WQ0019908_NOD-2019-PC-0207_20190926

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ROY COOPER
Governor
MICHAEL S. REGAN
Secretary - 4•M'�
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
September 26,2019
Chris McDonald
General Manager
Johnston County Golf and Country Club
694 Country Club Road
Smithfield,NC 27577
Subject: NOTICE OF DEFICIENCY
NOD-2019-PC-0207
Compliance Evaluation Inspection
Johnston County Golf and Country Club
Conjunctive Reclaimed Water Utilization System
Permit Number W00019908
Johnston County
Mr.McDonald,
On September 26,2019, Rick Trone of the Raleigh Regional Office of the Division of Water Resources
conducted a compliance evaluation inspection of the Conjunctive reclaimed water irrigation system at
Johnston County Golf and Country Club. The purpose of this inspection was to ensure compliance with
the subject permit. During the inspection,the cooperation and assistance of Mr. Stephen Andrews was
helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit;
• Review of the owner/facility information;
• Review of ORC logbooks,Non-discharge wastewater monitoring reports(NDMR)and;
• On-site inspection of treatment components and spray fields
The current permit was issued October 12,2015 and expires on November 30,2020.
Reclaimed water used for irrigation on the golf course and some nearby homes is generated at the Central
Johnston County Wastewater Treatment Plant under permit NC0030716. Reclaimed water enters the golf
course at a metered location where staff tracks the amount of water utilized. Reclaimed water is also
utilized to wash equipment at one location. Appropriate signage was observed at the start of the course
and a sign is in place at the wash location behind the maintenance shop.
Q North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh.North Carolina 27609
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r+� 919.791.4200

The irrigation system is broken up into dozens of zones which can be individually controlled via radio or
computer.During the inspection Mr. Stephens activated a few zones via radio. Spray patterns appeared
acceptable,though one spray head observed in operation needs maintenance to restore a good spray
pattern. The course turf appeared to be in good condition.
Two locations on the course experience ponding during irrigation events one of which was observed
during the inspection.The areas of ponding are low areas where the paved golf cart path meets the turf.
Mr. Stephens indicated the spray heads in these areas could be redirected or turned off.
NDMR records for 2018-2019 were reviewed.The current permit does not require effluent monitoring.
The only required monitoring is for reclaimed water distributed and is to be reported on form NDMR.The
facility cannot track the amount of flow to each zone. Mr. Stephens indicated the course is irrigated daily.
NDMR's for some months in 2019 indicate zero water irrigated which according to Mr. Stephens is not
accurate. During those months,the reclaimed water meter was not producing a readout of the total water
used,however,the facility irrigated as usual. In instances like that,Mr. Stephens should explain on form
NDMR why the amount of reclaimed water utilized cannot be reported since reporting zero is not
accurate.
Lastly, the facility does not currently have an Operation and Maintenance Plan as required by the permit.
The facility does have a map of the irrigation system posted on the wall of the maintenance shop.
The following permit condition deficiencies were noted during the September 26,2019 compliance
inspection and records review:
III. Operation and Maintenance Requirements
Condition 2,which states that,"The Permittee shall maintain an Operation and Maintenance Plan,which
at a minimum shall include the following:
a. Description of the System...
b. A map of all distribution lines...
c. Description of anticipated maintenance activities;
d. Include provisions for safety measures...
e. Spill control provisions including response to upsets and bypasses including control, containment,
remediation, and contact information for plant personnel, emergency responders, and regulatory
agencies.
The facility needs to create an Operation and Maintenance Plan meeting the permit requirements
and submit a copy of the Plan to this office in their response to this inspection letter.
Condition 5,which states that, "Adequate measures shall be taken to prevent reclaimed water ponding in
or runoff from the irrigation sites.Explain how the facility will prevent reclaimed water from ponding
at the two locations noted above.
To prevent further action,please respond in writing to this office within 30 days upon your receipt
of this Notice of Deficiency regarding your plans or measures to be taken to address the indicated
deficiencies and other identified issues,if applicable. Please include in your response all corrective
actions already taken and a schedule for completion of any corrective actions not addressed.

If you have any questions about this inspection or this letter,please contact Rick Trone at
rick.tronef&,ncdenr.gov or 919-791-4200.
Sincerely,
1�
Rick Bolich, L.G.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files