WQ0016247_Staff Report_20200928

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Permit No.: (WQ0016247)
Attn: Ranveer Katyal Facility name: Synagro Western Piedmont RLAP
Chatham County

From: Gary Kreiser
Choose an item. RRO 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 applicable.

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 9/28/2020
b. Site visit conducted by:
c. Inspection report attached? Yes or No
d. Person contacted: and their contact information: ext. Nate Roth, Synagro
e. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Sub-basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification:
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
DocuSign Envelope ID: 6A0936AF-A129-487E-9D19-6256AF937DC0
FORM: WQROSSR 04-14 Page 2 of 5
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters: Pretreatment Program (POTWs only):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: 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:
Proposed flow: NA
Current permitted flow:
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.).
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:

DocuSign Envelope ID: 6A0936AF-A129-487E-9D19-6256AF937DC0
FORM: WQROSSR 04-14 Page 3 of 5
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
Monitoring Well Latitude Longitude
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
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:
13. Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
14. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain:
15. 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:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
17. Possible toxic impacts to surface waters:
18. Pretreatment Program (POTWs only):

DocuSign Envelope ID: 6A0936AF-A129-487E-9D19-6256AF937DC0
FORM: WQROSSR 04-14 Page 4 of 5
IV. 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
LSS Soils Report for sties
CH-78 Fields 1,2,3 and 5
and site CH-73 Field 10
Application package did not have a complete report from a LSS for these new
fields.
Transfer of Field 2 from
another permit
CH-78-2 is already permitted in WQ0039391 as BB-1. This field will need to
be transferred to this permit.

3. List specific permit conditions recommended to be removed from the permit when issued: NONE
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: )
6. Signature of report preparer:
Signature of regional supervisor:
Date:

DocuSign Envelope ID: 6A0936AF-A129-487E-9D19-6256AF937DC0
9/29/2020
FORM: WQROSSR 04-14 Page 5 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

On September 28, 2020, RRO staff conducted site visits to the proposed new land application fields in Chatham County. RRO st aff
agrees with WSRO staff’s assessment that the application did not contain the required soil information. Only a copy of the N RCS
county soil survey for each site and one soil profile description from a hand auger boring were included. NCAC 02T .1104(c)(2)
requires that soils evaluations shall be presented in a report. The Division’s Soil Scientist Evaluation Policy explains exp ectations
from these rules and requires that the Soils Report 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 the
LSS (Policy item 4.b).

There was a statement from the LSS stating that the work was done by him o r someone under his supervision but it did not indicate
that they confirmed the NRCS county soils map or make a recommendation on the suitable of the sites. Recommend that soils report
be updated to meet the requirements of rule and guidance document.

CH-78-2 was found to be already permitted in WQ0039391 as BB-1. This field will need to be transferred to this permit and permit
WQ0039391 will need to be modified to r emove this field. Recommend that paperwork showing this transfer be submitted before
issuance of permit.

DocuSign Envelope ID: 6A0936AF-A129-487E-9D19-6256AF937DC0