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HomeMy WebLinkAboutWQ0001800_Staff Report_20210928DWR Division of Water Resources State of North Carolina Department of Environmental Quality Division of Water Resources WATER QUALITY REGIONAL OPERATIONS SECTION NON -DISCHARGE APPLICATION REVIEW REQUEST FORM September 8, 2021 To: WSRO-WQROS: Lon Snider / Jenny Graznak From: Erick Saunders, Water Quality Permitting Section - Non -Discharge Branch Permit Number: WQ0001800 Permit Type: Land Application of Residual Solids (503) Applicant: Town of Yadkinville Project Type: Renewal with Major Modification Owner Type: Municipal Owner in BIMS? Yes Facility Name: Town of Yadkinville RLAP Facility in BIMS? Yes Signature Authority: Jacob Swaim Title: Public Works Director Address: PO Box 816, Yadkinville, NC 27055 County: Yadkin Fee Category: Non -Discharge Minor Fee Amount: $245 - Major Modification Comments/Other Information: jswaim@yadkinville.org; afox@synagro.com Attached, you will find all information submitted in support of the above -referenced application for your review, comment, and/or action. Within 45 calendar days, please take the following actions: ® Return this form completed. ❑ Attach an Attachment B for Certification. ❑ Return a completed staff report. Issue an Attachment B Certification. When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and return it to the appropriate Central Office Water Quality Permitting Section contact person listed above. DocuSignedOD0949by: atitt- it RO-WQROS Reviewer: L{34O6 P 6-1-99B49D._. Date: 9/27/2021 FORM: WQROSNDARR 09-15 Page 1 of 1 XigIEC:V? State of North Carolina Division of Water Resources Water Quality Regional Operations Section Staff Report Date 9/27/2021 To: DWR Central Office — WQ, Non -Discharge Unit Application No.: WQ0001800 Attn: Erick Saunders Facility name: Yadkinville RLAP 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: 9/21/2021 b. Site visit conducted by: Caitlin Caudle c. Inspection report attached? n Yes or ® No d. Person contacted: Alex Fox and their contact information: (704) 881 — 3429 II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ® No ❑ N/A One of the listed ORCs has an invalid license and Mr. Fox is not the designated ORC. 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.)? n Yes or ® No Two houses have been built around YK-35-1, but setback waivers have been acquired. Submitted maps will have to be updated to reflect the new dwellings. 5. Is the residuals management plan adequate? ® Yes or n No 6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or n 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? I 1 Yes or ® No 9. Is the description of the facilities as written in the existing permit correct? ® Yes or n 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 n No Please summarize any findings resulting from this review: The previous annual report showed that the Yadkinville WWTP produced more residuals than permitted, and the lab used had a detection limit higher than the regulatory limit. 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 FORM: WQROSSR 04-14 Page 1 of 3 14. Check all that apply: ❑ No compliance issues ® Notice(s) of violation ❑ Current enforcement action(s) ❑ Currently under JOC ❑ Currently under SOC ❑ Currently under moratorium Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) An NOV was issued this calendar year in relation to the annual report (attached). 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 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: Item Reason Updated site map for YK- 35 New houses have been built within 500 ft of this field, setback waivers have been acquired. Updated topographic map for YK-29-2 The application area on the topographic map does not represent the application area. Updated application map for YK-33-4 A field ditch is present on the south side of the access road. A 25 ft buffer needs to be shown on the application map. Clarification on the requested dry tonnage for Yadkinville WTP The residuals source certification form states that the desired tonnage is 250 tons and the justification states 150 tons. Operator designation Mr. Fox works for a contract application company. The ORC in BIMS has an invalid license. Mr. Fox has not been designated as the ORC. 3. List specific permit conditions recommended to be removed from the permit when issued: Condition Reason I.2 This condition has been satisfied. I.3 This condition has been satisfied. 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 n Issue n Deny (Please state reasons: )—DocuSigned by: 6. Signature of report preparers DocuSigned by: (tla,D �� ?• S��dt�—8B834968199D49D... Signature of regional supervisor: Date: 9/28/2021 145B49E225C94EA... FORM: WQROSSR 04-14 Page 2 of 3 IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS A stie visit was completed on September 21, 2021. A review of the residuals source generating facility was not completed as there was no change in the facility, other than an increase in the permitted dry tonnage for the Yadkinville WTP. The new fields were reviewed. Mr. Alex Fox of Synagro was present. A soil boring was not done in YK-33-4 as soybeans were standing in the field. The compliance inspector will need to review this field in more detail before the first application on this field. A soil boring was done in YK-29-2 but auger refusal was met at —15 inches due to large gravel. The soil boring was downslope of the soil scientists soil boring. The application field appears to have been graded at some point as it is close to the WWTP. The soil descriptions provided by the soil scientist are similar to the designated soil series. Only one map unit was present in most of the application areas for both fields and there were no limiting slopes or landscape features that would suggest a different soil series. If all application rates are around 100 lb/ac PAN, the 95 permitted acres will be sufficient to sustain the residuals program. Field YK-08-6A and Field YK-08-6B need to be combined into a single field labeled YK-08-6 as set back waivers from property lines have been obtained. The application map included in the application depicts that change. FORM: WQROSSR 04-14 Page 3 of 3 Compliance Inspection Report Permit: WQ0001800 Effective: 09/10/20 Expiration: 02/28/22 Owner : Town of Yadkinville SOC: Effective: Expiration: Facility: Town of Yadkinville RLAP County: Yadkin 1620 Fred Hinshaw Rd Region: Winston-Salem Contact Person: Grant Trivette Directions to Facility: Yadkinville NC 27055 Title: Phone: 336-679-2184 System Classifications: LA, Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0020338 Town of Yadkinville - Yadkinville WWTP Inspection Date: 09/21/2021 Entry Time 11:OOAM Exit Time: 11:50AM Primary Inspector: Caitlin Caudle Phone: 336-776-9699 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Reconnaissance Permit Inspection Type: Land Application of Residual Solids (503) Facility Status: ❑ Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Land Application Site (See attachment summary) Page 1 of 3 Permit: WQ0001800 Owner - Facility:Town of Yadkinville Inspection Date: 09/21/2021 Inspection Type : Reconnaissance Reason for Visit: Routine Inspection Summary: A stie visit was completed on September 21, 2021. A review of the residuals source generating facility was not completed as there was no change in the facility, other than an increase in the permitted dry tonnage for the Yadkinville WTP. The new fields were reviewed. Mr. Alex Fox of Synagro was present. A soil boring was not done in YK-33-4 as soybeans were standing in the field. The compliance inspector will need to review this field in more detail before the first application on this field. A soil boring was done in YK-29-2 but auger refusal was met at —15 inches due to large gravel. The soil boring was downslope of the soil scientists soil boring. The application field appears to have been graded at some point as it is close to the WWTP. The soil descriptions provided by the soil scientist are similar to the designated soil series. Only one map unit was present in most of the application areas for both fields and there were no limiting slopes or landscape features that would suggest a different soil series. If all application rates are around 100 Ib/ac PAN, the 95 permitted acres will be sufficient to sustain the residuals program. Field YK-08-6A and Field YK-08-6B need to be combined into a single field labeled YK 08-6 as set back waivers from property lines have been obtained. The application map included in the application depicts that change. Additional comments are in the staff report. Page 2 of 3 Permit: WQ0001800 Owner - Facility:Town of Yadkinville Inspection Date: 09/21/2021 Inspection Type : Reconnaissance Reason for Visit: Routine Type Distribution and Marketing Land Application Land Application Site Is a copy of the permit on -site during application events? Is the application site in overall good condition? Is the site free of runoff/ponding? If present, is the application equipment in good operating condition? Are buffers being maintained? Are limiting slopes buffered? 10% for surface application 18% for subsurface application Are there access restrictions and/or signs? Is the application site free of odors or vectors? Have performance requirements for application method been met? For injection? For incorporation? Does permit require monitoring wells? Have required MWs been installed? Are MWs properly located w/ respect to RB and CB? Are MWs properly constructed (including screened interval)? Is the surrounding area served by public water? If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted? Are soil types consistent w/ Soil Scientist report/evaluation? Is the water table greater than 173' bls. Is application occurring at the time of the inspection? Comment: Yes No NA NE ❑ Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page 3 of 3 ROY COOPER. Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality July 23, 2021 CERTIFIED MAIL 7020 1810 0001 2075 0112 RETURN RECEIPT REQUESTED Mr. Jacob Swaim, Director of Public Works Town of Yadkinville P.O. Box 816 Yadkinville, NC 27055 SUBJECT: Notice of Violation (NOV-2021-PC-0359) Town of Yadkinville, Residuals Land Application Program Permit No. WQ0001800 Yadkin County Dear Mr. Swaim: The Division of Water Resources (DWR) acknowledges receipt of your 2020 Annual Report for the subject permit. A review of this report was conducted by DWR staff person Jim Gonsiewski. The following violations were noted from the review: 1. Attachment A of the permit states that the maximum dry tons to be land applied annually from the Yadkinville WTP is 30 dry tons. A total of 78.73 dry tons from the Yadkinville were distributed in 2020. This is an exceedance of 48.73 dry tons for the year. If you anticipate this condition occurring again, this office recommends that you apply for a permit modification to increase the permit limit. 2. Additionally, two constituents listed in the TCLP analysis for the WWTP were run with detection limits above the regulatory level. Chlordane had a reporting detection limit (RL) of 0.125 mg/L. The regulatory level is 0.03 mg/L. Heptachlor had a RL of 0.0125 mg/L. The regulatory level is 0.008 mg/L. In the future, please ensure that the laboratory analyzes the samples with detection limits at or below the regulatory levels. Please provide a response to this letter within 30 days of receipt by your office indicating the corrective actions taken to address these deficiencies. If these violations occur again, a Notice of Violation/Notice of Intent may be issued. NORTH D E n.o.rtm.m of ln.im.mo.t.i Ou.i` North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 If you or your staff have any questions concerning this letter, please contact me or Jim Gonsiewski at (336) 776-9800 or via email at jim.gonsiewski@ncdenr.gov. Sincerely, DocuSigned by: < mdu- 145B49E225C94EA... Lon T. Snider Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ — WSRO encl: Compliance Inspection Report cc: Yadkin County Environmental Health (Electronic Copy) Alex Fox— Synagro (Electronic Copy) WSRO Electronic Files Laserfiche Files LD_E NORTH CAROLINA gapartmeM of Environmental quaky North Carolina Department of Environmental Quality j Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 Q oo VAVA/oa --�_-- ------ �{ : it boc( o: I t : Lcock owv\eitf Ao\rvti doe-y) 0/6,-1-uvk v\doliovq_iv- sir I- Isla- eu 11-ctLek-Ack--vv\S Cjal 6v\1-C rnck-P wiadd ?aild \v„_ a N hka6r maYie s 0 a 1 I Se id1Wci icY1 lips Y1,Lw viou.a e i i I I ct ityla - 6 - - h ho (,KiX e -AC td I've euut ed -.on l , n o if or to ©i'eld j 750 DA C W -\\-h r G6--,\ ,VD t x� 8 APPLICATION UON MAP The compliance boundary isestablished at either 2SOfeet from the residuals application area nr5Ofeet within the property boundary, whichever |sclosest tmthe application area. The review boundary ioestablished midway between the compliance boundary and the perimeter nfthe residuals application area. All locations are approximate. Legend | -Streams 0 soil A A A App||ootionAme 0.15 Miles / I ^ i / I / | ~~Property Boundary Onsite � offsite A well Residentiall Property Line Buffer & Unsuitable Area ���- � ���� ���~z~~r Field-2 APPLICATION MAP The compliance boundary is established at either 250 feet from the residuals application area or 50 feet within the property boundary, whichever is closest to the application area. The review boundary is established midway between the compliance boundary and the perimeter of the residuals application area. 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