WQ0039924_Staff Report_20221220

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Zachery Mega
From: Tony Honeycutt
Fayetteville Regional Office
Application No.: W00039924
Facility name: Von Drehle Corporation — Cordova
Class A (503 Exempt)
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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: 23 August 2022
b. Site visit conducted by: Tony Honeycutt
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Mitchell Luckie and their contact information: [phone] ext.
e. Driving directions: From Rockingham, take US Hwy 1 South approximately 3 miles and turn right at the
intersection of US 1 and Rosalyn road. Drive approximately 2 miles and the von Drehle plant is on the right.
2. Discharge Point(s): N/A. Both Class A and Class B residuals are stored behind the main production plant,
adiacent to belt press. The coordinates below are the approximate center of the storage area.
Latitude: 34.918454
Latitude:
Longitude:-79.828977
Longitude:
3. Receiving stream or affected surface waters: N/A (Hitchcock Creek is adjacent to the Von Drehle production
plant site
Classification: "C"
River Basin and Subbasin No.: Yadkin -Pee Dee (YAD16) (13-39-10)
Describe receiving stream features and pertinent downstream uses: From the Von Drehle plant site to the
Pee Dee River is forest/woodlands on both sides the Hitchcock Creek.
11. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification:
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
FORM: WQROSSR 04-14 Page 1 of 4

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. -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:
8. 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:
9. Possible toxic impacts to surface waters:
10. 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 Branch Certificate #: LA-15676 Backup ORC: Vaughn Stevenson Certificate #: LA-998715
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: Paper recycling facility that produces cake residual.
Proposed flow: 35,000 DTs/year.
Current permitted flow: 35,000 DTs/year.
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.) N/A
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:
FORM: WQROSSR 04-14 Page 2 of 4

10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessarv):
Monitoring Well
Latitude
Longitude
0 / //
0 I II
0 / //
0 I it
0 / //
0 I It
0 / //
0 I it
0 / //
0 I it
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: Residuals produced are primarily being land
applied under the Bio-Nomic Services RLAP Class B permit W00038570 and the Von Drehle Class A
permit W00039924. Annual reports reviewed with no issues noted.
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.) N/A
If the facility has had compliance problems during the permit cycle, please explain the status. N/A Has the RO
been working with the Permittee? N/A Is a solution underway or in place? N/A
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: N/A
17. Pretreatment Program (POTWs only): N/A
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
N/A
FORM: WQROSSR 04-14 Page 3 of 4

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
N/A
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
N/A
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
❑ Dgny kW§ggbgate reasons: )
6. Signature of report preparer:
Signature of regional
Date: 12/20/2022
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Von Drehle Class A cake residuals is managed under the Class A permit and is marketed to area farmers in
Richmond, Scotland, Anson and Moore counties that have sandy soil profiles, as a soil amendment. Some Class A
residuals may also be land applied in South Carolina, as in past history.
FORM: WQROSSR 04-14 Page 4 of 4