WQ0031246_Staff Report_20210422

DocuSign Envelope ID: 01 C5C893-EA80-4503-8234-C98A4BE54059
Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: n NPDES Unit ® Non -Discharge Unit
Attn: Poonam Giri
From: Randy Sipe
Washington Regional Office
Application No.: WQ0031246
Facility name: Riversound Development
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 applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or n No
a. Date of site visit: 3/30/21
b. Site visit conducted by: R. Sipe and R. Tankard
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: George Hill and their contact information: (252) 484 - 2086 ext.
e. Driving directions: No change since last permit was issued.
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:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Noah Deckard Certificate #: 1009715/WW-2 Backup ORC: James Pittman Certificate #:999085/WW-4
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? n Yes or ® No
If no, please explain: The WWTP was found to be essentially intact during the inspection on 3/30/21; however,
the ORC stated that it was inoperable because of multiple equipment failures. It has been collecting influent from
two onsite residences for approximately a year but has not been treating or disposing any wastewater. An NOV
was issued requesting the permittee address the maintenance and operation of the WWTP. Subsequently, WaRO
has been in discussion with them concerning a temporary pump and haul permit until the condition of the WWTP
can be addressed.
Description of existing facilities: anoxic, aeration, and post anoxic zones followed by membrane bioreactors.
Proposed flow: 64,000 GPD
Current permitted flow: 64,000 GPD
FORM: WQROSSR 04-14
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DocuSign Envelope ID: 01 C5C893-EA80-4503-8234-C98A4BE54059
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.) See comment above.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or n No
If no, please explain: The infiltration system appears to be in adequate condition.
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.)? n Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ® Yes or n No
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or n No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ® Yes n No n 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? n 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 n No
If no, please explain:
10. Were monitoring wells properly constructed and located? ® Yes n No n N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? n Yes ® No n N/A
If no, please complete the following (expand table if necessary): Monitoring wells are in four clustered pairs
around the infiltration basin.
Monitoring Well
Latitude
Longitude
MW-1 and MW-2
36°4'
23.9082"
-76°29'
35.5626"
MW-3 and MW-4
36°4'
21.4608"
-76°
29'
29.2266"
MW-5 and MW-6
36°4'
17.3094"
-76°
29'
32.2548"
MW-7 and MW-8
36°4'
19.8372"
-76°
29'
38.4426"
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or n No
Please summarize any findings resulting from this review: They have not been submitting monthly reports;
however, WaRO is requesting that they start providing monthly reports documenting no flow through the system.
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 n No
If yes, please explain: See our comments in Item III.4 below.
14. Check all that apply:
n No compliance issues n Current enforcement action(s) n Currently under JOC
Z Notice(s) of violation n Currently under SOC n Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) An NOV
was issued as a result of the inspection performed on 3/30/21.
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? WaRO is working with the permittee to address
the inoperable state of the WWTP. We are in discussion with them about a temporary pump and haul permit until
they are able to address the condition of the WWTP.
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DocuSign Envelope ID: 01 C5C893-EA80-4503-8234-C98A4BE54059
Have all compliance dates/conditions in the existing permit been satisfied? n Yes Z No n N/A
If no, please explain: WaRO has no record of an O&M plan being submitted, as per Condition I.4.
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
fYes ®NofN/A
If yes, please explain: WaRO does not believe the compliance issues noted during the 3/30/21 inspection should
affect the renewal of the permit.
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? n 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
O&M Plan
WaRO has no record of receiving an O&M plan as required by Condition I.4.
Alternatively, this requirement could continue to be included as a schedule
condition, but with a time limit, such as 60 days.
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
Conditions IIL9 and IV.6
WaRO requests that these conditions be expanded to include the requirement of
a minimum freeboard of two feet in the EQ and digester tanks of the WWTP to
assist in keeping the tanks from becoming completely full as was observed
during the 3/30/21 inspection.
Condition IV.3 and
Attachment A
WaRO requests that this condition and attachment be expanded to require
documentation and reporting of both influent and effluent flows so that flow
through the WWTP can be better managed.
5. Recommendation: n Hold, pending receipt and review of additional information by regional office
Z Hold, pending review of draft permit by regional office
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DocuSign Envelope ID: 01 C5C893-EA80-4503-8234-C98A4BE54059
n Issue upon receipt of needed additional information
n Issue
n Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor: R4444 T "
Date: 4/22/2021
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 4 of 4