WQ0019755_Staff Report_20150522

DWR
State of North Carolina
Department of Environment and Natural Resources
"�� Division of Water Resources
Division of Water Resources
Water Quality Programs
Regional Staff Report
May 22,2015
To: Central Office—Non-Discharge Permitting Unit Application No.: WQ0019755
Attn: Alice Wessner,Water Quality Permitting Section Permittee: JPC Utilities, LLC
From: Patrick Mitchell Winston-Salem Regional Office Guilford County
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: May 5,2015
b. Site visit conducted by: P. Mitchell & Jim G.
c. Inspection report attached? ❑ Yes or ® No
d. Person contacted: Chad Leinbach, ORC and their contact information: [phone] ext.
e. Driving directions: See file.
II. FACILITY AND APPLICATION INFORMATION
1. Are there appropriately certified Operators in Charge(ORCs) for the facility? ❑ Yes ® No ❑ N/A
ORC: Chad Leinbach 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 ❑ No ❑ N/A- If no,please explain below in Section IV. Review Items
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 below in Section IV. Review Items
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 below in Section IV. Review Items
5. Is the residuals management plan adequate? ® Yes or ❑ No-If no,please explain below in Section IV. Review
Items
6. Are the existing application rates(e.g.,hydraulic,nutrient) still acceptable? ® Yes or ❑ No- If no,please
explain below in Section IV. Review Items
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program below in Section IV. Review
Items
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes,provide comments below 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 below in Section IV. Review Items
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A If no,please explain below in
Section IV. Review Items.
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.,NDMR,NDAR, GW)? ❑ Yes or ® No
Please summarize any findings resulting from this review below in Section IV. Review Items.
FORM:APSRSR 04-10 Pagel of 3

13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or® No
If yes,please explain below in Section IV. Review Items.
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.)
15. Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no,please explain below in Section IV. Review Items.
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑ Yes ® No ❑ N/A
If yes,please explain below in Section IV. Review Items.
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 APS Central Office to obtain through an additional information request:
3. List specific permit conditions recommended to be removed from the permit when issued:
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
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: May 22,2015
IV.ADDITIONAL REGIONAL STAFF REVIEW ITEMS
• Item II. 1.: BIMS shows that the facility does not have a designated back-up ORC. WSRO to request this be
done in a compliance letter.
• Item II. 9.: This office recommends describing the"surface irrigation system"components separately from
the"reclaimed water system"components in the descriptive paragraph on the first page of the permit. These
are operated independent of each other. The only connection is the upset pipe from the reclaimed water
system treatment works that leads to the"5-day upset pond". This is utilized when the effluent does not meet
reclaimed water system limits; from there the effluent is irrigated utilizing the standard surface irrigation
system which does not have effluent limits.
• Item II. 15.: This office does not have a copy of the Engineer Certification for the reclaimed system. The
Permittee indicated that this was completed in/or around 2006 and a copy was submitted to the Division.
ADDITIONAL REVIEW ITEMS ON BACK OF PAGE
FORM: APSRSR 04-10 Page 2 of 3

• There was some discussion over the standard wastewater irrigation system having independently operated
spray zones. The ORC indicated that while these zones are irrigated independent of each other,they are set to
cycle through all zones evenly. Therefore, according to the ORC, each non-reclaimed irrigation zone receives
the same dosing on average. As long as there are no compliance issues with nutrient loading,ponding or
runoff,this office is ok with this practice.
• There are two offsite sewage lift stations connected to this system.Not sure if these should be listed as part of
this system or if they are considered a deemed collection system.
• Attached is a copy of the site map showing the WWTFs for the standard wastewater irrigation system and for
the reclaimed water system.
FORM: APSRSR 04-10 Page 3 of 3