WQ0005910_Staff Report_20201202

DocuSign Envelope ID: AA58FAE5-F373-4FC9-A8CD-F8F2ACAE2FE8
,s 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.: WQ0005910
Attn: Poonam Giri Facility name: Avoca, LLC
From: Randy Sipe
Washington Regional Office
Note: This form has been adapted from the non -discharge facilily 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: N/A
b. Site visit conducted by: N/A
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: N/A and their contact information: (_)
e. Driving directions: N/A
2. Discharge Point(s): N/A, non -discharge system
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A, non -discharge system
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
ext.
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
ORC: Certificate #: Backup ORC: Certificate #:
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: N/A, modification only involves the groundwater monitoring network.
Description of existing facilities: N/A, modification only involves the groundwater monitoring network
Proposed flow: N/A, modification only involves the groundwater monitoring network.
Current permitted flow: N/A, modification only involves the groundwater monitoring network.
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.)
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DocuSign Envelope ID: AA58FAE5-F373-4FC9-A8CD-F8F2ACAE2FE8
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: N/A, modification only involves the groundwater monitoring network.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No
If no, please explain: N/A, modification only involves the groundwater monitoring network.
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. N/A, modification only involves the groundwater monitoring network.
9. Is the description of the facilities as written in the existing permit correct? ❑ Yes or ❑ No
If no, please explain: N/A, modification only involves the groundwater monitoring network.
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): The modification application includes the
coordinates of both the new and existing monitoring wells.
Monitoring Well
Latitude
Longitude
C
C
C
C I II
C I II
C I II
C I II
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 the groundwater monitoring data revealed
elevated nitrate levels at MW4 and elevated ammonia levels at MW-8. As a result, WaRO issued Avoca an
NORR requesting that they investigate these groundwater exceedances. An investigation and subsequent report
performed by Groundwater Management Associates, Inc. (GMA) concluded that MW-4 was not in hydraulic
communication with the irrigation system and storage pond due to onsite surface water features and topography.
The report also, recommended the installation of an additional upgradient well at irrigation zone 5 to help evaluate
if conditions observed at MW-8 were being influenced by the effluent irrigation or the adjacent agricultural
practices. Therefore, WaRO requested that Avoca abandon MW-4 and replace it with MW-11, which is located
downgradient of irrigation zone and the storag`pond. Also, MW-10 was installed upgradient of irrigation zone 5.
This modification is to incorporate these changes into the permit.
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: Please see the discussion in Section II.12 above.
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? Please see the discussion in Section IL12 above.
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Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ❑ No ® N/A
If no, please explain: N/A, modification only involves the groundwater monitoring network.
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, non -discharge system.
17. Pretreatment Program (POTWs only): N/A, non -discharge system.
III. 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
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: pw"
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DocuSign Envelope ID: AA58FAE5-F373-4FC9-A8CD-F8F2ACAE2FE8
Signature of regional supervisor:
Date: 12/1/2020
P10" T"
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 4 of 4