WQ0000962_Staff Report_20210628

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

Date June 22, 2021

To: DWR Central Office WQ, Non-Discharge Unit Application No.: WQ0000962
Attn: Poonam Giri Facility name: Culp, Inc.

From: Caitlin Caudle
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.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: February 11, 2021
b. Site visit conducted by: Caitlin Caudle
c. Inspection report attached? Yes or No
d. Person contacted: Mark Creech and their contact information: (336) 485 - 2653
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, please explain:
Description of existing facilities:
Proposed flow:
Current permitted flow:
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.)
An earthen berm surrounds the secondary concrete containment structure. When this berm is full of rainwater or
down drift from the evaporator, a valve is turned to allow the mix of rainwater/effluent to drain from between the
earthen embankment and the concrete containment system. At the time of inspection there was not a well
established vegetative cover on the earthen berm.
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: N/A. Closed loop recycle system that uses an evaporator to dispose of effluent.
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. Closed loop recycle system that uses an evaporator to dispose of effluent.
FORM: WQROSSR 04-14 Page 1 of 3

7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program: The sampling parameters
may need to be reassessed based on split sampling results.See additional comments.
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:
been competed and can be removed from the permit description.
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):
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: There have been chronic historic exceedances of iron
and manganese in all wells, TDS in MW4, and occasional exceedances of pH in all wells.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
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?
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
III. 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:
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
I.1 Permit condition has been completed.
I.2 Permit condition has been completed.
I.3 Permit condition has been completed.
I.4 Permit condition has been completed.
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
FORM: WQROSSR 04-14 Page 2 of 3

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:
Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
An earthen berm surrounds the secondary concrete containment structure. This earthen berm has a drain on the inside
of the berm. The drain leads to an outlet on the other side of the berm that is controlled by a valve. Anything released
from the berm will eventually reach a small creek that flows past the evaporator. I am concerned that down drift from
the evaporator is comingling with stormwater that collects behind the berm and is then discharged to the creek.
Attached are the sampling results and a summary table of those results. The effluent monitoring parameters and
schedules may need to be reassessed as dissolved organic carbon, total organic carbon, and total residual chlorine are
the only effluent parameters sampled for once a year in November.

FORM: WQROSSR 04-14 Page 3 of 3