WQ0041136_Staff Report_20191009

State of North Carolina
Department of Environmental Quality
Division of Water Resources

Water Quality Permitting
Regional Staff Report

FORM: APSRSR 04-10 Page 1 of 3
October 9, 2019

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0041136
Attn: Tessa Monday Regional Login No.:

From: Mikal Willmer
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No No fields to verify, only treatment component setbacks to property
lines, streams and wells. Facility and WWTP are not yet constructed. Pre-construction meeting will be scheduled
once project is approved.
a. Date of site visit: N/A
b. Site visit conducted by: N/A
c. Inspection report attached? Yes or No
d. Person contacted: Mark Brooks and their contact information: 828-232-4700
e. Driving directions: 648 Ladson Rd. Take I-40W to I-26 East towards Hendersonville. Take exit 40 to airport
rd. (NC-280 W). Stay on 280 W for approximately 5 miles. Turn left onto 191-S (haywood Rd) for 1.4 miles.
Turn right onto school house rd. and take an immediate slight left onto Ladson Rd. 648 Ladson Rd. is 0.7 miles
on the left.
II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain: See additional staff review items. Closed-loop wastewater is being mixed with reclaimed effluent
before irrigation.
3. Are site conditions (soils, depth to water table, etc) consistent with the submitted reports? Yes No N/A
If no, please explain: Setbacks from treatment units to property lines and closest wells appear adequate.
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain: Setbacks appear adequate, partially in floodplain but fill is supposed to be above BFE.
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
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: No land application
proposed. Upset pond will be placed in fill material.
9. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)
DocuSign Envelope ID: B873621B-1FC4-4936-8BBE-0AD7961E7FD8
FORM: APSRSR 04-10 Page 2 of 3

III. EXISTING FACILITIES FOR 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 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.
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
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
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: .
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.)
15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
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:
DocuSign Envelope ID: B873621B-1FC4-4936-8BBE-0AD7961E7FD8
FORM: APSRSR 04-10 Page 3 of 3
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain: If concerns are addressed no, but effluent quality does not appear to be maintained before
irrigation with current system design. See below.
2. List any items that you would like Non-Discharge Central Office to obtain through an additional information
request:
Item Reason
Verify effluent quality
immediately prior to
irrigation
Reclaimed wastewater effluent will be comingled with recycle system
wastewater in the final tanks prior to irrigation. Mixing appears to occur after
sampling and turbidity readings. (See further explanation under section V).
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 WQROS regional supervisor:

Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Irrigation Water- domestic wastewater onsite will be treated to type 2 reclaimed standards and off-spec effluent will
be diverted to the 5-day pond; however, the reclaimed effluent that meets specifications will be mixed with recycle
wastewater from closed-loop system before being sent through the hydroponic irrigation system. The current design
indicates the wastewater being irrigated onto the crop is not reclaimed water meeting 2U specifications for food-chain
crops.
DocuSign Envelope ID: B873621B-1FC4-4936-8BBE-0AD7961E7FD8
10/10/2019