WQ0002883_Staff Report_20221020

DocuSign Envelope ID: 2F3C34A5-BD57-4AC6-A516-E9A5F9BE13D0
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.: WQ0002883
Attn: Erick Saunders
From: Randy Sipe
Washington Regional Office
Facility name: Elizabeth City Class B 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: 10/19/22
b. Site visit conducted by:
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: None and their contact information: ()
e. Driving directions: No change since last permit was issued
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: Bryan Lincoln Certificate #: 1005539/LA Backup ORC: Stephen Cummings Certificate #:1011179/LA
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: NA, Land application of Class B residuals only.
Proposed flow: NA, Land application of Class B residuals only.
Current permitted flow: NA, Land application of Class B residuals 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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DocuSign Envelope ID: 2F3C34A5-BD57-4AC6-A516-E9A5F9BE13D0
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or n 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: During the site visit on 10/19/22 site conditions were observed to be consistent with those
presented in the application package.
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: NA, Land application of
Class B residuals below agronomic rates on non -dedicated fields only.
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 BIMS? ❑ 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 ,
If
0
/
II
o ,
If
0
/
II
o ,
If
0
/
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o ,
If
0
/
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o ,
If
0
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12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or n 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
n Notice(s) of violation n Currently under SOC n 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 n No n N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
nYes ®NonN/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 n No
If yes, please explain: The addition information request below should be provided by the permittee and/or their
consultants before issuance of a permit is considered.
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
Application RLAP 06-16
Section III.3
The operators given in the application do not correspond to those listed for this
permit in BIMS. The operator designation form provided is not for
WQ0002883. An operator designation form naming the new operators for
WQ0002883 should be provided.
Site Maps
In the cover letter it is requested that the field numbers revert to those used on
previous site maps prepared by S&ME. WaRO has no issue with this change;
however, any revised maps should show the structures at the north end of
current fields WB-25 and 26 (S&ME field WB-8). These structures were
observed during the site visit on 10/19/22 and are not shown on the previous
maps from S&ME.
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
n Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
❑ Issue
Deny (Please state reasons: )
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DocuSign Envelope ID: 2F3C34A5-BD57-4AC6-A516-E9A5F9BE13D0
6. Signature of report preparer: D44 z 'iA•t.dy 54G
Signature of regional supervisor: Rati41 TT4.4444
Date: 10/20/2022
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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