WQ0002005_Staff Report_20230907

DocuSign Envelope ID: 519ECB5D-B76B-4072-9F80-7D570657627E
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.: WQ0002005
Attn: Erick Saunders Facility name: House of Raeford -Rose Hill
From: Helen Perez
Wilmington Regional Office
Note: This form has been adapted from the non -discharge fg acili , 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: 02/21/2023
b. Site visit conducted by: Helen Perez
c. Inspection report attached? ❑ Yes or ® No Uploaded to Laserfiche
d. Person contacted: Mason Drew and their contact information: (910) 298 - 1813 ext.
e. Driving directions:
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. 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 Pagel of 5

DocuSign Envelope ID: 519ECB5D-B76B-4072-9F80-7D570657627E
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: 14ason Drew. Certificate #: _ Backup ORC: Matt Sutton Certificate #:1006243
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
Proposed flow: N/A
Current permitted flow: 800,000 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:
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:
FORM: WQROSSR 04-14 Page 2 of 5

DocuSign Envelope ID: 519ECB5D-B76B-4072-9F80-7D570657627E
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
O l 11
O I //
O / //
O I It
o
o , „
O / //
O I It
O I I/
O I /I
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: There have not been any NDMR/NDAR violations
in this permit cycle. The MWs located around the 2 facultative lagoons (MW 7, 8 10,11) have had
ammonia and TDS exceedances. MWs 13 & 14, located on the north adjacent property, have had ammonia
and TDS exceedances. MW 4, located just south of the storage lagoon has also had ammonia and TDS
exceedances. The MWs located around the irrigation fields have no exceedances. The current permit
(Section II.6 & 7) only state a compliance and review boundary around the disposal system, not the
facultative lagoon system.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
The Permittee requested reduced monitoring of pH and TRC from 5 times/week to 2 times/month. The
current permit states a frequency of "per Event", not 5 times/week. The ORC stated during the inspection
that they spray approximately 3 times a week and use a contract lab to do the field testing for them. If the
frequency of these parameters cannot be reduced to 2/month, I suggested to the ORC that they could get a
,field lab certification and test themselves.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ® Yes or ❑ No
If yes, please explain: The 3 x Year same mg othe monitoring wens in the Curren perms is March, July
and November but is listed in BIMS as February, June and September. Please change to February, June
and September on the renewal permit to match the months for the 3 x Year sampling of the effluent.
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):
FORM: WQROSSR 04-14 Page 3 of 5

DocuSign Envelope ID: 519ECB5D-B76B-4072-9F80-7D570657627E
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
❑ Deny4bGAkp�p reasons: )
6. Signature of report preparers I *d.e�
..
Signature of regional supervisor: `1D645B4A39694BE.
Date: 9/15/2023
- E3ABA14AC7DC434...
FORM: WQROSSR 04-14 Page 4 of 5

DocuSign Envelope ID: 519ECB5D-B76B-4072-9F80-7D570657627E
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
18. This Staff Report was prepared for the renewal of Permit W00002005, House of Raeford -Rose Hill. The
current permit description is accurate. Please review Section 12 above, the review of GW-59s and the
comment on the request for reduced monitoring. The 3 x Year sampling of the monitoring wells in the
current permit is March, July and November but is listed in BIMS as February, June and September.
Please change to February, June and September on the renewal permit to match the months for the 3 x
Year sampling of the effluent.
FORM: WQROSSR 04-14 Page 5 of 5