WQ0003504_Staff Report_20211104

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;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: Erick Saunders
From: (J. Chris Smith)
Raleigh Regional Office
Application No.: WQ0003504
Facility name: City of Durham RLAP
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 gPplicable.
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
d. Person contacted: Ryan Copeland and their contact information: (336) 607 - 4494
e. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Subbasin 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:
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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: John Dodson Certificate #: LA25935 Backup ORC: Charles Cocker Certificate #:LA13526
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:
Proposed flow:
Current permitted flow:
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
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 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:
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:
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11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ❑ N/A
If no. Dlease complete the following (expand table if necessarv):
Monitoring Well
Latitude
Longitude
0 , „
0 , rr
0
0
0
0
0
0
0
0
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:
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:
17. Pretreatment Program (POTWs only):
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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: See Additional Regional Staff Review Items
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 Docu Signed by:
❑ Deny (Please state reasons: ) �,I� VtS Swl&
6. Signature of report preparer:
Signature of regional supervisor:
Date: 11/4/2021
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1D427000DBE94E9...
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Several items are missing from the modification application.
No information has been provided regarding the NEW fields NC-PS-3-5 and NC-PS-3-6.
No soils evaluation and no CPLR statement has been provided for NEW field NC-AM-10-1.
No soils evaluation or statement has been provided for MODIFIED fields NC-OR-15-1, NC-OR-87-1, and NC-OR-
87-2.
Please see the guidance below from the NC Division of Water Resources Soil Scientist Evaluation Policy regarding
new or expanding non -dedicated sites for the land application of residuals under the 15A NCAC 02T rules.
4) For new or expanding non -dedicated sites for the land application of residuals. A
soils report shall include the following componen(s:
a) General Requirements
i) The soil scientist evaluation shall conform to all criteria outlined in 1A
NCAC 0 T .1104(c)(2).
ii) A North Carolina licensed soil scientist (L. . .) shall sign, seal and date the
report as required by G.S. 8F.
iii) The report shall identify all the siteS/fieldS with project name, location, and
include a statement that the sites/fields were recommended by the Licensed
Soil Scientist (L.S.S.) for the proposed land application activity.
iv) Lf the site(soil evaluation was performed more than one year prior to the
submittal of the application package, a statement should be included
indicating that the site has not changed since the original investigation.
b) Detailed Soils leap
i) The soil map shall consist of:
(1) A copy of a U. .D.A. Natural resources Conservation Service (Nl )
county soil survey map that has been confirmed for accuracy by a field
evaluation by an L.S.S. or;
(2) A map that has been created by an L.S.S.
ii) The soils map shall meet all of the following requirements:
(1) The snap shall encompass the entire land application area including
buffers.
() Be clear and reproducible in black and white.
(3) Be of an appropriate scale to show the necessary detail for the land
application of residuals.
(4) Include a map legend that identifies all soil map units and special symbols.
A separate map unit legend shall be included if this information will not fit
OD the soil map.
() Contain the following appropriate labeling.
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(a) N1S neaps: soil survey name, map scale and north arrow.
(b) .L.S.S. maps: project name, date of snap completion, be signed and
sealed by the L.S.S. responsible for the map, map scale and north
arrow. Show the locations of ditches and other physical features,
streams, water bodies, and identified wetlands.
() Show the location of all soil profile descriptions.
(7) Label all roads and other landscape and cultural features that aid with
orientation. Include site/field numbers on the maps when possible.
c) Soil Characterization Data
i) Soil Profile Descriptions
(1) A ininlmuin of one soil profile description shall be required for each field.
This soil profile description should be for the dominant Soil series found
within the field.
(2) In areas where extensive soil -disturbing activities such as grading have
taken place, soil profile descriptions shall be written for the dominant soil
conditions. Separate soil profile descriptions shall be written for areas
where soil has been removed (cut) and areas where soil has been added
(fill).
(3) Soil profile descriptions shall describe soil conditions within seven feet of
the land surface or to a Cr or R horizon.
(4) Soil profile descriptions shall be fully written out or if abbreviated, use the
conventional USDA Natural Resources Conservation Service field note
abbreviation S. 8
(5) Soil profile descriptions, based on examinations of excavation pits or
auger borings, shall describe the following parameters by individual
diagnostic horizons:
(a) Thickness of the horizon (ineasureinent of the top and bottoin of the
soil horizon in inches from the soil surface)
(b) Texture (USDA soil texture, use texture modifiers as necessary
[gravelly, very gravelly, extremely gravelly, etc.])
(c) Color and other diagnostic features
(i) Primary matrix color as well as the abundance, size, and color of
mottles.
(ii)1 lunsell Color Chart notation (example: 10 R 3)
(iii)identify soil moisture at the time the soil color was described for
each horizon (inoist sail is asstuned unless noted as dry).
(iv)Colors that are redoximorphic features shall be identified as such
(i.e. redox concentrations, redox depletions, etc.)
(d) Structure (grade, size, and type)
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(a) N1S neaps: soil survey name, map scale and north arrow.
(b) .L.S.S. maps: project name, date of snap completion, be signed and
sealed by the L.S.S. responsible for the map, map scale and north
arrow. Show the locations of ditches and other physical features,
streams, water bodies, and identified wetlands.
() Show the location of all soil profile descriptions.
(7) Label all roads and other landscape and cultural features that aid with
orientation. Include site/field numbers on the maps when possible.
c) Soil Characterization Data
i) Soil Profile Descriptions
(1) A ininlmuin of one soil profile description shall be required for each field.
This soil profile description should be for the dominant Soil series found
within the field.
(2) In areas where extensive soil -disturbing activities such as grading have
taken place, soil profile descriptions shall be written for the dominant soil
conditions. Separate soil profile descriptions shall be written for areas
where soil has been removed (cut) and areas where soil has been added
(fill).
(3) Soil profile descriptions shall describe soil conditions within seven feet of
the land surface or to a Cr or R horizon.
(4) Soil profile descriptions shall be fully written out or if abbreviated, use the
conventional USDA Natural Resources Conservation Service field note
abbreviation S. 8
(5) Soil profile descriptions, based on examinations of excavation pits or
auger borings, shall describe the following parameters by individual
diagnostic horizons:
(a) Thickness of the horizon (ineasureinent of the top and bottoin of the
soil horizon in inches from the soil surface)
(b) Texture (USDA soil texture, use texture modifiers as necessary
[gravelly, very gravelly, extremely gravelly, etc.])
(c) Color and other diagnostic features
(i) Primary matrix color as well as the abundance, size, and color of
mottles.
(ii)1 lunsell Color Chart notation (example: 10 R 3)
(iii)identify soil moisture at the time the soil color was described for
each horizon (inoist sail is asstuned unless noted as dry).
(iv)Colors that are redoximorphic features shall be identified as such
(i.e. redox concentrations, redox depletions, etc.)
(d) Structure (grade, size, and type)
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(e) Depth, thickness, and type of restrictive horizon(S) (i.e. compacted
layers, plow pans, fragipans, plinthite, brittle layers, etc.)
s Schoeneberger, P_J_, Wysocki, D.A., Benham, E-C_, and Broderson, _D_ (editors), 2002. Field book for
describing and sampling soils, Version 2.0 Natural Resources Conservation Service, National Soil Survey
Center, Lincoln, NE. (Online download: htlplisoils_usda.goyltechnicaVfieldbookf )
Soil Scientist Evaluation Policy
September 12, 200E
Page 14
(i) If the restrictive feature is found in only part of the horizon,
estimate the percentage by volume that the restrictive feature
occupies (example: 10 percent plinthite by volume)_
(6) Each soil profile description shall also include the following information;
(a) Soil series name. If the described pedon is outside the range in
characteristics of an established soil series, use the best naive, denote
that it is a variant, and list the soil properties that put it outside the
range (example: Helena variant, kaolinitie mineralogy)
(b) Landscape position (i.e- side slope, toe slope, foot slope, etc_)
(c) Percent slope
(d) Classification to family level using Soil Taxonomy (e.g. Norfolk
Series be written as fine -loamy, kaolinitic, thermic Typic
Kandiudults).
(e) Internal drainage: Presence or absence and depth of evidence of any
seasonal high water table (SHWT). The type of water table (apparent
or perched) shall also be identified.
(f) Name of soil scientist(S) who wrote description
(g) Date of description
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