WQ0020239_Staff Report_20210708

DocuSign Envelope ID: A7B827AF-8218-4789-BC92-6B62F65698E5
Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0020239
Attn: Poorva Mokashi
From: Randy Sipe
Washington Regional Office
Facility name: Town of Hertford 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 ❑ No
a. Date of site visit: 7/7/21
b. Site visit conducted by:
c. Inspection report attached? ® Yes or ❑ 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 system.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A, non -discharge system.
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: J. Bryan Smith Certificate #: LA/13598 Backup ORC: Brad Granger Certificate #:LA/985517
Note: Currently there is no ORC listed in BIMS and Mr. Smith is listed as the Backup. If the permittee has not
already submitted a ORC change form they should do so.
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 Hertford 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
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DocuSign Envelope ID: A7B827AF-8218-4789-BC92-6B62F65698E5
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.) See the comments under Item II.4 below.
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: Site conditions at the land application fields were observed during the site visit to be
adequate.
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: As shown on the attached map and photos, during the site visit a shooting range was
observed in the SW corner of Field 2-1 and two public water supply wells were observed NW of Field 2-1 along
Pender Road. The application and map should be revised to address the presence of these features.
5. Is the residuals management plan adequate? ® Yes or ❑ 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 ❑ No
If no, please explain: : Based on information provided in the annual reports and 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? ['Yes ❑ 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? ['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: See Item 7 above.
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary): See Item 7 above.
Monitoring Well
Latitude
Longitude
O ,
„
0 ,
II
O ,
„
0 ,
II
O ,
„
0 ,
II
O ,
„
0 ,
II
O ,
„
0 ,
„
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: WaRO issued NOV/NOIs and Enforcements to the
Town of Hertford for application of residuals onto unpermitted fields in 2017 and for failing to collect the
required soil fertility analysis samples in 2020. These cases have been closed there is currently no outstanding
compliance issues associated with Permit # WQ0020239.
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 ❑ 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.) See the
comments under item II.12 above.
FORM: WQROSSR 04-14
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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 the comments under item 11.12 above.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No n 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, non -discharge system.
17. Pretreatment Program (POTWs only): N/A, non -discharge system.
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: The add. info. described under Item III.2 below should be provided before issuance of a
permit.
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
Revised Map for Field 2-1
and Revised Application
As shown on the attached map and photos, during the site visit a shooting range
was observed in the SW corner of Field 2-1 and two public water supply wells
were observed NW of Field 2-1 along Pender Road. The application and map
should be revised to address the presence of these features.
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
FORM: WQROSSR 04-14
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DocuSign Envelope ID: A7B827AF-8218-4789-BC92-6B62F65698E5
Issue upon receipt of needed additional information
fl Issue
n Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor: R'ode44 T4l . 4
Date: 7/8/2021
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 4 of 4