WQ0003902_Staff Report_20200103

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: (WQ0003902)
Attn: (Ranveer Katyal Non -Discharge Central Office) Facility name: City of Newton (Clark Creek WWTP)
From: (Edward Watson in MRO)
Mooresville Regional Office
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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 01/02/2020
b. Site visit conducted by: Inspection report attached? ❑ Yes or ® No, but available in BIMS/LF
c. Person contacted: Eric Jones and their contact information: (828) 695 - 4373 ext.
e. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: James Eric Jones Certificate #:25000
Synagro LA ORC Mike Cox Certificate #:13191
Backup ORC: Scott Bryan Certificate #: 985581
Backup ORC: Robert Roth Certificate #:1001672
2. Is 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: Clark Creek WWTP for the Town of Newton, NC
Proposed flow: N/A This is an RLAP (503) Non -Discharge permit
Current permitted flow: N/A
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.)
FORM: WQROSSR 04-14 Page 1 of 4

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
If yes, please explain: Fields are being removed and added to the permit.
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
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: Monitoring Wells are not
required. Monitoring wells are not required for this permit.
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: Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary):
11. 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: No compliance issues.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain: N/A
13. 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:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: Not if operated as a non -discharge system
16. Pretreatment Program (POTWs only): NA
FORM: WQROSSR 04-14 Page 2 of 4

III. 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 Non -Discharge Unit Central Office to obtain through an additional
information request:
Item
Reason
1
LOA for fields with name change for field CA-2 1, Warlick, from Synagro.
2
Updated maps displaying buffer areas, topography and other related
information for new fields from Synagro.
3
4
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
1
Fields CA-07, CA-14 and CA-17 are to be removed from the permit at the
Landowners request.
Field LT-117 is removing fields 3 and 4 from the permit. Total acreage to be
removed from the permit is 306.9, to be removed from Attachment B of the
permit.
4. 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: )
5. Signature of report preparer: Edward Watson 1 /3/2020
DocuSigned by:
Aoa�
f/ Nu"
F161 FB69A2D84A3...
Signature of regional supervisor:
Date: 1.3.20
FORM: WQROSSR 04-14 Page 3 of 4

IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The application package indicates the WTP is being added to the permit. This is not correct. The only source of
residuals will be the Clark Creek WWTP. The application package also indicates that PVAR is by 38% reduction.
However, this facility uses lime stabilization for pathogen reduction and indicated they would continue.
Fields will be added to the permit for an additional —200 acres. Given the fields removed, the total net loss of acreage
will be —107 acres.
Two fields that are planning to be added to the permit were reviewed during this site visit. Field NC-CA-27 is owned
by Jason Little. There is a stream area that runs across this property that will require adequate buffering to comply
with 02T offsets for surface water features.
Also, field NC-CA-47 owned by Randy Leatherman was reviewed during the site visit. This field has a pond on site.
However, the pond will be outside of the residuals application area.
FORM: WQROSSR 04-14 Page 4 of 4