WQ0000798_Staff Report_20210811

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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.: W00000798
Attn: Lauren Plummer Facility Name: Shallotte WWTF
From: Bryan Lievre
Wilmington 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: 6/23/2021 (w/ 6/30/21 follow up)
b. Site visit conducted by: Bryan Lievre, Morella Sanchez -King & Tyler Benson (& Patrick Mitchell)
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Tim Webb and their contact information: [phone] ext.
e. Driving directions: 349 Forest St Ext., Shallotte, NC 28470. From Wilmington: US Hwy 17S then right onto
Frontage Rd, right onto Forest St Ext NW and facility will be on left
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS — N/A
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Michael Garrity Certificate #: 1006246 Backup ORC: Ricky Babson Certificate #: 992603
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: A 175,000 gpd and a separate 325,000 gpd wastewater treatment and irrigation
facilities. Current permit issued 9/24/2019 properly describes system and for an itemized list refer to 6/23/21
Inspection Report, copy attached.
Proposed flow: 500,000 gpd
Current permitted flow: 500,000 gpd
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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.). Although the current facility is only perated while staff are present on -site, neither of the two existing
duplex pump stations for spray fields are equipped with visual or audible alarms, neither is connected to telemetry
and backup power is not available for either of these stations. However, flow to all the lagoons can be pumped to
the West Brunswick Water Reclamation Facility Permit WQ0023693) by activating pumps within the transfer
station located at the Shallotte WWTF and these pumps have an emergency generator and the transfer station is
equipped with telemetry.
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:
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
C I II
C I II
C I II
C I II
C I II
C I II
C I II
C I II
C 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: No violations issued during the current permit cycle
(i.e. since 9/2019,). Although Monitoring and Reporting Violations were listed in BIMS, violations were reported
as a result of reporting errors on forms (some due to fact that Outfall Numbers were changed on most recent
permits.), due to no sampling due to holidays, some parameters were reported late, etc. When Monitoring
Violations were observed the system reportedly did not irrieate and for this and the above reasons- no further
actions were deemed necessary.
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:
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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: N/A
17. Pretreatment Program (POTWs only):
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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
Please See Section V
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,IPLgAW,,, reasons: )
6. Signature of report preparer: -1
Signature of regional supervisor:
Date: 8/11/2021
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Please note that an attempt was made by WiRO staff to review the permit modification application. Activities performed
in review of the application have included review of past inspections of the wastewater treatment facility (WWTF),
performing an updated inspection of the WWTF, review of past violations and a cursory review of the permit modification
application information. The WWTF inspection included a secondary inspection with Patrick Mitchell from the WSRO in
order to corroborate in -situ statements regarding surficial soil descriptions and other observable site conditions.
Staff from WiRO along with some assistance from Patrick Mitchell (WSRO) have performed a cursory review of the
approximately 2,332 pages within the permit modification application, dated 6/3/2021. In correspondence, dated
6/28/2021, a request was made to provide a more organized permit application and make the application specific to this
project, without information specific for the Mulberry Branch WRF (Permit Application WQ0042579). As a result of the
request, the applicant submitted a revised permit modification application with approximately 1,734 pages (1597 pages of
forms, reports and text and approximately 137 pages of plans), dated 7/25/2021. Although a cursory review of the later
permit application was also performed, the document was found to still contain a substantial amount of information
relevant to the proposed Mulberry Branch WRF application and an inordinate amount of time was required to ascertain
information relevant information regarding this project.
With the review provided, please see the comments below:
1. As indicated on Form WWIS 06-16, Item IV. 8., a small portion of a proposed spray field is located in a Zone A
100-year flood plain, which is illustrated in Plan Sheet C8. Although an attempt was made by the applicant to
justify allowing the installation of spray heads in this ar , our office would prefer the applicant to find other
suitable area(s) which are not within the flood plain.
2. Form WWIS 06-16, Item V. 3. included a statement (within the last sentence) that "An additional drain line
connecting from Upper Lagoon No. 1 to Lower Lagoon No. 3 will be used for maintenance purposes and is not
intended to be used to bypass Upper Lagoon No. 2."
The above statement was included within the application originally provided 6/3/2021 and the original Plan Sheet
C16 illustrated a pipe configuration to substantiate the proposed configuration. During the 6/23/2021 site
inspection, concerns were provided to the applicant and their engineer about the proposed pipe configuration. Of
particular concern was the location of the discharge pipe from Lagoon No. 1 in relation to the inlet pipe to Lagoon
No. 1. A statement was made to all regarding the significant amount of short circuiting which would likely occur
in the event Lagoon No. 2 was taken off line and discharge from Lagoon No. 1 drains to Lagoon No. 3.
The current application, dated 7/25/21 provided the same statement on Form WWIS 06-16, Item V. 3., and a
revised Plan Sheet C16 which no longer illustrates a pipe leading from Lagoon No. 1 to Lagoon No. 3. It is
uncertain how Lagoon No. 1 will drain directly to Lagoon No. 3 if Lagoon No. 2 is needed to be temporarily
taken out of service. Also, how will the facility operate if Lagoon No. 1 is needed to be taken out of service (e.g.
for solids removal, etc.)? Please ask for clarification of how the facility will operate in the event any of the
lagoons are needed to be temporarily taken out of service for maintenance or other activities.
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3. Form WWIS 06-16, Item V. 11. a. provides a volume of 3.125 gpd for the mechanical bar screen. The
specifications indicate the unit should have a peak design flow of 3.125 mgd, but please have the
engineer/applicant confirm on the application.
4. The revised application of 7/25/21 referenced Plan Sheet C53 within Attachment 1. Our copy of the plans did not
contain Sheet Pan C53. Please provide a copy of the missing sheet or revise accordingly. v
5. The existing system utilizes two separate duplex pump stations to spray all the fields for the WWTF. One pump
station utilizes two 400 gpm submersible pumps and the other station utilizes two 820 vertical turbine pumps. It
is understood that the submersible duplex pump station will be de -activated and the duplex turbine pump station
will provide flow to all the spray fields. Information could not be located within the application to demonstrate
the suitability of the turbine pumps for the additional spray fields. At a minimum, head loss calculations should
be provided for the additional spray fields, pump curves to demonstrate the appropriateness of the pumps,
specifications for the additional (existing) spray heads to be incorporated with the turbine pumping system, etc.
In regards to a review of the hydrogeological information, Patrick Mitchell provided comments, as noted below.
Below are the items that either require additional information be provided or that the applicant's consultants needs to
clearly point out the location of items in the two giant, overlapping application packages that they submitted. To add to
the confusion, the hydrogeologist & soil scientist also provided report information and data from previous project work
(some unrelated to this project) which has made it difficult to determine if minimum evaluation criteria specific to this
proposed irrigation area and project is present. Again, I am not saying with 100% confidence that the info is not present
somewhere in the 4,000 pages of reports, maps and data, just that I cannot find it or it is not clear, and in some cases there
are even some conflicting information that was provided between prior project reports. If they had taken only the pertinent
info from prior site evaluation work conducted for other projects and clearly identified or summarized it in an updated
report specific to this project... it would have really helped and sped things up and maybe prevented some add info
requests.
There are also a couple of recommendations below for the final permitting for the Attachment B.
A. I was unable to determine the following items related to the soils evaluation and hydraulic conductivity
measurements in the application package that was submitted:
o Was there a sufficient number of hydraulic conductivity measurements conducted for each soil series
mapped within the proposed spray fields? There are contrasting soils present within the proposed
irrigation areas which may have more restrictive layers present. Was a site map provided that shows the
proposed spray fields, soil series map layer and the locations of all hydraulic conductivity measurements?
proposed irrigation area related to the soils mapped in this area.
o Were the hydraulic conductivity measurements conducted within the most limiting horizon(s) and/or were
sufficient measurements conducted to determine which horizon is the most limiting layer for each soil
series present in the proposed spray fields? Was a complete soil profile description provided for each
hydraulic conductivity measurement point to a sufficient depth below the measurement point? Request
complete soil profile description be provided for each hydraulic conductivity measurement point.
o Were the hydraulic conductivity measurements run until they reached a steady state for each test
conducted within each restrictive horizon for each soil series? Request field measurements and a
summary of measurements for each soil series present in the proposed irrigation area.
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Please request that this information either be provided or that the applicant provide a written response to each
item and clearly point us to this information in the existing application. If information is provided, please request
that this specific information be clearly provided without resubmitting the entire package. This information is
required to determine if the minimum required data and sufficientidata;hhas b n provided in the application. The
Division's Soil Scientist Evaluation Policy provides the consultan expectations and guidance on when
more than the minimum is expected.
B. Kureb soils appears to be the dominant soils present in the proposed new spray field. However, the edges of the
field do contain more limiting soils and inclusions of these soils or variants of these soils are possible within the
new spray field. While a maximum annual loading rate of 52.0 inches/year may be acceptable (if the
additional information provided supports the initial review), it is recommended that nothing greater than
52.0 inches/year should be accepted without proper justification that considers the contrasting soil
inclusions and the more limiting soils present on edges of the field.
C. In the application they listed a maximum hourly loading rate of 2.0 inches/hour for the proposed new irrigation
field. Based upon observations of the proposed site and soil characteristics, it is recommended that the
permitted maximum hourly loading rate should not be no more than 1.0 inches/hour in the Attachment B
of the permit. The recommendation is due to the presence of inclusions of Leon soils with evidence of seasonal
high water table observed at 18 to 30 inches deep and additional more limiting soils mapped along some edges of
the proposed irrigation area. A loading rate of 2.0 inches/hour could result in ponding and runoff at times due to
the presence of shallower water table and more hydraulically restrictive Bh and/or Bt soil horizons, along with the
likely presence of other limiting soils along edges.
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