WQ0011869_Staff Report_20191112

Dow& n Envelope ID: 08EF75F5-A9AF-4033-AA9D-B600BA8713D5
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Erik Saunders
From: Geoff Kegley
Wilminp,ton Regional Office
November 7, 2019
Application No.: WQ0011869
Facility name: CFPUA DCAR
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:
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: and their contact information: ext.
e. Driving directions:
2. Discharge Point(s): N/A
Latitude:
Latitude:
Longitude:
Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS: N/A
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
ORC: Certificate #: Backup ORC: Certificate #:
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: Distribution of Class A residuals.
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:
FORM: WQROSSR 04-14 Page 1 of 4

DocuSign Envelope ID: 08EF75F5-A9AF-4033-AA9D-B600BA8713D5
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:
Is the residuals O&M 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.
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:
I t . 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 / //
O / //
O / //
O I 11
O / //
O I 11
O / //
O / //
O / //
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: 2018 Annual report was compliant.
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: none
17. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 2 of 4

DocuSign Envelope ID: 08EF75F5-A9AF-4033-AA9D-B600BA8713D5
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: ) r—DocuSigned by:
0
Signature of report preparer:
Signature of regional supervisor:
Date: 11/12/2019
C
—001=515MB417...
h6a'Ua. San.
—E3ABA14AC7DC434...
FORM: WQROSSR 04-14 Page 3 of 4

DocuSign Envelope ID: 08EF75F5-A9AF-4033-AA9D-B600BA8713D5
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This review was conducted for a request by the Cape Fear Public Utilities (CFPUA) to renew and modify
their distribution of Class A residuals permit. The modification is to delete three sources (NC0023965,
NC0023973, and NC0039527). The maximum dry tons per year remaining will be 3,480 from the Sweeney
WTP — NC0002879. The residuals analysis indicate metals are below ceiling concentration limits and
TCLP results demonstrate residuals are non -hazardous. In 2018, no Class A residuals were distributed.
It should be noted that the CFPUA derives the majority of its water supply from the Cape Fear River
and the Cape Fear River has been documented as containing Per and Polyfluoroalkyl Substances
(PFAS). The CFPUA's water treatment plants and wastewater treatment plants are not designed to
completely remove these compounds. However, the rules and regulations that apply to residuals
(CFR 503 regulations and 15A NCAC 2T) do not address "emerging contaminants" (i.e. PFAs,
GenX, etc.).
FORM: WQROSSR 04-14 Page 4 of 4