WQ0003992_Staff Report_20201007

DocuSign Envelope ID: 3B2F6227-9BD7-4CA3-AC6C-772D5B70C879
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October 7, 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.: W00003992
Attn: Ranveer Kates Facility name: Town of West Jefferson 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 most recent site visit: March 26, 2019
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑ Yes or ® No
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
ORC: Brandon Patrick Certificate #:LA-1003070 Backup ORC: Nicholas Walters Certificate #:LA-1007912
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. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
Note: As long as the setback waiver is recorded at register of deeds.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
12. Has a review of all self -monitoring data been conducted (e.g., Annual Report)? ® Yes or ❑ No
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
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
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
FORM: WQROSSR 04-14 Page 1 of 2

DocuSign Envelope ID: 3B2F6227-9BD7-4CA3-AC6C-772D5B70C879
15. 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 acreages on RLAP
The total acreage does not include the increase in acreage gained by reducing
form
the residental setback. See item #3 in Section IV. below.
Register of Deeds recorded
The setback waiver has been notarized but it is unclear if it has been recorded at
setback waiver form.
register of deeds.
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 supervi
Date: October 7, 2020
gate reasons: )
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Loti —C 15.A ltr
A review of the subject application for permit modification has been completed. The subject modification to add field
area by reducing the setback from a neighboring residence was previously reviewed and approved by the Division.
Also, the site was reviewed on March 26, 2019 during the most recent permit renewal. Therefore, no site visit was made
as part of this review. Below is a summary of notes from review of the application, including items that may warrant
additional information to be requested.
1. It appears this application included two modifications (reduced setback and renaming one of the sites). Site AP-1
has been renamed to DP-2. This site is now owned by Dennis Pennington; signed LOA form included. OK.
2. The area originally approved by the Division for DP-2 (formerly named AP-1) is 10.53 acres. The proposed new
acreage is 10.53 acres. By reducing the setback to the neighboring residence, the full field area can be utilized again.
3. The new total acreage for this permit should be 27.98 acres, but the application listed 26.56 acres (no increase). The
correct new acreage total should be 27.98 acres. Request a revised RLAP application form with the correct new
total acreage.
4. It is unclear if the setback waiver provided in the application has been recorded at the Ashe County Register of
Deeds. Request copy of recordation of setback waiver with register or deeds. If unable to produce a recorded
copy from register of deeds, the only modification that should occur is the name change (AP-1 to DP-2).
FORM: WQROSSR 04-14 Page 2 of 2