WQ0015931_Compliance Evaluation Inspection_20210405

ROY COOPER
Governor
DIONNE DELLI-GATTI
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
Mr. Gavin Arsenault, General Manager
Trump National Golf Club Charlotte, LLC
120 Meeting House Square
Mooresville, North Carolina 28117
Dear Mr. Arsenault:
April 5, 2021
via email
Subject: Non -Discharge Permit Inspection
TNGC - Permit No.: WQ0015931
Reclaimed Water Irrigation
Iredell County
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on March 5'
2021, which included the pump station, reclaimed water treatment, irrigation sites and a records
review.
The MRO and Central Office would like to thank the Tri-County Wastewater (TCW) staff, Mr.
Brandon Long and Mr. Brian Stephens for their time during the site inspection. The operators
have managed to keep the system treatment functional; however, the age of the facility is showing
with rust in critical areas of the plant, which if unchecked could lead to functional and potential
safety concerns:
• The bar screen and grit removal support beams (also supports grating that operators walk on
every visit to access and maintain the plant) and aeration fixtures are rusted and need
assessment for repair/replacement. Both of these locations are critical to appropriate
treatment.
Left: Support beams under walkway at head of the plant. Right: Shows corrosion at aeration fixtures.
1:tE
Department of Environmental (Wally
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

• Both pumps were replaced at the EQ Basin, but the full supports were rusted out, so the rails
were removed and support redesigned for the new pumps; in addition, there is a hole in the
wall between the EQ Basin and Digester train that is currently off-line. If this train of the system
were utilized a system bypass would occur when Basin volume was approximately 18 inches
below the top of the tank.
• Most tanks need rehabilitation for rust removal, potential repairs and repainting. Per previous
inspections/conversation the operators were in discussion with TNGC for a complete plant
replacement so many repairs were postponed; however, the plant replacement was postponed.
MRO staff recommends consultation with your engineering and installation contractors to
adequately assess repairs vs. replacement and establishment of a timeline for the decided
course of action.
Additional items to address to maintain overall compliance:
• TCW is to establish a timeline for completion of the field lab certification for proposed pH
and Total Residual Chlorine, and/or plans for currently certified contractors to assist until
certification is completed. There have been legitimate, unforeseen delays in the process;
however, Permit Condition IV.2 requires final effluent parameters be analyzed by a
certified lab, for all facilities TCW provides this service for, so this item should be a priority.
Per on -site discussion, lab certified commercial field operators may be located on our
DWR Lab website via this link (scroll table to "Field Commercial"):
https://deq. nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-
home-paqe/laboratory-certification-branch/certified-laboratory-listings
• Some irrigation fields need maintenance. Drainage feature(s) have developed which are
likely leading to runoff and need to be filled with clean soils and/or regraded. Many downed
trees, uprooted stumps and underbrush need removal and holes filled. Mulching of irrigation
fields is no longer required by permit conditions as it may clog emitters and inhibit dripline
assessment. Some permittees have opted to continue using a minimal layer of mulch as
preventative measure from animals chewing on the driplines. MRO staff will leave it to the
permittee and operator to determine if/when a mulch layer is beneficial, but the mulch
application should be minimal and not bury the driplines.
• Telemetry at the pump station and the visual alarm at the WWTP were inoperable at the
time of inspection. Per email from Mr. Long on March 18th, 2021 the telemetry was repaired
and lab data requested for the additional records review was received by MRO staff. The
light bulb should be replaced at the WWTP alarm, if not already addressed.
Lab data reviewed supported entry in the corresponding NDMRs. Daily WWTP operations
logs were reviewed onsite, a couple items were discussed for addition including notation in
the comments for all maintenance items (ex: recent pump replacements, dripline repairs,
etc.) A separate log is maintained for any contractor residuals cleanouts at the collection
system and WWTP. Per records the collection system is likely due for cleanout, as the
Grease Traps were last pumped in May 2018 and the Lift Station in July 2019. One lid was
sealed in place and needs to be repaired for access.
There should be a separate maintenance, visitation log for pump station checks to include
date, time of visit, initials of person inspecting, notation of gas volume in generator and
pump(s) run-times, etc. Mr. Long stated all logs are kept at the WWTP office; however,
when telemetry is not functional, the log should be located at the pump station where TNGC
staff will have access for weekend documentation.

You may contact Maria Schutte via email ([e-mail]) or phone [phone]) with
any questions about this report or your permit.
for
Sincerely,
1—DocuSigned by:
`—A14CC681 AF27425...
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment: WQ0015931 Compliance Inspection Report
CC: Brandon Long, ORC, Tri-County Wastewater (email)
Tim Bannister, BU-ORC and Signature Authority, Tri-County Wastewater (email)

Compliance Inspection Report
Permit: WO0015931
SOC:
County: Iredell
Region: Mooresville
Contact Person: Gavin Arsenault
Directions to Facility:
System Classifications: SI, WW2,
Primary ORC: Charles Brandon Long
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 03/05/2021
Primary Inspector: Maria Schutte
Secondary Inspector(s):
Effective: 06/01/18 Expiration: 05/31/23
Effective: Expiration:
Title: General Manager
Entry Time 09:34AM
Reason for Inspection: Routine
Permit Inspection Type: Reclaimed Water
Facility Status: In Compliant ❑ Not Compliant
Question Areas:
▪ Treatment Flow Measurement -Effluent
1. Treatment Flow Measurement -Water
Use Records
▪ Treatment Filters
▪ End Use -Irrigation
▪ Treatment Disinfection
▪ Storage
(See attachment summary)
DocuSigned by:
-A14CC681AF27425...
Owner : Tngc Charlotte LLC
Facility: Trump National Golf Club Charlotte WWTP
1954 Brawley School Rd
Certification: 991385
Mooresville NC 28117
Exit Time: 01:22PM
Phone:
Phone: [phone]
Phone: [phone]
Inspection Type: Compliance Evaluation
▪ Treatment Flow Measurement -Influent
▪ Treatment
▪ Record Keeping
▪ Treatment Influent Pump Station
▪ Treatment Flow Measurement
▪ End Use -Reuse
4/5/2021
▪ Miscellaneous Questions
▪ Treatment Barscreen
▪ Treatment Lagoons
▪ Treatment Clarifiers
▪ Treatment Return pumps
▪ Standby Power
Page 1 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on March 5th, 2021, which included the
pump station, reclaimed water treatment, irrigation sites and a records review.
The MRO and CO would like to thank the Tri-County Wastewater (TCW) staff, Mr. Brandon Long and Mr. Brian Stephens for
their time during the site inspection. The operators have managed to keep the system treatment functional; however, the
age of the facility is showing with rust in critical areas of the plant, which if unchecked could lead to functional and potential
safety concerns:
* The bar screen and grit removal support beams (also supports grating that operators walk on every visit to access and
maintain the plant) and aeration fixtures are rusted and need assessment for repair/replacement. Both of these locations
are critical to appropriate treatment.
* Both pumps were replaced at the EQ Basin, but the full supports were rusted out, so the rails were removed and support
redesigned for the new pumps; in addition, there is a hole in the wall between the EQ Basin and Digester train that is
currently off-line. If this train of the system were utilized a system bypass would occur when Basin volume was
approximately 18 inches below the top of the tank.
* Most tanks need rehabilitation for rust removal, potential repairs and repainting. Per previous inspections/conversation the
operators were in discussion with TNGC for a complete plant replacement so many repairs were postponed; however, the
plant replacement was postponed. MRO staff recommends consultation with your engineering and installation contractors
to adequately assess repairs vs. replacement and establishment a timeline for the decided course of action.
Additional items to address to maintain overall compliance:
* TCW is to establish a timeline for completion of the field lab certification for proposed pH and Total Residual Chlorine,
and/or plans for currently certified contractors to assist until certification is completed. There have been legitimate,
unforeseen delays in the process; however, (Permit Condition IV.2. requires final effluent parameters be analyzed by a
certified lab, for all facilities TCW provides this service for, so this item should be a priority. Per on -site discussion, lab
certified commercial field operators may be located on our DWR Lab website via this link (scroll table to "Field Commercial"):
https://deq.nc.gov/about/divisions/water-resources/water-resources-data/water-sciences-home-page/laboratory-certification-h
ranch/certified-laboratory-listings
* Some irrigation fields need maintenance. Drainage feature(s) have developed which are likely leading to runoff and need to
be filled with clean soils and/or regraded. Many downed trees, uprooted stumps and underbrush need removal and holes
filled. Mulching of irrigation fields is no longer required by permit conditions as it may clog emitters and inhibit dripline
assessment. Some permittees have opted to continue using a minimal layer of mulch as preventative measure from animals
chewing on the driplines. MRO staff will leave it to the permittee and operator to determine if/when a mulch layer is
beneficial, but the mulch application should be minimal and not bury the driplines.
* Telemetry at the pump station and the visual alarm at the WWTP were inoperable at the time of inspection. Per email from
Mr. Long on March 18th, 2021 the telemetry was repaired and lab data requested for the additional records review was
received by MRO staff. The light bulb should be replaced at the WWTP alarm, if not already addressed.
Lab data reviewed supported entry in the corresponding NDMRs. Daily WWTP operations logs were reviewed onsite, a
couple items were discussed for addition including notation in the comments for all maintenance items (ex: recent pump
replacements, dripline repairs, etc.) A separate log is maintained for any contractor residuals cleanouts at the collection
system and WWTP. Per records the collection system is likely due for cleanout, as the Grease Traps were last pumped in
May 2018 and the Lift Station in July 2019. One lid was sealed in place and needs to be repaired for access.
There should be a separate maintenance, visitation log for pump station checks to include date, time of visit, initials of
Page 2 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
person inspecting, notation of gas volume in generator and pump(s) run-times, etc. Mr. Long stated all logs are kept at the
WWTP office; however, when telemetry is not functional, the log should be located at the pump station where TNGC staff will
have access for weekend documentation.
You may contact Maria Schutte via email ([e-mail]) or phone [phone]) with any questions about
this report or your permit.
Page 3 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Infiltration System
Lagoon Spray, LR
Single Family Spray, LR
Activated Sludge Spray, HR
Activated Sludge Spray, LR
Activated Sludge Drip, LR
Recycle/Reuse
Single Family Drip
Reuse (Quality)
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
• 000
■ ❑❑❑
Comment: See summary section. WWTP is rusted and needs assessment for repairs vs. replacement.
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?
Yes No NA NE
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• ❑ ❑ ❑
Comment: At the time of inspection there was a communication error with the Pump Station Telemetry
system. Visual alarm was working. Audible alarm was on a 30 min delay. Returned to hear it
operating after remaining inspection was completed. Plant operator notified facility manager of
the situation to provide daily pump station inspections until telemetry communication was
repaired. The repair was completed and reported via email on 3-18-21 to MRO staff. The
WWTP is not required & does not have telemetry. The visual alarm on the system was not
working and noted for bulb replacement by the plant operator.
Treatment Flow Measurement -Influent
Is flowmeter calibrated annually?
Is flowmeter operating properly?
Does flowmeter monitor continuously?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑❑❑
Page 4 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Does flowmeter record flow? ❑ • ❑ ❑
Does flowmeter appear to monitor accurately? • ❑ ❑ ❑
Comment: Manual read of plant flowmeter. Flow and turbidity meters were calibrated 9-29-2020.
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: The Effluent flow is the Irrigation to each field.
Standby Power
Is automatically activated standby power available?
Is generator tested weekly by interrupting primary power source?
Is generator operable?
Does generator have adequate fuel?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Comment: MRO staff checked both generators for fuel. Gauges appeared accurate and both were 3/4s or
more full. Plant staff does not operate the generators. The Pump station generator is set for
automated weekly tests every Monday when the Golf Club is closed. The plant generator is
maintained and tested by another contract company.
Treatment Barscreen
Is it free of excessive debris?
Is disposal of screenings in compliance?
Are the bars spaced properly?
Is the unit in good condition?
Yes No NA NE
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▪ ❑ ❑ ❑
Comment: Support beams at head of the plant are rusted and should be assessed for repair/replacement.
These support beams hold the plant grates (walkways) in place & also support the bar screen
unit.
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?
Yes No NA NE
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Page 5 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Is the sludge blanket at an acceptable level?
Is the effluent from the clarifier free of excessive solids?
• •
❑ ❑ ❑
❑ ❑ ❑
Comment: Appears fats still get through the system and build up around the weir. Plant operator says wher
he removes all build-up, it adversely impacts his effluent. Keeping a mini -wall of build-up
in -place, seems to capture/collect the fat/scum in that location and prevents it from entering the
effluent. It is recommended this situation be assessed, when the rust is evaluated to determine
a more appropriate fix for proper fat/scum removal.
Treatment Return pumps
Are they in place?
Are they operational?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: Most pumps at the plant were replaced last year. The return pump at the 5-day upset pond is not
operable. Plant operator periodically returns volume using plant pumps to create reverse flow,
until that pump is also replaced.
Treatment Filters
Is the filter media present?
Is the filter media the correct size and type?
Is the air scour operational?
Is the scouring acceptable?
Is the clear well free of excessive solids?
Is the mud well free of excessive solids and filter media?
Does backwashing frequency appear adequate?
Yes No NA NE
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▪ ❑ ❑ ❑
Comment: Sludge judge of mud well water was very cloudy throughout volume. Settled solids were not
visible. Clear well was clear. Sand filter backwashed manually twice per week, per previous
inspection reports.
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?
Yes No NA NE
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Page 6 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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: UV system has not operated well. Using chlorine tablets. Received a design and quote from
their engineer and a system installer to add an in -ground UV module between the chlorine
contact chamber and the 5-day upset pond. They hope to return to UV and eliminate use of
chlorine tablets (except for backup). There may not be a need for them to acquire field
certification for Total Residual Chlorine.
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?
# 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?
❑ ❑ • ❑
❑ ❑ • ❑
Yes No NA NE
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Page 7 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Comment: This Reclaimed Permit does not require groundwater monitoring. To address COVID concerns,
records were reviewed outside and additional items requested via email. One month of data
was reviewed onsite via laptop computer and two additional months were reviewed upon email
receipt 3-18-21. MRO staff recommended maintenance repairs be noted on daily log sheets.
Also need to keep weekly log sheets to document pump station visits and these should include
date, time of visit, initials of inspector, pump run times, gas volume in generator, etc. Logs show
digester pumped in Oct 2020, Lift Station July 2019 & grease traps May 2018. Grease traps and
pump station should be scheduled for cleanout.
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
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O 0110
Comment: Per previous inspection report, area served by a community well about 800 ft from WWTP.
Groundwater monitoring is not required.
End Use -Reuse
Is the acreage in the permit being utilized?
Does the acreage specified in the permit correspond to the measured acreage at the site?
Are all essential units provided in duplicate?
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?
Does the turbidity meter have recording capabilities?
Yes No NA NE
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Page 8 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Is all flow diverted at the appropriate times?
Is all upset wastewater diverted from reuse storage unit?
Is all upset wastewater treated, retreated, or disposed of acceptably?
Is upset wastewater treated prior to discharge to irrigation storage?
Is public access restricted from irrigation area during active site use?
If golf course, is a sign posted in plain sight on the club house?
Is the cover crop acceptable?
Are buffers adequate?
Is the site free of ponding/runoff?
Is the acreage in the permit being utilized?
Is the application equipment acceptable?
Is the application area free of limiting slopes?
How close is the closest water supply well?
Are any supply wells within the CB?
Are any supply wells within 250' of the CB?
Is municipal water available in the area?
Are GW monitoring wells required?
Are GW monitoring wells located properly w/ respect to RB and CB?
Are GW monitoring wells properly constructed, including screened interval?
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Comment: Signs are posted, but application fields are not fenced off. The spray system at the driving range
continues to utilize another water source for irrigation (well or lake). The driving range acreage is
permitted and plumbed for spray irrigation, but has never been utilized for the reclaimed system.
Signage would need to be placed at the driving range if this area is to be utilized for reclaimed
distribution.
Some application fields need clean-up for downed trees, undergrowth and repair of holes
created by uprooted trees and newly formed drainage features to prevent ponding and runoff. It
just rained the day before, so driplines were not assessed. (See summary and cover letter for
comments.)
STORAGE - Reclaimed v
Treatment Lagoons
Lagoon Type
Primary/Secondary
Influent structure
Banks/berms (seepage and erosion)
Vegetation (excessive vegetation on banks/berms)
Liner
Liner Type
Yes No NA NE
None
Primary
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❑ • ❑ ❑
• ❑ ❑ ❑
Full, synthetic
Page 9 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Baffles/curtains
Freeboard Marker
Required freeboard
• ❑ ❑ ❑
2
Feet
Actual freeboard 5.2
Feet
Are increments clearly marked on gauge at adequate intervals? • ❑ ❑ ❑
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall? ❑ ❑ ❑ •
No Evidence of overflow ❑ • ❑ ❑
Acceptable color • ❑ ❑ ❑
Floating mats • ❑ ❑ ❑
Excessive solids buildup ❑ ❑ ❑ •
Aerators/mixers ❑ ❑ • ❑
Effluent structure ❑ ❑ • ❑
Lagoon cover ❑ ❑ • ❑
UPSET - 5-day upset por
Treatment Lagoons Yes No NA NE
Lagoon Type None
Primary/Secondary Secondary
Influent structure • ❑ ❑ ❑
Banks/berms (seepage and erosion) ❑ • ❑ ❑
Vegetation (excessive vegetation on banks/berms) ❑ • ❑ ❑
Liner • ❑ ❑ ❑
Liner Type Full, synthetic
Baffles/curtains ❑ El • El
Freeboard Marker • ❑ ❑ ❑
Required freeboard 2
Feet
Actual freeboard 5.2
Feet
• ❑ ❑ ❑
Are increments clearly marked on gauge at adequate intervals?
Page 10 of 11

Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC
Inspection Date: 03/05/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
No Evidence of overflow
Acceptable color
Floating mats
Excessive solids buildup
Aerators/mixers
Effluent structure
Lagoon cover
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
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