NCG551741_Staff Report_20171106

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.: NCG551741
Attn: (name of Reviewer in Raleigh) Facility name: 5026 Wayah Rd.

From: Mikal Willmer
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: 06/23/2017
b. Site visit conducted by: Mikal Willmer & Tim Heim
c. Inspection report attached? Yes or No
d. Person contacted: Marcie Cramer and their contact information: (828) 369 - 9993 ext.
e. Driving directions: Head west on I-40 from the ARO. Take exit 27 (US-74) towards sylva. Take exit 81 off
of US-74. Travel on US-23 S to US-64 W for approximately 24 miles, then turn right onto Patton Rd and take
the first left onto Wayah Rd. Proposed facility is five miles on the left (5026 Wayah Rd.)
2. Discharge Point(s):
Latitude: 35.161478 Longitude: -83.536484
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification: WS-III Tr
River Basin and Subbasin No. Little Tennessee, Upper Little Tennessee Subbasin (06010202)
Describe receiving stream features and pertinent downstream uses: Wayah Creek flows into
Cartoogechaye Creek, a WS-III, Tr, CA (Town of Franklin’s Water Supply Intake).
II. PROPOSED FACILITIES: NEW APPLICATIONS
1. Facility Classification: Failed subsurface septic system. Propose SFR Discharge <1000 GPD
Proposed flow: 360 gallons
Current permitted flow: Two bedroom home ~240 GPD
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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FORM: WQROSSR 04-14 Page 2 of 6
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. Property has site constraints. Setbacks are <30’ from property lines,
<15’ from building foundation, <100’from water supply wells, & <50’ from creekbank.
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: all wastewater discharges have the potential to negatively impact surface
waters.
11. Pretreatment Program (POTWs only): NA

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:
Proposed flow:
Current permitted flow:
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
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:
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FORM: WQROSSR 04-14 Page 3 of 6
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

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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):

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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

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
Require Grade I NC
Licensed WW ORC w?
Operator Visitation
1/month
This is a WS-III, B, Tr stream that feeds into WS a CA (Water Supply for the
Town of Franklin). Additionally, SFR (NCG55) systems have a relatively low
compliance rate in Asheville region.
Operator visitation log
required to be retained (add
to Part II, Section E:1)
See above.

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: 4567DA2B-47DB-46B3-8350-30DBD6705980
11/3/2017 11/6/2017
11/6/2017
FORM: WQROSSR 04-14 Page 6 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See facility inspection report for additional site-visit details.

DocuSign Envelope ID: 4567DA2B-47DB-46B3-8350-30DBD6705980
EPA
United States Environmental Protection Agency
Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 N 52 NCG551741 17/06/23 R S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
5026 Wayah Road
5026 Wayah Rd
Franklin NC 28734
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:20AM 17/06/23
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Other Facility Data
12:00PM 17/06/23
Name, Address of Responsible Official/Title/Phone and Fax Number
Marcie Cramer,117 Longbranch Rd Winter Park FL 32792//407-657-8555/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date
Timothy H Heim ARO WQ//828-296-4665/
Mikal Willmer ARO WQ//828-296-4686/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
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11/3/2017
11/6/2017
11/6/2017
NPDES yr/mo/day
17/06/23
Inspection Type
R3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Mikal Willmer and Tim Heim with the Asheville Regional Office conducted a Reconnaissance
Inspection of the property located at 5026 Wayah Rd in Macon County. This inspection was conducted
to gather additional information about site suitability for a potential issuance of a General NPDES
discharge permit through the North Carolina Division of Water Resources. Marcie Cramer (owner),
David Smith (Consulting Engineer), Karen Wallace (NC DHHS), Kyle Jennings and Jonathan Fouts
(Macon Environmental Health) and Hugh Shannon and Richard Ledford (Mountain Soils).
Observations of the subject property, site history and receiving stream are as follows:
March 2017: I (Mikal Willmer) initially spoke with Ms. Cramer at the end of March in regard to her
interest in purchasing 5026 Wayah Rd and a part-time home. We discussed the potential issues with
the current septic system. I provided Ms. Cramer with information about the permitting process through
our division and informed her that even a repair denial from the health department did not guarantee an
application with our Division would be approved.
May 2017: I spoke with Ms. Cramer in May and she informed me they had purchased the property and
were denied an improvement permit (increase bedroom size from two to three bedrooms). They were
also issued a Notice to Repair the septic system at that time. I provided Ms. Cramer with the options
she needed to explore before submitting an application to our Division, along with lists of Environmental
Engineers and NC On-site Water Protection Branch's contact information. At the end of May Ms.
Cramer began to explore a potential pump & haul (P&H) permit to use the property until a working
septic system could be installed.
June 2017: After verifying the Division's regulations in regards to temporary P&Hs, Tim Heim, informed
Ms. Cramer we were unable to issue a P&H permit since she did not have a permitted system with
DWR. The local health department and NC DHHS confirmed their regulations did not allow them to
issue a permanent P&H permit unless an owner is denied all other wastewater disposal options.
June 23, 2017: Tim Heim and I met with Ms. Cramer on-site to assess site conditions and have the
health department go over their findings for the property. The septic tank was located within the 2nd
bedroom of the home under a hatch in the floor. The local health department had no record or permit
for this system (house was built in the 60's). The septic tank failed all leak tests and any wastewater
generated from the home was more than likely making its way into Wayah Creek. The property is
approximately half an acre and the home sits on the bank directly above the creek. The property has
severe site restrictions (property line, right-of-way, well and creek setbacks). Wayah Creek is listed at
a WS-III, B, Tr stream that flows into the town of Franklin's Water Supply.
August 2017: Ms. Cramer was provided with the pump and haul application and regulations for her
records. Tim Heim reiterated she could apply for a pump and haul permit, but it would only be
considered if she were approved for coverage under a General NPDES permit.
See staff report for ARO recommendations.
NCG551741 17 (Cont.)
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Permit:NCG551741
Inspection Date:06/23/2017
Owner - Facility:
Inspection Type:
5026 Wayah Road
Reconnaissance
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
See summary for details of site-visit.Comment:
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