NC0020214_Staff Report_20180425

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.: NC0020214
Attn: Natalie Norberg Facility name: Sylva WWTP (TWSA #2)

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: 04/23/2018
b. Site visit conducted by: Mikal Willmer and Beverly Price
c. Inspection report attached? Yes or No
d. Person contacted: Stan Bryson and their contact information: (828) 586 - 9318 ext.
e. Driving directions: From Swannanoa, take I-40 W to exit 27 for US-74 W. Continue on US-74 W for
approximately 25 miles. Take exit 83 toward Sylva. Continue on Grindstaff Cove Rd. for 0.7 miles. Turn right
onto Mill St/W Main St and continue for 0.7 miles. Take a slight right onto Old Home Town Rd. The WWTP
access road is approximately 400 ft on the right.
2. Discharge Point(s):
Latitude:35.373553 Longitude: -83.241436
Latitude: Longitude:
3. Receiving stream or affected surface waters: Scott Creek
Classification: C, Tr
River Basin and Subbasin No. Little Tennessee 04-04-02
Describe receiving stream features and pertinent downstream uses: Scott Creek is protected for secondary
recreation and trout propagation. It flows into the Tuckasegee River, used for rafting and fly fishing.
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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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.
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: Ben Henson Certificate #:16864 Backup ORC: Stan Bryson Certificate #:9922
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: Facility is currently meeting all permit limits; however, many of the treatment components
are reaching the end of their useable life. Facility staff are continuously repairing failing equipment. The bar
screen and grit system do not adequately remove debris. Significant pass through to the stilling well and digester.
Description of existing facilities: Manual bar screen, influent pump station, valve box, aerated grit chamber, two
aeration zones, stilling well, aerobic digester (used as facultative) gas chlorination/dechlorination and reaeration
tank.
Proposed flow: N/A
Current permitted flow: 0.5 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.)
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.
9. Is the description of the facilities as written in the existing permit correct? Yes or No
If no, please explain:
DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
FORM: WQROSSR 04-14 Page 3 of 6
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
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: No violations during the most recent 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.)
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): N/A

DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
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: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
4/25/2018
FORM: WQROSSR 04-14 Page 6 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See attached inspection report for additional observations and recommendations.

DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C

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

April 25, 2018

Stan Bryson, Operations Superintendent
Tuckaseigee Water & Sewer Authority
1246 West Main St.
Sylva, NC 28779

SUBJECT: Compliance Inspection Report
TWSA #2 (Sylva WWTP)
NPDES WW Permit No. NC0020214
Jackson County, NC

Dear Mr. Bryson:

The North Carolina Division of Water Resources conducted a Compliance Evaluation Inspection
of the TWSA #2 Plant (Sylva WWTP) on April 23, 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. NC0020214. Based on the on-site visit, the facility was determined to be in
compliance.

The following additional items were noted during the inspection and should be addressed:
 Sampling: The composite sampler is set to time, not flow proportional. Composite samples
must be flow proportional, unless prior approval is received from the Division. Please
notify our office once the sampler is reprogrammed.
 Electrical: Recommend prioritizing electrical upgrades to facilitate further facility
improvements
 Stand-by Power: Currently the on-site generator will only run the facility’s pumps. This
should be included in the electrical upgrades to the facility.
 Flow EQ: Recommend installation of an EQ basin to help mitigate the impact of flow
surges on TWSA #2. Flow diversion to TWSA #1 can overwhelm the downstream pump
station.
 Bar Screen & Grit Removal: The bar screen is not easily accessible, a safety concern and
does not adequately screen incoming debris. The grit removal system has not functioned
properly since installed. Recommend upgrading system components to prevent the pass
through of significant debris through the treatment system.

DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C

Please refer to the enclosed inspection report for additional observations and recommendations.
Your assistance during the inspection 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].

Sincerely,

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

Ec: WQS-ARO Server
NPDES-LF

20180425_NC0020214_CEI.cover letter
DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
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 NC0020214 18/04/23 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)
TWSA WWTP#2
114 Hometown Pl Rd
Sylva NC 28779
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
12:00PM 18/04/23 13/02/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Stan D Bryson/ORC/828-586-9318/
Other Facility Data
12:45PM 18/04/23 17/10/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Joe Cline,1246 W Main St Sylva NC 28779//828-586-5189/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 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
Beverly Price Division of Water Quality//828-296-4500/
Mikal Willmer Division of Water Quality//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: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
4/25/2018
4/25/2018
NPDES yr/mo/day
18/04/23
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Inspectors Mikal Willmer and Beverly Price, with the Asheville Regional Office, conducted a
Compliance Evaluation Inspection of the Sylva WWTP owned and operated by the Tuckaseigee Water
and Sewer Authority (TWSA). Stan Bryson, Backup ORC and Wastewater Operations Superintendent,
was present and assisted in the facility inspection.
Overall the WWTP appeared to be well operated and maintained, considering the age of the facility.
TWSA staff repair equipment in house as needed. It should be noted this is an aging facility and it
appears staff expend significant time repairing and maintaining failing equipment.
The facility was determined to be in compliance at the time of the inspection; however, the following
items were noted and should be addressed.
Sampling: Composite samples must be flow proportional. Time composite samples are only allowed
when effluent flow rates vary less than 15 percent and only with prior Division approval.
Electrical: Recommend prioritizing electrical upgrades to facilitate further facility improvements.
Stand-by Power: The on-site generator will only run the facility's pumps in the event of a power failure,
due to electrical constraints. This should be addressed to prevent a potential upset during an extended
power failure.
Flow EQ: Recommend an equalization basin to help mitigate the impact of flow surges. While flow can
be diverted from the influent pump station to TWSA #1, staff report heavy flows can overwhelm the
downstream pump station.
Bar Screen & Grit Removal: The current mechanical bar screen is not easily accessible, a safety
concern and does not adequately screen incoming debris. The Grit Removal system has not worked
properly since installed. Recommend upgrading these system components to prevent the pass
through of significant debris and solids through the treatment system. This is of primary concern
because of its' potential impact on the receiving stream. Plastic debris was noted in the stilling well and
along the weirs.
NC0020214 17 (Cont.)
Page#2
DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
Permit:NC0020214
Inspection Date:04/23/2018
Owner - Facility:
Inspection Type:
TWSA WWTP#2
Compliance Evaluation
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
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:
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?
Draft Permit is out for public comment.Comment:
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Page#3
DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
Permit:NC0020214
Inspection Date:04/23/2018
Owner - Facility:
Inspection Type:
TWSA WWTP#2
Compliance Evaluation
Operations & Maintenance Yes No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
MLSS analyzed on ABs and RAS. Volatile solids are also analyzed on the 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?
The screen has recently been repaired; however, it does not adequately screen incoming
debris. The screen is in a brick manhole and not easily accessible. A mechanical hoist is
used to lift the steel screen out of the manhole for cleaning three times a week. An upgraded
mechanical screen would reduce safety concerns, improve accessibility and screening of
debris. The backup ORC believes a band screen would significantly reduce pass through
debris.
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?
Mr. Bryson reports the aerated grit chamber has not performed properly since installed.
TWSA should evaluate whether to replace or repair.
Comment:
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures?
Is the wet well free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Is SCADA telemetry available and operational?
Page#4
DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
Permit:NC0020214
Inspection Date:04/23/2018
Owner - Facility:
Inspection Type:
TWSA WWTP#2
Compliance Evaluation
Pump Station - Influent Yes No NA NE
Is audible and visual alarm available and operational?
Wet well uses ultrasonic level transducer with float back-up. Flow can be diverted from
TWSA #2 to TWSA #1 during heavy flows or when repairs are needed; however, heavy
flows can overwhelm the downstream pump station. Recommend the addition of an EQ
basin to help offset the effect of flow surges and help maintain plant and collection system
compliance.
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
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)
Staff maintain DO at approximately 1.5 mg/L.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)
Sludge blanket was not visible; however, debris is making its way into the stilling well and
some debris is passing through to the weir. There did not appear to be visible debris in the
effluent launder.
Comment:
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DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
Permit:NC0020214
Inspection Date:04/23/2018
Owner - Facility:
Inspection Type:
TWSA WWTP#2
Compliance Evaluation
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Facility utilizes Air lift pumps. Valves were installed to allow staff to adjust RAS rates.Comment:
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
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?
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-____-____)
If yes, then when was the RMP last updated?
Backup ORC states they maintain approximately 9 chlorine cylinders on-site.Comment:
De-chlorination Yes No NA NE
Type of system ?Gas
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?
Are the tablets the proper size and type?
Sulfur dioxide is used for dechlorination. The facility has tubing installed to feed a liquid
dechlor agent when needed.
Comment:
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?
Page#6
DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
Permit:NC0020214
Inspection Date:04/23/2018
Owner - Facility:
Inspection Type:
TWSA WWTP#2
Compliance Evaluation
Flow Measurement - Effluent Yes No NA NE
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Calibrated annually by ISIComment:
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)?
Mr. Bryson stated the composite sampler is set to time not flow proportional. This item was
briefly mentioned in an inspection report from October 7, 2010. Composite sampling is
required to be flow proportional. See summary for further details.
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?
Post-aeration tank located before outfall. Also serves as a chlorine contact chamber.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?
TWSA Staff service and maintain the generator. The generator is tested under load every
Monday at 8 am. It should be noted, in the event of a power failure, the generator is currently
only wired to run the facilities pumps. The blowers are not connected, due to needed
electrical upgrades. Recommend prioritizing electrical upgrades to facilitate further facility
improvements.
Comment:
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DocuSign Envelope ID: F697D10E-5A73-48B0-BAB5-2B26BB340D8C
Permit:NC0020214
Inspection Date:04/23/2018
Owner - Facility:
Inspection Type:
TWSA WWTP#2
Compliance Evaluation
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?
Digester is not being aerated. Facility staff are using it as a facultative digester. There are
approximately 12 years of debris sitting on the surface of the digester. Improvements need
to be made to the headworks of the facility to prevent this amount of pass-through. Digester
surface can only be cleaned when the tank is completely drained.
Comment:
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