WQ0011413_Staff Report_20191210

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: (WQ0011413)
Attn: (Poonam Giri) Facility name: Odom Correctional Facility
RLAP
Northampton County
From: (Gary Kreiser)
Choose an item. 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: 12/06/2019
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):
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:
Il. 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:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 5

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
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:
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.)
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.
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:
FORM: WQROSSR 04-14 Page 2 of 5

11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessarv):
Monitoring Well
Latitude
Longitude
o , Ff
O I 11
O 1 „
D / 11
ff
O l II
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:
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
❑ 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.)
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:
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 5

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
Seasonal application
restrictions for Tract A and
B
Depth to seasonal high water table. See summary for more details
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 regional supervisor:
Date: Al- 41W11-
FORM: WQROSSR 04-14 Page 4 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
A site visit was performed on 12/6/19. The last site inspection noted that Field B appeared wet. Tract B is a mature pine plantation
with multiple lanes cut for access for the equipment to apply the residuals. The typical conditions of these lanes were rutted, with
standing water and some hydrophytic vegetation. On the day of inspection, the lanes had recently been mowed and had no tall
vegetation. Soil borings were performed outside of these lanes and place throughout the area. Overall, the soils had at least twelve
inches to seasonal high water table. The actual land application area is typically free of ruts and standing water and appears to be
overall suitable for land application. However, the lanes where the equipment is driven could become unusable during wet conditions.
Rehabilitation of these lanes was discussed. Previous version of this permit had a seasonal restriction for this tract. The ORC was still
operating under these conditions even though the current permit does not mention them. It is recommended that a seasonal restriction
be put in again for this tract. Land application should only occur from April to November because of the conditions of the lanes where
the equipment is operated.
Tract A was also inspected. Because Tract A is in a flood zone anything that is applied here would need to be incorporated. Tract A
has never been used for land application. Tract B is the only area were application has occurred. Soil borings were performed in this
area. The soil borings indicated a shallow depth to seasonal high water table. At time of inspection there was no free water in the
boring hole. Tract A is vegetated with junus, briars, and other small brush. There should be a seasonal restriction for this tract as
well. Application should only occur when there is evidence that there is not water within 12 inches of depth of residuals. Application
should be limited to only to the months when the SHWT would most likely be the deepest ( i.e. June, July, August).
Tract C has not been used previously for land application, but could be used without seasonal restrictions and would be a good
alternative to use instead of Tract B.
FORM: WQROSSR 04-14 Page 5 of 5