WQ0013808_Permit Renewal_20180213

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
February 13,2018
To: DWR Central Office—WQ,Non-Discharge Unit Application No.: W000 13808
Attn: Ashley Kabat Facility name: Summerfield Shopping Center WWTF—Wastewater Irrigation
From: Patrick Mitchell
Winston-Salem Regional Office
Note:This form has been adapted from the non•discharae facility staff report to document the review of both non-dueharee and NPDES Permit applications and/or renewals.Please complete all sections as they are aonlicable
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted?®Yes or❑No
a. Date of site visit: January 30,2018
b. Site visit conducted by: P.Mitchell and R. Chandler
c. Inspection report attached? ❑Yes or®No
d. Person contacted: Chad Leinbach,ORC and their contact information: [phone] ext.
e. Driving directions: Near intersection of Hwy 220 N and Hwy 150 W.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge(ORCs)for the facility?❑Yes ®No❑N/A
ORC: Chad Leinbach Certificate#:SI-23928 Backup ORC: Bradley Flynt Certificate#:WW-4 27171
Explain: The primary ORC did not renew certification.Backup does not possess an irrigation certification.
2. Are the design,maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ®Yes or❑No
3. Are the site conditions(e.g., soils,topography,depth to water table,etc)maintained appropriately and adequately
assimilating the waste? ®Yes or❑No
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
5. Is the residuals management plan adequate? ❑ Yes ❑No ®NE
If no,please explain: Not sure if the facility has established an O&M plan or residuals management plan.
6. Are the existing application rates(e.g.,hydraulic,nutrient)still acceptable?®Yes or❑No
7. Is the existing groundwater monitoring program adequate? ❑Yes ❑No®N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or®No
Explain:None with the existing permit setbacks.Recommend keeping those in place.
9. Is the description of the facilities as written in the existing permit correct? ❑Yes or®No
If no,please explain: We need an updated site map showing a labeled as built of the system. See Additional
Regional Staff Review Items for more details.
10. Were monitoring wells properly constructed and located? ❑ Yes❑No N/A
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes❑No®N/A
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: Exceedances of the following limits: daily max flow,
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max annual irrigation, and less than the minimum 2 ft.freeboard. See Additional Regional Staff Review Items for
more details.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑Yes or®No
If yes,please explain: Unless it is discovered that the system is inadequate.
14. Check all that apply:
❑No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
Notice(s)of violation ❑ Currently under SOC 0 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?See Additional Regional Staff Review Items.
Have all compliance dates/conditions in the existing permit been satisfied? ❑Yes ®No 0 N/A
If no,please explain: It appears that we have not recieved an Engineer Certification for the system modificaitons
that took place after 2007. A staff gauge has not been installed in the storage pond. Waste staff gauges have not
been installed in the wetland cells. SEE ADDITIONAL REGIONAL STAFF REVIEW ITEMS.
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:
III.REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? 0 Yes or®No
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
Updated Site Map WWTF described onsite does not match permit description.Plus system was
modified after 9/01/2006.Therefore,requiring an updated site map.
Engineer Certification WSRO does not have this on file.Not sure this has been completed.
Certificate of Public Is this a privately owned public utility?The application for renewal indicated.
Convenience&Necessity
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
PPI-01 This was for"Prior to construction".No longer applicable.
Wetland Cell Staff Gauges These have gravity flow in series,and should not fluctuate.
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
5. Recommendation: ®Hold, pending receipt and review of additional information by regional office
0 Hold,pending review of draft permit by regional office
0 Issue upon receipt of needed additional information
❑Issue
❑Deny(Please state reasons: )
6. Signature of report preparer: JJ��� /�z
Signature of regional supervisor: �GtL�•,, V e a.l-
Date: February 13,2018
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IV.ADDITIONAL REGIONAL STAFF REVIEW ITEMS
1. There are three separately owned parcels present(see attached site map).One contains the majority of the WWTF and the
drip fields. One contains one of the waste generating facilities with multiple septic tanks and a grease trap serving that
facility.One that contains the other waste generating facility with a septic tank serving that facility.Are setback waivers or
easements necessary,if not already obtained?If this is truly a privately owned public utilities,would that make a difference?
It seems like the septic tanks are part of the WWTF(solids removal)and should be listed as such in the permit.
2. There are no soil moisture sensors present on the system as described in the permit,only precipitation sensors were found to
be present.Portions of the WWTF as described onsite do not match the system description.The proposed plans do not
exactly match the onsite described system.There was no as built site map present at the facility.Request that an updated set
of plans and system description be submitted.
3. A staff gauge has not been installed in the storage pond.NOTE:There was a pvc pipe with hand written measurements
present in the storage pond pump station.This pipe was not stationary to the tank,and it was unclear if the measurements are
appropriate for accurately indicating freeboard in the storage pond.
4. There is no Engineer Certification present in the WSRO files.It is unknown if this has been completed.Request that they
submit the PE Certification,or include this as a schedule that must be done within 90 days of permit issuance.If this is a
scheduled item,WSRO will conduct follow-ups and proceed to enforcement if necessary.
5. PPI-001 can be removed from the permit since all has been constructed.The system modification,installation and initial use
of the system occurred prior to my employment in WSRO.Reportedly all the modifications have been installed.
6. Review of the last five years of self-monitoring and compliance files suggests that the facility has had issues periodically
with exceeding the permitted daily flow,exceeding the 12-month irrigation limit,and with exceeding the 2 ft. freeboard in
the wet weather storage pond.The ORC attributes all of these to mechanical and electrical failures with the system,and
failure of the owner to make necessary repairs in a timely manner.
However,WSRO staff noted questionable operations that were observed during the site visit which could have also
contributed to these violations.Examples: 1)The ORC had the power turned off to the storage pond pump station;2)There
was a board placed in the flow splitter box,blocking flow from the wet weather storage pond and forcing 100%of effluent
flow to the irrigation pump station;among others. WSRO staff are in progress of writing an NOV/NOI for these permit
condition violations,and others.
7. As mentioned above in item#5,WSRO staff are in progress of issuing an NOV/NOI to the subject facility.In addition to the
items already listed above,the following violations were also noted during the site visit:
• The subject system failed to renew the permit prior to the expiration date,despite multiple reminders from
WSRO staff. The facility has been operating without a valid permit.
• The subject system currently does not have valid ORCs designated.The listed primary ORC does not
currently possess valid operator certifications.The listed backup ORC does not possess an irrigation
certification.
• Weather codes and precipitation measures are not being reported for all dates with irrigation events.
• The sand filter is discharging out of the south side of the sand filter,resulting in a bypass of partially
treated wastewater into the effluent storage pond.The ORC indicated they have been dealing with this
issue for several years.NOTE: ORC indicated that there have been issues in the past with the grease trap
overflowing, and allowing grease to enter the WWTF. The sand filter may be clogged and the media may
need to be replaced.
• There was an inline filter that was being bypassed in the dose station for the sand filter at the time of
inspection.The cap to the filter was missing, allowing wastewater to overflow from the top.
• At the time of arrival,the power was turned off to the controls for the sand filter dosing tank. When the
power was turned back on(at the request of WSRO staff),the alarm immediately started.It was unclear at
the time as to what the issue was,but this needs to be investigated and resolved.
• There was a small tree(appeared to be a willow tree)found to be growing in the wetland cells.
• Public access to the WWTF and drip zones is not restricted from Hwy 220 N.;signage or fencing needs to be placed
at the entrance.The access restricting fence along the east side of the drip zones has been knocked down in places
due to trees falling,and needs repair/replacing.
• The drip fields need to be cleared of all dead trees(including those that are still standing).Damage to drip tubing
and to the distribution system were noted during the site visit.This has resulted in ponding,runoff,and an illegal
discharge of wastewater to surface waters(all observed during the site visit).
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