WQ0030775_Staff Report_20210122

Division of Water Resources
State of North Carolina
Department of Environmental Quality
Division of Water Resources
WATER QUALITY REGIONAL OPERATIONS SECTION
NON -DISCHARGE APPLICATION REVIEW REQUEST FORM
November 12, 2020
To: WiRO-WQROS: Morella Sanchez -King / Tom Tharrington
From: Lauren Plummer, Water Quality Permitting Section - Non -Discharge Branch
Permit Number: WQ0030775
Applicant: Aqua North Carolina, Inc.
Owner Type: Organization
Facility Name: Avendale WWTP
Signature Authority: Michael A. Melton
Address: 202 MacKenan Ct., Cary, NC 27511
Fee Category: Non -Discharge Major
Permit Type: High -Rate Infiltration
Comments/Other Information: [e-mail]; [e-mail]
Project Type: Renewal
Owner in BIMS? Yes
Facility in BIMS? Yes
Title: Engineering Manager
County: Pender
Fee Amount: $0 - Renewal
Attached, you will find all information submitted in support of the above -referenced application for your review, comment,
and/or action. Within 45 calendar days, please take the following actions:
® Return this form completed. ® Return a completed staff report.
❑ Attach an Attachment B for Certification. ❑ Issue an Attachment B Certification.
When you receive this request form, please write your name and dates in the spaces below, make a copy of this sheet, and
return it to the appropriate Central Office Water Quality Permitting Section contact person listed above.
RO-WQROS Reviewer:
DocuSigned by:
E1 D9294C4D3746E...
Date:
1/22/2021
FORM: WQROSNDARR 09-15 Page 1 of 1

DocuSign Envelope ID: 817452D8-DF95-4179-B2B7-0019A7B3DC9C
,s 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.: WQ0030775
Attn: Lauren Plummer Facility name: Avendale WWTF
From: Dean Hunkele
Wilmington Regional Office
Note: This form has been adapted from the non -discharge facilily 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: 1-15-2021
b. Site visit conducted by: Dean Hunkele with Tyler Benson & John Perry
c. Inspection report attached? ❑ Yes or ® No In BIMS and on Laserfiche
d. Person contacted: Joel Mingus and their contact information: 910 270 - 1412 ext.
e. Driving directions: Site is accessed via asphalt path off an unnamed dead end road to the immediate right from
the 2nd development entrance of Avendale Drive off NC Highway
2. Locations Point(s):
Latitude: 34.23.3 3
Latitude:
Longitude: 77.46.09
Longitude:
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:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 4

DocuSign Envelope ID: 817452D8-DF95-4179-B2B7-0019A7B3DC9C
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
ORC: Kirklyn Fields Certificate #: 996782 WW-3 Backup ORC: Michael Cowell Certificate 9:1007662 WW-2
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: System description in 2016 staff report and permit remain accurate.
Proposed flow: 72,000 gpd
Current permitted flow: 72,000 gpd
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.) See below
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: Ponding observed on about 15-20% of infiltration bed #2 along WWTF site proper,
supposedly same area repaired with new soil/sand added in same area during 2018 when same issue occurred.
This wetter area can be observed on aerial photo of site.
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: The developer changed his development plans from townhomes to single-family residences
adjacent to 5-DayUpset Pond and it appears the property lines have encroached into the required buffer setback.
It appears that the residential privacy fences are on their property line which are only about 15 feet off the top of
the pond's synthetic liner on top of its berm. Thus, its believed that the setback is now violated whether its 50 or
100 feet. Homes on the other side of the pond were estimated at 40-50 off same liner location, both would need
to be verified by pdated survey from Aqua.
5. Is the residuals management plan adequate? ® Yes or ❑ No Listed as source on WQ0034806
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:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ® Yes or ❑ No
If yes, attach a map showing conflict areas. See Item 4 above
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DocuSign Envelope ID: 817452D8-DF95-4179-B2B7-0019A7B3DC9C
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 I II
C I II
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: As flows and food mass have increased, the facility
has been gradually reducing the use of adding a carbon source. Facilijy could probably cease use if only
operating a single treatment train, but staff indicated flows had reached a point whereby 2nd train is becoming
needed. The facility hasn't had any effluent violations since 2-2017. Aqua indicated that the infiltration
dewatering`ystem has just recently started having a discharge on occasion.
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: Unit needs to inquire if Aqua ever plans to install the approved 5-dgy pond lowering system
approved in 2013. It should be removed if they are not going to, the facility currently uses a small pump under
manual control versus the gravity connection it originally used aeneratina the need for the approved lowering
system.
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:
17. Pretreatment Program (POTWs only):
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: The setback issue on the 5-Dgy pond may need to be resolved prior to issuance, but that's a
Unit decision.
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
FORM: WQROSSR 04-14 Page 3 of 4

DocuSign Envelope ID: 817452D8-DF95-4179-B2B7-0019A7B3DC9C
New Survey
Possible setback issue to 5-Day pond
5-Day Pond Lowering
Inquire if they intend to ever install the approved system from 2013 issuance. If
not remove it from description.
Public Access to
Currently the basins have no fencing around them nor is the overall WWTF site
Infiltration Basins
secured by such. The treatment works and the 5-day pond are separately fenced
on the site.
Doesn't the meter require a recording mechanism to either chart flow or collect
data periodically to allow charting over any period of time? The facility had an
Effluent Flow Meter
ultrasonic flow meter & chart back in 2015, but have apparently switched to a
bubbler meter and no chart was present. Need to confirm with Aqua that
current unit can at least collect flow data so it can be charted.
Does it not require continuous recording of the values and report the highest for
Turbidity Meter
each day? Unknown if current unit has ability for data logging or charting but
none observed. Values being reported as only the instantaneous value on the
screen when operator observes it.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
Infiltration sites operate based on hydraulic loading only thus nutrient uptake is
Condition IV. 10 Soils
not needed. Consequently, any vegetation allowed on beds/basins should be
Report
kept minimal and not necessarily overly healthy. Thus, is a soil analysis needed
if soil amendments shouldn't be needed nor required for any vegetation present?
Condition II. 5
Remove reference to green area or repair area since regulation is now gone,
correct?
Condition III. 3
Related to Condition IV. 10; vegetation isn't desired on infiltration beds/basins
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
May need a compliance schedule to address the public access to site or at least
the infiltration beds.
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
❑ DocuSigned by: Deny (Please state reasons: )
6. Signature of report preparers
Signature of regional supervisor:
Date: January 22, 2021 DocuSigned by:
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 4 of 4