WQ0024544_Final Permit_20080118

\N A T Michael F. Easley, Governor
`0= 4G William G. Ross Jr., Secretary
Uj North Carolina Department of Environment and Natural Resources
> -! Coleen H. Sullins, Director
Division of Water Quality
January 18, 2008
MR. LEE A. WULF'EKUHLE, PRESIDENT
WULFEKUHLE INJECTION & PUMPING, INC.
27657 HIGHWAY 52 NORTH
NEW VIENNA, IOWA 52065
Subject: Permit No. WQ0024554
Wulfekuhle Injection & Pumping, Inc.
City of Jacksonville Residuals
Land Application Program
Land Application of Residual Solids (503)
Onslow County
Dear Mr. Wulfekuhle:
In accordance with your modification request received July 11, 2007, and subsequent additional
information received October 5, 2007, we are forwarding herewith Permit No. WQ000024554, dated
January 18, 2008, to Wulfekuhle Injection & Pumping, Inc for the continued operation of the subject land
application of residuals solids program. The requested modifications to the permit include the addition of
residuals previously stored in the City of Jacksonville Brynn Marr Lagoons and the addition of 566.7 net
acres of land to the land application permit.
This permit shall be effective from the date of issuance until November 30, 2009, shall void
Permit No. WQ000024554 issued December 10, 2004, and shall be subject to the conditions and
Iimitations as specified therein. Please pay particular attention to the monitoring requirements in this
permit. Failure to establish an adequate system for collecting and maintaining the required operational
information will result in future compliance problems.
If any parts, requirements, or limitations contained in this permit are unacceptable, you have the
right to request an adjudicatory hearing upon written request within thirty (30) days following receipt of
this permit. This request must be in the form of a written petition, conforming to Chapter 150B of the
North Carolina General Statutes, and filed with the Office of Administrative Hearings, 6714 Mail Service
Center, Raleigh, NC 27699-6714. Unless such demands are made this permit shall be final and binding.
During a site visit on October 3, 2007 it was noted that the soil pH in several fields was low. Soil
pH must be maintained in accordance to permit condition III.9.h. In addition, it was noted that several
fields had received chicken litter (Fields 2-51, 2-39, 2-40, 2-41 and 2-47), Application of chicken litter
should be accounted for before application of the residuals generated as part of this permit. Application
of chicken litter to these fields should be avoided in the future as long as these fields are permitted for
land application of residuals.
None hCaroI'
Aquifer Protection Section 1636 Mail Service Center Raleigh, NC 27699-1636 Telephone: [phone]
Internet: www.ncwaterquality.ore Location: 2728 Capital Boulevard Raleigh, NC 27604 Fax 1: [phone]
Fax 2: [phone]
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/ l 0% Post Consumer Paper Customer Service: [phone]

During a separate permitting process for the City of Jacksonville it was discovered that a
landowner permitted within your program was seeking to be removed from the program and added to
another program. In the event that a landowner provides written request to be removed from a program,
the landowner agreement becomes void and you may no longer apply residuals to those fields. When this
occurs the Permittee must request a permit modification to remove the fields from the permit.
Note that this permit does not approve steps necessary for complete closure of the Brynn Marr
Lagoons, and redevelopment of the lagoons. Approval for lagoon closure must be obtain from the
Wilmington Regional office prior to closure.
Please note that on September 1, 2006 State Administrative Code 15A NCAC Subchapter 02T —
Waste not Discharged to Surface Water was adopted. This permit incorporates the requirement of these
rules. Remember to take the time to review this permit thoroughly, as some of the conditions
contained therein may have been added, changed, or deleted from those in previously issued permits
If you need additional information concerning this matter, please contact Jon Risgaard at (919)
715-6167 [e-mail].
Sincerely,
for Coleen H. Sullins
cc: Mr. Robert T. Branch, L.S.S., Branch Residuals & SoIids, L.L.C.
Mr. Raymond L. Holder, City of Jacksonville
Onslow County Health Department
Wilmington Regional Office - Aquifer Protection Section
Technical Assistance and Certification Unit
APS Central Files
LAU Files

NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
RALEIGH
LAND APPLICATION OF RESIDUAL SOLIDS PERMIT
In accordance with the provisions of Article 21 of Chapter 143, General Statutes of North Carolina as
amended, and other applicable Laws, Rules, and Regulations
PERMISSION IS HEREBY GRANTED TO
Wulfekuhle Injection & Pumping, Inc.
Onslow County
FOR THE
continued operation of a residuals land application program for Wulfekuhle Injection& Pumping, Inc and
consisting of the land application of residuals generated by the residuals source -generating facilities listed
in the most recently -certified Attachment A to the land application sites listed in the most recently -certified
Attachment B with no discharge of wastes to surface waters, pursuant to the permit modification
application package received on July 11, 2007, and subsequent additional information received October 5,
2007, and in conformity with the project plan, specifications, and other supporting data subsequently filed
and approved by the Department of Environment and Natural Resources and considered a part of this
permit.
This permit shall be effective from the date of issuance until November 30, 2009, shall void Permit
No. WQ000024554 issued December 10, 2004, and shall be subject to the following specified conditions
and limitations:
I. SCHEDULES Fplease review the entire permit for reporting, monitoring,and other on -going activities
The Wilmington Regional Office, telephone number [phone], shall be notified at least forty-
eight (48) hours in advance (excluding weekends and holidays) of commencement of residuals
removal from the Brynn Marr Lagoons to allow for an inspection. Such notification to the regional
supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday
through Friday, excluding State Holidays,
WQ0024554 Version 1.1 Shell VCTSion 070716 Page 1 of 19

2. No later than six months prior to the expiration of this permit, the Permittee shall request renewal of
this permit on official Division forms. Upon receipt of the request, the Division will review the
adequacy of the facilities described therein, and if warranted, will extend the permit for such period
of time and under such conditions and limitations as it may deem appropriate. Please note that Rule
15A NCAC 02T .0105(d) requires an updated site map to be submitted with the permit renewal
application.
II. PERFORMANCE STANDARDS
The issuance of this permit shall not relieve the Permittee of the responsibility for damages to
surface waters or groundwater resulting from the operation of this residuals land application program
2. No residuals other than those generated by the residuals source -generating facilities listed in the
most recently -certified Attachment A of this permit shall be approved for land application in
accordance with this permit.
Only the land application sites listed in the most recently certified Attachment B of this permit are
approved for residuals land application. A permit modification application is required for any new
land application sites to be added to Attachment B.
4. The pollutant concentrations in any residuals that are land applied to any land application site shall
not exceed the following Ceiling Concentrations (i.e., dry weight basis):
Parameter
Ceiling Concentration
(milligrams per kilogram)
Arsenic
75
Cadmium.
85
Copper
4,300
Lead
840
Mercury
57
Molybdenum
75
Nickel
420
Selenium
100
Zinc
7,500
5, The pollutant loading rates on any land application site shall not exceed the following Cumulative
Pollutant Loading Rates (CPLRs):
Parameter
CPLR
(pounds per acre)
Arsenic
36
Cadmium
34
Copper
1,338
Lead
267
Mercury
15
Molybdenum
n/a
Nickel
374
Selenium
89
Zinc
2,498
WQ0024554 Version 1.1 Shell Version 070716 Page 2 of 19

The Permittee shall determine compliance with the cumulative pollutant loading rates using one of
the following methods:
1. Use site specific analytical data from all historical land application events not otherwise
exempted.
2. For land on which land application events of residuals has not occurred or for which the data is
incomplete, use background concentrations through representative sampling.
6. When residuals are land applied under the conditions of this permit, the Class B pathogen reduction
requirements in 15A NCAC 02T .1106 (a) and (c), and one vector attraction reduction requirements
in 15A NCAC 02T .1107 (a) shall be met. Additionally, an evaluation shall be performed that
demonstrates the residuals' ability to comply with this requirement. Upon request, a copy of this
evaluation, including all test results and calculations, shall be submitted. Only residuals that are
generated by the residuals source -generating facilities that are identified as being exempt from this
condition in the most recently -certified Attachment A shall not be required to comply with the
specified pathogen reduction and vector attraction reduction requirements.
7. The facilities permitted herein must be constructed and maintained according to the following
setbacks.
a. For residuals treatment and storage facilities, the following minimum setbacks shall be maintained
(all distances in feet):
Description of Setback
Setback
i. Habitable residence or place of public assembly under separate ownership or not
to be maintained as part of the project site
100
ii. Property lines
50
iii. Private or public water supply
100
iv. Surface waters (streams — intermittent and perennial, perennial waterbodies,
and wetlands
50
v. Wells with exception to monitoring wells
100
WQ0024554 Version 1.1 Shell Version 070716 Page 3 of 19

b. When land applying residuals to any land application site, the following setbacks shall be
maintained (all distances in feet):
Setback by type of application
Surface
Surface
Application
Application
by
Injection /
Description of Setback
by Vehicle
Irrigation
Incorporation
i. Habitable residence or place of public assembly
under separate ownership or not to be maintained
as part of the project site
400
400
200
ii. Habitable residence or places of public assembly
owned by the permittee, the owner of the land, or
the lessee/operator of the land to be maintained
as part of the project site
0
200
0
iii. Pro erty lines
50
150
50
iv. Public right of way
50
50
50
v. Private or public water supply
100
100
100
vi. Surface Waters (streams — intermittent and
perennial, perennial waterbodies, and wetlands)
100
100
50
vii. Surface water diversions (ephemeral streams,
waterways, ditches)
25
100
25
viii. Groundwater lowering ditches (where the bottom
of the ditch intersects the SHWT)
25
100
25
ix. Subsurface groundwater lowering system
0
100
0
x. Wells with exception to monitoring wells
100
100
100
xi. Bedrock outcrops
25
25
25
xii. Top of slope of embankments or cuts of two feet
or more in vertical height
15
15
15
xiii. Building foundations or basements
0
15
0
xiv. Waterlines
0
10
0
xv. Swimming pools
100
100
100
xvi. Nitrification fields
0
20
0
Specific residuals land application area boundaries shall be clearly marked on each land application
site prior to and during a residuals land application event.
9. Residuals and other sources of Plant Available Nitrogen (PAN) shall be land applied to all land
application sites at or below agronomic rates. Appropriate agronomic rates shall be calculated using
expected nitrogen requirements based on the Realistic Yield Expectations (RYE) for each approved
land application site. Realistic Yield Expectations for crop types and specific fields or soils types
shall be determined by using any of the following methods:
North Carolina Historical Data for specific crop and soil types as provided by North Carolina
State University Department of Soil Science. The Department webpage is located at:
hiip://www.soil.ncsu.edqLnmp/ncnmwg/vieldsl
b. Site Specific Historical Data for crop types on specific fields or soil types by calculating the
mean of the best three yields of the last five consecutive crop harvests for each field.
WQ0024554 Version 1.1 Shell Version. 070716 Page 4 of 19

C. If the RYE cannot be determined using methods 9(a) or (b) above, RYE can be established
from specially developed soil interpretation records for Nutrient Management Planning, Farm
Service Agency Records, university trials, or inference from crop performance on soil with
very similar physical and chemical features.
d. Realistic Yields Expectations and acceptable nitrogen application rates that use the above
methodology are required parts of many agricultural planning documents. The Permittee may
use the RYE and appropriate agronomic rates reported in any of the following documents:
i. Crop management plan as outlined by the local Cooperative Extension Office, the North
Carolina Department of Agriculture and Consumer Services, the Natural Resource
Conservation Service, or other agronomist,
ii. Waste Utilization Plan as outlined by Senate Bill 1217 Interagency Group- Guidance
Document: Chapter 1. Guidance for the completion of the plan can be found at:
hM:l/www.enr.state.nc.us/DSWC/pages/guidance does.html.
iii. Certified Nutrient Management Plan as outlined by Natural Resources Conservation
Services (NRCS). These plans must meet the USDA-NRCS 590 Nutrient Management
Standards, which are available at:
ftp:/Iftp-fc.sc.egov.usda. gov/NHO/�ractice-standards/standards/590.pdf.
For any crop type for which the RYE and appropriate nitrogen application rate cannot be
determined, the Permittee shall contact the Division to determine necessary action.
10. If the land application sites are to be overseeded (e.g., bermuda grass in the summer and rye grass in
the winter with BOTH crops to receive residuals), then the second crop shall receive an application
of PAN at a rate of no greater than 50 pounds per acre per year. This practice shall be allowed as
long as the second crop is to be harvested. If the second crop is to be planted for erosion control
only and is to be tilled into the soil, then no residuals shall be land applied to these sites because the
PAN will essentially be returned to the soil.
Prior to application of PAN to permitted sites at rates exceeding the agronomic rate, the Permittee
must submit and receive approval by the Division.
11. Should any of the residuals generated by the residuals source -generating facilities listed in the most
recently -certified Attachment A of this permit contain a high salt content (i.e., high sodium
adsorption ratio (SAR) of ten (10) or higher), the Permittee shall obtain and implement
recommendations from the local Cooperative Extension Office, the Department of Agriculture and
Consumer Services, the Natural Resource Conservation Service, a North Carolina -licensed Soil
Scientist, or other agronomist regarding sodium application rate, soil amendments (e.g., gypsum,
etc.) or other ameliorative mechanism for maintaining the integrity of the site in terms of suitability
for land application of residuals and maintaining conditions conducive to crop growth. The
Permittee shall maintain written records of each monitoring event that includes details of the sites
covered and rate of soil amendment application.
WQ0024554 Version 1.1 Shell Version 07071E Page 5 of 19

12. The COMPLIANCE BOUNDARY for residuals land application programs is specified by
regulations in 15A NCAC 2L (i.e., "Groundwater Classifications and Standards"). 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 residuals land
application area. Per 15A NCAC 2T .0105(h), upon the request by the Permittee the Compliance
Boundary may be located closer to the waste disposal area (provided the groundwater standards can
be met at the newly established Compliance Boundary). Any approved relocation of the
COMPLIANCE BOUNDARY will be noted in the most recently -certified Attachment B of this
permit. An exceedance of Groundwater Standards at or beyond the Compliance Boundary is subject
to remediation action according to 15A NCAC 2L .0106(d)(2) as well as enforcement actions in
accordance with North Carolina General Statute 143-215.6A through 143-215.6C.
13. The REVIEW BOUNDARY shall be established around each land application site midway between
the Compliance Boundary and the perimeter of the residuals land application area. Any exceedance
of Groundwater Quality Standards at the Review Boundary shall require action in accordance with
15A NCAC 2L .0106 (d)(1).
14. The appropriate local governmental official (i.e., county manager, city manager, etc.) shall be
notified at least 24 hours prior to the initial residuals land application event to any new land
application site. In addition, the appropriate county manager's office shall be notified prior to the
initial residuals land application event on any new site so that they will be aware that residuals land
application activities have commenced on the site.
15. The Aquifer Protection Section of the appropriate Division's regional office shall be notified at least
24 hours prior to the initial residuals land application event on any new land application site. Such
notification to the Regional Aquifer Protection Supervisor shall be made during normal office hours
(i.e., from 8:00 a.m. until 5:00 p.m.) between Monday and Friday, but excluding State Holidays. A
list of the Division's regional offices, their county coverage, and their contact information may be
downloaded from the web site at.http;//www.enr.state.nc.us/litml/regionaloffices.html.
III. OPERATION AND MAINTENANCE REQUIREMENTS
1. The residuals land application program shall be effectively maintained and operated at all times as a
non -discharge system to prevent the discharge of any wastes resulting from the operation of this
program. The Permittee shall maintain an Operation and Maintenance Plan pursuant to 15A NCAC
02T .1110 including operational functions, maintenance schedules, safety measures, and a spill
response plan.
In the event that the residuals land application program is not operated satisfactorily, including the
creation of nuisance conditions, the Permittee shall cease land applying residuals to the site, contact
the Aquifer Protection Section of the appropriate Division of Water Quality's (Division) regional
office, and take any immediate corrective actions as may be required by the Division.
Upon classification of the residuals land application program by the Water Pollution Control System
Operators Certification Commission (WPCSOCC), the Permittee shall designate a certified land
application/residuals operator to be in responsible charge (ORC) of the program. The operator shall
hold a certificate of the type classification assigned to the program by the WPCSOCC. The
Permittee shall also designate a certified back-up operator of the appropriate type to comply with the
conditions of 15A NCAC SG .0201.
WQ0024554 Version 1, I Sbell Version 070716 Page 6 of 19

4. This permit shall become voidable if the soils of the land application sites fail to assimilate the
residuals or the application causes contravention of surface water or groundwater standards and may
be rescinded unless the land application sites are maintained and operated in a manner that will
protect the assigned water quality standards of the surface waters and groundwater.
5. A copy of this permit shall be maintained in all manned equipment at the land application sites when
residuals are being land applied during the life of this permit. The spill prevention and control plan
shall be maintained in all residuals transport and application vehicles.
6. Adequate provisions shall be taken to prevent wind erosion and surface runoff from conveying
residuals from the land application sites onto adjacent properties or into any surface waters.
7. Adequate procedures shall be provided to prevent surface runoff from carrying any land applied or
stored residuals into any surface waters.
8. No residuals shall be stored at any land application site at any time, unless written approval has first
been requested and obtained from the Division.
9. Bulk residuals shall not be applied to the land under the following conditions:
a. If the residuals are likely to adversely affect a threatened or endangered species listed under
section 4 of the Endangered Species or its designated critical habitat;
b. If the application causes prolonged nuisance conditions;
c. If the land fails to assimilate the bulk residuals or the application causes the contravention of
surface water or groundwater standards;
d. If the land is flooded, frozen, or snow-covered or is otherwise in a condition such that runoff of
the residuals would occur;
e. Within the 100-year flood elevation unless the bulk residuals are injected or incorporated within
a 24-hour period following the residuals land application event;
f. During a measurable precipitation event (i.e., >.01" per hour) or within 24 hours following a
rainfall event of 0.5 inches or greater in a 24-hour period. Any emergency residuals land
application measures shall first be approved in writing by the Division;
g. If the slope for land is greater than 10 percent when bulk liquid residuals are surface applied, and
if the slope of the land is greater then 18 percent with bulk liquid residuals are injected or
incorporated;
h. If the pH is not maintained in the soil, residuals, and lime mixture, greater than 6.0, on land
application sites onto which residuals are applied. Residuals may be applied to the sites
provided that sufficient amounts of lime is also applied to achieve a final pH of the soil mixture
of at least 6.0, or if an agronomist provides information indicating that the pH of the soil,
residuals, and lime mixture is suited for the specified crop type. Any approved variations to the
acceptable soil pH (6.0) for land application will be noted in the most recently certified
Attachment B of this permit.
i. If the land does not have an established vegetative cover in accordance with the crop
management plan outlined by the local Cooperative Extension Office, the Department of
Agriculture and Consumer Services, the Natural Resource Conservation Service, or other
agronomist unless the bulk residuals are incorporated within a 24-hour period following the
residuals land application event or injected (This requirement does not apply to no -till
fields);
WQ0024554 Version 1.1 Shell Version 070716 Page 7 of 19

j. If the vertical separation of the seasonal high water table and the depth of residuals application is
less than one foot;
k. If the vertical separation of the depth to bedrock and the depth of residuals application is less
than one foot;
10. For land onto which bulk residual that do not meet the Class A Pathogen Reduction Requirements
(15A NCAC 02T .1106(b)), the following public access restrictions apply:
a. Public access to public contact sites shall be restricted for one calendar year after any residuals
land application event;
b. Public access to land that is not a public contact site shall be restricted for 30 days after any
residuals land application event;
It. For land onto which bulk residual that do not meet the Class A pathogen Reduction Requirements
(I5A NCAC 02T .1106(b)), the following harvesting and grazing restrictions apply:
a. Animals shall not be allowed to graze on land application sites for 30 days after any residuals
land application event. Sites that are to be used for grazing shall have fencing that will be used
to prevent access after each event;
b. Food crops, feed crops, and fiber crops shall not be harvested for 30 days after any residuals land
application event;
c. Food crops with harvested parts that touch the residual/soil mixture and are totally above the
land surface (e.g., tobacco, melons, cucumbers, squash, etc.) shall not be harvested for 14
months after any residuals land application event;
d. Food crops with harvested parts below the surface of the land (i.e., root crops such as potatoes,
carrots, radishes, etc.) shall not be harvested for 20 months after any residuals land application
event when the residuals remain on the land surface for four months or longer prior to
incorporation into the soil;
e. Food crops with harvested parts below the surface of the land shall not be harvested for 38
months after any residuals land application event when the residuals remain on the land surface
for less than four months prior to incorporation into the soil;
f. Turf grown on land where residuals are applied shall not be harvested for 12 months after any
residuals land application event.
12. This permit shall become voidable unless the agreements between the Permittee and the landowners
and lessees or operators of any land application sites listed in the most recently -certified Attachment
B of this permit not owned by the Permittee are in full force and effect. These agreements shall be
considered expired concurrent with the expiration date of the permit and shall be renewed at the
same time the permit is renewed.
13. Upon entering an agreement with landowners to apply residuals to a land application site, the
Permittee shall require of the landowner or lessee/operator a statement detailing the volume of
nutrient sources (waste residuals, manufactured fertilizers, manures, or other animal waste products)
other than the residuals to be applied by the Permittee, that have been applied to the land, and a copy
of the most recent Nutrient Management Plan, (NMP), if available, for the fields within the
agreement. For the purpose of this permit condition, a Crop Management Playa (CMP), Waste
Utilization Plan (WUP) or Certified. Nutrient Management Plan (CLAMP) shall also be
considered a Nutrient Management Plan.
WQ0024554 Version 1.1 Shell Version 070716 Page 8 of 19

The NMPs must be provided only for those operations where a NMP is required by the US
Department of Agriculture - National Resources Conservation Service (MRCS) or other State
Agencies. The Permittee shall rely on the provided information to calculate appropriate reductions
in allowable nutrient loading rates. If the calculation shows that the agronomic rates in the NMP
(including PAN) have already been met or exceeded on a field, no additional residuals shall be land
applied to that field.
IV. MONITORING AND REPORTING REQUIREMENTS
1. Any monitoring (i.e., including groundwater, surface water, residuals, soil, or plant tissue analyses)
deemed necessary by the Division to ensure protection of the environment shall be established, and
an acceptable sampling and reporting schedule shall be followed.
2. Residuals generated by each residuals source -generating facility listed in the most -recently -certified
Attachment A of this permit shall be analyzed to demonstrate that they are non -hazardous under the
Resource Conservation and Recovery Act (RCRA). A corrosivity, ignitability, and reactivity
analysis as well as a Toxicity Characteristics Leaching Procedure (TCLP) analysis shall be
conducted on residuals generated by each residuals source -generating facility listed in the most
recently -certified Attachment A of this permit. The analyses shall be performed at the frequency
specified in the most recently -certified Attachment A of this permit, and the results shall be
maintained on file by the Permittee for a minimum of five years.
If residuals generated by a particular residuals source -generating facility are insufficient to require a
land application events during a required sampling period as specified in the most recently -certified
Attachment A of this permit (e.g. no land application occur during an entire year when annual
monitoring is required), no sampling data is required during the period of inactivity. The Permittee
shall submit an annual report, as required in condition IV. 10., even in the event that no land
application events occur during an entire year; the annual report shall include an explanation for
missing sampling data.
Only residuals that are generated by the residuals source -generating facilities that are identified as
being exempt from this condition in the most recently -certified Attachment A of this permit shall not
be required to comply with this monitoring requirement.
The TCLP analysis shall include the following parameters (i.e., note the regulatory level in
milligrams per liter in parentheses):
Arsenic (5.0)
Barium (100.0)
Benzene (0.5)
Cadmium (1.0)
Carbon tetrachloride (0.5)
Chlordane (0.03)
Chlorobenzene (100.0)
Chloroform (6.0)
Chromium (5.0)
rra-Cresol (200.0)
o-Cresol (200.0)
p-Cresol (200.0)
Cresol (200.0)
2,4-D (10.0)
1,4-Dichlorobenzene (7.5) Nitrobenzene (2A)
1,2-Dichloroethane (0.5)
Pentachlorophenol (100.0)
1,1-Dichloroethylene (0.7)
Pyridine (5.0)
2,4-Dinitrotoluene (0. 13)
Selenium (1A)
Endrin (0.02)
Silver (5.0)
Hexachlorobenzene (0.13)
Tetrachloroethylene (0.7)
Heptachlor (and its hydroxide) (0.008)
Toxaphene (0.5)
Hexaehloro-1,3-butadiene (0.5)
Trichloroethylene (0.5)
Hexachloroethane (3.0)
2,4,5-Trichlorophenol (400,0)
Lead (5.0)
2,4,6-Trichlorophenol (2.0)
Lindane (0.4)
2,4,5-TP (Silvex) (1.0)
Mercury (0.2)
Vinyl chloride (0.2)
Methoxychlor (10.0)
Methyl ethyl ketone (200.0)
WQ0024554 Version 1.1 Shell Version 070716 Page 9 of 19

After the residuals have been monitored as specified above for two years at the frequency specified
in the most recently -certified Attachment A of this permit, the Permittee may submit a request to the
Division for a permit modification to request a reduction of this monitoring requirement. In no case,
however, shall the frequency of monitoring be less than once per permit cycle.
An analysis shall be conducted on residuals generated by each residual source -generating facility
listed in the most recently certified Attachment A of this permit. The analysis shall be performed at
the frequency specified in the most recently certified Attachment A of this permit, and the results
shall be maintained on file by the Permittee for a minimum of five years. The analysis shall include,
but shall not necessarily be limited to, the following parameters:
Aluminum
Ammonia -Nitrogen
Arsenic
Cadmium
Calcium
Copper
Lead
Sodium Adsorption Ratio
(SAR)
Magnesium pH
Mercury Plant Available Nitrogen
(by calculation)
Molybdenum
Nickel
Nitrate -Nitrite Nitrogen
Phosphorus
Potassium
Selenium
Sodium
% Total Solids
TKN
Zinc
If residuals generated by a particular residuals source -generating facility are insufficient to require a
land application events during a required sampling period as specified in the most recently -certified
Attachment A of this permit (e.g, no land application occur during an entire year when annual
monitoring is required), the Permittee shall make up the missed sampling either by taking additional
samples during land application events previous to a planned period of inactivity or by taking
additional samples during land application events immediately following the period of inactivity.
The Permittee shall submit an annual report, as required in condition IV. 10., even in the event that
no land application events occur during an entire year; the annual report shall include an explanation
of additional sampling data intended to compensate for periods of inactivity, or an explanation for
missing sampling data
After the residuals generated by a particular residuals source -generating facility have been monitored
for two years at the frequency specified in the most recently -certified Attachment A of this permit,
the Permittee may submit a request to the Division for a permit modification to reduce the frequency
of this monitoring requirement. The request must include notification from EPA that a reduced
sampling frequency has been approved as required by 40 CFR 503.16(a)(2). In no case, however,
shall the frequency of this monitoring be less than once per year when a residuals land application
event of residuals generated by the residuals source -generating facility occurs during that year.
WQ0024554 Version 1.1 Shell Version 070716 Page 10 of 19

4. Residuals generated by each residuals source -generating facility listed in the most recently -certified
Attachment A of this permit shall be monitored for compliance with Condition 11. 6. The monitoring
shall be performed at the frequency specified in the most recently -certified Attachment A of this
permit, and data to verify pathogen and vector attraction reduction of the residuals shall be
maintained on file by the Permittee for a minimum of five years. The required data shall be specific
to the stabilization process utilized, but also shall be sufficient to demonstrate clear compliance with
the Class A pathogen reduction requirements in 15A NCAC 02T .1106 (a) and (b) or the Class B
pathogen reduction requirements in 15A NCAC 02T .1106 (a) and (c), and one vector attraction
reduction requirements in 15A NCAC 02T .1107 (a) shall be met. In addition, the Environmental
Protection Agency (EPA) certification statements concerning compliance with pathogen reduction
requirements, vector attraction reduction requirements, and management practices shall be
completed at the frequency specified in the most recently -certified Attachment A of this permit by
the proper authority or authorities, if more than one is involved (i.e., either the person who prepares
the residuals, the person who derives the material, or the person who applies the residuals). Only
residuals that are generated by the residuals source -generating facilities that are identified as being
exempt from, Condition IT. 6. in the most recently -certified Attachment A of this permit shall not be
required to comply with this monitoring requirement.
5. A representative annual soils analysis (i.e., Standard Soil Fertility Analysis) shall be conducted on
each land application site on which a residuals land application event in the respective calendar year
has occurred or is to occur, and the results shall be maintained on file by the Permittee for a
minimum of five years. The Standard Soil Fertility Analysis shall include, but is not necessarily
limited to, the following parameters:
Acidity Exchangeable Sodium Percentage (by calculation)
Calcium Magnesium Phosphorus
Cation Exchange Capacity Manganese Potassium
Copper Percent Hurnic Matter Sodium
Base Saturation (by calculation) pH Zinc
6. Laboratory analyses of parameters as required by Condition IV. I., Condition IV. 2., Condition IV.
3., and Condition IV. 4. shall be performed/gathered on the residuals as they are to be land applied.
7. Laboratory analyses of parameters as required by Condition IV. I., Condition N. 2., Condition IV.
3., Condition IV. 4., and Condition IV. 5. shall be in accordance with 15A NCAC 02B .0505.
Proper records shall be maintained by the Permittee tracldng all residuals land application events.
These records shall include, but are not necessarily limited to, the following information:
a. Source of residuals;
b. Date of land application;
c, Location of land application (i.e., site, field, or zone number as listed in Attachment B);
d. Method of land application;
e. Weather conditions (e.g., sunny, cloudy, raining, etc.);
f. Predominant Soil Mapping Unit (e.g., CbB2);
g. SoiI conditions (e.g., dry, wet, frozen, etc.);
h. Type of crop or crops to be grown on field;
i. Nitrogen Application Rate based on RYES.
WQ0024554 Version 1.1 Shell Version 070716 Page 11 of 19

j. Volume of residuals land applied in gallons per acre, cubic yard per acre , dry tons per acre, wet
ton per acre , or kilograms per hectare;
k. Volume of animal waste or other nutrient source applied in gallons per acre, dry ton per acre, or
kilograms per hectare (if applicable);
1. Volume of soil amendments (e.g., lime, gypsum, etc.) applied in gallons per acre, dry ton per
acre, wet tons per acre, or kilograms per hectare (if applicable); and
m. Annual and cumulative totals of dry tons per acre of residuals as well as animal waste and other
sources of nutrients (e.g., if applicable), annual and cumulative pounds per acre of each heavy
metal (e.g., shall include, but shall not be limited to, arsenic, cadmium, copper, lead, mercury,
molybdenum, nickel, selenium, and zinc), annual pounds per acre of PAN, and annual pounds
per acre of phosphorus applied to each field.
9. All records required as part of this permit shall be retained a minimum of five years.
10. Three copies of an annual report shall be submitted on or before March I". The annual report shall
meet the requirements described in the Instructions For Residuals Application Annual Reporting
Forms. The most recent instructions for reporting and annual report forms are available on the Land
Application Unit website at http:/ih2o.enr.state.nc.us/lau/compliance.html, or can be obtained by
contacting the Land Application Unit directly. The annual repost shall be submitted to the following
address:
NCDENR-DWQ
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
11. Noncompliance Notification
The Permittee shall report by telephone to the Wilmington Regional Office, telephone number (910)
796-7215, as soon as possible, but in no case more than 24 hours or on the next working day
following the occurrence or first knowledge of the occurrence of any of the following:
a. Any occurrence with the land application program which results in the land application of
significant amounts of wastes which are abnormal in quantity or characteristic.
b. Any failure of the land application program resulting in a release of material to receiving waters.
c. Any time that self -monitoring information indicates that the facility has gone out of compliance
with the conditions and limitations of this permit or the parameters on which the system was
designed.
d. Any process unit failure, due to known or unknown reasons, that render the facility incapable of
adequate residual treatment.
e. Any spillage or discharge from a vehicle or piping system during transportation of residuals.
For any emergency that requires immediate reporting (e.g., discharges to surface waters, imminent
failure of a storage structure, etc.) outside normal business hours must be reported to the Division's
Emergency Response personnel at telephone number [phone], [phone], or (919) 733-
3300.
WQ0024554 Version 1.1 Shell Version 070716 Page 12 of 19

Persons reporting such occurrences by telephone shall also file a written report in letter form within
five (5) days following first knowledge of the occurrence. This report must outline the actions taken
or proposed to be taken to ensure that the problem does not recur.
V. INSPECTIONS
Adequate inspection and maintenance shall be provided by the Permittee to ensure proper operation
of the subject facilities.
2. Prior to each residuals land application event, the Permittee or his designee shall inspect the
residuals storage, transport, and application facilities to prevent malfunctions and deterioration,
operator errors, and discharges that may cause or lead to the release of wastes to the environment, a
threat to human health, or a nuisance, The Permittee shall maintain an inspection log or summary
including at least the date and time of inspection, observations made, and any maintenance, repairs,
or corrective actions taken by the Permittee. This log of inspections shall be maintained by the
Permittee for a period of five years from the date of the inspection and shall be made available to the
Division or other permitting authority, upon request.
Any duly authorized officer, employee, or representative of the Division may, upon presentation of
credentials, enter and inspect any property, premises, or place on or related to the land application
sites or facilities at any reasonable time for the purpose of determining compliance with this permit;
may inspect or copy any records that must be kept under the terms and conditions of this permit; and
may obtain samples of groundwater, surface water, or leachate.
�. GLI;LRAT, C ) DITIONS
This permit shall become voidable unless the residuals land application events are carried out in
accordance with the conditions of this permit, the supporting materials, and in the manner approved
by the Division.
2. This permit shall be effective only with respect to the nature and volume of residuals described in
the application and other supporting data.
Failure to abide by the conditions and limitations contained in this permit may subject the Permittee
to an enforcement action by the Division in accordance with North Carolina General Statutes § 143-
215.6A through §143-215.6C.
4. The annual administering and compliance fee shall be paid by the Permittee within 30 days after
being billed by the Division. Failure to pay the fee accordingly may cause the Division to initiate
action to revoke this permit, as specified by 15 NCAC 2T .0105 (e).
5. The issuance of this permit does not exempt the Permittee from complying with any and all statutes,
rules, regulations, or ordinances, which may be imposed by other government agencies (local, state,
and federal) that have jurisdiction. Of particular concern to the Division are applicable river buffer
rules in 15A NCAC 02B .0200, erosion and sedimentation control requirements in 15A NCAC
Chapter 4 and under the Division's General Permit NCGO10000, and any requirements pertaining to
wetlands under 15A NCAC 02B .0200 and 02H .0500.
WQ0024554 Version 1.1 Shell Version 070716 Page 13 of 19

6. This permit may be modified, revoked, and/or reissued to incorporate any conditions, limitations and
monitoring requirements the Division deems necessary in order to protect the environment and
public health adequately.
7. This permit shall not be automatically transferable. In the event that there is a desire for the
residuals land application program to change ownership or to change the name of the Permittee, a
formal permit request shall be submitted to the Division documentation from the parties involved
and other supporting materials as may be appropriate. The approval of this request shall be
considered on its merits and may or may not be approved.
Permit issued this the 18"i day of January 2007,
NORTH C A ENV NMENTAL MANAGEMENT COMMISSION
Coleen H. Sullins, Director
Division of Water Quality
By Authority of the Environmental Management Commission
Permit Number WQ0024554
WQ0024554 Version 1.1 Shell Version 070716 Page 14 of 19

Permit No. WQ0024554
January 18, 2008
ENGINEER'S CERTIFICATION
Partial Final
1, , as a duly registered Professional Engineer in the State of
North Carolina, having been authorized to observe (periodically, weekly, full tune) the construction of the
project,
Project Name
Location and County
for the Permittee hereby state that, to the best of nay abilities, due care and diligence was used in the observation
of the construction such that the construction was observed to be built within substantial compliance and intent
of this permit, the approved plans and specifications, and other supporting materials.
Signature
Date
Registration No.
WQ0024554 Version 1.1 Shell Version 070716 Page 15 of 19

ATTACHMENT A - Approved Residual Sources
Permit Number: WQ0024554 Version: 1.1
Wulfekuhle Injection & Pumping, Inc
Certification Date: January 18, 2008
Monitoring
Frequency for
Maximum
Monitoring
Condition IV. 3.
Approved
Issued
Is
Dry Tons
Frequency for
and Condition
Mineralization
Owner
Facility Name
County
Permit Number
By
503?
Per Year
Condition W. 2.
IV. 4.
Rate
City of
Jacksonville WWTF'h
Onslow
WQ0009267
DWQ
503
1,600.
Annually
4 X year
.30
Jacksonville
City of
City of Jacksonville
Onslow
WQ0024554
503
290.
See Permit
See Permit
.00
Jacksonville
Brynn Marr Lagoons
Total
1,890.
a Removal of the residuals from the two lagoons shalt be scheduled and performed so as not to interrupt the service provided by and the proper
operation of the existing wastewater treatment and spray irrigation facilities not result in an overflow, bypass, or discharge of wastewater or
residuals.
Removal of the residuals from the two lagoons shall be performed so as to minimize damage to or any loss of integrity to the existing curtain,
liner, and/or dike systems. Following completion of all residuals removal activities, a certification shall be received from a North Carolina -
licensed professional engineer certifying that the activities have been successfully completed and that subsequent inspection of the existing
curtain, liner, and dike systems does not indicate any evidence of damage or loss of integrity. Should it be determined by the North Carolina -
licensed professional engineer or the Division that any of the systems is compromised in any way, the Permittee shall submit a corrective action
plan for making any repairs or replacements as well as a schedule for implementing the plan to the Division for approval. Two copies of the
certification and/or corrective action plan (i.e., as appropriate) shall be mailed to the NCDENR-DWQ, Aquifer Protection Section, Land
Application Unit, 1636 Mail Service Center, Raleigh, NC 27699-1636 within 30 calendar days of completing all residuals removal activities.
WQ0024554 Version 1.1 Shell Version 070716 Page 16 of 19

ATTACHMENT B - APPROVED LAND APPLICATION SITES
Permit Number: WQ0024554 Version: 1.1
Wulfekuhle injection & Pumping, Inc
Certification Date: January 18, 2008
Field/
Site
Owner
Lessee
County
Latitude
Longitude
Net
Acreage
Dominant
Soil Series
01-01
Jones, Kenneth W
Onslow
34055'40"
77035'60"
20.10
Norfolk
01-02
Jones, Kenneth W
Onslow
34055'35"
7703545"
16.70
Norfolk
01-03
Jones, Kenneth W
Onslow
3405577"
77035'36"
55.40
Norfolk
01-04
Jones, Kenneth W
Onslow
34055'14"
77035135"
38.90
Norfolk
01-05
Jones, Kenneth W
Onslow
34055'05"
77035126"
22.60
Goldsboro
01-06
Jones, Kenneth W
Onslow
3405549"
77035109"
30.40
Norfolk
01-07
Jones, Kenneth W
Onslow
34"56'01"
77"35'18"
40.30
Norfolk
01-08
Jones, Kenneth W
Onslow
34056'11"
77035107"
33.30
Norfolk
02-01
Cox, Ronald
Onslow
34046'53"
77029'50"
20.90
Goldsboro
02-02
Cox, Ronald
Onslow
34046'28"
77"30'29"
20.60
AutryvilIe
02-03
Cox, Ronald
Onslow
3404645"
77030'23"
24.10
Goldsboro
02-04
Cox, Ronald
Onslow
34046'30"
77030'18"
27.50
Au Mlle
02-05
Cox, Ronald
Onslow
34053'06"
77"32'31"
17.50
Autryville
02-06
Cox, Ronald
Onslow
34053'13"
77032'25"
9.00
Norfolk
02-07
Cox, Ronald
Onslow
34053'21"
77032129"
11.50
Goldsboro
02-08
Cox, Ronald
Onslow
34053,16"
77"32'16"
10.20
Norfolk
02-09
Cox, Ronald
Onslow
34053'15"
77032'15"
13.50
Norfolk
02-10
Cox, Ronald
Onslow
34°53'16"
77032'09"
4.60
Norfolk
02-11
Cox, Ronald
Onslow
34053'24"
77032'08"
15.20
Norfolk
02-12
Cox, Ronald
Onslow
34"53'34"
77032'10"
26.10
Norfolk
02-13
Cox, Ronald
Onslow
34°5327"
77032'20"
16.30
Goldsboro
02-14
Cox, Ronald
Onslow
34"53'22"
7703221"
4.20
Goldsboro
WQ0024554 Version 1.1 Shell Version 070716 Page 17 of 19

Field/
Site
Owner
Lessee
County
Latitude
Longitude
Net
Acreage
Dominant
Soil Series
02-15
Cox, Ronald
Onslow
34053134"
77032'26"
18.80
Goldsboro
02-16
Cox, Ronald
Onslow
34°53153"
77"3222"
14.30
Goldsboro
02-17
Cox, Ronald
Onslow
34"5342"
77031153"
12.60
Norfolk
02-18
Cox, Ronald
Onslow
34053'39"
77031'24"
34.40
Norfolk
02-19
Cox, Ronald
Onslow
34053'54"
77031'08"
48.70
Norfolk
02-20
Cox, Ronald
Onslow
34054113"
77°30'52"
34.30
Norfolk
02-21
Cox, Ronald
Onslow
34°54'23"
77030'45"
23.50
Goldsboro
02-22
Cox, Ronald
Onslow
34"54'14"
77"30'34"
17.80
Norfolk
02-23
Cox, Ronald
Onslow
34"53'60"
77"30'32"
13.10
Norfolk
02-24
Cox, Ronald
Onslow
34"53152"
77030'22"
15.70
Norfolk
02-25
Cox, Ronald
Onslow
34"53'40"
77029'43"
22.60
Autryville
02-26
Cox, Ronald
Onslow
34054'28"
77031'28"
55.80
Norfolk
02-27
Cox, Ronald
Onslow
34"5445"
77031'34"
50.70
Norfolk
02-28
Cox, Ronald
Onslow
34054'S5"
77031'57"
21.70
Norfolk
02-29
Cox, Ronald
Onslow
34°55'02"
77°3128"
14.90
Norfolk
02-30
Cox, Ronald
Onslow
34055'02"
77030'50"
38.80
Norfolk
02-31
Cox, Ronald
Onslow
34055'25"
77031'20"
28.70
Norfolk
02-32
Cox, Ronald
Onslow
34055'36"
77"30'56"
6.20
Norfolk
02-33
Cox, Ronald
Onslow
34055'22"
77031102"
6.50
Norfolk
03-01
Howard, Stuart E
Onslow
34"51'29"
77"32'24"
16.70
Norfolk
2-04A
Cox, Ronald
Onslow
34"4645"
77"30'04"
22.00
Lynchburg fine sandy loam
2-17A
Cox, Ronald
Onslow
34053'28"
7791'46"
12.90
Norfolk loamy fine sand,
0 to 2% slopes
2-34
Cox, Ronald
Onslow
34054'16"
77°3l'18"
23.80
Norfolk loamy fine sand,
0 to 2% slopes
2-35
Cox, Ronald
Onslow
1 34°54'51"
77032'04"
18.90
Norfolk loamy fine sand,
0 to 2% slopes
W00024554 Version Li Shell Version 070716 Page 18 of 19

Field/
Site
Owner
Lessee
County
Latitude
Longitude_
Net
Acreage
Dominant
Soil Series
2-36
Cox, Ronald
Onslow
34"5445"
77"31'55"
11.20
Norfolk loamy fine sand,
0 to 2% slopes
2-37
Cox, Ronald
Onslow
3405446"
77"32'18"
26.40
Norfolk loamy fine sand,
0 to 2% slopes
2-38
Cox, Ronald
Onslow
34054`35"
77032'14"
30.40
Norfolk loamy fine sand,
0 to 2% slopes
2-39
Cox, Ronald
Onslow
34057'45"
7703023"
39.40
Goldsboro fine sandy loam,
0 to 2% slope
2-40
Cox, Ronald
Onslow
34057'34"
77030'26"
81.60
Goldsboro fine sandy loam,
0 to 2% slope
2-41
Cox, Ronald
Onslow
34°57'14"
77°30'16"
26.10
Goldsboro fine sandy loam,
0 to 2% slope
2-42
Cox, Ronald
Onslow
34053'08"
77"31'52"
6.90
Lynchburg fine sandy loam
2-43
Cox, Ronald
Onslow
34"52'36"
77031'56"
20.90
Autryville loaLuy fine sand
2-44
Cox, Ronald
Onslow
34052'45"
77031'54"
39.70
Autryville loamy fine sand
2-45
Cox, Ronald
Onslow
34052'53"
77031'49"
10.00
Norfolk loamy fine sand,
0 to 2% slopes
2-46
Cox, Ronald
Onslow
34352'54"
77"31'38"
40.30
Goldsboro fine sandy loam,
0 to 2% slope
2-47
Cox, Ronald
Onslow
3405170"
77032`36"
6.30
Norfolk loamy fine sand,
0 to 2% slopes
2-48
Cox, Ronald
Onslow
34"51'26"
77"32'27"
17.20
Norfolk loamy fine sand,
0 to 2% slopes
2-49
Cox, Ronald
Onslow
34°51'21"
77"32`18"
39.90
Norfolk loamy fine sand,
0 to 2% slopes
2-50
Cox, Ronald
Onslow
3405120"
77"33`42"
31.00
Aut ville loamy fine sand
2-51
Cox, Ronald
Onslow
34°51'22"
77032'51"
56.40
Norfolk loamy fine sand,
0 to 2% slopes
lbtal
1,536.00
WQ0024554 Version 1.1 Shell Version 070716 Page 19 of 19

Vicinity and Buffer Maps

IM

N
Al i III5 t 5 ^I !
i-; i 5 It 5 I 'S.n _
..
-/�. � 9P:•'
.xG Fx xn �ti���:F � •- �xrrn,mow� ;'Y� I I I s~`,s' i"�'''�' t , ! ^� c.n,wn^ I - �! ! � i �\ '" \.a-
f's � 1 !Bran ,•• 1 ^:#'-r^-_°
Fields 39 -
a
iitufROExlllxx _.•'�i -' "_A1
Y"" e � 1 li #� x\•\ --'^ �
4 - lr I
L i'`^_,._ 1"fit \ ! �_ � e ! t -- _ I I •'
i r �z•-�t ?Q �. � fi NsxYx FHs�YMR p9p.. � �-'•— 1 -./-i5 "t'1-..�
24 j 4' ,
I -�
25B 4 ,!Aauf
ICFII SLSXIp Fields 34 and 35 - 38`
/{F �
Fields 1.7A and 42 - 46
r_ � _ ; [ r nn I Gam ` ?'�: t•,� a'F\�
�� I i '[` , � r ^ � � ' � "� .},-'a ...� � ' � � ' ems`•/\ ^'�1�— tl
f FieldsP47 51 d t
� fOUMR[n 1 r 15 .: n � •• j
farenb4ua - 1 I # r =
S•. 'roan R f ^H , � _ �, / `- - ;�, . _ I � r_ ,r , IfWlip
Fields 2-1 and 24A
��-
qrq
WT
Rt
�
.-._!-a .1'`��_ � ' 4 a-- -- •.' \ il='rt i�. }• , -.�_.3.. _ ,�f ul 'aown as I eF: - - �_ '
f ' r
I -- � SI�r19�ya' � �� ti •,�� - - 2? I�' $1Ati •�.: ..
i
e N RIYbf
flkY
SCALE: 1r\ 2-4 miles Wulfekuhle Injection & Pumping, Inc. Site
'HECILED ex: Land Application Program Vicinity
DRAWN BY: RTB BRANCH Ronnie Cox Farm Map
DATE: RESIDUALS
Jun-07 & SOULS, LLC Project No. 2007-0

7
tires4�
7'
45
Z
WLMM
SCALE: P 660'
Wulfekuhle Injection & Pumping, Inc.
CHECKED BY: YTB
Land Application Program
Buffer
13RANCH
Ronnie Cox Farm
Map
DPAWN BY: RTB
RESYDUAILS
DATE; Sept - 07
& SOILS, LLC
--rUJCft r No,
20017-63 I
to510T

Z.�m

V,
Fvu
,,.w'• .. •p,% F,+�C .v - w • ~..ice ..
r
_ L1
W Owl
„�� L �� � •�� Z ,H it "� �'� ti� '. r �F
SCALE: V = 66V
a14 Walfekuhle Injection & Pumping, Inc.
CHECKED BY- RTB 4' Land Application Program Buffer
ERANCH Ronnie Cox Farm Map
DRAWN BY: jtTs �+6�`ID�[r��S Z
DATE: Sept - 07 � SOILS, LLC F
Project No. 2007_63
(o(,rlU7

C_l

or
I �^ tt�
1
P111E�
�t
�i
IIIh�.
'A Field 240
bE
:4j�}�.�
+r
IP�
baler
{rg�`
r - ya 'ii�.�t'€�����f6All Houses]BufferedB.
At Injection Distances
JP
• IF1E°� ',�;
IPrliUamM
j�l
k&�
OccupiedHouse
Z1, Out Building
40 ■ Unoccupied House
'' .� e • '� *ems

"An Houses Are Buffered
l-
,z�it, 'A'At Iniection Distances
7

•d
VA
- �.�,�"e���� ,�..��•=`"'.�� ",�.�'�� �-`-sic �_ �� ,.. l \a���� '
FAll■ I j yC o w
ouses Are B
njection Distances
r .iti- I