WQ0004797_Staff Report_20200325

State of North Carolina
Department of Environment and Natural Resources
Division of Water Resources

Water Quality Permitting
Regional Staff Report

FORM: APSRSR 04-10 Page 1 of 4
March 25, 2020

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0004797
Attn: Vivien Zhong Regional Login No.:

From: Mikal Willmer
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 01/25/2019
b. Site visit conducted by: Bev Price & Mikal Willmer
c. Inspection report attached? Yes or No In Laserfiche
d. Person contacted: Tracy Wolfe and their contact information: [phone]
e. Driving directions: From I-26 take Exit 44 to US Hwy. 25S. Go 2.5 miles to Industrial Park Rd., turn left;
facility is located 1 mile on the left. Sprayfield: Continue past Industrial Park Rd. to Brookside Camp
Rd., turn left, go 1.5 miles, fields are 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:
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:
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)

DocuSign Envelope ID: FB490FE5-F334-44AD-AB78-CDF84B625FEE
FORM: APSRSR 04-10 Page 2 of 4
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: Tracy Wolfe Certificate #:SI 995501 Backup ORC: Dale Wolfe Certificate #:SI 987551
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 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: No physical changes; however, due to GW exceedances and consistent wetness of
several fields, application rates may need to be reassessed for several of the permitted fields.
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: Under assessment, several fields are often too wet to irrigate.
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program: Clement Papas is currently
and voluntarily monitoring Mud Creek upstream (SW-1) and downstream (SW-2) of the land application
field. Because monitoring wells MW-7R and MW-8 continue to exceed the State groundwater standard for
nitrate, these two surface water monitoring locations should be included in this permit cycle. The ARO can
provide the specifics on the draft permit.
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: Additional aerator needs to be added to the permit (listed in permit app as 25 hp?)
and the 475-gpm transfer pump needs to be removed. This was no longer in use as of the last inspection
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: Since 2015, nitrate concentrations in
monitoring wells MW-7R and MW-8 have exceeded the applicable groundwater standard. More
recently, nitrate concentrations at monitoring well MW8 have declined and are now below the
groundwater standard. Clement Pappas theorized that Mud Creek was responsible for the elevated
nitrate but surface water monitoring has shown nitrate concentrations consistently below 1 mg/l.
cis-1,2-dichloroethene, trichloroethene, and tetrachloroethene continue to be detected at the
background monitoring well MW-5. DWM IHSB has conducted a n investigation but a source area has
not been identified.
DocuSign Envelope ID: FB490FE5-F334-44AD-AB78-CDF84B625FEE
FORM: APSRSR 04-10 Page 3 of 4
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.)
One NOV issued in 2016 for a frequency violation and an NOD issued in 2017 for a late NDMR. Facility in
conjunction with the ARO’s Hydrogeologist have been monitoring and investigating the cause of
exceedances in several of the monitoring wells .
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:
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 Non-Discharge Permitting Unit to obtain through an additional information
request:
Item Reason

Updated Site Map
Please update one site map to show all fields, irrigation zones, boundaries and
labeled setbacks (reference application for site map requirements).
Additionally, please clarify nomenclature of fields and zones so the new permit
reflects the facility’s site map labeling.
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
Surface water monitoring
Clement Pappas is currently and voluntarily monitoring Mud Creek upstream
(SW-1) and downstream (SW-2) of the land application fields. Because nitrate
concentrations continue to exceed the applicable standards in monitoring wells
MW-7R and MW-8, these surface water monitoring sites need to be included in
the next permit cycle. The ARO will provide specifics in the draft permit.
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: )

DocuSign Envelope ID: FB490FE5-F334-44AD-AB78-CDF84B625FEE
FORM: APSRSR 04-10 Page 4 of 4
6. Signature of report preparers:

FOR WQ regional supervisor: _____________

Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See most recent inspection for current facility operations and additional comments.

DocuSign Envelope ID: FB490FE5-F334-44AD-AB78-CDF84B625FEE
3/26/2020