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Home My WebLink AboutWQ0004797_Compliance Evaluation Inspection_20220127 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED January 27, 2022 Wade Anderson Email: wade.anderson@lassonde.com Clement Pappas SUBJECT: Compliance Inspection Report Clement Pappas WWTF Non-discharge Permit No. WQ0004797 Henderson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Clement Pappas WWTF on 11/04/2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0004797. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report. Please pay particular attention to Mr. Laverty’s recommendations regarding 02L fecal exceedances in MW-5, 6 & 8. Specific corrective actions and any issuance of violations pertaining to 02L exceedances will be addressed under separate cover. If you should have any questions, please do not hesitate to contact me at 828-296-4686/ mikal.willmer@ncdenr.gov or Brett Laverty at 828-296-4681/brett.laverty@ncdenr.gov. Sincerely, Mikal Willmer, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Dale Wolfe, ORC DocuSign Envelope ID: 6C8575C1-463D-46C3-9477-0313BFCF25F6 Compliance Inspection Report Permit:WQ0004797 Effective:09/01/20 Expiration:07/31/26 Owner :Clement Pappas NC LLC SOC: Contact Person: Region: County: Directions to Facility: Henderson Asheville Dale Irvin Wolfe Effective:Expiration:Facility:Clement Pappas WWTF 125 Industrial Park Rd Hendersonville NC 28792 Title:Phone:828-693-0711 From I-26E take exit 44 to US Hwy 25S. Travel 2.5 miles to Industrial Park Rd, turn left. Facility is loacted 1 mile on the left. To spray field, continue past Industrial Park Rd to Brookside Camp Rd, turn left, go 1.5 miles, fields are on left. Secondary ORC(s): 828-693-0711Phone:987551Certification:Dale Irvin WolfePrimary ORC: SI,System Classifications: On-Site Representative(s): Related Permits: Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 11/04/2021 10:00AM 11:30AM Mikal Willmer 828-296-4686 Brett Laverty Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Wastewater Irrigation Compliance Evaluation Question Areas: Miscellaneous Questions Treatment Record Keeping Treatment Lagoons End Use-Irrigation Treatment Influent Pump Station Wells (See attachment summary) Page 1 of 6 DocuSign Envelope ID: 6C8575C1-463D-46C3-9477-0313BFCF25F6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004797 11/04/2021 Compliance Evaluation Clement Pappas NC LLC Routine Inspection Summary: Mikal Willmer and Brett Laverty, with the Asheville Regional Office, conducted a compliance evaluation inspection of Clement Pappas’ wastewater treatment facility. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with permit no. WQ0004797. The facility appeared to be operated and maintained in compliance. Part of the facility flow is currently routed to the Hendersonville CS under an industrial user permit. Mr. Wolfe stated the IUP has not been renewed for the upcoming year. Clement Pappas intends to connect on to the recently completed Mud Creek interceptor which will convey process wastewater to MSD for treatment. Clement pappas will also retain and maintain the spray irrigation system. No major process modifications have occurred or been implemented since the permit renewal. Septic Tank: Solids were pumped in May 2021 by VLS. VLS also removes solids generated by the DAF unit. Collection System/Pump Station: Process wastewater is pumped to the lagoon. Staff maintain and monitor the wet well near the processing facility. No major issues with pumps clogging due to septic tank immediately upstream. Lagoon: Staff report little solids build up within basin due to upstream settling tank (septic tank). 5 aerators currently in use. Spare parts are maintained onsite, and repairs are usually performed in-house. Freeboard records were readily available. There was over 4’ of freeboard in the lagoon at the time of the inspection. No issues with burrowing animals. Embankments are vegetated and free of trees and other woody vegetation. Spray Heads: All heads were calibrated in February of 2021. Irrigation equipment only requires calibration once per permit cycle. Mr. Wolfe indicated all the spray heads in Zone 3 and half the heads in Zone 2 have been replaced so far this year as part of routine preventative maintenance. All equipment was reported to be in working order as of 11/3/2021. Irrigation Fields: Inspectors were unable to observe irrigation due to rain. All fields appeared to have a healthy stand of fescue. Only minor weeds apparent in Field 4 and fescue was beginning to go to seed in some areas. Staff have been experimenting with winter crops to improve the overall health of the fields. The crop is still cut and baled by staff and given to local farmers. Zones 4, 5B, 10 & 11 were overseeded; however, the seed washed out due to flooding. Mr. Wolfe reports there is still limited use of these fields due to wet conditions. Depth to the water table is recorded and maintained and staff perform the soil ribbon test to estimate moisture conditions. No issues reported with runoff from the fields and no ponding or pooling was noted at the time of the inspection. Soil Fertility Analysis: Staff collect the field composites for the annual soil fertility analysis. Five subsamples are collected from each field to create composite samples. ESP values were within recommended guidelines. Recommend staff continue to monitor zinc levels in Field 1. The 2021 soil fertility analysis for field 1 shows the Zn-I at 1376. The NC department of agriculture recommends new application fields when zinc indices reach 2000. Also, continue to monitor the P-I of the soils since very high indices (>100) increase P mobility and can lead to micronutrient deficiencies and phosphorus loss from soils to ground and surface waters. Monitoring Well MW-7R: Discussed ongoing exceedances of the State’s groundwater standard for nitrate at monitoring well MW-7R. Surface water monitoring suggests Mud Creek is not the source of elevated nitrate. Inspector spoke with Anchor QEA engineer Jennifer Verde who recently inspected the monitoring well with a downhole camera. She observed plant roots penetrating the screened interval of the well and a buildup of organic debris at the bottom of the well casing. This organic debris may be impacting groundwater quality immediately around the well screen and sand pack. ARO is recommending that MW7R be redeveloped in order to remove the organic debris from the well casing. Removal of the root mass on the outside of the casing or within the sand pack may not be possible. Please confirm plans and timeframe to address the elevated nitrate concentrations at MW-7R. Monitoring Wells MW-5, MW-6, and MW-8: Discussed intermittent detections for fecal coliform bacteria at monitoring wells MW-5, MW-6, and MW-8. ARO is recommending additional steps be taken to address the presence of fecal coliform bacteria. This may include sampling for E. coli bacteria to confirm a human/animal source and possible well redevelopment Page 2 of 6 DocuSign Envelope ID: 6C8575C1-463D-46C3-9477-0313BFCF25F6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004797 11/04/2021 Compliance Evaluation Clement Pappas NC LLC Routine and/or well disinfection. Please confirm plans and timeframe to address the presence of fecal coliform bacteria at monitoring wells MW-5, MW-6, and MW-8. Monitoring Well MW5: Briefly discussed ongoing detections for cis-1,2-dichloroethene (1,2-DCE), trichloroethene (TCE), and tetrachloroethene (PCE) at background monitoring well MW-5. TCE and PCE concentrations are exceeding the State’s groundwater standards. It is important to note the NC Division of Waste Management sampled multiple private water supply wells up gradient of monitoring well MW-5 in 2015. The investigation was unable to identify a potential source for the chlorinated solvents. The ARO also sampled a private water supply well at 44 High Hills Road in 2017. There were no detections for volatile and semi-volatile organic compounds. Page 3 of 6 DocuSign Envelope ID: 6C8575C1-463D-46C3-9477-0313BFCF25F6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004797 11/04/2021 Compliance Evaluation Clement Pappas NC LLC Routine Type Yes No NA NE Single Family Spray, LR Infiltration System Reuse (Quality) Activated Sludge Spray, HR Activated Sludge Spray, LR Single Family Drip Activated Sludge Drip, LR Recycle/Reuse Lagoon Spray, LR 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? 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: 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)? Page 4 of 6 DocuSign Envelope ID: 6C8575C1-463D-46C3-9477-0313BFCF25F6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004797 11/04/2021 Compliance Evaluation Clement Pappas NC LLC Routine 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? See summary for details.Comment: End Use-Irrigation Yes No NA NE 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? Page 5 of 6 DocuSign Envelope ID: 6C8575C1-463D-46C3-9477-0313BFCF25F6 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004797 11/04/2021 Compliance Evaluation Clement Pappas NC LLC Routine Are GW monitoring wells properly constructed, including screened interval? Are monitoring wells damaged? GW is monitored for more parameters than effluent. Facility does not have effluent limits. Anchor QEA is currently assessing whether there is damage or issues with the monitoring wells. Report is forthcoming. See summary for additional details. Comment: AERATED LAGOON - Treatment Lagoons Yes No NA NE Lagoon Type Aerated Primary/Secondary Primary Influent structure Banks/berms (seepage and erosion) Vegetation (excessive vegetation on banks/berms) Liner Liner Type Full, clay Baffles/curtains Freeboard Marker Required freeboard 2 Feet Actual freeboard 4 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 Page 6 of 6 DocuSign Envelope ID: 6C8575C1-463D-46C3-9477-0313BFCF25F6