WQ0004972_NOV and Intent to Assess_20191206

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
NORTH CAROLINA
Environmental Quality
December 6, 2019
CERTIFIED MAIL 7013 1710 0002 1922 4037
RETURN RECEIPT REQUESTED
George Gudgeon, Senior Vice President
MHT TT Inc.
2North Riverside Drive
Chicago, Illinois 60606
SUBJECT: NOTICE OF INTENT TO ENFORCE (NOV-2019-PC-0764)
Forest Lake Preserve — Wastewater Irrigation System
Permit No. WQ0004972
Davie County
Dear Mr. Gudgeon:
On November 21, 2019, staff of the North Carolina Division of Water Resources Winston Salem
Regional Office (DWR) performed a compliance evaluation inspection of the subject wastewater
treatment and surface irrigation system. This inspection was conducted by DWR staff person
Justin Henderson. Accompanying DWR for this inspection was Mr. Glenn Price, ORC of R&A
Labs, and Duncan Curll, maintenance personnel of Forest Lake Preserve. The facility was found
to be non -compliant Permit WQ0004972. The following violations require your immediate
attention and action:
1) Failure to develop and/or maintain an Operation and Maintenance Plan (O&M Plan)
for the wastewater collection facilities as required by Permit Condition II. (4.) (c.). The
collection facilities O&M Plan shall include pump station inspection frequency,
preventative maintenance schedule, spare parts inventory, and overflow response plan
in accordance with 15A NCAC 02T .0403 (3).
2) Failure to conduct and document pump station inspections per the frequencies required
by Permit Condition II. (4.) (d) & 0) and in accordance with 15A NCAC 02T .0403 (4)
& (10). The subject collection facilities include a total of seven lift stations, none of
which are connected to telemetry, therefore requiring inspection by the Permittee or its
representative every day, 365 days per year.
D North Carolina Department of Environmental Quality I Division of Water Resources
EQ�p
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NORTH CAROLINA �
o•o•°"•mme""°"^•"vin"•i� /� 336.776.9800

3) There was no evidence that a grease control program had been developed,
implemented, nor maintained as required by Permit Condition II. (4) (g.) and 15A
NCAC 02T .0403 (8) (B).
4) Failure to generate and/or maintain inspection and maintenance records for Conditions
II. (4) (a) through II. (4) (i) as required by Permit Condition II. (4) 0.).
5) Failure to properly manage the solids volume within the wastewater treatment facility.
Reportedly, 10 of the 13 diffusers located in the aeration basin were inoperable or
completely missing. Inadequate aeration will impede proper nitrification from
occurring. Also, proper sludge wasting from the aeration basin into the digestor is
currently not possible according to the ORC as a result of the inadequate aeration. The
aeration basin appeared to contain excessive solids and floating sludge "mats" were
observed during this inspection. Permit Condition III. 1. states: the facilities shall be
properly maintained and operated at all times.
6) Wastewater was observed "gushing" out of a broken standpipe when the effluent pump
was activated as part of this inspection. As a result, effluent ponding and runoff was
observed during this event as well. Permit Condition III. (1) states: the facilities shall
be properly maintained and operated at all times. Permit Condition III.4 states:
adequate measures shall be taken to prevent effluent ponding in or runoff from the
irrigation site.
7) Observations of the remaining spray heads made during this inspection while the
effluent pump was activated are, there was one spray head that appeared to be clogged,
preventing a proper spray pattern, another spray head was surrounded by overgrown
vegetative growth that was contributing to an impeded spray pattern, and one spray
head had been previous taken "off-line" due to a broken standpipe. Permit Condition
III. (1) requires the facilities to be properly maintained and operated at all time. At least
four (4) of the 18 total spray heads were in need of maintenance at the time of this
inspection.
The previous compliance inspection report dated September 24, 2018, contained the
following description: ...thick undergrowth of vegetation between spray heads and
throughout the field was not suitable for a full system inspection and may impede
proper spray dispersal as well.
8) Failure to include a Spill Response Plan and safety measures within the Operation and
Maintenance Plan for the wastewater treatment and irrigation facilities as required by
Permit Condition III. (1.)
9) Vegetative growth was observed in the scum basin located between the aeration basin
and the clarifier. The vegetative growth had persisted long enough that it had extended

above and through the catwalk that was providing access to the various treatment units
contained in the wastewater treatment facility. This scenario constitutes a violation of
Permit Condition III. (1.) for failure to conduct proper maintenance and creates a
safety/trip hazard to authorized personnel operating or inspecting the facilities.
10) Direct discharge of effluent to the ground surface and subsequent ponding outside of
the permitted irrigation area. This discharge was observed occurring at a partially
opened lateral clean -out, upon effluent pump activation. Permit Condition III. (1)
states: the facilities shall be effectively maintained operated to prevent the discharge of
any wastewater. Permit Condition III. (4) requires adequate measures be taken to
prevent effluent ponding in or runoff from the irrigation sites.
The previous compliance inspection report dated September 24, 2018, contained the
following description: DWR staff noted two lateral line clean -outs had been left open.
The clean -outs were observed directly discharging effluent wastewater onto the
ground surface away from the spray field and preventing the spray heads from fully
pressurizing, therefore improperly operating as designed....
11) Failure to properly maintain the earthen embankment associated with the effluent
storage lagoon. Permit Condition III. (14) states: Trees, shrubs, and other woody
vegetation shall not be allowed to grow on the earthen dikes or embankments. Earthen
embankment areas shall be kept mowed or otherwise controlled and accessible.
12) Failure to effluent monitoring for Total Nitrate Nitrogen as specified by Attachment A.
Permit Condition IV. (4) states: The Permittee shall monitor the effluent from the
subject facilities as the frequencies and locations for the parameters specified in
Attachment A.
The facility has incorrectly been monitoring effluent for Total Nitrite + Total Nitrate
Nitrogen as opposed to the specified Total Nitrate analysis.
13) Application rates reported on Form NDAR are being inaccurately calculated.
Application rates are being calculated based upon nine (9) acres being utilized for
irrigation, however reportedly only seven (7) acres are being utilized for irrigation.
Permit Condition IV. (5) states: The Permittee shall maintain adequate records tracking
the amount of effluent irrigated.
14) Failure to submit copies of laboratory analysis along with the Compliance Monitoring
Form GW-59 when reporting ground water monitoring results. Permit Condition IV.
(11) states: Two copies of the monitoring well sampling and analysis results shall be
submitted on a Compliance Monitoring Form GW-59, along with attached copies of

laboratory analyses, on or before the last working day of the month following the
sampling month.
15) Monitoring well #3 (MW-3) was not secured with a locking apparatus as required by
15A NCAC 02C .0108 (1).
16) Monitoring well #3 (MW-3) was not equipped with a steel outer well casing or flush
mount cover, set in concrete as required by 15A NCAC 02C .0108 (m).
In addition to the above described violations, the following items of concern also require your
attention and action:
a.) Reportedly seven (acres) are currently being utilized for irrigation, however per
Attachment B, there are nine (9) acres permitted for irrigation. It is the Division's
understanding that not all the permitted spray heads were installed. This discrepancy
led the Division to conducted square footage calculations based up the total installed
spray heads. Square footage calculations for 18 total spray heads with a 60' diameter
spray pattern suggest that the actual wettable acreage being utilized is less than two (2)
acres. Should this be confirmed, then application rates (both hourly and cumulative
annual) are being severely underreported. This would also raise concerns as if
agronomic rates are also being exceeded. Permit Condition II. (6) states: application
rates, whether hydraulic, nutrient, or other pollutant, shall not exceed those specified
in Attachment B. [15A NCAC 02T .0505 (c), 02T .0505 (n)]
Due to this discrepancy, the Division is requesting that calibration of the irrigation
equipment (required once per permit cycle per Permit Condition III. (6)) be conducted
within the next 90-days. As part of this calibration event, a "wettable acreage"
determination shall also be conducted to accurately demonstrate the acreage that is
utilized for irrigation. Field documentation of the calibration event and for the wettable
acreage determination shall be submitted to this office upon completion.
b.) There was no back-up power available, at the facility, to supply power to any of the
seven lift stations nor to the wastewater treatment facility in the event of a power
outage. Reportedly, water supply and therefore water use would not necessarily be
interrupted during a power outage. Should water use remain uninterrupted during a
power outage, the risk of sewer overflows at the lift -stations and/or the wastewater
treatment facility would greatly increase in the absence of back-up power availability.
Sewer overflows that occur due to failure to provide back-up power at necessary
locations may result in future violations and/or civil penalties to be incurred.
c.) The annual representative soils analysis (i.e. Standard Soil Fertility Analysis), required
by Permit Condition IV. (12) had not been conducted for the current year at the time of
this inspection.

d.) A small leak in the piping at the effluent irrigation pump was observed upon pump
activation. If not repaired in a timely manner, pressurization issues in the irrigation
field, pump performance issues, and/or bypass violations may be incurred. Permit
Condition III. (1) requires proper maintenance be conducted at all times and Permit
Condition III. (11) prohibits the diversion or bypassing of untreated or partially treated
wastewater.
e.) The facility only has one effluent irrigation pump that is operable. The back-up
irrigation pump is no longer operable due to failure to perform proper maintenance. A
leak noted, in the previous inspection, was not repaired and the pump subsequently
froze, and the pump housing busted, rendering the pump inoperable.
The previous compliance inspection report, dated September 24, 2018, contained the
following description: a small leak was noted on the back -side of the effluent lagoon
pump. Please repair to prevent further leaks or problems with the pump.
f.) The facility has a deemed collection system with seven grinder pump lift stations.
Review of each of the lift stations was conducted as part of this inspection. Findings of
this review are summarized here: Lift Station #2 had an unlocked access opening, and
an the visible high water alarm was inoperable; Lift Station #4 the audible high water
alarm was inoperable; Lift Station #7 the audible high water alarm was inoperable;
Several of the pump vaults/wet-wells were covered with wooden lids to prohibit
unauthorized access. Please be aware that unless the integrity of these covers are
maintained to prevent rot or other issues, it could be ineffective in protecting these
units.
g.) During this inspection the effluent storage lagoon had a freeboard level of 3.1'
according to the staff gauge that was present. The ORC reported, that during irrigation
events, when the freeboard level nears 3.5' solids being to be sucked into the irrigation
pumps. This indicates that storage within the effluent storage lagoon has likely been
reduced from its original design capacity due in part to the violation described above
in #5. Design criteria for irrigation systems typically include a minimum of 5-days of
wet weather storage. The finding described herein and the documented influent flows,
suggest that the subject facility may have less than 5-days of wet weather storage,
which could lead to expensive "pump-n-haul" cost if irrigation became prohibited in
accordance with Permit Condition III. (5). Failure to prevent solids from being pulled
into the irrigation pumps could also lead to costly pump repairs.
It is strongly recommended that a sludge survey be conducted in the effluent storage
lagoon, to determine whether a sludge clean -out event is warranted to re-establish
the designed storage capacity.

h.) The permitted treatment equipment describes a bar screen. Bar screens are intended to
prevent large solids/debris from impacting the downstream treatment pumps or other
equipment. While a bar screen was technically present at the subject treatment facility,
it was inaccessible thus preventing proper maintenance from occurring. Proper bar
screen maintenance should allow for screenings to be removed from the bar screen for
proper disposal at a frequency that would protect the downstream treatment equipment.
It is recommended that access to the bar screen be provided to allow proper
maintenance to be conducted.
This office is considering the pursuit of punitive sanctions for these violations. If you wish to
present an explanation for the violations cited, or if you believe there are other factors which should
be considered, please send such information to me in writing within ten (10) days following
receipt of this letter. Any additional information will be reviewed, and if an enforcement action
is still deemed appropriate, that information will be forwarded to the Director with the enforcement
package for their consideration. Please include in this response an outline for actions taken to
remedy any future violations of those listed above.
Your written response should be sent to my attention at the address shown on the letterhead. Be
advised that NC General Statutes provide for penalties of up to $25,000 per day per violation as
well as criminal penalties for violations of state environmental laws and regulations.
Your immediate attention is greatly appreciated. Please refer to the enclosed compliance inspection
report for additional observations and comments. If you have any questions regarding this Notice,
please contact Justin Henderson or me at the letterhead address or phone number, or by email at
justin.hendersongncdenr. og_v or Ion. sniderkncdenr. gov
Sincerely,
DocuSigned by:
145B49E225C94EA...
Lon Snider- Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
enc: Inspection Report
cc: Glenn Price, ORC- [e-mail]
Laserfiche Files (electronic copies)

Compliance Inspection Report
Permit: WQ0004972
SOC:
County: Davie
Region: Winston-Salem
Contact Person: David Kozy
Effective: 04/29/16 Expiration: 03/31/21 owner: Mhc Tt Inc
Effective: Expiration: Facility: Forest Lake Preserve
192 Thousand Trails Dr
Title: Vice President
Advance NC 27006
Phone: [phone]
Directions to Facility:
From Winston travel 1-40 West to HWY 801 South. Travel 801 S to intersection with US 64 and turn Left. Enterance to campground
is approx. 0.5 mile west of the Yadkin River on N. side of US 64
System Classifications: SI, WW2,
Primary ORC: Glenn Fredrick Price Certification: 987931 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 11/21/2019 EntryTime: 10:OOAM
Primary Inspector: Justin L Henderson
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
Exit Time: 02:OOPM
Phone: [phone]
Inspection Type: Compliance Evaluation
Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent
Treatment Flow Measurement -Water Treatment
Use Records
Record Keeping Treatment Activated Sludge
End Use -Irrigation Treatment Clarifiers
Treatment Flow Measurement Storage
Wells
(See attachment summary)
Miscellaneous Questions
Treatment Barscreen
Treatment Sludge Storage/Treatment
Treatment Disinfection
Standby Power
Page 1 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
On November 21, 2019, staff of the North Carolina Division of Water Resources Winston Salem Regional Office (DWR)
performed a compliance evaluation inspection of the subject wastewater treatment and surface irrigation system. This
inspection was conducted by DWR staff person Justin Henderson. Accompanying DWR for this inspection was Mr. Glenn
Price, ORC of R&A Labs, and Duncan Curll, maintenance personnel of Forest Lake Preserve. The facility was found to be
non -compliant Permit W00004972. The following violations require your immediate attention and action:
1) Failure to develop and/or maintain an Operation and Maintenance Plan (O&M Plan) for the wastewater collection facilities
as required by Permit Condition 11. (4.) (c.). The collection facilities O&M Plan shall include pump station inspection
frequency, preventative maintenance schedule, spare parts inventory, and overflow response plan in accordance with 15A
NCAC 02T .0403 (3).
2) Failure to conduct and document pump station inspections per the frequencies required by Permit Condition 11. (4.) (d) &
0) and in accordance with 15A NCAC 02T .0403 (4) & (10). The subject collection facilities include a total of seven lift
stations, none of which are connected to telemetry, therefore requiring inspection by the Permittee or its representative every
day, 365 days per year.
3) There was no evidence that a grease control program had been developed, implemented, nor maintained as required by
Permit Condition II. (4) (g.) and 15A NCAC 02T .0403 (8) (B).
4) Failure to generate and/or maintain inspection and maintenance records for Conditions II. (4) (a) through II. (4) (i) as
required by Permit Condition 11. (4) 0.).
5) Failure to properly manage the solids volume within the wastewater treatment facility. Reportedly, 10 of the 13 diffusers
located in the aeration basin were inoperable or completely missing. Inadequate aeration will impede proper nitrification from
occurring. Also, proper sludge wasting from the aeration basin into the digestor is currently not possible according to the
ORC as a result of the inadequate aeration. The aeration basin appeared to contain excessive solids and floating sludge
"mats" were observed during this inspection. Permit Condition III. 1. states: the facilities shall be properly maintained and
operated at all times.
6) Wastewater was observed "gushing" out of a broken standpipe when the effluent pump was activated as part of this
inspection. As a result, effluent ponding and runoff was observed during this event as well. Permit Condition III. (1) states:
the facilities shall be properly maintained and operated at all times. Permit Condition 111.4 states: adequate measures shall
be taken to prevent effluent ponding in or runoff from the irrigation site.
7) Observations of the remaining spray heads made during this inspection while the effluent pump was activated are there
was one spray head that appeared to be clogged, preventing a proper spray pattern, another spray head was surrounded by
overgrown vegetative growth that was contributing to an impeded spray pattern, and one spray head had been previous taken
"off-line" due to a broken standpipe. Permit Condition III. (1) requires the facilities to be properly maintained and operated at
all time. At least four (4) of the 18 total spray heads were in need of maintenance at the time of this inspection.
The previous compliance inspection report dated September 24, 2018, contained the following description: ... thick
undergrowth of vegetation between spray heads and throughout the field was not suitable for a full system inspection and
may impede proper spray dispersal as well.
8) Failure to include a Spill Response Plan and safety measures within the Operation and Maintenance Plan for the
wastewater treatment and irrigation facilities as required by Permit Condition III. (1.)
9) Vegetative growth was observed in the sludge trough located between the aeration basin and the clarifier. The vegetative
growth had persisted long enough that it had extended above and through the catwalk that was providing access to the
various treatment units contained in the wastewater treatment facility. This scenario constitutes a violation of Permit
Condition III. (1.) for failure to conduct proper maintenance and creates a safety/trip hazard to authorized personnel operating
Page 2 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
or inspecting the facilities.
10) Direct discharge of effluent to the ground surface and subsequent ponding outside of the permitted irrigation area. This
discharge was observed occurring at a partially opened lateral clean -out, upon effluent pump activation. Permit Condition III.
(1) states: the facilities shall be effectively maintained operated to prevent the discharge of any wastewater. Permit Condition
III. (4) requires adequate measures be taken to prevent effluent ponding in or runoff from the irrigation sites.
The previous compliance inspection report dated September 24, 2018, contained the following description: DWR staff noted
two lateral line clean -outs had been left open. The clean -outs were observed directly discharging effluent wastewater onto the
ground surface away from the spray field and preventing the spray heads from fully pressurizing, therefore improperly
operating as designed....
11) Failure to properly maintain the earthen embankment associated with the effluent storage lagoon. Permit Condition III.
(14) states: Trees, shrubs, and other woody vegetation shall not be allowed to grow on the earthen dikes or embankments.
Earthen embankment areas shall be kept mowed or otherwise controlled and accessible.
12) Failure to effluent monitoring for Total Nitrate Nitrogen as specified by Attachment A. Permit Condition IV. (4) states: The
Permittee shall monitor the effluent from the subject facilities as the frequencies and locations for the parameters specified
in Attachment A.
The facility has incorrectly been monitoring effluent for Total Nitrite + Total Nitrate Nitrogen as opposed to the specified Total
Nitrate analysis.
13) Application rates reported on Form NDAR are being inaccurately calculated. Application rates are being calculated
based upon nine (9) acres being utilized for irrigation, however reportedly only seven (7) acres are being utilized for irrigation.
Permit Condition IV. (5) states: The Permittee shall maintain adequate records tracking the amount of effluent irrigated.
14) Failure to submit copies of laboratory analysis along with the Compliance Monitoring Form GW-59 when reporting
ground water monitoring results. Permit Condition IV. (11) states: Two copies of the monitoring well sampling and analysis
results shall be submitted on a Compliance Monitoring Form GW-59, along with attached copies of laboratory analyses, on
or before the last working day of the month following the sampling month.
15) Monitoring well #3 (MW-3) was not secured with a locking apparatus as required by 15A NCAC 02C .0108 (1).
16) Monitoring well #3 (MW-3) was not equipped with a steel outer well casing or flush mount cover, set in concrete as
required by 15A NCAC 02C .0108 (m).
In addition to the above described violations, the following items of concern also require your attention and action:
a.) Reportedly seven (acres) are currently being utilized for irrigation, however per Attachment B, there are nine (9) acres
permitted for irrigation. It is the Division's understanding that not all the permitted spray heads were installed. This
discrepancy led the Division to conducted square footage calculations based up the total installed spray heads. Square
footage calculations for 18 total spray heads with a 60' diameter spray pattern suggest that the actual wettable acreage
being utilized is less than two (2) acres. Should this be confirmed, then application rates (both hourly and cumulative annual)
are being severely underreported. This would also raise concerns as if agronomic rates are also being exceeded. Permit
Condition 11. (6) states: application rates, whether hydraulic, nutrient, or other pollutant, shall not exceed those specified in
Attachment B. [15A NCAC 02T .0505 (c), 02T .0505 (n)]
Due to this discrepancy, the Division is requesting that calibration of the irrigation equipment (required once per permit cycle
per Permit Condition III. (6)) be conducted within the next 90-days. As part of this calibration event, a "wettable acreage"
determination shall also be conducted to accurately demonstrate the acreage that is utilized for irrigation. Field
documentation of the calibration event and for the wettable acreage determination shall be submitted to this office upon
Page 3 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
completion.
b.) There was no back-up power available, at the facility, to supply power to any of the seven lift stations nor to the
wastewater treatment facility in the event of a power outage. Reportedly, water supply and therefore water use would not
necessarily be interrupted during a power outage. Should water use remain uninterrupted during a power outage, the risk of
sewer overflows at the lift -stations and/or the wastewater treatment facility would greatly increase in the absence of back-up
power availability. Sewer overflows that occur due to failure to provide back-up power at necessary locations may result in
future violations and/or civil penalties to be incurred.
c.) The annual representative soils analysis (i.e. Standard Soil Fertility Analysis), required by Permit Condition IV. (12) had
not been conducted for the current year at the time of this inspection.
d.) A small leak in the piping at the effluent irrigation pump was observed upon pump activation. If not repaired in a timely
manner, pressurization issues in the irrigation field, pump performance issues, and/or bypass violations may be incurred.
Permit Condition III. (1) requires proper maintenance be conducted at all times and Permit Condition III. (11) prohibits the
diversion or bypassing of untreated or partially treated wastewater.
e.) The facility only has one effluent irrigation pump that is operable. The back-up irrigation pump is no longer operable due
to failure to perform proper maintenance. A leak noted, in the previous inspection, was not repaired and the pump
subsequently froze, and the pump housing busted, rendering the pump inoperable.
The previous compliance inspection report, dated September 24, 2018, contained the following description: a small leak was
noted on the back -side of the effluent lagoon pump. Please repair to prevent further leaks or problems with the pump.
f.) The facility has a deemed collection system with seven grinder pump lift stations. Review of each of the lift stations was
conducted as part of this inspection. Findings of this review are summarized here: Lift Station #2 had an unlocked access
opening, and an the visible high water alarm was inoperable; Lift Station #4 the audible high water alarm was inoperable; Lift
Station #7 the audible high water alarm was inoperable; Several of the pump vaults/wet-wells were covered with wooden lids
to prohibit unauthorized access. Please be aware that unless the integrity of these covers are maintained to prevent rot or
other issues, it could be ineffective in protecting these units.
g.) During this inspection the effluent storage lagoon had a freeboard level of 3.1' according to the staff gauge that was
present. The ORC reported, that during irrigation events, when the freeboard level nears 3.5' solids being to be sucked into
the irrigation pumps. This indicates that storage within the effluent storage lagoon has likely been reduced from its original
design capacity due in part to the violation described above in #5. Design criteria for irrigation systems typically include a
minimum of 5-days of wet weather storage. The finding described herein and the documented influent flows, suggest that the
subject facility may have less than 5-days of wet weather storage, which could lead to expensive "pump-n-haul" cost if
irrigation became prohibited in accordance with Permit Condition III. (5). Failure to prevent solids from being pulled into the
irrigation pumps could also lead to costly pump repairs.
It is strongly recommended that a sludge survey be conducted in the effluent storage lagoon, to determine whether a sludge
clean -out event is warranted to re-establish the designed storage capacity.
h.) The permitted treatment equipment describes a bar screen. Bar screens are intended to prevent large solids/debris from
impacting the downstream treatment pumps or other equipment. While a bar screen was technically present at the subject
treatment facility, it was inaccessible thus preventing proper maintenance from occurring. Proper bar screen maintenance
should allow for screenings to be removed from the bar screen for proper disposal at a frequency that would protect the
downstream treatment equipment. It is recommended that access to the bar screen be provided to allow proper maintenance
to be conducted.
Page 4 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Yes No NA NE
Activated Sludge Drip, LR
❑
Reuse (Quality)
❑
Single Family Spray, LR
❑
Single Family Drip
❑
Activated Sludge Spray, HR
❑
Recycle/Reuse
❑
Infiltration System
❑
Activated Sludge Spray, LR
❑
Lagoon 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: Several diffuser are broken in the aeration basin, prevent proper wasting of sludge into the
digestor. One effluent irrigaiton pump is inoperable due to a cracked housing.
Treatment Flow Measurement -Influent
Yes No NA NE
Is flowmeter calibrated annually?
❑
❑ 0 ❑
Is flowmeter operating properly?
❑
❑ 0 ❑
Does flowmeter monitor continuously?
❑
❑ 0 ❑
Does flowmeter record flow?
❑
❑ 0 ❑
Does flowmeter appear to monitor accurately?
❑
❑ ❑
Comment:
Treatment Flow Measurement -Water Use Records Yes No NA NE
Is water use metered? ❑ ❑ ❑
Are the daily average values properly calculated? ❑ ❑ 0 ❑
Comment:
Treatment Flow Measurement -Effluent
Yes No NA NE
Is flowmeter calibrated annually?
0
❑ ❑ ❑
Is flowmeter operating properly?
0
❑ ❑ ❑
Does flowmeter monitor continuously?
0
❑ ❑ ❑
Does flowmeter record flow?
❑
❑ 0 ❑
Does flowmeter appear to monitor accurately?
0
❑ ❑ ❑
Comment: Flow is recorded manually by ORC.
Standby Power
Yes No NA NE
Page 5 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Is automatically activated standby power available? ❑ ❑ ❑
Is generator tested weekly by interrupting primary power source? ❑ ❑ ❑
Is generator operable? ❑ ❑ ❑
Does generator have adequate fuel? ❑ ❑ ❑
Comment: There is no stand-by power availabe for the WWTP nor any of the seven grinder lift stations
present in the collection system.
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? ❑ 0 ❑ ❑
Is disposal of screenings in compliance? ❑ 1:10 ❑
Are the bars spaced properly? 0 ❑ ❑ ❑
Is the unit in good condition? 0 ❑ ❑ ❑
Comment: Bar Screen is inaccessible therefore preventing screenings from being removed from system
and disposed of properly.
Treatment Activated Sludqe
Is the aeration mechanism operable?
Is the aeration basin thoroughly mixed?
Is the aeration equipment easily accessed?
Is Dissolved Oxygen adequate?
Are Settleometer results acceptable?
Is activated sludge an acceptable color?
Comment: Several of the diffusers connected to the blowers are inoperable or missing completely. The
aeration basin appears to be transitioning towards septic conditions based upon the lack of
aeration and inadequate mixing.
Treatment Clarifiers
Are the weirs level?
Are the weirs free of solids and algae?
Is the scum removal system operational?
Is the scum removal system accessible?
Is the sludge blanket at an acceptable level?
Is the effluent from the clarifier free of excessive solids?
Comment: Clarifier was cover with duckweed so unable to determine if solids were Dresent in clarifier at
Yes No NA NE
Yes No NA NE
■❑❑❑
■❑❑❑
❑ ❑ ❑
❑❑❑■
time of this inspection. Scum removal system had not been properly maintained and vegetative
growth had extended above and into the catwalk of the plant.
Treatment Sludge Storage/Treatment Yes No NA NE
Is the aeration operational? ❑ ❑ 0 ❑
Is the aeration pattern even? ❑ ❑ ❑
If required, are Sanitary "Ts" present in tankage? ❑ ❑ ❑
Page 6 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Comment:
Treatment Disinfection
Yes No NA NE
Is the system working?
❑
❑ ❑
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?
❑
❑ ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
❑
❑ ❑
If yes, then is there a Risk Management Plan on site?
❑
❑ ❑
If yes, then what is the EPA twelve digit ID Number? (1000-
If yes, then when was the RMP last updated?
Comment: The effluent laaoon is the sample location for effluent fecal. Fecal results are consistentl
elevated, however it could be regrowth within the storage lagoon that is responsible for elevated
fecal results rather than treatment issues. To discern if treatment is adequate, fecal samples
should be collected from both the eflluent storage lagoon and immediately downstream of the
contact chamber.
Record Keeping
Yes No NA NE
Is a copy of current permit available?
❑ ❑ ❑
Are monitoring reports present: NDMR?
❑ ❑ ❑
NDAR?
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑ ❑ ❑
Are flow rates less than of permitted flow?
❑ ❑ ❑
Are application rates adhered to?
❑
❑ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
❑ ❑ ❑
Are all samples analyzed for all required parameters?
❑ ❑ ❑
Are there any 2L GW quality violations?
❑
❑ ❑
Is GW-59A certification form completed for facility?
❑
❑ ❑
Is effluent sampled for same parameters as GW?
❑ ❑ ❑
Do effluent concentrations exceed GW standards?
❑ ❑ ❑
Page 7 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation Reason for Visit:
Routine
Are annual soil reports available?
❑ ❑ ❑
# Are PAN records required?
❑
❑ ❑
# Did last soil report indicate a need for lime?
❑ ❑ ❑
If so, has it been applied?
❑
❑ ❑
Are operational logs present?
❑ ❑ ❑
Are lab sheets available for review?
❑ ❑ ❑
Do lab sheets support data reported on NDMR?
❑ ❑ ❑
Do lab sheets support data reported on GW-59s?
❑ ❑ ❑
Are Operational and Maintenance records present?
❑ ❑ ❑
Were Operational and Maintenance records complete?
❑ ❑ ❑
Has permittee been free of public complaints in last 12 months?
❑ ❑ ❑
Is a copy of the SOC readily available?
❑
❑ ❑
No treatment units bypassed since last inspection?
❑
❑ 0 ❑
Comment: Unable to verify if application rates are adhered to in accordance with permit requirements,
beacuse reported wettable acreage is less than permitted wettable acreage and square footage
calculations based upon total spray heads appear to indicated wettable acreage may be even
less than reported. Application rates are being erroneously calculated using the total permitted
acreage which is more than the reported wettable acreage currently.
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
0
❑ ❑ ❑
Is the cover crop type specified in permit?
0
❑ ❑ ❑
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 RIB and CB?
❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
❑
❑ ❑
Are monitoring wells damaged?
❑
❑ ❑
Page 8 of 9

Permit: WQ0004972 Owner - Facility: Mhc Tt Inc
Inspection Date: 11/21/2019 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Comment: MW-3 does not have a locking apparatus nor is it protected by a steel casing. One standpipe
was broken and gushing water while effluent irrigation pump was running resulting in ponding
and runoff. A clean -out at the end of a lateral used to bleed the line after irrigation had been left
Partially open as was contributing to runoff outside of the irrigation boundary. Two spray heads
had impeded spray patterns likely due to clogging or partially clogging. One spray head had
impeded spray pattern due to overgrown vegetation surounding it. One standpipe had been
temporarily taken out of service due to a break in the standpipe.
Page 9 of 9