WQ0032855_Staff Report_20220127 (2)

State of North Carolina
Department of Environmental Quality
Division of Water Resources

Water Quality Permitting
Regional Staff Report

FORM: APSRSR 04-10 Page 1 of 3
January 27, 2022

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0032855
Attn: Vivien Zhong Regional Login No.:

From: Mikal Willmer
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 11/24/2021 – Facility Inspection (NPDES). Field inspection not conducted yet due to
weather and scheduling conflicts.
b. Site visit conducted by: Mikal Willmer
c. Inspection report attached? Yes or No
d. Person contacted: Zack Key, SSB and their contact information: [phone]
e. Driving directions: From I-40E, take exit 85, stay on Hwy. 221 through the Town of Rutherfordton.
Approximately 0.5 mi outside city limits, turn left on gravel road to WWTP (just before intersection of
221 & Thunder Rd.)
II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)

DocuSign Envelope ID: BBB7EC08-8DE8-4F4A-9E14-22360163822D
FORM: APSRSR 04-10 Page 2 of 3
III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Dennis Key Certificate #:15704 Backup ORC: Zack Key Certificate #:27660
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:
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: No changes according to Land App firm. I am scheduled to visit the site next week
with US Biosolids to verify there have been no new wells or changes nearby the application fields.
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. See section V for details.
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:
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
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
12. Has a review of all self-monitoring data been conducted (e.g., NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review: Rutherfordton’s residuals were land applied under
US biosolids RLAP permit in 2020 due to ownership changes of the permitted fields. WWTP ORC reported
US Biosolids Land applied to the Town of Rutherfordton’s permitted fields in 2021. Historical annual
reports indicate no issues with Zinc and Copper concentrations in the soil fertility analyses. ESP is below
15.
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.)
DocuSign Envelope ID: BBB7EC08-8DE8-4F4A-9E14-22360163822D
FORM: APSRSR 04-10 Page 3 of 3
15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
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 Non-Discharge Central Office to obtain through an additional information
request:
Item Reason
Clarify in writing Land
Application Site
Information
Fields 10, 10A, 11, 12, 13, 14, 15 & 17 are coded as “N”; however, these fields
are the same previously permitted and no changes have been documented
according to US Biosolids.
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 (Please state reasons: )

6. Signature of report preparer:

Signature of WQROS regional supervisor:

Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The fields have changed ownership since the last permit renewal. Mr. Beam is now the owner of what was previously Henry
Edwards’ property. The application mistakenly has fields 10 through 17 listed as “N” for new. These fields should be listed as
“R” as US Biosolids indicates there have been no changes to the fields in this renewal. It appears Mr. Beam is now also owner
of the property/house the setback waiver was submitted for in 2016. It should be noted the ARO has been unable to visit the
fields since receiving the staff report request due to weather and scheduling conflicts for several weeks. Currently planned to
visit the application sites with US Biosolids next week barring additional delays.

DocuSign Envelope ID: BBB7EC08-8DE8-4F4A-9E14-22360163822D
1/27/2022