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Home My WebLink AboutWQ0037637_Additional Information Request_20200521ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director JOHN W. DUNHAM — PRESIDENT CRAVEN AG SERVICES, INC. 2155 NC HIGHWAY 55 NEW BERN, NORTH CAROLINA 28562 Dear Mr. Dunham: NORTH CAROLINA Environmental Quality May 21, 2020 Subject: Application No. WQ0037637 Additional Information Request Craven Ag Services RLAP Land Application of Class B Residuals Craven County Division of Water Resources' Central and Regional staff has reviewed the application package received March 19, 2020. 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 June 22, 2020. 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 and B, 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 two paper copies and one electronic copy submitted to my attention at the address below. If you have any questions regarding this request, please do not hesitate to contact me at (919) 707- 3659 or erickson.saunders@ncdenr.gov. Thank you for your cooperation. Sincerely, Erick Saunders Division of Water Resources cc: Washington Regional Office, Water Quality Regional Operations Section (Electronic Copy) Bob Branch, LSS — Branch Residuals & Soils, LLC (Electronic Copy) Permit Application File WQ0037637 D E Q�� 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 NoarH c oaouNa � oePxnmem i enmmomenwi auaiN /� 919.707.9000 Mr. John W. Dunham May 21, 2020 Page 2 of 3 A. Application: 1. Item III.4.a of the Distribution of Class A Residuals form (FORM: DCAR 06-16) states that the maximum amount of residuals to be certified is 51 dry tons per year (DT/yr.). However, the submitted Residuals Source Certification (FORM: RSC 06-16) summary forms propose a total of 36 DT/yr. Please clarify the proposed annual dry tons for this permit, as these two values should be consistent. 2. The submitted RSC 06-16 summary forms include the renewal of three previous sources and one new source. Once source included in the most recent June 21, 2017 Attachment A Certification, the C & P Enterprises' Ocean Bay Villas WWTP (WQ0003067), was not included in this table as renewed or deleted. It does not appear any data was submitted for this source for the renewal. Please indicate whether the source is being removed or renewed. If the latter, please submit an RSC 06- 16 form with the accompanying data. The proposed maximum DT/yr. for the Pruitt Health Care WWTP (NC0047759) source is given as 1 DT/yr., but the previously permitted dry tonnage limit was 0.73 DT/yr in the June 21, 2017 Attachment A Certification. The status for this source was listed as renewed, but an increase in dry tonnage would indicate a modification. Please indicate which of this these values are correct. (NOTE: This application is already a major modification request, so no additional fee would be required if it were to increase) 4. Operational data was not submitted in the application to support that each residuals source meets pathogen reduction and vector attraction reduction requirements. Please submit supporting data that each residuals source facility complies with pathogen and vector attraction reduction requirement alternatives chosen in sections II.7. and 11.8. of the RSC 06-16 for that source. B. Site Map: According to the summary table in the Land Application Site Certification form (FORM: LASC 06-16), some of the renewed residuals land application fields have increased in acreage from the previous permit. Upon comparison of the application's site maps with the site maps in the previous April 17, 2015 permit, it appears that this is in part due to setbacks between land application fields and perennial stream being changed from 100' to 33'. These fields include: a. Field 2-1 b. Field 2-3 c. Field 2-4 d. Field 2-5 e. Field 3-2 f. Field 3-3 g. Field 6-4 h. Field 7-1 i. Field 7-2 j. Field 7-3 k. Field 8-1 1. Field 10-1 While the setbacks in the rules have changed from 100' to 32.8' in the readoption of the 15A NCAC 02T .1100 rules effective September 1, 2018, the new sections of land application area opened up by the reduced setback were not previously permitted and would require a major modification of Mr. John W. Dunham May 21, 2020 Page 3 of 3 the permit to be included. These areas are typically in lower landscape positions and may have areas unsuitable for land application, and the original soil evaluation may not have included these areas because they were already outside of allowable setbacks at the time. We cannot permit the addition of land application area without an accompanying soil evaluation determining that this new area is suitable for land application. In order to use the extent of the fields using the 32.8' setback, a major modification request shall be submitted. Please note that no additional fee would be required because this is already a major modification request. This request should either include a new soils evaluation from a Licensed Soil Scientist (LSS) to determine soil suitability in these new areas, or a signed and sealed statement from a LSS stating that the soils are consistent with the original evaluation. If a major modification is not requested, a new LASC 06-16 summary form and site maps consistent with the previously permitted land application areas shall be submitted.