WQ0038499_Additional Information Response_20210909

willcoX&'l abe
SOIL SOLUTIONS
September 9, 2021
NCDEQ/DWR
Non -Discharge Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: Mr. Erick Saunders
Reference: Application for Bio-Green Services - Residuals Land Application Program
Permit No. WQ0038499
Additional Information Request dated September 3, 2021
Stanly County, North Carolina
Willcox & Mabe Soil Solutions, PLLC Project No. 21-06
Dear Mr. Saunders:
Willcox & Mabe Soil Solutions, PLLC (WMSS) is submitting the enclosed Additional
Information Response for the referenced permit application for Bio-Green Services
Residuals Land Application Program. Please accept this letter and the attachments as
response to the referenced items within the Additional Information Request from the
North Carolina Department of Environmental Quality (NCDEQ) — Division of Water
Resources (DWR), Non -Discharge Branch (NDB) dated September 3, 2021. WMSS is
providing response to the following items with the request and response given below:
Item III: The 2021 annual permit fee (2021 PR006694) is listed as overdue. In accordance
with 15A NCAC 02T .0120(c), this permit shall not be renewed if the Permittee or any
affiliation has not paid the required annual fee. The invoice for this fee is attached.
Response: Bio-Green Services has submitted the annual permit fee
Item D1: See Item E.I. Please clarify in the O&M plan the method of disposal for the
Enterprise Rendering Co. WWTF.
Response: The O&M Plan submitted indicates that permitted sources will demonstrate
compliance with Pathogen and Vector Attraction Reduction requirements based upon
conditions set forth in Permit No. WQ0038499. In the case of the Enterprise Rendering
Co. WWTF, since the source is generated from animal processing residuals, injection or
incorporation will be utilized for Vector Attraction Reduction.
Item E1: In Section II.8. of the RSC for the Enterprise Rendering Co. WWTF, it was
indicated that a vector attraction reduction alternative is not applicable because it is a
non -biological residual with no domestic wastewater. However, this is considered a
biological residual because it is a residual generated during the treatment of animal
processing wastewater and would require vector attraction reduction. This section of the
RSC shall be updated to indicate the vector attraction reduction alternative chosen.
Willcox & Mabe Soil Solutions, PLLC / 7231 B Summerfield Road / Summerfield, INC 27358 / Rob 336.339.9128 or
Martin 336.312.1396 / www.willcoxmabesoil.com

Application for Bio-Green RLAP WMSS Project No. 21-06
Additional Information Request —Application No. WQ0038499 September 9, 2021
Please note that the footnote in this section states that for animal processing residuals, only
injection and incorporation may be chosen due to the nuisance conditions that typically
occur when these residuals are applied and left on the land surface.
Response: Corrected RSC 06-16, Section IL8 is attached to indicate the source is
generated from animal processing residuals, and injection or incorporation will be
utilized for Vector Attraction Reduction.
Item E.2: The plant available nitrogen (PAN) calculation for the Enterprise Rendering
Co. WWTF residuals that were provided was for surface application of residuals. Please
provide the PAN calculations for subsurface application.
Response: The Residual PAN Calculation worksheet submitted has been updated to
reflect injection only and the applicable volatilization of ammonia nitrogen (attached).
Question FI : The soil series indicated that the predominant soil series present in Field 06-
O 1 is Badin (BaB). The soil boring located inside this field was mapped as Badin, but the
NRCS soil survey map shows the field consisted of almost 50% Goldston (GoC), and a
Division -placed soil boring on the eastern side of the field (shown in the attached site
map sketches) found that area to contain Goldston soils. Division staff contend that the
Goldston series is the predominant soil series of the field. The LASC summary form shall
update to show that Goldston (GoC) is the predominant soil series for Field 06-01.
Response: Updated LASC is attached
Item F2: The Soil Evaluation submitted in this report indicated that the predominant soil
series for Field 06-04 was Goldston, but the LASC summary page states that Badin is
predominant. The LASC table shall be updated to reflect that Goldston (GoC) is the
predominant soil series for this field
Response: Updated LASC is attached
Item F3: Division -placed soil borings indicate that there is an area in the northeastern
side of Field 06-02 which is adjacent to a surface water feature that has unsuitable depths
to rock and to the water table. The attached site map sketch indicates the location of
these unsuitable areas. The buffer map shall be revised to remove this area and the field
acreage for this field shall be updated in the LASC.
Response: Updated buffer map and revised LASC is attached
Item F4: There is a drainage ditch adjacent to field 06-04 which appears to extend into
the edge of the field, but due to access restrictions and standing row crops, Division staff
were unable to confirm if the ditch extended into the field and required buffers. This
drainage feature shall be shown on the application map, and the correct buffer shall be
applied. If the acreage of the field is affected, the LASC shall be updated with the
correct field acreage.
Response: The property line buffer indicated on the buffer map accounts for any buffer
necessary associated with this drainage feature. No updates to map or LASC is necessary.
2

Application for Bio-Green RLAP WMSS Project No. 21-06
Additional Information Request —Application No. WQ0038499 September 9, 2021
Item Gl: The LOA for field 06-05 did not indicate any need for a re -defined
compliance boundary for this site. However, the site map for this field indicates there
are multiple wells on this parcel that could be within the compliance boundary for this
field. 15A NCAC 02L .0107(d) prohibits the construction and operation of water supply
wells within the compliance boundary. Please indicate whether the wells on this field
are water supply wells. If so, then Section III of the LOA for this field shall be edited
to request a re -defined compliance boundary for this field in accordance with 15A
NCAC 02T .0105(h) with the rationale for the requested re -location of the
compliance boundary.
Response: Revised LOA is attached with rationale that the compliance boundary will
remain as indicated in the footnote on Figure 4 — Buffer Map.
WMSS appreciates the opportunity to assist in responding to the Additional Information
Request for the Bio-Green Residuals Land Application Program. If after reviewing the
enclosed information you have any questions or require any additional information,
please contact us at your convenience.
Sincerely,
Willcox & Mabe Soil Solutions, PLLC
Martin E. Mabe Rob Willcox, L.S.S.
Agronomist Soil Scientist
Attachments
cc: Bio-Green
Shared\WMSS Projects\2021\21-06 Enterprise Rendering Co\Additional Information Request\21-06 Enterprise Rendering
Add Info 9-9-21.doc
3

ATTACHMENTS

7. Pathogen Reduction: Per 15A NCAC 02T.1106, specify how residuals will meet the pathogen reduction requirements:
a. For Distribution/Land Application of Class A or Equivalent:
A fecal coliform density that is demonstrated to be less than 1,000 MPN per gram of total dry solids,
or
A salmonella sp. density that is demonstration to be less than 3 MPN per 4 grams of total dry solids.
AND one of the followings (except for non -biological residuals):
Alternative 1 [15A NCAC 02T.I 106(b)(3)(A)] - Time/Temperature Compliance.
Alternative 2 [15A NCAC 02T.I 106(b)(3)(B)] - Alkaline Treatment.
Alternative 3 [15A NCAC 02T.I 106(b)(3)(C)] - Prior Testing for Enteric Virus/Viable Helminth Ova.
Alternative 4 [15A NCAC 02T.I 106(b)(3)(D)] - No Prior Testing for Enteric Virus/Viable Helminth Ova.
Alternative 5 [15A NCAC 02T.I 106(b)(3)(E)-(K)] - Process to Further Reduce Pathogens (PFRP).
Specify one: In composting, 0 heat drying, n heat treatment,
❑ thermophilic aerobic digestion, Q beta ray irradiation,
Q gamma ray irradiation, or Q pasteurization.
b. For Land Application of Class B:
Alternative 1 [15A NCAC 02T.I 106(c)(1)] - Fecal Coliform Density Demonstration.
Alternative 2 [15A NCAC 02T.I 106(c)(2)] - Process to Significantly Reduce Pathogens (PSRP).
Specify one: aerobic digestion, air drying, L] anaerobic digestion,
composting, i I lime stabilization.
c. For Surface Disposal:
11 Select One of the Class A or Equivalent Pathogen Reduction Alternatives in Item II. 7a. above.
EJ Select One of the Class B or Equivalent Pathogen Reduction Alternatives in Item II. 7b. above.
El Exempt -If Daily Cover Alternative is chosen in Item II.8. below [15A NCAC 02T.1106(a)(2)].
[] Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
8. Vector Attraction Reduction (VAR): Per 15A NCAC 02T.1107, specify how residuals will meet the VAR requirements:
Q Alternative 1 [15A NCAC 02T.I 107(a)(1)] - 38% Volatile Solids Reduction (Aerobic/Anaerobic Digestion).
Q Alternative 2 [15A NCAC 02T.I 107(a)(2)] - 40-Day Bench Scale Test (Anaerobic Digestion).
Q Alternative 3 [15A NCAC 02T.I 107(a)(3)] - 30-Day Bench Scale Test (Aerobic Digestion).
Q Alternative 4 [15A NCAC 02T.I 107(a)(4)] - Specific Oxygen Uptake Rate Test (Aerobic Digestion).
Q Alternative 5 [15A NCAC 02T.I 107(a)(5)] - 14-Day Aerobic Processes.
Q Alternative 6 [15A NCAC 02T.I 107(a)(6)] - Alkaline Stabilization.
Q Alternative 7 [15A NCAC 02T.I 107(a)(7)] - Drying of Stabilized Residuals.
Alternative 8 [15A NCAC 02T.I 107(a)(8)] - Drying of Unstabilized Residuals.
Alternative 9 [15A NCAC 02T.I 107(a)(9)] - Injection.
Alternative 10 [15A NCAC 02T.I 107(a)(10)] - Incorporation.
Alternative for Surface Disposal Units Only - Soil/Other Material Cover [15A NCAC 02T.I 107(b)(2)].
Not Applicable - Non -Biological Residuals with NO Domestic Wastewater Contribution.
Note: For animal processing residuals, only alternatives 9 or 10 may be chosen due to the nuisance conditions that typically
occur when these residuals are applied and left on the land surface.
FORM: RSC 06-16 Page 5 of 5

Willcox & Mahe Soil Solutions, PLLC
RESIDUAL PAN CALCULATION
Enterprise Rendering Lagoon
TKN= 11,000 mg/kg
NH3= 1,600 mg/kg
NO3-NO2-N= 1.8 mg/kg
Min Rate= 0.20
PAN= [min.rate (TKN - NH3) + (NH3) + NO3-NO21
0.20 9,400 1,600
PAN= 3481.82 mg/kg
1.82
Calculate residual nitrogen for years 2,3,4 and 5 following the initial application to determine
the amount of PAN/DT remaining.
2ND YEAR RESIDUAL PAN
PAN= [min.rate (1st year org. - N 2nd year min. - N]
0.10 9,400 1,880
PAN= 752.00 mg/kg remaining from 1 st year application
3RD YEAR RESIDUAL PAN
PAN= [min.rate (2nd year org. - N 3rd year min. - N]
0.05 7,520 752
PAN= 360.96 mg/kg remaining from 1 st year application
4TH YEAR RESIDUAL PAN
PAN= [min.rate (3rd year org. - N 4th year min. - N]
0.03 6,768 361
PAN= 213.57 mg/kg remaining from 1 st year application
5TH YEAR RESIDUAL PAN
PAN= [min.rate (4th year org. - N 5th year min. - N]
0.02 6,407 214
PAN= 120.03 mg/kg remaining from 1 st year application
Residual PAN from years 2 thru 5 after the initial application = 1446.56 mg/kg
Application
Five Year Maximum
Method
First Year PAN
Adjusted PAN
(mg/kg)
(mg/kg)
Incorporation
3,482
4,928
Application
Five Year Maximum
Method
First Year PAN
Adjusted PAN
(lbs/DT)
(lbs/DT)
Incorporation
6.96
9.86

I. STIPULATIONS:
1. The landowner or his representative shall not enter into any additional residuals application contracts or agreements with another permitted
entity for the site(s) specified by this Agreement.
2. Should the landowner or his representative lease or otherwise permit the use of the land application site(s) to a third party, the landowner shall
be responsible to ensure that the third party agrees and complies with the terms and conditions of this Agreement.
3. The landowner or his representative shall adhere to the provisions of this Agreement until all of the site restrictions (under Section II) are met.
4. Notification of cancellation of this Agreement shall be immediately forwarded to NCDENR-DWR, Non -Discharge Permitting Unit, 1636
Mail Service Center, Raleigh, NC 27699-1636.
5. The Permittee must request and obtain a permit modification from the Division prior to a transfer of the land application site(s) to a new
landowner. In addition, the current landowner shall give a notice to the new landowner that gives full details of the residuals applied at the
land application site(s).
6. The Permittee has provided the landowner or his representative with information and data concerning the residuals land application program,
including an analysis of constituents of the residuals, residuals application methods, schedules for typical cropping patterns, a description of
the equipment used by the Permittee.
7. The Permittee will provide the landowner or his representative with a copy of the residuals permit prior to commencement of any residuals
land application event and a copy of the results of each soil analysis.
8. If the soil pH of the land application site(s) is not maintained at 6.0 or greater, sufficient amounts of lime shall be applied to achieve a final
soil pH of at least 6.0, unless an agronomist provides information indicating that the pH of the soil, residuals and lime mixture is suitable for
the specified crop.
9. The landowner or his representative and the Permittee will agree on residuals application rates and schedules based on crop patterns, results of
soil samples, and the permitted application limits.
10. The landowner or his representative will provide the Permittee with information regarding the amount and analysis of other sources of
nutrients (e.g., fertilizer, unregulated animal waste, etc.) that have been applied to the land application site(s).
11. The landowner or his representative will inform the Permittee of any revisions or modifications to the intended use and cropping patterns for
the land application site(s) prior to each planting season to enable the Permittee to amend this Agreement and schedule residuals land
application events at appropriate periods.
12. Specific residuals land application area boundaries shall be clearly marked on the land application site(s) by the Permittee, the landowner, or
his representative prior to and during a residuals land application event.
13. The landowner or his representative hereby authorizes the Permittee, local officials, and State officials or their representatives to; enter and
inspect any property, premises, or place on or related to the land application site(s) at any reasonable time for the purpose of determining
compliance with the permit; establish monitoring facilities on or near the land application site(s) as required by the permit; copy any records
that must be kept under the terms and conditions of the permit; take necessary leachate, surface water, groundwater, or soil samples during the
term of, and 12 months after termination of, this Agreement.
II. RESTRICTIONS:
1. Appropriate measures must be taken by the Permittee and/or the landowner or his representative to control public access to the land
application site(s) during active use and for the 12-month period following a residuals land application event. Such controls may include the
posting of signs that indicate the activities being conducted at the land application site(s).
2. Animals shall not be grazed on the land application site(s) for a 30-day period following a residuals land application event. Land application
sites that are to be used for grazing shall have fencing that will be used to prevent access during these periods after such residuals land
application events.
3. Food crops, feed crops, and fiber crops shall not be harvested for a 30-day period following a residuals land application event.
4. Food crops with harvested parts that touch the residuals/soil mixture and are totally above the land surface shall not be harvested for a 14-
month period following a residuals land application event.
5. Food crops with harvested parts below the surface of the land shall not be harvested for a 20-month period following a residuals land
application event when the residuals remain on the land surface for four months or longer prior to incorporation into the soil.
6. Food crops with harvested parts below the surface of the land shall not be harvested for a 38-month period following a residuals land
application event when the residuals remain on the land surface for less than four months prior to incorporation into the soil.
7. Turf grown on land where residuals are applied shall not be harvested for a 12-month period following a residuals land application event.
III. ALTERNATIVES FOR WATER SUPPLY WELLS INSIDE THE COMPLIANCE BOUNDARY: (please check one)
15A NCAC 02L .0107(d) prohibits water supply wells within the compliance boundary. However, 15A NCAC 02T .0105(h) allows the
compliance boundary to be placed closer to the waste disposal area, such that the water supply well is situated outside of the compliance
boundary provided the groundwater standards can be met at the newly -established compliance boundary. Please mark one of the following;
® A re -defined compliance boundary is needed for field(s) ID: 6-05 will have an alternative compliance boundary of 50' from each water
supply well that is located within 250' of the residual land application area, that is not also within 50' of the property boundary
(Please include the rationale for the requested re -location of the compliance boundary and attach a map showing the newly proposed
compliance boundary to the application package)
❑ A re -defined compliance boundary is not needed for this site.
IV. ACKNOWLEDGEMENT OF FIELD TRANSFER: (if needed)
❑ The land application field(s) ID: is currently permitted under another
residuals land application program; Permit Number WQ: The land owner hereby acknowledge that by signing this
agreement, he/she is requesting that the field(s) be removed from the previously permitted residuals land application program and transferred
into the new program;
(Name of the new program)
FORM: LOA 06-16 Page 2 of 3

LAND APPLICATION SITE CERTIFICATION
Applicant's name: BioGreen Services, Inc.
Land application sites currently certified: 56.8 net acres and Total to be certified: 71.9 net acres.
I. LAND APPLICATION SITE INFORMATION (See Instruction B):
Status
Code'
Site/Field
IDSeries
Landowners
s or O s
Lessee(s) Operator(s)
Net Acres
CountyCrop(s)
Predominant Soil
Nameb
Mapping Unit
or Rep. Slope'
D / T
02-01
Vereen, Pearly
15.0
Brunswick
DT
03-01
Green, Doris T. Thornton
6.4
Brunswick
D
03-02
Vereen, Nancy Tucker
4.7
Brunswick
D
03-03
Green, Doris T. Thornton
2.9
Brunswick
D
05-01
Saunders, Virginia Williams
7.6
Moore
D
05-02
Saunders, Virginia Williams
4.2
Moore
D
05-03
Saunders, Virginia Williams
4.5
Moore
D
05-04
Saunders, Virginia Williams
2.9
Moore
D
05-05
Saunders, Virginia Williams
2.2
Moore
D
05-06
Saunders, Virginia Williams
6.4
Moore
N
06-01
Enterprise Rendering,
Carroll Braun, Jr.
16.2
Stanly
Row Crops
Goldston
GoC
N
06-02
Enterprise Rendering,
Carroll Braun, Jr.
10.7
Stanly
Row Crops
Badin
BaB
N
06-03
Enterprise Rendering,
Carroll Braun, Jr.
10.6
Stanly
Row Crops
Goldston
GoB
N
06-04
Enterprise Rendering,
Carroll Braun, Jr.
26.6
Stanly
Row Crops
Goldston
GoC
N
06-05
Carroll Braun, Jr.
7.3
Stanly
Row Crops
Goldston
GoB
'Status Code for land application sites are: ♦ N (New) ♦ R (Renewed) ♦ M (Modified) ♦ T (Transferred) ♦ D (Deleted)
n Soil Series Name (i.e. Appling, Cecil, etc.)
`Mapping Unit must be consistent with those used in the County Soil Survey (i.e. for a 2-8% slope Cecil in Anson County the mapping unit is CeB2)
II. WATERBODY AND CLASSIFICATIONS INFORMATION (See Instruction C):
Site/Field ID
Latitude
Longitude
Location
Datum
Location Method Code
Location Accuracy
Waterbody Subbasin and
Stream Index No.
Current and Proposed
p
Class
06-01
350 13' 48"
800 16' 52"
NAD 83
MAP
Nearest Second
Unnamed tributary to Horse Branch/13-17-31-6
C
06-02
350 13' 44"
800 16' 36"
NAD 83
MAP
Nearest Second
Unnamed tributary to Horse Branch/13-17-31-6
C
06-03
350 13' 06"
800 16' 23"
NAD 83
MAP
Nearest Second
Unnamed tributary to Long Creek/13-17-31
C
06-04
350 13' 25"
800 16' 13"
NAD 83
MAP
Nearest Second
Unnamed tributary to Long Creek/13-17-31
C
06-05
350 13' 29"
800 15' 50"
NAD 83
MAP
Nearest Second
Unnamed tributary to Long Creek/13-17-31
C
FORM: LASC 06-16 Page 1