwater flow as
required. The Conclusion states that the
groundwater flow patterns are consistent with
the conceptual model. Where is this information?
The Conclusion also states that irrigation can
occur during all months of the year. Based on
Table 6, irrigation cannot occur in the existing
field during April.
The report also states that wastewater flow is
constrained by storage and irrigation fields to
33,238 GPD. The requested flow is 49,000 GPD.
The hydro report supports that flow cannot be
increased to 49,000 GPD.
This model does not account for the seasonal
nature of the campground, where peak flow can
be sustained for several days. It should also be
considered that irrigation is limited by
temperature, and limiting temperatures were not
included in the water balance calculations.

The figures do not appear to be referenced
correctly, or all figures included. Ex: The last
paragraph on Pg 73 references a Figure 5 showing
contours, but that is show in Figure 3 on the
following page. The cross section B-B' is also not
shown. These errors make the report hard to
follow and it appears that not all information is
included for review.
Water Balance
The application guidance states that residential
facilities must have a minimum of 14 days
storage. The water balance shows that only 12
days of storage are available with flow
constrained to an average of 33,238 GPD. Can a
campground be considered residential? Only
domestic waste will be entering the system.
The convergent water balance also shows that all
available storage will be used by April. This facility
has had some chronic storage issues during wet
months.
Engineering Plans (start pg 99)
There are several areas on the site plan where
the irrigation patterns and irrigation heads exceed
the soil review area. The irrigation patterns need
to be restricted, or the soil scientist confirm that
those areas are suitable as well.
Site Plans (pg 468)
The site plan does not show streams or surface
drainage features within 500ft of the treatment,
storage, and irrigation sites.
How do the camp sites need to be handled? The
site plan does not show where the individual
camp sites are.
There is an access road to the irrigation field and
MW3 that is not shown on the map. This road
also has ditches on both sides. Irrigation from the
new zones should be restricted from these
ditches. There are also two ditches within ZB and
ZC that should be buffered and excluded from the
irrigation area.
The RB and CB are not shown.
Operation and Maintenance Plan (starts pg 473)
A spill prevention plan was not provided.
Residuals Management Plan (pg 1844-1846)
An oil and grease removal plan was not provided.
There is a small grill on the property.
Unlabeled well at toe slop of storage pond
A well is located at the bottom of the storage
embankment
pond embankment beside the access road to the

irrigation fields (35.8637604,-80.3961658). What
is this well? Is it an old monitoring well? Why
wasn't it abandoned? If it is an old monitoring
well, it should be properly abandoned, and the
required form submitted.

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KHA PROJECT
149701046
FOREST LAKE WWTP REPLACEMENT
LICENSED PROFESSIONAL
SHEET NUMBER
DATEKimley*Horn
11/17/2022
AND SPRAY FIELD EXPANSION
COREY KING P.E.
© 2022 KIMLEY—HORN AND ASSOCIATES, INC.
200 SOUTH TRYON STREET, SUITE 200, CHARLOTTE, INC 28202
PREPARED FOR
EQUITY LIFESTYLE PROPERTIES INC.
NC LICENSE NUMBER
PERMIT APPLICATION SITE
FIG 1
SCALE AS SHOWN
DESIGNED BY SNR
PHONE: [phone]
WWW.KIMLEY-HORN.COM
DAVIE NC
048981
DATE: ----
MAP FIGURE
0
100% PERMITTING PLANS - NOT RELEASED FOR CONSTRUCTION
11/17/2022
CAB
DRAWN BY CAB
No.
REVISIONS
DATE
BYJ
CHECKED BY CK

Caudle, Caitlin
From: Mitchell, Patrick
Sent: Friday, June 2, 2023 9:20 AM
To: Caudle, Caitlin
Subject: Soils TA for Forest Lake WWI - Davie County, NC
Attachments: Forest Lake Soils Map 20230530.pdf
Caitlin,
On May 30, 2023, a soils investigation was conducted for the subject project. The purpose of the soils investigation was
to review the site and soil conditions for proposed expansion of the wastewater irrigation fields serving the facility. Soils
were investigated using hand auger borings. A total of seven soil borings were advanced within the proposed expansion
spray areas. Attached is a soils map showing the approximate location of auger borings in relation to the proposed
expansion. A review of the soils report and agronomic report included with the application package, provided by
Piedmont Environmental Associates, P.A. (PEA), was also completed. Below is a summary of findings and
recommendations from the investigation and the review of the PEA reports.
Findings:
1. The soils observed within the proposed expansion areas during the investigation closely match the Pacolet soil
series mapped by NRCS in the soil survey. This concurs with the soils report that was provided by PEA.
2. Sandy loam topsoil layers were present in the hand auger borings. The observed depths ranged from 4 to 8
inches (most being 4 or 5 inches deep) in all borings except boring #7, which had less than one inch of sandy
loam before transitioning into a thin sandy clay loam layer and clay subsoil.
3. Subsoil horizons observed in auger borings suggests that the depths in which PEA measured hydraulic
conductivities is likely appropriate. The Ksat values reported by PEA are within an acceptable range for the soil
properties described in the soil borings.
Recommendations:
■ The slopes in the areas of soil borings #5 and #6 were near 20% slope, as indicated in PEA borings #15 & #17.
In addition, the depth of the sandy loam topsoil above clayey subsoils were found to be approximately 5
inches thick. Given the slope and thickness of topsoil, it is recommended that the hourly loading rate in this
area be reduced. An hourly loading rate of 0.20 — 0.25 inches/hour may be more appropriate.
■ The sandy loam topsoil layer observed in the area of soil boring #7 was found to be less than one inch thick
before transitioning into clayey subsoils. It is recommended that the hourly loading rate in this area be
reduced also. A maximum hourly loading rate of 0.20 inches/hour may be more appropriate.
The proposed maximum annual hydraulic loading rate of 36.82 inches/year using a max drainage coefficient of
10% proposed by PEA is acceptable for most areas. However, due to the slopes present in the area of soil
borings #5 & #6 it is recommended that the annual hydraulic loading rate be reduced in this area. The annual
hydraulic loading rate of this area could be decreased by >20% (i.e., reduce the max annual rate to "30 in./yr.
or less) to account for increased slopes.
In the table under section VI1.3. of the application form ("Soil Evaluation Recommended Loading Rate"), it
indicated: 31 fields with a B slope and loading recommended at 1.27 in./hr. and 15.64 in./yr. and 25 fields with
a C slope and loading recommended at 1.27 in./hr. and 12.24 in./yr. These values are inconsistent with the
recommendations made in the PEA soil report. The hourly loading rate of 1.27 in./hr. if grossly over the max
recommended by PEA and greater than the estimated capability of the topsoils present. The annual loading
rates of 15.64 & 12.24 in./yr. in this section of the application would likely require significantly more storage to
be added to this system. This could be a typo in the application. An explanation should be requested.
The annual agronomic loading rates proposed by PEA should be appropriate for most areas. It should be noted
that vegetation in the area of soil borings #1, #2 & #4 is a mixed hardwood forest with some pine understory
rather than an evergreen pine forest. The agronomic loading rate could be lowered in this area as a result.

Given the proposed lower loading rates for Nitrogen and Phosphorus, this should not present an issue.
However, if loading rates increase or nutrient concentrations in wastewater increases, nutrient overloading
could potentially result in this area.
■ In the table under section VI1.7. of the application form, it indicated that the soil series "RecUom" with 0.5%
slopes were used for the agronomic determination. This is not consistent with the Agronomic Report provided
by PEA. This could be another typo, but an explanation should be requested.
■ Some of the hydraulic conductivity measurement data provided by PEA warrants additional review. Examples:
some measurement run times were the same but the reported flow rates went up on the last readings, some
flow rate measurements appeared to be dropping when the tests were ended without reaching steady state. I
did not see the field measurement data included in the application package. Review of the field data may
answer these questions. An explanation or walk through of the field data with PEA may also help.
■ There were a couple of drainage features located in or immediately adjacent to the proposed wetted areas
that are not shown on the maps provided in the application package. The irrigation areas should be >15 ft.
from these ditches.
■ It should be noted that none of the calculation values provided by PEA in the soils report and agronomic report
were checked for accuracy. Recommend verifying calculation results are accurate before proceeding with
permitting.
Please let me know if you have any questions or would like to discuss any of the items above.
Thank you,
Patrick
Patrick L. Mitchell, LSS
Regional Soil Scientist
Division of Soil and Water Conservation
NC Department of Agriculture and Consumer Services
Phone: [phone]
Mailing Address: PO Box 845, Mocksville, NC 27028
Office Location: 191 S. Main St., Mocksville, NC 27028
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.

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