WQ0001990_Staff Report_20240104

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: WQ0001990
Attn: Erickson Saunders Facility name: Town of Valdese

From: Melanie Kemp
Asheville 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.

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 8/11//2022
b. Site visit conducted by: Melanie Kemp
c. Inspection report attached? Yes or No In LF
d. Person contacted: Candace Cox and their contact information: 828-874-6785 ext.
e. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Subbasin 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:
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:
DocuSign Envelope ID: 707267E3-7D6B-4A3D-9C81-BD74E3163695
FORM: WQROSSR 04-14 Page 2 of 5
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.
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):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Lonnie Laird Certificate #: 1013758 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: Residuals management program for the Town of Valdese and consisting of
the distribution of Class A residuals generated by the Town of Valdese.
Proposed flow: 1,300 dry tons Class A residuals distributed per year, maximum
Current permitted flow: 2,500 dry tons Class A residuals distributed per year, maximum
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:
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:
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

DocuSign Envelope ID: 707267E3-7D6B-4A3D-9C81-BD74E3163695
FORM: WQROSSR 04-14 Page 3 of 5
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
Monitoring Well Latitude Longitude
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
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 reporting issues noted on the 2022 Annual
DCAR report (CEIARR dated 6/26/2023) were addressed and a revised report was submitted by the Town
on 6/27/2023.
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.)
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:
17. Pretreatment Program (POTWs only):

DocuSign Envelope ID: 707267E3-7D6B-4A3D-9C81-BD74E3163695
FORM: WQROSSR 04-14 Page 4 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

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
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:
Date:

DocuSign Envelope ID: 707267E3-7D6B-4A3D-9C81-BD74E3163695
1/4/2024
FORM: WQROSSR 04-14 Page 5 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Errors/issues noted in the application:
Form DCAR 06-16:
 Section II (Permit Information) note that permit number is WQ0001990
 Section IV (Residuals Quantity Information) note that the current permitted flow is 2,500 dry tons of
Class A residuals distributed per year, maximum. This does not match the quantity applied for (1,200
dry tons).
Form RSC 06-16:
 Section II.3 (Hazardous Waste Determination): TCLP result for Lead value (3.68 mg/l) does not match
results on Meritech lab report (<0.100 mg/l).
Residuals Source Facility Summary: does not include proposed maximum dry tons per year amount.
List of contacts on the Composting Operation Personnel and Spill Response Contact List needs to be amended
(ORC is currently Lonnie Laird and include Alexander Garrison as BORC).

DocuSign Envelope ID: 707267E3-7D6B-4A3D-9C81-BD74E3163695