WQ0034386_Staff Report_20190410

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.: WQ0034386
Attn: Tessa Monday Facility name: Town of LaGrange WWTP - Reclaimed Water
From: Will Hart
Washineton 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 gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: March 28, 2019
b. Site visit conducted by: Stewart White and Will Hart
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: J Wesley Sutton and their contact information: (252) 566 - 3186 ext.
e. Driving directions: Driving directions are in BIMS.
2. Discharge Point(s): N/A
3. Receiving stream or affected surface waters: N/A
II. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ® Yes ❑ No ❑ N/A
ORC: Certificate #: Backup ORC: Certificate #:
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:
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.
FORM: WQROSSR 04-14 Pagel of 3

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:
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
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: ORC is currently reporting data collected for their
NPDES permit to meet the requirements of Attachment A of WQ0034386. The reclaimed water permit is utilized
infrequently. Daily reporting presents mM opportunities for Limit Violations when irrigation has not actually
occurred.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. Most recently
issued NPDES Permit issued to the Town of LaGrange reduced monitoring frequency from 5 X Week to 2 X
Week based on an evaluation of historical monitoring data.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ® Yes or ❑ No
If yes, please explain: The most recent version of NCO021644 has reduced monitoroing to twice weekly.
This reduction in monitoring frequency was based on analysis of historical data. Reduction of monitoring
frequency of WQ0034386 to match NCO021644 will likely reduce the volume of violations created in BIMS.
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
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
III. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? ❑ Yes or ® No
If yes, please explain:
2. 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: )
WX H4.z
3. Signature of report preparer:
Signature of regional supervisor: ZaW Tow4oL'd
Date: 04/10/2019
FORM: WQROSSR 04-14 Page 2 of 3

IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The monitoring frequency for the Town of LaGrange NPDES Permit, NC0021644, was recently reduced from daily
(SXWeek) to twice weekly, based on an evaluation of historical monitoring data. We support the decision to reduce
monitoring frequency for WO0034386 to twice weekly; in order to help streamline analytical efforts for the Town and
to eliminate recurring violations in BIMS when irrigation is not occurring. The Town of LaGrange wastewater
treatment plant is producing a high quality effluent with genereallnoproblems meeting limits for Reclaimed Water.
FORM: WQROSSR 04-14 Page 3 of 3