WQ0002520_Staff Report_20220112

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Lauren Plummer
From: Will Hart
Washington Regional Office
Application No.: WQ0002520
Facility name: Town of Bath WWTF
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:
b. Site visit conducted by:
c. Inspection report attached? ❑ Yes or ❑ No
d. Person contacted: and their contact information:
e. Driving directions:
2. Discharge Point(s): NA
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: NA
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: Garland Grant Certificate #: Backup ORC: Randy Merrill Certificate #:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or n No
If no, please explain:
Description of existing facilities: Facility description should be modified to remove "7.1 acre high -rate
infiltration basin." Due to failure of the basin to infiltrate treated effluent.
Proposed flow:
Current permitted flow:
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.)
FORM: WQROSSR 04-14 Page 1 of 4

3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? n Yes or ® No
If no, please explain: Sprayfield (IR-1) is performing as usual; it has been determined that IB-1 (high rate
infiltration basin) is not assimilating treated effluent.
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: Description needs to be modified to remove "7.1 acre high -rate infiltration basin" due to
failure to assiilate treated effluent.
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):
Monitoring Well
Latitude
Longitude
O ,
If
0
/
„
O ,
If
0
/
„
O ,
If
0
/
/,
O ,
If
0
/
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O ,
If
0
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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: The facility is experienceing difficulties meeting
limits, for a variety of reasons.
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? n Yes or ® No
If yes, please explain:
14. Check all that apply:
n No compliance issues n Current enforcement action(s) n 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? There does not exist one simple solution to Bath
WWTF noncompliance as there have been various causes.
Have all compliance dates/conditions in the existing permit been satisfied? n Yes n 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:
FORM: WQROSSR 04-14
Page 2 of 4

16. Possible toxic impacts to surface waters: NA
17. Pretreatment Program (POTWs only): NA
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
II.6., II.7., and II. 12. a.
address Compliance
Boundary, Review
Boundary, and setbacks for
IB-1.
IB-1/PPI 001 should be removed from the permit; connections have been
terminated.
III. 12., III. 13., III. 15. and
III. 16. remove references
to infiltration.
IB-1 should be removed from the permit.
IV. 6., IV. 7., and N. 14. f.
references to infiltration.
IB-1 removal
V. 1., V. 2., and V. 3. refer
to infiltration facilities.
IB-1 removal
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Close IB-1 by breaching
dike at ground level within
one year of permit
issuance.
Irrigation Basin IB-1 failed to adequately assimilate treated effluent; pond is
filling with precipitation and periodicaly needs to be pumped to lower water
level.
5. Recommendation: n 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
n Issue
n Deny (Please state reasons: )
FORM: WQROSSR 04-14
Page 3 of 4

Wai H4 41
6. Signature of report preparer:
Signature of regional supervisor: R"� Te.a.�ik4cl
Date:
1/12/2022
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The Town of Bath stopped using high -rate infiltration basin IB-1 when it was determined that the basin was not
infiltrating treated effluent and piping to IB-1 was truncated. We would like to take the oportunity to clean up the
permit by removing all references to high -rate infiltration. The facility has struggled with compliance during the
permit cycle for a variety of reasons, including, but not limited to, seasonal changes, equipment problems, and late
2020/early 2021 both opertors had simultaneous health scares.
Please also remove Attachment A PPI 001 and remove IB-1 from Attachment B
FORM: WQROSSR 04-14 Page 4 of 4