WQ0044733_Staff Report_20231024

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 3

To: NPDES Unit Non-Discharge Unit Application No.: WQ0044733
Attn: Elton Luong Facility name: 953 Martha's Chapel Rd
SFR

From: Chris Smith
Raleigh Regional Office

Note: This form has been adapted from the non-discharge facility 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: October 19, 2023
b. Site visit conducted by: Chris Smith and Kevin Fowler
c. Inspection report attached? Yes or No
d. Person contacted:
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: SFR (Please attach completed rating sheet to be attached to issued permit)
Proposed flow: 600 GPD
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:
DocuSign Envelope ID: 1174E452-789D-4E3E-963D-E586DB479F3B
FORM: WQROSSR 04-14 Page 2 of 3
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain: See Additional Regional Staff Review Items
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. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain: See Additional Regional Staff Review Items
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
DocuSign Envelope ID: 1174E452-789D-4E3E-963D-E586DB479F3B
FORM: WQROSSR 04-14 Page 3 of 3
Issue upon receipt of needed additional information
Issue
Deny (Please state reasons: See Additional Regional Staff Review Items)

6. Signature of report preparer:
Signature of regional supervisor:
Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

DWR Regional Staff conducted a site visit on October 19, 2023. The soil profile characteristics (texture,
horizon depths, color) observed during the site visit generally agreed with those presented in the permit
application. The Ksat nest locations were not flagged or marked in any way on site. This prevented Regional Staff
from locating the nest sites with 100% certainty to evaluate soil profiles at the exact Ksat nest locations. However,
the profile descriptions provided and verified on site were consistent enough that evaluation of the provided
descriptions in locations approximating the Ksat nests is considered sufficient.
The site is described as having a perched SHWT, but no evidence has been provided to support this
description. One (1) profile description extends to a depth of 84” (7 feet). Once observed/described, indicators of an
extended period of saturation continue through the entire depth of the profile description. This is indicative of an
apparent SHWT that requires a minimum of 18” of separation between the surface and the SHWT.
It is the opinion of the reviewer that the Recommended Loading Rate of 18.67 in/yr is unacceptable. This
loading rate value is achievable (mathematically) only by using a Drainage Coefficient (DC) of 25%. The LSS
states in the project narrative that the DC used is 17%, but the DC used in the SFR Irrigation Area Calculation
Worksheet by the LSS is 25%. This could be considered misleading. According to the DWR Soil Scientist
Evaluation Policy and the EPA Process Design Manual: Land Treatment of Municipal Wastewater Effluents (EPA
625/R-06/016) a DC of 4-10% is recommended and any DC greater than this should be accompanied by a
statement of justification supported by technical data. The justification provided states that the surface horizon
texture supports the high loading rate. Surface texture governs instantaneous loading rates and does not increase
the maximum vertical drainage capacity of the soil or justify such an elevated DC. No supporting data has been
provided.
According to the Soils Report narrative the site was evaluated in January 2022. Evaluations conducted more
than 1 year prior to application submission should be accompanied by a statement from the LSS indicating if the
site has changed in any significant way since the evaluation was conducted. No statement has been provided.
DocuSign Envelope ID: 1174E452-789D-4E3E-963D-E586DB479F3B
10/24/2023