WQ0038499_Staff Report_20210726

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
July 26, 2021
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Erick Saunders
Application No.: WQ0038499
Facility name: Bio-Green Services RLAP
From: Patrick Mitchell
Winston-Salem 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: July 22, 2021
b. Site visit conducted by: P. Mitchell and C. Caudle
c. Inspection report attached? ❑ Yes or ® No
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: S. Ray Gambill Certificate #:LA-985951 Backup ORC: Denise Harrison Certificate #:LA-987968
2. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes ❑ No ® N/A
Explain: Applicant dropping all existing land app. sites and all existing residuals source facilities from permit.
3. Is the description of the facilities as written in the existing permit correct? ® Yes or n No
4. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes No ® NE
5. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? ❑ Yes ® No ❑ N/A
If no, please explain: See IV. - Additional Regional Staff Review Items
6. Do the plans and site map represent the actual site (property lines, wells, etc.)? ® Yes ❑ No ❑ N/A
7. Is the proposed residuals management plan adequate? ® Yes ❑ No ❑ N/A
8. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? n Yes ® No n N/A
If no, please explain: See IV. - Additional Regional Staff Review Items
9. Are there any setback conflicts for proposed treatment, storage and disposal sites? ® Yes or ❑ No
Explain: See IV. - Additional Regional Staff Review Items; See attached maps.
10. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
11. For residuals, will seasonal or other restrictions be required? ❑ Yes ® No ❑ N/A
12. Has a review of all self -monitoring data been conducted (Annual Reports)? ❑ Yes or ® No
Summarize: Permittee has failed to submit an Annual Report for the previous two years (i.e., no 2019 & no 2020).
13. Are there any permit changes needed in order to address ongoing BIMS violations? n Yes or ® No
14. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
® Notice(s) of violation n Currently under SOC n Currently under moratorium
FORM: WQROSSR 04-14 Page 1 of 3

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Please explain: WSRO is in process of writing an NOV-NOI for failure to submit Annual Reporting for the
second year in a row, with possible enforcement to follow.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes n No ❑ N/A
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or n No
If yes, please explain: Site map corrections, soils corrections, etc. need to be corrected before permit issuance.
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 site maps
See IV. - Additional Regional Staff Review Items. Areas with unsuitable soil
depth to rock and water table must be buffered out of land app area.
Revised LASC tables in
Application Form
See IV. - Additional Regional Staff Review Items. Incorrect soil series for
fields needs to be revised.
Request info on VAR or
potential nuisance
conditions
See IV. - Additional Regional Staff Review Items. This is a rendering facility
which could potentially create nuisance conditions during land applicaiton
events. There was no discussion of this in applicaiton and VAR was checked
N/A on forms. If injection/incorporation is response, PAN calculation will need
to be revised and there will be footnotes required in the Att. B of permit for
depth restrictions for some fields. Will be provided if applicable.
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Item
Reason
Land application event
notifications to be made to
the Regional Office where
fields are located.
This will allow Division inspection of field activities. Source & fields located in
MRO while Permittee is located in WSRO. The two offices should coordinate
to ensure facility a comprehensive review of the facility is completed.
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
n Issue
n Deny (Please state reasons: )
,-DocuSigned by:
6. Signature of report preparer: Pafyict Akifttatt
Signature of regional supervisOr-5548B6CO265C47A...
Date: July 26, 2021
DocuSigned by:
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FORM: WQROSSR 04-14
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On July 22, 2021, WSRO staff conducted a review of the proposed new land application fields. The proposed new
residuals source facility was not reviewed. Below is a summary of notes from this review, including items which warrant
additional information to be requested. It should be noted that a detailed review of many field areas was not possible
due to access restrictions and standing row crops in the fields.
1. The RSC application form indicated Fecal Coliform will be utilized to meet Pathogen Reduction requirements but
listed "Not Applicable" for Vector Attraction Reduction requirements. This is a rendering facility; would VAR
alternatives 9 or 10 (injection or incorporation) or alternate method not be required to prevent nuisance conditions
during land application events? The PAN calculation utilized was for surface application, which suggests they
intend to surface apply residuals. This is a critical piece of information as it has implications on some land
application fields which would have restricted injection/incorporation depths because of shallow depths to
unsuitable characteristics. Request the Applicant provide an explanation or intent as related to potential
nuisance conditions associated with residuals from a rendering facility.
2. Residuals appear to meet regulatory limits (TCLP, Metals, & Pathogen).
3. The application indicated that predominant soil series present in Field 1 is Badin (BaB). The NRCS soil survey map
showed the field consisting of near 50% Goldston (GoC). The consulting Soil Scientist only placed one soil boring
located inside the area mapped as Badin but did not place any other soil borings in the proposed field. Division staff
placed soil borings on the eastern side of the field that was mapped as Badin and found that area to contain Goldston
soils. Therefore, the Goldston series is the predominant soil series present in Field 1.
This impacts the agronomic loading limits for Field 1. For example; Corn Silage for BaB = 224 lbs PAN/acre/year
while GoC = 104 lbs PAN/acre/year. See attached Soils Map sketch with notes. The LASC table in the application
needs to be updated to show Goldston (GoC) as the predominant soil series for Field 1.
4. The application indicated that predominant soil series present in Field 4 is Badin (BaB). However, the Soils Report
included in the application package indicated the predominant soil series for Field 4 is Goldston series. The NRCS
soil survey map in the application also showed Goldston (GoC) as the predominant soil series for Field 4. The
LASC table in the application needs to be updated to show Goldston (GoC) as the predominant soil series
for Field 4.
5. There is an area located in the northeastern side of Field 2, adjacent to the surface water feature, that has unsuitable
depths to rock and to water table. See attached Site Map Sketch 1 for location. The buffer map needs to be revised
to remove this unsuitable area and the field acreage needs to be updated in the application.
6. There is a drainage ditch in the offsite field adjacent to Field 4 which appears to extend to the edge of Field 4. See
Site Map Sketch 2 for location. Due to access restrictions and standing row crops, Division staff were unable to
confirm if the ditch stopped or if it extended into Field 4 requiring buffers. Regional Office staff need to inspect
this area once crops are removed or during the initial land application event to ensure minimum setbacks
are met and site maps are accurate.
7. Review of soil sampling results:
• The soil fertility sampling results showed soil pH levels below 6.0 with lime amendment recommendations
for Fields 1 and 5. Fields should receive lime as recommended or resampled to demonstrate acceptable soil
pH levels.
• The Sodium and Exchangeable Sodium Percentage values reported for all fields are acceptable.
• The background heavy metals sampling results were all well below the EPA risk assessment acceptable soil
concentrations.
8. It appears that sufficient land application field acreage is proposed to meet the agronomic loading limits without
expected issues with overloading. Based upon the information provided in the application, around 30 acres is
needed, and the proposal is for 71 acres. However, 100% of the proposed fields are currently row crop fields. This
could present issues with storage and the need for an alternative means of disposal during row crop growing
cycles.
FORM: WQROSSR 04-14 Page 3 of 3

WQ0038499 Soils Map

WQ0038499 Site Map Sketch 1
Unsuitable Depth
to Rock & Water Table

WQ0038499 Site Map Sketch 2