WQ0010615_Staff Report_20190403

State of North Carolina
Department of Environmental Quality
Division of Water Resources

Water Quality Permitting
Regional Staff Report

FORM: APSRSR 04-10 Page 1 of 4
April 3, 2019

To: DWR Water Quality Permitting Section Central Office Application No.: WQ0010615
Attn: Ranveer Katyal Regional Login No.:

From: Bev Price
Asheville Regional Office
I. GENERAL SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 03/28/2018
b. Site visit conducted by: Beverly Price
c. Inspection report attached? Yes or No
d. Person contacted: Mike Mehaffey and their contact information: 828-926-0866 Ext. 102
e. Driving directions: I-40 to Exit #20 (Maggie Valley), right on Jonathan’s Creek Rd. Go approximately ½ mi.
turn left at Exxon, cross northbound Jonathan’s Crk. Rd. to gravel road. Cross wooden bridge & go through
red cattle gate. WWTP is at end of road.
II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
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:
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)

DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C
FORM: APSRSR 04-10 Page 2 of 4
III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A
ORC: Certificate #: Backup ORC: 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:
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 N/A
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:
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., NDMR, NDAR, GW)? Yes or No
Please summarize any findings resulting from this review: 2018 Annual Report review not complete due to
missing information.
13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No N/A
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.)
15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain:
16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
Yes No N/A
If yes, please explain:
DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C
FORM: APSRSR 04-10 Page 3 of 4
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 DWR 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 APS regional supervisor:
Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

Ignitability: Our application only references flashpoint. RCRA only has standard methodologies to classify wastes as
ignitable for liquid wastes (ASTM Methods D-93-79, D 93-80 & D-3278-78). Those methods do not apply to classifying
solids as hazardous. The permittee listed a burn-rate analyzed using SW-846 method 1030 because the product is a solid
(Total percent solids: 87.5 %). As method 1030 states, there is no specific test for ignitable solids required by RCRA.
Only a waste meeting the narrative definition at 40 CFR 261.21 (a)(2) can be classified as an ignitable hazardous waste
because it is an ignitable solid. Can this be clarified for permittee within their renewed permit (i.e. the use of a narrative
description or allow use of DOTs burn rate limit)?
Corrosivity: 40 CFR 261.22 states: a) A solid waste exhibits the characteristic of corrosivity if a representative sample of
the waste has either of the following properties:
(1) It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, as determined by a pH meter using
Method 9040C in “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” EPA Publication SW-846, as
incorporated by reference in §260.11 of this chapter.
(2) It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of
55 °C (130 °F) as determined by Method 1110A in “Test Methods for Evaluating Solid Waste, Physical/Chemical
Methods,” EPA Publication SW-846, and as incorporated by reference in §260.11 of this chapter.
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FORM: APSRSR 04-10 Page 4 of 4
A solid waste is classified as aqueous if the moisture content is ≥ 20% moisture (see SW-846 Method 9040 C). RCRA
only addresses aqueous solid wastes under characteristics of corrosivity. This does not apply to facilities with total solids
>80%. Can this be clarified within their renewed permit (i.e. should they be required to report a corrosivity since 261.22
of RCRA does not yet apply to solids)?
Reactivity: Per EPA FAQ regarding Hazardous Waste Characteristics there are no specific methods currently available
for reactive cyanide and reactive sulfide for reactivity characteristic determination. Such guidance and methods used to
exist, including regulatory thresholds, but the methods were removed from SW-846 in 1998 due to a variety of issues
(e.g., the tests worked well with pure compounds, but failed with waste mixtures such that results were very unreliable).
Additionally, the FAQ indicates the following is an acceptable method for determining reactivity: a descriptive definition
of reactivity for cyanide and sulfide wastes and depends on the generator's knowledge of their waste stream to classify it
as a D003 waste, without the benefit of a characteristic test. Can this be clarified within their renewed permit (i.e. a
narrative description of the wastes reactivity characteristics is acceptable)?

DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C
DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C

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

April 25, 2018

Michael Lee Mehaffey
Town of Maggie Valley
3987 Soco Rd
Maggie Valley, NC 28751

SUBJECT: Compliance Inspection Report
Annual Report (2017) Review Inspection
Maggie Valley WWTP
Non-discharge Permit No. WQ0010615
Haywood County

Dear Mr. Mehaffey:

The North Carolina Division of Water Resources conducted a review of the Maggie Valley
WWTP’s 2017 Annual Report on 3/28/2018. This inspection was conducted to verify that the
facility is operating in compliance with the conditions and limitations specified in Non-discharge
Permit No. WQ0010615. The findings and comments noted during this inspection are provided
in the enclosed copy of the inspection report entitled "Compliance Inspection Report".

There were no significant issues or findings noted during the inspection and therefore, a
response to this inspection report is not required.

If you should have any questions, please do not hesitate to contact me at 828-296-4500 or
via email at [e-mail].

Sincerely,

Beverly Price, Environmental Senior Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ

ATTACHMENT: Inspection Report

Ec: WQS ARO Server
LF
20180425_WQ0010615_CEIARR.rtf
DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C
Compliance Inspection Report
Permit:WQ0010615 Effective:08/01/14 Expiration:07/31/19 Owner :Town of Maggie Valley
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Haywood
Asheville
Michael Lee Mehaffey
Effective:Expiration:Facility:Maggie Valley WWTP
U S Hwy 276 N
Maggie Valley NC 28751
Title:Phone:[phone]WWTP ORC
Secondary ORC(s):
Phone:Certification:Primary ORC:
System Classifications:
24 hour contact name Michael Lee Mehaffey 828-400-9494
On-site representative Michael Lee Mehaffey 828-400-9494
On-Site Representative(s):
Related Permits:
NC0056561 Town of Maggie Valley - Maggie Valley WWTP
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
03/28/2018 04:00PM 05:00PM
Beverly Price 828-296-4500
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Distribution of Residual Solids (503)
Annual Report Review
Question Areas:
Miscellaneous Questions Record Keeping Treatment
Pathogen and Vector Attraction
(See attachment summary)
Page:1
DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010615
03/28/2018 Annual Report Review
Town of Maggie Valley
Routine
Inspection Summary:
The inspection consisted of a review of the 2017 Annual Report. The inspection was conducted by Beverly Price of the
Asheville Regional Office.
138 dry tons of residuals were distributed to the public in 2017. 46 dry tons were landfilled in the Santek Environmental
Landfill in Haywood County in 2017. The permit distribution limit is 300 dry tons per year.
Monitoring frequencies for Metals/Nutrients/Pathogen & Vector Attraction Reduction (VAR) are based on the actual dry tons
distributed per year. Based on the 2017 tonnage, annual monitoring was required. TCLP monitoring is required annually.
The metals data appeared to be compliant with Ceiling and Monthly Average Concentrations. TCLP data appeared to be
compliant with permit limits. All required parameters were analyzed. Pathogen reduction is verified using Fecal Coliform
Density and Alternative B – Alkaline Treatment. Vector Attraction Reduction (VAR) is met when Alternative B is met as the
pH requirement for Alternative B exceeds the pH requirement of Option 6 for VAR.
The pH time frame requirement for Alternative B is 72 consecutive hours.
The Pathogen and Vector Attraction Reduction Form (PVRF 02T Rules) should be used for the Annual Report. A copy will
be emailed to the permittee.
Page:2
DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010615
03/28/2018 Annual Report Review
Town of Maggie Valley
Routine
Type Yes No NA NE
Land Application
Distribution and Marketing
Record Keeping Yes No NA NE
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on-site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
No seasonal restriction window.Comment:
Pathogen and Vector Attraction Yes No NA NE
a. Fecal coliform SM 9221 E (Class A or B)
Class A, all test must be <1000 MPN/dry gram
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
Fecal coliform SM 9222 D (Class B only)
Geometric mean of 7 samples per monitoring period for class B<2.0*10E6 CFU/dry gram
b. pH records for alkaline stabilization (Class A)
c. pH records for alkaline stabilization (Class B)
Temperature corrected
d. Salmonella (Class A, all test must be < 3MPN/4 gram day)
Page:3
DocuSign Envelope ID: 239CA5C1-334B-4E64-AE34-FBD0A9FC8A8C
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0010615
03/28/2018 Annual Report Review
Town of Maggie Valley
Routine
e. Time/Temp on:
Digester (MCRT)
Compost
Class A lime stabilization
f. Volatile Solids Calculations
g. Bench-top Aerobic/Anaerobic digestion results
Comment:
Treatment Yes No NA NE
Check all that apply
Aerobic Digestion
Anaerobic Digestion
Alkaline Pasteurization (Class A)
Alkaline Stabilization (Class B)
Compost
Drying Beds
Other
Alkaline Stabilization for Class A.Comment:
Page:4
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Certificate Of Completion
Envelope Id: 239CA5C1334B4E64AE34FBD0A9FC8A8C Status: Completed
Subject: Please DocuSign: 20190403_WQ0010615_STFRPT.docx, WQROSNDARR20190311.pdf, 20180425_WQ0010615_CEI...
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217 W. Jones Street
Raleigh, NC 27699
[e-mail]
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North Carolina Department of Environmental Quality
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