WQ0023310_Staff Report_20240819

Docusign Envelope ID: BEB20877-EAB4-41C0-B404-C15FB77EB6DA
State of North Carolina
Division of Water Resources
®r'. Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Leah Parente
From: Tyler Benson
Wilmington Regional Office
Application No.: WQ00023310
Facility name: Warsaw Sanitation Trailer Wash
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 applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: July 31, 2024
b. Site visit conducted by: Tyler Benson
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Bradley Herring and their contact information: (910) 296 - 1800 ext.
e. Driving directions:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Bradley Herring Certificate #: SI 988691
Backup ORC: Michael Norris Certificate #:_SI 23931
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: As described in permit
Proposed flow: 20,000 GPD
Current permitted flow: 20,000 GPD
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:
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Docusign Envelope ID: BEB20877-EAB4-41C0-B404-C15FB77EB6DA
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: See below 012, for limit
exceedances
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:
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Docusign Envelope ID: BEB20877-EAB4-41C0-B404-C15FB77EB6DA
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
O l 11
O I //
O / //
O I It
O / //
O I /I
O l lI
O I it
O l lI
O 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:
The following summary of ground water monitoring data is a list of the consistent limit violations of 00620
Nitrogen, Nitrate Total:
March 2024:
14 mg/l
MW 3
July 2023:
10.8 mg/1
MW 3
March 2023:
12 mg/l
MW 1
16.5 mg/1
MW 3
July 2022:
16.3 mg/1
MW 1
12 mg/l
MW 3
March 2022:
12.5 mg/1
MW 1
17.7 mg/1
MW 3
November 2021: 12.4
mg/1 MW 1
July 2021:
17 mg/l
MW 1
18.4 mg/l
MW 3
March 2021:
14.5 mg/1
MW 1
24.8 mg/1
MW 3
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
Please see summary in Section IV.
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:
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Docusign Envelope ID: BEB20877-EAB4-41C0-B404-C15FB77EB6DA
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Docusign Envelope ID: BEB20877-EAB4-41C0-B404-C15FB77EB6DA
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
Map representing
groundwater flow
Monitoring Well 3 is showing consistent Total N limit exceedances. This map
will offer essential information for identifying potential locations to place
monitoring wells along the compliance boundary.
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
Schedules Condition I.2 -
Six (6) months
Per Condition III.18, modifications to the Waste Utilization Plan is required to
be submitted to the Division. Please see summary note below for
operational/crop plan changes as discussed with Smithfields Staff.
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: )
D 6' tl by:
6. Signature of report preparer: fi�7;1,t&
�E DEI 1926EI. 56166..
Signature of regional supervisor: F�erc a�a 4t;" wb4
Date: 8/19/2024 E3N AICACZD 34_
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Docusign Envelope ID: BEB20877-EAB4-41C0-B404-C15FB77EB6DA
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The Warsaw Sanitation Trailer Wash is permitted for the operation of a 7.3 MG per year non -discharge facility. This
facility is in compliance with Permit No. WQ0023310. However, the groundwater monitoring data submitted in every
March, July, and November sampling shows a consistent trend of Total N limit exceedances within MW 1 and MW 3.
This trend is described above in Question 12, as well as on the line graph below:
PARAMETER: 00620 - Nitrogen, Nitrate Total (as N)
28
24
20
m
16
12
8
4
0
Di T' TT'u� T� 0i
9 A A °19��a % ��R �PR Q� �2T ��T
GW59 Date
TTi, q T Ti QiiP7 �i�- Ti �Ti T�;P0�
f MW-1R
MW-2R
MW-3R
Please note: After discussion with staff affiliated with the Warsaw Sanitation Trailer Wash, on August 16, 2024,
operations will be modified on Field H (adjacent to MW-3). These operational changes include the removal of row
cropping and only planting soybeans in hopes of having MW-3 to be in compliance.
FORM: WQROSSR 04-14 Page 6 of 6