NC0074306_Staff Report_20180726

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. NC0074306
Attn: Brianna Young Facility name: Forest City WTP

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: 02/22/2018
b. Site visit conducted by: Mikal Willmer & Beverly Price
c. Inspection report attached? Yes or No (previously sent)
d. Person contacted: Jason Webb and their contact information: (828) 248 - 5215 ext.
e. Driving directions: Take I-40 E from Swannanoa for approximately 40 miles, take exit 83 for Ashworth rd,
turn right. Turn right onto US-221 S. Stay on US-221 S for 10 miles, turn left onto Hudlow Rd. Stay on Hudlow
Rd. for 11.5 miles. Turn left onto Lincoln Rd, take a right onto Horn Bottom Rd and continue onto Vance St.
The WTP is on the right.
2. Discharge Point(s):
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: UT to Forest Lake which connects to the Second Broad
Classification: WS-V
River Basin and Subbasin No. Broad River Basin; 03050105
Describe receiving stream features and pertinent downstream uses: Receiving stream is a UT to the Second
Broad, classified as WS-V, protected for all class C uses and downstream water supplies.
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: Sonny Penson Certificate #:29329 Backup ORC: NA 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: This facility was given a monitoring and visitation waiver in 2008 because they have not
discharged since 1996. ORC reports the facility receiving stream is a dry ditch. Currently backwash water is not
dechlorinated before entering the settling ponds.
Description of existing facilities: Filter backwash water is alternated between two earthen settling ponds. A valve
in the effluent wet well allows the flow to either be sent back to the head of the WTP for reuse or discharged to a
UT to Forest Lake and onto the Second Broad. Valve to the effluent pipe is currently closed.
Proposed flow: NA
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.) ORC still visits the site multiple times a week, even with the waiver in place. Only concern is this facility has
not discharged since 1996, so backwash water is not dechlorinated and routine sampling has not been needed in
over 20 years. Facility staff would need to clear a path to the effluent pipe and resume sample collection if they
needed to discharge.
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:
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FORM: WQROSSR 04-14 Page 3 of 6
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: Currently no facility description included within the Permit. This facility has an 8 MGD
potable water flowrate and generates approximately 0.056 MGD of backwash water. Filter backwash, is
discharged into two alum settling ponds/lagoons (2 MG combined storage capacity). Valves and pumps within a
combined manhole allow for surface water discharge or for the supernatant to be recycled back to the head of the
WTP for reuse. Effluent valve to the UT has been closed since 1996. WTP Residuals are distributed under DRS
Permit No. WQ0038071.
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:

DocuSign Envelope ID: D7AF5EDA-941D-4E21-93B2-8B7C2B9F4A05
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: Facility has had a monitoring waiver since 2008.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable. Facility has
not had a reported discharge since 1996. The Division granted a monitoring and visitation waiver in 2008.
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: chlorine and alum sludge
17. Pretreatment Program (POTWs only): N/A

DocuSign Envelope ID: D7AF5EDA-941D-4E21-93B2-8B7C2B9F4A05
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
Notification of Intent to
Discharge
Facility has not discharged since 1996. A monitoring and visitation waiver has
been in place since 2008. Access to effluent pipe is not currently being
maintained. Sampling protocols would have to be re-established and effluent
monitoring would need to be re-activated. Backwash water is not currently
dechlorinated. Minor potential for discharge of chlorine to the receiving stream.

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: D7AF5EDA-941D-4E21-93B2-8B7C2B9F4A05
7/27/2018
FORM: WQROSSR 04-14 Page 6 of 6

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See compliance inspection conducted on February 22, 2018.
The WTP current recycle system falls under 15A NCAC 02T .1003 Permitting by Regulation (a)(4) The reuse or
return of wastewater within the treatment works of a permitted wastewater treatment system.
The recycle water is considered wastewater. If the NPDES permit is ever rescinded, then a Closed Loop Recycle
permit would be needed.

DocuSign Envelope ID: D7AF5EDA-941D-4E21-93B2-8B7C2B9F4A05