WQ0044259_Additional Information Request_20230619

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
RICH DEMING — CEO
CAROLINA POULTRY POWER RG2, LLC
3730 NORTH MAIN STREET
FARMVILLE, NORTH CAROLINA 27828
Dear Mr. Deming:
NORTH CAROLINA
Environmental Quality
June 19, 2023
Subject: Application No. WQ0044259
Additional Information Request
Carolina Poultry Power —
Wilson CUS
Reclaimed Water System
Wilson County
Division of Water Resources' Central and Regional staff have reviewed the application package
received March 27, 2023. 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 July 19, 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 L, 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: h!Ws://edocs.deq.nc.,gov/Fonns/NonDischarge-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact Erick Saunders at [phone]
or [e-mail]. Thank you for your cooperation.
Sincerely,
�2GCf2d8rL �Gse:��,.�i2.�
Erick Saunders, Engineer
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Kim Melvin, PE — Project Integration, Inc. (Electronic Copy)
Michael Montebello — NPDES Permitting Program (Electronic Copy)
Laserfiche File (Electronic Copy)
E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA -
OepaMlent at EnulmnmeMal Duality 919.707.9000

Mr. Rich Deming
June 19, 2023
Page 2 of 5
A. Cover Letter/Introduction:
1. The City of Wilson's existing pond is identified as an "existing evaporation pond". The reclaimed
water generation permit (WQ0018709) includes a 3.4 million gallon (MG) synthetically -lined
storage basin in its facility description; however, our records indicate that this basin is located
further west than the pond identified in this submittal (Latitude: 35.685095°, Longitude: -
77.897819°). A review of the NPDES permit (NC0023906) identifies an unspecified number of
"polishing ponds" that are out of service. It is unclear whether the referenced polishing ponds
include the existing pond being proposed for use in the Carolina Poultry Power (CPP) thermal loop
design. Please clarify which existing pond is being repurposed for use in the proposed thermal
loop. Please specify the permit currently associated with this feature.
2. The first paragraph of the introduction states that the evaporation pond will have the ability to
receive "city water" if additional water is needed. Is the "city water" described here the City of
Wilson's reclaimed water or potable water? If potable water, please provide information
addressing how the potable water infrastructure will be protected from backflow and cross -
connection. Please also revise the engineering plans to adequately depict the potable water
infrastructure to be installed to serve the evaporation pond.
3. The introduction describes the existing pond as being lined with "gunite" concrete and a partial
synthetic/plastic liner. Information regarding the synthetic/plastic liner appears to be limited, and
it is unclear whether this liner is suitable for use in a heat transfer process. Is there manufacturer's
information available regarding the existing liner fabric and its temperature rating? Please provide
additional information.
4. The pond design overview and Figure 2 indicate that hot water generated by the thermal facility is
to be directed to multiple locations in the permitted City of Wilson NPDES/reclaimed water
generation facility at Hominy Creek. These proposed hot water lines appear to serve the treatment
processes described within Permit No. NCO023906 and WQ0018709 and may require permit
modifications to those permits. Please provide additional information regarding the proposed uses
of generated hot water within the City of Wilson -owned facility and contact Mr. Michael
Montebello with the NPDES Permitting Program and Mr. Nathaniel Thornburg with the Non -
Discharge Branch to determine whether modifications to the NPDES/reclaimed water generation
permits are required.
It is unclear whether the reclaimed water in the proposed evaporation pond is to be discharged
under the City of Wilson's NPDES permit under certain conditions or circumstances. The NPDES
permit has temperature monitoring and reporting requirements for the water they discharge, and it
is unclear whether high temperature water from this process would interfere with water quality
standards in the receiving water body. Please provide additional information regarding whether
discharge under the NPDES permit may occur during the operation of the CPP conjunctive
utilization facility.
6. This facility will spray reclaimed water at a high discharge velocity with fine droplet size coming
out of the spray nozzles that is more susceptible to drift during. What measures are being taken to
minimize the risk of drift from this facility?
7. How will the circulation of hot water from the facility to the to the Wilson treatment facility as
mentioned in the cover letter be controlled? Who would be responsible for the distribution of this
water into the treatment process, and how would it be delivered?

Mr. Rich Deming
June 19, 2023
Page 3 of 5
B. Application Fee:
1. No comments.
C. Application (Form RWPI 06-16):
1. No comments.
D. Application (Form RWCU 06-16):
1. In Item II.4 the estimated amount of reclaimed water to be used is 1.8 MGD. Does this volume
represent the quantity pumped out of the reclaimed water storage pond to the CPP facility or the
evaporative loss from the CPP thermal loop process? Please clarify.
2. In Item IV.2 the response indicates that potable water will not be used to supplement the reclaimed
water. Please confirm that this response agrees with the information requested in Comment A.2.
3. In Item V.3 it lists that there are no discharge points (including pipes) from the evaporation pond
impoundment. Please confirm that there are no outlet structures or other piping associated with the
City of Wilson's reclaimed water system Permit No. WQ0018709 or the NPDES Permit No.
NCO023906 serving this pond.
4. The Earthen Impoundment Dimensions in Item V.11. list the impoundment bottom elevation at 70
ft, but the surveyed bottom of pond elevation on Drawing No. 1966 is 88.4 ft. Please review the
impoundment information in this table and revise as necessary.
Item VI.5 references the drawings package and engineering plans (as well as the partial
specifications depicted on the final sheet of the engineering plans). Only the engineering plans
have been signed and sealed by a North Carolina Professional Engineer.
E. Property Ownership Documentation:
1. The Lease Agreement and the First Amendment to Lease documents between Stockport Limited
Partnership ("Stockport") and Carolina Poultry Power RG2, LLC (CPP) were not notarized. In
accordance with 15A NCAC 02U .0201(e)(4), agreements to lease the property shall be written,
notarized, and signed by both parties and accompanied by a plat or survey map. These documents
shall be executed and notarized to meet these requirements.
2. The Memorandum of Lease attached as Exhibit B to the Lease agreement between Stockport and
CPP was not executed. Item 17 on Page 9 indicates that this memorandum would be executed
simultaneous of the execution of the lease agreement in recordable form. Please provide the
executed and recorded memorandum.
3. The survey maps provided as an Exhibit to the Lease Agreement between Stockport and CPP are
listed as "Preliminary — Not for Recordation, Conveyances, or Sales". Please provide a survey map
or plat that is finalized to meet the requirements of 02U .0201(e)(4).
F. Engineering Plans:

Mr. Rich Deming
June 19, 2023
Page 4 of 5
1. The plans do not appear to show a full piping plan for the proposed thermal loop, including joints,
valves, and other appurtenances. A site plan shall be provided for the configuration of the piping
network, including where the system ties into the City's existing reclaimed water line.
2. In accordance with Item E of the Reclaimed Water Systems — Conjunctive Utilization Instruction
form, please provide a profile view of cooling basin.
3. There appear to be several section callouts on Sheets 1633 and 1634 that were not provided in the
plans, including P3 and P4. Please review the section and detail callouts and provide the correct
drawings as necessary.
4. The engineering plans depict reclaimed water piping on Sheets 1964 and 1967 within the limits of
construction. Are these features part of the existing facility piping at the City of Wilson treatment
plant? Please note that new reclaimed water distribution piping (including tapping locations, pipe
diameters and lengths, valves, and other appurtenances) shall be described in the engineering
documents for inclusion in the permit. New distribution lines are to meet the requirements of 15A
NCAC 02U .0403.
5. The CPP thermal facility appears to be proposed at a location within the spray irrigation utilization
site "CU-6" permitted under WQ0018709. Has the irrigation infrastructure on the parcel owned
by the Stockport Limited Partnership been abandoned and capped in place by the City of Wilson?
Please provide additional information.
6. On Sheet 1963, the piping left of the evaporation cooling pond (labeled `8" � (E) Water') appears
to go off -plan and away from the pump house and is outside the proposed limits of construction.
Should this piping be terminating at the pump house location? Please review and revise.
7. On Sheet 1966, the pump station equipment lists Mark ID M-0113/14 for the circulation cooling
pumps as having "Blue Standard Paint". Pursuant to 15A NCAC 02U .0403(c)(1), all reclaimed
water piping and appurtenances shall be either colored purple (Pantone 522 or equivalent) with
blue identification paint being reserved for use with potable water. Please revise.
G. Specifications:
A set of product cut sheets and construction notes on Sheet 8 of the "Engineering Plans" were
provided in lieu of formal engineering specifications. Pursuant to 15A NCAC 02U .0201(c),
engineering plans and engineering specifications are to be separate documents. The specifications
shall describe the materials to be used, methods of construction, and means for ensuring quality
and integrity of the finished product, including leakage testing. The specifications shall also
describe construction sequence and include information regarding anticipated interruptions at the
City of Wilson facility because of the installation of the Carolina Poultry Power thermal loop
equipment. The specifications shall include a cover page that is signed and sealed by a North
Carolina Professional Engineer in good standing.
2. The "Design Criteria Distribution Lines" section of the construction notes on Sheet 8 of the
"Engineering Plans" set is incomplete and references "Sheet 9" which was not provided. Please
include the appropriate specifications for reclaimed water distribution piping and appurtenances
meeting the 15A NCAC 02U requirements and pertinent AWWA standards within the formal
specifications document requested in Comment G.1.

Mr. Rich Deming
June 19, 2023
Page 5 of 5
H. EnEineerins Calculations:
1. Shorthand and other identifiers were used throughout the calculations package. Please provide
clarification on the following descriptions:
a. Within the "Design Summary" table, the column Ref/Comment includes quantitative
values but it is unclear what these values represent.
b. Does Wellons Water Characteristics represent the City of Wilson's generated
reclaimed water?
Multiple numbered Sources are listed including "Foods Process Flows". Please
provide a summary of the source inputs and clarify what "Foods Process Flows"
represents.
2. The calculations for "Storm Water Metrics" refer to a 10-year, 1-hr rain intensity event. Reclaimed
water storage units that are not protected from rainfall and runoff are to be designed to contain the
accumulation of water from a 25-year, 24-hour storm event. Please revise the calculations
accordingly.
I. Site Map:
The cover letter/introduction document indicated that a signed/sealed/dated site map was included
in Appendix F "Drawings Package"; however, the sheets within this package were not
signed/sealed/dated and were all marked "Preliminary — Not for Recordation, Conveyance, or
Sales". Please provide a site map meeting the requirements of 15A NCAC 02U .0201(d) that
clearly depicts the proposed conjunctive utilization system. We would also like to request an 8.5
x 11 copy of Figure 2 "Pond Thermal Loop Diagram" shown in the cover letter/introduction
document.
J. Operation & Maintenance Plan:
1. The proposed facility utilizes an existing pond structure that is part of an active reclaimed water
generation facility. Please provide an operation and maintenance plan for the proposed reclaimed
water conjunctive utilization evaporation pond meeting the requirements of 15A NCAC 02U .0801.
K. Additional Documentation:
➢ Wastewater Chemical Analysis:
1. Please confirm that no chemical additives are being used by the Carolina Poultry Power thermal
facility to improve the efficacy/performance of the reclaimed water thermal loop.
L. Recommendations: (Response not required)
1. No comments.