WQ0002376_Additional Information Request_20220404

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
SUMMER WOODARD — CITY MANAGER
CITY OF REIDSVILLE
1100 VANCE STREET
REIDSVILLE, NORTH CAROLINA 27320
Dear Ms. Woodard:
NORTH CAROLINA
Environmental Quality
April 4, 2022
Subject: Application No. WQ0002376
Additional Information Request
City of Reidsville Class B Residuals
Program
Land Application of Class B
Residuals
Rockingham County
Division of Water Resources' Central and Regional staff has reviewed the application package
received November 9, 2021 and additional information received January 5, 2022. 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 May 4, 2022.
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 through C, or failure to provide the additional information on or before the above requested
date may result in your application being returned as incomplete pursuant to 15A NCAC 02T .0107(e)(2).
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 an
electronic response submitted to my attention at: https://edocs.deq.nc.gov/Fonns/NonDischar�4e-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
151r zz;lot�
Erick Saunders, Engineer
Division of Water Resources
cc: Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Brent Collins — EMA Resources Inc. (Electronic Copy)
Laserfiche File (Electronic Copy)
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
NORTH CAROLINA -
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Ms. Summer Woodard
April 4, 2022
Page 2 of 2
A. NC-RC-012-02
1. The updated site map for this field has a well shown in the middle of field 02B next to a structure.
The provided Landowner Agreement form (LOA) checked that a re -defined compliance boundary
is not needed, but in accordance with 15A NCAC 02L .0107(d), water supply wells are prohibited
within the compliance boundary. Please clarify whether this is a water supply well, and if it is a
redefined compliance boundary shall be requested in accordance with 15A NCAC 02T .0105(h).
B. NC-RC-015-01:
1. The previous additional information request from Vivien Zhong requested that field NC-RC-015-
01 be separated into several fields due to the differences in soil types and the size of the field. The
response on January 5, 2022 was as follows:
This field is farmed as one field and we do not wish to split this field into multiple fields. Every
field in all of our programs has multiple soil series. This is addressed as the predominant soil
series, which the soil scientist we hired to do the work has indicated. I haven't ever had DWR
suggest how afield should be farmed. Three different application rates for the same hayfield
doesn't work for us or the farmers involved.
The Division has concerns about the realistic yield indices (RYES) of the different soil types at the
hand auger borings (209 lb/ac for Clifford, 154 lb/ac for Fairview) combined with the apparent
proportion of the field that is listed as a Fairview or a Nathalie soil in the NRCS Soil. This field is
large enough that management as one soil series that isn't appropriate for a large proportion of the
field could result in more significant environmental impacts. Applying on this field at an agronomic
rate as a Clifford soil could lead to the over -application of nitrogen on approximately 20 acres. Due
to concern, we shall require a more conservative soil series for this section of the field. This can be
accomplished through either the establishment of separate management areas or categorizing the
whole field with a more conservative soil series.
2. The Permittee's Certification in the LOA for this field from Summer Woodard does not appear to
be certified through an e-signature. We received an e-signature signed by Summer Woodard dated
December 3, 2021 for the LOA of field NC-RC-012-02 that was certified by Adobe Sign, but no
such verification was provided for this LOA. Please provide an appropriate signature to verify the
Permittee's Certification.
C. NC-RC-126-06:
1. The Land Application Site Certification form (LASC) stated that Auman French would be the
Lessee or Operator for this field, but the Lessee's/Operator's Certification was not filled out in the
LOA. If Auman French is to be included as the lessee or operator for the field, this certification
shall be signed. If not, please clarify that there is no lessee for this site.
2. See comment B.2. The Permittee's Certification in the LOA for this field from Summer Woodard
does not appear to be certified through an e-signature. Please provide an appropriate signature to
verify the Permittee's Certification.