WQ0000543_Staff Report_20240305

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 4

To: NPDES Unit Non-Discharge Unit Application No.: WQ0000543
Attn: Cord Anthony Facility name: City of Sanford
RLAP

From: Chris Smith
Raleigh 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: September 26, 2022
b. Site visit conducted by: Chris Smith
c. Inspection report attached? Yes or No
d. Person contacted:
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. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Robert N. Roth Certificate #: 1001672 Backup ORC: NONE 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:
Proposed flow:
Current permitted flow:
DocuSign Envelope ID: 65AB73C2-25D3-4C53-B01B-535008888C66
FORM: WQROSSR 04-14 Page 2 of 4
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:
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:
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?
DocuSign Envelope ID: 65AB73C2-25D3-4C53-B01B-535008888C66
FORM: WQROSSR 04-14 Page 3 of 4
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):
III. 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

DocuSign Envelope ID: 65AB73C2-25D3-4C53-B01B-535008888C66
FORM: WQROSSR 04-14 Page 4 of 4
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:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The application appears to be complete. The modification requested will remove approximately 30
acres of application fields from the permitted application area. This will leave the facility with
approximately 798 acres of application area which should be sufficient to meet the disposal need.
DWR records do not include a backup ORC for this facility. The application indicates Adam
Brigman (Certification No.1006653) will be designated as back-up ORC.

DocuSign Envelope ID: 65AB73C2-25D3-4C53-B01B-535008888C66
3/6/2024