WQ0007217_Staff Report_20201120

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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.: W00007217
Attn: Poonam Girl Facility Name: Piney Island (BT-11) WWTF
From: Bryan Lievre
Wilmington Regional Office
Note: This form has been adapted from the non -discharge facili . 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: 11/09/2020
b. Site visit conducted by: Bryan Lievre
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Timothy Lawrence and their contact information: 252) 466 - 2754 ext.
e. Driving directions: from Morehead City: NC Hwy 70E to NC Hwy 12N then board boat to Piney Island
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification: SA NSW HQW
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses: Shell fishing/ in recreation
II. PROPOSED FACILITIES: NEW APPLICATIONS — N/A
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Jeff Clams Certificate #: 998515 Backup ORC: Patricia Davis Certificate #: 986492
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 3,800 gallon septic tank, a duplex pump station with two 75 gpm pumps, two
265 square feet recirculating surface sand filters, a tablet chlorine contact tank, a 64,100 gallon holding basin, a
duplex sprayirrigation pump tank with two 140 gpm pumps, a 1.44 acre spray irrigation field with two spray
heads and associated piping and gppurtenances.
Proposed flow: 1,750 gpd
Current permitted flow: 1,750 gpd
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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.). The current permit was issued May 23, 2016 and specified that the Permittee shall remove the spray fields
and create a new waste disposal method no later than December 31, 2017. This requirement was due to the
condition of the spray field which is prone to flooding and ponding. The Permittee has submitted reports to DEQ
which have evaluated various treatment alternatives and recommended the conversion of the existingholding
olding
basin into an infiltration basin. Approval for the recommended alternative was denied from DEQ since the
proposed alternative would not adhere to established setback standards. Ponding was observed in numerous areas
within the spray field during the 11/9/2020 visit.
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: Fields are routinely not absorbing wastewater and are often ponded
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: Existing field unacceptable for spray irrigation due to poor drainage
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. Treatment facility is less than 50' to surface water, but the facilities
are not new/expanding
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:
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
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: No reported limit violations since 2015
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
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
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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: None
17. Pretreatment Program (POTWs only): N/A
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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
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
WiRO suggests that a
compliance schedule is
included in the new permit to
WiRO recommends the re -issue of the permit along with conditions for the
Permittee to investigate options to avoid ponding.
update recommendations to
avoid ponding (i.e. through
proper disposal of treated
effluent, and/or reducing
Although the Permittee has previously documented alternative disposal
options and provided their recommendations, more recent discussions may
have provided additional information to aid in their decision making process.
influent flow, 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
❑ DeajPlease state reasons: )
cuSigned by:
6. Signature of report preparer:
Signature of regional supery
Date: 11/20/2020
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
I would recommend that the applicant continue investigating ways to reduce flow to the WWTF. A recommendation
was already made by regional staff to eliminate flow backwash water from the water treatment facility from entering
the WWTF. System staff have stated that one of the buildings on the island is planned to be razed. These and other
items should reduce flow to the WWTF.
Options that were analyzed in November 2017, include:
1) Research ways to reduce the flow at the island.
2) Replace existing spray heads for a finer mist to allow for more evaporation and possible increase the number of
finer heads (stay in the same permitted area).
3) Incorporate operations changes that include more frequent spraying so that lower volumes are being sprayed.
4) Installing a holding tank for wet weather.
5) Installing a boardwalk to spray fields to remove the damage caused by the crawler.
Other activities should investigate other disposal options. With reduced flow to the WWTF, alternatives previously
identified may become viable and/or other technologies employed.
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