WQ0042882_Staff Report_20211216

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: [e-mail]
From: [e-mail]
Mooresville Regional Office
Application No.: WQ0042882
Facility name: Abilene Rd. - Downey SFR
County: Cabarrus
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: 12/09/2021.
b. Site visit conducted by: Maria Schutte.
c. Inspection report attached? ❑ Yes or ® No, NA — new facility.
d. Person contacted: Trevor Hackney (AWT) and their contact information: [e-mail].
Cell Phone: [phone].
e. Driving directions: From MRO travel NC3 north to Odell School Rd; turn left onto Hwy 73; Right onto Central
St. (short cut to) Right onto Hwy 29/601; Left to stay on Hwy 601 N; Left onto Cold Springs Road; Left onto
Abilene Rd. Sit is on the right past A.T. Allen Elementary School.
NOTE: This property is not assigned a street # yet — the permittee is working on purchase of a portion
of this property which will be between the sellers Home/WWT system and the irrigation field that serves
the sellers home. An easement and property line setback waiver will be part of this property and permit.
Each owner will need a property line setback waiver for the irrigation fields encroachment.
2. Discharge Point(s): NA — this is a non -discharge permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: SFR — not applicable. (Please attach completed rating sheet to be attached to issued
permit)
Proposed flow: 3 Bedroom home = 360 GPM.
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ® Yes or No
If no, explain:
FORM: WQROSSR 04-14 Page 1 of 5

3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ® Yes ❑ No ❑ N/A
If no, please explain: The irrigation site is wooded and large trees are proposed to remain. Some underbrush and
smaller trees will be removed. There is a restrictive clay soils layer across the site at about 12 — 15 inches. Per
Soil Scientist's evaluation only depressions in isolated areas of the application field will require additional soils
(build-up) to meet SHWT separation requirement, as the examination showed > 12 inches of separation from
SHWT; however, during the site visit SHWT was encountered at approximately 10 - 11 inches in one borehole
and that area will require additional fill.
The Downey's intend to purchase a portion of this property located between the seller's proposed
home/WWT system and the seller's irrigation field. Property line setback waivers for both (WQ0042881
and W00042882) irrigation fields and an easement for the plumbing to the W00042881 field are proposed.
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ® Yes ❑ No ❑ N/A
If no, please explain: Yes — as determined from flagging around the site: but, it is uncertain if the flagging was
placed by a licensed surveyor. Contractor is expected to ensure proposed distances from property lines, etc. are
accurate at the time of installation.
5. Is the proposed residuals management plan adequate? ® Yes ❑ No ❑ N/A
If no, please explain: SFR — will use typical septic tank cleanout guidelines.
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. The current owner (Carter) is parceling the property with plans
to sell to the Downey's. Site plans show: An easement on this proposed parcel to allow for plumbing to the
Carter property (WQ0042881) irrigation field; And, reduced property line setbacks for both proposed drip fields.
The contractor (AWT) determined the arrangement of the drip fields being adjacent as the best solution for both
facilities and area soils. There is a path between both fields that is not part of either drip field. Although the path
is a low lying area between the fields, the slope of each irrigation site appears to be away from this path (former
access to farm land at North property line).
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 if operated as a non -discharge system and the owner maintains for
appropriate domestic use.
11. Pretreatment Program (POTWs only): n/a
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS N/A
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes No N/A
WWTP ORC: SI 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.)
FORM: WQROSSR 04-14 Page 2 of 5

3. Are the site conditions (e.g., soils, topography, depth to water table, etc.) maintained appropriately and adequately
assimilating the waste? n Yes or n 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:
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? n Yes or n No
If yes, please explain:
14. Check all that apply:
❑ No compliance issues n Current enforcement action(s) n 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? n Yes n No n N/A
If no, please explain:
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
nYes nNonN/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: Potential issue anytime soil is added to meet vertical SHWT separation. Rainy weather in
recent years created extreme conditions for some SFR permits in this region and there was little the owner(s) or
MRO staff could do when the site condition was too wet for pumper truck access. And, complications w/property
easements and setback waivers when property(s) are sold. Division should consider language that will address a
situation where someone refuses to sign a waiver for an existing system.
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
The proposed O&M
schedule is included
with the blue prints on
page WW-10
The O&M plan would be best as a single page document, for the owner to keep
with the permit. This comment is at CO discretion if deemed necessary. In
addition, item 1. sounds as though the homeowner may maintain the system
themselves, but item 5. sounds as though they are required to have a certified
operator by the manufacturer. Reference to a contract with a certified operator
is also mentioned on page 184 of the Laser Fiche document.
Since the Operator Certification Group has not designated that a SFR system
requires a Certified Operator, MRO staff feels it should be made clear to the
Owner (via the cover letter for Add Info and the Final permit), that currently
DEQ does NOT require the permittee designate a certified operator.
Narrative Description of
Surface Drip System (see
Laser Fiche Application
Laser Fiche
2997 pgs. 66 — 68)
WQ00appropriate.
MRO found this summary document in another permit WQ0042997 quite
helpful and it was not present in this permit application. Is this a required
document? MRO staff is currently working on both WQ0042881 and
WQ0042882 staff reports and would request the Summary Document if
CO staff has already
requested additional
information.
Awaiting response.
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
Will leave to CO
Permit proposed for construction only until property subdivision is finalized,
ownership change form and notarized setback waivers are received.
Is more restrictive fencing
warranted, other than
typical 2-strand wire fence?
The path between the adjacent irrigation sites is believed to have been a farmer
access to fields at the North; however, the path through the Carter SFR
proposed irrigation site is thought to be from ATV use; and, there is an
elementary school across the street from both proposed irrigation sites. MRO
staff will leave it to CO staff to determine if a more restrictive fence can be
recommended.
FORM: WQROSSR 04-14
Page 4 of 5

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
n Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date: 12/16/2021
Maria Schutte — December 16th, 2021
D.c.SS'gned by
H
A14CC681AF27425...
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
None.
FORM: WQROSSR 04-14 Page 5 of 5