HomeMy WebLinkAboutWQ0019782_Staff Report_20200511DocuSign Envelope ID: ABA6B73A-7FDD-4879-8985-981D52780E7B
Q�
May 11, 2020
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: DWR Central Office — WQ, Non -Discharge Unit Application No.: W00019782
Attn: Poonam Giri Facility name: YMCA Camp Weaver Wastewater Irrigation
From: Patrick Mitchell
Winston-Salem Regional Office
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.
L GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: May 7, 2020
b. Site visit conducted by: P Mitchell & C. Caudle
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Jamie Cosson and their contact information: (336) 697 - 0525
e. Driving directions: See file.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
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
5. Is the residuals management plan adequate? ® Yes or ❑ No
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
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: See IV. Additional Regional Staff Review Items.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
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
FORM: WQROSSR 04-14 Pagel of 3
DocuSign Envelope ID: ABA6B73A-7FDD-4879-8985-98lD52780E7B
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? ® Yes ❑ No Is a solution underway or in place? Working on it. See IV. for details
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ® No ❑ N/A
If no, please explain: Condition I.1. concerning the installation of a freeboard staff gauge has not been completed.
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ®No❑N/A
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
3
C!
List specific permit conditions recommended to be removed from the permit when issued:
List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
I.1. Staff Gauge installation within
60 days of permit issuance.
The facility is using a manul measurement currently, but was unable to
demonstrate this during the site visit.
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
6. Signature of report preparer:
Signature of regional supervisor:
Date: May 11, 2020
e state reasons: )
by:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
On May 7, 2020, WSRO staff made a site visit for review of the subject facility related to application for permit renewal. Jamie
Cosson (YMCA), Chip White, ORC (Envirolink), and David Burton, BU-ORC (YMCA) accompanied staff on the site visit. Overall,
the system appears to be maintained and in working order. However, there were several concerns noted during the site visit which
warrant a WSRO follow-up inspection. Below is a summary of notes from observations made during the site visit.
1. The current permit has a schedule condition that required a freeboard gauge shall be installed within 60 days of permit issuance.
However, no measurement gauge has been installed to date. Onsite representatives (including the primary and backup ORCs)
offered to demonstrate the manual measurement method that is currently being used but were unable to do so. Recommend
that this schedule condition be included in the renewed permit with a 60-day timeframe for installation. WSRO staff
will conduct an onsite follow-up inspection to ensure this is completed.
Average daily influent flows have exceeded the permitted max daily design flow during peak operations (mainly summer
months). The remainder of the year the reported average daily flows are compliant. The facility is aware of the issue and has
been working towards a solution. A flow equalization basin which would allow timed flow may address this issue. The facility
has reportedly taken the following actions thus far:
• Purchased neighboring property for potential expansion of the system,
• Had a preliminary soils evaluation completed on the exiting property and the new neighboring property to evaluate
potential permitting options.
• Hired an Engineer to evaluate the potential for connection to public sewer, which reportedly is located within 1 mile
of the facility.
Facility representatives indicated that the sewer connection is their 1 It
choice. They now are considering potentially expanding
the camp with the new property that was purchased.
FORM: WQROSSR 04-14 Page 2 of 3
DocuSign Envelope ID: ABA6B73A-7FDD-4879-8985-981D52780E7B
3. The reported 12-month loadings, and hourly loadings have exceeded the permitted limits for hourly and annual loading. Facility
representatives indicated that this was the result of a computer dosing system error which resulted in overloading. This also
resulted in some irrigation zones (e.g. zone #3) being used more heavily than others. Reportedly the issue has been corrected.
The area adjacent and downslope of the irrigation zones was reviewed during the site visit. No evidence of runoff was observed,
but irrigation was not being conducted at the time. WSRO staff to follow-up to ensure loading limits have returned to
compliance.
It should be noted: based on the past 12-months NDMR/AR reporting data the Plant Available Nitrogen (PAN) loading to the
drip zones is greater than the agronomic limits for the irrigation areas. This data suggests PAN loadings in excess of 560 lbs.
PAN/acre/year has occurred at times. If loading rates greater than agronomic limits continues, groundwater monitoring
requirements should be considered and nutrient loading reporting on NDMLR forms should be required.
4. Review of the soil sampling results from the most recent 4 years (i.e. 2017 — 2020) suggests that there may be issues with
Exchangeable Sodium Percentage (ESP) in the drip zones. ESP values reported in these results are elevated with values reported
from 6% to as high as 47%. ESP values of 10 — 15% or higher can result in reduced infiltration and permeability of the soil.
Recommend that WSRO staff request an effluent sampling event for Na, Mg, and Ca to evaluate the Sodium Adsorption Ratio
(SAR) of the effluent. Also, a follow-up inspection with detailed review of drip should be conducted. Review soil sampling
method & sampling depth should also be conducted to ensure proper samples are collected which are representative of the
irrigation zones. A split sample event could be considered.
FORM: WQROSSR 04-14 Page 3 of 3
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OWNER.
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YMCA OF GREENSBORO
620 —A STREET: I GREENSBORO, EENAN'C. 21405' SUITE 210
CONTACT. JAMIE COSSON
/ (336) E91-0525
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SRE DATA:
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DEED, BON/PAGE 129/4
USE: CAMP(LUC-3)
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PARKING DATA:
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REOUIRED PARKING:
1 SPACES.F. OF POM AREA
14,900 S.F./I00 S.F. - 149SPACES REWIRED
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TOTAL SPACES PRONDED - 154 SPACES (ACL 10 H/C)
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Comoliance Insoection Resort
Permit: WQ0019782 Effective: 10/01/15 Expiration: 09/30/20 Owner: The Young Men's Christian Association of
Greensboro Inc
SOC: Effective: Expiration: Facility: YMCA Camp Weaver WWTP
County: Guilford 4924 Tapawingo Trl
Region: Winston-Salem
Greensboro NC 27406
Contact Person: Jamie Cosson
Title:
Phone: 336-854-8410
Directions to Facility:
From 1-40 East/1-85 North take the Lee Street Exit #128. Turn Right (south) on Lee Street and follow until it ends. Right onto
Young's Mill Road and follow until it ends. Left onto Mill Point Road and follow for 3/4 mile. right on Tapawi
System Classifications: SI, WW2,
Primary ORC: Robert Charles White Certification: 1004687 Phone: 336-503-2383
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 05/07/2020 Entry Time 09:30AM
Primary Inspector: Patrick Mitchell
Secondary Inspector(s):
Caitlin Caudle
Reason for Inspection: Other
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Exit Time: 11:OOAM
Phone: 336-776-9698
Inspection Type: Reconnaissance
E Neither
Page 1 of 3
Permit: WQ0019782 Owner - Facility: The Young Men's Christian Association of Greensboro Inc
Inspection Date: 05/07/2020 Inspection Type : Reconnaissance Reason for Visit: Other
Inspection Summary:
On May 7, 2020, WSRO staff made a site visit for review of the subject facility related to application for permit renewal.
Jamie Cosson (YMCA), Chip White, ORC (Envirolink), and David Burton, Back -Up ORC (YMCA) accompanied staff on the
site visit. Overall the system appears to be well maintained and in working order. However, there were several concerns
noted during the site visit which warrant a WSRO follow-up inspection. Below is a summary of notes from observations made
during the site visit.
1. The current permit has a schedule condition that required a freeboard gauge shall be installed within 60 days of permit
issuance. However, no measurement gauge has been installed to date. Onsite representatives (including the primary and
backup ORCs) offered to demonstrate the manual measurement method that is currently being used but were unable to do
so. Follow-up inspection required to ensure this is completed.
2. Average daily influent flows have exceeded the permitted max daily design flow during peak operations (mainly summer
months). The remainder of the year average daily flows are compliant. The facility is aware of the issue and has been
working towards a solution. Aflow equalization basin which would allow timed flow may address this issue. The facility has
reportedly taken the following actions:
• Purchased neighboring property for potential expansion of the system,
• They had a preliminary soils evaluation completed on the exiting property and the new neighboring property to evaluate
permitting options.
• They have hired an Engineer to evaluate the potential for connection to public sewer, which reportedly is within 1 mile of the
facility.
Facility representatives indicated that the sewer connection is their 1 st choice. They now are considering expanding the
camp with the new property that was purchased.
3. The 12-month loading, and hourly loadings reported have exceeded the permitted limits for hourly and annual loading.
Facility representatives indicated that this was the result of a computer dosing system error which resulted in overloading.
This also resulted in some irrigation zones (#3) being used more heavily than others. Reportedly the issue has been
corrected. The area adjacent and downslope of the irrigation zones was reviewed during the site visit. No evidence of runoff
was observed. WSRO staff to follow-up to ensure loading limits are returned to compliance.
It should be noted, based on the past 12-months NDMR/AR reporting data; Plant Available Nitrogen (PAN) loading to the drip
zones is greater than the agronomic limits for the irrigation areas. This data results in PAN loadings in excess of 560 lbs.
PAN/acre/year at times. If this loading rate continues, groundwater monitoring requirements should be considered.
4. Review of the soil sampling results from the most recent 4 years (i.e. 2017 — 2020) suggests
that there may be issues with Exchangeable Sodium Percentage (ESP) in the drip zones. ESP values reported in these
results are elevated with values reported from 6% to as high as 47%. ESP values of 10 — 15% or higher can result in
reduced infiltration and permeability of the soil.
Recommend that WSRO staff request an effluent sampling event for Na, Mg, and Ca to evaluate the Sodium Adsorption
Ratio (SAR) of the effluent. Also, a follow-up inspection with detailed review of drip should be conducted. Review soil
sampling method & sampling depth should also be conducted to ensure proper samples are collected which are
representative of the irrigation zones.
Page 2 of 3
Permit: WQ0019782
Inspection Date: 05/07/2020
Owner - Facility: The Young Men's Christian Association of Greensboro Inc
Inspection Type : Reconnaissance Reason for Visit: Other
Type
Yes No NA NE
Lagoon Spray, LR
❑
Single Family Drip
❑
Activated Sludge Spray, LR
❑
Single Family Spray, LR
❑
Recycle/Reuse
❑
Infiltration System
❑
Reuse (Quality)
❑
Activated Sludge Spray, HR
❑
Activated Sludge Drip, LR
Page 3 of 3