WQ0012948_Staff Report_20240419

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 6

To: NPDES Unit Non-Discharge Unit Application No.: WQ0012948
Attn: Anthony Cord Facility name: Pisgah Center for Wildlife Education WWTF

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: September 30, 2022
b. Site visit conducted by: Melanie Kemp
c. Inspection report attached? Yes or No In LF
d. Person contacted: Danielle Hunter and their contact information: 828-251-1900 ext.
e. Driving directions: From Pisgah Forest, take Hwy 276 North. Turn left on Fish Hatchery Road and follow
to the Wildlife Center.
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:
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
DocuSign Envelope ID: 34CEA8AF-3D06-4358-A36F-39885193D849
FORM: WQROSSR 04-14 Page 2 of 6
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: Danielle Hunter Certificate #: 1007992 Backup ORC: Robert Barr Certificate #:24262
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: Operation of a 7,500 gallon per day (GPD) wastewater treatment and
irrigation facility consisting of the: continued operation and subsequent abandonment of the sand filter
dosing pumps; two 1,500 square foot ft) recirculating sand filters; and all associated piping, valves,
controls, and appurtenances; the construction and operation of two duplex 38 gallons per minute (GPM), 1
horsepower (hp) recirculation pumps systems (i.e., four total pumps) to be installed in the existing 4,000-
gallon recirculation tank; two approximately 138 W Model 5L EZ-Treat filter media pods; and all
associated piping, valves, controls, and appurtenances; and the continued operation of a 4,000 gallon
baffled septic tank; a 2,000 gallon baffled septic tank; a 5,000 gallon baffled septic tank; a 4,000 gallon
recirculation tank (to be modified to dose the new EZ- Treat filter media pods); a flow splitter box; a 4,000
gallon dosing/ storage tank with dual 40 gallon per minute (GPM) pumps, and high-water alarms; a 49 kW
backup power generator and automatic transfer switch; a modified Pere-Rite drip irrigation pump unit; a
tablet chlorinator; a 20,340 gallon subsurface wetland cell; a 100, 500 gallon surface wetland cell; a 1.6 acre
drip irrigation area with approximately 17,000 linear feet of 2- inch diameter polyethylene pressure
compensating drip irrigation piping; rain sensors; and all associated piping, valves, controls, and
appurtenances to serve the Pisgah Center for Wildlife Education WWTF.
Proposed flow: Application indicates 7,500 gpd, although updated flow calculations indicate 3,605 gpd.
Current permitted flow: 7,500 gpd
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
The existing Pisgah Wildlife Education Center was damaged in 2021 due to flooding and has been unused
since then. The Forest Service is planning on demolishing the existing Wildlife Education building and
replacing it with Public Restrooms. The septic tanks that feed into the WWTF and associated
infrastructure will be removed/replaced.
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: Septic tanks are being replaced and multiple gravity sewer lines and manholes are
being demolished/replaced.
DocuSign Envelope ID: 34CEA8AF-3D06-4358-A36F-39885193D849
FORM: WQROSSR 04-14 Page 3 of 6
5. Is the residuals management plan adequate? Yes or No
If no, please explain: Not provided
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: Will need to be modified once additional information is provided.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

DocuSign Envelope ID: 34CEA8AF-3D06-4358-A36F-39885193D849
FORM: WQROSSR 04-14 Page 4 of 6
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:
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:
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):

DocuSign Envelope ID: 34CEA8AF-3D06-4358-A36F-39885193D849
FORM: WQROSSR 04-14 Page 5 of 6
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
General The application did not include a cover letter, outlining the proposed permit
modifications.
Application Checklist
Items D, H, K, L, M, N,
and P
These items from the application checklist were missing. See section V for
more information.
Application Checklist Item
I
Issues were noted on plan sets CE-101 and C-220. See section V for additional
information.
Application Checklist Item
J Additional specification sheets are needed. See section V for more details.
Application Section IV.7 Please clarify how flow calculations were determined and complete the table
based on the last page provided with the application package.
Application Section V.1 Engineering calculations need to be provided to substantiate this section.
Application Section V.9 A box needs to be checked here.
Application Section V.11 This section needs to be completed.
Application Section VIII.3 This section needs to be completed.
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: )

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FORM: WQROSSR 04-14 Page 6 of 6
6. Signature of report preparer:

Signature of regional supervisor:

Date:

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
It should be noted that the current permit description and as-built drawings do not clearly indicate which facilities
are connected to the existing septic tanks. Based on original as-built drawings, the following facilities flow into the
existing WWTF:
 2 x Septic Tanks (4,000 gallons and 2,000 gallons):
o 3 x 3-bedroom homes
o Hatchery staff building
 Septic Tank 3 (5,000 gallons)
o Wildlife Education Center
The existing septic tanks will be removed and replaced with the following:
 Septic Tank 1 (4,000-gallon tank; expected 1,655 gpd flow):
o Hatchery staff bathrooms (new building)
o 3 x 3-bedroom houses (existing buildings)
 Septic Tank 2 (3,500/4,000-gallon tank; expected 1,950 gpd flow):
o Public Restroom (new building)
The following deficiencies were noted in the application package:
 Item A (Cover Letter): There is no cover letter provided.
 Item D (Property Ownership Documentation): Property ownership documentation is not included.
 Item H (Water Balance): Water balance is not provided (changes in storage indicate a need for this).
 Item I (Engineering Plans): The following issues were noted in the plans provided:
o CE-101: Plans show 2 x 5,000 gallon septic tanks next to the old visitors center, but existing permits
and as-built drawings indicate one – please clarify. Plans also label “4,000 gallon septic tanks” – are
there multiple tanks or just the one indicated on the existing permit? Is the 2,000-gallon septic tank,
noted on the current permit, identified on this drawing?
o C-220: Plans show contradictory sizes of septic tanks (1 x 4,000 gallon and 1 x 3,500 gallon on map
but 2 x 4,000 gallon on elevation profile).
 Item J (Specifications): There was no specification information provided on the “Proposed effluent
recirculation pump station” show on plan set C-220. There are no septic tank specifications provided.
 Item K (Engineering Calculations): Signed/sealed engineering calculations were not provided.
 Item L (Site Map): A Site Map was not provided.
 Item M (Power Reliability Plan): A Power Reliability Plan was not provided.
 Item N (Operations and Maintenance Plan): A copy of the existing or updated O&M Plan was not
provided.
 Item P (Additional Documents): The existing permit and floodway regulation compliance documents were
not provided).
The following issues were noted in the application:
 IV. 7: Design flow table is not filled out correctly. Previous approved flow rate was 7,500 but based on
calculations provided in application, updated flow is 3,605, as determined by 02T .0114 rules.
 V.1: There are no engineering calculations provided to substantiate the modifications.
 V.9: A box needs to be checked here.
 V.11: Facility design criteria needs to be provided.
 VIII.3: Setback information needs to be provided or marked as N/A where applicable.
DocuSign Envelope ID: 34CEA8AF-3D06-4358-A36F-39885193D849
4/19/2024