WQ0000672_More Information (Requested)_20230619

ROY COOPER Governor lktv
ELIZABETH S. BISERSecretary
RICHARD E. ROGERS, JR. NORTH CAROLINA
Director Environmental Quality
June 19, 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 on April 26, 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: httDs://edocs.dea_.nc.2_ ov/Fonns/NonDischar2_ e-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: 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
June 19, 2023
Page 2 of 7
A. Cover Letter:
1. No comment.
B. ADolication Fee:
1. No comment.
C. AnDlication (Form: RLAP 06-16):
1. Item III.3. — In regards to the Applicant's response to Comment C. La. in the Response Letter dated
March 18, 2023, an ORC Designation Form was not received via email. Please include a copy of
this completed form in the Applicant's response.
2. Item III.4.a. — Please revise this table per Comment F.
3. Item III.4.b. — Please revise the acreages in this table accordingly per Comment O.
4. Item III.4.c. — Please revise this table per Comment F.
D. Operation & Maintenance Plan:
1. No comment.
E. Summary for Form: RSC 06-16:
1. No comment.
F. ADDlication (Form: RSC 06-16):
1. Lumberton WWTP —
a. Item II.5.e. — The provided PAN concentrations are incorrect. The calculation spreadsheet uses
0.4 (anaerobic digestion) for the mineralization rate instead of 0.3 (aerobic digestion). Please
revise.
2. Lumberton WTP —
a. Item II.5.e. — The provided PAN concentrations are incorrect. The calculation spreadsheet uses
an incorrect value for Total Kjeldahl Nitrogen (TKN), which should be 6,500 mg/kg according
to the provided laboratory results. Typically, a mineralization rate of zero is used for WTPs as
well. Please revise.
G. Process Flow Diagrams) & Narrative(s):
1. No comment.

Mr. Corey J. Walters
June 19, 2023
Page 3 of 7
H. Ouantitative Justification(s):
1. Please revise the acreages and PAN calculations accordingly per Comments F and O.
I. Sampling Plans(s):
1. Please add Pathogen Reduction and Vector Attraction Reduction details for the Lumberton WWTP.
2. Please revise the laboratory testing schedule under the "Pollutants" heading to match the O&M
Plan.
J. Laboratory Analvtical Report(s):
1. No comment.
K. Pathogen Reduction (PR) & Vector Attraction Reduction (VAR) Compliance Documentation:
1. No comment.
L. Application (Form: LASC 06-16):
1. Please revise the acreages accordingly per Comment O.
M. County Board Notification(s):
1. No comment.
N. Application (Form: LOA 06-16):
On Page 2 of the LOA for Site NC-RO-20 (Fields 3 & 6-8), please clear Section IV and move that
information to the LOA that contains the four fields transferred from Permit No. WQ00000527.
2. Please separate the LOA for Site NC-RO-20 (Fields 15-21) into two different LOAs and have them
re -signed and re -notarized. One that has the transferred fields (i.e., Fields 15-18) with Section IV
on Page 2 filled out (See Comment N.1.) and one that has the new fields (i.e., Fields 19-21).
Barbara Bullard no longer owns Fields 1A, 113, and 2 for Site NC-RO-39. Please revise the
associated LOAs to reflect the current landowners. If a single field is located on two separate
parcels with different landowners, please put that field on each LOA.
O. Vicinity/Setback Mav(s):
1. Overall — There are discrepancies between the vicinity/setback maps of the previous permit dated
April 27, 2017, and the vicinity/setback maps included in the submitted application package for the
renewed land application fields. The April 27, 2017, vicinity/setback maps have been included for
reference. There are previous comments in the Additional Information Request letter dated January
3, 2023, that were not addressed as well. r15A NCAC 02T .1104(c)(1)]

Mr. Corey J. Walters
June 19, 2023
Page 4 of 7
Please verify and revise all vicinity/setback maps for the following:
a. Show the latest property boundaries within 500 feet of the land application fields. Some maps
do not show property boundaries or show them shifted around, which will make property
setbacks incorrect. Recommend combining adjacent parcels for the same owner.
b. Show the line work for streams, surface waters (ponds), channels, and ditches within 500 feet
of the land application fields. Most maps do not have this delineated while others do. This
comment was not addressed in the Additional Information Reauest letter dated January 3. 2023.
Please refer to the April 27, 2017, vicinity/setback maps, which show drainage features for all
renewed land application fields.
c. Please mark all on -site and off -site habitable residences within 500 feet of the land application
fields. For off -site habitable residences, please show a setback radius for each individual
dwelling that is marked. Please note that for surface application by vehicle and
injection/incorporation by irrigation, there is no required setback for on -site habitable
residences. Some maps have unlabeled habitable residences, missing setback radii, two
habitable residences contained within one setback radius, setback radii not centered at the
habitable residence, etc.
d. For all setback radii, please show a symbol in the center representing what the setback is for
(i.e., off -site dwelling, well, etc). Please note that for surface application by vehicle and
injection/incorporation by irrigation, there is no required setback for on -site residences. Most
maps do not show these symbols while others do. This comment was not addressed in the
Additional Information Reauest letter dated January 3. 2023. Please also distinguish the
symbols used for on -site residences and off -site residences from one another. [15A NCAC
02T .1108(c)]
e. Please show the area within setback radii, 50-foot property boundary setbacks, and drainage
feature setbacks as unsuitable areas within the property boundaries of the land application site.
Please refer to the April 27, 2017, vicinity/setback maps, which show these areas buffered out
for all renewed land application fields. [15A NCAC 02T .1108(c)]
f. Please revise the title blocks to show figure number locations but do not add figure numbers.
The figures will be numbered for the draft permit.
g. Recommend making the line work for the application area the top layer in ArcGIS.
h. Recommend adding a scale label formatted as "1 in = 500 ft" and adjusting the map scale to
even increments so setbacks are easily verifiable.
i. Recommend that map legends have the same content and follow the same symbology.
2. Site NC-RO-16 (Fields 1-8) —
a. There are two wells shown on the April 27, 2017, vicinity/setback maps that are not shown on
this map. Please verify and revise.
b. Are 50-foot property boundary setbacks met for Fields 2, 4, 8, and 5? It is hard to verify this
without the property boundaries or buffer areas shown. [15A NCAC 02T .1108(c)]
c. Instead of a single radius, the pond boundary should be delineated and buffered from the pond
boundary. Please revise.

Mr. Corey J. Walters
June 19, 2023
Page 5 of 7
3. Site NC-RO-16 (Fields 16-19) —Are 50-foot property boundary setbacks met for Fields 2, 4, 8, and
5? It is hard to verify this without the property boundaries or buffer areas shown. r15A NCAC
02T .1108(c)]
4. Site NC-RO-17 (Fields 1 & 6) —
a. The map is labeled as "Field 1-6", but only the entirety of Fields 1 and 6 are shown. Please
revise.
b. Compared to the April 27, 2017, vicinity/setback maps, Field 1 is increasing by roughly 8 acres
with no significant change in the application area boundary. The application area boundary on
the north side goes outside of the established field boundary on the aerial. Please explain this
increase in area and revise the application area boundary.
5. Site NC-RO-17 (Fields 2 & 3) —
a. The map is labeled as "Field 1-2", but only the entirety of Fields 2 and 3 are shown. Please
revise.
b. The property boundaries shown do not match the Robeson County GIS. Recommend
combining all of the City of Lumberton parcels. Please verify and revise.
c. The drainage features are not buffered correctly. They should be buffered equally on each side
using the appropriate setbacks and rounded where appropriate (i.e., at the end of a line). Please
refer to the April 27, 2017, vicinity/setback maps, which show the correct buffer areas and
additional drainage features not shown on this map. Please revise. f 15A NCAC 02T .1108(01
d. Compared to the April 27, 2017, vicinity/setback maps, Field 2 is increasing by roughly 26
acres with additional area being added on the west side. If this additional area is to be added,
please provide a Soil Evaluation per 15A NCAC 02T .1104(c)(2). If not, please remove this
area from Field 2.
e. Compared to the April 27, 2017, vicinity/setback maps, Field 3 is increasing by roughly 14
acres with no significant change in the application area boundary. Please explain this increase
in area.
f. Both Fields 2 and 3 look heavily saturated in the most recent aerial. Are there SHGWT issues
with these fields or is overapplication occurring?
6. Site NC-RO-17 (Fields 4 & 4A) —Compared to the April 27, 2017, vicinity/setback maps, Field 4
is increasing by roughly 18 acres with a significant decrease in the application area boundary. The
application area boundary on the northwest side goes outside of the established field boundary on
the aerial. Please explain this increase in area and revise the application area boundary.
7. Site NC-RO-17 (Field 5) — The parcel lines shown do not match the Robeson County GIS.
Recommend combining all of the City of Lumberton parcels. Please verify and revise.
Site NC-RO-20 (Field 4) — Please show the setback radius for the off -site habitable residence
located at 5020 Shannon Road (Parcel No. 181101032) and update the application area boundary
accordingly. r15A NCAC 02T .1108(c)]

Mr. Corey J. Walters
June 19, 2023
Page 6 of 7
9. Site NC-RO-20 (Fields 6-8 & 14) —
a. How did Field 8 stay the same acreage after removing the northwest portion shown in the April
27, 2017, vicinity/setback maps?
b. There is a well next to Field 8 shown on the April 27, 2017, vicinity/setback maps that is not
shown on this map. Please verify and revise.
c. Since Field 14 is not owned by Ronald G. Hammonds, 50-foot property boundary setbacks
must be shown for Field 14 and the portions of Fields 7 and 8 that border Field 14. Please
revise. [15A NCAC 02T .1108(c)]
10. Site NC-RO-20 (Fields 3 & 15-17) —
a. There are missing setback radii for off -site habitable residences along Rennert Road. Please
revise and update application area boundaries accordingly. [15A NCAC 02T .1108(c)]
b. Instead of a single radius, the pond boundary between Fields 3, 15, and 17 should be delineated
and buffered from the pond boundary. There are also drainage features nearby that have not
been called out. Please revise. f.15A NCAC 02T .1108(c)1
c. Please delineate the pond boundary near Field 16 and show the setback. r 15A NCAC 02T
.1108(c)]
d. Compared to the April 27, 2017, vicinity/setback maps, Field 3 is increasing by roughly 5 acres
with no significant change in the application area boundary. Please explain this increase in
area.
e. Compared to the June 26, 2019, vicinity/setback maps for Permit No. WQ0000527, Field 15
(previously Field 2) is increasing by roughly 2 acres with no significant change in the
application area boundary. Please explain this increase in area.
11. Site NC-RO-20 (Field 18) —
a. There are four wells shown on June 26, 2019, vicinity/setback maps for Permit No.
WQ0000527, that are not shown on this map. Please verify and revise.
b. Please show the setback radii for the off -site habitable residences located at 1105 Shannon
Road (Parcel No. 20090100301) and Parcel No. 200901002 and update the application area
boundary accordingly. [15A NCAC 02T .1108(c)]
12. Site NC-RO-20 (Fields 19 & 21) — Please show the missing property boundaries around the
northwest portion of Field 20 and the entirety of Field 21.
13. Site NC-RO-28 (Fields 1-3) — At the bottom, the owner is shown as Carnell Locklear, which is
incorrect. Please revise.
14. Site NC-RO-39 (Fields 1-6) —
a. Please add the acreages of Fields 5 and 6 to the table.
b. The property boundaries shown do not match the Robeson County GIS. Please verify and
revise.

Mr. Corey J. Walters
June 19, 2023
Page 7 of 7
c. Please delineate the pond boundaries near Fields 2 and 2 and show the setbacks. [15A NCAC
02T .1108(c)]
d. There are multiple wells shown on the April 27, 2017, vicinity/setback maps that are not shown
on this map. Please verify and revise.
15. Site NC-RO-39 (Fields 7 & 8) —
a. Please show the pond setback next to Field 7. [15A NCAC 02T .1108(c)]
b. Please adjust the Field 8 northeast application area boundary to match what was shown on the
April 27, 2017, vicinity/setback maps.
c. Please remove the stray text shown along Saddletree Road.
16. Site NC-RO-39 (Field 9) —
a. The total acreage shown in the table is less than the application area. Please verify and revise.
b. Please adjust the Field 9 application area boundary to match what was shown on the April 27,
2017, vicinity/setback maps.
17. Site NC-RO-40 (Fields 1 & 2) — Please show the pond setback next to Field 1 and the well setback
next to Field 2. [15A NCAC 02T .1108(c)]
18. Site NC-RO-40 (Fields 4-7) —
a. Please show the well setbacks. [ 15A NCAC 02T .1108(c)]
b. There is unsuitable application area shown over the application area boundary for Field 5.
Please verify and revise.
19. Site NC-RO-42 (Fields 1-2) — The property boundaries shown do not match the Robeson County
GIS. Please verify and revise.
P. Soil & Agronomic Evaluation(s):
1. No comment.
Q. Undated Cumulative Pollutant Loading Rates (CPLRs):
1. Please provide the updated CPLRs for the four fields transferred from Permit No. WQ0000527.