WQ0005763_Staff Report_20240425

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: WQ0005763
Attn: Erick Saunders Facility name: Tuckaseigee Water and Sewer Authority

From: Melanie Kemp
Asheville 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: June 20, 2023
b. Site visit conducted by: Melanie Kemp
c. Inspection report attached? Yes or No In LF
d. Person contacted: Stan Bryson, ORC and their contact information: 828-586-9318ext.
e. Driving directions: Take I-40 W from ARO, then take exit 27 to get on US-74 W. Take exit 81 towards
US-23 S towards US-441 S. Turn left on N River Rd and WWTP is about 2 miles up on the right.
2. Discharge Point(s):
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. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
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FORM: WQROSSR 04-14 Page 2 of 5
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas.
8. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Joseph Ward Certificate #: 1006418 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:
Description of existing facilities:
Continued operation of a residuals management program for Tuckaseigee Water and Sewer Authority and
consisting of the distribution of Class A residuals generated by: TWSA Plant #1 (permit NC0039578),
TWSA Plant #2 (NC0020214), TWSA Plant #3 (NC0063321), and Whittier WWTP (NC0087602).
Proposed flow: 659 dry tons per year, maximum
Current permitted flow: Same as above
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:
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: Note that the facility name on Attachment A of the existing permit (NPDES permit
NC0039578) is incorrect and should be amended to “TWSA Plant #1”.
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FORM: WQROSSR 04-14 Page 3 of 5
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:
The site has had no limits or reporting violations recently.
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?
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:
17. Pretreatment Program (POTWs only):

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FORM: WQROSSR 04-14 Page 4 of 5
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

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

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:

DocuSign Envelope ID: 01576064-B039-4942-898C-6131487371BC
4/25/2024
FORM: WQROSSR 04-14 Page 5 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Note that the facility name on Attachment A of the existing permit (NPDES permit NC0039578) is incorrect and
should be amended to “TWSA Plant #1”.

Residuals from all four facilities are combined into 2 digestors located at TWSA Plant #1. From there they are
dewatered, and heat dried before being stored in a silo. Samples are collected from the silo prior to distribution.

The following issues were noted on the RSC 11-13 forms:
 All lab reports were missing.
 II.3 –
o TCLP sampling did not include Cresol and Methyl Ethyl Ketone analysis.
 II.5.e
o PAN calculation is incorrect based on sampling results from section b - should be 3,421 mg/kg
 III.8
o VAR Alternative 7 (drying of stabilized residuals) is selected here and identified in the attached
O&M Plan, but please note that the 2023 Residual Annual Report indicates that VAR Alternative 8
(drying of unstabilized residuals) is being utilized. Please be sure to select the appropriate method
in the Annual Report moving forward.

DocuSign Envelope ID: 01576064-B039-4942-898C-6131487371BC