WQ0006101_Emergency approval_20020904

WA rFRQ Michael F. Easley, Governor
�O G William G. Ross Jr., Secretary
Cq y North Carolina Department of Environment and Natural Resources
D Alan W. Klimek, P.E., Director
Division of Water Quality
September 4, 2002
MR. MICHAEL USKIEWICZ, CITY MANAGER
CITY OF DUNN
POST OFFICE BOX 1065
DUNN, NORTH CAROLINA 28335
Subject- Permit No. WQ0006101 Emergency Approval
City of Dunn
City of Dunn Residuals Land Application Program
Land Application of Residual Solids (503)
Harnett County
Dear Mr. Uskiewicz:
On August 29, 2002, the Division of Water Quality (Division) received a letter request from Mr.
Robert T. Branch, L.S.S. of Branch Residuals & Soils, L.L.C. on the City of Dunn's behalf regarding the
above -referenced permit. Specifically, in this request, Mr. Branch described the Permittee's current
situation with respect to its residuals land application program and requested the Division's consideration
to approve acreage not presently permitted to receive residuals by Permit No. WQ0006101, issued on
December 7, 2001, for immediate use on an emergency basis only.
This request for emergency approval has come about as the result of several occurrences related
to the Permittee's residuals land application program. This program currently has 827.58 acres (i.e.,
779.38 acres in Harnett County and 48.20 acres in Cumberland County) owned by three different
landowners approved for residuals land application under the existing permit. The size and flexibility of
the program appears in theory to be adequate for the Permittee. However, two of the three landowners
have recently expressed a desire to be significantly compensated by the Permittee for continued use of the
acreage that they own. The Permittee cannot honor the landowners' request at this time. The land
application site owned by the third landowner is currently planted in corn and soybeans and is located in a
floodplain area; therefore, by the time that the cover crop can be harvested, site ' conditions may be
unsuitable for a residuals land application event.
Because a major residuals land application event was being planned when the above -described
events occurred, the Permittee now has a holding tank full of residuals at the wastewater treatment plant
that are in need of land application. The digester at the wastewater treatment plant is approximately at 90
percent capacity, and it has been reported to the Division that the inability to remove solids from the
wastewater treatment plant within the next two weeks would necessitate using one of the two aeration
basins for residuals storage, which would in turn cause the plant to violate wastewater effluent limits
imposed by the NPDES permit. In addition, construction at the water treatment plant has resulted in the
generation of additional sediment in the storage basin. If the water treatment plant cannot backwash the
filters because of residuals management problems, the Permittee may not only violate rules enforced by
the Division of Environmental Health but also jeopardize quality of the potable water and public health.
The request proposed one land application site in Cumberland County onto which the Permittee's
residuals may be land applied until a permit modification application package is prepared by the
Permittee as well as submitted to and reviewed by the Division. This information is summarized in the
following table and on the attached maps:
Non -Discharge Permitting Unit Internet http://h2o.enr.state.nc.us/ndpu
1617 Mail Service Center, Raleigh, NC 27699-1617 Telephone [phone] Fax [phone]
DENR Customer Service Center Telephone [phone]
An Equal Opportunity Action Employer 50% recycled/10% post -consumer paper

Site No.
Owner / Operator
Estimated
Comments
Applicable
Acreage
CU-02-01
Franklin R_ Clark / Joel Garrett
44.70
Predominant soil series Candor and
Blaney. Two to nine percent slopes.
Used for coastal bermuda ha cro .
Total
44.70
Mr. Grady Dobson of the Water Quality Section of the Division's Fayetteville Regional Office,
along with Mr. Vincent Lewis of the Division of Soil and Water and Mr. Art Barnhardt of the
Groundwater Section of the Division's Fayetteville Regional Office, investigated the proposed land
application site on August 27, 2002 and determined that it was (1) adequately depicted in the attached
maps and (2) suitable for residuals land application activities year-round.
Under these very special circumstances, the Division will allow the commencement of emergency
residuals Iand application activities on the above -listed land application site. The activities shall be
limited to the application of up to 90 dry tons of residuals that need immediate removal from the digester
and holding tank at the City of Dunn's Wastewater Treatment Plant (i.e., NPDES Permit No.
NC0043176) as well as the application of up to 65 dry tons of residuals that need immediate removal
from the storage basin at the City of Dunn's Water Treatment Plant (i.e., PWS ID No, 03-43-010). All
activities shall occur within 180 calendar days of the date of this correspondence.
Note that all other conditions and limitations of Permit No. WQ0006101, issued on December 7,
2001, shall be valid and binding to these emergency residuals land application activities. Even though not
a condition of the existing permit, the Division requests that the Permittee notify the Water Quality
Section of the Division's Fayetteville Regional Office as well as the appropriate local official and the
county manager's office in Cumberland County prior to the initiation of the activities. Be aware that this
approval is a one-time occurrence in that Site No. CU-02-01 shall not receive additional residuals once
this approval expires unless a formal permit modification is sought from and approved by the Division.
The Permittee is encouraged to seek the Division's approval of additional acreage for the subject residuals
land application program as soon as possible. c
If you need any additional information concerning this matter, please contact Ms. Shannon Mohr
Thornburg by telephone at [phone], extension 353, or via e-mail at
[e-mail].
Sincere ,
for Alan W. Klimek, P.E.
cc: Cumberland County Health Department
Harnett County Health Department
Mr. Robert T. Branch, L.S.S., Branch Residuals & Soils, L.L.C.
Mr. Grady Dobson, Fayetteville Regional Office -Water Quality Section
Mr. Art Barnhardt, Fayetteville Regional Office -Groundwater Section
Ms. Debra J. Watts, Central Office -Groundwater Section
Mr. Daryl Merritt, Non -Discharge Compliance/Enforcement Unit
Permit File WQ0006101
2

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RESIDUALs
DATE: Aug-42 & SOILS, LLC ProiKlxa 2002-16

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Joel Garrd/ Rudy Clark CU2 Asap
Project No- 2002-016 1

City of Dunn emergency application site evaluation
Subject: City of Dunn emergency application site evaluation
Date: Wed, 28 Aug 2002 16:21:04 -0400
From: Grady Dobson <[e-mail]>
Organization: NC DENR Division of Water Quality
To: Shannon Thornburg <[e-mail]>
Shannon: on iFuesday August 27,2002 I along with Art Barnhrdt,FRO GW
section, Mr Vincent Lewis , Soil Scientist, Division of Soil &Water,
Wilmington Regional office met with Mr. Bob Branch, Branch' Residuals &
Soil.LLC & Mr. William 'roman, Agri- South Biosolid Services to review a
proposed emergency land -application site located in Northern
Cumberland County for the City of Dunn's residuals program ( Permit #
WQ0006101). The site was 44.7 acres in size. The soils on the site were
the Candor & Blaney series. Both are excellent soils for land
application of residuals. Mr. Lewi's performed several borings around the
site & concurred with the soil type in the emergency.package.'The site
twill have no buffer, slope, or local residential concerns. The site is
very isolated & all acreage surrounding the proposed field is owned bye
the same property owner. The site has a well established coastal bermuda
cover crop which would defly benifit from the residuals
application.
The City of.Dunn is exper.3,rfig a situation which we have recently
experienced with, Porter Environmental & the City of Hamlet. Several of
the farmers in Dunn's residuals program are requiring that the City
significantly compensate them for the use of their land for residuals
application. ( $50/acre). This is cost prohibitive for Dunn durning
these tight economic•times or normal economic times.
I also went to the WWT plant to observe first hand the situation. The
.5 MG residuals storage tank is full, the digester( .3MG) is at 90%
compacity & the ORC, Bobby Burnett indicated that if they could not
remove solids within 2 weeks, he would have to take,one of the areation
basins off line to use as residuals storage, which would likely create
an ammonia violation in the NPDES Permit. Thus, this is really an
emergency sitruation- not a Hoax!!
'The City still has one farmer that greed has to date not yet affected!
This site is flood plain which has seasonal restrictions. Currently,
the cover crop is corn & soybeans. Dunn cannot utilize this acreage
until these cover crops are harvested. Once harvested this land which
is permitted could be utilized, however if wet weather sets in, then
with•the'other situation discussed the City has no where to go other
than this proposed emergency site.
My question to you is can this emergency site be utilized for more than
one application event should the amendment package to include the
emergency site &other acreage be held up for some reason? What does
one- time application mean in:a situation like thisV If one -time means.
until the new amendment package is submitted & is complete for the
issuance of -a new permit, then I feel the current emergency can be
deflated & the NPDES Permit can remain compliant'.
Bob indicates the he will or has by now forwarded you the appropriate
Maps of this property with all land owner agreements & other pertinent
information.
If you receive all the required information, this office has no problem
with this site,to utilize for emergency residuals application
Let me know if you need any additional information, Grady
1 of 2 - 8/29/2002 11:28 AM

BRANCH. RESIDUALS & SOIL, LLC
2007 Yanceyville Street • Suite 108 • Box 45 • Greensboro, NC 27405
PHONE [phone] • FAX [phone]
August 23, 2002
N.C. Department of Environment and Natural Resources
Water Quality Section
Non -Discharge Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
ATTENTION: Ms. Shannon Thornburg
REFERENCE: CITY OF DUNN WQ0006101
City of Dunn
Dunn, North Carolina
BR&S Job No. 2002-16
Dear Ms. Thornburg:
Due to circumstances beyond its control, the City of Dunn finds itself:in need. of immediate relief of
approximately 700,000 gallons of biosolids from the wastewater plant and 600,000 gallons of water
treatment plant residuals. The haul event will require approximately one month to complete,
depending on weather conditions. A potential application site has been identified that is not
permitted in this or any land application program. Information associated with this site
(owner/operator agreement form, site vicinity map, soil survey map, ;buffer map, topographic map,
and preliminary soil and agronomist information) has been attached. The proposed site will be
reviewed on August 27, 2002 by Mr. Vince Lewis and Mr. Grady Dobson with the NCDENR-
DWQ Fayetteville Regional office.
The City of Dunn has had several farmers express desire to be significantly compensated for the use
of their land in this program: The desires of the farmers were not made known until recently when
the proposed application event was being planned. The late determination of this condition has
placed the City of Dunn in the position of having no suitable applicable land for this event. Since
learning of this condition, the City of Dunn and its agents has endeavored to fmd and procure land
through the normal modification process. However, the needs of the wastewater and water

NCDENR — DWQ
City of Dunn WQ0006101 BR&S Project No 2002-16
August 23, 2002
treatment plant are immediate. These needs have been made critical due to recent construction
activities at the facility. As soon as sufficient land has been identified, a permit modification (
including this land) will be sent to DWQ for approval. The City of Dunn respectfully requests that
this emergency approval of land be granted immediately.
Your assistance in this matter is greatly appreciated. Please call me if you have any questions.
Sincerely,
.0.--
Robert T. Branch, L.S.S.
Project Manger/Soil Scientist
Attachments — Emergency Permit Site Information
cc: Mr. Joe Campbell — City of Dunn
Mr. William Toman - Agri -South Biosolid'Services, Inc.
Mr. Grady Dobson —NCDENR-DWQ Fayetteville Regional Office
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City of Dunn
Land Application Program
Joel Garret/ Rudy Clark CU 2
Project No.
2002-16
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BRANCH
RESIDUALS
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City of Dunn
Land Application Program
Joel Garret/ Rudy Clark CU 2
Project No.
2002-16
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RESIDUALS
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Project No.
City of Dunn
Land Application Program
Joel Garret/ Rudy Clark CU 2
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BRANCH
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ProjectNo:
City 'of Dunn
Land Application Program
Joel Garret/ Rudy Clark CU 2 •
2002-16
Aerial
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City of Dunn
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BRANCH Joel Garret/ Rudy Clark CU2 Map
RESIDUALS
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CITY OF DUNN
CUMBERLAND COUNTY
GARRET / CLARK FARM
TRACT CU-2
Field
Net
Acreage
Soil
Symbol
Soil Descrpition
Crop
1
' CaB
BaB
Candor sand, 1 to 8 percent slopes
Blaney loamy -sand, 2 to 8 percent slopes
Coastal Bermuda
Total 44.7

Project Name
-SOIL EVALUATION FORM
BRANCH RESIDUALS & SOILS,'LLC
2007 Yanceyville Street - Suite 108 - Box 45 - Greensboro; NC 27405
PHONE [phone] — FAX [phone]
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Operator Z;e..I. G,a,�4
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Sample No.
Project Number
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Additional Comments
Depth to Apparent Water Table (in.) 3`f . " Depth to Seasonal Water Table (in.) 36
Depth to Restrictive Horizon (in.) Wit Type of Restrictive Horizon +: x1ode
Most Closely Related Soil Series
Discussion of Site
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