NC0025381_SOC (application),_20200619

LaBella
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June 19, 2020
Division of Water Resources RECEIVED
NPDES Compliance & Expedited Permit Unit SEP 0 4 2020
1617 Mail Service Center
Raleigh,NC 27699-1317 NCDEQ/DWR/NPDES
SUBJECT: Lake Lure Special Order by Consent (SOC)
To whom it may concern:
The Town of Lake Lure,NC would like to enter an SOC with NC DEQ—DWR in regard to the effluents
limits of the Lake Lure WWTP and collection system,NPDES Permit#NC0025381 and WQCS00131
respectively. This SOC would be a first step toward the goal of long-term NPDES compliance.
Enclosed is one original and two copies of the SOC application. Please advise if you have any questions
or need additional information.
Sincerely,
Cn\04/JIA:t4 (taifivi"—
Maurice J. Walsh, P.E.
LaBella Associates, P.C.
Program Manager
400 S.Tryon Street, Suite 1300 Charlotte. NC 28285 p(704) 376-6423 f(704) 332-6177
www.labellapc.com
1

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER RESOURCES
APPLICATION FOR A SPECIAL ORDER BY CONSENT (SOC)
I. PERMIT RELATED INFORMATION:
1. Applicant (corporation, individual, or other): _Town of Lake Lure
RECEIVED
2. Print or Type Owner's or Signing Official's Name and Title:
SEP 0 4 1010
Shannon Baldwin, Town Manager NCDEQ/DWR/NPDES
3. Facility Name (as shown on Permit): _Lake Lure Wastewater Treatment Plant
4. Owner Phone: _(828) 625-9983 (or)
5. Owner Email: [e-mail]
4. Application Date: _June 19, 2020
5. NPDES Permit No. (if applicable): NC0025381
6. Name of the specific wastewater treatment facility(if different from 1.3. above):
II. PRE-APPLICATION MEETING:
Prior to submittingthis completed application form, applicants must meet with the appropriate
P Pp p
regional office staff to discuss whether or not an SOC is appropriate for this situation. Please
note the date this meeting occurred and who represented the permittee:
Representative: Shannon Baldwin, Town Manager Date: _2/12/2020
III. ADDITIONAL FLOW OR FLOW REALLOCATION:
In accordance with NCGS 143-215.67(b), only facilities owned by a unit of government may
request additional flow.
Additional flow may be allowed under an SOC only in specific circumstances. These
circumstances may include eliminating discharges that are not compliant with an NPDES or
Non-discharge permit. These circumstances do not include failure to perform proper
maintenance of treatment systems, collection systems or disposal systems. When requesting
additional flow, the facility must include its justification and supporting documentation.

If the requested additional flow is non-domestic, the facility must be able to demonstrate the
ability to effectively treat the waste and dispose of residuals. The applicant must provide a
detailed analysis of the constituents in the proposed non-domestic wastewater.
The total domestic additional flow requested: 0 gallons per day.
The total non-domestic additional flow requested: 0 gallons per day.
The total additional flow(sum of the above): 0 gallons per day.
Please attach a detailed description or project listing of the proposed allocation for additional
flow, with an explanation of how flow quantities were estimated. Further, any additional flow
requested must be justified by a complete analysis, by the permittee, that additional flow will not
adversely impact wastewater collection/treatment facilities or surface waters.
IV. NECESSITY NARRATIVE:
Please attach a narrative providing a detailed explanation of the circumstances regarding the
necessity of the proposed SOC. Include the following issues:
• Existing and/or unavoidable future violations(s) of permit conditions or limits(s),
• The existing treatment process and any process modifications that have been made to
date to ensure optimum performance of existing facilities,
• Collection system rehabilitation work completed or scheduled(including dates),
• Coordination with industrial users regarding their discharges or pretreatment facilities.
Identify any non-compliant significant industrial users and measure(s) proposed or
already taken to bring the pretreatment facilities back into compliance. If any industrial
facilities are currently under consent agreements,please attach these agreements,
• Date and outcome of last Industrial Waste Survey,
• Whether or not the facility is acting as a regional facility receiving wastewater from other
municipalities having independent pretreatment programs.
V. CERTIFICATION:
The applicant must submit a report prepared by an independent professional with expertise in
wastewater treatment. This report must address the following:
• An evaluation of existing treatment units, operational procedures and recommendations
as to how the efficiencies of these facilities can be maximized. The person in charge of
such evaluation must sign this document.
• A certification that these facilities could not be operated in a manner that would achieve
compliance with final permit limits. The person making such determination must sign
this certification.
• The effluent limits that the facility could be expected to meet if operated at their
maximum efficiency during the term of the requested SOC (be sure to consider interim
construction phases).
• Any other actions taken to correct problems prior to requesting the SOC.

VI. PREDICTED COMPLIANCE SCHEDULE:
The applicant must submit a detailed listing of activities along with time frames that are
necessary to bring the facility into compliance. This schedule should include milestone dates for
beginning construction, ending construction, and achieving final compliance at a minimum. In
determining the milestone dates,the following should be considered:
• Time for submitting plans, specifications and appropriate engineering reports to DWR for
review and approval.
• Occurrence of major construction activities that are likely to affect facility performance
(units out of service, diversion of flows, etc.)to include a plan of action to minimize
impacts to surface waters.
• Infiltration/Inflow work, if necessary.
• Industrial users achieving compliance with their pretreatment permits if applicable.
• Toxicity Reduction Evaluations (TRE), if necessary.
VII. FUNDING SOURCES IDENTIFICATION:
The applicant must list the sources of funds utilized to complete the work needed to bring the
facility into compliance. Possible funding sources include but are not limited to loan
commitments,bonds, letters of credit,block grants and cash reserves. The applicant must show
that the funds are available, or can be secured in time to meet the schedule outlined as part of this
application.
If funding is not available at the beginning of the SOC process, the permittee must submit a copy
of all funding applications to ensure that all efforts are being made to secure such funds.
Note: A copy of the application should be sufficient to demonstrate timeliness unless regional
office has reason to request all information associated with securing funding.
THE DIVISION OF WATER RESOURCES WILL NOT ACCEPT THIS APPLICATION
PACKAGE UNLESS ALL OF THE APPLICABLE ITEMS ARE INCLUDED WITH THE
SUBMITTAL.
Required Items:
a. One original and two copies of the completed and appropriately executed application
form, along with all required attachments.
• If the SOC is for a City / Town, the person signing the SOC must be a ranking
elected official or other duly authorized employee.
• If the SOC is for a Corporation / Company / Industry / Other, the person signing
the SOC must be a principal executive officer of at least the level of vice-
president, or his duly authorized representative.
• If the SOC is for a School District, the person signing the SOC must be the
Superintendent of Schools or other duly authorized employee.

Note: Reference to signatory requirements in SOCs may be found in the North
Carolina Administrative Code [T15A NCAC 2H .1206(a)(3)].
b. The non-refundable Special Order by Consent (SOC) processing fee of $400.00. A
check must be made payable to The Department of Environment and Natural
Resources.
c. An evaluation report prepared by an independent consultant with expertise in
wastewater. (in triplicate)
APPLICANT'S CERTIFICATION:
(NO MODIFICATION TO THIS CERTIFICATION IS ACCEPTABLE)
I, Shannon Baldwin, Town Manager , attest this application for a Special Order by
Consent (SOC) has been reviewed by me and is accurate and complete to the best of my
knowledge. I understand if all required parts of this application are not completed and if all
required supporting information and attachments are not included, this application package may
be returned as incomplete. (Please be advised that the return of this application does not prevent
DWR from collecting all outstanding penalties upon request). Furthermore, I attest by my
signature that I fully understand that an upfront penalty, which may satisfy as a full
settlement of outstanding violations, may be imposed. {Note: Reference to upfront penalties
in Speci • rs by Con ent may be found in the North Carolina Administrative Code [T15A
N H .l 6(c)(3
Date 06/19/2020
Signature of S' ning Official
Shannon Baldwin
Printed Name of Signing Official
THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO
COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT
TO THE FOLLOWING ADDRESS:
NORTH CAROLINA DIVISION OF WATER RESOURCES
POINT SOURCE BRANCH
1617 MAIL SERVICE CENTER
RALEIGH,NORTH CAROLINA 27699-1617
IF THIS APPLICATION IS FOR A NON-DISCHARGE SYSTEM, THEN SEND TO:
NORTH CAROLINA DIVISION OF WATER QUALITY
AQUIFER PROTECTION SECTION
1636 MAIL SERVICE CENTER
RALEIGH, NORTH CAROLINA 27699-1636

Attachments

III. ADDITIONAL FLOW OR FLOW REALLOCATION:
No additional flow is requested.
IV. NECESSITY NARRATIVE:
The Plant was originally constructed as a 0.350 MGD activated sludge plant in 1969. The
subaqueous sanitary sewer(SASS)was constructed around 1926, prior to filling the lake. Before
the construction of the Plant, the SASS discharged directly into the Broad River. In 1991, the
Plant was renovated and converted into a physical-chemical process (P/C) and was permitted for
an annual average daily flow rate of 0.995 MGD. In 2019, geotubes were installed to improve
sludge handling,with marginal results. The plant continues to struggle to meet the NPDES
permit limits during the winter and routinely fails to meet them in the summer months,
particularly in the recently imposed ammonia limits. The root cause of the issues with the Plant
are the lake infiltration. This flow enters the SASS at numerous points along its 14 mile length
of submerged cast iron pipe, manholes, and private laterals. The flow is such that the wastewater
is diluted to the extent that use of the activated sludge process is not possible and was the driving
force in the conversion to a physical-chemical plant. In addition to the issues the infiltration
creates with the Plant today, the already excessive infiltration is worsening as the pipe ages
beyond its useful service life. NC DEQ's recognition of this, as well as the potential catastrophic
consequences of a significant pipe failure resulted in their declaration of the SASS as
noncompliant as well. Unfortunately, the current treatment process is ineffective in meeting
some of the parameters of the plant's NPDES permit. The Plant has a legacy of frequent NPDES
violations that is expected to continue unless changes are made to the Plant or collection system,
or both. The current P/C process was not designed to remove ammonia, as such the Plant will
continue violate the NPDES ammonia limits. The plant is currently considered"noncompliant"
by the NC DEQ,with the most frequently cited NOV's being in regards to total suspended
solids, ammonia, and flow. In addition, the operations of the Plant represents a considerable
expenditure on Town's budget. This is only expected to increase due to the necessity of capital
improvements and material and chemical cost increases. A summary of the plant history is
provided below:
In addition to the residents of Lake Lure, the Town also serves several public and private
collection systems. The magnitude of the flow received from these systems is described in the
collection and treatment systems evaluation. There is currently not a pretreatment system on any
of the connecting independent collection systems. The Town also does not have any industrial
waste users, as such they have not completed an industrial waste survey.
The path forward is in the early stages of definition. The Town has taken certain steps related to
the SASS. In 2007, the Town undertook a project to smoke test and video as much of the SASS
as was accessible. A significant submerged joint leak was identified and repaired. In addition, a
pipe wrap project was undertaken in 2009 to wrap the exposed joints in the SASS. The
manufacturer recommended service life of the pipe wrap is 15 years. The effectiveness of these
efforts is seen in the chart below, it should be noted that the graph also shows an upward trend
after 2013. Also in 2019 while the lake was lowered twelve feet to accommodate penstock
rehabilitation on the dam, the Town took the opportunity to have the exposed backshore area

topographically surveyed. As a risk mitigation measure, the Town installed a mainline valve on
the gravity sewer below the dam, which would allow the stoppage of a catastrophic leak in the
subaqueous main while repairs are made. The Town has installed a flow meter on the
Rutherford county line serving Chimney Rock Village that is believed to contribute inflow and
infiltration and to quantify those flow contributions. The Town has secured an SRF loan in the
amount of$12.5M to begin the replacement or rehabilitation of the SASS and Plant. To that end,
the Town has engaged LaBella to develop the ER-EID to define the replacement alternative,
scope, and schedule for achieving short-term, mid-term, and long-term NPDES compliance of
both the Plant and the collection system. Prior to these efforts, the Town investigated a couple of
alternatives which were determined to be either cost-prohibitive or otherwise infeasible. To
investigate the best alternatives to consider,the Town commissioned a Technical Memorandum
that lays out eleven alternatives for correction of the excessive infiltration issues and for each
one, considers benefits and liabilities, identifies an order-of-magnitude cost and provides
LaBella's recommendation as to whether to continue its evaluation or eliminate it from further
consideration. These recommendations are summarized in the table on the following page, along
with indication of which alternatives could accommodate a phased approach. Five alternatives
are recommended for further consideration, which LaBella is proposing to develop as the next
task in the Town's renewed effort to resolve this urgent infrastructure issue. A summary of the
SASS history is below:
• 1926 - Initial Construction
• 1927 - Submerged following Dam construction
• 1969—Initial Construction as a 0.350 MGD activated sludge plant
• 1991 —Conversion to a 0.995 MGD PC process
• 1991-2006— Sand filter bypassed due to I&I
• 2007—Town entered into an SOC
• 2007—CCTV, smoke testing,joint repair project
• 2008—Plant upgrade including screen, sludge removal, sampling, chemical feed and
other improvements.
• 2009—Pipe wrap project- $3M (grant funded)
• 2009—NPDES permit issued with more stringent limits and additional testing
• 2019—Installation of geotubes for sludge management
• 2019—Geotechnical exploration&report- $35K
• 2019—Installation of emergency access valve

Annual Average Flow 2007, Leak Repaired
1 r. •
0.9
o.s — _.�__. _�___.___.___' 2009, Joint Wrap
0.7 , —
- 0.5 • —0—Average Annual Flow
0.4 _ • NPDES Permit(Teir 1)
0.3 -- —0—NPDES Permit(Teir 2)
0.2
0.1
0
1990 1995 2000 2005 2010 2015 2020
Year
When the lake infiltration issue is resolved, the Plant compliance issue will become more readily
(technically) solvable, and so the timing of the Plant solution will depend on the progress of the
collection system resolution. As the SASS replacement progresses, the lake infiltration will be
reduced and the concentration of the wastewater will increase. This increase is necessary to
achieve biological treatment, however it will cause issues with effluent compliance until
biological treatment can begin. Timing and other particulars of the Plant solution (e.g.,
rehabilitation or replacement, facility location,process selection)will be identified in
coordination with the selection of a collection system alternative. As a short-term compliance
measure, the Town is applying for a Special Order by Consent(SOC)with NC DEQ to prevent
additional NOV's and fines.

Subaqueous Sanitary Sewer Alternatives
Cost Order of Consider
Alternative Magnitude Phase-able Further
S 1 -Do Nothing n/a
S2-Land-based Low Pressure Sewer System $50M- $65M
S3 - Backshore Low Pressure Sewer System $30M- $40M
S4 - Backshore Series Pump Station System $30M-$40M
S5 - Backshore HDPE Gravity System $25M-$35M
S6-Backshore HDPE Gravity/Lift Station System $30M-$40M
S7 -Subaqueous Accessible Manholes $20M-$30M
S8 -Tethered Buoyant HDPE System $40M-$50M
S9- Submerged HDPE System Not Established
S10-Drain and Replace Approach Not Established
(if Dam renovation drains lake)
S 11 -Repair&Rehabilitate Perimeter Manholes $1 M-$3M
(partial solution)

V. CERTIFICATION:

Town of
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Qst. 1927 North Carolina
Collection and Treatment Systems
Evaluation
June 9, 2020
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Maurice J. Walsh, P.E.
07.1 LaBella
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Table of Contents
I. Project Background 1
II. Description of the Current Process 3
III. Regulatory Compliance Assessment 6
IV. Proposed Phase I— Plant and SASS rehabilitation and replacement 8
V. Proposed SOC - NPDES Limits 9
Biochemical Oxygen Demand (BOD) 12
Total Suspended Solids (TSS) 12
Ammonia(NH3) 12
Iron (Fe) 13
Sanitary Sewer Overflow (SSO) 13
Collection and Treatment Evaluation ii

Acronym List
BOD Biochemical Oxygen Demand
CI Cast lion
Fe Iron
GPM Gallons per Minute
I&I Inflow and Infiltration
MGD Million Gallons per Day
NC DEQ North Carolina Department of Environmental Quality
NOV Notice of Violation
NPDES National Pollutant Discharge Elimination System
O&M Operation and Maintenance
P/C Physical/Chemical
SSO Sanitary Sewer Overflow
TSS Total Suspended Solids
WWTP Wastewater Treatment Plant
Collection and Treatment Evaluation iii

I. Project Background
The Town currently owns and operates a 0.995 MGD wastewater treatment plant (Plant)that
uses a physical-chemical process to settle solids and provide disinfection. The current NPDES
permit is NC0025381. The Plant was originally constructed as a 0.350 MGD activated sludge
plant in 1969. Prior to this,the wastewater was discharged directly into the Broad River. In
1991, the Plant was renovated and converted into a physical-chemical process (P/C) and was
permitted for an annual average daily flow rate of 0.995 MGD. The plant continues to struggle
to meet the NPDES permit limits during the winter and routinely fails to meet them in the
summer months. The main cause of the issues with the Plant are the lake infiltration and inflow
and infiltration from the connecting land-based collection systems. These flows are such that the
wastewater is diluted to the extent that use of the activated sludge process is not possible,which
was the driving force in converting to a physical-chemical plant. Unfortunately,the current
treatment process is ineffective in meeting some of the parameters of the plant's NPDES permit.
The Plant has a legacy of frequent NPDES violations that is expected to continue unless changes
are made to the Plant and collection system. The current P/C process was not designed to
remove ammonia, as such the Plant will continue violate the NPDES ammonia limits. The plant
is currently considered"noncompliant"by the NC DEQ, with the most frequently cited NOV's
being in regards to total suspended solids, ammonia, and flow.
The NPDES permit is a two tier permit. The tiers are based on the average annual daily flow of
the previous year. The two tiers are based on a flow of 0.495 MGD and 0.995 MGD and are
indicated in the tables below.
NPDES Permit
Limits
Monthly Weekly Daily
Effluent Characteristics Average Average Maximum
Flow 0.495 MGD
BOD, 5-day 30.0 mg/L _ 45.0 mg/L
Total Suspended Solids 30.0 mg/L 45.0 mg/L
NH3 as N (April 1- October 31) 9.4 mg/L 28.2 mg/L
NH3 as N (Nov 1- March 31) Monitor and Report
Collection and Treatment Evaluation

II. Description of the Current Process
The physical-chemical process involves dosing the wastewater with alum to facilitate the
settlement of the suspended solids. The 350,000 gallon existing aeration basis was converted
into a sediment basin, where the floc is allowed to settle. The settled sludge is pumped into a
holding tank and disposed of by land application. The disinfection is accomplished with the
addition of an oxidizer, sodium hypochlorite. Excess chlorine residual is removed by calcium
thiosulfate. The sludge holding tank is only 50%utilized as a result of structural deficiencies
that allow sludge to leak if completely filled. The table below demonstrates the detention time of
the current process. For comparison, the current detention time requirement for a water plant
sedimentation basin is 4 hours per the 10 States Standards, 2012 edition.
Current Treatment Process
Design Flow 0.995 MGD
_2019 AAF 0.5355 MGD
Tier 1 Flow 0.495 MGD
Volume of Basin 330000 Gal
Detention Time
Design Flow 7.960 Hrs
2019 AAF 14.790 Hrs
Tier 1 Flow 16.000 Hrs
The DMR table below highlights the challenges faced by the Plant in meeting the NPDES permit
limits. This is particularly acute for the ammonia limit as can be seen in the graph below. The
Plant exceeded the monthly average ammonia limit twenty-two (22)times during the summer
months from 2015 to 2019. The NPDES permit does not require influent sampling, as a result
limited influent characteristics data is available. The information presented in this assessment is
effluent data,with the exception of the flow data.
DMR Data (2015-2018)
BOD TSS NH3 Summer)
Description mg/L Limit mg/L Limit mg/L Limit
Max Monthly 25.3 30 23.4 30 15.2 9.4
Average Monthly 11.3 30 22.0 30 10.2 9.4
Max Weekly 26.1 45 26.3 45 8.3 28.2
Average Weekly 7.2 45 26.2 45 2.9 28.2
Collection and Treatment Evaluation 3

II. Description of the Current Process
The physical-chemical process involves dosing the wastewater with alum to facilitate the
settlement of the suspended solids. The 350,000 gallon existing aeration basis was converted
into a sediment basin, where the floc is allowed to settle. The settled sludge is pumped into a
holding tank and disposed of by land application. The disinfection is accomplished with the
addition of an oxidizer, sodium hypochlorite. Excess chlorine residual is removed by sulfur
dioxide. The sludge holding tank is only 50% utilized as a result of structural deficiencies that
allow sludge to leak if completely filled. The table below demonstrates the detention time of the
current process. For comparison, the current detention time requirement for a water plant
sedimentation basin is 4 hours per the 10 States Standards, 2012 edition.
Current Treatment Process
Design Flow 0.995 MGD
2019 AAF 0.5355 MGD
Tier 1 Flow 0.495 MGD
Volume of Basin 330000 Gal
Detention Time
Design Flow 7.960 Hrs
2019 AAF 14.790 Hrs
•
Tier 1 Flow 16.000 Hrs
The DMR table below highlights the challenges faced by the Plant in meeting the NPDES permit
limits. This is particularly acute for the ammonia limit as can be seen in the graph below. The
Plant exceeded the monthly average ammonia limit twenty-two (22) times during the summer
months from 2015 to 2019. The NPDES permit does not require influent sampling, as a result
limited influent characteristics data is available. The information presented in this assessment is
effluent data, with the exception of the flow data.
DMR Data (2015-2018)
BOD TSS NH3(Summer)
Description mg/L Limit mg/L Limit mg/L Limit
Max Monthly 25.3 30 23.4 30 15.2 9.4
Average Monthly 11.3 30 22.0 30 10.2 9.4
Max Weekly 26.1 45 26.3 45 8.3 28.2
Average Weekly 7.2 45 26.2 45 2.9 28.2
Collection and Treatment Evaluation 3

DMR Data(2019)
BOD TSS NH3(Summer)
Description mg/L Limit mg/L Limit mg/L Limit
Max Monthly 15.2 30 23.5 30 10.9 5.2
Average Monthly 7.9 30 21.3 30 8.8 5.2
Max Weekly 20 45 25.8 45 7.6 15.6
Average Weekly 14.4 45 25.8 45 3.0 15.6
Occurred during monitor and report period
Monthly Average NH3
18 1.2
16
1
14
12 0.8
10
to
\A e tr,\I\
0.6 Tier 1 NPDES
8 .Tier 2 NPDES
NH3
6 0.4
4
0.2
2
0 0
Dec-14 Jul-15 Jan-16 Aug-16 Mar-17 Sep-17 Apr-18 Oct-18 May-19 Dec-19 Jun-20
Date
The Town has made changes in 2019 to the sludge handling by the addition of geotubes to
thicken and dewater sludge. These have only been marginally effective due to the high moisture
content of the sludge. The Town staff is investigating different methods of sludge handling to
improve efficiency and reduce operational cost.
The peak flow rates in the SASS is predominately determined by the lake infiltration, pipe
degradation, and I&I of connecting systems, such as Chimney Rock Village. This is shown in
Collection and Treatment Evaluation 4
1

the average annual flow from 1994 to 2019 in the chart below. Two repairs are shown that
dramatically reduced the flow rate.
Annual Average Flow 2007, Leak Repaired
1
0.9 2009, Joint Wrap
0.8
0.7
p' 0.6
- -Average Annual Flow
NPDES Permit(Teir 1)
LL 0.4 --NPDES Permit(Teir 2)
0.3
0.2
0.1
0 2020
1990 1995 2000 2005 2010 2015
Year
The chart
below shows the average daily flow rate contrasted with the pounds per dayof stays fairly
ammonia. The concentration of ammonia in a predomisawhat residential
expect d given the
constant. The increase in pounds per day of ammoniaia
general growth rate of the population of the sewer shed. Typicallycase the change n dmilmy on�nonia
would correlate with changes in thee n average daily flow thisw rate,however in case
further confirms that the flow
content is independent of the Chang
rate in the SASS is greatly influenced by lake infiltration and inflow and infiltration from the
land based and connecting systems.
Annual Average Flow to NH3 lbs/day
1
40 0.9
3S 0.8
30 0.7
0.6 �
o� 0.5
25
20 p -#NH3
0.4 2
--AAF
Z 15 0.3
10 0.2
0.1
5
0
0
ti ti ti 1. ti 1. ti ti ti ti ti ti 1, ti - ti
Year
5
Collection and Treatment Evaluation

III. Regulatory Compliance Assessment
The Plant and SASS have a legacy of noncompliance that is a direct result of the lake infiltration
and from the inflow and infiltration of connecting land-based sewer systems. This inflow and
infiltration diluted the wastewater flow to the extent that biological treatment was not possible.
In 1991, the plant was converted to a P/C process. This process can provide for BOD and TSS
removal settling the suspended solids in the wastewater. The detention times for BOD and TSS
removal are significantly shorter than that required for ammonia removal. The detention time
shown in section II are generally sufficient for BOD and TSS removal. The detention time for
ammonia removal is generally estimated at 5 to 7 days and require higher water temperature and
additional dissolved oxygen'. The table below demonstrates the flow capacity of the plant to
remove ammonia. As the table indicates, the estimated design flow for ammonia removal would
be 0.0471 MGD (47,100 GPD) or about 8.80% of the 2019 flow rate. Ammonia exists in
wastewater in two forms, as a gas (NH3) or as the ion ammonium (NH4). The proportion of the
two forms is pH dependent. Regardless of the form of ammonia, the current process is incapable
of ammonia removal in any significant capacity. As a result, it would be expected that the vast
majority of ammonia in the influent will exit in the effluent.
Ammonia Removal
Detention Time 7 Days
Volume of Basin 330,000 Gal
Available Capacity 0.0471 MGD
Percent of 2019 AAF 8.80%
The Town is currently undertaking steps with the ultimate goal of returning the plant to a
biological process. A critical step in this task is removing the lake infiltration from the system.
It is important to note that the lake infiltration is not the source of the ammonia, and only serves
to dilute the ammonia. Consequently, as the Town reduces the infiltration, the ammonia
concentration will increase. The chart below graphs the annual average flow vs. the annual
average ammonia concentrations, and demonstrates this point. As the flow rate decreases the
ammonia concentration increases and vice versa. In contrast when the concentration is
normalized with the flow rates as pounds of ammonia per day in the chart above, this
demonstrates that the amount of ammonia entering the system does not correlated with the
observed flow rate.
Nye,Joe"Addressing the Challenge of Removing Ammonia from Wastewater",WaterWorld,March 2010,online
Collection and Treatment Evaluation 6

Annual Average Flow to NH3
14 1
0.9
12
0.8
10 0.7
8 0.6
0.5 -
'" NH3
Z 6 0.4
4 0.3 -Average Annual Flow
0.2
2
0.1
0 0
cr Lt.) co on N m 1 ( o0 0-)
0 0 0 0 o O <-1 N ..
0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0
N N N N N N N N N N N N N N N N
Year
The expected increase in concentration as the flow decreases demonstrates the continued
noncompliance with the NPDES permit. The Town must reduce the flow considerably in order
to return to biological treatment. However, the current infrastructure and operation of the plant
cannot be optimized or modified without additional processes or equipment to treat the ammonia.
As such, the plant will continue to release effluent that is out of compliance with the NPDES
permit limit until such time as the Plant undergoes a substantial rehabilitation or replacement.
The Town also has issues meeting the TSS limits. This is primarily due to the limited ability to
process and store solids. The existing storage tank can only be filled approximately 50%, which
eliminates the ability to thicken the sludge and decant. This reduces the ability of the Plant staff
to transfer solids from the sedimentation basin and increases the cost and frequency of third-
party solids removal. The solids removal issue reduces the Plant's capacity to settle BODs and
TSS, and increases the risk of non-compliance,particularly during a high flow event. At the
time of this writing, the sedimentation basin is in need of solids removal due to the availability of
room in the sludge holding tank and the financial cost of disposal. The Town is in the process of
awarding a contract to remove the solids accumulated in the Plant, and has tasked LaBella with
investigating operational and process changes to more efficiently settle solids and address the
sludge removal. Recent Influent sampling test have revealed that the Plant has much higher TSS
than would be expected from a typical WWTP.
In addition to issues with the Plant, the Town also has regulatory compliance issues with the
SASS. The primary infractions with the SASS are SSOs from lake infiltration and inflow and
Collection and Treatment Evaluation 7

i
The Historic Effluent DMR data is summarized on the table below, and further demonstrates the
inability of the Plant to meet the NPDES limits.
Historic DMR Data(Jan/2004-Jan/2020)
BOD TSS NH3(Summer)
Description mg/L Limit mg/L2 Limit mg/L4 Limit
Max Daily 65.9 N/A 120 N/A 27.2 N/A
Average Daily 10.0 N/A 25.7 N/A 8.1 N/A
Max Weekly 52.1 45 26.3 45 22.3 28.2/15.6
Average Weekly 10.0 45 24.3 45 6.8 28.2/15.6
Max Monthly 32.4 30 26.3 30 17.1 9.4/5.2
Average Monthly 9.9 30 24.3 30 6.8 9.4/5.2
Until recently, composite influent test results were not available. The currently available influent
and corresponding effluent limits are shown below, with the removal quantities.
Plant Composit Sampling
Influent(mg/L) Effluent(mg/L) Removal (mg/L)
Date BOD TSS NH3 BOD TSS NH3 Fe BOD TSS NH3
4/21/2020 62 720 4.9 3.2 16 4.9 58.8 704 0
4/22/2020 47 220 5.4 3.2 18 5.7 43.8 202 -0.3
4/27/2020 76 360 5.3 3.2 29 5.9 11 72.8 331 -0.6
4/29/2020 54 300 4.9 3.4 23 5.5 50.6 277 -0.6
5/4/2020 80 350 4.6 4.4 13 4.9 0.078 75.6 337 -0.3
5/5/2020 24 50 4.4 4.4 20 4.4 19.6 30 0
5/19/2020 67 310 6.1 4.2 17 5.6 62.8 293 0.5
5/20/2020 38 260 3.4 3.4 19 3.7 34.6 241 -0.3
Average 56.00 321.25 4.88 3.68 I 19.38 5.08 I 5.54 52.33 I 301.88 I -0.20
Sample consumed DO
The influent characteristics above were used to approximate the change in characteristics with
reductions in lake infiltration. This was accomplished by using the average pounds per day of in
each category and then calculating the concentration at various flow rates. The historic average
removal efficiencies were used to estimate the effluent characteristics. These are shown in table
and chart form below, and are the basis for the proposed SOC limits.
Collection and Treatment Evaluation 10
1

The Historic Effluent DMR data is summarized on the table below, and further demonstrates the
inability of the Plant to meet the NPDES limits.
Historic DMR Data(Jan/2004-Jan/2020)
BOD 1 TSS I NH3(Summer)
Description mg/L Limit mg/L2 Limit mg/L4 Limit
Max Daily 65.9 N/A 120 N/A 27.2 N/A
Average Daily 10.0 N/A 25.7 N/A 8.1 N/A
Max Weekly 52.1 45 26.3 45 22.3 28.2/15.6
Average Weekly 10.0 45 24.3 45 6.8 28.2/15.6
Max Monthly 32.4 30 26.3 30 17.1 9.4/5.2
Average Monthly 9.9 30 24.3 30 6.8 9.4/5.2
Until recently, composite influent test results were not available. The currently available influent
and corresponding effluent limits are shown below, with the removal quantities.
Plant Composit Sampling
Influent(mg/L) Effluent(mg/L) Removal (mg/L)
Date BOD TSS NH3 BOD TSS NH3 Fe BOD TSS NH3
4/21/2020 62 720 4.9 3.2 16 4.9 58.8 704 0
4/22/2020 47 220 5.4 3.2 18 5.7 43.8 202 -0.3
4/27/2020 76 360 5.3 3.2 29 5.9 11 72.8 331 -0.6
4/29/2020 54 300 4.9 3.4 23 5.5 50.6 277 -0.6
5/4/2020 80 350 4.6 4.4 13 4.9 0.078 75.6 337 -0.3
5/5/2020 24 50 4.4 4.4 20 4.4 19.6 30 0
5/19/2020 67 310 6.1 4.2 17 5.6 62.8 293 0.5
5/20/2020 38 260 3.4 3.4 19 3.7 34.6 241 -0.3
Average 56.00 321.25 4.88 3.68 I 19.38 I 5.08 5.54 52.33 I 301.88 -0.20
Sample consumed DO
The influent characteristics above were used to approximate the change in characteristics with
reductions in lake infiltration. This was accomplished by using the average pounds per day of in
each category and then calculating the concentration at various flow rates. The historic average
removal efficiencies were used to estimate the effluent characteristics. These are shown in table
and chart form below, and are the basis for the proposed SOC limits.
Collection and Treatment Evaluation 10
I

Estimated Average Monthly Characteristics
Average Observed Removal 58% 50% 0%
Flow Influent(mg/L) Effluent(mg/L)
MGD BOD TSS NH3 BOD TSS NH3
0.10 358.78 2006.95 31.49 150.69 1003.47 31.49
0.15 239.18 1337.97 20.99 100.46 668.98 20.99
0.20 179.39 1003.47 15.75 75.34 501.74 15.75
0.25 143.51 802.78 12.60 60.27 401.39 12.60
0.30 119.59 668.98 10.50 50.23 334.49 10.50
0.35 102.51 573.41 9.00 43.05 286.71 9.00
0.40 89.69 501.74 7.87 37.67 250.87 7.87
0.45 79.73 445.99 7.00 33.49 222.99 7.00
0.50 71.76 401.39 6.30 30.14 200.69 6.30
0.55 65.23 364.90 5.73 27.40 182.45 5.73
Estimated Average Weekly Characteristics
Average Observed Removal 58% 50% 0%
Flow Influent(mg/L) Effluent(mg/L)
MGD BOD TSS NH3 BOD TSS NH3
0.10 538.16 3010.42 47.24 226.03 1505.21 47.24
0.15 358.78 2006.95 31.49 150.69 1003.47 31.49
0.20 269.08 1505.21 23.62 113.01 752.61 23.62
0.25 215.27 1204.17 18.89 90.41 602.08 18.89
0.30 179.39 1003.47 15.75 75.34 501.74 15.75
0.35 153.76 860.12 13.50 64.58 430.06 13.50
0.40 134.54 752.61 11.81 56.51 376.30 11.81
0.45 119.59 668.98 10.50 50.23 334.49 10.50
0.50 107.63 602.08 9.45 45.21 301.04 9.45
0.55 97.85 547.35 8.59 41.10 273.67 8.59
The modified SOC limits represent what the Plant can be reasonable expected if operated at its
maximum efficiency.
Collection and Treatment Evaluation 11

Biochemical Oxygen Demand(BOD)
The DMR data shows a high degree of variation in the Plant effluent BOD concentration. The
Plant violated the monthly and weekly NPDES limits. This variation in BOD is reflective of the
inefficiencies inherit in the Plant's current process. The proposed SOC limits for average
monthly and weekly are 60.0 mg/L and 90.0 mg/L respectively, and are reflective of the Plants
ability to remove BOD based on historical data from 2004 to present.
Total Suspended Solids(TSS)
The DMR data shows a fairly consistently, but high level of TSS. The average influent TSS was
321 mg/L. The daily maximum TSS during this period was 720 mg/L, which demonstrates the
potential for TSS related NOV's. This is particularly the case as the system ages and as the
phase 1 project is undertaken. The proposed SOC limits for average monthly and weekly are
340 mg/L and 510 mg/L respectively.
Ammonia (NH3)
The DMR data shows a high degree of variation in the Plant ammonia effluent concentration and
an inverse relationship with the flow rate. The table below shows the limitedly available
influent, effluent ammonia concentrations and the removal percentages. The data confirms that
the plant does not remove ammonia. In fact, the solids handling issues at the plant are such that
the removal percentages are negative. The Town is currently bidding a project to remove and
alleviate this issue, however the process will continue to allow ammonia to "pass through"the
Plant. The maximum monthly average in pounds per day measured 64.7 pounds and occurred in
July 2014. The maximum weekly in pounds per day measured 81.4 pounds and occurred in July
2017. The daily maximum in pounds per day measured 116 pounds and occurred in August
2011. As the flow rates decrease, the concentration of ammonia will increase. Given that the
current process cannot remove ammonia,the effluent concentrations increase accordingly. The
high variation in ammonia concentrations, and the realization that improvements to the SASS
will increase these concentrations, makes the estimation of the estimated ammonia
concentrations speculative. As such, the Town is proposing the SOC limits for average monthly
and weekly would be monitor and report for both the summer and winter limits during the SOC
period.
Collection and Treatment Evaluation 12
I _

Ammonia Concentrations
Date Influent Effluent %-
(mg/L) (mg/L) Removal
4/21/2020 4.9 4.9 0.0%
4/22/2020 5.4 5.7 -5.6%
4/27/2020 5.3 5.9 -11.3%
4/29/2020 4.9 5.5 -12.2%
5/4/2020 4.6 4.9 -6.5%
5/5/2020 4.4 4.4 0.0%
5/19/2020 6.1 5.6 8.2%
5/20/2020 3.4 3.7 -8.8%
Average 4.875 5.075 -4.53%
Iron (Fe)
The level of iron in the wastewater received by the Plant has long been a source of curiosity for
the Town. In an effort to determine the source of the iron, we took samples from the Lake itself
and determined by the iron content of the lake water was 0.387 mg/L on average. The historic
average iron effluent is 30.03 mg/L, which is over 77 times the lake concentration. It is
conclusive that the lake water and naturally occurring iron are not the primary source of the iron.
Based on videos of the pipe condition, it is believed that the CI pipe itself is the source of the
iron as it daily degrades. The full effect of iron on a potential biological process is still being
investigated. The current NPDES requirements for iron is monitor and report. The Town would
propose that this requirement would remain as part of the SOC.
Sanitary Sewer Overflow(SSO)
The Town is unable to consistently comply with the conditions set forth in Section I, paragraph 2
of permit WQCS00131 as it relates to SSOs corresponding to General Statutes 15A NCAC
02T.0108. The Town would propose to meet all the terms and conditions of the permit, except in
relation to Section I,paragraph 2 mentioned above. The Town shall make every effort to prevent
the discharge of wastewater to the ground or surface waters, and shall engage in a phased project
to reduce the lake infiltration, to reduce the potential for and magnitude of an SSO.
Collection and Treatment Evaluation 13

The table below summarizes proposed modified SOC limits.
Proposed SOC Limits
Permit Limits Modified Limits(SOC)
Parameter Units Mnthly Avg. Weekly Avg., Mnthly Avg. Weekly Avg.
Biochemical Oxygen Demand (BOD;mg/L 30.0 45.0 60.0 90.0
Total Suspended Solids(TSS) mg/L 30.0 45.0 340 510
NH3- N (April 1-Oct 31) mg/L 9.4 28.2 Monitor&Report
Fe mg/L Monitor&Report Monitor&Report
Collection and Treatment Evaluation 14
L

VI. PREDICTED COMPLIANCE SCHEDULE:
The Table below establishes a number of milestones and completion dates. These milestones
will need to be completed as part of the process to achieve long-term NPDES compliance.
However, these steps alone will not achieve long-term compliance. The steps below are
attempting to achieve short and mid-term compliance in a multiphase, multiple year project.
This phasing is due to the realities of the complexity of the infrastructure issues and financial
cost of the improvements compared with the financial abilities of the Town. These steps are a
large part of the process, with the remaining step following as funding becomes available.
SOC Compliance Schedule
Milestones Completion Date
Issue Request for Qualifications for On-Call Services 11/4/2019
Interview Qualified Firms 1/7/2020
Award On-Call Services 1/14/2020
Present Technical Memo to NC DEO, UAB,and Town Council 1/29/2020
Pre-application Meeting 2/12/2020
Install meter to monitor ADF and l&I from Rutherford County line serving CRV 4/15/2020
Develop a lake infiltration model 6/26/2020
Begin Collecting composite influent samples at WWTP 7/3/2020
Present flow, l&I,and composite effluent findings to DWR 8/20/2020
Complete AIA grant application 9/30/2020
Compete Phase ldesign 3/1/2021
Phase 1 Permitting 5/1/2021
Complete Phase 1 Construction 4/30/2022

VII. FUNDING SOURCES IDENTIFICATION:
• The Town is currently preapproved for a$12.5 million CWSRF loan, and is in the
process of completing the ER-EID necessary to finalize the funding. A copy of the intent
to fund is attached.
• The Town will apply for an AIA grant from the State of North Carolina. These grants are
up to $150K and allow for the inventory and condition assessment of existing assets.
• The Town has increased utility rates and is evaluating future rate increases to fund debt
service, consulting, and other cost related to capital improvement projects.

PAT MCCRORY
;:• (La vaw.
1)ONAt.I) R. VAN DER VAART
Water Infrastructure
CNVIRONNENTAL OUALI(Y KIM H. COLSON
August I,2016
Mr. Ron Nalley, Manager
Town of Lake Lure
P.O. Box 255
Lake Lurc, NC 287/16
SUBJECT: Clean Water State Revolving Fund
Letter of Intent to Fund
Gremlin
April 2016 Application Cycle
Project No.CS370489-05
Dear Mr. Karr:
The Division of Water Infrastructure has reviewed your application to the Clean Water
State Revolving Fund(CWSRF)program,and the State Water Infrastructure Authority has
approved your project as eligible to receive a low-interest loan. The total loan amount will be
$12,580,261.$500,000 of the total loan will be in the form of principal forgiveness and the
balance will have a maximum interest rate of 0%. A loan fee of 2% will be invoiced after bids
have been received.
Please note that this intent to fund is contingent on approval of the loan through the Local
Government Commission and on meeting all of the following milestones:
Milestone Date
Engineering Report Submittal December 1, 2016
Engineering Report Approval May 1,2017
Bid and Design Package Submittal November 1,2017
Bid and Design Package Approval March 1,2018
Advertise Project,Receive Bids, July 2,2018
Submit Bid information, and Receive
Authority To Award
Execute Construction Contract(s) August 1,2018
The first milestone is the submittal of an Engineering Report by close of business on
December 1,2016. The Engineering Report must be developed using the updated guidance
found on our website (http:/lportal.ncdenr.orglwehtwilhome). Failure to meet any milestone
may result in the forfeiture of funding for the proposed project.
is> Notliin0 Compares:
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1633 1,14 Sc,.k C'c n c i,R tkigli,North Csrolina 27699 I Lurntim 512 N.Solishury Sarre?,P,AkO,Nntlh Carolpn 21604
919 707 9160 7
•
II

I
VIII. EMERGENCY RESPONSE PLAN

Town of
-we" /Vie
est. 192 i 'North Carolina
Collection System Emergency Response Plan
June 2020
Maurice J. Walsh, P.E.
LaBella
JWered by partnership.

Table of Contents
I. Emergency Contacts 1
g Y
II. Emergency Alerting List 2
III. Purpose 2
IV. Situation and Assumptions 2
V. ERP Sequence of Actions 2
Suggested Emergency Preparedness Actions 3
Sequence of ERP Events 3
SASS Emergency Response Plan ii

I. Emergency Contacts
Name Organization Phone Number
Shannon Baldwin, City Mangager Lake Lure [phone]
David Arrowood , PWD Lake Lure [phone]
Scott Biddy, Sewer Dpt. Sup. Lake Lure [phone]
Dean Lindsey, Dam/Hydro Dir. Lake Lure [phone]
Dustin Wacaster, Fire Chief Lake Lure [phone]
SASS Emergency Response Plan 1

II. Emergency Alerting List
Name Q ganization Phone Number
Tim Heim, Env. Eng. DWR—Asheville RO [phone]
Mikal Willmer, Env. Sp. II DWR—Asheville RO [phone]
III. Purpose
This emergency response plan (ERP)has been developed to provide procedures for the Town of
Lake Lure (Town)to respond to a catastrophic failure of the subaqueous sewer system(SASS)
that results in a continuous and uncontrollable sanitary sewer overflow(SSO).
IV. Situation and Assumptions
The SASS consists of approximately 14 miles of cast iron pipe installed in the late 1920's, and
placed adjacent to the broad river prior and then submerged as the lake was filled. The SASS is
prone to lake infiltration, has undergone numerous repair projects, and a majority of the SASS is
of an unknown condition. It is assumed that a failure in part of the line would result in a
sustained flow that would present as an SSO at the headworks pumping station. This failure, if
left unattended, would drain the lake above the failure and cause immediate economic,
and social impact to both the Town o f Lake Lure and the surroundingarea.
environmental, p
V. ERP Sequen
ce of Actions
The Town of Lake Lure staff and elected officials have primary responsibility for the SASS, and
for maintaining, repairing, and reporting its condition to the related stake holders.
SASS Emergency Response Plan 2

Suggested Emergency Preparedness Actions
• Interview and select a diving contractor with the relevant experience who could respond
as quickly as possible to potential SASS failure and assist in the location and repair of
said failure.
o The emergency contact information for two or more representatives should be
added to the emergency contact list.
• Lake Lure should procure and store the necessary repair materials that may reasonably be
used to repair a SASS failure.
o These should be stored in a known location and readily accessible to Town staff.
• Lake Lure should hold a training session annually with the Town staff over how to
respond to a SASS failure.
• Until the completion of the SASS replacement, the Town of Lake Lure should include an
ERP briefing in a public commissioners meeting on an annual basis.
• Lake Lure should investigate the best method for providing an emergency announcement
to the Lake Lure community in the event of an SASS failure.
•
Sequence of ERP Events
• Upon the discovery of an SSO, Town staff shall respond to the head works pump station
and assess the magnitude of the SSO event.
• Town staff should evaluate the operation of the pump station to determine if the SSO is
the result of pumping failure or overwhelming flow from the SASS.
• In the event of pumping failure, the Town should take what actions are necessary to
return the pump station to normal operations.
• If the pump station is fully operational, the Town staff shall access the cause of the
excess flow, such as I&I from a rain event.
• Town staff should begin the SSO notification process that includes DWI—Asheville RO,
Town Manager, and other elected officials.
• Town staff shall visually inspect the connection points with contributing systems such as
Rumbling Bald and the County line serving Chimney Rock Village to determine if the
SSO is a result of a failure in a connecting system.
• If the magnitude and duration of the SSO is such that it is continuous and uncontrolled,
the Town shall begin the notification process of the individuals listed in Sections I and II.
SASS Emergency Response Plan 3

• The Town shall begin the lake drawdown process subject to the established requirements
and conditions until that lake level is reduced to its lowest level or the SSO stops, which
ever come first.
• The Town shall notify the public of a potential SASS failure and shall restrict access to
Lake Lure for staff, contractors, consultants, and related regulatory staff.
• The Town shall execute the closing procedures of the emergency shutoff valve to reduce
the flow until the SSO is eliminated.
• The selected diving contractor/s shall be mobilized to begin searching for the leak.
• The Town shall throttle the emergency shut-off valve the extent that the subsequent flow
and sound may be utilized in the search for the failure.
o The flow rate shall not exceed the headworks pumping capacity.
o This process shall take place with close coordination of applicable.
o The emergency shut-off valve shall be continuously staffed when it is not fully
closed for the duration of the failure event.
• 1The Town shall activate the Sewer Access Valve and begin the lake drawdown process
subject to the established requirements and conditions until that lake level is reduced to
its lowest level or the SSO stops, which ever come first.
• Once the failure is located,the pipe shall be repaired, and the location documented.
o If possible a coupon of the pipe shall be taken for further analysis.
o The repair should be documented with video and/or photographs.
• The emergency access valve shall be opened slowly to drain the SASS and verify the
failure event is suspended.
• Once the failure event has been resolved, the Town shall notify the public and emergency
contacts that the situation is resolved.
• The Town shall restore the lake levels to normal and open the lake to normal operations
' The Sewer Access Valve is a proposed capability
SASS Emergency Response Plan 4