WQ0007569_Staff Report_20200318

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,s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Ashley Kabat
From: Bryan Lievre
Wilmington Regional Office
Application No.: WQ0007569
Facility Name: Brandywine Bay WWTP
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: 2/14/2020
b. Site visit conducted by: Bryan Lievre
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Stack and their contact information: 252 659 - 0513 ext.
e. Driving directions: 104 Sleepy Ct., Morehead City, NC 28557. From Jacksonville head east on NC Hwy 24,
make a left onto Brandywine Blvd., right onto Breezy Ln., left onto Carefree Ln., right onto Sleepy Ct, turn
right onto dirt drive in approx. 225 feet
2. Discharge Point(s): NA
3. Receiving stream or affected surface waters: NA
IL PROPOSED FACILITIES: NEW APPLICATIONS NA
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III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
Facility is classified WW-2 and SI
ORC: Stacy Go
Backup ORC: Anthony Chilton
Backup ORC: Gregory Spillman
Certificate #: SI 1000417, WW-4 998882
Certificate #:WW-3 994079
Certificate #: SI 1008006
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 permitted (see Section V.).
Proposed flow: 300,000 GPD
Current permitted flow: 150,000 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.)
During the recent visit, the metal extended aeration units and weirs were observed to have significant corrosion.
Operation staff feel uncomfortable walking close to some of the vessels, due to concerns of structural integrity.
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: 5-day and 30-dayponds as well as gold course ponds are infiltrating
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:
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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: Wells seem to be located as indicated in BIMS, but the construction of the wells was not
verified and MW-I I was proposed but never installed
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
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: Since 1/1/2018, 2L GW exceedances for IDS in wells
MW4, MW-5 & MW-8 in 3/18, 7/18, 11/18, 3/19, 7/19 & 11/19.
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: Treated affluent from the WWTF flows to ponds within the golf course.
All of the ponds within the course are connected by way of ditches and swales. The eventual overflow for these
structures appears to be toward the north to Hull Swamp (Class C Waters,) tributary to the Newport River.
17. Pretreatment Program (POTWs only): NA
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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: Refer to Section V.
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
Several Items See Section V for details
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: )
/­DocuSigned by:
6. Signature of report preparer:
Signature of regional supery
3/18/2020
Date:
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS (From IV.2)
1) Provided below is a bulleted itemized list of components for the wastewater treatment facility. The list is
organized in sequential order (,following the direction of the flow, starting at the headworks) and broken down by
the major components. This method is preferred over the existing style in order to provide the reviewer with an
understandingof f the process flow and assist the inspector to understand all components. Placing information
together in this manner would prevent the omission of data (as missing from the design air flowrate for the 50,000
gpd extended aeration units mentioned below) and gain a full understanding of the system limitations. The way
some of the current processes are currently described, it is often difficult to understand if the permit limit is based
on the treatment system design parameters or the disposal system limitations. In general, it is recommended that
applicants provide a bulleted lists of the WWTF's components and the flow diagram of the WWTF that would be
included as part of the permit (in this case, the applicant included the flow diagram as part of the application).
Please request the permittee to verify that the list of the components of the proposed systemrefer to 1.2) is
accurate.
1.1)The current systems include:
o Two duplex influent pump stations (one at the plant and the other located at the entrance to the plant on east side
of Sleepy Court)
o A 37,500 gallon equalization (EQ) tank with
• A bar screen and,
• Dual 100 cubic feet per minute (cfin) blowers (servingthe he equalization tank and the digester)
o A 5-way flow splitter box
o Dual 100,000 gpd extended aeration units containing:
• Dual 50,000 gpd aeration basins
• Dual 8,373 gallon hopper bottom clarifiers and v-notched weirs
• A 7,539 gallon digesteraka aerated sludge tank)
• Dual 100 cfm blowers (,for EQ tank and digester)
• Dual 400 cfm blowers (,for aeration basins and air-lift pumps for RAS and WAS)
o Dual 50,000 gpd extended aeration units (installed in parallel to the 100,000 gpd units) containing:
• Dual 25,000 gpd aeration basins
• Dual —6,000 gallon hopper bottom clarifiers with v-notched weirs
• Dual 4,000 gallon digesters (aka aerated sludge holdingtanks)
anks)
• Dual blowers per train serving the aeration basins and set up for air lift pumps serving the RAS & WAS
(information is not available about the design air flowrate for the units and although the system is currently
equipped with four Tuthill Model 5009-A6L2CV 1-A2 blowers, w/o knowing the design speed, one cannot
determine the anticipated air flowrate for the unit)
o Dual Fluidyne 200,000 gpd fixed -plate cloth tertiary filters, installed in parallel
o Two Trojan 3200K PTP ultraviolet (UV) disinfection units, installed in series
o A 9,700 gallon liquid chlorination contact tank
o An effluent flowmeter
o An in -line turbidimeter
o An auto -dialer control panel
o An 85 kilowatt (kW) auxiliga generator
o A 1.25 million gallon MG (-1.70 acre) unlined five-day holding pond with a manual influent diversion valve and
a 3/4 horsepower (hp) return pump
o A 7.5 MG (-3.35 acre) effluent storage/infiltration pond
o A 350,000 GPD sprayirrigation system with receivingpond(s) and 84.6 acres of Mray irrigation area consisting
of golf course holes 1 — 18
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12)The proposed system includes the following new components, unless indicated otherwise:
o An influent pump station (the existing unit at the WWTF,) with:
• coarse screen (1/4") and grit removalsystem
• two 750 gpm pumps
o An SBR unit with pressure transducers- float switches and dissolved oxveen sensors in each of the four tanks as
well as:
• Dual SBRs at 210,637 gals, each and designed for 0.30 MGD with:
— 500 cfm blowers (& 1 backup for total of 3) and jet aeration headers
— 1,830 gpm jet motive pumps (total of two)
— Floating solids decanters (total of two)
— Siemens (or equal) flow measuring device (total of two)
• One post flow equalization basin at 195,224 gals with:
— A 145 cfm blower
— Two (2) 320 gpm self primingsewage ewage effluent pumps
• One eVOQUA aerobic digester at 127,027 gals with:
— A 240 cfin blower
— A 1,098 gpm jet motive pump
o Three cloth media tertiary filters, installed in parallel
• Two (existing) Fluidyne filters at 0.2 mgd each
• One Fluidyne filter at 0.6 mgd
o Two WEDECO ultraviolet disinfection units at 0.3 mgd each, in parallel
o A flow distribution box w/ Isco (or equivalent) flow recorder/totalizer
o Standby diesel fuel powered emergency generator
o Two (2) hieh rate infiltration basins at 0.86 acres- each and 4 apd/ft^2 and 150-000 apd_ each with interior of
raised encapsulating berms filled with "open graded sand"
o A 691,200 GPD groundwater lowering system surrounding high rate infiltration basins with discharge into golf
course ponds, and:
• Fifty-two (52) two inch diameter dewatering wells all interconnected by two inch diameter Schedule 80 PVC
suction header pipe
• Nine (9) 75 gpm dewatering pumps Myers (or equivalent) connected by two inch diameter Schedule 80 PVC
discharge header pipe
• Three (3) two inch diameter groundwater level observation wells, each equipped with pulse radar level
transmitters
2. The permit modification application would provide for the installation and operation of a 300,000 GPD
sequencing batch reactor, the removal of the existing 150,000 gpd extended aeration units, to modify the 5-daX
and 30-dayponds to serve as high rate infiltration basins and to abandon the use of the spray irrigation system.
In the past- this facilitv did not irrigate on the permitted aolf course. The storage pond infiltrated enoueh so
irrigation was not needed. The storage/infiltration pond has been mentioned in past staff reports, inspection
reports and permits. A study was required to be submitted in 2014 documenting how much the storage pond was
infiltrating. In a meeting in November of 2017, Carolina Water Services told WIRO that unknown amounts of
effluent stored in the storage/infiltration pond has been flowingthrough hrough a rg avity line to a pond located on the
eolf course. At some time- the eolf course owners reportedly connected the discharge pond to a second pond
within the golf course.
Would the ponds) at the golf course and at the WWTF reauire a "proper closure" in accordance with 15A NCAC
2T .0105(j) and per the June 22, 2012 Guidelines for the Closure of Permitted Wastewater Ponds and Lagoons? If
so, which ponds would require this proper closure (e.g 5 dqy pond, 30-dgy pond, the first pond receiving flow
from the re -use effluent, the second pond at the golf course which has been subsequently connected to the first
pond at the golf course, or all the ponds within the golf course since they could be hydraulically connected)?
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Although the most recent permits issued for the system i.e. WQ0007569 dated 11/20/19, 10/2/13, 2/29/08,
5/19/05, 8/22/03, 9/17/99 and 10/29/97, do not specifically refer to the ponds within the golf course and only refe
to 85 acres of spray irrigation area, the permit dated 3/30/94 refers to "the golf course spraysystem", and the
permit issued 7/6/88 refers to "the existing golf course irri air lion pond for spray irrigation of treated effluent... "
3. More recently, Carolina Water Services (CWS) staff informed WiRO staff that they do not have an agreement to
operate or maintain the spray irrigation system at the golf course. CWS staff are reportedly required to inform the
golf course owners two to three days in advance if desiring to entire the golf course and that CWS staff are not
permitted to alter the flow to each of the zones with the irrigation area. For reporting purposes CWS are simply_
equally dividing estimated flow throughout the irrigation system to each of the 18 holes in the golf course,
whether valid or not.
It is understood that an agreement between CWS and the golf course owners is crucial to the proper operation of
the spray irrigation system and WiRO will continue to work with CWS to ensure that the system is being properly
operated and maintained. However, our office is concerned about the amount of time it will take CWS to gain
compliance.
A similar situation regarding_golf courses capabilities to receive treated effluent happened at the CWS Belvedere
Plantation WWTF, Permit No. W0001664. In the Belvedere Plantation situation, several pump and haul permits
were issued to CWS because of effluent disposal restrictions at the golf course (field play, a�ty, aesthetics, etc.).
Currently, the Belvedere Plantation WWTF permit lists spray irrigation at the golf course as a conjunctive
reclaimed water utilization systemirrigation is a backup disposal option).
The removal of the spray irrigation system from the proposed permit modification would prevent the need for an
agreement between CWS and the golf course. Moreover, DWR does not have enforcement authority over an
agreement between the facility and the golf course. In an effort to ensure that the system is properly operated
within the most expedient manner, please request CWS to provide a timeframe for the installation and operation
of the proposed SBR WWTF and high rate infiltration system.
4. The proposed modification includes a groundwater lowering system surrounding the two proposed high rate
infiltration basins. The recovered groundwater is proposed to be sent by the way of existing pipes to the existing
pond system within the golf course. Sheet C3 of 13 included with the application depicts the layout of the
proposed groundwater lowering system. However, it should be noted that the existing 8" line noted to transport
the recovered groundwater is not an "irrigation line" as indicated on the figure but rather a line that discharges
treated effluent from the existing manhole near the north side of the 5-day pond into a pond at the golf course.
The golf course then recovers water from the pond with a pump system and sprays the recovered water on the golf
course.
As already mentioned, one of the reasons CWS has decided to remove the golf course irrigation system from the
proposed system is due to the fact that there is no agreement between the two parties and CWS must obtain
permission from the golf course prior to entry on the premises. Since no agreement has been established between
the two parties, it is uncertain if discharge(s) onto the golf course property should be allowed with the future
permit.
5. It is understood that the proposed SBR system will be installed adjacent to the existing extended aeration
structures. This will enable a smooth transition for the operation of one system to another in that the SBR can be
seeded with the older system and then switched over when conditions are appropriate. However, the
reconstruction of the 5-day and 30-dayponds into infiltration basins is of concern (e.g. ensuringappropriate flows
are maintained and some of the ponds are not overfilled, that excessive solids are not sent downstream, etc.). Can
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we request that CWS provide a plan for the reconstructing these structures while ensuring adherence to existing
permits and other requirements (i.e. based on quantity and quality of downstream flow)?
6. The Map of Upgrades ades provided with the permit application depicts the proposed Review and Compliance
Boundaries at 50' and 100', respectively from the Waste Boundary. Although these proposed boundaries may be
applicable when the system is close to the property lines, it seems as though the respective boundaries should be
increased to 125' and 250' north, south and east of proposed Basin # 1.
7. It is uncertain if the proposed WWTF design provides for duplicity of essential treatment units as required in 15A
NCAC 2T .0705 (v). Although the proposed design provides for 2 sequencing batch reactors, both reactors are
incorporated within one structure. Also, the design only provides for one digester and one post equalization
basin. I would greatly ppreciate it if you could inform me how duality is achieved for these issues.
8. The proposed plans depict monitoring wells MW-9 and MW-10 adjacent to the proposed infiltration basins.
Please note that there are already wells with these designations located in association with the WWTF. Existing
wells MW-9 and MW-10 are located near the tee and fairway, respectively, along Hole 13 of the golf course off
the northwest corner of Hillcrest Dr._ & Lord Granville Dr. If additional wells are installed it is recommended
that these numbers not be used.
9. Additional details are requested for the dewatering wellhead. Practical experience demonstrates that significant
pressure (vacuum) losses can occur if the recoverysystem is not air tight. The Dewatering Well Section provided
on Sheet C10 of 13 simply depicts a cap at the top of the dewater well. A typical PVC cap placed on top of the
well is insufficient to provide a vacuum tight connection.
10. Proposed wells do not appear to have been proposed to be constructed in accordance with 2C Standards. The
dewatering wells and groundwater level observation wells must be installed by a licensed well driller. Per 2C
.0108 the wells must be equipped with a two feet concrete pad around the perimeter of the well, an outer casing, a
permanently affixed registration plate, and a locking well cap. The plans should also depict the proposed total
depth of the wells.
11. The following information could not be located with the application package:
• Dimensions of the influent pump station (please check station for size as system currently uses two pum
stations and the proposal is to send flow from second station to this station and directly into WWTP as
currently established)
• Anticipated flow (GPM) at pressure (TDH) for the groundwater wells, as requested in Section V. 11. e. of
High Rate Infiltration Systems, Form HRIS 06-16
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