WQ0039924_Staff Report_20210405

State of North Carolina
'D WRDepartment of Environmental Quality
WATER QUALITY REGIONADivision of Water Resources
L OPERATIONS SECTION
Division of Water Resources NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
February 1, 2021
To: FRO-WQROS: Trent Allen / Mark Brantley
From: Erick Saunders, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0039924
Applicant: von Drehle Corporation
Owner Type: Organization
Facility Name: von Drehle Corporation DCAR
Signature Authority: Justin Dawkins
Address: 126 First St., Cordova, NC 28330
Permit Type: Distribution of Residual Solids (503 Exempt)
Project Type: Major Modification
Owner in BIMS? Yes
Facility in BIMS? Yes
Title: Plant Manager
County: Richmond
Fee Category: Non -Discharge Major Fee Amount: $395 - Major Modification
Comments/Other Information: [e-mail]; [e-mail]
Attached, you will find all information submitted in support of the above -referenced application for your review, comment,
and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: 0 mL Eft6l��
Date: 3
FORM: WQROSNDARR 09-15 Page 1 of 1

To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Erick Saunders
From: Jim Barber
Fayetteville Regional Office
Application No.: W00039924
Facility name: von Drehle Corporation — Cordova
Class A (503 Exempt)
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 February 2021
b. Site visit conducted by: Jim Barber
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Chris Fowler and their contact information: 9( 10) 410 - 9131 ext.
e. Driving directions: From Rockingham, take US Hwy 1 South approximately 3 miles and turn right at the
intersection of US 1 and Rosalyn road. Drive approximately 2 miles and the von Drehle plant is on the right.
2. Discharge Point(s): N/A. Both Class A and Class B residuals are stored behind the main production plant,
adjacent to belt press. The coordinates below are the approximate center of the storage area.
Latitude: 34.918454
Latitude:
Longitude:-79.828977
Longitude:
3. Receiving stream or affected surface waters: N/A (Hitchcock Creek is adjacent to the von Drehle production
plant site
Classification: "C"
River Basin and Subbasin No.: Yadkin -Pee Dee (YAD16) (13-39-10)
Describe receiving stream features and pertinent downstream uses: From the von Drehle plant site to the
Pee Dee River is forest/woodlands on both sides the Hitchcock Creek.
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
FORM: WQROSSR 04-14 Page 1 of 6

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)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. 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: Chris Fowler Certificate #: LA-1003082 Backup ORC: Bob Branch Certificate #: LA-15676
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: Paper recycling facility that produces press cake residual. At the current
time, von Drehle has a Class A and Class B permit (W00005135—12,500 DTs/year) and two land
application farms for residuals that can't meet Class A standards.
Proposed flow: The current modification request is 35,000 DTs/year.
Current permitted flow: Current Dry Tons allowed to be land applied under the Class A permit is 16,499
DTs/year.
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.
FORM: WQROSSR 04-14 Page 2 of 6

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:
FORM: WQROSSR 04-14 Page 3 of 6

11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no. please complete the following (expand table if necessarv):
Monitoring Well
Latitude
Longitude
O 1 I/
O l 11
O 1 11
_ O l If
I If
O l I/
O 1 If
O / I/
O / If
O 1 If
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: Residuals produced are primarily being land
applied under the von Drehle Class B permit on two farms; one located outside of Hamlet and one along
U.S. Hwy I south of Cordova near the South Carolina/North Carolina line.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
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
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ 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:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters: N/A
17. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 4 of 6

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
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
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 supervi�
Date: 3 Z
FORM: WQROSSR 04-14 Page 5 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Von Drehle is requesting an increase in tonnage for managing Class A cake residuals, with most of the paper residuals
managed under the Class A permit marketed to farmers in Richmond, Scotland, Anson and Moore counties that have
sandy soil profiles as a soil amendment (i.e Candor, Wagram, Wakulla, etc.). Some Class A residuals may also be
land applied in South Carolina, as in past history. South Carolina DHEC will require von Drehle or Bionomics to
apply for a industrial land application permit if Class A residual is to be land applied.
Also at this time, Bionomics (residuals contractor for von Drehle) is currently requesting modification of their Class B
permit (W00038570) to add von Drehle as a source, along with other nutrient sources and the von Drehle farm sites.
The other nutrient sources being request in the Bionomics modification also have their own land application permits
that Bionomics administer, hence the von Drehle site will be a secondary permit for residuals management.
Once the von Drehle Class A permit is modified and the Bionomics Class B permit modified; von Drehle intends to
rescind their Class B permit.
Wastewater from belt pressed residuals and domestic flow are discharge to the City of Rockingham collection
system/wastewater treatment plant.
FORM: WQROSSR 04-14 Page 6 of 6