WQ0000838_Correspondence_20230322

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:
45A56104B4524E7...
Zachary J. Mega, Engineer II
Division of Water Resources
cc: Raleigh Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Drew Matthews — 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 17
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"
• We are referring to the same sources. Is it truly necessary to update the cover letter? All source names
will be updated in the Attachment A.
• The cover letter does not have to be updated. Please disregard these comments.
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.
• See comments under Section I and J.
2. Item 111.2.c — Please recalculate the required acres using the updated PAN values from Item III.2.a.
• See comments under Section I and J.
3. There is no signature in the Applicant's Certification. Please provide a signature in compliance
with 15A NCAC OT .0106.
• Our records show this page was signed.
• The version that was submitted through our website does not have a signature. This comment will be
retained in the revised letter.
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.

Mr. Jason A. Smith
March 10, 2023
Page 3 of 17
E. Sampling Plans(s):
1. No comment.
F. Process Flow Dinram(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.
• See comments under Section I and J.
G. Quantitative 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.
• The City of Wilson, Roanoke Rapids Sanitary District, and the City of Rocky Mount all hold Class B
permits. This permit serves as a supplement for these sources. Please see section III.6 of the submitted
RLAP form.
• These comments have been satisfied.
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.
• This was an oversight. Maps for these two sources will be added to the O&M Plan.
• These comments will be retained in the revised letter.

Mr. Jason A. Smith
March 10, 2023
Page 4 of 17
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 NCO083101.
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 WRF".
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, III" to "Arbor Hill MHP".
Please revise the facility name to "Arbor Hill MHP WWTP".
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 WRIT".
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.

Mr. Jason A. Smith
March 10, 2023
Page 5 of 17
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".
• All source names and permit numbers were taken directly from the most recently approved Attachment
A of the permit. Often times we are not made aware of changes to permit numbers and minor name
changes. Rather than update each individual RSC 06-16 form, we recommend updating the Residuals
Source Facility Summary form instead.
• Only the summary form needs to be updated. Comments to update facility names in other areas have
been removed from the revised letter. In the future, the latest NPDES permits can be accessed via the
public Laserfiche to verify the latest permit owner/facility name:
https:Hedocs.deq.nc. gov/WaterResources/Welcome.aspx?dbid=0&repo=WaterResources&cr=1
J. Application (Form: RSC 06-16):
1. SGWASA WTP —
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)]
• Please see Footnote 6 in the Attachment A of Permit No. WQ0005537. VAR is not required for this
source. We request that the same footnote be added to this permit.
• This comment has been satisfied.

Mr. Jason A. Smith
March 10, 2023
Page 6 of 17
4. Consolidated Diesel —
a. Item 1.1. —Please revise the facility name from "Consolidated Diesel WWTP" to "Consolidated
Diesel".
b. Item I.S. — Please provide the approximate percentages of industrial and domestic wastewater.
c. Item 11.1. —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".
10. SGWASA WWTP —
a. Item I.2. — Please choose an option.
11. Neuse River RRF —
a. Item I.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.I. —Please revise the facility name from "Shearon Harris WWTP" to "Shearon Harris
NPP".
14. Knightdale Estates MHP WWTP —
a. Item I. L — Please revise the facility name from "Knightdale MHP WTTP" to "Knightdale
Estates MHP WTTP".

Mr. Jason A. Smith
March 10, 2023
Page 7 of 17
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 name from "Birchwood RV Park" to "Birchwood MHP
WWTP".
17. Cole Park Plaza Shopping Center WWTP —
a. Item 1.1. — 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.1. — 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
WRF".
20. Pope Industrial Park WWTP —
a. Item I.I. —Please revise the facility name from "Pope Industrial Park" to "Pope Industrial Park
WWTP".
21. Kings Grant Subdivision WWTP —
a. Item 1.1. — 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.I. —Please revise the facility name from "Little Creek WWTP" to "Little Creek RRF".

Mr. Jason A. Smith
March 10, 2023
Page 8 of 17
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.1. —Please revise the facility name from "Sunset WTP" to "Sunset Avenue WWTP".
27. The Preserve at Jordan Lake WWTP —
a. Item I.I. —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 I.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.
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.
• Once again, most of these requests are minor name changes. Rather than update each individual
RSC 06-16 form, we recommend updating the Residuals Source Facility Summary form instead.
• Only the summary form needs to be updated. Comments to update facility names in other areas have
been removed from the revised letter. In the future, the latest NPDES permits can be accessed via the
public Laserfiche to verify the latest permit owner/facility name:
https://edocs. deq.nc. gov/WaterResources/Welcome.aspx?dbid=0&repo=WaterResources&cr=1
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

Mr. Jason A. Smith
March 10, 2023
Page 9 of 17
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)]
• We began renewing this permit over 2 years ago. The process was severely hampered by the COVID
pandemic. 2021 lab data was submitted for all sources because it was the most recent year that we had a
complete year of data. When renewing permits we try to use the same calendar year data because all
reporting is done on a calendar year basis. This gives us the most accurate snapshot of the program in
regard to average PAN loadings and field acreages used on an annual basis. The data provided is an
accurate representation of each source. We cannot locate in the 2T rules or application instructions where
it states that data must be from within 12 months of the submittal date.
• Items II.3.b., II.4.a., and II.S.a. of Form: RSC 06-16 specify that the "latest" analyses be provided, and all
monitoring frequencies generally fall within one calendar year. Given that the 2022 Residuals Annual
Report was recently submitted, please provide a signed certification from Mr. Jason A. Smith that
confirms the 2022 Residuals Annual Report contains:
o Laboratory analyses that are representative of the 2021 results used in this renewal application.
o Laboratory analyses that are within the required limits for TCLP, metals, corrosivity, ignitability,
and reactivity.
• This will satisfy the comments concerning the age of the laboratory analyses except for Arbor Hill MHP
WWTP, Lake Royale WWTP, and Pope Industrial Park WWTP, which did not provide any
documentation for PR/VAR. The following comments will be combined into one and modified in the
revised letter.
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
• Kerr Lake Regional WTP
• Enfield WTP
• Mallinckrodt WWTP
• Consolidated Diesel
• Governors Club WWTP
• Spring Hope WWTP
• Louisburg WRF
• Pittsboro WWTP
• Henderson WRF
• Warrenton WWTP
• Wilson WWTP
• Oxford WWTP
• Enfield WWTP
• SGWASA WWTP
• Neuse River RRF
• Kittrell Job Corps Center
• Tar River Regional WWTP
• Arbor Hill MHP WWTP
• Neuse River Village WWTP
• Shearon Harris NPP
• Knightdale Estates MHP WTTP
• Barclay Downs WWTP
• Bunn WTTP
• Lake Royale WWTP
• Birchwood MHP WWTP
• Nature Trails MHP WWTP
• Fearrington Village WWTP
• Hawthorne Subdivision WWTP
• Cole Park Plaza Shopping Center WWTP
• Ashley Hills WWTP
• Avocet WWTP
• Cross Creek Mobile Estates
• Chatham WRF
• Mallard Crossing WWTP
• Lake Ridge Aero Park WWTP
• Pope Industrial Park WWTP
• Beachwood WWTP
• Amherst Subdivision WWTP
• Woodlake Country Club WWTP
• 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

Mr. Jason A. Smith
March 10, 2023
Page 10 of 17
• 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.5.a.), update the tables under Item 11.4.a. and Item II.5.b. for
all the facilities listed above. Please also recalculate the SAR under Item II.5.c., the PAN
concentrations under Item II.5.e., and any associated calculations on the Field Loading Estimates
worksheet. [ 15A NCAC 02T .1105, 02T .1111(c)]
• We began renewing this permit over 2 years ago. The process was severely hampered by the COVID
pandemic. 2021 lab data was submitted for all sources because it was the most recent year that we had a
complete year of data. When renewing permits we try to use the same calendar year data because all
reporting is done on a calendar year basis. This gives us the most accurate snapshot of the program in
regard to average PAN loadings and field acreages used on an annual basis. The data provided is an
accurate representation of each source. We cannot locate in the 2T rules or application instructions where
it states that data must be from within 12 months of the submittal date.
• See the previous comment.
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:
•
Fearrington Village WWTP
•
Mallinckrodt WWTP
•
Hawthorne Subdivision WWTP
•
Consolidated Diesel
•
Cole Park Plaza Shopping Center WWTP
•
Governors Club WWTP
•
Ashley Hills WWTP
•
Spring Hope WWTP
•
Avocet WWTP
•
Louisburg WRF
•
Cross Creek Mobile Estates
•
Pittsboro WWTP
•
Chatham WRF
•
Henderson WRF
•
Mallard Crossing WWTP
•
Warrenton WWTP
•
Lake Ridge Aero Park WWTP
•
Wilson WWTP
•
Pope Industrial Park WWTP (None provided.)
•
Oxford WWTP
•
Beachwood WWTP
•
Enfield WWTP
•
Amherst Subdivision WWTP
•
SGWASA WWTP
•
Woodlake Country Club WWTP
•
Neuse River RRF
•
Kings Grant Subdivision WWTP
•
Kittrell Job Corps Center
•
Crooked Creek WWTP
•
Tar River Regional WWTP
•
Briarwood Farms WWTP
•
Arbor Hill MHP WWTP (None provided.)
•
Wildwood Green WWTP
•
Neuse River Village WWTP
•
Deer Chase WWTP
•
Shearon Harris NPP
•
Willowbrook WWTP
•
Knightdale Estates MHP WTTP
•
Neuse Colony WWTP
•
Barclay Downs WWTP
•
Kenly Regional WWTP
•
Bunn WTTP
•
Cottonwood/Baywood WWTP
•
Lake Royale WWTP (None provided.)
•
Tradewinds WWTP
•
Birchwood MHP WWTP
•
Franklin County WWTP
•
Nature Trails MHP WWTP
9
Whippoorwhill Valley WWTP

Mr. Jason A. Smith
March 10, 2023
Page 11 of 17
• 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)]
• We began renewing this permit over 2 years ago. The process was severely hampered by the COVID
pandemic. 2021 lab data was submitted for all sources because it was the most recent year that we had a
complete year of data. When renewing permits we try to use the same calendar year data because all
reporting is done on a calendar year basis. This gives us the most accurate snapshot of the program in
regard to average PAN loadings and field acreages used on an annual basis. The data provided is an
accurate representation of each source. We cannot locate in the 2T rules or application instructions where
it states that data must be from within 12 months of the submittal date.
• See the previous comment.
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
• Governors Club WWTP
• Spring Hope WWTP
• Louisburg WRF
• Pittsboro WWTP
• Henderson WRF
• Warrenton WWTP
• Wilson WWTP
• Oxford WWTP
• Enfield WWTP
• SGWASA WWTP
• Neuse River RRF
• Kittrell Job Corps Center
• Tar River Regional WWTP
• Arbor Hill MHP WWTP (None provided.)
• Neuse River Village WWTP
• Shearon Harris NPP
• Knightdale Estates MHP WTTP
• Barclay Downs WWTP
• Bunn WTTP
• Lake Royale WWTP (None provided.)
• Birchwood MHP WWTP
• Nature Trails MHP WWTP
• Fearrington Village WWTP
• Hawthorne Subdivision WWTP
• Cole Park Plaza Shopping Center WWTP
• Ashley Hills WWTP
• Avocet WWTP
• Cross Creek Mobile Estates
• Chatham WRF
• Mallard Crossing WWTP
• Lake Ridge Aero Park WWTP
• Pope Industrial Park WWTP (None provided.)
• Beachwood WWTP
• Amherst Subdivision WWTP
• Woodlake Country Club WWTP
• Kings Grant Subdivision WWTP
• Crooked Creek WWTP
• Briarwood Farms WWTP
• Wildwood Green WWTP
• Deer Chase WWTP
• Willowbrook WWTP
• Neuse Colony WWTP
• Kenly Regional WWTP
• CottonwoodBaywood 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

Mr. Jason A. Smith
March 10, 2023
Page 12 of 17
• 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)]
We began renewing this permit over 2 years ago. The process was severely hampered by the COVID
pandemic. 2021 lab data was submitted for all sources because it was the most recent year that we had a
complete year of data. When renewing permits we try to use the same calendar year data because all
reporting is done on a calendar year basis. This gives us the most accurate snapshot of the program in
regard to average PAN loadings and field acreages used on an annual basis. The data provided is an
accurate representation of each source. We cannot locate in the 2T rules or application instructions where
it states that data must be from within 12 months of the submittal date.
• See the previous comment.
K. Application (Form: LASC 06-16):
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.
This was omitted in error. The LASC 06-16 can be provided.
This comment will be retained in the revised letter.
L. County Board Notification(s):
1. N/A
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.
• We are referring to the same site. This has no effect on the Attachment B of the permit.
• This comment has been removed from the revised letter.
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.
• Scott Deans owns and operates the field, he signed both by mistake. His name can be left off as the
operator on the Attachment B of the permit. There is no need to re-sign the LOA.
• This comment has been removed from the revised letter.

Mr. Jason A. Smith
March 10, 2023
Page 13 of 17
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.
• Mr. Wilton Sykes is deceased. His daughter, Catherine Sykes Carpenter, is heir to the property so
she signed the LOA as the responsible party.
• This comment has been satisfied.
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.
• This can be addressed as a footnote on the Attachment B.
• Please correct Page 2 of the LOA to add the well. It does not need to be resigned or re -notarized.
This comment will be retained in the revised letter.
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.
• Mrs. Barbara Sykes is in a nursing home facility and unfit to handle her affairs. Her daughter, Lisa
Sykes Lewis, is her legal POA so she signed the LOA as the responsible party.
• This comment has been satisfied.
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.
• This is a mistake. It should be 6 and 7. Fields 6 and 7 belong on the same LOA and Fields 5
and 8 belong on the same LOA.
• Please correct these LOAs. They do not need to be resigned or re -notarized. This comment will be
retained in the revised letter.
N. Setback Waiver Amement(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):
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.
When updating imagery on maps, site features rarely match up exactly as when they were originally
drawn. This makes it appear that the maps are not accurate and creates issues. The map is a guide as to
what to look for in the field, all buffers are flagged in accordance to what is found in the field prior to
application.
The aerial imagery does not need to be updated unless it is specifically called out to be substantially
different. The Non -Discharge Branch is transitioning to be fully digital and we would prefer to have the
highest quality maps attached to the permits. The Map Guidance for Residuals Land Application Fields
policy specifies that "all maps are to be originals or I" generation copies to insure they are clear and
legible". The quality of the aerial in black and white makes it difficult to discern field boundaries and

Mr. Jason A. Smith
March 10, 2023
Page 14 of 17
buffers. This comment will be revised in the letter, but color original or 1 It
generation copies must be
provided for all vicinity/setback 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.
• All of these maps have been previously approved. The maps that have the language were drawn after the
map requirements were updated.
• This comment has been removed from the revised letter. However, a renewal is a re -permitting process
and anything previously approved is subject to comment. This may be due to previous reviewer errors,
rule changes, etc.
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.
Putting the field acreages inside of the fields boundaries on the maps makes it difficult for field
operators to read and decipher all buffers on the map. All of these maps have been previously approved.
This comment has been removed from the revised letter. However, a renewal is a re -permitting process
and anything previously approved is subject to comment. This may be due to previous reviewer errors,
rule changes, etc.
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.
• We will discuss with the property owners and see how to move forward with this.
• These comments will be retained in the revised letter. After reviewing 15A NCAC 02T .1108(c), a
400-foot setback buffer or setback waiver is needed from Mr. Phillips regardless of if he is to be
retained as the lessee for the LOA because his residence is not maintained as part of the project site.
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.

Mr. Jason A. Smith
March 10, 2023
Page 15 of 17
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.
• These maps have been previously approved on multiple occasions. The property lines mentioned do
not effect buffers or field acreages.
• A renewal is a re -permitting process and anything previously approved is subject to comment. This
may be due to previous reviewer errors, rule changes, etc. The property lines mentioned do affect
the buffers and/or field acreages as they are the parcel boundaries surrounding the field(s). There are
different owners on each side of these property lines as well. These comments will be retained in
the revised letter except for the well comment.
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.
• This is a mistake. One of these should be field 7.
• This comment will be retained in the revised letter.
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.
• These houses to the North of field 4 are either buffered 400 foot or the 400 foot buffer falls into an
area that is already buffered out due to slope. The acreage is correct.
• This comment has been satisfied.
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.
• These maps have been previously approved on multiple occasions. The acreage is correct.
• A renewal is a re -permitting process and anything previously approved is subject to comment. This
may be due to previous reviewer errors, rule changes, etc. The aerial imagery is substantially different
in the Field 4 area. The Site BC maps are difficult to discern where the application area is for all
fields. These comments will be retained in the revised letter except for the habitable residences buffer
comment.
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.

Mr. Jason A. Smith
March 10, 2023
Page 16 of 17
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.
• If this map is updated with new property lines and the map is re -drawn, how will the division handle
any areas located under the old property line buffers and any increases in acreage that may occur?
• An abbreviated soil report shall be provided by a licensed soil scientist that certifies the previously
buffered areas are consistent with the soil type of the current field application area and are suitable for
residual land application. No additional borings or laboratory testing is needed. This comment will
be retained and modified in the revised letter.
12. Site LF —
a. Please mark the on -site dwelling just east of Field A.
• The house is uninhabitable.
• This comment has been satisfied.
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.
• The same landowner owns both parcels and the property line does not effect the field buffers?
• This comment has been removed from the revised letter.
c. Please mark the on -site dwelling just west of Field D.
• The structure is a barn, not a dwelling.
• This comment has been satisfied.
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.
• We will discuss this with the property owner and see how to move forward with this.
• This comment will be retained in the revised letter.
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.
• The CPLR summary is generated by GFI's database program that is used to track all land application. The
program keeps track of all sites that have been historically permitted, whether the site is still permitted or
not. The row alignment between the field and the data is slightly shifted, however all data is still correct.

Mr. Jason A. Smith
March 10, 2023
Page 17 of 17
The misalignment is minimal, this seems a bit excessive? Some fields may be out of order but all data is
present, with the exception of GFI fields 7A and 12A. CPLR data for those 2 fields can be provided.
• Only the updated CPLR data is needed for the missing fields. The other comments will be removed
from the revised letter.
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.
• New forms will be used in future applications.
• This comment will be retained in the revised letter.
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.
• These typos have no effect on the application or our operations. We are not sure what is gained by
pointing these out?
• These comments are provided as a courtesy. No response is required for them. These comments will be
retained in the revised letter.
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 Ion 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.