WQ0044258_Additional Information Request_20230619

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
JOSEPH P. VILLARI — MANAGER
MICRO LAND GROUP, LLC
1015 ASHES DRIVE, SUITE 102
WILMINGTON, NORTH CAROLINA 28405
Dear Mr. Villari:
NORTH CAROLINA
Environmental Quality
June 19, 2023
Subject: Application No. WQ0044258
Additional Information Request
Micro Land Group WWIS
Wastewater Irrigation System
Duplin County
Division of Water Resources' Central and Regional staff has reviewed the application package
received on March 24, 2023. 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 July 19,
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 Q, 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: h!Ws://edocs.deq.nc.aov/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,
Erick Saunders, Engineer
Division of Water Resources
cc: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
William G. Simmons, PE — Cavanaugh & Associates, P.A. (Electronic Copy)
Laserfiche File (Electronic Copy)
D EQ �� 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 -
OepaNnent at EnulmnmeMal Deall 919.707.9000

Mr. Joseph P. Villari
June 19, 2023
Page 2 of 8
A. General Comments:
1. The Division has concerns with the lack of treatment provided for this wastewater effluent based
on its chemical analysis, which has not been fully characterized at the time of this letter. The
effluent contains high concentrations of nutrients and sodium as it is currently proposed, exceeding
agronomic limits and recommendations at the site which could lead to leaching of contaminants
from the wastewater into groundwater and degradation of groundwater quality standards listed in
with 15A NCAC 02L. The Soil Scientist Evaluation Report in this application alludes several times
that additional treatment of this wastewater was necessary prior to land application in the analysis
of the nitrogen loadings and sodium adsorption ratio (SAR) values, stating that SAR value "should
be reduced to within the acceptable range of SAR values of water for spray irrigation use after
treatment."
Due to the nature of the wastewater, the recommendations of the soil scientist, and the potential for
contamination of groundwater standards due to irrigation of this high strength industrial
wastewater, the Applicant shall propose a treatment system for this wastewater to reduce the sodic
and nutrient concentrations of the wastewater to protect the long-term health of the facility and
ensure proper operation of the facility and protection of waters of the state.
B. Cover Letter:
1. No comments.
C. Application Fee:
1. No comments.
D. Application (Form: WWIS 06-16):
In the cover letter, it is stated that there are no Nationwide 12 / Section 404 or Wetlands 401
certifications required for this project, but the site plan in Plan Sheet C.3.1 indicates a ditch within
Field 4 requiring a wetland delineation and jurisdictional delineation by the Army Corps of
Engineers. Please provide the status for any jurisdictional certifications required to add fill to this
ditch. Construction of Zone 4 will not be allowed until approval is received by the Division from
an appropriate authority because this field would contain an area violating the 25-foot setback to
surface water diversions listed in 15A NCAC 02T .0508(a).
2. Item IV.6. states that the wastewater flow is limited by storage, but according to the agronomic
evaluation in the Soil, field agronomics appear to be the limiting parameter at this facility. The Soil
Evaluation calculates a plant available nitrogen (PAN) loading rate of 518 lb. PAN/acre/year at the
facilities proposed average daily flow. Item IV.6. shall be updated to reflect the correct wastewater
flow and limiting parameter.
3. How were the Designed Effluent Concentrations in Item V.1 determined? The values don't appear
to correspond to the wastewater chemical analyses provided, and those analyses did not contain
every parameter in the table.

Mr. Joseph P. Villari
June 19, 2023
Page 3 of 8
4. Item V.5. requests approval from the Director so this facility would not require an automatically
activated standby power supply. However, all the requirements of 02T .0505(1)(2) shall be met for
this request to be approved. Please provide a narrative to address how each of the three conditions
of this rule are met individually.
Item V.9. indicates that the influent pump station for the facility does not meet the design criteria
in 02T .0305(h) as required in 02T .0505(r). All influent pump stations shall meet the influent pump
station design criteria of 02T .0300 as required by 02T .0505(r). Please indicate whether Pump
Station 1 shown in the plans meets the criteria of this rule, or if it is to be permitted separately.
6. The tables in Item V.11. were not completed for the equipment proposed in the application. This
includes, but is not limited to, pump information in V.1 Le for the irrigation pumps and the influent
pump station (if the sewer system is to be permitted under this application), recording devices in
V.I Lh, and the irrigation pump systems' information in V.1 Li. The information in these tables
shall be completed for all units/equipment proposed in this application.
7. Phosphorus Uptake Rates were not provided for in the table of Item VII.7. This information shall
be provided in an updated table.
Item VII.8. has designed loading rates for some fields exceeding the field's dominant soil series'
recommended rates as listed in the Soil Certification in violation of 15A NCAC 02T .0505(n). For
instance, Field IA has a designed annual rate of loading rate of 49.75 in/year in this application,
but Section 3.1 in the Soil Scientist Evaluation Report dated December 3, 2022 recommends a
maximum annual loading rate of 40 inches or less in the field's dominant Norfolk soil. Field 2 and
4 also appear to also share this issue.
Designed loading rates in this table shall be updated not to exceed the hydraulic loading rates
provided by the Licensed Soil Scientist. Total disposal capacity for the system shall be checked
based on this change.
9. What is the "78di" value shown in the setback table for surface waters in Item VII.3?
10. Item VII.8. indicates that there is "Annual" loading for each soil series, meaning there are no
seasonal restrictions to land application. However, the mounding model in the Hydrogeologic
Report indicates no irrigation was applied to any field in January, while several fields like 113 did
not irrigation from October through March. These results suggest that these fields may require
seasonal restrictions to prevent groundwater mounding. Please provide a list of seasonal restricted
months for each field or provide a justification for why seasonal restrictions are not required.
E. Property Ownership Documentation:
In accordance with 15A NCAC 02T .0504(f), property ownership documentation for leases shall
be written, notarized, and signed by both parties, indicating the intended use of the property,
accompanied by a plat or survey map and adhere to the requirements of 15A NCAC 02L .0107. In
accordance with 02L .0107(k), if the permittee is not the owner of the land within the compliance
zone, the landowner of the land shall execute and file in the Register of Deeds in the county in
which the land is located, an easement running with the land to establish a compliance boundary
on the landowner's land.

Mr. Joseph P. Villari
June 19, 2023
Page 4 of 8
To satisfy 02T.0504(f), the leases shall be accompanied by a plat or survey map and contain
easement agreements executed by all landowners who own land containing a compliance zone
(areas within the compliance boundary), meaning all parcels containing a waste disposal area. This
easement shall adhere to 15A NCAC 02L and shall be recorded in the Duplin County Register of
Deeds.
2. According to the Duplin County GIS website, the properties containing the irrigation system and
lagoons (Parcels 01- 11, 01- 1656, and 01- 253) are owned by Leonard Franklin Sutton Jr. The
signer of the leases are representatives of Sutton Land Renewal, LLC and Rock Creek Livestock,
LLC, but the property records referenced in the application's cover letter were not included to
verify they are the owners of this property containing the facilities of this application. It is unclear
whether these entities have the authority to lease these properties to the Permittee for the
construction and operation of this facility. Documentation shall be provided to prove that these
entities are signature authorities for these parcels.
F. Soil Evaluation:
1. The cover letter references a permit WQ0001173. Please clarify whether this permit is related to
this application, and update accordingly.
2. The PAN value of 61.90 mg/1 in Section 3.2 states it is obtained using October 2022 data, but the
wastewater chemical analyses in the application do not contain enough information to calculate
PAN. Please provide the October 2022 laboratory data referenced in this report.
3. The soils map included in this report does not match the Duplin County Soil Survey map on the
Duplin County GIS website. Please review and provide an explanation for the discrepancy.
G. Agronomist Evaluation:
The Wastewater Chemical Analysis provided has sodium adsorption ratios as high as 70, while the
soil scientist report calculates a value of 32.0. Sodium overapplication will damage the structure
of the soils on site and adversely impact cover crop health, reducing the overall effectiveness of the
non -discharge system by reducing infiltration rates and nutrient uptake. In other Non -Discharge
programs, the Permittee is required to obtain and implement recommendations from a soil
professional prior to land application of material containing an SAR of 10 or higher.
If irrigation of wastewater containing SAR of greater than 10 is being proposed, the Permittee shall
obtain and implement recommendations to address sodium overapplication concerns from at least
one of the following: the local Cooperative Extension Office; the Department of Agriculture and
Consumer Services; the Natural Resource Conservation Service; a North Carolina Licensed Soil
Scientist; or an agronomist. The recommendations shall address the sodium application rate, soil
amendments (e.g., gypsum), or a mechanism for maintaining site integrity and conditions
conducive to crop growth.
H. Hydrogeologic Report:
1. It was noted in the WWIS form that the Hydrogeologist has requested feedback from the Division
as to where monitoring wells shall be located. Please contact the Wilmington Regional Office and
the Central Office Hydrogeologist to set up a discussion regarding the well location proposals so
that they may be incorporated into an updated WWIS form and shown on updated plan sets.

Mr. Joseph P. Villari
June 19, 2023
Page 5 of 8
2. The section for slug tests under the Water Levels and Hydraulic Conductivity Testing header on
page 9 references an analysis curve in Attachment 2. Please provide this attachment, as well as all
supporting/field data for the slug tests.
3. The extinction depth of 10 feet for this study on page 16 is said to be based upon the deep-rooted
deciduous trees present in the modeled area. Why is data for deciduous trees used in this model
when the site is predominantly used for row cropping?
4. The mounding analysis maps in Figures 13 through 23 did not include a map for January. Please
provide this map.
5. The irrigation capacities for the srayfields in Table 7 exceed the maximum annual hydraulic loading
rates recommended by the soil scientist for certain fields as mentioned in Item D.B. The mounding
analysis shall be updated using irrigation capacities not exceeding the recommended rates of the
soil scientist.
6. Please provide a status on all test wells and piezometers used in data collection for this report. Any
wells that remain pen, if any, should be noted. Otherwise, all test wells or monitoring wells shall
be properly abandoned prior to operation of the facility.
7. There are concerns that wastes could be applied above agronomic rates in violation of 15A NCAC
02T .0505(c) based on the wastewater chemical analyses provided, but no predictive modeling has
been provided in this Hydrogeologic report to demonstrate protection of State groundwater
standards. A contaminant transport model shall be conducted in accordance with the May 31, 2007
Groundwater Modeling Policy to predict contaminant concentration at the compliance boundary.
This analysis shall, at the minimum, be modeled for the following contaminants:
a. Nitrate (as N);
b. Ammonia;
c. Chloride;
d. Phosphorus; and
e. Dissolved Solids (Total).
I. Water Balance:
1. See H.S. of this request. The water balance shall be recalculated with irrigation capacities to not
exceed the recommended rates of the soil scientist.
J. Engineering Plans:
1. See H.1. Proposed locations for monitoring wells shall be shown on updated plans.
2. A detail drawing shall be provided for all equipment, including "Rain Shutoff Sensor" shown on
Sheet C.3.1 and the flow meter/meter box shown on C.4.0.

Mr. Joseph P. Villari
June 19, 2023
Page 6 of 8
K. Specifications:
1. As stated in the cover letter, technical specifications were included in the application on the plans.
However, these are two separate engineering documents in accordance with 15A NCAC 02T
.0504(c), requiring two discrete document packages for approval. A separate specifications package
meeting the requirements of 02T .0504(c)(2) shall be submitted for review.
2. See Item DA. The updated specifications package shall ensure the requirements of 15A NCAC 02T
.0305(h) are met if the influent pump station is permitted in this permit.
3. The specifications package shall include materials to be used and methods of construction for
directional drilling as mentioned in Plan Sheet CA. 1.
4. Please provide the manufacturer's equipment specifications for the proposed HDPE liner of the
basins.
L. Engineering Calculations:
1. An EPANET hydraulic analysis was provided for the influent pump station, but a pump curve was
not provided for the proposed pump. Additionally, pump hydraulics analyses were not provided for
the pumps in Irrigation Stations 1 and 2. The system curve analysis shall be provided for each pump
in accordance with 02T .0505(c)(3).
2. Irrigation design calculations shall be provided to verify that the design does not exceed the
recommended precipitation rates established in the soils report as required in 02T .0505(n).
3. In accordance with Item K of the WWIS 06-16 Instruction Form, please provide manufacturer's
information for all equipment, including pumps, flow meters and irrigation system.
4. Why was the PAN Rate of 424 lb/ac/yr chosen for the "Summary Calculations: Irrigation Area
Hydraulic and PAN Loading Rates" sheet? According to the agronomic evaluation of the cover
crops and the soils on site, PAN uptakes are only as high as 300 lb/ac/yr based on the NCSU
Realistic Yield Index, which would be considered the maximum PAN Rate for this calculation for
agronomic loadings. Assuming all fields have a PAN Rate of 300 lb/ac/yr and using the proposed
flow of 0.332 MGD in this equation, the Specified PAN Concentration separating Hydraulically
Limited and PAN Limited is around 35 mg/L, not 50 mg/L.
M. Site Map:
1. No comments.
N. Power Reliability Plan:
1. See Comment DA.

Mr. Joseph P. Villari
June 19, 2023
Page 7 of 8
0. Operation & Maintenance Plan:
1. In accordance with 02T .0507(a)(4), the spill control plan shall include provisions for responding
to upsets and bypasses and include control, containment, and remediation actions to be taken in the
event of a spill. Contact information for plant personnel, emergency responders and regulatory
agencies shall also be included. The spill control provisions shall be updated to include this
information.
P. Residuals Management Plan:
1. It is stated in the cover letter that the Applicant has obtained written commitment from GFL to
accept, manage, and dispose of residuals from this facility. In accordance with 15A NCAC 02T
.0508(a)(3), please provide a copy of this written commitment to the permittee from an approved
residuals management program capable of accepting the residuals.
Q. Additional Documentation:
➢ Certificate of Public Convenience and Necessity:
1. N/A
➢ Existing Permit:
1. N/A
➢ Final Environmental Document:
1. N/A
➢ Floodway Regulation Compliance:
1. No comments.
➢ Operational Agreements:
1. N/A.
➢ Threatened or Endangered Aquatic Species Documentation:
1. No comments.
➢ Wastewater Chemical Analysis:
1. In accordance with 15A NCAC 02T .0504(h), a chemical analysis shall be provided by the
applicant for industrial wastewaters. The analysis provided included some of the required
parameters, but not all. The following parameters are required in accordance with this rule:
1) Total organic carbon (not provided);
2) 5-day biochemical oxygen demand (BOD5) (provided);
3) Chemical oxygen demand (COD) (provided);
4) Nitrate nitrogen (NO3-N) (not provided);

Mr. Joseph P. Villari
June 19, 2023
Page 8 of 8
5) Ammonia nitrogen (NH3-N) (provided);
6) Total Kjeldahl nitrogen (TKN) (not provided);
7) pH (provided);
8) Chloride (provided);
9) Total phosphorus (provided);
10) Phenol (not provided);
11) Total volatile organic compounds (not provided);
12) Fecal coliform (not provided);
13) Calcium (provided);
14) Sodium (provided);
15) Magnesium (provided);
16) Sodium adsorption ratio (SAR) (provided);
17) Total trihalomethanes (not provided); and
18) Total dissolved solids (not provided).
An updated chemical analysis shall be submitted containing each of the missing parameters for
review.