WQ0013808_Follow Up_20210804

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
August 4, 2021
William Kotis
Kotis Properties, Inc.
P.O. Box 9296
Greensboro, North Carolina 27429
SUBJECT: Follow Up Inspection to NOV-2021-PC-0325
Summerfield Shopping Center
Wastewater Surface Irrigation
Permit No. WQ0013808
Guilford County
Dear Mr. Kotis:
On July 27, 2021 Division of Water Resources staff persons Caitlin Caudle and Patrick
Mitchell completed a scheduled follow up inspection to review repairs to non-compliance
items identified during the June 15, 2021 compliance inspection discussed in previous
correspondence dated June 22, 2021. Chad Leinbach, ORC, of Connor Consulting, LLC,
Alan Willard of Kotis Properties, and another representative of Kotis Properties were
present during the entire inspection. The majority of violations, deficiencies, and concerns
were addressed by the follow up inspection. The following further actions are required in
order to resolve all non-compliance items listed in NOV-2021-PC-0325:
Item 2: An engineer certification of all staff gauges must be submitted within thirty (30)
days of receipt of this letter.
Item 3: Please remove or take off-line, temporarily, the drip lines directly below the terrace
on the western side of Field 2 as discussed in the follow up inspection. This area may be
returned to use after it has dried with close monitoring to ensure that ponding and runoff
do not continue.
Item I: Once all alarms are operational, please notify Ms. Caudle and provide
documentation that all alarms are working, such as a video.
NORTH
D E
D.o.rtm.m of ln.im.mo.tol au.i`
North Carolina Department of Environmental Quality Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

An updated Non Discharge Application Report is enclosed that includes the wet weather
storage pond and both wetland cells. Please refer to the enclosed inspection report for
additional observations and comments. If you have any questions please contact Caitlin
Caudle at 336-776-9699 or caitlin.caudIQncdenr.gov.
Sincerely,
1 DocuSiiggned by: <
o l U. JM.IAhr
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
enc: Inspection Report
Non Discharge Application Report
cc: Guilford County Environmental Health([e-mail])
Chad Leinbach, ORC ([e-mail])
WSRO Electronic Files
DWR Laserfiche File WQ0013808
LD_E
NORTH CAROLINA
gapartmeM of Environmental quaky
North Carolina Department of Environmental Quality j Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0013808 Effective: 08/29/18 Expiration: 07/31/23 Owner : Kotis Properties Inc
SOC: Effective: Expiration: Facility: Summerfield Shopping Center WWTF
County: Guilford 4548 US 220 N
Region: Winston-Salem
Summerfield NC 27358
Contact Person: Allen Willard Title: Phone:
Directions to Facility:
take 1-40 east to Hwy 150 in kernesville, turn left at top of ramp. turn right on Hwy 220 then take first left gravel driveway behind the
shopping center
System Classifications: SI, WW1,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 07/27/2021
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Entry Time 10:01AM Exit Time: 12:02PM
Patrick Mitchell
Reason for Inspection: Follow-up
Permit Inspection Type: Wastewater Irrigation
Facility Status: E Compliant Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Phone: [phone]
Inspection Type: Compliance Evaluation
Page 1 of 5

Permit: WQ0013808 Owner - Facility: Kotis Properties Inc
Inspection Date: 07/27/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Follow-up
Inspection Summary:
On July 27, 2021 Division of Water Resources staff persons Caitlin Caudle and Patrick Mitchell completed a scheduled
follow up inspection to review repairs to non-compliance items identified during the June 15, 2021 compliance inspection.
Chad Leinbach, ORC, of Connor Consulting, LLC, Alan Willard of Kotis Properties, and another representative of Kotis
Properties were present during the entire inspection. Non-compliance items will be addressed as they are listed in Notice of
Violation/Notice of Intent to Enforce NOV-2021-PC-0325 dated June 22, 2021. This follow up inspection was scheduled after
Mr. Leinbach provided a response to NOV-2021-PC-0325.
Violations:
Item 1: Continued bypass of untreated effluent from the sand filter into the wet weather storage pond.
Response: The piping in the manifold box was exposed and inspected for leaks, and dose times have been increased. No
effluent has bypassed the sand filter since the compliance inspection.
Observations: The sand filter was dosed and there was no evidence that effluent was bypassing the sand filter or filling the
manifold box. The manifold box was damp but there was no evidence of ponding water. The lagoon liner was dry and the
ground immediately downslope of the manifold box was not saturated as it had been in the past. Photos are in the event
folder. Mr. Willard stated that the sand filter is being dosed more frequently at lower volumes for a shorter period of time. Mr.
Willard stated that the sand filter bypasses to the wet weather storage pond when >1" rainfall events occur. No water was
standing in the valve boxes on the surface of the sand filter.
Item 2: Staff gauges in wet weather storage pond and the wetland cells were not installed.
Response: Staff gauges are now in each wetland cell and the wet weather storage pond.
Observations: Staff gauges for the wetland cells were initially installed on the back side of concrete structures present in
both wetland cells. The markings the staff gauges were not clearly visible as they were initially installed and Ms. Caudle
stated that staff gauges must be clearly visible and marked. Ms. Caudle requested that the staff gauges be moved where
they were clearly visible and someone not familiar with the system would be able to read them. The staff gauges were
reinstalled on the side of the concrete structures during the site visit. In the new location the staff gauges were clearly visible
and could easily be read. Mr. Leinbach stated that the wetland cells were originally designed to have one foot of freeboard,
not two. Mr. Mitchell recommended that Mr. Leinbach submit a request for a minor permit modification as the current permit
states the wetland cells shall not have less than two feet of freeboard. Mr. Leinbach has a history of "stacking" water in the
wetland cells during wet weather conditions to prevent effluent from entering the wet weather storage pond. This is an
improper use of the wetland cells, and extended periods of elevated effluent levels can impact the proper function of the
wetland cells. Photos are in the event folder.
The staff gauge for the wet weather storage pond was installed on the edge of the embankment and is laying on the liner.
Mr. Leinbach stated that a laser level was used to determine the lowest elevation in the storage pond embankment. Mr.
Leinbach stated that he used the appropriate measurements and calculations to mark the staff gauge as required by the
permit.
Further Actions: Ms. Caudle requested that an engineer certify all freeboard markers.
Item 3: Ponding in Field 2.
Response: Numerous repairs have been made on Zone 1, 2, and 3 to prevent ponding. No ponding was present in Zones 1
and 2 on 7/13/2021.
Observations: Ponding was clearly visible in Field 2, which Mr. Willard stated was from repairing large leaks in that area. Mr.
Leinbach and Mr. Willard stated that numerous repairs to the drip lines have been completed today and the previous week.
They stated that major leaks appear almost every day due to squirrels damaging the drip lines. The old control panel did not
Page 2 of 5

Permit: WQ0013808 Owner - Facility: Kotis Properties Inc
Inspection Date: 07/27/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Follow-up
provide high flow notifications, but the new control panel should notify them both when high flows occur during irrigation and
shut the system off. At the time of the follow up there was a large area behind a terrace in Field 2 that had a large amount of
standing water. This area is downslope of most of the drip zone, and the drip lines here are some of the lowest in the drip
zone. As a result the drip lines are draining to this area and it may be dosed at a higher rate than other areas, and any runoff
from upslope is ponding in this area. There was also evidence that effluent from that area had flowed downslope and may
have left the drip zone. There was evidence that the drip zones had been repaired that day.
Further Actions: Ms. Caudle requested that the drip lines in the area behind the terrace be removed or taken off line
temporarily to allow the area to dry. This area may be returned to use after the area has dried with close monitoring to
ensure that ponding and runoff do not continue. Field 2 may need to have seasonal acreages determined during the next
permit renewal if there is evidence that it cannot assimilate effluent during the wetter months.
Item 4: Large leak in Field 1 directly above a manifold box. Evidence that the effluent was flowing underground, entering the
manifold box, and running off to a stormwater outfall downslope. Another manifold box was full of effluent. A supply line pipe
was exposed. Multiple large leaks were present in Field 1 and 2, and Field 3 was unusable.
Response: Numerous repairs have been made on Zones 1, 2, and 3 to prevent ponding. No ponding was present in Zones 1
and 2 on 7/13/2021. We have determined that there are no major leaks in Zone 1 near the stormwater pond. The erosion
noted in the ditch between Zones 1 and the stormwater pond was caused by heavy rain. We are installing soil and rock to
stabilize the erosion.
Observations: There were no large leaks located in Field 1. The manifold box that had water running through it during the
previous inspection did not have water running through it while the system was on. Some water was present in the manifold
box. Mr. Willard attributed this to large leaks that were fixed directly above slope of the manifold box that morning. The ditch
with the exposed supply line pipe was filled in, and Mr. Willard and Mr. Leinbach stated they will install logs, rocks, or some
erosion control measure to prevent the new soil from eroding. The manifold box next to the pumphouse was dry and a lid
was placed on it. There were no large leaks located in Field 2, but several small leaks were located. These leaks were
repaired while on site. Small leaks in drip lines can introduce a concentrated flow into the drip zones, and if the zones are
dosed enough these small leaks can cause ponding and runoff. Field 3 had been cleared of all brush and other debris, and
the necessary repairs made.
Deficiencies:
Item A: Spill plan was not on site.
Response: The spill plan is posted on site in my field office.
Observations: The spill plan is posted on the interior of the office door on the inside of the pumphouse.
Item B: The pipe connecting the wet weather storage pond and the wet well is blocked.
Response: more water from the wet weather storage pond must be removed, projected to be done in August.
Observation: Mr. Leinbach stated that the pipe was blown out that morning. Mr. Leinbach stated that a large amount of
debris had covered the gravel that protects the end of the pipe. The wet well is recharging normally now.
Item C: Two trees are growing on the interior embankment of the second wetland cell.
Response: The trees will be removed in the fall so that they may be transferred to Zone 1 for planting.
Observations: The trees were still present. Ms. Caudle asked that the trees be removed immediately to prevent any further
damage to the integrity of the clay pack liner of the wetland cell. The trees could not be removed as removal would further
damage the clay pack liner. Mr. Willard removed the trees while on site and stated he would take measures to ensure that
Page 3 of 5

Permit: WQ0013808 Owner - Facility: Kotis Properties Inc
Inspection Date: 07/27/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Follow-up
the trees would not regrow.
Item D: The most recent permit was not on site.
Response: Permit is now on site.
Observations: The most recent copy of the permit was on site in the field office in the pumphouse.
Concerns:
Item I: The audible and visual alarm for the wet well beside the wet weather storage pond was not working properly, and the
audible and visual alarm on the front of the pump house was not working.
Response: A buzzer and light bulbs are on order.
Observations: The alarms were still not working properly. The pumphouse high water alarm is not wired correctly to be
triggered by the new control panel. Parts have not arrived to repair the wet weather storage pond wet well alarm.
Further Actions: Once the alarms are operational, please notify Ms. Caudle so a follow up visit may be scheduled or send a
video of the alarms in operation.
Item II: Weeds and other vegetation were growing on the sand filter.
Response: Weeds have been removed.
Observations: There were no weeds present in the sand filter.
Item III: A small leak was visible at a coupling on the irrigation pumps.
Response: Leaks in piping are being repaired.
Observations: There was no visible leak at the irrigation pump.
Other Observations:
• The pipe on the back of the chlorine contact chamber is a vent that exits on the exterior of the building.
• The only way for effluent to enter the wet weather storage pond is from the pumps in the pumphouse. There is no gravity
flow or any other flow.
• The sand filter was reviewed in operation and there was no evidence of ponding or runoff. There was a large biofilm that
was present in one pipe that was reviewed. Mr. Willard removed the cap of a single pipe and a large amount of black debris
was flushed from the pipe. Mr. Willard stated that the pipes are flushed 3-4 times per year.
• A new control panel has been installed and will notify Mr. Leinbach and Mr. Willard of any issues.
• The high water alarm float in the wet well beside the wet weather storage pond was in the wrong location on the float
tree. The alarm was trigged while there was still approximately half a foot of freeboard in the wet weather storage pond. Mr.
Willard and Mr. Leinbach attempted to place the float in the correct location but were not able to accomplish that while DWR
staff were on site. Ms. Caudle recommended that the consult the engineer to determine the correct elevation to install the
float and at what angle the float is activated. This may need to be reviewed at the next compliance inspection.
• The final designs not released for construction available to the Division show that effluent from the wet weather storage
pond is chlorinated before entering the irrigation wet well. This is not how the system was built. Effluent currently goes
directly into the irrigation wet well.
Page 4 of 5

Permit: WQ0013808 Owner - Facility: Kotis Properties Inc
Inspection Date: 07/27/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Follow-up
Page 5 of 5

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d Blockage bet,, �en the wet well and thg. wet weather storage? .B\euo i15- 0,24 VSAnO011'1
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Audible and visual al�rms orking on top of pump house and at wet well?
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ENVIRONMENTAL - WATER SUPPLY - WASTEWATER - GEOTHERMAL
CONNER CONSULTING, LLC
1284 WINDY RIDGE ROAD, CHAPEL HILL, NORTH CAROLINA 27517
PHONE: [phone]
July 15, 2021
Ms. Jennifer Grayak
NC DEQ, Division of Water Resources
Winston-Salem Regional Office
450 West Hanes Mill Road, Suite 300
Winston-Salem, North Carolina 27105-7407
Re: Notice of Violation (NOV-2021-PC-0325)
Summerfield Renaissance Center Wastewater Disposal System
Summerfield, Guilford County
Permit # WQ0013808
Dear Ms. Grayak:
On behalf of Kotis Properties, the following responses are warranted for the continued operation
of the wastewater disposal system at Summerfield Renaissance Shopping Center which was
deficient on a few items.
4123 .01100 (ad Said a ju —ed valv-ea c106;v S1nora-e-v-l;wwe3 vr»re frequen+(y
1. Manifold box at RSF (recirculating sand filter) - The piping inside the manifold box was
exposed and inspected for leaks — no leaks were found. Since the inspection we have
increased the dose time which appears to have solved the problem. No wastewater has
bypassed the RSF since the inspection.
2. Staff gauges are now in each wetland cell and the WWS (wet weather storage) pond.
Maw were Ntie3-e `ir 4 ailed?Wino e14 i}?
3 and 4. Numerous repairs have been made on Zones 1, 2 and 3 to prevent ponding. Squirrels
are responsible for the leaks and are being relocated. Traps remain in place to convince them to
move. We are checking the zones weekly to make sure major leaks are not continuing to persist.
Minor leaks are not causing ponding or runoff, I will be glad to demonstrate on your next visit.
Bythe way the new control panel will shut down irrigation when large variations in flow are
calculated.
No ponding was present in Zones 1 and 2 on 7/13/21. Zone 3 is off and been off due to trees
falling and disrupting the drip lines. The trees in zone 3 should be removed by next week. The
areas in field 1 near the junction boxes were a result of squirrel damage. We have determined

- 2 •
N6w7 L ()V\ c\kovtk m.tivlain `faicl bb/ nest
that there are no major leaks in zone 1 near the stormwater pond. The erosion noted in the ditch `f .{ Ae,
between zone 1 and the stormwater pond was caused by heavy rain. We are installing soil and p061).3c
rock to stabilize the erosion. We will have that completed by September. Ms. Caudle was
notified by phone about repairs and observations about leaks in the junction boxes made by me
the week following the inspection and about the status of the 2-inch manifold supply line.
The trees in zone 3 are scheduled for removal. We do not need to use this field until they are
removed. We are still experiencing trouble with the squirrels. Any suggestions? We are not
alone, what are other systems doing?
Deficiencies noted.
a. The Spill Plan is posted on site in my field office.
b. We must remove more water from the WWS pond to fix the lag in water filling the
WWS wet well. I anticipate August as our target to resolve the lag. This by the way is
not affecting operation of the system. 11V`e_ e\ `° 5ut re
c. The trees will be removed in the fall so that we may transfer them to Zone 1 for
planting. N! (low .
d. Permit is on site now.
Additional concern:
I. A buzzer and light bulbs are on order from American Manufacturing.
II. Weeds — they will be removed and are not welcome to grow back.
III. Leaks in piping are being repaired especially important as the equipment referenced is a
major part of our irrigation process.
New control panel update! As of today we have installed the new control panel on the irrigation
system. However, we have a few problems to iron out with American Manufacturing, I will be in
touch to extend you an invite for reinspection when we get these minor details fixed. Please call
with questions and comments.
Sincerely yours,
Chad Leinbach, ORC
Cc: Allen Willard, Kotis Properties
Brian Gaster, Kotis Properties

Date Facility Description
2/1/2021
WQ0013808
Chad called about an email that
I sent to clarify about weather
codes and rainfall, said the
rainfall reported is a total for
the week, weather codes are
coming from a Weather
Underground station close to
the facility, asked that he send
me Novembers reports, sent
him the link to submit reports
electronically, Chad called again
about the online submission, I
had since reviewed November
and December monitoring
reports, out of compliance with
freeboard, reminded him that
he needs to notify the office
and can call me directly
2/1/2021
WQ0013808
Chad called about an email that
I sent to clarify about weather
codes and rainfall, said the
rainfall reported is a total for
the week, weather codes are
coming from a Weather
Underground station close to
the facility, asked that he send
me Novembers reports, sent
him the link to submit reports
electronically, Chad called again
about the online submission, I
had since reviewed November
and December monitoring
reports, out of compliance with
freeboard, reminded him that
he needs to notify the office
and can call me directly
3/30/2021
WQ0013808
Chad called to let me know they
are updating the system, just
updating the software, said they
want to remove the sludge from
the ponds, I told him they could
use a contract hauler and they
would handle the solids, also
recommended EMA resources.
6/11/2021
WQ0013808
Chad called about scheduling a
compliance inspection

6/23/2021
WQ0013808
Chad called to say that the
permit is on site, spill plan is on
site, there is no more leak
around the junction box in field
one, all the water is caused by
the hole in the line from the
squirrels, the manifold box at
the sand filter is dried up
because they adjusted the
valves and changed the dosing
of the sand filter (smaller doses
more frequently)
7/14/2021
WQ0013808
Chad called to say that the
freeboard markers are going in
soon and the high water alarms
are getting replaced, the trees
down in zone 3 will be removed
soon, and the control panel will
be replaced soon. He plans on
responding to the NOV NOI
today.

FORM: NDAR-1 10-13
NON -DISCHARGE APPLICATION REPORT (NDAR-1)
Page of
Permit No.: WQ0013808
Did irrigation occur at
this facility?
❑YES NO
Facility Name: Summerfield Shopping Center WWTF I County: Guilford
Field Name:
1
Area (acres):
0.71
Cover Crop:
Hourly Rate (in):
0.3
Annual Rate (in):
34.75
co
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Weather
Freeboard
Field Irrigated?
OYES ONO
11 � •�
I[�u1'!I
of
in
a)
as
O
cn
ft
Ili
ft
1� - I�
ft
W 13
E a'
= a
> • <
gal
E H •r
.i
min
c
'�
0 o
J
in
E
§ L
E 5 ii
as
as = J
in
Field Name:
Area (acres):
Cover Crop:
Hourly Rate (in):
Annual Rate (in):
Field Irrigated?
E a'
= a
>° a
gal
13
E c
H
.i
min
2
0.52
0.3
34.75
❑YES NO
>, c
co (izs
0J
in
in
Field Name:
Area (acres):
Cover Crop:
Hourly Rate (in):
Annual Rate (in):
Field Irrigated?
E a'
= a
>a
gal
E c
H
.i
min
3
Month: I Year:
Field Name:
0.17
Area (acres):
Cover Crop:
0.3
Hourly Rate (in):
34.75
Annual Rate (in):
OYES ONO
Field Irrigated?
❑YES ❑� NO
c
'�
0 o
J
in
E
§ i c
E 5 ii
ca
as = J
in
E a'
= a
>a
gal
13
E c
H
.i
min
c
�
co (izs
0J
in
in
Monthly Loading:
12 Month Floating Total (in): 7#####d4
A r
A r
/, r
// A A

FORM: NDAR-1 10-13 NON -DISCHARGE APPLICATION REPORT (NDAR-1) Page of
Did the application rates exceed the limits in Attachment B of your permit?
Were adequate measures taken to prevent effluent ponding in or runoff from the sites?
Was a suitable vegetative cover maintained on all sites as specified in your permit?
Were all setbacks listed in your permit maintained for every application to each permitted site?
Were all freeboards maintained in accordance with the specified freeboard heights in your permit?
❑ Compliant ❑Non -Compliant
❑ Compliant ❑Non -Compliant
❑ Compliant ❑Non -Compliant
❑ Compliant ❑Non -Compliant
❑ Compliant ❑Non -Compliant
If the facility is non -compliant, please explain in the space below the reason(s) the facility was not in compliance. Provide in your explanation the date(s) of the non-compliance and describe the corrective
action(s) taken. Attach additional sheets if necessary.
Operator in Responsible Charge (ORC) Certification
Permittee Certification
ORC:
Certification No.:
Grade: Phone Number:
Has the ORC changed since the previous NDAR-1? ❑Yes ❑No
Permittee:
Signing Official:
Signing Official's Title:
Phone Number: Permit Exp.:
Signature
By this signature, I certify that this report is accurrate and complete to the best of my knowledge.
Date
Signature Date
I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that all qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations.
Mail Original and Two Copies to:
Division of Water Resources
Information Processing Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Formulas
Daily Loading (uiches) =
Volttme Appiied (gallons)
Area (acres) x 27,152 ( gallons
acre • inch
If Time Irrigated is < 60 minutes:
Maximum hour 1. Loading (inches) = Daily Loading (inches)
If Time Irrigated is > 60 minutes:
DaivLoc2thng (znches) tes)
;blaximunt Hourly LOaWfl9 (inches) = x 60
Time Irrigated (minutes) 4., hour
fonth1 Loading (inches) = Sum of Daily Loading (nc)es)
12 Month F!oatzng Total (inches) = Sum of this month's Itfonthly Loading (inches) and previous 11 monthts Monthly Loading (inches)
Weather Codes
Clear
C
Cloudy
CL
Partly Cloudy
PC
Rain
R
Sleet
SL
Snow
SN