WQ0001271_Additional Information Request_20200204

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Ditrcror
NORTH CAROLINA
Environmental Quality
February 4, 2020
MILTON S. VANN — WASTEWATER SUPERINTENDENT
CAPE FEAR PUBLIC UTILITY AUTHORITY
235 GOVERNOR CENTRE DRIVE
WILMINGTON, NORTH CAROLINA 28403
Subject: Application No. WQ0001271
Additional Information Request
CFPUA RLAP
Land Application of Class B
Residuals
New Hanover County
Dear Mr. Vann:
Division of Water Resources' Central and Regional staff has reviewed the application package
received November 26, 2019. However, additional information is required before the review may be
completed. Please address the items on the attached pages no later than the close of business on March 5,
2020.
Please be aware that you are responsible for meeting all requirements set forth in North Carolina
rules and regulations. Any oversights that occurred in the review of the subject application package are
still the Applicant's responsibility. In addition, any omissions made in responding to the outstanding items
in Sections A through E, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete.
Please reference the subject application number when providing the requested information. All
revised and/or additional documentation shall be signed, sealed and dated (where needed), with two paper
copies and one electronic copy submitted to my attention at the address below.
If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3659 or [e-mail]. Thank you for your cooperation.
Sincerely;
L j1,✓� ✓l Ly i, '.
Erick Saunders, Eh/ infer
Division of Water Resources
cc: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Nate Roth — Synagro, LLC (Electronic Copy)
Permit Application File WQ0001271
D El Q_''. North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
°gi°°'m'�°ntl.Oi""""I\ 919.707.9000

Mr. Milton S. Vann
February 4, 2020
Page 2 of 4
A. Setback Waivers:
1. The submitted application maps for the following fields include reduced setbacks between residuals
land application fields and habitable residences or places of assembly under separate ownership.
These are shown on the maps as a reduced setback around an offsite house that is labeled "BW-#".
However, any previous setback waivers would no longer be in effect without a new waiver being
submitted with this application. The following application maps included reduced setbacks to
offsite houses.
➢ NC-CO-21 Fields 1-3
➢ NC-CO-30 Fields 1-5 — This residence appears to be owned the same as the owner of these
fields (Hubert D. and O. Malette Godwin) so it may be considered an ` onsite house".
➢ NC-CO-30 Fields 6-7
➢ NC-CO-164 Fields 2, 4, 5, 8, 9
➢ NC-PE-03 Fields 1-2
The submitted Land Application Site Certification form (LASC 06-16), Land Owner Agreement
forms (LOA 06-16), and site maps presume that these setback waivers are still active. In order to
be able to use the full extents of these fields, new setback waivers must be obtained from the owners
of these properties. These setback waivers must be submitted in accordance with 15A NCAC 02T
.1108(e) in that they shall be written, notarized, signed by all parties involved, and recorded with
the county Register of Deeds. A copy of a residuals setback waiver is attached.
If a setback waiver cannot be obtained for a field, the effected field must be buffered out so that it
is in compliance with all the 15A NCAC 02T .1108(c) setbacks for habitable residences or places
of assembly under separate ownership. The new acreage for any reduced field shall be resubmitted
in an updated LASC 06-16 form.
B. Compliance Boundary 115A NCAC 02T .0105(h)l:
1. The following fields were marked in section III of the Land Owner's Agreement (LOA 06-16)
forms as needing re -defined compliance boundaries.
a. NC-BR-21-01
b. NC-CO-08-01
c. NC-CO-16-02 and 04B
d. NC-CO-17-OIA
e. NC-CO-21-02
f NC-CO-22-01 and 09 (mislabeled as NC-21-01 and 09 on the LOA)
g. NC-CO-20-01, 02, 03, 06, 08, 09, and 10
h. NC-CO-30-01 and 03
i. NC-CO-36-03
j. NC-CO-37-03
k. NC-CO-60-02, 04, and 05
1. NC-CO-164-04, 08, and 09
in. NC-PE-03-02
The submittal did not include the rationale for the requested re -location of the compliance boundary
and these changes were not included in the maps. Please submit this information. Please note that
the re-established compliance boundary must be delineated or included in a footnote describing the

Mr. Milton S. Vann
February 4, 2020
Page 3 of
redefined compliance boundary in accordance with the June 9, 2011 memo "Map Guidance for
Residual Land Application Fields" and the January 31, 2007 memo "Alternatives for Water Supply
Wells Inside the Compliance Boundary'.
C. Application:
1. Milton S. Vann did not sign the Permittee's Certification in the Landowner's Agreement form for
Fields NC-BR-21. Please have Mr. Vann or another signature authority sign to certify that the
Permittee agrees to the stipulations and restrictions of this document for these fields.
2. The field owners for the fields in NC-CO-22 do not correspond to the actual owners of the fields
according to the Columbus County GIS. Fields 1 and 2 are located primarily on the land of Saundra
Amos, but was signed for in the Landowner's Agreement by Isaac Pridgen. Field 4 was signed by
Carol P. Henry, but the field is owned by Isaac Pridgen. Page 1 of the LOA 06-16 forms shall be
updated to reflect the correct owners of the fields based on what parcel they are on. Please also see
D.4. of this request that has to do with these fields as well.
D. Site Map:
1. There is a parcel (parcel #94723 in Columbus County) within the application area for field NC-
CO-16-02 which is not owned by the Landowner who signed the LOA. The parcel shall be shown
on an updated site map, along with the appropriate property line buffers. If this buffer encroaches
on the field, the new acreage for this field shall be resubmitted in an updated LASC 06-16 form.
2. Fields NC-CO-17-01A and 0111 located on parcel 28884 in Columbus County was sold by Nelson
Applewhite to Giles Edwin Byrd in 2019. Please have Mr. Byrd sign the Landowner's Agreement
form (LOA 06-16) in order to be able to use these fields in the pemilt. If this Landowner's
Agreement cannot be obtained, then the fields shall be removed from the application and removed
in an updated LASC 06-16 form.
3. Field NC-CO-21-03 is located on 5 different parcels that are not owned by the Landowner who
signed the LOA 06-16. The parcel shall be shown on an updated site map, along with the
appropriate property line buffers. If this buffer encroaches on any NC-CO-21 field, the new
acreages for these fields shall be resubmitted in an updated LASC 06-16 form.
4. The fields in NC-CO-22 are located on parcels that are two separate owners, Isaac Pridgen and
Saundra Amos. Some of these fields are located between the two properties. However, the property
line setbacks are supposed to be applicable unless the permittee, the entity from which the permittee
is leasing, or the entity that executed the notarized landowner agreement owns both parcels
separated by the property line [15A NCAC 02T .1108(f)]. As there are two separate owners for
these parcels, the appropriate 50 foot buffer shall be applied on the property line between properties
087709 and 004207. This buffer shall be shown on an updated site map and the new acreages for
these fields shall be resubmitted in an updated LASC 06-16 form. Please also see the comments to
C.2. of this request.
5. Part of field NC-CO-29-01 is located on parcel 099093 in Columbus County (previously where
field NC-CO-29-11 was located) which is owned by Penelope R. Obrecht. The appropriate property
line buffers shall be shown on an updated map, and the new acreage of this field shall be
resubmitted in an updated LASC 06-16 form.

Mr. Milton S. Vann
February 4, 2020
Page 4 of 4
6. There are three offsite houses shown on the map for NC-CO-29 located on parcels 93446, 063377
and 060724 in Columbus County that were not buffered out. The house on parcel 093446 was
shown as an onsite house, but is owned by Dalan and Shonna Hobbs. The other two were listed as
offsite houses but no buffer was applied. The appropriate buffer for habitable residences under
separate ownership shall be applied to these residences, or an explanation shall be given as to why
these houses were not buffered out. If these buffers encroach on the existing field, then the field
shall either be reduced, or a setback waiver shall be obtained for these residences. Any changes to
the field area shall be shown on the updated LASC 06-16 form.
7. There is a house on parcel 085384 in Columbus County owned by Ellerbe Hazel that has a residence
that was not shown on the map for NC-CO-37-01. The residence shall be shown on an updated site
map, along with the appropriate buffers. If these buffers encroach on the existing field, then the
field shall either be reduced, or a setback waiver shall be obtained for this residence. Any changes
to the field area shall be shown on the updated LASC 06-16 form.
E. GeneralOuestions:
The Operational Functions section of the Operation and Maintenance (O&M Plan that was
submitted in this renewal indicates that sludge from the Sweeny WTP is piped and dewatered at
the Nouthside W WTP. All dewatered residuals from the Northside W WTP to the Southside W WTP
where everything (i.e. dewatered residuals from all three sources) is blended.
The footnotes 7-16 in the current Attachment A that was certified March 17, 2016 indicate that
there is land application of residuals that have not been prepared in this manner. For example,
footnote describes that liquid residuals can be land applied directly from the Sweeny WTP directly
without needing to be blended. Footnote 11 describes the same thing for residuals from Nouthside
WWTP. Please clarify whether the submitted operational functions are accurate regarding the
blending and land application of the residuals (i.e. does land application occur of residuals not
prepared in accordance with the submitted O&M plan where all three sources are blended).