WQ0002829_Hydrogeologic Report_20060406

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Hydrogeologic Report
KDHWWTP
Kill Devil Hills, North Carolina
S&ME Project No. 1584-03-100A
Prepared For:
Landmark Building and Development
7518 Caratoke Highway
Jarvisburg, North Carolina 27947
:7
KDHWWTP, LLC
P.O. Box 3629
Kill Devil Hills, North Carolina, 27948
Prepared By:
S&ME, Inc.
3718 Old Battleground Road
Greensboro, NC 27410
October 19, 2005
Edmund Q. B. Henriques, U.G.
Environmental Department Manager
A P A - 6 2006
J
WASHINGTON heGIONA, OFFICE
D'VQ
David R. Loftis, P.E.
Project Professional

•
i October 19, 2005
KDHWWTP, LLC
do Landmark Building and Development
! 7578 Caratoke Highway
Jarvisburg, North Carolina 27947
Attention: Mr. Michael Robinson
Reference: Hydrogeologic Report
KDHWWTP
Kill Devil Hills, Dare County, North Carolina
S&ME Project No. 1584-03-100A
S&ME, Inc. (S&ME) has completed the authorized Hydrogeologic Report (ref. S&ME's Proposal
No. 1584-04-P195 dated December 22, 2004) for the KDHWWTP, located in Kill Devil Hills,
North Carolina. The attached report presents the results of S&ME's evaluation of the referenced
site as authorized by our Agreement for Services contract.
We hope this report meets your needs. If we can be of any further assistance, please call.
S&ME, Inc.
Edmund Q. B. Henriques, L. .
Environmental Department Manager
EQBH/DRLdrl
SWE, Inc. [phone]
3718 Old Battleground Road [phone] fax
Greensboro, North Carolina 27410 [phone]
David R. Loftis, P.E.
Project Professional
www.smainc.com

Table of Contents
Pase No.
1.0 Introduction..........................................................................................................................I
1.1 Project Authorization.................................................................................................2
1.2 Purpose and Scope......................................................................................................2
1.3 Limitations and Sole Use Statement.........................................................................3
1.3.1 Limitations ................ »................ ».......... »..................................................... 3
1.3.2 Sole Use Statement ........... »...........................................................................3
2.0 Model Verification..................................................................................................................4
2.1 Calibrated Groundwater Model ............................. ».......... ».................................... 4
2.2 Model Verification ............................................. »................ »..................................... 7
1 3.0 Predictive Simulations......................................................................»..»..............................13
3.1 Model Setup »........ »................. »»........ »..................... »........ »...... .... .......................... 4
3.1.1 Grid Space ...... »......... »......... ».......»».....»..»..................... 3
3.1.2 Green Area .»»».... »..»....... »....... »... ».......... :.....».»»........»............ ............. »3
3.1.3 Infiltration Ponds ......... »....... ...............
3.2 Flow Simulation...»............................................................... ».................................... 7
3.2.1 Normal Operation ....................... »........................... ».................................... 3
3.2.2 5-Day Upset ....................... ».......... »...»......... »......... »............... »»..».... ».»»... 3
3.3 Nitrate Fate and Transport Simulation ...» .......................... »»..... ....... ....... ....... —7
3.4 Model Assumptions/Limitations...................... »....................................................... 7
4.0 Potential Impacts of the Disposal System...........................................................................15
j4.1 Surface Runoff.......................................................... ».............................. ....4
4.2 Drainage Features ..»......................... ».... »..».».... »... »........ ..... ............... ........... ....»4'
5.0 Compliance Monitoring Wells.............................................................................................16
6.0 References ............................................... »............................................ »............................... 26
�I
Tables
I— I Table 1: Calibrated Model Input Parameters
Table 2: Groundwater Elevation Data
Table 3: December 2004 and January 2005 Operation
—! Table 4: Input Parameters for "Normal Operation" Predictive Model
Table 5: "Normal Operation" Disposal Volumes
Table 6: Input Parameters for the 115-Day Upset" Predictive Model
Table 7: 115-Day Upset" Disposal Volumes
Table 8: Summary of Fate and Transport Predictive Models

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
June 16, 2006
GEORGE E. GOODRICH — MANAGING PARTNER
KDHWWTP, LLC
POST OFFICE BOX 3629
KILL DEVIL HILLS, NORTH CAROLINA 27948
Subject: Permit No. WQ0002829
KDHWWTP, LLC
Wastewater Treatment, High Rate
Infiltration and Low Rate
Reclaimed Infiltration and
Irrigation Facilities
Dare County
Dear Mr. Goodrich:
In accordance with your permit modification request received January 17, 2006 which was
returned for failure to provide additional information, and the resubmittal received April 6, 2006 and
subsequent additional information received May 4, 2006 and May 23, 2006, we are forwarding herewith
Permit No. WQ0002829, dated June 16, 2006, to KDHWWTP, LLC for the construction and continued
operation of the subject wastewater treatment, high rate infiltration facilities and low rate reclaimed
infiltration and irrigation facilities.
This permit shall he effective from the date of issuance until May 31, 2009, shall void Permit No.
WQ0002829 issued June 21, 2004, and shall be subject to the conditions and limitations as specified
therein. Please pay particular attention to the monitoring requirements in this permit. Failure to establish
an adequate system for collecting and maintaining the required operational information will result in
future compliance problems.
Please pay particular attention to Conditions H(14), which prohibits the irrigation of reclaimed
water onto any impervious surfaces. Please also note that High Rate Infiltration Beds 2 and 8 have been
removed from the permit.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made this-1-11 lie final -gurl hi
I J U N 21 2006
t
f WASHINGTON REGIONA, OFFICE
DWQ
NOn` CamlI��,na
�aturrr!!y
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone [phone] Customer Service
httpl/www.ncwaterquality.org 2728 Capital Boulevard Raleigh, NC 27604 Fax [phone]
Fax [phone]
An Equal Opportunity/Affirmative Action Employer — 501/6 Recycled/] 01/6 Post Consumer Paper

One set of approved plans and specifications is being forwarded to you. If you need additional
information concerning this matter, please contact Analee Harris at [phone].
Sincerely
L
?CAlan W. Klimek, P.E.
cc: Dare County Health Department
e a or--- o , .
Michael W. Robinson, P
Technical Assistance and Certification Unit
Aquifer Protection Section Central Files
LAU Files
2

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
WASTEWATER TREATMENT, HIGH RATE INFILTRATION SYSTEM, LOW RATE
RECLAIMED INFILTRATION, AND RECLAIlgED IRRIGATION PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
KDEM WTP, LLC
Dare County
• ; r1i
continued operation of a 500,000 gallon per day (GPD) wastewater collection, treatment and high rate
infiltration disposal systems (based on a loading rate of 10 GPD/SF) consisting of a manually cleaned bar
screen; a 118,000 gallon aerated flow equalization basin; three (3) 37,000 gallon aerated flow equalization
basins; (3) 43,000 gallon aerated equalization basins (cumulative flow equalization volume of
approximately 197,000 gallons); two-(2) flow equalization pumps (416 GPM @ 20' TDH); a flow splitter
box; three (3) 104,000 gallon aeration basins; two (2) 155,000 gallon aeration basins; two (2) 91,000
gallon clarifiers; a 50,000 gallon clearwell with ,two (2) pumps (957 gpm @ 40' TDH), two (2) rapid sand
filters each with a 156 square foot (ft) surface area (rated at 1.11 gpm/ft); a 35,000 gallon filter dosing
tank with two (2) filter dosing pumps (833 gpm @ 25' TDH); a 20,000 gallon mudwell with two (2)
pumps (280 gpm @ 20' TDH); a 142,000 gallon aerated sludge digester; five (5) aeration blowers rated at
800 cubic feet per minute (cfm); an air scour blower rated at 781 cfin; a MicroTolo turbidimeter; four (4)
UV disinfection banks each rated at 400,000 GPD; ten (10) pumps (three (3) 7.5 hp and seven (7) 15 hp);
ten (8) high rate infiltration beds with a cumulative disposal area of 58,681 ft ; a 10-inch butterfly valve
with electric actuator (automatically closes when turbidity exceeds 10 NTU); an Ultra Mag flow meter; a
2,000 gallon pump station with dual 7.5 hp pumps and alarms; two (2) interconnected low rate reclaimed
infiltration ponds with a cumulative disposal area of 91,465 ft ; a stand-by power system consisting of a
45 kW generator, 115 kW generator;
construction and operation of an Ultra Mag flow meter, an irrigation system pump station consisting of
two (2) pumps (one (1) 25 hp and one (1) 3 hp); 24.55. acres of seven (7) reclaimed irrigation zones for a
total treatment capacity of 500,000 GPD and a total disposal facility of 500,000 GPD to serve
KDHWWTP, with no discharge of wastes to the surface waters, pursuant to the application received April
6, 2006, and subsequent additional information received by the Division, and in conformity with the
project plan, specifications, and other supporting data subsequently filed and approved by the Department
of Environment and Natural Resources and considered a part of this permit.
This permit shall be effective from the date of issuance until May 30, 2009, shall void Permit No.
WQ0002829 issued June 21, 2004, and shall be subject to the following specified conditions and
limitations:

I. PERFORMANCE STANDARDS
1. The two (2) low rate infiltration ponds shall receive reclaimed water only and shall not exceed a
daily application volume of 136,283 GPD. High rate infiltration spray beds 1-A and 1-B shall
only receive wastewater during treatment plant upset conditions.
2. Upon completion of construction and prior to operation of this permitted facility, a certification
must be received from a professional engineer certifying that the permitted facility has been
installed in accordance with this permit, the approved plans and specifications, and other
supporting materials. If this project is to be completed in phases and partially certified, you shall
retain the responsibility to track further construction approved under the same permit, and shall
provide a final certificate of completion once the entire project has been completed. Mail the
Certification to the Land Application Unit, 1636 Mail Service Center, Raleigh, NC 27699-1636.
The Washington Regional Office, telephone number [phone], shall be notified at least
forty-eight (48) hours in advance of operation of the installed facilities so that an in -place
inspection can be made. Such notification to the regional supervisor shall be made during the
normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State
Holidays.
4. The reclaimed water utilization facilities (i.e., low rate infiltration ponds and irrigation areas) and
high rate infiltration facilities shall be effectively maintained and operated at all times so that
there is no discharge to the surface waters, nor any contamination of ground waters, which will
render them unsatisfactory for normal use. In the event that the facilities fail to perform
satisfactorily, including the creation of nuisance conditions or failure of the infiltration areas to
adequately assimilate the wastewater, the Permittee shall take immediate corrective actions,
including those actions that may be required by the Division of Water Quality (Division), such as
the construction of additional or replacement wastewater treatment or disposal facilities.
This permit shall become voidable if the soils fail to adequately assimilate the wastes and may be
rescinded unless the facilities are installed, maintained, and operated in a manner which will
protect the assigned water quality standards of the surface waters and ground waters. The
ponding of wastewater on the surface of the spray beds when the dosing cycle commences shall
be considered as evidence of failure of the soils to adequately assimilate the wastewater.
Additionally, such failure shall be interpreted as a violation of this permit condition.
6. The residuals generated from these treatment facilities must be disposed in accordance with
General Statute 143-215.1 and in a manner approved by the Division.
7. Adequate measures shall be taken to divert stormwater from the high rate infiltration and low rate
reclaimed infiltration and irrigation areas and to prevent wastewater runoff.
8. Diversion or bypassing of the untreated wastewater from the treatment facilities is prohibited.
9. The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface or groundwaters resulting from the operation of this facility.
10. Public access to the irrigation sites shall be controlled during active site use. Such controls may
include the posting of signs showing the activities being conducted at each site, mailers, and
notification of prospective buyers or upon sale of property. Signs shall be posted in plain sight at
a minimum of 200-foot intervals around the low rate reclaimed infiltration ponds.
2

11. The following buffers shall be maintained:
a. 50 feet between wastewater treatment units and property lines,
b. 100 feet between wastewater treatment units and wells,
c. 10 feet between high rate infiltration unit and any on -property residential units that are to be
sold (e.g., condominiums, subdivisions),
d. 500 feet between high rate infiltration unit and any impounded public surface water supply or
public shallow (less than 50 feet deep) ground water supply,
e. 100 feet between high rate infiltration unit and any private. or public water, supply source,
f. 200 feet between high rate infiltration unit and any streams classified as WS or B,
g. 200 feet from mean high water between high rate infiltration unit and any "SA" or "SB"
classified surface waters,
h. 200 feet from normal high water between high rate infiltration unit and any other stream,
canal, marsh, or coastal waters,
i. 200 feet from normal high water between high rate infiltration unit and any Class I or Class II
impounded reservoir used as a source of drinking water,
j. 200 feet between high rate infiltration unit and any other lake or impoundment,
k. 200 feet between high rate infiltration unit and any Drainage systems (ditches, drains, surface
water diversions, etc.) and from any groundwater lowering and surface drainage ditches,
1. 50 feet between high rate infiltration unit and property lines,
m. 50 feet between high rate infiltration unit and public right of ways,
n. 100 feet between low rate infiltration pond and water supply wells,
o. 100 feet between low rate infiltration pond and waters classified as SA,
p. 25 feet between low rate infiltration pond and surface waters not classified as SA,
q. 50 feet between reclaimed water storage/irrigation ponds and property lines.
r. 100 feet between irrigation areas and water supply wells,
s. 100 feet between irrigation areas and waters classified as SA,
t. 25 feet between irrigation areas and surface waters not classified as SA.
12. The following shall be requirements for the reclaimed water distribution, storage, and utilization
facilities:
a. All reclaimed water valves, storage facilities, and outlets shall be tagged or labeled to warn
the public or employees that the water is not intended for drinking. Where appropriate, such
warning shall inform the public or employees to avoid contact with the water.
b. All reclaimed water piping, valves, outlets, and other appurtenances shall be color -coded,
taped, or otherwise marked to identify the source of the water as being reclaimed water.
i. All reclaimed water piping and appurtenances shall be either colored purple (i.e., Pantone
522) and embossed or integrally stamped or marked "CAUTION: RECLAIMED
WATER — DO NOT DRINK" or be installed with a .purple (i.e., Pantone 522)
identification tape or polyethylene vinyl wrap. The warning shall be stamped on opposite
sides of the pipe and repeated every three feet or less.
ii. Identification tape shall be at least three inches wide and have white or black lettering on
purple (i.e., Pantone 522) field stating "CAUTION: RECLAIMED WATER — DO NOT
DRINK." Identification tape shall be installed on top of reclaimed water pipelines,
fastened at least every 10 feet to each pipe length and run continuously the entire length
of the pipe.
c. All reclaimed water valves and outlets shall be of a type, or secured in a manner, that permits
Operation by authorized personnel only.
3

d. Above -ground hose bibs (i.e., spigots or other hand -operated' connections) shall not be
present. Hose bibs shall be located in locked below -grade vaults that shall be clearly labeled
as being of non -potable quality. As an alternative to the use of locked below -grade vaults
with standard hose bibs services, hose bibs, which can only be operated by a special tool or
connected to a special hose connection may be placed in non -lockable underground services
boxes clearly labeled as non -potable water.
13. A usable green area shall be maintained for wastewater disposal. The green area shall have the
capability of accommodating the average daily flow of the facility being served without
exceeding the loading rates of the green area. A "green area", as defined in 15A NCAC 2H .0404
(g)(7), is an area suitable for waste disposal, either in its natural state or which has been modified
by planting a vegetative cover of grasses or low growing shrubbery.
II. OPERATION AND MAINTENANCE REQUIREMENTS .
1. The facilities shall be properly maintained and operated at all times.
2. Upon' classification of the wastewater treatment and infiltration facilities by the Water Pollution
Control System Operators Certification Commission (WPCSOCC), the Permittee shall designate
and employ a certified operator to be in responsible charge (ORC) and one or more certified
operator(s) to be back-up ORC(s) of the facilities in accordance with 15A NCAC 8G .0201. The
ORC shall visit the facilities in accordance with 15A NCAC 8G .0204 or as specified in this
permit and shall comply with all other conditions specified in these rules.
3. The screenings removed from the wastewater treatment plant shall be properly disposed in a .
sanitary landfill or by other means that have been approved by this Division.
4. The facilities shall be effectively maintained and operated as a non -discharge system to prevent
the discharge of any wastewater outside of the high rate infiltration disposal areas, reclaimed
infiltration ponds, and irrigation areas which result from the operation of this facility.
5. Diffusers shall be cleaned as needed to ensure that adequate aeration is provided. The Permittee
shall maintain records of this maintenance.
6.. An automatically activated standby power source shall be on site and operational at all times. If a
generator is employed as an alternate power supply, it shall be tested weekly by interrupting the
primary power source.
7. No type of wastewater other than that from KDHWWTP shall be disposed of in the infiltration
and irrigation areas.
8. No traffic or equipment shall be allowed on the disposal areas except while installation occurs or
while normal maintenance is being performed.
9. The high rate infiltration spray beds shall be raked twice weekly during the months April through
October and once a week during the months of November through March.
10. Vegetative growth must be kept out of the high rate infiltration spray beds at all times. All
vegetation must be removed manually so that minimal disturbance will occur to the disposal area.
11. The application of chemicals to the high rate infiltration spray beds is expressly prohibited.
12. Freeboard in the low rate infiltration ponds shall not be less than two (2) feet at any time.
4

13. A protective vegetative cover shall be established and maintained on all earthen basin
embankments (outside toe of embankment to maximum pumping elevation), berms, pipe runs,
erosion control areas, and surface water diversions. Trees, shrubs, and other woody vegetation
shall not be allowed to grow on the earthen basin dikes or embankments. Earthen basin
embankment areas shall be kept mowed or otherwise controlled and accessible.
14. The reclaimed water shall not be irrigated onto any impervious surfaces.
15. The following application rates for the high rate infiltration system (Spray Beds 1-A through 7-B)
and low rate reclaimed infiltration system (Ponds 1 and 2) shall not be exceeded:
Disposal Site
Area
W)
Maximum Volume
(GPD)
Design Loading
Rate
(GPD/ftz
Maximum Loading
Rate
GPD/ft2
1-A
12,000
0
0
10
1-B
12,000
0
0
10
3
2,827
26,715
9.45
10
4
5,027
47,505
9.45
10
5
2,827
26,715
9.45
10
6
9,000
85,050
9.45
10
7-A
7,500
70,875
9.45
10
7-B
7,500
70,875
9.45
10
Ponds 1 and 2
91,465
136,283
1.49
1.5
' Spray beds 1-A and 1-B shall only received treated wastewater during treatment plant upset
conditions.
16. The following application rates -for the low rate greenspace irrigation system shall not be
exceeded:
Irrigation.Zone
Wetted Area
acres
Dominant Soil
Series
Loading Rate
in/hr
Loading Rate
in/
1
4.60
Ousley
1.0
118
2
6.47
Corolla
1.0
118
3
3.27
Corolla
1.0
118
4
5.62
Ousley
1.0
118
5
0.94
Newhan
1.0
118
6
1.65
Ousley
1.0
118
7
2.00
Newhan
1.0
118
9

M. MONITORING AND REPORTING REQUIREMENTS
Any monitoring (including groundwater, surface water, soil or plant tissue analyses) deemed
necessary by the Division to insure surface and ground water protection will be established and
an acceptable sampling reporting schedule shall be followed.
2. Three (3) copies of all monitoring data [as specified in Conditions 1II(3) and M(4)] on Form
NDMR-1 and three (3) copies of all operation and disposal records [as specified in Condition
III(5)] on Form NDAR-2 shall be submitted on or before the last day of the following month. All
information shall be submitted to the following address:
Information Processing Center
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
3. Influent flow shall be continuously monitored and daily flow values shall be reported on Form
NDMR-
The Permittee shall install an appropriate flow measurement device consistent with approved
engineering and scientific practices to ensure the accuracy and reliability of influent flow
measurement. Flow measurement devices selected shall be capable of measuring flows with a
maximum deviation of less than 10 percent from true flow, accurately calibrated at a minimum of
once per year, and maintained to ensure that the accuracy of the measurements is consistent with
the accepted capability of that type of device. Records of flow measurement device calibration
shall be kept on file by the Permittee for a period of at least three years. At a minimum, data to
be included in this documentation shall be:
a. Date of flow measurement device calibration
b. Name of person performing calibration
c. Percent from true flow
4. As an indicator of proper operation and maintenance, the facility shall produce an effluent in
compliance with the following limitations:
a. High Rate Infiltration Spray Beds:
Parameter
Monthly Average'
Daily (Instantaneous)
Maximum
Flow
327,735 GPD
BOD5 (5-day, 20°C)
10 mg/1
NH3 as N
4 mg/1
TSS
20 m
Fecal Coliform
14 per 100 ml
43 per 100 ml
The effluent pH shall not be less than 6.0 standard units nor greater than 9.0 standard units.
a
Monthly averages for all but fecal coliform shall be the arithmetic mean of all samples
collected during the reporting period.
b
Monthly average for fecal coliform shall be the geometric mean of all samples collected
during the reporting period.
Daily maximum shall be the maximum value of all samples collected during the reporting
period.

The effluent from the subject facilities shall be monitored, by the Permittee, at a point prior to
high rate infiltration for the following parameters:
Parameter
Sampling Point
Sampling Frequency
Type of Sam le
Flow
Influent or Effluent
Continuous
Recording
BOD5 (5-day, 20°C)
Effluent
' 2/Week
Composite
NH3 as N
Effluent
' 2/Week
Composite
TSS
Effluent
` 2/Week
Composite
Fecal Coliform
Effluent
" 2/Week
Grab
Settleable Matter
Effluent
Daily
Grab
Residual Chlorine
Effluent
Daily
Grab
NO3
Effluent
'" Triannually
Grab
TDS
Effluent
*` Triannually
Grab
TOC
Effluent
" Triannually
Grab
Chloride
Effluent
Triannually
Grab
Orthophosphate
Effluent
Triannually
Grab
VOC
Effluent
Triannually
Grab
pH
Effluent
" Triannuall
Grab
* 2/Week sampling frequency only during the months of June through August. During the
remainder of the year, these parameters shall be monitored monthly.
** Triannually sampling shall be conducted during March, July and November.
If Groundwater sampling indicates or predicts problems with compliance with of the
Groundwater Standards, this permit will be modified to include additional and/or more
restrictive limitations.
b. Low Rate Reclaimed Infiltration Ponds:
Parameter
b
Monthly Average
Daily (Instantaneous)
Maximum d
Flow'
136,283 GPD
BOD5 (5-day, 20°C)
10 mg/1
15 mg/1
NH3 as N
4 mg/1
6 mg/1
TSS
5 m
10 m
Fecal Coliform
14 per 100 mlc
25 per 100 nil
Turbidity
10 NTU
The effluent pH shall not be.less than 6.0 standard units nor greater than 9.0 standard units.
a The volume applied into Low Rate Reclaimed Infiltration Ponds 1 and 2 shall be
determined by subtracting the volume removed for irrigation from the total volume
received by the pond.
b
Monthly averages for all but fecal coliform shall be the arithmetic mean of all samples
collected during the reporting period.
c Monthly average for fecal coliform shall be the geometric mean of all samples collected
during the reporting period.
d
Daily maximum shall be the maximum value of all samples collected during the reporting
period.
7

The effluent from the subject facilities shall be monitored, by the Permittee, at a point prior to
low rate reclaimed infiltration for the following parameters:
Parameter
Sampling Point
SEMling Frequency
Type of Sa le
Flow
Influent or Effluent
Continuous
Recording
Turbidity
Effluent
Continuous
Recording
BODS (5-day, 20°C)
Effluent
* 2/Week
Composite
NH3 as N
Effluent
` 2/Week
Composite
TSS
Effluent
` 2/Week
Composite
Fecal Coliform
Effluent
' 2/Week
Grab
Settleable Matter
Effluent
Daily
Grab
Residual Chlorine
Effluent
Daily
Grab
NO3
Effluent
"' Triannually
Grab
TDS
Effluent
" Triannually
Grab
TOC
Effluent
" Triannually
Grab
Chloride
Effluent
" Triannually
Grab
Orthophosphate
Effluent
" Triannually
Grab
VOC
Effluent
" Triannually
Grab
H
Effluent
`" Triannuall
Grab
* 2/Week sampling frequency only during the months of June through August. During the
remainder of the year, these parameters shall be monitored monthly.
** Trianrivally sampling shall be conducted during March, July and November.
If Groundwater sampling indicates or predicts problems with compliance with of the
Groundwater Standards, this permit will be modified to include additional and/or more
restrictive limitations.
c. Reclaimed Greenspace Irrigation system:
Parameter
Monthly Avera e `
Flow
215,456 GPD
' The monthly average shall be the arithmetic mean of all samples collected during the
reporting period.
The effluent from the subject facilities shall be monitored, by the Permittee, at a point prior to
reclaimed infiltration for the following parameters:
Parameter
Saaling Point
Sampling Frequency
Type of Sample
Flow
Influent or Effluent
Continuous
Recording
If Groundwater sampling indicates or predicts problems with compliance with of the
Groundwater Standards, this permit will be modified to include additional and/or more
restrictive limitations.
Ll

5. Adequate records shall be maintained by the Permittee tracking the amount of wastewater
disposed. These records shall include, but are not necessarily limited to the following
information:
a. Date and time of disposal,
b. Volume of wastewater irrigated,'
c. Zone irrigated,
d. Length of time zone is irrigated,
e. Continuous weekly, monthly, and year-to-date hydraulic (inches/acre) loadings for each zone,
f. Weather conditions.
6. A record shall be maintained of all residuals removed from this facility. The record shall include
the name of the hauler, the permit 'authorizing the disposal or a letter from a municipality
agreeing to accept the residuals, the date the residuals were hauled, and the volume of residuals
removed.
7. A maintenance log shall be maintained at this facility including, but not limited to, the following
items:
a. Daily sampling results including dissolved' oxygen in the aeration basin and at the clarifier ,
weir;
b. Visual observations of the plant and plant site;
c. Record of preventative maintenance (changing of filters, adjusting , belt tensions, alarm
testing, diffuser inspections and cleanings, etc.);
d. Date of calibration of flow measurement device;
e. Date and results of power -interruption testing on alternate power supply; and
f. Dates beds were raked and inspected.
8. Noncompliance Notification:
The Permittee'shall report by telephone to the Washington Regional Office, telephone number
[phone], as soon as possible, but in no case more than 24 hours or on the next working
day following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence at the wastewater treatment facility which results in the treatment of
significant amounts of wastes which are abnormal in quantity or characteristic, such as the
dumping of the contents of,.a basin or tank, the known passage of a slug of hazardous
substance through the facility, or any other unusual circumstances;
b. Any process unit failure, due to known or unknown reasons, that renders the facility
incapable of adequate wastewater treatment, such as mechanical or electrical failures of
pumps, aerators, compressors, etc.;
c. Any failure of a pumping station, sewer line, or treatment facility resulting in a by-pass of all
or any portion of the influent to such station or facility; or
d. Any time that self -monitoring information indicates that the facility is not,in compliance with
its permit limitations.
Occurrences outside normal business hours may also be reported to the Division's Emergency
Response personnel at telephone number [phone], [phone], or [phone].
Persons reporting such occurrences by telephone shall also file a written report in letter form
within five (5) days following first knowledge of the occurrence. This report must outline the
actions taken or proposed to be taken to ensure that the problem does not recur.
9

IV. GROUNDWATER REQUIREMENTS
1. Well Construction / Abandonment Criteria:
a. Within sixty (60) days of permit issuance, monitoring wells CW-B and CW-E shall be
permanently abandoned. Within thirty (30) days of abandonment, a Well Abandonment
Record (GW-30 form) shall be completed for each well abandoned and mailed to the address
listed in the "Reporting / Documentation" section of the Groundwater Requirements. The
wells must be abandoned by a North Carolina Certified Well Contractor, the property owner,
or the property lessee according to General Statutes 87-98.4(b)(2). If the abandonment is not
performed by a certified well contractor, the property owner or lessee must physically
perform the actual well abandonment. activities and the wells must be abandoned according to
the North Carolina Well Construction Standards (15A NCAC 2C .0113) and local county
rules.
b. Prior to beginning waste disposal operations, CW-B-1 and CW-E-1-shall be installed to
monitor groundwater quality. The wells shall be constructed such that the water level in the
well is never above or below the screened (open) portion of the well at any time during the
year. Each monitoring well shall be constructed in accordance with this permit and approved
by the Washington Regional Office.
The wells must be constructed by either a North Carolina Certified Well Contractor, the
property owner, or the property lessee according to General Statutes 87-98.4(b)(2). If a
certified well contractor does not perform the construction, the property owner or lessee,
provided that they are a natural person, must physically perform the actual well construction
activities. All wells must be constructed according to the North Carolina Well Construction
Standards (15A NCAC 2C .0108) and any local county rules.
d. The Washington Regional Office, telephone number [phone], shall be notified at least
forty-eight (48) hours prior to the construction of any monitoring well so that an inspection
can be made of the monitoring well location. Such notification to the regional Aquifer
Protection supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00
p.m. on Monday through Friday, excluding state holidays.
e. Within thirty (30) days of completion of all well construction activities, a certification must
be received from a professional engineer or a licensed geologist certifying that the monitoring
wells are located according to this permit.
2. Sampling Criteria:
Monitorwell(s) CW-A, CW-B-1, CW-C, CW-D, CW-E-I, CW-F, CW-G shall be sampled
initially after construction and prior to waste disposal operations, and thereafter January,
April, and September for the parameters listed below. Prior to sampling the parameters, the
measurement of water levels must be taken. The depth to water in each well shall be
measured from the surveyed point on the top of the casing. The measuring points (top of well
casing) of all monitoring wells shall be surveyed relative to a common datum.
Nitrate
I Total Phosphorus
pH field
Water Level
Total Ammonia
Total Organic Carbon
Fecal Coliform
Chloride
Total Dissolved Solids
Volatile Organic
Compounds '
' Sampled in September only
10

b. For Total Organic Carbon (TOC), if concentrations greater than 10 mg/1 are detected in any
downgradient monitoring well, additional sampling and analysis must be conducted to
identify the individual constituents comprising this TOC concentration. If the TOC
concentration as measured in the background monitor well exceeds 10 mg/1, this
concentration will be taken to represent the naturally occurring TOC concentration. Any
exceedances of this naturally occurring TOC concentration in the down -gradient wells shall
be subject to the additional sampling and analysis as described above.
c. For Volatile Organic Compounds (VOCs) sampled in September, use only one of the
following methods:
1) Standard Method 6230D, Practical Quantitation Limit (PQL) at 0.5 µg/L or less
2) Standard Method 6210, PQL at 0.5 µg/L or less
3) EPA Method 8021, Low Concentration, PQL at 0.5 µg/L or less
4) EPA Method 8260, Low Concentration, PQL at 0.5 µg/L or less
5) Another method with prior approval by the Division.
Any of the referenced methods used for VOCs must at a minimum, include all the
constituents listed in Table VIII of Standard Method 6230D. Any method used must provide
a PQL of 0.5 µg/L or less, which must be supported by laboratory proficiency studies as
required by the DWQ Laboratory Certification Unit. Any constituents detected above the
Method Detection Limit (MDL) but below the PQL of 0.5 µg/L must be qualified (estimated)
and reported.
d. Any laboratory selected to analyze parameters must be Division of Water Quality (DWQ)
certified for those parameters required.
3. Reporting / Documentation:
a. All reports and documentation (GW-1, GW-30, GW-59) shall be mailed to the following
address:
Information Processing Center
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
b. For the initial sampling of the well(s), the permittee shall submit a copy of the GW-1 Form
(Well Construction Record) with the Compliance Monitoring Form (GW-59) for each well to
the address listed in the "Reporting / Documentation" section of the Groundwater
Requirements. Initial Compliance Monitoring Forms that do not include copies of the GW-1
form may be returned to the permittee without being processed. Failure to submit these
forms as required by this permit may result in the initiation of enforcement activities pursuant
to NC General Statutes 143-215.6A.
The results of the sampling and analysis must be received on Form GW-59 (Groundwater
Quality Monitoring: Compliance Report Form) by the Division (address listed in the
"Reporting / Documentation" section of the Groundwater Requirements), on or before the last
working day of the month following the sampling month. The data of all groundwater
sampling analyses required by the permit conditions must be reported using the most recent
GW-59 form along with attached copies of the laboratory analyses.
11

d. Within sixty (60) days of completion of monitoring wells CW-B-1 and CW-E-1, the
permittee shall submit two original copies of a scaled site map (scale no greater than
1 "=100'); however, special provisions may be granted upon prior approval for large
properties. The map(s) must include the following information:
1) The location and identity of each monitoring well.
2) The location of major components of the waste disposal system.
3) The location of property boundaries within 500 feet of the disposal area(s).
4) The latitude and longitude of the established horizontal control monument.
5) The elevation of the top of the well casing (which shall be known as the "measuring
point") relative to a common datum.
6) The depth of water below the measuring point at the time the measuring point is
established.
7) The location of Review and Compliance boundaries.
8) The date the map is prepared and/or revised.
Control monuments shall be installed in such a manner and made of such materials that the
monument will not be destroyed due to activities that may take place on the property. Maps
and any supporting documentation shall be sent to the Division as addressed in the
"Reporting / Documentation" above.
The permittee is responsible for the geographic accuracy of any map submitted, however
produced
4. Vertical Separation Requirements:
Waste shall not be applied or discharged onto or below the land surface when the vertical
separation between the waste and the seasonal high water table is less than one (1) foot.
5. Applicable Boundaries:
a. The COMPLIANCE BOUNDARY for the disposal system is specified by regulations in 15A
NCAC 2L, Groundwater Classifications and Standards. The Compliance Boundary for the
disposal system individually permitted on or after December 30, 1983 is established at either
250 feet from the waste disposal area, or 50 feet within the property boundary, whichever is
closest to the waste disposal area. An exceedance of Groundwater Quality Standards at or
beyond the Compliance Boundary is subject to remediation action according to 15A NCAC
2L .0106(d)(2).
b. The REVIEW BOUNDARY is established around the disposal systems midway between the
Compliance Boundary and the perimeter of the waste disposal area. Any exceedance of
standards at the Review Boundary shall require action in accordance with 15A NCAC 2L
.0106(d)(1).
V. INSPECTIONS
1. Adequate inspection, maintenance, and cleaning shall be provided by the Permittee to insure
proper operation of the subject facilities.
12

2. The Penr ittee or his designee shall inspect the wastewater treatment and disposal facilities to
prevent malfunctions and deterioration, operator errors and discharges which may cause,or lead to
the release of wastes to the environment, a threat to human health, or a nuisance. The Permittee
shall maintain an inspection log or summary including at least the date and time of inspection,
observations made, and any maintenance, repairs, or corrective actions taken by the Permittee.
This log of inspections shall be maintained by the Permittee for a period of three years from the
date of the inspection and shall be made available to the Division or other permitting authority,
upon request.
3. Any duly authorized officer, employee, or representative of the Division may, upon presentation
of credentials, enter and inspect any property, premises or place on or related to the disposal site
or facility at any reasonable time for the purpose of determining.compliance with this permit, may
inspect or copy any records that must be maintained under the terms and conditions of this
permit, and may obtain samples of groundwater, surface water, or leachate.
VI. GENERAL CONDITIONS
1. This permit shall become voidable unless the facilities are constructed -in accordance with th'e
conditions of this permit, the approved plans and specifications, and other supporting data.
2. . This permit is effective only with respect to the nature and volume of wastes described in the
application and other supporting data.
3. This permit is not transferable. In the event there is a desire for the facilities to change
ownership, or there is a name change of the Permittee, a formal permit request must be submitted
to the Division accompanied by an application fee, documentation from the parties involved, and
other supporting materials as may be appropriate. The approval of this request will be considered
on its merits and may or may not be approved.
4. The subject wastewater treatment and disposal facilities shall be connected to an, operational
publicly owned wastewater collection system within 180 days of its availability to the subject
facilities, if the subject wastewater treatment or disposal facilities are in noncompliance with the
terms and conditions of this non -discharge permit or the governing statutes or regulations. Prior
to the initiation of these connection activities, appropriate approval must be received from this
Division.
5. The annual administering and compliance fee must be paid by the Permittee within thirty (30)
days after being billed by the Division. Failure to pay the fee accordingly may cause the Division
to initiate action to revoke this permit as specified by 15A NCAC 2H .0205 (c)(4).
6. Failure to abide by the conditions and. limitations contained in this permit may subject the
Permittee to an enforcement action by the Division in accordance with North Carolina General
Statute 143-215.6A to 143-215.6C.
7: The issuance of this permit does not exempt the Permittee from complying with any and all
statutes, rules, regulations, or ordinances which may be imposed by other government agencies
(local, state, and federal) which have jurisdiction, including but not limited to applicable river
buffer rules in 15A NCAC 2B.0200, erosion and sedimentation control requirements in 15A
NCAC Chapter 4 and under the Division's General Permit NCGO10000, and any requirements
pertaining to wetlands under 15A NCAC 2B .0200 and 2H .0500.
8. A set of approved plans and specifications for the subject project must be retained by .the
Permittee for the life of this project.
13

9. The Permittee, at least six (6) months prior .to the expiration of this permit, shall request its
extension. Upon receipt of the request, the Commission will review the adequacy of the facilities
described therein, and if warranted, will extend the permit for such period of time and under such
conditions and limitations as it may deem appropriate.,
Permit issued this the 16th day of June, 2006
NORTH C OLINA ONMENTAL MANAGEMENT COMMISSION
.,jo�—Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0002829
14

• Permit No. WQ0002829
June 16, 2006
ENGINEER'S CERTIFICATION
Partial Final
L , as a duly registered Professional Engineer in the State
of North Carolina, having been authorized to observe (periodically, weekly, full time) the construction of
the project,
Project Name
Location and County
for the Permittee hereby state that, to the best of my abilities, due care and diligence was used in the
observation of the construction such that the construction was observed to be built within substantial
compliance and intent of this permit, the approved plans and specifications, and other supporting
materials.
Signature
Date
Registration No.
15

1 Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
1.0 Introduction
KDHWWTP is located in the Town of Kill Devil Hills, North Carolina (see Figure 1). As seen in
Plate A, an existing wastewater treatment plant occupies a small area near the southeast corner of a
development site. In April 2004, S&ME completed a hydrogeologic study for the subject
property. The study included groundwater modeling used to predict "groundwater mounding"
and the distribution of nitrate concentrations within the site's groundwater as a result of applying
effluent water from the wastewater treatment plant via high rate infiltration beds and low rate
infiltration basins (i.e. ponds). The results of the hydrogeologic study were presented to
KDHWWTP, LLC (e.g. owners of the wastewater treatment plant) in a report entitled
"Hydrogeologic Report, Proposed High Rate Disposal Site, Sunset Bay Project" dated April 14,
2004.
The North Carolina Department of Environment and Natural Resources — Division of
Environmental Management (NCDENR-DEM) issued Permit No. WQ0002829 dated June 21,
2004, that allows treated wastewater to be disposed of using high rate infiltration beds and low rate
infiltration ponds. Several active infiltration beds and infiltration ponds are currently used to
dispose of treated wastewater generated by the treatment plant. The locations of the permitted
infiltration beds (1 through 8) and the infiltration basins (Ponds 1 and 2) are indicated on Plate A.
It is S&ME's understanding that the KDHWWTP, LLC would like to modify the treated
wastewater disposal options by (1) eliminating infiltration beds 2 and 8 and (2) applying reclaimed
water to green areas identified within the development. KDH AVTP, LLC desires to keep the
disposal capacity at 500,000 gallons per day as currently permitted
The conceptual plan is for the treated wastewater to be routed to infiltration beds and infiltration
ponds. Some of the water will be removed from the infiltration ponds and be irrigated to green
areas on the subject site. As part of the Hydrogeologic Report, KDHVWVTP, LLC requested site
1

l
i
Hydrogeologic R rt S&ME Project No. 1584-03-100A !�
KDHWWTP, Kill Devil Hills, NC October 19, 2005
specific groundwater modeling to evaluate groundwater mounding and the fate and transport of
nitrates discharged to the site. Preliminary locations of proposed structures, paved areas, green
areas, and infiltration ponds were depicted on an untitled "Preliminary Site Plan" provided to
S&ME by Mr. Mike Robinson.
_I 1.1 Project Authorization
S&ME, Inc. has completed an updated hydrogeologic study for the wastewater disposal
modifications proposed by KDHWW IP, LLC. S&ME developed this Hydrogeologic Report
using and relying upon information included in the following reports generated by S&ME for the
L _l subject site:
• Hydrogeologic Report, Proposed High Rate Disposal Site, April 14, 2004
• Additional Information Request Response, May 19, 2004
i_J
Our scope of services was performed in accordance with the criteria outlined in 15A NCAC 2H
.0205(d)(5)(E&F) and in accordance with the scope of work outlined in S&ME's Proposal
No. 15 84-04-P 195 dated December 22, 2004.
1.2 Purpose and Scope
The purpose of this evaluation was to examine the potential elimination of infiltration beds 2 and 8
along with the addition of green space irrigation. This evaluation relied upon the results of prior
Hydrogeologic Report investigations referenced in Section 1.1 and additional groundwater
elevation data collected during 2005. The following is a summary of the scope of work completed
at the site:
J Installed twenty-three (23) shallow piezometers at the site.
ij

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
• Measured and recorded the depth to water in the shallow piezometers and existing compliance
monitoring wells CW-A, CW-B, CW-D, CW-E, CW-F, and CW-G.
Developed an updated groundwater flow map.
Compared the updated groundwater flow map to a predictive groundwater flow map generated
using the calibrated groundwater model from the April 2004 Hydrogeologic Report.
Performed predictive groundwater modeling to evaluate the groundwater mounding potential
from the proposed disposal modifications.
l�
Performed predictive groundwater modeling to evaluate the fate and transport of nitrate as a
result of the proposed disposal modifications.
Summarized the collected information into a Hydrogeologic Report.
1.3 Limitations and Sole Use Statement
1.3.1 Limitations
The findings of this report are applicable and representative of conditions encountered at the subject
site on the dates of this evaluation at the locations evaluated. The groundwater modeling portion of
this scope of work relied upon site layout information and wastewater system design data provided
to S&ME by Mr. Robinson.
1.3.2 Sole Use Statement
All materials and information used for this project were obtained by S&ME. The resulting report is
provided for the sole use of Mike Robinson and KDHWWTP, LLC, for which it was prepared.
Use of this report by any third parties will be at such party's sole risk, and S&ME disclaims liability
LJ for any use or reliance by third parties.
3

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
2.0 Model Verification
- 2.1 Calibrated Groundwater Model
In the Hydrogeologic Report dated April 14, 2004, S&ME developed a calibrated, steady state
groundwater model of the subject site. The calibrated model was generated to perform predictive
modeling to evaluate the water table response from the application of treated wastewater from
the Kill Devil Hills wastewater treatment plant.
A steady state single layer model was constructed using Visual MODFLOW version 3.1
software. Using a single layer model, the aquifer system was simulated as one unconfined
aquifer. Figure 2 indicates the grid space in relation to the site map.
The grid space has general head boundaries to the north, south, and east and a constant head
boundary to the west. Figure 3 indicates the location and types of boundaries that were
7-47m,"I K -�l
l The steady state model was calibrated by comparing the simulated groundwater elevation heads
to the observed groundwater heads collected in November 2003. Several assumed parameter
values were used in the calibrated model. Several unknown parameter values were varied to
calibrate the model. The input parameter values for the calibrated model are summarized in
Table 1.
Additional information regarding the calibrated model including aquifer testing, input
parameters, residual analysis, and sensitivity analysis can be found in the Hydrogeologic Report
dated April 14, 2004.
4

j Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
2.2 Model Verification
On February 21 and 22, 2005, twenty-three (23) shallow piezometers (T-1 through T-23) were
installed at the subject site. On February 23, 2005, S&ME measured and recorded the depth to
groundwater in the shallow piezometers and compliance monitoring wells CW-A through CW-G.
j The depth to groundwater data is summarized in Table 2. The locations of the piezometers and
compliance monitoring wells are displayed in Figure 4. A groundwater flow map (see Figure 4)
was developed using the depth to groundwater data collected in February 2005.
Enviro-Tech, the operators of the wastewater treatment plant, provided S&ME with the plant's
operational data for November 2004, December 2004, and January 2005. The operational data is
i included in Appendix I. Enviro-Tech indicated to S&ME that during December 2004 and
.J
January 2005, that 61.3%, 19.5%, and 19.5% of the wastewater flowrate is routed to infiltration
beds 3, 5, and 6. During this period, no water was applied to the remaining infiltration beds or
the infiltration ponds.
Using the information provided by Enviro-Tech, S&ME generated a predictive, steady state
groundwater model to evaluate the water table response from the implied stresses. The input
parameters for the predictive model are summarized in Table 3. Sample calculations for the
infiltration application rates are provided in Appendix H.
Plate B displays the observed groundwater elevations versus the predicted groundwater
elevations using the December 2004 and January 2005 operational data. Observations indicate
that the predictive, steady state model over -estimated the height at which groundwater would
mound at the site. This suggests that the calibrated model yields conservative, predictive models.
t`
0

i Hydrogeologic Report S&ME Project No. 1594-03-100A
KDHVWW'IT, Kill Devil Hills, NC October 19, 2005
The measured and predictive groundwater elevations were compared assuming that the measured
groundwater data was collected during steady state conditions achieved during the December
f 2004 and January 2005 hydraulic stresses. The groundwater data may have been collected during
unsteady conditions and may explain the differences between the measured and predicted
�i
} groundwater elevations.
M

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
3.0 Predictive Simulations
3.1 Model Setup
The permit modification will propose that, during normal operation, effluent water be discharged to
six infiltration beds, two infiltration ponds, and as spray irrigation onto the site's landscaping. It is
our understanding that only tertiary treated wastewater meeting the NCDENR `reclaimed"
+ , wastewater standards will be discharged to the infiltration ponds and used for irrigation of the site's
landscaping. The six high rate infiltration beds will receive `reclaimed" wastewater also.
However, when the wastewater plant is not able to meet the "reclaimed" water standards, the
wastewater will be discharged only to the high rate infiltration beds (e.g. see 5-day upset scenario).
3.1.1 Grid Space
The grid space of the model was refined to allow for a more precise selection of the green space
areas to receive irrigation water. Figure 5 indicates the refined grid spare in relation to the site
3.1.2 Green Area
f�
Figure 6 displays the green area selected to be irrigated during normal operation of the disposal
system. The spray irrigation operations were buffered 25 feet from the surface water basins
located near the property boundaries of the subject site as well as the pond located on the western
portion of the property. Buzzard Bay, the body of water located along the western boundary of
the site, is classified as SC. The spray irrigation operations are buffered 25 feet from Buzzard
Bay. In addition, S&ME assumed that no spray irrigation would occur on the dunes located near
the eastern portion of the property.
7

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDH AM, Kill Devil Hills, NC October 19, 2005
3.1.3 Infiltration Ponds
The two infiltration ponds (Ponds 1 and 2) are connected by a culvert and considered one
infiltration pond for modeling purposes. As with the current permit, Pond 3 is not considered for
use as a disposal feature.
3.2 Flow Simulation
3.2.1 Normal Operation
"Normal operation" of the disposal system will include application of the "reclaimed"
wastewater to six infiltration beds, one infiltration pond, and as spray irrigation onto the site's
green areas. Using the calibrated model, S&ME performed steady state model simulations to
evaluate the volume of effluent water that could be applied to the subject site using the
infiltration beds, infiltration pond, and green areas. The volume of effluent water than can be
applied is partially controlled by the magnitude of "groundwater mounding" that occurs. This
determination was made by comparing the groundwater elevation heads of the predictive model
to the proposed grade elevation of the subject site.
In accordance with 15A NCAC 2H .0219(e), the separation between the waste and the season high
water table must be greater than 1-foot. It is S&ME's understanding that rapid infiltration systems
are excluded from meeting this minimum design requirement outlined in 15A NCAC 2H .0219(e).
This exclusion is reported based on the fact that most rapid infiltration systems are considered
disposal only systems.
Table 4 summarizes the final input parameters for the simulation of the disposal of wastewater
effluent during "normal operation". A summary of the disposal volumes for the "normal
operation" simulation is included in Table 5. Plate C displays the predicted groundwater
.I

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
elevation contour map using the Table 4 values and the proposed grade elevation of the subject
site. The model predicted conditions shown in Plate C suggests that the water table should be
below the ground surface of the subject site.
The predictive groundwater modeling for the "normal operation" scenario suggests that the water
table elevation is predicted to be at or above the bottom elevation of the drainage feature south of
the infiltration pond. According to Mr. Robinson, this drainage feature provides storage of
surface water and does not route water to the Buzzard Bay.
The predictive model groundwater modeling also suggests that there is not at least 1 foot of
separation between the waste and the water table in the area north of the wastewater treatment
plant. This finding was also identified in the Hydrogeologic Report dated April 14, 2004. As
stated in the April 2004 report, it is S&ME's understanding that KDHWWTP, LLC plans to grade
the area north of the wastewater treatment plant to reduce this potential concern. However, given
the minimal separation thickness predicted near the wastewater treatment plant, a potential exists
for isolated groundwater discharges at the ground surface, if actual conditions exceed the model
predicted conditions.
3.2.2 5-Day Upset
The "5-Day Upset" simulation was evaluated to predict the groundwater conditions in a situation
in which, for a five day period, all wastewater (e.g. wastewater not meeting NCDENR
"reclaimed" wastewater standards) is diverted to the infiltration beds and no water is placed into
infiltration ponds or applied to the green areas. To predict the worst case for this scenario, the
"5-Day Upset" parameters were applied after the "normal operation" model has reach steady
state conditions. Transient modeling conducted on the "normal operation" simulation suggests
that steady state conditions occur before day 150.
N

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
For the "5-Day Upset" simulation, a transient model was evaluated using the "normal operation"
inputs from day 0 to 150. From day 150 to 155 of the transient model, all wastewater flow is
diverted to the infiltration beds. The model inputs for the "5-Day Upset" simulation are
summarized in Table 6. A summary of the disposal volumes during "5-Day Upset" conditions is
included in Table 7. Plate D displays the predicted groundwater elevation contour map using
the Table 6 values and the proposed grade elevation of the subject site.
The model predicted conditions shown in Plate D suggests that the water table on day 5 of a 5-
Day Upset condition should be separated from the waste by at least 1 foot in all areas except the
area north of the wastewater treatment plant. As previously stated, it is S&ME's understanding
that KDHWWTP, LLC plans to grade the area north of the wastewater treatment plant to reduce
this potential concern.
3.3 Nitrate Fate and Transport Simulation
Fate and transport simulations were performed using the MT3D module of MODFLOW to
predict the distribution and subsequent migration of nitrate in the site's groundwater. The
transport model was simulated assuming that no retardation or degradation of the nitrate is
� I -11 4
Enviro-Tech provided S&ME with effluent data from the treatment plant from December 2004 to
August 2005. The data sheets are included in Appendix III. The data indicates an average total
nitrate concentration of 1.43 milligrams per liter (mg/L). The ammonia nitrate concentrations are
typically less than 0.1 mg/L with some detections of 0.3 mg/L and 0.7 mg/L.
For modeling purposes, S&ME used a nitrate concentration of 5 mg/L. Background nitrate data
obtained during to the April 2004 hydrogeologic study indicated nitrate concentrations ranging
from less than the quantitation limit (0.05 mg/L) to 2 mg/L. Steady state and transient
10

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
simulations were performed using the input parameters 3b=arized in Table 8. The simulated
transport models are displayed in Plates E and F.
It is S&ME's understanding that the disposal system at the subject site is considered "hybrid"
since the system disposes of `reclaimed" and non -"reclaimed" wastewater utilizing multiple
disposal features. For this reason, the compliance boundary for the "reclaimed" portion (i.e.
green area irrigation) of the disposal system will be the property boundary. For the non -
"reclaimed" portion (i.e. infiltration beds), the compliance boundaries will be 250 feet from the
edge of the infiltration bed or the property boundary, whichever is nearest.
The simulations suggest that the nitrate concentration will not exceed the NCAC 2L groundwater
quality standard of 10 mg/L at the compliance boundaries for the `reclaimed" features and "5-day
upset" features. The compliance boundaries are included on Plates E and F.
3.4 Model Assumptions/Limitations
Computer aided models such as MODFLOW, when applied properly, can be good tools for
predicting potential impacts to the site and identifying unforeseen site limitations. However, the
resultant data should be viewed as predictions and not facts. Contour lines for predicted
groundwater elevations or nitrate concentrations should be viewed as reasonably foreseen and
anticipated conditions and not actual.
The predictive models performed for this hydrogeologic study were evaluated using the
calibrated model of the site generated during the April 2004 hydrogeologic study. The calibrated
model of the site was generated with the model assumptions/limitations presented in the
Hydrogeologic Report, Proposed High Rate Disposal Site dated April 14, 2004.
11

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP Kill Devil Hills NC October 19, 2005
4.0 Potential Impacts of the Disposal System
The proposed irrigation activities could potentially affect the underlying groundwater or surface
waters in the following ways. However, proper final design and operation of the disposal system
reduce any of the potential affects listed below.
4.1 Surface Runoff
The maximum instantaneous hydraulic loading rates recommended in S&ME's Soil
Scientist/Agronomist report should not be exceeded. Exceeding these loading rates can cause
surface runoff that can impact site surface waters.
4.2 Drainage Features
The predictive groundwater modeling for the "normal operation" and "5-Day Upset" scenarios
suggest that the water table elevation is predicted to be at or above the bottom elevation of the
drainage feature south of the infiltration pond. According to Mr. Robinson, this drainage feature
provides storage of surface water and does not discharge to Buzzard Bay. The predictive
modeling suggests that groundwater containing nitrates may disperse into the water stored in the
drainage feature. According to the predictive simulations, the nitrate concentrations near the
drainage features should be less than 4.75 mg/L.
12

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDH) VWTP. Kill Devil Hills, NC October 19, 2005
5.0 Compliance Monitoring Wells
According to 15A NCAC 2H the compliance boundary and review boundary for groundwater shall
be the property boundary for reclaimed water systems. Therefore, the property boundary will serve
as the compliance boundary for the spray irrigation (i.e. green area) portion of the disposal system.
For the "upset" disposal features (i.e. infiltration beds) the compliance boundary will be 250 feet
from the edge of the infiltration bed or the property boundary, whichever is nearest. The
compliance boundaries are indicated on Plate G.
S&ME proposes that monitoring well CW-B be abandoned and reinstalled near the review
boundary for infiltration bed 1. The proposed location is indicated on Plate G.
S&ME proposes that monitoring well CW-H be installed to provide monitoring at the eastern
compliance boundary for the spray irrigation disposal feature. The proposed location for
monitoring well CW-H is indicated on Plate G.
S&ME believes that existing compliance monitoring wells CW-A, CW-C through CW-G will be
adequate to monitor the remaining compliance boundaries for resuse and non -"reclaimed"
features.
13

Hydrogeologic Report S&ME Project No. 1584-03-100A
KDHWWTP, Kill Devil Hills, NC October 19, 2005
6.0 References
Fetter, C.W.
Applied Hydrogeology
Columbus: Merrill
1988, Second Edition
pp.196-199
Heath, C. Ralph, March 1994.
Ground -Water Recharge in North Carolina
Waterloo Hydrogeologic
Visual MODFLOW User's Manual
S&ME, Inc.
Hydrogeologic Report, Proposed High Rate Disposal Site
April 14, 2004
S&ME, Inc.
Additional Information Request Response
May 19, 2004
14

Table 1
Calibrated Model Input Parameters
Sunset Bay Project
Dare County, North Carolina
S&ME Project No. 1584-03-100A
Parameter
Variable
Value
Units
Northern Boundary
istance from the western head boundary to the grid
D,
450
feet
Distance from the eastern head boundary to the grid
D2
550
feet
Western boundary head elevation
h,
2.5
feet
Eastern boundary head elevation
h2
11
feet
Hydraulic Conductivity
k
46.37
feet/day
Southern Boundary
istance from the western head boundary to the grid
D,
450
feet
Distance from the eastern head boundary to the grid
D2
350
feet
Western boundary head elevation
h,
6.9
feet
Eastern boundary head elevation
h2
9.2
feet
Hydraulic Conductivity
k
46.37
feet/day
Eastern Bound
Distance from the head boundary to the grid
D
200
feet
Boundary head elevation
h
13.5
feet
Hydraulic Conductivity
k
46.37
feet/day
Hydraulic Conductivity
Horizontal
kX
46.37
feet/day
Horizontal
k
46.37
feet/day
Vertical
kz
19.29
feet/day
Recharge
Net Recharge Rate
R
13
inches/year
Existing High Rate Infiltration Sites I
I
4,710
inches/ ear

1
Table 2
Groundwater Elevation Data
Sunset Bay Project
Dare County, North Carolina
S&ME Project No. 1584-03-100A
WelUPiezomete
r ID
Top of Casing
Elevation
A.R%,170LLJL LUGroundwater
Groundwate
Elevation
T-1
14.62
5.66
8.96
T-2
15.10
6.83
8.27
T-3
17.79
10.38
7.41
T-4
15.12
6.73
8.39
T-5
12.65
5.14
7.51
T-6
9.28
2.97
6.31
T-7
12.26
7.10
5.16
T-8
10.93
6.73
4.2
T-9
10.41
7.34
3.07
T-10
ND
7.45
-
T-11
13.29
7.09
6.2
T-12
14.87
8.58
6.29
T-13
10.88
7.42
3.46
T-14
11.02
7.86
3.16
T-15
15.56
6.52
9.04
T-16
14.94
6.30
8.64
T-17
24.78
16.60
8.18
T-18
18.38
6.62
11.76
T-19
14.39
8.02
6.37
T-20
14.70
7.22
7.48
T-21
14.59
6.63
7.96
T-22
34.98
dry
-
T-23
19.01
8.84
10.17
CW-A
14.35
4.72
9.63
CW-B
16.78
7.70
9.08
CW-C
19.07
10.95
8.12
CW-D
23.42
15.24
8.18
CW-E
12.00
6.75
5.25
CW-F
11.51
5.33 1
6.18
CW-G
10.17
4.34 15.83
Notes: Data is in feet.
Measurements taken on February 23, 2005
Data obtained from Bissell.

Table 3
December 2004 and January 2005 Operation
Sunset Bay Project
Dare County, North Carolina
S&ME Project No. 1584-03-100A
Parameter
Variable
Value
Units
Northern Boundary
Distance from the western head boundary to the grid
D,
450
feet
Distance from the eastern head boundary to the grid
D2
550
feet
Western boundary head elevation
hi
2.5
feet
Eastern boundary head elevation
h2
11
feet
Hydraulic Conductivity
k
46.37
feet/day
Southern Boundary
Distance from the western head boundary to the grid
D,
450
feet
Distance from the eastern head boundary to the grid
D2
350
Western boundary head elevation
hi
6.9
feet
Eastern boundary head elevation
h2
9.2
feet
Hydraulic Conductivity
k
46.37
feet/day
Eastern Boundary
Distance from the head boundary to the grid
D
200
feet
Boundary head elevation
h
13.5
feet
Hydraulic Conductivity
k
46.37
feet/day
Hydraulic Conductivity
Horizontal
kX
46.37
feet/day
Horizontal
k
46.37
feet/day
Vertical
kZ
11.65
feet/day
Rechar e
Net Recharge Rate
R
13
inches/year
Infiltration Bed #1
1
13
inches/year
High Rate Infiltration Bed #2
I
13
inches/year
High Rate Infiltration Bed #3
I
3,029
inches/year
High Rate Infiltration Bed #4
1
13
inches/year
High Rate Infiltration Bed #5
I
3,029
inches/year
High Rate Infiltration Bed #6
I
2,998
inches/year
High Rate Infiltration Bed #7
I
13
inches/year
High Rate Infiltration Bed #8
I
13 1
inches/year
Infiltration Pond Ponds 1 and 2
I 1
0 1
inches/year

Table 4
Input Parameters for "Normal Operation" Predictive Model
Sunset Bay Project
Dare County, North Carolina
S&ME Project No. 1584-03-100A
Parameter
Variable
Value
Units
Northern Boundary
Distance from the western head boundary to the grid
Di
450
feet
Distance from the eastern head boundary to the grid
D2
550
feet
Western boundary hears elevation
hi
2.5
feet
Eastern boundary head elevation
h2
11
feet
Hydraulic Conducj!IL
k
46.37
feet/day
Southern Boundary
Distance from the western head boundary to the grid
D,
450
feet
Distance from the eastern head boundary to the grid
D2
350
Western boundary head elevation
hi
6.9
feet
Eastern boundary head elevation
h2
9.2
feet
Hydraulic Conductivity
k
46.37
feet/day
Eastern Boundary
Distance from the head boundary to the grid
D
200
feet
Boundary head elevation
h
13.5
feet
Hydraulic Conductivily
k
46.37
feet/day
Hydraulic Conductivity
Horizontal
k,,
46.37
feet/day
Horizontal
ky
46.37
feet/day
Vertical
kZ
11.65
feet/day
Recharge
Net Recharge Rate
R
13
inches/year
High Rate Infiltration Bed #1
I
1,500
inches/year
High Rate Infiltration Bed #2
Not Used
High Rate Infiltration Bed #3
I
4,637
inches/year
High Rate Infiltration Bed #4
1
4,637
inches/year
High Rate Infiltration Bed #5
1
4,637
inches/year
High Rate Infiltration Bed #6
1
4,637
inches/ ear
High Rate Infiltration Bed #7
I
1,500
inches/year
High Rate Infiltration Bed #8
Not Used
Infiltration Pond(Ponds 1 and 2
I
1,000
inches/year
Green Areas
1
52
inches/ ear

I
Table 5
"Normal Operation" Disposal Volumes
Sunset Bay Project
Dare County, North Carolina
S&ME Project No. 1584-03-100A
Disposal Areas
Recharge Rate
(in/year)
2
Area (ft)
Loading Rate
z
( d/ft)
Volume
(gpd)
Infiltration Bed
1
1,500
23,915
2.56
61,261
3
4,637
2,827
7.92
22,390
4
4,637
5,027
7.92
39,805
5
4,637
2,827
7.92
22,390
6
4,637
8,979
7.92
71,100
7
1,500
14,979
2.56
38,370
Infiltration Pond
1,000
91,465
1.71
156,201
Green Areas
52
996,508
0.09
88,494
Totals
1
500,011
Notes: in/year = inches per year
gpd/ftz = gallons per day per square foot
gpd = gallons per day

---k _
Table 6
Input Parameters for the "5-Day Upset" Predictive Model
Sunset Bay Project
Dare County, North Carolina
S&ME Project No. 1584-03-100A
Parameter
Time
0 to 150 days
150 to 155 days
Variable
Value
Units
Variable
Value
Units
Northern Boundary
Distance from the western head boundary to the grid
D1
450
feet
Di
450
feet
Distance from the eastern head boundary to the grid
DZ
550
feet
DZ
550
Western boundary head elevation
hi
2.5
feet
h,
2.5
feet
Eastern boundary head elevation
h2
11
feet
h2
11
feet
Hydraulic Conductivity
k
46.37
feet/day
k
46.37
feet/da
Southern Boundaryy
Distance from the western head boundary to the grid
D,
450
feet
D,
450
feet
Distance from the eastern head boundary to the grid
DZ
350
feet
DZ
350
feet
Western boundary head elevation
h,
6.9
feet
h,
6.9
feet
Eastern boundary head elevation
hz
9.2
feet
h2
9.2
feet
Hydraulic Conductivi
k
46.37
feet/day
k
46.37
feet/da
Eastern Boundaryy
Distance from the head boundary to the grid
D
200
feet
D
200
feet
Boundary head elevation
h
13.5
feet
h
13.5
feet
Hydraulic Conductivity
k
46.37
feet/day
k
46.37
feet/da
Hydraulic Conductivityy
Horizontal
kx
46.37
feet/day
kx
46.37
feet/day
Horizontal
ky
46.37
feet/day
k
46.37
feet/day
Vertical
kZ
11.65
feet/day
kZ
11.65
feet/day
Rech e
Net Recharge Rate
R
13
inches/year
R
13
inches/year
High Rate Infiltration Bed #1
I
1,500
inches/year
1
2,000
inches/year
High Rate Infiltration Bed #2
Not Used
High Rate Infiltration Bed #3
I
4,637
inches/year
I
13,825
'inches/year
High Rate Infiltration Bed #4
1
4 637
inches/year
I
13 825
inches/year
High Rate Infiltration Bed #5
I
4,637
inches/year
I
13,825
inches/year
High Rate Infiltration Bed #6
I
4 637
inches/year
I
7,500
inches/year
High Rate Infiltration Bed #7
I
1,500
inches/ -ear
I
2,000
inches/year
High Rate Infiltration Bed #8
Not Used
Infiltration Pond(Ponds 1 and 2
1
1,000
inches/year
I
0
inches/ ear
Green Areas
1
52
inches/year
I
13
1 inches/year

Table 7
"5-Day Upset" Disposal Volumes
Sunset Bay Project.
Dare County, North Carolina
S&ME Project No. 1584-03-100A
Disposal Areas
Recharge Rate
(in/year)
2
Area (ft)
Loading Rate
( d/ft2)
Volume
(gpd)
Infiltration Bed
1
2,000
23,915
3.42
81,681
3
13,825
2,827
23.61
66,755
4
13,825
5,027
23.91
118,676
5
13,825
2,827
23.61
66,755
6
7,500
8,979
12.81
114,999
7
2,000
14,979
3.42
51,160
Infiltration Pond
0
91,465
0.00
0
Green Areas
0
996,508
0.00
0
Totals
500,026
Notes: in/year = inches per year
gpd/ft2 = gallons per day per square foot
gpd = gallons per day

Table 8
Summary of Fate and Transport Predictive Models
Sunset Bay Project
Dare County, North Carolina
S&ME Project No. 1584-03-100A
Parameter
Variable
Units
Plate E
Plate F
Model Type
Steady State
Transient
Operation Scenario
Normal
5-Day Upset
Northern Boundary
Distance from the western head boundary to the grid
Dr
feet
450
450
Distance from the eastern head boundary to the grid
D2
feet
550
550
Western boundary head elevation
hi
feet
2.5
2.5
Eastern boundary head elevation
h2
feet
11
11
Hydraulic Conductivity
k
feet/day
46.37
46.37
Southern Boundary
Distance from the western head boundary to the grid
D,
feet
450
450
Distance from the eastern head boundary to the grid
D2
feet
350
350
Western boundary head elevation
hr
feet
6.9
6.9
Eastern boundary head elevation
h2
feet
9.2
9.2
Hydraulic Conductivi
k
feet/day
46.37
46.37
Eastern Boun
Distance from the eastern head boundary to the grid
D
feet
200
200
Boundary head elevation
h
feet
13.5
13.5
Hydraulic Conductivi
k
feet/day
46.37
46.37
Hydraulic Conductivity
Horizontal
k.
feet/day
46.37
46.37
Horizontal
k,
feet/day
46.37
46.37
Vertical
k�
feet/day
11.65
11.65
Recharge
Net Recharge Rate
R
inches/year
13
13
High Rate Infiltration Bed #1
I
inches/year
1,500
2,000
High Rate Infiltration Bed #2
Not Used
High Rate Infiltration Bed #3
I
inches/year
4 637
13 825
High Rate Infiltration Bed #4
I
inches/year
4,637
13,825
High Rate Infiltration Bed #5
I
inches/year
4,637
13,825
High Rate Infiltration Bed #6
I
inches/year
4 637
7,500
High Rate Infiltration Bed #7
I
inches/year
1 500
2000
High Rate Infiltration Bed #8
Not Used
Infiltration Pond Ponds 1 and 2
I
inches/year
1,000
0
Green Areas
I
incbes/year
52
13
Effluent Nitrate Concentration
-
milligrams per liter
5
5
Initial Nitrate Concentration
-
milligrams per liter
2
2

PERMIT NUMBER:
FACILITY NAME:
W 00002829
KII Devil Hills WWTP
MONTH: May YEAR: 2005
COUNTY: Dare
Flow Monitoring Point: Effluent: X Influent: .......................................
Parameter Monitoring Point: Effluent: X Influent: Surface Water (SW):
SW Codta/Name:
Was There Effluent Flow For This Month Generated At This Facility: ES Yes: No: X
D
A
T
E
operator
Arrival
Time 2400
Clock
opwatnr
Th. onsit.
ORC on
Site?
50050
10
00400
50060
00310
00610
00530
31616
940
515
660
620
Daily Rate
(Flow) Into
Treatment
System
Temp.
Ceidus
pH
Residual
Chlorine
BOD-5
20'C
N43-N
TSS
F-al
pollfwrn
(o. blc
N.m')
Chloride
TDS
TOC
Settle-
able
matter
Ortho -
phos-
phate
Nitrate
HRS
YIN
MOD
UNITS
UG/L
MG/L
MG/L
MO/L
/100ML
MG/L
MO/L
MG/L
MOIL
MG/L
MOIL
1
9:30
1
0.036
0.92
2
12:00
3
0.129
0.48
3
12:00
3
0.132
7.46
1.94
2
<.1
<1
2
4
11:00
3
0.104
1.21
5
12:00
2
0.089
1
7.38
1.54
6
10:00
3
0.145
0.74
7
9:30
1
0.135
0.52
s
9:30
1
0.099
0.27
9
8:40
1.5
0.111
7.34
0.24
10
8:35
2
0.128
7.27
0.55
11
10:15
1.5
0.103
1
0.85
12
10:20
1.5
0.124
7.27
1.04
13
9:20
2
0.139
7.32
0.24
14
7:00
1
0.122
1.43
15
8:00
1
0.054
1.21
16
13:00
2
0.022
0.74
17
9:00
2
0.184
7.41
UV
1 s
12:15
3
0.145
UV
19
9:00
3
0.177
7.29
UV
20
9:30
3
0.191
UV
21
10:30
1
0.109
1
UV
22
9:00
3
0.118
UV
23
10:45
2
0.114
UV
24
10:00
2
0.114
7.05
UV
4
<.1
1
<1
25
11:30
2
0.116
UV
26
27
10:45
11:15
3
3
0.111
0.114
7.21
UV
UV
26
10:00
1
0.155
UV
29
9:30
2.5
0.015
UV
30
9:00
2
0.229
UV
31
11:45
2
0.138
UV
Average
0.119
bdl
7.30
0.37
3.00
bdl
1.00
2.00
bdl
bdl
#DIV/0!
Dally Maximum
0.229
0.00
7.46
1.94
4.00
0.00
1.00
2.0
0.0
0.W
0
Dally Mlnlmum
0.015
0.00
7.05
0.24
2.00
0.00
1.00
2.00
0.00
0.00
0
Composite (C) / Grab (G)
G
c
c
c
Monthly Limit
1 0.5
1
6 to 9
1 10
4
20
14
Operator In Responsible Charge (ORC):
Check Box If ORC Has Changed:
Certified Laboratories (1):
Person(s) Collecting Samples
Mall ORIGINAL and TWO COPIES to:
ATTN: Non -Discharge Compliance Unit
DENR
Division of Water Quality
William G. Freed Grade:
ORC Certification Number:
Universal Laboratories #51706 (2):
Dave Robertson/Mike Langston
III Phone: [phone]
23702
(SIGNATURE OF OPERATOR IN RESPONSIBLE CHARGE)
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE
AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
i