WQ0001231_CEI_NOD2017PC0251 & STFRPT_20171108

State of North Carolina | Environmental Quality | Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

Water Resources
Environmental Quality

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director

November 8, 2017

Charles R Huff, Owner
943 Old Hendersonville Hwy
Brevard, NC 28712

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2017-PC-0251
Permit No. WQ0001231
Charlie's Sand and Gravel
Transylvania County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Charlie's Sand and Gravel on
November 7, 2017. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Non-discharge Permit No. WQ0001231. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.

The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville
Regional Office. The following deficiency(s) was noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________
Record Keeping Freeboard records are required weekly. Freeboard records have not been recorded since
December 2012. _________________________________________________________________________________________________________________________________________________________________________
In addition, the issues below must also be addressed:

Compliance Issue(s):

The Operation & Maintenance Plan should be updated. See Permit Condition III. 1.

Remedial actions should have already been taken to correct this problem and prevent further occurrences in the
future. The Division of Water Resources may pursue enforcement action for this and any additional violations of
State law. To prevent further action, carefully review these deficiencies and address the causes of
non-compliance to prevent the recurrence of similar situations.

DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E
Compliance Inspection Report
Permit:WQ0001231 Effective:01/09/09 Expiration:12/31/17 Owner :Charles R Huff
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Transylvania
Asheville
Charles R Huff
Effective:Expiration:Facility:Charlie's Sand and Gravel
1120 Wilson Rd
Pisgah Forest NC 28768
Title:Phone:[phone]Owner
From intersection of Hwy. 64 & Hwy. 276: Go west on Hwy. 64 to Ecusta Rd (SR 1512). Go approximately 1.5 mi to Old
Hendersonville Rd and turn right, then immediately left onto Wilson Rd (SR 1540). Go approx 3 mi to facility on right (blue metal
bldg)
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
24 hour contact name Charles R Huff 828-877-3737
On-site representative Charles R Huff 828-877-3737
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
11/07/2017 09:30AM 10:00AM
Beverly Price 828-296-4500
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Closed-Loop Recycle
Compliance Evaluation
Question Areas:
Miscellaneous Questions Record Keeping
(See attachment summary)
Page:1
DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0001231
11/07/2017 Compliance Evaluation
Charles R Huff
Routine
Inspection Summary:
The inspection was conducted by Beverly Price of the Asheville Regional Office. Mr. Charles Huff assisted with the
inspection. The inspection was in conjunction with the permit renewal request.
The permit was originally issued in 1989 to wash sand/gravel dredged from the French Broad River. The permit is for a
closed-loop recycle system. Mr. Huff has never recycled water at this facility. Water for washing is pumped from a fresh
water supply pond adjacent to the facility. After the sand is washed, the water drains to a settling pond and then to the
storage pond. The ponds are not lined and are located approximately 50 feet from the river. Any water in the storage pond
seeps back into the ground/river. As the river level rises the water level in the storage pond rises. Both ponds can be
inundated when the river floods.
There was no water in either pond at the time of inspection. The ponds do not have dams, they are basically holes in the
ground. The ponds are surrounded by kudzu. The facility has been used 5-6 times so far, this year.
Freeboard records are not being maintained.
The Operation & Maintenance Plan needs to be updated.
Page:2
DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0001231
11/07/2017 Compliance Evaluation
Charles R Huff
Routine
Type Yes No NA NE
Infiltration System
Reuse (Quality)
Lagoon Spray, LR
Single Family Spray, LR
Activated Sludge Spray, HR
Activated Sludge Spray, LR
Activated Sludge Drip, LR
Single Family Drip
Recycle/Reuse
Record Keeping Yes No NA NE
Is a copy of current permit available?
Are monitoring reports present: NDMR?
NDAR?
Are flow rates less than of permitted flow?
Are flow rates less than of permitted flow?
Are application rates adhered to?
Is GW monitoring being conducted, if required (GW-59s submitted)?
Are all samples analyzed for all required parameters?
Are there any 2L GW quality violations?
Is GW-59A certification form completed for facility?
Is effluent sampled for same parameters as GW?
Do effluent concentrations exceed GW standards?
Are annual soil reports available?
# Are PAN records required?
# Did last soil report indicate a need for lime?
If so, has it been applied?
Are operational logs present?
Are lab sheets available for review?
Do lab sheets support data reported on NDMR?
Do lab sheets support data reported on GW-59s?
Are Operational and Maintenance records present?
Were Operational and Maintenance records complete?
Has permittee been free of public complaints in last 12 months?
Is a copy of the SOC readily available?
Page:3
DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0001231
11/07/2017 Compliance Evaluation
Charles R Huff
Routine
No treatment units bypassed since last inspection?
Freeboard records are required weekly. Freeboard records have not been recorded since
December 2012.
Comment:
Page:4
DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E

If you should have any questions, please do not hesitate to contact Beverly Price with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.

Sincerely,

G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENTS: Inspection Report

Cc: WQS Asheville Regional Office - Enforcement File
Non-Discharge Compliance/Enforcement Unit - Enforcement File

20171108_WQ0001231_NOD2017PC0251.rtf
DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E
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 3
November 8, 2017

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0001231
Attn: Alice Wessner Regional Login No.:

From: Bev Price
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: November 7, 2017
b. Site visit conducted by: Bev Price
c. Inspection report attached? Yes or No
d. Person contacted: Charlie Huff, Owner and their contact information: 828-226-1238
e. Driving directions: From intersection of Hwy. 64 & Hwy. 276: Go west on Hwy. 64 to Ecusta Rd (SR
1512). Go approximately 1.5 mi. to Old Hendersonville Rd., turn right, then immediately left onto
Wilson Rd. (SR 1540). Continue for approximately 3 mi. to facility on the right (blue metal bldg.).
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)

DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E

FORM: APSRSR 04-10 Page 2 of 3
III. EXISTING FACILITIES FOR 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: See attached inspection summary Page 2. and Section V. of this report.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? Yes or No N/A
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:
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. There are no setbacks given in the most recent permit.
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: The permittee has never recycled water at this facility.
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., NDMR, NDAR, GW)? Yes or No N/A
Please summarize any findings resulting from this review:
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: x Notice of Deficiency
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:
DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E

FORM: APSRSR 04-10 Page 3 of 3
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 APS Central Office to obtain through an additional information request:
Item Reason

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 APS regional supervisor:
Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
It is unclear what environmental benefit/protection is accomplished through this permit. The facility is located within
50 feet of the French Broad River (FBR). The wash water is not recycled; it seeps into the ground/river. When the
river floods, the ponds can be inundated. Fresh water is used to wash sand/gravel that was pulled from the FBR. If
mechanical recycling is going to occur, the storage pond would need to be lined. The storage pond basically functions
as an infiltration basin.
DocuSign Envelope ID: 8D14A6B2-490B-4F3A-BA93-7E39EC6DCD1E
11/8/2017