WQ0018087_Staff Report_20200915

DocuSign Envelope ID: 6608A156-73C5-42A3-9B05-3C4413CEB474
f. as
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
September 15, 2020
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0018087
Attn: Poonam Giri Facility name:
DAK Americas - Cape Fear Manufacturing Facility SDU
From: Geoff Kegley
Wilmin on 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 gpplicable.
L 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: Larry Young Certificate #: Backup ORC: Certificate #:
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: 12 acre Surface Disposal Unit (SDU). The SDU no longer receives and
activated sludge and has been closed under the approved closure plan. Post -closure care and groundwater
monitoring continues.
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: 6608A156-73C5-42A3-9B05-3C4413CEB474
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: See narrative below.
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
No lat/long data available on new
wells
o ,
_ o , Pr
O l lI
O I II
O l lI
O I II
O / //
O / II
O / //
O / 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: see narrative below.
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: 6608A156-73C5-42A3-9B05-3C4413CEB474
18. 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. 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
Submit monitoring well
location data
No location data received.
(latitude/longitude)
Modify Attachment C to
increase sampling frequency
Exceedances present in groundwater at the review boundary.
to semi-annual.
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
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ElDeny
by:
Deny (Please state reasons: ) 9/15/2020
6. Signature of report preparer:
Signature of regional supervisor:
Date: 9/15/2020
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DocuSign Envelope ID: 6608A156-73C5-42A3-9B05-3C4413CEB474
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This review was conducted for a request by DAK Americas to renew their surface disposal of Class B
residuals permit. The 12 acre Surface Disposal Unit (SDU) is no longer in operation and has been closed
under the approved Closure Plan. Post -closure care under the approved Closure Plan and groundwater
monitoring under this permit continues.
The groundwater monitoring at this site has shown exceedances at the review boundary. This possibility
was anticipated before closure of the SDU and plugging of the underdrain system. Additionally, the
permittee believes some of these exceedances were attributable to the disturbances that occurred in the
area during the capping of the SDU basin and surrounding site activities. The thought was that after the
system was capped, there would not be further contaminant input to the groundwater system and they
would continue to monitor any trends. With the limited data set, the apparent trends for the constituents
of interest (ammonia, nitrate, TDS and arsenic) have been trending downward or relatively stable (see
attached graphs).
Since there are exceedances present at the review boundary, per 2L, the permittee would be allowed to
demonstrate, through predictive calculations or modeling, that the violations at the review boundary
won't result in exceedances at the compliance boundary. However, since the sampling frequency is only
annual, more data would be likely be required to perform any evaluation or modeling. Therefore, it is
recommended that the frequency of groundwater monitoring be increased to semi-annual.
After review of the submitted application, the WiRO has no objection to issuance of this permit renewal.
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