NC0028975_STFRPTCEI_20180319

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.: NC0028975
Attn: Joe Corporon Facility name: Saluda WWTP

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: 03/02/2018
b. Site visit conducted by: Mikal Willmer
c. Inspection report attached? Yes or No
d. Person contacted: Trevor McMinn and their contact information: (828) 691 - 7191 ext.
e. Driving directions: From Swannanoa: I-40 W to I-26 E. Stay on I-26 E for approximately 28 miles. Take exit
59 for Saluda. Turn right onto State Rd. 1142/Ozone Dr. Continue on ozone drive for 0.8 miles. Turn right onto
E Main St. Turn left onto Pearson Falls Rd. Facility will be on the right.
2. Discharge Point(s):
Latitude: 35.230641 Longitude: -82.343810
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification: Class C
River Basin and Subbasin No. Broad;03-08-06
Describe receiving stream features and pertinent downstream uses: Joel’s Creek is a Class C surface water
protected for secondary recreational use. It flows into the North Pacolet River, classified C;Tr.
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: 98E57A0C-A210-4353-93D8-C0ADA9A75038
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: Trevor McMinn Certificate #:15084 Backup ORC: Ken Deaver Certificate #:27295
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: Baffled grit chamber. Manual bar screen. Dual treatment trains consisting of
~66,000 gallon diffused air aeration basins and 33,000 gallon circular clarifiers. Two 10,000 gallon aerobic
digesters. Chlorination/dechlorination contact chamber. Effluent weir box and ultrasonic flow meter.
Proposed flow: N/A
Current permitted flow: 0.10 MGD
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.) ORC cannot sample 350’ downstream due to accessibility. Refer to attached inspection report for additional
details. Contract firm is requesting a modification of the downstream sampling site on behalf of the City of
Saluda.
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 N/A
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.
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain: Facilities description is currently missing the aeration basins.
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
FORM: WQROSSR 04-14 Page 3 of 5
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: Saluda has had 2 BOD violations, 1 fecal and one
unauthorized bypass during the current permit cycle.
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.) The
facility has had a few violations during this current permit cycle. The City of Saluda switched contract operating
firms at the end of 2016. The current ORC took over operations in May of 2017.
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? There have been no apparent prolonged
compliance issues. The facility has adequate digester capacity to waste as needed. The new ORC plans to increase
the frequency of cleaning solids from the clarifier.
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: 98E57A0C-A210-4353-93D8-C0ADA9A75038
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

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: 98E57A0C-A210-4353-93D8-C0ADA9A75038
3/19/2018
FORM: WQROSSR 04-14 Page 5 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
Facility has requested modification of downstream sampling location. See attached inspection report and the email
from KACE Environmental on behalf of the City of Saluda for additional details.

DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038

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

March 19, 2018

Jonathan Cannon, City Manager
City of Saluda
PO Box 248
Saluda, NC 28773

SUBJECT: Compliance Inspection Report
Saluda WWTP
NPDES WW Permit No. NC0028975
Polk County, NC

Dear Mr. Cannon:

The North Carolina Division of Water Resources conducted a Compliance Evaluation Inspection
of the Saluda WWTP on March 2, 2018. This inspection was conducted to verify that the facility
is operating in compliance with the conditions and limitations specified in NDPES WW Permit
No. NC0028975. Based on the on-site visit and discussions with plant staff, the facility was
determined to be in compliance.

The following additional items were noted during the inspection:
 Clarifier: Solids appeared to be accumulating in the center-well and algae was beginning
to grow on the weir teeth. Solids should be removed and the clarifier should be washed as
needed to maintain optimal performance.
 Chemical Containment: There did not appear to be a means of containing a spill on-site.
Recommend, at a minimum, maintain a chemical spill kit on-site.

Please refer to the enclosed inspection report for additional observations and recommendations.
The assistance of ORC Trevor McMinn was greatly appreciated. If you have any questions, please
do not hesitate to contact me at 828-296-4686 or by email at [e-mail].

DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038

Sincerely,

Mikal Willmer, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
Enclosure: Inspection Report

Ec: Trevor McMinn, ORC
WQS-ARO Server
NPDES-LF

20180319_NC0028975_CEI
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
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 NC0028975 18/02/26 C 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)
Saluda WWTP
Pearson Falls Rd
Saluda NC 28773
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:30AM 18/02/26 14/08/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Trevor Clyde McMinn/ORC/828-691-7191/
Other Facility Data
11:30AM 18/02/26 18/07/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Rodney A Gibson,PO Box 248 Saluda NC 287730248//828-749-2581/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program Sludge Handling Disposal Pollution Prevention Facility Site Review
Effluent/Receiving Waters
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
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.
Page#1
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
3/19/2018
3/19/2018
NPDES yr/mo/day
18/02/26
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspector Mikal Willmer, with the Asheville Regional Office, conducted a Compliance Evaluation
Inspection of the Saluda WWTP on March 2, 2018. This inspection was conducted to determine if the
facility is being operated and maintained in compliance with NPDES Permit No. NC0028975. ORC
Trevor McMinn, with KACE Environmental Inc, was present and assisted in the inspection.
Overall the plant appeared to be operating in compliance with NPDES Permit No. NC0028975;
however, there were a few items noted during the inspection that should be addressed.
Chemical Containment: Currently containment booms and berms are not kept on-site in the event of a
chemical spill. The chemical feed building does not have built-in containment. Recommend, at a
minimum, maintaining a chemical spill kit on-site.
Solids in Center Well: At the time of the inspection, solids appeared to be building-up in the center well
of the clarifier. ORC stated he planned to increase the cleaning from annually to semi-annually. Solids
wasting and removal should be done as needed to prevent the discharge of solids to the receiving
stream.
Weir Teeth: Algal growth was occurring on the weir teeth at the time of the inspection and was
beginning to restrict flow through the weirs. Recommend washing down the weirs to remove any
blockages to allow for optimal performance.
Downstream Sampling: The ORC reports he is unable to collect the downstream sample at the
required 350'. The ORC is currently collecting the downstream sample approximately 106'
downstream of the effluent discharge. Mr. McMinn reports the downstream parcel owner does not want
plant staff on his property collecting samples. The Town should request a change/modification in
sampling location downstream due to accessibility.
NC0028975 17 (Cont.)
Page#2
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
Permit:NC0028975
Inspection Date:02/26/2018
Owner - Facility:
Inspection Type:
Saluda WWTP
Compliance Evaluation
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?
Permit renewal was received on February 1, 2018.Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
ORC reports MLSS, DO and a sludge judge are utilized in monitoring the facility.Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is sampling performed according to the permit?
The Influent sampler is set to time composite. ORC stated the influent sampler's aliquot
volume has not been checked regularly. Recommend checking sample aliquot volume to
ensure a minimum of 100 mL is being pulled at a time.
Comment:
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Page#3
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
Permit:NC0028975
Inspection Date:02/26/2018
Owner - Facility:
Inspection Type:
Saluda WWTP
Compliance Evaluation
Record Keeping Yes No NA NE
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
on each shift?
Is the ORC visitation log available and current?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility classification?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Comment:
Grit Removal Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
The Grit chamber is positioned before the bar screen. Influent flows into a baffled chamber
to allow debris to settle out before flowing through the bar screen and into the aeration
basins.
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Page#4
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
Permit:NC0028975
Inspection Date:02/26/2018
Owner - Facility:
Inspection Type:
Saluda WWTP
Compliance Evaluation
Bar Screens Yes No NA NE
The manual screen catches most of the incoming debris before entering the Basins;
however, the ORC installed an additional screen before the clarifiers due to leaves and
pass-through debris clogging return pumps. The Town may eventually install a mechanical
bar screen at the facility; however, funding for the current budget year is going to be
allocated to reducing I&I in the collection system.
Comment:
Aeration Basins Yes No NA NE
Mode of operation Plug flow
Type of aeration system Diffused
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Does the foam cover less than 25% of the basin’s surface?
Is the DO level acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/l)
Facility has three blowers, but only two are currently in use. ORC reports he maintains a DO
of about 2.4 mg/L and prefers to keep settleability about 50% in the Basins.
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
Page#5
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
Permit:NC0028975
Inspection Date:02/26/2018
Owner - Facility:
Inspection Type:
Saluda WWTP
Compliance Evaluation
Secondary Clarifier Yes No NA NE
During the inspection, solids appeared to be building in the center well of the clarifier. The
clarifier center well is only being cleaned annually. ORC, Trevor McMinn reports he plans to
increase this to twice a year. At the time of the inspection Mr. McMinn reported there was
approximately 8' of clear water in the 20' clarifier. Recommend removing solids from the
clarifier as needed to prevent an upset and possible discharge of solids. The weirs appeared
to be level and there did not appear to be significant solids leaving the clarifier; however,
algae were beginning to grow on the weir teeth. It is recommended the weir teeth be
completely washed down to allow for optimal performance.
Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
The generator self-tests weekly.Comment:
Disinfection-Liquid Yes No NA NE
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de-chlorination?
Chlorine feed is added at a set amount. The ORC believes this is the reason for occasional
fecal exceedances. The Town is considering changing the feed system to flow proportional.
See summary for spill containment recommendations.
Comment:
De-chlorination Yes No NA NE
Type of system ?Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de-chlorination substance stored away from chlorine containers?
Comment:
Page#6
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
Permit:NC0028975
Inspection Date:02/26/2018
Owner - Facility:
Inspection Type:
Saluda WWTP
Compliance Evaluation
De-chlorination Yes No NA NE
Are the tablets the proper size and type?
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
At the time of the inspection, the effluent flow meter had not been calibrated for the year.
Last calibration sticker indicated it was due in November 2017. Laboratory Instruments was
contacted by KACE Environmental Inc. after the inspection. The flow meter was calibrated
on 3-13-2018. Dry weather flows are about 0.05 MGD. The facility experiences average wet
weather flow increases of about 0.02 MGD. The Town is currently working on reducing I&I.
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
All sampling is being performed as required by the permit.Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
The effluent pipe is easily accessible. ORC reports the creek has overtopped the pipe, but
has never backed up to the effluent weir.
Comment:
Upstream / Downstream Sampling Yes No NA NE
Page#7
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038
Permit:NC0028975
Inspection Date:02/26/2018
Owner - Facility:
Inspection Type:
Saluda WWTP
Compliance Evaluation
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and
sampling location)?
All sample frequencies are being met; however, the ORC reports he is unable to collect the
downstream sample at the required 350'. The ORC is currently collecting the downstream
sample approximately 106' downstream of the effluent discharge. Mr. McMinn reports the
downstream parcel owner does not want plant staff on his property collecting samples. The
Town should request a change in sampling location downstream due to accessibility.
Comment:
Aerobic Digester Yes No NA NE
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
ORC reports he wastes solids approximately 30 mins a week.Comment:
Page#8
DocuSign Envelope ID: 98E57A0C-A210-4353-93D8-C0ADA9A75038