WQ0034806_Staff Report_20200529

DocuSign Envelope ID: 5618E046-FD20-42CE-B9D2-3C28914BA8C4
State of North Carolina
®r- Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
May 29, 2020
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0034806
Attn: Ranveer Kaytal Facility name: Coastal Farms and Residuals
From: Geoff Kegley
Wilmington 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 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:
e. Driving directions:
2. Discharge Point(s): N/A
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: Wesley Wooten Certificate #: 993105 Backup ORC: Martin Mabe Certificate #: 22753
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: Permit currently allows for land application of 1500 DTIX class B residuals
from 14 sources on 12 fields (545 net acres)
Proposed flow: Proposal is to add 1 new source (175 DT/yr) to net 1675 DT/fir.
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.)
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DocuSign Envelope ID: 5618E046-FD20-42CE-B9D2-3C28914BA8C4
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:
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 / 11
O / //
O I II
O I //
O I /I
O I //
O I It
O / //
O I 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: Review of the 2019 annual report was deemed
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
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DocuSign Envelope ID: 5618E046-FD20-42CE-B9D2-3C28914BA8C4
18. REGIONAL OFFICE RECOMMENDATIONS
I . 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: DOCUSigned by:
6. Signature of report preparers DocuSigned by:
Signature of regional supervisor: I h6ftt1 A. SOft
Date: 6/ 1/ Z 0 Z 0 UABAUA=C434...
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DocuSign Envelope ID: 5618E046-FD20-42CE-B9D2-3C28914BA8C4
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This review was conducted for a request by Coastal Farms and Residuals to modify their land
application of residuals permit. The permit modification requests the addition of one new source: SE
Brunswick (WQ0013200) with 175 dry tons/year. This would 'increase the total amount of residuals to
be certified to 1,675 dry tons/year.
In 2019, a total of 668.67 dry tons were land applied utilizing 93.4 acres. Field loading rates for metals
and PAN are being calculated, along with cumulative pollutant loading rates which are compliant. The
sludge analysis for the new source indicate metals are below ceiling concentration limits and sodium
adsorption rates (SAR) results were below 10 and TCLP results were below limits. With the large
amount of acreage available for land application activities, it appears that Coastal Farms has the capacity
to add this additional source and not overload their fields.
On April 21, 2020 the regional office granted temporary/emergency approval for this additional source
until the formal permit modification process could be finalized, see attached email.
After review of the submitted application, the WiRO has no objection to issuance of this permit
modification.
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