WQ0000838_More Information (Requested)_20230310

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
JASON A. SMITH — VICE PRESIDENT
GRANVILLE FARMS, INC.
POST OFFICE BOX 1396
OXFORD, NORTH CAROLINA 27565-1396
Dear Mr. Smith:
NORTH CAROLINA
Environmental Quality
March 10, 2023
Subject: Application No. WQ0000838
Additional Information Request
GFI Class B Residuals Program
Land Application of Class B
Residuals
Granville County
Division of Water Resources' Central and Regional staff has reviewed the application package
received on December 14, 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 April 10,
2023.
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 R, 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/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,
DocuSigned by:
A4-16 3
45A56104B4524E7...
Zachary J. Mega, Engineer II
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Drew Matthew — Soil Plus (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 -
OepaMlent of
EnulmnmeMal Duality 919.707.9000

Mr. Jason A. Smith
March 10, 2023
Page 2 of 14
A. Cover Letter:
1. Please revise "Roanoke Rapids Sanitary District WWTP" to "Roanoke River WWTP".
2. Please revise "Cole Park Plaza WWTP" to "Cole Park Plaza Shopping Center WWTP"
3. Please revise "Carolina Meadows WWTP" to "Chatham WRY".
4. Please revise "Briar Chapel Development WWTP" to "Briar Chapel WWTP"
5. Please revise "Louisburg WWTP" to "Louisburg WRF"
6. Please revise "Sunset WTP" to "Sunset Avenue WTP".
7. Please revise "Little Creek WWTP" to "Little Creek RRF"
B. Application Fee:
1. No comment.
C. Application (Form: RLAP 06-16):
1. Item III.2.a. — Please recalculate the PAN values in this table based on the latest laboratory
analytical reports.
2. Item III.2.c — Please recalculate the required acres using the updated PAN values from Item III.2.a.
3. There is no signature in the Applicant's Certification. Please provide a signature in compliance
with 15A NCAC OT .0106.
4. See Sections I and J. Please revise the facility names on the PAN calculation worksheet to match
the comments below for the RSC forms and the summary table.
D. Operation & Maintenance Plan:
1. No comment.
E. Sampling Plans(s):
1. No comment.
F. Process Flow Diauam(s) & Narrative(s):
1. See Sections I and J. Please revise the facility names to match the comments below for the RSC
forms and the summary table.

Mr. Jason A. Smith
March 10, 2023
Page 3 of 14
G. Ouantitative Justification(s):
1. See Sections I and J. Please revise the facility names to match the comments below for the RSC
forms and the summary table.
2. The 3-year average for Wilson WWTP (Hominy Creek WWTP) is 4,979 DT/yr and the proposed
dry tonnage for this facility is 2,000 DT/yr. Please verify that this permit will only be used as an
alternate for residuals generated from this source.
3. The 3-year average for Roanoke River WWTP (Roanoke Rapids WWTP) is 555 DT/yr and the
proposed dry tonnage for this facility is 318 DT/yr. Please verify that this permit will only be used
as an alternate for residuals generated from this source.
4. The 3-year average for Tar River Regional WWTP is 1,751 DT/yr and the proposed dry tonnage
for this facility is 800 DT/yr. Please verify that this permit will only be used as an alternate for
residuals generated from this source.
5. The 3-year average for Tar River WTP is 714 DT/yr and the proposed dry tonnage for this facility
is 318 DT/yr. Please verify that this permit will only be used as an alternate for residuals generated
from this source.
H. Source Vicinity Map(s):
1. See Sections I and J. Please revise the facility names to match the comments below for the RSC
forms and the summary table.
2. Governors Club WWTP is not shown in Figure 4. Please revise.
3. Lake Royale WWTP is not shown in Figure 29. Please revise.
I. Summary for Form: RSC 06-16:
1. Please revise the permit number for SGWASA WTP to NC0058416.
2. Please revise the permit number for Kerr Lake Regional WTP to NC0083101.
3. Please revise the permit number for Enfield WWTP to NC0084034.
4. Please revise the permit number for Consolidated Diesel to WQ0040079.
5. Please revise the permit number for Governors Club WWTP to WQ0000088.
6. Please revise the facility name from "Louisburg WWTP" to "Louisburg WRY".
7. Please revise the facility name from "Hominy Creek WWTP" to "Wilson WWTP".
8. Please revise the facility permit holder from "Kittrell Job Corp Center" to "U.S. Department of
Labor". Please revise the facility name to "Kittrell Job Corps Center".
9. Please revise the facility permit holder from "Luther Thomas Harden, 111" to "Arbor Hill MHP".
Please revise the facility name to "Arbor Hill MHP WWTP".

Mr. Jason A. Smith
March 10, 2023
Page 4 of 14
10. Please revise the facility permit holder for Shearon Harris NPP to "Duke Energy Progress, LLC".
11. Please revise the facility name from "Barclay Downs" to "Barclay Downs WWTP".
12. Please revise the facility permit holder from "Birchwood RV Park, LLC" to "ACG Birchwood,
LLC". Please revise the facility name from "Birchwood RV Park" to "Birchwood MHP WWTP".
13. Please revise the facility permit holder for Nature Trails MHP WWTP to "Nature Trails Association
CLP".
14. Please revise the facility permit holder for Fearrington Village WWTP to "Fearrington Village,
LLC".
15. Please revise the facility name from "Cole Park Plaza WWTP" to "Cole Park Plaza Shopping
Center WWTP".
16. Please revise the facility name from "Carolina Meadows WWTP" to "Chatham WRF".
17. Please revise the facility name from "Pope Industrial Park" to "Pope Industrial Park WWTP".
18. Please revise the facility permit holder from "Clarke Utilities" to "Clarke Utilities, Inc.". Please
revise the facility name to "Deer Chase WWTP".
19. Please revise the facility permit holder for Whippoorwhill Valley WWTP to "Clarke Utilities, Inc.".
20. Please revise the facility name from "Little Creek WWTP" to "Little Creek RRF".
21. Please revise the permit number for Tar River WTP to NC0072125.
22. Please revise the facility name from "Sunset WTP" to "Sunset Avenue WTP". Please revise the
permit number to NC0072133.
23. Please revise the facility name from "The Preserve at Jordan Lake" to "The Preserve at Jordan Lake
WWTP".
24. Please revise the facility name from "Colvard Farms" to "Colvard Farms WWTP".
25. Please revise the facility name from "Rockbridge Subdivision" to "Rockbridge WWTP".
26. Please revise the facility name from "The Legacy at Jordan Lake" to "Legacy at Jordan Lake
WWTP". Please revise the county to Chatham.
27. Please revise the facility name for "Briar Chapel Development" to "Briar Chapel WWTP".
28. Please revise the facility permit holder for Hasentree Golf Community to "Hasentree Owners
Association, Inc.".
29. Please revise the facility name from "Roanoke Rapids Sanitary District WWTP" to "Roanoke River
WWTP".

Mr. Jason A. Smith
March 10, 2023
Page 5 of 14
J. Application (Form: RSC 06-16):
a. Item 11.1. — The residuals generated from this facility are regulated under 40 CFR Part 257.
Please revise.
b. Item 11.2. —The residuals are defined as non -biological under 15A NCAC 02T .1102(6). Please
revise.
2. Kerr Lake Regional WWTP —
a. Item I.2. — Please choose an option.
3. Mallinckrodt WWTP —
a. Item I.1. — Please revise the facility name from "Mallinckrodt LLC" to "Mallinckrodt WWTP".
b. Item 11.8. —The residuals generated from this facility are biological. Please select a vector
attraction reduction (VAR) requirement and provide the latest laboratory results showing
compliance. [15A NCAC 02T .1107(a), 02T .1111(a), 02T .1111(c)]
4. Consolidated Diesel —
a. Item I.1. —Please revise the facility name from "Consolidated Diesel WWTP" to "Consolidated
Diesel".
b. Item I.5. — Please provide the approximate percentages of industrial and domestic wastewater.
c. Item II.1. — The residuals generated from this facility are regulated under 40 CFR Part 257.
Please revise.
5. Spring Hope WWTP —
a. Item I.2. — Please choose an option.
6. Louisburg WRF —
a. Item I.1. — Please revise the facility name from "Louisburg WWTP" to "Louisburg WRF".
7. Pittsboro WWTP —
a. Item I. I. — Please revise the facility name from "Town of Pittsboro WWTP" to "Pittsboro
WWTP".
8. Wilson WWTP —
a. Item 1.1. — Please revise the facility name from "Hominy Creek WWTP" to "Wilson WWTP"
9. Oxford WWTP —
a. Item I.1. — Please revise the facility name from "City of Oxford WWTP" to "Oxford WWTP".

Mr. Jason A. Smith
March 10, 2023
Page 6 of 14
10. SGWASA WWTP —
a. Item I.2. — Please choose an option.
11. Neuse River RRF —
a. Item 1.1. — Please revise the facility name from "Neuse River WWTP" to "Neuse River RRF".
12. Kittrell Job Corps Center —
a. Item I.2. — Please choose an option.
13. Shearon Harris NPP —
a. Item I.1. —Please revise the facility name from "Shearon Harris WWTP" to "Shearon Harris
NPP".
14. Knightdale Estates MHP WWTP —
a. Item I.1. — Please revise the facility name from "Knightdale MHP WTTP" to "Knightdale
Estates MHP WTTP".
15. Bunn WWTP —
a. Item I.1. —Please revise the facility name from "Town of Bunn WTTP" to "Bunn WWTP"
b. Item I.2. — Please choose an option.
16. Birchwood MHP WWTP —
a. Item I.1. — Please revise the facility naive from "Birchwood RV Park" to "Birchwood MHP
WWTP".
17. Cole Park Plaza Shopping Center WWTP —
a. Item I.1. — Please revise the facility name from "Cole Park Plaza WWTP" to "Cole Park Plaza
Shopping Center WWTP".
18. Cross Creek Mobile Estates —
a. Item I.I. —Please revise the facility name from "Cross Creek WWTP" to "Cross Creek Mobile
Estates".
19. Chatham WRF —
a. Item I.1. — Please revise the facility name from "Carolina Meadows WWTP" to "Chatham
WRY".
20. Pope Industrial Park WWTP —
a. Item I.I. —Please revise the facility name from "Pope Industrial Park" to "Pope Industrial Park
WWTP".

Mr. Jason A. Smith
March 10, 2023
Page 7 of 14
21. Kings Grant Subdivision WWTP —
a. Item I.I. — Please revise the facility name from "Kings Grant WWTP" to "Kings Grant
Subdivision WWTP".
22. Deer Chase WWTP —
a. Item 1.1. — Please revise the facility name from "Deerchase WWTP" to "Deer Chase WWTP".
23. Franklin County WWTP —
a. Item I.6. — Our records show this facility does have an approved pretreatment program. Please
revise.
24. Whippoorwhill Valley WWTP —
a. Item I.2. — Please choose an option.
25. Little Creek RRF —
a. Item I.1. — Please revise the facility name from "Little Creek WWTP" to "Little Creek RRF".
b. Item II.3.b. — Please revise the table with the results from the included TCLP analysis
performed in 2022.
26. Sunset Avenue WTP —
a. Item I.I. —Please revise the facility name from "Sunset WTP" to "Sunset Avenue WWTP".
27. The Preserve at Jordan Lake WWTP —
a. Item I.1. — Please revise the facility name from "The Preserve at Jordan Lake" to "The Preserve
at Jordan Lake WWTP".
28. Legacy at Jordan Lake WWTP —
a. Item 1.1. — Please revise the facility name from "The Legacy at Jordan Lake" to "Legacy at
Jordan Lake WWTP".
29. Briar Chapel WWTP —
a. Item I.1. —Please revise the facility name from "Briar Chapel Development" to "Briar Chapel
WWTP".
30. Hasentree Golf Community —
a. Item I.3. — Please provide contact information from the Hasentree Owners Association, Inc.

Mr. Jason A. Smith
March 10, 2023
Page 8 of 14
31. Roanoke River WWTP —
a. Item I.1. — Please revise the facility name from "Roanoke Rapids Sanitary District WWTP" to
"Roanoke River WWTP".
b. Item II.3.b. — Please revise the table with the results from the included TCLP analysis
performed in 2022.
32. The following residual source -generating facilities have a more recent toxicity characteristic
leaching procedure (TCLP) and corrosivity, ignitability, and reactivity laboratory results based on
the established monitoring frequencies in the existing permit:
• Mallinckrodt WWTP
• Pittsboro WWTP
• Neuse River RRF
• Tar River Regional WWTP
• Bunn WTTP
• Chapel Ridge WWTP
Please provide laboratory results within one calendar year of December 14, 2022, (i.e., the
application submittal date) or later for TCLP, corrosivity, ignitability, and reactivity, and update
Item II.3.b. for all the facilities listed above. [15A NCAC 02T .1111(a)]
33. The following residual source -generating facilities have more recent laboratory results for
nutrient/micronutrient and metal concentrations based on the established monitoring frequencies in
the existing permit:
• SGWASA WTP
•
Barclay Downs WWTP
• Kerr Lake Regional WTP
•
Bunn WTTP
• Enfield WTP
•
Lake Royale WWTP
• Mallinckrodt WWTP
•
Birchwood MHP WWTP
• Consolidated Diesel
•
Nature Trails MHP WWTP
• Governors Club WWTP
•
Fearrington Village WWTP
• Spring Hope WWTP
•
Hawthorne Subdivision
• Louisburg WRF
WWTP
• Pittsboro WWTP
•
Cole Park Plaza Shopping
• Henderson WRF
Center WWTP
• Warrenton WWTP
•
Ashley Hills WWTP
• Wilson WWTP
•
Avocet WWTP
• Oxford WWTP
•
Cross Creek Mobile Estates
• Enfield WWTP
•
Chatham WRF
• SGWASA WWTP
•
Mallard Crossing WWTP
• Neuse River RRF
•
Lake Ridge Aero Park
• Kittrell Job Corps Center
WWTP
• Tar River Regional WWTP
•
Pope Industrial Park
• Arbor Hill MHP WWTP
WWTP
• Neuse River Village
•
Beachwood WWTP
WWTP
•
Amherst Subdivision
• Shearon Harris NPP
WWTP
• Knightdale Estates MHP
•
Woodlake Country Club
WTTP
WWTP

Mr. Jason A. Smith
March 10, 2023
Page 9 of 14
• Kings Grant Subdivision
WWTP
• Crooked Creek WWTP
• Briarwood Farms WWTP
• Wildwood Green WWTP
• Deer Chase WWTP
• Willowbrook WWTP
• Neuse Colony WWTP
• Kenly Regional WWTP
• Cottonwood/Baywood
WWTP
• Tradewinds WWTP
• Franklin County WWTP
• Whippoorwhill Valley
WWTP
• Little Creek RRF
• Sunset Avenue WTP
• The Preserve at Jordan Lake
WWTP
• Colvard Farms WWTP
• Chapel Ridge WWTP
• Rockbridge WWTP
• Briar Chapel WWTP
• Westfall WWTP
• Hasentree Golf Community
• Roanoke River WWTP
Please provide laboratory results within one calendar year of December 14, 2022, (i.e., the
application submittal date) or later for nutrient/micronutrient and metal concentrations (including
total solids percentage under Item II.S.a.), update the tables under Item II.4.a. and Item II.S.b. for
all the facilities listed above. Please also recalculate the SAR under Item II.S.c., the PAN
concentrations under Item II.S.e., and any associated calculations on the Field Loading Estimates
worksheet. [ 15A NCAC 02T .1105, 02T .1111(c)]
34. The following residual source -generating facilities have more recent laboratory results for pathogen
reduction (PR) compliance based on the established monitoring frequencies in the existing permit:
• Mallinckrodt WWTP
•
Nature Trails MHP WWTP
• Consolidated Diesel
•
Fearrington Village WWTP
• Governors Club WWTP
•
Hawthorne Subdivision
• Spring Hope WWTP
WWTP
• Louisburg WRF
•
Cole Park Plaza Shopping
• Pittsboro WWTP
Center WWTP
• Henderson WRF
•
Ashley Hills WWTP
• Warrenton WWTP
•
Avocet WWTP
• Wilson WWTP
•
Cross Creek Mobile Estates
• Oxford WWTP
•
Chatham WRF
• Enfield WWTP
•
Mallard Crossing WWTP
• SGWASA WWTP
•
Lake Ridge Aero Park
• Neuse River RRF
WWTP
• Kittrell Job Corps Center
•
Pope Industrial Park
• Tar River Regional WWTP
WWTP (None provided.)
• Arbor Hill MHP WWTP
•
Beachwood WWTP
(None provided.)
•
Amherst Subdivision
• Neuse River Village
WWTP
WWTP
•
Woodlake Country Club
• Shearon Harris NPP
WWTP
• Knightdale Estates MHP
•
Kings Grant Subdivision
WTTP
WWTP
• Barclay Downs WWTP
•
Crooked Creek WWTP
• Bunn WTTP
•
Briarwood Farms WWTP
• Lake Royale WWTP (None
•
Wildwood Green WWTP
provided.)
•
Deer Chase WWTP
• Birchwood MHP WWTP
0
Willowbrook WWTP

Mr. Jason A. Smith
March 10, 2023
Page 10 of 14
• Neuse Colony WWTP
• Kenly Regional WWTP
• Cottonwood/Baywood
WWTP
• Tradewinds WWTP
• Franklin County WWTP
• Whippoorwhill Valley
WWTP
• Little Creek RRF
• The Preserve at Jordan Lake
WWTP
• Colvard Farms WWTP
• Chapel Ridge WWTP
• Rockbridge WWTP
• Briar Chapel WWTP
• Westfall WWTP
• Hasentree Golf Community
Please provide laboratory results within one calendar year of December 14, 2022, (i.e., the
application submittal date) or later showing compliance with the selected PR requirement under
Item II.7.b. for all the facilities listed above. [15A NCAC 02T .1106(b), 02T .1111(a), 02T
.1111(c)]
35. The following residual source -generating facilities have more recent laboratory results for vector
attraction reduction (VAR) compliance based on the established monitoring frequencies in the
existing permit:
• Consolidated Diesel
•
Ashley Hills WWTP
• Governors Club WWTP
•
Avocet WWTP
• Spring Hope WWTP
•
Cross Creek Mobile Estates
• Louisburg WRF
•
Chatham WRF
• Pittsboro WWTP
•
Mallard Crossing WWTP
• Henderson WRF
•
Lake Ridge Aero Park
• Warrenton WWTP
WWTP
• Wilson WWTP
•
Pope Industrial Park
• Oxford WWTP
WWTP (None provided.)
• Enfield WWTP
•
Beachwood WWTP
• SGWASA WWTP
•
Amherst Subdivision
• Neuse River RRF
WWTP
• Kittrell Job Corps Center
•
Woodlake Country Club
• Tar River Regional WWTP
WWTP
• Arbor Hill MHP WWTP
•
Kings Grant Subdivision
(None provided.)
WWTP
• Neuse River Village
•
Crooked Creek WWTP
WWTP
•
Briarwood Farms WWTP
• Shearon Harris NPP
•
Wildwood Green WWTP
• Knightdale Estates MHP
•
Deer Chase WWTP
WTTP
•
Willowbrook WWTP
• Barclay Downs WWTP
•
Neuse Colony WWTP
• Bunn WTTP
•
Kenly Regional WWTP
• Lake Royale WWTP (None
•
CottonwoodBaywood
provided.)
WWTP
• Birchwood MHP WWTP
•
Tradewinds WWTP
• Nature Trails MHP WWTP
•
Franklin County WWTP
• Fearrington Village WWTP
•
Whippoorwhill Valley
• Hawthorne Subdivision
WWTP
WWTP
•
Little Creek RRF
• Cole Park Plaza Shopping
•
The Preserve at Jordan Lake
Center WWTP
WWTP

Mr. Jason A. Smith
March 10, 2023
Page 11 of 14
• Colvard Farms WWTP
• Chapel Ridge WWTP
• Rockbridge WWTP
• Briar Chapel WWTP
• Westfall WWTP
• Hasentree Golf Community
Please provide laboratory results within one calendar year of December 14, 2022, (i.e., the
application submittal date) or later showing compliance with the selected VAR requirement under
Item II.8. for all the facilities listed above. [ 15A NCAC 02T .1107(a), 02T .1111(a), 02T .1111(c)]
K. Application (Form: LASC 06-16):
1. This was not included in the submitted application package. Please provide a completed Form:
LASC 06-16, which can be downloaded from the Non -Discharge website.
L. County Board Notification(s):
f1M►//1
M. Application (Form: LOA 06-16):
1. Site GF —
a. Please revise the Site/Field ID to "Site GF" on Page 1.
b. Please revise "GFI" to "GF" under Section III on Page 2.
2. Site 4801-CH —
a. On the LOA for Field 11, please revise Page 3 to leave Lessee's/Operator's Certification blank
as Mr. Deans already owns the field.
3. Site JC —
a. On the LOA for Fields 1-4, the signature under the Landowner's Certification is not the deeded
landowner. Please revise to Mr. Syke's signature or explain why Ms. Carpenter signed in place
of Mr. Sykes.
b. On the LOA for Fields 1-4, please add Field 3 under Section III on Page 2. There is a well next
to Field 3 within the property boundary.
c. On the LOA for Fields 5 and 8, the signature under the Landowner's Certification is not the
deeded landowner. Please revise to Ms. Syke's signature or explain why Ms. Lewis signed in
place of Ms. Sykes.
d. On the LOA including Field 7, Field 8 is listed again. Field 6 is not listed on any of the LOAs
for Site JC. Please revise.

Mr. Jason A. Smith
March 10, 2023
Page 12 of 14
N. Setback Waiver Aueement(s):
If a setback waiver will be obtained from a property owner for reduced setbacks to habitable
residences, please provide a completed Form: NDRMPW-LAS 11-18, which can be downloaded
from the Non -Discharge website. Please also make sure to update the buffer radius and notate the
residence on the applicable buffer map to show that the habitable residence has an associated
setback waiver.
O. Vicinity/Setback May(s):
1. Please provide color maps that are the original exports from ArcGIS. Also, make sure that the most
recent aerial imagery is shown for all maps.
2. Please put the compliance boundary language in a white text box for visibility on all maps. Some
maps have these while others do not.
3. Please add additional field number labels (without acreages) if the field is divided. Move the field
number and acreage labels inside the field boundary if possible. Use leader arrows where it may
be unclear. See how the Site MJ maps were labeled for an example.
4. Site MP —
a. If Charles M. Phillips is to be removed as the lessee, the 400-foot habitable residence setback
is not met for his property located at 1522 Bethlehem Church Rd (Parcel No. 035095) to Fields
1 and 14. Please either show the 400-foot setback buffer and reduce the field acreages
accordingly or obtain a setback waiver from Mr. Phillips. See Section N.
b. The 400-foot habitable residence setback is not met for the property located at 1532 Bethlehem
Church Rd (Parcel No. 003617) to Fields 1 and 14. Please either show the 400-foot setback
buffer and reduce the field acreages accordingly or obtain a setback waiver from the property
owner. See Section N.
c. The 400-foot habitable residence setback is not met for the property located at 1543 Bethlehem
Church Rd (Parcel No. 007084) to Field 14. Please either show the 400-foot setback buffer
and reduce the field acreage accordingly or obtain a setback waiver from the property owner.
See Section N.
5. Site 2009 —
a. There are updated property boundaries shown on the Granville County GIS portal located
around the western portion of Field 2. Please update the map to reflect the latest property
boundaries.
b. A redefined compliance boundary is required for the well located between Fields 1, 2, and 3.
Please show the 100-foot buffer, reduce the field acreages accordingly, and update Page 2 of
the LOA.
c. There are updated property boundaries shown on the Granville County GIS portal located
around the western portion of Field 4. Please update the map to reflect the latest property
boundaries.

Mr. Jason A. Smith
March 10, 2023
Page 13 of 14
6. Site 375 —
a. Please remove the labels, buffers, and application boundary areas for Field 3 since it will be
removed from this permit. Please also revise the title block of the map to reflect this.
7. Site GF —
a. Is the entire boundary of Field 6 shown on the map view?
8. Site JTB —
a. There is a duplicate "Field 2" label. Please revise.
9. Site BC —
a. There are application boundaries shown within buffer boundaries for all fields. Please revise
as it is unclear where the land application is occurring.
b. Why are there no 400-foot setback buffers shown for the habitable residences to the north of
Field 4? Please either show the 400-foot setback buffer and reduce the field acreage
accordingly or obtain a setback waiver from the applicable property owners. See Section N.
c. Comparing recent aerial imagery to what was shown on the Field 4 map, there appear to be
trees that have been cleared within the field boundaries. Please show the most recent aerial
imagery.
10. Site 8015-01 —
a. Please remove the labels, buffers, and application boundary areas for Field 1 since it will be
removed from this permit. Please also revise the title block of the map to reflect this.
11. Site JC —
a. There are updated property boundaries shown on the Nash County GIS portal located between
Fields 3, 5, 6, 7, and 8. Please update the map to reflect the latest property boundaries.
12. Site LF —
a. Please mark the on -site dwelling just east of Field A.
b. There is a parcel subdivision shown on the Nash County GIS portal located south of Field C.
Please update the map to reflect this parcel subdivision.
c. Please mark the on -site dwelling just west of Field D.
d. Comparing recent aerial imagery to what was shown on the Field D map, there appears to be a
new house within a separate parcel just east of the field boundary. Please update the map to
reflect the latest parcel boundaries and mark the off -site dwelling. Please either show the 400-
foot setback buffer and reduce the field acreage accordingly or obtain a setback waiver from
the property owner. See Section N.

Mr. Jason A. Smith
March 10, 2023
Page 14 of 14
P. Soil & Agronomic Evaluation(s):
1. N/A
Q. Updated Cumulative Pollutant Loading Rates (CPLRs):
1. Please remove any CPLR data listed for fields that will be removed from this permit.
2. Please revise the row alignments to line up with the correct field as they are shifted.
3. Please reorder the field names to be in sequential order. Some skip from 1 to 10, etc.
4. Please provide updated CPLR data for Site GF Fields 7A and 12A.
R. Recommendations: (Response not required)
1. Outdated forms were used throughout the submitted application package. For future submittals,
please make sure to download the latest forms from the Non -Discharge website before starting the
application process.
2. There is a typo in the word "Control" on one of the divider pages in the O&M Plan.
3. There is a typo in the word "Assessment" in Section 14.0 of the O&M Plan.
4. There is a typo in the "Kerr Lake Regional WTP" label on Figure 15.
5. A TCLP analysis was provided in the submitted application package for Tar River WTP and Sunset
Avenue WTP. Per the existing permit, these are not required to be submitted and can be omitted
from future application packages and responses.
6. There is extra text copied from Page 1 on Page 2 of the Site 4801-WP LOA.
7. For Site 4801-JH Field 8, there is a 400-foot habitable residence setback shown for an on -site
dwelling at the southern edge of the field. This is not required for on -site dwellings and can be
removed to increase the application area of the field if desired.
8. For Site JC Fields 1, 3, and 4, there is a 50-foot property setback shown on the interior boundary.
This is not required because the same landowner owns all four parcels that contain these three
fields. The buffer can be removed to increase the application area of the field if desired.