WQ0010197_Staff Report_20221102

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: (WQ0010197)
Attn: (Alys Hannum) Facility name: American & Efrid Closed Loop Recycle
From: (Edward Watson)
Mooresville 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
Date of site visit: 05/20/2022
Site visit conducted by: Inspection report attached? ['Yes or ® No
a. Person contacted: Jimmy Summers and their contact information: (704) 951 - 2576 ext.
e. Driving directions:
2. Discharge Point(s): N/A This is a closed Loop Recycle system. There is no outfall for this permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: This is a non -discharge permit. There is no outfall associated with
this permit.
Classification: N/A
River Basin and Subbasin No. N/A
Describe receiving stream features and pertinent downstream uses: N/A
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: John Smith, Certification# 987090 PC-1 Backup ORC: Larry Hendren, Certification# 1007925
2. Is 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: Treatment consisting of 1-million-gallon basin with aeration and piping to
remove solids from the alum floc basin, to remove drain water, and to remove existing sand filter backwash
before returning to the recycle system. The recycle system consists of three separate treatment units that run in
scheduled cycles to treat the pond water before it returns to the system as cooling water. 68,000 GPD WWT
Closed loop recycle.
Proposed flow: 68,000 GPD WWT Closed loop recycle.
Current permitted flow: 68,000 GPD WWT Closed loop recycle
FORM: WQROSSR 04-14 Page 1 of 3

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.) All areas of concern were adequately buffered, and the maps were updated to display the revised buffer
boundaries.
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: N/A
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: Residuals are not generated typically generated in this closed loop system — However, the
permit references removing solids from the alum floc basin. If alum floc needs to be removed, the alum would be
pumped out and sent to a landfill for final disposal. Waste manifests would be kept as a matter of record as a
tracking method for disposal.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ['Yes or ❑ No
If no, please explain: N/A
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: Groundwater monitoring is not required for this facility.
11. 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: Review of self -monitoring is kept as part of the
facility O&M records. These records were reviewed during the 5/20/2022 CEI with no issues noted.
There are no current requirements to submit, GW-59, NDAR, or NDMR records. No LA/ Spray application is
incorporated in this permit.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
12. Are there any permit changes needed to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain: N/A
13. Check all that apply:
® No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
n Notice(s) of violation n 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? n Yes n No ® N/A
If no, please explain:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
nYes ®NonN/A
If yes, please explain:
FORM: WQROSSR 04-14 Page 2 of 3

15. Possible toxic impacts to surface waters: This is a non -discharge recycle system permit and should not discharge
to surface waters. The ponds are located at a distance such that even if the ponds were to breach, it would
have to travel a significant distance before entering surface water.
16. Pretreatment Program (POTWs only): N/A
REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
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: Edward Watson, Hydrogeologist 2 November 2022.
—DocuSigned by:
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Signature of regional supervisor: —F,s,Fesgazoaaas...
Date: 11/2/2022
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
1. This is a simple permit renewal. No changes or other modifications are being made to the permitted non -discharge
operations.
FORM: WQROSSR 04-14 Page 3 of 3