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HomeMy WebLinkAboutWQ0001346_More Information Received_20231130Initial Review Reviewer nathaniel.thorn burg Is this submittal an application? (Excluding additional information.) * Yes No If not an application what is the submittal type?* Annual Report Residual Annual Report Additional Information Other Permit Number (IR) * W00001346 Applicant/Permittee City of Monroe Email Notifications Does this need review by the hydrogeologist? * Yes No Regional Office CO Reviewer Admin Reviewer Submittal Form Project Contact Information Please provide information on the person to be contacted by NDB Staff regarding electronic submittal, confirmation of receipt, and other correspondence. Name* Rob Willcox Email Address* rob@willcoxmabesoil.com Project Information Application/Document Type* New (Fee Required) Modification - Major (Fee Required) Renewal with Major Modification (Fee Required) Annual Report Additional Information Other Phone Number* 3363399128 Modification - Minor Renewal GW-59, NDMR, NDMLR, NDAR-1, N DAR-2 Residual Annual Report Change of Ownership We no longer accept these monitoring reports through this portal. Please click on the link below and it will take you to the correct form. https://edoes.deq.nc.gov/Forms/NonDischarge_Monitoring_Report Permit Type:* Wastewater Irrigation High -Rate Infiltration Other Wastewater Reclaimed Water Closed -Loop Recycle Residuals Single -Family Residence Wastewater Other Irrigation Permit Number:* WQ0001346 Has Current Existing permit number Applicant/Permittee Address* Post Office Box 69; Monroe, N.C. 28111 Facility Name* City of Monroe Class B Residuals Program Please provide comments/notes on your current submittal below. Response to Additional Information Request Letter dated October 18, 2023 At this time, paper copies are no longer required. If you have any questions about what is required, please contact Nathaniel Thornburg at nathaniel.thornburg@ncdenr.gov. Please attach all information required or requested for this submittal to be reviewed here. (Application Form, Engineering Plans, Specifications, Calculations, Etc.) 15-10 City of Monroe Add Info 11-28-23.pdf 2.51 MB Upload only 1 PDF document (less than 250 MB). Multiple documents must be combined into one PDF file unless file is larger than upload limit. * By checking this box, I acknowledge that I understand the application will not be accepted for pre -review until the fee (if required) has been received by the Non -Discharge Branch. Application fees must be submitted by check or money order and made payable to the North Carolina Department of Environmental Quality (NCDEQ). I also confirm that the uploaded document is a single PDF with all parts of the application in correct order (as specified by the application). Mail payment to: NCDEQ — Division of Water Resources Attn: Non -Discharge Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Signature 9U�ll�x Submission Date 11/30/2023 willcox&mate SO I L SOL U T I ON S November 28, 2023 NCDEQ/DWR Non -Discharge Branch 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Attention: Mr. Elton Luong Reference: Application for City of Monroe Class B Residuals Land Application Program Permit No. WQ0001346 Additional Information Request dated October 18, 2023 Union County, North Carolina Willcox & Mabe Soil Solutions, PLLC Project No. 15-10 Dear Mr. Luong: Willcox & Mabe Soil Solutions, PLLC (WMSS) is submitting the enclosed Additional Information Response for the referenced permit application for the City of Monroe Class B Residuals Land Application Program (RLAP). Please accept this letter and the attachments as response to the referenced items within the Additional Information Request from the North Carolina Department of Environmental Quality (NCDEQ) — Division of Water Resources (DWR), Non -Discharge Branch (NDB) dated October 18, 2023. WMSS is providing response to the following items with the request and response given below: Item J.1.: Per 15A NCAC 02T .1104(b)(3), the sampling plan for each source needs to describe how compliance with pollution limits and pathogen reduction (15A NCAC 02T .1105, 02T .1106, 02T.1107) will be met. Please verify and revise. Response: Updated sampling plan attached Item 0.1.: For Site NC-UN-030, Tom Appenzeller signed Form: LOA 06-16 instead of Margaret Appenzeller, who is the listed owner on the Union County GIS. The Division could not locate the property deed. Please confirm that Tom Appenzeller has the authority to sign for Margaret Appenzeller and re- sign if necessary. Response: Power of Attorney for Mr. Tom Appenzeller to sign is attached Item P.L: Per Form: LASC 06-16 Instruction B, please provide existing setback waivers for all applicable fields. [15A NCAC 02T .1108(e)]. Willcox & Mabe Soil Solutions, PLLC / 7231 B Summerfield Road / Summerfield, NC 27358 / Rob 336.339.9128 or Martin 336.312.1396 / www.willcoxmabesoil.com Application for City of Monroe RLAP WMSS Project No. 15-10 Additional Information Request — Application No. WQ0038499 November 28, 2023 Response: No setback waivers are applicable for any of the renewal or modification sites. Item Q.1.: For Field NC-UN-035-02, please verify the location and usage (public water or irrigation) of any existing wells and their appropriate setbacks. Maria Schutte of the Mooresville Regional Office (MRO) commented that this field may be similar to Field NC-UN-035-03, which indicates a habitable residence with a well. [15A NCAC 02T .I c . Response: There are no existing water supply wells associated with Field NC-UN-035-02. The residence associated with this field is serviced by a public water source. Item Q.2.: For Field NC-UN-035-03, Maria Schutte of the MRO commented that the acreage on the southwest side of the pond will not be used for land application. Please verify the land application use and revise the applicable maps for acreage changes. Response: Updated buffer map identifying net acreage (18.3 acres) associated with reduction of the acreage on the southwest side of the pond not to be used is attached. Item T.1.: The process flow diagram on Page 142 (Form: RSC-06-16 for the City of Monroe WTP) does not reflect the most recent upgrades (centrifuge, residual processing, etc.) described by the MRO. Please provide an updated process flow diagram. This will not hold up the permit renewal process. Response: Updated process flow diagram is attached. WMSS appreciates the opportunity to assist in responding to the Additional Information Request for the City of Monroe Class B Residuals Land Application Program. If after reviewing the enclosed information you have any questions or require any additional information, please contact us at your convenience. Sincerely, Willcox & Mabe Soil Solutions, PLLC Martin E. Mabe Partner / Agronomist Attachments cc: City of Monroe Rob Willcox, L.S.S. Partner / Soil Scientist Shared\WMSS Projects\2015\15-10 City of Monroe\2023 Permit Renewal\NCDEQ Submittal Info\Additional Information 10-18-23\15-10 City of Monroe Add Info 11-15-23.doc ATTACHMENTS • Updated Sampling Plan • Power of Attorney for Mr. Tom Appenzeller • Updated Buffer Map — NC-UN-035-03 • Updated process flow diagram — City of Monroe WTP Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page I of 21 Land Application Program Introduction The City of Monroe, in an effort to better serve the citizens, started its own Land Application Program. This gives the City an avenue to dispose of residuals created from the treatment of wastewater and the treatment of raw water for drinking. Residuals have many characteristics that are beneficial to soil and plants. For this reason, Federal and State Government consider land application "beneficial use" of residuals. The residuals are applied to local farmer's fields as a source of fertilizer. This process is regulated federally by the Environmental Protection Agency (EPA). Federal regulations establish minimum national standards for residuals management under Title 40 Code of Federal Regulations Part 503. The EPA allows individual states to adopt regulations at least as stringent as the federal regulations, but allows states to adopt more restrictive regulations and to administer them differently. In North Carolina, the Department of Environmental Quality (DEQ) is authorized by the NC General Assembly to develop and implement state regulations and to issue permits for the generation and disposal of residuals. These responsibilities are delegated to DEQ's Division of Water Resources (DWR). These regulations, 15A NCAC 2T .1100, specifically incorporate and require compliance with 40 CFR Part 503. Each entity that desires to land apply residuals, must apply for and be granted a permit. The City of Monroe's current permit number is WQ0001346. The permit requires an Operator in Responsible Charge (ORC) and at least one back-up Operator in Responsible Charge (BORC) to be named to oversee the Land Application program. The ORC for the City of Monroe is the Wastewater Treatment Plant Superintendent, the Land Residual Coordinator and Wastewater Treatment Plant Chief Operator are the Backup ORC's. All of these individuals must possess a valid land application of residuals system operator certification. The City of Monroe has a calendar of annual activities and various checklists that coincide with land application to ensure compliance with the regulations. This calendar is included later in the Standard Operating Procedure (SOP) and Best Business Practice (BBP). Land must be permitted to be applied on. Several factors influence whether land can be accepted into the permit. Some of these factors include the type of soil, the absorption rates of the particular soil, depth of the soil, and depth of groundwater. The City of Monroe consults with agronomists and soil engineers to identify suitable sites for land application. Once land is included in the permit, the City of Monroe and the land owner enter into a mutually beneficial partnership to use the land. The landowner receives residuals that are beneficial to build up his land. The City now has a place to manage the residuals it has generated. The 40 CFR Part 503 and 15A NCAC 2T regulations dictate where residuals can be applied on the permitted land, how much can be applied, and limits for constituents in the residuals that are applied. Residuals must be sampled throughout the year to Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 2 of 21 identify the presence of organic and inorganic solids. The frequency of sampling and the parameters of safe residuals are addressed later in the SOP/BBP. Yearly soil samples are taken to ensure the soil is not being affected adversely by the application of residuals. In the end, the Land Application Program is a partnership between the landowners in the permit and the City of Monroe Wastewater and Water Treatment Plants. All good partnerships have benefits for each party. Citizens are benefitted by the program being run efficiently and in a safe manner to keep fees lower and limit negative environmental impacts. Permitted landowners use the residuals to make their land more fertile. The City of Monroe benefits by controlling when, where, and how residuals are disposed of. It is in everyone's best interest for the City of Monroe's Land Application Program to be run with integrity and to the highest standard of compliance with regulations. Safety Considerations • Biohazards • Traffic safety • Equipment safety Tools and Equipment Required Tankers and dump trailer Pick-up Truck Tractor, pull tank, spreader, skid steer loader, Large tire loader Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 3 of 21 Operation and Maintenance Plan The City of Monroe Land Application Standard Operation and Maintenance Plan is outlined in the different areas which is in compliance with 15A NCAC 02T .I 110: 15A NCAC 02T .I I IOOPERATION AND MAINTENANCE (a) An Operation and Maintenance Plan shall be maintained for all residuals management programs. The plan shall:(I)describe the operation of the program and all associated facilities and equipment in sufficient detail to show what operations are necessary for the program to function and by whom the functions are to be conducted; (2)describ e anticipated maintenance of facilities and equipment that are associated with the program;(3)include provisions for safety measures, including restriction of access to the site and equipment, as appropriate;(4)include spill control provisions, including:(A)response to upsets and bypasses, including control, containment, and remediation; and(B)contact information for program personnel, emergency responders, and regulatory agencies;(5)detail procedures for sampling and monitoring to ensure that the program stays in compliance with this Section and each issued permit; and(6)for surface disposal units, detail procedures for post -closure care management.(b) The permittee shall ensure that an electronic or physical copy of their permit and the Operation and Maintenance Plan required by Paragraph (a) of this Rule is available when land applying residuals.(c) Residuals shall be stored or staged in a manner to prevent runoff of leachate and other wastewaters generated from residuals storage or staging.(d) Class A residuals may be staged at the application site for up to 30 days for biological residuals and 60 days for non -biological residuals. Storage or staging that exceeds these limits shall require written approval from the Division.(e) Class B residuals shall not be stored or staged at any land application site without prior written approval from the Division.(f) The permittee shall perform inspections and maintenance on storage, distribution, and application facilities.(g) Class B land application areas shall be clearly marked on each site prior to and during any land application of residuals. History Note: Authority G.S. 143-215.1; 143-215.3(a);Eff. September 1, 2006;Readopted Eff. September 1, 2018. And in accordance with permit number WQ0001346. Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 4 of 21 The City of Monroe program has two plants that produce residuals. Each of these plants has the capability to produce a liquid sludge and a more solid cake sludge. Both types of sludge can be applied to the field but the City of Monroe primarily applies cake sludge. The Wastewater Treatment Plant has a belt press and the Water Treatment Plant has a centrifuge to dewater sludge. By dewatering the residuals, it produces a product that is more concentrated and contains more solids. This has advantages for both the City and the landowners. With a more concentrated product, less loads have to be hauled out. This saves the City money with their trucking contractors, fuel, and maintenance. The landowners appreciate the cake product more because with less loads being hauled through the field compaction doesn't become an issue. Compaction results in crop loss and it makes the land harder to till or plant. Storage pads are located at both facilities to hold cake waiting to be land applied. The Land Residuals Coordinator is tasked with the daily operations of the program. This includes coordinating with the landowners the schedule for land applying. Once it is determined which field will be applied on, the Pre -operating Checklist, located later in this SOP, should be completed and a certified Land Application operator must flag the field. The field is flagged to show the setbacks outlined in the 15A NCAC 2T regulations and the permit. This process shows the buffered areas of the field where no residuals can be applied. When it's time for application, City personnel use a rubber tire loader or backhoe to load the cake into trucks. Trucks haul the cake to the predetermined field. Once it's in the field it will be dumped in a designated unloading area. This area should be reasonably level to ensure safe dumping for the trucks and enable the land application operator to load the product into spreader easily. This area is also strategically located to ensure application is done efficiently. It is loaded into a spreader that is pulled by a tractor and broadcast over the field within the flagged limits. The permit does not allow biosolids to be stockpiled in the field. If circumstances arise that prohibit the biosolids to be spread that day, it must be loaded back up into trucks and hauled back to the plant. In rare instances, liquid sludge may have to be hauled. Each plant has pumps and overhead loading stations to load tankers. The City of Monroe has a pull tank to hook behind the tractor to apply liquid sludge. Liquid would only be land applied in case of emergency. For instance if the dewatering equipment was down for an extended period of time or when drawing down a tank or digester. When application is complete, there is a visual checklist that must be completed located later in this SOP/BBP. The 15A NCAC 2T regulations and permit dictate when the landowner can use this field next. For example, the landowner can't graze cattle on that particular field for 30 days after completion of land application. The Land Residuals Coordinator is responsible for maintaining equipment used in land application while in the field. This equipment consists of a tractor, pull tank, cake spreader, Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 5 of 21 Bobcat, service truck, tankers, dump trailer, dump truck, and a road tractor. Daily visual inspections are performed on the equipment and, at least annually, taken in for fleet maintenance. The loading stations and storage pads are maintained by plant maintenance and operators. This consists of daily plant checks and preventative maintenance by plant operators and/or EM personnel. Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 6 of 21 Sampling and Monitoring Plan The Land Residual Coordinator is responsible for taking all samples. Samples are composite samples of multiple grab samples, these samples are sent to outside labs to avoid any conflict of interest with the sample data. Currently the contract laboratories doing the analytical work are Waypoint Analytical, PAR Laboratories, Inc. and PACE Analytical Services, LLC. If the Land Residual Coordinator is unavailable, the Wastewater Plant Superintendent or Chief Operator will designate personnel to perform the sampling. Samples must be taken in accordance with 40 CFR Part 503.32(a) or (b), 40 CFR Part 503.33 and the issued permit so that pathogen and vector attraction specifications are met. Pollutant concentrations are checked prior to field application events. The plant available nitrogen will be calculated to ensure field will not be overloaded along with ceiling limits of pollutants checked. Cumulative pollutant loading rates must be checked and tracked. Pollutants cannot be allowed to accumulate over years of land application events above Federal and State regulated specifications. Residuals applied shall also be monitored as listed in rules .1105(a), .1105(d), .1106 and .1107. Laboratory parameter analyses shall be performed on the residuals as they are land applied, and shall be in accordance with the monitoring requirements in 15A NCAC 02B .0505. [15A NCAC 02B .0505]. The sampling point for cake is the cake storage beds. The sampling point for applying liquid is digester 95 at the WWTP and thickener at the WTP. The City of Monroe currently samples once per quarter. The frequency of the monitoring is required as the following: Metric tons per 365 day period (dry weight basis) Monitoring frequency Greater than zero but less than 290 once per year Equal to or greater than 290 but less than 1500 once per quarter (4 times per year) Equal to or greater than 1500 but less than 15000 once per 60 days (6 times per year) Equal to or greater than 15000 once per month (12 times per year) Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 7 of 21 An analysis shall be conducted on residuals from each source generating facility at the frequency specified in Attachment A of current permit, and the Permittee shall maintain the results for a minimum of five years. The analysis shall include the following parameters: Aluminum Mercury Potassium Ammonia -Nitrogen Molybdenum Selenium Arsenic Nickel Sodium Cadmium Nitrate -Nitrite Nitrogen Sodium Adsorption Ratio (SAR) Calcium Percent Total Solids TKN Copper pH Zinc Lead Phosphorus Magnesium Plant Available Nitrogen (by calculation) [15A NCAC 02T. 1101] Residuals shall be monitored for compliance with pathogen and vector attraction reduction requirements at the frequency specified in Attachment A of current permit, The required data shall be specific to the stabilization process utilized, and sufficient to demonstrate compliance with the Class B pathogen reduction requirements in 15A NCAC 02T. 1106 (a) and (c), and one vector attraction reduction requirement in 15A NCAC 02T .1107 (a) shall be met. Any exceptions from the requirements in this condition shall be specified in Attachment A. [15A NCAC 02T .1106, 02T .1107, 02T A I I 1(c)] The City of Monroe currently uses Fecal Coliform (Geom. Mean) and Volitile Solids reduction using Van Kleek equation. Sample for In starting digestion is taken at WAS pumps. Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 8 of 21 Pollutant concentrations in residuals applied to land application sites listed in Attachment B of current permit shall not exceed the following Ceiling Concentrations (i.e., dry weight basis) or Cumulative Pollutant Loading Rates (CPLRs): Parameter Ceiling Concentration (milligrams per kilogram) CPLR (pounds per acre) Arsenic 75 36 Cadmium 85 34 Copper 4,300 1,338 Lead 840 267 Mercury 57 15 Molybdenum 75 n/a Nickel 420 374 Selenium 100 89 Zinc 7,500 2,498 The Permittee shall determine compliance with the CPLRs using one of the following methods: a. By calculating the existing cumulative level of pollutants using actual analytical data from all historical land application events of residuals, or b. For land where residuals application has not occurred or for which the required data is incomplete, by determining background concentrations through representative soil sampling. [15A NCAC 02T .1105] Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 9 of 21 Residuals shall be analyzed to demonstrate they are non -hazardous under the Resource Conservation and Recovery Act (RCRA). Residuals that tests or is classified as a hazardous or toxic waste under 40 CFR Part 261 shall not be used or disposed under this permit. The analyses [corrosivity, ignitability, reactivity, and toxicity characteristic leaching procedure (TCLP)I shall be performed at the frequency specified in Attachment A of current permit, and the Permittee shall maintain these results for a minimum of five years. Any exceptions from the requirements in this condition shall be specified in Attachment A of current permit. The TCLP analysis shall include the following parameters (the regulatory level in milligrams per liter is in parentheses): Arsenic (5.0) 1,4-Dichlorobenzene (7.5) Nitrobenzene (2.0) Barium (100.0) 1,2-Dichloroethane (0.5) Pentachlorophenol (100.0) Benzene (0.5) 1, 1-Dichloroethylene (0.7) Pyridine (5.0) Cadmium (1.0) 2,4-Dinitrotoluene (0.13) Selenium (1.0) Carbon tetrachloride (0.5) Endrin (0.02) Silver (5.0) Chlordane (0.03) Hexachlorobenzene (0.13) Tetrachloroethylene (0.7) Chlorobenzene (100.0) Heptachlor (and its hydroxide) (0.008 Toxaphene (0.5) Chloroform (6.0) Hexachloro- 13-butadiene (0.5) Trichloroethylene (0.5) Chromium (5.0) Hexachloroethane (3.0) 2,4,5-Trichlorophenol (400.0) m-Cresol (200.0) Lead (5.0) 2,4,6-Trichlorophenol (2.0) 0-Cres01 (200.0) Lindane (0.4) (Silvex) (1.0) p-Cres01 (200.0) Mercury (0.2) Vinyl chloride (0.2) Cresol (200.0) Methoxychlor (10.0) 2,4-D (10.0) Methyl ethyl ketone (200.0) Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 10 of 21 Once the residuals have been monitored for two years at the frequency specified in Attachment A, the Permittee may submit a permit modification request to reduce the frequency of this monitoring requirement. In no case shall the monitoring frequency be less than once per permit cycle. [15A NCAC 13A .0102(b), 02T .1101, 02T .1105] An annual representative soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on each land application site listed in Attachment B on which a residuals land application event will occur in the respective calendar year. This analysis shall be in accordance with the "Guidance on Soil Sampling" located in the Sampling Instructions section of the NC Department of Agriculture & Consumer Services' website Lhiip://www.ncagr.gov/agronomi/Tubs.htm). The Permittee shall maintain these results and a description of the sampling methodologies used to determine soil fertility for a period of no less than five years, and shall be made available to the Division upon request. At a minimum, the Standard Soil Fertility Analysis shall include the following parameters: Acidity Exchangeable Sodium Percentag Phosphorus Base Saturation (by calculation) Magnesium Potassium Calcium Manganese Sodium Cation Exchange Capacity Percent Humic Matter Zinc Copper pH [15A NCAC 02T .0108(c), 15A NCAC 02T .1111(d)] Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 11 of 21 Spill Control Plan In the unlikely event of a spill, the following actions shall be immediately taken: 1. Management of cleanup activities: The first City of Monroe representative at the scene will begin procedures to halt the spill and initiate cleanup activities. Upon arrival of the Land Residual Coordinator, Wastewater Treatment Plant Superintendent or Wastewater Treatment Plant Chief Operator will take immediate action to coordinate all activities. In the event additional labor and equipment are required, assistance shall be requested from City of Monroe Water Resources Department. The LRC or WWTS with the approval of Director of Water Resources and/or City Public Information Officer will also communicate with the public on the scene, answer questions and advise of cleanup activities. 2. Contain Spill: Attempt to halt spill from ruptured containers. Form barriers from earthen materials, straw or foam to contain spill. The person in charge on the site will advise the clean up personnel where to get straw, lime, and other items necessary to contain the spill. 3. Clean Up: Water Resources department will supply front end loaders, vacuum equipment, local septic tank services or any other equipment needed to remove as much spilled product as possible. Straw and sand will be used to soak up remaining materials then removed to a designated site. 4. Final Clean Up: Rotary brush sweeper or street cleaner shall be utilized. Lime will be applied to the site. If the spill occurs on private property, the cleanup will be completed to the satisfaction of the property owners and the City of Monroe representatives. The ultimate goal is to return the spill site to its original condition. 5. Reporting_ The LRC or WWTS will notify other City of Monroe personnel as needed. The regional office of DENR will be contacted as soon as possible, but no later than 24 hours after the spill occurrence. The LRC or WWTS shall provide a written report within 48 hours of the spill to DENR. The report will list all relative information and actions taken. City of Monroe personnel will file a written report to DENR within 5 days of the occurrence. Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 12 of 21 Contact information Land Residual Coordinator Mobile — (704) 361-6035 Office — (704) 282-4679 Wastewater Treatment Superintendent Mobile - (704) 226-6093 Office — (704) 282-4612 Water Treatment Superintendent Mobile — (704) 661-2131 Office — (704) 282-4668 Wastewater Treatment Chief Operator Mobile — (704) 695-2458 Office — (704) 282-4678 Water Resources Director Mobile — (980) 315-9845 Office — (704) 282-4624 Local Police and Fire Emergency 911 Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 13 of 21 Procedures Land Application Program Annual Activities January • WWTP Activities Effecting Land Application - Start preparing annual report for DWQ and EPA - Quarterly samples (Fecal Coll forms, volatile solids 38% reduction, 503 metals) send samples to contract labs. - Take fecal samples to contract laboratory. - Run belt press as personnel and weather permits - Start preparing land application program budget for next Fiscal Year - Retrieve soil samples for annual report • WTP Activities Effecting Land Application - Quarterly samples (503 metals only) Send samples to contract laboratory. - Haul from WTP to WWTP if needed due to weather, emergency only. • Crop Considerations - Fescue, Grassland • Equipment Maintenance Plans - General maintenance (grease pull tank, spreader, tractor, ect...) - Take tractor to shop for yearly service - Do monthly inspection of all equipment • Application possibilities — Land application is not done during this month due to weather conditions, annual report having to be done February • WWTP Activities Effecting Land Application - Finish preparing annual report for DWQ and EPA - EPA report needs to be sent off by no later than Feb. 18t` - DWQ report has to be sent off no later than Feb. 28t` - Haul cake to field if possible, liquid emergency only - Run belt press as much as personnel and weather will permit • WTP Activities Effecting Land Application - Haul from WTP to WWTP if needed due to weather, emergency only. - Haul cake to fields if possible, liquid emergency only Crop Considerations Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 14 of 21 - Fescue, Grassland • Equipment Maintenance Plans - Critical to ensure equipment is ready for land Application - Preventative maintenance on all trailers — Air lines, brakes, tires, lighting, baffles, stress cracks - General maintenance (grease pull tank, spreader, tractor, ect...) - Do monthly inspection of all equipment • Application possibilities — Wet weather typical, limited land application available March WWTP Activities Effecting Land Application - Haul cake to fields if possible, liquid emergency only - Run belt press as much as personnel and weather will permit WTP Activities Effecting Land Application - Haul cake to fields if possible, liquid emergency only - Haul from WTP to WWTP if needed, emergency only. Crop Considerations - Fescue, Grassland only available • Equipment Maintenance Plans - General maintenance on all equipment (grease pull tank, spreader, tractor, ect...) - Do monthly inspection of all equipment • Application possibilities - Wet weather typical, limited land application available April • WWTP Activities Effecting Land Application - Quarterly samples (Fecal Coll forms, volatile solids 38% reduction, 503 metals) send samples to contract labs. - Take fecal samples to contract laboratory. - Haul cake to fields, liquid emergency only - Run belt press as much as personnel and weather will permit • WTP Activities Effecting Land Application - Quarterly samples (503's) send samples to contract laboratory - Haul cake to fields, liquid emergency only - Haul from WTP to WWTP if needed, emergency only. • Crop Considerations - Contact farmers to line up fields for land application - Contact Contractors about liming fields before applications • Equipment Maintenance Plans - General maintenance on all equipment (grease pull tank, spreader, tractor, ect...) - Do monthly inspection of all equipment • Application possibilities - warmer/dryer, try to maximize application to fields May Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 15 of 21 • WWTP Activities Effecting Land Application - Run belt press as much as personnel and weather will permit - Haul cake to fields, liquid emergency only • WTP Activities Effecting Land Application - Haul cake to fields, liquid emergency only - Haul from WTP to WWTP if needed, emergency only. • Crop Considerations - Fescue, Grassland • Equipment Maintenance Plans - General maintenance on all equipment (grease pull tank, spreader, tractor, ect...) - Do monthly inspection of all equipment • Application possibilities - warmer/dryer, try to maximize application to fields • Train Water Plant staff member and WWTP Chief Operator one day each, operating tractor and land applying. June • Check budget for availabilities of funds for end of fiscal year • WWTP Activities Effecting Land Application - Haul cake or to fields, liquid emergency only - Run belt press as much as personnel and weather will permit • WTP Activities Effecting Land Application - Haul cake to fields, liquid emergency only - Haul from WTP to WWTP if needed, emergency only. • Crop Considerations - Fescue, Grassland • Equipment Maintenance Plans - General maintenance on all equipment (grease pull tank, spreader, tractor, ect...) - Do monthly inspection of all equipment • Application possibilities - warmer/dryer, try to maximize application to field July • Start of new budget year - Setup PO for contract laboratory(s) - Resign contract for trucking and setup PO - Setup PO for Lime Applications to fields • WWTP Activities Effecting Land Application - Quarterly samples (Fecal Coll forms, volatile solids 38% reduction, 503 metals) send samples to contract laboratory - Take fecal samples to contract laboratory - Run belt press as much as personnel and weather will permit - Do annual TCLP samples (send to contract laboratory) Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 16 of 21 WTP Activities Effecting Land Application - Quarterly samples (503's) send samples to contract laboratory - Haul from WTP to WWTP if needed, emergency only. - Do annual TCLP samples (send to contract laboratory) Crop Considerations - Fescue, Grassland • Equipment Maintenance Plans - General maintenance (grease pull tank, spreader, tractor, ect.) - Do monthly inspection of all equipment • Application possibilities - warmer/dryer, try to maximize application to fields August • WWTP Activities Effecting Land Application - Haul cake to fields, liquid emergency only - Run belt press as much as personnel and weather will permit • WTP Activities Effecting Land Application - Haul cake to fields, liquid emergency only - Haul from WTP to WWTP if needed, emergency only. • Crop Considerations - Fescue, Grassland • Equipment Maintenance Plans - General maintenance (grease pull tank, spreader, tractor, ect.) - Do monthly inspection of all equipment • Application possibilities - warmer/dryer, try to maximize application to field • Train Water Plant staff member and WWTP Chief Operator one day each, operating tractor and land applying. September • WWTP Activities Effecting Land Application - Run belt press as much as personnel and weather will permit - Haul cake to fields, liquid emergency only • WTP Activities Effecting Land Application - Haul cake to fields, liquid emergency only - Haul from WTP to WWTP if needed, emergency only. • Crop Considerations - Starting to cut corn, check for open row crop fields - Fescue, Grassland • Equipment Maintenance Plans - General maintenance (grease pull tank, spreader, tractor, ect.) - Inspection due on F-250 pickup - Do monthly inspection of all equipment Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 17 of 21 • Application possibilities - warmer/dryer, try to maximize application to field October WWTP Activities Effecting Land Application - Quarterly samples (Fecal Coll forms, volatile solids 38% reduction, 503 metals) send samples to contract labs. - Take fecal samples to contract laboratory. - Haul cake to fields, liquid emergency only - Run belt press as much as personnel and weather will permit - Haul cake to fields if possible, liquid emergency only WTP Activities Effecting Land Application - Quarterly samples (503's) Send samples to contract laboratory - Haul to WWTP if needed, emergency only. - Haul cake to fields if possible, liquid emergency only Crop Considerations - Starting to cut soybeans, check for open row crop fields - Fescue, Grassland • Equipment Maintenance Plans - General maintenance (grease pull tank, spreader, tractor, ect.) - Do monthly inspection of all equipment • Application possibilities - warmer/dryer, try to maximize application to fields November WWTP Activities Effecting Land Application - Run belt press as much as personnel and weather will permit - Try to have storage beds empty for wet weather - Try to have digester 95 empty if possible - Pull soil samples on fields that have received land application where no second application is anticipated during the year - Send samples to NCDA&CS for analysis - Start gathering paper work for annual report - Haul cake to fields if possible, liquid emergency only WTP Activities Effecting Land Application - Haul to WWTP if needed, emergency only. - Haul cake to fields if possible, liquid emergency only Crop Considerations - Finish cutting soybeans, check for open row crop fields - Fescue, Grassland Equipment Maintenance Plans - Plan for any major repairs during wet weather Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 18 of 21 - General maintenance (grease pull tank, spreader, tractor, ect.) - Do monthly inspection of all equipment • Application possibilities —wetter conditions, Application to fields limited due to weather December • WWTP Activities Effecting Land Application - Run belt press as much as personnel and weather will permit - Pull soil samples on fields that have been applied on during Nov. and Dec. - Haul cake to fields if possible, liquid emergency only • WTP Activities Effecting Land Application - Target all drying beds (WTP) and thickener empty for the winter - Haul to WWTP if needed, emergency only. - Haul cake to fields if possible, liquid emergency only • Crop Considerations - Fescue, Grassland • Equipment Maintenance Plans - Plan for any major repairs during wet weather - General maintenance (grease pull tank, spreader, tractor, ect.) - Do monthly inspection of all equipment • Application possibilities - wetter conditions, application to fields limited due to weather Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 19 of 21 Field Inspections The Land Residual Coordinator is responsible for flagging the field to make sure all buffered areas are in accordance with State, Federal regulations and the issued permit. This person is also responsible for applying the product to the field. One of the qualifications for this position is to be a certified operator with the State of North Carolina. The City of Monroe has a Pre -operating checklist to be completed before land application begins. There is a Post Operating checklist to be completed prior to application. These checklists provide extra opportunities to make sure there is no runoff in the field, nothing was spread in the buffered areas, and the amount of residuals spread did not exceed specifications. They also provide another chance to review administrative details such as owners name, location and size of the field. Both of these checklists are included in this SOP/BBP. These are more examples of the safeguards put in place to ensure the program stays in compliance with regulations. Record Keeping • Sampling and application records are kept in L\8040 WWTP and Collection\Land Application • Vehicle and equipment records are maintained in the office and fleet shop. Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 20 of 21 PREOPERATING CHECKLIST Verify field is listed in permit Verify e-mail has been sent to DEQ of what field to be applied Verify landownership has not changed Verify PAN loading rate for crop to be grown 50 lbs. only if second crop to be grown Rain gauge on site and field flagged Signs posted at application site as required Date land application is est. to start Location of application site Acres to be applied on Source of residuals WTPL WWTPL WTPC WWTPC WWTPLM NAME DATE Water Resources Standard Operating And Best Business Practice Procedure Name Land Application of Biosolids Effective Date 11/1/20 Number 8040-LA-01 Revision Date 11/28/23 Responsible Division Waste Treatment Page 21 of 21 VISUAL CHECKLIST AFTER APPLICATION Signs posted at application site as required Verify field was left neat and clean Verify date application started Check for runoff due to rain Field was checked during application Field was checked after application Source of residuals WTPL WWTPL WTPC WWTPC WWTPLM NAME DATE If any violation are noted the Land Residual Coordinator or Plant superintendent will notify the regional office of the DENR by telephone as soon as possible, but no latter than24 hours, or the next working day. The Land Residual Coordinator or Plant Superintendent will file a written report to DEQ within 5 days of the violation. Robert D. Palmer, PLLC 614 West Main Street, P.O. Box 489 Marshville, North Carolina 28103 TELEPHONE 704.624.1909 October 9, 2019 Margaret L. Appenzeller c/o Herbert T. Appenzeller 830 Cover Leaf Road Marshville, NC 28103 RE: General Power of Attorney Dear Ms. Appenzeller and Mr. Appenzeller: FACSIMILE 704.624.1942 Please find enclosed the original General Power of Attorney that has been recorded with the Register of Deeds office in Guilford County, North Carolina. Please file this in a safe place with your other legal documents. Thank you in advance for your cooperation with this matter. We look forward to hearing from you.. Sincerely, f Robert D. Palmer Attorney at Law RDP/es enc BK. R 8199 1111�11�1�1111�11j11�11[�lfl 11 l 11 02-2 2102-2406 11 Ec i2EC6 OED 09-26-2019 2019052181 GUILFORD COUNTY, AFC NC FEE $26.00 01:49:00 PM JE;FF L. THIGPeN NY;JEANETTC MOMS. MEDLEY REGISTER DEPUTY -GB OF DEEDS 44 Return to: Robert D. Palmer STATE OF NORTH CAROLINA COUNTY OF UNION Qa, ER D PALMER, PLLC 614 W. MAIN S-r PO BOX 489 MARSHVILLE, NC 28103 POWER OF ATTORNEY "NOTICE: THE POWERS GRANTED BY THIS DOCUMENT ARE BROAD AND SWEEPING. THEY ARE DEFINED IN CHAPTER 32C OF THE NORTH CAROLINA GENERAL STATUES WHICH EXPRESSLY PERMITS THE USE OF ANY OTHER OR DIFFERENT FORM OF POWER OF ATTORNEY DESIRED BY THE PARTIES CONCERNED." IMPORTANT INFORMATION This power of attorney authorizes another person (your agent) to make decisions concerning your property for you (the Principal). Your agent will be able to make decisions and act with respect to your property (including your money) whether or not you are able to act for yourself. The meaningof authority over subjects listed on this form is explained in the North Carolina Uniform Power of Attorney Act. This power of attorney does not authorize the agent to make health care decisions for you. You should select someone you trust to serve as your agent. Unless you specify otherwise, generally the agent's authority will continue until you die or revoke the power of attorney or the agent resigns or is unable to act for you. EYour agent is entitled to reasonable compensation unless you state other wise in the Addition Provisions and xclusions. This form provides for designation of one agent, successor agent, and second successor agent. Ifyou wish to name more than one agent, successor agent, and second successor agent, you may name a coagent, successor coagent, or second successor coagen t in -the Additional Provisions and Exclusions. Coagents, successor coagents, or second successor coagents are not required to act together unless you include that requirement in th Provisions and Exclusions. e Additional If your agent is unable or unwilling to act for you, your power of attorney will end unless you have named a successor agent. You may also name a second successor agent. This power of attorney becomes effective immediately. If YOU have questions about the power of attorney or the authority you are granting to your agent, you should seek legal advice before signing this form. DESIGNATION OF AGENT 1, Margaret Little Appenzeller, born March 4,1929, currently residing at 5704 Old Oak Ridge Road, Greensboro, North Carolina, appoint the foIlawing persons to act jointly as my co -agents, such that any decision based on at least two out of the three (a majority) of my said agents, shall be binding as to any decision made. My agents include: Herbert Thomas Appenzeller, Jr., born February 16, 1951, and currently residing at 830 Cover Leaf Road, MarshvilIe, North Carolina; Linda Appenzeller Partee, born January 11, 1953 and currently residing at 3007 Cricket Lane, Lancaster, South Carolina; and Mary Appenzeller Somers, born May 4, 1956 and currently residing at 103 Sherborne Drive, Spartanburg, South Carolina, DESIGNATION OF SUCCESSOR AGENT(S) If either of my three agents named herein this Power of Attorney shall predecease me or oare otherwise unavailable or unwilling to act, then the remaining agent or agents may act alone. INITIAL below if you want to give an agent the power to name a successor agent. I give to my acting agent the full power to appoint another to act as my agent, and full power to revoke such appointment, if no agent name by me above is willing or able to act for me. GRANT OF GENERAL AUTHORITY I grant my agent and any successor agent general authority to act for me with respect to the following subjects as defined in the North Carolina Uniform Power of Attorney Act, Chapter 32C of the General Statutes: (.INITIAL each subject you want to include in the agent's general authority. If you wish to grant general authority over all of the subjects you may initial "All Preceding Subjects" instead of initialing each subject.) (1) Real Property; (2) Tangible Personal Property; (3) Stocks and Bonds; (4) Commodities and Options; (5) Banks and Other Financial Institutions; (6) Operation of Entity or Business; (7) Insurance and Annuities; (8) Estates, Trusts, and Other Beneficial Interests; (9) Claims and Litigation; (10) Personal and Family Maintenance; (11) Benefits from Governmental Programs or Civil or Military Service; (12) Retirement Plans; (13) Taxes; 9 -t ft, (14) All Preceding Subjects GRANT OF SPECIFIC AUTHORITY (OPTIONAL) My agent MAY NOT do any of the following specific acts for me UNLESS I have INITIALED the specific authority listed below: (CAUTION: Granting any of the following will give your agent the authority to take actions that could significantly reduce your property or change how your property is distributed at your death. INITIAL ONLY the specific authority you WANT to give your agent.) (1) Make a gift, subject to the limitations provided in General Statute 32C-2-217; (2) Create or change rights of survivorship; (3) Create or change a beneficiary designation; (4) Authorize another person to exercise the authority granted under this Power of Attorney; (5) Waive my right to be a beneficiary of a j oint and survivor annuity, including a survivor benefit under a retirement plan; Mj,& (6) Exercise fiduciary powers that I have authority to delegate; MA—W (7) Disclaim or refuse an interest in property, including a power of appointment; 4nLp,W (8) Access the content of electronic communications EXERCISE OF SPECIFIC AUTHORITY IN FAVOR OF AGENT (OPTIONAL) UNLESS INITIALED, an agent MAY NOT exercise any of the grants of specific authority initialed above in favor of the agent or an individual to whom the agent owes a legal obligation of support. ADDITIONAL PROVISIONS AND EXCLUSIONS (OPTIONAL) If at arry time there are only two agents actin on my behalf, they must unanimously Agree on any decision made by this power of attorney. Otherwise if all three agents are actin, then only a majority decision will be required to be binding and final If there should hap. -Pen to onl be one of my designated agents remaining to act on my behalf, then the decision of such individual agent shall be binding. EFFECTIVE DATE AND DURABII ITY This Power of Attorney is effective immediately AND will at all times be and remain durable and effective. This Power of Attorney shall not be affected by my subsequent incapacity or mental incompetence. NOMINATION OF GUARDIAN (OPTIONAL) fil If it becomes necessary for a court to appoint a guardian of ray estate of a general guardian, I nominate my agent acting under this Power of Attorney to be the guardian to serve without bond or other security. RELIANCE ON THE POWER OF ATTORNEY Any person, including my agent, may rely upon the validity of this Power of Attorney or a copy of it unless that person knows it had terminated or is invalid. MEANING AND EFFECT The meaning and effect of this Power of Attorney shall for all purposes be determined by the law of the State of North Carolina. SIGNATURE AND ACKNOWLEDGMENT This the 23" day of September, 201.9. (SEAL) M garet Little Appen er STATE OF NORTH CAROLINA COUNTY OF UNION On this 23 `d day of September, 2019 personally appeared before me, the said named Margaret Little Appenzeller, to me known and known to me to be the person described in and who executed the foregoing instrument and he acknowledged that he executed the same and being duly sworn by me, made oath that the Statements in the foregoing instrument are true. r Notary .Public My Commission Expires: 01/22/2021 TwORTANT INFORMATION FOR AGENT AGENTS DUTIES When you accept the authority granted under this power of attorney, a special Iegal relationship is created between you and the Principal. This relationship imposes upon you Iegal duties that continue until you resign or your authority is terminated or the power of attorney is terminated or revolted. You must: (1) Do what you know the Principal reasonably expects you to do with the Principal's property or, if you do not know the Principal's expectations, act in the Principal's best interest; (2) Act in good faith; (3) Do .nothing beyond the authority granted in this power of attorney; and (4) Disclose your identity as an Agent whenever you act for the Principal by writing or printing the name of the Principal and signing your own name as "Agent" in the following manner: (Principal's Name) by (Your Signature) as Agent. Unless the Additional Provisions and Exclusions in this Power of Attorney state otherwise, you must also: (1) Act loyally for the Principal' benefit; (2) Avoid conflicts that would impair your ability to act in the Principal's best interest; (3) Act with care, competence, and diligence; (4) Keep a record of all receipts, disbursements, and transactions made on behalf of the Principal; (5) Cooperate with any person that has authority to make health care decisions for the Principal to do what you know the Principal reasonably expects, or if you do not know the Principal's expectations, to act in the Principal's best interest. (6) Attempt to preserve the Principal's estate plan if you know the plan and preserving the plan is consistent with the Principal's best interest; and (7) Account to the Principal (or a person designated by the Principal (if any)) in the Additional Provisions and Exclusions. TERMINATION OF AGENT'S AUTHORITY You must stop acting on behalf of the Principal if you Iearn of any event that terminated or revoked this Power of Attorney or your authority under this Power of Attorney. Events that terminate a Power of Attorney or your authority to act under a Power of Attorney include: (1) Death of a Principal; (2) The Principal's revocation of the Power of Attorney or the termination of your authority; (3) The occurrence of a termination event state in the Power of Attorney; (4) 'The purpose of the Power of Attorney is fully accomplished; or (5) If you are married to the Principal, your divorce from the Principal, unless the Additional Provisions and Exclusions in this Power of Attorney state that your divorce from the Principal will not terminate your authority. LIABILITY OF AGENT The meaning of the authority granted to you is defined in the North Carolina Uniform Power of Attorney act. If you violate the North Carolina Uniform Power of Attorney Act or act outside the authority granted, you may be liable for any damages cause by your violation. If there is, anything about this document or your duties that you do not understand, you should seek legal advice. 49N _ a � 'A , ANC HWY 7 _ • r ®#3 ` t #4 M NC-UN-35-4 • t • y NC-UN-35-3 � y :.� NC-UN-35-2 #2� 000 1 �_ 1, v —' ��Na. • .HQS;TYrRD ' �" REVIEW BOUNDARY shall be established around each land application site midway between the Compliance Boundary and the perimeter of the residuals land application area. COMPLIANCE BOUNDARY: The Compliance Boundary for each land application site is established at either 250 feet from the residuals land application area or 50 feet within the property boundary, whichever is closest to the residual land application area. REFERENCE: GIS DATA LAYERS WERE OBTAINED FROM ESRI, INC. PLEASE NOTE THIS MAP IS FOR INFORMATIONAL PURPOSES ONLY. IT IS NOT MEANT FOR DESIGN, LEGAL, ORANY OTHER USES. THEREARE NO GUARANTEESABOUT ITSACCURACY. WMSSASSUMES NO RESPONSIBILITY FORANY DECISION MADE OR ANYACTIONSTAKEN BYTHE USER BASED UPON THIS INFORMATION. NC-UN-35-1 \ _ �s CD c?I WC) Q 1 w co o� U d _ '..� ','• 'L o M o �U) O z t •� ,- O d p z W U • •__ t * , ` • b F r Z W W LLJ U W z J Q a w i ` f U) y� �A�, � ,.,it z 4 • i ,�x W O O U) ' -j0 Access Road - • Well Q � � z A Structure o ■ Dwelling 0 U- LID ® Hand Auger Boring J 1 § o' Q Z of Oz Drain W U LL � Pond �j Z m ® Buffer W O Q H O - J Streams z • y Field Boundary o - Property Boundary 0 o FIELD TOTAL ACRES BUFFERED ACRES NET ACRES o N NC-UN-35-1 29.2 3.1 26.1 NC-UN-35-2 28.5 5.2 23.3 FIGURE NO. `m b NC-UN-35-3 33.5 15.2 18.3 /� NC-UN-35-4 35.1 10.5 24.6 'T '0 y..+— lbftw.-� ' . Vh2K � � r