WQ0000672_More Information (Requested)_20230103

ROY COOPER Governor lktv
ELIZABETH S. BISERSecretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Environmental Quality
January 3, 2023
COREY J. WALTERS — PUBLIC WORKS DEPUTY DIRECTOR
CITY OF LUMBERTON
POST OFFICE BOX 1388
LUMBERTON, NORTH CAROLINA 28359
Subject: Application No. WQ0000672
Additional Information Request
City of Lumberton Class B
Residuals Program
Land Application of Class B
Residuals
Robeson County
Dear Mr. Walters
Division of Water Resources' Central and Regional staff has reviewed the application package
received December 2, 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 February
2, 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 S, 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: httt)s://edocs.dea_.nc.e_ ov/Fonns/NonDischar2_ e-Branch-
Submittal-Form-Ver2.
If you have any questions regarding this request, please contact me at [phone] or
zacharv.meaa(&ncdenr.aov. Thank you for your cooperation.
Sincerely,
DocuSigned by:
A4-163-
45A56104B4524E7...
Zachary J. Mega, Engineer II
Division of Water Resources
cc: Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Michael C. Hunt, PG — Enviro-Choice Recycling, LLC (Electronic Copy)
Laserfiche File (Electronic Copy
Flo
Q North Carolina Department of Environmental Quality I Division of Water Resources
D E vvvJ/ 512 North Salisbury Street 1 1617 Mail Service Center I Raleigh, North Carolina 27699-1617
NORTH CAROLINA
oePemmem of Environmental uuahty /`� 919.707.9000

Mr. Corey J. Walters
January 3, 2023
Page 2 of 7
A. Cover Letter:
1. No comment.
B. Application Fee:
1. No comment.
C. Application (FORM: RLAP 06-16):
1. Section III — Residuals Land Application Program Information:
a. Item 3 — The ORC and Back -Up ORCs listed here do not match our current records. Michael
C. Hunt is listed as the ORC and Henry B. Harper and Eric T. Locklear are listed as the Back -
Up ORCs for this permit. If Matthew F. Markus and Paul J. Ivey are to be added and Henry B.
Harper is to be retained, please submit the latest WPCSOCC form, which has been attached,
listing their information. Please follow the directions at the bottom of the form as it should be
sent to the listed WPCSOCC address and the Fayetteville Regional Office. After this has been
completed, the designated ORC and Back -Up ORCs will be updated in our records. [15A
NCAC 02T .0117, 08G .0204]
b. Item 4.a. — The calculated PAN values are incorrect. Please correct these values. See Section
E.3.e.
c. Item 4.c. — The minimum acreages calculated are based on incorrect first -year and five-year
PAN values. Please update this table using the correct PAN calculations. See Section E.3.e.
D. Operation and Maintenance Plan:
1. No comment.
E. Application (FORM: RSC 06-16):
If the City of Lumberton WTP is to be added back onto this permit as a residuals source facility, a
separate FORM: RSC 06-16 must be completed and a vicinity map, process flow diagram,
quantitative justification, sampling plan, laboratory analytical reports, and PRNAR compliance
documentation must be provided. Please make sure to adjust the proposed maximum dry tons per
year and all related calculations to account for the additional residuals source facility. [15A NCAC
02T .I 104(b)]
2. Summary for FORM: RSC 06-16:
a. Please correct the permit number for the City of Lumberton WWTP to the NPDES permit
number.
b. Please correct the status code for the City of Lumberton WTP to "New" and provide a proposed
dry tonnage.

Mr. Corey J. Walters
January 3, 2023
Page 3 of 7
3. Section II — Residuals Quality Information:
a. Item 3 — The TCLP results are from August 26, 2021. Please provide the latest lab results. If
the lab reports list "ND" as the result, please list the detection limit for the analyte instead. The
results for the reactivity test should be filled out as well. [15A NCAC 02T .1104(b)]
b. Item 4 — The reported metal concentrations are from August 26, 2021. Please provide the latest
lab results. If the lab results are reported on a wet weight basis (mg/L), please convert them to
a dry weight basis (mg/kg) using the total solids percentage before reporting them in this table.
Please provide a worksheet showing these conversions. [ 15A NCAC 02T .1104(b), 02T .1105]
c. Item 5.b. — The reported nutrient/micronutrient concentrations are from August 26, 2021.
Please provide the latest lab results. If the lab reports list "ND" as the result, please list the
detection limit for the analyte instead and use this value for calculations. [15A NCAC 02T
.1104(b)]
d. Item 5.c. — The calculated SAR is incorrect. Please recalculate using the latest lab results. Using
the previously reported values, we are getting a SAR of 9.27, which is close to the allowable
maximum without special recommendation.
e. Item 5.e. — The calculated PAN values are incorrect. Please recalculate these values using the
latest lab results and reference the attached worksheet example.
F. Process Flow Diagram:
1. No comment.
G. Ouantitative Justification:
1. No comment.
H. Samuling Plan:
1. No comment.
I. Laboratory Analvtical Reuorts:
1. For future application submittals, please only attach the relevant lab results that are listed within
the application forms or used for calculations. No response is required.
J. PR/VAR Compliance Documentation:
1. No comment.
K. Auulication (FORM: LOA 06-16):
1. For future application submittals, please list the City of Lumberton under the "Applicant's name"
section on the first page of the LOA instead of the landowner. No response is required.

Mr. Corey J. Walters
January 3, 2023
Page 4 of 7
2. For Site NC-RO-17, "Y" is filled out in the "Lease" columns, but no lessee is provided on the last
page of either LOA. On the LASC, the lessee is listed as Delois Allen. Please add the lessee's
information to these two LOAs.
3. For Field NC-RO-20-03 and Fields NC-RO-20-06 through NC-RO-20-08, Section IV of the LOA
should only be filled out if fields are to be transferred from a different permit to WQ0000672.
Please remove this information as these fields are already part of this permit.
4. For Fields NC-RO-39-07 and NC-RO-39-08, "Y" is filled out in the "Lease" column, but no lessee
is provided on the last page of the LOA or the LASC. Please change it to "N" if there is no lessee
for these fields.
L. Application (FORM: LASC 06-16):
1. Comparing the LASC to the previous permit's Attachment B, Fields NC-RO-18-01, NC-RO-18-
02, and NC-RO-21-01 through NC-RO-21-05 are missing from this application. Are these fields to
be removed from this permit? For future application submittals, please summarize any new,
modified, transferred, or removed fields in the cover letter to aid in review.
2. For Fields NC-RO-16-16 through NC-RO-16-19, the lessee listed on the signed LOA is Arrin
Ozzell Baker and not Delois Baker. Please correct.
For Fields NC-RO-17-01 through NC-RO-17-04, there are duplicate Field IDs with different
acreages. Please remove the duplicates and update the total acreage to be certified for this permit.
If the previously permitted fields are increasing in acreage, please list them as modified and not
renewed.
4. For Site NC-RO-17, the landowner is listed as either Lumberton Municipal Airport or the City of
Lumberton while the corresponding LOAs list the landowner as only the City of Lumberton. Please
verify and update.
For Fields NC-RO-39-05 and NC-RO-39-06, Barbara Bullard is listed as the landowner with
Patrick Bullard as the lessee, however, Patrick Bullard is listed as the landowner with no lessee on
the signed LOA. Please correct.
6. For Field NC-RO-39-09, there is no listed lessee, but on the signed LOA Patrick Bullard is listed
as the lessee. Please update.
Vicinitv/Setback Maps:
1. For information on completing vicinity/setback maps please refer to the items listed under 15
NCAC 02T .1104(c)(1) and Map Guidance for Residuals Land Application Fields, which has been
attached. Please update all vicinity/setback maps for the following:
a. The title block for each map should contain the county where the site is located, the landowner's
name, the name of the permittee and/or permit number, and the Site ID/Field IDs.
b. The total field acreages and net applicable acreages (application area) for each field after
setbacks are considered should be included on each map.
c. Show linework for streams, surface water, channels, and ditches on each map. Some maps do
not have this delineated, while others do.

Mr. Corey J. Walters
January 3, 2023
Page 5 of 7
d. For all setback radii, please show a symbol in the center representing what the setback is for
(i.e., off -site dwelling, well, surface water, etc.) Please note that for surface application by
vehicle and injection/incorporation by irrigation there is no required setback for on -site
dwellings. Some maps do not show these icons, while others do. [15A NCAC 02T .11081
e. Add a note to each map stating "The compliance boundary is established at either 250 feet from
the residuals land application area or 50 feet within the property boundary, whichever is closest
to the residuals land application area." [15 NCAC 02T .1104]
f. Recommend that map legends across all maps have the same content and follow the same
symbology.
g. Recommend decreasing the line weight for the application area boundary for readability. On
some maps, it appears that the application area is overlapping with setback radii.
h. Recommend labeling at least one road on each map with a visible font/outline.
2. On the Site NC-RO-16 map:
a. What is the small radius between Fields 5 and 6?
b. Please show the 400-foot setbacks for the off -site dwellings located at 735 and 769 Solomn
Road. This may reduce the application area of Field 8.
c. Please show the 400-foot setback for the off -site dwelling in the rear of the property located at
313 Solomn Road, just south of Field 6.
d. Why is there one radius larger than the others in the bottom left?
3. The two maps for Site NC-RO-17 are duplicated. Please remove these in the resubmittal.
4. On the Site NC-RO-20 map for Fields 6-8 and 14:
a. There are additional stray labels on the right side. Please remove.
b. What is the group of small radii next to Field 8 denoting?
5. On the Site NC-RO-20 map for Field 18, there is an off -site dwelling labeled within the unsuitable
area. This appears to be owned by the same owner who owns the field and should be an on -site
dwelling encompassed in the parcel boundary. Please update.
6. On the Site NC-RO-20 map for Fields 19-21:
a. Field 20 appears to extend beyond the delineated parcel boundary. Please adjust the application
area or confirm the landowner owns the adjacent parcel and show this.
b. Why are there setbacks shown for on -site dwellings intersecting Field 20? Please note that for
surface application by vehicle and injection/incorporation by irrigation there is no required
setback for on -site dwellings.
7. On the Site NC-RO-39 map for Fields 7-8, there appear to be surface water setbacks missing near
Field 7. Please delineate these.

Mr. Corey J. Walters
January 3, 2023
Page 6 of 7
8. On the Site NC-RO-40 map for Fields 1-2, there appear to be symbols used on the map that are not
shown in the legend. There also appears to be a missing parcel outline where the unsuitable area
boundary crosses outside the parcel boundary. Please correct.
9. On the Site NC-RO-40 map for Fields 3-7, Field 5 extends beyond the delineated parcel boundary.
Please adjust the application area or confirm the landowner owns the adjacent parcel and show this.
N. Soils Mans:
1. For information on completing soil maps please refer to 15A NCAC 02T . 1 104(c)(2)(A) and Map
Guidance for Residuals Land Application Fields, which has been attached. Please update all soil
maps for the following:
a. The title block for each map should contain the county where the site is located, the landowner's
name, the name of the permittee and/or permit number, and the Site ID/Field IDs.
2. There are no soil maps included for Fields NC-RO-20-15 through NC-RO-20-18. Please submit
these.
3. There are soil maps included for Fields NC-RO-41-01 through NC-RO-41-10, NC-RO-43-01, and
NC-RO-43-02, but these are not listed anywhere else in the application. If these were added by
mistake, please remove them. If they were not, please provide the additional documentation for
these fields and update the rest of the application accordingly.
Soil Scientist Report:
1. No borings were completed for the Fields NC-RO-20-15 through NC-RO-20-18. Please submit a
soil scientist report per 15A NCAC 02T . 1104(c)(2)(A) for these fields.
2. Why were borings performed and analyzed for Fields NC-RO-41-01 through NC-RO-41-10, NC-
RO-43-01, and NC-RO-43-02 if they are not listed in the LASC for this permit application? If these
were added by mistake, please remove them. If they were not, please provide the additional
documentation for these fields and update the rest of the application accordingly.
O. Touoerauhic Maus:
1. For information on completing topographic maps please refer to Map Guidance for Residuals Land
Application Fields, which has been attached. Please update all topographic maps for the following:
a. The title block for each map should contain the county where the site is located, the landowner's
name, the name of the permittee and/or permit number, and the Site ID/Field IDs.
b. Recommend removing the soil boring locations shown on some of the maps as this is not
required for topographic maps.
Q. Application (FORM: CBN 06-16):
1. No comment.

Mr. Corey J. Walters
January 3, 2023
Page 7 of 7
R. Soils and Agronomv Report:
1. For Site NC-RO-17, the listed acreages do not match the LASC. Please correct.
2. For Site NC-RO-40:
a. The listed acreages do not match the LASC. Please correct.
b. For Field 2, the soil type is listed as GoA — Goldsboro Loamy Sand while the LASC lists Ra -
Rains Sandy Loam. Please verify and update to match.
c. For Field 6, the soil type is listed as NoA — Norfolk Loamy Sand while the LASC lists Ra —
Rains Sandy Loam. Please verify and update to match.
3. For Site NC-RO-42, the soil type for Field 3 is listed as Ra — Rains Sandy Loam while the LASC
lists Me — Meggett Fine Sandy Loam. Please verify and update to match.
4. For Site NC-RO-20, the soil type for Field 20 is listed as GoA — Goldsboro Loamy Sand while the
LASC lists Co — Coxville Loam. Please verify and update to match.
5. The Heavy Metals Soils Reports for Sites NC-RO-17 and NC-RO-40 are corrupted and the text is
garbled. Please resubmit these.
S. Cumulative Pollutant Loading Rates:
1. No comment.