NC0065986_STFRPT_20200918

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: NC0065986
Attn: Sydney Carpenter Facility name: Dogwood Trails

From: Mikal Willmer
Asheville Regional Office

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: 08/24/2020
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: Head west on I-40 from Asheville and take Exit 27 towards Waynesville/Maggie
Valley. Take exit 103 (Dellwood Rd.) and continue on towards Maggie Valley for approximately 7 miles.
Turn right onto Evans Cove Rd. Go about one mile and turn left onto Cottontail trail. The community
is gated, but the WWTP is immediately to left when you enter.
2. Discharge Point(s): Outfall 001- Coordinates need to be updated in BIMS
Latitude: 35.528184, Longitude: -83.088142
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification: C, Tr.
River Basin and Subbasin No. French Broad, Pigeon River Subbasin 06010106
Describe receiving stream features and pertinent downstream uses: Evans Cove flows into Jonathans
creek, used for trout fishing.
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:
DocuSign Envelope ID: 05DCE873-055F-4983-B801-93E1E066BEF2
FORM: WQROSSR 04-14 Page 2 of 5
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 #: 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:
Description of existing facilities: A 0.01 MGD package plant consisting of an aeration basin, diffusers,
rectangular clarifier, sludge holding tank, chlorinator and dechlor.
Proposed flow:
Current permitted flow: 0.02 MGD (needs to be updated)
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.) Please note there are discrepancies based on the originally issued AtoC and the permitted flow over
the years. Our records indicate the facility was originally issued an AtoC for a 0.01 MGD facility which
would later be phased to 0.02 MGD as the development grew (addition of a second treatment train). No
records in our database show an additional or revised AtoC was ever issued. During my inspection, the
facility did not appear adequately sized visually to be permitted for 0.02 MGD. The permittee was asked to
verify or provide documentation of the true hydraulic capacity. The ORC conducted a volume test and
determined the aeration basin was sized for approximately 0.01 MG. Environmental Inc. Contract firm
indicated they would submit an email regarding the volume test.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No - NA
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: See comments above about recorded permitted flow.
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 NA
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:
DocuSign Envelope ID: 05DCE873-055F-4983-B801-93E1E066BEF2
FORM: WQROSSR 04-14 Page 3 of 5
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: See comments above.
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: One monitoring violation in 2017. No consistent
compliance issues noted
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?
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: Chlorine disinfection; however, dechlorinated before discharged.
17. Pretreatment Program (POTWs only): N/A

DocuSign Envelope ID: 05DCE873-055F-4983-B801-93E1E066BEF2
FORM: WQROSSR 04-14 Page 4 of 5
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

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 regional supervisor:

Date:
DocuSign Envelope ID: 05DCE873-055F-4983-B801-93E1E066BEF2
9/17/2020
FORM: WQROSSR 04-14 Page 5 of 5
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Environmental Inc. should be sending in an email stating the results of the volume test conducted by the ORC.
No additional documentation on file in the ARO and/or central office indicate modifications were made to
permit or increase the originally issued AtoC from 0.01 to 0.02 MGD. Please note, the ARO does not currently
have any concern with the facility, as of right now, of exceeding the hydraulic capacity of the currently
installed treatment train (0.01 MGD). The annual average daily flow from the past 12 months was
approximately 800 gallons.

DocuSign Envelope ID: 05DCE873-055F-4983-B801-93E1E066BEF2