WQ0008008_Staff Report_20220606

DocuSign Envelope ID: 06C1D510-8471-40A4-A1BC-DA46EEB4B93B
Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0008008
Attn: Erick Saunders
From: Randy Sipe
Washington Regional Office
Facility name: Pasquotank County WTP 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 applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ® No
a. Date of site visit: NA
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: NA and their contact information: ()
e. Driving directions: NA
2. Discharge Point(s): NA, non -discharge system.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA, non -discharge system.
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
ext.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No ® N/A
ORC: Certificate #: Backup ORC: Certificate #:
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: Based on past inspections of the Pasquotank County WTP and information provided in past
Annual Reports for Permit # WQ0008008, the facility appears to be operating adequately.
Description of existing facilities: NA, RLAP permit only.
Proposed flow: NA, RLAP permit only.
Current permitted flow: NA, RLAP permit only.
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.)
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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? n Yes or n No
If no, please explain: NA, proposed Class A residuals distribution only.
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: NA, proposed Class A residuals distribution only.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program: GW monitoring is not
considered required since the residuals are being applied at or below agronomic rates to non -dedicated fields.
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: See comment under Item II.7 above.
11. Are the monitoring well coordinates correct in RIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary): See comment under Item II.7 above.
Monitoring Well
Latitude
Longitude
O ,
,/
0 ,
II
O ,
,/
0 ,
II
O ,
,/
0 ,
II
O ,
„
0 ,
II
O ,
„
0 ,
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: Based on information provided in the annual reports,
WaRO is not aware of any compliance issues with Permit # WQ0008008. No public complaints have been
received by WaRO concerning this permit.
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? n Yes or ® No
If yes, please explain:
14. Check all that apply:
® No compliance issues n Current enforcement action(s) n 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 I I 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: NA, non -discharge system.
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17. Pretreatment Program (POTWs only): NA, non -discharge system.
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: The permittee should provide the additional information requested below prior to issuance
of a permit.
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
RSCA
WaRO requests that the permittee provide justification for their request to
increase the annual dry tons allowed under the permit. The information
provided in the application does not appear to support their request.
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
fl Issue
n Deny (Please state reasons: )
6. Signature of report preparer: N444 'RA4.04y S:K
Signature of regional supervisor: Rom Tt.l—.d
Date: 6/6/2022
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DocuSign Envelope ID: 06C1D510-8471-40A4-A1BC-DA46EEB4B93B
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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