HomeMy WebLinkAboutWQ0010528_Staff Report, BIMS Inspection Report, Field Notes & Site Map._20191231DocuSign Envelope ID: E24D1 1 C9-FDC3-463D-B8C3-99B834723837
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
December 31, 2019
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00010528
Attn: Erick Saunders Facility name: Town of Ramseur, Surface Disposal Unit (SDU)
From: Patrick Mitchell
Winston-Salem Regional Office
Note: This form has been adapted from the non -discharge facility staff report to document the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: December 30.2019
b. Site visit conducted by: P. Mitchell & J. Gonsiewski
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Terry Lewallen, ORC and their contact information: (336) 824 - 3939
e. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
5. Does the site map represent the actual site (property lines, wells, etc.)? ❑ Yes ® No
If no, please explain: Site map does not provide minimum required details.
6. Is the residuals management plan adequate? ® Yes or ❑ No
7. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
8. Is the existing groundwater monitoring program adequate? ❑ Yes ® No
If no, explain: There currently is no groundwater monitoring program.
9. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
10. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
11. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
12. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
13. Has a review of all self -monitoring data been conducted (e.g., Annual Reports)? ® Yes or ❑ No
14. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
15. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
FORM: WQROSSR 04-14 Page 1 of 3
DocuSign Envelope ID: E24D11C9-FDC3-463D-B8C3-99B834723837
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
RSCA form, Section II. 8.
The applicant used an old application form and X'ed out the VAR
Determination in Section II. 8. as not applicable. However, this is required.
Updated Site Map
The site map included in the applicaiton does not contain the minimum required
information.
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Groundwater monitoring
plan schedule
To investigate groundwater & surface water concerns. See IV. Additional
Regional Staff Review Items.
5. Recommendation: ® Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Den Please state reasons: )
o uSigned by:
6. Signature of report preparer: A
Signature of regional supervisor 5546116co265C47"...
4
..
Date: December 31.2019 `0D2D3CE3F167456.
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On December 30, 2019 WSRO staff made a site visit to the subject facility for review associated with application for
permit renewal. Both of the residuals source facilities (WWTP & WTP) were visited during this review. Mr. Terry
Lewallen, WWTP-ORC accompanied staff on the entire review, and Mr. Mark Grose, WTP- ORC accompanied staff
on the WTP site visit only. Below are the items noted during the site visit or in the application package that requires
attention. Recommendations for requesting additional information are in listed in bold.
An old version of the RSCA form was submitted in the application. Section II. 8. for VAR Determination was
crossed out as nonapplicable. However, VAR is required unless the Division has approved type and thickness
for daily soil fill to be placed over residuals in the SDU. The facility does not utilize daily cover, it has not been
approved by WSRO, and this practice is not described in the updated O&M Plan. Therefore, a revised
application with the section for VAR completed must be submitted. The Permittee utilizes lime stabilization
methods for both pathogen and VAR.
2. The updated site map submitted with in the application package does not contain the minimum requirements.
WSRO has created an updated site map that intended for internal use. This internally created site map can be
utilized or if CO deems it necessary, request an updated site map that meets the minimum map
requirements.
FORM: WQROSSR 04-14 Page 2 of 3
DocuSign Envelope ID: E24D11C9-FDC3-463D-B8C3-99B834723837
3. The updated O&M Plan submitted with the application contained an old phone number for WSRO. The
Permittee was made aware of this during the site visit and will update the phone numbers in plans. If CO deems
it necessary, request a copy of the updated plans with up to date phone numbers.
4. Groundwater monitoring is currently not required for the subject SDU. A review of the archive files suggests
that groundwater monitoring was recommended by the Groundwater Section during initial permitting and was
also recommended by the Groundwater Section during the first permit renewal. However, groundwater
monitoring has not been required to date. The following concerns warrant groundwater monitoring
consideration:
• According to the original application and initial permit renewal correspondence, the clay liner thickness
is inadequate with only 14 inches of clay depth separation to rock and weathered rock. The SDU was
originally designed to be a treatment lagoon as part of an NPDES WWTP and not as a disposal unit. It
was installed in 1961.
• According to the original application and the initial permit renewal correspondence, a site & soil
evaluation was completed when the treatment lagoon was permitted to be a SDU. This evaluation
consisted of only one hand auger boring placed in one corner of the unit. This is grossly inadequate for
a 10-acre surface disposal unit. Therefore, the conditions present below the SDU are unknown.
The soils report for the initial conversion of the treatment lagoon to a SDU did not include onsite
measurements of hydraulic conductivity. Rather, a generic Ksat range was assigned to the liner based
on the properties described in the one hand auger boring. The generic Ksat range provided in that report
suggests that hydraulic conductivities for the SDU liner range from 0 to 4.23 x 10-' cm/second. This
means the conductivity is estimated to range from suitable to unsuitable values. This estimated range
exceeds the maximum liner permeability allowed by the 2H regs in place during initial permitting
(i.e. 1 x 10-' cm/second) and in the current 2T regs (i.e. 1 x 10-' cm/second).
• The close proximity of the SDU in relation to surface waters and floodplain area could result in non -
point contribution to the receiving surface waters. The surface water feature in question is relatively
large with a large volume of flow. Groundwater monitoring would allow measurement to evaluate
potential impacts to groundwater and surface waters.
According to notes in the file, the primary reason groundwater monitoring was not required during the initial
permitting was that the only accessible areas for the review and compliance boundaries were estimated to be
located within the floodplain. However, WSRO staff reviewed the areas surrounding the SDU and located an
accessible area along a gravel path, just outside the review boundary, that is potentially suitable for a
downgradient monitoring well to be installed. This area was located using GPS and added to the site map
utilizing GIS (see attached site map). There is also area available upgradient of the SDU for installation of a
background monitoring well.
Based upon the initial/current concerns warranting groundwater monitoring listed above, and the accessibility
of potentially installing a monitoring well at or beyond the review boundary, it is recommended that a
groundwater monitoring plan be submitted for this existing facility. Recommend that a permit schedule
condition be added to the new permit, requiring a groundwater monitoring plan to be submitted within 90 days
of permit issuance.
FORM: WQROSSR 04-14 Page 3 of 3
Compliance Inspection Report
Permit: WQ0010528 Effective: 07/24/17 Expiration: 04/30/20 owner: Town of Ramseur
SOC: Effective: Expiration: Facility: Ramseur WWTP
County: Randolph
Roundleaf Rd
Region: Winston-Salem
Ramseur NC 27316
Contact Person: Bobbie Hatley Title: Phone: 336-824-8530
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0026565 Town of Ramseur - Ramseur WWTP
Inspection Date: 12/30/2019 EntryTime: 10:OOAM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Certification:
Phone:
Exit Time: 12:30PM
Phone: 336-776-9698
Jim J Gonsiewski
Reason for Inspection: Other Inspection Type: Reconnaissance
Permit Inspection Type: Surface Disposal of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant g Neither
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3
Permit: WQ0010528 Owner - Facility: Town of Ramseur
Inspection Date: 12/30/2019 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On December 30, 2019 WSRO staff made a site visit to the subject facility for review associated with permit renewal. Both
residuals source facilities were reviewed during the visit. Mr. Terry Lewallen (WWTP ORC) accompanied staff on the entire
visit. Mr. Mark Grose (WTP ORC) accompanied staff on the WTP source facility visit only. Below is a brief summary of
notes from the visit. See 12/31/2019 staff report and site map for additional details.
- Issues with the application package which might require add info request was discussed with the representatives onsite.
- The potential for a groundwater monitoring plan was also discussed. There is a gravel access path leading to the river along
the SE side of the disposal unit. GPS coordinates were taken along the path showing that the review boundary and beyond
is accessible for potential MW installation.
- There is a concrete stormwater catch located on the NW side of the disposal unit in a depressional area. This feature
reportedly has a drain outlet that empties beyond on the north corner of the disposal unit (either inside or outside the fence).
*THIS STORMWATER OUTLET NEEDS TO BE REVIEWED FOR DISPOSAL UNIT LEACHATE SEEPAGE DURING THE
NEXT INSPECTION AND PERIODICALLY DURING ROUTINE INSPECTIONS.
Page 2 of 3
Permit: WQ0010528
Owner - Facility: Town of Ramseur
Inspection Date: 12/30/2019
Type
Distribution and Marketing
Land Application
Inspection Type : Reconnaissance
Reason for Visit: Other
Yes No NA NE
Page 3 of 3
North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS B RESIDUALS
General Information
Facility Name: RRAIr E' 'r �urMw �irri�sa� /o rw�
Permit No.: W006 10 528
Owner: Tan+ of game ,e-'•+/
Plant ORC Name: Tpr r ti Le~../a 1 �
LA ORC / Contract Compa y: Mar/ ra sc
Other Contact(s):
Facility �ocation (address, gps or directions). f
County: R4,14611
Permit Issuance Ddte: 1 23 wjr,
Permit ExpirWnn Date: ? ZeZO
Telephone No.: _ 3-46-8�-39M �t 3s6-736 0S3Z
Telephone No.: a�9z.Y-7�7/ CP' 33G-3oz- r98Z
Telephone No.:
spa ± �t� Kd L wsP. f; c, kh Aaey L R°®�
Reason for Inspection �(PERMITTING
Cgene wo
❑ ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ Other:
Comments (attach additional pages as necessary)
Nl,lts fGgllaway)Qe. C5Z)?S7-/0`76, / iii�Tln nl 15,rufS% / 4�ye pp
/H "ss)
old RSCA 4/m ,,k u� . I a�x�r� 9 / l , V_
/ A+.�/L XC� Dori; /!�' alVed rnA�Er! f),'v6M� R/ao'vVe �^ �� �•avr
�Sec/ro .tP tgqar //O�AK del%r-rm/ n/WgJS / ij i1 r / !r
i.f .O[r[�� AJ- %^ �n0 �I"� e4-
'* LM+t ,lAbr/ru� e 9
5;)e, MAf Sh� rw4 M)n'k M My
V U� d a f444CM yI , s�,0/�I� h� a� "awsROPI�nG � �1 r� �
ONsTTzer r 2=V�2tl till
qe
/ SI-�M nIG/n[NT CP�aaW✓N �Mawt�i Prof %n P� aK�✓"'t� '177L d�C�J/
;ZS
( lj Gov %s Z M i��d
�p� MO /o t
�,�p/,� ? L.s w �Gw.
S�; w W'^� 1 / 11 J� l 1�., rnw. ix �o Camels
r) S�rM un� U CR�LIv Oti�lC 1 ✓fl / 16
Is a follow-up inspection necessary? Yes ❑ No Vity
Primary Inspector: Fi M ' * « Secondary Inspector: 7i GovyrevU-cK-;
Date of Inspection: 2-13 6 20 Entry Time: /6 _'GDgM Exit Time: r•
Non -Discharge Compliance Inspection Report \
Residuals Generating Facility
Was the residuals generating facility inspected? Yes ❑ No
Residuals Storage:
Describe storage: W
Number of days/weeks/months of storage: a i,
Residuals Sampling:
Is sampling adequate and representative? W I r -P
Describe Sampling (Pathogens, VAR, Nutrients/Metals, TCLP): V TF :
Transport Vehicle: Cvrff 0A I
Is transport occurring at time of inspection?
Are necessary records (i.e. permit & spill plan) present in vehicle? ID of observed vehicles)
1C Y N NA NE
❑ ❑ ❑ ❑
Record Keeping and Reporting Information:
Is current permit and prior annual reports available upon request?
Has the facility been free of public complaints for the last 12 months?
TCLP analysis conducted and results available? Frequency? ❑ 1/yr or ❑ 1/permit cycle
Residuals metals and nutrient analysis conducted? Frequency? (See permit for frequency)
Nutrient and metals loading calculations? (to determine most limiting parameter)
Do lab sheets support data reported on Residuals Analysis Summary?
Are PAN balance records available and within permit limits?
Are there nutrient (crop) removal practices in place?
Are hauling records available? (gal and/or tons hauled during calendar year to date)
Are field loading records available?
Are field inspections conducted and are records available?
Are soil sample results available?
Did soil results call for time amendment? If so, are there records of application?
Soil results indicate that Cu & Zn indices are <3,000 (ideally <2, 000)?
Soil results indicate Na <0.5 meq/100 cm', and Exchangeable Sodium Percentage (ESP) <15%?
Does the permit require groundwater monitoring?
Are groundwater lab results present?
There are no 2L GW standard violations indicated in the lab results?
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction:
Which Alternative was used to demonstrate compliance?
temative I Fecal Coliform Density.
mples collected and geometric mean <2 million mpn/efu?
❑ Alternative 2 Proc i ificantly Reduce Pathogens (S options)
❑ Alternative 3 Use of Equiva a SRP (Not commonly used - See White House
If Alternative 2 was used, select which Option w7at68'F
ed and complete the section b lesi!
❑ Option I - Aerobic Digestion
Are logs present showing time and temre?
Was the time &temp. between 40 days (20°C 60 da t5�9° F (15°C)9
❑ Option 2 - Air Drying
Y
El
11
NA
El
NA
NE
El
El
NE
Y N NA NE
❑ ❑ —,-n' ❑
Y N NA NE
❑ Option 3 - Anaerobic Digestion
Are logs present sho true and temperature? ❑ ❑ ❑
Was the tim emp. between 15 days at 95° F — 1310 F (350-550 C) and
60 at >68° F (20° C)? El❑ ❑
ption 4 — Composting (Not commonly used -See White House Manual)
Option 5 - Lime Stabilization
Are logs present showing time and temperature? ❑ ❑ ❑ ❑
Was the pH raised to > 12 after two hrs of contact? ❑ ❑ ❑ ❑
Was the temperature corrected to 25° C (77° F) (by calculation, NOT auto correct)? ❑ ❑ ❑ ❑
Page 2 of 4
Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions
LJ Option I - 38% Volatile Solids Reduction
Y
N
NA
NE
Are lab results and calculations present?
❑
❑
❑
Was the reduction on volatile solids (not total solids)?
❑
❑
❑
Were samples collected at correct locations?
❑
❑
❑
❑
ginning ofdigestion process & before land application)
Wa here a>38%reduction?
❑
❑
❑
❑ Option 2 - 40- ay Bench Scale Test
Y
N
NA
NE
Were resi Is from an anaerobic digester with average temp. 30°C — 40°C?
El
❑
El
Are lab result nd calculations present?
❑
❑
❑
Was the test anae bically digested in lab, and test run for 40 days?
❑
❑
❑
Was the lab bench-s le test done between 30°C (86°F) and 370C (99°F)?
❑
❑
❑
Was the reduction of o volatile solids (not total solids)?
❑
❑
❑
❑
Was the reduction less th 17%?
❑
❑
❑
❑
❑ Option 3 - 30-Day Bench Scale Tes
Y
N
NA
NE
Were residuals from aerobic dige 'on?
❑
❑
❑
❑
Are lab results and calculations pres ?
❑
❑
❑
❑
Were residuals 2% or less total solids?
❑
❑
❑
❑
If not 2% total solids, was the test ran on a ple diluted to /o
with unchlorinated effluent?
❑
❑
❑
❑
Was the test run for 30 days?
❑
❑
❑
❑ "
Was the test done at 20°C (68°F)?
❑
❑
❑
❑
Was the reduction of on volatile solids (not to solids)?
❑
❑
❑
❑
Was the reduction less than 15%?
❑
❑
❑
❑
❑ Option 4 - Specific Oxygen Uptake Rate (S R Test)
Y
N
NA
NE
Were residuals from aerobic digest' ?
❑
❑
❑
❑
Were residuals <2% total solids ry weight basis) (not diluted)?
❑
❑
❑
❑
Was the test done between I (50°F) and 30°C (86°F)?
❑
❑
❑
❑
Was the temperature corn ed to 20°C (68°F)?
❑
❑
❑
❑
Was the sampling hol ' g time <2 hours?
❑
❑
❑
❑
Was the test starte ithin 15 minutes of sampling or aeration maintained?
❑
❑
❑
Was the SOUR ual to or less than 1.5 mg of oxygen per hour per gram of
total residua olids (dry weight basis)?
❑
❑
❑
❑ Option 5 - 14 ay Aerobic Process
Y
N
NA
NE
Wer e residuals from aerobic digestion?
❑
❑
❑
the average residuals temperature higher than 45°C (I 13°F)?
❑
❑
❑
ere the residuals treated for 14 days and temperature maintained higher
�J Option 6 - Alkaline Stabilization
Y N
NA
NE
p Was the pH of the residuals raised to >_12 and maintained for two hours
without addition of more alkali?
❑
❑
❑
Did the pH of residuals remain at > 11.5 an additional twenty-two hours
(i.e. 24 hours total) without the addition of more alkali?
❑
❑
❑
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)?
❑
❑
❑
on7-Dryngo
Y'
N
The r o not contain unstabilized residuals?
❑
❑
+' Were the residuals mi any other materials?0
❑
❑
Were the residuals dried >75%tota s
❑
❑
❑
❑
❑ Option 8 - Drying of Unstabilized Residuals
Y
N
NA
NE
Were the residuals mixed with an erials?
❑
❑
❑
❑
Were the residuals dr' _ o total solids?
❑
❑ O t' — njection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4
�l�((�zd%CJf4+wi �(qltNon-Discharge Compliance Inspection Report
eat �ite(sj
Were application site(s) inspected? Ifso, please list Site ID(s) below.
Yes ❑ No
Is application occurring at the time of inspection?El Yes
Weather Conditions.
Partly Cloudy El Cloudy
�El Windy (winddirection:,(Breeze
918CJ No Precipitation ❑ Dri
Is there a rain gauge onsite? m
❑ Yes? � o
Weather Notes (i.e. Significant Changes, orecasts, etc):
Temp. (° F): 0 <32 ❑ 32 — 40 ❑ 40 — 60
Permit and Spill Plan onsite during application? M
I-
Application Occurring at
time of visit: El Yes No
Application Method:, Surface
1 ✓�
VeBeta Clntosa n�-__
f1 Ar n F n�
^ n
OVectors: °dor do,None ❑MildMld ❑Mderatg0
None ❑ Stron
❑ Few ❑ Many ❑ Excessive
Application Details: Y N NA
AmF aa1
is even (no ponding)?
oiusunus vtstble on surface?
Site Restrictions
Public access is restricted / Signage present?
Off Site Transport
No If no, note the date of the last
❑ Overcast
❑ Calm
❑ Cloudburst
❑ Stormy
(If applicable, precipitation measurement: _ J
60 — 80 ❑ >80
Yes ❑ No
Site -Field ID(s):
op. PAN
Rate (gallons/acrej.
. PPHUUHOIIoccurring at time of visit: ❑ Yes ❑ No
Application Ne
thod: ❑ Surface ❑ Incorp/Injection
Incorporation/] 'ection during visit: ❑ Yes ❑ No ❑
Vegetative Buffer escription: ❑None ❑Grass
❑Tree ❑ Other
Current Field Condit[ ns:
❑ Bare ❑ Stubble Planted cm
Soil Condition:
❑ Dry ❑ Moist ❑ t ❑ Saturated
❑ Not -Frozen ❑ Frost Frozen
Slope: ❑ 0-3% ❑ 3-6% 6-10%
Odor: ❑ None ❑ Mild der[
Vectors: ❑None [Few any
Application Details:
Application areas clearly marke .
Application within authorized ea?
Application method approprte?
Application is even (no po ing)?
Sufficient setbacks from ells/residences?
Sufficient setbacks fro urface waters,
Slopes >10% avoided urface App.)?
Slopes >18% avoid, (Incorp/inject)?
Incorp./Injection w in time -frame?
u u olusuuasvistble surface?
�Y/ N NA NE Site Restrictio
p,..Z ❑ ❑ Public access' restricted/ Signage present?
'tlrti$a' Grazing restr' tions are met?
Transfer of iosolids is in permitted area?
r��"❑'$-8- No ,vide a of shallow G W?
`-u--u�-P SuDicie timing for harvest restrictions?
Y N NA NE Off Si Transport
Trac g is prevented?
B' Bin lids tun -off is prevented?
Wi dblown biosolids prevented?
$ V getat" buffers exist?
Page 4 of 4
❑ Shrub
❑ Pasture
10-18% ❑ >l8%
Ie ❑ Strong
❑ Excessive
Y N NA NE
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Y N NA NE
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑❑❑❑
❑ ❑ ❑ ❑
❑ Ell❑
Y N NA NE
El❑❑❑❑❑
❑° ❑ ❑❑ ❑°
Site Map WQ0010528