NC0021369_Staff Report_20190405

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State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ® NPDES Unit ❑ Non -Discharge Unit Application No.: NCO021369
Attn: Sydney Carpenter Facility name: Columbus WWTP
From: Mikal Willmer
Asheville Regional Office
Note: This form has been adapted from the non -discharge fg acili , 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: 03/25/2019
b. Site visit conducted by: Mikal Willmer
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: Chris Cochran and their contact information: (828) 827 - 9204 ext.
e. Driving directions: Head west on I-40 from the ARO. Take exit 46A for I-26 East towards
Hendersonville/Spartanburg for approximately 35 miles. Keep right at the fork and follow signs for 74-E
towards Rutherfordton. Take exit 163 108-w towards Columbus and continue straight through the intersection
onto Fox Mountain Rd. Take a right onto Woodland Rd and a left onto Levi Rd. The WWTP is on your left.
2. Discharge Point(s):
Latitude: 35.253939
Latitude:
Longitude:-82.165907
Longitude:
3. Receiving stream or affected surface waters: UT to White Oak Creek? Our regional map lists this as White Oak
Creek; however, USGS blue line map does not. May need further clarification.
Classification: C
River Basin and Subbasin No. Broad, 03050105
Describe receiving stream features and pertinent downstream uses: This section of white oak creek is
protected for secondary recreation. White Oak Creek flows into the lower section of the Green River,
Classified WS-IV.
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:
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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: Chris Cochran Certificate #:1005199 Backup ORC: Ric , Mc ug inn Certificate #:1006296
Facility was recently updated with the appropriate classification (WW-III). Ricky McGuinn has passed his Grade
II; however, is listed as an OIT potentially due to needing additional operational experience. Waiting for
clarification from Operator Certification to determine if an interim Back-up is required.
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: When the Aeration Basin was divided when flows were reduced, the ability to remove
solids was also removed and/or no lonjZer accessible from the basins active side. Solids have continued to build
within the basin and need to be removed to allow the facility to operate as designed. Additional solids storage
capacity may also be warranted.
Description of existing facilities: Mechanical screw auger, vortex grit removal, aeration basin, dual circular
clarifiers, aerobic digester/sludge holding tank, chlorine contact chamber with ,gas chlorine and liquid calcium
thiosulfate (dechlor) and ultrasonic flow meter.
Proposed flow:
Current permitted flow: 0.8 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.) Excessive solids in basin and throughout facility, potentially hydraulically short circuiting in the aeration
basin. See inspection report for further details. Curtain wall dividing the current aeration basin is structurally
compromised and needs to be assessed immediately.
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: Facility solids are land applied under Syna,gro's Class B permit (W00016247)
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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: Facility description should be updated to reflect the correct treatment components since the
last upgrade.
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
O / //
O I II
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: Three upsets were reported to the ARO last ,year
during hey rains. This may be due to the excessive number of solids currently in the facility. Does not appear to
be related to size of chlorine contact chamber and ability to clean this out. Excessive solids may also be
contributing to spikes in fecal on occasion. Additional organic matter suspended in the effluent could be reducing
the effectiveness of the chlorine treatment during heavy flows.
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: The facility needs to assess the current hydraulic capabilities within the Aeration Basin,
determine a means of solids removal from the Aeration Basin and determine if, during normal operational
conditions, there is adequate solids storage capacity within the current digester to allow for routine wasting to
maintain a healthy sludge age.
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? As mentioned above, three upsets were reported
and sent notices of violation. The most recent compliance evaluation inspection was also non -compliant due to the
excessive number of solids being stored in the facility with no easy means of removal.
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: No issues before issuance, however, a plan for addressing items listed within the inspection
report should be added. Potentially a special condition to ensure the facility can maintain compliance.
16. Possible toxic impacts to surface waters: unknown, chlorine is reduced below permitted limit before discharge.
17. Pretreatment Program (POTWs only): Facility does not have a formal pretreatment program.
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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
Aeration basin is full of solids and does not appear to have been addressed
Solids Removal
during the upgrades to the facility (no current piping in place to waste to
digester from AB). This is having negative impacts downstream of the Aeration
Basin.
Curtain wall within the basin is holding back decades of sludge and other
Curtain Wall Assessment
unknown materials. The wall, as of the last inspection, is structurally
compromised and beginning to buckle. This has the potential to render the plant
inoperable for indeterminate amount of time should the wall fail.
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 for regional supervisor:
4/8/2019
Date:
DocuSigned by:
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DocuSign Envelope ID: 10FDCD57-51C7-4427-90C0-716FCB55AFF6
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
See the most recent inspection report dated 3/25/2019. Also, please reference the 2008 permit special condition
(aeration basin hydraulic study), I am unsure if this was ever carried out before the permit was reissued in 2013. No
written correspondence on file regionally.
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