WQ0035595_Staff Report_20211122

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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
L 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
Application No.: WQ0035595
Facility name: Granville Farms RLAP
d. Person contacted: Drew Matthews and their contact information: (252) 883 - 9301
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:
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:
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.
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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 #: 13266 Backup ORC: Bryan A. Smith Certificate #: 13265
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ❑ Yes or ❑ No ® N/A
If no, please explain: This permit is for a distribution only operation. All treatment facilities involved are
permitted separately,
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:
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� ViS Swl&
6. Signature of report preparer:
Signature of regional supervisor:
Date: 1112212021
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The application appears to be complete. Land use agreements and CPLR reports have been provided for all the
application areas. There are a few minor corrections that need to be made and clarifications would be helpful in some
areas.
Fields T6-2, T6-3, T6-4, T6-5, T6-6, T6-7, EB-01, and EB-02 are listed as New fields in the Status Code column on
page 1036 of the electronic application document. These fields were included in the previous permit and should be
labeled as Renewal.
Lab analyses for metals and nutrients are required to be conducted annually for the Lewiston Woodville WWTP,
Arbor Hills MHP, and Lake Royale WWTP. The lab results for these facilities are dated 2019 instead of 2020. The
permittee contact explained that these are very small facilities and are only sampled prior to residuals removal and
application which may occur only once every 4-5 years. The lab results are the most recent available for these
facilities. A statement clarifying this matter may be something the permit writer(s) want to include in the application
package.
The field acreage in this application is insufficient for the stated PAN amounts generated by the source facilities. On
page 8 of the electronic application document there is the following statement: "Many of these sources will also
maintain their current land application program in conjunction with this one. For most sources this permit will not
serve as an exclusive land application program, but rather as a supplement." The permit writer(s) may want a more
detailed statement explaining that the full amount of the stated dry tonnage/PAN will not be applied to the fields
included in the permit application.
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