WQ0004270_Staff Report_20190905

State of North Carolina
Nr 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.: WQ0004270
Facility name: A. B. Carter — Gastonia WWTF
County: Gaston
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: 9-3-2019
b. Site visit conducted by: Maria Schutte & Ori Tuvia
c. Inspection report attached? ❑ Yes or ® No BIMS is to be updated..
d. Person contacted: Lee Pennin tgton and their contact information: [phone] or [phone].
e. Driving directions: From the MRO travel to I-77 S; to 1-485 exit toward Pineville; I-85 S; take exit 22 toward
Cramerton and turn left onto S. Main St. Continue straight road names change to: Redbud Dr., Hoffman Rd.
& Robinwood Rd.; left onto Union Rd, Right onto Robinson Rd, right onto Little Mountain Rd., left onto
Forbes Rd: right onto US-321 N: RiLrht onto Davis Heiehts Dr. Facilitv address is: 4801 York Hwv. Gastonia
28052.
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
Classification:
River Basin and Sub -basin 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:
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:
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: Robert L. Pennington Certificate #: SI-987583 Backup ORC: Charles E. Parker Certificate #: SI-19607
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: The facility has two treatment systems. The industrial process water goes
their pre-treatment plant prior to Two Rivers Utilities. The site domestic goes to this small system. Flow is
estimated based on standard design flow and # of employees and is significantly reduced from original permitted
volume of 5000gpd. Per Mr. Pennington, currently approx. 60*25gpd=1500gpd, but they wish to keep the
5000gpd flow rate.
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: Both this domestic system and their pre-treatment systems are adequately maintained for
their age, but show signs of rust.
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: MRO did not inquire about site septic tanks. They should be assessed along with the plant
and pumped as needed.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No ❑ N/A
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.
FORM: WQROSSR 04-14 Page 2 of 5

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: This is an older permit with established well system. Current MRO staff can only assume
wells were properly constructed. There are 3 active wells related to this permit. A background, one near the
fields and one near the lagoon. The background well appears to be on a review boundary and the other two wells
inside the review boundary.
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 / 11
O l 11
O / 11
O / //
O I it
O / I/
O I it
O / I/
O I it
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.
Current permit already has reduced monitoring. MRO is okay with present monitoring.
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: MRO staff discussed proper chlorination tablets and field certification for, plus calibration
of their residuals chlorine meter; and, emailed state lab contact information for assistance.
® 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: Per comments in previous inspection, a lagoon water level gauge was installed & pH is
currently analyzed on -site by a contractor to meet 15min required hold time.
Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
If yes, please explain:
15. Possible toxic impacts to surface waters: "Unknown, ND permit should not result in discharges to surface
waters. "
16. Pretreatment Program (POTWs only):
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
Updated Map ? See comment under section V.
FORM: WQROSSR 04-14 Page 3 of 5

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
Note requirement for
wastewater treatment grade
chlorine tablets
Permittee was unaware as their permit was not specific.
Note review of Spill and
O&M plans, with updates
as needed.
Just as a reminder to keep them up to date for changing staff, etc.
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: 9.5.19
Maria Schutte September 5th, 2019
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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61 FB69A2D84A3...
Their storm water permit was inadvertently included in the application package. The MRO does not need another copy of
their existing ND permit, but this item is noted as it is a requirement for renewal packages.
The existing man is a decent site man: however. the 3 current MWs are lost in the sea of previous inactive MWs. The
current MW location points in BIMS were updated earlier this year from file data and should be sufficient if CO
permitting staff wish to generate a more technologically, current satellite image for this permit; otherwise, an additional
information reauest is warranted. Mr. Pennineton stated. he could submit another map with those wells circled to stand
out.
FORM: WQROSSR 04-14 Page 4 of 5

BIMS lists Ernest Sumner as a contact person and signature authority. MRO staff does not know that person and meets
with Lee Pennington, the Environmental and Finishing Manger and SI-ORC, who reports to Al Abedi, Vice President.
FORM: WQROSSR 04-14 Page 5 of 5