WQ0001122_Staff Report_20190304

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ROY COOPER a
MICHAEL S.REGAN {
Secretary
UNDA CULPEPPER NO'iTH CAROL %4A
Direr for Environmental Quality
March 4, 2019
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To: Water QuaIiZL2er_mitting Section Cent[a] Office Application No.: M000235
Attn: Erick Saunders Permittee: Curtis insulation
Regional Log-in
No.:
From: Bay
Milosh
_Raleigh Regional Office
Nash County
1. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or❑ No
a. Date of site visit: Eebruary 15. 2019
b. Site visit conducted by: Ray Milosh
c. Inspection report attached? ®Yes or❑ No
d. Person contacted: Pete Curtis and their contact information: ( 19) - ext.
e. Driving directions:
11. FACILITY AND APPLICATION FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: Is this correct? ❑Yes❑ No
If no, please explain:
2. Are the new treatment facilities adequate for the type of waste and disposal system?
❑Yes ❑ No
If no, please explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted
reports? ❑ Yes❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, acreage, wells, etc.)?
❑Yes ❑ No ❑ N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
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6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑Yes ❑ No
❑ N/A
if no, please explain:
7. Are there any setbacks conflicts for proposed treatment, storage and disposal sites? ❑
Yes❑ No ❑ N/A
If yes, attach a map showing conflict areas.
S. Is the proposed or existing groundwater monitoring program adequate? ❑Yes ❑ No
❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
M. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility?❑Yes❑ No
® N/A
ORC: Certificate#: 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 below in Section IV.
Review Items
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 below in Section IV. Review Items
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 below in Section IV.Review Items
5. Is the residuals management plan adequate? ®Yes or❑ No- If no,please explain below
in Section IV. Review Items
6. Are the existing application rates(e.g.,hydraulic, nutrient) still acceptable?®Yes or❑ No
- If no,please explain below in Section IV. Review Items
7. Is the existing groundwater monitoring program adequate? ❑Yes❑ No® N/A
If no,explain and recommend any changes to the groundwater monitoring program below
in Section IV. Review items
8. Are there any setback conflicts for existing treatment,storage and disposal sites? ❑Yes or
® No
If yes, provide comments below 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 below in Section IV. Review Items
10. Were monitoring wells properly constructed and located? ®Yes❑ No❑ N/A If no,
please explain below in Section IV. Review Items.

11. Are the monitoring well coordinates correct in BIMS? ®Yes❑ No ❑ N/A
If no,please complete the following ex and table if necessary):
Monitoring Well Latitude Longitude
12. Has a review of all self-monitoring data been conducted (e.g., NDMR, NDAR,GW)? ®Yes
❑ No or❑ N/A
Please summarize any findings resulting from this review below in Section IV. Review
Items.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑Yes
or® No
Ifyes,please explain below in Section IV. Review Items.
14. Check all that apply:
® No compliance issues ❑ Current enforcement ❑ Currently under JOC
action(s)
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under
❑ Notice(s) of deficiency moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV,
NOD,etc.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No
❑ N/A
If no,please explain below in Section IV. Review Items.
16. Are there any issues related to compliance/enforcement that should be resolved before
issuing this permit?
❑Yes® No❑ N/A
If yes,please explain below in Section IV. Review Items.
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 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.
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Signature of APS regional supervis r:
Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Staff of the NC Division of Water Resources (DWR), Water Quality Regional Operations Section
inspected the subject closed loop recycle system on February 15,2019. 1 wish to thank Pete Curtis
for his help during the inspection. The purpose of the visit was to conduct a compliance inspection.
The factory has been closed since 2002, but the equipment and pond are still present.
On the day of the inspection, the freeboard in the lagoon was more than 2 feet. The pond is
escavated into the ground and has no large berm. The vegetation on the berm is mowed
periodically. The facility is surrounded by a fence limiting public access. Wells were found to be
in good condition. Sampling requirements have been suspended.
Mr. Curtis was informed that the permit could be rescinded but that if he wanted to keep it, he
would have to pay overdue annual fees and complete the permit renewal application. Mr. Curtis
would like to keep the permit. He completed the permit renewal form during the inspection. 1
submitted it on February 22, 2019. He was also given bills for the 2017 and 2018 annual fees.
The permit renewal process will begin when the overdue fees have been received.