WQ0004230_Staff Report_20201123

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State of North Carolina
®r- Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0004230
Attn: Erick Saunders Facility name: A Place at the Beach 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: I1/18/2020
b. Site visit conducted by: Helen Perez
c. Inspection report attached? ❑ Yes or ® No (uploaded to Laserfiche)
d. Person contacted: Don O'Mara and their contact information: (252) 725 - 2129 ext.
e. Driving directions: 1904 E. Ft. Macon Road, Atlantic Beach
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: EBF46E36-C126-476F-93F4-FBDBAC824E5B
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: Lee Buck Certificate #:993396 Backup ORC: Karrie O'Mara Certificate
#:14393
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:
Same as the 1 l/13/2006 Permit with the following changes:
Remove the word "construction". Facility has been in operation since 2007.
There are three (3) UV disinfection trains, not two (2) as stated in the permit.
Remove abandonment of old facility paragraph.
Proposed flow: N/A
Current permitted flow: 55,000 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.)
This ReCip biological reactor system is a series of concrete cells, approximately 10 ft tall, filled with various sizes
of rock media that treats wastewater similar to a tricklingfystem. Removal of solids from the cell reactors is
limited due to the design and it is suspected that solids have accumulated over time in the cells. It appears there
will be challenges in cleaning or replacing the rock media.
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:
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DocuSign Envelope ID: EBF46E36-C126-476F-93F4-FBDBAC824E5B
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: See #2 above.
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 (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 I //
O / 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: In the last 2 ,years there have been 5 NOVs issued for
monthly Total Nitrogen exceedances and 1 monthly Fecal exceedance. GW monitoring shows TDS exceedances
in MW#6, likely naturally occuring in a barrier island environment.
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: EBF46E36-C126-476F-93F4-FBDBAC824E5B
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 facility map
icluding MWs and review
and compliance boundaries.
No updated map in RO file.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition
Reason
MW #4 monitoring
Inactive well
Section 11.6
High -rate infiltration fields are covered in gravel.
Total Residual Chlorine
monitoring
Facility has UV disinfection
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: )
,e—Docuftned by:
6. Signature of report preparer:
Signature of regional supervisor:
Date: 11/23/2020
14AC7DC434...
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DocuSign Envelope ID: EBF46E36-C126-476F-93F4-FBDBAC824E5B
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This staff report was prepared for the renewal of Permit W00004230, A Place at the Beach WWTF. This ReCip
biological reactor system treats wastewater similar to a tricklingfilter ilter system. It appears to be a challenging system to
operate. Windward Dunes WWTP, WQ0002314, is also a ReCip system in Carteret County that was renewed in 2018.
This facility has a Nitrate limit of 10 mg/1 instead of a Total Nitrogen limit of 10 mg/1. WIRO recommends, if
setbacks allow, a Nitrate limit instead of a Total Nitrogen limit. Section 111.2 needs to be change from influent flow
monitoring to effluent flow monitoring. This facility never had an influent flow meter.
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