WQ0037135_Staff Report_20220607

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

June 7, 2022

To: DWR Central Office WQ, Non-Discharge Unit Application No.: WQ0037135
Attn: Erick Saunders Facility name: US Biosolids 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: 6/6/2022
b. Site visit conducted by: C. Caudle and M. Schutte
c. Inspection report attached? Yes or No
d. Person contacted: Zach Key and their contact information: (336) 467 - 3550
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Dennis Key Certificate #: 15704 Backup ORC: Zach Key Certificate #:27660
David Key (23629) was also listed as a BUORC but is not designated in BIMS.
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? Yes or No
3. Is the residuals management plan adequate? Yes or No
4. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
5. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
6. Is the description of the facilities as written in the existing permit correct? Yes or No
7. Has a review of all self-monitoring data been conducted (e.g., NDMR, NDAR, GW, AR)? Yes or No
Please summarize any findings resulting from this review: An NOD was issued for the 2021 AR as a source went
over their permitted tonnage. This modification is increasing the tonnage for that facility. An NOD was issued for
the 2020 AR and an NOV for the 2021 AR. The last compliance inspection was completed by MRO and reflected
compliance with the subject permit.
Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
8. 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? The facility has been having issues with AR
submission. WSRO has been working with the Mr. Zach Key through add info requests and discussions about the
ARs.
FORM: WQROSSR 04-14 Page 1 of 2

9. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
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
Designation of David Key
David Key is not designated in BIMS.
as a BUORC
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 (Please state reasons: )
4. Signature of report preparer:
Signature of regional supervisor:
Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Please see attached site visit report of Lowell WWTP.
WSRO staff see no issue with increasing the permitted dry tonnage of the North Wilkesboro Thurman Street WWTP.
There is enough land currently permitted to support the addition of Lowell WWTP and the increased production from
N. Wilkesboro. Mr. Key stated that another permit modification application will soon be submitted to add
approximately 200 acres to this permit.

FORM: WQROSSR 04-14 Page 2 of 2