WQ0016376_Staff Report_20200622

DocuSign Envelope ID: 4BC6E882-631 E-4CD5-8E4B-B833361 AF856
,s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Vivien Zhong
From: Bryan Lievre
Wilmington Regional Office
Application No.: WQ0016376
Facility name: S & J Villari Livestock WWTF
Note: This form has been adapted from the non -discharge facilily 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
a. Date of site visit: NA
b. Site visit conducted by:
c. Inspection report attached'? ❑ Yes or ® No
d. Person contacted:
and their contact information: ( ) - ext.
e. Driving directions: From Wilmington, take I-40 North to Exit 364. Turn right onto College Street and travel
approximately 025 miles. Turn left onto North Cross Street and travel two blocks. Turn left onto Penny
Branch Road and travel approximately 0.5 miles. Facility is on the North side of the road.
2. Discharge Point(s): N/A
3. Receiving stream or affected surface waters: N/A
FORM: WQROSSR 04-14 Page 1 of 5

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III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Gerald Matthews, Certificate #: SI-993131 Backup ORC: Matthew Jones, Certificate #:SI-993141
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: Surface irrigation treatment facility consisting of a solids separator, solids
collection area with leachate collection, 10,000 gallon storage tank, 2,000 gallon pump tank, a 3,650,428 gallon
lined facultative lagoon with 2 floating aerators, a 1.88 million gallon above -ground storage tank, a center pivot
irrigation system covering 20.56 acres and zones 14E & 14W, a solid set irrigation system covering 21.45 acres
with 13 zones, and another set of solid set irrigation zones (15-17,) covering 3.12 acres for a Total of 45.13 acres.
Proposed flow: 100,260 GPD
Current permitted flow: 100,260 GPD
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
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
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:
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10. Were monitoring wells properly constructed and located? ® Yes ❑ No ❑ N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
If no, please complete the following (expand table if necessary):
Monitoring Well
Latitude
Longitude
o
o
- 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:
We are aware of intermittent exceedances of nitrate in monitorine well MW-2 and intermittent exceedances of
ammonia in MW-9. We are closely following these results but violations have not been issued due to intermittent
exceedances, due to general decreasing trends and other factors.
Historically, e.g. circa 2016) the ORC was using old forms (and therefore not providing all information as
required on new forms) this has been corrected and with the exception of some late submittals and the above
mentioned exceedances, no noteworthy issues have been encountered.
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:
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:
Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes, please explain:
Possible toxic impacts to surface waters:
14. Pretreatment Program (POTWs only):
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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:
Item Reason
See Section V
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 (P�,�;,, Wasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date: 6/22/2020
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Permit W00016376 was issued January 3, 2020. On January 31, 2020, Cavanaugh & Associates, P.A., submitted three requests for
modifications to the permit within an email from Jeffrey Cappadona to Ashley Kabat. In correspondence dated April 7, 2020,
Cavanaugh & Associates, P.A., included as an attachment an updated water balance. Provided below are each of the issues brought up
by Cavanaugh from their 1/30/3020 email as well as our responses:
Issue 1
Cavanaugh Comment: The hourly rates in Attachment B should be 0.6 in/hr for most zones, rather than 0.34 in/hr. This dates back to
the same error that happened in 2013, see attached email and the revised PDF ("NCDENR WWIS Permit Revision Approval (Dated
2013-7-26) (TR).pdf I) that we received at that time.
WiRO Response: Changing each of the zones to 0.6 in/hr seems to be in keeping with prior permit limits (and associated amended
permit limits)
Issue 2
Cavanaugh Comment: In Attachment C, the new permit shows "Nitrogen, Ammonia Total (as N)" as 1.5 mg/L, whereas the old
permit had 1,500 mg/L. We would like this changed back to 1,500 mg/L as it's shown in the previously approved permit (see attached
"NCDENR WWIS Permit Approval (Dated 2013-5-17) (With Notes) (TR).pdf').
WiRO Response: It is our opinion that the Nitrogen limit should be kept at 1.5 mg/L as noted on the 1/3/2020 permit. The limit of
1500 mg/L Nitrogen limit established on the prior permit, dated 5/17/13 was most likely an error and does not seem to be in keeping
with 2L Standards of 1 mg/L for Nitrate and 10 mg/L for Nitrate. The limit of 1500 mg/L for Nitrogen would also not enable one to
identify an exceedance of 2L standards.
Issue 3
Cavanaugh Comment: Villari has informed us that the sprinklers in Zone 1 and one sprinkler in Zone 2 should be shown as full -
circles, rather than semi -circles, so I'm asking whether we can send updated information to incorporate those adjustments with this
approved permit, or whether it needs to be done as a separate permit modification.
WiRO Response: Although we do not necessarily have any issues with the water balance study, we would have issue with increasing
the radial influence of Zone 1 irrigation heads and to a lesser extent the easternmost spray head for Zone 2. A map was provided on
the last page of the 1/3/2020 permit which illustrated the radial influence of each of the spray heads for each zone. Extrapolating the
radial influence for Zone 1 spray heads and the easternmost spray head for Zone 2 would indicate that spraying is occurring on an un-
vegetated and likely more densely packed dirt access road. Irrigating in these areas would likely result in ponding or runoff and seem
to be in violation of 15A NCAC 2T .0507 (b), (c), and (e). We believe that the spray heads in these areas need to be adjusted to
coincide with the radial influences as depicted on the map provided with the permit or additional reasoning to justify their increases
while maintaining compliance with 15A NCAC 2T. We would also like to see an updated site map, similar to the map provided in the
12/3/2020 permit with the radial zones clearly depicted.
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