WQ0001863_Staff Report_20190702

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: [e-mail]
From: [e-mail]
Mooresville Regional Office
Application No.: WQ0001863
Facility name: City of Mount Holly RLAP
County: Gaston
Note: This form has been adapted from the non -discharge fg acili , 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.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No With Doug Shoudt (Mount Holly) and Adam Brigman (Synagro).
a. Date of site visit: 6-24-2019
b. Site visit conducted by: Maria Schulte
c. Inspection report attached? ❑ Yes or ® No In BIMS.
d. Person contacted: Adam Brigman and their contact information: abri man &synagro.com or (104) 650 - 4341
ext.
e. Driving directions: From MRO travel to 1-77 S; take I-485 exit south, toward Pineville; take exit 14 for Mt
Holly Rd. and turn rt., Turn Left to stay on Mt. Holly Rd.; Left onto Highland St. and cont. straight on S Main
st.; Left onto Tuckaseege Rd.; Left onto Broome St. (travel thru park to reach WWTPJ
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 4

5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Doug Shoudt Certificate #: LA-998746 Backup ORC: Michael Ben Moretz Certificate #: LA-989274
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities:
Proposed flow:
Current permitted flow:
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.)
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain:
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 Field sites MG-37 and GA-41 modified for property line
changes and Sites CL-11, GA-44 and GA-45 removed as noted in Cover Letter.
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No ❑ N/A
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
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11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ❑ N/A
If no, please complete the following (expand table if necessary): MRO staff updated existing permit for
recent cell phone photo data. CO staff should verif �mation is available to current aRRHEajjM
Monitoring Well
Latitude
Longitude
o
Offf
O l 11
O I /I
O l 11
O / /I
O l 11
O / II
O l 11
O / //
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: Residuals totals and PVAR data.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
MRO is okay proceeding with renewal and addressing requested items in cover-letter/permit if CO staff is.
Item
Reason
Updated map with correct
NC-GA-41 Fields 1, 6, 10, 14. Near field 10, the map has a 400' radius around
setback buffer at field 10
a centroid for the school structure, but portions of the school building fall
for school structures.
outside that radius; it would be best if the radius was sufficient to be from all
parts of the various school structures. Also see comment below under V.
Corrected map. Only small
field North center (with
NC-LT-46 Field 7. Correct map and scale to remove property East of Hwy 16
hatch marks) is permitted.
since it is NOT in the permit and the current map presentation is confusing.
FORM: WQROSSR 04-14 Page 3 of 4

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
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
❑ Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date: 7.2.19
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
nd 2019 --D... S
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Some existing sites in Lincoln and Gaston county were viewed roadside to assess area changes detected with on-line
mapping. It appears structures in question were either tractor or warehouse storage, so will not impact setback
requirements.
Maps (adjusted for hue) and additional PVAR data received at MRO were not mentioned above. Information was
forwarded to CO by email on 7-2-19.
1V. First item. MRO believes that the intent of the "place of assembly" setback of 400 ft. applies to the school structure
and gathering spots which may include the dugouts and bleachers at the ball field, which would be the closest points to
field 10 and may require minor adjustment to the application area. However, it is not clear to the MRO that the setback
should apply to the remainder of the outfield of the ball field, which could significantly alter the application area.
FORM: WQROSSR 04-14 Page 4 of 4