WQ0037135_Staff Report_20221222

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: [e-mail]
From: [e-mail]
Mooresville Regional Office
Application No.: WQ0037135
Facility name: U.S. Biosolids Class B Residuals Program
County: New Source — Gaston; Facility Office — Wilkes
Note: This form has been adapted from the non -discharge fg acili , 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: Last site visit was on 3-17-2022 for the Dallas WWTP Residuals Permit renewal submitted
by U.S. Biosolids.
b. Site visit conducted by: Maria Schutte w/ Ori Tuvia as 2" d
c. Inspection report attached? ❑ Yes or ® No Available in BIMS and Laser Fiche — The Dallas
WWTP (ORC) provides consistent communication with MRO staff for residuals management since
communication from their contractor (U.S. Biosolids) was lacking in recent years.
d. Person contacted: Michael Stafford, Dallas WWTP-ORC [phone] & mstafford&dallasnc.net.
For U.S. Biosolids: Dennis Key is noted as LA-ORC and Zach Key as BUORC; however, current MRO
staff has never met with Dennis Key at any permitted facility or LA site — it is recommended that U.S.
Biosolids determine best person for ORC designation to meet operator 08G rules and submit an updated
designation form as needed.
e. Driving directions: To Dallas WWTP only: From the MRO travel to I-77-S; take I-485 Exit toward Mt. Holler
access 1-85 S; Take exit 20 to 279N (New Hope Rd.); Turn Left onto E. Main St.; Left to stay on E. Main St;
Left onto Davis St.; Left onto E. Holly St.
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
FORM: WQROSSR 04-14 Pagel of 5

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:
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:
9. 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:
10. Possible toxic impacts to surface waters:
11. 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 See
comments under section I.d. about ORC duties under 08G rules. In application Dennis Key is noted as ORC.
ORC: Dennis Key Certificate #: 13532 Backup ORC: Zach Key Certificate #: 27660
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: Dallas WWTP is also connected by sanitary sewer to Two Rivers Utilities
(TM or Gastonia, because they cannot manage flow in rain events. Most likely this plant will need si ign ficant
upgrades for capacity as the area population increases. Existing_ drying beds are used for tank cleanouts until
material is landfilled. Drying beds are not and currently should not be used for biosolids, unless reconditioned
and biosolids are managed separately from tank cleanouts.
Proposed flow:
Current permitted flow:
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.)
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: These are existing fields and MRO staff did not view them for this renewal. Only the
Gaston Co. fields formerly permitted with Dallas (see WQ0020912 version 2.2) were observed online to verify
BIMS coordinates and check for potential buffer changes from new structures. A potential setback issue was
noted for a home across the street from NC-GA-MH-02-05 (see comments in IV.2 1
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:
FORM: WQROSSR 04-14 Page 2 of 5

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 ❑ N/A
If no, please explain: This is a land application permit. Application rates need to be calculated with relevant
sampling results.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program: Currently groundwater
monitoringis s only required with dedicated fields or to assess a suspected incident.
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:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the following (expand table if necessary): I have no records that these MWs exist.
Monitoring Well
Latitude
Longitude
O I //
O I II
O I //
O I /I
O I //
O I /I
O / //
O / //
O / //
O I II
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: Currently only annual reports apply. Dallas WWTP
residuals records were up to date as of the March 2022 inspection. — These comments are related to the new
source only and the MRO review of the 2021 AR under the Dallas in-house hermit. The MRO has not reviewed
data related to the U.S. Biosolids WQ0037135 Annual Report.
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: BIMS shows NOD or NOV issued for this permit for past 4 yrs. by WSRO staff. The MRO
did not review each but does not see the violations adversely impacting this modification to add a source.
❑ 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?
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain: MRO did NOT assess the U.S. Bioys�olids Permit beyond viewing the BIMS violation historX
— comments are limited to the known source in this re ig oll.
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: Only by spill or run-off from over -application (fecal, solids, etc.). ND
permit should not result in discharges to surface waters.
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 5

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
Clarify ORC & BUORC
In application Dennis is noted as ORC. Current MRO staff has never met Dennis
designations.
Key at any facility or land application site. See comments in sections I & III.
This application is for WQ0037135. Header of the O&M plan states
WQ0037135 but body states the Dallas permit # WQ0020912. (See LF pg#14
last paragraph). And on second page — request that MRO contact information
be added for notification of LA activity and/or issues on land in this region.
Correct O&M plan for
permit #.
Process description states drying beds are used for residuals processing and they
are not — typically LA contract company mixes and pulls liquid material
Outdated or generic
directly from the biosolids digestor for land application. (See LF pg#27)
Process description
Residuals are only moved to drying beds when ORC determines plant is too full
correction.
and they cannot land apply. Dried residuals are typically disposed in a landfill.
The Town of Dallas periodically hauls to the Rocky River WWTP in Cabarrus
County when scheduling/weather dictate — they are a source under the WSACC
Permit #WQ0032332 for incineration.
Verify Property Setback for
400 Old Lowesville Road, Stanley appears approx. 220 ft across Road and do
NC-GA-MH-02-05
not see a waiver agreement. Owners Jason & Kelly Edwards Parcel#222965.
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
FORM: WQROSSR 04-14 Page 4 of 5

❑ 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:
Signature of regional supervisor:
Maria Schulte December 21, 2022
Date: 1212 21202 2 '-- F161 FB69A2D84A3...
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Some fields local to the MRO were permitted as part of the Town of Dallas RLAP and a few years ago transferred from
that permit to this U.S. Biosolids (Regional or Statewide) Permit. MRO staff questioned CO about this and made Bill
Trudnak (Dallas) aware of the change. He was not aware, but after speaking with Zach Key emailed that they had enough
land in the Dallas permit. During the recent renewal for the WQ0020912 Dallas Permit, CO review staff caught a
discrepancy for limited acreage vs. volume of residuals permitted. The "fix" was to reduce the volume permitted in line
with the current acreage under their permit. This acreage is all owned by the same person. Now, their land application
contractor is adding them as a source under their WQ0038608 permit as a back-up plan to utilize the same fields they
previously had permitted (a different owner — that allowed potential for flexibility in the WQ0020912 Permit). And,
seemingly, create unnecessary additional effort for everyone involved with this permit modification and others like them.
- This comment is posed for CO staff consideration of the extent to which LA contractors can continue to expand their
permits at the potential expense of existing permittees and the customers they claim to serve.
The landowner is the only one who has say-so over how their land is utilized and if they choose to participate. There are
times they may request being moved to another program; however, for the past several years, since these Regional or
Statewide Permits were allowed, there is a greater incentive for LA contractors to secure land under their permits and
landowners are swayed with the promise of more material because more sources can now be utilized on that same land.
In addition, when a LA permit is up for renewal, frequently first question now asked of the permittees by their contractors
is do you want to move as a source (with all your land) to the contractor's permit?
What options and responsibilities do non -discharge staff have to better address the current trend and assist all our
permittees? Currently permittees are not required to be notified when land is transferred out of their program.
Photo: Parcel Near NC-GA-MH-02-05
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Select from the drop -down below a feature
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Parcels
Property Details
Primary Property Address
1
400 OLD LOWESVILLE RD
STANLEY, NC 28154
Parcel #
PIN #
Township
® Current
Owners
Tax Information
222965
3690273662
RIVER BEND TOWNSHIP
EDWARDSJASONA
EDWARDS KELLY T
Mailing 400 OLD LOWESV€LLE RD ,
Address STANLEY NC 20164-0000
FORM: WQROSSR 04-14 Page 5 of 5