WQ0034367_Staff Report_20191029

Dow& n EnveloC1D:E0CD4A1 D-F3BD-463F-B7D0-4763343534BB
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.: WQ0034367
Attn: Ashley Kabat Facility name: Northwest Regional WRF
From: Bryan Lievre
Wilmington Regional Office
Note: This form has been adapted from the non -discharge fg acili , 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: 10/10/2019
b. Site visit conducted by: Bryan Lievre
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Mark Young and their contact information: (910) 937 - 7572 ext.
e. Driving directions: 189 Mills Field Rd., Richlands, NC 28574. From Wilmington: US Hwy 17N to NC Hwy
258N, right on NW Bridge Rd., left on Gum Branch Rd., left on Mills Field Rd.
11. PROPOSED FACILITIES: NEW APPLICATIONS N/A
2. Are the tfeatmeat f4eilities
for- the type
disposal
system? E] Yes or- E] No
fiew adequate
of
waste a -Rd
3. Afe depth to
table,
the
D Yes E] No
site eendifiens (soils,
wa4ef ete) eeasistei4
with
stibmitted r-epefts?
ifno, please explaiw:
4. Do the
the
lifies,
ells, ete.)? [Z-] Yes E] No
plans and site Fnap r-epFesen4
aetual site (pr-epeft-y
if no, please explain.: —
5. is the -esid
ao,,.
n Yes n No
n N/A
proposed all management
1€
plan
no, please explain:
FORM: WQROSSR 04-14 Pagel of 5

DocuSign Envelope ID: EOCD4A1D-F3BD-463F-B7DO-4763343534BB
e
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Mark Young Certificate #: 1001105 Backup ORC: Michael Lutz Certificate #:1005688
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: Correct as currently permitted
Proposed flow: 2 MGD treatment
Current permitted flow: 2 MGD treatment
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

DocuSign Envelope ID: EOCD4A1D-F3BD-463F-B7DO-4763343534BB
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 l 11
O I //
O l lI
O I II
O l lI
O I 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: Reviewed records from 1/2017 through 8/2019.
System has been unable to obtain samples from PPI 002 — Groundwater Lowering System Effluent due to fact
that water is onlv present within the system during periods when levels are elevated in nearbv streams (e.a. New
River and Cowhorn Swam
Although random daily exceedances have occurred for fecal coliform (e.g. 6/4/2019, 2/2019, 11/26/2018, etc.),
the system staff have kept the regional office aware of these events, have made appropriate changes (e.g. sending
effluent back to 5-day ponds for re -treatment instead of infiltration basins, etc.) and have not exceeded the
monthly average.
BeLyinnine the first week of Mav 2016 and extendina into 2017. the plant accepted leachate from the Onslow
County Landfill. Although a study was apparently conducted to investigate the facilities ability to accept the
waste, the facility eventually determined that it was not able to properly treat the leachate. NOVs were issued
3/10/17, 3/23/17, 8/8/17 and 9/5/17 for exceedances of numerous daily parameters from samplin events
vents
conducted from 5/16 through 5/17. Corrective actions were eventually undertaken to clean out the facility and
the leachate is no longer sent to the facility for treatment.
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: As previously documented by others, the infiltration basins were
constructed into limestone. The concern is that partially treated wastewater would enter the nearby adjacent
streams (e.g. New River and Cowhorn Swamp) through limestone cavities. A review of past samplingresults
esults
from monitoring wells MW-1 through MW-4 was performed. Concentrations of Ammonia, Nitrate and TDS
seem to have remained the same since 7/l/2015. Levels of Phosphate may be increasing in monitoring
MW-1, MW-2 and MW-3. However, the current permit does not have limits for phosphorous and the possible
increases could also be attributed to naturally occurring presence of phosphorous. Further sampling and review is
recommended.
17. Pretreatment Program (POTWs only): N/A
FORM: WQROSSR 04-14 Page 3 of 5

DocuSign Envelope ID: EOCD4A1D-F3BD-463F-B7DO-4763343534BB
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain: see #16 above
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
System staff have verbally requested removal of sampling for Groundwater
Lowering System Effluent. Since water is only present within this system when
levels in New River and Cowhorn Swamp are unusually high, this system does
not seem to be associated with draining the naturally occurring groundwater
Attachment A, PPI 002
table, as proposed. WiRO does not oppose this request as long as additional
monitoring wells would be required in the event additional infiltration basins
are installed or if the system chooses to activate surface spray field(s).
Conversely, WiRO staff have informed the system staff that sampling of the
Groundwater Lowering System is not required if no flow conditions are present
(therefore the system already does not have to sample this system).
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
❑ D uD�Ete9 seed reasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date: 10/28/2019
DocuSigned by:
E3ABA14AC7DC434...
FORM: WQROSSR 04-14 Page 4 of 5

DocuSign Envelope ID: EOCD4A1D-F3BD-463F-B7DO-4763343534BB
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The facility is currently operating in the manual mode due to damage caused by flooding from Hurricane Florence and a
subsequent cyber-attack. The entire Solids Filtration/Chemical Feed Building was being bypassed on the date of the site
inspection, performed on 10/10/2019. The building includes the two disc filters, one membrane filter skid (although up to
four skids were permitted but the remainder never installed), Trojan UV disinfection, backwash equipment, as well as
pumps and chemical feeds for sodium biosulfate and sodium hydroxide. A new temporary disc filter capable of handling
600,000 GPD was placed alongside the building to handle the flow and disinfection was being performed with an
injection of sodium hypochlorite.
One of the two sequencing batch reactors is being used for flow equalization and one of the two sludge digesters is off-
line due to low flow conditions.
FORM: WQROSSR 04-14 Page 5 of 5