WQ0044883_More Information (Requested)_20240123

January 23, 2024
WILLIAM G. ALLEN – MANAGER
EAST COAST INVESTORS, LLC
3129 SPRINGBANK LANE – SUITE 201
CHARLOTTE, NORTH CAROLINA 28226
Subject: Application No. WQ0044882
Additional Information Request #1
The Peninsula at Hyco Lake – Lot
41 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 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,
Cord Anthony, Engineer II
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. Allen
January 22, 2024
Page 2 of 5
A. Cover Letter:
1. No comments.
B. Application Fee:
1. No comments.
C. 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 22” to 28” (1.83’ to 2.33’). 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 – Please provide the minimum field observed distances for any private or public water
supply source and any water line from a disposal system per 15A NCAC 02T .0606.
4. Item V.19 - “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 41. 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.
5. Item V.20 – See Comment E.1.
6. 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.
7. 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.
8. Item VII.4 – The coordinates for the drip irrigation field are incorrect based upon the plan set
provided. Please verify and revise.
D. Property Ownership Documentation:
1. No comments.

Mr. Allen
January 22, 2024
Page 3 of 5
E. Setback Waivers:
1. According to the engineering plans, a setback waiver has been recorded reducing the property line
setback to irrigation from 50 feet to 10 feet. This waiver has not been included within the
application package. Additionally, individual parcels have not yet been subdivided from the parent
parcel to form individual lots.
Per Item V.20 of Form: SFRWWIS 06 -16 and 15A NCAC 02T .0606(c), please address how the
proposed facility will meet setback distances for future parcel subdivision and subsequent
operation. Please note that, if parcel numbers have not been issued for each lot, this permit will be
issued for construction only.
F. Soil Evaluation:
1. Dorothy Robson of the Raleigh Regional Office (RRO) reviewed the Soil Evaluation and provided
the following comments:
a. 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.
b. The soils evaluation does not discuss the existing cover crop at the site or if the cover crop of
the irrigation field will change. In accordance with 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. The soil evaluation shall
be updated to evaluate existing cover crop conditions and address any changes that will be
proposed.
c. Please only include the relevant information for Lot 41 on the soil map.
d. Soil boring logs do not necessarily indicate hydric soils, however, an assertion was made that
mottling of 10YR 6/1, 2.5YR 5/8 has occurred in each KSAT nest. Very little details on
mottling/redoximorphic indicators have been given for layers other than the BC horizon. Please
give further insight into how a perched water table at 21” was determined.
e. The KSAT data provided do not give sufficient evidence to determine steady-state conditions for
KSAT Nest 2 (i.e., no horizontal trend among a minimum of three plotted values, KSAT values
used for averages are not within ±10% of the lowest value, etc.). Please explain or provide
details to support the findings of the Soil Evaluation.
f. 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 to 2006. This data is outdated and may not
be representative of current conditions as precipitation data and PET data may have changed
since 2006. The SFRLRW shall be updated using precipitation and PET data that incorporates
the most recent data from RDU International Airport.
[15A NCAC 02T .0604(b)]
Please provide insight on why the KSAT tests were run over such a small duration (approximately
three hours for each). Please also clarify why the final three KSAT values of Nest 2 were omitted
from consideration and not used in the calculation of the average. [15A NCAC 02T .0604(b)]
Mr. Allen
January 22, 2024
Page 4 of 5
2. 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 0.252 acres, which is greater than the design irrigation
area of 0.209 acres specified in Item VII.4 of Form: SFRWWIS 06-16. Please also verify that the
recalculated minimum irrigation area is less than the design irrigation area.
G. Engineering Plans:
1. Overall –
a. 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.
H. Specifications:
1. No comments.
I. 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.
J. Site Map:
1. Per Form: SFRWWIS 06-16 Section J., the location of all wells shall be included on the site map.
Please include the any intended drinking water well locations and the relevant setbacks associated
with them.
K. Operation & Maintenance Plan:
1. No comments.
L. Operation & Maintenance Agreement (Form: SFRWWIS-O&M 09-18):
1. No comments.

Mr. Allen
January 22, 2024
Page 5 of 5
M. Additional Documentation:
 County Health Department Denial Letter:
1. In accordance with 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 41 that 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 41 for suitability for
a subsurface system. This investigation shall include soil borings and a map id entifying the
specific location of the investigation.
 Floodway Regulation Compliance:
1. Once accurate coordinates for the field are provided, floodway regulation compliance can be
assessed.
 Threatened or Endangered Aquatic Species Documentation:
1. No comments.
N. 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.