WQ0000672_Renewal Permit_20170315

<. State of North Carolina
Division of Water Resources
C. Water Quality Regional Operations Section
Environmental Staff Report
Quality
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To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0006672
Attn: Troy Doby Facility name: City of Lumberton RLAP
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From: Jim Barber
Fayetteville 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.
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I. GENERAL AND SITE VISIT INFORMATION
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1. Was a site visit conducted? ® Yes or ❑ No
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a. Date of site visit: 15 March 2017
b. `Siite visit conducted by: Jim Barber
c. Inspection report attached? ❑ "Yes "or ® No
d. Pierson contacted: Chad Hayes and their contact information: (919) 799 - 0766 ext. Cell #
e. Driving directions: From Fayetteville take I-95 south to Hw11(exit #20). Turn left at top of exit and proceed
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2. Discharge Point(s): N/A
Latitude: Longitude:
A
Latitude: Longitude:
3. Receiying stream or affected surface waters: N/A
Classification:
River Basin and Sub -basin No.:
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j Describe receiving stream features and pertinent downstream uses:
H. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued, permit)
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:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A '
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 6 ,

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 El 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.
8. 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):
M. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ® No ❑ N/A
ORC: Creighton Brown Certificate #:LA-1001685(Invalid) Backup ORC: Howard Floyd Certificate #:LA-28040
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: Municipal wastewater treatment facility that receives domestic, commercial and
industrial wastewater. Thefacility is designed and permitted for 20 MGD and receives between 3 to 6 MGD per
DMR's received in the Fayetteville regional office NPDES group. The facility has three primary sludge aeration
basins and has converted one wastewater treatment basin aeration basin into an aerated sludge storage basin see
attached site map).
Proposed flow: 1500 DTs/year (permitted sludge volume)
Current permitted flow: 1500 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.)
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: Lumberton is permitted for 1500 DTs/Year and currently land applies approx.. 900 to 1000
DTs/year. The facility has more than adequate storage to allow for land application at the appropriate time for the
farmers in the program. The Lumberton program has both row crop farmland and bermuda pasture/hay land so
year round application can take place if necessary. Due to the reduced .flow into the wastewater plant from textile
industry leaving Robeson County, sludge volumes are reduced from historical highs (1980's and 1990's).
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:
FORM: WQROSSR 04-14 Page 2 of 6

8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or 0 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:
FORM: WQROSSR 04-14
Page 3 of 6

11. Are the monitoring well coordinates correct in BIMS? ❑ Yes No Z N/A
If no, please complete the following iexnsnd table if necessarvl— -
Monitoring Well
Latitude
Longitude
O / it
O I It
O I If
O 1 H
O , „
O / //
-
O / if
O I If
O / „
O I If
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: Reviewed the last three annual reports. Dry tons
applied are well below permitted amount.
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:
Z 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:
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
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17. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 4 of 6

' 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
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
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4. List specific_special conditions or compliance schedules recommended to be included in the permit when issl
Condition Reason
5.. Recommendation: H 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 preparers
Signature of regio al supervisor: 1 =V % 'U
Date: Z%
FORM: WQROSSR 04-14 Page 5 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
that have changed ownership the only other piece of information needed is a new ORC designation form to addfess
the appropriate ORC for the City of Lumberton land application program Once the new ownership forms and ORC
designation forms are received; the draft permit can be sent to all parties ,The facility can operate with one of the
Back -Up ORC's functioning as the ORC as specified in 15A NCAC 08G 0205 (1)
All fields are in good shape and currently being cultivated. The fields that Synagro is requesting be removed from the
City of Lumberton permit are acceptable and in"production with no complaints from the farmers) other than not
receiving enough sludge on a more frequent basis. The buffer maps prepared for the permit renewal are accurate with
respect to on -site and off -site homes, property lines surface water features etc Once the revised landowner
agreements are received (along with any buffer maps or field information sheets that need to be revised to reflect the
correct property owner) and any other information requested in the add info letter; the draft permit can be prepared for
review by all parties.
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FORM: WQROSSR 04-14 Page 6 of 6

Chad. Hayes; .
Here's the link to. the Operators Certification webpage (. http://dep.hc.gov/about/divisions/water-resources/operator
certification/wastewater-operator-certification/wastewater-operator-certification-downloads ) for -the ORC/BU-ORC .
designation form.to be used in updating the ORC information for,the City of Lumberton land -application program. At this .
time'the DWR database indicates that Creighton Brown is the ORC and the-permit.renewal application also identifies.
Creighton Brown as the.ORC: According to -our conversation.this afternoon; Creighton Brown no longer works for
Synagro and therefore rieeds to. be removed as an operator for the City of-Lumberton.land'application program:. Also;
Creighton Brown's land application certification- is currently: invalid in the DWR database (reason not known): .:
If you are.the replacement .fo"r. Creighton Brown; please execute.the ORC.-designation form and submit -to the Division
with your add. info response -and to the.address:for the.WPCS000.-Please also email a copy to the Fayetteville Regional
Office for our files.,I'm:also attaching two screen shots from the DWR database forthe name -"Hayes". I didn't find your
information in the database. If you are one of the "Hayes" in the list proy'ided, please email me your certification
number so I can add that information -to my staff reportfor Troy Doby: If. you are not certified to be �an ORC; then
another Synagro employee or one of -the two Back -Up ORC's from:Lumberton need to be designated as ORC. One of the
BU ORC s can operate as the ORC until.a new ORC is designated per 15A NCAC 08G .0205 (!):on page -five of the rules
that are attached for.your reference.
If you have any'questions or need additional. assistance,.please.email me or Tony:Honeycutt or call -me at;the number
below.
Thanks
.. ... - - -
.: f
Jim Barber
Environmental Engineer
NCDE4-DWR-WQRO ..
Fayetteville_ Regional Office .. ......
. 91.0-433-3340 voice
910-486-0767 faz
lim:barberAmcdenr:aov .
E-mail correspondence to and from this address.may be subject to the North Carolina Public Records.Law and -
may be disclosed to third parties.
Go Green I. Print this email only when necessary::Thank you for. helping, NCDENR be environmentally responsible

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