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Access risers (indicated as 24" for septic tanks, 30" for surge/dosing tank) inadequate <br />for physical entry; normally minimum 36 to 48 inches with ladder required for entry. <br />The above operational issues should be addressed or the design modified to eliminate the <br />anticipated risks and problems. The rational for proposing such deep tanks and sewer lines is <br />unclear. <br />3. Problematic Effluent Sewer Design. The effluent sewer design which incorporates a dozen <br />or more conventional sewer manholes is problematic and contrary to industry practice for <br />effluent sewer systems conveying septic tank effluent. Sewer manholes are unnecessary since <br />the sewage solids are retained in the septic tanks. More importantly, concrete manholes (not <br />vented) will rapidly deteriorate from the corrosive gases given off by the anaerobic septic <br />tank effluent passing though the pipes. They will be a constant source of nuisance odors — <br />and also a potential safety issue due to collection of hazardous gases. Conveyance of septic <br />tank effluent from septic tanks to the surge/dosing tank should be via fully sealed piping. The <br />only access to the pipes (e.g., for flushing) should be through capped clean -outs installed at <br />various points in the collection system. Also, for the deep sewer line depth proposed, the <br />manholes will introduce additional points of entry for groundwater infiltration into the <br />wastewater system, which has very limited capacity for extraneous water. <br />4. Filter Bed Drain Rock Depth. Detail 9 ("Leach Field Line") on Sheet C7.3 indicates an 8 - <br />inch depth of drain rock below the 4" perforated pipe; 12 inches is required. <br />APPENDIX A — NITRATE LOADING STUDY (Chesney Consulting, dated May 6, 2019) <br />The appended Nitrate Loading Study by Chesney Consulting utilizes an annual chemical -water <br />mass balance analysis (per Hantzsche-Finnemore Equation) to estimate the nitrogen loading <br />impact on groundwater from onsite disposal of wastewater for the E&E Trading project. <br />The analysis projects a resultant percolate concentration of 1.55 mg-N/L reaching the <br />groundwater table, averaged over the 42 -acre footprint of the E&E Trading project site. This is <br />compared against the drinking water nitrate -nitrogen standard of 10 mg-N/L to conclude that the <br />discharge is within appropriate Iimits and will not significantly degrade groundwater quality. <br />Comments: <br />Methodology. The mass balance analysis per the Hantzsche-Finnemore Equation is a <br />simplified method for assessing wastewater -nitrogen loading for typical rural residential <br />properties served by septic systems. It doesn't explicitly account for large amounts of <br />impervious surface, nor drainage retention facilities, as proposed for this proposed project. <br />The improvement plans indicate nearly the entire site will be covered with buildings and <br />paving, leaving very limited amount of open land area for deep percolation/recharge. The <br />rainfall -runoff from impervious surfaces is planned to be collected and routed to an adjacent <br />detention/retention basin for percolation and downstream discharge. The concept and <br />