WQ0035784_NOD-2022-PC-0204_20230706

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
July 6, 2023
Delivered electronically via email to: Christopher.garnic _mapletree.com.sg
Christopher Garnic
Wallace Loft LLC
5 Bryant Park 28th Floor
New York, NY 10018
SUBJECT: Continued Notice of Deficiency (NOD-2022-PC-0204)
Follow Up Inspection
The Cottages of Boone WWTP
Permit No. WQ0035784
Watauga County
Dear Mr. Garnic:
On June 29, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora
completed a follow up inspection. Todd Robinson, ORC, Christy Hodgen, Complex
Manager, and David Smith, Maintenance Director, were present during the entire
inspection. A review was completed of all Deficiency items noted in NOD-2022-PC-0204
dated January 9, 2023. This letter will address each item as listed in the NOD, and the
permit schedule conditions in the most recently issued permit.
Permit Condition 1.1: Within 30 days of permit issuance, the Permittee shall designate
and employ one or more certified operators as back-up operators in responsible charge
(BUORCs).
On May 24, 2023, a BUORC was designated for the WW-2 classification of the system.
The designation of ORCs and BUORCs was discussed during the inspection. Mr.
Robinson stated that another EnviroLink employee is currently working towards a SI
certification to serve as the BUORC for the facility. An employee in the complex is also
assisting with the operation of the system and working under Mr. Robinson's license. As
a reminder, a BUORC must be designated for the SI classification as well.
Item A: The knife valve was reportedly replaced. No leaks were noted.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
NoanicaaouNn
oep.m.m or em�nmen� Qualm
336.776.9800

Item B: Pump P-8001 B was repaired by replacing the seal. The seal in pump P-8001A
was replaced at the same time and is now leaking in the same manner as pump P-8001 B.
Mr. Robinson has installed measures to direct all leaking wastewater to the floor drains,
which drain to the sump tank. Mr. Robinson stated that the floors are washed down daily
before staff leave for the day. Make the necessary repairs to the pump motor.
Item C: The level transducers in the equalization basin were reportedly repaired. Mr.
Robinson stated that the level transducers have been working correctly since he began
operating the system.
Item D: The dissolved oxygen meter was reportedly repaired. Mr. Robinson stated that it
has been operating correctly since he began operating the system.
Item E: The UV bank has not been repaired or replaced. Mr. Robinson stated that the UV
bank will likely have to be replaced. Ms. Caudle reminded Mr. Robinson that if the UV
bank is replaced, it must be replaced with a comparable model. Continue to make
efforts to repair or replace the UV bank. As a reminder, the unit as described in the
permit description is a 130 gpm Severn Trent UV disinfection system.
Item F: The forcemain to Zones 1-4 was reportedly repaired and in operation when Mr.
Robinson began operating the system. Ms. Caudle reviewed the PercRite system control
panel and Z4 and Z6 had high flow failure messages, and Z1, 2, and 5 had high flow
warning messages. The total flows showed that Z4 and 6 were not being irrigated. Zones
4 and 6 must be inspected and repaired as there is likely a break in the drip lines
causing high flows. Zones 1, 2, and 5 must also be inspected and repaired as
needed.
Item G: The embankment above the storage tanks was not repaired at the time of
inspection, but Ms. Hodgens provided an invoice for a landscaper that will be completing
the work.
Item of Concern: The storage tanks appeared to be in good condition with no visible
leaks.
Item of Concern: The brush screen room was cleaned, and efforts have been made to
remove screenings on a more regular basis.
The following items were noted during this follow up inspection:
• A three sided, open atmosphere box was present over one access port of the sump
tank. A screen was present at the bottom of the box. There was not a cover over
the box, or a cap for the access point. Ms. Caudle recommended getting a cover
for the box to prevent rainwater and stormwater from entering the treatment
system.
NORTH CARCLINAD ��R
o.o+ro..m m EnNmnmenfnl n..i�
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
336.776.9800

• At the time of inspection, irrigation Pump-B was not operational. Mr. Robinson
stated that a work order has been submitted for the pump. Please repair the pump
as soon as possible.
• At the time of inspection, the cable for the freeboard marker was broken and the
visible marker was on the ground. Mr. Smith stated that staff visually observe the
freeboard in the tanks at least once a week by climbing the tanks. Please repair
the cable as soon as possible to make freeboard readings readily visible for
all staff.
Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact me or Caitlin Caudle at the letterhead address
and phone number, or by email at jenny.graznak6c�deg.nc.gov or
Caitlin.caudle(a_deg.nc.gov.
Sincerely,
Docu Signed by:
OD2D3CE3F1 B7456_.
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ — WSRO
Enc: Inspection Report
Cc: Todd Robinson, ORC (electronic copy)
Madelyn Mills, Envirol-ink (electronic copy)
Christy Hodgen, Complex Manager (electronic copy)
Watauga County Environmental Health (electronic copy)
NORTH CAROLINAD � ��
oeo+ro�.m m F,mro���w n�si�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0035784 Effective: 06/05/23 Expiration: 04/30/30 Owner: Wallace Loft LLC
SOC: Effective: Expiration: Facility: The Cottages of Boone WWTP
County: Watauga 1002 Fallview Ln
Region: Winston-Salem
Boone NC 28607
Contact Person: Ashley Vargo Title: Phone:
Directions to Facility:
Take 140 BUS W/US-158 W/US-421 N from N Lierty Street. Follow 421 N to E King Street in Boone. Take US 221 S and NC 105 S to
Boone Circle
System Classifications: SI, WW2,
Primary ORC: Todd Franklin Robinson Certification: 1006252 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
WQCSD0738 Wallace Loft LLC - Cottages of Boone WWCS
Inspection Date: 06/29/2023 Entry Time 10:19AM Exit Time: 11:45AM
Primary Inspector: Caitlin C udfle� °�llll°S 9°ed b". Phone: [phone]
Secondary Inspector(s): uwuv, l,MD&
8B834968199D49D_
Reason for Inspection: Follow-up Inspection Type: Compliance Evaluation
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Miscellaneous Questions Treatment Treatment Barscreen
End Use -Irrigation Treatment Disinfection Storage
(See attachment summary)
Page 1 of 6

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 06/29/2023 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Inspection Summary:
On June 29, 2023, Division of Water Resources staff Caitlin Caudle and Kristen Potwora completed a follow up inspection.
Todd Robinson, ORC, Christy Hodgen, Complex Manager, and David Smith, Maintenance Director, were present during the
entire inspection. A review of all Deficiency items noted in NOD-2022-PC-0204 dated January 9, 2023. This report will
address each item as listed in the NOD, and the permit schedule conditions in the most recently issued permit.
Permit Condition 1.1: Within 30 days of permit issuance, the Permittee shall designate and employ one or more certified
operators as back-up operators in responsible charge (BUORCs).
On May 24, 2023, a BUORC was designated for the WW-2 classification of the system. The designation of ORCs and
BUORCs was discussed during the inspection. Mr. Robinson stated that another Envirol-ink employee is currently working
towards a SI certification to serve as the BUORC for the facility. An employee in the complex is also assisting with the
operation of the system and working under Mr. Robinson's license. As a reminder, a BUORC must be designated for the SI
classification as well.
Item A: The knife valve was reportedly replaced. No leaks were noted.
Item B: Pump P-8001 B was repaired by replacing the seal. The seal in pump P-8001A was replaced at the same time and
is now leaking in the same manner as pump P-8001 B. Mr. Robinson has installed measures to direct all leaking wastewater
to the floor drains, which drain to the sump tank. Mr. Robinson stated that the floors are washed down daily before staff
leave for the day. Make the necessary repairs to the pump motor.
Item C: The level transducers in the equalization basin were reportedly repaired. Mr. Robinson stated that the level
transducers have been working correctly since he began operating the system.
Item D: The dissolved oxygen meter was reportedly repaired. Mr. Robinson stated that it has been operating correctly since
he began operating the system.
Item E: The UV bank has not been repaired or replaced. Mr. Robinson stated that the UV bank will likely have to be
replaced. Ms. Caudle reminded Mr. Robinson that if the UV bank is replaced, it must be replaced with a comparable model.
Continue to make efforts to repair or replace the UV bank. As a reminder, the unit as described in the permit description is a
130 gpm Severn Trent UV disinfection system.
Item F: The forcemain to Zones 1-4 was reportedly repaired and in operation when Mr. Robinson began operating the
system. Ms. Caudle reviewed the PercRite system control panel and Z4 and Z6 had high flow failure messages, and Z1, 2,
and 5 had high flow warning messages. The total flows showed that Z4 and 6 were not being irrigated. Zones 4 and 6 must
be inspected and repaired as there is likely a break in the drip lines causing high flows. Zones 1, 2, and 5 must also be
inspected and repaired as needed.
Item G: The embankment above the storage tanks was not repaired at the time of inspection, but Ms. Hodgens provided an
invoice for a landscaper that will be completing the work.
Item of Concern: The storage tanks appeared to be in good condition with no visible leaks.
Item of Concern: The brush screen room was cleaned, and efforts have been made to remove screenings on a more regular
basis.
The following items were noted during this follow up inspection:
• A three sided, open atmosphere box was present over one access port of the sump tank. A screen was present at the
bottom of the box. There was not a cover over the box, or a cap for the access point. Ms. Caudle recommended getting a
cover for the box to prevent rainwater and stormwater from entering the treatment system.
• At the time of inspection, irrigation Pump-B was not operational. Mr. Robinson stated that a work order has been
submitted for the pump. Please repair the pump as soon as possible.
• At the time of inspection, the cable for the freeboard marker was broken and the visible marker was on the ground. Mr.
Smith stated that staff visually observe the freeboard in the tanks at least once a week by climbing the tanks. Please repair
the cable as soon as possible to make freeboard readings readily visible for all staff.
Other observations:
• Operator changes have caused some information to be lost. Mr. Robinson was able to speak to the state of the system
since he was designated ORC and started operating the system.
• Mr. Robinson stated that additional membrane bioreactors have been ordered.
Page 2 of 6

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 06/29/2023 Inspection Type: Compliance Evaluation
Reason for Visit: Follow-up
Type
Yes No NA NE
Infiltration System
❑
Reuse (Quality)
❑
Lagoon Spray, LR
❑
Single Family Spray, LR
❑
Activated Sludge Spray, HR
❑
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Single Family Drip
❑
Activated Sludge Spray, LR
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ ❑ ❑
Do all treatment units appear to be operational? (if no, note below.) ❑ 0 ❑ ❑
Comment: See summary.
Treatment Barscreen
Yes No NA NE
Is it free of excessive debris?
0
❑ ❑ ❑
Is disposal of screenings in compliance?
❑ ❑ ❑
Are the bars spaced properly?
❑
❑ ❑
Is the unit in good condition?
❑ ❑ ❑
Comment:
Treatment Disinfection
Yes No NA NE
Is the system working?
0
❑ ❑ ❑
Do the fecal coliform results indicate proper disinfection?
❑ ❑ ❑
Is there adequate detention time (>=30 minutes)?
❑ ❑ ❑
Is the system properly maintained?
❑
❑ ❑
If gas, does the cylinder storage appear safe?
❑
❑ ❑
Is the fan in the chlorine feed room and storage area operable?
❑
❑ ❑
Is the chlorinator accessible?
❑
❑ ❑
If tablets, are tablets present?
❑
❑ ❑
Are the tablets the proper size and type?
❑
❑ ❑
Is contact chamber free of sludge, solids, and growth?
❑
❑ ❑
If UV, are extra UV bulbs available?
❑ ❑ ❑
If UV, is the UV intensity adequate?
❑ ❑ ❑
# Is it a dual feed system?
❑
❑ ❑
Page 3 of 6

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 06/29/2023 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? ❑ ❑ 0 ❑
If yes, then is there a Risk Management Plan on site? ❑ ❑ ❑
If yes, then what is the EPA twelve digit ID Number? (1 000-- )
If yes, then when was the RMP last updated?
Comment: See summary.
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
0
❑ ❑ ❑
Is the cover crop type specified in permit?
❑ ❑ ❑
Is the crop cover acceptable?
❑ ❑ ❑
Is the site condition adequate?
❑ ❑ ❑
Is the site free of runoff / ponding?
❑
❑ ❑
Is the acreage specified in the permit being utilized?
❑
❑ ❑
Is the application equipment present?
❑ ❑ ❑
Is the application equipment operational?
❑
❑ ❑
Is the disposal field free of limiting slopes?
❑ ❑ ❑
Is access restricted and/or signs posted during active site use?
❑ ❑ ❑
Are any supply wells within the CB?
❑
❑ ❑
Are any supply wells within 250' of the CB?
❑
❑ ❑
How close is the closest water supply well?
❑
❑ ❑
Is municipal water available in the area?
❑
❑ ❑
# Info only: Does the permit call for monitoring wells?
❑ ❑ ❑
Are GW monitoring wells located properly w/ respect to RB and CB?
❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
❑ ❑ ❑
Are monitoring wells damaged?
❑
❑ ❑
Comment: See summa
5-DAY UPSET TANK -
Storage Yes No NA NE
Storage Type?
Storage amount?
# At what point is side -stream wastewater returned to treatment?
Is there a Spill Control Plan? ❑ ❑ ❑ ❑
Aerated or Mixed?
If aeration is present, is it adequate? ❑ ❑ ❑ ❑
If present, are diffusers cleaned regularly? ❑ ❑ ❑ ❑
Is influent structure acceptable? ❑ ❑ ❑ ❑
Are banks/berms free of seepage and erosion? ❑ ❑ ❑ ❑
Page 4 of 6

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 06/29/2023 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Are banks/berms free of excessive vegetation? ❑ ❑ ❑ ❑
Is pond lined? ❑ ❑ ❑ ❑
Liner Type
Is liner acceptable? ❑ ❑ ❑ ❑
Are baffles/curtains acceptable? ❑ ❑ ❑ ❑
Does the pond have a freeboard marker? ❑ ❑ ❑ ❑
Required freeboard?
Actual freeboard?
Is there suitable grassed vegetation?
❑
❑ ❑ ❑
Is the vegetation maintained?
❑
❑ ❑ ❑
Is the area free of excessive weeds and/or woody species?
❑
❑ ❑ ❑
Is the area free from signs of overflow?
❑
❑ ❑ ❑
Is color acceptable?
❑
❑ ❑ ❑
Are floating mats acceptable?
❑
❑ ❑ ❑
No excessive buildup of solids?
❑
❑ ❑ ❑
Are aerators/mixers acceptable?
❑
❑ ❑ ❑
Is effluent structure acceptable?
❑
❑ ❑ ❑
If present, is pond cover acceptable?
❑
❑ ❑ ❑
Comment:
WET WEATHER STORAC
Storage Yes No NA NE
Storage Type?
Storage amount?
# At what point is side -stream wastewater returned to treatment?
Is there a Spill Control Plan?
❑
❑ ❑ ❑
Aerated or Mixed?
If aeration is present, is it adequate?
❑
❑ ❑ ❑
If present, are diffusers cleaned regularly?
❑
❑ ❑ ❑
Is influent structure acceptable?
❑
❑ ❑ ❑
Are banks/berms free of seepage and erosion?
❑
❑ ❑ ❑
Are banks/berms free of excessive vegetation?
❑
❑ ❑ ❑
Is pond lined?
❑
❑ ❑ ❑
Liner Type
Is liner acceptable?
❑
❑ ❑ ❑
Are baffles/curtains acceptable?
❑
❑ ❑ ❑
Page 5 of 6

Permit: WQ0035784 Owner - Facility: Wallace Loft LLC
Inspection Date: 06/29/2023 Inspection Type: Compliance Evaluation Reason for Visit: Follow-up
Does the pond have a freeboard marker?
Required freeboard?
Actual freeboard?
Is there suitable grassed vegetation?
Is the vegetation maintained?
Is the area free of excessive weeds and/or woody species?
Is the area free from signs of overflow?
Is color acceptable?
Are floating mats acceptable?
No excessive buildup of solids?
Are aerators/mixers acceptable?
Is effluent structure acceptable?
If present, is pond cover acceptable?
Comment:
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
❑ ❑ ❑ ❑
Page 6 of 6