WQ0006017_Staff Report_20210421

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

April 21, 2021
To: NPDES Unit Non-Discharge Unit Application No.: WQ0006017
Attn: Poorva Mokashi Facility name: Town of Beaufort Land Application of Residuals

From: Geoff Kegley
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: and their contact information:
a.Driving directions: .
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Subbasin 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 4

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: Robert Roth Certificate #: 1001672 Backup ORC: John Culp Certificate #:1000733
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: Class B residuals land application program: 1 source, 140
maximum dry tons per year total, 2 fields with 63.34 net acres for application.

Proposed flow: n/a

Current permitted flow: n/a

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.
FORM: WQROSSR 04-14 Page 2 of 4

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
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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:
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:
17. Pretreatment Program (POTWs only):
IV. 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
Resubmit the Landowner Agreement
The Landowner Agreement Form was not signed by the Permittee.
Form (LOA 06-16)

FORM: WQROSSR 04-14 Page 3 of 4

3. List specific permit conditions recommended to be removed from the permit when issued:
ConditionReason

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:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

This review was conducted for a permit renewal for the Town of Beaufort
of residuals program. The 2020 annual report was received and reported that 82.12 dry
tons were applied on 40.0 acres. Average dry tons per year have consistently been below
the 140 dry tons/year currently permitted. Metals and TCLP results were within limits,
PAN loading rates and cumulative pollutant loading rates on the application fields were
within permit limits, SAR rates were below 10, and pathogen and vector attraction
reduction requirements were demonstrated.

After review of the submitted permit application, previous annual reports, current residuals
analysis and application fields PAN loading rates, the WiRO has no objection to renewal of
the permit. However, the Landowner Agreement Form was not signed by the permittee
and should be requested to be resubmitted before issuance of the permit.

FORM: WQROSSR 04-14 Page 4 of 4