WQ0002378_Staff Report_20210126

,s 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.: (WQ0002378)
Attn: (Erick Saunders) Facility name: Mooresville Rocky River WWTP Monofill
From: (Edward Watson)
Mooresville Reaional Office
Note: This form has been adapted from the non -discharge facili . 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: 11/16/2020
b. Site visit conducted by: Inspection report attached? ❑ Yes or ® No, available in BIMSILF
c. Person contacted: Jamie Levis and his contact information: (104) 662 - 8341 ext.
e. Driving directions:
2. Discharge Point(s): N/A
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: Jamie Levis Certificate #: WW-41994871 Backup ORC: Larry Hendren Certificate 9:1008714
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: This is a closed Surface Disposal Monofill. Current material is being removed
from the Monofill cells and being hauled to a local landfill for permanent disposal. Removal activities occur
during winter months when city road crews are less busy with road maintenance issues.
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.)
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: Nitrates have been identified in GW associated with the monofill and the Town has
FORM: WQROSSR 04-14 Page 1 of 3

completed a CSA. N11?0 staff do not see a clear indication of what may be the cause of the elevated nitrates in
MW-7 located away from the monofill.
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: N/A no application occurs associated with this permit.
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:
10. Were monitoring wells properly constructed and located? ❑ Yes ® No ❑ N/A
If no, please explain: It appears that well MW-7 may have well construction issues due to historic elevated
turbidity values, it's not clear if the turbidity and elevated nitrates in this well are linked or not.
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 I II
C I II
O I II
C I II
O I II
C I II
O I II
C I II
O I II
C I II
12. 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: Provide input to help the permit writer evaluate any
requests for reduced monitoring, if applicable. See #3 above and #14 below
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
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
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? In general, the wells located around the
monofill appear to have defined the vertical and horizontal extent of the nitrate plume. However, conditions at
offsite well sentinel well MW-7 indicate there are well construction concerns with this well. Also, the presence of
elevated nitrates around this well indicate the need for additional assessment.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain: The MRO feels additional assessment is needed to determine the nitrate source around
offsite well MW-7.
Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes, please explain:
FORM: WQROSSR 04-14 Page 2 of 3

15. Possible toxic impacts to surface waters: N/A
REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
IV.5 Monitoring and
Reporting Requirements
Please remove the ambient air requirement for methane sampling as stipulated
in Section IV Monitoring and Reporting Requirement Item 5. All prior
sampling events have reported no methane present in the ambient air samples
and residuals in the monofill trenches are quite old, which would significantly
reduce any potential methane release.
3. 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: )
4. Signature of report preparer: Edward Watson 1-26-2021.
[DocuSigned by:
A444tW H P441114
5. Signature of regional supervisor: F161FB69A2D84A3... Date:
6. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
1.26.21
The NIRO will be directing the permittee to hire a contractor to evaluate the source of elevated nitrates in MW-7.
It is suspected there may be an unknown source of Nutrients such as buried animal ponds or septic system flow
that has been previously unknown from past land use activities.
FORM: WQROSSR 04-14 Page 3 of 3