WQ0012709_Staff Report_20240418

DocuSign Envelope ID: 47220EC1 -FD73-4613-B20D-31 BF93D9245D
}
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit® Non -Discharge Unit Application No.: WQ0012709
Attn: Leah Parente Facility name: Wells Pork -Beef Products WWTF
From: Chad Coburn
Wilmington Regional Office
Note: This form has been adapted from the non -discharge facifily 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: 03-22-2024
b. Site visit conducted by: Chad Coburn
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Marty Fritz ORC and their contact information: 910) 319 - 0037 ext.
e. Driving directions: I-40 to NC-53 E in Burgaw. exit 398 from I-40, Take NC 53 to Murray Town Rd; to
Croomsbridge Rd: Facility is at 750 Croomsbridge Rd
IL PROPOSED FACILITIES: NEW APPLICATIONS
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Marty Fritz
Certificate #: 995923
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: At least two of the four above ground 17,000 gallon storage tanks have large cracks within
the walls and are not suitable for use without repair.
Description of existing facilities: 2,100 gallon per day (GPD) surface irrigation treatment and disposal facility
consisting of two-1,500 gallon holding tanks, a 1,500 gallon pump tank with two'/2 horsepower (hp) submersible
pumps, and a high water alarm system, four above ground 17,000-9allon storage tanks, a 3.65 acres spray
irrigation area with associated solid set spray irrigation equipment, to include 20-Senniger 7025-1 spray nozzles
and one -five horsepower irrigation pump: and all associated valves, piping and appurtenances. At least two of the
tanks show signs of leaks.
Note: The ORC mentioned that the facili , typically generates approximately 100 gpd of wastewater. The
permitted flow (2,00gpd) may be much greater than is needed. Given the small amount of flow generated, it is
not necessary to use the entire spray irrigation system at one time.
Proposed flow: 2,100 gpd
Current permitted flow: 2,100 gpd
FORM: WQROSSR 04-14 Page 1 of 4

DocuSign Envelope ID: 47220EC1 -FD73-4613-B20D-31 BF93D9245D
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: ORC stated that Lewis farms pumps out the tanks but is unsure how often this occurs.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ® No
If no, please explain: Effluent pump is not adequate to operate the ENTIRE irrigation system of spray nozzles
simultaneously. The ORC valves off the desired branches and irrigates one section at a time. The ORC submitted
information that a 6 horsepower pump would be adequate to run the entire system at once.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ® No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program: There are no monitoring
wells on this site, the water supply well is located on site and adhears to required setback.
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: One of the tanks and grease trap has been removed at some point in time from the
original description of the storage and holdings tanks.
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
C I II
C I II
C I II
C I II
C I II
C I II
C I II
C I II
C I II
C I II
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: Late or missing NDMR's and NDARI's for October,
November, and December 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: Condition L2. of the permit states, "No later than three months from the date of issuance of this
FORM: WQROSSR 04-14 Page 2 of 4

DocuSign Envelope ID: 47220EC1 -FD73-4613-B20D-31 BF93D9245D
permit, the Permittee shall have evaluated and tested, by a qualified professional, the integrity of the three wastewater
storage tanks, pump tanks, and associated valves and piping." The permittee submitted a letter from Steve Blanchard
Engineering dated December 4, 2023, stating "Per your request, I performed a visual inspection integrity test on three ( 3)
— 17, 000 gallon above ground storage tanks (AST) on November 29, 2023. There are four tanks total on site, the most
northern tank was out of service and not inspected. Based upon my visual inspection, I certify the structural integrity of
the three 17,000 gal AST. The tanks have no signs of leakage, infill piping and drain piping are secure and in good
condition. Access hatches are properly fastened." During the site visit by DWR staff on March 14, 2024, large cracks with
leakage were observed on the two tanks currently being used (Outer tanks of the four the southern most and northern most
tanks) of the four total. The two inner tanks did not appear to have any visual cracks or leaks. The two outer tanks could
be shut off and repaired while the two inner tanks are used.
Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
® Yes ❑ No ❑ N/A
If yes, please explain: See comments above and below.
15. Possible toxic impacts to surface waters:
16. Pretreatment Program (POTWs only):
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
Condition L2
The two outer 17,000 gallon holding tanks are currently being used. Both show
signs of instability, cracking, and leakage. Additionally, the northern most tank
that is currently being used shows the most signs of instability and should be
evaluated and tested by a qualified professional.
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
Certification as required by the permit was due by August 8, 2017 but was not
Condition I.2
received. An incomplete certification for 3 of the 4 tanks was received on
December 8, 2023. The regional office recommends that this be completed and
submitted within 90 calendar days of receiving the new permit if issued.
FORM: WQROSSR 04-14 Page 3 of 4

DocuSign Envelope ID: 47220EC1 -FD73-4613-B20D-31 BF93D9245D
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: 4/8/2024
DocuSigned by:
Cyow
8237FC6EDFCC4A3...
DocuSigned by:
fibwJ Tt,aVVY46VU
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This staff report was prepared in preparation for the permit renewal. The current effluent pump (5hp) is not adequate to
operate the entire irrigation system at one time. However, per the ORC the facility does not need or wish to operate the
entire system at one time given the small amount of wastewater generated per day.
Condition 12. of the permit states, "No later than three months from the date of issuance of this permit, the Permittee shall
have evaluated and tested, by a qualified professional, the integrity of the three wastewater storage tanks, pump tanks, and
associated valves and piping."
The permittee submitted a letter from Steve Blanchard Engineering on December 8, 2023, stating "Per your request, I
performed a visual inspection integrity test on three ( 3) — 17, 000 gallon above ground storage tanks (AST) on
November 29, 2023. There are four tanks total on site, the most northern tank was out of service and not inspected. Based
upon my visual inspection, I certify the structural integrity of the three 17,000 gal AST. The tanks have no signs of
leakage, infill piping and drain piping are secure and in good condition. Access hatches are properly fastened."
During the site visit by DWR staff on March 14, 2024, large cracks with leakage were observed on the two tanks currently
being used (the two outer tanks) the southern -most and northern -most tanks of the four total. The two inner tanks did not
appear to have any visual cracks or leaks. The two outer tanks could be shut off and repaired while the two inner tanks
are used. It appears that the facility is required to have the four tanks (68,000-gallon total storage) due to the permitted
flow being 2,100gpd (63,000 gallons over 30 days per 15A NCAC 02T .0505(o)). The facility may want to ask for a
reduction in the permitted flow to align with the actual total. The Wilmington Regional Office issued a Notice of
Violation on March 22, 2024, for not fulfilling Permit Condition 12. and for failing to maintain the storage tanks.
FORM: WQROSSR 04-14 Page 4 of 4