WQ0044463_More Information (Requested)_20230825

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
RICHARD KELLY — MANAGER
MULBERRY FARM — MADISON, LLC
1126 UPPER THOMAS BRANCH ROAD
MARSHALL, NORTH CAROLINA 28753
Dear Mr. Kelly:
NORTH CAROLINA
Environmental Quality
August 25, 2023
Subject: Application No. WQ0044463
Additional Information Request
Mulberry Farm WWIS
Wastewater Irrigation System
Madison County
Division of Water Resources' Central and Regional staff has reviewed the application package
received on June 8, 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 September 25, 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 P, 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: hllps:Hedocs.deg.nc.gov/Forms/NonDischarge-Branch-
Submittal-Form-Vert.
If you have any questions regarding this request, please contact me at [phone] or
cord.anthony_gdeq.nc.gov. Thank you for your cooperation.
DocuSigned by:
Sincerely, f i A�
2D03237162FA4E5...
Cord Anthony, Engineer II
Division of Water Resources
cc: Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Kevin D. Davidson, PE — Agri -Waste Technology, Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA +
©o"rh"nt of min^m^^�� n^am� 919.707.9000

Mr. Richard Kelly
August 25, 2023
Page 2 of 5
A. Cover Letter:
1. The cover letter notes that the proposed system will receive waste from The School of Wholeness
and Enlightenment (SoWE). However, the provided Wastewater Treatment Agreement states that
wastewater will be treated via facilities owned by the Mulberry Farm Property Owners Association.
This suggests that not all the irrigated effluent will originate from the SoWE. Please clarify the
origin(s) of the irrigated effluent and how treatment standards will be monitored.
B. Application Fee:
1. No comment.
C. Application (Form: WWIS 06-16):
1. Section VII of the application lists a designed annual hydraulic loading rate of 14.34 in/yr across
6.11 acres. Using these numbers, an average overall irrigation capacity of 6,522 GPD was found.
This is below the 10,000 GPD currently requested for the facility. Additionally, the soil scientist
recommended a wetted acreage of 12.89 acres to handle the proposed effluent disposal volume.
Please double-check the design calculations for the system to ensure that adequate disposal capacity
exists.
D. Property Ownership Documentation:
1. Per 15A NCAC 02T .0504(f), property ownership documentation shall be provided. The Deed of
Combination included in the permit application package is for a neighboring parcel. Please provide
property ownership documentation and any other easements or landowner agreements where the
proposed irrigation fields will be constructed (Parcel No. 8799408553).
E. Soil Evaluation:
1. The Soil Evaluation included with the permit application package was not signed and sealed by a
licensed soil scientist. Per 15A NCAC 02T .0504(b) a Soil Evaluation shall be signed, sealed, and
dated by a North Carolina Licensed Soil Scientist. Please revise the Soil Evaluation.
2. The soil scientist notes a maximum irrigable output from surface drip lines to be 0.124 in/hr. The
designed rates for Fields A and B, however, are listed as 0.188 in/hr. Please clarify where this
excess flow is originating from.
On July 13, 2023, Regional Soil Scientist Patrick Mitchell evaluated the site. In the
discussion/recommendation section of the report, the following was stated: "Given the relatively
thin topsoil in places, the fine -loamy soil textures found within the topsoil, and the steep slopes in
the proposed irrigation area, a maximum hourly irrigation rate of 0.15 inches/hour may be
appropriate. " Please respond to the above comment and provide further justification on why a
maximum hourly hydraulic loading rate of 1.47 in/hr is appropriate for the site.

Mr. Richard Kelly
August 25, 2023
Page 3 of 5
F. Agronomist Evaluation:
1. No comment.
G. Hvdroieolo6c Report:
1. N/A
H. Water Balance:
1. Form: WWIS 06-16 lists the yearly irrigation rate as 14.34 in/yr while the Water Balance lists the
irrigation rate as 15.14 in/yr. Please confirm which value is correct for the design and revise.
2. A drainage coefficient of 12.5% is being used instead of the typical maximum of 10%. This was
not discussed in the Soil Evaluation. Please revise the Soil Evaluation to justify the use of this
drainage coefficient.
I. En2ineerin2 Plans:
Per 15A NCAC 02L .0107(b), a compliance boundary shall be established either 250 feet from the
waste boundary or 50 feet within the property boundary, whichever is closest to the source. The
compliance boundary is delineated on the Engineering Plans; however, no monitoring wells are
shown. Section IV.10 of Form: WWIS 06-16 mentions waste meeting reclaimed standards. This
claim, however, is not mentioned elsewhere within the application. The permit for the treatment
facility will be required to verify waste is being treated to reclaimed standard.
How will groundwater quality within the compliance boundary be monitored? Furthermore,
regional staff noted the proximity of the application area toe slope to multiple blue line streams.
The addition of monitoring wells in these areas was recommended by regional staff. Please provide
further information on preventative measures in place to avoid runoff and/or subsurface flow into
these streams.
J. Specifications:
1. No comment.
K. En2ineerin2 Calculations:
Per 15A NCAC 02T .0504(c)(3), representative Engineering Calculations shall be provided.
According to the calculations, an average flow of 10,000 GPD was given for the proposed surface
irrigation system. This seems to be based on the overall capacity of the separately permitted
treatment plant minus the capacity of the separately permitted 5,000 GPD subsurface irrigation
system.
The permit application package, however, specifies that the intent of the proposed surface irrigation
system is to receive treated wastewater from The School of Wholeness and Enlightenment. Please
provide calculations for the expected daily flow from The School of Wholeness and Enlightenment
during an average day of operation pursuant to 15A NCAC 02T .0114.

Mr. Richard Kelly
August 25, 2023
Page 4 of 5
Per 15A NCAC 02T .0504(c)(3), calculations for the designed hydraulic loading rates shall be
provided. The Engineering Plans indicate that the spray head wetted area (utilized for line flushing)
will overlap the currently designed subsurface drip irrigation system within the proposed Fields A
and B. There is concern that the additional loading from the surface spray heads combined with
subsurface drip irrigation could cause hydraulic overloading and runoff. Please provide the
maximum loading rate achieved in these areas during flushing (i.e., worst -case scenario).
L. Site Map:
It is difficult to determine the location of the surface drip irrigation fields, spray heads, existing
subsurface drip irrigation fields, storage units, treatment system, buildings, and boundaries with
one another. Surface water features are also difficult to discern. Additionally, the
compliance/review boundaries and multiple setbacks are either missing or not labeled. Please
resubmit a Site Map that clearly shows the requirements of 15A NCAC 02T .0504(d) and ensure
that all setbacks are being met, especially concerning any surface water features located on the
property.
2. Per 15A NCAC 02T .0504(d), a scaled Site Map shall be included. Please include whichever scale
has been utilized for the Site Map.
M. Power Reliability Plan:
1. No comment.
N. Operation & Maintenance Plan:
1. No comment.
O. Residuals Management Plan:
1. No comment.
P. Additional Documentation:
➢ Certificate of Public Convenience and Necessity:
1. N/A
➢ County Health Department Denial Letter:
1. N/A
➢ Existing Permit:
1. The attachment of any previous permits is a requirement of Form: WWIS 06-16. It was noted
that treatment would occur via a wastewater treatment system separately permitted through the
Madison County EHS and owned by the Mulberry Farm Property Owner Association. Please
provide a copy of this permit.

Mr. Richard Kelly
August 25, 2023
Page 5 of 5
➢ Final Environmental Document:
1. N/A
➢ Floodway Regulation Compliance:
1. No comment.
➢ Operational Agreements:
1. N/A
➢ Threatened or Endangered Aquatic Species Documentation:
1. No comment.
➢ Wastewater Chemical Analysis:
1. N/A