WQ0005910_Staff Report_20190418

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: Erick Saunders Facility name: Avoca — Merry Hill WWTP
From: Randy Sipe
Washington 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: 7/11/17
b. Site visit conducted by: Sarah Toppen & Scott Vinson
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Brian Conner and their contact information: (252) 482 - 2133 ext.
e. Driving directions: No change since last permit was issued.
2. Discharge Point(s): N/A, non -discharge system.
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 #:993283 (WW -2) Backup ORC: Certificate #:
Note: The previous Backup ORC just left the company last week and a replacement is currently being trained.
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: Aeration, DAF unit, tertiary aerated effluent lagoon,pray irri ag tion
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.) See changes in Facili , Description in Item 11.9.
FORM: WQROSSR 04-14 Page 1 of 4

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: MW -6 was abandoned and
replaced by MW -9 in 2017(see attached GW -1 and GW -30). The permit should be revised to reflect this change.
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: The effluent flow meter now has a totalizer instead of a recorder. There are actually
irrigation pumps (two 350 GPM pumps and two 520 GPM pumps). The unused 750 gal. neutralization tank has
been removed.
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): See coordinates for new well MW -9
Monitoring Well Latitude
Longitude
MW -9 350 59' 55.737"
-760 43' 15.4086"
O I //
O I II
O I 1/
O I II
O / //
O / It
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: There are recurring elevated nitrate concentrations at
MW -4 and elevated ammonia concentrations at MW -8 which do not appear to correlate to the relatively low
concentrations in the effluent being irrigated. WaRO has issued a NORR to the facility and as a result the
permittee is working with a consultant to evaluate groundwater conditions.
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
❑ Notice(s) of violation
❑ Current enforcement action(s) ❑ Currently under JOC
❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.) WaRO is
currently working with the permittee and their consultants to evaluate groundwater conditions at the facility.
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? WaRO is currently working with the permittee
and their consultants to evaluate ,groundwater conditions at the facility.
FORM: WQROSSR 04-14 Page 2 of 4

Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain: Monitoring wells MW -1, MW -2, and MW -3 were abandoned in May 2014 as required bX
Condition 1.1 (see attached GW -30s).
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, non -discharge system.
17. Pretreatment Program (POTWs only): N/A, non -discharge system.
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
Facility Description
Revise as noted in Item II.9 above to reflect what is actually present at the
facility.
The current permit calls for Nitrate as N (00620) and TKN (00625) to be
reported; however, the customized NDMR provided by the Central Office to the
Attachment A
permittee, as well as previous versions of the permit, call for Nitrate + Nitrite
(00630) and TKN (81639) to be reported. These discrepancies in effluent
reporting need to be resolved.
Attachment C
Replace MW -6 with MW -9.
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
FORM: WQROSSR 04-14 Page 3 of 4

G9
❑ Issue
❑ Deny (Please state reasons: )
Signature of report preparer: Dw"'A 9"`i% sot
Signature of regional supervisor:
Date: 4/18/2019
Raw T"
IV. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
FORM: WQROSSR 04-14 Page 4 of 4