WQ0010059_STFRPT_20200616

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
June 16, 2020

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0010059
Attn: Ranveer Katyal 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: December 18, 2019
b. Site visit conducted by: Mikal Willmer & Tim Heim
c. Inspection report attached? Yes or No (In LF file)
d. Person contacted: Elisa Triplett, WWTP Superintendent and their contact information: [phone]
e. Driving directions: From Hwy. 64E in Lenoir, turn right on SW Blvd. Take the first exit to Virginia St. Turn
left on Virginia St. and continue to Broadland Rd. on the right. Facility is approx. ½ mile on 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: 03C96BA9-EC26-49DE-8B7E-F11C41092E36
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: 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 Plans indicate all generated Class A residuals will be under roof and protected
on three sides. Updated O&M was submitted last year in response to add-info, but was not resubmitted
with the renewal/modification.
3. If no, please explain:
4. 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:
5. 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 N/A
If yes, please explain: Site has not changed; however, permittee is looking to add a residual’s source.
6. Is the residuals management plan adequate? Yes or No
If no, please explain:
7. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No N/A
If no, please explain:
8. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
9. Are there any setback conflicts for existing treatment, storage and disposal sites? Yes or No
If yes, attach a map showing conflict areas. Does not appear to be based on approved NPDES AtoC.
10. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: An AtoC was issued by the NPDES Permitting Unit on August 1, 2019. After
upgrade, solids processing equipment will have changed. The addition of a new residuals source is also
being requested at this time.
11. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
12. 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
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
13. 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: Reviewed facilities annual residuals report in April
of 2020. All residuals were sent to the Foothills Landfill in 2019.
14. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain:
15. 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.)
DocuSign Envelope ID: 03C96BA9-EC26-49DE-8B7E-F11C41092E36
FORM: APSRSR 04-10 Page 3 of 4
16. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
17. 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 ND Central Office to obtain through an additional information request:
Item Reason
See section V comments.

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 WQ regional supervisor:

Date:

DocuSign Envelope ID: 03C96BA9-EC26-49DE-8B7E-F11C41092E36
6/18/2020
FORM: APSRSR 04-10 Page 4 of 4
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The updated O&M plan previously submitted on 11/5/19 in response to an add-info, appears to be missing. Form RSC
for Lower Creek is missing. The most recent Lower Creek TCLP results and RSC form were submitted with the
previous renewal application (from 2020); however, the return letter indicated the contract laboratory’s RLs were at or
above the regulatory limit for Chlordane and Heptachlor and its Hydroxide. Blowing Rock’s sludge results only have
the TCLP metals reported in mg/L. The volatile and semi-volatile results are not identified as TCLP and are reported
in mg/kg. Unable to determine if this is a reporting error or if the laboratory determined the leaching procedure was
not required due to total waste analysis results being less than the regulatory limit or if extraction by TCLP was just
not requested/run. Additionally, several of the required parameters are missing. Specifically, Chlordane, Cresols,
Endrin, Heptachlor and its hydroxide, Hexachloro-1,3-Butadiene, Lindane, Methoxychlor, MEK, Pyridine,
Toxaphene, 2,4,5-Trichlorophenol, and Silvex.
DocuSign Envelope ID: 03C96BA9-EC26-49DE-8B7E-F11C41092E36