WQ0013398_Compliance Evaluation Inspection_20210916

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
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ROY COOPER
Governor
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ELIZABETHS.BISERr
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Secretary
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S. DANIEL SMITH
NORTH CARouNA
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Ennrunmentaf Quality
October 01, 2021
Tim Tilma, Utility Manager
904 Georgetown Treatment Plant LLC
800 Sandpiper Club Drive
Sunset Beach, NC 28468
SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2021-PC-0495
Permit No. WQ0013398
Sandpiper Bay WWTP
Brunswick County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Sandpiper Bay WWTP on
September 16, 2021. This inspection was conducted to verify that the facility is operating in compliance with the
conditions and limitations specified in Non -discharge Permit No. WQ0013398. A summary of the findings and
comments noted during the inspection are provided in the enclosed copy of the inspection report.
The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Wilmington
Regional Office. The following deficiencies or items were noted during the inspection:
Inspection Area Description of Deficiency
Treatment Activated Sludge Provide plan for taking an aeration basin or pair down for repair & cleaning and cleaning
& any needed repairs to subordinate clarifier.
Treatment Barscreen Provide a plan and timetable for repair or replacement of the splitter box portion or the entire
structure.
Treatment Filters Provide a plan and timetable for repair of the automatic backwashing function, repair of air
scour leaks, possible leak between unit(s) & EQ Basin noted in engineering report,
replacement of media & any needed repairs on underdrains.
Treatment Influent Pump Notify the inspector when the remaining repairs on the influent pump station are complete
along with the exposed electrical junction boxes.
Please provide the above plans within 30 days of your receipt of this report & Notice. The Division of Water
Resources may pursue enforcement action for failing to properly operate and maintain treatment unit components
and any additional violations of State law. To prevent further action, carefully review these deficiencies and
address the causes of non-compliance to prevent the recurrence of similar situations.
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DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water Quality
Regional Operations Section in the Wilmington Regional Office at 910-796-7215.
Sincerely,
EDocuSigned by:
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7F141E73B6F3456...
Tom Tharrington, Asst. Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
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DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Compliance Inspection Report
Permit: WQ0013398 Effective: 10/21/20 Expiration: 01/31/27 Owner : 904 Georgetown Treatment Plant LLC
SOC: Effective: Expiration: Facility: Sandpiper Bay WWTP
County: Brunswick 7407 Hermitage Ln
Region: Wilmington
Sunset Beach NC 28468
Contact Person: Blair C Tanner Title: Corporate Manager Phone: [phone]
Directions to Facility:
System Classifications: SI, WW2,
Primary ORC: Sunny Wright Certification: 28813 Phone: [phone]
Secondary ORC(s):
Wilburn Allen Williams 15664 910-454-0512
On -Site Representative(s):
On -site representative Timothy P Tilma 910-579-9120
On -site representative Sunny Wright 910-880-4178
Related Permits:
WQCSD0526 904 Georgetown Treatment Plant LLC - Sandpiper Bay Deemed Collection
System
Inspection Date: 09/16/2021 Entry Time 10:OOAM Exit Time: 11:45AM
Primary Inspector: Dean Hunkele Docusigned by: Phone: [phone]
Secondary Inspector(s): EE 101112021
E1D9294C4D3746E...
DocuSigned by:
Reason for Inspection: Routine
-Tom- —N..cr, o, Inspection Type: Compliance Evaluation
Permit Inspection Type: Reclaimed Wate
7F141E73B6F3456...
Facility Status: ❑ Compliant Not
Compliant
Question Areas:
Treatment Flow Measurement -Effluent
Treatment Flow Measurement -Influent
Miscellaneous Questions
Treatment Flow Measurement -Water
Treatment
Treatment Barscreen
Use Records
Treatment Filters
Record Keeping
Treatment Lagoons
Treatment Activated Sludge
Treatment Sludge Storage/Treatment
Treatment Influent Pump Station
Treatment Clarifiers
Treatment Disinfection
Treatment Flow Measurement
Treatment Return pumps
Storage
End Use -Reuse
Standby Power
(See attachment summary)
Page 1 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Some repair issues noted during previous site visits are finally beginning to take place with new electrcial panels installed for
the influent pump station & the main plant, but several electrical junction boxes and electrical controls for filter backwashing
remain non-functional or exposed to the elements due to corrosion representing a significant electricution safety issue.
Some metal work for connecting basins was ongoing during the visit.
The Division is in possession of an updated, comprehensive engineering report from May 2019 commissioned by the Utility
that analyzed and evaluated the entire treatment facility using a previous report from the same firm in October 2009. The
highlights/recommendations of that report include the following:
1. Replace pump rails in influent pump station, upgrade its panel, and repair back-up generator.
2. Mentions reviewing the capacity of the facility's blower system which is beyond the inspector's ability to comment, but
no issues were detected during the very limited operation of the blowers while present. Blowers were replaced or
soundproofing added following a complaint back in April 2015.
3. Mentions an air leak in one of the clarifier returns needing repair; this was not observed during the limited air use while
on -site. If still present it should be repaired when the basins feeding it are taken down for cleaning, inspection, and repair on
air delivery & diffusers.
4. Mentions a leak in the common wall between the EQ Basin and filter needing repair; this was not observed, thus either it
has been repaired (unlikely) or is significantly below the waterline or not easily observed with grating in place. If still present,
this would allow untreated wastewater to enter the filter & bypass treatment plus lead to increased fouling of the filter's
surface. The filter should be cleaned & inspected for additional needed repairs and have its media replaced when the leak is
repaired; operator indicates the last O&M on filter occurred about 9 years ago.
5. Mentions the same observations made during this inspection on the condition of the chlorine contact basin feed and
chlorinators.
6. Mentions replacement of the treatment facility's main control panel which has been completed and repair of electrical
junction boxes which were noted during this and the previous inspection
Page 2 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398
Inspection Date: 09/16/2021
Owner - Facility:904 Georgetown Treatment Plant LLC
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, HR
❑
Activated Sludge Spray, LR
❑
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Single Family Drip
❑
Reuse (Quality)
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: Operational issues with units will be discussed in those sections and/or in the summary.
Treatment Influent Pump Station Yes No NA NE
Is the pump station free of bypass lines or structures? 0 ❑ ❑ ❑
Is the general housekeeping acceptable? ❑ ❑ ❑
Are all pumps present? ❑ ❑ ❑
Are all pumps operable? ❑ ❑ ❑
Are floats/controls operable? ❑ ❑ ❑
Are audio and visual alarms available? 0 ❑ ❑ ❑
Are audio and visual alarms operational? ❑ ❑ ❑
# Are SCADA/Telemetry alarms required? ❑ ❑ ❑
Are SCADA/Telemetry available? ❑ ❑ ❑
Are SCADA/Telemetry operational? ❑ 0 ❑ ❑
Comment: The pump rails remain broken inside the wetwell and are slated to be replaced. The electrical
panel was recently replaced, but the telemetry component is on back order due to pandemic
supply issues. Until telemetry is available, the facility should be inspected daily to ensure
station is operating and plant is powered in some manner.
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?
Yes No NA NE
❑❑■❑
Page 3 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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? ❑ ❑ ❑
Is flowmeter operating properly? ❑ ❑ ❑
Does flowmeter monitor continuously? ❑ ❑ ❑
Does flowmeter record flow? ❑ ❑ ❑
Does flowmeter appear to monitor accurately? ❑ ❑ ❑
Comment: Meter was calibrated on 9-29-2021 after post inspection request for previous calibration report:
no info provided on previous date.
Standby Power Yes No NA NE
Is automatically activated standby power available? 0 ❑ ❑ ❑
Is generator tested weekly by interrupting primary power source? ❑ ❑ ❑
Is generator operable? ❑ ❑ ❑
Does generator have adequate fuel? ❑ ❑ ❑
Comment: Generator was recently repaired, but the unit is showing its age and effects of exposure to the
elements. If replaced, it is recommended that the generator be covered to limit its exposure
and help prolong its life.
Treatment Barscreen Yes No NA NE
Is it free of excessive debris? 0 ❑ ❑ ❑
Is disposal of screenings in compliance?
Are the bars spaced properly?
Is the unit in good condition?
❑❑❑■
Comment: Screenings are collected in buckets and assumed to be disposed of off -site since no dumpster
is present on the site. The bar spacing is adequate for solids handling pumps which is what
the sewer system & influent pump station supposedly utilize. The unit is in fair condition but is
all connected with the splitter box which is in poor condition with the inability to adjust basin
feed weirs and excess overflow from pump feed rate. Based on a design flow of 150K/day, the
feed rate into the aeration basins should be approx. 104-qpm and the permit renewal indicates
the installed pumps are 156-qpm, thus the overlow needs to be functional & adjustable. The
combination unit is steel and needs to be replaced with a corrosion resistant material ideally
ctninlacc ctacl
Treatment Activated Sludge
Is the aeration mechanism operable?
Is the aeration basin thoroughly mixed?
Is the aeration equipment easily accessed?
Yes No NA NE
■❑❑❑
■❑❑❑
❑■❑❑
Page 4 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is Dissolved Oxygen adequate? ❑ ❑ ❑
Are Settleometer results acceptable? ❑ ❑ ❑
Is activated sludge an acceptable color? 0 ❑ ❑ ❑
Comment: The diffusers appear to have a single header thus accessing the diffusers would require
draining the tankage completely for inspection and maintenance which would require planning
and possible use of a temporary frac tank for excess influent if the remaining basins in
operation & EQ basin is insufficient. Flows are at approx 40% of installed design which will
make taking half of plant (2 basins) down without overburdening the remaining half more
difficult especially if flows increase, thus any work needed with a basin(s) off-line should be
planned soon. If functional valving between the paired basins is available, then it may be
possible to isolate each tank and use temporary pumps to move flow from tank #1 to its
dedicated clarifier.
Treatment Clarifiers
Yes No NA NE
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:
Treatment Return pumps Yes No NA NE
Are they in place? 0 ❑ ❑ ❑
Are they operational? 0 ❑ ❑ ❑
Comment:
Treatment Filters
Yes No NA NE
Is the filter media present?
0
❑ ❑ ❑
Is the filter media the correct size and type?
❑
❑ ❑
Is the air scour operational?
0
❑ ❑ ❑
Is the scouring acceptable?
❑
0 ❑ ❑
Is the clear well free of excessive solids?
0
❑ ❑ ❑
Is the mud well free of excessive solids and filter media?
0
❑ ❑ ❑
Does backwashing frequency appear adequate?
❑
0 ❑ ❑
Comment: The filter has to be manually backwashed as the electrical components allowinq the auto
backwashing function needs replacement/repair. Prior to operating the scour manually, the
filter surface had considerable solids present and the cycle appeared unable to fully clean it
with a single cycle, thus ideally the filter should function automatically with manual scour
periodically used if deemed necessary. The air delivery appeared uneven and at least one
leak was observed: the operator stated filter hasn't been cleaned and inspected in at least 9
years, thus it appears time to do so which requires planning and adequate space in the 5-Day
Upset Pond or a Frac tank to accept flow that might fail turbidity.
Page 5 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Treatment Sludge Storage/Treatment Yes No NA NE
Is the aeration operational? ❑ ❑ ❑
Is the aeration pattern even? ❑ ❑ ❑
If required, are Sanitary "Ts" present in tankage? ❑ ❑ ❑
Comment: Plenty of space to waste was available.
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 steel junction box and piping feeding the tablet chlorinators are heavily corroded and need
to be replaced soon. Additionally, the plastic tablet chlorinators are becoming degraded and
are cracked/broken where they connect to the junction box piping,
thus will need to be
replaced when the junction box is replaced. This work will likely
be needed within the next
couple of years unless it fails prior to that time.
Record Keeping
Yes No NA NE
Is a copy of current permit available?
0
❑ ❑ ❑
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)?
❑
❑ 0 ❑
Are all samples analyzed for all required parameters?
❑ ❑ ❑
Page 6 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Are there any 2L GW quality violations?
❑
❑ 0 ❑
Is GW-59A certification form completed for facility?
❑
❑ 0 ❑
Is effluent sampled for same parameters as GW?
❑
❑ 0 ❑
Do effluent concentrations exceed GW standards?
❑
❑ 0 ❑
Are annual soil reports available?
❑
❑ 0 ❑
# Are PAN records required?
❑
❑ 0 ❑
# Did last soil report indicate a need for lime?
❑
❑ 0 ❑
If so, has it been applied?
❑
❑ 0 ❑
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?
❑
❑ 0 ❑
Are Operational and Maintenance records present?
0
❑ ❑ ❑
Were Operational and Maintenance records complete?
❑
❑ 0 ❑
Has permittee been free of public complaints in last 12 months?
❑
❑ ❑
Is a copy of the SOC readily available?
❑
❑ 0 ❑
No treatment units bypassed since last inspection?
❑
❑ ❑
Comment: Records/invoices for recent repairs were available.
End Use -Reuse
Yes No NA NE
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?
❑ ❑ ❑
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?
❑
❑ ❑
Page 7 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
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? 0 ❑ ❑ ❑
Are GW monitoring wells required? ❑ ❑ 0 ❑
Are GW monitoring wells located properly w/ respect to RB and CB? ❑ ❑ 0 ❑
Are GW monitoring wells properly constructed, including screened interval? ❑ ❑ 0 ❑
Comment: There is a simple sign about use of reclaimed water where green fees are paid; no further info
provided, but utility should have an informational sheet for residents or golfers about reclaimed
wastewater. The disposal volume was reduced with last renewal to reflect the hydraulic
capacity of the only approved & utilized golf course holes, thus additional disposal will need to
be added with any treatment capacity expansion.
IRRIGATION POND 1 -
Storacte Yes No NA NE
Storage Type? Pond
Storage amount?
# At what point is side -stream wastewater returned to treatment?
Is there a Spill Control Plan?
❑
❑ ❑
Aerated or Mixed?
NONE
If aeration is present, is it adequate?
❑
❑ ❑
If present, are diffusers cleaned regularly?
❑
❑ ❑
Is influent structure acceptable?
❑ ❑ ❑
Are banks/berms free of seepage and erosion?
❑
❑ ❑
Are banks/berms free of excessive vegetation?
❑
❑ ❑
Is pond lined?
❑
❑ ❑
Liner Type
Is liner acceptable?
❑
❑ ❑
Are baffles/curtains acceptable?
❑
❑ ❑
Does the pond have a freeboard marker?
❑ ❑ ❑
Required freeboard?
2
Feet
Actual freeboard?
4
Feet
Is there suitable grassed vegetation?
0
❑ ❑ ❑
Page 8 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Is the vegetation maintained? 0 ❑ ❑ ❑
Is the area free of excessive weeds and/or woody species? 0 ❑ ❑ ❑
Is the area free from signs of overflow? 0 ❑ ❑ ❑
Is color acceptable? 0 ❑ ❑ ❑
Are floating mats acceptable? 0 ❑ ❑ ❑
No excessive buildup of solids? ❑ ❑ 0 ❑
Are aerators/mixers acceptable? ❑ ❑ 0 ❑
Is effluent structure acceptable? ❑ ❑ 0 ❑
If present, is pond cover acceptable? ❑ ❑ 0 ❑
Comment: Some minor erosion on inner wall of berm separating 5-Day pond from this one. Trees and
brush beginning to overhang pond adding to input of deritus into it. Effluent withdrawal
structural supports damaged by tropical storm and pipe currently held off bottom by ropes.
Plan is to replace supports or add floatation to piping
5-DAY UPSET 1
Treatment Lagoons
Yes No NA NE
Lagoon Type
None
Primary/Secondary
Primary
Influent structure
0 ❑ ❑ ❑
Banks/berms (seepage and erosion) ❑ ❑ 0 ❑
Vegetation (excessive vegetation on banks/berms) ❑ ❑ 0 ❑
Liner 0 ❑ ❑ ❑
Liner Type
Full, clay
Baffles/curtains
❑ ❑ 0 ❑
Freeboard Marker
0 ❑ ❑ ❑
Required freeboard
2
Feet
Actual freeboard
2.5
Feet
Are increments clearly marked on gauge at adequate intervals?
0 ❑ ❑ ❑
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall? ❑ ❑ ❑
No Evidence of overflow 0 ❑ ❑ ❑
Acceptable color 0 ❑ ❑ ❑
Floating mats ❑ ❑ ❑
Excessive solids buildup ❑ ❑ 0 ❑
Page 9 of 10

DocuSign Envelope ID: D9749B5A-3649-479E-A761-A01A009CA8B7
Permit: WQ0013398 Owner - Facility:904 Georgetown Treatment Plant LLC
Inspection Date: 09/16/2021 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Aerators/mixers
Effluent structure
❑❑■❑
❑❑■❑
Lagoon cover ❑ ❑ 0 ❑
Page 10 of 10