WQ0000088_NOD-2020-PC-0112_20200312

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Mr. Shannon Becker
President, AQUA North Carolina, INC.
202 MacKenan Court
Cary, NC 27511
Mr. Becker,
NORTH CAROLINA
Envkvnmenlal Quality
March I2, 2020
Subject: NOD-2020-PC-0112
Compliance Evaluation Inspection
Governors Club WWTP
Reclaimed Water Generation and Non -Conjunctive Utilization
System
Permit Number WQ0000088
Chatham County
On March 11, 2020, Rick Trone and Gary Kreiser of the Raleigh Regional Office conducted a compliance
evaluation inspection of the non -conjunctive wastewater treatment and reclaimed water generation system
located at Governors Club. The purpose of this inspection was to ensure compliance with the subject
permit. During the inspection, the cooperation of Mr. Jackie Jackson, Mr. Joe Pearce, and the Operator in
Responsible Charge (ORC), Alfred McNeill 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, calibration documentation, Non -discharge wastewater monitoring
reports (NDMR), Non -discharge application reports (NDAR), Groundwater Monitoring Forms
(GW-59a) and;
• On -site inspection of treatment components and spray fields
The current permit was issued August 23, 2018 and expires on July 31, 2023. A permit modification
request was recently received to add a digester and repair the current one. The current digester is close to
structural failure. The inspection also included a review of the on -site components related to this change.
Components of the wastewater package plant appeared to be overall well -maintained and operational.
Water moving through the clarifier weirs was clear and free of solids. The ultraviolet lights were
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional office 13800 Barrett Drive I Ralelgh. North Carolina 27609
�O"a\ 919.791.4200

operational. The facility has plenty of chlorine tablets available. Monitoring Well 7 was observed and
appeared free of damage. The well cap was unlocked. Please ensure monitoring wells are secured.
The inspector reviewed the facilities Operation and Maintenance Plan which was found to be adequate.
Flowmeter and turbidimeter calibration records indicate both devices have been calibrated per permit
requirements (October 2019). The facility is certified to run a couple field parameters in house (e.g., pH).
A calibration log is maintained for the pH meter. A check of pH calibration standards found that pH 10
standard expires this month but was nearly empty. No issues were noted with the 5-day upset pond on the
day of the inspection. The pump station located at the 5-day upset pond has a lighted alarm and will call
the facility when in alarm status. The alarm functioned when a float was pulled, and the pumps could be
heard running.
Overall, the facility appears to be monitoring the package plant effluent according to permit requirements.
However, Total Nitrogen was not reported for the months of June, September, and October 2019. The
facility also needs to have the NDMR forms updated, the current forms do not list Phosphorous, TKN,
and Total Nitrogen. Currently, the facility is having to write these parameters in by hand and several
months were missed. The facility reported the numbers, but without the headers for the columns. Two
random months ofNDMR data were compared to lab results from Enco and no deficiencies were found.
No issues were noted with the NDAR reports. The facility always reports the same freeboard (9') for the
5-day upset pond. On the day of the inspection the freeboard about was 7'.
Monitoring well compliance sampling forms were compared against lab results from Environment 1.
Some minor errors were found on the November 2019 report which were discussed with Mr. Jackson.
Wells often have exceedances of groundwater standards for TDS and Chlorides. The facility needs to
submit form GW-59a Certification Form with each packet of GW-59's. GW-59's have not been received
by the Division for March 2019.
The facility maintains several spray fields located within an existing power line easement and a golf
course. Appropriate signage near the fields warns residents of the use of reclaimed water usage. No issues
were noted with the fields and golf course areas.
The following permit condition deficiencies were noted during the March 11, 2020 compliance
inspection and records review:
III.Operation and Maintenance Requirements
Condition 3, which states that, "Upon the Water Pollution Control System Operators Certification
Commission's classification of the subject non -discharge facilities... the Permittee shall designate and
employ a certified operator in responsible charge (ORC)..." Mr. Alfred McNeil is not listed as a certified
operator for permit WQ0000088. Please have this updated to reflect the current operator:
h ttps: li de q. nc.gov/about/divisions/water-resources/operator-certificat ion/wastewater-operator-
certification/wastewater-operator-certification-downloads
IV. MONITORING AND REPORTING REQUIREMENTS
Condition 4, which states that, "the Permittee shall monitor the reclaimed water from the generating
facility at the frequencies and locations for the parameters specified in Attachment A." The facility

should request updated NDMR forms from the Divisions Central Office, Non -Discharge Branch
that include Total Phosphorous, TKN, and Total Nitrogen. The facility failed to report Total
Nitrogen for the months of June, September, and October 2019. Please submit amended NDMR
forms for these months to the address on the form.
Condition I I which states that, "Monitoring wells shall be sampled at the frequencies and for the
parameters specified in Attachment C." The facility has not submitted well sampling records for
March 2019. Please submit these documents to the address on the forms as soon as possible.
This office requests that you respond to this letter in writing within 30 days of receipt. Your
response should be sent to this office at the letterhead address. Your response should address the
following items as noted above. 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.troneancdennaov or 919-7914200.
Sincerely,
1)�q ���
Scott Vinson, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office, NCDEQ
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files
Laserfiche

Compliance Inspection Report
Permit: W00000088 Effective: 08/23/18 Expiration: 07/31/23 Owner: Aqua North Carolina Inc
SOC: Effective: Expiration: Facility: Governors Club WWTP
County: Chatham Farrington Rd
Region: Raleigh
Chapel Hill NC 27517
Contact Person: Michael J Myers Title: Phone: [phone]
Directions to Facility:
Take Hwy. 64 West toward Pittsboro. Take a right onto Farrington Road. The entrance for the Governors Club development is
located on the left, about 8.5 miles after this turn.
System Classifications: St. WW2,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03111 /2020 Entry Time 10:OOAM Exit Time: 11:15AM
Primary Inspector: Rick V Trone Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine
Inspection Type: Compliance Evaluation
Permit Inspection Type: Reclaimed Water
Facility Status: ❑ Compliant
Not Compliant
Question Areas:
Miscellaneous Questions
Treatment
Treatment Barscreen
Record Keeping
Treatment Lagoons
End Use -Irrigation
Treatment Influent Pump Station
Treatment Clarifiers
Treatment Disinfection
Storage
End Use -Reuse
Standby Power
Wells
{See attachment summary}
Page 1 of 7

Permit: WQ0000088 Owner - Facility: Aqua North Carolina Inc
Inspection Date: 03/11/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Page 2 of 7

Permit: WC0000088 Owner - Facility: Aqua North Carolina In_
Inspection Date: 03/11/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Type
Yes No NA NE
Infiltration System
Lagoon Spray, LR
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Spray, HR
Activated Sludge Drip, LR
Reuse (Quality)
Recycle/Reuse
Single Family Drip
Treatment
Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit?
Do all treatment units appear to be operational? (if no, note below.)
Comment:
Treatment Influent Pump Station
Yes No NA NE
Is the pump station free of bypass lines or structures?
0 0 0
Is the general housekeeping acceptable?
Are all pumps present?
Are all pumps operable?
Are floats/controls operable?
Are audio and visual alarms available?
0O so
Are audio and visual alarms operational?
# Are SCADAITelemetry alarms required?
❑ 0 so
Are SCADA/Telemetry available?
0 0 No
Are SCADA/Telemetry operational?
❑ 0 No
Comment:
Standby Power
Yes Na NA NE
Is automatically activated standby power available? 0❑ ❑ O
Is generator tested weekly by interrupting primary power source? 0 ❑ ❑ ❑
Is generator operable? 0 0❑
Does generator have adequate fuel?
Comment:
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? 0000
Page 3 of 7

Permit: wO0000088 Owner - Facility -Aqua North Carolina Inc
Inspection Date: 03I11l2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
is disposal of screenings in compliance? 0 ❑ ❑ ❑
Are the bars spaced properly? M ❑ ❑ ❑
Is the unit in good condition? 0 110 ❑
Comment:
Treatment Clarifiers
Yes No NA NE
Are the weirs level?
0 ❑ 110
Are the weirs free of solids and algae?
E ❑ ❑ ❑
1s the scum removal system operational?
E ❑ ❑ ❑
Is the scum removal system accessible?
0 ❑ 130
Is the sludge blanket at an acceptable level?
❑ ❑ ❑
Is the effluent from the clarifier free of excessive solids?
0 ❑ ❑ ❑
Comment:
Treatment Disinfection
Yes No NA NE
Is the system working?
E ❑ ❑ ❑
Do the fecal coliform results indicate proper disinfection?
0 ❑ ❑ ❑
Is there adequate detention time (-30 minutes)?
0 ❑ ❑ ❑
Is the system properly maintained?
E ❑ ❑ ❑
If gas, does the cylinder storage appear safe?
❑ ❑ M ❑
Is the fan in the chlorine feed room and storage area operable?
❑ ❑ M ❑
Is the chlorinator accessible?
❑ ❑M ❑
If tablets, are tablets present?
❑ ❑ ❑
Are the tablets the proper size and type?
M ❑ ❑ ❑
Is contact chamber free of sludge, solids, and growth?
M ❑ ❑ ❑
If UV, are extra UV bulbs available?
M ❑ 130
If UV, is the UV intensity adequate?
M ❑ ❑ ❑
# Is it a dual feed system?
M ❑ ❑ ❑
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)?
❑ ❑ M ❑
If yes, then is there a Risk Management Plan on site?
❑ ❑ M ❑
If yes, then what is the EPA twelve digit ID Number? (1000-
If yes, then when was the RMP last updated?
Comment:
Record Keeping Yes No NA NE
Is a copy of current permit available? 011011
Are monitoring reports present: NDMR? 0000
NDAR? 0000
Page 4 of 7

Permit: W00000088 Owner - Facility -Aqua North Carolina Inc
Inspection Date: 03/11/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Are flow rates less than of permitted flow?
M D ❑ Cl
Are flow rates less than of permitted flow?
0 ❑ ❑ ❑
Are application rates adhered to?
0❑ ❑ ❑
Is GW monitoring being conducted, if required (GW-59s submitted)?
N ❑ ❑ ❑
Are all samples analyzed for all required parameters?
❑ 0 ❑ ❑
Are there any 2L GW quality violations?
0❑ ❑
Is GW-59A certification form completed for facility?
❑ E ❑ ❑
Is effluent sampled for same parameters as GW?
E0 o
Do effluent concentrations exceed GW standards?
0 0 0 ❑
Are annual soil reports available?
❑ 0 N 0
# Are PAN records required?
0 0 No
# Did last soil report indicate a need for lime?
O 0 E ❑
If so, has it been applied?
❑ ❑ M ❑
Are operational logs present?
0 0 ❑
Are lab sheets available for review?
■ ❑ 013
Do lab sheets support data reported on NDMR?
0 ❑ ❑ 0
Do lab sheets support data reported on GW-59s?
E ❑ ❑ ❑
Are Operational and Maintenance records present?
0 000
Were Operational and Maintenance records complete?
E 0 ❑ ❑
Has permittee been free of public complaints in last 12 months?
0 ❑ ❑ ❑
Is a copy of the SOC readily available?
❑ 0 on
No treatment units bypassed since last inspection?
0 ❑ No
Comment: Facility has not submitted GW-59 for March 2019. Facility
does not submit GW-59a forms.
Some arameters have been unreported on form NDMR
see summary),
End Use -Irrigation
Yes No NA NE
Are buffers adequate?
00 0 ❑
Is the cover crop type specified in permit?
0 0 0 El
Is the crop cover acceptable?
0❑ 00
Is the site condition adequate?
0❑ ❑ 0
Is the site free of runoff ! ponding?
00 ❑ 0
Is the acreage specified in the permit being utilized?
0 0 0 ❑
Is the application equipment present?
00 00
Is the application equipment operational?
■
Is the disposal field free of limiting slopes?
Is access restricted and/or signs posted during active site use?
0 0 El 0
Are any supply wells within the CB?
0 0 00
Page 5 of 7

Permit. W00000088 owner - Facility: Aqua North Carolina Inc
Inspection Date: 03/11/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine
Are any supply wells within 250' of the CB? ❑ ❑ ❑
How close is the closest water supply well? ❑ ❑ ❑ 0
Is municipal water available in the area? ❑ ❑ ❑
# Info only: Does the permit call for monitoring wells? M ❑ ❑ ❑
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: .
End Use -Reuse
Yes No NA NE
Is the acreage in the permit being utilized?
0 ❑ ❑ ❑
Does the acreage specified in the permit correspond to the measured acreage at the site?
0 ❑ ❑ ❑
Are all essential units provided in duplicate?
❑ ❑ ❑ M
Is an automatically activated standby power source available?
■ ❑ ❑ ❑
Is the equalization capacity adequate?
❑ ❑ ❑
Is aerated flow equalization present?
❑ ❑ ❑
Has the turbidity meter been calibrated in the last 12 months?
M ❑ ❑ ❑
Does the turbidity meter have recording capabilities?
M ❑ ❑ ❑
Is all flow diverted at the appropriate times?
M ❑ ❑ ❑
Is all upset wastewater diverted from reuse storage unit?
N ❑ ❑ ❑
Is all upset wastewater treated, retreated, or disposed of acceptably?
M ❑ ❑ ❑
Is upset wastewater treated prior to discharge to irrigation storage?
0 ❑ ❑ ❑
Is public access restricted from irrigation area during active site use?
M ❑ ❑ ❑
If golf course, is a sign posted in plain sight on the club house?
0 ❑ 130
Is the cover crop acceptable?
M ❑ ❑ ❑
Are buffers adequate?
IN ❑ ❑ ❑
Is the site free of ponding/runoff?
0 ❑ ❑ ❑
Is the acreage in the permit being utilized?
0 ❑ ❑ ❑
Is the application equipment acceptable?
■ ❑ ❑ ❑
Is the application area free of limiting slopes?
0 ❑ ❑ ❑
How close is the closest water supply well?
❑ ❑ ❑ N
Are any supply wells within the CB?
❑ ❑ ❑ N
Are any supply wells within 250' of the CB?
❑ ❑ ❑
Is municipal water available in the area?
❑ ❑ ❑
Are GW monitoring wells required?
0 ❑ ❑ ❑
Are GW monitoring wells located properly wl respect to RB and CB?
❑ ❑ ❑
Are GW monitoring wells properly constructed, including screened interval?
M Cl ❑ ❑
Page 6 of 7

Permit: W00000088 Owner - Facility: Aqua Forth Carolina Inc
Inspection Date: 03111/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment:
Page 7 of 7