WQ0017321_Staff Report_20181203

State of North Carolina
Division of Water Resources
" Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0017321
Attn: Troy.Dobygncdenr.gov Facility name: Cargill Incorporated
DCAR County: Mecklenburg
From: [e-mail]
Mooresville 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: 11-20-2018
b. Site visit conducted by: Maria Schulte and Edward Watson
c. Inspection report attached? ❑ Yes or ® No, Emailed separately.
d. Person contacted: Daniel Imoudu, Refinery Superintendent: (704) 679 - 7120 ext.
e. Driving directions: From MRO travel to I-77S; Exit at Woodlawn Road, Turn left onto Woodlawn, Turn Right
onto South Blvd.; Facility is on the Right. This facility requires: steel toes shoes, helmet, eve wear and will
provide special chemical resistant cloves for plant tour.
2. Discharge Point(s): NA — this is a non -discharge permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
11. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, 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, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Pagel of 5

5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. 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)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A; The permittee
contracts with Waste Management rg_oup to haul residuals for composting at Wallace Farms. The permittee could
rescind this permit anytime, as they have not utilized it for land application or distribution during the several years
current MRO-DWR staff have conducted inspections.
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:
Description of existing facilities: This is a non-503 distribution permit. The facility processes residuals by belt -
press. The cake is captured in a roll -off and hauled by Waste Management services to Wallace Farms for
composting. Both the hauler and composter are permitted through Division of Waste Management.
Proposed flow:
Current permitted flow:
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.) The facility addressed residuals processing concerns noted in the 2017 inspection via: Use o a new
flocculant, additional "u " bend plumbing to increase contact time, new belt on the press and floor drain pump
Yepairs.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No This question is not applicable, since they haul all residuals for
compostin,-.
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:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No This question is
not applicable, since they haul all residuals for compostinz
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:
FORM: WQROSSR 04-14 Page 2 of 5

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 necessarv):
Monitoring Well
Latitude
Longitude
0 / //
0 I II
0 / lI
0 I It
0 / //
0 I II
0 / lI
0 I It
0 / //
0 / //
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: NA - Analydcal data is not required by this permit.
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?
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:
16. Possible toxic impacts to surface waters: Yes, for any residuals hauling, application or distribution activity.
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 5

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: 11/30/2018
44" H p44,t4 12/03/18
F161 FB69A2D84A3...
FORM: WQROSSR 04-14 Page 4 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
MRO staff discussed option to rescind this permit during the inspection; however, per 11-30-18 email from Daniel Imoudu,
management has opted to retain their permit and continue with this renewal. The facility could rescind this permit anytime, as
they are NOT utilizing it.
FORM: WQROSSR 04-14 Page 5 of 5