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HomeMy WebLinkAboutWQ0023178_Final Permit_20041008pF W A TFj� Michael F. Easley, Governor WilliamG. Ross Jr., Secretary t? D Q r— North Carolina Department of Environment and Natural Resources (] Alan W. Klimek, P.E. Director Division of Water Quality October 8, 2004 MR. R. STEVEN BIGGS, TOWN MANAGER TOWN OF CLAYTON POST OFFICE BOX 879 CLAYTON, NORTH CAROLINA 27520 Subject: Permit No. WQ0023178 Town of Clayton Town of Clayton Residuals Land Application Program Land Application of Residual Solids (503) Johnston County Dear Mr. Biggs: In accordance with your permit application package received on September 25, 2003 as well as the additional information received on October 2, 2003; October 9, 2003; October 16, 2003; March 19, 2004; and August 18, 2004; we are forwarding herewith Permit No. WQ0023178, dated October 8, 2004, to the Town of Clayton for the subject residuals land application program. This permit shall be effective from the date of issuance until September 30, 2009 and shall be subject to the conditions and limitations as specified therein. Make note of this permit's expiration date and the fact that a permit renewal application is due to the Division of Water Quality (Division) no later than six months prior to that date (i.e., see Condition VI. 7.), as the Division does not send reminders to apply for permit renewal. This permit is being issued to approve the operation of a residuals land application program for the Town of Clayton. Please take the time to review this permit thoroughly. Pay particular attention to the monitoring requirements in this permit. Failure to establish an adequate system for collecting and maintaining the required operational information will result in future compliance problems. The Division would like to provide a couple of notes of caution regarding the operation of this program: ♦ Information presented in the permit application package stated that tobacco may be one of the crops grown on Site No. 01-03. Be aware of the harvesting restriction in Condition II. 16. regarding crops like tobacco. It is imperative that you communicate frequently with the landowner/lessee/operator of this land application site such that compliance with this condition is assured. ♦ The permit application package also states that lime stabilization is proposed as the method to meet the pathogen and vector attraction reduction requirements stipulated in Condition I. 7. Take care to ensure that the residuals are land applied at not more than agronomic rates, including the residuals' Iiming equivalent. Initial testing of Site No. 0I-03 indicates that the soil pH is already elevated; therefore, overapplication of lime through repeated residuals land application event could cause the soil pH to rise so high such that crop yield is adversely affected. N°"` hCarolina ,U&Aally Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Phone (919) 733-3221 Customer Service Internet: http:/lh2o,enr.state.ac.us 2728 Capital Boulevard Raleigh, NC 27604 Fax (919) 715-0588 1-877-623-6748 Fax (919)715-6048 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Mr. R. Steven Biggs October 8, 2004 Page 2 ♦ Finally, the Division did receive significant written comment from Johnston County regarding the permitting of the land application sites that are located in that county. The stated concerns included proximity to Johnston County's potable water intake, the Neuse River, and several residential subdivisions. After a thorough investigation of the permit application package, the Division found that the sites met all of the required regulations, to be generally suitable for residuals land application, and somewhat remote. However, knowing that Johnston County is concerned about residuals land application taking place on these sites, the Division urges you and your land applier to be extra vigilant to ensure permit compliance, respond quickly and adequately to inquiries, and to keep the lines of communication with county officials open. If any parts, requirements, and/or limitations contained in this permit are unacceptable, you have the right to request an adjudicatory hearing upon written request within 30 days following receipt of this permit. This request shall be in the from of a written petition, conforming to Chapter 150B of the North Carolina General Statutes and filed with the Office of Administrative Hearings at 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such demands are made, this permit shall be final and binding. If you need any additional information concerning this matter, please contact Ms_ Shannon Mohr Thornburg by telephone at (919) 715-6167, or via e-mail at shannon.thornburg@ncmail.net. Sincerely, for Alan W. Klimek, P.E. cc: Mr. Rick Baker, Buyer's Agency & Consulting, Inc. Mr. A. Davis Benton, Atlantic Coast Contracting, Inc. Johnston County Health Department Sampson County Health Department Fayetteville Regional Office - Aquifer Protection Section Raleigh Regional Office - Aquifer Protection Section Technical Assistance and Certification Unit APS Central Files APS Files LAU Residuals Program Coordinator NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RALEIGH LAND APPLICATION OF RESIDUAL SOLIDS (503) PERMIT In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as amended, and other applicable Laws, Rules, and Regulations PERMISSION IS HEREBY GRANTED TO Town of Clayton Johntson County FOR THE operation of a residuals land application program for Town of Clayton and consisting of the land application of residuals generated by the residuals source -generating facilities listed in the most recently - certified Attachment A to the land application sites listed in the most recently -certified Attachment B with no discharge of wastes to surface waters, pursuant to the permit application package received on September 25, 2003 as well as the additional information received on October 2, 2003; October 9, 2003; October 16, 2003; March 19, 2004; and August 18, 2004; and in conformity with the project plan, specifications, and other supporting data subsequently filed and approved by the Department of Environment and Natural Resources and considered a part of this permit. This permit shall be effective from the date of issuance until September 30, 2009 and shall be subject to the following specified conditions and limitations: I. PERFORMANCE STANDARDS 1. The residuals land application program shall be effectively maintained and operated as a non - discharge system to prevent the discharge of any wastes resulting from the operation of this program. 2. This permit shall become voidable if the soils of the land application sites fail to assimilate the residuals adequately and may be rescinded unless the land application sites are maintained and operated in a manner that will protect the assigned water quality standards of the surface waters and groundwater. 3. The issuance of this permit shall not relieve the Pennittee of the responsibility for damages to surface waters or groundwater resulting from the operation of this residuals land application program. 4. In the event that the residuals land application; program is not operated satisfactorily, including the creation of nuisance conditions, the Permittee shall cease land applying residuals to the site, contact the Aquifer Protection Section of the appropriate Division of Water Quality's (Division) regional office, and take any immediate corrective actions as may be required by the Division. S. No residuals other than those generated by the residuals source -generating facilities listed in the most recently -certified Attachment A of this permit shall be approved for land application in accordance with this permit. 6. The pollutant concentrations in any residuals that are land applied to any land application site shall not exceed the following Ceiling Concentrations (i.e., dry weight basis): Parameter Ceiling Concentration (milligrams per kilogra»z) Arsenic 75 Cadmium 85 Copper 4,300 Lead 840 Mercury 57 Molybdenum 75 Nickel 420 Selenium 100 Zinc 7,500 7. When residuals are land applied under the conditions of this permit, the Class A pathogen requirements and site restrictions in 40 CFR Part 503.32(a) or the Class B pathogen requirements and site restrictions in 40 CFR Part 503.32(b), and one of vector attraction reduction requirements in 40 CFR Part 503.33 shall be met. Additionally, an evaluation shall be performed that demonstrates the residuals' ability to comply with this requirement. Upon request, a copy of this evaluation, including all test results and calculations, shall be submitted. Only residuals that are generated by the residuals source -generating facilities that are identified as being exempt from this condition in the most recently -certified Attachment A shall not be required to comply with the specified pathogen reduction and vector attraction reduction requirements. Only the land application sites listed in the most recently -certified Attachment B of this permit are approved for residuals land application. 9. This permit shall become voidable unless the agreements between the Permittee and the landowners and lessees or operators of any land application sites listed in the most recently - certified Attachment B of this permit not owned by the Permittee are in full force and effect. These agreements shall be considered expired concurrent with the expiration date of the permit and shall be renewed at the same time the permit is renewed. 10. The appropriate local governmental official (i.e., county manager, city manager, etc.) shall be notified at least 24 hours prior to the initial residuals land application event to any new land application site. In addition, the appropriate county manager's office shall be notified prior to the initial residuals land application event on any new site so that they will be aware that residuals land application activities have commenced on the site. 11. The Aquifer Protection Section of the appropriate Division's regional office shall be notified at least 24 hours prior to the initial residuals land application event on any new land application site. Such notification to the Regional Aquifer Protection Supervisor shall be made during normal office hours (i.e., from 8:00 a.m. until 5:00 p.m.) between Monday and Friday, but excluding State Holidays. A list of the Division's regional offices, their county coverage, and their contact information may be downloaded from the web site at ii L-p://li2o.enr.state.ne.-as/ndpu/. H. OPERATION AND MAINTENANCE REQUIREMENTS 1. The facilities and land application sites shall be properly maintained and operated at all times. 2. Upon classification of the residuals land application program by the Water Pollution Control System Operators Certification Commission (WPCSOCC), the Permittee shall designate a certified land application/residuals operator to be in responsible charge (ORC) of the program. The operator shall hold a certificate of the type classification assigned to the program by the WPCSOCC. The Permittee shall also designate a certified back-up operator of the appropriate type to comply with the conditions of 15A NCAC 8G A202. 3. No residuals shall be stored at any land application site at any time, unless written approval has first been requested and obtained from the Division. 4. A copy of this permit shall be maintained in all manned equipment at the land application sites when residuals are being land applied during the life of this permit. A spill prevention and control plan shall be maintained in all residuals transport and application vehicles. When land applying residuals to any land application site, the following buffer zones shall be maintained at all times: a. 400 feet from residences or places of public assembly under separate ownership for surface application methods; however, the buffer zone requirement may be reduced to a minimum of 100 feet upon written consent of the owner and approval from the Aquifer Protection Section of the appropriate Division's regional office in Attachment B of this permit; b. 200 feet from residences or places of public assembly under separate ownership for subsurface application methods; however, the buffer zone requirement may be reduced to a minimum of 100 feet upon written consent of the owner and approval from the Aquifer Protection Section of the appropriate Division's regional office in Attachment B of this permit; c. 100 feet from any public or private water supply source, waters classified as SA or SB, and any Class I or Class H impounded reservoir used as a source of drinking water for both methods; d. 100 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal waters and any other lake or impoundment for surface application; e. 50 feet from any streams classified as WS or B, any other stream, canal, marsh or coastal waters and any other lake or impoundment for subsurface application; f. 50 feet from property lines for both surface and subsurface application methods; g. 50 feet from public right of ways for both surface and subsurface application methods; h. 10 feet from upslope interceptor drains and surface water diversions for both surface and subsurface application methods; and i. 25 feet from downslope interceptor drains, surface water diversions, groundwater drainage systems, and surface drainage ditches for both surface and subsurface application methods. 6. Maximum slope for land application of residuals shall be 10 percent for surface application methods and 18 percent for subsurface application methods. 7. Specific residuals land application area boundaries shall be clearly marked on each land application site prior to and during a residuals land application event. 8. The metal loading rates on any land application site shall not exceed the following Cumulative Pollutant Loading Rates (CPLRs): Parameter CPLR (kilograms per hectare) CPLR (pounds per acre) Arsenic 41 36 Cadmium 39 34 Copper 1,500 1.338 Lead 300 267 Mercury 17 15 Molybdenum n/a n/a Nickel 420 374 Selenium 100 89 Zinc 2,800 2,498 9. An acceptable pH shall be maintained in the soil, residuals, and lime mixture, greater than 6.0, on all land application sites onto which residuals are land applied to ensure optimum yield for the crops specified in Condition II. 13. The agronomist shall provide information on the pH best suited for the specified crop and the soil type. 10. Should any of the residuals generated by the residuals source -generating facilities listed in the most recently -certified Attachment A of this permit contain a high salt content (i.e., high sodium adsorption ratio (SAR) of five or higher), the exchangeable sodium percentage (ESP) or other method as approved by the Division, using the results from the annual soils analysis as required by this permit, shall be monitored on all of the land application sites. The local Cooperative Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, a North Carolina -licensed Soil Scientist, or other agronomist shall review the results and make recommendations regarding soil amendments (e.g., gypsum, etc.) or other ameliorative mechanism for maintaining the integrity of the site in terms of suitability for land application of residuals and maintaining conditions conducive to crop growth. The Permittee shall implement such recommendations accordingly and shall maintain written records of each monitoring event that includes details of the sites covered and rate of soil amendment application. 4 11. Prior to land applying residuals to any land application site that has previously received or is intended to receive animal waste (e.g., poultry litter, etc.) or other source of nutrients (e.g_, fertilizer, etc.) in the future, the Permittee shall obtain information pertaining to the volume and analysis of the applied waste/nutrients from the landowner and/or lessee/operator of the site. The Permittee shall be responsible for verifying the volume of residuals that may be land applied to the site such that the plant available nitrogen (PAN) loading rate for the specified crop (i.e., see Condition H. 13.) shall not be exceeded by all of the sources of PAN applied. Should the maximum PAN loading rate be met or exceeded, then no additional residuals shall be land applied to the site. 12. A suitable vegetative cover, as listed in Condition U. 13., shall be maintained on land application sites onto which residuals are land applied in accordance with the crop management plan outlined by the local Cooperative Extension Office, the Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, or other agronomist and as approved by the Division. 13. Residuals and other sources of PAN shall be land applied to all land application sites at agronomic rates in accordance with the crop management plan outlined by the local Cooperative Extension Office, the North Carolina Department of Agriculture and Consumer Services, the Natural Resource Conservation Service, or other agronomist. Under no circumstances shall the following PAN loading rates land applied to any site exceed the following for the specified crops: PAN PAN Crop (pounds per Crop (pounds per acre er year) acre er ear Alfalfa 200 Forest (Hardwood or Softwood)75 Bermuda Grass 220 Milo 100 (Hay or Pasture) Blue Grass 120 Small Grain (Wheat, Barley, or Oats)100 Corn 160 Sorghum or Sudex 180 Grain (Pasture) Corn 200 Sorghum or Sudex 220 (Silage) (Silage) Cotton 70 Soybeans 200 Fescue 25D Timothy, Orchard, or 200 Rye Grasses The Permittee shall apply for and receive a modification of this permit before land applying residuals on any land application site that is to be established in a crop other than those listed above. A maximum PAN loading rate for the desired crop shall be approved with the permit modification. If the land application sites are to be overseeded (e.g., bermuda grass in the summer and rye grass in the winter with BOTH crops to receive residuals), then the second crop shall receive an application of PAN at a rate of no greater than 50 pounds per acre per year. This practice shall be allowed as long as the second crop is to be harvested. If the second crop is to be planted for erosion control only and is to be tilled into the soil, then no residuals shall be land applied to these sites because the PAN will essentially be returned to the soil. Residuals shall not be land applied at rates greater than agronomic rates, unless authorized by the Division. 14. Animals shall not be grazed on any land application site for 30 days after any residuals land application event. Sites that are to be used for grazing shall have fencing that will be used to prevent access after each event. 15. Food crops, feed crops, and fiber crops that do not come in contact with the residuals shall not be harvested for 30 days after any residuals land application event. 16. Food crops with harvested parts that touch the residual/soil mixture and are totally above the land surface (e.g., tobacco, melons, cucumbers, squash, etc.) shall not be harvested for 14 months after any residuals land application event. 17. Food crops with harvested parts below the surface of the land (i.e., root crops such as potatoes, carrots, radishes, etc.) shall not be harvested for 20 months after any residuals land application event when the residuals remain on the land surface for four months or longer prior to incorporation into the soil. 18. Food crops with harvested parts below the surface of the land shall not be harvested for 38 months after any residuals land application event when the residuals remain on the land surface for less than four months prior to incorporation into the soil. 19. Turf shall not be harvested for one year after any residuals land application event. 20. Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying residuals from the land application sites onto adjacent properties or into any surface waters. 21. Adequate procedures shall be provided to prevent surface runoff from carrying any land applied or stored residuals into any surface waters. 22. Surface -applied residuals shall be plowed or disced within 24 hours after land application on land application sites with no cover crop established. 23. For land application sites that are prone to flooding or within the 100-year flood elevation, residuals shall be land applied only during periods of dry weather. The residuals shall be incorporated into the soil within 24 hours after land application. 24. Residuals shall not be land applied during inclement weather or until 24 hours following a rainfall event of 0.5-inch or greater in 24 hours. Any emergency residuals land application measures shall first be approved in writing by the Division. 25. Residuals shall not be Iand applied to any land application site that is flooded, frozen, or snow-covered. 26. Appropriate measures shall be taken to control public access to the land application sites during active site use and for the 12-month period following the Iast residuals land application event. Such controls may include the posting of signs indicating the activities being conducted at each site. 6 RI. MONITORING AND REPORTING REQUIREMENTS Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue analyses) deemed necessary by the Division to ensure protection of the environment shall be established, and an acceptable sampling and reporting schedule shall be followed. 2. Residuals generated by each residuals source -generating facility listed in the most -recently - certified Attachment A of this permit shall be analyzed to demonstrate that they are non- hazardous under the Resource Conservation and Recovery Act (RCRA). A corrosivity, ignitability, and reactivity analysis as well as a Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be conducted on residuals generated by each residuals source - generating facility listed in the most recently -certified Attachment A of this permit. The analyses shall be performed at the frequency specified in the most recently -certified Attachment A of this permit, and the results shall be maintained on file by the Pennittee for a minimum of five years. If residuals generated by a particular residuals source -generating facility are land applied at a frequency less than that which is specified in the most recently - certified Attachment A of this permit, the analyses shall be required for each residuals land application event. Only residuals that are generated by the residuals source -generating facilities that are identified as being exempt from this condition in the most recently -certified Attachment A of this permit shall not be required to comply with this monitoring requirement. The TCLP analysis shall include the following parameters (i.e., note the regulatory level in milligrams per liter in parentheses): Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0) Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0) Benzene (0.5) 1, 1 -Dichloroethylene (0.7) Pyridine (5.0) Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (1.0) Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0) Chlordane (0.03) Hexachlorobenzene (0.13) Tetrachloroethylene (0.7) Chlorobenzene (100,0) Heptachlor (and its hydroxide) (0,008) Toxaphene (0.5) Chloroform (6.0) Hexachloro-1,3-butadiene (0.5) Trichloroethylene (0.5) Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol (400.0) m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0) o-Cresol (200.0) Lindane (0.4) 2,4,5-TP (Silvex) (1.0) p-Cresol (200.0) Mercury (0.2) Vinyl chloride (0.2) Cresol (200.0) Methoxychlor (10.0) 2,4-D (10.0) Methyl ethyl ketone (200.0) After the residuals have been monitored as specified above for two years at the frequency specified in the most recently -certified Attachment A of this permit, the Permittee may submit a request to the Division for a permit modification to request a reduction of this monitoring requirement. In no case, however, shall the frequency of monitoring be less than once per permit cycle. 7 3. An analysis shall be conducted on residuals generated by each residuals source -generating facility listed in the most recently -certified Attachment A of this permit. The analysis shall be performed at the frequency specified in the most recently -certified Attachment A of this permit, and the results shall be maintained on file by the Permittee for a minimum of five years. If residuals generated by a particular residuals source -generating facility are land applied at a frequency less than that which is specified in the most recently -certified Attachment A of this permit, an analysis shall be required for each residuals land application event. The analysis shall include, but shall not necessarily be limited to, the following parameters: Aluminum Ammonia -Nitrogen Arsenic Cadmium Calcium Copper Lead Magnesium Mercury Molybdenum Nickel Nitrate -Nitrite Nitrogen Percent Total Solids pH Phosphorus Potassium Selenium Sodium Total KjeIdahl Nitrogen Zinc Plant Available Nitrogen (by calculation) After the residuals generated by a particular residuals source -generating facility have been monitored for two years at the frequency specified in the most recently -certified Attachment A of this permit, the Pemrittee may submit a request to the Division for a permit modification to reduce the frequency of this monitoring requirement. In no case, however, shall the frequency of this monitoring be less than once per year when a residuals land application event of residuals generated by the residuals source -generating facility occurs during that year. 4. Residuals generated by each residuals source -generating facility listed in the most recently - certified Attachment A of this permit shall be monitored for compliance with Condition I. 7. The monitoring shall be performed at the frequency specified in the most recently -certified Attachment A of this permit, and data to verify pathogen and vector attraction reduction of the residuals shall be maintained on file by the Permittee for a minimum of five years. The required data shall be specific to the stabilization process utilized, but also shall be sufficient to demonstrate clear compliance with the Class A pathogen reduction requirements in 40 CFR Part 503.32(a) or the Class B pathogen reduction requirements and site restrictions in 40 CFR Part 503.32(b) as well as one of vector attraction reduction requirements in 40 CFR Part 503.33. Th addition, the Environmental Protection Agency (EPA) certification statements concerning compliance with pathogen reduction requirements, vector attraction reduction requirements, and management practices shall be completed quarterly by the proper authority or authorities, if more than one is involved (i.e., either the person who prepares the residuals, the person who derives the material, or the person who applies the residuals). Only residuals that are generated by the residuals source -generating facilities that are identified as being exempt from Condition I. 7. in the most recently -certified Attachment A of this permit shall not be required to comply with this monitoring requirement. 5. Laboratory analyses as required by Condition III. 2., Condition 111. 3., and Condition III. 4. shall be performed/gathered on the residuals as they are to be land applied. Furthermore, analytical determinations made pursuant to the monitoring and reporting requirements of this permit shall be made by a laboratory certified by the Division for the required parameter(s) under 15A NCAC 2H .0800 or 15A NCAC 2H .1100. 8 6. Proper records shall be maintained by the Permittee tracking all residuals land application events. These records shall include, but are not necessarily limited to, the following information: a. Source of residuals; b. Date of land application; c. Location of land application (i.e., site, field, or zone number); d. Method of land application; e. Weather conditions (i.e., sunny, cloudy, raining, etc.); Soil conditions (i.e., dry, wet, frozen, etc.); g. Type of crop or crops to be grown on field; h. Volume of residuals land applied in gallons per acre, dry tons per acre, or kilograms per hectare; i. Volume of animal waste or other nutrient source applied in gallons per acre, dry ton per acre, or kilograms per hectare (if applicable); j. Volume of soil amendments (i.e., lime, gypsum, etc.) applied in gallons per acre, dry ton per acre, or kilograms per hectare (if applicable); and k. Annual and cumulative totals of dry tons per acre of residuals as well as animal waste and other sources of nutrients (i.e., if applicable), annual and cumulative pounds per acre of each heavy metal (i.e., shall include, but shall not be limited to, arsenic, cadmium, copper, lead, mercury, molybdenum, nickel, selenium, and zinc), annual pounds per acre of PAN, and annual pounds per acre of phosphorus applied to each field. 7. A representative annual soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on each land application site on which a residuals Iand application event in the respective calendar year has occurred or is to occur, and the results shall be maintained on file by the Permittee for a minimum of five years. The Standard Soil Fertility Analysis shall include, but is not necessarily limited to, the following parameters: Acidity Exchangeable Sodium Percentage (by calculation) Calcium Magnesium Phosphorus Cation Exchange Capacity Manganese Potassium Copper Percent Humic Matter Sodium Base Saturation (by calculation) pH Zinc 8. Three copies of all required monitoring and reporting requirements as specified in Condition III. L, Condition III. 2., Condition III. 3., Condition III. 4., Condition III, 5., Condition III, 6., and Condition III. 7. shall be submitted annually on or before March 1st of the year following the residuals land application event to the following address: NCDENR-DWQ Information Processing Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 9. Noncompliance Notification: The Permittee shall report by telephone to the Aquifer Protection Section of the Division's Raleigh Regional Office at telephone number (919) 5714700, as soon as possible, but in no case more than 24 hours or on the next working day following the occurrence or first knowledge of the occurrence of any of the following: a. Any occurrence with the residuals land application program that results in the land application of significant amounts of residuals that are abnormal in quantity or characteristic. b. Any failure of the residuals land application program resulting in a release of material to receiving waters. c. Any time that self -monitoring information indicates that the residuals land application program has gone out of compliance with the conditions and limitations of this permit or the parameters on which the program system was designed. d. Any process unit failure, due to known or unknown reasons, that render the residuals land application program incapable of adequate residuals treatment. e. Any spillage or discharge from a vehicle or piping system transporting residuals to the application site. Persons reporting such occurrences by telephone shall also file a written report in letter form within five. days following first knowledge of the occurrence. This report shall outline the actions taken or proposed to be taken to ensure that the problem does not recur. IV. GROUNDWATER REQUIREMENTS 1. Land Application Site Requirements: a. Each land application site identified with a GW-A in the most recently -certified Attachment B of this permit is dominated by soils with a mean seasonal high water table greater than three feet below the land surface. Residuals land application events may occur on these sites throughout the year. b. Each land application site identified with a GW-B in the most recently -certified Attachment B of this permit is dominated by soils with a mean seasonal high water table between one and three feet below the land surface. Residual land application events on these sites shall be prohibited from December through March, inclusive. No residuals shall be land applied to these sites when the vertical separation between the depth of residuals land application and the water table is less than three feet. The actual water table depth for seasonally -restricted soils shall be verified by soil borings within 24 hours prior to any residuals land application event that occurs from April through November, inclusive. The number of borings advanced shall be sufficient to characterize water table conditions across the land application site adequately. Any open borings shall be properly filled with native soil, prior to the residuals land application event, to decrease the chance of any residuals contaminating the groundwater. 10 2. Applicable Boundary Requirements: a. The COMPLIANCE BOUNDARY for residuals land application programs is specified by regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards"). The Compliance Boundary for each land application site is established at either 250 feet from the residuals land application area or 50 feet within the property boundary, whichever is closest to the residuals land application area. An exceedance of Groundwater Quality Standards at or beyond the Compliance Boundary is subject to immediate remediation action according to 15A NCAC 2L .0106 (d)(2). b. The REVIEW BOUNDARY shall be established around each land application site midway between the Compliance Boundary and the perimeter of the residuals land application area. Any exceedance of Groundwater Quality Standards at the Review Boundary shall require action in accordance with 15A NCAC 2L .0106 (d)(2). 3. Additional Requirements: Any groundwater quality monitoring, as deemed necessary by the Division, shall be provided. V. INSPECTIONS Prior to each residuals land application event, the Permittee or his designee shall inspect the residuals storage, transport, and application facilities to prevent malfunctions and deterioration, operator errors, and discharges that may cause or lead to the release of wastes to the environment, a threat to human health, or a nuisance. The Permittee shall maintain an inspection log or summary including at least the date and time of inspection, observations made, and any maintenance, repairs, or corrective actions taken by the Permittee. This log of inspections shall be maintained by the Permittee for a period of five years from the date of the inspection and shall be made available to the Division or other permitting authority, upon request. 2. Any duly authorized officer, employee, or representative of the Division may, upon presentation of credentials, enter and inspect any property, premises, or place on or related to the land application sites or facilities at any reasonable time for the purpose of determining compliance with this permit; may inspect or copy any records that must be kept under the terms and conditions of this permit; and may obtain samples of groundwater, surface water, or leachate. VI. GENERAL CONDITIONS This permit shall become voidable unless the residuals Iand application events are carried out in accordance with the conditions of this permit, the supporting materials, and in the manner approved by the Division. 2. This permit shall be effective only with respect to the nature and volume of residuals described in the application and other supporting data. Failure to abide by the conditions and limitations contained in this permit may subject the Permittee to an enforcement action by the Division in accordance with North Carolina General Statutes § 143-215.6A through § 143-215.6C. 11 4. The annual administering and compliance fee shall be paid by the Permittee within 30 days after being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate action to revoke this permit, as specified by I5 NCAC 211 .0205 (c)(4). 5. The issuance of this permit does not preclude the Permittee from complying with any and all statutes, rules, regulations, or ordinances that may be imposed by other government agencies (i.e., local, slate, and federal) which have jurisdiction, including, but not limited to, applicable river buffer rules in 15A NCAC 213 .0200, soil erosion and sedimentation control requirements in 15A NCAC Chapter 4 and under the Division's General Permit NCG010000, and any requirements pertaining to wetlands under 15A NCAC 2B .0200 and 15A NCAC .0500. b. This permit may be modified, revoked, and/or reissued to incorporate any conditions, limitations and monitoring requirements the Division deems necessary in order to protect the environment and public health adequately. 7. The Permittee, at least six months prior to the expiration of this permit, shall request its extension. Upon receipt of the request, the Division shall review the adequacy of the facilities and residuals land application program described therein, and if warranted, shall extend the permit for such period of time and under such conditions and limitations as it may deem appropriate. ' 8. This permit shall not be automatically transferable. In the event that there is a desire for the residuals land application program to change ownership or to change the name of the Permittee, a formal permit request shall be submitted to the Division documentation from the parties involved and other supporting materials as may be appropriate. The approval of this request shall be considered on its merits and may or may not be approved. Permit issued this the eighth day of October, 2004. NORTH C LINA EYMONMENTAL MANAGEMENT COMMISSION for Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit Number WQ0023178 12 ATTACHMENT A - Aooroved Residual 5oureeGeneratine Facilities PermirNo. WQ0023178 Town of Clayton Town of Clayton Residuals Land Application Program Owner Facility Name County Permit Number Issued By Is 503? Maximum Monitoring Monitoring Approved Dry Taos Frequency for Frequency for Mineralization Per Year Condition 111.2. Condition Ill. 3. and Rate Condition I11.4. Town of Clayton Little Creek W WTP Johnston NCO025453 DWQ 503 4o0.W Annually 4 X year .30 Total 400.00 Permit N7o. WQ0023178 Page 1 of l Certification Date: October 8, 2004 _ATTACHMENT B - Approved Land Application Sites Permit -No. WQ0023178 Town of Clayton Town of Clayton ,Residuals Land Application Program Site/Field 10 Landowner Lessee/Operator County Latitude Longitude Net Acreage Applicable Restriction in Condition N. 1. 01-03 Bo ette, Larry Johnston 35.40.04 78.25.19 27.50 GW-A 02-013 Vinson, Jr., Robert T. Johnston 35.37.51 78.22.37 24.30 GW-A 02-02 Vinson, Jr., Robert T. Johnston 35.36.50 78.28.09 3.50 GW-A 02-03 Vinson, Jr., Robert T. Johnston 35.36.13 78.27.59 9.40 GW-A 02-04 Vinson, Jr., Robert T. Johnston 35.36.07 78.23.04 2.20 GW-A 02-05 Vinson, Jr., Robert T. Johnston 35.36.05 78.27.57 10.20 GW-A 02-06 Vinson, Jr., Robert T. Johnston 35.35.59 78.28.58 12.90 GW-A 03-02 Parrish, Leona P. Parrish, Jr., Benjamin L. Johnston 35.35.32 78.20.05 27.40 GW-A 03-03 Parrish, Leona P. Parrish, Jr., Benjamin L. Johnston 35.35.30 78.20.12 8.10 GW-A 03-04 Parrish, Leona P. Parrish, Jr., Benjamin L. Johnston 35.34.09 78.20.53 25.30 GW-A Total For County Johnston 150.80 JD-01 Draughon, Toka M. Drau hon, Jr., James L. Sampson 35. 13.03 78.33.45 16.60 GW-A JD-03 Drau hon, Jr., James L. Sampson 35.15,57 78.32.13 6.50 GW-B JD-04 Drau hon, Jr., James L. Sampson 35.15.52 78.32.04 16,50 GW-B Total For County Sampson 39.60 Total I 1 1 190.40 ° A 25-foot setback/buffer shall be maintained from all rock outcrops on this land application site. Permit No. WQ0023178 Page I of 1 Certification Date: October 8, 2004 \v L 4 OJ � � tiv ljl FAS � 1 371 1 tw5 ' - v � f1 I) p 177f 1 JZ1 ► I v t» —! rTl• � 1Tp1 1f BV/IaLO ).1 3LIt � Y 1� !may y 'A 1, G� •_��i �>✓ vex �Z } I 1 TIT I)l) I } t)oo f FFS f.5 4 loot 9 II 2 q ll�) 5111 Ia ZI! 217;. T a � i� .S• Y 1• 4h'LE' )gym ' c ZLl1 .e tr !) p �uffnln U lzu Pb w+ir im l .e pah n m 1 Ila. z �FIELa wa.rnL v 4 fir' .� . J zxca lTu 20'�'"• } + }} lw Mt71r j !e .SEII,{.4',•. "��` J_._1 ro 1^ r W. 140] a T::: 4 }1P ✓,Nr � � ~ � J � FhP'• �' ♦ i Sal lc� � JO lit S FIE LIM 10 Air • �� ', 1�i• 1� �I�rffe �C � �� � V l Lhe4 Cr..i 04, Cry,>i 1.7�i •'1.7 b � '• c .Q 1� `} 1610 1y.� Creek 11 •i • 1?2� ii.ir In• � � � vs � •y ,S•, l7 8r. Huddle � 3l7! x } y�G lslP S7� y •` e� , Y Ilopevsll ! 5 Ch •' S111 Ida 5udn iZ - !P '3 .•b A. aiZf 1.5 rti. �iZl ! 7 7 �Ty • ro p —� HOL75 }�- ,� • - 1m—, lips- 7ia 1~s LAXF f 1l,a 'C /FqiiiiirrR 4X CSB OYETTE FARM ( SITE 1) LTD SITE VICINITY MAP SCALE: 1" = 2.1 MILES TOWN OF CLAYTON ENGINEERING LAND APPLICATION PROGRAM CONSULTING ,�,� SERVICES,LTD Twoa-18-03 G-7B79 FIELD 3 LEGEND DWELLING ^-IWOODED AREA r C5 r STRUCTURE(BARN) ----+DRAINAGEWAY dPOND = ACCESS ROAD • WELL —PROPERTY LINE = BUFFER AREA � FENCE W WET AREA ® HAND AUGER BORING SCALE: I" = 660' ATLANTIC COAST CONTRACTING, INC. pu 0 SR1706 B 4 / 3E-2 BOYETTE FARM (SITE 1) BUFFER MAP TOWN OF CLAYTON LAND APPLICATION PROGRAM unv W/o � romm m TAC/07--30-04 0-7878 2239 -f," im 7 IU lzl# Irel Eal 37- A iz.0 13 I LEN- 2!uxt jilts UZ 'V. liar SLLI. a.//. fo JELL I'm polo LW 0 r2pm L ;916 IL 4 fAs pps Ij AM-L im 1w I -4 An! IF41 Lm 1-, . lcdp, R-d HL4 1911 -,-1 -p I u- 0 4 Ck. '4 qJ,vzi J RIVER A Fl Ila Ui ep iza J= 7 CIAMN JIM Im Ll HFIEL VvVT .2 X3 144 FA3 14 -Iuzzj 17 11 FIELD Uffi. Cl-A 01 1 �lw C, 7 um- JAL k ilu fic ?AAdk 7 Jlz* jl�t 1-/ 11114 JLW au UL, up_ D 1147 Ila lim I JILL DID St— Lm 13 Dw 1 411� lau CSVINSON FARM (SITE 2) LTD SITE VICINITY MAP SCALE: 1" = 2.1 MILES TOWN OF CLAYTON ENGINEERING LAND APPLICATION PROGRAM CONSULTING Kl� ""m m� .ar.r*Tm - SERVICES,LTD TAC/06-16—m —7a7g nu7- RIVER WOODS ` SLOPE BUFFE TERRACED AREA WOODS LEGEND M DWELLING ^AWOODED AREA s 3E-2 k PONDSMUT[JRE(BARN) -•—•ACCESS ROAY AD ATLANTIC COAST VINSON FARM (SITE 2) a POND = ACCESS ROAD WELL - FENCE LINE BUFFER MAP ® BUFFER AREA 0 FENCE CONTRACTING 1F WET AREA ® HAND AUGER BORING , INC. TOWN OF CLAYTON SCALE: 1" = 660' LAND APPLICATION PROGRAM ® moor o� TAC/07-30-04 G-7879 SR1560 r a � . ♦ f ♦ QHT FIELD 3 FIELD 2 *f*!/ SR1557 LEGEND DWELLING NWA1/OGDED AREA � STRUCTURE(BARN)----+DRAINAGERAY POND � ACCESS ROAD WELL - PROPERTY LINE OPE Em BUFFER AREA - FENCE R WET AREA ® HAND AUGER BORING SCALE: I" = 660' FIELD 5 (UNOCCUPIED TRAILER OWNED BY VINSON) ATLANTIC COAST CONTRACTING, INC. 3E 2 VINSON FARM (SITE 2) BUFFER MAP TOWN OF CLAYTON LAND APPLICATION PROGRAM G-7879 TAC/07-30-04 SR1557 SR1558 ! OHT SR1555 ■ ! ■ A A as OUT FIELD 6 OUT 1 r ACCESS ■ TRAILER Jo PARK ■ ! r i OUT } RODS WOODS AUG Q 4 2004 SR1557 SR1560 LEGEND E�°2 r DWELLING PN-AWOODED AREA . : A STRUCTURE(BARN) C�POND -•--+DRAINAGEWAY - ACCESS ROAD VZNSON FARM (SITE �11 ATLANTIC CQAST 1 1 • WELL ® BUFFER AREA if - --- PROPERTY LINE FENCE CONTRACTING,BUFFER MAP WET AREA 0 H.AND AUGER BORMG INC. TOWN OF CLAYTON SCALE: 1" = 660' LAND APPLICATION PROGRAM mv. TAC/07-30-04 �� �m G-7879 zz ii ......... ......... 3, 2N ijM 21 E.1 P2 lUz -3910 fAs 1-d MW 12D 03, — lit sd _e Creek 1103 17 in, RIVER 'F1 DS 2-3 731 Wil— im, AQ), 42 ,istO 7o EL 2.6 ML e_ 70 k Z� I HFIEL 1.3 .2 A W, WT� 13 1, � x. f- 01 A --- Au 'I" FA 2W ti 1-2 IA73 Aau, xal -LU2 0—k 01 A.Im 1$4 1 1 'L .6 =-p I & vL B, IM JULc LK Im 'o Albanvo .2U o Y—Y Gr IND -uI7 P6 *As T D7 C6-1-d Wm— v9 Mc xza spdnol Ile 4 PARRISH FARM (SITE 3) LTD SITE VICINITY MAP SCALE: 1 2.1 MILES TOWN OF CLAYTON ENGINEERING LAND APPLICATION PROGRAM CONSULTING w/mm - 7AM/00-18-03 G-7879 SERVICES,LTD I SR1909 x LEGEND + W DWELLING M�1f00nED AREA • STRUMM(BARN)-•-•-iDRAINAGE;WAYQsLmrD dPOND — ACCESS ROAD • WELL - --- PROPERTY LINE SCALE 1'� — 66 [} = 19un?m AREA ,. �. MCE Wn Am 0 HAND AUGER BORDiG ENGINEERING CONSULTING SERVICES,LTD RIVER PARRISH FARM (SITE 3) BUFFEF: MAP TOWN OF CLAYTON LAND APPLICATION PROGRAM n... wr/mm I ®=W m/bA-M G-7879 nova IK 3E—z _ HWY. 70 BYPASS WOODS ACCESS 1 OWNER \ RESIDENCE \\ SR1913 PROPERTY — - J BOUNDARY LEGEND � e 3E-2 STRUCTURE(BARN) DWELLINGP �-+DRA NA AREA SRRUCTITRE(HARH)--�DRAINAGE1fAY PARRISH FARM {SATE - 'OND = ACCESS ROAD ��.-PROPERTY LING hgSL TD BUFFER MAP ® BUFFER AREA .-,-,- FENCE W WET AREA ® HAND AUGER BORING TOWN OF CLAYTON SCALE: 1" = 660' ENGINEERING LAND APPLICATION PROGRAM CONSULTING �� , m SERVICES,LTD TAC7/oe-Ib-w G-7579 p } �I � fields JD-3 and 4 6. yi� , Field JD-1 CP SCALE: 1° = approx. mile , Town of 4NAYIne1v Site CHECKED BY: Is�� ��� Jimmy Draughan Farm Location DPAVVN BY: SD3 Land f;pplicatian Program Map ��,7E: Feb'D2 JOB ND, GBD9D Fi-.3e -� SCALE: CHECKED BY: DRAWN BY: SDB DATE: Feb'02 WLR'ARLA At1CUM "OPLINC N Wfv - kvxrct 7wd1E l/-ceirtrAYloov . _. Town of L'CAYr-M+ Jimmy Draughan Farm Buffer Land Application Program Map JOB NO: G6990 Fiq. 3 c- 3 MR. R. STEVEN BIGGS, Tow TOWN OF CLAYTON POST OFFICE BOX 879 CLAYTON, NORTH CAROLIN Dear Mr. Biggs: The Division of W, detailed technical review of is required before we may cc not yet been completed the Offices. Therefore, additiu generated by those reviews. i Form RSCA: 1. Item I. 8. on PaE of unit process ( being returned t additional inforn i 2. Item I. 8. on Pa; rather than'a resi treatment and, if 3. The copy of the (i.e., too small a clear copy for th, 4. The laboratory method used to 245.1. Note tha pollutants requii "Test Methods regulated metal: then analyzed b analysis of, the rf I Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Alan W. Klimek, P.E., Director Coleen H. Sullins, Deputy Director Division of Water Quality February 19, 2004 RECEIVED MANAGER FEB 2 3 2094 27520 DENR - FAYM EVALLE REGIONAL OFRCE Subject:.[ pplicatio`n No' WQ0023T78J Additional Information Request +town of"Clay on Town of Clayton Residuals Land Application Program Land Application of Residual Solids (503) Johnson County r Quality's (Division) Non -Discharge Permitting Unit has completed a subject permit application package. At this time, additional information inue our review. Note that detailed technical reviews of the package have ater Quality Section of the Division's Raleigh and Fayetteville Regional 1 requests for information may be necessary to address any comments )wever, please address the following items no later than March 19, 2004: 3 of 8 mentions a "clarigester." The Division is unfamiliar with this type gybe this is simply a clarifier to settle out solids from wastewater prior to the oxidation ditch or wasted to the aerobic digester?). Please provide :ion accordingly. 3 of 8 lists the aerated sludge holding tank as a residuals treatment unit als storage unit. Please clarify whether or not this unit is, in fact, used for , why (i.e., aerobic digester'is undersized, etc.). )rocess flow diagram that was provided in Attachment 2-b was not legible d unclear due to being a Xeroxed copy of a fax). Please provide a more Division's review and reference. port from Tritest, Inc. that was provided in Attachment 2-e lists that the analyze for the mercury concentration of the residuals was EPA Method 40 CFR Part 503.8(b)(4) requires that the analytical methods for inorganic 3 to be monitored under this regulation must conform to those in SW-846 )r Evaluating Solid Waste - Physical/Chemical Methods." For the nine samples may be prepared using either Method 3050 or Method 3051 and Method 7480, Method 7481, or Method.6010. Please provide a mercury iduals that is compliant with the federal regulations. NC DENIA Non -Discharge Permitting Unit Internet http://h2o.enr.state.nc.us/ndpu 1617 Mail Service Center, lRaleigh, NC 27699-1617 Telephone (919) 733-5083 Fax (919) 715-6048 DENR Customer Service Center Telephone 1 800 623-7748 An Equal Opportunity Action Employer 50% recycled/10% post -consumer paper Form RSCA (continued): 4 (cont). EPA Method 245.1 is a common method for analyzing total mercury present in water -based samples, like effluent. Be aware that the Division issued guidance that requires all Pennittees that are to monitor mercury as a requirement of their NPDES permits to use EPA Method 1631,' effective September 2003. The Town may want to make sure that its contract laboratory is using the,correct method for its effluent analytical work as well as conveying to them the requirement to use methods in SW-846 for the Town's residuals analytical work (i.e., for inorganic pollutants only). 5. The pH of the residuals is listed on Tritest, Inc.'s chain of custody sheet that was provided in Attachment 2-e. Please clarify whether the result of 7.33 was properly temperature corrected prior to reporting. Also, be aware that the Town may be subject to the Division's field parameter certification requirements, if the Town is monitoring and reporting for parameters that are measured in the field such as pH, temperature, dissolved oxygen, etc. Contact the Certification Unit of the Division's Laboratory Section at www.dwqlab.org or (919) 733- 3908 for more information about this program. 6. The Division's verification calculations show that the sodium adsorption ratio (SAR) of the residuals is 1.02 and not 0.86, as is listed in Item II. 5c. No action is required to respond to . this comment other than to state that it is acceptable for the Division to make a pen change to the permit application package and to correct the equation that the Town is using to calculate SAR. 7. Item H. 8. states the Alternative 1 (i.e., 38 percent volatile solids reduction) or Alternative 6 (i.e., alkaline stabilization) will be used to meet the vector attraction reduction (VAR) requirement contained in 40 CFR Part 503. No verification that the Little Creek WWTP can meet either of these alternatives was provided in the permit application package,"per the second checkmark of Instruction C. on Page 1 of 8. Please provide such laboratory analyses or operational data accordingly. Note that, typically, wastewater treatment facilities that employ processes that run at high mean cell residence times like extended aeration or oxidation ditches have difficulty meeting VAR through Alternative 1. In these cases, an additional digestion test or the specific oxygen uptake rate (SOUR) test may be useful. It is true that both state and federal guidance require that the SOUR test may not be used if the total solids of the residuals exceeds two percent; therefore, if you are relying on the aerated sludge holding tank (i.e., post thickening) for meeting minimum stabilization requirements, this may not be the best alternative for the Town. However, if the Town's aerobic, digester is running at less than two percent total solids, is at temperatures between 10 and. 30 degrees Celsius, and is the primary residuals treatment unit, the Town may want to look at using the SOUR test for VAR compliance. Remember that, once the Town has met VAR in a particular residuals treatment process, it does not have to demonstrate compliance again as long as additional untreated residuals are not being'added to the process (i.e., alkaline stabilization is the"one exception to this rule). 2 E Form RSCA (continued): 8. Please review the instructions for preparing. Attachment 2-d, and amend the sampling plan as needed to ensure that all requirements are adequately met. It may be helpful to think of the sampling plan as a document that could be picked up by a new WWTP operator and, by following it, would be compliant with all state and federal requirements with respect to residuals monitoring, without otherwise having formal training in these requirements. Some initial continents on the draft that was e-mailed to the Division for consideration. ♦ CorrosIivity, ignitability, and reactivity are not analyzed on leachate generated from the residuals. Therefore, technically, they are not included in the toxicity characteristics leaching procedure (TCLP) analyses. Rather, contract laboratories. should refer to SW- 846 fo'r correct analytical methodologies. ♦ What is "proper sampling protocol" for the various analyses? ♦ 'EPA guidance regarding pathogen reduction compliance recommends that the seven fecal coliform/total solids samples be taken over a two -week period. ♦ What methol s are used for the analysis of fecal coliform and total solids? ♦ 40 CFR Part 503 stipulates monitoring frequency based on dry tons of residuals that are land applied per calendar year regardless of the number of land application events that take place. (Therefore, because the Town will be approved to land apply a maximum of 400 dry tons of residuals per year, it will be required to have four representative monitoring events per year, even if all 400 dry tons of residuals are land applied in a 1 2 ♦ No detail is provided at all regarding how sampling/monitoring for VAR compliance is to be completed. The Division's calculations show that net acreages of all proposed new and transferred land application sites, as listed in Item I. 1. on Page 2 of 3 and Page 3 of 3 add up to 208.00 acres and not 197.50 acres as is listed in this form as well as in Item III. 3. on Page 4 of 5 on Form NDRLAP Please clarify so that the Division may make the appropriate pen change. The net acreage's for some of the proposed new land application sites are listed differently in Item I. 1. on Page 2 of 3 and "Table 1." Please clarify which of the two different net acreages is correct, and provide amended information as necessary: Site No. Net Acreage in Item I. 1. Net Acreage in Table 1 02-0'1 25.10 24.80 02-62 5.80 5.60 03-Ul 8.80 Not Listed 1 03-6,4 26.50 25.30 3 Form LASCA (continued): 3. Please address the following with respect to the buffer map submitted for the proposed new land application sites. Note that it may be necessary to submit Form BWAA, amend the buffer maps, amend the field net acreages in Item I. 1. of Form LASCA, as well as amend the total net acreage in Form LASCA and Form NDRLAP, depending on how this comment is addressed. Ensure that residences owned by the landowner or by a person who executed Form BWAA are indication as such on all buffer maps. ♦ Site No. 01-03: Clarify what is at the southeastern tip of this site (i.e., a residence, a structure/barn, etc.). If it is a residence, it does not appear as if a 400-foot buffer has been provided. In addition, verify whether or not a water supply well is present in this location. If there is, a minimum 250-foot buffer must be provided in order to establish the well outside of the site's compliance boundary. ♦ Site Nos. 02-02, -03, and -04: Verify whether or not a water supply well is present at the location of the unoccupied trailer in the middle of these sites. If there is, a minimum 250- foot buffer must be provided in order to establish the well outside of the sites' compliance boundaries. 4. No vicinity map or buffer map was included in the permit application package for Site No. 03-01, as is required by the fourth checkmark under Instruction B on Page 1 of 3. Please provide these maps accordingly. - Please reference the subject permit application number when providing the requested information. Four copies of all revised information should be submitted to my attention at the address on the first page of this correspondence. 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 this application package are still the responsibility of the applicant. In addition, any omissions made in responding to the requested additional information items may result in future additional information requests and delays in the issuance of a final permit. Therefore, read each additional information item carefully, and provide the information that is requested as well as any information that results from changes made as a result of this additional information request. If there is any question about what information is being requested or is desired, please do not hesitate to contact me at any time at (919) 733-5083, extension 353, or at shannon.thornburg@ncmail.net, and I will be happy to provide additional explanation as required. M Y Thank you in advance Ior your cooperation and assistance. S'. erely, Shannon Mohr Thornburg Environmental Engineer i cc: Mr. Scott D. Berg, Engineering Consulting Services, Ltd. Mr. A. Davis Benton, Atlantic Coast Contracting, Inc. Mr. Randall S. Jones, Raleigh Regional Office - Water Quality Section Mr. Grady Dobson, Fayetteville Regional Office - Water Quality Section Mr. Jay Zimmerman, P.G., Raleigh Regional Office - Groundwater Section 1VIr- -Art B ar-nhardt; Fa- etteAlle-Regional-Office =Groundwater Section -I Mr. David A. Goodrich, Central Office - Groundwater Section Permit File WO0023178 I 5 I t