WQ0010583_Additional Information Request_20220121

January 21, 2022
JOHNNY LAMBERT – UTILITIES DIRECTOR
DAVIE COUNTY
123 SOUTH MAIN STREET
MOCKSVILLE, NORTH CAROLINA 27028
Subject: Application No. WQ0010583
Additional Information Request
Davie County Class B Residuals
Program
Residuals Management System
Davie County
Dear Mr. Lambert:
Division of Water Resources’ Central and Regional staff has reviewed the application package
received November 1, 2021. 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 February
21, 2022.
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 K, 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 an
electronic copy submitted to my attention at the address below or the our upload site (URL:
https://edocs.deq.nc.gov/Forms/NonDischarge-Branch-Submittal-Form-Ver2).

If you have any questions regarding this request, please do not hesitate to contact me at (919) 707-
3660 or [e-mail]. Thank you for your cooperation.
Sincerely,
Lauren Raup-Plummer, Engineer III
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Brent Collins – EMA Resources Inc. (Electronic Copy)
Permit Application File WQ0010583
Mr. Johnny Lambert
January 21, 2022
Page 2 of 4

A. Cover Letter:
1. No comment.
B. Application Fee:
1. Two of the fields were modified to increase acreage beyond updates due to mapping technology
(Fields NC-DV-008-04 and NC-DV-012-03). Increased acreage constitutes a major modification
and will require the appropriate fee (Non-Discharge Application Fees). Please submit the
appropriate major modification fee so that we may proceed with your application review.
C. Application (RLAP 06-16):
1. No comment.
D. Environmental Assessments:
1. Not applicable.
E. Operation and Maintenance Plan:
1. No comment.
F. Residuals Source Certification(s):
1. No comment.
G. Land Application Site Certification(s):
1. The Land Owner’s Agreement (LOA 06-16) was not included in the application submittal for the
property owned by Herbert Eugene Dooley and Jettie Virginia Dooley (Fields NC-DV-012-01
through NC-DV-012-05).
2. Cumulative Pollutant Loading Rate (CPLR) results were not provided for the following fields that
are being renewed with this permit: NC-DV-009-01, NC-DV-009-02, NC-DV-012-03, NC-DV-
012-04, and NC-DV-012-05. The CPLR results are to be determined for these fields in accordance
with 15A NCAC 02T .1105.

Mr. Johnny Lambert
January 21, 2022
Page 3 of 4
H. Site Maps:
1. The field geometry depicted on the site maps for fields NC-DV-008-04 and NC-DV-012-03
includes areas that were not shown in the previously permitted site maps and is considered to be a
modification beyond updated mapping technology. Additional acreage to the north has been
included for NC-DV-008-04, and additional acreage to the west has been included for NC-DV-
012-03. The acreage to the west of NC-DV-012-03 appears to have been hatched out in a
previously provided map, is it an area of unsuitable soils? The increased acreage for these fields
requires a sealed statement from a licensed soil scientist verifying that this new area is represented
by the same soil series as the existing field(s), and that there are no issues with the depth to
groundwater and slope.
2. Within the digital files it is unclear whether 100 ft setbacks are provided for all of the depicted
water supply wells. The on-site well near the middle of the property between fields 07 and 08
appears to be within 100 feet of field NC-DV-008-08. Please note that 15A NCAC 02L .0107(d)
prohibits water supply wells within the compliance boundary. However, 15A NCAC 02T .0105(h)
allows for a re-defined compliance boundary placed closer to the waste disposal area. Please review
and confirm that a re-defined compliance boundary is not needed for this well.
3. Figure 2 for the NC-DV-008 field maps has a considerable scale for the size of the map (1” = 660’)
which makes some of the features difficult to parse out. The aerial base map for Field NC-DV-
008-09, when viewed through mapping software, appears to depict a surface water feature in the
“wet area” that is not shown on the map. It is unclear whether the feature is a stream or drain,
please review and revise the map and setbacks as needed.
4. The maps for Fields NC-DV-009-01 and NC-RO-001-01 indicated setback waivers were required.
Copies of the setback waivers for Fields NC-DV-009-01 and NC-RO-001-01 were not provided in
the submittal and are required for field renewal. Please provide a copy of the associated setback
waivers for these fields.
I. Calculations:
1. Please see Comment 1 under “Lab Results”.
J. Quantitative Justification:
1. No comment.
K. Additional Documentation:
 Existing Permit:
1. No comment.

 Residual Information Sheet:
1. The provided residuals information sheet references permit WQ0002376. The Davie County
Class B Residuals Program is permitted under WQ0010583. Please provide the correct residual
information sheet for this program.

Mr. Johnny Lambert
January 21, 2022
Page 4 of 4
 Lab Results
1. Lab results for nutrient/micronutrient analysis dated 8/10/2021 (provided in the submittal)
depict a significantly higher Sodium Absorption Ratio (SAR) than the values used to fill out
form RSC 06-16 (lab results dated 6/10/21). The RSC 06-16 results also have a notably
different total solids percentage (19.3%) versus those tested on 8/10/2021 (4.35%). Is one of
these results for the material in the holding basin versus what is currently being generated on
site? The PAN values for the residual source certification should be calculated for the most
recent representative sample (dated 8/10/2021). Please clarify and provide additional
information and/or revised calculations. Please note, the application must be revised to reflect
any changes made regarding the PAN loading and required acreage.