WQ0037637_Staff Report_20200323

DocuSign Envelope ID: 7CB310OC-EA5A-4B41-902F-OA68E3208BB5
,s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0037637
Attn: Erick Saunders Facility name: Craven Ag RLAP
From: Randy Sipe
Washington Regional Office
Note: This form has been adapted from the non -discharge facilily 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: 3/10/20
b. Site visit conducted by:
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: John "Billy" Dunham and their contact information: 252) 670 - 8530 ext.
e. Driving directions: No change since last permit was issued.
2. Discharge Point(s): N/A non -discharge system.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A non -discharge system.
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: John Dunham Sr. Certificate #: LA/13203 Backup ORC: Mac Dunham Certificate #:LA/24992
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: Land application of residual solids by vehicle after lime and alkaline treatment.
Proposed flow: N/A, RLAP permit (Annual Residuals Limit — 21.73 dry tons)
Current permitted flow: N/A, RLAP permit (Annual Residuals Limit — 51 dry tons)
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.) None.
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DocuSign Envelope ID: 7CB310OC-EA5A-4B41-902F-OA68E3208BB5
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: O&M Plan needs to be revised to note that a copy of the O&M Plan should be onsite during
application events along with a copy of the permit, as required by Condition IIL6 of the current permit.
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:
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
C
C
C
C I II
C I II
C I II
C I II
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: Based on a site visit during an application event on
3/10/20 and review of the 2019 Annual Report on 3/12/20 the facility is considered in compliance with the current
permit.
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: N/A non -discharge system.
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DocuSign Envelope ID: 7CB310OC-EA5A-4B41-902F-OA68E3208BB5
17. Pretreatment Program (POTWs only): N/A non -discharge system.
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: Issuance of a permit should not be considered until the items described below are addressed
by the permittee and their consultants
2. List any items that you would like the NPDES Unit orNon-Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
The O&M Plan needs to be revised to note that a copy of the O&M Plan should
O&M Plan
be onsite during application events along with a copy of the permit, as required
by Condition III.6 of the current permit.
Item IIL4 of the completed Form RLAP 06-16 gives a proposed total of 51
Forms RLAP 06-16 and
annual dry tons of residuals. The Residual Source Facility Summary provided
RSC 06-16
with the RSC 06-16 Forms only shows a total of 36 annual dry tons of
residuals. The permittee and their consultants should clarify the actual
proposed annual dry tons for the new permit.
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: )
6. Signature of report preparer: D+uL��4e
Signature of regional supervisor: I�awd Gay
Date: 3/23/2020
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DocuSign Envelope ID: 7CB310OC-EA5A-4B41-902F-OA68E3208BB5
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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