WQ0000267_Staff Report_20220425

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Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0000267
Attn: Lauren Plummer
From: Randy Sipe
Washington Regional Office
Facility name: Gates County WWTF
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: 4/19/22
b. Site visit conducted by: R. Sipe & S. Toppen
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Tiffany Finn and their contact information: (252) 267 - 3861 ext.
e. Driving directions: no change since last permit was issued
2. Discharge Point(s): N/A non -discharge system
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A non -discharge system.
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ['Yes ® No ❑ N/A
ORC: Tiffany Finn Certificate #: SI/1011384 (Invalid) Backup ORC: Timothy Hedgepeth Certificate #: SI/995918
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: The county continues to only operate the "old" 15,000 GPD WWTP which has a spray field
that cannot adequately assimilate effluent an inoperable chlorination system; and an inoperable influent flow
meter. Although a "new" 40,000 GPD SBR WWTP was constructed and certified in 2019, the county has yet to
operate this system for reasons that WaRO staff do not fully understand. Because the county continues to only
operate the "old" system, there also continues to be a moratorium on additional flow on W00000267.
Description of existing facilities: The "old" WWTP is a facultative lagoon with a 7 acre spray field. The recently
constructed "new" WWTP is an SBR system with a storage lagoon and 25.7 acre spray field.
Proposed flow: 15,000 GPD — "old" lagoon WWTP 40,000 GPD — 'new" SBR WWTP
Current permitted flow: 15,000 GPD — "old" lagoon WWTP 40,000 GPD — 'new" SBR WWTP
FORM: WQROSSR 04-14 Page 1 of 4

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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.) This facility is still classified in BIMS as only SI, even though the "new" WWTP has a SBR system with
advanced treatment and nutrient reduction. WaRO believes this WWTP should be classified as at least a WW2
and require the corresponding ORC classification.
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: As has been known for some time, the spray field at the "old" WWTP cannot adequately
assimilate the effluent sprayed onto it. It is for this reason that the "new" WWTP was permitted and constructed.
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: See comments under Items II.2 and II.3 above.
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
o
, ,,
0
I
„
o
,
0
1
o
I ,,
0
1
II
o
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0
1
II
o
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1
II
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: Most of the violations in BIMS are related to missing
TRC results due to the inoperable chlorination system and also some reporting issues. The "old" WWTP appears
to essentially be meeting the other effluent limits.
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.) An
NOVINOI will be issued as a result of the 4/19/22 inspection to address the conditions observed at the spray field,
lack of an influent flow meter, and damaged fencing/lack of public access control at the "old" WWTP.
FORM: WQROSSR 04-14
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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? The proposed modification is to address the
issue of no chlorination at the "old" WWTP.
Have all compliance dateslconditions 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: WaRO does not believe any of the ongoing issues with this facility will affect the renewal
and modification of this permit.
16. Possible toxic impacts to surface waters: N/A non -discharge system.
17. Pretreatment Program (POTWs only): N/A non -discharge system.
M. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain: WaRO has no issues with the renewal and modification of this permit.
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
Influent Pump Station
The influent pump station included in the facility description is not associated
with any collection permit. During the latest inspection it became apparent that
the ORC and permittee were not aware of the requirements for inspection,
maintenance, and operation of the pump station. WaRO requests that a
condition be included in the permit that the pump station be operated per the
requirements of 2T .0403.
FORM: WQROSSR 04-14
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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:' 4v S4`
Signature of regional supervisor: Zava T. 1.d
Date: 4/28/2022
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORI`I: WQROSSR 04-14 Page 4 of 4