WQ0023306_Staff Report_20220922

DocuSign Envelope ID: 68010430-B4A3-4D24-9F37-2F01 1354A7609
;s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Erick Saunders
From: Randy Sipe
Washington Regional Office
Application No.: WQ0023306
Facility name: New Bern Class A Residuals
Note: This form has been adapted from the non -discharge facilily 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: NA
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: NA and their contact information: (�
e. Driving directions: NA
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: Certificate #: Backup ORC: Certificate #:
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. Class A residuals distribution only.
Proposed flow: NA, RLAP permit only.
Current permitted flow: NA, RLAP permit 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: 68010430-B4A3-4D24-9F37-2F01 B54A7609
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: NA, Class A residuals distribution only.
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: NA, Class A residuals distribution only.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program: GW monitoringis s not
considered required since the residuals are being applied as cover at a county solid waste landfill where GW is
being regulated.
ated.
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 IL7 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 IL7 above.
Monitoring Well
Latitude
Longitude
o
o
o
o
o
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: The 2021 annual report and the renewal application
cover letter states that 5274 dry tons of residuals were distributed in 2021. This is greater than the maximum
annual amount of 3122 dry tons included in Attachment A of the current Permit # WQ0023306. In Item IIL2
below WaRO is requesting that the permittee provide an explanation of this discrepancy: and, if necessary,
provide a permit modification if this amount of residuals is expected to continue to be produced.
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: See comment under Item II.12 above.
❑ 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? See comment under Item IL 12 above.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
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DocuSign Envelope ID: 68010430-B4A3-4D24-9F37-2F01 B54A7609
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: NA, non -discharge system.
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 ❑ No
If yes, please explain: It is WaRO's opinion that a permit should not be issued until the additional info. items
requested below have been provided by the permittee.
2. List any items that you would like the NPDES Unit orNon-Discharge Unit Central Office to obtain through an
additional information request:
Item
Reason
The 2021 annual report and the renewal application cover letter states that 5274
dry tons of residuals were distributed in 2021. This is greater than the maximum
Cover letter and 2021
annual amount of 3122 dry tons included in Attachment A of the current Permit
Annual Report
# WQ0023306. WaRO requests that the permittee provide an explanation of
this discrepancy; and, if necessary, provide a permit modification if this amount
of residuals is expected to continue to be produced.
Residual Source
Item L8 of the form provides an average annual amount of residuals produced
Certification for
by this facility as 25 dry tons. This seems very low for a WWTP with an
NCO025348
average daily flow of 4.45 MGD, as given in Item L7. The permittee should
provide justification for this value of residuals.
Residual Source
Certification for
The dates of residual analytical results provided in this form are all from 2017.
WQ0003765
The permittee should provide more recent analytical results.
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
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DocuSign Envelope ID: 68010430-B4A3-4D24-9F37-2F01 B54A7609
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: N
Signature of regional supervisor: 14 "Z T""
Date: 9/22/2022
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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