WQ0001048_Staff Report_20191007

DocuSign Envelope ID: 38DCBD32-299E-4924-B78A-2B13B36C6265
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Ranveer Katyal
From: Randy Sipe
Washington Regional Office
Application No.: WQ0001048
Facility name: Contentnea MSD RLAP
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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ❑ Yes or ❑ No
a. Date of site visit: 4/22/19 (2018 Annual Report Review)
b. Site visit conducted by: R. Sipe
c. Inspection report attached? ❑ Yes or ❑ No
d. Person contacted: none and their contact information: (_)
e. Driving directions: No change since current permit was issued
2. Discharge Point(s): N/A, non -discharge system.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A, non -discharge system.
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
ext.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ❑ N/A
ORC: Renee Smith Certificate #: LA/14790 Backup ORC: Charles Smithwick Certificate 9:991850
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: Aerobic digestion of residual solids and land application by traveling gun. In
2013 the facilitv was modified and uDeraded_ includine two screw Dresses that can produce hieh solids content
residuals that are shipped offsite for composting by Granville Farms.
Proposed flow: N/A. RLAP permit (Annual Residuals Limit — 291 da tons)
Current permitted flow: N/A, RLAP permit (Annual Residuals Limit — 291 dry tons)
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,
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DocuSign Envelope ID: 38DCBD32-299E-4924-B78A-2B13B36C6265
etc.). Since the WWTP was modified and upgraded in 2013 and the new screw presses began operation, the
majority of residuals produced at the facility have been shipped offsite for composting by Granville Farms. The
amount of residuals beingland and applied under WQ0001048 has been well below the annual limit in the permit and
also well below the agronomic limit of the permitted fields.
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:
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: Because the application of
residuals under this permit is well below the agronomic limit for the permitted fields and also well below the
annual dry ton limit, WaRO recommends that groundwater monitoringbpended.
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 necessary):
Monitoring Well Latitude Longitude
C I II C I II
C I II C I II
C
C
C
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: There have been occasional, random exceedances of
the 2L std. for chromium in the monitoring wells, however, at WaRO's request, the facility and their consultants
performed a study in April through July 2019, that concluded that these exceedances were related to well
conditions and sampling methods and were not related to impacts from residual application. Re -development of
the wells performed during the study has resulted in reduced chromium levels in groundwater samples.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. See comment
above.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain: See comment above.
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.)
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DocuSign Envelope ID: 38DCBD32-299E-4924-B78A-2B13B36C6265
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? See the comment to Item IL 12 above.
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: N/A, non -discharge system.
17. Pretreatment Program (POTWs only): N/A, non -discharge system.
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
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
Groundwater monitoring
WaRO recommends that groundwater monitoring be suspended. Since the
WWTP was modified and upgraded in 2013 and the screw presses began
operation, the majority of residuals produced at the facility has been shipped
offsite for composting. The amount of residuals being land applied under
WQ0001048 has been well below the annual limit in the permit and also well
below the agronomic limit of the permitted fields.
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
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DocuSign Envelope ID: 38DCBD32-299E-4924-B78A-2B13B36C6265
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
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6. Signature of report preparer:
y �'PT V �Ifate reasons: )
Signature of regional supervisor:
Date: 10/7/2019
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 4 of 4