WQ0016247_Staff Report_20220705

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: WQ0016247
Attn: Erick Saunders Facility name: Synagro Polk Co. Fields

From: Melanie Kemp
Asheville 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: June 30, 2022
b. Site visit conducted by: Melanie Kemp and Mikal Willmer
c. Inspection report attached? Yes or No
d. Person contacted: Alex Fox and their contact information: [e-mail]; 704-881-3429 ext.
e. Driving directions: From Swannanoa take I-40 E to US-221 S. After about 23 miles, turn right on Poors Ford
Rd. Take a sharp left on Lee Cudd Rd after 6.8 miles and then a left on Chesnee Rd after about 2.2 miles. Field
F-1 can be accessed via a gravel driveway associated with 4464 Chesnee Road (private residence). Field F-2
can be accessed via Tryon Auto Care (4752 Chesnee Rd). Recommend clearance and 4WD if possible, to access
fields using vehicle.
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
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:
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FORM: WQROSSR 04-14 Page 2 of 5
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: Robert Roth Certificate #: LA / 1001672 Backup ORC: Adam Brigman Certificate #:LA /
1006653
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: Solids from the Columbus WWTP are digested for land application.
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: Permit has not been issues for thes fields yet.
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: Does not apply
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:

DocuSign Envelope ID: E0FC442C-896C-47D7-BB20-CB59C1494C90
FORM: WQROSSR 04-14 Page 3 of 5
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 ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″ ○ ′ ″ - ○ ′ ″
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: Agronomist report confirms soil type and that no
seasonally high water table was observed in the fields reviewed. Sludge sampling confirms no exceedances
above Class B land application standards as defined in 02T .1105.
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):

DocuSign Envelope ID: E0FC442C-896C-47D7-BB20-CB59C1494C90
FORM: WQROSSR 04-14 Page 4 of 5
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
Setbacks Verify setbacks or modification to area with woody debris in field PO-09-2
Setbacks Consider buffering cattle watering troph present in field PO-09-2

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:

Signature of regional supervisor:
Date:

DocuSign Envelope ID: E0FC442C-896C-47D7-BB20-CB59C1494C90
7/5/2022
FORM: WQROSSR 04-14 Page 5 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
It appears field PO-09-1 and 2 meet the setback requirements established under 02T.1108. No apparent slopes greater
than 10% exist in either field. Ownership records on Polk County GIS corresponded to the signed landowner
agreements. It is recommended that Synagro label the setbacks illustrated on the field maps with the actual distances.
Inspectors assume the wells shown are buffered 100’ and the houses are buffered 400’ from the proposed land
application area. Polk County GIS depicted what appears to be a drainageway within field PO-09-2 (F-2); however,
inspectors did not observe a swale or ditch at the time of the site visit. No surface waters or ditches were apparent in
either field. See the add-info request above regarding the depression/debris pile in the northern portion of field PO-09-
2. Recommend excluding this portion of the field from the application area unless debris is removed, the area is
regraded, and a crop is established. A cattle watering station is in the eastern portion of PO-09-2. While not required,
its recommended that this area be buffered since there is a concrete slab underneath.

DocuSign Envelope ID: E0FC442C-896C-47D7-BB20-CB59C1494C90