WQ0014306_Staff Report_20240521

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 4

To: NPDES Unit Non-Discharge Unit Application No.: WQ0014306
Attn: Nathaniel Thornburg Facility name: Eagle Creek WWTP – Currituck Water and Sewer, LLC

From: Robbie Bullock
Washington 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: and their contact information: ext.
e. Driving directions:
2. Discharge Point(s): N/A
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. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: David Pharr Certificate #: WW-4 #26526 Backup ORC: Michelle Pharr Certificate #:WW4 #1012441
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: The existing travelling bridge filter is not functioning correctly. It is proposed that a
refurbished AquaDisk be retrofitted in place of the existing travelling bridge filter to ensure the facility can
treat the originally permitted flow of 350,000 GPD.
Description of existing facilities:
Proposed flow: 350,000 GPD
Current permitted flow: 175,000 GPD
FORM: WQROSSR 04-14 Page 2 of 4
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: Randy Sipe noted in the October 30, 2023 inspection that no records of sludge hauling
or disposal could be provided by the facility.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
If no, please explain: Randy Sipe noted in the October 30, 2023 inspection that reuse water had not been
sent to the irrigation pond for at least one year. All wastewater has been sent to the infiltration pond.
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. Agreements to waive setbacks are included in the modification
request
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: The proposed Aquadisk filter will need to be added in the description of the permit
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
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
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
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: A review of violations from January 2020 through
December 2023 showed numerous monitoring and limit violations associated with this permit. These
violations were associated with the previous owner.
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?
FORM: WQROSSR 04-14 Page 3 of 4
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain: Randy Sipe’s inspection on October 30, 2023 noted the following issues:
Condition I. 10 of the existing permit required all woody vegetation from around the infiltration pond be
removed within 1 year after effective date of the permit. This condition had not been met during the
inspection on October 30, 2023.
The infiltration basin does not have a properly installed staff gauge. The current one is not tied to the berm
height by a survey and cannot be used to accurately measure freeboard. This is a violation of Condition I.7
of Permit No. WQ0014306 that requires the permittee to properly install a staff gauge at the infltration
basin 60 days after the effective date of the permit (August 4, 2021).

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):
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

FORM: WQROSSR 04-14 Page 4 of 4
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:
Signature of regional supervisor:
Date:
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

The following Conditions were noted in the permit that was issued on August 4, 2021. The facility has a new owner
and the new permit will need to have these conditions listed in the permit
Prior to the expansion of the facility above the currently permitted 175,000 GPD, the Permittee shall provide a new
Soil Evaluation and Hydrogeologic Report to determine the total disposal capacity of the facility. This report is
required due to concerns of a high groundwater table at the site which could affect the performance of the existing
vacuum sewer collection system and previous instances of ponding on the golf course which affect the playability of
the golf course. These new evaluations will also aid in documenting whether site characteristics and conditions have
changed over the life of the facility since it was originally permitted. This document shall be submitted in a
modification request to support the increase in flow to the wastewater treatment facilities. [15A NCAC 02T
.0108(b)(1)(B)]
The gauge to monitor waste levels in the 5.5 MG high-rate infiltration basin shall be repaired and functional within 60
days of the effective date of the permit. Caution should be taken not to damage the integrity of any liner (if present)
when installing a gauge. [15A NCAC 02T .0108(b)(1)(B), 02T .0705(c)]
Within one year of the effective date of this permit, all trees, shrubs and other woody vegetation shall be removed
from all earthen dikes and embankments of the 5.5 MG high-rate infiltration basin and the 7.431 MG wet weather
storage /irrigation pond to comply with Condition III.17. The Washington Regional Office shall be notified upon
completion of these repairs. [15A NCAC .108(b)(1)(B), 02T .0707(g), 02U .0801(g)]
5/21/2024