WQ0000889_Staff Report_20210920

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.: WQ0000889
Attn: Lauren Plummer Facility name: PCS Phosphate WWTP
From: Will Hart
Washington 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: 08/25/2021
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: J Chandler Stroud and their contact information: ext.
e. Driving directions: NC Highway 306, Aurora
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: L Dale Davis Certificate #: 1004832 Backup ORC: Raleigh Lee Certificate #:10792
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
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:
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:
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:
FORM: WQROSSR 04-14 Page 1 of 4

11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
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: NDMR/NDAR are complete and accurate with no
violations to speak of. GW-59 have historically exhibited nitrate concentrations above 02L Groundwater Quality
Standard in MW-2, concentrations reported for MW-2 are now below 10 mg/L.
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: The system uses uV disinfection with a chlorine tablet dechlorinator as a backup
should the uV malfunction. Chlorine is included in the Attachment A schedule even though it is not used at
the facility: each month BIMS flags a violation for missing chlorine. Please suspend monitoring for chlorine
or change the frequency to per event in order to prevent this in the future.
WaRO recommends conditions in the
14. Check all that apply:
❑ No compliance issues
® Notice(s) of violation
t to be similar to the
❑ Current enforcement action(s)
❑ Currently under SOC
is of the NORR.
❑ Currently under JOC
❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) WaRO
is sending PCS/Nutrien a Notice of Regulatory Requirements for the groundwater violations that are occurring in
MW 2 at the review boundary. The wwtp has consistently disposed of effluent with Nitrates at high
concentrations (above 10 mg/1)
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? Knowledge of the compliance problems were
made aware with the renewal of the permit.
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:
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 specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Within ninety (90) days of issuance of this permit,
Groundwater contamination of Nitrates have been
the permittee shall submit a report on how the
detected in MW 2 at the review boundary and the
facility meets 15A NCAC 2L .0106(f).
effluent is consistent) over 10 m /l.
Within twelve (12) months of issuance of this
Groundwater contamination of Nitrates have been
permit, the permittee shall submit a report on how
detected in MW 2 at the review boundary and the
the facility meets 15A NCAC 2L .0106(d).
effluent is consistently over 10 mg/l.
Within twelve (12) months of issuance of this
permit, the permittee shall submit a corrective
Groundwater contamination of Nitrates have been
action plan which addresses the restoration of
detected in MW 2 at the review boundary and the
groundwater in accordance with 15A NCAC 2L
effluent is consistently over 10 mg/l.
.0106(h).
FORM: WQROSSR 04-14 Page 2 of 4

3. 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: )
4. Signature of report preparer:
Signature of regional supervisor: Plow T "
9/22/2021
Date:
FORM: WQROSSR 04-14 Page 3 of 4

IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The facility is well maintained and well operated. The wastewater staff is generally proactive, when issues arise
efforts are made to address them quickly. The system has historically struggled with high nitrate concentrations in
effluent. When exceedences of Groundwater Quality Standards were observed at the Review Boundary PCS began to
investigate the issue. In July of 2019, when Groundwater Standard violations persisted, operation of the closest
irrigation field was terminated, except for approximately one week in late Sep 2020. Nitrate concentrations at MW-2
have spiked at concentrations nearlyequal to effluent concentrations, in the absence of effluent irrigation, and
returned to below 10 mg/L. A chemical feed was added to the treatment system,possibly mid 2020 based on effluent
concentrations. Details of PCS' efforts/investigation into the treatment plant and hydrogeology of the wMV facilily are
forthcoming.
FORM: WQROSSR 04-14 Page 4 of 4