WQ0032016_Staff Report_20211018

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
October 18, 2021

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0032016
Attn: Erick Saunders Regional Login No.:

From: Mikal Willmer & Brett Laverty
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
a. Was a site visit conducted? Yes or
b. Date of site visit: May 20, 2021
c. Site visit conducted by: Mikal Willmer.
d. Inspection report attached? Yes or No In LF.
e. Person contacted: Robert Barr, RPB Systems and their contact information: 828-230-1021
e. Driving directions: Take I-240 W to Patton Ave, US-74 Alt/23. Turn right on New Leicester Hwy (NC-63)
and continue for approximately 10 miles. The WWTF and application field will be on the right.
f.
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)

III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
DocuSign Envelope ID: 19DAF812-A95D-44C4-87AB-85DF65C06965
FORM: APSRSR 04-10 Page 2 of 4
ORC: Kevin Bryan Certificate #:SI-1010633 WW-II-1002130 Backup ORC: Kenneth Rummel-SI & Bob
Barr-WW Certificate #:SI-1002130 & 8928 (WW-III)
Currently SI & WW backup are different, will clarify with operations firm.
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 Appears to be and new management is taking active steps to
improve the facility. Some weed patches and bare spots but does not appear to be enough to affect overall
assimilation of wastewater. No ponding, pooling or erosion noted during inspection. Recommend facility
overseed the field and remove thatch as needed to improve overall crop health.
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:
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: Facility never approaches current approved application rate. If new groundwater
monitoring indicates any potential impact and/or oversaturation is observed, then application rates will be
reassessed.
7. Is the existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program: See Brett Laverty’s
comments below:
Since March 2009, approximately 25% of the groundwater samples collected at downgradient
monitoring wells MW2 and MW3/MW3B have tested positive for fecal coliform bacteria. These
concentrations range from 2 - 50 CFU/100 ml. This pattern is not present at background monitoring well
MW-1. It is also important to note all three monitoring wells are capable of producing extremely turbid
water samples. Reported turbidity levels can range from less than 10 NTU’s to greater than 500 NTU’s.
In order to ensure the laboratory analysis reflects as little as bias as possible, the Division recommends a
turbidity concentration of less than 10 NTU’s prior to collecting groundwater samples.

The water table beneath the drip irrigation field is somewhat shallow and ranges between approximately
8 feet below the land surface at MW-2 to approximately 4 feet below the land surface at MW-3B. The
application field has been in continual operation for the last 12 years. There is a private water supply well
and a surface water receptor roughly 300-400 feet downgradient of the application field. To date,
groundwater monitoring has primarily focused on fecal coliform bacteria, ammonia, nitrate, and
phosphorus. Metals and other ions that make up the mineral structure of the subsurface can behave very
differently depending on whether they are in an oxidized or reduced groundwater environment.
Continual application of wastewater can change these redox conditions and potentially mobilize some
inorganic contaminants.

The regional office is recommending changes to groundwater monitoring requirements that will focus on
assessing the redox condition beneath the application field, address exceedances for fecal coliform
bacteria, reducing in-well turbidity, and monitoring for inorganic contaminants. The first
recommendation is to begin collecting groundwater samples using low-flow purge/sampling techniques,
which require the monitoring of field parameters including temperature, specific conductivity, pH,
dissolved oxygen, oxidation reduction potential, turbidity, and depth to water. Reduced groundwater
conditions are typically defined as dissolved oxygen concentrations below 1 mg/l and oxidation reduction
potentials below 30 – 40 mv including negative values. The second recommendation is for the addition of
arsenic, barium, chromium, copper, lead, iron, manganese, nitrite, and zinc to the list of groundwater
monitoring parameters.
DocuSign Envelope ID: 19DAF812-A95D-44C4-87AB-85DF65C06965
FORM: APSRSR 04-10 Page 3 of 4

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 Coordinates were previously
corrected in BIMS. MW #2 is listed on the review boundary; however, the placement appears to be
between the review boundary and the compliance boundary based on facility site maps. Coordinates listed
in application appear to be incorrect.
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: Had several BOD exceedances attributed to a
faulty blower and slug coming into the facility. Recommended operations staff analyze more process
controls as sampling is only required once per month. Repeated hits for fecal in the monitoring wells since
2009. May be due to presence of turbidity. No noted hits in the two GW monitoring events conducted so far
this year.
13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No
If yes, please explain: Turbidity has been recorded in the MWs during sampling which can cause
interference with the method used to determine fecal coliform. Suggesting low flow sampling, in part to
determine if fecal hits are caused by a failure of the drip irrigation field or influenced by turbidity. This is
also part of a system assessment as described above.

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:
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 WQROS Central Office to obtain through an additional information request:
Item Reason
DocuSign Envelope ID: 19DAF812-A95D-44C4-87AB-85DF65C06965
FORM: APSRSR 04-10 Page 4 of 4

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
Groundwater Monitoring
Parameters
Recommend adding arsenic, barium, chromium, copper, lead, iron,
manganese, nitrite, and zinc to the list of groundwater monitoring
parameters. Due to adjacent groundwater receptors, need to verify
whether application of wastewater is mobilizing inorganic contaminants.
Regional office can provide updated Appendix C - groundwater monitoring
and limitations table.
4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
Groundwater Sample
Methodology
Recommend requiring low flow purge/sampling methodology as a means to
reduce in-well turbidity to less than 10 NTU’s. Field parameters (i.e.,
temperature, specific conductivity, pH, dissolved oxygen, and oxidation
reduction potential will be key to assessing the redox condition beneath the
application field. It will be important for the permittee to report these field
parameters on the GW-59 reporting forms. The regional office will be the
point of contact for any questions related to the low flow purge/sampling
methodology.
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 WROS regional supervisor:

Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
New HOA members have been taking active steps to improve the irrigation field. The permittee should continue to
monitor the field for the spread of weeds and bare patches. Grass is not currently baled or removed after cutting due to the
potential of damaging the drip lines. Thatch may eventually prevent fescue from thriving and allow moisture tolerant weeds
to proliferate. Additionally, even though the facility is hydraulically limited, crop removal is an essential part of nutrient
management within the field. It is recommended the permittee consult an agronomist if crop health does not continue to
improve.

DocuSign Envelope ID: 19DAF812-A95D-44C4-87AB-85DF65C06965
10/18/2021