WQ0030132_Staff Report_20210623

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Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: n NPDES Unit ® Non -Discharge Unit
Attn: Poonam Giri
From: Randy Sipe
Washington Regional Office
Application No.: WQ0030132
Facility name: Town of Plymouth RLAP
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 n No
a. Date of site visit: 6/22/21
b. Site visit conducted by: R. Sipe
c. Inspection report attached? ® Yes or n No
d. Person contacted: None and their contact information:
( ) -
e. Driving directions: no change since last permit was issued
2. Discharge Point(s): N/A, Non -discharge permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A, Non -discharge permit
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
ext.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Bryan Smith Certificate #:13265 Backup ORC: Jason Smith Certificate #:13266
2. Are 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: Based on past inspections of the Plymouth WWTP it has adequate sludge treatment and
holding capacity.
Description of existing facilities:
Proposed flow: N/A, land application of residuals
Current permitted flow: N/A, land application of residuals
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.)
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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: Site conditions at the land application fields were observed during the site visit to be
adequate and consistent with the information included in the application.
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 n No
If no, please explain: See the comment in Item 2 above.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or n No
If no, please explain: Based on information provided in the annual reports conditions observed during site visits,
the fields have been adequate for residual disposal at or below agronomic rates.
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: GW monitoring is not
considered required since the residuals are being applied below agronomic rates to non -dedicated fields.
8. Are there any setback conflicts for existing treatment, storage and disposal sites? Z Yes or n No
If yes, attach a map showing conflict areas. Setback waivers were not provided for adjacent properties at 8432,
8650, and 8707 Long Ridge Road.
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: See Item 7 above
11. Are the monitoring well coordinates correct in BIMS? n Yes n No Z N/A
If no, please complete the following (expand table if necessary): See Item 7 above
Monitoring Well
Latitude
Longitude
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
C
I
II
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: Based on information provided in the annual reports
residuals have been applied below agronomic rates at the fields proposed for continued inclusion in the permit.
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? n Yes or ® No
If yes, please explain:
14. 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.) An NOV
was issued in 2018 as a result of violations observed during an application event. The permittee adequately
responded and corrected the violations.
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? See response above.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes n No n N/A
If no, please explain:
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15. 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:
16. Possible toxic impacts to surface waters: N/A Non -discharge permit
17. Pretreatment Program (POTWs only): N/A Non -discharge permit
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? n Yes or Z 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
Setback Waivers
Setback Waivers from adjacent landowners (8432, 8650, and 8707 Long Ridge
Road) were not included with the application, as was done during the previous
renewal in 2016.
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
n Issue upon receipt of needed additional information
n Issue
n Deny (Please state reasons: )
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6. Signature of report preparer: D'i' ��'"`e.
Signature of regional supervisor:
Date: 7/1/2021
g44 TTs.
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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