WQ0019960_STFRPT_20210409

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
April 9, 2021

To: DWR Non-Discharge Permitting Branch Application No.: WQ0019960
Attn: Poorva Mokashi 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: 04/08/2021 Recon fields and visited WWTP on February 5th. Compliance inspection
2019.
b. Site visit conducted by: Mikal Willmer
c. Inspection report attached? Yes or No
d. Person contacted: Zach Key and their contact information: 336-957-7871
e. Driving directions: From Asheville: I-40 E to Exit 86. Turn left on Hwy. 226. The WWTP is approximately
½ mile on the right.
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: 66F51EBA-05B3-4911-AEF9-C2C416576402
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: Dennis Key Certificate #:15704 Backup ORC: Zack Key Certificate #:27660
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: Two of the previous permitted fields are being deleted due to change of ownership and
potential development. Based on a nitrogen application rate for the current crop, there is still adequate
acreage; however, phosphorus levels should be closely monitored. See additional information in Section V.
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:
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
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: .
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:
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.)
15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
DocuSign Envelope ID: 66F51EBA-05B3-4911-AEF9-C2C416576402
FORM: APSRSR 04-10 Page 3 of 4
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 Non-Discharge Central Office to obtain through an additional information
request:
Item Reason
Corrosivity Methodology
Request permittee verify corrosivity methodology used by the contract
laboratory. 9045D is used to determine the pH of matrices that have a water
content less 20%. Marion’s digested sludge failed the paint-filter test and had a
percent moisture of 98.3%. It appears 9040C should have been used to
appropriately assess corrosivity characteristics of the sample under RCRA.
Resubmit Data The certificate of analysis from ETS is eligible after scanning. Believe it
contains the nutrient and metals determinations.
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 WQROS regional supervisor:

Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
It is recommended phosphorus levels continue to be monitored closely. Application rates and monitoring are
currently based on the nitrogen uptake rate of the crop for the soil series of each field. Specifically, fields F1
and F3 should continue to be evaluated as the P-I was very high (around 200) during the last soil fertility
analysis.
DocuSign Envelope ID: 66F51EBA-05B3-4911-AEF9-C2C416576402
4/9/2021
FORM: APSRSR 04-10 Page 4 of 4
The staff report from 2015 indicated concerns with land application on fields K1 & K2 due to it previously
being used as an apple orchard. For the permitting record, these fields are being deleted this permit cycle due
to change of ownership and potential development.
DocuSign Envelope ID: 66F51EBA-05B3-4911-AEF9-C2C416576402