WQ0037135_Additional Information Request_20240628

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
ZACHERY D. KEY — PRESIDENT
U.S. BIOSOLIDS, INC.
POST OFFICE BOX 146
RONDA, NORTH CAROLINA 2860
Dear Mr. Key:
NORTH CAROLINA
Environmental Quality
June 28, 2024
Subject: Application No. WQ0037135
Additional Information Request #1
U.S. Biosolids Class B Residuals
Program
Land Application of
Class B Residuals
Wilkes County
Division of Water Resources' Central and Regional staff have reviewed the application package
received on April 1, 2024. 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 July 29, 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 T 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
erickson.saunders(cdeq.nc. og_v. Thank you for your cooperation.
Sincerely,
Erick Saunders, Engineer
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
D EQ �� 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
NORTH CAROLINA -
OepaNnent at EnulmnmeMal Deall 919.707.9000

Mr. Zachery D. Key
June 28, 2024
Page 2 of 5
A.
Overall:
1.
B.
Cover Letter:
1.
No comments.
C.
Application
Fee:
1.
See Comment F.1.
D.
Application
(Form: RLAP 06-16):
1.
No comments.
E.
Operation
& Maintenance Plan:
1.
No comments.
F.
Summary for Form: RSC 06-16:
The proposed maximum dry tons per year for the YVSA WWTP (Permit No. NC0020567) and the
Forest City WWTP (Permit No. NC0025984) are both increasing from their previously permitted
annual dry tonnage. However, the sites are listed as renewed and the quantitative justifications for
each mention the previously permitted value. Please clarify whether this application is requesting
to increase the permitted annual dry tonnage, and note that increasing the permitted tonnage of
either source is a major modification of the permit, requiring a major modification fee for this
renewal.
G. Application (Form: RSC 06-16):
Methyl Ethyl Ketone concentrations were found in elevated levels for several residuals sources,
including the Baxter Healthcare facility, the City of Belmont WWTP (Permit No. NC0021181),
and the Town of Dallas WWTP (Permit No. NC0068888). The result for the Belmont facility even
exceeded the hazardous waste standard of 200 mg/L. Another report was submitted for this facility
that was within standards, but please provide an explanation for these elevated results in several
residuals sources.
2. The City of Belmont's results for ammonia and total Kjeldahl nitrogen (TKN) in Item II.5.b are an
order of magnitude less than what is listed in the submitted lab report. As a result, the plant available
nitrogen (PAN) calculations in Item II.5.e are incorrect. An updated RSC form shall be submitted
with the corrected values and calculations.
3. The PAN calculations in Item I1.5.e appear to be incorrect for the City of Spindale WWTP (Permit
No. NC0020664). An updated RSC form shall be submitted with the corrected values and
calculations.

Mr. Zachery D. Key
June 28, 2024
Page 3 of 5
4. The sodium adsorption ratio (SAR) and the first year PAN for injection/incorporation both appear
to be incorrect for the YVSA WWTP. An updated RSC form shall be submitted with the corrected
values and calculations.
H. Vicinity Maus:
1. No comments.
I. Process Flow Diagram & Narrative:
1. No comments.
J. Quantitative Justification:
1. No comments.
K. Sampling Plan:
1. No comments.
L. Laboratory Analytical Reports:
1. No comments.
M. Pathogen Reduction (PR) & Vector Attraction Reduction (VAR) Compliance Documentation:
1. No comments.
N. Application (Form: LASC 06-16):
1. The soil type in the LASC for Fields NC-RU-NM-01 and 02 is listed as PaB2, but in the most
recent permit the soil types are listed as PaC2. This shall be updated in an updated LASC.
2. The acreage for Field NC-WK-LT-03 is 2.6 acres, but in the most recent permit and the site map it
is listed as 2.3 acres. This shall be updated in an updated LASC.
3. The map for field NC-WK-BP-01 shows the field split into BPI-1 (10.9 acres) and BPI-2 (0.69
acres). The sum of these two acreages is 11.59 acres, but the acreage in the LASC and the previous
permit is 11.04 acres. Please explain the discrepancy between these two values and make any
necessary changes in the application.
4. Based on the site map for NC-WK-CM-02 submitted, subfield 2A to the north of Greenhorn Rd.
has been removed. This subfield is on Parcel No. 0607196 which is not owned by the signatory of
the LOA. However, the full 6.3 acres is still being proposed even with this area removed. This field
shall be noted as modified and the net acreage shall be updated.

Mr. Zachery D. Key
June 28, 2024
Page 4 of 5
O. County Board Notification:
1. N/A.
P. Application (Form: LOA 06-16):
1. Fields NC-GA-MH-02-02 and 05 extend onto Parcel No. 207154 owned by Rhonda Martin, who
did not sign an LOA. An LOA shall be executed by Ms. Martin or her representative agreeing to
allow land application of residuals on this parcel. If an LOA cannot be obtained, the areas of land
application area on this parcel shall be removed, and an updated setback map and LASC shall be
provided.
2. Field NC-WK-BP-04 is located on two separate parcels, Parcel No. 0606476 owned by Joseph
Garrett Byant and Parcel No. 0606478 owned by Kathleen G. Porter. While Kathleen Porter signed
an LOA for fields BP-01 through BP-03, she did not sign one for field BP-04. An updated LOA
shall be provided from Mrs. Porter agreeing to land apply residuals for this site.
Q. Setback Waivers:
See Comment P.1. Field NC-WK-BP-04 is located on two parcels owned by different owners. Even
if each of these owners signed an LOA, each is entitled to their 50-foot setback from the
neighboring parcel. To use the area 50 feet on each side of the property line, each parcel owner
shall execute reciprocating setback waivers to waive setbacks up to their property line. Otherwise,
the field shall be buffered with the appropriate property line setbacks, and an updated setback map
and LASC shall be provided.
R. Vicinity/Setback Maps:
1. The site map provided for NC-RU-FC-02 and 03 does not label which field is which. An updated
map shall be provided to indicate each field.
2. There is a habitable residence not owned by the signatory of the LOA located to the north of NC-
RU-FLA-02 on Parcel No. 1632860 that is not shown on the setback map. The appropriate setbacks
shall be shown in an updated setback map with an updated LASC noting any acreage changes.
3. There is a habitable residence not owned by the signatory of the LOA located to the south of NC-
RU-NM-02 on Parcel No. 1652505 that is not shown on the setback map. The appropriate setbacks
shall be shown in an updated setback map with an updated LASC noting any acreage changes.
4. There are habitable residences not owned by the signatory of the LOA located to the southwest of
NC-WK-BP-02 on Parcel No. 0602455 and to the southeast on Parcel No. 0605798 that are not
shown on the setback map. Additionally, there is a house listed as a "Land Owner House" on Parcel
No. 0606378 that is no longer owned by the land owner and shall be considered an off -site house.
The appropriate setbacks shall be shown in an updated setback map with an updated LASC noting
any acreage changes.
5. See Comment N.3. This subfield shall be completely removed in an updated map. Additionally,
there is a pond between these fields which is not depicted on the map. While it may not impact
setbacks, it shall be shown in an updated map with the appropriate setbacks.

Mr. Zachery D. Key
June 28, 2024
Page 5 of 5
6. There is a habitable residence not owned by the signatory of the LOA located to the northwest of
NC-WK-TL-01 on Parcel No. 0600534 that is not shown on the setback map. The appropriate
setbacks shall be shown in an updated setback map with an updated LASC noting any acreage
changes.
7. There is a habitable residence not owned by the signatory of the LOA located to the northwest of
NC-WK-TL-03 on Parcel No. 0606284 that is not shown on the setback map. There is also a
structure on Parcel No 0604164 that is further south to the already listed house on this property,
and it is unclear whether this is a habitable residence. The appropriate setbacks shall be shown in
an updated setback map with an updated LASC noting any acreage changes.
S. Soil & Agronomic Evaluation:
1. N/A.
T. Updated Cumulative Pollutant Loading Rates (CPLRs):
1. No comments.