WQ0000520_Staff Report_20170227

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
February 27,2017
To: DWR Central Office—WQ,Non-Discharge Unit Application No.: W00000520
Attn: Troy Doby Facility name: Burlington Class B RLAP
From: Patrick Mitchell
Winston-Salem Regional Office
Note:This form has been adapted from the non-discharee facility staff renortto document the review of both non-dis ham antUVDES permit applications and/or renewal.Please complete all sections as der are applicable,
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted?®Yes or El No
a. Date of site visit: February 17,22, &23, 2017
b. Site visit conducted by: P.Mitchell(and J. Henderson only on 2/17&2/22/2017)
c. Inspection report attached? ®Yes or El No
d. Person contacted: Shane Fletcher(Burlington)and their contact information: (336)675 - 5927 ext.
e. Driving directions: See file.
U. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge(ORCs)for the facility? ®Yes ❑No ❑N/A
ORC: Shane Fletcher Certificate#: LA-988754 Backup ORC: Eric Davis Certificate#:LA-26305
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 new site conditions(soils,depth to water table,etc)consistent with the submitted reports?
El Yes ®No El N/A If no,please explain: See attached report.
4. Are the existing site conditions(e.g., soils,topography,depth to water table,etc)maintained appropriately and
adequately assimilating the waste? ®Yes or❑No
5. 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: See attached report.
6. Are there any setback conflicts for proposed treatment,storage and disposal sites? ®Yes or❑No
Please explain: See attached report.
7. Do the plans and site maps represent the actual sites(property lines,wells,etc.)?❑Yes ®No El N/A
If no,please explain: See attached report.
8. Is the residuals management plan adequate? ®Yes or El No
If no,please explain:
9. Are the existing application rates(e.g.,hydraulic,nutrient)still acceptable?® Yes or El No
If no,please explain:
10. For residuals,will seasonal or other restrictions be required? El Yes El No®N/A
11. Is the existing groundwater monitoring program adequate? ❑Yes El No ®N/A
FORM:WQROSSR 04-14 Page 1 of 2

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PPIPPr-
12. Are there any setback conflicts for existing treatment, storage and disposal sites? ®Yes or❑No
Please explain: See attached report.
13. Is the description of the facilities as written in the existing permit correct? ® Yes or❑No
If no,please explain:
14. Were monitoring wells properly constructed and located? ❑Yes❑No ®N/A
If no,please explain:
15. Are the monitoring well coordinates correct in BIMS? ❑Yes❑No ®N/A
16. Has a review of all self-monitoring data been conducted(e.g.,DMR,NDMR,NDAR, GW)? ®Yes or❑No
17. Are there any permit changes needed in order to address ongoing BIMS violations? ❑Yes or®No
18. 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
19. 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 Non-Discharge Unit Central Office to obtain through an additional
information request:
Item Reason
Revised Maps Missing or incorrect.
Revised Acreages Map changes impact.
Missing Soils Maps Missing.
Others See attached inspection report memo.
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(Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor: >j- 4'A. - ut
Date: February 27,2017
IV.ADDITIONAL REGIONAL STAFF REVIEW ITEMS
ki See attached inspection report memo.
® WQROSSR 04-14 Page 2 of 2

ROY COOPER
Governor
�Y
MICHAEL S. REGAN
Secretary
.. S. JAY ZIMMERMAN
Director
Water Resources
ENVIRONMENTAL QUALITY
MEMORANDUM
DATE: February 27, 2017
TO: Troy Doby, DWR CO—WQ Permitting-ND Unit
THROUGH: Sherri Knight, WSRO Supervisor f\))L
FROM: Patrick Mitchell, WSRO
SUBJECT: Inspection Report
Permit Modification& Renewal Application for:
City of Burlington, Residuals Land Application Program
Permit No. WQ0000520
On February 17th, 22nd, and 23r1, 2017 WSRO staff met with Mr. Shane Fletcher, ORC (City of
Burlington) to review land application fields included in the application for modification and
renewal of Permit No. WQ0000520. The residuals source facilities proposed for renewal were
NOT visited as part of this review. Accompanying WSRO staff on all site visits was Mr. Shane
Fletcher with the City of Burlington.
Many renewal sites were reported with changes in acreages when compared to the previously
approved sites listed in the current Attachment B. It appears that a number of these were due to
map modifications. Based upon WSRO's reconnaissance review of the candidate fields in this
permit modification/renewal application, the following items must be addressed, additional
information received and reviewed before the permit can be issued:
y1. This application package was submitted as a permit renewal with no modifications.
However, there were numerous modifications included in this application package
including two brand new fields not previously permitted, changes in annual residuals
tonnage, new maps with revised application area boundaries, revised acreages, etc. If the
applicant has not already done so, a revised application indicating the presence of
major modifications and the associated fee is warranted.
V 2. The Landowner Agreement forms included in the package were missing pages. Most seem
to be missing the first two pages. Request these pages be submitted.
3. There were a number of property lines and associated buffers that were removed from the
existing approved maps. It appears that the draft add info from Central Office has captured
the majority of these. Therefore, sites listed in the draft add. info. letter was not listed
again in this report.Any additional sites will be noted below in the site specific details.
450 W.Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone:[phone] FAX:[phone] Customer Service 1-877.623-6748
Internet www.ncdenr.gov-www.ncwater.org

✓4. The new maps submitted in the subject application package require the following
corrections/additions:
• New land app. site maps did not contain map legends.
• The new map symbols utilized on the new maps are not sufficient. For example: a
solid blue line symbol was utilized for ditches, ephemeral streams, and for
intermittent/perennial streams; A square box was drawn for structures and it is
unknown if these boxes are outbuildings, offsite residences, onsite residences,
places of public assembly, etc.
• In addition to the existing approved site maps,there are two new series of new maps
in the application package (a total of 4 different styles of maps).Neither of the two
new map styles utilized a map legend,and both of these had differing symbols from
each other and from the existing maps which did have a map legend.
Request that new maps are redrawn utilizing consistent map symbols that
differentiate site features of interest. Request that a map legend be added to every
map contained in the application package. Again, currently there are four sets of maps
(i.e.hand drawn Synagro maps,GIS drawn Synagro maps,and two different styles of EMA
hand drawn maps)utilized for the proposed site maps for this permit.
5. The sites listed below require additional information and/or corrections to be made.
AM-06: The predominant soil series found to be present in Fields #8 and #9 is the Durham soil
series and not Appling as previously listed. The new Attachment B should reflect this change.
NOTE: Durham PAN = 194 lb PAN/acre/year versus Appling PAN = 237 lb PAN/acre/year for
the proposed crop.
f' AM-13: The predominant soil series found to be present in all site fields is the Tarrus soil series
and not Georgeville as previously listed.The new Attachment B should reflect this change.NOTE:
Tarrus PAN = 190 lb PAN/acre/year versus Georgeville PAN= 211 lb PAN/acre/year for fescue
hay.
/ AM-17: Field#3 has a drain present which needs to be added to the site map with the associated
buffers.Need revised acreage reported as result.
t✓AM-72: There is a well present which is not shown on the site map.Need the map revised to show
the well and the associated buffer.
The soils map was missing in the WSRO copy of the application package for Site AM-72. Request
the missing soils map be submitted.
AM-73: Field #1 has a stream and buffer which were not accurately shown on the site map. The
site map needs to be revised and the buffer shown as 100 feet on the map.
✓ Field #2 has increased in area due to new house buffers being signed. However, there was no
change in acreage reported... Request new acreage be reported.
/ Field #3 has a drain flowing through the field which was shown on the existing map but was
removed on the new map. Request the drain and buffers be added on the new map.
Page 2 of 4

AM-110: Field#2 has reduced in area due to the northern neck of the field now being buffered.
However, no change in acreage was reported. Request new acreage be reported.
AM-116: Fields #7 & #8 have property lines which are not shown on the maps. Request revised
map and acreages showing property lines and buffers.
AM-119: There is a typo in the cover letter of the application package. The letter indicated that
Field #1 increased in acreage, when it really was Field #2 which increased and was shown as
increased on the maps.Not really requesting info on this;just wanted to point out the typo in case
there was any confusion.
AM-126: Field#1 has a stream present on the northwest border which was shown on the existing
maps with a buffer.However,the new maps did not show this stream with buffer.Request a revised
map and updated acreage showing this stream and associated buffers.
Fields #5 & #6 were found to have Davidson soil series as the predominant soils, and not
Georgeville as currently listed. The new Attachment B should reflect this change. NOTE:
Davidson PAN = 237 lb PAN/acre/year versus Georgeville PAN =211 lb PAN/acre/year for the
proposed crop.
AM-127: Reportedly the acreage contained within the 2014 Attachment B was not correct. The
revised acreage submitted in this application package was reported as being corrected.Not really
requesting add. info. for this item;just wanted to list it in case there was any confusion.
AM-128: There were numerous site changes (e.g. new residences, new ponds, new roads, etc.)
present for nearly every field which were not shown on the site maps. Due to these numerous site
modifications, the Permittee verbally indicated that they desire to remove this site entirely
from the application package and the land app program.
CH-39: Field#3 has an area in the northwest section of which has soil wetness issues (i.e. <12"
V' to seasonal high water table) this was noted and not corrected during the last permitting project
which occurred in 2014;there is also a stream which may or may not be intermittent. If this feature
is buffered as a stream on the northern most area it will remove the area with unsuitable depth to
soil wetness and address the stream question. Request a revised site map showing the northern
most area of this feature being buffered out.
Field #4 has two wells present which are not shown on the site maps. Request revised site maps
showing the two wells and buffers.
/ CH-98: Field#5 has a large new field section which was not previously permitted. The back half
of the new area is unsuitable due to depth to bedrock and numerous rock outcrops. Request a
revised site map showing this area buffered from land application. There were numerous rock
outcrops adjacent or in the field area which were not shown on the site map. The revised site map
should include these features and associated buffers. Revised acreage is required.
/ Field #6 has a large new field section which was not previously permitted. The entire proposed
new area was found to be unsuitable for land application due to an unsuitable depth to seasonal
Page 3 of 4

•
high water table and depth to bedrock. Request a revised sit map removing this entire area and
updating the acreage as result.
j CS-36:Field#12 has a new residence that has been constructed across the road which is not shown
on the site maps. Request a revised site map showing the residence and buffers. Revised acreage
will result.
The soils for this site have been updated to the Frogsboro soil series.NOTE: there is currently no
RYE value for PAN for this soil series. The soil properties of the Frogsboro series is similar to the
Enon soil series. Therefore, this office recommends utilizing the PAN loading of Enon until
NCSU establishes RYE for the new soil series.
CS-113: Field #5 was found to have the Vance soil series as the predominant soil present, and
NOT Pacolet as currently listed. The new Attachment B should reflect this change.
/ CS-117: Field#1 is missing the Landowner Agreement form. Request this be submitted.
OR-79: The site maps submitted for this site are not representative and accurate.These maps have
not been updated as required. Request updated site maps for the entire site, and updated acreages.
Below are some details of note.
Field#1 has a drain present which is not shown on the site map.Request a revised site map showing
this feature and the associated buffers.Need revised acreage as result.
Field #6 had no land application site map and no soils map included in the application package.
Request these missing maps be submitted.
There is a house that is shown on the site map to the south which is no longer present at the site.
If desired, a revised site map with this house and buffer being removed can be submitted. Revised
acreage would also be required.
The above described items have been verbally requested of the Permittee,but not to the Permittee's
consultant (EMA). The buffers, features, parcel boundaries, etc. of the remaining reviewed
acreage were found to be accurately depicted in the submitted report. Various soil hand auger
borings were placed on sites reviewed(see field notes and field maps in file for details).
Due to access restrictions and/or time constraints the following sites were not visited as part of
this review: AM-02,AM-05, AM-07,AM-08,AM-14,AM-15,AM-16, AM-18,AM-35,AM-55,
AM-98, AM-100,AM-125, CH-95, and OR-22.
The proposed increase in annual dry tons for Eastside WWTP should be ok. It appears that the
proposed land application site acreage will accommodate the anticipated PAN/year.
Please let me know if you need additional information or have any questions.
Page 4 of 4

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• State of North Carolina
Department of Environmental Quality
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
Division of Water Resources NON-DISCHARGE APPLICATION REVIEW REQUEST FORM
NC Department of
January 23, 2017 • Environmental Quality
Received
To: varimprespormiiirmagirsia JAN 2 5 2017
From: Troy Doby, Water Quality Permitting Section-Non-Discharge Permitting Unit Winston-Salem
Regional Office
Permit Number: WQ0000520 Permit Type: Land Application of Residual Solids(503)
Applicant: City of Burlington Project Type: Renewal
Owner Type: Murjcipal Owner in BIMS?Yes
Facility Name: City of Burlington RLAP Facility in BIMS?Yes
Signature Authority: Shane Fletcher Title: Residuals Management Coordinator
Address: Post Office Box 1358, Burlington,North Carolina 27216 County: Alamance
Fee Category: Non-Discharge Major Fee Amount: $0
Comments/Other Information:
Attached, you will find all information submitted in support of the above-referenced application for your review,
comment,and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: f..1 4- r i c 1 ► ' e
Date:
FORM: WQROSNDARR 09-15 Page 1 of 1