WQ0024577_NORR-2020-LV-0150 Response_20200414

April 14, 2020
NC DEQ/DWR
Washington Regional Office
Attn: Robert Tankard
943 Washington Square Mall
Washington, NC 27889
Subject: NORR Response
NORR-2020-LV-0150
Sutton's Retirement Center WWTF
W0024577
Wayne County
Dear Mr. Tankard,
I am in receipt of your letter dated February 26, 2020 regarding high nitrate nitrogen levels in
MW - 2 for December 2018 and November 2019. The following comments are made concerning the
exceedances:
• The effluent Total Kjeldahl Nitrogen (TKN) normally averages approximately 10.0 mg/L. There appeared
to be an abnormal effluent sample on July 31, 2019 when nearly every sampled parameter was
extraordinarily high.
• During the spray event, a certain percentage of the TKN will volatilize. The manuals suggest that 50% of
the ammonia nitrogen will be lost during this process. Based on the average TKN in the effluent and even
accounting for a volatilization rate that is less than 50%, it does not appear that there is potential for the
wastewater to cause an exceedance of the nitrate nitrogen groundwater standard.
• In our July 2018 permit renewal application, we questioned the validity of the MW monitoring results as
they pertained to the Retirement Center. The MWs surrounding the spray field are in a highly agricultural
area and any possible contamination may be due to these influences. These influences include a hog
lagoon, cow pastures and cropland. Directly across the property line from MW — 2 is a field that
regularly has animal waste applied to it.
• A proper cover crop is maintained on the spray field year-round.
• Sampling procedures will be evaluated to ensure that representative samples are being taken.
• When possible, sampling of the MWs may be adjusted if an agricultural application has recently been
made on the adjoining property.
Thanks for your consideration in this matter. In addition to the retirement center, I am a lifetime farmer and
recognize the importance of properly protecting the land and groundwater. If you have any questions or
comments, please call me at: 919/738-2236.
Sincerely,
l
i
Gary Sutton
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