WQ0034842_Staff Report_20210629

DocuSign Envelope ID: 46BEDF91-A7E7-4FC4-99B4-79B190F3FC94
Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
June 28, 2021
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: Town of Morehead City WQ0034842
Attn: Poonam Giri
Facility name: Town of Morehead City's Distribution of Class A Residual Solids
From: Geoff Kegley
Wilmington 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
a. Date of site visit:
b. Site visit conducted by:
c. Inspection report attached? n Yes or ® No
d. Person contacted: and their contact information:
a. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? n Yes or _ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? [ Yes No
If no, please explain:
�. Do the plans and site map represent the actual site (property lines, wells, etc.)? n Yes [ No [ N/A
If no, please explain:
FORM: WQROSSR 04-14
N/A
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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? n Yes n No n N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? n Yes or n No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? n Yes n No n N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? n Yes n No n 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: Certificate #: Backup ORC Certificate #
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: Distribution of Class A Residuals program, 1,200 maximum
dry tons per year.
Proposed flow: n/a
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.)
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.)? n 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? n Yes or ® No
If yes, attach a map showing conflict areas.
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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? n 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):
12. 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:
2020 Annual Report reviewed and demonstrates compliance.
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 n Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation n 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:
17. Pretreatment Program (POTWs only):
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:
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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
DocuSigned by:
❑ Deny (Please state reasons: ) 6/29/2021
6. Signature of report preparer:
(-DocuSigned by:
Signature of regional supervisor: Hoult4544,443, last
Date:
6/29/2021 �E3ABA14AC7DC434
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
C017E2515D3B417...
This review was conducted for a permit renewal request by the Town of Morehead City for their
distribution of Class A residuals program. The 2020 annual report has been reviewed and was deemed
compliant. The residuals analysis indicate metals are below ceiling concentration limits and TCLP
results demonstrate residuals are non -hazardous. No other compliance issues were noted. After review
of the application and supporting documentation the WiRO recommends issuance of the permit renewal.
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