WQ0001861_Staff Report_20191028

Dow& n Envelope ID: 9F697583-D80E-424F-A303-3260C287D2F6
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
October 28, 2019
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Poonam Giri, Water Quality Permitting Section
From: Geoff Kegley
Wilminp,ton Regional Office
Application No.: WQ0001861
Facility name: Gregory Poole Equipment Company
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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 10/22/2019
b. Site visit conducted by: Geoff Kegley
c. Inspection report attached? ❑ Yes or ® No -See BIMS/Laserfiche
d. Person contacted: Ronald Vaughn and their contact information: [phone] ext.
e. Driving directions: Hwy 17 in Leland to Gregory Rd to 151 Backhoe Road NE, Leland, NC 28451.
2. Are the tfeatmeat f4eilities
for- the type
disposal
system? E] Yes or- E] No
fiew adequate
of
waste a -Rd
3. Afe depth to
table,
the
D Yes E] No
site eendifiens (soils,
wa4ef ete) eensisteal
with
stibmitted r-epet4s?
ifno, please e�plaiw:
4. Do the
the
lines,
ells, ete.)? [Z—] Yes E] No
plans and site Fnap r-epFesen4
aetual site (pr-epeAy
if no, please explain.: —
5. is the -esid
ao,,.
n Yes n No
n N/A
proposed all management
if
plan
ne, please explain:
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e
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
ORC: Backup ORC:
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: As described in permit W00001861
Proposed flow: n/a
Current permitted flow: 10,000 GPD
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.) Holding pond has not been in use in many years and according to the operations staff is disconnected and is
not needed. Pond appears in need of maintenance if it is put back in service (vegetative ,growth inside berms.
Freeboard marker is in place and records are being maintained. If this pond is in fact unnecessary for operations
at the facility. it is recommended that the Dond be Dronerly closed out and a hermit modification reauest is anDlied
for to remove it from the permit.
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 ® N/A
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.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
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DocuSign Envelope ID: 9F697583-D80E-424F-A303-3260C287D2F6
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 l lI
O I II
O / //
O / //
O l 11
O / //
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: The groundwater monitoring well sampling data
is being submitted and no exceedances of the standards have been reported. However, the reporting of Total
Dissolved Solids (TDS) on the GW-59 form is being ported in micrograms per Liter (ug/L) and the form
calls for milligrams per Liter (mg/L). Data entry staff are entering the values reported as mg/L and therefore
triggering limit violations in BIMS. This reporting issue was discussed during the inspection and in follow-
up correspondence.
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? Refer to question 12.
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: ,
17. D,-ot,-e tm e t D,-.,.,-.-.,m (120TA's ....ly
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DocuSign Envelope ID: 9F697583-D80E-424F-A303-3260C287D2F6
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
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: ) /­DocuSigned by:
6. Signature of report preparer:
Signature of regional supervisor:
Date: 10/28/2019
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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—0017E2515D3B417...
FORM: WQROSSR 04-14 Page 4 of 4