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HomeMy WebLinkAboutWQ0034806_Staff Report_20210610 State of North Carolina Division of Water Resources Water Quality Regional Operations Section Staff Report June 9, 2021 To: NPDES Unit Non-Discharge Unit Application No.: WQ0034806 Attn: Erickson Saunders Facility name: Coastal Farms and Residuals From: Bryan Lievre 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? Yes or No d. Person contacted: e. Driving directions: 2. Discharge Point(s): N/A 3. Receiving stream or affected surface waters: N/A Classification: River Basin and Subbasin No. Describe receiving stream features and pertinent downstream uses II. PROPOSED FACILITIES: NEW APPLICATIONS: N/A III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A ORC: Wesley Wooten Certificate #: 993105 Backup ORC: Martin Mabe Certificate #: 22753 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: Permit currently allows for land application of 2,175 DT/yr class B residuals from 16 sources on 12 fields (545 net acres) Proposed flow: Proposal is to remove 1 source (Military Ocean Terminal/Sunny Pt, NC0029122) and increase land application of three sources (Wallace Chicken Processing Plant NC0003344 from 150 to 250 DT/yr; Beau Rivage WWTP NC0065480 from 10 to 25 DT/yr; and, Swansboro WWTP WQ0023261 from 35 to 50 DT/yr) to net 2,205 DT/yr. FORM: WQROSSR 04-14 Page 1 of 4 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. 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., DMR, NDMR, NDAR, GW)? Yes or No Please summarize any findings resulting from this review: Review of the 2020 annual report was deemed compliant. A Notice of Violation was issued in 2017 (Tracking Number NOV-2017-PC-0646) resulting from an inspection of a site where waste was found to be ponded in excess of agronomic rates, no signage was present, no suitable cover was observed and residuals were stockpiled in violation of Permit Condition III. 8. (whereas Class B residuals shall not be stored at any land application site without approval from the Division). All issues associated with the above NOV have been resolved. 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.) 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? FORM: WQROSSR 04-14 Page 2 of 4 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: none 17.Pretreatment Program (POTWs only): N/A 18.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 supervisor: Date: FORM: WQROSSR 04-14 Page 3 of 4 IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS This review was conducted for a request by Coastal Farms and Residuals to modify their land application of residuals permit. The permit modification requests permission to: - Remove 1 source (Military Ocean Terminal/Sunny Pt, NC0029122); - Increase land application of Wallace Chicken Processing Plant NC0003344 from 150 to 250 DT/yr; - Increase land application of Beau Rivage WWTP NC0065480 from 10 to 25 DT/yr; and, - Increase land application of Swansboro WWTP WQ0023261 from 35 to 50 DT/yr. These changes would increase the total amount of residuals to be certified to 2,205 dry tons/year. In 2020, a total of 482.80 dry tons were land applied utilizing 93.4 acres. Field loading rates for metals and PAN are being calculated, along with cumulative pollutant loading rates which are compliant. The sludge analysis for the new source indicate metals are below ceiling concentration limits and sodium adsorption rates (SAR) results were below 10 and TCLP results were below limits. With the large amount of acreage available for land application activities, it appears that Coastal Farms has the capacity to add this additional source and not overload their fields. After review of the submitted application, the WiRO has no objection to issuance of this permit modification. FORM: WQROSSR 04-14 Page 4 of 4