NC0085294_Staff Report_20180307

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.: NC0085294
Attn: Emily Phillips Facility name: Pavillon-Britten Creek 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: 03/07/2018
b. Site visit conducted by: Mikal Willmer and Dan Boss
c. Inspection report attached? Yes or No
d. Person contacted: Juanita James (James & James Environmental) 828-697-0063 & Tara Hamlin (Pavillon
Facilities Director) 828-625-8210.
e. Driving directions: From Swannanoa: I-40 W to Exit 53A to US-74 Alt E. Continue on US-74 Alt E for
approximately 25 miles. Turn right on NC-9, turn right onto Coopers Gap Rd. Take a left onto Lake Adger Rd.
Stay on Lake Adger Rd. for approximately 0.2 miles. You will take a left down an access road before reaching
Pavillon Pl. Go past the parking lot on the right and keep left at the fork. Take a right at the next fork in the
road. The WWTP plant will be on the right.
2. Discharge Point(s):
Latitude: 35.367432 Longitude: -82.213202
Latitude: Longitude:
3. Receiving stream or affected surface waters: Britten Creek
Classification: Class C
River Basin and Subbasin No. Broad, 03-08-02
Describe receiving stream features and pertinent downstream uses: Britten Creek is a Class C waterbody
protected for secondary recreational use. Britten Creek flows into the Green River (Class C), downstream
of the Lake Adger Dam.
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:
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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)
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: Juanita James Certificate #:24074
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: Back-up ORC, Juanita James, reports the 1000-gallon aerobic digester does not have
adequate capacity to waste solids as often as needed. This is currently being supplemented by pumper truck visits.
Description of existing facilities: Aerated EQ Basin, followed by aeration basin equipped with diffused air set on
timers. Hopper style clarifier with airlift pump. 1000-gallon aerobic digester. Chlorination tubes/chlorine contact
chamber, Effluent weir box, ultrasonic flow meter with chart recorder. Effluent pump station, dechlorination tubes
and wet well.
Proposed flow: NA
Current permitted flow: 5860 GPD
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.) Current permit and permit application listed the components of the previous sand filter system. The entire
WWTP was upgraded in 2014-2015 to an activated sludge facility. The permit was never updated to reflect these
changes (treatment components, effluent parameters and monitoring frequency).
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: Facility description should be updated to reflect changes.
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: Permit was never updated to reflect the facility upgrade. See above for a list of currently
installed treatment components.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

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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 four limit violations since the facility
was upgraded in 2015. One TSS, two BOD and one Flow limit violation.
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.): There
was one NOV for a BOD limit violation in the most recent 12-month monitoring period.
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? Ms. James reports they have not experienced
issues with flow since installing the new WWTP. Flow readings need to be verified. According to the ORC’s
logbook the flow meter is reading inaccurately. The ORC is reporting grab flows on the DMR. Flow meter, if
going to be used, needs to be replaced or calibrated more frequently. See inspection report for additional details.
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

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: A5E497D6-2FDE-4FF8-8254-067C97C01F39
4/4/2018
FORM: WQROSSR 04-14 Page 6 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See inspection report for additional details.

DocuSign Envelope ID: A5E497D6-2FDE-4FF8-8254-067C97C01F39