WQ0022810_Staff Report_20220809

DocuSign Envelope ID: 2797EOAB-4D18-4292-BCA7-OCB76A11DBFF
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.: WQ0022810
Attn: Cord Anthony Facility name: 166 Democracy Pl. SFR
From: J. Chris Smith
Raleigh 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 applicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: August 2, 2022
b. Site visit conducted by: Chris Smith
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: N/A and their contact information: (_) - ext.
e. Driving directions: 166 Democracy Place, Apex, NC 27523
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
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: 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:
Proposed flow: 600 gud
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.)
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DocuSign Envelope ID: 2797EOAB-4D18-4292-BCA7-OCB76A11DBFF
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ❑ Yes or ❑ No ® N/A
If no, please explain: System has not been constructed vet.
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: Permit modification is for an unconstructed system.
Is the residuals management plan adequate? ❑ Yes or ❑ No ® N/A
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ® No
If no, please explain: New system design and significant changes to the site.
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: New system design.
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 (ex and table if necessary):
Monitoring Well
Latitude
Longitude
O l 11
O 1 if
O / //
O I if
O / //
O I II
O l lI
O l if
O / //
O / //
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ❑ Yes or ❑ No
® N/A
Please summarize any findings resulting from this review:
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: N/A
17. Pretreatment Program (POTWs only): N/A
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III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ® Yes or ❑ No
If yes, please explain: See comments
2. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request: See comments
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
DOcu Signed by:
❑ Deny (Please state reasons: ) (,I� ViS SM&
6. Signature of report preparers DocuBi ned by: 1D427000DBE94E9...
Signature of regional supervisor: I vo t,SSa . h h,d
Date:
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IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Although the application is put together in an organized and thorough manner, this a problematic site and proposed
disposal area solution for a number of reasons.
An extremely large amount of fill material will need to be added to the disposal area to provide the minimum 12
inches of separation between the soil/application surface and the Seasonal High Water Table (SHWT) depth. The
addition of fill materials to a site to achieve the minimum 12 inches of separation between the disposal surface and the
SHWT is generally only suitable when there is naturally occurring mineral soil present in the topsoil horizon and the
slopes are less than 15%. All the topsoil in this area has been removed. It is a very real possibility that the
subsoil/fractured rock/parent material layer that is now the surface of the proposed disposal area will cause lateral
flow of applied effluent resulting in inadequate wastewater treatment and run off from the disposal area.
The following observations were made during the site visit:
The surface texture governing the instantaneous loading rate described in the application (Sandy Loam in narrative;
Silty Clay Loam in profile descriptions) was observed in a few locations (mostly in ponded areas) in the proposed
disposal field, but much of the area has a coarser surface texture (potentially indicating significant erosion) with the
presence of expansive clays just below the surface. These areas were also very compacted. There were 2 areas in the
field that had ponded water on them indicating a lack of infiltration, the presence of expansive clays, and possibly a
perched water table. As mentioned, adjacent areas were very compacted and completely dry to at least several inches
depth also indicating a lack of infiltration and probable runoff. Multiple large rills were noted on the more sloped
areas of the disposal field. The slopes in these areas were estimated to be greater than 15%. In several places the rills
have uncovered what appears to be saprolite/parent material visible 2-3 inches below the surface.
Many of the observations noted above signal a difficult time to be had stabilizing the proposed fill and establishing
vegetative cover. Additionally, a large amount of sediment is leaving the site and entering an intermittent stream and
pond on the property and adjacent properties. There is an ephemeral stream that follows the northern property
boundary that discharges into the intermittent stream mentioned.
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DocuSign Envelope ID: 2797EOAB-4D18-4292-BCA7-OCB76A11DBFF
This office recommends that the following issues be addressed in an additional information request:
1. The differing textures of the native material (subsoil/saprolite/fractured rock/expansive clays) and fill material
will make lateral flow over the native material very likely. The application states that the fill material should
be incorporated into the native material to a depth of 5-6 inches. This may not be enough mixing to integrate
the fill and native materials. Additionally, fractured rock/saprolite/parent material was observed just below the
surface in many parts of the proposed disposal area that may significantly hinder incorporation. How does the
applicant plan to ensure that incorporation/integration of the fill material with the subsoil/parent material
native to the site will be done in a manner that prevents lateral flow between the fill material and the native
material?
2. There are currently multiple large rills in the proposed disposal area. This indicates a high erosion potential.
The typical prescribed texture for fill materials also has a high erosivity potential. Rills indicating preferential
flow in the disposal area raise the concern for cross connection between incompletely treated wastewater and
local surface waters and land not included in the proposed disposal area. How does the applicant plan to
address the high potential for erosion and migration of incompletely treated wastewater from the disposal
area?
3. Following on the previous question/observation; how does the applicant plan to ensure the establishment and
maintenance of competent vegetative cover on the easily eroded slopes of the proposed disposal area?
4. Increasing the level of treatment to meet TS-11 or Reuse standards would lessen the impacts of any effluent
that might leave the disposal area before sufficient soil contact/treatment time has been achieved and/or could
allow the effluent to be used for irrigation. Has the applicant considered this option?
Note: If the currently proposed non -discharge system is determined to be inadequate, the presence of ephemeral
and intermittent streams on the property suggests the possibility of a NPDES permitted treatment system. The
applicant may want to consider this option.
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