WQ0016247_Staff Report_20210730

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

To: NPDES Unit Non-Discharge Unit Application No.: WQ00016247
Attn: [e-mail] Facility name: Synagro Western Piedmont Regional RLAP
County: NA Multi-Regional
From: [e-mail]
Mooresville 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 NA
d. Person contacted:
e. Driving directions:
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
Classification:
River Basin and Sub-basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
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? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 5

6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7.Are there any setbackconflictsfor proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No 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: R. Nate Roth Certificate #: 1001672 Backup ORC: Adam Brigman Certificate #: 1006653
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: This is a multi-regional Class B land application permit. The current
modification is to add 3 sources (2 in MRO & 1 in RRO) and several fields (only existing transferred fields in the
MRO, both transferred and new fields in RRO). MRO staff reviewed existing fields in this region only, via GIS
and BIMS.
NC-CL-08-14 is noted on map title, but blocked out on the map as it is not part of this modification.
NC-CL-21-03and04. Is division between fields still accurate? Per current GIS image it appears the extent of
And/or farming practices should be assessed to
determine if the northern acreage of both sites is in different crop(s) than currently stated in land application
program. LOA states Pasture/Hay.
found on the last page of this staff report that shows the differences between the application and current land use.
NC-CL-21-07 was corrected in BIMS for coordinates under the current permit WQ0002544 Clariant-MHW.
NC-LT-32-04 has four associated setback waivers (verify they were updated) MRO staff did not locate them in
the application.
Proposed flow: NA this is a land application permit.
Current permitted flow: NA
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 But, see previous comments in III.2 about potential field
buffer changes.
If yes, please explain:
5. Is the residuals management plan adequate? Yes or No
If no, please explain:
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6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No N/A
If no, please explain: This is a land application permit. Application rates need to be calculated with relevant
sampling results.
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program: Groundwater monitoring is
currently not required on non-dedicated application sites.
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): I have no records that these MWs exist.
Monitoring Well Latitude Longitude
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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: SAR calculations missing from 2020 Annual Report,
received in separate email from Nate Roth, per Maria Schutte blanket additional information request for all MRO
LA permits operated by Synagro.
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?
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: ND permit should not result in discharges to surface waters. Typically,
only by spill or run-off from over-application (fecal, solids, etc.). There is also a potential that impacted
groundwater could interact with surface water.
17. Pretreatment Program (POTWs only):
IV. REGIONAL OFFICE RECOMMENDATIONS
FORM: WQROSSR 04-14 Page 3 of 5

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
Verify fields noted in III.2.
above are accurate for See comments in III.2.
buffers and waivers.
Should CO request additional information, MRO staff would also like to review

prior to permit issuance.

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: )
th
6. Signature of report preparer: Maria Schutte July 30, 2021
Signature of regional supervisor:
Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Fields NC-CL-21-03and04 referenced in III.2. Photo of their map vs. Google aerial image of site:
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