WQ0006147_Staff Report_20181210

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
December 10, 2018
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0006147
Attn: Troy Doby Facility name: Butterball RLAP
From: Geoff Kegley
Wilmington Regional Office
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:
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 Batchelor Certificate #: 993694 Backup ORC: 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: 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:
FORM: WQROSSR 04-14 Pagel of 3

DocuSign Envelope ID: 1AC58168-56A6-4613-B196-1C41C53D1874
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 sanitaryplant is pumped to the
primarlagoon per ORC Joshua Batchelor, therefore this permit WQ0006147 RLAP should not be a 503 exempt
permit. This permit is maintained as a back -Lip 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
7 no, please complete the following ex and 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
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DocuSign Envelope ID: 1AC58168-56A6-4613-B196-1C41C53D1874
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: )
/—Docuftned by:
6. Signature of report preparer:
Signature of regional supervisor:
Date: 12/11/2018
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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.
A reminder in the cover letter to send in the annual report even when no application occurs
would be helpful as this is consistently overlooked by the permittee.
FORM: WQROSSR 04-14 Page 3 of 3