WQ0037135_Staff Report_20181126

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.: WQ0037135
Attn: Troy.Dobygncdenr.gov Facility name: Southern Soil Builders RLAP
County: Wilkes
From: [e-mail]
Mooresville Regional Office
Note: This form has been adapted from the non-discharge fg acili , 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:NA. But 11-26-18 phone conversations with Troy Dob(CO)and Bill Trudnak(Dallas
WWTP)to address concerns of acreage removal from the Dallas program. Mr. Trudnak discussed with Zach
Key and relayed to MRO,there were no concerns and Dallas WWTP would have adequate land for their
program.
b. Site visit conducted by: NA
c. Inspection report attached? ❑ Yes or®No,NA
d. Person contacted: See comments under La. above. Otherwise,typical contact would be the permittee,Dennis
Key: (336)957 -7878 ext.
e. Driving directions: NA. This is a regional permit. Directions will vary for source facilities and field sites.
2. Discharge Point(s): NA—this is a non-discharge permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Sub-basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
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:
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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)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program(POTWs only):
III.EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge(ORCs)for the facility?®Yes❑No❑N/A;The permittee
will also be the ORCs—Dennis Key&Zach Key.
ORC: Dennis Key Certificate#: LA 15704 Backup ORC: Zach Key Certificate#: LA 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:
Description of existing facilities: This is a Regional Land Application Permit with a modification to add the
Belmont WWTP(an existingf acilitx) as a source and transfer exiting land from the Town of Dallas permit
#WQ0020912.
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.) Discussed concerns over transfer of land from the Dallas permit as it reduces their fields from 6 to 2;
land owners from 2 to I and net acreage from 145.6 to 56.6. Phone discussions were with Troy Doby(CO) and
Bill Trudnak(Town o Dallas
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:
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.
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9. Is the description of the facilities as written in the existing permit correct? ® Yes or❑No
If no,please explain: Existing fields were not visited for this report. Site conditions change; so, setbacks are to
be determined at the time of application. Buffer maps are ONLY a guide.
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
O l lI O I II
O / // O / //
O l 11 O I //
O l 11 O / 11
O l 11 O / //
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: NA -Analytical data is not required by this permit.
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:
16. Possible toxic impacts to surface waters: Yes, for an,, l�pplication activity if not managed properly.
17. Pretreatment Program(POTWs only):
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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 the NPDES Unit or Non-Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
Statement from Southern
Soil Builders, showing the
reduction in acreage from For reasons stated in III.2. As the ORC for the Dallas program, it is best they
the Dallas permit will NOT submit something in writing.
adversely affect their
RLAP program.
Updated procedural forms Southern Soil Builders needs updated forms for their O&M and sampling plans
(these are just minor edits) to reflect appropriate Regional Office,local County contacts, etc.
Resubmit Map Missing note about the compliance and review boundaries. Reference the map
submitted with the Dallas WQ0020912 renewal in 2017.
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: Maria Schutte Do Signed-
Signature of regional supervisor: �,4", H P444" 11/27/18
Date: 11/26/2018 F161 FB69A2D84A3...
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T. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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