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HomeMy WebLinkAboutWQ0004059_Staff Report_20190822Dow& n Envelope ID: 6B557BE5-B6F3-42F8-846F-A28D2A36B973 State of North Carolina Division of Water Resources Water Quality Regional Operations Section Environmental Staff Report Quality August 22, 2019 To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0004059 Attn: Ashley Kabat, Water Quality Permitting Section Facility name: Atlantic Station WWTF From: Geoff Kegley Wilmington 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 gpplicable. I. GENERAL AND SITE VISIT INFORMATION 1. Was a site visit conducted? ❑ Yes or ® No a. Date of site visit: last inspection on 2/1/2019 b. Site visit conducted by: Geoff Kegley c. Inspection report attached? ❑ Yes or ® No d. Person contacted: Dan Fortin and their contact information: (252) 241 - 9208 ext. e. Driving directions: From Wilmington travel north on US Highway 17 to NC 24 to NC58 to Atlantic Beach, NC. Turn Right onto Fort Macon Road. The facilitv is located on the south side of Fort Macon Road directiv across from Bojangles Restaurant. 3. Are depth to table, the El Yes H NO H N,/A site eendifiens (sails, wa4er- ete) eensistent with submiffed r-epei4s? if no, please explain.: — if no, please explain: FORM: WQROSSR 04-14 Page I of 4 DocuSign Envelope ID: 6B557BE5-B6F3-42F8-846F-A28D2A36B973 ... vm-1 IN ... W'' i Mal Lb III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A ORC: Joseph A. Lawrence Certificate #:6418 Backup ORC: Robert C. Howard Certificate #:996013 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: As described in permit W00004059 Proposed flow: n/a Current permitted flow: 100,000 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.) A review of monitoring reports was conducted and in general, the compliance record has been good. There have been some irregular violations and a NOV was issued for an ammonia violation (monthly average) in December 2018. The groundwater monitoring has shown some exceedances of Nitrate and TDS in MW-1. Sugarloaf Utility was assessed a civil penalty in March 2017 for failure to apply for a permit renewal. The sludge holding tank is severely corroded and needs to be evaluated and likely replaced. Consideringthe he age and condition of the plant, the wastewater treatment plant still appears to be well operated and maintained. 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: The sampling program is gppropriate, the location of MW-1 is not. MW-1 needs to be abandoned and replaced with a new monitoring well. The ORC indicated that the well is submerged in a normal rain event. The well is also located immediately adiacent to Fort Macon Road and given its shallow nature and location within a wet area. anv stormwater from the FORM: WQROSSR 04-14 Page 2 of 4 DocuSign Envelope ID: 6B557BE5-B6F3-42F8-846F-A28D2A36B973 road will infiltrate around the well. During the last inspection a more suitable location was found nearby, an gpproximate location has been marked on the attached map, 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: MW-1 needs to be relocated ,given its history of non-compliance which may be due to its location and proximity to Fort Macon Road. 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 lI O I II O l lI O I II O l lI O I II O / // O / // O / // O / // 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: A review of self -monitoring data indicates there have been some irregular violations and a NOV was issued for an ammonia violation in December 2018. The groundwater monitoring has shown some exceedances of Nitrate and TDS in MW-1. Sugarloaf Utility was assessed a civil penalty in March 2017 for failure to apply for a permit renewal. 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: Relocating MW-1 may resolve the continuing GW-59 monitoring exceedances. 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? Refer to question 12. 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: , FORM: WQROSSR 04-14 Page 3 of 4 DocuSign Envelope ID: 6B557BE5-B6F3-42F8-846F-A28D2A36B973 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 This is a high rate infiltration facility. No vegetation is allowed in the III.3 infiltration areas. see current condition III.12. I.1 The (old)1.1 condition need to be replaced, as indicated in item 4 (below). 4. List specific special conditions or compliance schedules recommended to be included in the permit when issued: Condition Reason The new I.1 condition should relate to abandonment of existing MW-1 and replacement with a new well (MW-lA) at an appropriate location not in a low I.1 (proposed) lying area or subject to flooding (see map for approximate location). The WiRO would like to be contacted by the permittee to verify the proper location. The new I.2 condition should relate to abandonment of old MW-3 which is I.2 (proposed) currently temporarily abandoned and needs to be permanently abandoned. The new I.2 condition should relate to the sludge holding tank which is severely I.3 (proposed) corroded and needs to be evaluated and likely replaced. Needs to be updated. The wells to be listed are: MW-lA (new/proposed Attachment C replacement well), MW-2A, MW-4A, MW-5, and MW-6. 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: ) r—DocuSigned by: 6. Signature of report preparer: Signature of regional supervisor: Date: 8/23/2019 V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS C 5D3B417... EDocu Signed by: o 6" E3ABA14AC7DC434... FORM: WQROSSR 04-14 Page 4 of 4 MU,J, IA 1 `� R pW O PUBU�C - - - -4` 18"RCP , l,l TALI ` -n_-- ig42• 410.65 pc e Of CO - NPS 32 GATE r \- \ MW-1 0 LAT 34.700398° LONG-76.753833 / p WOODE i ---i �lr METER pf RE`11EW I . . tTtt - .�... 1 w � • • OGKf• mVVE C I it .. •'�i �} ! ��-b-,`-_�__y-_ s 9D l PP Z< ,i STORAG i BU I L D I G Z0 5 ,'3820 3 .. •'• "^•• \ - \ (A , ROTOR `'., LAT 34.6M raz \\ rr N •i I WMo ( LONG -76- 752E ma 0 N \i N \\ SEWER \, P^ �• CLEARED m / Y PLANT -a' r � m ` •' r Z I IT I I m ..' �-e-'� ram• i ,.