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Home My WebLink AboutWQ0001271_Staff Report_20191217DocuSign Envelope ID: 2CD06F3C-8875-42A0-A7E6-5593AA35C21 F DWR DFaision of Water Resources To: ❑ NPDES Unit ® Non -Discharge Unit Attn: Erick Saunders From: Bryan Lievre, Geoff Kegley Wilmington Regional Office State of North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Regional Operations Section Staff Report Application No.: W00001271 Facility Name: Cape Fear Public Utility Authority Note: This form has been adapted from the non -discharge f�ty staff report to document the review of both non - discharge and NPDES permit applications and/or renewals. Please complete all sections as they are !qpplicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? ❑ Yes or ® No 2. Discharge Point(s): N/A 3. Receiving stream or affected surface waters: N/A II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS: N/A 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: Robert N. Roth Certificate #: 1001672 Backup ORC: John A. Culp Certificate #: 1000733 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: Existing permit: 8,270 DT/yr on 2,964.97 permitted acres (not 2,156.97 permitted acres as identified on table in Attachment B in current permit) FORM: WQROSSR 04-14 Page 1 of 4 DocuSign Envelope ID: 2CD06F3C-8875-42A0-A7E6-5593AA35C21F 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: A. Removal of Walnut Hill WWTP as a source. B. Maximum da tonnage to be reduced from 8,270 da tons/year to 8,250 da tons/year C. Removal of 12 fields: NC-CO-16-01, NC-CO-16-03, NC-CO-19-05, NC-CO-19-06, NC-CO-28-01, NC-CO- 28-02, NC-CO-28-03, NC-CO-29-11, NC-CO-36-02, NC-PE-07-01, NC-PE-07-02 and NC-PE-07-03 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: I t . Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A If no, please complete the following (ex and table if necessary): Monitoring Well Latitude Longitude O / // O / II O / // O / If 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: Consistently compliant during this permit period, except for a 2/22/2016 site visit by WiRO staff when it was suspected that residuals were dumped and left on field NC-CO-15-03 for several months. A NOV was issued on 3/4/16 regarding the incident and a response was provided in correspondence, dated 3/28/2016, which provided additional information regarding the potential incident. Additional activities were reportedly_ placed into effect to prevent recurrences and no additional enforcement activities were deemed necessary. 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: FORM: WQROSSR 04-14 Page 2 of 4 DocuSign Envelope ID: 2CD06F3C-8875-42A0-A7E6-5593AA35C21F 16. Possible toxic impacts to surface waters: N/A 17. Pretreatment Program (POTWs only): N/A 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: 5 0 Condition Reason 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 ❑ Den j o Please state reasons: ) uSigned by: Signature of report preparer: B an 1 r. 2 DocuSi ned b : Signature of regional supervi 74249ABED37443E... Wn& S _u Date: 12 /17/2019 EMBAUAC7DC434 FORM: WQROSSR 04-14 Page 3 of 4 DocuSign Envelope ID: 2CD06F3C-8875-42A0-A7E6-5593AA35C21 F V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS This review was conducted for a request by the Cape Fear Public Utility Authority (CFPUA) to renew and modify their land application of residuals permit. The permit modification requests the removal of the Walnut Hill WWTP as a source, the renewal of 95 fields and the deletion of 12 fields with a corresponding decrease of maximum dry tonnage from 8,270 dry tons to 8,250 dry tons. The total net acreage to be permitted is 2,800.55 acres. Please note that the 2015 and 2019 permit applications listed field NC-PE-03-01 as having 28.70 acres; however, the 2016 Permit mistakenly listed the field at 26.50 acres. Also, please be advised that the total acreage in the field summary table in Attachment B for the 2016 Permit was incorrect and the current total should equal 2,800.55 acres. Copies of TCLP results for select compounds could not be located within the permit application. The missing parameters include: - m-Cresol - o-Cresol - p-Cresol - Cresol - Lindane - 2, 4, 6-Trichlorophenol In 2018, 3,519.50 total dry tons were land applied. This was well below the 8,270 dry tons/year previously permitted. In addition, Cape Fear Public Utility Authority will have 2,800.55 acres permitted while only 693.57 acres were utilized in 2018. Field loading rates for metals and PAN are being calculated, along with cumulative pollutant loading rates. The sludge analysis for the sources indicate metals are below ceiling concentration limits and sodium adsorption rates (SAR) results were below 10. Pathogen and vector attraction reduction requirements are being met. 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