WQ0002284_Additional Information Request #1_20240111

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS,]R.
Director
NORTH CAROLINA
Environmental Quality
January 11, 2024
TONY KONSUL — DIRECTOR OF OPERATIONS
CAROLINA WATER SERVICE, INC. OF NORTH CAROLINA (EMERGENCY OPERATOR)
POST OFFICE BOX 240908
CHARLOTTE, NORTH CAROLINA 28224
Subject: Application No. WQ0002284
Additional Information Request #1
Kinnakeet Shores WWTP
Reclaimed Water Generation and
Dedicated Utilization System
Dare County
Dear Mr. Konsul,
Division of Water Resources' Central and Regional staff has reviewed the application package
received on October 27, 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 February
12, 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 M 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
zacharv.me2aa,dea.nc.2ov. Thank you for your cooperation.
Sincerely,
DocuSigned by:
A4-163-
45A56104B4524E7...
Zachary J. Mega, Engineer III
Division of Water Resources
cc: Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Manjiang Chen, PE, PhD — McKim & Creed, Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
Q 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
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Mr. Tony Konsul
January 11, 2024
Page 2 of 5
A. Overall:
The submitted application package is unclear whether the Permittee for the issued permit should
be Outer Banks/Kinnakeet Associates, LLC or Carolina Water Service, Inc. of North Carolina
(CWS). Signature authority delegation documentation was provided for CWS employees, and it is
mentioned that CWS has been designated as the Emergency Operator for the facility by the North
Carolina Utilities Commission (NCUC). Please clarify this and provide documentation from the
NCUC that shows which entity will be acting as the Permittee going forward.
B. Cover Letter:
1. No comment.
C. Application Fee:
1. No comment.
D. Application (Form: RWPI 06-16):
Item I.3 — If the Permittee will be Outer Banks/Kinnakeet Associates, LLC, please submit a
properly executed Operational Agreement (Form: HOA 01-20) per 15A NCAC 02T .0115(c). If
the Permittee will be CWS, please submit a Certificate of Public Convenience and Necessity from
the NCUC or a letter from the NCUC's Water and Sewer Division Public Staff stating an
application for a franchise has been received and that the service area is contiguous to an existing
franchised area or that franchise approval is expected.
2. Item I.4 — Please complete all parts of this item.
E. Application (Form: RWG 06-16):
1. Section IV — Please complete all items in this section.
2. Item VII.e — Please add information on the proposed chemical metering pumps to this table.
F. Setback Waivers:
1. Per Condition I. La of the Final Permit issued on August 17, 2018, and 15A NCAC 02H .0219(i)(5),
please submit fully executed setback waivers for any habitable residence or place of assembly
(including tennis courts) under separate ownership that (1) are within 100 feet of the two -foot
freeboard elevation in the 3.07 million gallon (MG) lined five-day upset pond and (2) were
constructed before the five-day upset pond was originally permitted on August 7, 2002.

Mr. Tony Konsul
January 11, 2024
Page 3 of 5
G. Engineering Plans:
1. Overall — Per Instruction D of Form: RWG 06-16, please revise the title sheet and title block on all
plan sheets to remove the phrase "PRELIMINARY DESIGN — NOT FOR CONSTRUCTION" and
replace it with "FINAL DESIGN — NOT RELEASED FOR CONSTRUCTION".
2. Sheet C01.2 —
a. Please remove all structures, pipes, valves, and appurtenances that are proposed to be
demolished on Sheet CO1.1 for clarity.
b. Please remove the traveling bridge filter and UV channel labels for clarity.
H. Specifications:
1. Overall — Per Instruction E of Form: RWG 06-16, please revise the cover sheet to remove the phrase
"FINAL DESIGN — ISSUED FOR PERMIT — NOT FOR CONSTRUCTION" and replace it with
"FINAL DESIGN — NOT RELEASED FOR CONSTRUCTION".
2. Section 46 33 42 (Liquid Chemical Metering Pump) —
a. Please include the three proposed chemical storage tanks for liquid chlorine in the
Specifications.
b. Please include a Safety Data Sheet (SDS) for the selected liquid chlorine in the Specifications.
I. Engineering Calculations:
1. Overall —
a. Per Instruction F of Form: RWG 06-16, please submit manufacturer information for the
proposed chemical metering pumps and chemical storage tanks.
b. Per Instruction H of Form: RWG 06-16, please include an evaluation of the residuals generated
from the proposed tertiary filters that include calculations for (1) the anticipated residuals
production rate of the proposed tertiary filters, (2) the maximum anticipated residuals
production rate for the modified facility, and (3) the residuals storage capacity of the modified
facility. Please demonstrate that the modified facility still meets the minimum required 30 days
of residual storage for dedicated reclaimed water systems per 15A NCAC 02U .04020).

Mr. Tony Konsul
January 11, 2024
Page 4 of 5
J. Site Map:
1. Per Instruction J of Form: RWG 06-16 and 15A NCAC 02U .0201(d). please submit a Site Map
that has been signed, sealed, and dated by a North Carolina licensed Professional Engineer (PE) or
Professional Land Surveyor (PLS) and shows:
a. All facility -related structures and fences within 500 feet of all treatment and storage units and
all existing and proposed treatment and storage units (please exclude the roof).
b. The location of all wells (including usage and construction details if available), streams
(ephemeral, intermittent, and perennial), springs, lakes, ponds, and other surface drainage
features within 500 feet of all treatment and storage units.
c. Setbacks as required by 15A NCAC 02U .0701(a). Please note that the 5.1 MG
storage/infiltration pond that was originally permitted on August 7, 2002, has the setbacks
listed under 15A NCAC 02H .0219(k). If any listed setback features do not exist within 500
feet of all treatment and storage units, please disregard them.
d. All habitable residences or places of public assembly (including tennis courts) within 500 feet
of all treatment and storage units.
Because the dedicated reclaimed water utilization system is currently inoperable and is planned to
have a future modification, the Site Map only needs to show the treatment and storage units
associated with the Kinnakeet Shores WWTP.
K. Distribution Svstem Monitoring Plan:
1. Per Instruction I of Form: RWG 06-16, please submit a distribution system monitoring plan for
verifying that reclaimed water standards outline under 15A NCAC 02U .0301.
L. Additional Documentation:
➢ Existing Permit:
1. Per Conditions I.4, I.7, and I.10 of the Final Permit issued on August 17, 2018, and 15A NCAC
02T .0108(b)(1)(B), please provide Form GW-1 for each of the proposed monitoring wells (i.e.,
MW-10, MW-11, and MW-12). Robert Tankard of the Washington Regional Office (WaRO)
conducted a site visit on September 31, 2023, and confirmed these monitoring wells have been
constructed, however, the Non -Discharge branch has not received construction documentation.
➢ Operational Agreement:
1. See Comment D.1.

Mr. Tony Konsul
January 11, 2024
Page 5 of 5
M. Recommendations (Response not required):
1. Engineering Plans —
a. Sheet C01.2 —Recommend revising the typo in "Sodium Hypochlorite" in the top left corner.
Recommend revising the text conflict below the existing mudwell and valve vault.
b. Sheet M02.1 — Recommend revising the sheet number shown on the section view labels to
"M02.1".
2. Specifications — Section 46 33 42 (Liquid Chemical Metering Pump) — Recommend revising
"Pump" to "Pumps" for this section title.