WQ0008349_Staff Report_20240710

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 4

July 10, 2024

To: NPDES Unit Non-Discharge Unit Application No.: WQ0008349
Attn: Elton Luong Facility name: Town of Newport RLAP

From: Chad Coburn & Ann Marie Baxter
Wilmington 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:
b. Site visit conducted by:
c. Inspection report attached? Yes or No
d. Person contacted: and their contact information: ext.
e. Driving directions:
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS: N/A

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Billy Dunham Certificate #:13203 Backup ORC: Mack Dunham Certificate #:24992
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: Existing permit: 200 DT/yr Class B residuals on 93.77 acres.
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:
Docusign Envelope ID: 38CCD1B7-83C9-477C-A791-C332409CB540Docusign Envelope ID: 45251C4C-CD3B-47A5-8BE0-4768E523D474Docusign Envelope ID: C8215EEC-F5E5-4B2D-8FFE-324C4971D61C
FORM: WQROSSR 04-14 Page 2 of 4
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 O&M plan adequate? Yes or No
If no, please explain: TCLP was required to be analyzed annually in previous permit but O&M says “once every
permit cycle”
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: 2023 Annual report was not compliant. TCLP analysis
was required annually but was not done.
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? TCLP analysis was required annually but was
not done.
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: TCLP analysis was required annually but was not done.
16. Possible toxic impacts to surface waters: none
17. Pretreatment Program (POTWs only): N/A

Docusign Envelope ID: 38CCD1B7-83C9-477C-A791-C332409CB540Docusign Envelope ID: 45251C4C-CD3B-47A5-8BE0-4768E523D474Docusign Envelope ID: C8215EEC-F5E5-4B2D-8FFE-324C4971D61C
FORM: WQROSSR 04-14 Page 3 of 4
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: 38CCD1B7-83C9-477C-A791-C332409CB540Docusign Envelope ID: 45251C4C-CD3B-47A5-8BE0-4768E523D474Docusign Envelope ID: C8215EEC-F5E5-4B2D-8FFE-324C4971D61C
7/10/2024
FORM: WQROSSR 04-14 Page 4 of 4
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

This review was conducted for a request by the Town of Newport to renew their land application of
residuals permit. The modification includes the addition of three application fields which would bring the
total acreage to 142.61 acres.
The residuals analysis indicates metals are below ceiling concentration limits. Pathogen and vector
attraction reduction requirements are being met by fecal coliform density demonstration and
incorporation. In 2023, only 28.50 total dry tons were land applied to 16.00 of 93.77 available acres. Field
loading rates for metals and PAN are being calculated, along with cumulative pollutant loading rates and
they are compliant.
Annual TCLP sampling and analysis as required by the 2019 permit was not done because the permittee
was under the impression that it was only required once per permit cycle (Refer to email from Bob Branch
on July 3, 2024). The most recent TCLP sample and analysis was for 2023 and is included in the
application documentation. A new TCLP sample is planned for 2024 per the application.

The WiRO recommends issuance of the permit renewal.

Docusign Envelope ID: 38CCD1B7-83C9-477C-A791-C332409CB540Docusign Envelope ID: 45251C4C-CD3B-47A5-8BE0-4768E523D474Docusign Envelope ID: C8215EEC-F5E5-4B2D-8FFE-324C4971D61C