WQ0016247_Additional Information Request_20220823

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS,]R.
Director
NORTH CAROLINA
Environmental Quality
August 23, 2022
ROBERT N. ROTH — TECHNICAL SERVICES MANAGER
SYNAGRO CENTRAL, LLC
284 BOGER ROAD
MOCKSVILLE, NORTH CAROLINA 27028
Subject: Application No. WQ0016247
Additional Information Request
Synagro Western Piedmont Class B
Residuals Program
Land Application of Class B
Residuals
Statewide
Dear Mr. Roth:
Division of Water Resources' Central and Regional staff has reviewed the application package
received May 25, 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 September 22, 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 H, 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: b!Vs://edocs.deg.nc.gov/Fonns/NonDischarge-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,
czC�01
Erick Saunders, Engineer
Division of Water Resources
cc: Asheville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Mooresville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Winston-Salem Regional Office, Water Quality Regional Operations Section (Electronic Copy
Laserfiche File (Electronic Copy)
North Carolina Department of Environmental Quality I Division of Water Resources
QEQ>
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
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919.707.9000

Mr. Robert N. Roth
August 23, 2022
Page 2 of 6
A. Cover Letter:
1. No comments.
B. Application Fee:
1. No comments.
C. Residuals Land Application Program (FORM: RLAP 06-16) Application:
1. No comments.
D. Operation and Maintenance Plan (O&M Plan):
1. In accordance with 02T A I I0(a)(4)(B), spill control provisions shall include contact information for
program personnel, emergency responders, and regulatory agencies. The reporting section of the Spill
Response Plan mentions that the Mooresville Regional Office will be contacted in case of a spill. However,
this program expands through multiple regions. Please update the spill control provisions to include contact
information for all regional offices included in the program.
E. Residuals Source Certification (FORM: RSC 06-16) Form:
1. Please note that some of the RSC forms provided were using the RSC 08-11 and RSC 11-13 forms,
which is an outdated form. For future permit applications, please use the most up to date version of
this form to account for any rule changes.
2. The sodium adsorption ratio (SAR) for the Clariant Corporation Mount Holly West facility was
listed as 19.09. In accordance with Item II.5.c. of the RSC form, if SAR is above 10, the applicant
shall obtain recommendations from a professional regarding the sodium application rate. Please
note that this will need to be obtained prior to land application of residuals from this facility.
F. Land Application Site Certification (FORM: LASC 06-16) Form:
1. In accordance with Item B on the Instruction for FORM: LASC 06-16, an updated accounting of
the cumulative pollutant loading rate shall be provided for renewed and transferred fields. Some
fields did not include CPLRs, including NC-CH-044-07 through 11 (previously fields 32-14
through 32-17 in permit WQ0001169), NC-CH-072-03, NC-CH-073 Fields 3 through 6, NC-CH-
78 Fields 3 and 5, and NC-LT-54-RP-01 and RP-02.

Mr. Robert N. Roth
August 23, 2022
Page 3 of 6
2. There are several places of assembly under separate ownership that are depicted with reduced
setbacks on the setback maps without accompanying setback waivers. The following locations were
noted:
a. South of field NC-IR-20-03 on parcel 4774595828.000 in Iredell County;
b. North of field NC-IR-20-04A on parcel 4775809254.000 in Iredell County;
c. West of field NC-IR-37-03 on parcel 4820079509.000 in Iredell County;
d. South of field NC-RA-05-01 on parcel 271 020 in Rowan County;
e. North of field NC-RA-05-01 on parcel 271 025 in Rowan County; and
f. West of field NC-ST-02-01 on parcel 10000 in Stanly County.
The setbacks for a place of public assembly under separate ownership shall be shown on
resubmitted site maps for these fields, and any acreage change shall be included in an updated
LASC form. Alternatively, setback waivers 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 County Register of Deeds.
3. In accordance with 15A NCAC 02T . 1104(c)(2)(B), a representative soils analysis for standard soil
fertility and all pollutants listed in Rule .1105(b) shall be provided for new land application sites.
The analysis for NC-CD-03-04 is missing all metals in .1105(b) except mercury and the full soil
fertility analysis, while fields NC-CH-081-01 and 02 are missing the full soil fertility analysis.
Please provide a full representative soil analysis for these new fields.
4. The LASC summary page did not include a predominant soil series for the transferred and modified
fields NC-CH-044-07 through 11. Please provide this information in an updated LASC summary
page.
5. A map was provided for fields NC-CH-073-02, 07, 08, and 09. However, these fields were not
included in the LASC nor mentioned in the LOA for the other fields within CH-073. Please clarify
whether these fields are to be included in the application. If they are not being proposed in this
application, updated application and vicinity maps shall be provided that remove this project area.
If they included, an LOA shall be provided for this land.
6. The map provided for field NC-CL-08 Fields 10 through 13 also include Field 14. However, this
field was not included in the LASC nor mentioned in the LOA for the other fields within CL-08.
Please clarify whether this field is to be included in the application. If it is not being proposed in
this application, updated application and vicinity maps shall be provided that remove this project
area. If it is included, an LOA shall be provided for this land.
7. There are properties to the west of field NC-CL-08-13 that are not owned by the signatory of the
LOA for this field. These property lines shall be depicted in an updated map, and an appropriate
buffer given for these property lines. If the acreage changes due to these buffers, the updated
acreages shall be listed in an updated LASC.
8. Field NC-CL-52-04 appears to be owned by two different owners, Ron and Amy Parker and
Charles and Yvonne Parker. Most of the field is owned by the former Parker couple but parcel
64852 owned by the latter couple bisects it. As these are two different owners, the field needs to
buffer out property lines between each owner, unless reciprocating setback waivers are submitted
to waive the property line buffer in accordance with 15A NCAC 02T . 1108(e).
9. The map for field NC-RC-49-01 includes the deleted fields 2 through 6. Please submit this map
without these deleted fields.

Mr. Robert N. Roth
August 23, 2022
Page 4 of 6
10. The LASC soil series for fields NC-CH-044-12 and 13, NC-CH-073-03 and CH-81-01 and 02 don't
match the soil scientist recommendations and are instead listed as complexes. It is unclear what the
rationale for these complexes are, and it was noted that field NC-CH-044-13 was given as a Badin-
Taurus complex even though the predominant complexes mapped in the soil survey don't contain
Taurus soils. Additionally, field NC-CH-073-03 was listed as a Georgeville (GaB) when it was last
in WQ0007066 but has changed to Nanford-Badin. Please provide the rationale for the predominant
soil series in the LASC being different than the soil scientist's recommendations and previous
determinations and update the LASC with the appropriate soil series.
11. The regional office noted that there were several features in fields NC-CH-044-13, NC-CH-081-
01, and NC-CH-081-02 that are not suitable for land application and would require buffers,
including rock outcroppings, drainage features and streams. These are shown in Figures 1 through
7, attached. These features shall be depicted in updated maps, the appropriate setbacks shall be
applied, and any acreage change shall be included in an updated LASC form.
12. The map for NC-IR-41-02 seems to be missing an onsite house to the northeast of the field directly
adjacent to the field. This is on the same parcel as the land application field, and it is unclear if
there is a water supply well at this site that would require a buffer. An updated map shall be
provided depicting the structures and any features that would require a setback.
13. There does not appear to be a vicinity map, soils map, and application map for the new fields NC-
LT-52-05 and 06 in the application. Please submit the site map for these fields.
14. The LASC and the LSS cover page list field NC-LT-57-02 as Pacolet, but the soil profile
description for this field lists the soil series as "Cecil". Please clarify which soil series this field is
and make any relevant changes to the LASC.
15. The site map for site NC-PO-09 does not show the property line boundaries on site, so it is difficult
to verify the setbacks to property lines, specifically to parcel P132-85. This map shall be
resubmitted with the property line buffers depicted.
16. Regional office staff noted that there were two areas within field NC-PO-09-02 that could be
unsuitable for land application. The first is a depression and debris pile in the northern portion of
the field, and the second is a cattle trough with a concrete base in the eastern portion of the field.
These areas shall be removed from the land application area, unless it can be verified that it is
suitable for land application. If the acreage changes due to these buffers, the updated acreages shall
be listed in an updated LASC.
17. The coordinates for NC-RA-62-01 do not appear to be correct in either the LASC summary page
or the soil profile descriptions for the field in the soil scientist certification, which has the
coordinates near field NC-RA-62-02. It is unclear where this field is, and whether this soil profile
description is for field 01 and is not a second boring in field 02. Please provide accurate coordinates
for the field in an updated LASC and provide the location of the soil boring for this field to verify
the profile description labeled "RA-62 Field 1" in the soil scientist certification corresponds to this
field.
18. The regional office noted that the outbuilding shown on the map for NC-RC-50 to the southeast of
Field 2 is a business which is considered a place of public assembly. This place of public assembly
under separate ownership shall be shown on resubmitted site maps with the appropriate setbacks,
and any acreage change shall be included in an updated LASC form. Alternatively, setback waivers
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 County Register
of Deeds.

Mr. Robert N. Roth
August 23, 2022
Page 5 of 6
G. Landowner Agreement (FORM: LOA 06-16) Form:
1. The provided LOA for NC-AL-15 Fields 1 through 3 was signed by Ray Isenhour, but the deeded
owners on parcels 12394 and 12395 are Vinsen Lamar and Mary D. Icenhour. A new LOA executed
by a deeded owner shall be provided, or these fields shall be removed from the application in an
updated LASC. Alternatively, information shall be provided allowing Mr. Isenhour to sign on
behalf of these properties.
2. The provided LOA for field NC-CA-06-03 was signed by Neill Properties, but the deeded owner
on parcel REID 3487 is RFE Farms, Inc. A new LOA executed by a representative of this deeded
owner shall be provided, or this field shall be removed from the application in an updated LASC.
3. The provided LOA for NC-CA-53-03 and NC-LT-53-01 signed by Howard F. Goodson, Jr. did not
include a Permittee's Certification. This page shall be signed by a Permittee signature authority and
resubmitted.
4. The provided LOA for NC-CD-03 Fields 6 and 7 was signed by Patrick Starnes, but the deeded
owners on parcel 2797658251 are Richard S. and Guynell W. Sears. A new LOA executed by a
deeded owner shall be provided. Alternatively, information shall be provided allowing Mr. Starnes
to sign on behalf of this property.
5. The provided LOA for NC-IR-41-02 Fields 6 and 7 was signed by Curtis Johnson, but the deeded
owner on parcel 4742915477.000 is Superior Properties of Iredell Limited Partnership. A new LOA
executed by a representative of the deeded owner shall be provided. Alternatively, information shall
be provided allowing Mr. Johnson to sign on behalf of this entity.
6. The LOA provided for following fields do not appear to be notarized in accordance with 02T
.1104(c)(4).
a. Fields NC-CA-06 signed by Dennis Lutz;
b. Fields NC-CD-03-02, 03, 06, and 07 signed by Patrick Starnes;
c. Fields NC-IR-23-02 through 05 signed by Loraine Paige;
d. Field NC-LT-06-02/NC-LT-45-01 signed by Mike Macomson;
e. Field NC-LT-107-01 and 02 signed by Jason Huitt;
f. Field NC-LT-120-02 and 03 signed by Wayne Gilbert;
g. Field NC-ST-04-02, 04, and 05 signed by the Lynette W. Anderson Living Trust
Please provide copies of these LOAs that are notarized in accordance with 02T .1104(c)(4).
7. It was noted that the fields in NC-RC-50 are already a part of a different land application program
under a different name. They are fields NC-RC-018 Fields 1 and 2 of permit WQ0002376 in the
most recent permit issuance dated June 4, 2020, and Attachment B Certification issuance dated
April 25, 2022. For these fields to be included in this permit, the LOA shall be re -executed with
the acknowledgement of the field transfer to verify that the landowner agrees to the transfer.
Additionally, an updated accounting of the CPLR shall be provided for these fields.

Mr. Robert N. Roth
August 23, 2022
Page 6 of 6
8. The LOAs for fields NC-LT-06-02, NC-LT-23-01, NC-PO-02-02, NC-ST-03-0113, and NC-ST-
03-04 did not indicate any need for a re -defined compliance boundary for these sites. However, the
site maps for these fields indicate there are adjacent water supply wells that could be within the
compliance boundary.
15A NCAC 02L .0107(i) prohibits the construction and operation of water supply wells within the
compliance boundary. Please indicate whether there are any water supply wells within the
compliance boundary. 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.
H. County Board Notification (FORM: CBN 06-16):
1. No comments.

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