WQ0019755_Staff Report_20200630

DocuSign Envelope ID: 6B94BCOB-FE84-4DCD-97F2-B7D4EBB2AA1A
June 30, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00019755
Attn: Vivien Zhona Facility name: Oak Ridge Commons, Conjunctive Reclaimed — Wastewater Irrigation
From: Patrick Mitchell
Winston-Salem Regional Office
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 applicable.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: June 23, 2020
b. Site visit conducted by: P. Mitchell & R. Chandler
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Doug Smith, ORC and their contact information: (336) 215 - 0949
e. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
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
Explain: Some of the spray heads have been capped off due to ponding & runoff. Hourly loading rates in permit
are too high. See section IV. Additional Regional Staff Review Items in this staff report for details.
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 or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ® No
Note: The Attachment B of the current permit incorrectly list rates for Zone 8A & B, and the max hourly loading
rates are too high. See section IV. Additional Regional Staff Review Items in this staff report for details.
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
Note: Groundwater monitoring is currently not required, but may need to be considered if PAN loading from the
reclaimed system continue to load at or near the agronomic limits. See section IV. Additional Regional Staff
Review Items in this staff report for details.
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: See section IV. Additional Regional Staff Review Items in this staff report for 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
FORM: WQROSSR 04-14 Page 1 of 4

DocuSign Envelope ID: 6B94BCOB-FE84-4DCD-97F2-B7D4EBB2AA1A
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: Confusion in reporting between the reclaimed water
irrigation and the standard wastewater irrigation .ystems. In accurate reporting of loading to zones 4A/B — 7A/B
and UP-01 — UP-07. See section IV. Additional Regional Staff Review Items in this staff report for details.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ® Yes or ❑ No
If yes, please explain: See section IV. Additional Regional Staff Review Items in this staff report for details.
14. Check all that apply:
❑ No compliance issues
® Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain: Related to confusion in the two system Wes and prior ORC issues. Note, the ORC designation
has changed, and new ORCs are working to address prior issues.
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? Yes, permit renewal with correction should help.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑Yes®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ 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:
3
4
Item
Reason
Updated site map &
updated acreages
See IV. Additional Regional Staff Review Items.
Acreage for 4A & 4B and
acreages for UP-01 through
See IV. Additional Regional Staff Review Items.
UP-07.
List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
There are no Zones 8A ad 8B, only Zone 8. There should be a Zone 4A and 4B
Correction to Attachment B
instead. See section IV. Additional Regional Staff Review Items in this staff
report for details.
Correction to Attachment A
The max daily flows are not correct. See section IV. Additional Regional Staff
PPI-001 and PPI-003
Review Items for details.
List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Install an upset flow meter
on the Reclaimed WWTP
To track Upset flows to Standard WW Irrigation system so that total daily flows
to the standard WW system can be accurately tracked.
5. Recommendation: ® Hold, pending receipt and review of additional information by regional office
® Hold, pending review of draft permit by regional office
DocuSigned by:
Signature of report preparer: PAfiV & kft�& ,—D---Sig ed hy.
Signature of regional supervisor:
Date: June 30.2020
145B49E225C94EA..
FORM: WQROSSR 04-14 Page 2 of 4

DocuSign Envelope ID: 6B94BCOB-FE84-4DCD-97F2-B7D4EBB2AA1A
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On June 23, 2020 WSRO staff conducted a site visit for review associated with the application for permit renewal.
Accompanying staff on the entire review were Mr. Doug Smith (SI-ORC) and Mr. Travis Carrel (Maintenance).
Mr. Phillip Cooke (Permittee) accompanied staff on records and WWTPs review only. There were no changes noted
for the facility or on adjacent neighboring properties since the last permit renewal.
A brief explanation of the two different systemXpes covered under this one permit and their operations: There is a
valve on the collection sewer line prior to either WWTP (see attached site plan), which can divert 100% of the influent
flow into either the "Reclaimed WWTP" or into the "Standard Wastewater Irrigation WWTP". Onsite representatives
indicated that the standard wastewater irrigation system WWTP is not utilized routinely and is rarely used. Reportedly
it is only used when repairs or maintenance to the reclaimed WWTP warrant. The ORCs did have receipts from a recent
solids pump out event on the septic tank serving the standard wastewater irrigation WWTP. Therefore, it is obviously
being used at times and it appears to be maintained.
The normal daily operations are running wastewater through the reclaimed WWTP only. It was indicated that the only
routine flows entering the standard wastewater irrigation system are derived from the upset wastewater on the reclaimed
WWTP. As the system is being operated, the primary limiting daily flow design is the reclaimed system WWTP. There
is the potential for additional flows to be manually diverted to the standard wastewater irrigation WWTP should daily
flows exceed 30,000 GPD. However, that volume of daily flow would have to be subtracted from the amount remaining
if any upset flows have contributed to the standard wastewater irrigation WWTP in each day. The site plan list the
reclaimed irrigation zones as "RC" and the standard wastewater irrigation zones as "UP".
Below is a summary of items noted during the review which require attention.
1. Some of the spray heads have been capped off in zones RC-03, RC-06, and UP-02 due to problematic issues
during irrigation events. An updated site map that shows the heads that are no longer being used in these
zones (and any others that have impacts) along with updated acreages for each impacted zone is needed.
2. The current Permit Attachment B is not correct. There are three issues that need to be corrected.
A. There are no irrigation zones 8A and 813 present for the subject system as currently listed. The Permit
Attachment B should list only zone 8 with a max annual loading rate of 22.21 inches/year. The acreage for
8A and 813 should be added together for the Net Acreage of zone 8.
B. Irrigation zone 4 is actually two separate zones, 4A and 413. The Attachment B should list zone 4A with
max annual loading of 22.21 inches/year & zone 413 with a max annual loading of 36.84 inches/year.
However, the acreage for each of these zones is unknown. Please request acreage for zones 4A and 4B.
See the attached site map which has the zones A and B labeled. The "A" zones have a different type of
spray head (i.e. wobble spray heads) versus the impact sprinkler spray heads found in the `B" zones.
Reportedly the wobble spray heads load approx. 0.1 inches/hour less than the impact sprinkler spray heads,
thus loading at a reduced annual loading rate when compared to the impact sprinkler zones.
C. The current Attachment B list "N" and 7.32 acres for the standard wastewater irrigation system. However,
there are seven independent irrigation zones present for the standard wastewater irrigation system. These
irrigation zones are dosed independently, one zone at a time. The Permit Attachment B needs to be corrected
to match the system and allow for accurate reporting. We need to request the acreages for each of these
zones to be listed in the new Attachment B.
It should be noted that the ORCs have been incorrectly dividing irrigation loading to zones 4A/413 — 7A/713 in
half and reporting the same loading to each zone on forms NDAR. This is not correct as the two zones have
different hourly loading rates. This is to be corrected for reporting moving forward. This will result in a period
where the 12-month loading totals will not be 100% accurate for these zones. BIMS needs to be updated
accordingly and customized NDAR reporting forms need to be made to address these corrections. WSRO
to follow-up to ensure corrections are made and that they are accurately tracked moving forward.
FORM: WQROSSR 04-14 Page 3 of 4

DocuSign Envelope ID: 6B94BCOB-FE84-4DCD-97F2-B7D4EBB2AA1A
3. The maximum hourly loading rates listed in the current Permit Attachment B are too high and should be
lowered. Currently the reclaimed irrigation zones are listed as 0.7 inches/hour max and the standard wastewater
irrigation zones are listed as 0.5 inches/hour max. During the site visit several soil borings were placed in both
reclaimed and wastewater irrigation zones. Based upon the top soils present, the landscape position of the
irrigation fields and the short distance to ditches and surface waters, the recommended max hourly rates should
be 0.30 inches/hour for the reclaimed irrigation zones and 0.25 inches/hour for the standard wastewater
irrigation zones.
The ORCs have been reporting hourly loading rates much lower than these on NDAR reports, but the accuracy
of those reports is questionable (as discussed above). It should be noted that there have been issues with ponding
and runoff noted in the past permit cycle even with the lower reported loading rates. Recommend that the
Permit Attachment B be updated to list max hourly loading rates of 0.30 inches for the reclaimed
irrigation zones and 0.25 inches for the standard wastewater irrigation zones.
4. The current Permit Attachment A list incorrect flow limits for both PPI-001 (Reclaimed) and PPI-002
(Wastewater). According to onsite representatives and as indicated on the attached Engineer site plan, the
reclaimed system should have a max daily flow of 30,000 GPD in PPI-001 and the standard wastewater system
should have a max daily flow of 6,000 GPD in PPI-002. The two combined is believed to be where the 36,000
GPD came from in the current PPI-001. Representatives indicated that the original Wastewater system flow of
12,094 GPD had to be reduced when the Reclaimed system was installed due to construction of the Reclaimed
storage lagoon eliminating some of the standard wastewater irrigation zones where it is located, and also to
accommodate the upset flows into the system. Please correct the Permit Attachment A to list PPI-001 with
max flow of 30,000 GPD and PPI-002 with a max flow of 6,000 GPD.
5. The current system description in the permit is not correct. There is a tablet chlorinator and an effluent flow
meter present on the standard wastewater treatment system. These need to be added to the system description
in the permit.
6. Currently there is no flow meter present on the upset line that distributes upset wastewater to the standard
wastewater system for disposal via the "UP" zones (i.e. upset aka standard wastewater irrigation zones).
Therefore, the facility has not been accurately tracking or reporting these additional daily flows to the standard
wastewater system as required in PPI-002. WSRO staff has requested meter installation over the past two years,
but it has not been completed yet. Permittee indicated that they are working on this addition. Please add a
schedule condition that request an upset flow meter be installed within 90 days of permit issuance.
7. Groundwater monitoring is currently not required for the subject system. Review of self -monitoring data for
the past 12 months suggests that the reclaimed water irrigation system is loading as much as 132.4 lbs. of
PAN/acre/year. The self -monitoring data reported for the standard wastewater irrigation system is not correct
(see item 2.C. above) and therefore the PAN loading could not be determined. There is some debate on what
the maximum agronomic needs are for forestland. This agronomic loading rate is near or slightly above some
of the reported limits for PAN loading.
The stream that flows between the irrigation zones was reviewed during the site visit. There were no obvious
signs of impact (clear water, odorless, no algal growth, no fungal growth, fish observed). However, WSRO to
review this surface water feature and agronomic loading over the next permit cycle to determine if groundwater
and/or surface water sampling is needed.
8. The "Upset Lagoon" liner has a hole in it and needs repair. The facility is aware of this issue and reportedly has
ordered the repair work and is waiting on contractors to do the work. WSRO staff to conduct a follow up
compliance inspection to ensure this is completed in a timely manner.
FORM: WQROSSR 04-14 Page 4 of 4

Compliance Inspection Report
Permit: WQ0019755 Effective: 12/04/15 Expiration: 11/30/20 Owner: JPC Utilities LLC
SOC: Effective: Expiration: Facility: Oak Ridge Commons WWTP
County: Guilford 2200 NC 68
Region: Winston-Salem
Oak Ridge NC 27310
Contact Person: Philip M Cooke Title: Phone: [phone]
Directions to Facility:
From Winston-Salem, take 1-40 East to Route 68 North. Proceed to the intersection of Route 68 and Route 150. The facility is
situated in the northwrst corner of the crossroads.
System Classifications: WW2, SI,
Primary ORC: Douglas Eugene Smith Certification: 1008007 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/23/2020 Entry Time 10:OOAM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Rebecca D Chandler
Reason for Inspection: Other
Permit Inspection Type: Reclaimed Water
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Exit Time: 12:30PM
Phone: [phone]
Inspection Type: Reconnaissance
Page 1 of 5

Permit: WQ0019755 Owner - Facility:JPC Utilities LLC
Inspection Date: 06/23/2020 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On June 23, 2020 WSRO staff conducted a site visit for review associated with the application for permit renewal.
Accompanying staff on the entire review were Mr. Doug Smith (SI-ORC) and Mr. Travis Carrel (Maintenance). Mr. Phillip
Cooke (Permittee) accompanied staff on records and WWTPs review only. There were no changes noted for the facility or on
adjacent neighboring properties since the last permit renewal.
A brief explanation of the two different system types covered under this one permit and their operations: There is a valve on
the collection sewer line prior to either WWTP (see attached site plan), which can divert 100% of the influent flow into either
the "Reclaimed WWTP" or into the "Standard Wastewater Irrigation WWTP". Onsite representatives indicated that the
standard wastewater irrigation system WWTP is not utilized routinely and is rarely used. Reportedly it is only used when
repairs or maintenance to the reclaimed WWTP warrant. The ORCs did have receipts from a recent solids pump out event
on the septic tank serving the standard wastewater irrigation WWTP. Therefore, it is obviously being used at times and it
appears to be maintained.
The normal daily operations are running wastewater through the reclaimed WWTP only. It was indicated that the only routine
flows entering the standard wastewater irrigation system are derived from the upset wastewater on the reclaimed WWTP. As
the system is being operated, the primary limiting daily flow design is the reclaimed system WWTP. There is the potential
for additional flows to be manually diverted to the standard wastewater irrigation WWTP should daily flows exceed 30,000
GPD. However, that volume of daily flow would have to be subtracted from the amount remaining if any upset flows have
contributed to the standard wastewater irrigation WWTP in each day. The site plan list the reclaimed irrigation zones as
"RC" and the standard wastewater irrigation zones as "UP".
Below is a summary of items noted during the review which require attention.
1. Some of the spray heads have been capped off in zones RC-03, RC-06, and UP-02 due to problematic issues during
irrigation events. An updated site map that shows the heads that are no longer being used in these zones (and any others
that have impacts) along with updated acreages for each impacted zone was requested to CO.
The current Permit Attachment B is not correct. There are three issues that need to be corrected.
A. There are no irrigation zones 8A and 8B present for the subject system as currently listed, only zone 8 with a max
annual loading rate of 22.21 inches/year. The acreage for 8A and 8B should be added together for the Net Acreage of zone 8
B. Irrigation zone 4 is actually two separate zones, 4A and 4B. The Attachment B should list zone 4A with max annual
loading of 22.21 inches/year & zone 4B with a max annual loading of 36.84 inches/year. The acreage for each of these
zones was requested to CO.
See the attached site map which has the zones A and B labeled. The "A" zones have a different type of spray head (i.e.
wobble spray heads) versus the impact sprinkler spray heads found in the "B" zones. Reportedly the wobble spray heads
load approx. 0.1 inches/hour less than the impact sprinkler spray heads, thus loading at a reduced annual loading rate when
compared to the impact sprinkler zones. There is an original design spec sheet onsite that list the exact loading rates for
each zone. Scan or take photo of this during next inspection to determine if new reporting is accurate based on gallons
dosed per minute.
C. The current Attachment B list "N" and 7.32 acres for the standard wastewater irrigation system. However, there are
seven independent irrigation zones present for the standard wastewater irrigation system. These irrigation zones are dosed
independently, one zone at a time. Requested the Attachment B to be corrected to match the system and allow for accurate
reporting. Also requested to CO that the acreages for each of these zones be obtained.
It should be noted that the ORCs have been incorrectly dividing irrigation loading to zones 4A/4B — 7A/7B in half and
Page 2 of 5

Permit: WQ0019755 Owner - Facility:JPC Utilities LLC
Inspection Date: 06/23/2020 Inspection Type : Reconnaissance Reason for Visit: Other
reporting the same loading to each zone on forms NDAR. This is not correct as the two zones have different hourly loading
rates. This is to be corrected for reporting moving forward. This will result in a period where the 12-month loading totals will
not be 100% accurate for these zones. BIMS needs to be updated accordingly and customized NDAR reporting forms need
to be made to address these corrections. WSRO to follow-up to ensure corrections are made and that they are accurately
tracked moving forward.
3. The maximum hourly loading rates listed in the current Permit Attachment B are too high and should be lowered.
Recommended to CO that the max hourly rates should be 0.30 inches/hour for the reclaimed irrigation zones and 0.25
inches/hour for the standard wastewater irrigation zones.
The ORCs have been reporting hourly loading rates much lower than these on NDAR reports, but the accuracy of those
reports is questionable. It should be noted that there have been issues with ponding and runoff noted in the past permit cycle
even with the lower reported loading rates.
4. The current Permit Attachment A list incorrect flow limits for both PPI-001 (Reclaimed) and PPI-002 (Wastewater).
According to onsite representatives and as indicated on the attached Engineer site plan, the reclaimed system should have
a max daily flow of 30,000 GPD in PPI-001 and the standard wastewater system should have a max daily flow of 6,000 GPD
in PPI-002. The two combined is believed to be where the 36,000 GPD came from in the current PPI-001. Representatives
indicated that the original Wastewater system flow of 12,094 GPD had to be reduced when the Reclaimed system was
installed due to construction of the Reclaimed storage lagoon eliminating some of the standard wastewater irrigation zones
where it is located, and also to accommodate the upset flows into the system. Requested to CO to correct the Permit
Attachment A to list PPI-001 with max flow of 30,000 GPD and PPI-002 with a max flow of 6,000 GPD.
5. The current system description in the permit is not correct. There is a tablet chlorinator and an effluent flow meter present
on the standard wastewater treatment system. These need to be added to the system description in the permit.
6. Currently there is no flow meter present on the upset line that distributes upset wastewater to the standard wastewater
system for disposal via the "UP" zones (i.e. upset aka standard wastewater irrigation zones). Therefore, the facility has not
been accurately tracking or reporting these additional daily flows to the standard wastewater system as required in PPI-002.
WSRO staff has requested meter installation over the past two years, but it has not been completed yet. Permittee
indicated that they are working on this addition. Requested to CO to add a schedule condition that request an upset flow
meter be installed within 90 days of permit issuance.
7. Groundwater monitoring is currently not required for the subject system. Review of self -monitoring data for the past 12
months suggests that the reclaimed water irrigation system is loading as much as 132.4 lbs. of PAN/acre/year. The
self -monitoring data reported for the standard wastewater irrigation system is not correct (see item 2.C. above) and therefore
the PAN loading could not be determined. There is some debate on what the maximum agronomic needs are for forestland.
This agronomic loading rate is near or slightly above some of the reported limits for PAN loading.
The stream that flows between the irrigation zones was reviewed during the site visit. There were no obvious signs of impact
(clear water, odorless, no algal growth, no fungal growth, fish observed). However, WSRO to review this surface water featur,
and agronomic loading over the next permit cycle to determine if groundwater and/or surface water sampling is needed.
Schedule a surface water sample event (up & downstream) at some point, with >48 hours no prior rainfall.
8. Reportedly Doug Smith samples effluent for the wastewater (upset) from the wet well just prior to irrigation. And Bradley
Flynt samples the reclaimed, but it was unknown where the sample is collected (Bradley not present). Follow-up during
inspection to determine if appropriate and representative.
9. The "Upset Lagoon" liner has a hole in it and needs repair. The facility is aware of this issue and reportedly has ordered
the repair work and is waiting on contractors to do the work. WSRO staff to conduct a follow up compliance inspection to
Page 3 of 5

Permit: WQ0019755 Owner - Facility:JPC Utilities LLC
Inspection Date: 06/23/2020 Inspection Type : Reconnaissance Reason for Visit: Other
ensure this is completed in a timely manner.
10. Follow-up review of suspect spray areas where erosion and ponding runoff have been present
11. During follow-up inspection ask how volume dosed to the wastewater irrigation (upset) is tracked? Is there a flow meter
on that system for irrigation dose?
*FOLLOW-UP INSPECTION NEEDED*
Page 4 of 5

Permit: WQ0019755 Owner - Facility:JPC Utilities LLC
Inspection Date: 06/23/2020 Inspection Type : Reconnaissance
Reason for Visit: Other
Type
Yes No NA NE
Activated Sludge Spray, HR
❑
Recycle/Reuse
❑
Single Family Spray, LR
❑
Single Family Drip
❑
Activated Sludge Drip, LR
❑
Infiltration System
❑
Activated Sludge Spray, LR
❑
Reuse (Quality)
Lagoon Spray, LR
Page 5 of 5

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ROBERT & DIANE 9.0 , \ I ° R REVIEW BOUNDARY
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' CAROLYN C. SVEDDELIUS - ^ . WETTED PERIMETER OF SPRAY FIELDS
UNDERWOOD \ / ' \ RYAN P. & JULIE McGIRR
I PIN: 7808559677 / / PIN: 7808640998 PIN: 7808640666 — — — — LIMITS OF SPRAY ZONES
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RECLAIMED WATER SPRINKLER
\p BEULAH L. YOST I �/ NOTES: SHEET
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North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
General Information WASTEWATER IRRIGATION
Facility Name: Oak Ridge Commons, Conjunctive Reclaimed -WWI
Permit No.: W00019755
Owner: JPC Utilities LLC
ORC Name:Voug Smith & Bradley Flynt WWTP
Backup OR Jarrell & Dou
Other Contact-Ahilip Coo Mana er v'f
Location (address, gps or directions): Hwy 66 . v981 R
L Haw River Rd., R Linville Rd., L Oak Ridge Rd.(150), on Left.
County: Guilford
Issuance Date: December 4 2015
Expiration Date: November 30 2020
Telephone No.: Doug R
336 215 0949 radleY 336 433-7262
Telephone No.: Randall- 919-210-2500
Telephone No.: 336-669 2724
rill Ch Rd., L Pinev Grove Rd.. Continue Goodwill Ch Rd.,
Reason for Inspection
❑ ROUTINE ❑ FOLLOW-UP ❑ COMPLAINT ® PERMITTING ❑ Other: Renewal
(attach additional pages as necessary)
Discuss general items on attached pag
GY{�I r�u dS CeMMeni S dp Jr_
Walk9ver reclaimed WWTP & walkover the wastewater WWTP, review each for permit match. wl4 i�t
;Ask about effluent sampling locations for reclaimed treatment system (fecal, TRC, others). g!
VA"sk about effluent sampling locations for wastewater treatment system (fecal, TRC, others).
* Are they appropriate? 1,4 ut%i W,,- 4 CLSe .
v'Keview, surface water feature that flows through irrigation zones (up and downstream of irrigation).
- Is samplin needed? Are there good up and downstream sample points?�/
��' 'b �r . �rw. �ao►�s c�aiesa, 1�10 q ,W5T eS.
✓ 'i �IA de,, 14 �dfprs>r+
view the stormwater outlets where runoff enters the irrigation zones. /
.t
iw. add'.
j 0 4 p9mew, ,
VII(eview the potentialrunoffpoints where they exit the irrigation zones.
N'D S13gj !( �4mx.
Is a follow-up inspection necessary
Primary Inspector: P. Mitchell
Date of Inspection: June 23, 2020
` SNSfttc� S`I orC tI w/, of IN 4of f Cc� n�c/nS.
NDA K ��d r l+ d zar�¢s a u,v4 �Ye r
fYes ❑ No dal ren�o�rea • J
Secondary Inspector: R. Chandler 8: �..,�
Entry Time: 10:00 am Exit Time:

I
Oak Ridge Commons Review Items
ti jl. ORC & Backup ORC designated now? Chad is still listed Primary for SLgqLion in
RIMS. data ent error?���,
1� The current permit list max Reclaimed flow of 36,000 GPD, but the site map list
the WWTF as a 30,000 GPD treatment plant... Why the difference? Don't know?
. The permit description does not describe disinfection system for the standard
wastewater treatment system, is one present? Only on the package lant for
reclaimed. � f/ � � � ����►� .
'. Effluent storage (adequate wet weather storage — 15+ days for both reclamin &
wstwtr, upset storage 5+ days for reclaim); Looking at NDAR freeboard data
compared to onsite observations, do they operate with adequate storage for
potential extended wet weather events? Any issues with freeboard exceedance
during most recent permit cycle? 666
If daily flows are >30,000 GPD, should flow being manually split at times to
ensure the reclaimed system is not overloaded? Thus allowing the 12 095 GPD
standard system to cover what it is designed to accommodate. Ask onsite.
VS. Any issues with storage (wet weather or upset related?) and/or application during.
rain to prevent storage issues? None reported
-------------------
7. There has been confusion in the past with reporting and tracking the two systems
due to two types of systems being included in one permit. Has this been
corrected? Better, but a oeaa,. tg not rnpw At'.ta&-,-,ent B & loading rates.
Any current issues with system, effluent limits, loading limits, etc.? None
reported.
,- >9. There was some question as to irrigation operations and the Attachment B being
inaccurate last permitting. appears- it is stili not accurate compared to system.,
diagram and A., B.
I," Reclaimed zones 5 — 8 have subzones A & B. The annual loading rates for A and'
B differ (22"/yr vs 36"/yr); These should be tracked and reported independently,
correct? Where are they on the map (see review map for Long-Lat locations?
Same for the standard wastewater zones, track and report each zones loading
independently. Address with CO. f1--_

' 1I.Why are NDARs reporting the limit as 31.95".yr. for some of the reclaimed
zones? A is 22" and B is 36", and again they should be reported separately.
Address with new corrected Att. B.
y yDO.
.The reclaimed water system is loading as/much as 132.4 lbs. of PAN/acre/year
based upon recent NDMR and NDAR data submitted (reviewed in BIMS). This is
at or greater th rc om. limit for forested land. Is groundwater monitoring
necessary? Discuss orisite Would the stream on the site be representative for
sampling?
13. The hourly irrigation rate for both the reclaimed (07 /hr) and the standard
�� wastewater (0.5"/hr) seem too high. Any issues with ponding and runoff? The
annual rates seem more appropriate. Review topsoil with push probe sam ler.
PO vA 14. When did they get the flow meter on reclaimed corrected? Was that for influent or
1/ w effluent dosed? Effluent meter was one with issues. Is there an influent flow
�f / meter for the reclaimed & non -reclaimed and one for the upset flows to the
0� storage lagoon/upset lagoon.
06. There are multiple offsite sewage lift stations connected to the collection system
serving this system. Is this still a deemed collection system? Is anyone reviewing
N� °�,440the lift stations and high priority lines? No. Discuss while onsite.
,16. Which zones had the erosion issues? Has this area with erosion and runoff been
properly addressed? RC-03 & UP-3. apme:- of the lower heads have been
removed in lower area of RC-03. How many removed how much acreage and
AE5 impacts to
.Are the reclaimed and standard wastewater operated independently at times or
��'� • ►" I during upsets? Is this tracked and reported accurately? Ask onsite.
on g p
. There should be three influent flow meters (Influent to Reclaimed, Influent to
Wastewater, and Upset influent into Upset Lagoon. All three should be tracked
0 onsite for reporting purposes. Is there a flow meter on the influent to the standard
wastewater treatment system and on "upset flows" diverted to the effluent
aM �f storage, in order to report accurate daily flows into the standard wastewater
system? If not they are needed.
\A �,9�Ask onsite about frequency of sludge solidi pumping out.
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