WQ0005910_Staff Report_20240604

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0005910
Attn: Nathaniel Thornburg Facility name: Avoca LLC
From: Robbie Bullock
Washington Regional Office
Note: This form has been adapted from the non -discharge facili . 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: May 30, 2024
b. Site visit conducted by: Robbie Bullock/Victoria Herdt
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Brian Conner and their contact information: 252-482-1304 ext.
e. Driving directions: No change since last permit was issued
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A, non -discharge system
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Brian Conner Certificate #: WW-2 993283, SI 991857 Backup ORC: Bobby Byrum Certificate #:WW-2
1010280, SI 1010629
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: The permit description in the existing permit is correct.
Proposed flow: 50,000 GPD
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.)
FORM: WQROSSR 04-14 Pagel of 3

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:
Is the residuals management plan adequate? ❑ Yes or ❑ No N/A
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:
It. Are the monitoring well coordinates correct in BIMS? ® Yes ❑ No ❑ N/A
If no, please complete the following ex and table if necessary):
Monitoring Well
Latitude
Longitude
O / //
O / //
O I //
O I I/
O I //
O I I/
O I //
O I I/
O I //
O I I/
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: The November and June 2023 NDMR was spot
checked for accuracy with no discrepancies found. Monitoring Well #11 is showing violations for Total
Dissolved Solids and Ammonia Nitrogen and Monitoring Well #5 is showing violations for Total Dissolved
Solids. The facility has not recently irrigated on this field where these monitoring wells are located.
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:
FORM: WQROSSR 04-14 Page 2 of 3

16. Possible toxic impacts to surface waters:
17. 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:
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: )
6. Signature of report preparer: /6&1 6 IFU&C
Signature of regional supervisor: RAva T""
Date: 6/4/2024
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 3 of 3