HomeMy WebLinkAboutWQ0044332_More Information (Requested)_20230721ROY COOPER lktv
Governor ELIZABETH S. BISERSecretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Environmental Quality
July 21, 2023
RICHARD DEMING — CHIEF EXECUTIVE OFFICER
CAROLINA POULTRY POWER RG3, LLC
3730 NORTH MAIN STREET
FARMVILLE, NORTH CAROLINA 27828
Subject: Application No. WQ0044332
Additional Information Request
Carolina Poultry Power— La Grange
Conjunctive Utilization System
Reclaimed Water System
Lenoir County
Dear Mr. Deming:
Division of Water Resources' Central and Regional staff has reviewed the application package
received on April 24, 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
21, 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: hiips://edocs.deg.nc.gov/Forms/NonDischarge-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at (919) 707-3659 or
erickson.saundersgdeq.nc.gov. Thank you for your cooperation.
Sincerely,
Erick Saunders, Engineer
Division of Water Resources
cc: Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Kim Melvin, PE — Carolina Poultry Power RG3, LLC (Electronic Copy)
Laserfiche File (Electronic Copy)
E Q�� 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 CAROHNA -
oePemmencatE.W —rdalQuari /� 919.707.9000
Mr. Rich Deming
July 21, 2023
Page 2 of 5
A. Cover Letter/Introduction:
1. This facility will spray reclaimed water at a high discharge velocity with fine droplet size coming
out of the spray nozzles that is more susceptible to drift during. What measures are being taken to
minimize the risk of drift from this facility?
B. Application Fee:
1. No comments.
C. Application (Form: RWPI 06-16):
1. No comments.
D. Application (Form: RWCU 06-16):
1. In Item II.4 the estimated amount of reclaimed water to be used is 1.8 MGD. Does this volume
represent the quantity pumped out from the generator to the CPP facility or the evaporative loss
from the CPP thermal loop process? Please clarify.
2. Please update Item IL5. to include the permit number for the reclaimed water generator.
Item V.5. indicates the impoundment is designed to receive surface water runoff, but the drainage
area provided matches the top of dam water surface area in Item V.11. Item V.5. refers to any
additional drainage areas contributing runoff into the basins other than the berm surface area. Please
clarify if any additional drainage areas contribute to the stormwater into the system.
4. The table in Item IV. I. references Appendix C, Sheet 8. The plans in Appendix C only contain a
total of six sheets, so it is unclear if there are missing plan sheets in the application. The references
in this table shall be revised to reference the correct plan sheets and specification pages information.
5. The mean seasonal high water table (SHWT) is not included in Section V in Item V.8 or the Table
in V.11. The mean SHWT shall be provided. If the SHWT is higher than the impoundment bottom,
an explanation shall be provided for how the liner will be protected from bubbling and groundwater
infiltration.
Item V.9. was not completed. This section shall be updated with the specification page for liner
installation and testing requirements.
There appear to be discrepancy between the elevations of the earthen impoundment in Item V.11.
and what are included in the plans. For instance, the freeboard elevation is given as 95.5 ft in the
table, but the water surface on Sheets 1963 and 1964 is 96 ft. The top of embankment elevation is
given as 97.5 ft in the table but shown to be 97.01 ft on Sheet 1962. Due to these discrepancies, it
is difficult to verify that the system meets the required two feet of freeboard design criteria in
accordance with 15A NCAC 02U .0401(h). This table shall be updated to align with the design in
the plans and meet the required two feet of freeboard.
Mr. Rich Deming
July 21, 2023
Page 3 of 5
8. The Spray Utilization Design Element table in Item VL5. appears to provide design criteria for the
entire system, but this table is for the individual spray nozzles. This table shall be updated with the
equipment information for the proposed spray nozzles and shall include the nozzle model.
The Waterbody/Stream Index column in the table in VIL2. includes the name of the water body,
not the stream index number. Additionally, the values in the Classification column does not
correspond to any water planning classifications listed. This section shall be updated with the
correct stream index under and associated classification.
10. What are the differences between the four different sites listed in the table in VII.2?
E. Property Ownership Documentation:
In accordance with 15A NCAC 02U .0201(e)(4), leases provided by the applicant to demonstrate
property ownership shall be written, notarized, and signed by both parties and accompanied by
survey maps or plats. The Lease Agreement dated the 12th of April 2022 between Stockport Limited
Partnership and Carolina Poultry Power RG3, LLC and the First Amendment to this lease dated the
13th of September 2022 were not notarized. Property ownership meeting the documentation
requirements of 02U .0201(e)(4) shall be provided.
F. Enaineerina Plans:
The sealed plans do not appear to show a full piping site plan for the proposed thermal loop,
including joints, valves, and other appurtenances. A site plan shall be provided for the configuration
of the piping network, including where the system ties into the City's existing reclaimed water line.
2. A pipe trenching shall be included, if applicable.
3. See Comment C.7. The impoundment elevations are not consistent throughout the plans. The
bottom of the pond elevation in Detail 2 of Sheet 1962 is 88.5', but 89' in Detail 2 on Sheet 1963.
The plans shall be updated to include the correct impoundment elevations.
4. See Comment C.7. The freeboard of 24" listed in the Evaporative Cooling System Design
Summary on Sheet 1962 does not appear to be met based on the plans. The water level is given as
96' in several details while the top of the berm is given as 97' or 97.01'. If these values are true,
there is not enough freeboard designed for this facility. The plans shall be updated so that the design
meets the required two feet of freeboard required in 02U .0501(h).
Detail 1 on Sheet 1962 and the process flow drawing on 1965 show a reclaimed pond water makeup
valve coming from the reclaimed water line which flow into the south side of the pond. The overall
site plan arrangement drawing in Appendix F, Sheet 1100 shows a 4" reclaimed water line to the
CHP plant from the City of La Grange's treatment plant, but this line runs into the utility building
and doesn't depict the reclaimed water makeup valve on the south side of the basin. Please clarify
the piping configuration connecting the reclaimed water generation facility to the evaporation basin
and update the plans accordingly.
Please indicate the elevation of the pump suction with the basket screen indicated in Detail 2 of
Sheet 1963.
Mr. Rich Deming
July 21, 2023
Page 4 of 5
The condenser loop schematic on Sheet 1965 indicates a line with a 2" valve for the high
temperature circulation water that is sent to the City of La Grange's Water Treatment Plant.
However, this line was not depicted in the rest of the sealed plans. A `2" Hot Water to La Grange'
line is depicted in Appendix F. Sheet 1100, but the utilization of this reclaimed water doesn't appear
to be mentioned anywhere else in the application. Please clarify whether the circulating water will
be sent to the City's plant. If it is proposed, the water line connecting to the City's treatment plant
shall be shown in an updated plan set and an explanation shall be provided for how these operations
will be conducted.
8. The piping plan in Appendix F, Sheet 1100 shows the reclaimed waterline crossing an existing 8"
sanitary sewer line. A detail of this crossing shall be provided to verify that the required separation
distances for reclaimed water distribution lines in accordance with 02U .0403(h) through 0).
G. Specifications:
A set of products cut sheets and construction notes on Sheet 8 of the "Engineering Plans" were
provided in lieu of formal engineering specifications. Pursuant to 15A NCAC 02U .0201(c),
engineering plans and engineering specifications are to be separate documents. The specifications
shall describe the materials to be used, methods of construction, and means for ensuring quality
and integrity of the finished product, including leakage testing. The specifications shall include a
cover page that is signed and sealed by a North Carolina Professional Engineer in good standing.
The "Design Criteria Distribution Lines" section of the construction notes on Sheet 8 of the
"Engineering Plans" set is incomplete and references a "Sheet 9" which was not provided and
references the City of Wilson project. Please include the appropriate specifications for reclaimed
water distribution piping and appurtenances for this project meeting the 15A NCAC 02U
requirements and pertinent AWWA standards within the formal specifications document requested
in Comment G.1.
See Comment C.6. The submitted specification package shall include methods of liner installation
and leakage testing.
4. Please provide the manufacturer's information for the proposed spray nozzles.
H. Engineering Calculations:
1. In accordance with 02U .0201(c)(3), engineering calculations shall include a total dynamic head
and system curve analysis for each pump. These calculations shall be prepared by a professional
engineer for the specified cooling water pumps and submitted for review.
2. Shorthand and other identifiers were used throughout the calculations package. Please provide
clarification on the following descriptions:
a. Within the "Design Summary" table, the column Ref/Comment includes quantitative values,
but it is unclear what these values represent.
b. Does Wellons Water Characteristics represent the City of La Grange's generated reclaimed
water?
c. Multiple numbered Sources are listed including "Foods Process Flows". Please provide a
summary of the source inputs and clarify what "Foods Process Flows" represents.
Mr. Rich Deming
July 21, 2023
Page 5 of 5
3. The calculations for "Storm Water Metrics" refer to a 10-year, 1-hr rain intensity event. Reclaimed
water storage units that are not protected from rainfall and runoff are to be designed to contain the
accumulation of water from a 25-year, 24-hour storm event. Please revise the calculations
accordingly
I. Site May:
1. Section A on Appendix F, Sheet 1100 lists the bottom pond elevation as 97.5', which is the same
as the top of the berm elevation. Please review these elevations and update the drawing accordingly.
2. The `4" Reclaimed Water to CHP Plant' line on Appendix F, Sheet 1100 is shown to end before it
connects any appurtenance of the LaGrange treatment plant. Please clarify where this line connects
to the reclaimed water generating facility.
J. Operation & Maintenance Plan:
1. No comment.
K. Additional Documentation:
➢ Wastewater Chemical Analysis:
1. Please confirm that no chemical additives are being used by the Carolina Poultry Power thermal
facility to improve the efficacy/performance of the reclaimed water thermal loop.
L. Recommendations (Response not required):
1. No comments.