WQ0002376_Staff Report_20200219

DocuSign Envelope ID: 953911E5-978B-4936-8BO7-AAOBF02B9D34
February 19, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00002376
Attn: Ranveer Kates Facility name: City of Reidsville RLAP
From: Patrick Mitchell
Winston-Salem 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.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: February 7, 2020
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Brent Collins (EMA) and their contact information: (336) 751 - 1441
e. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
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
5. Do the plans and site maps represent the actual site (property lines, wells, etc.)? ❑ Yes ® No ❑ N/A
If no, please explain: See Section IV. Additional Regional Staff Review Items and attached site map sketches.
6. Is the residuals management plan adequate? ® Yes or ❑ No
7. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
8. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
9. Are there any setback conflicts for existing treatment, storage and disposal sites? ® Yes or ❑ No
If yes, attach maps: See Section IV. Additional Regional Staff Review Items and attached site map sketches.
10. For residuals, will seasonal or other restrictions be required? ❑ Yes ® No ❑ N/A
11. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
12. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
13. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
14. Has a review of all self -monitoring data been conducted? ® Yes or ❑ No
15. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
FORM: WQROSSR 04-14 Page 1 of 3

DocuSign Envelope ID: 953911E5-97813-4936-81307-AA013F02139D34
16. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
17. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
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
LOA Forms for two sites.
Sites RC-18 and RC-19 do not have signed LOA forms.
Explanation or revised
Sites RC-19 and RC-119 had significant increases in acreage with little or no
acreages for two sites.
change to maps. See Section IV. Additional Regional Staff Review Items for
more details on fields.
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
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
❑ DenX (Please state reasons: )
ocuSigned by:
Signature of report preparer: I-P .Jed_b
Signature of regional supervisor5548B6°°265°"A... L-41 "T t:)"it'
Date: February 19, 2020
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On February 7, 2020, WSRO staff conducted a reconnaissance review of many of the land application sites included in
the application. A number of the site maps were found to have application area boundaries that have been modified
from the previously approved maps. Below is a summary of notes from the site visits and from review of this application
package.
Note: The issues with the site map features was verbally discussed with the consulting contractor (i.e. Brent Collins of
EMA) during review. Mr. Collins electronically submitted revised site maps and a revised LASC on February 19, 2020.
A copy is being forwarded to CO. Items listed below still requiring additional information requests are bolded and
underlined.
1. Residuals analyses indicate regulatory limits are met (TCLP, Metals, Pathogen and Vector Attraction Reduction).
2. CPLRs reported for renewal land application sites appear to be below limits also.
3. There are two land application sites included in this application for renewal and modification in which they indicated
that they have not obtained Landowner Agreement forms (LOA) to date. Request these missing forms, and if they
do not provide them, recommend that they not be permitted. A modification to add them back in can be
submitted when/if they are able to obtain signed LOA forms.
FORM: WQROSSR 04-14 Page 2 of 3

DocuSign Envelope ID: 953911E5-978B-4936-8B07-AAOBF02B9D34
4. There are two land application sites with fields that significantly increased in size, but little or no changes were
noted in the application areas shown on the site maps. Request an explanation for the increase in acreage for
the site -fields listed below.
- RC-19 Fields #1 & #2: Field #1 increased 5.19 acres and Field #2 increased 2.46 acres. Why?
- RC-119 Fields #4, #6, & #8: Field #4 increased 1.04 acres, Field #6 increased 1.08 acres, and Field #8
increased 3.14 acres. Why?
5. The application area maps for the sites and fields listed below included modifications to the application areas that
created setback conflicts. See attached site map sketches for the approximate locations. As mentioned above,
revisions to the maps and updates to acreages have already been completed and submitted. The revisions described
below all appear to have been properly addressed on the revised maps.
- RC-01, Field #3: There is an area located to the south that was previously buffered due to unsuitable
(US) slope & topography.
- RC-05, Field #1: There is a residence located at #172 Green Acres Drive that is shown as a structure.
Field #2: There is a small pond in the wooded area. This was previously shown on the site map with
buffer.
Field #5: The property line setback is not shown along the north side of the eastern most section.
- RC-09, Field #2: There is an area located in the northern section that was previously buffered due to a
drain and/or slopes.
Field #3: There are three drains that were previously buffered.
- RC-11, Field #1: There is an area near the center of the field at end of driveway that was buffered due
to slope & topography.
- RC-18, Field #2: There is an area located to the north and west that was previously buffered due to
slope & topography.
- RC-41, Field #2: There is an area located in this field that was previously buffered. I do not recall if
this was an US soil depth issue or a slope issue.
- RC-119 Fields #1, 2, 3, 5, 9, 11: There are a number of areas that were previously buffered due to slopes
and topography.
- RC-125, Fields #1 & #2: There are drains and/or ditches that were previously buffered.
- RC-126, Field #5: There is a drainage ditch that was previously buffered.
FORM: WQROSSR 04-14 Page 3 of 3

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Compliance Inspection Report
Permit: WQ0002376 Effective: 05/15/15 Expiration: 04/30/20 owner: City of Reidsville
SOC: Effective: Expiration: Facility: City of Reidsville Residuals Land Application Progral
County: Rockingham
230 W Morehead St
Region: Winston-Salem
Reidsville NC 27320
Contact Person: Steven L Routh Title: Director of Public Works Phone: [phone]
Directions to Facility:
System Classifications: LA,
Primary ORC: Brent M Collins
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02/07/2020
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Certification: 27651 Phone: [phone]
Entry Time: 10:45AM Exit Time: 02:30PM
Phone: [phone]
Reason for Inspection: Other Inspection Type: Reconnaissance
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant ENeither
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 3

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 02/07/2020 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On 02/07/2020 WSRO staff conducted review of land applicaiton sites with modifications to the site maps creating setback
issues. The residuals source facility was not visited during this review. See staff report dated 02/19/2020 for details from the
review.
Page 2 of 3

Permit: WQ0002376
Owner - Facility: City of Reidsville
Inspection Date: 02/07/2020
Type
Distribution and Marketing
Land Application
Inspection Type : Reconnaissance
Reason for Visit: Other
Yes No NA NE
Page 3 of 3