WQ0044886_Additional Information Request #1_20240123

January 23, 2024
WILLIAM G. ALLEN
EAST COAST INVESTORS, LLC
3129 SPRINGBANK LANE – SUITE 201
CHARLOTTE, NORTH CAROLINA
Subject: Application No. WQ0044886
Additional Information Request #1
The Peninsula at Hyco Lake – Lot
53 SFR
Single-Family Residence
Wastewater Irrigation System
Person County
Dear Mr. Allen,
Division of Water Resources’ Central and Regional staff has reviewed the application package
received on November 1, 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
22, 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 O 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,
Zachary J. Mega, Engineer III
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
David C. Barcal, PE – MacConnell & Associates, P.C. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. William G. Allen
January 23, 2024
Page 2 of 5
A. Overall:
1. No comment.
B. Cover Letter:
1. No comment.
C. Application Fee:
1. No comment.
D. Application (Form: SFRWWIS 06-16):
1. Item V.1 – The designed effluent concentration of 1.5 mg/L specified for total suspended solids
(TSS) does not match the Engineering Calculations. Please verify and revise.
2. Item V.3 – “No” was selected for this item, however, the soil borings in the Soil Evaluation indicate
that the depth to partially weather bedrock (PWR) is between 34” to 47” (2.83’ to 3.92’). The
Engineering Plans depict excavation up to 114” (9.5’) for the field dosing tank. Please verify and
revise the Engineering Plans and Specifications per 15A NCAC 02T .02T .0605(d), if necessary.
3. Item V.19 –
a. Please provide the separation distances for any private or public water supply source and any
water line from a disposal system per 15A NCAC 02T .0606.
b. “N/A” is specified as the separation distance to any habitable residence or place of assembly
under separate ownership not to be maintained as part of the project site. There are adjacent
properties also with proposed non-discharge systems and accompanying habitable residences
within 500 feet of Lot 53. Please revise this item to include the separation distances from the
irrigation system and treatment/storage units to habitable residences under separate ownership
per 15A NCAC 02T .0606.
4. Item V.20 – The property line separation distances provided in Item V.19 do not meet the setback
requirements of 50 feet for both irrigation sites and treatment/storage units listed in 15A NCAC
02T .0606. It is noted that the parcel has not been subdivided and these values are based on
preliminary property lines. Please address how setback distances will be met and verified prior to
the operation of this facility.
5. Item VI.2.d – The effective volume of 3,018.5 gallons specified for the 3,500 gallon field dosing
tank does not match the Engineering Calculations. Please verify and revise.
6. Item VI.2.e – The design flow of 12.4 gallons per minute (GPM) and 113 feet of total dynamic
head (TDH) specified for the field dosing pump does not match the Engineering Calculations.
Please verify and revise.
E. Property Ownership Documentation:
1. No comment.
Mr. William G. Allen
January 23, 2024
Page 3 of 5
F. Setback Waivers:
1. See Comment D.4.
G. Soil Evaluation:
1. Dorothy Robson of the Raleigh Regional Office (RRO) reviewed the Soil Evaluation and provided
the following comments:
a. The drainage coefficient (DC) in the report is specified as 4.2%, however, the SFR Loading
Rate Worksheet uses a DC of 10.3%. Please revise to match.
b. Concerning the drainage coefficient justification, the report states “We feel that this is a
reasonable drainage rate given the surface texture of the A horizon…”. The annual hydraulic
loading rate should be based on the most restrictive horizon, which is the Bt horizon as shown
in the KSAT tests, and not the A horizon. Please revise.
c. The Soil Evaluation does not discuss the existing cover crop at the site or if the cover crop of
the irrigation field will change. Per the Soil Scientist Evaluation Policy, if the proposed cover
crop is not the existing cover crop and irrigation will take place to help establish the crop, the
precipitation rate shall consider the irrigation of bare soil. Please revise the Soil Evaluation to
evaluate existing cover crop conditions and address any proposed changes.
d. Please only include the relevant information for Lot 53 on the soil map.
e. The perched water table depth is unclear. The soil borings do not indicate hydric soils. Please
explain how a perched water table was determined between 17” and 18” in the soil borings and
no water table depth was noted for any of the KSAT tests.
f. The KSAT data provided do not give sufficient evidence to determine steady-state conditions
(i.e., no horizontal trend among a minimum of three plotted values, K SAT values used for
averages are not within ±10% of the lowest value, etc.). The graphs included do not add any
valuable information to determine steady-state conditions because they do not plot measured
KSAT values against time. Please explain or provide details to support the findings of the Soil
Evaluation.
g. The precipitation data and calculated potential evapotranspiration (PET) data used in the
Single-Family Residence Loading Rate Worksheet (SFRLRW) were both provided using 58
years of data from RDU International Airport between 1948 and 2006. This data is outdated
and may not be representative of current conditions (precipitation data and PET data may have
changed since 2006). Please update the SFRLRW using precipitation and PET data that
incorporates the most recent data from RDU International Airport.
[15A NCAC 02T .0604(b)]
2. Please explain or provide details on the large measurement intervals (up to 12 hours) and the overall
lack of KSAT data (maximum of four measurements) for each KSAT nest. Please also explain or
provide details on the negative elapsed time and water consumption rate shown at K SAT Nest 2.
[15A NCAC 02T .0604(b)]

Mr. William G. Allen
January 23, 2024
Page 4 of 5
3. Please revise the SFR Loading Rate Worksheet to use the reduced daily flow of 270 GPD (90
GPD/BR) specified in Item IV.5 of Form: SFRWWIS 06-16. The SFR Loading Rate Worksheet
currently lists a minimum irrigation area of 0.253 acres, which is greater than the design irrigation
area of 0.204 acres specified in Item VII.4 of Form: SFRWWIS 06-16. Please also verify that the
recalculated minimum irrigation area is less than the designed irrigation area.
H. Engineering Plans:
1. Overall –
a. There are two sheets labeled the “Overall Site Plan” and with the sheet number “C-103”, which
differs from the sheet index on the title sheet. Please revise and ensure all references
concerning these two sheets are correct throughout the Engineering Plans for overall clarity.
b. The proposed arrangement of the clean-outs (COs) is shown inconsistently between the plan
and profile views throughout the Engineering Plans (i.e., one on the influent side of the septic
tank, one on the effluent side of the septic tank, etc.). Please revise for clarity.
2. Sheet D-103 – Is it intentional that the stone bedding depth specified for the field dosing tank in
Section View A is 12”? The remainder of the details specify a 6” thickness.
I. Specifications:
1. No comment.
J. Engineering Calculations:
1. Please ensure that all sizing calculations use the reduced daily flow of 270 GPD (90 GPD/BR)
specified in Item IV.5 of Form: SFRWWIS 06-16.
K. Site Map:
1. No comment.
L. Operation & Maintenance Plan:
1. No comment.
M. Operation & Maintenance Agreement (Form: SFRWWIS-O&M 09-18):
1. No comment.

Mr. William G. Allen
January 23, 2024
Page 5 of 5
N. Additional Documentation:
 County Health Department Denial Letter:
1. Per 15A NCAC 02T .0604(g), a letter from the local county health department denying the site
for all subsurface systems shall be submitted to the Division by the Applicant. The Person
County Health Department denial letter provided is not unique to Lot 53 which is being
proposed in this application. Each individual parcel shall have its own denial letter to verify
that the site cannot support a subsurface system.
The Person County Health Department shall investigate the proposed Lot 5 3 for subsurface
system suitability. This investigation shall include soil borings and a map identifying the
specific location of the investigation.
 Floodway Regulation Compliance:
1. No comment.
 Threatened or Endangered Aquatic Species Documentation:
1. No comment.
O. Recommendations (Response not required):
1. Engineering Plans –
a. Overall – Recommend consistently labeling the “Finished Grade” across all detail sheets in the
Engineering Plans.
b. Sheet C-102 – Recommend revising the sheet reference on Detail 1 from “C-100” to C-102”.
c. Sheet C-103 (1) – Recommend that the acronyms used on the plan view for the proposed
treatment system correspond with the legend on the right.
d. Sheet C-107 – Recommend adjusting the underline for the 15A NCAC 02T .0605(b) effluent
limits in Detail 1 for clarity.