NC0025321_Meeting Notes_20220421

Weaver, Charles
From: Forrest Westall <[e-mail]>
Sent: Thursday, April 21, 2022 2:25 PM
To: Davidson, Landon
Cc: Rob Hites; Boss, Daniel J; Heim, Tim; Weaver, Charles
Subject: [External] Meeting Summary, April 19, 2022: Waynesville WWTP
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Hello Landon,
Thank you, the regional Water Quality staff, and Charles Weaver in the DWR central office for your time and input
during the meeting this past Tuesday to discuss the Waynesville WWTP. The focus of the meeting was the Town's plans
to submit a request for revision to the current SOC. However, that discussion also covered important compliance issues
at the facility. Relative to main focus, we identified several important components we need to address as we pull
together a successful request for revising the SOC.
To confirm the action items we are following up on, I want to summarize those and seek your input to make sure we are
all on the same page. While this list has a first and last item, the list includes all of the items we discussed without
respect to priority. All of the items are important and must and will be addressed prior to finalizing a revision request:
• The Town will seek an increase in allowable additional wastewater flow allocation to the collection system
during the SOC period (section 8 of the SOC). We spent significant time discussing this item and the Town has
noted that the demand for wastewater flow allocation to facilitate projects as they move through local
government approval steps and collection system permitting (as required) by DWR. At this point the Town has
allocated almost all of the 155,000 gals/day (gpd) of additional flow allocation in the SOC (only about 8,000 gpd
of allocation remains uncommitted). However, as of this date, none of this allocated flow is tributary to the
WWTP and many of the new projects with allocation have not even "broken ground" to begin the physical
development of the project site. As relayed in the meeting, this ability to allocate flow within the normal
process of new project development is essential to the economic viability of the Town and Haywood County as
well as to the wastewater service fees charged to system users (as connections are approved, this provides
revenue to the Town now and in the future to pay for the operation of the system and for retirement of debt
associated with plant improvements). The Town identified several other reporting metrics that can accompany
future flow allocation, including a "status" determination of the project's development stage (i.e. does the
project have all local approvals needed, has any required sewer extension permit been requested, has the
collection system permit been issued, is the project under construction, is there any additional wastewater flow
connected to the collection system, what is the amount of any collected flow relative to allocation, if not
currently under construction, when does the Town expect the project to begin and an estimate of its
completion, etc.). The Regional Office noted its interest in this additional information and indicated that any
revised SOC would include additional reporting requirements along these lines. The Town will work
cooperatively with DWR to develop a more robust set of reporting parameters for inclusion in a revised SOC.
• The Town continues and has expanded its efforts to address Infiltration and Inflow (I&I) of ground, surface
water, and precipitation (stormwater) into the collection system. The Town has done a significant amount of
collection system evaluation, including physical inspection of lines, "smoke -testing," and has purchased and is
using video equipment for the evaluation of sewer collection line integrity to identify problems and assist in
establishing priority for its capital improvements plan (CIP) on the sewer collection system. Most immediately,
the Town is proceeding with the replacement a collection line within he Waynesville Country Club that was
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identified as a significant source of I&I. Monitoring and evaluation of this line has projected that I&I from this
area of the collection system is adding approximately 40,000 gpd under baseflow conditions and 900,000 gpd
during high rainfall/flow conditions. The Town expects the replacement project The Town acknowledged its
commitment to provide more timely reporting of I&I progress. Also, the Town has been seeking funding for I&I
reduction work, but so far have not been successful. DWR Regional Office offered to provide supporting
correspondence on any future grant/funding requests. The Town appreciates this offer and committed to
keeping DWR informed of its funding requests during the application development timeframe so DWR is
aware of these efforts and so they can provide support for the funding. The Town also committed to updating
its CIP for the collection system and adjusting priority on needed projects based on updates to its collection
system assessment efforts. Short term, the Town is The Regional Office indicated that any revised SOC would
include more frequent reporting of I&I reduction activities and that projects undertaken and completed will
include a projected reduction in WWTP flow during base and high flow periods expected as a result of a
project. The Town noted the challenges related to other independent organizations and jurisdictions that add
their wastewater flow to the collection system. The Town of Clyde and the Lake Junaluska Sanitary District
have existing agreements that commits Waynesville to provide WWTP services to their flow. The Town will
continue to work to renegotiate those agreements and to promote I&I control within these independent
areas of the collection system.
• The Town continues to assess the compliance issues at the WWTP related mainly to TSS and BOD-5 effluent
violations (SOC and NPDES permit) and to take timely action to improve plant performance. Most recently,
the Town's sludge belt press has been "down" and removal of waste sludge has not been possible. The Town
knows that carrying additional solids in the WWTP represents an increased risk of "solids loss" into the effluent
(resulting in elevated TSS and BOD-5) as well as decreased treatment efficiency for BOD-5 reduction (carrying
"old" solids in the plant which have limited "activated" biology also results in impacts to BOD reduction
efforts). The belt press is under repair now and is or should be available soon to reduce the inventory of solids
in the bio-mass within the plant. This should improve effluent quality. Recent monitoring results shows, at
times, a wide variation in effluent values for TSS and BOD-5 even on a day to day basis with limited variation in
overall WWTP flow. Some of these variations are very large and for daily composite sampling results this is just
not indicative of activated sludge facilities. Certainly, high flow periods can cause such variation, but some of
the data shows these inconsistencies even when flow is relatively stable. Both the Town and DWR agree that an
independent operational and monitoring assessment is needed to help identify operational adjustments that
may help performance and to verify that monitoring results are properly reflecting the variations shown in the
current data. The Town is proceeding with identifying appropriate resources to do these assessments, test
and implement promptly any identified operational adjustments that may improve performance, and to
provide information to DWR on short term actions taken in response to the assessments, and include this
information in support of the request for revision of the SOC.
• As noted and acknowledged, the violations experience by the Town within the last year or so, are indictive of
some significant change in the performance of the WWTP. The Town, based on the assessment identified
above may conclude that revisions in the SOC limitations in the current Order are needed. If so, the Town will
provide in its submittal of a request to revise the SOC information to support a requested revisions in
limitations. The Town seeks to evaluate the need for this adjustment of the SOC in cooperation with DWR.
• Due to delays since the AtoC for the WWTP improvements project was issued (in compliance with the date in
the SOC) related to efforts for additional "value engineering" review coordinated with the Division of Water
Infrastructure (DWI) and DWR, the final compliance date in the SOC will need to be revised. The Town will
include an evaluation of the need for this change in its application for a revised SOC. DWR indicated that it
will consider this request in accordance with the overall structure of the SOC. DWR did state that it will be
seeking additional changes to the SOC (compliance schedule, reporting and some other points noted above)
to address other aspects of the current SOC. The Town seeks to work through these aspects in a positive and
cooperative manner with DWR.
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• DWR identified some important SOC revision application administrative and review issues that will need to be
factored into the timeframe. If the performance -related efforts identified that will support the application for
revision show that revisions to the SOC limitations section may need to be revised, DWR pointed out that any
potential water quality impacts to the receiving water would have to be assessed relative to any requested
increase in limits for parameters related to water quality standards. This is specifically true for potential
dissolved oxygen standard impacts from BOD-5. Should the Town conclude a request for SOC limits for BOD-5 is
needed, DWR indicated they would work as quickly as possible to provide an appropriate "impact" analysis on
the receiving waters for any increase sought in BOD-5 limits. The Town will also provide some comments in
their application identifying any expected water quality impacts for any requested limit revisions.
The Town is extremely interested and committed to making I&I reductions and performance improvements at the plant
as soon as possible. These efforts, as noted, will be reported on and shared with DWR promptly. The Town is also
extremely interested and committed to receiving permission to allocate additional wastewater flow to "new"
projects. This is critical for economic and governance issues in the Town and the County. The Town understands DWR's
concerns about achieving the highest performance level reasonably possible at the WWTP during the plant upgrade
process. This list of actions and efforts above will provide timely information on these efforts prior to the formal
submittal of an SOC modification request.
As we discussed on Tuesday, it may require 4 to 5 months of effort to work through the assessment process and to
develop the support information for the SOC modification request. However, we are going to proceed as quickly as
possible and keep DWR informed of the progress and status of the efforts outlined here. It may be helpful during the
assessment and information -development process to meet or discuss specific preliminary findings with you and your
staff. We will definitely keep this in mind as we move the process forward and keep you all informed. Additionally, as
we begin to build the application for revision to the SOC, we plan to make a pre -submittal draft available to you for a
preliminary review. We want to take into consideration preliminary input on the application to avoid unnecessary
delays due to communication challenges. People are busy and it will serve no purpose if a request for revision comes to
DWR that doesn't include information you need to make a final review and decision. We want to do our part to
promote a quick review and decision -making process. Also, we want clarity and transparency on any concerns about an
application before it is formally submitted. This project and all of its components, including the provisions of the SOC
are vitally important to the Town of Waynesville and the surrounding area of Haywood County. No matter what
perspective anyone has on this effort, putting an upgraded WWTP into successful service benefits water quality and
wastewater management in the Waynesville area.
Please let us know if you have any questions. It would be helpful to have your feedback on the items noted here so we
can have as much clarity as possible moving forward.
Thanks,
Forrest
Shaping
Communities
Together ®
Forrest R. Westall, Sr. PE
Principal
McGill Associates, PA
55 Broad Street, Asheville, NC 28801
T 828.252.0575
C 828.231.6840
[e-mail]
mcgillassociates.com
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From: Davidson, Landon <[e-mail]>
Sent: Monday, April 18, 2022 8:43 PM
To: Forrest Westall <[e-mail]>
Cc: Rob Hites <[e-mail]>; Boss, Daniel J <[e-mail]>
Subject: Re: [External] Waynesville SOC
Sounds good, see you there.
G. Landon Davidson, P.G.
Regional Supervisor
Water Quality Operations Section
Asheville Regional Office
828-230-4057
From: Forrest Westall <[e-mail]>
Sent: Monday, April 18, 2022 6:52:41 PM
To: Davidson, Landon <[e-mail]>
Cc: Rob Hites <[e-mail]>; Boss, Daniel J <[e-mail]>
Subject: RE: [External] Waynesville SOC
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Hi Landon,
Just to note again, we will be at your office tomorrow at 10. I think the communication was clear, but just wanted to
again let you know we plan to meet face to face tomorrow. If you have any questions, please let me know.
I will see you tomorrow!
Have a good evening.
Forrest
mcgill
Shaping
Communities
Together ®
Forrest R. Westall, Sr. PE
Principal
McGill Associates, PA
55 Broad Street, Asheville, NC 28801
T 828.252.0575
C 828.231.6840
[e-mail]
mcgillassociates.com
From: Davidson, Landon <[e-mail]>
Sent: Friday, April 1, 2022 2:01 PM
4

To: Forrest Westall <[e-mail]>
Cc: Rob Hites <[e-mail]>; Boss, Daniel J <[e-mail]>
Subject: Re: [External] Waynesville SOC
Sounds good Forrest.
G. Landon Davidson, P.G.
Regional Supervisor
Water Quality Operations Section
Asheville Regional Office
828-230-4057
From: Forrest Westall <[e-mail]>
Sent: Friday, April 1, 2022 12:11:23 PM
To: Davidson, Landon <[e-mail]>
Cc: Rob Hites <[e-mail]>; Boss, Daniel J <[e-mail]>
Subject: RE: [External] Waynesville SOC
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Thanks Landon. How about 10 AM on the 19th of April at your office?
Forrest
mcgill
Shaping
Communities
Together ®
Forrest R. Westall, Sr. PE
Principal
McGill Associates, PA
55 Broad Street, Asheville, NC 28801
T 828.252.0575
C 828.231.6840
forrest.westall©mcgillassociates.com
mcgillassociates.com
From: Davidson, Landon <[e-mail]>
Sent: Friday, April 1, 2022 11:43 AM
To: Forrest Westall <[e-mail]>
Cc: Rob Hites <[e-mail]>; Boss, Daniel J <[e-mail]>
Subject: RE: [External] Waynesville SOC
Forrest,
The 19th is the preferred meeting date. The morning and afternoon are currently available for Dan and me. Please feel
free to send to me prior to the meeting any proposals or requests that are available currently.
Regards,
Landon
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G. Landon Davidson, P.G.
Regional Supervisor — Asheville Regional Office
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
828 296 4680 office
828 230 4057 mobile
[e-mail]
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
NC DEQ Permit Directory
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Forrest Westall [mailto:[e-mail]]
Sent: Thursday, March 31, 2022 6:16 PM
To: Davidson, Landon <[e-mail]>
Cc: Rob Hites <[e-mail]>
Subject: [External] Waynesville SOC
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
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Hi Landon,
Thanks for talking with me recently about Waynesville's SOC. As I noted, the Town would like to modify the SOC to add
additional flow allocation. We discussed some of the issues you all see with that and the Town would like to sit down
with you and the Regional staff to discuss the SOC and how to proceed. I've checked with Rob Hites, the Town Manager,
and we are available on April 13tn 19th and before 11 on the 20th. Are any of these dates/times workable for you
all? We are prepared to come to the Regional Office if that is possible. Thanks for your time and consideration.
Forrest
mcgill
Shp ping
Communities
Together;
Forrest R. Westall, Sr. PE
Principal
McGill Associates, PA
55 Broad Street, Asheville, NC 28801
T 828.252.0575
C 828.231.6840
[e-mail]
mcgillassociates.com
6