HomeMy WebLinkAboutWQ0037287_Additional Information Request #1_20240531
May 31, 2024
MAURICE W. GALLARDA, PE – MANAGING MEMBER
PLURIS HAMPSTEAD, LLC
POST OFFICE BOX 297
HAMPSTEAD, NORTH CAROLINA 28443
Subject: Application No. WQ0037287
Additional Information Request #1
Pluris Hampstead WWTP
High-Rate Infiltration System
Pender County
Dear Mr. Gallarda,
Division of Water Resources’ Central and Regional staff have reviewed the application package
received on March 6, 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 July 1, 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 (919) 707-3658 or
zachary.mega@deq.nc.gov. Thank you for your cooperation.
Sincerely,
Zachary J. Mega, Engineer III
Division of Water Resources
cc: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Michael C. Gallant, PE, PA – Gallant Environmental, Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 2 of 10
A. Overall:
1. The Engineering Plans (including the P&ID) depict the proposed 500,000 gallon per day (GPD)
treatment train effluent routed through the existing high-rate infiltration basins to the groundwater
storage pond for a total of 1 million gallons per day (MGD) (Sheet C1.0). Item VII.9.b of Form:
HRIS 06-16 also shows the existing high-rate infiltration basins receiving a total of 1 MGD.
Condition I.2 of the Final Permit issued on August 2, 2021, requires the Permittee to address the
groundwater storage pond’s ability to accommodate the proposed flow increase if the Permittee
applies for a permit modification to increase the disposal capacity from the currently approved
250,000 GPD for each high-rate infiltration basin. The submitted application package does not
include documentation to satisfy this Compliance Schedule pursuant to 15A NCAC 02T
.0108(b)(1)(A).
Please clarify where the Permittee plans to send this additional 500,000 GPD flow (i.e., either
disposed of via the existing NPDES Permit No. NC0089524 and/or the groundwater storage pond)
and revise the application package accordingly. The issued Final Permit will be for construction
only of the proposed 500,000 GPD treatment train until the Permittee increases the disposal
capacity to accommodate the additional 500,000 GPD flow in Permit No. NC0089524 and/or
WQ0037287.
2. The Engineering Plans (including the P&ID) depict the grinder station as simplex. Pursuant to Item
V.4 of Form: HRIS 06-16 and 15A NCAC 02T .0705(j), multiple pumps shall be provided
wherever pumps are used. Please either revise the application package to propose a duplex grinder
station or maintain a spare uninstalled replacement grinder pump onsite that meets Alternative
Design Criteria pursuant to 15A NCAC 02T .0105(n).
B. Cover Letter:
1. See Comment A.1.
C. Application Fee:
1. No comment.
D. Application (Form: HRIS 06-16):
1. Item IV.10 – The status of monitoring well MW-1 is listed as “Permanently Abandoned”.
Condition I.5 of the Final Permit issued on August 2, 2021, requires the Permittee to temporarily
abandon monitoring well MW-1 within 60 days of permit issuance. Please clarify the status of
monitoring well MW-1 and provide documentation to satisfy the Compliance Schedule pursuant to
15A NCAC 02T .0108(b)(1)(B).
2. Item V.11.e – The number of chemical feed pumps is listed as six (6), however, the Engineering
Plans depict ten (10) including the clean-in-place (CIP) and peracetic acid chemical feed pumps
(five [5] duty/five [5] shelf spare).
3. Item V.11.f – The number of pre-aeration (PA) blowers is listed as one (1), however, the
Engineering Plans (including the P&ID) depict two (2) PA blowers for a total of five (5) blowers
serving the proposed treatment train.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 3 of 10
E. Property Ownership Documentation:
1. No comment.
F. Engineering Plans:
1. Overall – Please provide plans/details for the contractor-specific electrical work including the
automatically activated standby generator pursuant to Instruction I of Form: HRIS 06-16 and 15A
NCAC 02T .0704(c)(1).
2. Sheet C0.0 (Project Information) –
a. Please revise “Preliminary Plan Not For Construction” to “Final Plan – Not Released For
Construction pursuant to Instruction I of Form: HRIS 06-16 and for consistency with the other
sheets.
b. Please revise the sheet index to include the P&ID under Appendix 1.
3. Sheet C1.2 (Hydraulic Profile) – Please revise the text label in the bottom right to “NPDES
Discharge 001 (Existing) and 002 (Proposed)” for clarity.
4. Sheet C1.4 (Plant Equipment Spreadsheet) – The number of CIP chemical feed pumps is listed as
one (1), however, Sheet C8.0 depicts two (2) and Page 140 of the Specifications lists one (1)
duty/one (1) shelf spare. Please verify and revise.
5. Sheet C2.1 – See Section J – Site Map.
6. Sheet C2.2 (Grading Plan) –
a. The PVC wasting line diameter is labeled 4” on this sheet and 3” on the next sheet. Please
verify and revise.
b. The influent force main diameter is labeled 8” on this sheet and 6” on the next sheet. Please
verify and revise.
7. Sheet C2.4 (Profile 1) –
a. The PVC wasting line diameter is labeled 4” on the plan view and 3” on the profile view below
and the previous sheet. Please verify and revise.
b. The PVC wasting line diameter at the existing digester is labeled 2” on this sheet and 4” on the
next sheet. Please verify and revise.
8. Sheet C2.5 (Profile 2) –
a. The PVC wasting line diameter is labeled 4” on the plan view and 2” on the profile views
below. Please verify and revise.
b. The influent force main diameter is labeled 8” on the plan view and 6” on the profile views
below. Please verify and revise.
9. Sheet C3.0 (Commonwall Tank Structural Plan and Dimensions) – There are dimensions and labels
on the left side of the sheet that are cut off. Please revise for clarity.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 4 of 10
10. Sheet C4.0 (Fine Screens) –
a. On the “Fine Screen Placement Plan”:
i. The 10” influent lines to the fine screens (IS-01 and IS-02) are labeled as ductile iron pipe
(DIP) but labeled as PVC on Sheet HNC-I-05 of the P&ID. Please revise for consistency.
ii. The gate valve GV-102 from Sheet HNC-I-05 of the P&ID is labeled “GV-201”. Please
revise for consistency.
iii. The compactor (CP-01) depicted is not included on Sheet HNC-I-05 of the P&ID. Please
revise for consistency.
b. On the “Fine Screen Plumbing Plan”:
i. The pipe labeled “2” PVC-WWLS-001” is labeled “2”-PVC-PW-002” on Sheet HNC-I-05
of the P&ID. Please revise for consistency.
ii. The pipe labeled “1” SCED 80 PVC-WWLS” is labeled “1” PEX-WWLS” on the next
sheet. Please revise for consistency.
11. Sheet C4.1 (Fine Screens) – The pipe labeled “2” PVC-WWLS-001” on the “Fine Screen Plumbing
Section” is labeled “2”-PVC-PW-002” on Sheet HNC-I-05 of the P&ID. Please revise for
consistency.
12. Sheet C5.0 (FF/IR-RAS-Slide Gate) –
a. The internal recycle (IR) line diameters are labeled 10” and 6”, while both are labeled 6” on
Sheet HNC-I-06 of the P&ID. Please revise for consistency.
b. The feed-forward (FF) line diameters are labeled 10”, while both are labeled 6” on the next
sheet and Sheet HNC-I-09 of the P&ID. Please revise for consistency.
c. The combined FF/IR line diameters are labeled 12”, while both are labeled 10” on the next
sheet and Sheet HNC-I-09 of the P&ID. Please revise for consistency.
d. The following text labels for valves, gauges, meters, etc. on this sheet do not correspond to the
P&ID: the control valve CV-1104 is labeled “PV-1104”, the flow meter FE/FIT-110101 is
labeled “FE120101”, the pressure gauge PG-110101 is labeled “PG-10101”, the pressure gauge
PG-110102 is labeled “PG-10102”, the pressure gauge PG-110201 is labeled “PG-10201”, and
the pressure gauge PG-110202 is labeled “PG-10202”. Please revise for consistency.
13. Sheet C5.1 (FF/IR-RAS-Slide Gate) – The flow meter FE/FIT-110101 from Sheet HNC-I-09 of the
P&ID is labeled “FE120101”. Please revise for consistency.
14. Sheet C6.0 (PA Diffuser/Air Supply) –
a. The text labels for valves, gauges, meters, etc. within the control building on this sheet do not
correspond to Sheet HNC-I-15 of the P&ID. Please revise for consistency.
b. The fine bubble diffuser FB-08-01 from Sheet HNC-I-07 of the P&ID is labeled “FB-08-02”.
Please revise for consistency.
15. Sheet C6.1 (PA Diffuser/Air Supply) –
a. See Comment F.14.a.
b. Please revise the text label “8”-SS-PA-001,002” to “8”-304SS-PA-001,002” for consistency
with Sheet HNC-I-15 of the P&ID.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 5 of 10
16. Sheet C7.0 (MBR Equipment Plan) – The flow meter FE/FIT-140201 from Sheet HNC-I-15 is
labeled “FE-140102”. Please revise for consistency.
17. Sheet C7.1 – (MBR Equipment Sections) – The following text labels for valves, gauges, meters,
etc. on this sheet do not correspond to the P&ID: the blowers B-14-01 and B-14-02 are labeled “B-
15-01,02”, the flow meter FE/FIT-140201 is labeled “FE 140101,102” and “FE 140102”, the
pressure gauges PIT -140101 and PIT-140201 are labeled “PIT 140101,102”, the pressure gauges
PG-130102, PG-130202, and PG-130302 are labeled “PG 130102,202,203”.
18. Sheet C8.0 (WWLS-CIP) –
a. Please include and label the turbidity meter drain shown as influent to the washwater lift station
(WWLS) on Sheet HNC-I-19 of the P&ID.
b. The pipe section on the “Washwater Lift Station Section” is labeled “WW LS Effluent”.
Should this be the permeate pump effluent? Please verify and revise, if necessary.
c. There are two influent lines from the permeate pumps and turbidity meter drain (excluding the
peracetic acid chemical feed) and three effluent lines to the fine screens, CIP system, and high-
rate infiltration basins depicted on Sheet HNC-I-19 of the P&ID. This does not correspond to
the section/plan views on this sheet. Please verify and revise.
d. The two components labeled “PS-10-01” and “HP-10-01” on the “Washwater Lift Station/CIP
Plan” are not included in the P&ID. Please verify and revise.
e. The text labels for valves, gauges, meters, etc. on this sheet do not correspond to Sheet HNC-
I-19 of the P&ID. Please revise for consistency.
19. Sheet C11.1 (Seeding Specifications/Erosion Control Details) – This sheet is missing a sheet
number in the title block. Please revise.
G. Engineering Plans (P&ID):
1. Overall – The listed volumes for treatment units are inconsistent with the remainder of the
application package. Please verify and revise.
2. Sheet HNC-I-04 (Equalization Basin) –
a. Please complete the left side sheet connection symbol and pipe number.
b. Please specify the existing volume of the equalization basin (EQ-01).
c. The ball valves BV-0301 and BV-0302 are depicted and labeled as gate valves on Sheet C2.3
of the Engineering Plans. Please verify and revise.
d. The pipe 6”-PVC-RAS-001 from EQ-01 is labeled “6”-PVC-INF-001” on Sheet HNC-I-05.
Please revise for consistency.
3. Sheet HNC-I-05 (Fine Screens) –
a. The waste activated sludge (WAS) pipe 3”-WAS-PRM-001 additionally specifies PVC as the
pipe material on Sheet C9.0 of the Engineering Plans. Please revise for consistency.
b. The left side sheet connection symbol for PW-002 includes “W3” on Sheet HNC-I-19. Please
revise for consistency.
c. Should the sheet connection symbol for the WAS from the WAS pumps have a letter/number
designation (e.g., A1) per Sheet HNC-I-02 since it is included in this contract? Please verify
and revise, if necessary.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 6 of 10
4. Sheet HNC-I-06 (Pre-Anoxic Basin) – The slide gate depicted in the pre-anoxic basin (PAX-01)
uses a weir symbol instead of the slide gate symbol shown on Sheet HNC-I-03. Please revise.
5. Sheet HNC-I-07 (Pre-Aeration Basin 01) –
a. Please revise the pipe “8”-304SS-PA-XXX” to “8”-304SS-PA-001” next to sheet connection
symbol V1 for consistency with Sheet HNC-I-14.
b. Please revise “AX-01” to “PAX-01” on sheet connection symbol B1.
c. Please revise the pipe “1/2”-TUBE-NaOH-002” to “1/2”-TUBE-NaOH-001” next to sheet
connection symbol A2 for consistency with Sheet HNC-I-17.
6. Sheet HNC-I-08 (Pre-Aeration Basin 02) –
a. Please revise the pipe “8”-304SS-PA-XXX” to “8”-304SS-PA-002” next to sheet connection
symbol W1 for consistency with Sheet HNC-I-14.
b. Please revise “AX-01” to “PAX-01” on sheet connection symbol C1.
c. Please revise the pipe “1/2”-TUBE-ALUM-001” to “1/2”-TUBE-ALUM-002” next to sheet
connection symbol Z2 for consistency with Sheet HNC-I-17.
7. Sheet HNC-I-09 (FF & IR Pumps) – The FF/IR influent pipe 12”-PVC-FF/IR-001 and 12”-PVC-
FF/IR-002 are labeled 10” on previous sheets. Please revise for consistency.
8. Sheet HNC-I-10 (Post-Anoxic Basin) – See Comment G.4.
9. Sheet HNC-I-11 (Membrane Basin 01) – The effluent pipe 10”-PVC-RAS-001 is labeled as DIP
for its entire length on Sheet C5.1. Please revise for consistency.
10. Sheet HNC-I-12 (Membrane Basin 02) – See Comment G.9.
11. Sheet HNC-I-13 (Permeate Collection) –
a. Please revise the sheet connection symbol “N1” to “M1” for consistency with Sheet HNC-I-
11.
b. There are no pipe sizes specified on the reducer between butterfly valves BF-1301 and BF-
1302. Please revise.
c. There are two pressure gauges labeled “PG-130202”. Please revise.
d. Please revise “Typ. 2” to “Typ. 3” for the instrumentation/controls of the permeate pumps.
e. Please indicate which sheet the turbidity meter drain connects to. Sheet HNC -I-19 lists it on
the left side with a sheet connection symbol and pipe number.
f. There are no pipe sizes specified around ball valve BV-1301. Please revise.
g. Please add a pipe number for the permeate to the WWLS.
h. Should the sheet connection symbol for the permeate to the WWLS have a letter/number
designation (e.g., A1) per Sheet HNC-I-02 since it is included in this contract? Please verify
and revise, if necessary.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 7 of 10
12. Sheet HNC-I-14 (WAS Pumps) –
a. See Comment G.3.a.
b. The valves, gauges, meters, etc. associated with the WAS pipe 3”-WAS-PRM-DIG-001 are
duplicates of the ones above. Please revise to be consistent with Sheet C9.0 of the Engineering
Plans.
13. Sheet HNC-I-15 (MBR & PA Blowers) –
a. There are many valves missing pipe sizes and numbers on this sheet. Please verify and revise.
b. There are three ball valves labeled “BV-1402” and three pressure gauges labeled “PIT-
140201”. Please verify and revise to be consistent with the Engineering Plans.
14. Sheet HNC-I-16 (Clean-In -Place) –
a. The left side sheet connection symbol for PW-001 includes “W2” on Sheet HNC-I-19. Please
revise for consistency.
b. Only one (1) chemical drum/chemical drum pump is shown for the CIP system while two (2)
chemical drums/chemical drum pumps are depicted on Sheet C8.0 and one (1) duty/one (1)
shelf spare are listed on Page 140 of the Specifications. Please verify and revise.
c. The pipe sizes for the reducer next to ball valve BV-1602 appear to be flipped. Please verify
and revise.
15. Sheet HNC-I-17 (Alum & NaOH Injection) –
a. Chemical storage is shown as open atmosphere tanks (TK-001 and TK-002) on this sheet but
as chemical drums on Sheet C10.0 of the Engineering Plans. Please verify and revise.
b. There are two chemical feed lines labeled “1/2”-TUBE-ALUM-001” and two chemical feed
lines labeled “1/2”-TUBE-ALUM-002”. Please verify and revise.
c. Should the sheet connection symbol for the WAS to the fine screens have a letter/number
designation (e.g., A1) per Sheet HNC-I-02 since it is included in this contract? Please verify
and revise, if necessary.
16. Sheet HNC-I-18 (Carbon Injection) – See Comment G.15.a.
17. Sheet HNC-I-19 (Washwater Lift Station) –
a. Should the sheet connection symbol for the permeate and turbidity meter drain have a
letter/number designation (e.g., A1) per Sheet HNC-I-02 since they are included in this
contract? Please verify and revise, if necessary.
b. Please revise the sheet title from “Carbon Injection” to “Washwater Lift Station” for
consistency with the drawing list on Sheet HNC-I-01.
c. The four (4) ball valves on this sheet use a plug valve symbol instead of the ball valve symbol
shown on Sheet HNC-I-03. Please revise.
d. Please revise “Sht. 4” to “Sht. 5” under the sheet connection symbol W3.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 8 of 10
H. Specifications:
1. Overall –
a. Many of the headers for the “Kubota Supplied Equipment” section list “Section IV” instead of
“Section V”, which differs from the Table of Contents. Please revise.
b. Please provide the applicable specifications for the grinder station pursuant to Instruction J of
Form: HRIS 06-16 and 15A NCAC 02T .0704(c)(2).
2. Section V-D (FF/IR & WAS Pumps) – The specified duty point of 1,563 gallons per minute (GPM)
@ 15 feet of total dynamic head (TDH) for the FF/IR pumps (Page 85) differs from the Engineering
Calculations, which list 1,634 GPM @ 16.1 feet of TDH. Please verify and revise.
3. Section V-F (Chemical Feed Pumps) – Page 99 does not include the peracetic acid chemical feed
pumps nor is it listed anywhere else in the Specifications. Please revise.
4. Section V-H (Membrane and PA Blowers) – Page 110 lists a total of two (2) PA blowers comprised
of one (1) duty/one (1) common standby, while the Engineering Plans (including the P&ID) depict
a total of three (3) PA blowers comprised of two (2) duty/one (1) common standby. Please verify
and revise.
I. Engineering Calculations:
1. Overall – Please provide (1) the sizing calculations for the proposed automatically activated
standby generator and (2) flotation and pump sizing calculations for the grinder station pursuant to
Instruction K of Form: HRIS 06-16 and 15A NCAC 02T .0704(c)(3).
2. Appendix E (Biological Process Calculations) – The required pre-aeration volume calculations list
a negative result. Please clarify.
3. Appendix I (Commonwall Tank, Control Building Slab Calculations & Geotechnical Engineering
Report) –
a. A North Carolina licensed Professional Engineer (PE) did not sign, seal, and date t he
Geotechnical Engineering Report completed by S&ME, Inc. Please provide this pursuant to
Instruction K of Form: HRIS 06-16 and 15A NCAC 02T .0704(c)(3).
b. The Geotechnical Engineering Report does not discuss the existing borrow area located
between monitoring wells MW-1 and MW-4, which typically contains water. Please discuss
whether the Permittee is proposing any structures within or adjacent to the existing borrow area
and provide specific recommendations for these structures, if necessary.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 9 of 10
J. Site Map:
1. Pursuant to Instruction L of Form: HRIS 06-16 and 15A NCAC 02T .0704(d), please revise the
Site Map to include the following:
a. All facility-related structures within the wastewater treatment, storage, and infiltration area,
which shall include the equalization tank, aerobic digester, passive groundwater lowering
system (GWLS), and piping/valving from the high-rate infiltration basins and passive GWLS
to the groundwater storage pond and NPDES outfalls. See Comment A.1.
b. The existing borrow area and its proximity to the proposed 500,000 GPD treatment train. The
latest aerial imagery appears to show the existing borrow area acting as a surface water feature,
which would require a 50 foot setback pursuant to 15A NCAC 02T .0706(d) unless further
justification and/or clarification is provided. See Comment I.3.b.
c. Setbacks pursuant to 15A NCAC 02T .0706 for all wastewater treatment/storage facilities and
infiltration sites.
K. Power Reliability Plan:
1. See Comment I.1.
L. Operation & Maintenance Plan:
1. The submitted O&M Plan is for the previous 250,000 GPD treatment train that the Division added
to the Final Permit issued on April 29, 2025. The issued Final Permit will include a Compliance
Schedule to submit an amended O&M Plan prior to the operation of the modified facilities pursuant
to 15A NCAC 02T .0108(b)(1)(B) and 02T .0707(a). No response is required.
2. Mr. Bryan K. Lievre of the Raleigh Regional Office (RRO) has reviewed the application package
and requests that the Permittee adds the following contact numbers to the O&M Plan: NCDEQ
Environmental Emergency Contact (Non-Business Hours) 1-800-858-0368, owner and regional
contacts, and any other the Permittee feels may be appropriate (e.g., poison control, etc.) No
response is required.
M. Residuals Management Plan:
1. No comment.
N. Additional Documentation:
Certificate of Public Convenience and Necessity:
1. No comment.
Existing Permit:
1. See Comment A.1.
2. See Comment D.1.
Mr. Maurice W. Gallarda, PE
May 31, 2024
Page 10 of 10
Threatened or Endangered Aquatic Species Documentation:
1. No comment.
O. Recommendations (Response not required):
1. Overall – Mr. Bryan K. Lievre of the RRO completed a site visit on September 9, 2023, and noted
the following items for future consideration given the increased development in the area:
a. There is a potential need to upgrade screening in the equalization tank as the operator must
manually remove debris from the static screen/trash rack and some large debris may escape
removal.
b. Wastewater odors are noticeable as one approaches the facility’s entry gate.
c. Flies have become abundant during recent site visits around the blower building and tanks.
2. Engineering Plans –
a. Overall – Recommend adding section view labels to the corresponding plan views for clarity.
b. Sheet C1.4 (Plant Equipment Spreadsheet) – Recommend repeating the header row at the top
of this sheet.
c. Sheet C2.1 (Site Map) – Recommend revising the typo in “Future Development".
d. Sheet C2.6 (Profile 3) – Recommend moving the text label on the profile view of the
directionally bored pipe up for clarity.
e. Sheet C8.0 (WWLS-CIP) – Recommend removing the stray arrows above the “Washwater Lift
Station/CIP Plan”.
f. Sheet C10.0 (Process Control/Yard Hydrant Locations) – Recommend removing the stray
arrows on either side of the PA basins.
3. Engineering Plans (P&ID) –
a. Overall – Recommend adding the missing “2” in the top-right corner of the grid template.
b. Sheet HNC-I-12 – Recommend revising the sheet title to “Membrane Basin 02” for consistency
with Sheet HNC-I-11.
c. Sheet HNC-I-14 – Recommend removing the stray line under the flow meter FE/FIT-170101.
d. Sheet HNC-I-16 – Recommend shifting the sheet back within the plot view to match the other
sheets.