WQ0037555_STFRPT_20210104

State of North Carolina
Department of Environmental Quality
Division of Water Resources

Water Quality Permitting
Regional Staff Report

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

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0037555
Attn: Lauren Plummer 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: 03/11/19- Infiltration basin not currently in use, but visited site in 2019 during NPDES
inspection (NC0059200)
b. Site visit conducted by: Mikal Willmer
c. Inspection report attached? Yes or No (NPDES Inspection in LF , ND compliance inspection not
conducted, only visited the facility components-facility not in use. ) ND Inspection will occur later this
month.
d. Person contacted: Freddie Boan, General Manager and their contact information: 828.226.9161
e. Driving directions: WWTP: Take I-40 W from Swannanoa and take exit 27 towards Sylva, stay on US-
74 W for approximately 21 miles to Exit 85. Follow NC-107 for 26 miles and then turn right onto N
Norton Rd. Turn right onto fenley forest trail. The WWTP is 0.3 miles on the right. Infiltration Basin-
Take the left immediately before you reach fenley forest trail and then a left at the T intersection. The
infiltration basin is approximately 0.1 miles from the intersection.
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: 38BD4323-7AAF-4CE6-B547-F8BBFEAEDC03
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
WW-II Facility rating. ORC: Michael Beck Certificate #:7930 Backup ORC: Robert Barr Certificate #:8928
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: Unknown, High-rate infiltration basin has not been put into use. The WWTP has had
structural and manufactural defects since being put into operation. Facility is still struggling to consistently
comply with NPDES permit limits.
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: Unknown, facility has not been used. During last site visit vegetation appeared
maintained and staff attempt to sample monitoring wells, but they are consistently dry.
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: Wells are dry- regional office was not contacted before drilling, site is vegetated
(originally permitted without vegetation).
5. Is the residuals management plan adequate? Yes or No N/A
If no, please explain: Solids are hauled to Franklin WWTP
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: Unable to sample due to
wells being dry.
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: Need clarification on what is installed. A to C certification sent to NPDES Unit in 2016
does not match what is listed in the ND permit. Infiltration basin was also constructed with a vegetative
cover. Engineer has yet to submit a signed certification letter for ND portion of the facility. MW-4 is not
installed and should be removed from the permit. There are two downgradient wells W2 & W3. W1 is
upgradient.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain: ARO hydrogeologist was not notified before well construction. Wells are consistently
dry when staff attempt to sample. Our records indicate we have still not received the GW-1 well
construction forms.
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary): Still show as “proposed” in BIMS, no record
of GW-1s being submitted. No coordinates listed in BIMS. Application lists MW-4, which was not
installed, should be MW-3.
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: No NDMR data has been collected, but facility has
had consistent NPDES permit limit exceedances. No data on GW-59s because wells are dry.
DocuSign Envelope ID: 38BD4323-7AAF-4CE6-B547-F8BBFEAEDC03
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.)
Facility never submitted all or the correct requested additional information for modification application in
2018.
15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain: Previous modification application was returned due to missing items from the
additional information request. Most of these items still appear to be missing. The modification submitted
by Mr. Burgin in 2020 appears to be a resubmittal of information generated in 2014.
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: Yes, issues noted above.
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain: No issue if all requested items are submitted.
2. List any items that you would like Non-Discharge Central Office to obtain through an additional information
request:
Item Reason
Updated O&M Plan
Modification submitted in 2018 did not appear to contain updated O&M Plan to
address maintaining vegetative cover on Infiltration basin. Most recent
submittal is dated November 2014. Information does not appear to have been
submitted with 2020 renewal/modification. (02T.0707)
GW-1
Provide GW-1 forms for monitoring wells drilled with correct designations and
coordinates- (BIMS lists MW-1, MW-2 & MW4. Trillium installed MW1, 2 &
3. These were never submitted, as requested in 2018.
Updated Site Map
Site Map submitted in 2018 does not appear to identify/label any streams, ponds
or natural drainage features within 500’ of all facilities. The 500’ boundary
depicted appears greater than 500’ on the east and west side of the infiltration
basin. Wetted perimeter is not labeled. The property owners within 500’ are not
identified on the map, only parcel locations. Clearly label and identify all
required items within the map’s legend. (02T.0704(d))
Engineering Certification
Engineering certification does not appear to have ever been submitted. Ensure
component descriptions are accurate as there have been discrepancies from the
originally listed components. Phase I installed WWTP components were
designed for 80,000 gpd not 104,000 gpd according to previous emails with Mr.
Burgin and engineering plans. Currently the facilities combined disposal
volume is 40,000 gpd under the NPDES permit and 17,533 gpd to the one
constructed infiltration basin for a total permitted flow of 57,533 gpd between
both permits.

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason

DocuSign Envelope ID: 38BD4323-7AAF-4CE6-B547-F8BBFEAEDC03
FORM: APSRSR 04-10 Page 4 of 4

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 WQROS regional supervisor:

Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
1. During the site visit in 2019 and after reviewing submitted drawings and maps, it was noted a force main was
routed to one of the golf course ponds from the WWTP. This force main was not permitted in either the NPDES
modification and/or the non-discharge application. A reclaimed application was never submitted. Additionally,
the freshwater irrigation pond is unlined and has a standpipe that discharges to Norton Creek WS-III Tr. Trillium
staff were directed to lockout the valve to the pond from the WWTP. Staff were informed a discharge to this
pond from the WWTP would be considered a discharge without a valid permit and in violation of state statute.
Trillium was provided a reclaimed use application and advised of the steps necessary to utilize reclaimed quality
wastewater for golf course irrigation.

2. Currently the ARO is not requesting redrilling of the wells. The issue of dry wells during sampling will be
reassessed if/when Trillium begins using the high-rate infiltration basin.

DocuSign Envelope ID: 38BD4323-7AAF-4CE6-B547-F8BBFEAEDC03
1/4/2021
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Subject: Please DocuSign: WQ0037555_STFRPT_20210104.docx
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Mikal Willmer
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Environmental Specialist
North Carolina Department of Environmental Quality
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G. Landon Davidson
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Asheville Regional Office, Regional Supervisor
DEQ, Division of Water Resources, Water Quality
Regional Operatoins
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