WQ0044892_Staff Report_20231212

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.: WQ0044892
Attn: Cord Anthony Facility name: 2501 Hollyheight Dr
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:
b. Site visit conducted by:
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: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow: 600GPD
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/E
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/E
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
DocuSign Envelope ID: 59012F91-B31E-489E-85BF-92549785E2A8
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:
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
Issue upon receipt of needed additional information
DocuSign Envelope ID: 59012F91-B31E-489E-85BF-92549785E2A8
FORM: WQROSSR 04-14 Page 3 of 3
Issue
Deny (Please state reasons: )
6. Signature of report preparer:
Signature of regional supervisor:
Date:

IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

The following concerns about the submitted soils evaluation need to be addressed:
• The evaluation narrative states “The area evaluated and suitable for the proposed system is about 46,000
ft2, so ample space is available for the wastewater irrigation system anywhere within the evaluated area.”
The disposal area calculation is using a Drainage Coefficient (DC) of 13%. 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. The inconsistency of the Ksat
values (0.01, 0.02, and 0.09 in/hr) and the stated shallow depth to the high water table do not support an
elevated DC. DWR staff recommends that the DC be reduced to a maximum of 10% and the disposal area
size be increased.

• The report states the water table on the site is perched. Low chroma colors are described at depths of 5”,
6”, and 11” for Ksat measurement locations 1, 2, and 3 respectively. The low chroma values continue to be
described throughout the soil profile after the initial observance depth at every Ksat nest location. The
continued observance of these low chroma values throughout the evaluation range potentially indicates an
extended period of saturation through the lower parts of the soil profile and does not support the statement
that the water table encountered is perched.

• The site drawing provided indicates that several soil borings were performed in addition to the Ksat nest
locations, but logs for these soil borings were not provided.

• The application does not include a clear and detailed soils map. A site drawing is included, but lines
delineating various features are not continuous due to the inclusion of text labels. An aerial image map
clearly delineating soil series polygons, Ksat nest locations, and soil boring locations should be provided to
assist DWR staff in locating these features in the field.

• The site drawing provided appears to show both Creedmoor and White Store soil series with differing
slopes present in the proposed disposal area, but only Creedmoor is mentioned in the evaluation. Ksat data
and soil profile descriptions are provided only for the Creedmoor series. No explanation has been offered
for the exclusion of the White Store series from the soils evaluation. Please explain.

DocuSign Envelope ID: 59012F91-B31E-489E-85BF-92549785E2A8
12/12/2023