NC0085952_Fact Sheet_20210413

DENR/DWQ
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit: NCO085952
2021 Renewal
This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets.
Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be
administratively renewed with minor changes, but can include facilities with more complex issues (Special
Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns).
Facility and Stream Information
Applicant/Facility Name:
TA Operating, LLC Candler Travel Center
Applicant Address:
24601 Center Ridge Road, Suite 200; Westlake, OH 44145-5634
Facility Address:
153 Wiggins Road; Candler, NC
Facility Class Permit Status:
Grade II Biological
WPCS Renewal
Permitted Flow (as built)
0.025 MGD
Type of Waste
100% Domestic
Receiving Stream
UT to George Branch
Stream Class ID
C 6-76-3
River Basin
French Broad
Subbasin
04-03-02
HUC
0601010SO502
USGS Too
Canton, NC 177SE
7Q10 Sum Win cfs
0 0
30Q2 cfs
0.05
Avg. Stream Flow cfs
0
IWC %
100%
County
Buncombe
I Regional Office
ARO
Basic Information for
Expedited Permit Renewal
Permit Writer / Date
Bradley Bennett / February 8, 2021
Does permit need daily max NH3 limits?
Limits in permit 2 10 S ; 4 20 W
Does permit need TRC limits/language?
Limit in permit 17µ L
Does permit have toxicity testing?
No - does have NH3-N limits
Does permit have Special Conditions?
No
Does permit have instream monitoring?
Yes; U D for DO and Temp
Stream on 303 d List? For w/parameter?
None other than statewide mercury listing
Any compliance concerns?
See compliance discussion below
Any modifications since last permit?
Cover letter notes tertiary filter has been removed
New expiration date:
I October 31, 2025
FACILITY OVERVIEW:
This facility is 100% domestic waste. The application notes that the facility serves a commercial establishment
(travel center/gas station) with 20 employees. The facility has a restaurant, bathrooms and showers and is
permitted at 0.025 MGD. The treatment system is an extended aeration plant and consists of the following
wastewater treatment components:
• 6,260- gallon aerated equalization basin
• Bar screen
• Flow splitter box
• 31,250-gallon aeration basin configured in two trains
• Dual secondary clarifiers
• Dual cell (dual media) tertiary filtration system (Offline)
• 530-gallon chlorine contact tank
• Dechlorination
• 3,800-gallon sludge holding tank
• Standby power supply

The cover letter with the application noted one change at the facility. It was indicated that the effluent tertiary
filter had malfunctioned and was not rebuilt because it was not cost effective. The letter also indicated that the
filter was not necessary to meet the permit effluent limits. Asheville Regional Office (ARO) staff has
communicated with the ORC on this issue and are satisfied with the facility's decision on this component at this
time. The tertiary filter will remain in the components list in the permit but will be noted as "Offline." The
Division will continue to monitor this issue and may request that the filter be reinstalled in the future.
Owner Name: On this application the Owner is indicated as HPT TA Properties Trust. In BIMS the owner is
listed as TA Operating, LLC. The owner contact, Rob Porges, indicted that HPT has owned the property since
2007 but TA Operating, LLC operates the site. He also noted that the 2015 application was submitted the same
way. Checking the Secretary of State website, HPT Properties Trust is not a listed corporation in NC. Since TA
Operating is the apparent operator and is a valid NC corporation this appears okay.
INSPECTION
The most recent inspection (September 12, 2018)) noted that a new flow meter was being purchased and that
sampling was timed and before the dechlorination. In addition, the inspection summary noted that solids levels
were high and that the tertiary filters were not in use (see discussion above). ARO staff also visited the site on
September 13, 2018 for a technical assistance visit and discussed these issues, especially the tertiary filters.
COMPLIANCE:
During the permit cycle this facility received six (6) enforcement actions. These actions assessed $ 1,950 in
penalties along with $706.79 in enforcement costs. The last enforcement action occurred in December 2019.
The facility received one (1) NOD for inspection issues in 2018 and ten (10) NOVs mainly for BOD exceedances,
but also for a few NH3-N violations. There were no NOV's or enforcement actions in 2020.
MONITORING DATA REVIEW:
Parameter Units
Avg.
High
Low
Permit Limit
Comments
6 individual values >0.025 but no
Flow (MGD)
0.025 MA
monthly values > 0.02
5.0 MA
9 daily values > 7.5 (out of 156)
BOD (mg/L) Summer
3.35
12.6
<2
7.5 DM
4 monthly avg. > 5 out of 35
10 MA
4 daily values > 15 (out of 109)
BOD (mg/L) Winter
3.90
20.2
<2
15 DM
1 monthly avg. > 10 out of 25
TSS (mg/L)
30 MA
No exceedances
45 DM
Temp (C) - Upstream
14.35
25.1
3
-
Temp (C) - Effluent
17.49
26.4
5
Temp (C) - Downstream
14.18
21
3
DO (mg/L) - Upstream
7.36
11.8
5.2
45 values < 6; nearly 10% of all values
DO (mg/L) - Effluent
7.04
9.8
6
Not < 6.0
No exceedances
DO (mg/L) - Downstream
7.88
11.9
5.4
-
20 values <6; 4% of all values
Fecal (#/100ml)
21.76
228
<1
200 MA
No exceedances
400 DM
pH (SU)
n a
8.3
6
6 to 9
None out of range
NH3-N (mg/L) Summer
0.90
9.2
<0.1
2 MA
3 monthly averages > 2
10 DM
NH3-N (mg/L) Winter
1.27
11.3
<0.1
4 MA
1 monthly average > 4
20 DM
TRC (µg/L)
5.37
7.5
5
17 DM
No exceedances
MA - Monthly Average DM - Daily Max Daily Average
The data reviewed for the renewal is from November 2015 through December 2020.
Candler Travel Center WWTP Fact Sheet
NPDES Renewal 2021 - February 15, 2021
Page 2

BOD AND NH3-N - LIMITS REVIEW
Candler Travel Center's main areas of concern have historically been with meeting restrictive limits for BOD
and NH3-N. Both of these parameters have effluent limits for summer and winter conditions. These limits were
set in a 1996 Waste Load Allocation (WLA) for discharge to a UT that is considered a zero flow stream. There
are some unique circumstances for Candler due to changes in drainage patterns over the years associated with
DOT roads that have resulted in impacts on their outfall location. The Candler discharge point is in very close
proximity with another permitted discharge (Days Inn NC0025933). That facility is considered to discharge
directly to George Branch and has higher effluent limits.
In 2018 the ARO staff questioned the issue of the different limits for the two discharges and requested review
of Candler's limits to potentially increase them. This issue was held for consideration during the permit
renewal. Central and Regional Office staff discussed the limit situations with these two facilities as they have
both been up for renewal. For Days Inn it was determined that their outfall location is actually in the flood
plain area of George Branch and it's higher limits based on dilution impacts are appropriate. The discharge
point for Candler is at a little different location in an area where a number of pipes from roadway drainage
come together. While the regional office has indicated that the area usually has flow, it does not always and the
discharge location is not connected directly to the flood plain area like Days Inn. Candler cannot extend their
discharge pipe to access George Branch directly because they cannot get access from DOT to put the line under
a road. It was determined that the limits in the Candler permit will remain unchanged.
This facility has been able to more consistently meet the permit limits for BOD and NH3-N over the last few
years. This is most likely due to improved operation of the facility with the current ORC. There have been no
BOD violations since 2018 and none for NH3-N since 2019. Hopefully this trend will continue. However,
regional office and central office permitting staff feel that it is reasonable in the fact sheet to point on these
issues so they can be considered in the future if issues arise with limit violations. Candler Travel should be
given some consideration for these circumstances when considering compliance actions in the future.
SAMPLE TYPE REVIEW
After the last permit issuance the ARO communicated with permitting staff about the sample type in the permit.
The permit requires composite monitoring for certain parameters even though the permitted flow is 0.025
MGD. Permitting staff indicated at the time that composite monitoring had been required when the permit was
initially issued and the permittee had not requested review. This was noted to be considered during the next
permit renewal. ARO staff have confirmed with the ORC that the permittee would like to change to grab
samples. The region notes that the plant discharge is not gravity but is pump controlled and not continuous.
This makes continuous flow and monitoring difficult. The region is in agreement with the change and the rules
[15A NCAC 2B .0505(c)(3)(B)] specify grab samples for facilities with design flows of 0.03MGD or less. Sample
type for BOD, TSS and NH3-N have been modified to Grab.
FILE HISTORY REVIEW SUMMARY
This facility was originally issued a NPDES discharge permit under NCO059188 in 1984. No treatment
system was ever built under that permit and it served as a potential backup to the onsite system. Since
the facility was never built, the permit was rescinded in 1993. Subsequently the onsite system failed
and with no other alternatives, this permit was issued December 1, 1997.
1996 Wasteload Allocation - The WLA was developed for a discharge to a zero flow tributary to George
Branch. This resulted in tertiary limits with BOD limits of 5/10 (s/w); NH3-N of 2/4; DO of 6; TSS at 30;
pH of 6-9; TRC of 17 and Oil and grease at 30. Instream sampling was also required for DO, TRC and
Temperature.
2000 Permit Renewal - This renewal removed influent monitoring for BOD and TSS, removed instream
monitoring for TRC and changed Oil and Grease monitoring type to grab.
Candler Travel Center WWTP Fact Sheet
NPDES Renewal 2021 — February 15, 2021
Page 3

2005 Permit Renewal - This renewal added daily limits for NH3-N. The review noted the presence of a
tire and repair shop onsite and need to review potential impacts in the discharge.
2010 Permit Renewal - The review documents note a number of permit violations that are attributed to
deficient operation. Violations were noted as decreasing with a new ORC in place. This permit updated
the treatment system description, added qualifiers on TRC compliance and removed oil and gas
monitoring. The renewal review also denied a request by the permittee for a change in BOD
monitoring.
2015 permit Renewal - The permit remained essentially the same in this renewal with updates for
eDMR and rule citations added.
PROPOSED PERMIT CHANGES:
• Updated eDMR requirements to be consistent with final EPA rule.
• Added regulatory citations throughout permit as needed.
• Updated treatment system components list in the permit to indicate that the tertiary filter is
"Offline."
• Modified sample type for various parameters that, by rule, can be handled as grab samples.
• Updated Latitude/Longitude and location of outfall on map.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: February 23, 2021
Permit Scheduled Effective Date: May 1, 2021
STATE CONTACT:
If you have questions concerning the above or the attached documents, please contact Bradley Bennett
at [e-mail] or [phone].
Candler Travel Center wwTP Fact Sheet
NPDES Renewal 2021 — February 15, 2021
Page 4

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4/13/2021
Mail - Bennett, Bradley - Outlook
[External] RE: Draft Permit - Candler Travel Center WWTP - NCO085952
Rob Porges <[e-mail]>
Thu 2/2S/2021 1:04 PM
To: Bennett, Bradley <[e-mail]>
Cc: [e-mail] <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Bradley:
Bob and I have reviewed the draft permit and do not have any comments.
Rob Porges
Director, Environmental Services
TA Operating LLC
24601 Center Ridge Road
Westlake, OH 44145-5639
440-808-7368
FAX [phone]
From: Rob Porges
Sent: Thursday, February 25, 2021 7:46 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Cc: [e-mail]
Subject: RE: Draft Permit - Candler Travel Center WWTP - NCO085952
Bradley:
Thanks for providing a copy of the draft permit. Yes, I was able to download/ view the file. I will review the draft and
discuss with Bob Gertzen.
Rob Porges
Director, Environmental Services
TA Operating LLC
24601 Center Ridge Road
Westlake, OH 44145-5639
440-808-7368
FAX [phone]
From: Bennett, Bradley <[e-mail]>
Sent: Thursday, February 25, 2021 7:36 AM
To: Rob Porges <[e-mail]>
Cc: bgertzen(@utilityservicescorp.com
Subject: [EXTERNAL] Draft Permit - Candler Travel Center WWTP - NCO085952
Mr. Porges,
The draft permit for your wastewater NPDES discharge permit is completed and will be going to public notice
later this week. I have attached a copy of the draft permit and cover letter here for your review. Please
respond to this email to let me know that you received the draft permit and were able to view the file and
download it for your records.
Bradley Bennett
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Ni1 hNGU4LTY3M2El ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/2

4/13/2021
Mail - Bennett, Bradley - Outlook
Compliance and Expedited Permitting Phone: [phone]
NC Division of Water Resources
1617 Mail Service Center Email: [e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public records laws
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2/16/2021
Mail - Bennett, Bradley - Outlook
Re: [EXTERNAL] Permit Renewal - Candler Travel Center - NCO085952
Rob Porges <[e-mail]>
Mon 2/15/2021 7:04 AM
To: Bennett, Bradley <[e-mail]>
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as
an attachment to Report Spam.<mailto:report.spam nc.gov>
Yes, electronic receipt is fine with me.
Rob Porges
Director, Environmental Services
TA Operating LLC
24601 Center Ridge Road
Westlake, OH 44145-5639
440-808-7368
FAX [phone]
From: "Bennett, Bradley" <[e-mail]>
To: "Rob Porges" <[e-mail]>
Date: 02/14/2021 07:58 PM
Subject: Re: [EXTERNAL] Permit Renewal - Candler Travel Center -
NC0085952
Thanks Rob. Could you also respond to let me know if you will approve
receipt of documents from us electronically?
Thanks
Bradley Bennett
Compliance and Expedited Permitting Phone:
[phone]
NC Division of Water Resources
1617 Mail Service Center Email:
[e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public
records laws
From: Rob Porges <[e-mail]>
Sent: Sunday, February 14, 2021 6:02 PM
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/3

2/16/2021
Mail - Bennett, Bradley - Outlook
To: Bennett, Bradley <[e-mail]>
Cc: [e-mail] <[e-mail]>
Subject: Re: [EXTERNAL] Permit Renewal - Candler Travel Center - NCO085952
CAUTION: External email. Do not click links or open attachments unless you
verify. Send all suspicious email as an attachment to Report Spam.<
mailto:report.spam nc.gov>
Bradley:
The 2015 permit application also noted HPT TA Properties Trust as the
property owner. HPT TA Properties Trust has owned this site in 2007. TA
Operating LLC operates the site and prior permits were issued to that
entity. Nothing has changes with the owner/ operator arrangement since
2007.
Rob Porges
Director, Environmental Services
TA Operating LLC
24601 Center Ridge Road
Westlake, OH 44145-5639
440-808-7368
FAX [phone]
From: "Bennett, Bradley" <[e-mail]>
To: "[e-mail]" <[e-mail]>
Cc: "[e-mail]"
<[e-mail]>
Date: 02/14/2021 02:38 PM
Subject: [EXTERNAL] Permit Renewal - Candler Travel Center -
NC0085952
Mr. Porges,
am the permit writer for renewal of the Candler Travel Center NPDES
wastewater discharge permit (NC0085952). I hope to have the draft permit
ready for public notice in the next week or so. I did have a couple of
things to contact you about in our review.
The submitted renewal application noted HPT TA Properties Trust as the
owner. Our permitting system, however, lists TA Properties, LLC as the
owner. if ownership of the property has changed then you may need to
provide documentation of the change. I have attached our name/ownership
change form. In addition, please review and respond to the information
below about electronic transmittal of documents.
https://outlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 2/3

2/16/2021 Mail - Bennett, Bradley - Outlook
In order to provide more convenience, control, and security to our
permittees and assist them in processing their transactions, The Division
of Water Resources is currently transitioning towards electronic
correspondence. This will hopefully provide more efficient service to our
permittees and other partners and will allow us to more effectively process
and track documents. We are writing to ask you for your approval of the
transmittal of documents related to your permitting and related activities
with the Division in an electronic format. Documents will be emailed to
the appropriate contact person(s) in your organization in a PDF format.
Please respond to me through email with verification that transmittal of
your documents in an electronic manner is acceptable to you. If you have
any questions, please feel free to contact me.
Bradley Bennett
Compliance and Expedited Permitting Phone:
[phone]
NC Division of Water Resources
1617 Mail Service Center Email:
[e-mail]
Raleigh, NC 27699-1617
Email correspondence to and from this address may be subject to public
records laws[attachment "Name-Ownership-Change-Form-2020.docx" deleted by
Rob Porges/Environmental/TCA]
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2/14/2021 Mail - Bennett, Bradley - Outlook
RE: NCO085952 Why Composite Sampling
Wiggs, Linda <[e-mail]>
Wed 2/10/2021 12:07 PM
To: Bennett, Bradley <[e-mail]>
Yes, the ORC and I discussed that today at length as well. He is not having issues with the plant and believes if he had to put those back online they'd cause issues due to something
related to clogging/rinse water/build up on the filters. If he can operate the facility in compliance with the effluent limits without using them directly I am ok with his professional
judgement.
�DEQ
Environmental Senior Specialist/Division Water Resources
North Carolina Department of EnN ironmental Quality
828-296-4500 (Office)
[e-mail]
a.r• .:. . . r + rrr s. .a . . .. _ . •.,
From: Bennett, Bradley
Sent: Wednesday, February 10, 2021 12:02 PM
To: Wiggs, Linda <[e-mail]>
Subject: Re: NCO085952 Why Composite Sampling
We had talked about that and I can do that. They only question I have is if you guys feel like this is okay and they can meet their permit limits without the filter?
BB
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
Email correspondence to and from this address may be subject to public records laws
From: Wiggs, Linda <[e-mail]>
Sent: Wednesday, February 10, 2021 11:58 AM
To: Bennett, Bradley <bradley. ben nettoncdenr.gov>
Subject: RE: NCO085952 Why Composite Sampling
Are you going to list the tertiary filter as inactive? I can't remember where we landed with that.
D_EQ
lot
r ■ 4 rw-■ ■ ■ ■.
From: Bennett, Bradley
Sent: Wednesday, February 10, 2021 11:28 AM
To: Wiggs, Linda <linda.wiggs@ncdencgov>
Subject: Re: NCO085952 Why Composite Sampling
Thanks Linda. I'll plan to move this one to grab.
BB
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
,1:>trnda
Environmental Senior SpecialisvDivision Water Resources
North Carolina Department of Eni-ironmental Quality
828-296-4500 (Office)
[e-mail]
Phone: [phone]
Email: [e-mail]
Email correspondence to and from this address may be subject to public records laws
https:Houtlook.office365.com/mail/search/id/AAMkADglYjdhZmlxLTMzMGYtNGU3Nil hNGU4LTY3M2E1 ODhmOGQxYgBGAAAAAACylgPJgHeWQptj... 1/3

2/14/2021 Mail - Bennett, Bradley - Outlook
From: Wiggs, Linda <[e-mail]>
Sent: Wednesday, February 10, 2021 10:44 AM
To: Bennett, Bradley <bradley. ben nett@ncdenngov>
Subject: RE: NCO085952 Why Composite Sampling
Hi, I just spoke with the ORC.
He checks U/D just U/D from the discharge pipe, which can be tight but I am ok with that.
He also said he'd rather is go with the grab than the continuous, so I am game for the grab as well. This plant is not gravity so the discharge is pump controlled and not continuous which
makes continuous flow and sampling difficult,,,, it does tend to cause the equipment issues too.
Environmental Senior Specialist/Division Water Resources
North Carolina Department of Environmental Quality
828-296-4500 (Office)
Linda. wiggsgncd=.gov
r a+rr r:. r r r .rrr sti + r s r r r• r
r• ■tirr.+-r ■ r.
From: Bennett, Bradley
Sent: Wednesday, February 10, 20219:56 AM
To: Wiggs, Linda <linda.wiggs@ncdenngov>
Subject: Re: NCO085952 Why Composite Sampling
Yea, I noticed something in the file about them getting a new meter etc. and was wondering the same thing. Maybe we should just let it go. I think technically by the
rules they could be grab. Sorry, I have had some other thing going this week and just getting back to renewals.
BB
Bradley Bennett
Compliance and Expedited Permitting
NC Division of Water Resources
1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Email: [e-mail]
Email correspondence to and from this address may be subject to public records laws
From: Wiggs, Linda <[e-mail]>
Sent: Wednesday, February 10, 20219:40 AM
To: Bennett, Bradley <bradley. ben [e-mail]>
Subject: RE: NCO085952 Why Composite Sampling
What did you find out about this? I found an email from 2018 where they'd bought a new flow meter and composite sampler. Perhaps we should just keep it at composite. I think I was
pushing for grab years ago before so they didn't have to spend the money on new equipment, but I guess I didn't get an answer soon enough and they bought the new equipment. I still
haven't spoken with the ORC about this yet.
D E 0
Zdnda 0�1/
Environmental Senior Specialist/Division Water Resources
North Carolina Department of EnN ironmental Quality
828-296-4500 (Office)
Linda.wiggs&cd=.goc
r a+rr r:. r r r .rrr sti + r s r r r• r
r• ■tirr.+-r ■ r.
From: Bennett, Bradley
Sent: Monday, February 1, 2021 12:07 PM
To: Wiggs, Linda <linda.wiggs@ncdencgov>
Subject: Re: NCO085952 Why Composite Sampling
Yea, that is the email I had in the file. I think if there are no WQ concerns we could look at putting them on grab if you want to do that. I'll check into it
BB
Bradley Bennett
Compliance and Expedited Permitting Phone: [phone]
INC Division of Water Resources
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2/14/2021
1617 Mail Service Center
Raleigh, NC 27699-1617
Mail - Bennett, Bradley - Outlook
Email: [e-mail]
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From: Wiggs, Linda <[e-mail]>
Sent: Monday, February 1, 202112:01 PM
To: Bennett, Bradley <[e-mail]>
Subject: FW: NCO085952 Why Composite Sampling
I believe this is the last email I had with Charles.
D-E Q
From: Weaver, Charles
Sent: Wednesday, October 17, 2018 11:04 AM
To: Wiggs, Linda <Iinda.wiggs_@n nngpv>
Subject: RE: NCO085952 Why Composite Sampling
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Environmental Senior Specialist/Division Water Resources
North Carolina Deparunent of EnN ironmental Quality
828-296-4500 (Office)
Linda. wiggs gcdenr.gov
Due to the WQ concerns when the permit was originally drafted (1996), they were given composite sampling. Since then, no one has requested a change to Grab.
CHW
From: Wiggs, Linda
Sent: Monday, October 15, 2018 5:04 PM
To: Weaver, Charles <charles.weaver@.ncdenr.gpvv>
Subject: NCO085952 Why Composite Sampling
Charles,
I thought we addressed this question previously but did not find an email relating.
Why does Candler Travel (NC0085952) have to perform composite sampling? It is less than 30,000 plant which usually means Grab
sampling.
Thanks
Environmental Senior Specialist —Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4500 office
828 299 7043 fax
Email: linda.wiggsncdenr.gov
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
ci.
Nothing Compares
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