WQ0042577_Staff Report_20210709

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

To: NPDES Unit Non-Discharge Unit Application No.: WQ0042577
Attn: Poorva Mokashi, Water Quality Permitting Section Non-Discharge Unit
Facility name: 2206 Shaw Rd. SFR

From: J. Chris Smith
Raleigh 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.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 06/17/2021
b. Site visit conducted by: Chris Smith
c. Inspection report attached? Yes or No
d. Person contacted: Evan T. Morgan: [phone]
e. Driving directions: 2206 Shaw Rd. Durham, NC 27704
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: Surface Drip Irrigation with TS-II Pretreatment (Please attach completed rating sheet to
be attached to issued permit)
Proposed flow: 360 gpd
Current permitted flow: N/A
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 Page 1 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: None
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: 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:
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.)
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:
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:

FORM: WQROSSR 04-14 Page 2 of 5

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
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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:
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:
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: Site is currently unsuitable for waste disposal. See Additional Regional Staff Review Items
below.
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:

FORM: WQROSSR 04-14 Page 4 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
NCDEQ does not currently have specific guidelines addressing site characteristics for fill systems. If the WQ permit is
issued before the fill project takes place the WQ permit is being issued for an area that is currently unsuitable for
wastewater disposal.
This office recommends that this permit be issued for construction only and that an additional soils report certifying the
fill system be required once site improvements have been completed.
The additional soils report should address the following:
Soil compaction being adequate and stable for the proposed irrigation
Saturated hydraulic conductivity of the least permeable layer
Soil fertility report for fill material and amendments (if any) that were added to fill material
Verification of fill suitability and depth of fill (and to the SHWT) across the field
This office recommends that only after review of the additional soils report by Division staff should the permit be reissued
for operation.
The proposed disposal field is in a wooded area. The following modifications to the provided Fill Application Plan are
also recommended:

Clear and grub site by hand in such a manner as to minimize native soil loss and compaction.
ace and
least five (5) feet beyond the proposed wetted area on all sides.
The fill material should extend at least five (5) feet beyond the wetted area and blend into the natural contours of
the area.
Remove vegetation less than 8 inches in diameter from the disposal area.
Avoid placing fill material under the drip line of any trees that are to be left within the disposal area to prevent tree
death (an arborist can provide more guidance on tree protection). The application area Fill Plan will need to be
modified to compensate for any area removed from the proposed application area for tree protection.
FORM: WQROSSR 04-14 Page 5 of 5