WQ0037637_Additional Information Received_20200601

BRANCH RESIDUALS & SOILS,LLC
1735 Heckle Blvd,Suite 103-291,Rock Hill,SC 29732
PHONE[phone]
May 28,2020
N.C. Department of Environmental Quality
Division of Water Resources RECEIVEDINCDEQIDWR
512 North Salisbury Street JUN Q 1 2020
1617 Mail Service Center
Raleigh,North Carolina 27699-1617
Non-Discharge
ATTENTION: Mr. Erick Saunders Permitting Unit
REFERENCE: APPLICATION NO.WQ0037637
ADDITIONAL INFORMATION REQUEST
Craven Ag Services, Inc.
New Bern,North Carolina
BR&S Job No. 2019-133
Dear Mr. Saunders:
On behalf of Craven Ag Services, Branch Residuals & Soils has prepared the following response
concerning the above referenced Additional Information Request dated May 21, 2020 (Attachment
A). There are three items of additional information requested in the afore-mentioned letter. They
will be addressed separately below:
Application
1. Item 111.4 of the DCAR states that maximum number of dry toms is 51 dry tons per year, However
the RSCA summary forms propose a total of 36 dry tons.
A DCAR is required for a Class A Distribution permit. Each of these sources are Class B and the
appropriate RLAP form was completed and attached. The amount listed in the RLAP is correct at 51
dry tons per year. The Residuals Source Facility Summary has been modified to reflect the correct
dry tons (Attachment B).
2. The submitted RSC 06-16 summary forms include the renewal of three previous sources and one
new source. No mention was made of the C&P Enterprises'Ocean Bay Villas WWTP.Please
clarify the intent regarding this source.
It is Craven Ag services desire to remove the Ocean Bay villas as a source. The Residuals Source
Facility Summary has been modified to reflect the correct dry tons (Attachment B).

P
• 'Craven Ag Services,Inc. Permit WQ0037637 BR&S Project 2019-133
NCDEQ—DWR Additional Information Request May 25, 2020
3. The proposed maximum DT/yr for the Pruitt Health Care WWTP source is given as 1 DT/yr
which is different from 0.73 DT/yr currently listed in the permit, which is correct?
It is Craven Ag services desire to change the proposed dry tons from 0.73 to 1. The Residuals Source
Facility Summary has been modified to reflect the correct dry tons(Attachment B).
4. Operation Vector and Pathogen Data were not included,please advise.
Branch Residuals & Soils did not include any vector and pathogen data because I assumed the
NCDEQ review staff had access to the 2019 Land Application Annual Report for Craven Ag Services.
This was the first year I prepared the annual report and do not have any additional vector and pathogen
data other than reported in the 2019 annual report. I have included the available lime stabilization
data for the Towns of Bridgeton and Maysville(Attachment C). I do not have any Pathogen or vector
attraction data for Pruitt Health or River Bend (as it is a new source). This should not be as issue as
the permit establishes treatment standards.
5. Site Maps and Acreages.
As better imagery, parcel information, and GIS data become available changes will continue to be
made to maps that reflect the best most accurate version of the land application sites available. As
time has progressed it has often resulted in changes in the acreages that have been submitted and
approved. With changes in the NCDEQ approved setbacks, changes in the permitted acreage are
bound to occur. The change in the approved setbacks to surface water from 100 feet to 32.8 feet to
Class B surface land application is certainly unprecedented particularly since the Class A setbacks for
surface water remain at 100 feet. One thing to remember when reviewing these fields the buffer at
the time these fields were permitted was 50 feet for subsurface application. All of these fields were
previously approved for subsurface application with rates and acreages provided in the Attachment B
in 2017.
To provide a bit of explanation,I have enclosed several figures in Attachment D. The first was copied
from the Craven County Soil Survey Figure 19 and givens a brief visual representation of how
artificial surface drains can work. This is called the catena effect. This figure illustrates how it can
be manipulated through artificial drainage but if the drainage is not artificial it is not groundwater
lowering(it is just native water table). The point being that the shallowest water table in the coastal
plain is not always but typically the midpoint between two surface water features in certain
topography and landscape positions.
2

Craven Ag Services, Inc. Permit WQ0037637 BR&S Project 2019-133
NCDEQ—DWR Additional Information Request May 25, 2020
Each of the figures submitted in the original renewal modification package had buffering of 33 feet
for surface water features. On the topographic maps these are listed as "blue line streams" and are
not groundwater lowering devices, although they may have been at one time. Now these are
considered waters of the state of North Carolina
The second figure is a Goggle Earth image that shows Figure that illustrates Fields 2-1 through 2-5.
Note that adjacent to the fields with the reduced buffer there is a white area. This white area is the
road the farmer used to navigate around the fields. The white area often denotes better drained
conditions. This is consistent with the cantina effect from a water table perspective.
The third figure is a blowup of a portion of Figure 2 that illustrates that the pink solid (33 ft surface
water buffer) does not encroach on the 50 foot property line buffer and those distances remain
mutually exclusive (Attachment D). Therefore, no additional land has been included only a
clarification of application maps.
Based on the presented data in Attachment D,the following observations are provided for the various
fields.
a. Field 2-1 —Soil Scientist Certification is attached.
b. Field 2-3 —A portion of this field has a separation for the property line and has no different
dimension than previously permitted in the last submittal and a portion of the field has a Soil
Scientist Certification.
c. Field 2-4—A portion of this field has a separation for the property line and has no different
dimension than previously permitted in the last submittal and a portion of the field has a Soil
Scientist Certification.
d. Field 2-5- A portion of this field has a separation for the property line and has no different
dimension than previously permitted in the last submittal and a portion of the field has a Soil
Scientist Certification.
e. Field 3-2—All of this field has a separation of the property line and has no different dimension
that previously permitted.
f. Field 3-3- A portion of this field has a separation for the property line and has no different
dimension than previously permitted in the last submittal and a portion of the field has a Soil
Scientist Certification.
3

Craven Ag Services, Inc. Permit WQ0037637 BR&S Project 2019-133
NCDEQ—DWR Additional Information Request May 25, 2020
g. Field 6-4-Soil Scientist Certification is attached.
h. Field 7-1- Soil Scientist Certification is attached.
i. Field 7-2- A portion of this field has a separation for the property line and has no different
dimension than previously permitted in the last submittal and a portion of the field has a Soil
Scientist Certification.
j. Field 7-3 - Soil Scientist Certification is attached.
k. Field 8-1 -All of this field has a separation of the property line and has no different dimension
that previously permitted.
1. Field 10-1 - All of this field has a separation of the property line and has no different
dimension that previously permitted.
As stated previously a minor permit modification fee was submitted with the Craven Ag services
renewal and modification submittal. This modification can and does cover Both
• Changes to sources (dry tons) addition or sources and deletion of sources and
• Changes to land acreage.
In times past the changes in the acreage have often been minute and the result of more accurate
mapping that clarify the maps to be used without the cost or a modification fee. If that is no longer
the case, please inform me as soon as possible as that will alter the way I submit future renewals and
modifications.
Branch Residuals & Soils and Craven Ag Services continue to be advocates for the safe land
application of these soils in an environmentally protective manner. Once you receive this response, I
will be glad to explain this once you have the information to review. If you or others have any
question or comments,please contact me at(336)312-9007.
Sincerely,
)77(
Robert T.Branch
Soil Scientist
Attachments
A Additional Information Request dated May 21, 2020
B Updated Residual Source Facility Summary Form
C Lime Stabilization Information for Maysville and Bridgeton for 2019
D Soil Scientist certification and Catena Effect Supporting Evidence
4

Attachment A
Additional Information Request dated May 21, 2020

o, STATE y��y"�
4 - i, yt
ROY COOPER s� ��
Governor u
MICHAEL S.REGAN '`� n�• /ate
Secretary ` ,,"'°
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
May 21,2020
JOHN W.DUNHAM—PRESIDENT
CRAVEN AG SERVICES,INC.
2155 NC HIGHWAY 55
NEW BERN,NORTH CAROLINA 28562
Subject: Application No. WQ0037637
Additional Information Request
Craven Ag Services RLAP
Land Application of Class B
Residuals
Craven County
Dear Mr. Dunham:
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. 1
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 [e-mail]. Thank you for your cooperation.
Sincerely,
spun
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
1 North p of m :act Qu i i W Re
512 NorthCarolina SalisburyDe Streetartment 1KI7Env Mailiron Service Centerality; RaleigDivhsion.Northofater Carolinasources 27b99 1h17
0.� /`d 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.
3. 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 I1.7. and II.8.of the RSC 06-16 for that source.
B. Site Map:
1. 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.

Attachment B
Updated Residuals Source Facility Summary

RESIDUALS SOURCE FACILITY SUMMARY
Applicant's name:Craven Ag Services, Inc,
Status Maximum Dry Tons Per Year
Facility Permit Holder Facility Name County Permit Number
Code Current b Proposed
R Town of Maysville Maysville WWTP Jones NC0021482 15 30
R Town of Bridgeton Bridgeton WWTP Craven NC0074837 5 5
R Pruitt Health—Sea Level,NC Pruitt Health Care Carteret NC0047759 1 1
N Town of River Bend River Bend WWTP Craven NC0030406 0 15
D C&P Enterprises Ocean Bay Villas WTP Craven WQ0003067 1 0
a Status Code for source facility are: •N(New) •R(Renewed) •M(Modified) •D(Deleted)
b The amount of residuals currently permitted for distribution,land application,or disposal(i.e,not applicable to new facility).
SUMMARY FOR FORM:RSC 06-16 Page 1

Attachment C
2019 Lime Stabilization for Maysville and Bridgeton

,
CRAVEN AG SERVICES INC.
Alkaline Stabilization Of Solids Analysis Bench Sheet
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Attachment D
Soil Scientist Certification and Catena Effect Supporting Evidence

Allen Roach Farm
Allen Roach has two tracts with Fields 2-1, 2-2, 2-3, 2-4, 2-5, 3-1, 3-2, and 3-3 (owned by Allen
and wife Gloria) and Fields 6-1, 6-2, 6-3, 6-4, 7-1, 7-2, 7-3, 7-4, 8-1, and 10-1 ( owned by the
Winfred Roach Trust). Please refer to the buffer maps for a visual depiction of the fields. Each
of these fields had been previously permitted form surface and subsurface application. The
previous permitted acreage had a setback from surface water of 100 feet and 50 feet for subsurface
application. With the recent changes in the surface water setback for Class B land application,the
setback is now 33 feet. This resulted in small amounts of acreage being added to these fields (the
difference of 17 feet along surface water—50 feet minus 33 feet). In my professional opinion,the
17 feet change in selected areas of the fields are soils that are similar to those originally mapped
as the predominant soil for the field, if not better drained. Even if the soil is better drained, due
to the small amount of acreage, the predominant soil type would remain unchanged.
It should be noted in several of these fields that the 33 feet surface water setback is also overlapped
with the 50-foot parcel line buffer. As has been the case in the past,the stricter buffer(the 50-foot
property line) still takes precedence.
These fields are mapped with soils that will be make it difficult to land apply at will due to soil wetness
conditions. Timing of applications due to crop planting, harvesting, soil wetness, and rainfall will
continue to provide challenges. Crop management guidelines that will be of importance for this
site will be:
• Proper coordination with land applier to incorporate biosolids,
• Good communication with farmer, land applier, and WWTP ORC, and
• proper coordination between application events and crop harvesting and planting.
,gyp SOIL SC
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52 Soil Survey
Each strip is crowned to aid
surface water movement to
drainage ditches.
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Figure 19.—Artificial drainage systems are commonly used in areas of very poorly drained soils.The distance between ditches varies with
the kind of soil and the crops to be grown.
In the wetter soils, the area between the ditches is Erosion. Control of water and wind erosion is needed
crowned in the middle to allow excess water to run off. on some sods in Craven County. Water erosion is a
In some fields, water furrows, or hoe drains, are used to hazard on the gently sloping Bragg, Craven, and Norfolk
carry the surface water to the field ditches. Drainage soils and on the moderately steep Suffolk soils. Some
ditches, tile drains, and flashboard risers can be used to short steep slopes along major drainageways and some
control the removal of excess water and subsurface small, narrow, gently sloping areas of soils near smaller
irrigation. By impounding runoff water, they also aid in drainageways are also susceptible to erosion.
denitrification, which improves water quality. Land Conservation practices that help control water erosion
grading is often used to fill in low areas or depressions, include grassed waterways (fig. 21), field borders,
to smooth fields, and to make a uniform grade for conservation tillage, crop residue management,
removing excess rain water. Caving of ditchbanks can be diversions, close-growing crops in rotations, and, on
a problem in some coarse-textured soils. some soils, a permanent plant cover. A combination of
Tillage of wet, loamy soils destroys soil structure, and these practices is generally needed where row crops are
large clods form (fig. 20), resulting in a poor seedbed. grown. In areas of the more poorly drained soils, the use
The Bayboro, Craven, Leaf, Lenoir, Meggett, and of hoe drains can cause erosion. Drop structures are
Roanoke soils are particularly susceptible to clodding. needed where the hoe drains let out into open ditches to
Timing farming operations on the wet organic soils is prevent ditchbanks from washing away. Erosion can be
critical because these soils are subject to becoming reduced on these soils by land grading the fields to
waterlogged and untrafficable. Subsidence, exposure of reduce the number of hoe drains needed. Controlling
buried logs and wood, and possible ground fires after erosion improves crop production and water quality and
drainage are also concerns in management of organic lowers the loss of nutrients.
soils.

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