WQ0001800_Staff Report_20200427

DocuSign Envelope ID: 8CC173A7-BBCC-482A-A7BC-42C41BCB6499
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April 27, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00001800
Attn: Ranveer Kates Facility name: Town of Yadkinville RLAP
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: April 24, 2020
b. Site visit conducted by: P. Mitchell & C. Caudle
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Alex Fox (Synagro) and their contact information: (336) 703 - 8681 ext.
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 site conditions (soils, depth to water table, etc) consistent with the submitted reports? ® Yes ❑ No ❑ N/A
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ® No ❑ N/A
Explain: There were site features not shown on site maps. See IV. Additional Regional Staff Review Items.
5. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ® Yes ❑ No ❑ N/A
6. Are there any setback conflicts for proposed treatment, storage and disposal sites? ® Yes or ❑ No
If yes, attach a map showing conflict areas.
7. For residuals, will seasonal or other restrictions be required? ❑ Yes ® No ❑ N/A
8. Is the residuals management plan adequate? ® Yes or ❑ No
9. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
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 (Annual Report)? ® 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
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
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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
Revised site maps.
Site maps need to be corrected to show all site features and applicable setbacks.
Plus adjacent features that are requried.
Revised acreage on forms.
Changes to site maps will reduce land application areas in fields.
Missing soil test results.
Not all required heavy metals were sampled for these new land application
fields. Soil sample results for Field #5 were not included in the application.
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:
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
6. Signature of report preparer:
Signature of regional
Date: April 27, 2020
state reasons: )
by:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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145B49E225C94EA...
On April 24, 2020, WSRO staff conducted soil and site reviews of the proposed new land application fields. The existing
residuals generating facilities were not visited, since there were no proposed modifications to them. Mr. Alex Fox of
Synagro accompanied staff on the site reviews. There were several site features noted during the site reviews which
warrant corrections to the land application site maps. A summary of notes from the review of each field, which includes
any items that warrant an additional information request is listed below.
1. The soil sample results for all four of the proposed new fields were missing Mercury and Molybdenum, which
are required for all new land application fields. In addition, the four soil sample results were for 1, 2, 3 and 4;
where are the results for Field #5? Please request these missing heavy metals parameters and results for
Field #5 be submitted.
2. The setback site maps submitted for all four proposed new fields are missing onsite features and adjacent site
features which are required to be shown on the land application site maps. Please request that the setback site
maps be revised to include all required features listed below. Please refer the applicant to the Division's
Map Guidance Policy and 15A NCAC 02T .1104 (c)(1) for setback map requirements, as these mapping
errors are repeat for this consultant.
• There are surface water features (ephemeral, intermittent and perennial streams) on and adjacent to the
land application areas not shown on the site map. 15A NCAC 02T .1104 (c)(1)(13) requires that all
surface water features within 500 ft. of the site must be shown on the setback maps.
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• There are drainage features on and adjacent to the land application areas not shown on the site map.
15A NCAC 02T .1104 (c)(1)(B) requires that all drainage features within 500 ft. of the site must be
shown on the setback maps.
• No property lines are shown beyond the exterior boundary of each site parcel. 15A NCAC 02T .1104
(c)(1)(D) requires that all property lines within 500 ft. of the site must be shown on the setback maps.
• None of the fence lines, onsite buildings, barns, etc. are shown on the setback maps. 15A NCAC 02T
.1104 (c)(1)(A) requires that all structures, including fences which are located within the land
application area shall be shown on the setback maps.
• Nearly every Road Name was missing on the setback maps. 15A NCAC 02T .1104 (c)(1) requires
setback maps to accurately depict the location, orientation and relationship of the land application
fields. This includes labeling all Road Names on the map.
In addition, the private roads, driveways, and farm access roads that run through or adjacent to land
application areas were not shown on the setback maps. Map Policy Item #4 explains the requirements
in 15A NCAC 02T. 1104 (c)(1) and includes a list of all features that must be clearly shown on setback
maps.
3. YK-42 Field #1 has the following site features missing which also require buffers that will reduce the
application areas:
• There is a stream which flows along the western border of the application area, below the pond which
is not shown on the setback map (see attached map sketch). The site map needs to be revised to show
this stream and the applicable surface water setback.
• There is an access road that runs east to west which is not shown on the setback map. This access road
has a ditch that runs adjacent to the north side for the entire stretch (see attached map sketch). The site
map needs to be revised to show the access road, ditch and applicable ditch setback.
• The perennial stream that flows adjacent to the entire site needs to be added to the site map.
4. YK-42 Field #4 has a drainage way with a channel present that is not shown on the setback map (see attached
map sketch). The site map needs to be revised to show this feature and the applicable buffer. There is also
a perennial stream that flows adjacent to the entire site needs to be added to the site map.
Other Notes:
- Some fields were reported as fescue crop in the application but were found to be planted in row crops during
site visits. It was indicated that these fields will be converted to fescue before land application occurs. WSRO
staff to check crops present during inspections of YK-42 Fields 1 and 2 to ensure accurate loading is reported.
- Some fields reported as "fescue" in the application. Some were found to be utilized as pasture while others for
hay crop. WSRO staff to check crops present during inspections to ensure accurate field loadings are reported.
- According to the reported PAN concentrations, —100 to 145 acres is needed for the permitted annual dry tons.
With the addition of new fields there will be 187.1 acres. OK
FORM: WQROSSR 04-14 Page 3 of 3

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Compliance Inspection Report
Permit: WQ0001800 Effective: 02/04/19 Expiration: 02/28/22 Owner: Town of Yadkinville
SOC: Effective: Expiration: Facility: Town of Yadkinville RLAP
County: Yadkin 1620 Fred Hinshaw Rd
Region: Winston-Salem
Yadkinville NC 27055
Contact Person: Grant Trivette Title: Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Michael Wayne Boone
Secondary ORC(s):
On -Site Representative(s):
Certification: 987521 Phone: [phone]
Related Permits:
NC0020338 Town of Yadkinville - Yadkinville WWTP
Inspection Date: 04/24/2020 Entry Time 10:OOAM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Exit Time: 01:30PM
Phone: [phone]
Caitlin Caudle
Reason for Inspection: Other Inspection Type: Reconnaissance
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant $ Neither
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0001800 Owner - Facility: Town of Yadkinville
Inspection Date: 04/24/2020 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On April 24, 2020, WSRO staff conducted soil and site reviews of the proposed new land application fields associated with
an application for permit modification. The existing residuals generating facilities were not visited, since there were no
proposed modifications to them. Mr. Alex Fox of Synagro accompanied staff on the site reviews. There were several site
features noted during the site reviews which warrant corrections to the land application site maps. A summary of notes from
the review of each field, which includes any items that warrant an additional information request is listed below.
1. The soil sample results for all four of the proposed new fields were missing Mercury and Molybdenum, which are required
for all new land application fields. In addition, the four soil sample results were for 1, 2, 3 and 4; the results for Field #5 were
not included.
2. The setback site maps submitted for all four proposed new fields are missing onsite features and adjacent site features
which are required to be shown on the land application site maps.
• There are surface water features (ephemeral, intermittent and perennial streams) on and adjacent to the land application
areas not shown on the site map.
• There are drainage features on and adjacent to the land application areas not shown on the site map.
• No property lines are shown beyond the exterior boundary of each site parcel.
• None of the fence lines, onsite buildings, barns, etc. are shown on the setback maps.
• Nearly every Road Name was missing on the setback maps and the private roads, driveways, and farm access roads that
run through or adjacent to land application areas were not shown on the setback maps.
3. YK-42 Field #1 has the following site features missing which also require buffers that will reduce the application areas:
• There is a stream which flows along the western border of the application area, below the pond which is not shown on the
setback map (see attached map sketch).
• There is an access road that runs east to west which is not shown on the setback map. This access road has a ditch that
runs adjacent to the north side for the entire stretch (see attached map sketch).
• There is a perennial stream that flows adjacent to the entire site which is not shown on the site map.
4. YK-42 Field #4 has a drainage way with a channel present that is not shown on the setback map (see attached map
sketch). The site map needs to be revised to show this feature and the applicable buffer. There is also a perennial stream
that flows adjacent to the entire site needs to be added to the site map.
Other Notes:
- Some fields were reported as fescue crop in the application but were found to be planted in row crops during site visits. It
was indicated that these fields will be converted to fescue before land application occurs. WSRO staff to check crops
present during inspections of YK-42 Fields 1 and 2 to ensure accurate loading is reported.
- Some fields reported as "fescue" in the application. Some were found to be utilized as pasture while others for hay crop.
WSRO staff to check crops present during inspections to ensure accurate field loadings are reported.
- According to the reported PAN concentrations, --100 to 145 acres is needed for the permitted annual dry tons. With the
addition of new fields there will be 187.1 acres. OK
Page 2 of 3

Permit: WO0001800
Inspection Date: 04/24/2020
Type
Distribution and Marketing
Land Application
Owner - Facility: Town of Yadkinville
Inspection Type : Reconnaissance
Reason for Visit: Other
Yes No NA NE
Page 3 of 3