WQ0016247_Staff Report_20210310

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: n NPDES Unit ® Non -Discharge Unit Application No.: (WQ0016247)
Attn: (Erick Saunders) Facility name: Synagro Western Piedmont Regional Permit
From: (Edward Watson)
Mooresville 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
Date of site visit: 12/04/2020
Site visit conducted by: Inspection report attached? ❑ Yes or ® No
a. Person contacted: Alex Fox and their contact information: (336) 403 - 4324 ext.
e. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: This is a non -discharge permit. There is no outfall associated with this
permit.
Classification: N/A
River Basin and Subbasin No. N/A
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: Robert Roth Certificate #: 1001672 Backup ORC: Adam Brigman Certificate #:1006653
2. Is the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or n No
If no, please explain:
Description of existing facilities: Municipal WWTPs.
Proposed flow: N/A This is a Land Application permit. No flow will occur as a results of Land Application
activities.
Current permitted flow: N/A
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.) MRO staff viewed the fields that are planned to be added to the permit. All areas of concern were
adequately buffered and the maps were updated to display the revised buffer boundaries.
FORM: WQROSSR 04-14 Page 1 of 4

3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ® Yes or n 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 n No
If yes, please explain: New fields and new sources are being added to the RLAP permit.
5. Is the residuals management plan adequate? ® Yes or n No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or n No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? n Yes n 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? n Yes or Z 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 n No
If no, please explain:
10. Were monitoring wells properly constructed and located? n Yes n No ® N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 2 of 4

11. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or n No
Please summarize any findings resulting from this review:
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? n Yes or ® No
If yes, please explain:
13. Check all that apply:
Z No compliance issues n Current enforcement action(s) n Currently under JOC
n Notice(s) of violation n Currently under SOC n 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 n No n N/A
If no, please explain:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
n Yes ®No n N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: The maps presented in the permit modification display that all surface
water features have been buffered to prevent run-off of the sludge to nearby surface water.
16. Pretreatment Program (POTWs only): N/A
REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? n 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
1
New Source to add: Mount Holly WWTP NPDES Permit NC0021156 proposed
780 dry tons/yr.
2
New Source to add: City ofLincolnton WWTP NPDES Permit NC0025496
proposed 600 dry tons/yr.
3. Recommendation: n Hold, pending receipt and review of additional information by regional office
n Hold, pending review of draft permit by regional office
n Issue upon receipt of needed additional information
® Issue
n Deny (Please state reasons: )
4. Signature of report preparer: Edward Watson, Hydrogeologist 9 March 2021.
Signature of regional supervisor:
,--DocuSigned by:
A4•441-441 H P44,14.
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FORM: WQROSSR 04-14
Page 3 of 4

3.10.21
Date:
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The new sources being added to this permit all qualify under 40 CFR 503. The sources are all considered to be
Biological in nature.
The permit modification will include new sources and new land. Below are the additional residual cake sources:
1. Mount Holly WWTP permit NC0021156 with a permitted flow of 4.0 MGD and an average daily flow of 2.1
MGD.
2. Lab results indicate that a TCLP/Ignitability Test PENSKY-MARTENS CLOSED CUP TO CHARACTERIZE
FLASHPOINT of the waste residual in January 2020 was elevated at >140°F.
3. City ofLincolnton WWTP permit NC0025496 with a permitted flow of 6 MGD and an avg. daily flow of 2.4
MGD.
4. The modification will also include the addition of 621.80 acres that are new or transferred from existing permits.
MRO staff viewed these fields in December 2020 with a representative of Synagro. All maps are updated to
include additional buffers for surface water features or potential conveyances to surface water.
5. WQ0016247_Modification _20210121 (2) is the document in Laserfiche where the modification application can
be found to review the land being added to the permit.
6. Signed LOAs are attached with the modification application.
7. Soil Scientist Profile descriptions are present as part of the modification application.
8. Synagro will be assisting both Mt Holly (WQ0001863) and Lincolnton (WQ0002712) with upcoming requests to
rescind their respective land application permits.
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