NC0086584_Staff Report_20190521

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.: NCO086584
Attn: Derek Denard Facility name: Belhaven WTP
From: Scott Vinson
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: 5/3/2019
b. Site visit conducted by: Scott Vinson, Robbie Bullock & Stewart White
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Steve Hall and their contact information: (252) 943 - 3055 ext.
e. Driving directions: The facility is at 662 Harbinger Rd., off NC Hwy 99, in the Town of Belhaven, Beaufort
Co., North Carolina.
2. Discharge Point(s): Latitude: 35.560457 Longitude:-76.625427
3. Receiving stream or affected surface waters: Freshwater Tributary (field ditch) to Pantego Creek
Classification: Freshwater trib. to Tidal Saltwaters is "C" per rule 15A NCAC 02B .0301(i)(B)
Pantego Creek is the first named receiving stream is SC; Sw, NSW
River Basin and Subbasin No. Tar -Pamlico River Basin and 03-03-07 [Index# 29-34-34-(2)1
Describe receiving stream features and pertinent downstream uses: The receiving stream is a field ditch that
drains down through a ditch network eventually leading to Pantego Creek which is classified and used for
secondary recreation in include boating, wading and other uses involving human contact, for wildlife
habitat, for supporting aquatic life and propagation and is used for fishing to include fish consumption.
II. PROPOSED FACILITIES: NEW APPLICATIONS n/a
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ® No ❑ N/A
ORC: Stephen Hall Certificate #: 988630 Backup ORC: BACKUP NEEDED 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:
Description of existing facilities: A Reverse Osmosis water treatment plant with two nanofiltration units, with a
potable 0.5 MGD rate and a monthly average wastewater discharge flow rate of 0.033 MGD for these past 12
months.
Proposed flow: n/a
FORM: WQROSSR 04-14 Pagel of 3

Current permitted flow: n/a
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 ® N/A
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ❑ Yes or ❑ No ® N/A
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:
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
O / //
O / //
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: Monthly Total Copper sampling was added to the new
permit "Corrected" on October 31, 2018, but the ORC, Steven Hall did not get a copy and for several months did
not have this parameter analyzed for reporting. An NOD-2019-MV-0012 was issued for November 2019. As of
March 2019, Total Copper has started being reported with <10ug/l for both March & April 2019.
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.)
Monthly Total Copper sampling was added to the new permit "Corrected" on October 31, 2018, but the ORC,
Steven Hall did not get a copy and for several months did not have this parameter analyzed for reporting. An
NOD-2019-MV-0012 was issued for November 2019. As of March 2019, Total Copper has started being
reported with <10ug/l for both March & April 2019.
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Yes, the problem has been resolved. Is a solution underway or in place? Yes
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 2 of 3

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: Although Belhaven does eventually drain to Pantego Creek "SC"
waters, it initially drains to a receiving stream that is an unnamed freshwater tributary to tidal saltwaters
which by rule 15A NCAC 02B .0301(i)(B) is classified as "C", therefore for the renewal, it would be prudent
to revised the WET test species back to Ceriodaphnia dubia from the current species of Mysidopsis bahia.
This facility has been failing WET testing regularly with Ceriodaphnia since 2015 and should undergo a
Discharge Alternatives Analysis to determine if there are any better alternatives than discharging this
wastewater to surfacewaters.
17. Pretreatment Program (POTWs only): n/a
IV. 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
none
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
none
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
Require a Discharge
This WTP has been regularly failing their WET testing and needs to determine
Alternatives Analysis
if there is a better alternative to discharging their wastewater to this class C
freshwater receiving stream.
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: Zagva Tea."
Date: 5/21/2019
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
None.
FORM: WQROSSR 04-14 Page 3 of 3