WQ0016247_Staff Report_20210826

;s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Erickson.Saunders(ii)ncdenr.eov
From: Maria.Schutte(a)ncdenr.eov
Mooresville Regional Office
Application No.: WQ00016247
Facility name: Synagro Western Piedmont Regional RLAP
County: NA — Multi -Regional
Note: This form has been adapted from the non -discharge facilily 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 setback conflicts for 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 BfMS.
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
"03" West of the water feature is now or should be part of "04". 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. An image from Synagro's application alongside a Google Maps aerial can be
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 W00002544 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 Should be `;yes ", but a site visit was not conducted.
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 IIL2 about potential field
buffer changes.
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain:
FORM: WQROSSR 04-14 Page 2 of 5

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 BU\4S? ❑ 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
C I II
C
C
C I II
C I II
C I II
C I II
C I II
C I II
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 bySynargro.
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. Ty ically,
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 IIL2.
above are accurate for
buffers and waivers.
See comments in IIL2.
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: )
6. Signature of report preparer:
Signature of regional supervisor:
Date: 7. 30.21
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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Fields NC-CL-21-03and04 referenced in IIL2. Photo of their map vs. Google aerial image of site:
FORM: WQROSSR 04-14 Page 4 of 5

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