WQ0023896_Compliance Evaluation Inspection_20231026

DocuSign Envelope ID: F2187A88-111 F-4CF4-8137-144991 E521 B8
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Mr. Larry Daw
Environmental Compliance Office
University of North Carolina at Chapel Hill
1120 Estes Drive, Campus Box 1650
Chapel Hill, North Carolina 27599-1650
Sent Via Email
\f QUAFt N� j
NORTH CAROLINA
Environmental Quality
October 26, 2023
Subject: Monitoring Well and Drip Field Reconnaissance Inspection
Permit # WQ0023896
Bingham Facility Wastewater Treatment Facility (WWTF)
1907 Orange Chapel Clover Garden Road
Chapel Hill, NC 27516 — Orange County
Mr. Daw:
On October 24, 2023, Michael Hall and Tyler Clark of the Division of Water Resources (DWR), Raleigh
Regional Office (RRO) performed a site inspection at the above -referenced facility. In addition, the
operator in responsible charge (ORC), James Smith, and his backup, Christian Teague, were both in
attendance. This inspection was performed at your request, in support of your evaluation of periodic
detections of fecal coliform in compliance groundwater samples collected to comply with the
requirements of non -discharge permit WQ0023896.
The inspection included the monitoring well system for the facility, the drip fields, and a general overview
of the wastewater collection, treatment, and storage system. The facility is permitted to treat 3,556
gallons per day (gpd), but according to the ORC, treats approximately —1,500 gpd. Treated wastewater is
chlorinated, and then stored in a 1,1222,440-gallon clay -lined wet weather basin prior to drip application
to one four fields totaling 5.72 acres. The monitoring well system inspected included the five wells
associated with the permit (MW-1, MW-3, MW-4, MW-5, and MW-6), in addition to four additional wells
that were apparently installed as part of the initial design investigation for the facility.
Overall, the facility is well -maintained and managed. The wells were locked within sound, steel protective
casings (see attached photographic log). With the exception of MW-1, the wells inspected had
identification plates attached, and uniform, square concrete pads. The pad for MW-1 appears to have
been either poured in an irregular form, or the form was broken and damaged after construction. The
pad for MW-5 had significant pitting of the concrete around the base of the steel protective casing, but
there was no evidence of corrosion at the base. The pad for MW-3 also had incipient pitting of the
concrete around the base of the steel protective casing. The inspector recommended repair of these pads
to prevent pooling of water around the base of the steel protective casing, which could result in corrosion.
Spray field 1 is fenced, and covered with grass that is uniform, and mowed. No evidence of surface flow
was observed on the field. The other three fields were forested, and significantly overgrown with shrubs,
as well as small to medium-sized trees (see attached photographic log). A number of fallen trees were
observed, and in at least one case, the root ball of a fallen tree had pulled up one of the drip lines. Exposed
drip lines were observed on the ground surface, and in particular around apparent erosional channels or
medium-sized trees. The thick undergrowth and fallen trees clearly hamper inspection and maintenance
of the drip fields, and the ORC indicated that Field 4 is currently not used because of damage to the drip
lines, and the difficulty of inspecting and repairing the system in this field. Fields 2-4 requiring clearing of
undergrowth and fallen trees so that they can be properly inspected, and as necessary, maintained.
Where erosion is observed, it will need to be controlled, and exposed drip lines will need to be covered
with mulch to prevent damage. This assessment is documented in the attached inspection form.
NORTHCAROLINAD_E
aepadmeM ofEn,kow ntal pual� f
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: F2187A88-111 F-4CF4-8137-144991 E521 B8
Overall, there does not appear to be any obvious reason for the periodic detection of fecal coliform in
groundwater from the wells associated with the permit. A quick review of historical data does not indicate
elevated fecal coliform in the effluent, but is should be noted that the effluent is sampled prior to storage
in the wet weather pond, and it is possible that fecal coliform could be introduced during storage of the
water prior to drip application. Mr. Daw indicated that he planned to sample the effluent just prior to
drip application, in order to assess if there was elevated fecal coliform in the wastewater being applied to
the fields. There was one anomaly in the historical data, insofar as wells MW-1, MW-3, and MW-4 had
low, or no detections of chloride, while wells MW-5 and MW-6 had regular detections of chloride at
concentrations 1-2 orders of magnitude above the detection limit. Elevated chloride in groundwater is an
indicator of residual chlorine, and the low levels detected in wells MW-1, MW-3, and MW-4 suggest the
possibility that the wastewater applied in the vicinity of these wells has no residual chlorine.
In general, fecal coliform is rarely the only constituent that is detected when there is insufficient
attenuation in a drip field, or if there is direct infiltration of surface water into a poorly -sealed well (which
does not appear to be the case). A quick review of the historical data for groundwater samples from the
permit wells does not show elevation of other target parameters that would indicate impact from
wastewater. This being the case, the most likely reason that fecal coliform is detected in the wells is
because of contamination during sampling. Mr. Daw indicated that the wells are sampled with bailers,
which present numerous opportunities for contact with the sides of the well, the protective casing, and
the sampler's hands. The Bingham Facility raises dogs, and fecal coliform is likely widespread on the
surface. Contamination of sampling equipment would be very easy, barring extremely protective
sampling procedures.
The inspectors told Mr. Daw that detections of fecal coliform in groundwater samples should still be
identified as exceedances of permitted standards, but that in the absence of any other obvious signs of
wastewater impact, would not be identified as a violation of the permit requirements. The inspectors
also recommended that if no obvious cause for the fecal coliform in groundwater samples could be
identified, it would be helpful for Mr. Daw to provide a technical memorandum providing a summary of
his evaluation, and supporting the assessment that it was not indicative of wastewater impact on
groundwater.
If you have any questions regarding this letter, please contact Michael Hall at [phone] or via email
at [e-mail].
Sincerely,
ocuSigned by:
E�D
& f, �lA utt
2916E6AB32144F...
Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Enclosure
-Inspection Photographs
-Inspection Form
cc: Laserfiche
NORTH eARo��N � E Q
oepanmem of Environmental UualNII
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: F2187A88-111 F-4CF4-8137-144991 E521 B8
Bingham WWTF (WQ0023896) Reconnaissance Inspection
October 24, 2023
Photograph 1
Photograph 2
View of Monitoring
Well MW-5. Note pitting of concrete around base
View of monitoring well MW-3.
of steel protective casing.
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DocuSign Envelope ID: F2187A88-111 F-4CF4-8137-144991 E521 B8
Bingham WWTF (WQ0023896) Reconnaissance Inspection
October i 2023Photograph
7
Photograph 8
View of •• e• drip line in field 3.
View of down in Field 3.
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DocuSign Envelope ID: 5344FA43-FD55-4F98-9054-81D5537B40BE
Compliance Inspection Report
Permit: WQ0023896 Effective: 10/01/20 Expiration: 11/30/26 Owner: The University of North Carolina at Chapel Hill
SOC: Effective: Expiration: Facility: Bingham Facility WWTF
County: Orange 1907 Clover Garden Church Rd
Region: Raleigh
Chapel Hill NC 27516
Contact Person: Larry Daw Title: Environmental Compliance Offic Phone: [phone]
Directions to Facility:
Take 1-40 west to chapel hill, take Hwy 54West to carborro. Continue on 54 west past White Cross. Turn left on Morrow Mill go
about a mile and veer left on Clover garden church road. Gate to facility is on left about 2 miles down.
System Classifications: SI,
Primary ORC: James Edward Smith Certification: 985237 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 10/24/2023 Entry Time 09:11AM Exit Time: 11:53AM
Primary Inspector: Michael Hall °°`°Signed by: Phone: [phone]
--I A L^I 10/26/2023
Secondary Inspector(s): 1F
372DC.WB u1 E4AQ_y:
Timothy Clark
Reason for Inspection: Routine 3D2F887B781044E...
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant 0 Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Inspection Type: Reconnaissance
End Use -Irrigation
Wells
Page 1 of 5

DocuSign Envelope ID: 5344FA43-FD55-4F98-9054-81D5537B40BE
Permit: WQ0023896 Owner - Facility: The University of North Carolina at Chapel Hill
Inspection Date: 10/24/2023 Inspection Type : Reconnaissance Reason for Visit: Routine
Inspection Summary:
On October 24, 2023, Michael Hall and Tyler Clark of the Division of Water Resources (DWR), Raleigh Regional Office
(RRO) performed a site inspection at the above -referenced facility. In addition, the operator in responsible charge (ORC),
James Smith, and his backup, Christian Teague, were both in attendance. This inspection was performed at the request of
Larry Daw, in support of his evaluation of periodic detections of fecal coliform in compliance groundwater samples collected
to comply with the requirements of non -discharge permit WQ0023896.
The inspection included the monitoring well system for the facility, the drip fields, and a general overview of the wastewater
collection, treatment, and storage system. The facility is permitted to treat 3,556 gallons per day (gpd), but according to the
ORC, treats approximately--1,500 gpd. Treated wastewater is chlorinated, and then stored in a 1,1222,440-gallon clay -lined
wet weather basin prior to drip application to one four fields totaling 5.72 acres. The monitoring well system inspected
included the five wells associated with the permit (MW-1, MW-3, MW-4, MW-5, and MW-6), in addition to four additional
wells that were apparently installed as part of the initial design investigation for the facility.
Overall, the facility is well -maintained and managed. The wells were locked within sound, steel protective casings (see
photographic log in inspection letter). With the exception of MW-1, the wells inspected had identification plates attached,
and uniform, square concrete pads. The pad for MW-1 appears to have been either poured in an irregular form, or the form
was broken and damaged after construction. The pad for MW-5 had significant pitting of the concrete around the base of the
steel protective casing, but there was no evidence of corrosion at the base. The pad for MW-3 also had incipient pitting of
the concrete around the base of the steel protective casing. The inspector recommended repair of these pads to prevent
pooling of water around the base of the steel protective casing, which could result in corrosion.
Spray field 1 is fenced, and covered with grass that is uniform, and mowed. No evidence of surface flow was observed on
the field. The other three fields were forested, and significantly overgrown with shrubs, as well as small to medium-sized
trees (see photographic log in inspection letter). A number of fallen trees were observed, and in at least one case, the root
ball of a fallen tree had pulled up one of the drip lines. Exposed drip lines were observed on the ground surface, and in
particular around apparent erosional channels or medium-sized trees. The thick undergrowth and fallen trees clearly hamper
inspection and maintenance of the drip fields, and the ORC indicated that Field 4 is currently not used because of damage
to the drip lines, and the difficulty of inspecting and repairing the system in this field. Fields 2-4 requiring clearing of
undergrowth and fallen trees so that they can be properly inspected, and as necessary, maintained. Where erosion is
observed, it will need to be controlled, and exposed drip lines will need to be covered with mulch to prevent damage.
Overall, there does not appear to be any obvious reason for the periodic detection of fecal coliform in groundwater from the
wells associated with the permit. A quick review of historical data does not indicate elevated fecal coliform in the effluent,
but is should be noted that the effluent is sampled prior to storage in the wet weather pond, and it is possible that fecal
coliform could be introduced during storage of the water prior to drip application. Mr. Daw indicated that he planned to
sample the effluent just prior to drip application, in order to assess if there was elevated fecal coliform in the wastewater
being applied to the fields. There was one anomaly in the historical data, insofar as wells MW-1, MW-3, and MW-4 had low,
or no detections of chloride, while wells MW-5 and MW-6 had regular detections of chloride at concentrations 1-2 orders of
magnitude above the detection limit. Elevated chloride in groundwater is an indicator of residual chlorine, and the low levels
detected in wells MW-1, MW-3, and MW-4 suggest the possibility that the wastewater applied in the vicinity of these wells
has no residual chlorine.
In general, fecal coliform is rarely the only constituent that is detected when there is insufficient attenuation in a drip field, or
if there is direct infiltration of surface water into a poorly -sealed well (which does not appear to be the case). A quick review
of the historical data for groundwater samples from the permit wells does not show elevation of other target parameters that
would indicate impact from wastewater. This being the case, the most likely reason that fecal coliform is detected in the
wells is because of contamination during sampling. Mr. Daw indicated that the wells are sampled with bailers, which
present numerous opportunities for contact with the sides of the well, the protective casing, and the sampler's hands. The
Bingham Facility raises dogs, and fecal coliform is likely widespread on the surface. Contamination of sampling equipment
would be very easy, barring extremely protective sampling procedures.
Page 2 of 5

DocuSign Envelope ID: 5344FA43-FD55-4F98-9054-81D5537B40BE
Permit: WQ0023896 Owner - Facility: The University of North Carolina at Chapel Hill
Inspection Date: 10/24/2023 Inspection Type : Reconnaissance Reason for Visit: Routine
The inspectors told Mr. Daw that detections of fecal coliform in groundwater samples should still be identified as
exceedances of permitted standards, but that in the absence of any other obvious signs of wastewater impact, would not be
identified as a violation of the permit requirements. The inspectors also recommended that if no obvious cause for the fecal
coliform in groundwater samples could be identified, it would be helpful for Mr. Daw to provide a technical memorandum
providing a summary of his evaluation, and supporting the assessment that it was not indicative of wastewater impact on
groundwater.
Page 3 of 5

DocuSign Envelope ID: 5344FA43-FD55-4F98-9054-81D5537B40BE
Permit: WQ0023896 Owner - Facility: The University of North Carolina at Chapel Hill
Inspection Date: 10/24/2023 Inspection Type : Reconnaissance Reason for Visit: Routine
Type
Yes No NA NE
Reuse (Quality)
❑
Infiltration System
❑
Lagoon Spray, LR
❑
Single Family Spray, LR
❑
Activated Sludge Spray, LR
❑
Activated Sludge Spray, HR
❑
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Single Family Drip
❑
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
❑
❑ ❑ ❑
Is the cover crop type specified in permit?
❑
❑ ❑ ❑
Is the crop cover acceptable?
❑
❑ ❑ ❑
Is the site condition adequate?
❑
❑ ❑
Is the site free of runoff / ponding?
❑ ❑ ❑
Is the acreage specified in the permit being utilized?
❑
❑ ❑
Is the application equipment present?
❑ ❑ ❑
Is the application equipment operational?
❑
❑ ❑
Is the disposal field free of limiting slopes?
❑ ❑ ❑
Is access restricted and/or signs posted during active site use?
❑ ❑ ❑
Are any supply wells within the CB?
❑
❑ ❑
Are any supply wells within 250' of the CB?
❑
❑ ❑
How close is the closest water supply well?
❑
❑ ❑
Is municipal water available in the area?
❑
❑ ❑ ❑
# Info only: Does the permit call for monitoring wells?
❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB?
❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
❑ ❑ ❑
Are monitoring wells damaged?
❑
❑ ❑
Page 4 of 5

DocuSign Envelope ID: 5344FA43-FD55-4F98-9054-81D5537B40BE
Permit: WQ0023896 Owner - Facility: The University of North Carolina at Chapel Hill
Inspection Date: 10/24/2023 Inspection Type : Reconnaissance Reason for Visit: Routine
Comment: The DWR responded to a request from the permittee to inspect the drip irrigation fields and
monitoring wells to evaluate potential causes for periodic detections of fecal coliform bacteria in
aroundwater samDles collected from the Site. The monitorina wells were in aood condition.
generally, althought two of the wells (MW-5 and MW-3) had obvious signs of concrete
deterioration around the protective casing, which need repair to prevent potential corrosion at
the base of the protective casing. Three of the drip fields for the site are forested (Field 2,3,
and 4), and are significantly overgrown with small understory trees and brush. In addition, we
observed several large trees that had fallen, and were left in place. The understory trees and
brush need to be cut and removed to allow proper inspection and repair of the drip lines. The
drip lines were exposed in many areas, and should be covered. In at least one location, the
fallen tree had Dulled uD the drib line. and had stretched it tauaht.
Page 5 of 5