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HomeMy WebLinkAboutWQ0004972_More Information (Requested)_20230718ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality July 18, 2023 GEORGE GUDGEON — SENIOR VICE PRESIDENT MHC TT, L.P. 2 NORTH RIVERSIDE PLAZA — SUITE 800 CHICAGO, ILLMIS 60606 Subject: Application No. WQ0004972 Additional Information Request Forest Lake Preserve WWTP Wastewater Irrigation System Davie County Dear Mr. Gudgeon: Division of Water Resources' Central and Regional staff has reviewed the application package received on April 28, 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 August 17, 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: httl)s:Hedocs.deci.nc.2ov/Forms/NonDischarl;e-Branch- Submittal-Form-Ver2. If you have any questions regarding this request, please contact me at (919) 707-3658 or zachary.mega@deq.nc.gov. Thank you for your cooperation. Sincerely, DocuSigned by: 45A5610464524E7... Zachary J. Mega, Engineer II Division of Water Resources cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy) Corey W. M. King, PE — Kimley-Horn and Associates, Inc. (Electronic Copy) Laserfiche File (Electronic Copy) �D_E Q`J/ 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 DepaMlent of Environmental Duality 919.707.9000 Mr. George Gudgeon July 18, 2023 Page 2 of 15 A. Cover Letter: A cover letter was not included in the submitted application package. Please include a cover letter that summarizes what existing structures will remain, what existing structures will be abandoned and how they will be abandoned, what structures are proposed, and the treatment capacity and disposal capacity of the proposed system in GPD. This will aid in the continued review of the project. B. Application Fee: 1. No comment. C. Application (Form: WWIS 06-16): 1. Overall — a. Our records currently show the designated ORC and the Back-up ORC do not have their WW- 2 certifications applied to this facility, which has a WW-2 classification in addition to the SI classification. Please submit an Operator Designation Form via email to the Water Pollution Control System Operators Certification Commission (WPCSOCC) and include a copy of this completed form in your response to me to have this information updated in our records. [ 15A NCAC 02T .01171 b. The collection system was recently expanded from what is listed in the existing permit facility description. Please consult with the Permittee to verify the current number of grinder pump stations and linear feet of collection piping. 2. Item III.3. — Mr. G. Christopher Murray did not provide the Hydrogeologic Report. Please revise this section with Mr. Eric G. Lappala's information. 3. Item IV.3. — Both "Yes" and "No" were selected for this item. Please clarify this selection. 4. Item IV.7. — a. The item concerning flow reductions was left blank. Please provide an answer to this application item. b. Please recalculate the wastewater daily design flow per the existing permit facility description, coordination with the Permittee, and 15A NCAC 02T .0114. Caitlin Caudle of the Winston- Salem Regional Office (WSRO) listed 283 campsites, 18 cabins, two swimming pools, multiple bathhouses, multiple laundry facilities, and an office building. 5. Item IV.8. — "No" was selected for this item, however, the 100-year floodplain boundary is near the proposed and existing irrigation sites. Please confirm that any portion of the irrigation sites are not located within the 100-year floodplain. If they are, please complete this application item. 6. Item IV.9. — "No" was selected for this item but documentation was provided for threatened or endangered aquatic species. Please clarify this selection. 7. Item V.3. — Both "Yes" and "No" were selected for this item. Please clarify this selection. Mr. George Gudgeon July 18, 2023 Page 3 of 15 8. Item VA — "No" was selected for this item. Please explain how the proposed design will comply with 15A NCAC 02T .0505(k). 9. Item V.11. — The treatment unit volumes do not match the Engineering Plans. Please verify and revise. 10. Item V.1 I.c. — a. The existing permit facility description lists the existing storage pond as 408,000 gallons. Please verify and revise. b. How was the 525-minute detention time for chlorine disinfection calculated? Please add this to the Engineering Calculations. c. How will the WWTP effluent have enough chlorine contact time between the clearwell and the storage pond pipe outlet? Will there not be significant dilution when the effluent enters the storage pond? How will variations in the storage pond water level affect the chlorine disinfection efficacy? d. Where will WWTP effluent samples be taken to prove that the chlorine disinfection system is effective and the irrigated effluent is meeting the fecal coliform limits of 200 colonies/100 mL? f 15A NCAC 02T .0505(b)(1)] e. What will the irrigation schedule be if the proposed chlorine contact time within the storage pond is 525 minutes? 11. Item V.11.e. — a. Please depict and label the chemical CIP, priming (air purge), anoxic mixing, and anti- foam/alkalinity feed pumps on the Engineering Plans. b. The number of transfer and FAS pumps is listed as one, however, there is one transfer pump and two FAS pumps shown on the Engineering Plans. Please verify and revise. c. The flow capacity for the transfer pump in the record drawings of the Cloacina O&M Manual is listed as 45 GPM. Please verify and revise. d. Please add the chlorine feed pump to this table. Please also depict and label it on the Engineering Plans. 12. Item V.1 Lf. — a. What is the sixth unit being served by the HIBlow blowers? There are only five treatment units listed in the Cloacina O&M Manual. Please verify and revise. b. The Cloacina O&M Manual record drawings list four different types of blowers with different capacities. Please verify and revise. Mr. George Gudgeon July 18, 2023 Page 4 of 15 13. Item V.1 l.h. — a. Please depict and label the influent and effluent flow measuring devices on the Engineering Plans. b. The Cloacina O&M Manual includes a WAS flow measuring device and a turbidimeter within the instrumentation equipment. Will these be included in this specific package plant? If so, please depict and label them on the Engineering Plans and add them to this application item. 14. Item V11.2. — "No" was selected for this item, however, Caitlin Caudle of the WSRO noted multiple ditches located within and adjacent to the proposed irrigation sites that are not shown on the Engineering Plans or addressed in the Soil Evaluation and Hydrogeologic Report (see the attached figure). Please depict and label these ditches on the Engineering Plans. Please also discuss these ditches in the Soil Evaluation and Hydrogeologic Report and complete this application item. 15. Item VII.3. — The recommended loading rates listed do not match the Soil Evaluation and the number of fields is incorrect. The Soil Evaluation only discusses one soil series for the project area. Please revise the Soil Evaluation to discuss both soil series present and revise this table. 16. Item VII.5. — Caitlin Caudle of the WSRO noted there are existing golf cart trails near the proposed irrigation sites and recommends more robust protection than a standard two -strand fence with gated access. 17. Item VII.6. — Please depict and label the irrigation system flow meter on the Engineering Plans. 18. Item VII.7. — a. The proposed cover crop for the irrigation sites is not evergreen trees per the Agronomist Evaluation and the average slope will be much higher than 0.5%. The listed soil series does not apply to this site. Please verify and revise this table. b. Please correct the proposed nitrogen mineralization rate. c. How were the minimum irrigation areas calculated based on the nitrogen and phosphorus balances? These calculations were not discussed in the Agronomist Evaluation and appear to be too small considering the proposed WWTP daily design flow. Please verify and revise. d. How were the minimum irrigation areas calculated based on the Water Balance? These calculations were not discussed in the Hydrogeologic Report or included in the Engineering Calculations and appear to be too small considering the proposed WWTP daily design flow. Please verify and revise. 19. Item VII.8. — a. The listed irrigation site names and acreages do not match the Engineering Plans. Please verify and revise. b. The listed design hourly loading rate does not match the Engineering Plans. Please verify and revise. c. The listed design annual loading rate is incorrect and too low. It should be based on the daily design flow calculated in Item IV.7. (subtracting out the existing disposal capacity and area as shown on Sheet C-6 of the Engineering Plans) and not divided between the total number of proposed irrigation sites. Please verify and revise. Mr. George Gudgeon July 18, 2023 Page 5 of 15 20. Item VIII.3. — a. The individual campsites on the property are considered on -site places of assembly. Please verify that the proposed irrigation sites are a minimum of 200' from the cleared treeline of the individual campsites per 15A NCAC 02T .0506(a). There appear to be newly constructed campsites located to the west of the WWTP not accounted for in the design. b. Caitlin Caudle of the WSRO noted an unmarked well located at the southwestern toe slope of the storage pond (see the attached figure). Please determine if this well is still active (and its current use) or has been previously abandoned by the Permittee. If it is still active, please verify that it is a minimum of 100' from any treatment or storage unit (permitted freeboard elevation for the storage pond) and depict/label the well on the Engineering Plans and Site Map. 21. Item VIIIA — "Yes" was selected for this item, however, the listed effluent concentrations do not match the Engineering Calculations and the values for fecal coliforms and turbidity are missing. The listed effluent concentrations also do not meet the requirements outlined in 15A NCAC 02U .0301. Based on the proposed site layout, this facility would not benefit from reduced irrigation setbacks to property lines as standard setbacks are already met. Please either revise the listed effluent concentrations or clear this section and select "No" for this application item. D. Property Ownership Documentation: 1. No comment. E. Soil Evaluation: 1. Overall — a. Section VII of Form: WWIS 06-16 and the Engineering Plans specify two predominant soil series (PcB2 and PcC2) based on the range of slopes present at the project site (3-20%). Please revise the Soil Evaluation to provide recommendations for the two different soil series. Annual and hourly hydraulic loading rates (HLR) will be reduced because of the higher slopes. b. The Soil Evaluation was completed more than one year before the submittal of this application package. Please provide a statement from the soil scientist indicating that the site has not changed since the original investigation. c. There are areas of the proposed irrigation sites where spray radii are outside of the Suitable Soil Boundary (SSB) established in the Soil Evaluation (see the attached figure). Please either revise the proposed spray head layout to be within the SSB or have the soil scientist provide a statement that confirms these areas outside the established SSB are composed of the same soil series analyzed in the Soil Evaluation. Mr. George Gudgeon July 18, 2023 Page 6 of 15 2. Patrick L. Mitchell, LSS, the Regional Soil Scientist for the Central Region of the Division of Soil and Water Conservation provided the following recommendations about the Soil Evaluation. He and Caitlin Caudle of the WSRO conducted a soil investigation of the facility on May 30, 2023. Seven soil borings were collected using a hand auger within the areas of the proposed irrigation sites (see the attached figure) and compared to those provided by Piedmont Environmental Associates, P.A. (PEA). a. The slopes in the areas of soil borings #5 and #6 were roughly 20%, as indicated in PEA soil borings #15 and #17. In addition, the depth of the sandy loam topsoil above the clayey subsoils was found to be approximately five inches thick. Given the slope and thickness of the topsoil, it is recommended that the hourly HLR in this area be reduced. An hourly HLR of 0.20 to 0.25 in/hr may be more appropriate. b. The sandy loam topsoil layer observed in the area of soil boring #7 was found to be less than one inch thick before transitioning into clayey subsoils. It is recommended that the hourly HLR in this area be reduced as well. An hourly HLR of 0.20 in/hr may be more appropriate. c. The proposed annual HLR of 36.82 in/yr using a maximum drainage coefficient of 10% proposed by PEA is acceptable for most areas. However, due to the slopes present in the area of soil borings #5 and #6, it is recommended that the annual HLR be reduced in this area. The annual HLR could be decreased by > 20% (i.e., reduce the annual HLR to approximately 30 in/yr or less) to account for the increased slopes. 3. Hydraulic Conductivity Analysis — a. This section recommends "a maximum dosing rate of 0.3 inches per dose" and a "minimum two-hour "soak period" between irrigation events. What is considered a "dose" in this scenario? How does this differ from the recommended hourly HLR? b. Some of the KsaT measurements provided were not at a steady state before the test was concluded and consecutive KsAT measurements were not always used to calculate the average result for the soil horizon at each site. Please provide the field worksheets used to calculate the recommended KsAT for the Water Balance and an explanation for these discrepancies. F. Agronomist Evaluation: 1. Section I — This section mentions "over approximately 14 [acres] of newly dedicated spray field.", which is incorrect based on the Engineering Plans. Please revise. 2. Section II — This section mentions "one major soil series", which should be two based on the Engineering Plans. Please revise. 3. Section III — This section states "Soils were not analyzed for nitrogen due to the dynamic nature of soil N." Please obtain updated soil fertility results that provide a nitrogen loading recommendation. 4. Section IV — The effluent TN concentration used is incorrect. The Engineering Calculations show a proposed effluent TN concentration of 10 mg/L. Please verify and revise. Mr. George Gudgeon July 18, 2023 Page 7 of 15 5. Section V — a. Please provide the calculations used to obtain the estimated annual nitrogen loading rate of 36.7 lb N/ac/yr. b. Where was the RYE of 80 lb N/ac/yr mentioned in Section V obtained? Tree crops are not available on the NCSU website(https://realisticyields.ces.ncsu.edu/l. 6. Section VI — Please provide the calculations used to obtain the estimated annual phosphorous loading rate of 8.3 lb P205/ac/yr. 7. Section VII — This section mentions "reclaimed wastewater". Please revise to "wastewater". G. Wdroaeoloeic Report: 1. Overall — a. There is no discussion of the 100-year floodplain in this report. Given the proximity of the 100-year floodplain to the irrigation sites, please discuss this in the report and how it will affect site conditions. b. Due to the historic use of the project site for wastewater irrigation, a contaminant transport analysis is necessary to assess the existing groundwater conditions. Please conduct a contaminant transport analysis and summarize the results in the report. c. MW-4 is currently located in the middle of a proposed irrigation site. This well must be permanently abandoned before the operation of the modified facilities. This was not discussed in the report. Please discuss the permanent abandonment of MW-4. d. The report does not discuss the new downgradient monitoring well that will need to replace MW-4. Additionally, it is recommended that a second new monitoring well be installed on the western edge of the proposed irrigation sites. Please provide a figure showing the proposed locations of all new monitoring wells and discuss this in the report. 2. The "Introduction" section on Page 4 mentions "the areas evaluated for the additional sprayfields areas comprise approximately 14 acres" which is incorrect based on the Engineering Plans. Please revise. 3. The "Approach" section on Page 5 states that three borings were installed in areas identified for new irrigation sites. However, there is no mention of these borings anywhere else in the report. Were these borings completed? If so, please provide a figure showing the location of these borings, construction records, and any other relevant data. 4. The topographic map provided on Page 6 is not legible enough to show information for the immediate project site. Please provide a larger, more legible topographic map that shows the project site in detail. In multiple locations (Pages 7 and 12), it states that the project site is located within the Carolina Slate Belt, which is not correct. The project site is located within the Charlotte and Milton Belts. On Page 12, it states that the hydraulic conductivity of Unit 2 was assigned an initial value of 0.01 ft/day based on literature values for fractured granite and rocks of the Carolina Slate Belt. Please revise the report and model to use the correct geology for the project site and comment on any changes to the model results. Mr. George Gudgeon July 18, 2023 Page 8 of 15 6. Our records for well construction data on the four existing monitoring wells located at the facility are insufficient. Page 10 states that data collected from MW-1 was not included in the geometric mean for hydraulic conductivity because it may be partially screened into the fractured bedrock. The media where the existing monitoring wells are located should be verified to determine if the calculated hydraulic conductivity is appropriate for the project site. Please provide well construction records for the four existing monitoring wells and revise the report and model as necessary. 7. Page 10 states that the calculated geometric mean for hydraulic conductivity of the surficial unit is 2.63 ft/day. However, on Page 12 it states that 3 ft/day was used in the model. Please justify using 3 ft/day instead of the calculated value of 2.63 ft/day, which is more conservative. Page 10 states that boring logs were used to determine subsurface conditions. There were no boring logs included in the report. Please provide all boring logs for the project site. 9. Mounding Analysis (Page 20) — a. Please explain why the existing irrigation site has no irrigation capacity for April. b. Please justify the use of a variable drainage coefficient for the existing irrigation site while keeping the proposed irrigation sites constant or change the model to use a single drainage coefficient for all irrigation sites. c. Please revise the acreages for the existing and proposed irrigation sites to match the Engineering Plans. d. The existing permit lists the annual hydraulic loading rate for the existing irrigation site as 46.8 in/yr. Why is it listed as 26.17 in/yr for the mounding analysis? e. This section states that the red areas in Figures 11 through 22 indicate where the modeled depth to groundwater is one foot or less, however, the figure captions state two feet or less in depth. Please verify and revise. 10. Conclusion (Page 33) - a. The beginning of this section mentions existing water supply well information. There are no existing water supply wells at this facility. Please revise. b. This section states that "the simulated groundwater flow patterns are consistent with the conceptual model". Groundwater flow patterns are not discussed in the report. Please clarify this statement and include a discussion of groundwater flow patterns. c. The groundwater model does not account for seasonal peak flows, which historically have occurred at this facility and can continue for several days. Recommend adding peak flow analysis to the groundwater modeling and discussing this in the report. H. Water Balance: 1. Please revise the acreages for the existing and proposed irrigation sites to match the Engineering Plans. 2. The existing permit lists the annual hydraulic loading rate for the existing irrigation site as 46.8 in/yr. Why is it listed as 26.17 in/yr for the Water Balance? Mr. George Gudgeon July 18, 2023 Page 9 of 15 3. Please explain why the existing irrigation site has no irrigation for April. 4. The Water Balance assumes the initial water level in the storage pond is zero. This is an incorrect assumption because the storage pond will never be empty due to the minimum liquid level required to protect the submerged pumps. Please coordinate with the Permittee and revise the Water Balance to start with a realistic operating water level in the storage pond. I. Engineering Plans: 1. Overall — a. Are the existing force mains traffic bearing? The new unpaved access road is proposed over them. If not, please revise the plans as necessary (i.e., pipe sleeves, etc.) and add the required details and specifications. b. Please provide more clarification on the plans for the abandonment of the existing treatment train (i.e., what will be removed from the site, what will be abandoned in place, etc.) 2. Sheet C-2 — Some of the call -outs for the existing force mains point to blank space. Please revise. 3. Sheet C-3 — Please show the proposed unpaved access road. 4. Sheet C-4 — a. The elevations shown for the FFE/TOW of the proposed WWTP and sludge holding tank do not match Sheet C-5. Please verify and revise. b. Please show the proposed unpaved access road. 5. Sheet C-5 — a. The top of the sludge holding tank is labeled as "WS EL. 749.50". Should this be the top of the tank instead? b. The peak water -surface elevation for the clearwell chamber is listed as 749.58', which is only 0.20' below the specified TOW. Please verify and revise. c. Please revise the pipe linework above the chlorine dosing tank. d. Please provide elevations for the storage pond discharge and irrigation pump station. e. The tank volumes listed on the process flow diagram do not match those specified in Form: WWIS 06-16. See Comment C.9. f. The hydraulic profile labels the influent screen as "Fine Screens" and the process flow diagram as "Micro Screen". Please verify and revise to be consistent. g. Should the influent static screen on the repurposed equalization tank be included in the process flow diagram? Mr. George Gudgeon July 18, 2023 Page 10 of 15 6. Sheet C-6 — a. The calculated irrigation rate of 20,333 GPD for the existing irrigation site in the bottom left of the sheet does not match the label on the plan view. This calculation should also use the average daily flow (ADF) for the treatment facility, not the peak flow. The designed hourly hydraulic loading rate is one decimal place off as well. Please verify and revise. b. Please label the proposed location of air release valves for each irrigation site. c. Please verify the overlapping irrigation area between Fields A and B is not double -counted. d. Please delineate and label the 100-year floodplain boundary. See Comment C.5. e. Please delineate and label the on -site ditches. See Comment C.14. f. Please show the missing major and minor contour lines on the majority of the sheet. See Comment L.9. g. See Comments L.5. and L.8. 7. Sheet C-7 — a. Will the existing fence be impacted during the construction of the three new effluent mains and retrofit of the existing effluent main? b. Should a pressure relief valve be specified for the first effluent main? This effluent main runs to the proposed irrigation site with the highest spray head elevation. c. Please label the location of the precipitation/soil moisture sensor and backflow preventers. 8. Sheet C-10 — a. Please provide details for backflow preventers and proposed irrigation site fencing. b. Please label the brick supports on Detail 4 to be consistent with the other details. c. Is Detail 8 for the "Typical Air/Vacuum Release" the same as the pressure relief valves shown for the effluent mains on Sheet C-7? 9. Sheet M-2 — a. There is a note about a canopy structure on this sheet, which was not mentioned anywhere else in the Engineering Plans. Please clarify this note. b. Are all seven blowers specified under Item V.1 Lf. on Form: WWIS 06-16 contained in the two housings shown in Section 1? Mr. George Gudgeon July 18, 2023 Page 11 of 15 10. Sheet M-3 — a. Please label the air diffusers shown in Section 1. b. Please add the "Existing Tank to be Abandoned in Place" note shown in Section 3 to Sheet C- 3. It is not mentioned anywhere else in the Engineering Plans. c. What is the pipe shown intersecting the steel wall in Section 3? 11. Sheet M-4 — a. Please dimension the total height of the sludge holding tank in Detail 3. b. Detail 3 labels the sludge holding tank as 2,000 gallons and the call -out specifies 5,000 gallons. Sheet C-5 and the Residuals Management Plan specify 6,000 gallons. Please verify and revise. 12. Sheets M-5 & M-6 — Some of these details were not called out on the previous sheets. Were they used? J. Specifications: 1. Overall — a. Please provide equipment specifications/product cut sheets for the equalization pumps, chlorine disinfection system, sludge transfer pump, sludge holding tank, and Or-Tec LO- FLOW screen (i.e., any proposed equipment/treatment unit/storage unit outside of the package plant). Please also provide a chemical data sheet for the liquid chlorine that will be used in the proposed disinfection system. b. Please provide equipment specifications/product cut sheets for the irrigation system components (spray heads, irrigation pumps, etc.) 2. Under the heading "1.02 Related Sections" in Sections 02315 and 02320 there is a reference to Section 02240, Dewatering, which was not included in the Specifications. Please either remove this reference or add this section. Section 11300, Wastewater Treatment Plant Supplemental Equipment - a. Please add specifications for the external sludge holding tank with air diffusers. b. Please expand the description of "chlorine tank" under the heading "1.01 Scope of Work" to include the components of the proposed chlorine disinfection system. c. Under the heading "2.01.13. Flow Equalization Pumps and Flow Control Box" there is a reference to a flow splitter box. The only flow splitter box shown in the Engineering Plans is labeled to be demolished after construction is complete. Please add this flow splitter box to the Engineering Plans. d. Under the heading "2.03 Chlorination" it states "the pond shall have a minimum capacity of 2,010 gallons total". How was this determined? The listed information about the chlorine feed pump differs from what is listed in Section 11500, Liquid Chlorine Feed Equipment. Please either verify and revise this information or remove it from this section. Mr. George Gudgeon July 18, 2023 Page 12 of 15 e. Under the heading "2.04 Sludge Transfer Pump" the listed information about the sludge transfer pump differs from what is listed in Section 11500, Liquid Chlorine Feed Equipment. Please either verify and revise this information or remove it from this section. 4. Section 11500, Liquid Chlorine Feed Equipment — Under the heading "1.02 Related Sections" every section that is referenced except for Division 16 — Electrical is not included in the Specifications. Please either remove these references or add the specified sections. 5. Section 11503, Dry Pit Pumps — a. The listed flow capacity and total dynamic head (TDH) do not match what is specified in Item V.1 Le. on Form: WWIS 06-16. Please verify and revise. b. Under the heading "2.06 Source Quality Control" there is a reference to Section 16150, which is not included in the Specifications. Please either remove this reference or add this section. 6. Section 15050, Pipe Systems — General (Piping Schedule) — a. The pipe material listed for the plant effluent and process air piping does not match the Engineering Plans. They are shown as PVC and PVC/DI respectively. Please verify and revise. b. The influent force main is included in the Piping Schedule, however, it is listed as existing on the Engineering Plans. Is this the piping from the repurposed equalization tank to the head of the package plant? If so, this is shown as DI on the Engineering Plans. Please verify and revise. K. Engineering Calculations: Overall — No calculations were provided for the irrigation site design (i.e., designed hourly and annual hydraulic loading rates, irrigation pump sizing, etc.) and the specified auxiliary power source per Instruction K on Form: WWIS 06-16. Pump sizing and friction/total dynamic head (TDH) should also be calculated for the proposed pumps outside of the package plant (equalization pumps, sludge transfer pumps, and irrigation pumps). Please provide the specified calculations. 2. Treatment/Sizing Calculations — a. What is the design flow to be permitted for this package plant expansion? There are multiple flows mentioned in the calculations but none of them correspond with the 49,000 GPD specified in Item IV.7. of Form: WWIS 06-16. b. The "Project Altitude" within the aeration calculations should be roughly 740 instead. Please revise. c. Is a temperature range of 15°C (59°F) to 25°C (77 17) realistic for an open atmosphere tank in North Carolina (specifically in the summer months)? d. Is the repurposed aeration tank factored into these calculations as additional capacity? The calculated volume of the aeration chamber does not meet the required volume specified above. e. Please show the sizing calculations for the other treatment units of the package plant. £ Please show the pollutant removal efficiencies for all treatment units and the calculation to reach the listed effluent concentrations. Mr. George Gudgeon July 18, 2023 Page 13 of 15 3. Blower Calculations — a. The elevation for the inlet flow to the aeration blowers should be roughly 740' instead. Please revise. b. Please verify the specified exceedances shown in red on each blower calculation spreadsheet will not cause operational issues. c. Please provide blower calculations for the transfer chamber, equalization tank, repurposed aeration tank, sludge chamber, and sludge tank. L. Site Man: 1. Please sign, seal, and date the Site Map per Instruction L on Form: WWIS 06-16. f 15A NCAC 02T .0504(d)] 2. Please delineate and label the compliance and review boundaries for the irrigation sites per 15A NCAC 02L .0107 and 02L .0108. 3. Please delineate and label the on -site ditches. Please also verify and show they meet the 25' setback per 15A NCAC 02T .0506(a). See Comment C.14. 4. Please label the name and acreage of the irrigation sites. 5. Please extend the 150' property setback hatched polygon past the existing irrigation site. Please also revise the irrigation spray area boundary (and spray head layout, if applicable) so it does not intersect the 150' property setback hatched polygon. 6. Please update the habitable residency/place of assembly boundary to include the newly constructed campsites to the west of the WWTP. See Comment C.20.a. 7. Please delineate and label the 100-year floodplain boundary. See Comment C.5. 8. Please depict and label the proposed and existing fencing around the irrigation sites. 9. Please clip the two different contour sources shown so they do not overlap. M. Power Reliabilitv Plan: 1. Please provide a Power Reliability Plan per Instruction M on Form: WWIS 06-16. N. Operation & Maintenance Plan: 1. The pages within the submitted O&M Plan are blank. Please resubmit the complete O&M Plan. Mr. George Gudgeon July 18, 2023 Page 14 of 15 O. Residuals Management Plan: 1. Please revise the rule reference in Section Ito either 15A NCAC 02T .0504(i) or 15A NCAC 02T .0508. 2. Section II discusses an Or-Tec auger that will collect trash and sediment. Is this the same as the Or-Tec LO-FLO screen reference in the Engineering Plans? Please revise for consistency. 3. Should the static bar screen located at the head of the existing treatment train be discussed in Section II? 4. The sludge management plan described only leaves an excess of roughly 20 gallons when the sludge chamber of the package plant has its high-water elevation adjusted to 9'. Will this be realistically manageable for an operator? P. Additional Documentation: ➢ Existing Permit: 1. No comment. ➢ Floodway Regulation Compliance: 1. Please provide Floodway Regulation Compliance per Instruction P on Form: WWIS 06-16 given the proximity of the 100-year floodplain to the irrigation sites. ➢ Threatened or Endangered Aquatic Species Documentation: 1. See Comment C.6. Q. Recommendations (Response not required): 1. Sheet G-3 — Recommend adding the acronyms FAS, REC, SOC, and TOW that were used throughout the Engineering Plans to the standard abbreviations list. 2. Sheet C-1 — Recommend cleaning up the leader lines. The majority of them stray from the label target. 3. Sheet C-8 — Recommend rotating some of the Davie County details that have mostly horizontal text. 4. Sheet C-10 — a. There is a typo in the word "Rotor" in Details 1 and 2. b. The note numbers and text for Detail 3 are misaligned. c. The labels for Details 5 and 6 overlap. 5. Sheets M-1 & M-3 — Recommend changing the section label "5 (M-3)" to "2 (M-3)" for clarity. Mr. George Gudgeon July 18, 2023 Page 15 of 15 6. Sheet M-2 — Sections 1 and 2 should have their label changed to "M-2" to match the current sheet number. 7. Sheet M-3 — Sections 1, 2, and 3 should have their label changed to "M-3" to match the current sheet number. 8. Sheet E-5 — There is a typo in Ms. Amy Howard's name next to her signature in the title block. 9. Specifications Sections 11503 and 15110 —The main heading label numbers stray from the heading. 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SCALE AS SHOWN PREPARED FOR 200 SOUTH TRYON STREET, SUITE 200, CHARLOTTE, NC 28202 DESIGNED BY SNR EQUITY LIFESTYLE PROPERTIES, INC. NC LICENSE NUMBER 11/17/2022 CAB PHONE: 704-333-5131 DRAWN BY CAB 048981 WWW.KIMLEY-HORN.COM DATE BY CHECKED BY CK DAVIE NC DATE: - - -- Ck ra GRAPHIC SCALE IN FEET 0 50 100 200 PERMIT APPLICATION SITE MAP FIGURE SHEET NUMBER FIG 1 a 0 NO Eta 00 .� �, ao 4. _