WQ0011313_Staff Report_20240411

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State of North Carolina
®r'. Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0011313
Attn: Leah Parente Facility name: Peppertree WWTF
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: 01/24/2024
b. Site visit conducted by: Helen Perez
c. Inspection report attached? ❑ Yes or ® No Uploaded to Laserfiche
d. Person contacted: Dan 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:
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:
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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: Robert Howard Certificate #:996013 Backup ORC: Dan Fortin Certificate #:7180
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: 80,000 GPD
Current permitted flow: 80,000 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:
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.
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:
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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 I /I
O l lI
O I it
O l lI
O I II
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:
NDMR/NDAR
2019: 3 NOVs and 1 Civil Penalty for TSS
2020: 2 NOVs for Fecal
2022: 2 NOVs for BOD and 1 Civil Penalty for BOD, TSS
1 NOV for inspection
2023: NOV for BOD, TSS and 1 Civil Penalty for BOD
2024: NOV/NOI for inspection
GW-59
MW-1: Nitrate limit exceedances since October 2021 and TDS exceedances since February 2022
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?
The WIRO is currently working with the Permittee on the issues listed in the NOWNOI issued for the
1/24/2024 inspection (NOV-2024-PC-0091 attached). It appears, from their response and open
communication with new management, that these issues will be resolved soon. The WIRO will be
completing a follow-up visit to check on their compliance status.
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): N/A
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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
Submit a Operator
Designation Form to
Certification Unit.
ORCBORC is not correct in BIMS.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
Schedule I.1 and 2 Completed.
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Permittee should
investigate per 2L .0106
(d).
Persistent groundwater exceedances present beyond the review boundary in
MW-1.
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
❑ Dery4PW_A-Kjst;;te reasons: )
6. Signature of report preparer:
1D645B4A39694BE...
Signature of regional supervisor:
Date: 4/11/2024
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V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This Staff Report was completed for the renewal of the Peppertree WWTF, W00011313 Permit. The
ORC/BORC is not correct in BIMS and an Operator Designation Form needs to be submitted. Since there are
persistent groundwater exceedances for Nitrate and TDS present beyond the review boundary in MW-1, the
permittee should investigate per 2L .0106 (d). It is recommended that a permit condition is added to the
permit for this requirement. MW-I is located down -gradient from one of the high -rate infiltration drip fields.
The facility has an anoxic basin, but the operator has used it as a second EQ tank instead. The Nitrate levels in
the effluent are typically way over 10m2/1, but the facility currently does not have a Nitrate or Total Nitrogen
limit.
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