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HomeMy WebLinkAboutWQ0044463_Staff Report_20230803State of North Carolina Division of Water Resources Water Quality Regional Operations Section Staff Report FORM: WQROSSR 04-14 Page 1 of 6 To: NPDES Unit Non-Discharge Unit Application No.: WQ0044463 Attn: Anthony Cord Facility name: Mulberry Farm – Madison, LLC From: Melanie Kemp Asheville Regional Office Note: This form has been adapted from the non-discharge facility staff report to document the review of both non- discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? Yes or No a. Date of site visit: July 13, 2023 b. Site visit conducted by: Melanie Kemp (DWR – ARO); Patrick Mitchell and Dalton Buchanan (NC Division of Soil & Water Conservation); Kevin Davidson and Jessi Banks (Agri-Waste Technology) c. Inspection report attached? Yes or No In LF d. Person contacted: Kevin Davis and their contact information: 609-432-2657 ext. e. Driving directions: Take Hwy. US-25 N/US-70 W north towards Marshall. Turn right on Upper Thomas Branch Road. The site is located at the end of the road (physical address 1126 Upper Thomas Branch Rd). 2. Discharge Point(s): Latitude: Longitude: Latitude: Longitude: 3. Receiving stream or affected surface waters: Tributary of Hopewell Branch (Index 6-109-4) Classification: C River Basin and Subbasin No. French Broad Describe receiving stream features and pertinent downstream uses: Tributary that leads into Hopewell Branch II. PROPOSED FACILITIES: NEW APPLICATIONS 1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit): NA Proposed flow: 10,000 GPD to the irrigation area (an additional 5,000 gallons/day will be routed to the subsurface drip field). Current permitted flow: NA 2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No If no, explain: Overall, the non-discharge system is adequately designed. Note that the treatment system is being permitted through Madison County EHS. 3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A If no, please explain: Generally, soils are consistent with the submitted report, but hydraulic loading rates DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 FORM: WQROSSR 04-14 Page 2 of 6 differed based on findings in the field. Soils were assessed by Patrick Mitchell and Dalton Buchanan, and a full report is attached. Based on thin topsoils and steep slopes, it is recommended that the maximum loading rate be adjusted to 0.15 inches/hour (application lists 1.47 in/hr). 4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A If no, please explain: The blueline stream represented in the site map needs to be checked against the stream delineation data that was verified with the USACE. See summary for details. 5. Is the proposed residuals management plan adequate? Yes No N/A If no, please explain: 6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A If no, please explain: The application rates are acceptable, but there is the potential for overloading/ponding where the spray heads and drip zones overlap at the toe of the slope. See summary for details. 7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No If yes, attach a map showing conflict areas. 8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A If no, explain and recommend any changes to the groundwater monitoring program: Groundwater monitoring was not proposed in the application. The application area is located on sloping ground that is boarded by two Class C streams referred to as Hopewell Branch and an unnamed tributary to Hopewell Branch. The distance between the jurisdictional streams and the toe of the application area is on the order of 100 – 150 feet. The Asheville Regional Office is recommending the installation of one upgradient monitoring well and two downgradient monitoring wells. It is recommended that the monitoring wells be sampled in the months of March, July, and November. The groundwater analytes should include ammonia, nitrate, nitrite, total phosphorus, chloride, fecal coliform bacteria, total organic carbon, total dissolved soils, and volatile organic compounds (November only). 9. For residuals, will seasonal or other restrictions be required? Yes No N/A If yes, attach list of sites with restrictions (Certification B) Describe the residuals handling and utilization scheme: 10. Possible toxic impacts to surface waters: 11. Pretreatment Program (POTWs only): III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A ORC: Certificate #: Backup ORC: Certificate #: 2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal system? Yes or No If no, please explain: Description of existing facilities: Proposed flow: Current permitted flow: Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc 3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately assimilating the waste? Yes or No If no, please explain: 4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance boundary, new development, etc.)? Yes or No If yes, please explain: DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 FORM: WQROSSR 04-14 Page 3 of 6 5. Is the residuals management plan adequate? Yes or No If no, please explain: 6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No If no, please explain: 7. Is the existing groundwater monitoring program adequate? Yes No N/A If no, explain and recommend any changes to the groundwater monitoring program: 8. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No If yes, attach a map showing conflict areas. 9. Is the description of the facilities as written in the existing permit correct? Yes or No If no, please explain: 10. Were monitoring wells properly constructed and located? Yes No N/A If no, please explain: 11. Are the monitoring well coordinates correct in BIMS? Yes No N/A If no, please complete the following (expand table if necessary): Monitoring Well Latitude Longitude ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ 12. Has a review of all self-monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? Yes or No Please summarize any findings resulting from this review: Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. 13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No If yes, please explain: 14. Check all that apply: No compliance issues Current enforcement action(s) Currently under JOC Notice(s) of violation Currently under SOC Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been working with the Permittee? Is a solution underway or in place? Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A If no, please explain: 15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? Yes No N/A If yes, please explain: 16. Possible toxic impacts to surface waters: 17. Pretreatment Program (POTWs only): DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 FORM: WQROSSR 04-14 Page 4 of 6 IV. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? Yes or No If yes, please explain: 2. List any items that you would like the NPDES Unit or Non-Discharge Unit Central Office to obtain through an additional information request: Item Reason Appendix D Submit the revised deed and figure representing the area of site that includes the drip irrigation field. Appendix E Ensure a 100’ buffer from all surface water features in the soils report and all attached figures. Appendix E Soils Report findings for hydraulic loading rates need to be reassessed based on findings from the 7/13 site visit (see attached Soils Investigation Report). Appendix I Ensure location of blueline stream identified is accurately reflected on all site figures, and a 100’ setback is maintained. Appendix J Remove overlap between drip irrigation areas and spray irrigation areas at the toe of zones A and B. Additional Figures Recommended to include a schematic and/or permit submitted to the Madison County EHS that outlines the design of the treatment system and interconnection with the irrigation system. 3. List specific permit conditions recommended to be removed from the permit when issued: Condition Reason 4. List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason Monitoring well installation Application area is located up gradient from two Class C streams. ARO recommends installation of one up gradient and two down gradient monitoring wells located on the review boundary. The monitoring wells need to be surveyed to establish coordinates and elevation. The permittee should contact the ARO to coordinate well installation. Groundwater Monitoring ARO recommends groundwater monitoring at three monitoring wells in the months of March, July, and November. Monitoring analytes should include ammonia, nitrate, nitrite, total phosphorus, chloride, fecal coliform bacteria, total organic carbon, total dissolved soils, and volatile organic compounds (November only). Site Map ARO recommends developing a site map with a variety of layers including the waste boundary, review boundary, compliance boundary, monitroing well locations, topography, and streams. The site map should be completed 60 days after the monitoring wells are installed. 5. Recommendation: Hold, pending receipt and review of additional information by regional office Hold, pending review of draft permit by regional office Issue upon receipt of needed additional information Issue DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 FORM: WQROSSR 04-14 Page 5 of 6 Deny (Please state reasons: ) 6. Signature of report preparer: Signature of regional supervisor: Date: DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 8/3/2023 FORM: WQROSSR 04-14 Page 6 of 6 V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS A site visit was conducted on July 13, 2023 to review plans, inspect the proposed location of the drip/irrigation field, and verify soil conditions against the findings within the application. The pretreatment system for the subsurface drip field is being permitted through the Madison County EHS. A Notice of Intent Application has been submitted. Wastewater from the site will primarily be treated utilizing Orenco AX-Max units. Additional treatment components include an eco unit, constructed wetland, sand filter, moss rock trickling wall filter, and UV. Treated effluent will be diverted to either the subsurface septic system or the storage tanks connected to the surface drip irrigation field. Approximately 10,000 gallons/day will be routed to the irrigation area (an addition 5,000 gallons/day will be routed to the subsurface drip field). See the attached Site Visit Report for additional information. Notes/Issues: • Appendix D: The recombination deed and figure included with application does not include the area of the proposed drip field. • Appendix E: The figures included with the Soils Report represent a 50’ setback from the surface water feature below the drip field. It should be noted that setbacks from all surface water features, including intermittent and perineal streams, should be 100 ft according to 02T .0506. • Appendix E, Section 3.1: Based on topsoils and site topography, as assessed by the NC Division of Soil and Water Conservation, the hydraulic loading rate for the site needs to be reviewed and potentially amended from 1.47 in/hr to 0.15 in/hr. • Appendix H: Based on site use, a seasonal loading schedule is recommended in the water balance. To accommodate the potential for future site use changes, an annual permit is recommended. • Appendix I: The exact location of the blueline stream, delineated in accordance with the USACE, needs to be checked against the figures provided in the application to all setbacks have been met. • Appendix J: Section 1.1 outlines the process of flushing the spin filter via the 6 irrigation spray heads at the toe of drip areas A and B. In order to prevent potential overloading and ponding/runoff, is recommended that the spray heads and drip tubing are offset (not overlapped) in these areas. • A schematic outlining the layout of the treatment system and interconnection with the irrigation system would be beneficial to keep on record. • Groundwater monitoring is recommend (see above). Attachments: A. Site Visit Inspection Summary B. Site Photographs C. Soils Investigation Report – North Carolina Division of Soil and Water Conservation DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 Compliance Inspection Report Permit:WQ0044463 Effective:Expiration:Owner :Mulberry Farm - Madison LLC SOC: Contact Person: Region: County: Directions to Facility: Madison Asheville Richard Kelly Effective:Expiration:Facility:Mulberry Farm WWIS 1126 Upper Thomas Branch Rd Marshall NC 28753 Title:Phone: Secondary ORC(s): Phone:Certification:Primary ORC: System Classifications: On-Site Representative(s): Related Permits: Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 07/13/2023 10:30AM 12:30PM Melanie Kemp Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Other Wastewater Irrigation Reconnaissance Question Areas: Miscellaneous Questions (See attachment summary) Page 1 of 3 DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0044463 07/13/2023 Reconnaissance Mulberry Farm - Madison LLC Other Inspection Summary: Melanie Kemp, with the Asheville Regional Office, completed an initial site visit of the Mulberry Farms WWIS on July 13, 2023 (non-discharge permit number WQ0044463). This visit was conducted to determine whether the site is suitable for constructing a wastewater irrigation storage area and drip field based on the application submitted June 2, 2023. Patrick Mitchell and Dalton Buchanan from NC Division of Soil and Water Conservation were available to compare site soils against the findings of the soils report within the application. Kevin Davidson and Jessi Banks, engineers representing Agri-Waste Technology, Inc., were available to answer questions and provide a tour of the treatment area and proposed drip field. The wastewater treatment area is being permitted through the Madison County EHS Department and it should be noted that an overview of the system specifications would be beneficial to understand the connection to the drip irrigation system vs. the subsurface drip field. Overall, the site appeared to be adequate for the proposed system. The site is being built as a seasonal retreat center, processing approximately 15,000 gallons of wastewater per day. After treatment approximately 10,000 gpd will be diverted to the irrigation area and 5,000 gpd will be diverted to the subsurface drain field. During low-flow months (November – February), all flow on-site will be diverted to the sub-surface drip field. The proposed storage tanks for the drip field will be placed at the top of a hill (referred to as Sunset Hill) within the southwest corner of site. The three storage tanks will feed four proposed drip irrigation zones, spanning 6.113 acres, that will be placed along a steep, forested hillside that slopes towards a tributary of Hopewell Branch. At the base of drip zones A and B, six spray heads will installed to allow for an occasional higher pressure flush cycle of the spin filter. Due to the site layout and steep topography, there will not be a way to pump effluent from the base of the drip zones back up to the storage area. The entire site will be powered utilizing solar energy, with multiple power banks placed throughout site. The site will have backup connection to the power grid. The site engineers indicated that the tributary of Hopewell Branch was recently delineated as a blueline stream feature, in coordination with the USACE. The GPS head and location of the stream feature needs to be loaded into the site figures to ensure the appropriate setbacks have been met from all surface water features. Below is a summary of questions/issues identified during the site visit and within the application, which need to be addressed prior to permit issuance: •Appendix D: The recombination deed and figure included with application does not include the area of the proposed drip field. •Appendix E: The figures included with the Soils Report represent a 50’ setback from the surface water feature below the drip field. It should be noted that setbacks from all surface water features, including intermittent and perineal streams, should be 100 ft according to 02T .0506. •Appendix E, Section 3.1: Based on topsoils and site topography, as assessed by the NC Division of Soil and Water Conservation, the hydraulic loading rate for the site needs to be reviewed and potentially amended from 1.47 in/hr to 0.15 in/hr. •Appendix H: Based on site use, a seasonal loading schedule is recommended in the water balance. To accommodate the potential for future site use changes, an annual permit is recommended. •Appendix I: The exact location of the blueline stream, delineated in accordance with the USACE, needs to be checked against the figures provided in the application to all setbacks have been met. •Appendix J: Section 1.1 outlines the process of flushing the spin filter via the 6 irrigation spray heads at the toe of drip areas A and B. In order to prevent potential overloading and ponding/runoff, is recommended that the spray heads and drip tubing are offset (not overlapped) in these areas. •A schematic outlining the layout of the treatment system and interconnection with the irrigation system would be beneficial to keep on record. Page 2 of 3 DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0044463 07/13/2023 Reconnaissance Mulberry Farm - Madison LLC Other Type Yes No NA NE Reuse (Quality) Infiltration System Lagoon Spray, LR Single Family Spray, LR Activated Sludge Spray, LR Activated Sludge Spray, HR Activated Sludge Drip, LR Single Family Drip Recycle/Reuse Page 3 of 3 DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 Atachment B – Site Photographs Taken 7/13/2023 by Melanie Kemp Photo 1: Sunset Hill, where irriga�on holding tanks will be placed Photo 2: Representa�ve view of proposed drip field area. Zones were recently flagged by a surveyor. Photo 3: Beyond base of drip fields, looking towards blueline stream feature. Photo 4: Orenco Ax-Max filtra�on unit, u�lized within the treatment area. DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 Photo 5: View of treatment building, including constructed wetland on the exterior. Photo 6: Inside of addi�onal treatment area that includes floa�ng plant chamber and trickling moss filtra�on over rock wall. Photo 7: Sand filter and UV filter within treatment building. Photo 8: View from Ax-Max pods looking towards green roof of treatment building. DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 1 North Carolina Division of Soil and Water Conservation Environmental Services Section Soils Investigation Report Report Date: July 17, 2023 Date of Investigation: July 13, 2023 Project: Mulberry Farms, Proposed Wastewater Surface Irrigation System Client: NCDEQ – DWR Objective of Soils Investigation: To characterize soil and site conditions present where a potential wastewater drip irrigation system may be installed. Also, to verify the soils report and agronomic report that were provided in the permitting application package. Soil Scientist: Patrick Mitchell, LSS Other Participant(s): Melanie Kemp – NCDWR; Kevin Davidson & Jessi Banks – AWT, Inc; and Dalton Buchanan – NCDSWC Location: The site is located near 1126 Upper Thomas Branch Rd., Marshall, NC. Coordinates for the proximity of area investigated in decimal degrees are 35.861449, -82.728632 (see the attached soil map). Site Geology / Soils / Topography: The site is situated within the Intermediate Mountain Soils System. The Madison County Soil Survey indicates the investigation area consist of Evard-Cowee soils complex with slopes ranging from 15 – 30 and 30 – 50% (EvD & EvE). These soils formed in residuum weathered from felsic to mafic igneous, and high-grade metamorphic rocks. Soils Review / Field Work: A total of three soil hand auger borings were advanced within the proposed wastewater irrigation areas. Abbreviated soil profile descriptions for each boring are attached to this report. A soils map showing the locations of the borings is also attached to this report. A review of the soils report and the agronomic report included with the permitting application package was also completed. Findings / Results: The soils observed within the proposed irrigation area mostly matched the Evard-Cowee soil complex. Soil boring #1 was classified as being in the Evard Soil Series and soil boring #3 more closely resembled the Cowee Soil Series. Soil boring #2 was classified as being in the Clifton Soil Series. Clifton is a similar soil to the Evard, but with slightly higher clay content in the subsoils. These findings concur with the soils map that was included in the soils report in the permitting application package in relation to the soil series that are found within the proposed irrigation area. Discussions / Recommendations: 1. The proposed irrigation area contains soils that are suitable for wastewater irrigation. DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 2 2. The thickness of the topsoils observed during the investigation ranged from two to four inches in thickness. The soil textures described in the topsoils were found to be sandy clay loam, loam, and sandy loam. The average slopes within the proposed irrigation area were reported as being 36% in the application package. The soils report included in the permitting application package recommended a maximum hourly loading rate of no more than 1.47 inches/hour. Given the relatively thin topsoils in places, the fine-loamy soil textures found within the topsoils, and the steep slopes in the proposed irrigation area, a maximum hourly irrigation rate of 0.15 inches/hour may be appropriate. 3. Subsoil horizons encountered in soil borings suggests that the depths of the hydraulic conductivity measurements as reported in the soils report included in the application package are appropriate. The reported results are within an acceptable range for the soil properties observed. 4. The annual hydraulic loading rates, the drainage coefficient that was utilized, and the annual agronomic loading rates as indicated in the reports included with the permitting application package appear to be within an acceptable range for the soils found onsite. It should be noted that none of the calculation values provided in the soils report, in the agronomic report, or in the water balance were checked for accuracy. It is recommended that calculation results are verified for accuracy before proceeding with the permitting. 5. There is some concern of the area at the toe of proposed irrigation zones A and B, where spray heads are proposed to be installed overtop the drip irrigation area. Reportedly the spray heads are only supposed to dose during maintenance flushes of the drip system. However, during the flush spray dispersal the drip system will dose at the same time. This could potentially lead to hydraulic overloading during flush events. The combined loading of spray and drip may exceed the instantaneous ability of the soil to assimilate wastewater potentially leading to runoff during flush events. For questions or to discuss further, please contact Patrick Mitchell at 919-280-4332 or at email: patrick.mitchell@ncagr.gov. Patrick L. Mitchell, LSS Regional Soil Scientist NC Division of Soil and Water Conservation Attachments: Soils Map Soil Profile Descriptions DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 3 RERERENCES: Daniels, R.B., Buol, S. W., Kleiss, H.J., Ditzler, C.A. 1999. Soil Systems in North Carolina, Technical Bulletin 314. North Carolina State University, Soil Science Department. Raleigh, North Carolina 27695- 7619. Natural Resources Conservation Service, National Soil Survey Center. 1998. Field Book for Describing and Sampling Soils. United States Department of Agriculture. Lincoln, Nebraska. Natural Resources Conservation Service, U.S. Department of Agriculture. Web Soil Survey. https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx, retrieved 7/10/2023. Natural Resources Conservation Service, U.S. Department of Agriculture. 2014. Keys to Soil Taxonomy, Twelfth Edition. DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 Project:Date: SWCD:County: Other: Depth (Inches)Moist Wet Plasticity Depth (in.) to:  SHWT = _____        OWT = _____  Depth (in.) to:  SHWT = _____        OWT = _____  Depth (in.) to:  SHWT = _____        OWT = _____  Depth (in.) to:  SHWT = _____        OWT = _____  Described by:Page 1 of   _____  LP &      % Slope LP &      % Slope Consistence²Other Notes (inclusions, fill materials,  parent material,          rock, mica, soil series, other)  Color¹   (matrix/mottles)Horizon  USDA²  Texture Structure Profile  ID LP &      % Slope LP &      % Slope USCS²  Class NC Division of Soil and Water Conservation Environmental Services Section Soil Profile Descriptions Test Method:        Auger          Pit          Other:__________________________________________ A Bt BC C 0 - 2 2 - 29 29 - 40 40 - 52 A Bt BC C A E Bt BC Boring terminated Boring terminated 33 - 46 0 - 3 3 - 21 7 - 28 28 - 42 4 - 7 0 - 4 42+ SCL SCL SCL/CL L-Sap. Sbk Sbk Mass. Sbk Fr Fr Fr Ft SS SS SS SS NP-SP SP SP SP --- --- --- 1 30-35% S NA NA NA NA NA NA July 13, 2023 XMadisonNA Mulberry Farms, Wastewater Irrigation System 2 2 3 Friable saprolite. Friable saprolite. --- --- --- --- --- --- --- --- --- Auger refusal 35-40% 20-25% N LS --- --- --- --- --- --- --- L SL SL C/CL CL L-Sap. Floater rock or Weathered Rock? EVARD SOIL SERIES SCL SCL Sbk Sbk Sbk Mass. Gr Sbk Sbk Sbk Fr Fr Fr Fr Fr Fr Fr Fr SS SS SS SS SS SS SS SS SP SP SP NP NP SP SP SP --- --- --- --- --- --- --- --- --- --- --- --- Multi. Br R-Br R-Br Y-R Br R R Br Br R-Br R-Br L-Saprolite inclusions/mix. L-Saprolite inclusions/mix. CLIFTON SOIL SERIES EVARD-COWEE COMPLEX 21 - 33 P. Mitchell & D. Buchanan SL-Saprolite inclusions/mix. Cr ? DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8 Page 2 of ____ Depth (Inches)Moist Wet Plasticity Depth (in.) to:  SHWT = _____        OWT = _____  Depth (in.) to:  SHWT = _____        OWT = _____  Depth (in.) to:  SHWT = _____        OWT = _____  Depth (in.) to:  SHWT = _____        OWT = _____  Horizon  Color¹   (matrix/mottles)     Moist consistence ‐ L (loose), VFr (very friable), Fr (friable), Fi (firm), Vfi (Very Firm), C (cemented), R (rigid)      Wet consistence ‐ NS (non‐sticky), SS (slightly sticky), S (moderately sticky), VS (very sticky)     Plasticity ‐ NP (non‐plastic), SP (slightly plastic), P (moderately plastic), VP (very plastic)  USDA²  Texture Structure 1 = Use Munsell color notations or  Y (yellow), R (red), Br (brown), Bk (black), G (gray), M (multi‐color) 2 = Field Estimates Consistence² LP &      % Slope LP &      % Slope LP &      % Slope LP &      % Slope Other Notes (inclusions, fill materials, parent material,          rock, mica, soil series, other)  USCS²  Class Profile  ID 2 DocuSign Envelope ID: 27024E05-33C6-4128-8EBD-32395BF10ED8