WQ0000795_Staff Report_20220228

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Staff Report
To: NPDESUnitNon-Discharge UnitApplication No.: WQ0000795
Attn: Lauren Plummer Facility name:Town of Surf City WWTF

From: Helen Perez
WilmingtonRegional Office
Note: This form has been adapted from the non-discharge facilitystaff reportto 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: 5/11/2021
b.Site visit conducted by: Helen Perez
c.Inspection report attached? Yes or NoUploaded to Laserfiche
d.Person contacted: Zack Butlerand their contact information: [phone]ext.
e.Driving directions: 173 Sarge Martin Road, Holly Ridge NC
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
1.Facility Classification: (Please attach completed rating sheetto 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 theplans and site maprepresent 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 04-14Page 1of 5

6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7.Are there any setbackconflictsfor 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: Zack Butler Certificate #:1003663 Backup ORC: Steve Smith Certificate #:994884
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: Same as current permit except for modifications of the replacement of existing
band screen with mechanical bar screen and the addition of a new mechanical bar screen have been completed. A
partial certification was submitted on 1/20/22.
Proposed flow: No new proposed flow.
Current permitted flow: Monthly Average: 1,100,000 GPD Annual Average: 767,800 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.)
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: See section III.2
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

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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
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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: During this permit cycle, one NOD was issued for
irrigation exceedances for one field on the Juniper Swamp site in 2/2019. GW 59s show some TDS and chloride
limit exceedances in MW #3 and #4 located on the Sarge Martin fields at plant site.
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? See Additional Regional Staff Review Items at
the end of report.
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): N/A

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 supervisor:
Date:

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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

-Discharge Permit WQ0000795. The
Town is currently working on the modifications listed in the current permit. The replacement of the existing band-
screen with a mechanical bar screen and the addition of a new mechanical bar screen has been completed (partial
certification submitted on 1/20/2022).
The permit has a monthly average flow limit of 1,100,000 GPD and an annual limit of 767,800 GPD. Although the
plant has a treatment capacity of 1,500,000 GPD, it does not reflect the limiting disposal of 767,800 GPD. Prior to the
permit issued on 1/11/2018, the Sarge Martin Fields had seasonal limit restrictions that were not able to be calculated
by BIMS and flagged for application violations. Since that seasonal limit was removed, the facility has shown non-
compliance for irrigation limit exceedances both on the Sarge Martin and Juniper Swamp sites and, for most of 2021,
on the Juniper Swamp site. Inspections of the sites by WIRO show the fields to be well maintained and operated in
spite of the exceedances, and parameters tested are well below the effluent limits. The Town has been working with
the WIRO and evaluating non-discharge and discharge disposal options with the WIRO and CO.

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