WQ0002056_Staff Report_20200109

Dow& n Envelope ID: 23D7612F-0384-4069-B2F3-5E6D1 F02D111
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.: WQ0002056
Attn: Ashley Kabat Facility name: Patriot Place MHP WWTF
From: Helen Perez
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: 07/19/2019
b. Site visit conducted by: Helen Perez
c. Inspection report attached? ❑ Yes or ® No
e. Person contacted: Michael Smith and their contact information: [phone]
Driving directions: 145 Hubert Blvd
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: (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:
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DocuSign Envelope ID: 23D7612F-0384-4069-B2F3-5E6D1 F02D111
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: Mikel Seely Certificate #: 991130 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:
A 90,000 gallon per da, (�GPD) wastewater treatment and irrigation facility consisting of two (2) 3.6 acre lagoons
in series; one (1) 2.0 acre storage lagoon; a tablet chlorination system; and irrigation pump station with one (1)
310- alg lon per minute (GPM) pump and one (1) 200 GPM pump; 18.6 acres of spra�gation area; and all
associated piping, valves, and appurtenances.
Proposed flow: N/A
Current permitted flow: 90,000 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.)
Change of ownership in the spring of 2018 from Gatlin -Ramsey to Patriot Place. ORC/BORC needs to be
updated. There was not a valid SI BORC at the time of inspection in July, 2019.
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.
es or ®No
g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Y
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? El Yes or ® No
If yes, attach a map showing conflict areas.
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DocuSign Envelope ID: 23D7612F-0384-4069-B2F3-5E6D1 F02D111
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ® No
If no, please explain: It should list a tablet chlorination system, not a liquid chlorination system.
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 ex and table if necessary):
Monitoring Well
Latitude
Longitude
O / //
O , 11
O / //
O , 11
O / //
O / //
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: Duringthpection review in July 2019, it was
discovered that the GW-59 reports had not been submitted since March 2017, though the monitoring wells were
sampled during that time period. All the reports were submitted in September of 2019.
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: N/A
17. Pretreatment Program (POTWs only): N/A
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DocuSign Envelope ID: 23D7612F-0384-4069-B2F3-5E6D1 F02D111
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
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
pH frequency reduction Change pH frequency from 5 x week to weekly (See Section V below)
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: )
/—DocuSigned by:
6. Signature of report preparer:
Signature of regional supervisor:
Date: 1/10/2020
14AC7DC434...
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DocuSign Envelope ID: 23D7612F-0384-4069-B2F3-5E6D1 F02D1 11
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This staff report has been prepared for the renewal of the Patriot Place MHP WWTF, permit WQ0002056. This
is a lagoon/spray irrigation system. It is permitted for 90,000 GPD but only averages approximately 16,000-
20,000 GPD. In 2018, the facility irrigated on an average of 4 days per month and less in 2019. In the current
permit, pH monitoring is required 5 x week with no limit. Because this is a lagoon type system requiring weekly
minimum ORC visitation, I recommend pH be reduced to weekly instead of 5 x week. The Permittee did not
request this reduction in the renewal application, but there was interest and a discussion in monitoring reduction
of pH during the inspection with the ORC, Mikel Seely and the MHP Manager, Michael Smith.
FORM: WQROSSR 04-14 Page 5 of 5