WQ0034603_Staff Report_20220330

;s 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.: WQ0034603
Attn: Lauren Plummer Facility Name: Seqirus, Inc.
County: Wake
From: Dorothy M. Robson
Raleigh Regional Office
Note: This form has been adapted from the non -discharge facilily 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: 3/28/2022
b. Site visit conducted by: Dorothy M. Robson and Vanessa E. Manuel
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: AnneMarie Baese and their contact information: 919 324 - 4910 ext.
e. Driving directions: N/A
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Sub -basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? ❑ Yes or ❑ No
If no, explain:
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? ❑ Yes ❑ No ❑ N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? ❑ Yes ❑ No ❑ N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 1 of 5

6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? ❑ Yes ❑ No ❑ N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? ❑ Yes ❑ No ❑ N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? ❑ Yes ❑ No ❑ N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
ORC: Certificate #: Backup ORC: Certificate #:
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: The Reclaimed Water System at Seqirus Inc. is designed and installed to
conduct spray irrigation of reclaimed water provided by Utley Creek (Town of Holly Springs) Permit #
WQ0032289. The facilities waste water is not treated onsite, but instead follows the sanitary sewer to Utley Creek
Facility.
Proposed flow: 301 GPD
Current permitted flow: 33,400 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,
etc.) Please update the persons associated with the permit. See attached sheets.
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: The system no longer utilizes cooling tower make-up and boiler wash down water. The
remainingdescription escription should remain the same.
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 2 of 5

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
U I II
C I II
O I II
C I II
O I II
C I II
O I II
C I II
O I II
C I II
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 facility has been submitting NDARs on a monthly
basis that describe amount of monthly flow and description of time, rate volume applied, and zones of irrigation at
the facility. However. NDARs are not reauired. and reclaimed water flow received / irrieated are to be reported on
NDMR forms.
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:
14. Check all that apply:
® 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.)
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?
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:
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 5

IV. 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
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
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 supery
Date: 3/30/2022
UaAWSa f.
-B2916E6AB32144F...
FORM: WQROSSR 04-14 Page 4 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The DWR, RRO performed a compliance evaluation inspection on March 29, 2022, and was accompanied by Bob
Rezek (EHS Director), Anne Marie Baese (EHS Specialist), Ellen La Russo (EHS Specialist), and Bill Smith with
Ideal Landscaping. Bill Smith maintains and operates the reclaimed system for Seqirus Inc.
Based on the Site Evaluation Inspection, the following was observed:
L The onsite records were reviewed and were adequate and in compliance. However, the facility has been reporting
NDAR monthly report with flow instead of the NDMR monthly report. Going forward the facility will submit
flow on the NDMR Monthly forms. NDARs can be optional to submit every month.
2. The facility confirmed that all domestic and industrial wastes are sent to the sanitary sewer, which are maintained
by Utley Creek (Town of Holly Springs -Permit # WQ0032289). However, the facility does on -site pH
neutralization (between 5-9 Units) prior to disposal to the sanitary sewer.
3. The facility irrigates the surrounding landscape grounds with reclaimed water from the Town of Holly Springs
Facility. The current acreage of 1.30 acres is irrigated with the reclaimed water. An additional acreage of 23.55
acres has been used in the past and may be used again in the future.
4. Signage was observed in areas throughout the facility grounds. However, the signage is faded or to far apart to be
noticed in areas of irrigation. New signage should replace the old signs of reclaimed water. In addition, more
signage should be placed in high traffic areas.
5. All exposed piping and appurtenances shall be color coded, purple (Pantone 522) in accordance's to the permit
(Section IL Performance Standards, 5.) If faded or missing, please replace or paint accordingly.
6. During the walk of the irrigation areas, no compliance issues were noted except for some minor repairs. Ideal
Landscaping manages the landscaping needs as well as the reclaimed water system. Bill Smith was
knowledgeable about how to properly maintain and operate the system to prevent ponding and runoff. They have
taken measures to direct spray away from stormwater BMPs and limit spray times on areas prone to pond or
runoff. Ideal sets irrigation to occur before sunrise to reduce the effects from wind speeds and personnel traffic
times.
7. There were three control panels and rain gauges throughout the facility grounds. They were located next to tall
buildings. The buildings may interfere with the rain gauges and would be better located in areas not effected by
the building. Bill Smith stated that he monitors the rain gauges and has not observed any issues with the gauges
near the buildings.
Based on the records review and site inspection, this facility appears to be compliant and well managed at this time.
FORM: WQROSSR 04-14 Page 5 of 5