WQ0002376_Staff Report_20211130

DWR
Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
November 9, 2021
To: WSRO-WQROS: Lon Snider / Jenny Graznak
From: Erick Saunders, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0002376 Permit Type: Land Application of Residual Solids (503)
Applicant: City of Reidsville Project Type: Major Modification
Owner Type: Municipal Owner in BIMS? Yes
Facility Name: City of Reidsville Class B Residuals Program Facility in BIMS? Yes
Signature Authority: Summer Woodard Title: City Manager
Address: 1100 Vance St., Reidsville, NC 27320 County: Rockingham
Fee Category: Non -Discharge Major Fee Amount: $395 - Major Modification
Comments/Other Information: [e-mail]; [e-mail]
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.
❑ Attach an Attachment B for Certification.
❑ Return a completed staff report.
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:
DocuSigned by:
Czti titA, ( )JL
8E8349681-Q 949D._.
Date:
11/30/2021
FORM: WQROSNDARR 09-15 Page 1 of 1

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
Date 11/30/2021
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: WQ0002376
Attn: Erik Saunders Facility name: Reidsville RLAP
From: Caitlin Caudle
Winston-Salem 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: 11/18/2021 and 11/24/2021
b. Site visit conducted by: Caitlin Caudle and Patrick Mitchell
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Brent Collins and their contact information: (336) 399 - 3646
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Mike Collins Certificate #: 24990 Backup ORC: Brent Collins Certificate #:27651
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
Facility was not visited for this permit modification.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ['Yes or ® No
Please see comments and attached maps.
4. Is the existing groundwater monitoring program adequate? n Yes ❑ No ® N/A
5. Are there any setback conflicts for existing treatment, storage and disposal sites? ® Yes or ❑ No
If yes, attach a map showing conflict areas. Please see comments for NC-RC-016.
6. Is the description of the facilities as written in the existing permit correct? ® Yes or n No
7. Were monitoring wells properly constructed and located? ['Yes ❑ No ® N/A
8. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
9. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? n Yes or ® No
10. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or ® No
11. Check all that apply:
® No compliance issues n Current enforcement action(s) n Currently under JOC
n Notice(s) of violation n Currently under SOC n Currently under moratorium
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
12. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
nYes ®NonN/A
FORM: WQROSSR 04-14 Page 1 of 3

III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
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
LOA for NC-RC-015
An operator is listed but did not sign the form.
Updated site map for NC-
RC-012-02.
An updated site map is needed to show new buffered areas and acreage.
Updated site map for NC-
RC-015-01.
An updated site map is needed to show new buffered areas, a stream on and
adjacent to the property, and the property boundary on the northern side.
Updated site map for NC-
RC-126-06.
An updated site map is needed to show new buffered areas and the irrigation
hydrants in the field. Property boundaries must also be shown.
Updated LASC form.
The acreage, soil series, and coordinates for the fields must be updated.
3. 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 (Pleeoe,stutebyeasons: )
4. Signature of report preparer: Ctli tint, C4 A4Lt-
'-8B834968199D49D...
Signature of regional supervisor:
Date: 11/29/2021
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Uocusigneo by:
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Site visits were completed on November 18, 2021, and November 24, 2021. Brent Collins of EMA Resources was
present on the November 18th visit. Assuming at least 100 lb PAN/ac are applied each year, the reported acreage is
sufficient to accommodate the permitted dry tonnage. All fields are managed for hay.
NC-RC-012-02
An updated LOA form is needed as an operator is listed on the LASC form.
The GPS coordinates on the LASC form are incorrect. The correct coordinates for this field are: 36° 20' 32" and 79°
50' 37".
Mr. Collins stated that the well next to Truman Road is 100 ft from the application area. Several surface water
diversions were noted in the field. The smallest application area next to Truman Road will be removed due to the
presence of horses and other livestock. All changes are noted on the attached field map.
Soil borings were not completed in this field due to time constraints. The soils report provided with the application
confirm the presence of the mapped soils.
This field needs to be split into two separate fields, 2A and 2B. The portion next to Truman Road is mapped as
Rhodhiss, which has a PAN rate of 167 lb/ac for fescue hay. The portion in the woods is mapped as Clifford, which
has a PAN rate of 209 lb/ac for fescue hay. This field can easily be split into two management areas.
NC-RC-015-01
The GPS coordinates on the LASC form are incorrect. The correct coordinates for this field are: 36° 17' 22" and 79°
56' 01".
The soil listed on the LASC form is incorrect. According to the soils report provided with the application, the correct
soil series is Clifford.
FORM: WQROSSR 04-14 Page 2 of 3

The parcel containing the application area is owned by an LLC, which Mr. Collins stated was owned by a trust. Two
of the surrounding properties are owned by a Trustee. Will this be a problem? One of the houses marked as an "on site
dwelling" will impact the application area next to Bennett Farm Road. Property lines may also impact the application
area.
Mr. Collins stated that the pond will be buffered out, with an increased buffered area due to the topography and
standing trees of the surrounding area. Staff suggested that he increased the buffered area to the lowest terrace in that
field. Two surface water diversion ditches were also present above the pond, Staff requested those be buffered. Staff
also requested that two areas be buffered due to the slope.
Additional areas to be buffered were found on the second field visit. Two ditches were noted and an area of exposed
soil with obvious erosion. Staff also found that the stream on the field map is closer to the application area than noted
on the map, and a buffer will be needed. A field ditch follows the access road next to the northern property line but
should have the appropriate buffer when the property line buffer is added.
Five soil borings were reviewed in this field. Two borings discovered an area of unsuitable soil in a lowland area. The
additional soil borings confirmed the suitability of the soils, and the accuracy of the soil map. Additional comments
can be found in the inspection report.
This field also needs to be split into several fields due to differences in soil types and the size of the field. There are
several individual management areas separated by access roads, Separating the field will also provide an easier way to
track residuals application. The predominate soil series in this field are Clifford (209 lb/ac for fescue hay), Fairview
(154 lb/ac for fescue hay), and Nathalie (178 lb/ac for fescue hay). Suggested field separations will be noted on the
attached field man.
Application Area
Soil Type
Approximate Acreage
IA
Clifford
4.1
1B
Clifford
5.8
1C
Clifford
14.8
1D
Clifford
10.3
1 E
Clifford
3.6
1F
Nathalie
1.6
1G
Fairview
7.3
1H
Nathalie
12
*Acreages are not accurate and were calculated using Web Soil Survey.
NC-RC-126-06
The soil listed on the LASC form is incorrect. According to the soils report provided with the application, the correct
soil series is Rhodhiss.
Three surface water diversions were noted in the field. Culverts were noted at the northern end of the field next to the
access road. Staff requested that a 25ft buffer be applied to each culvert beside the field. Irrigation hydrants are also in
this field and staff requested that each hydrant be marked on the field map.
The soils report provided by the application confirm the presence of the mapped soils.
FORM: WQROSSR 04-14
Page 3 of 3

Compliance Inspection Report
Permit: WQ0002376 Effective: 06/04/20 Expiration: 12/31/26 Owner : City of Reidsville
SOC: Effective: Expiration: Facility: City of Reidsville RLAP
County: Rockingham 230 W Morehead St
Region: Winston-Salem
Contact Person: Steven L Routh
Directions to Facility:
Reidsville NC 27320
Title: Director of Public Works Phone: [phone]
System Classifications: LA,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NC0024881 City of Reidsville - Reidsville WWTP
Inspection Date: 11/18/2021
Entry Time 09:15AM Exit Time: 12:39PM
Primary Inspector: Caitlin Caudle Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Reconnaissance
Permit Inspection Type: Land Application of Residual Solids (503)
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page 1 of 5

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 11/18/2021 Inspection Type : Reconnaissance
Reason for Visit: Routine
Inspection Summary:
On November 18, 2021, Division of Water Resources conducted a scheduled permitting visit for the purpose of reviewing
three fields that were being added to the subject permit. Brent Collins of EMA Resources was present during the entire visit.
A review of new application fields was completed, and a separate review of the permit application was completed in office. A
second field visit was completed on November 24, 2021, with Patrick Mitchell of NCDA to review the completed soils work.
NC-RC-012-02
Surface water diversions were discovered in the field and Ms. Caudle requested that they were buffered. A culvert leading
under the driveway was also buffered out as a drainage way. The smallest portion of the field was removed as horses and
other livestock were present in the field. The portion of the largest field that appears to be planted in pine trees on the
application map will also be removed.
The soils map shows that the largest field is mostly Clifford, and the field next to Truman Road is mostly Rhodhiss. The soil
scientist investigation confirmed this. Both fields are managed as fescue hay. The PAN for fescue hay for Clifford is 209
Ib/ac and the PAN for Rhodhiss is 167 Ib/ac. Ms. Caudle suggested splitting this field into 2A and 2B to prevent
overapplication on the Rhodhiss soils. The configuration of these fields and the soil mapping units would allow for this
change easily.
Ms. Caudle noted that on the landowner agreement form for this field a lessee signature is not present even though an
operator is listed on the LASC form. The LOA from requires that an operator/lessee sign the form. An updated form with the
operator must be submitted. Mr. Collins stated that the GPS coordinates listed on the LASC were incorrect. The correct
coordinates are 36° 20' 32" and 79° 50' 37."
A soil boring was not done at this field due to time constraints and the work submitted by the soil scientists.
NC-RC-015-01
Mr. Collins stated that the GPS coordinates listed on the LASC form were incorrect. The correct coordinates are 36° 17 22"
and 79° 56' 01." The soil series was incorrectly listed on the LASC form as Rhodhiss. The correct soil series is Clifford. All
individual fields on this property are managed as fescue hay.
Mr. Collins stated that the pond will be buffered. Ms. Caudle requested that a larger area surrounding the pond based on the
slope and standing trees. Mr. Collins stated that he will buffer the area to the lowest terrace. Ms. Caudle also requested that
two small drainage ways above that terrace be buffered. Two more areas with limiting slopes were requested to be buffered
out (shown on field notes). Upon the second field visit it was noted that the stream shown on the map is closer to the
application area and a buffer will need to be applied.
Two soil borings were reviewed in this field on 11/18/2021.
CLC1
0-6"Sandy, yellow in color
6-15" Picked up clay, 2.5YR 6/8
15-19" Small white inclusions, 2.5YR 7/4
19-29" More white inclusions, sandier
29-31" Mica flakes present
31-40+" Gley colors present
40+' 2.5Y 6/3, sandy
CLC2
0-3"Granular, brown in color, sandy
3-9"Granular, finer sand, 7.5YR 5/8
Page 2 of 5

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 11/18/2021 Inspection Type : Reconnaissance
Reason for Visit: Routine
9-17" Some mottles present, matrix color 7.5YR 6/8
17-30" Frequency of mottles increasing, matrix color 7.5YR 6/8
30-36" Coarser sand present, similar matrix colors
36+" Subangular blocky, more clay present
CLC1 was not consistent with the soil description for Nathalie, the mapped soil series. Gley colors were present below 15".
CLC2 had no evidence of a seasonal highwater table within 36". The boring was at the bottom of a terraced slope.
Three soil borings were reviewed in this field on 11/24/2021.
CLC4
0-3"10YR 4/4, common fine and medium roots, fine sandy loam, granular
3-9"7.5YR 5/6, sandy clay loam, medium subangular blocky
9-21" 5YR 5/8, medium subangular blocky, mica present
21-36" 5YR 5/8, 7.5YR 7/8 common to few mottles, mottles increase with depth, saprolite and weathered rock appear
36+" Saprolite, many to common yellow brown mottles
PM2
0-8"Yellow brown coarse sandy loam, granular
8-25" 7.5YR 7/1-2, silty clay loam, gley matrix, common iron inclusions 5YR 5/8
CLC5
0-2"Brown, common fine roots, sandy clay loam, fine sand
2-158" 10YR 5/6, fine sandy clay loam
15-20" 7.5YR 5/8, clay loam, few fine gray mottles
20+" Parent material/saprolite, gravelly
PM2 was not consistent with the soil description for Nathalie. This area is likely and inclusion of Hatboro soil series. This
area is not suitable for land application.
Clifford, Fairview, and Nathalie are common soil series in this field. Nathalie has a PAN of 178 Ib/ac, Clifford has a PAN of
209 Ib/ac, and Fairview has a PAN of 154 Ib/ac for fescue hay. The field is designated as Clifford but that is not
representative of the lowland areas of the field. This field should also be split into multiple individual fields to accurately
represent the soil series and prevent overapplication on those areas where Clifford is not present
A house on an adjacent parcel is marked as an onsite dwelling. The parcel with the application fields is owned by Bennett
Farms, LLC, the adjacent parcel is owned by W. Bert Bennett Trustee. W. Bert Bennett signed for the LLC.
A small pond was noted on the regional soils map. This pond was reviewed on 11/24/2021 and there was no standing water,
trees were growing in the pond.
NC-RC-126-06
The soil series on the LASC was incorrectly listed as Clifford, this field should be Rhodhiss.
A field drainage way was noted on both sides of the fence that divides the field. A culvert passes underneath the fence. Ms.
Caudle requested that the drainage way be buffered. Another small drainage way was noted above the flood plain,
crenulations can be seen on the application map that show the drainage way. A drainage way was noted above the field
drain depicted on the application map.
Irrigation hydrant hook ups are present in the northern portion of the field and Ms. Caudle requested that Mr. Collins mark
each hook up on the application maps. Ms. Caudle also noted that many of the terraces in the field drain to the access road
Page 3 of 5

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 11/18/2021 Inspection Type : Reconnaissance
Reason for Visit: Routine
where culverts or other stormwater measures are present. Ms. Caudle requested that Mr. Collins review the access road and
terraces to determine where culverts are present and place the appropriate buffers for these drainage features.
CLC3
0-2"Granular, brown
2-13" Subangular blocky, 5YR 4/6
13-31" Mottles with mica present, possibly saprolite or B/C
Page 4 of 5

Permit: WQ0002376 Owner - Facility: City of Reidsville
Inspection Date: 11/18/2021
Inspection Type : Reconnaissance
Reason for Visit: Routine
Page 5 of 5

Field Total Acres Applicable Acres
2 20.94
SCALE:
DATE:
DRAWN BY:
PROJECT NO:
WQ0002376
1 "=440'
07-25-21
BC 1 —Resources, Inc.
USDA,
On Site Dwelling
Structure
• Well
■ Off Site Dwelling
Stream
Buffer
Field Boundary
Ge®Eye
Aer@GRI
City of Reidsville
Land Application Program
NC-RC-012
Lawrence McCollum
FIGURE NO.
2
C:\Users\letsg\Documents\ArcGIS\GIS Data \ Reidsville \ Maps \RC012-02(2).mxd

PXw'(Z)-960321\sdeyy\alllnsP!aH\ele4 SIJ\slow s;uawnnoo4\6s3apsiasn\:3

Field TotalAcres App|icab|eAcres
1^=440'
10'13-21
PROJECT NO
VV00002370
City of Reidsville
Land Application Program
NC-RC'120
State ofNorth Carolina
Monitoring Well
Off Site Dwelling
Fonoe|ino
Drain
Buffer
Flood Zone
Pond
Field Boundary
Property Boundary
FIGURE NO.
C:\Users\letsg\Documents\ArcGIS\GIS Data\Reidsville\Maps\RC126-(06)(2).mxd