WQ0044990_More Information (Requested)_20240223

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS,]R.
Director
ABIGAIL F. SIEGRIST
168 MURPHY DRIVE
HIGH POINT, NORTH CAROLINA 27265
Dear Mrs. Siegrist,
NORTH CAROLINA
Environmental Quality
February 23, 2024
Subject: Application No. WQ0044990
Additional Information Request #1
312 Reese Rd. SFR
Single -Family Residence
Wastewater Irrigation System
Davidson County
Division of Water Resources' Central and Regional staff have reviewed the application package
received on December 7, 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 March 25,
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 F 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
cord.anthony(j�deq.nc.gov. Thank you for your cooperation.
Docu Signed by:
Sincerely, E
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2D03237162FA4E5...
Cord Anthony, Engineer II
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
David C. Barcal, PE — MacConnell & Associates, P.C. (Electronic Copy)
Laserfiche File (Electronic Copy)
North Carolina Department of Environmental Quality I Division of Water Resources
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512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
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919.707.9000

Mrs. Abigail F. Siegrist
February 23, 2024
Page 2 of 4
A. Setback Waivers:
1. The 100 foot irrigation setback illustrated on the sitemap shows a structure located on Parcel No.
6861-03-40-8300 similar to the structure for which the setback waiver included with the permit
application was filed for. Please clarify if this structure is fit for occupation, a general-purpose shed,
or something else altogether. If it is a habitable residence or place of assembly, please procure a
setback waiver allowing irrigation within 100 feet of the structure.
2. The drip irrigation field located at the top right-hand corner of the parcel owned by Mrs. Siegrist.
Based on GIS data, the edge of the irrigation zone is within approximately 20 feet of the property
line shared with Parcel 6861-03-40-6401 owned by Wendy Leigh Smith. Please procure a setback
waiver allowing irrigation within 50 feet of this property line.
B. Soil Evaluation:
1. Per 15A NCAC 02T .0604(b)(2), Ksat values are to be based upon the most restrictive horizon.
The soils report, however, states that the Ksat has been measured in the "least restrictive horizon".
Please clarify and or update the soils report.
2. No soil delineated map has been included. Per 15A NCAC 02T .0604(b)(3), a soil delineated map
shall be included within the soil evaluation. Please provide this documentation. Additionally,
Caitlin Caudle of the Winston-Salem Regional Office noted that "PnE and PnD are both in the
immediate area. Slopes for PnE are 15-25% and PnD are 8-15%. A soil map is needed to show the
location of the drip field in relation to mapped soil series.".
3. During a site visit conducted on January 29, 2024, regional staff performed additional borings and
found that the soil within the application area was more variable than observed soils described by
the licensed soil scientist in their report. More specifically they noted that "...descriptions are
within range of Poindexter and Wynott. The described soils appear to be more variable than
described by the LSS. Field observations do suggest a perched water table".
Then, on a subsequent visit performed on February 6, 2024, regional staff noted the following:
"The additional borings confirm that the observed soils are more variable than described by the
LSS. With the additional borings, staff believe that an eroded Enon phase is a more accurate soil
series.
The perched water table was evident around 20" based on the standing water observed in CLC2
and clay film encountered in CLCS at 21 ". The gray green colors are caused by the parent material,
which was visible in an eroded area. Expansive clay was encountered at 4-26" in staff borings.
Due to the lack of flagging or clear demarcation, it was unclear where the proposed application
area was. The application area could include a mowed path with evidence of traffic. The path would
be more compacted than the surrounding soils, limiting infiltration potential. There are also open
pits reportedly used for soil description purposes that will need to be filled in before drip lines are
installed."
Please respond to the above concerns and give insight into why the soil series differs from field
observations performed by regional staff.

Mrs. Abigail F. Siegrist
February 23, 2024
Page 3 of 4
4. Regional office staff member Caitlin Caudle noted the following in her staff report regarding the
soil scientist evaluation:
a. Soil profiles describe IOYR 6/1 mottles in Bt (4- —20") but no SHWT was specified and there
was no discussion of lithochromic features. Form: SFRWWIS 06-16 section VII.3 then lists
the SHWT as 1.5ft. The soil boring log shows SHWT at 12-14". Please clarify where the SHWT
occurs.
b. Listed the geologic unit as intermediate mafic unit, I found the system is located in the Charlotte
Belt unit.
c. Stated ksats were only measured in Bt horizon because lower horizons were too thin or had
poor structure. Poor structure can also limit movement of effluent. Why wasn't a ksat completed
in lower horizons? C horizon was described as very firm, very sticky, and structureless. The C
horizon is > 10" when described.
d. Ksat Nest 2 had a significantly lower measurement than the other two nests and the
corresponding soil description describes a CR horizon starting at 19-20". Please give insight
into the utilization of these values given the variance from the other Ksat nests.
Please respond to the above concerns regarding the location of the SHWT, the overall geology of
the site, and the measured saturated hydraulic conductivity.
C. Engineering Plans:
1. Winston-Salem Regional Office staff member Caitlin Caudle noted that "Soil profiles show that
CR is as shallow as 24".". This would indicate that some excavation into bedrock would be
occurring. Please confirm whether this is the case. If it is then please note that, per 15A NCAC 02T
.0605 d the Permittee shall line any excavation into bedrock with a 10 millimeter (mm) synthetic
liner.
D. Engineering Calculations:
1. The annual loading rate provided by the included calculations is 14.03 inches per year while Form:
SFRWWIS 06-16 lists the design rate as 32.23 inches per year.
The engineer calculations state the drip area is 5,007 square feet (0.1149 acres). Section VIIA of
Form: SFRWWIS 06-16 lists the drip field area as 0.20 acres. This acreage is also not included on
the engineering plans.
The numbers found within the calculation only result in an irrigable capacity of 120 gallons per
day, which is below the 270 gallons per day required for this system. Please review the calculations,
confirm the acreage and irrigation rate, and make any necessary changes to the design and/or
application.

Mrs. Abigail F. Siegrist
February 23, 2024
Page 4 of 4
E. Site May:
1. A stream is shown on both plans and the soil scientist report. The soil map shows a 100' setback
from the stream; however, the engineering plan set list this same setback as a 50' buffer zone, which
would be less than the required 100' setback from the stream. Please double check this setback and
make any necessary revisions.
2. No soil mapping units are included within the site map. Please represent the soil mapping units on
the site map.
3. Per 15A NCAC 02T .0604(d)(2), a delineation of the review and compliance boundaries shall be
provided. Please specify the location and existence of the compliance boundary (established at the
property line) in addition to the already mapped review boundary.
4. It is unclear if all relevant features within 500 feet of the site have been accounted for. Of note is
the lack of wells for both the Permittee and their neighbors. Please provide the location for any
well(s) within the 500-foot boundary and their relevant setbacks.
F. Recommendations (Response not re(juired):
1. The denial letter and SFR loading worksheet both use 480gpd. The design flow, however, following
the reduction of home size and acquiring of a flow reduction is 270 gpd. It may be worthwhile to
reach out to Davidson County and see if the newly designed flow regime would be low enough to
allow for the use of a subsurface system and/or make a difference in their evaluation.