WQ0024694_Staff Report_20240815

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: WQ0024694
Attn: Anthony Cord Facility name: Bright’s Creek Golf Club 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: March 1, 2023
b. Site visit conducted by: Melanie Kemp
c. Inspection report attached? Yes or No In LF
d. Person contacted: Rickie Daniels, ORC and their contact information: 704-507-3415ext.
e. Driving directions: I-26 E to Hwy 74 E. Take Mill Spring Ext (Hwy. 108) to intersection of Hwy 9. Turn
lft on 9, next left on Silver Crk Rd for approx. 7 mi. Left on Palmer Rd. to guard house- rt on Deep Gap
Rd, then rt on Reagon Jackson Rd to WWTP on 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:
Docusign Envelope ID: B63B2A27-BBFD-4651-8B1B-35606EF8EC4B
FORM: WQROSSR 04-14 Page 2 of 5
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: Rickie Daniels Certificate #: 1009769 Backup ORC: Stephen Hinson Certificate #: 1003263
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 120,000 gallon per day (GPD) reclaimed water generation and dedicated utilization facility
consisting of the continued operation of a 240,000 GPD reclaimed water generation system consisting of
rough screening; eight 10,000 gallon equalization basins; two flow splitter boxes; twenty-four 10,000 gallon
aeration basins; eight 5,290 gallon clarifiers; two 10,000 gallon aerated sludge holding basins; tertiary
filtration; an ultraviolet (UV) disinfection system; tablet chlorination disinfection system; a 171, 552 cubic
foot (ft3) synthetically lined five-day upset pond; an auxiliary standby emergency generator; flow meter;
and all associated piping, valves, controls, and appurtenances; and the continued operation of a 120,000
gallon per day (GPD) dedicated reclaimed water utilization system consisting of a 1,089,969 ft3
synthetically-lined wet weather storage pond; a 132.8 acre spray irrigation area; and all associated piping,
valves, controls, and appurtenances.
Proposed flow: 120,000 gpd
Current permitted flow: Same as above
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.
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 N/A
If no, please explain:
Docusign Envelope ID: B63B2A27-BBFD-4651-8B1B-35606EF8EC4B
FORM: WQROSSR 04-14 Page 3 of 5
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: The application indicates that there is a 1,283,306 ft3 5-day upset pond and an
8,153,534 ft3 storage pond, whereas the current permit description only lists a 1,089,969 ft3 synthetically-
lined wet weather storage pond. Please separate these out in the description on the new permit. Acreage
amount may need to be adjusted based on additional comments provided in this staff report.
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
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:
The site has had no limits or reporting violations recently.
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: B63B2A27-BBFD-4651-8B1B-35606EF8EC4B
FORM: WQROSSR 04-14 Page 4 of 5
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
Map and Section IX The field identifiers and areas provided in Section IX do not match the map
attached to the application. See additional comments below.

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: )

6. Signature of report preparer:

Signature of regional supervisor:
Date:

Docusign Envelope ID: B63B2A27-BBFD-4651-8B1B-35606EF8EC4B
8/15/2024
FORM: WQROSSR 04-14 Page 5 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Application notes:
 Section IX –
o Note that the deeded owner on Attachment B in the current permit is “Millspring Resort LLC” and
the deeded owner listed in this section of the application is “Bright’s Creek Resort Golf LLC”.
o Note that the areas listed on Attachment B in the current permit are different sizes than what is
provided in this section, although the overall net acreage is the same.
 Attachments:
o The plan set provided with the application, to be included as a map with the final permit, lists 18
wetted areas, which do not match the table provided in Section IX of the application or Attachment
B of the current permit. It is recommended that either Attachment B is amended to reflect the
layout provided on this map, or an alternative map is provided that outlines the fields listed in
Section IX of the application.

Docusign Envelope ID: B63B2A27-BBFD-4651-8B1B-35606EF8EC4B