WQ0044940_More Information (Requested)_20240215

February 15, 2024
KARINA M. ROGERS, KATHERINE M. ROGERS AND JOHN C. ROGERS
1313 WYNNCREST COURT
RALEIGH, NORTH CAROLINA 27603
Subject: Application No. WQ0044940
Additional Information Request #1
3093 Baptist Rd SFR
Single-Family Residence
Wastewater Irrigation System
Durham County
Dear Mr. and Mses. Rogers,
Division of Water Resources’ Central and Regional staff have reviewed the application package
received on November 20, 2024. 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 March 18,
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,
Erick Saunders, Engineer
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Kevin Davidson, PE and Jeff Vaughan, LSS – Agri-Waste Technology, Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
Ms. Karina M. Rogers, Ms. Katherine M. Rogers, and Mr. John C. Rogers
February 15, 2024
Page 2 of 4

A. Overall:
1. No comment.
B. Cover Letter:
1. The cover letter item for Appendix E references two setback waivers, one for the offsite residence
and one for the onsite residence. However, this does not appear to be included in the application.
Please provide these setback waivers for review.
C. Application Fee:
1. No comments.
D. Application (Form: SFRWWIS 06-16):
1. See Item B.1. The observed separation distances listed in Application Item V.19. do not meet the
15A NCAC 02T .0606(a) setback requirements for both on-site and off-site habitable residences,
and Item V.20 states that setback waivers are proposed for this facility. Waivers shall be provided
to ensure the 02T .0606 setback requirements are met.
2. The total volume, effective volume, and effective storage times of the pump tank listed in
Application Item VI.2.d for the pump tank does not match the calculations. The application refers
to a 3,500 gallon tank, while the calculations list a 3,000 gallon tank. This application form shall
be updated with the correct tank size that is consistent throughout the application, if required.
3. The flow rate for the dosing pump of 14.15 gallons per minute (GPM) in Application Item VI.2.e
does not match the value in the calculations of 12.30 GPM. Please explain the discrepancy and
update as needed.
E. Property Ownership Documentation:
1. No comments.
F. Setback Waivers:
1. See Items B.1. and D.1.
G. Soil Evaluation:
1. The provided soil evaluation was not signed, sealed, and dated by the Licensed Soil Scientist (LSS)
in accordance with 15A NCAC 02T .0604(b). An updated report shall be signed, sealed, and dated
by an LSS and submitted.

Ms. Karina M. Rogers, Ms. Katherine M. Rogers, and Mr. John C. Rogers
February 15, 2024
Page 3 of 4
2. It appears that at least one of the values used to calculate the geometric mean of the hydraulic
conductivity (Ksat) measurements is incorrect based on the data provided in Attachment 6. The
tables indicate a KB value of 0.02 in/hr, 0.03 in/hr, and 0.05 in/hr for sites 1, 2, and 3 respectively.
The values used in the geometric mean calculation seem to match for site 2 (0.031 in/hr) and site 3
(0.053 in/hr). However, site 1 is listed as 0.069 in/hr, which is over three times the measured value.
The values in the geometric mean calculation shall be reviewed and corrected. Any changes to the
calculated geometric mean shall be utilized in an updated Single-Family Residence Loading Rate
Worksheet (SFR-LRW) and updated in the soils report. If the LSS recommendations change based
on the new value, the application, engineering plans, and engineering calculations shall be reviewed
to verify that the design would not exceed the LSS recommended loading rates.
3. The report states the water table on site is perched. Review of the Ksat nests show low chroma
colors at depths of 3”, 2”, and 7” for sites 1, 2, and 3 respectively. These low chroma values also
continue to be described throughout the soil profile after initial observance depth at every Ksat nest
location. The continued observances of these low chroma values potentially indicates an extended
period of saturation through the lower parts of the soil profile and suggest the water table is apparent
and not perched. The depth and type (i.e. perched or apparent water table) impact fill
recommendations because of the different separation requirements in 15A NCAC 02T .0605(p) and
02T .0605(q). The soils report shall be updated to provide an additional justification for the
assessment that the water table on site is perched or fill recommendations appropriate to the
presence of an apparent water table shall be provided.
4. In accordance with 15A NCAC 02T .0604(b)(3) and the Soil Scientist Evaluation Policy, the soils
report shall include detailed soils maps delineating soil mapping units and showing the locations
of soil borings and Ksat data points. The maps in Attachment 3 do not label the boring locations.
An updated soils map clearly delineating soil series polygons, Ksat data points, and other soil
boring locations shall be provided to assist DWR staff in locating these features in the field.
5. The evaluation narrative states that “Numerous borings were performed throughout the area” but
soil boring logs were not provided as recommended by the Soil Scientist Evaluation policy. If
possible, these borings shall be provided.
H. Engineering Plans:
1. See Item D.2. The pump tank detail on Detail 2 of Sheet WW-5 lists a 3,000 gallon pump tank
which is consistent with the engineering calculations. However, the application form and other
sections of the plans list the pump tank as 3,500 gallons (such as in the flow schematic on Sheet
WW-3 and the system profile on Sheet WW-6). The plans shall be updated with the correct tank
sizing that is consistent throughout the application.
I. Specifications:
1. See Items D.2. and H.1. The pump tank in this specifications section is a 3,000 gallon tank. The
specifications shall be updated to be consistent with the rest of the application, if required.
J. Engineering Calculations:
1. See Items D.2., H.1., and I.1. If the tank is 3,500 gallons as it is shown in the system profile view
in the plans, updated effective volume calculations and system head analysis calculations shall be
required.
Ms. Karina M. Rogers, Ms. Katherine M. Rogers, and Mr. John C. Rogers
February 15, 2024
Page 4 of 4
2. See Item G.2. If the LSS recommended loading rates change, the system design shall be checked
to ensure it does not exceed the new recommended rates.
K. Site Map:
1. No comments.
L. Operation & Maintenance Plan:
1. No comments.
M. Operation & Maintenance Agreement (Form: SFRWWIS-O&M 09-18):
1. No comments.
N. Additional Documentation:
 County Health Department Denial Letter:
1. No comments.
 Floodway Regulation Compliance:
1. No comments.
 Threatened or Endangered Aquatic Species Documentation:
1. No comments.