WQ0034513_Staff Report_20210921

DocuSign Envelope ID: 873F1 02F-8881-47F5-871 F-649B574F8E3D
State of North Carolina
®r- Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
September 21, 2021
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0034513
Attn: Erick Saunders Facility name: Brunswick Co. RLAP
From: Geoff Kegley
Wilmin on 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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: September 21, 2021
b. Site visit conducted by: Geoff Kegley
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: and their contact information: Rob Wilcox 336-339-9128
e. Driving directions:
2. Discharge Point(s): N/A
Latitude:
Latitude:
Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Longitude:
Describe receiving stream features and pertinent downstream uses:
11. 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: Ray Gambill Certificate #: 985981 Backup ORC: Denise Harrison Certificate #:987968
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: Existing permit: 1,790 DT/fir ((6 sources) Class B residuals on 376.00 acres.
Permit modification proposal is to add new one land application site (Brunswick County — fields BC-1 through
BC-7, 261.4 acres) and transfer two fields into permit: Pearly Vereen, Jr. - Field PV-3 (15.0 acres) and Alan
Vereen — Field AV-2 (4.7 acres).
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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 O&M 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:
I t . Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following ex and table if necessary):
Monitoring Well
Latitude
Longitude
O / //
O / 11
O / //
O I II
O I //
O I /I
O I //
O I It
O / //
O I If
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: 2020 Annual report was compliant.
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: none
17. Pretreatment Program (POTWs only): N/A
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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
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: ) DocuSigned by:
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6. Signature of report preparer:
Signature of regional supervisor:
Date: 9/22/2021
DocuSigned by: C017E2515D3B417...
E73B6F3456...
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This review was conducted for a request by Brunswick County to renew and to modify their
land application of residuals permit. The permit modification requests the addition of new one
land application site (Brunswick County — fields BC-1 through BC-7, 261.4 acres) and transfer of
two fields into permit: Pearly Vereen, Jr. - Field PV-3 (15.0 acres) and Alan Vereen — Field AV-2
(4.7 acres). The addition of these proposed fields would bring the total available acres for land
application to 657.1 net acres.
The 2020 annual report has been reviewed and was deemed compliant. The sludge analysis for
the sources indicate metals are below ceiling concentration limits, TCLP results were below
hazardous limits and sodium adsorption rates (SAR) results were below 10. In 2020, 74.73 total
dry tons were land applied to 64.5 acres. Field loading rates for metals and PAN are being
calculated, along with cumulative pollutant loading rates and are all within limits.
On September 21, 2021, staff met with Rob Willcox from Willcox & Mabe Soil Solutions LLC and
Tim Webb from Brunswick County to visit the new fields BC-1 through BC-7 to inspect the sites
for suitability for land application and to confirm buffer setbacks. The site soils are mostly
Baymeade, Foreston, Goldsboro, Norfolk and Onslow series which should be good receiver soils
for land application, with adequate separation to the seasonal high water table. Appropriate
buffer setbacks were observed. Fields BC-4 through BC-7 have been recently cleared and will
soon be graded and prepped for Bermuda grass planting prior to application events. Fields BC-
1 through BC-3 were mostly in trees with some fields that have been fifth rowed. These fields
are not planned for use in the near future and some fields will take some work prior to
application events. The soil samples indicate a pH <6.0 however, the residuals will be lime
stabilized and increase the pH. The new fields appear to be good receiver sites for the
application of class B residuals.
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