WQ0034513_More Information (Received)_20211108

willcox&mabe
SOI L SOLUTIONS
November 8, 2021
NCDEQ/DWR
Non -Discharge Branch
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Attention: Mr. Erick Saunders
Reference: Application for Brunswick County Class B Residuals Program
Permit No. WQ0034513
Additional Information Request dated November 4, 2021
Brunswick County, North Carolina
Willcox & Mabe Soil Solutions, PLLC Project No. 15-04, Phase: 14
Dear Mr. Saunders:
Willcox & Mabe Soil Solutions, PLLC (WMSS) is submitting the enclosed Additional
Information Response for the referenced permit application for Brunswick County Class
B Residuals 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 November 4, 2021. WMSS is providing response to
the following items with the request and response given below:
Item DI: According to the Brunswick County GIS website, there is a parcel with a place
of assembly under separate ownership located between fields NC-BR-RC-05 and RC-06
on parcel 1240000803 that is not depicted on the buffer map. This property is owned by
Clyde Galloway who was previously the owner of the fields at this site, meaning the
property line and place of assembly setbacks were not an issue. However, these setbacks
now apply because the parcel is now under separate ownership because Mr. Galloway
didn't execute a Land Owner Agreement.
These setbacks shall be shown on the resubmitted site map for this field as required by Item
D.1., and any acreage change shall be included in an updated LASC form. Alternatively, a
setback waiver may be executed in accordance with 15A NCAC 02T .1108(e) to reduce a
setback. Setback waivers shall be written, notarized, signed by all parties involved, and
recorded with the Brunswick County Register of Deeds.
Response: Attached is an updated Buffer Map and updated LASC Form.
Item E1: Section III on each of the LOAs submitted for the renewed fields do not
specify whether a re -defined compliance boundary is required for these fields due to a
water supply well inside the compliance boundary as per 15A NCAC 02L .0107(d).
Please mark this section in each LOA to indicate whether a re -defined compliance
Willcox & Mabe Soil Solutions, PLLC / 7231 B SummerFeld Road / Summerfield, NC 27358 / Rob 336.339.9128 or
Martin 336.312.1396 / www.willcoxmabesoil.com

Application for Brunswick County RLAP WMSS Project No. 15-04; Phase: 14
Additional Information Reauest — Application No. WQ000034513 November 8. 2021
boundary is needed for every site covered in the LOA. If so, the affected fields shall be
noted in this section in accordance with 15A NCAC 02T .0105(h) with the rationale for
the requested re -location of the compliance boundary.
Please note that there appear to be wells within the compliance boundary of the following
fields:
a. NC-BR-AH-03;
b. NC-BR-RC-05;
c. NC-CO-HH-07; and
d. NC-CO-HH-12.
If these wells are not water supply wells, then please reply that these wells would not need
to meet 15A NCAC 02L .0107(d), which prohibits the construction and operation of a
water supply well within the compliance boundary of a disposal system.
Response: Revised LOA's and revised Buffer Maps indicating a re -defined compliance
boundary is needed are included for the following fields (NC-BR-RC-05; NC-BR-HH-07
and NC-BR-HH-12). Field NC-BR-AH-03 is not revised since the submitted Buffer Map
has a 250 foot buffer around the on -site water supply well.
WMSS appreciates the opportunity to assist in responding to the Additional Information
Request for the Brunswick County Class B Residuals 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.
Partner / Agronomist Partner / Soil Scientist
Attachments
cc: Brunswick County
Shared\WMSS Projects\2015\15-04 Brunswick County\Phase 14 - 2021 Class B Permit Renewal\Additional
Information Request\15-04 Brunswick County Add Info 11-8-21.doc

ATTACHMENTS

�a
ion
v�
•�
a
D
a
D
a
d
d
d
p
O
d
d
d
,
a
0
r�
rx
rx
rx
rx
rx
rx
rx
�
C7
C7
C7
C7
C7
C7
�
a
a
y
on
bn
an
O
0
O
0
O
0
o
0
o
0
o
0
o
o
a;
Z
an
�c
�c
�c
o
�c
�c
O
,-
,4
,�
C7
C7
C7
C7
C7
C7
a
C7
y
Q
O
Q
O
Q
O
Q
O
Q
O
Q
O
Q
O
a
O
0
x
x
o
O
0
O
0
O
0
O
0
O
0
O
0
O
U
U
U
U
U
U
U
O
R
O
R
O
R
O
R
O
R
O
R
O
R
O
R
O
R
cd
+-'
cd
O
R
O
R
O
R
O
R
O
O
Per
O
R
U
O
U
U
U
U
U
U
U
U
U
U
U
U
U
U
O
O
O
O
O
O
O
O
U
U
U
U
U
U
U
U
CO
VO
01
O
CDN
�--i
N
��
N
00
N
[—
oO
z
0
0
0
U
U
U
U
U
U
C
O
O
O
o
0
0
0
0
0
CO
O
rA,
U
U
U
U
U
UCO
x
CO
CO
O
O
O
O
O
O
w
w
w
N
N
N
N
N
N
�
�
�
�
PLI
D
D
D
o
o'er
o'er
o
0
0
F�
x
x
x
O
°
0
0
0
P�
x
ti
ti
ti
ti
ti
ti
x
x
x
x
x
x
A
x
x
U
U
U
U
fY•
o
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x
x

O' CL
G'
O
G'
O
O
y
a
O
�o
-
U
O
�
U�"•'
C
C
cd
cd
cd
cd
cd
cd
cd
U
U
U
U
U
p-I
p-I
O
O
u
u
O
O
O
o
U
U
U
U
U
i+
Z
h
L
L
�
�
CL
O
d
d
d
�
a
U
U
Q
P,
Q
000000000
U
U
U
U
U
U
U
U
oo
En
En
En
En
En
En
En
En
En
1�
r
wo A
00
U
U
U
U
U
U
po
po
Q
c�
N
R-

CL
sue,
U
U
U
U
U
U
U
U
U
QI y
rram,,
� V
y
V]
V]
V]
V]
V]
V]
V]
V]
V]
V
O
O
En
En
En
O
O
o
�
p
O
O
O
3�
S
S
�D
�D
u
CVJ
N
N
N
N
n
o
N
N
aVi
o
z
z
z
z
z
z
z
z
z
a
0
^O
O
O
a
M
M
M
M
M
M
�
M
�
M
�
M
009
9�
9�
9�
9�
9�
__
__
00
00
00
00
00
00
00
00
00
00
O
M
M
M
M
M
M
M
M
M
A
Lv--

L 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(hl 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: HH-07 & HH-12 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

L 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(hl 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: HH-7 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

L 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.
IL 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(hl 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: RC-5 & RC-6 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