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HomeMy WebLinkAboutWQ0031725_STFRPT_20210406State of North Carolina Department of Environmental Quality Division of Water Resources Water Quality Permitting Regional Staff Report FORM: APSRSR 04-10 Page 1 of 4 April 6, 2021 To: DWR Water Quality Permitting Section Central Office Application No.: WQ0031725 Attn: Poorva Mokashi Regional Login No.: From: Mikal Willmer Asheville Regional Office I. GENERAL SITE VISIT INFORMATION 1. Was a site visit conducted? Yes or No a. Date of site visit: 3/30/2021 b. Site visit conducted by: Mikal Willmer c. Inspection report attached? Yes or No d. Person contacted: Zach Key, US Biosolids and their contact information: 336-957-7871 e. Driving directions: To Fields from ARO, I-40 E to exit 103 and turn left onto US-64 E/S. Continue on 64 E through Lenoir. 64 E turns into NC 18 N, continue on NC 18N for 24 miles and take a left onto NC16 N/NC- 18. Merge onto US-421 S for 9 miles. Take exit 276 for Mathis farm rd and turn left. Follow rd for .7 miles and turn right onto NC-268E. Turn left on Hoots Rd and continue for approximately 1.5 miles. Turn right onto State Rd. 1924. II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS 1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit) 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: 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) DocuSign Envelope ID: 3687B565-B5FB-43A0-B1B0-4F7DCC1257E6 FORM: APSRSR 04-10 Page 2 of 4 III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A ORC: Dennis Key Certificate #: LA15704 Backup ORC: Zack Key Certificate #: LA27660 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: 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: Field DP1-A is a feeding area which appears denuded. A vegetative cover will need to be re-established prior to land application. Facility should continue to monitor phosphorus as soil indices have been high for several years. Plant removal of phosphorus is below levels applied annually. This may lead to micronutrient deficiency and increased P mobility. 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: 2019 & 2020 annual report soils analysis still indicate high phosphorus indices on all fields except DP6. The P-Is for fields DP1B and DP3C are over 300. Copper indices for DP1C and DP1B should also be closely monitored. Both are above 1200. At 2000 (40 ppm) it is recommended by NC Ag that new waste application sites be found. 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. 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., NDMR, NDAR, GW)? Yes or No Please summarize any findings resulting from this review: See #6 above 13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No If yes, please explain: 14. 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.) DocuSign Envelope ID: 3687B565-B5FB-43A0-B1B0-4F7DCC1257E6 FORM: APSRSR 04-10 Page 3 of 4 15. 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: 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 Non-Discharge Central Office to obtain through an additional information request: Item Reason 3. List specific permit conditions recommended to be removed from the permit when issued: Condition Reason 4. List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason Phosphorus Loss Assessment Recommend, at a minimum, requiring a phosphorus loss assessment of the fields this permit cycle due to the continued elevated levels of phosphorus recorded on the annual soil fertility analyses. 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 Water Quality Regional Supervisor: Date: V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS There appeared to be a good cover crop of fescue on all fields except DP1 which is used as a feeding area. As noted in the reconnaissance inspection, this will need to be reseeded before application occurs. US Biosolids indicated no additional fertilizers (chicken litter) are spread onto the 9 application fields in use. DP2 has not been applied to in years and is used for growing corn and covered with fescue between growing seasons. Mr. Duplin reportedly fertilizes DP2 with Chicken Litter. A pile was placed at the edge of field 5 at the time of the inspection. Mr. Key indicated this is only spread in certain buffered areas. High phosphorus levels should be closely monitored and considered in future applications. While phosphorus loss assessments are not required under 02T.1100, it is DocuSign Envelope ID: 3687B565-B5FB-43A0-B1B0-4F7DCC1257E6 4/6/2021 FORM: APSRSR 04-10 Page 4 of 4 recommended as a best management practice due to the PI of the fields. Reduction in the use of organic fertilizers may allow the fields to recover. DocuSign Envelope ID: 3687B565-B5FB-43A0-B1B0-4F7DCC1257E6