WQ0005173_Staff Report_20240207

DocuSign Envelope ID: 4B10483F-3239-4104-A72C-C6E544AF3113
State of North Carolina
®r- Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
February 6, 2024
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Leah Parente
From: Morella Sanchez King
Wilmington Regional Office
Application No.: WQ0005173
Facility name: Cape Fear Royall Dolphin Association
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: 01/11/2024
b. Site visit conducted by: Morella Sanchez King
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Daniel Fortin and their contact information: (252) 241 - 9208 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:
if140, eXPI
3. Afe depth to
table,
the
D Yes E] No
site eendifiens (soils,
wa4ef ete) eeasistei4
with
stibmitted r-epet4s?
if no, please explain: —
4. Do the
the
lines,
ells, ete.)? E] Yes E] No
plans and site M" FepFesen4
if
aetual site (pr-epei4y
no, please explaiw
s
5. is the o;a
.,degt, �o.
n Yes El No
D Th
proposed als management
if
plan
no, please explaiw
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DocuSign Envelope ID: 4B10483F-3239-4104-A72C-C6E544AF3113
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III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Daniel Fortin Certificate #:7180 Backup ORC: Robert Howard Certificate #:996013
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.
Description of existing facilities: This system is a dual -train activated sludge "package plant" with compartments
for equalization, aeration, clarification and sludge storage and digestion. Compressed air is supplied by dual
rotary, positive displacement type blowers with timers to regulate blower on time. Located after the final clarifier
compartments are dual, downflow tertiary filters with clear well, mudwell and backwash pumps. The final
effluent passes through a tablet chlorinator for disinfection before being pumped to either of two high -rate
infiltration sites from the dosing tank. The two rotary distributors include a stationary low pressure piping network
covered with gravel.
Proposed flow: No additional disposal capacity is proposed.
Current permitted flow: 50,000 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.): The facility is compliant with the conditions and limitations specified in the permit. Nothing abnormal was
observed during the site inspections or from the review of monitoring records.
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 anyway 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:
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.
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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: Well construction records (GW-l's) for the construction of wells MW5, MW6, and
MW7 were provided in 2014 and signed by a certified well contractor (Jason P. Morton). It seems that the wells
were properly constructed.
11. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
If no, please complete the following (expand table if necessary):
Abandoned wells: MW 1, MW2, and MW4
Active wells: MW3, MW5, MW6, and MW 7
Monitoring Well
Latitude
Longitude
O l 11
O / 11
O / //
O I it
O / //
O I it
O l lI
O I II
O / //
O I it
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:
Yes, refer to Section V.
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:
® 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:
17. Pretreatment Program (POTWs only):
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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
❑ Deny (Please state reasons: )
0
Signature of report preparer:
Signature of regional supervisor:
Date: 2/7/2024
Docu Signed by:
NC.ltA S
DABAUA=C434...
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DocuSign Envelope ID: 4B10483F-3239-4104-A72C-C6E544AF3113
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This review was conducted for the renewal of permit # WQ0005173.
The permitted flow of the facility is 50,000 gpd. For the permit cycle 2019-2024, the average flow per
year was —5,600 gpd, with the highest flow (-10,000- 18,000 gpd in 2020) in the summer months.
NOV in the permit cycle
February 2022 — Fecal Coliform violations daily maximum and monthly geometric mean
January 2020 — BOD monthly avergae
Civil Penalties in the permit cycle
April 2023 - BOD monthly average
January 2022 — Ammonia, Nitrogen monthly average
In 2022, by the time of the ammonia violation, operators were in the process of shutting down one side of
the plant and were trying to establish the mixed liquor. Effluent remained in compliance until the BOD
violation in April 2023. Prior to these exceedances monitoring records have generally shown consistent
compliance with permit limits.
Groundwater monitoring has been generally compliant except for some erratic TDS exceedances which
are common in the barrier island environment. Nitrates in monitoring wells are consistently compliant,
despite higher nitrates levels in the effluent (the plant is not designed to denitrify and does not have a total
nitrate effluent limit).
The WiRO has no objection to the renewal of the permit.
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