WQ0044733_More Information (Requested)_20231204

December 4, 2023
JOEL CARPENTER – MANAGER
MARTHA’S VINEYARD, LLC
1933 MORRISVILLE CARPENTER ROAD
CARY, NORTH CAROLINA 27519
Subject: Application No. WQ0044733
Additional Information Request #1
953 Marthas Chapel Rd. SFR
Single-Family Residence
Wastewater Irrigation System
Chatham County
Dear Mr. Carpenter,
Division of Water Resources’ Central and Regional staff has reviewed the application package
received on September 6, 2023. However, the Division requires additional information before completing
our review. Please address the items on the attached pages no later than the close of business on January
3, 2024.
Please be aware that the Applicant is responsible for meeting all requirements set forth in North
Carolina rules and regulations. The Applicant is also responsible for any oversights that occur during the
review of the subject application package. The Division may return the application as incomplete pursuant
to 15A NCAC 02T .0107(e)(2) if any omissions are made when responding to the outstanding items in
Sections A through N or the Applicant fails to provide the additional information on or before the above-
requested date.
Please reference the subject application number when providing the requested information. The
Applicant shall sign, seal, and date (where applicable) all revised and/or additional documentation and
submit an electronic response to my attention via the Non-Discharge online portal.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Elton Luong, Engineer I
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Gary S. MacConnell, PE – MacConnell & Associates, P.C. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Joel Carpenter
December 4, 2023
Page 2 of 4
A. Cover Letter:
1. No comment.
B. Application Fee:
1. No comment.
C. Application (Form: SFRWWIS 06-16):
1. No comment.
D. Property Ownership Documentation:
1. No comment.
E. Setback Waivers:
1. No comment.
F. Soil Evaluation:
1. J. Chris Smith of the Raleigh Regional Office has reviewed the soil evaluation and provided the
following comments:
a. Per Application Form: SFRWWIS 06-16 Item V.15, 15A NCAC 02T .0605(p), and 15A NCAC
02T .0605(q), the site is described as having a perched SHWT but no evidence has been
provided to support this. One (1) profile description extends to a depth of 84” (7 feet). Once
observed/described, indicators of an extended period of saturation continue through the entire
depth of the profile description. This is indicative of an apparent SHWT. Please provide
evidence of a perched SHWT.
b. Per DWR Regional Staff visit on October 19, 2023, the recommended annual loading rate of
18.67 in/yr and drainage coefficient (DC) of 25% is not justified. The DWR Soil Scientist
Evaluation Policy and the EPA Process Design Manual: Land Treatment of Municipal
Wastewater Effluents (EPA 625/R-06/016) recommends a DC of 4% to 10%. This loading rate
value is mathematically achievable only by using a Drainage Coefficient (DC) of 25%. Any
DC greater than this should be accompanied by a statement of justification supported by
technical data. The justification provided states that the surface horizon texture supports the
high loading rate. Surface texture governs instantaneous loading rates and does not increase
the maximum vertical drainage capacity of the soil or justify such an elevated DC. Furthermore,
the LSS states in the project narrative that the DC used is 17%, but the DC used in the SFR
Irrigation Area Calculation Worksheet by the LSS is 25%. Please provide supporting data for
this loading rate and the intended DC.

Mr. Joel Carpenter
December 4, 2023
Page 3 of 4
c. Per Application Form: SFRWWIS 06-16 Instruction F and DWR Regional Staff visit on
October 19, 2023, no statement has been provided showing that the site has not changed since
January 2022, which is when the site was last evaluated. Evaluations conducted more than one
(1) year prior to application submission must be accompanied by a statement from the Licensed
Soil Scientist (LSS) indicating if the site has changed in any significant way since the
evaluation was conducted. Please provide a statement.
2. Per Application Form: SFRWWIS 06-16 Instruction F, it is not apparent that the KSAT tests were
run until steady-state equilibrium was achieved, as indicated in Attachment 3 – Geometric Mean
KSAT Data. All three KSAT tests show inconsistent time measurement intervals, some of which are
greater than thirty (30) minutes, and minimal data points to characterize a four to six-hour test. In
addition, all tests ends with an empty cylinder, which invalidates the final data point. Please verify
and revise the KSAT data to provide more resolution.
G. Engineering Plans:
1. No comment.
H. Specifications:
1. Per page 7 of the Engineering Specifications, there are specifications related to fill work (10, 12,
and 13) but no other detail has been provided in other parts of the application. Please clarify if there
is fill work being proposed.
I. Engineering Calculations:
1. No comment.
J. Site Map:
1. No comment.
K. Operation & Maintenance Plan:
1. No comment.
L. Operation & Maintenance Agreement (Form: SFRWWIS-O&M 09-18):
1. No comment.
M. Additional Documentation:
 County Health Department Denial Letter:
1. No comment.

Mr. Joel Carpenter
December 4, 2023
Page 4 of 4
 Floodway Regulation Compliance:
1. No comment.
 Threatened or Endangered Aquatic Species Documentation:
1. No comment.
N. Recommendations (Response not required):
1. J. Chris Smith of the Raleigh Regional Office has reviewed the soil evaluation and provided the
following comments:
a. Please clearly flag KSAT nest locations for future site visits.