WQ0002503_Staff Report_20220207

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Environmental
Quality
State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0002503
Attn: Chloe Lloyd Facility name: Frit Car
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: 2/1/22
b. Site visit conducted by: R. Sipe
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Chris Barnes and their contact information: (252) 638 - 2675 ext.
e. Driving directions: N/A, 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: Danny Hornbeck Certificate #: SU26718 Backup ORC: Chris Barnes Certificate #: Pending
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: Sump tank with oil skimming system, clarifier with mixer for pH adjustment
with lime, drying beds for solids from clarifier.
Proposed flow: 867 GPD
Current permitted flow: 867 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,
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DocuSign Envelope ID: A44FDF89-C14F-40A9-9BC0-9101B654039B
etc.) The facility has not irrigated effluent since 2018. It is being shipped offsite for disposal by Shamrock
Environmental. Solids from the drying beds are transported to Tuscarora Landfill for disposal.
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: Spray field appeared 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.)? ❑ 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: The facility has performed a
groundwater investigation of exceedances at the existing monitoring wells as a result of an NORR issued by
WaRO. The conclusions of the study included that wells MW2 and MW4 were not correctly located with respect
to the compliance and review boundaries and that MW3 was not constructed correctly (too shallow). They have
installed 3 new wells (MW5, MW6, and MW7) during investigation to address this issue. WaRO wishes to revise
the groundwater monitoring network to include these wells and existing well MW1. We also request that MW2,
MW3, and MW4 be temporarily abandoned.
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: It was discovered during the inspection that the sump pump at the 1900-gallon sump was
been replaced with a bladder pump when the original pump stopped operating
10. Were monitoring wells properly constructed and located? ❑ Yes ® No ❑ N/A
If no, please explain: See the comment under Item II.7 above.
11. Are the monitoring well coordinates correct in BIMS? n Yes ® No ❑ N/A
If no, please complete the following (expand table if necessary): Below are locations for the recently installed
wells to be included in the groundwater monitoring network described in Item 11.7 above.
Monitoring Well
Latitude
Longitude
MW5
35° 9'
17.387"
-77°
1'
54.984"
MW6
35°9'
15.695"
-77°
1'
54.660"
MW7
35°9'
13.896"
-77°
1'
58.295"
°
, „
°
, „
°
, „
Of
„
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: There have been recurring occasional exceedances of
metals at some of the monitoring wells. WaRO issued the facility an NORR and the facility undertook an
investigation which revealed elevated natural levels of metals at the site and that the sampling techniques being
used were also affecting metal concentrations in samples. The investigation also determined that the existing
groundwater monitoring network was not adequate with respect to the compliance and review boundaries. WaRO
wishes to revise the groundwater monitoring network to include the recently installed wells. (See comment under
Item II.7 above).
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 the comments under Items II.7 and II.11 above.
14. Check all that apply:
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❑ No compliance issues ❑ Current enforcement action(s) Currently under JOC
Notice(s) of violation(NORR) n Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) See the
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? See the comments under Item II.12 above.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No n 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:
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
Facility Description
The description should be revised to replace the sump pump at the 1900-gallon
sump with a bladder pump which reflects the changes made at the facility
Attachment A
WaRO wishes to include Iron into the effluent monitoring requirements because
it has been determined to be a constituent of concern in groundwater around the
spray field. The facility is already testing the effluent for Iron.
Attachment C
WaRO wishes to revise the groundwater monitoring network by including
MWS, MW6, and MW7, which were installed during the groundwater
investigation, and temporarily abandoning MW2, MW3, and MW4 so that the
network is better positioned with respect to the compliance and review
boundaries.
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
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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: autzsta g1.44, 5;,tc
Signature of regional supervisor: g'x T
2/7/2022
Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
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