HomeMy WebLinkAboutWQ0037135_Staff Report_20230828August 28, 2023
To: DWR Central Office — WQ, Non -Discharge Unit
Attn: Erick Saunders
From: Caitlin Caudle
Winston-Salem Regional Office
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
Application No.: W00037135
Facility name: US Biosolids 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: 8/8/2023 and 8/9/2023
b. Site visit conducted by: C. Caudle and K. Potwora
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Zach Key and their contact information: zachkey@_usbiosolids.com
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Zach Key Certificate #: 27660 Backup ORC: Dennis Key Certificate #: 15704
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
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
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
8. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
9. Has a review of all self -monitoring data been conducted (e.g., AR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: NOD for 2022 AR as Lowell WWTP did not provide
2022 TCLP results.
10. Has a review of source facilities compliance history been completed (e.g., CEIs and DMRs)? ❑ Yes or ® No
11. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
FORM: WQROSSR 04-14 Page 1 of 2
12. Check all that apply:
® No compliance issues
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) The most
recent 2022 AR NOD and CEI correspondence are in LF.
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? WSRO attempted to obtain the 2022 TCLP
results for Lowell WWTP, but they have not been received to date.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
13. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
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
Several of the fields had buffers added after the site visits, and SP-7 is being
Updated LASC form.
removed as the LSS did not evaluate the field. An updated LASC is needed to
reflect the modified acreage.
Clarification of field names
One LOA has the fields named K1-6, and the other has SP1-7.
in Rutherford County.
Topo, vicinity, and soil
Staff did not see these maps in the application for the Rutherford fields.
maps for Rutherford fields.
Predominant soil series
The LSS included what soils were found in the field but did not include a
recommendation for
recommendation for the predominant soil series in each field.
Rutherford fields.
Updated application maps.
Several of the fields had buffers added after the site visits.
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: )
/—DocuSigned by:
4. Signature of report preparer:
Signature of regional supervisor:
Date: 8/28/202 3
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
DocuSigned by:
" , -T. :5.at'
145B49E225C94EA...
See attached site visit summary and application maps with Staff comments.
FORM: WQROSSR 04-14 Page 2 of 2
8/8-9/2023 Site Visit Summary
On August 8 and 9, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora conducted
a site evaluation to review proposed land application fields. Zach Key, US Biosolids, was present during
the entire site evaluation. Staff recommend the following predominant soil series for each field:
Field
Proposed Soil Series
Staff Recommendations
SP-1
Pacolet
Appling
SP-2
Pacolet
Pacolet
SP-3
REMOVED FROM MODIFICATION
SP-4
Pacolet
Pacolet
SP-5
Pacolet
Pacolet
SP-6
Pacolet
Pacolet
SP-7
Skyuka
Skyuka
TB-1
Fairview
Fairview
TB-2
Fairview
Fairview
The following observations were made for the Rutherford fields:
CI-Cl (35.482155,-82.025656)
0-3"
10YR 3/3, granular structure
3-6"
10YR 5/8, granular structure
6-9"
10YR 4/6, granular structure
9-32"
5YR 4/6, subangular blocky structure, clay increase
32-36"
5YR 5/8, subangular blocky structure, mica present, maybe saprolite?
This boring is within the range of characteristics for Pacolet.
CLC2 (35.483748,-82.030375)
0-3"
10YR 3/4, granular structure, gravel present
3-10"
7.5YR 4/6, subangular blocky structure, gravel and mica present
10-20"
5YR 3/4, subangular blocky structure, gravel and mica present
20-24"
5YR 3/4, massive structure, multi colored saprolite, auger refusal at 24"
Auger refusal occurred at 4" in two other borings at this location.
CLC3 (35.479507,-82.028438)
0-6"
10YR 4/4, clay loam, granular structure, gravel present
6-10"
5YR 4/6, sandy clay loam, subangular structure
10-20"
7.5YR 5/6, sandy clay loam, subangular blocky structure, manganese concentrations, clay
increase
20-36"
5YR 4/6, clay or clay loam, subangular blocky, manganese concentrations, redox features
present
This boring is within the range of characteristics of Appling. The LSS also described boring 8 in the same
field as Appling.
CLC4 (35.478815,-82.031247)
0-3"
10YR 3/3, sandy clay loam, granular structure
3-10"
5YR 4/6, clay loam, subangular blocky structure, clay increase
10-20"
5YR 4/6, clay or clay loam, subangular blocky structure, clay increase, some redox features
20-36"
5YR 4/6, clay or clay loam, subangular blocky structure, 10YR 5/6 depletions, mica present
This boring is within the range of characteristics of Appling. The LSS also described boring 8 in the same
field as Appling.
CLCS (35.481005,-82.027168)
0-3"
10YR 4/4, sandy clay loam, granular structure
3-12"
5YR 4/6 and 10YR 4/4, sandy clay loam, subangular blocky structure
12-25"
5YR 5/8, sandy clay loam, subangular blocky, clay increase, manganese present
25-36"
5YR 4/4, sandy clay, subangular blocky structure, 10YR 6/8 depletions
This boring is within the range of characteristics of Cecil. The LSS also described boring 7 as Cecil.
Field SP-7 was not reviewed due to overgrown vegetation. This field will be reviewed before first
application.
Field SP-3 will be removed from this modification as no soil evaluation was completed. Boring CLC2 was
completed in this field.
The following observations were made for the Wilkes fields:
CLC1 (36.264000,-81.005385)
0-4"
7.5YR 3/4, granular structure
4-19"
5YR 4/6, clay, subangular blocky structure, gravel present
19-34"
2.5YR 3/6, subangular blocky structure, gravel present
This boring is within the range of characteristics of Fairview.
The rock outcropping noted in the soil report in field TB-2 was not found by Staff. Ms. Caudle
recommended that Mr. Key monitor the field during first application to ensure a rock outcropping is not
present.
Mr. Key stated that cake will likely be spread on these fields. The application maps reflect that as slopes
>10% are not excluded.
Other Observations:
• The TCLP data provided for Marion WWTP was from 2020. The facility's individual permit only
required once per permit monitoring and a new permit was issued August 2021.
• The Rutherford County fields were removed from the Spindale RLAP permit.
• 10m (32.8ft) setbacks from surface waters are being used.
• Considering the majority of the permitted land is hay or pasture, which on average has a PAN
rate of 125 Ibs/ac or more, there is enough land to support the additional source.
• Several of the sources have individual RLAP permits. This permit will serve as a back up for the
individual permits when fields are not available due to crop status and livestock exclusions.
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SP6
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COMPIANCEAND EVIE BOUNDARIES.
The compliance bou idary is established either.250 feet
from the edge of the residuals application area or 50 fee
within the property b and ry, whichevecis closest to the
KOO N E P2 & S P4 application area. Thereviewboundary is established
_ halfway between the compliance boundary and the edgE of
Rutherfor Couty the residuals applica inn a ea:
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FG The co npli.nce boundary is establisbedaither 250 feet from
the edge of th residuals application area or 50 feet w thin the
utherfor County �� propert boundary, whichever, is closest to the pplica ion
a' area. T ie revi wr boundary is established halfw y between the
�f compliz nce b Undary and the edge of the resid Aals
applica ion ar a.
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COMPIA CEA D REVIEW BOUNDARIES:
The com Hance boundary is established either 2,10 feet
from the E dge of the residuals application area or 50 fee
KO �� within thit prope y boundary, whichever is closes t
applicatio area The review boundary is estabf ed
halfway b twee the compliance boundary d the edg
Rutherfo ton County \ of the res duals application area.
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COMPIANCEAN REVI VV BOUNDARIES:
The compliance b undar t is established either 250 feetfr mthe dgeof
the residuals appli ation area or 50 feet within the pi open boun Jary,
whichever is close tto th application area. The review b undar is
established halfwa betvu en the compliance boundary an the a ge of
the residuals appli ation �re..
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COMPIANCE AND REVIEW BOUNDARIES:
he compliance boundary is established either 250 feet from the edge of
e residuals application area or 50 feet within the property boundary,
ichever is closest to the application area. The review boundary is
ablished halfway between the compliance boundary and the edge od
residuals application area.
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