WQ0039181_Staff Report_20200917

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: (WQ0039181)
Attn: (Vivien Zhong, C/O Non -Discharge Permitting Group) Facility name: Carolina Malt House
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 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: Inspection report attached? ❑ Yes or ® No
c. Person contacted: and their contact information: (_) - ext.
e. Driving directions:
2. Discharge Point(s): N/A This is a non -discharge spray irrigation facility. No discharge to surface water will occur
as a result of activities associated with this facility. However, the LAT/LONG for the facility is
LAT35.737816 LONG-80.714802
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification: C
River Basin and Subbasin No. 12-108-20-4
Describe receiving stream features and pertinent downstream uses: N/A
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Lynn Aldridge Certificate #:993778 Backup ORC: Matthew S. Sechler Certificate #: 10011758
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: Waste Lagoon with three dedicated spray irrigation fields. Each field is
approximately 1 acre. No GW monitor wells have been required.
Proposed flow: N/A
Current permitted flow: The current application rate is 15.75 in./yr. spray irrigation; this request is to increase
the rate.
FORM: WQROSSR 04-14 Pagel of 3

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: The application rates need to be increased as they are currently too low for the facility to
operate at current production levels; the original application showed that the soils can accept significantly higher
hydraulic loading than they asked for originally.
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:
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: NDMR information indicates over application is
occurring based on the low limits in the existing permit; previous inspections have not shown runoff or other
adverse impacts. NOD-2019-LV-0160 and NOD-2019-LV-0086 have been issued and both notices were based on
flow exceedances and additional enforcement has been withheld while this flow increase was being requested.
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: The irrigation application rate needs to be increased to allow the facility to get into
compliance with the permit.
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: This modification to increase the spray application rate and will correct the compliance
issues presently occurring at the facility.
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: This modification should resolve compliance issues.
15. Possible toxic impacts to surface waters: None, unless not operated as a ND system.
16. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 2 of 3

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 specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition 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, Hydrogeologist 9/17/2020.
Docu Signed by:
Signature of regional supervisor: 54'44tw H P uft Date: 9.17.2020
F161 FB69A2D84A3...
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
In the initial permit application process, the permittee opted to accept the minimum design plan of 15.75 inches of
spray irrigation application.
During the last site visit to the facility on 1111912019, the facility was found not to comply with the permit due to over -
application on the spray fields, and NOD-2019-L V-0160 was issued as a result of exceeding the permitted limit. No
runoff or other adverse impacts were noted; it was a violation on paper.
The MRO has reviewed the request to increase the allowable irrigation rate, along with reviewing the updated 2020
report from Thompson Environmental Consulting. The 2020 evaluation from Mr. Thompson, LSS, indicates the
findings were consistent with the original 2017 application for the site and that there was no evidence of hydraulic
overload of the soils.
The evaluation submitted in 2017 notes that for a Soil Type 1, the recommended application rate should not exceed
1.1 inches/week of spray irrigation. All three of the dedicated spray fields are composed of Soil Type 1. Taking the
soil type into account, the recommended application rate of 1.1. inches/week for this soil type; the LSS recommended
application rate for each field calculates to 57.2 in./yr.
This information has also been reviewed by Patrick Mitchell, a LSS in the Winston-Salem Regional Office, who
believes that the 76.48 inches is far too much. Patrick also indicated by email that the 1.1 inches/week is what might
be considered under ideal conditions. Based on information from two LSSs, the MRO does not support the
permittee's request for 76.48 inches. .
Although the application rate of L I inches/week is considered to be high, the MRO does not have sufficient data to
dispute Mr. Thompson's application rate of 1.1 inches/week of spray irrigation application. Therefore, the MRO will
recommend that the guidance of an application rate not to exceed 1.1 inches/week of spray irrigation become the
adjusted rate of spray application allowed to be applied to the dedicated spray fields at this facility. The new
recommended spray irrigation application should reflect 57.2 inches/year as the maximum spray application rate for
this facility.
FORM: WQROSSR 04-14 Page 3 of 3