NC0004464_Staff Report_20180213

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.: NC0004464
Attn: Joe Corporon Facility name: Woodland Mills 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: 02/12/2018
b. Site visit conducted by: Mikal Willmer and Beverly Price
c. Inspection report attached? Yes or No
d. Person contacted: Juanita James and their contact information: (828) 697 - 0063 ext.
e. Driving directions: From Swannanoa: Take I-40 W to I-26 East. Stay on I-26 E for approximately 35 miles
and continue on US-74 E toward Ruthefordton/Columbus. Take exit 103 for NC 108 towards Columbus. Turn
left on 108 and continue for three miles. Turn left after Laughter Pond at the Woodland Mills Plant. The WWTP
is located down a dirt road adjacent to the Pond.
2. Discharge Point(s):
Latitude: 35.294223 Longitude: -82.166284
Latitude: Longitude:
3. Receiving stream or affected surface waters: South Branch
Classification: C
River Basin and Subbasin No. Broad Sub-basin #03-08-02
Describe receiving stream features and pertinent downstream uses: A Class C stream protected for
secondary recreational use, which flows into Little White Oak Creek, also Class C.
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:
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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: Shannon James Certificate #: 1002526 Backup ORC: Multiple 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: Previous issues with excessive solids throughout the plant. Backup ORC, Juanita James,
reports they have issues settling solids, even with the addition of Alum, due to flow surges from the lift station.
Polk County plans to upgrade the plant in phases. Phase I will be the addition of a chlorine contact chamber with
baffled walls and a de-chlorination test tank to allow for easier sample collection. Phase II will be the installation
of an EQ basin and Digester to help aid in solids management. Ms. James indicated an AtoC application has been
submitted and approved for Phase I. AtoC 004464A02 was issued December 19, 2017.
Description of existing facilities: 0.015 MGD activated sludge plant with manual bar screen, single train aeration
basin with diffusers, hopper style clarifier with skimmer, adjustable weir, tablet chlorination and de-chlorination.
Effluent post-treatment is not easily accessible.
Proposed flow: No proposed flow increases.
Current permitted flow: 0.015 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.) Treatment units are showing their age. Rust is evident throughout the facility. Currently no means of
controlling flow surges from the influent pump station and facility staff do not have the ability to waste solids
without a pump truck. High sludge blanket recorded in both clarifier hoppers. Ms. James states the clarifier is not
pumped more regularly because they try to maintain 40% settleability within the AB.
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:
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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:
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: There have been six BOD violations, one fecal
violation, four NH3 violations and 18 TSS violations since 2013.
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? Facility has had three non-compliant inspections
during this permit cycle. There were non-compliant inspections in 2015, 2017 and 2018. The facility still
experiences issues with solids wasting; however, there are current phased improvements planned. A chlorine
contact chamber and effluent well for sampling should be installed this year. Phase II improvements will include
the installation of an EQ Basin and Digester to better manage flow surges and solids.
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): N/A

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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

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:

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4/4/2018
FORM: WQROSSR 04-14 Page 6 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See the Compliance Sampling Inspection from 02/12/2018 for additional notes and comments. Plans, specifications
and funds are available for the installation of the Phase I upgrade. Polk County intends to have Phase II installed in
FY 19.

DocuSign Envelope ID: A8DC0113-D6B7-4A90-8AC3-C2AE2324F1E2