WQ0006147_More Information (Requested)_20240607

June 7, 2024
LANKFORD RUFFIN – DIRECTOR OF ENVIRONMENTAL AFFAIRS AND SUSTAINABILITY
BUTTERBALL, LLC
1628 GARNER CHAPEL ROAD
MOUNT OLIVE, NORTH CAROLINA 28635
Subject: Application No. WQ0006147
Additional Information Request #1
Butterball Class B Residuals
Program
Land Application of
Class B Residuals
Duplin County
Dear Mr. Ruffin:
Division of Water Resources’ Central and Regional staff have reviewed the application package
received on March 13, 2024. However, the Division requires additional information before completing our
review. Please address the items on the attached pages no later than the close of business on July 8, 2024.
Please be aware that the Applicant is responsible for meeting all requirements set forth in North
Carolina rules and regulations. The Applicant is also responsible for any oversights that occur during the
review of the subject application package. The Division may return the application as incomplete pursuant
to 15A NCAC 02T .0107(e)(2) if any omissions are made when responding to the outstanding items in
Sections A through T or the Applicant fails to provide the additional information on or before the above-
requested date.
Please reference the subject application number when providing the requested information. The
Applicant shall sign, seal, and date (where applicable) all revised and/or additional documentation and
submit an electronic response to my attention via the Non-Discharge online portal.
If you have any questions regarding this request, please contact me at [phone] or
[e-mail]. Thank you for your cooperation.
Sincerely,
Erick Saunders, Engineer
Division of Water Resources
cc: Wilmington Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
Mr. Lankford Ruffin
June 7, 2024
Page 2 of 4

A. Overall:
1. The annual permit fee is currently open, and the invoice is attached to this letter. Please note that
the permit cannot be granted if the annual fee has not been paid in accordance with 15A NCAC
02T .0120(c).
2. Permit Condition I.2. and Footnote 3 of the Attachment B of Permit No. WQ0006147 issued
February 4, 2019 state that the Permittee shall reevaluate the usable acreage and setbacks for Field
8 due to development of the church on an adjacent property. The habitable residence/place of
assembly on parcel 351100836386 has been constructed. The setbacks to this structure shall be
provided, and any changes shall be shown in an updated site map and an updated acreage shall be
provided in an updated LASC 06-16 form.
B. Cover Letter:
1. No comments.
C. Application Fee:
1. See Comments F.1 and N.2.
D. Application (Form: RLAP 06-16):
1. Item III.4.a notes the maximum amount of residuals to be certified is 998.4 dry tons per year
(DT/yr), but the maximum dry tons per year in the previous permit dated February 4, 2019 is 34
DT/yr. Please clarify the discrepancy, and update this form as needed.
2. Item III.4.b notes 34 acres of land application sites, but only 25.5 acres were previously permitted.
Please clarify the discrepancy, and update this form as needed.
E. Operation & Maintenance (O&M) Plan:
1. In accordance with Item E in the RLAP 06-16 Instructions form, an O&M Plan meeting the
requirements of 15A NCAC 02T .1110 shall be provided.
F. Summary for Form: RSC 06-16:
1. The maximum dry tons per year given in this form for the Butterball – Mt. Olive facility (Permit
No. WQ0000884, not WQ0006147 as stated) is 34 DT/yr, but the maximum in the previous permit
dated February 4, 2019 was 25.5 DT/yr. Please note that to increase the dry tonnage is a major
modification of the permit, requiring a $348 modification fee. Please clarify the proposed maximum
dry tonnage and provide any necessary modification fees.

Mr. Lankford Ruffin
June 7, 2024
Page 3 of 4
G. Application (Form: RSC 06-16):
1. The RSC form for the Butterball – Mt. Olive facility was not filled out. The sections of the
application that do not require laboratory reports shall be completed for review, including the
facility information in Section I, the mineralization rate in Item II.5.c., pollutants of concern in Item
II.6, the pathogen reduction alternative in Item II.7, and the vector attraction reduction alternative
in Item II.8.
2. Regional Office staff noted that waste activated sludge from the facility’s sanitary plant is pumped
to the primary lagoon. As this is a domestic wastewater residual, Item II.1 of this form shall be
regulated under 40 CFR Part 503, and not Part 257 as indicated. This shall be included in the
updated RSC form.
H. Vicinity Maps:
1. In accordance with Item B in the RSC 06-16 Instructions form, a vicinity map of the residuals
source generating facility (Permit No. WQ0000884) shall be provided.
I. Process Flow Diagram & Narrative:
1. In accordance with Item B in the RSC 06-16 Instructions form, a process flow diagram and/or
process flow diagram that describes how the residuals are generated, treated, processed, and stored
at the residuals source facility (Permit No. WQ0000884) shall be provided.
J. Quantitative Justification:
1. In accordance with Item B in the RSC 06-16 Instructions form, a quantitative justification for the
permitted residuals production rate shall be provided.
K. Sampling Plan:
1. In accordance with Item B in the RSC 06-16 Instructions form, a sampling plan for the residuals
source generating facility shall be provided.
L. Laboratory Analytical Reports:
1. No comments.
M. Pathogen Reduction (PR) & Vector Attraction Reduction (VAR) Compliance Documentation:
1. No comments.
N. Application (Form: LASC 06-16):
1. See Comment A.2. Any changes to the field based on this reevaluation shall be included in an
updated LASC.
Mr. Lankford Ruffin
June 7, 2024
Page 4 of 4
2. The LASC includes a field 12-SL, which was not included in the previous permit dated February
4, 2019. Please note that to increase the addition of this field to the program is a major modification
of the permit, requiring a $348 modification fee. Please clarify whether this field is being added to
this program and provide any modification fee and supporting documentation as necessary.
O. County Board Notification:
1. See Comment N.2. If field 12-SL is proposed to be added in this application, a CBN 06-16 form
and all supporting documentation shall be provided.
P. Application (Form: LOA 06-16):
1. No comments.
Q. Setback Waivers:
1. No comments.
R. Vicinity/Setback Maps:
1. The site map provided does not meet the requirements of the Map Guidance for Residuals Land
Application Fields guidance document or the 15A NCAC 02T .1104(c)(1) rules. This map does not
appear to show several property lines within 500 feet of the application sites and does not depict
setbacks in accordance with 15A NCAC 02T .1108 that may impact setbacks to the fields (such as
in the case of Comment A.2). An updated site map meeting the 02T .1104(c) and the guidance
document shall be submitted for review, and any changes in acreages shall be provided in an
updated LASC form.
2. See Comment N.2. An updated site map shall be provided to remove field 12-SL if it is not being
proposed in this application.
S. Soil & Agronomic Evaluation:
1. See Comment N.2. If field 12-SL is proposed to be added in this application, a soil and agronomic
evaluation in accordance with the Soil Scientist Evaluation Policy and 15A NCAC 02T .1104(c)(2)
shall be submitted for review.
T. Updated Cumulative Pollutant Loading Rates (CPLRs):
1. In accordance with Item B in the LASC 06-16 Instructions form, an updated accounting of the land
application site’s cumulative pollutant loading rates (CPLRs) shall be provided for all renewed
fields.