WQ0034981_Pre-Review Return_20221102

November 2, 2022
T RAVIS B UTCHER P UBLIC W ORKS D IRECTOR
T OWN OF E LKIN
P OST O FFICE B OX 857
E LKIN, N ORTH C AROLINA 28621
Subject: Application No. WQ0034981
Permit Application Return
Town of Elkin Class A
Residuals Program
Residuals Management System
Surry County
Dear Mr. Butcher:
This letter is in reference to your permit renewal request received September 13, 2022.
During the pre-review process, it was noted that the following items were missing from the
submitted application package:
1. Please complete Application Items 2, 3, 4, 5, and 6 in Section IV of the submitted Distribution
of Class A Residuals application (Form: DCAR).
2. Please sign the Applicants Certification on Page 6 of Form: DCAR.
3. Pursuant to Application Instruction D on Form: DCAR, provide Program Information that
includes:
Provide a narrative explaining:
o How the materials will be handled and transported from where the residuals were
produced to where it will be treated.
o How the residuals will be processed/treated (attach process flow diagram).
o How leachate collection will be handled.
o Where the residuals will be stored until processed.
o How the final product will be distributed (packaging, bulk, etc.)
o What nutrients or other constituents (i.e., nitrogen, phosphorous, aluminum, calcium,
etc.) are used or recommended as the limiting parameter for determination of residuals
loading rate to ensure that it does not overload the soil and cause contravention of
surface water or groundwater standards, limit crop growth, or adversely impact soil
quality.
Attach a marketability statement detailing destinations and approximate amounts of the
final product to be distributed.

Mr. Travis Butcher
November 2, 2022
Page 2 of 4

Provide either a label that shall be affixed to the bagged processed residual or an
information sheet that shall be provided to the person who receives the processed residual.
The label or information sheet shall contain, at a minimum, the following information:
o Name and address of the person who prepared the residual that is sold or given away.
o A statement that application of the residuals to the land shall be in accordance with the
instructions on the label or information sheet.
o A statement that the residuals shall not be applied to any site that is flooded, frozen or
snow-covered.
o A statement that adequate procedures shall be provided to prevent surface runoff from
carrying any disposed or stored residuals into any surface waters.
o Information on all applicable setbacks in accordance with 15A NCAC 02T .1108(b).
o A statement that the residuals shall be applied at agronomic or recommended rates for
intended uses.
4. Pursuant to Application Instruction H on Form: DCAR, provide an Operation and Maintenance
Plan in accordance with 15A NCAC 02T .1110 that includes:
Operational functions; describe the operation of the program to show what operations are
necessary for the program to function and by whom the functions are to be conducted.
Maintenance schedules; may include equipment calibration, maintenance of signs, etc.
Safety measures; may include safety training program, manuals, signs, etc.
Spill response plan; including control, containment, remediation, emergency contact
information, etc.
Inspection plan including the following information;
o Names and titles of personnel responsible for conducting the inspections.
o Frequency and location of inspections, including those to be conducted by the ORC,
and procedures to assure that the selected location(s) and inspection frequency are
representative of the residuals management program.
o Detailed description of inspection procedures including record keeping and actions to
be taken by the inspector in the event that noncompliance is observed.
Sampling and monitoring plan including the following information;
o Names and titles of personnel responsible for conducting the sampling and monitoring.
o Detailed description of monitoring procedures including parameters to be monitored.
o Sampling frequency and procedures to assure that representative samples are being
collected. Fluctuation in temperature, flow, and other operating conditions can affect
the quality of the residuals gathered during a particular sampling event. The sampling
plan shall account for any foreseen fluctuations in residuals quality and indicate the
most limiting times for residuals to meet pathogen and vector attraction reduction
requirements (e.g., facilities that land apply multiple times per year but have an annual
sampling frequency, may need to sample during winter months when pathogen
reduction is most likely to be negatively affected by cold temperatures.

Mr. Travis Butcher
November 2, 2022
Page 3 of 4

5. Please complete Section V of the submitted Distribution of Class A Residuals application
(Form: DCAR). A copy of the Residuals Source Certification form (Form: RSC) is attached
for your use.
6. Pursuant to Application Instruction B on Form: RSC, submit a vicinity map for each residuals-
source generating facility that shows the location of the facility and meets all of the criteria in
Map Guidance for Residuals Land Application Permits
7. Pursuant to Application Instruction B on Form: RSC, submit a detailed narrative and/or process
flow diagram for each residuals-source generating facility that describes how the residuals are
to be generated, treated, processed, and stored at the facility.
8. Pursuant to Application Instruction B on Form: RSC, submit a quantitative justification for the
value provided in Item I.8. Ensure that the amount of residuals listed is the maximum amount
expected to be generated by the facility for the life of the permit. In addition, ensure that this
amount is equivalent to that which is actually to be land applied, distributed, and/or disposed,
including any chemicals, amendments, or other additives that are added to the residuals during
processing.
9. Pursuant to Application Instruction B on Form: RSC, submit a detailed sampling plan for the
residuals source-generating facility. Ensure that the plan identifies sampling points, sampling
frequency, sample type, as well as the Division-certified laboratory to be used. In addition,
ensure that the plan details how the facility and/or the residuals are monitored for any applicable
pathogen reduction and vector attraction reduction requirements. Note that all sampling and
monitoring must be completed on the residuals as they are to be land applied, distributed, and/or
disposed.
10. Pursuant to Application Instruction C on Form: RSC, submit the laboratory analytical reports
and operational data - reports for all laboratory analyses used to complete this certification.
11. Pursuant to Application Instruction C on Form: RSC, submit documentation that each
residuals-source generating facility complies and/or the residuals comply with any applicable
pathogen reduction and vector attraction reduction requirements.
Accordingly, your permit renewal request is being returned as incomplete pursuant to 15A NCAC
02T .0107(b).
The success of th-Discharge Branch process depends
upon the receipt of complete and accurate applications and supporting documentation. Please amend the
application package to include the previously noted omitted items and resubmit with the appropriate permit
processing fee. When resubmitting, please submit the application electronically as a single PDF at:
https://edocs.deq.nc.gov/Forms/NonDischarge-Branch-Submittal-Form-Ver2.
Please be advised that construction and/or operation of the subject facilities without a valid
permit is a violation of G.S. 143-215.1, and may subject you to appropriate enforcement actions
pursuant to G.S. 143-215.6A., 6B., and 6C. Civil penalties of up to $25,000 per day per violation may
be assessed for failure to secure a valid permit.

Mr. Travis Butcher
November 2, 2022
Page 4 of 4

If you need additional information concerning this letter, please contact me at [phone] or
[e-mail].
Sincerely,
Nathaniel D. Thornburg, Branch Chief
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)