WQ0006147_Staff Report_20240425

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 3

April 25, 2024
To: NPDES Unit Non-Discharge Unit Application No.: WQ0006147
Attn: Erick Saunders Facility name: Butterball RLAP

From: Chad Coburn
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: Joshua Batchelor 919-658-6743
e. Driving directions: 1628 Garner Chapel Rd Mt. Olive
2. Discharge Point(s): N/A
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: Joshua T. Batchelor Certificate #: 993694 Backup ORC: Jason C. Murphy Certificate #: 991741
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 permitted facilities have not changed since last renewal.
Proposed flow: No additional tonnage proposed.
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.) N/A
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: CF18A4AC-B02F-4C98-B3DF-65E2D21A4B76DocuSign Envelope ID: 7DCF307B-B7AF-4C9B-8845-3A06DAB47085
FORM: WQROSSR 04-14 Page 2 of 3
3. 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:
4. Is the residuals management plan adequate? Yes or No
Currently send solids for composting at McGill Environmental. WAS from the sanitary plant is pumped to the
primary lagoon per ORC Joshua Batchelor, therefore this permit WQ0006147 RLAP should not be a 503 exempt
permit. This permit is maintained as a back-up plan and records show that there have been no land applications
per this permit in many years.
5. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
If no, please explain:
6. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
7. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain:
9. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
10. 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

11. 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: Permittee needs to be reminded to send in annual
report even when no application occurs.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. N/A
12. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain
13. 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:
14. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: none
16. Pretreatment Program (POTWs only): N/A

DocuSign Envelope ID: CF18A4AC-B02F-4C98-B3DF-65E2D21A4B76DocuSign Envelope ID: 7DCF307B-B7AF-4C9B-8845-3A06DAB47085
FORM: WQROSSR 04-14 Page 3 of 3
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
* *See narrative below

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:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This review was conducted for a permit renewal request for Butterball, LLC’s land application
of residuals program. Solids from the treatment facility are sent to a rendering plant or to
McGill Environmental for composting, therefore land application activities have not been
conducted and this permit is only maintained as a back-up plan.

According to the ORC, waste activated sludge from the facility’s sanitary plant is pumped to the
primary lagoon, therefore this permit should not be a 503 exempt permit.

It is recommended to keep permit condition I.3. to confirm buffer setbacks if they intend to
utilize field #8.

DocuSign Envelope ID: CF18A4AC-B02F-4C98-B3DF-65E2D21A4B76DocuSign Envelope ID: 7DCF307B-B7AF-4C9B-8845-3A06DAB47085
4/25/2024
Acting Regional Supervisor