WQ0016247_Staff Report_20200921

DocuSign Envelope ID: 8B17AFDA-EA04-4D95-8072-A98129AF131D
September 21, 2020
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Ranveer Katyal
From: Patrick Mitchell
Winston-Salem Regional Office
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
Application No.: WQ0016247
Facility name: Synagro Western Piedmont RLAP
Note: This form has been adapted from the non-discharee facility staff report to doc—nt the review of both non -discharge and NPDES permit applications and/or renewals. Please complete all sections as thev are applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: September 18, 2020
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Nate Roth
e. Driving directions: See file.
IL EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ® Yes ® No ❑ N/A
Note: See item 1. in section IV. of this staff report.
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
5. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ® Yes ❑ No ❑ N/A
6. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
7. For residuals, will seasonal or other restrictions be required? ❑ Yes ® No ❑ N/A
8. Is the residuals management plan adequate? ® Yes or ❑ No
9. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
10. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
11. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
12. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
13. Has a review of all self -monitoring data been conducted (e.g. Annual Reports)? ❑ Yes ❑ No ® NE
14. Are there any permit changes needed in order to address ongoing BIMS violations'? ❑ Yes or ® No
FORM: WQROSSR 04-14 Pagel of 3

DocuSign Envelope ID: 8B17AFDA-EA04-4D95-8072-A98129AF131 D
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the Non -Discharge Unit Central Office to obtain through an additional
information request:
Item
Reason
for
Report for
LSS Soils Repo
Applicaiton package did not have a complete report from an LSS for this new
proposed new Site
site. It appears the other new sites may have similar issues with incomplete soils
reports.
Revised application area
Site maps provided did not show adjacent streams or property lines adjacent to
setback maps for RC-49
the site.
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
5. Recommendation: ® Hold, pending receipt and review of additional information by regional office
0
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
❑ Den �P�.gegh state reasons:
o u igned y:
Signature of report preparers 1 Y1(&81111.
Signature of regional supervis 548B6co255c47A...
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Date: September 21, 2020 '--145B49E225C94EA.
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On September 18, 2020, WSRO staff conducted site visits to the proposed new land application fields in the subject
application package. The proposed new residuals source facility (Town of Mayodan) was recently visited by WSRO
staff and was not visited as part of this review. Below is a summary of notes from the site visits and review of the subject
application.
1. The application package did not really contain a Soils Report from the LSS for the proposed new fields in the
WSRO area. Only a copy of the NRCS county soil survey for the site and the soil profile descriptions from
hand auger borings were included. NC Administrative Code 02T .1104(c)(2) requires that soils evaluations
shall be presented in a report. The Division's Soil Scientist Evaluation Policy explains expectations from these
rules and requires that Soils Reports shall include the following components (missing from this application):
- A statement that the sites and fields were found to be suitable by the LSS for the proposed land
application activity. The report should contain all recommendations and discuss areas not suitable for
land application. (Policy items 4.a. and 4.d.)
- A detailed soils map created by the LSS or a copy of the NRCS county soil survey if confirmed by the
LSS and sealed by LSS. (Policy items 4.b.)
These items have been discussed verbally with Synagro over the past few permitting projects, including a recent
add info requests related to this deficiency. Recommend requesting these missing items in an effort to be
consistent with the requirements contained in 2T and the Division's Policy. Also allowing this is inconsistent
with what other submitted LSS projects contain which are incompliance with 2T and the Policy.
2. It appears there is barely enough permitted land application fields to support the dry tons based on the lab results
provided. There is 1,191.2 acres proposed and 1,000 to 1,200 acres is needed depending on crops. While this
does meet the needs, there is room for concern as row crops timing, cattle rotations, hay harvesting, etc. could
cause issues with acreage availability at times. No need for add info request currently. Just needs to be noted
by inspector.
FORM: WQROSSR 04-14 Page 2 of 3

DocuSign Envelope ID: 8B17AFDA-EA04-4D95-8072-A98129AF131D
3. Mayodan source appears to meet regulatory limits (TCLP, Metals, Pathogen & Vector).
4. Did not review proposed fields in Chatham or Harnett county. However, it was noted that no soil boring
locations were shown on maps, there was no LSS produced or approved soils map, no LSS statement in the
soils report on suitability, unsuitability areas, or any site recommendations. Again, this has been discussed with
Synagro on multiple projects now, other Permittee's and consultants are adhering to the regulations and policies.
Recommend requesting these missing items for this project as well.
5. The application area site map provided for proposed site RC-49 did not show most of the surface water features
adjacent to the land application site (see attached Field Notes Site Map). The Division's Map Guidance Policy
and 02T .1104(c)(1)(B) both require that the setback maps shall show the location of all ephemeral, intermittent
and perennial streams, ponds, etc. within 500 feet of the land application site. Maps should also show all
property lines within 500 feet according to 02T .1104 (c)(1)(D). Recommend requesting revised site maps
for RC-49 to show all adjacent surface water features and drains within 500 feet of site.
FORM: WQROSSR 04-14 Page 3 of 3

APPLICATION MAP
LEGEND
APPLICATION AREA UNSUITABLE AREA
f—�— —d— PRIVATE ROAD WATER
v STREAM ONSITE HOUSE
GRAPHIC SCALE
"_
DRAIN OFFSITE HOUSE
31 X FENCE OUTBUILDING 660' 0 660'
PROPERTY LINE WELL
SOIL BORING
The compliance boundary is established either 250 ft from the residuals application area or 50 feet within N C-RC`49
in the property boundary, whichever is closest to the application area. The review boundary is established
midway between the compliance boundary and the perimeter of the residuals application area, All
locations are approximate. Fields 1-6

TOPOGRAPHIC MAP
GRAPHIC SCALE
1"=800'
800, 0 800,
The compliance boundary is established either 250 ft from the residuals application area or 50 feet within N C-RC-49
in the property boundary, whichever is closest to the application area, The review boundary is established
midway between the compliance boundary and the perimeter of the residuals application area. All
locations are approximate. Fields 1-6

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Compliance Inspection Report
Permit: WQ0016247
SOC:
County: Alexander
Region: Mooresville
Contact Person: Alex Fox
Directions to Facility:
Effective: 08/03/20 Expiration: 10/31/22 Owner: Synagro Central LLC
Effective: Expiration: Facility: Synagro Western Piedmont RLAP
284 Boger Rd
System Classifications: LA,
Primary ORC: Robert Nathaniel Roth
Secondary ORC(s):
On -Site Representative(s):
Title:
Certification: 1001672
Related Permits:
NC0020591
City of Statesville - Third Creek WWTP
NC0043532
Stanly County - West Stanly WWTP
NC0031836
City of Statesville - Fourth Creek WWTP
NC0088722
Lincoln County - Killian Creek WWTP
NC0021890
Town of Granite Falls - Granite Falls WWTP
NC0021369
Town of Columbus - Columbus WWTP
NC0021628
Town of Norwood - Norwood WWTP
Inspection Date: 09/18/2020 Entry Time 11:30AM
Primary Inspector: Patrick
Mitchell
Secondary Inspector(s):
Mocksville NC 27028
Phone: [phone]
Phone: [phone]
Exit Time: 01:45PM
Phone: [phone]
Reason for Inspection: Other Inspection Type: Reconnaissance
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant Neither
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 2

Permit: WQ0016247 Owner- Facility:Synagro Central LLC
Inspection Date: 09/18/2020 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On September 18, 2020, WSRO staff conducted site visits to proposed new land application fields located within the WSRO
area for the subject permit. The proposed new residuals source facility (Town of Mayodan) was recently visited by WSRO
staff and was not visited as part of this review.
Of note related to compliance review for the subject permit:
• It appears there is barely enough permitted land application fields to support the dry tons based on the lab results provided.
There is 1,191.2 acres proposed and 1,000 to 1,200 acres is needed depending on crops. While this does meet the needs,
there is room for concern as row crops timing, cattle rotations, hay harvesting, etc. could cause issues with acreage
availability at times. This should be noted and reviewed for each source facility to ensure proper disposal of residuals and no
overloading of fields.
• Mayodan source appears to meet regulatory limits (TCLP, Metals, Pathogen & Vector).
See Staff Report dated September 21, 2020 and associated field notes for additional details from the application review and
the site visits.
Page 2 of 2