WQ0016247_Staff Report_20200619

State of North Carolina
Nr Division of Water Resources
" Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: (WQ0016247)
Attn: (Ranveer Katyal, CO Non -Discharge Group) Facility name: Synagro, Western Piedmont, Class B RLAP
From: (Edward Watson)
Mooresville Regional Office
Note: This form has been adapted from the non -discharge fg acili , 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: 06/17/2020
b. Site visit conducted by: Inspection report attached? ❑ Yes or ® No
c. Person contacted: Alex Fox and their contact information: (336) 703 - 8681 ext.
e. Driving directions: Meet at 4" Creek WWTP to travel to application fields.
2. Discharge Point(s): N/A
Latitude:
Latitude:
Longitude:
Longitude:
3. Receiving stream or affected surface waters: N/A, this is a Non -Discharge permit. There are no receiving waters.
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: Robert Roth Certificate #:LA/1001672 Backup ORC: Adam Brigman Certificate #:LA/1006653
2. Is 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: The source for the residual sludge are the associated WWTPS designated a
sources for this permit. This is a modification to an existing permit to add fields to accept Class B residual sludge
from the approved sources already listed in the permit.
Proposed flow: N/A
Current permitted flow: N/A
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.)
FORM: WQROSSR 04-14 Page 1 of 4

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: New fields are being added to the RLAP permit.
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: Wells are not required.
11. 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.
12. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
13. 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:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: Sludge entering surface water via a conveyance due to extreme weather
conditions.
16. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 2 of 4

III. 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. 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: )
4. Signature of report preparer: Edward Watson 6/17/2020
[Docu Signed by:
A44" H P4"
5. Signature of regional supervisor: F161FB69A2D84A3... Date:
6. ADDITIONAL REGIONAL STAFF REVIEW ITEMS:
6.19.2020
ORC info needs to be updated in RIMS. As noted above, Roth is the ORC and Brigman is the backup. Bruce is noted as
invalid in RIMS and needs to be removed. Alex Fox has been the MRO's primary contact for this modification and he's
listed as an affiliation, but he does not appear to be certified for LA at this time.
All additional fields were visited on 6/17/2020. The only field that had some ponding issues was Field IR-36-01. This field
has low spots where water will pond with significant precipitation.
None of the new fields had 10 % or greater slopes. All surface water features and conveyances appeared to be adequately
buffered.
All homes are on private water supply wells. These wells were adequately buffered.
Updated maps were presented at the request of the MRO to clearly show the application fields. The maps that were
submitted with the application were too dark to be able to clearly read.
Some of these new fields use chicken litter as the primary fertilizer. Synagro will be need to maintain soil loading rates
through means of regular soils reports to avoid an overload of nutrients and metals for these fields.
FORM: WQROSSR 04-14 Page 3 of 4

FORM: WQROSSR 04-14 Page 4 of 4