WQ0006101_Staff Report_20210728

Y State of North Carolina
Division of Water Resources
" Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Erick Saunders
From: Jim Barber
Fayetteville Regional Office
Application No.: W00006101
Facility name: City of Dunn RLAP
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.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 24 June 2021
b. Site visit conducted by: Jim Barber and Tony Honeycutt
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Heather Adams and their contact information: [phone] ext.
e. Driving directions: City of Dunn WWTP: 580 J.W. Edwards Lane, Dunn NC (P.O. Box 1064 Dunn NC 28335).
From Fayetteville take I-95 to Exit 73 (Hwy 421/Dunn). Turn left onto Hwy 421/West Cumberland St. and
proceed into Dunn. At the intersection of Hwy 421/W. Cumberland St and S. McKay Ave. turn left and drive
approx. 0.60 miles and turn right onto Susan Tart Rd. Follow Susan Tart Rd. for 0.80 miles and turn left
onto J.W. Edwards Ln. J.W. Edwards Ln terminates at the City of Dunn WWTP.
2. Discharge Point(s): Plant site is located as follows.
Latitude: 35.296568 Longitude:-78.637457 (approx.. center of wwtp site)
Latitude: Longitude:
3. Receiving stream or affected surface waters: Black River (NPDES discharge receiving stream)
Classification: C Sw
River Basin and Sub -Basin No.: Cape Fear 18-68-12-1
Describe receiving stream features and pertinent downstream uses: Agriculture consisting of row crop
farming with pasture grazing of cattle.
IL 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:
FORM: WQROSSR 04-14 Page 1 of 6

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:
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: Jason Smith Certificate 9: LA-13266 Backup ORC: Drew Matthews Certificate 9: LA-1003075
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: Land application of residual solids from the City of Dunn WWTP (NPDES
permit NC0043176) and City of Dunn WTP. Facility currently has a limit of 650 Dry Tons/Year for land
application and is requesting the same for this renewal.
Proposed flow: 3.75 MGD (NPDES NC0043176)
Current permitted flow: 3.75 MGD (NPDES NC0043176). Dunn WWTP is currently under a moratorium
due to average flows being at 3.75 MGD+.
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.). The Dunn WWTP was added as a source to the Granville Farms land application permit
(WO0002890) in Sampson County. Granville Farms assumed the permit from the City of Clinton. The
permit has approx. 1800+ acres of land associated with it and is all encompassed on one farm in Sampson
County. Granville Farms is the new land application contractor for Dunn, replacing SYnagro. Between the
remaining acreage (67 acres in the Dunn permit that is being modified) and the 1800 acres in the Granville
Farms permit; there is more than enough land for managing Dunn's current residuals volume and future
volumes once the plant is upgraded and discharge flows increase.
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: The farms being removed were recently added and very little application took place at
the farms. The existing farms that will remain in the permit have not changed nor has the surrounding
areas. Current buffer maps are acceptable.
FORM: WQROSSR 04-14 Page 2 of 6

5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain: Residuals will be managed by Granville Farms on land in the Dunn permit and
Granville Farms permit.
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:
FORM: WQROSSR 04-14 Page 3 of 6

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
C rr
C rr
C rr
C rr
C rr
C rr
C rr
C rr
C rr
C rr
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: Annual reports for the City of Dunn have been
reviewed for the past three Years by Tony Honeycutt. No compliance issues observed.
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: N/A
17. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 4 of 6

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: )
6. Signature of report preparer: Jim Barber
Signature of regional supervisor: Jim Barber for Trent Allen
Date: 26 July 2021
FORM: WQROSSR 04-14 Page 5 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The Fayetteville reeional office visited the fields beine removed and found the farms to be in very Good
condition, with no issued noted.
The City of Dunn land application permit will have approximately 67 acres consisting of row crop and grass
land in their proaram with this permit modification/renewal request. Combined with the Granville Farms
permit (WO0002890) with 1816 acres in bermuda grass pasture/hay production and the average dry tons per
year applied beine around 350 (for the past three years from the wastewater plant and water plant combined);
there is more than enough acreage available to the City of Dunn for residuals application.
FORM: WQROSSR 04-14 Page 6 of 6

State of North Carolina
Department of Environmental Quality
Division of Water Resources
. .. .Ott' WATER QUALITY REGIONAL OPERATIONS -SECTION
NON -DISCHARGE APPLICATION REVIEW REQUEST.FORM
Dlvislon of Water Resources
June 21, 2021
To: FRO-WQROS: Trent Allen / Mark Brantley
From: Erick Saunders, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0006101
Applicant: City of Dunn
Owner Type: Municipal
Facility Name: City of Dunn RLAP
Signature Authority: Heather Adams
Address: PO Box 1065, Dunn, NC 28335
Fee Category: Non -Discharge Major
Permit Type: Land Application of Residual Solids (503)
0
Comments/Other Information: [e-mail]; [e-mail]
Project Type: Renewal
Owner in BIMS? Yes
Facility in BIMS? Yes
Title: Public Utilities Director
County: Harnett
Fee Amount: $0 - Renewal
Attached, you will find all information submitted in support of the above -referenced application for your review, comment,
and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer: Jim .Barber
Date: 26 July 2021
FORM: WQROSNDARR 09-15 Page 1 of 1

ComDliance Inwection Report
Permit: WQ0006101 ' Effective: 07/08/20 Expiration: 09/30/21 Owner: City of Dunn
SOC: Effective: Expiration: Facility: City of Dunn RLAP
County: Harnett 580 J W Edwards Ln . .
Region: Fayetteville
Dunn NC 28334
Contact Person: Steven Neuschafer Title: City Manager Phone: [phone]
Directions to Facility:
From Fayetteville take 1-95 to exit 73. Turn left onto Hwy 421/West Cumberland St. and proceed into Dunn. At the intersection of Hwy
421 and S. McKay Ave. turn left & go 0.6 mi, turn right onto Susan Tart Rd. (go 0.8 mi), turn left onto J.W. Edwards Ln.
System Classifications: LA,
Primary ORC: Drew Matthews Certification: 1003075 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0043176 City of Dunn - Dunn WWTP
Inspection Date: 06/24/2021 Entry Time 09:30AM
Primary Inspector: Tony W Honeycutt
Secondary Inspector(s):
Exit Time: 11:30AM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions Record Keeping Land Application Site
(See attachment summary)
Page 1.of 4

Permit: WO0006101 Owner - Facility: City of Dunn
Inspection Date: 06/24/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Facility records were up to date and available for review.
The field sites were in good condition with a healthy vegatative crop.
Granville Farms Inc. has taken over hauling operations for the town.
No additional problems noted.
Page 2 of 4

Permit: WO0006101 Owner - Facility: City of Dunn
Inspection Date: 06/24/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there -any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutdent/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment:
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Are there access restrictions and/or signs?
Yes No NA NE
Yes .No NA NE
❑ ❑ E ❑
❑❑N❑
❑❑■❑
❑❑■❑
■❑❑❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑❑❑
■❑❑❑
❑ ❑ ❑ E
❑ ❑ E❑
■❑❑❑
❑ ❑ ❑
■❑❑❑
❑ ❑ ❑
❑❑❑
■❑❑❑
❑❑■❑
Yes No NA NE
❑❑■❑
■❑❑❑
■❑❑❑
❑ ❑ N❑
❑ ❑ ❑
Page 3 of 4

Permit: WQ0006101 Owner - Facility: City of Dunn
Inspection Date: 06/24/2021 Inspection Type : Compliance Evaluation Reason for Visit: Routine
- Is the application site free of odors or vectors? M ❑ ❑ ❑
Have performance requirements for application method been met?
For injection?
❑ ❑ 0 ❑'
For incorporation?
0 ❑- ❑ ❑
Does permit require, monitoring wells?
❑ ❑ M ❑
Have required MWs been installed?
❑ ❑ M ❑
Are MWs properly located w/ respect to RB and CB?
❑ ❑ 0 ❑
Are MWs properly constructed (including screened interval)?
❑ ❑ 0 ❑
Is the surrounding area served,by public water?
❑ M ❑ ❑
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
❑ ❑ 0 ❑.
Are soil types consistent w/ Soil Scientist report/evaluation?
0 ❑ ❑ El
Is the water table greater than, 173' bls.
❑ ❑ ❑'
Is application occurring at the time of the. inspection?
❑ 0 ❑ ❑
Comment: Public water is not available.
Land application operations were not taking place at the time of the inspection visit.
f
0
Page 4 of 4

Barber, Jim
From:
Sent:
To:
Subject:
Attachments:
Trent Allen
Fayetteville Regional Supervisor
Division of Water Resources
910 433 3336 office
910 303 1109 mobile
[e-mail]
225 Green Street — Suite 714
Fayetteville, NC 28301
Allen, Trent
Tuesday, June 22, 2021 10:28 AM
Barber, Jim; Honeycutt, Tony
FW: [STAFF REPORT REQUEST] WQ0006101 -.City of Dunn RLAP Renewal Application
WQ00061.01 WQROSNDARR 210621.pdf
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties
From: Thornburg, Nathaniel
Sent: Monday, June 21, 20213:01 PM
To: Allen, Trent <[e-mail]>; Brantley, Mark <[e-mail]>
Cc: Saunders, Erickson G <[e-mail]>
Subject: [STAFF REPORT REQUEST] WQ0006101- City of Dunn RLAP Renewal Application
RO Supervisors — Please assign this project to one of your staff for review.
APPLICATION LINK:
https://edocs.deg.nc.gov/WaterResources/DocView.aspx?id=1856060&dbid=0&repo=WaterResources
Thank you,
Nathaniel D. Thornburg
Branch. Chief
Non -Discharge Branch
Department of Environmental Quality
919 707 3653 office
[e-mail]
512 N. Salisbury St.
1
J

Initial Review
Reviewer Thornburg, Nathaniel D
Is.fhis.submittal an. application?'(Excluding additional information-.)*
r -Yes: C No
Permit Number (IR) * WQ0006101
Applicant/Permittee City of Dunn
Applicant/Permittee Address PO Box1'065 Dunn. NC 26335
Is the owner in BIMS?- C Yes. C No Is the facility1h BIMS? r Yes C No
t)wner•Type
Municipal
Facility Name
City of Dunn RLAP
County
Harnett
Fee Category. Major
Fee Amount t0
Is this a. complete
application? *'
r Yes C No
Complete App Date 06/21/2021
Signature Authority
Si g n atu ie -Authority. Title
Sig nature. Authority Email
Docume.nt:Type (fnon-application)
Email Notifications.
Does this need reviewtbythe hydrogeologist?*
C Yes r No
Regional'Office
CO Reviewer
Admid Reviewer
Below list any additional email address. that need..notification about a new project.
Email Address
Commenfs to be added to email notfication
Comments for Admin
Comments for RO

Submittal Form
Pcoledt.Cvntad Information
AePse pnv ud naE Lrt tx1 tte rsix� to be ceaata led by M1L8 haft rc�arcLrxu etectemac s �mltai'crnfmr n of reYz�pt a vi Other
Name`' Drew Matthews
Email Address* Phone. Number.*
dmatthews@soiiplusmot 2528639301
Prtsject Information
ApplicationlDdeument Type'
c New (Fee Required)
C. 'Modification - Major (Fee Required).
C Renewal with Major Modification (Fee
Required)
C• Annual Report
C Additional Information
r Other
0 'Modification - Minor.
C` Renewal
n OW-59, NDMR, NDMLR, NDAR-1,
NDAR-2
r Residual Annual Report
Change of Ownership
We' no"ionger accepE' iiese:monitoring reporis"through this.portal. Please click.on the link below and it will take you.to the correct form::
hzps:ireoocs.deq no.goviFormsiNonDischargo_P,icnitoring_Report
Permit Type:*
Permit Number:*
0 Wastewater Irrigation
r. Other Wastewater
C Closed-Loop.Recycle
r, Single -Family Residence Wastewater
Irrigafion
c° High -Rate Infiltration
0, Reclaimed Water
r Residuals
r� Other
WQ0006101
FesOfrentExst€itgpemitr ilm
Applicant/Permittee * City of Dunn
Applicant/Permittee Address,* PO box 1065 Dunn, NC 26335
Facility Name * City of Dunn RLAP
Please: provide comma ntslnotes on your current submittalbelow.
At this'time, papercopies are no longer required. if you have any questions aboutwhat is required, please contact Nathaniel Thornburg
atrtatha'[e-mail].
Please attach: all' information required or requested for this;submittal to be reviewed here.
(Aplfr.akn Form AWN Fign% ticatars,,Calculau6i s. Bc.)
2021 City of Dunn RLAP Permit Renewal!pdf 30. 5M13
t1cxicciyIFCFdwct,rt(L,ssthan 250hB)Mill°piedocurrenfsmstbecirt0edir oii8ftFfile .un[e6sJk- is bgffthm,
iptoad iitrit,
By checking this box, I acknowledge that I understand the application will not be
aceepted:for pre -review until the fee (if required) has been received by the: Nor -
Discharge Branch. Application fees must be submitted bycheck,or money order
and made payable to the North Carolina Department of Environmental Quality
(NCDEQ). Ialso confirm that the uploaded document is.a single PDF with all parts
of the application in correct order (as specified by the application).
Mail payment to:
NCDEQ.— Division of 1+5later Resources
Attn: Non-Oischaae Branch
1617 Mail Service Center
Raleigh, NC`27699-'1617
Signature
Submission Date 6/2112021

ROY COOPER
Governor
JOHN NICHOLSON
Interim Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
June 21, 2021
HEATHER ADAMS — PUBLIC UTILITIES DIRECTOR
CITY OF DUNN
POST OFFICE BOX 1065
DUNN, NORTH CAROLINA 28335
Subject: Acknowledgement of
Application No. WQ0006101
City of Dunn RLAP
Residuals Management System
Harnett County
Dear Ms. Adams:
The Water Quality Permitting Section acknowledges receipt of your permit application and
supporting documentation received on June 21, 2021. Your application package has been assigned the
number listed above, and the primary reviewer is Erick Saunders. .
Central and Regional Office staff will perform a detailed review of the provided application, and
may contact you with a request for additional information. To ensure maximum efficiency in processing
permit applications, the Division of Water Resources requests your assistance in providing a timely and
complete response to any additional information requests.
If you have any questions, please contact Erick Saunders at [e-mail].
Sincerely,
Nathaniel D. Thornburg, Supervisor
Division of Water Resources
cc: Fayetteville Regional Office, Water Quality Regional Operations Section (Electronic Copy)
Laserfiche File (Electronic Copy)
D_EC
tfON7?kC?i+^..1..MtA
UQcanne 10flAiNamC we"Itr
North Carolina Department of Environmental Quality I Division of Water Resources.
512 North Salisbury Street 1 1617 Mail Service Center- I Ra.leigh; North Carolina.27699-1617
919.707.9000