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Home My WebLink AboutWQ0004972_NOV-2020-PC-0460_20201030ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH NORTH CAROLINA Director Environmental Quality November 2, 2020 CERTIFIED MAIL 7018 1130 0000 1612 8151 RETURN RECEIPT REQUESTED George Gudgeon, Senior Vice President MHT TT Inc. 2North Riverside Drive Chicago, Illinois 60606 SUBJECT: NOTICE OF VIOLATION (NOV-2020-PC-0460) Forest Lake Preserve — Wastewater Irrigation System Permit No. WQ0004972 Davie County Dear Mr. Gudgeon: On October 21, 2020, 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 persons Justin Henderson and Caitlyn Caudle. Accompanying DWR staff during this inspection was Mr. Glenn Price, ORC of R&A Labs, Mark McKeithan, Senior Regional Manager, Sylvia Austin, Regional Manager, and Tracy Overdurf, Resort Manager of Forest Lake Preserve. The facility was found to be non -compliant Permit WQ0004972. The following violations require your immediate attention and action: 1) The subject permit has an expiration date of March 31, 2021. Permit Condition I. (1) requires that the Permittee shall request renewal of this permit on official Division forms, no less than six months prior to expiration of the permit. To date, an official request for permit renewal has not been received by the Division. 2) Review of the facility's May 2020 Form NDAR, a required monthly reporting form utilized to track irrigation events, indicated that irrigation of 33,984 gallons occurred on May 21, 2020. This irrigation event followed a documented rain event occurring on May 20, 2020, consisting of a reported rainfall total of 5.6 inches. This constitutes a violation of Permit Condition III. (5) which prohibits irrigation during inclement weather or when the ground is in a condition that will cause ponding or runoff. D_E rvahrI-1 cARoLIna Department el Environmental ouar� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 3) The Notice of Intent to Enforce (NOI) dated December 5, 2019, that was issued by this Office, following the previous compliance evaluation inspection, performed on November 21, 2019, brought the concern described below to your attention as well as a request to evaluate the described discrepancy via system calibration and wettable acreage determination: 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 H. (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)] At the time of this inspection, the ORC provided calibration and wettable acreage calculation results generated as part of a calibration event that was conducted on January 14, 2020, by Research and Analytical Laboratories. These calculations suggested that the wettable acreage utilized by the subject irrigation system totals 3.42 acres. These calculations support confirmation that the reported irrigation acreage of 7 acres is inaccurate, as well as the fact that application rates (both hourly and cumulative annual) are currently being underreported. Permit Condition IV. (5) states: The Permittee shall maintain adequate records tracking the amount of effluent irrigated. Application rates shall immediately be calculated based upon the wettable acreage of 3.42 acres as determined by the most recent calibration event conducted on 1/14/2020, and revised cumulative annual totals for the previous 12 months be submitted to this office within 90-days of receipt of this Notice. 4) A Residual Management Plan (RMP) in accordance with Permit Condition III. (10) reportedly did not exist at the time of this inspection Immediately generate and maintain a RMP pursuant to 15A NCAC 02T .0508. In addition to the above described violations, the following items of concern also require your attention and action: a.) Reportedly per the ORC, one spray head had been "offline/inactive" for the past year. This was done to prevent runoff from occurring, as some of the ground surface within reach of this spray head had been converted to an access road thus inhibiting proper assimilation of effluent. If this operation is to be continued, then ensure wettable acreage determination and subsequent calculation and reporting of application rates is representative of this "lost" acreage. 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. A follow-up inspection to evaluate the corrective actions implemented to resolve the violations described above is planned to be conducted within the next 60-days. Your immediate attention and action 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.henderson@ncdenr.gov or lon.snider@ncdenr.gov Sincerely, EDocuSigned by: .-4, 7 JMdtr 145B49E225C94EA... Lon Snider- Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO enc: Inspection Report cc: Mark McKeithan, Senior Regional Manager — mark_Mckeithan@equitylifestyle.com Tracy Overdurf, Resort Manager — forestlake_mgr@equitylifestyle.com Glenn Price, ORC- info@randalabs.com Laserfiche Files (electronic copies) Compliance Inspection Report Permit: WQ0004972 SOC: County: Davie Region: Winston-Salem Effective: 04/29/16 Effective: Expiration: 03/31/21 Expiration: Contact Person: David Kozy Title: Vice President Directions to Facility: From Winston travel 1-40 West to HWY 801 South. Travel 801 S to intersection with US 64 and turn Left. 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 Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 10/21/2020 Entry Time 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: ▪ Treatment Flow Measurement -Effluent ▪ Treatment Flow Measurement -Water Use Records ▪ Treatment Activated Sludge ▪ Treatment Influent Pump Station ▪ Treatment Flow Measurement ▪ Wells (See attachment summary) Exit Time: 01:30PM Owner : Mhc Tt Inc Facility: Forest Lake Preserve 192 Thousand Trails Dr Advance NC 27006 Phone: 312-279-1400 Enterance to campground Phone: 336-996-2841 Phone: 336-776-9701 Inspection Type: Compliance Evaluation ▪ Treatment Flow Measurement -Influent ▪ Treatment ▪ Treatment Sludge Storage/Treatment ▪ Treatment Clarifiers ▪ Treatment Return pumps ▪ Miscellaneous Questions ▪ Record Keeping ▪ End Use -Irrigation ▪ Treatment Disinfection ▪ Storage Page 1 of 7 Permit: WQ0004972 Owner - Facility: Mhc Tt Inc Inspection Date: 10/21/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On October 21, 2020, 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 persons Justin Henderson and Caitlyn Caudle. Accompanying DWR staff during this inspection was Mr. Glenn Price, ORC of R&A Labs, Mark McKeithan, Senior Regional Manager, Sylvia Austin, Regional Manager, and Tracy Overdurf, Resort Manager of Forest Lake Preserve. The facility was found to be non -compliant Permit WQ0004972. The following violations require your immediate attention and action: 1) The subject permit has an expiration date of March 31, 2021. Permit Condition I. (1) requires that the Permittee shall request renewal of this permit on official Division forms, no less than six months prior to expiration of the permit. To date, an official request for permit renewal has not been received by the Division. 2) Review of the facility's May 2020 Form NDAR, a required monthly reporting form utilized to track irrigation events, indicated that irrigation of 33,984 gallons occurred on May 21, 2020. This irrigation event followed a documented rain event occurring on May 20, 2020, consisting of a reported rainfall total of 5.6 inches. This constitutes a violation of Permit Condition III. (5) which prohibits irrigation during inclement weather or when the ground is in a condition that will cause ponding or runoff. 3) The Notice of Intent to Enforce (NOI) dated December 5, 2019, that was issued by this Office, following the previous compliance evaluation inspection, performed on November 21, 2019, brought the concern described below to your attention as well as a request to evaluate the described discrepancy via system calibration and wettable acreage determination: 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)] At the time of this inspection, the ORC provided calibration and wettable acreage calculation results generated as part of a calibration event that was conducted on January 14, 2020, by Research and Analytical Laboratories. These calculations suggested that the wettable acreage utilized by the subject irrigation system totals 3.42 acres. These calculations support confirmation that the reported irrigation acreage of 7 acres is inaccurate, as well as the fact that application rates (both hourly and cumulative annual) are currently being underreported. Permit Condition IV. (5) states: The Permittee shall maintain adequate records tracking the amount of effluent irrigated. Application rates shall immediately be calculated based upon the wettable acreage of 3.42 acres as determined by the most recent calibration event conducted on 1/14/2020, and revised cumulative annual totals for the previous 12 months be submitted to this office within 90-days of receipt of this Notice. 4) A Residual Management Plan (RMP) in accordance with Permit Condition III. (10) reportedly did not exist at the time of this inspection. Immediately generate and maintain a RMP pursuant to 15A NCAC 02T .0508. In addition to the above described violations, the following items of concern also require your attention and action: a.) Reportedly per the ORC, one spray head had been "offline/inactive" for the past year. This was done to prevent runoff fron occurring, as some of the ground surface within reach of this spray head had been converted to an access road thus inhibiting proper assimilation of effluent. If this operation is to be continued, then ensure wettable acreage determination and subsequent calculation and reporting of application rates is representative of this "lost" acreage. b.) There was no back-up power available, at the facility, to supply power to any of the seven lift stations nor to the Page 2 of 7 Permit: WQ0004972 Owner - Facility: Mhc Tt Inc Inspection Date: 10/21/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine 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. Page 3 of 7 Permit: WQ0004972 Owner - Facility: Mhc Tt Inc Inspection Date: 10/21/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Activated Sludge Drip, LR Single Family Spray, LR Single Family Drip Recycle/Reuse Infiltration System Reuse (Quality) Activated Sludge Spray, HR Activated Sludge Spray, LR Lagoon Spray, LR Treatment Are Treatment facilities consistent with those outlined in the current permit? Do all treatment units appear to be operational? (if no, note below.) Yes No NA NE Yes No NA NE • ❑ ❑ ❑ Comment: wettable acreage has been determined to be 3.42 acres as part of the system calibration event. This represents a discrepancy between the area indicated by the permit of 9 acres. This would indicate that applicaiton rates are under -reported due to this discrepancy. Treatment Influent Pump Station Is the pump station free of bypass lines or structures? Is the general housekeeping acceptable? Are all pumps present? Are all pumps operable? Are floats/controls operable? Are audio and visual alarms available? Are audio and visual alarms operational? # Are SCADA/Telemetry alarms required? Are SCADA/Telemetry available? Are SCADA/Telemetry operational? Comment: Treatment Flow Measurement -Influent Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? Comment: Yes No NA NE • ▪ ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page4of7 Permit: WQ0004972 Owner - Facility: Mhc Tt Inc Inspection Date: 10/21/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine Treatment Flow Measurement -Water Use Records Is water use metered? Are the daily average values properly calculated? Comment: Treatment Flow Measurement -Effluent Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? Comment: ORC manually records flow. Treatment Activated Sludge 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: 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? Yes No NA NE ❑ ❑ ❑ • ❑ ❑ ❑ • Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Significant amount of floating solids was observed in clarifier indicating the sludge/scum trough between aeration basin and clarifier may need to be cleaned more often, however the effluent appeared to be clear. Treatment Return pumps Are they in place? Are they operational? Comment: Treatment Sludge Storage/Treatment Is the aeration operational? Yes No NA NE Yes No NA NE • ❑ ❑ ❑ Page5of7 Permit: WQ0004972 Owner - Facility: Mhc Tt Inc Inspection Date: 10/21/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine Is the aeration pattern even? If required, are Sanitary "Ts" present in tankage? Comment: Treatment Disinfection 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: Record Keeping 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? Are annual soil reports available? • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑• ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑•❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑•❑ ❑ ❑•❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page6of7 Permit: WQ0004972 Owner - Facility: Mhc Tt Inc Inspection Date: 10/21/2020 Inspection Type : Compliance Evaluation Reason for Visit: Routine # 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? Comment: End Use -Irrigation Are buffers adequate? 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? ❑ ❑•❑ ❑ ❑•❑ ❑ ❑•❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑• ❑ ❑ ❑• • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: Wettable acreage determined by most recent calibration event indicated a total of 3.42 acres as opposed to that included in permit of 9 acres or the previously reported 7 acres. Page 7 of 7