WQ0000455_Staff Report_20200714

DocuSign Envelope ID: 9C462C44-99DC-46BA-877F-9B8463C274A8
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
July 14, 2020
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0034806
Attn: Ranveer Kaytal Facility name: Lewis Farms and Liquid Waste, Inc.
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 1,402 DTIX class B residuals on
19 fields (442.8 net acres)
Proposed flow: Proposal is to add 1 new source: Lear Corporation permit NC0002305 (500 DT/yr) to net 1,902
DT/-r.
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

DocuSign Envelope ID: 9C462C44-99DC-46BA-877F-9B8463C274A8
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
FORM: WQROSSR 04-14 Page 2 of 4

DocuSign Envelope ID: 9C462C44-99DC-46BA-877F-9B8463C274A8
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 preparer:
Signature of regional supervisor:
Date: 7/15/2020
WmItA J
E3ABA14AC7DC434...
el" ke.,,�
5D3B417...
FORM: WQROSSR 04-14 Page 3 of 4

DocuSign Envelope ID: 9C462C44-99DC-46BA-877F-9B8463C274A8
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This review was conducted for a request by Lewis Farms and Liquid Waste, Inc. to modify their land
application of residuals permit. The permit modification requests the addition of one new source: Lear
Corporation with 500 dry tons/year. This would increase the total amount of residuals to be certified to
1,902 dry tons/year.
In 2019, a total of 489.7 dry tons were land applied utilizing 285.2 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 Lewis Farms has the capacity
to add this additional source and not overload their fields.
After review of the submitted application, the WiRO has no objection to issuance of this permit
modification.
FORM: WQROSSR 04-14 Page 4 of 4