WQ0014306_Staff Report_20201028

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

To: NPDES Unit Non-Discharge Unit Application No.: WQ0014306
Attn: Erick Saunders Facility name: Eagle Creek WWTP

From: Randy Sipe
Washington Regional Office
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 No
a. Date of site visit: 8/19/20 and 10/21/20
b. Site visit conducted by: P. Mays and R. Sipe
c. Inspection report attached? Yes or No
d. Person contacted: Tracy Miller and their contact information: (828) 785 - 3323 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: Bryan Allen Certificate #: WW-2/1007616 Backup ORC: Kenny Harris Certificate #: WW-2/1001808
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: Although previous inspections found the maintenance and operation of the WWTP to be
lacking, observations made during the latest inspection found the maintenance and operation of the WWTP to be
adequate. Issues observed concerning the disposal system are discussed below.
Description of existing facilities: extended aeration/activated sludge with a tertiary traveling bridge filter and UV
disinfection.
Proposed flow: 175,000 GPD
Current permitted flow: 175,000 GPD
FORM: WQROSSR 04-14 Page 1 of 4

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 commentsaboveand below in Item II.7.
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: The permittee needs to maintain the woody vegetation on the berms around both the high-
rate infiltration basin and the reclaimed wet weather storage pond. See recommendations in Item II.4 below.
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: The facility is listed as a source on RLAP permit # WQ0000974.
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: A review of the effluent
flows from the WWTP vs. the amount of reclaimed water being irrigated out of the unlined wet weather storage
pond for the last few years indicates that the wet weather storage pond maybe acting as a infiltration device.
Therefore, WaRO suggests installing monitoring wells around this pond. A map with proposed well locations is
attached to this report. Also, there have been limit exceedances at the existing wells at the high-rate infiltration
basin. As a result, WaRO issued a NORR on 11/15/19 and is currently working with the permittee to investigate
the exceedances. Depending on the results of this ongoing investigation, additional wells may be required at the
high-rate infiltration basin.
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: See comment in Item II.7 above.
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary): The coordinates for the existing monitoring wells
are in BIMS. When the proposed wells are installed the coordinates should be provided.
Monitoring Well Latitude Longitude
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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: The majority of the NDMR violations in BIMS appear
to be related to reporting issues. A NORR was issued on 11/15/19 as a result of the GW exceedances as discussed
above in Item II.7. An NOV was issued as a result of observations of inadequate operation and maintenance
made during an inspection on 8/19/20.
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: New permit conditions are being requested to address operation and maintenance issues
discovered during recent inspections. These conditions are presented in Item III.4 below.
14. Check all that apply:
FORM: WQROSSR 04-14 Page 2 of 4

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.)See
comments under Item II.12 above.
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
GW issues and is recommending new permit conditions to address operation and maintenance issues.
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, 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: The permit should be able to be issued provided the revisions suggested below are
included.
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
The UV system was observed to be fully operational during the recent
Schedule Condition I.5
inspections documenting that the requested repairs have been made.

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
The calibration of the irrigation equipment, required by current Condition III.8,
has not been performed as of the latest inspection. Therefore, WaRO requests a
New Schedule Condition
new Schedule condition requiring this to be completed within 60 days if
issuance of a new permit.
FORM: WQROSSR 04-14 Page 3 of 4

During the latest inspection the permittee could not provide documentation that
the signage or resident notification, required by current Condition III.14, for
New Schedule Conditionreclaimed water irrigation onthe golf course had been performed. Therefore,
WaRO requests a new Schedule condition requiring this to be completed within
60 days of issuance of a new permit.
During the latest inspection the staff gauge at the high-rate infiltration basin,
required by current Condition III.17, was found to be damaged and not
New Schedule Condition
functional. Therefore, WaRO requests a new Schedule condition requiring the
necessary repairs to be completed within 60 days of issuance of a new permit.
During the latest inspections, extensive woody vegetation was observed on the
banks of both the high-rate infiltration basin and reclaimed wet-weather storage
New Schedule Condition pond, in violation of current Condition III.18. Therefore, WaRO requests a new
Schedule condition requiring the necessary repairs to be completed within 60
days of issuance of a new permit.
During recent inspections the ORCs have noted that the high-rate infiltration
basin is not functioning as designed. Therefore, WaRO requests a new
New Schedule Condition Schedule condition requiring the permittee to provide a plan within 60 days of
issuance of a new permit for cleaning/rehabilitation of the basin as required by
current Condition III.23.
As discussed in Item II.7 above, WaRO suspects that the wet-weather storage
pond is acting as an infiltration device. Therefore, WaRO requests a new
Schedule condition requiring the installation of monitoring wells around the
New Schedule Condition
pond and issuance of a new Site Plan be completed within 60 days of issuance
and Attachment C
of a new permit. A map showing potential well locations are being provided
with this staff report. Also, Attachment C should be revised to include the new
monitoring wells.
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:
Signature of regional supervisor:
Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
WaRO
adequate maintenance at the facility.

FORM: WQROSSR 04-14 Page 4 of 4