WQ0002708_Staff Report_20221213

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 4

To: NPDES Unit Non-Discharge Unit Application No.: WQ0002708
Attn: (Name of Reviewer in Raleigh) Facility Name: City of Raleigh-
Wrenn Road
County: Wake
From: Dorothy Robson
Raleigh Regional Office

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 12/22/2021
b. Site visit conducted by: Dorothy M Robson and Molly Nicholson
c. Inspection report attached? Yes or No
d. Person contacted: Jesse Walker and their contact information: 919-996-3171 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: NA
Current permitted flow: NA
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:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
DocuSign Envelope ID: 30689266-837D-4028-9950-FAA8E0F958F1
FORM: WQROSSR 04-14 Page 2 of 4
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: Steve Honeycutt Certificate #: 988689 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: Lagoon and wastewater spray irrigation
Proposed flow: NA
Current permitted flow: 662,885 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: New Wells have been installed (PMW-1, PMW-2, PMW-3, and PMW-4). WQROS
RRO has already reviewed and commented on the report attached. These wells should be sampled at the
same frequency as the ones in the permit. PMW-1 and PMW-2 are to be used for upgradient and
background reporting and PMW-3 and PMW-4 are to be used for compliance.
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:
DocuSign Envelope ID: 30689266-837D-4028-9950-FAA8E0F958F1
FORM: WQROSSR 04-14 Page 3 of 4
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary): The new wells are listed in Easting and
Northing and don’t seem to be plotted correctly in the report. BIMS only has lat./long. For 4 wells.
Monitoring Well Latitude Longitude
PMW-1 ○ ′ ″ - ○ ′ ″
PMW-2 ○ ′ ″ - ○ ′ ″
PMW-3 ○ ′ ″ - ○ ′ ″
PMW-4 ○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
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: Currently there are still violations of groundwater
exceedances in down gradient wells.
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: Groundwater violations are in BIMS, but they have not been verified and no NOVs
issued.
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.) I have
attached our responses to Raleigh Water concerning the background value for the facility. After review of
the report, we agreed to 0.057 mg/l instead of 0.05mg/l for manganese. This should be reflected in the
permit.
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: Not to date
17. Pretreatment Program (POTWs only): N/A
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

DocuSign Envelope ID: 30689266-837D-4028-9950-FAA8E0F958F1
FORM: WQROSSR 04-14 Page 4 of 4

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:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

DocuSign Envelope ID: 30689266-837D-4028-9950-FAA8E0F958F1
12/13/2022