WQ0035595_Staff Report_20201124

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November 18, 2020
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: CO Reviewer Name
From: Patrick Mitchell
Winston-Salem Regional Office
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
Application No.: W00035595
Facility name: Granville Farms RLAP
Note: This form has been adapted from the non-discharee facility staff report to docnment the review ofboth nondlscharee and NPDES permit applications and/or renewals. Pease complete all sections as they are applicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: November 17, 2020
b. Site visit conducted by: P. Mitchell
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Drew Matthews and their contact information: (252) 883 - 9301
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ® Yes ❑ No ❑ N/A
3. Do the plans and site map represent the actual site (property lines, wells, etc.)? ® Yes ❑ No ❑ N/A
4. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ® Yes ❑ No ❑ N/A
5. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ® No
6. For residuals, will seasonal or other restrictions be required? ® Yes ❑ No ❑ N/A
Note: See Section IV. of this Staff Report for recommended fields with restrictions.
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 NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
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:
Condition
Reason
Footnote for Attachment B:
Surface application only;
For Fields CB-1 and TW-2, due to seasonal high water table being present as
No injection or
shallow as 12 inches below grounds surface.
incorporation.
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
FORM: WQROSSR 04-14 Page 1 of 2

DocuSigned by:
6. Signature of report preparer:
DocuSigned by:
Signature of regional supervis-Oi-5548B6co265c47A...
Date: November 18.2020
B2916E6AB32144F...
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
11/24/2020
On November 17, 2020, Division staff conducted soil and site reviews of the proposed new land application fields
included in the subject application for permit modification. The residuals source facilities covered under this permit
were not visited during this review. Mr. Drew Matthews of Soil Plus accompanied staff on the reviews. Below is a
summary of notes from the reviews, including recommendations related to permit issuance.
The site maps were found to be accurate in the field. The soils reports were found to be mostly accurate, with the
exception of depth to seasonal high water table (SHWT) and soil series named in some areas for fields CB-1 and
TW-2. Fields CB-1 and TW-2 are only suitable for surface application of residuals. A Footnote should be included
for fields CB-1 and TW-2 restricting them to surface application only with injection/incorporation being
prohibited. The NRCS Soil Survey maps showed these areas mapped as Rains Soil Series, but the soils reports included
in the application package indicated that these soils were more like Lynchburg Soil Series. However, SHWT was found
at depths of 12 inches and 13 inches below grounds surface (in both of the subject areas) with the soils described more
closely matching the Rains Soil Series. These areas appear to be suitable for land application with restrictions on depth
and are not the predominant soils present for the proposed fields. Therefore, the proposed field maps and proposed
loading rates should still be appropriate for permitting.
The soil sampling results included in the application package indicated soil pH's were low for all the proposed fields.
Lime amendment is needed for each of these fields. Background levels of metals in the soils were found to be suitable.
The sodium levels and exchangeable sodium percentages were also reported as suitable.
Based upon the PAN concentrations and the proposed permitted dry tonnage in the application package; approximately
1,500 to 2,400+ acres are needed to support this program. The proposed acreage for permitting is only 668.59 acres.
Another concern is that much of the proposed acreage is listed as row crop fields which are only available for land
application between crop harvest — crop establishment times. The application included a statement that many of the
permitted sources also have their own independent RLAP permits to support the total annual tons. Recommend the
regional office closely monitor this program to ensure no overloading occurs.
FORM: WQROSSR 04-14 Page 2 of 2