WQ0031396_Staff Report_20221101

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 7

To: NPDES Unit Non-Discharge Unit Application No.: WQ0031396
Attn: Lauren Plummer Facility name: Santeetlah Lakeside WWTP

From: Melanie Kemp
Asheville Regional Office

Note: This form has been adapted from the non-discharge facility staff report to document the review of both non-
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: July 19, 2022
b. Site visit conducted by: Melanie Kemp and Mikal Willmer
c. Inspection report attached? Yes or No In LF
d. Person contacted: Tim Barbee and Jose Rosado and their contact information: [e-mail] ext.
e. Driving directions: Hwy. 19 through Nantahala Gorge to Hwy. 129 Robbinsville. Continue on Hwy. 129
through Robbinsville to Lake Santeetlah to Thunderbird Mtn. Rd. Go past Santeetlah Marina, facility is
located on the left.
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
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:
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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)
Describe the residuals handling and utilization scheme:
10. Possible toxic impacts to surface waters:
11. Pretreatment Program (POTWs only):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Certificate #: Backup ORC: Certificate #:
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:
Description of existing facilities: This re-use system was constructed in 2007 but has not been in use. Nothing
is connected to the system, but the applicant is looking to receive an operations permit to replace their
existing construction permit in order to proceed with development on-site. The development plan has
changed since the original permit was issued, which will alter the expected cumulative flow to the system. A
flow reduction was granted in 2019, and a copy is included with the permit modification application.
Proposed flow: Unknown
Current permitted flow: Seasonal at the following rates:
• 4,120 GPD- 5/1 through 10/31
• 2,750 GPD – April and November
• 1,360 GPD – 12/1 through 3/31
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership, etc
All operational issues identified during the July 2022 inspection have been resolved, according to the
project engineer (Tim Barbee). A service provider has not been selected to manage the generator that
supplies backup power to the system.
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:
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:
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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: As mentioned above, the number and types of connections have changed and the
permit description will need to be altered.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

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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., DMR, NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review: An upgradient monitoring well (MW-1) and a
downgradient monitoring well (MW-2) were drilled on July 6, 2022 and July 8, 2022 respectively. Both
monitoring wells were initially sampled on July 12, 2022. The ARO received the GW-59 reports on July 18,
2022. The monitoring wells were updated/activated in BIMS. The analytical data was entered into BIMS.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
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.)
If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place?
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain: See summary below.
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):

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FORM: WQROSSR 04-14 Page 5 of 7
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 the NPDES Unit or Non-Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
Permit Description
Information
A final summary of connections (number of bedrooms and lots) and any
additional shared amenities that will be connected to the re-use system needs to
be provided to update the permit description
O&M Plan The O&M Plan that was provided is inadequate and needs to be updated. See
summary below.
Site Map Per permit schedule item 6, the site map is missing some details. See summary
below.
Updated DOC and By-
Laws
Per permit schedule items 1 and 2, the DOC and By-Laws need to outline
information about the recreational amenity. The plat map should delineate this
amenity and be filed with the register of deeds. See summary below.
Engineering Certification
The engineering certification included with the original permit, verifying that
the facility was constructed in accordance with the original Division-approved
plans and specs, needs to be signed, sealed, and submitted. A copy of the blank
form is included as an attachment to this staff report. The engineering
certification that was submitted with this application is not acceptable.
3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
I. Schedules Schedule items 1, 2, 3, 5, 6, and 7

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
ORC Operations
Agreement Update
Designate qualified ORC and back-up ORC and submit a signed Operator
Designation Form at least 60 days prior to wastewater being introduced into the
system (per 15A NCAC 08G .0201).
New Schedule Item 2 Permit Condition IV.9 (initial GW sampling) should become a schedule item.
New Schedule Item 3
The facility must designate a qualified ORC and back-up ORC and submit a
signed Operator Designation Form at least 60 days prior to wastewater being
introduced into the system (per 15A NCAC 08G .0201).
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:
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11/1/2022
FORM: WQROSSR 04-14 Page 6 of 7
Signature of regional supervisor:
Date:

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11/1/2022
FORM: WQROSSR 04-14 Page 7 of 7

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
This facility is looking to receive an operations permit to replace their current construction-only. Several
maintenance items have been addressed, but the modification application is missing the following information:
• A description of the planned development (bedrooms/lots) to be connected to the re-use system is needed.
The previous permit description, stating the following, is inaccurate:
o 26 bedrooms on 13 residential lots, a private bathhouse restroom, and a 1,500 square foot food
stand.
• The Operations and Maintenance Plan is inadequate and does not meet permit requirements (Condition
III.2). The original approved O&M Plan is included as an attachment to this staff report for reference. The
O&M Plan should include the following:
o A description of the operation of the system in detail to show what operations are necessary for the
system to function
o A description of anticipated maintenance of the system
o Provisions for safety measures, including restriction of access to the site and equipment
o Spill control provisions that include a response to upsets and bypasses, including control
containment, and remediation, and contact information for personnel, emergency responders, and
regulatory agencies
• The DWR never received a copy of the signed engineering certification, provided with the permit, after
construction was completed. The document provided in this application package does not match the
language on this form, verifying that the facility was constructed in accordance with the Division-approved
plans.
• There is not a designed ORC in BIMS, and the contract agreement included with the application is for “no
flow” status only. An ORC and back-up ORC should be identified, and a signed Operator Designation
Form should be submitted at least 60 days prior to wastewater being introduced into the system (per 15A
NCAC 08G .0201).
• Existing permit schedules haven’t been met or are incomplete:
o Schedule Item 1: the plat map that was provided (attached to this staff report) needs to be updated
to include the exact location of the recreational amenity, noting the amenity as the responsibility of
the HOA. Proof of filing with the register of deeds should also be provided.
o Schedule Item 2: the Declaration of Covenants, Conditions, and Restrictions and By-Laws do not
include language about the recreational amenity. The site map included with these, labeled
“Common Areas Map for Santeetlah Lakeside” should also be updated and include the recreational
amenity area within the drip irrigation field. According to the permit these documents shall include
the residential owners financial responsibilities to upkeep and maintain the recreational amenity
through the contracted landscaping company. In addition, a budget shall be provided showing how
much each residential owner must annually pay to maintain the recreational amenity.
o Schedule Item 6: A site map was provided showing the location of the monitoring wells (attached to
this staff report) but the following is missing:
 Irrigation area fields/zones as outlined in Attachment B of the permit (provided in
application sheet C1 dated March 2007)
 Delineation of the waste and compliance boundaries.
 Distance measurements verifying all setbacks are being met.
 100-year floodplain
In the draft permit, special attention should be drawn to the fact that flows are seasonal at this facility based on
nutrient uptake, at the rates provided in Attachment A.
Attachments to this staff report:
• Original Operations & Maintenance Plan provided in May 2007
• Plat displaying Surveyed Monitoring Wells
• Blank Engineering Certification Form for WQ0031396 (3/28/2019)
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OPERATIONS AND MAINTENANCE PLAN
Phase II Wastewater System, Santeetlah Lakeside
IBEX Thunderbird, L.L.C.
Graham County, NC
System Description: Treatment system consists of a 5,000 gallon septic tank, flow
equalization pump station, two (2) Bioclere trickling filter/settling tanks in series, two (2)
automatic backwash sand filters and two (2) Ultraviolet Light Disinfection Systems. The
effluent will be disposed of by a surface drip irrigation system for a forested area on the
property. An auto -dialer is provided to notify the operator of high water alarms, drip
system failure, pump failures, or a power outage.
The influent wastewater enters the septic tank where solids, trash and grit will be settled
out and anaerobically digested. The septic tank will also act as sludge storage for the
system. The wastewater flows from the septic tank to the flow equalization pump station
by gravity and is pumped to the Bioclere trickling filters on a timed dose basis to
minimize peak flows. The chemical feed system is connected to the flow equalization
flow meter and should be adjusted as necessary to maintain pH at 7-8 in the effluent.
The Bioclere trickling filters consist of a baffled settling tank under a plastic media
trickling filter. Each Bioclere unit contains two dosing pumps that alternate pumping
flow to the trickling filter. A third pump in each unit returns sludge collected in the
settling tank to the septic tank. From the Bioclere Units the wastewater flows by gravity
into the automatic backwash filter feed tank. The sand filters use suction lift pumps to
draw water from the filter feed tank to the filters and then direct flow to the ultraviolet
light disinfection system. Backwash is initiated automatically for the sand filters when
the filter pressure is high. Backwash water is drawn from the filter backwash tank and is
directed to the septic tank for treatment.
The turbidimeter draws a continuous sample from the ultraviolet light system channel to
determine turbidity. If turbidity exceeds 10 NTU then the turbidimeter sends a signal to
the automatically actuated valves to direct flow to the reject storage tank. Treated
wastewater meeting the 10 NTU standard is directed to the filter backwash tank and
overflows by gravity to the drip system dosing tank.
The drip system dosing tank is connected to the effluent storage tanks (4 - 15,000 gallon
tanks) by a gravity line that allows flow to fill both the effluent storage tanks and the
dosing tank equally. The dosing tank will pump the flow through the drip system
hydraulic unit which contains automatically actuated valves controlled by the drip system
control panel. The drip hydraulic unit will direct flow to two (2) of the four (4) system
zones simultaneously when dosing and will record flow irrigated in the zones. The drip
system will automatically flush the drip lines one zone at a time based on the number of
doses discharged. Water flushed through the drip lines will be returned the septic tank for
treatment. Drip system shall not be utilized during freezing temperatures or precipitation
events.
General Maintenance:
All components of the system should be inspected at a minimum on a weekly basis.
Inspections shall include verification that all pumps are operational. Any pumps that are
not performing properly should be repaired or replaced as quickly as possible. Determine
Operations and Maintenance Plan Pg. I
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if water levels are normal and storage capacity remaining. If water levels are abnormal
verify appropriate valves are open and lines are not clogged. pH levels should be
monitored and chemical feed system for pH adjustment calibrated as necessary to
maintain 7-8 pH in the system.
Treatment Units Maintenance Descriptions
A. Septic Tank Maintenance:
Septic tank shall be pumped by a septage hauler a minimum of one (1) time
per year. During septic tank pumping the effluent filter shall be removed
and inspected. Effluent filter should be cleaned or replaced as necessary.
B. Flow Equalization Pump Station Maintenance:
Pump flow rates should be monitored if any significant decrease in flow
occurs pump should be pulled and inspected for wear. Wetwell should be
pumped down and hosed out a minimum of once per year to prevent solids
accumulation.
C.- . Treatment System
Refer to manufacturer's recommendations for maintenance of Aquapoint
Bioclere Trickling Filters, Automatic Backwash Sand Filters, and
Ultraviolet Light Disinfection System.
D. Drip Irrigation System
Drip irrigation system shall be inspected visually a minimum of once per
week. Operator shall walk the field and check for any wet areas or other
signs of damaged lines a minimum of once per quarter. Operator should
monitor flows to each zone carefully and note any increases that may
indicate damaged lines or decreases in flow that could indicate a clogging
problem.
Operations and Maintenance Plan Pg. 2
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