WQ0028806_Staff Report_20210217

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February 17, 2021
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Vivien Zohng
From: Patrick Mitchell
Winston-Salem Regional Office
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
Application No.: W00028806
Facility name: Davie County DCAR Program
Note: This form has been adapted from the non-discharee facility staff report to document the review ofboth nondlscharee and NPDES permit applications and/or renewals. Pease 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: February 16, 2021
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Brent Collins (EMA)
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
If no, explain: The proposal is for use of a sludge holding basin at a domestic mixed use WWTP, not a WTP. It is
unknown if these residuals can meet Process to Further Reduce Pathogens and the Vector Attraction Reduction
requirements for biological residuals.
3. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ® No ❑ N/A
If no, please explain: The site map included in the application shows the Cooleemee WWTP which is not a WTP.
See the attached site map which has labels added showing the WTP in relation to the WWTP sludge basin which
is referenced in the application package.
4. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes ❑ No ® N/A
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
6. Is the residuals management plan adequate? ❑ Yes or ® No
If no, please explain: Again, the residuals in question are at a WWTP and not at a WTP.
7. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes ❑ No ® N/A
8. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
9. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
10. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
Note: However, the WTP description in the application package is not correct.
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
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13. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® 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
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
If yes, please explain: The gpplication falsely refers to the sludge basin as part of the WTP, but it is not a part of
the WTP. It is part of the WWTP and receives biological sludge from the WWTP. WTP sludge is mixed into this
WWTP basin.
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
Analytics for meeting Class
A limits for biological
residuals explanation
Because the WWTP sludge basin inlcuded in this applicaiton package is
for how thiss WWTP sludge
designed and utilized by the WWTP for storage of WWTP sludge and decant
basin contains only WTP
water from the digesters.
residuals.
Explain why the Residuals
Source Facility Summary
table in the RSC form
The Cooleemee WTP is currently not included in the Attachement A of this
indicates current permitted
permit.
dry tons as 279.
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
El
6. Signature of report preparer:
Signature of regional
Date: February 17, 2021
state reasons: )
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On February 16, 2021, WSRO staff made a site visit to the 3-million gallon residuals basin included in the subject
application package as a proposed WTP residuals source facility to be added to Permit No. WQ0028806. It should be
noted that this 3-million gallon residuals storage basin is part of the Cooleemee WWTP which is listed as a source in
Class B residuals land application Permit No. WQ0010583.
The cover letter included with this application indicated that "we are asking to have the Cooleemee WTP added as a
source" to the subject permit and "there are approx. 834 dry tons of material to clean out of the 3,000,000 gallon basin."
However, as mentioned above this 3-million gallon residuals storage basin is part of the Cooleemee WWTP and is not
part of the WTP. See the attached site map which originally showed the WWTP basin falsely listed as part of the WTP.
This site map has been modified to show the WTP and labels have been added.
The RSC application form indicated that the residuals are from treatment of potable water, that these residuals are
regulated under 40 CFR Part 257, non -biological. That these residuals are exempt from process to further reduce
pathogens and from vector attraction reduction requirements. However, as indicated above this basin is part of the
WWTP and is utilized for biological WWTP residuals storage and can be utilized for decant wastes off the WWTP
digesters.
The analytical data provided in the application suggests that the residuals meet metals, TCLP and fecal coliform limits
for Class A residuals. However, no data was provided on which 503 alternative method for further reducing pathogens
will be utilized to meet requirements. Also, no data was provided on which 503 method for meeting vector attraction
reduction will be utilized to meet requirements. Lastly, there was no explanation provided for how non -biological WTP
residuals are stored inside a residuals basin that is actively utilized by a biological WWTP. See attached diagram from
the WWTP operations system which shows the basin tied into the WWTP which is actively in use. These WWTP
biological residuals could potentially be added as a source to this permit, but we need the missing analytical data to
proceed. Otherwise, we would need some written statement from the WWTP which demonstrates that the
biological basin has been properly cleaned and isolated to prevent mix of WTP residuals with the WWTP
residuals and digester decant wastes.
In addition to the above, the Residuals Source Facility Summary table in the RSC form listed current maximum dry
tons per year as 279, but the Cooleemee WTP is currently not listed in the Permit Attachment A as a source facility.
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