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Home My WebLink AboutWQ0003468_Staff Report_20230721DocuSign Envelope ID: FDAOBCEE-24FA-4622-9E1A-8E154F51E8FE State of North Carolina ®r- Division of Water Resources Water Quality Regional Operations Section Environmental Staff Report Quality July To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0003468 Attn: Leah Parente Facility name: Armour Lumber Mill CLRS From: Chad Coburn, Tyler Benson Wilmington Regional Office 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 pplicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? ❑ Yes or ® No a. Date of site visit: b. Site visit conducted by: c. Inspection report attached? ❑ Yes or ® No d. Person contacted: Lenore Popinchalk and their contact information: (910) 655 - 4106 ext. 211 e. Driving directions: 361 Federal Road, Riegelwood, NC 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: if , o Afe depth to table, the D Yes E] No site eendifiens (soils, wa4ef ete) eeasistei4 with stibmitted r-epefts? explain:3. if no, please Do the the lines, plans and site M" FepFesen4 aetual site (pr-epei4y wells,4. if no, please explain.: — oss Y 0 0�t is the r oa ;a,,,,l .,ao,,,,, �o. n Yes El No n Th �. if no, please explain: plan FORM: WQROSSR 04-14 Pagel of 5 DocuSign Envelope ID: FDAOBCEE-24FA-4622-9E1A-8E154F51E8FE III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 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: The eauipment used at this site consists of 2 recvcle ponds (Ash Pond 1 & 2 0.167 MG each), boiler blowdown water, wet boiler gas scrubber effluent, kiln dreg water, stormwater and washdown waters enter into Pond #1 where sediments, ash and woody debris settle. The water then flows by gravity to Pond #2 where it is pumped into a 13,000 gallon storage tank and then sent back into the facility for boiler water and scrubber supply water. Waste material and ash that accumulates in Pond #1 is periodically removed and sent to the New Hanover County Landfill for disposal. Water is evaporated from the settling ponds and infiltrates into the soil, no water is discharged. If needed water can be added to the system by purchasing it from the Town of Riegelwood or by using on -site well water. Proposed flow: 0 MGD Current permitted flow: 0 MGD 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.) A site inspection was conducted on 04/06/2022 where it was observed by DWR staff that the facility had previously removed the centrifuge system and installed a belt type oil skimming system (which utilizes a plastic tube as a belt) in the vehicle wash -down area to augment operations. System staff were informed that the changes noted above required a modification to the existing permit. 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: Unknown — The applicant needs to demonstrate that the system operates as a closed loop system (e.a. that the flow following the dumpster flows to Pond #1). DWR Regional staff requested confirmation that the system actually operates as a closed -loop system. This was to be accomplished either by conducting an assessment with a water balance approach or byprovidingdocumentation of the characteristics of the impermeable layer(s) in the two ash ponds to demonstrate that infiltration is not occurring. The results of the water balance analysis provided within the application produced an "highly uncertain" conclusion. The WiRO reauests that a feasible and practicable plan needs to be provided to determine whether or not the system is indeed acting as a closed loop recycle system. 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: See above #2 FORM: WQROSSR 04-14 Page 2 of 5 DocuSign Envelope ID: FDAOBCEE-24FA-4622-9E1A-8E154F51E8FE 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: A groundwater monitoring plan may be to be instituted to determine whether or not the system is functioning as a CLRS 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: See above #2 10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A If no, please explain: Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A if e Monitoring Latitude LMt9itU& �r a r rr �r a r rr a i ii a r rr a i it a r rr a i n a r rr Pfevide iapt4 to help the pemiit writer- evaloate &Ry requests for redueed monitoring, if applieable. 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: N/A FORM: WQROSSR 04-14 Page 3 of 5 DocuSign Envelope ID: FDAOBCEE-24FA-4622-9E1A-8E154F51E8FE IV. REGIONAL OFFICE RECOMMENDATIONS 1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No If yes, please explain: See items III.2. — 4. above and narrative below. 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 See narrative below in Part V. 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 ❑ DP8237FC6EDFCC4A3 LP„W§gb�.tate reasons: ) Docu Signed by: 6. Signature of report preparer: �ltiVLt fi�SOI� 6DCFCE2DD75L6E Signature of regional supervisor: .. -Toµ -Nrr, oti 7/21/2023 Date: 7F141 E73MF3456... FORM: WQROSSR 04-14 Page 4 of 5 DocuSign Envelope ID: FDAOBCEE-24FA-4622-9E1A-8E154F51E8FE V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS This review was conducted for a permit renewal and modification application for a closed loop recycle system facility to serve Armour Lumber Mill, a lumber processing facility. A site visit was last performed on April 6, 2022, with subsequent meetings with facility and DWR staff at later dates. During the site visit in April of 2022, it was observed by DWR staff that the facility had previously removed the centrifuge system and installed a belt type oil skimming system (which utilizes a plastic tube as a belt) in the vehicle wash -down area to augment operations. System staff were informed that the changes noted above required a modification to the existing permit. As a result of the April 2022 inspection, DWR staff then requested that the applicant demonstrate that the system operates as a closed loop recycle system (e.g. that the flow following the dumpster flows to Pond #1). This was to be accomplished either by conducting an assessment with a water balance approach or by providing documentation of the characteristics of the impermeable layer(s) in the two ash ponds to demonstrate that infiltration is not occurring. The results of the water balance analysis provided within the application produced an "highly uncertain" conclusion. The WiRO requests that a feasible and practicable plan needs to be provided to determine whether or not the system is acting as a closed loop recycle system. FORM: WQROSSR 04-14 Page 5 of 5