NC0033600_Staff Report_20200323

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 4

To: NPDES Unit Non-Discharge Unit Application No.: NC0033600
Attn: Kristin Litzenberger Facility name: Pigeon Valley Rest Home

From: Mikal Willmer
Asheville Regional Office

Date: 03/23/2020

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: 03/18/2020
b. Site visit conducted by: Mikal Willmer
c. Inspection report attached? Yes or No In LF
d. Person contacted: Joedavid Hall and their contact information: (828) 226 - 7784 (ext.
e. Driving directions:
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: Pigeon River
Classification: WS-III Tr
River Basin and Subbasin No. French Broad & 06010106 (8 digit HUC)
Describe receiving stream features and pertinent downstream uses: This portion of the Pigeon River runs
through a more rural portion of Haywood County and flows North through the Town of Canton. The
portion of the River from Canton to Clyde is impaired for benthos.
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:
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FORM: WQROSSR 04-14 Page 2 of 4
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:
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: Joedavid Hall Certificate #:993269 Backup ORC: David Helms Certificate #:1000269
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: Facility classification is listed incorrectly on the cover letter of the draft
permit and in BIMS. This is an extended aeration activated sludge facility and should be listed as Class II.
Monitoring requirements and frequencies appear to reflect those for a Class II.
Proposed flow:
Current permitted flow: 0.03 MGD – This should be 0.025 MGD (facility didn’t increase capacityto 0.03
MGD or request change in capacity during last modification)
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 N/A
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: ORC reports the influent grinder pump has not been operable in years and there are
DocuSign Envelope ID: D3E14074-83D7-48CB-993F-5711BBDCC55D
FORM: WQROSSR 04-14 Page 3 of 4
currently no plans to replace. Facility has an aerated sludge holding tank (not in use as digester). ORC also
reports the facility does not have post aeration anymore.
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: During the permit cycle the facility had several
BOD violations in 2016. Operations changed hands at the end of 2016. There was one daily fecal
exceedance in 2018.
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? See number 12 above. We have not seen
recurring compliance issues since 2016 before operations changed. Previous BOD violations may have been
related to solids handling and issues with blower motors that were not repaired. The facility has not had a
limit violation in the past two years. Facility is currently receiving 85% of permitted hydraulic capacity.
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: N/A
17. Pretreatment Program (POTWs only): N/A

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FORM: WQROSSR 04-14 Page 4 of 4
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
Accurate Facility
Description Current description does not match what’s onsite and what is still in use.
Outfall Coordinates Exact location is unknown. Requesting permittee in conjunction with operations
firm locate approximate discharge location.
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
WWTP Assessment Facility is only permitted for 0.025 MGD (typo in permit since 2010) and flows
are at 85% of permitted design capacity.
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:
7.
Signature of regional supervisor:

Date:

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See inspection report for additional information and comments. Facility is a Class II. No indication with
maintaining TSS and BOD in compliance with current permit limits since 2017.

DocuSign Envelope ID: D3E14074-83D7-48CB-993F-5711BBDCC55D
3/23/2020