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Home My WebLink AboutWQ0034715_Inspection Letter_20220331 North Carolina Department of Environmental Quality Division of Water Resources -Raleigh Regional Office 3800 Barrett Drive Raleigh, North Carolina 27609 March 31, 2022 Susan Dunnavant COO – Concert 12 Oaks, LLC 300 International Parkway, Suite 150 Lake Mary, FL 32746 Subject: Compliance Evaluation Inspection The Club at 12 Oaks Conjunctive Reclaimed Water Utilization System Permit Number WQ0034715 Wake County Susan Dunnavant, On March 22, 2022 Chris Smith of the Raleigh Regional Office conducted a compliance evaluation inspection of the conjunctive reclaimed water utilization system located at The Club at 12 Oaks. Reclaimed water is generated by the Town of Holly Springs Wastewater Treatment Plant (Permit NC0063096). The purpose of this inspection was to ensure compliance with the subject permit. During the inspection, the cooperation of John Parrish was helpful and appreciated. This compliance evaluation inspection consisted of the following: • Review of the permit • Review of the owner/facility information • Review of facility logbooks, calibration documentation, non-discharge wastewater monitoring reports (NDMR), and distribution records • On-site inspection of storage and distribution components The current permit was issued June 19, 2018 and expires on May 31, 2023. The reclaimed water at this facility is distributed from a storage pond to conjunctive use sites on the surrounding golf course by dual 550 gallon per minute (GPM) vertical turbine pumps connected to a solid set piping system. Reclaimed water distribution is recorded by a distribution flow meter. This inspection was conducted as part of a staff report required by the Non-Discharge Permit Ownership/Name Change Application submitted by the current owner(s) of the property where this facility is located. The current owner of the property is not the current permittee. While compliance with the facility’s permit conditions is the property owners’ responsibility, it is not clear whether the current property owner(s) has been aware of the permit requirements associated with this type of facility. DocuSign Envelope ID: 6C5311D4-615E-4611-A83A-AE88226B375A North Carolina Department of Environmental Quality Division of Water Resources -Raleigh Regional Office 3800 Barrett Drive Raleigh, North Carolina 27609 The record keeping and reporting requirements of this facility’s permit include, but are not limited to, maintenance of weekly freeboard records, submittal of monthly reclaimed water distribution reports to be submitted on form NDMR, and permit condition noncompliance notification. No freeboard records were available at the time of the inspection as required by the permit and no NDMR reports have been submitted since the last permit issuance (June 2018). At the time of the inspection there was insufficient freeboard in the reclaimed water storage pond and this noncompliance condition was not reported to the Raleigh Regional Office. There is a reclaimed water depth gauge in the storage pond, but it is unclear whether this gauge can also serve as the freeboard gauge for the pond. A clearly marked gauge for freeboard needs to be installed in the storage pond and weekly freeboard records need to be maintained. Permit conditions and requirements were reviewed with John Parrish (golf course superintendent and acting system operator). He was informed that the minimum freeboard level must be achieved immediately, that freeboard records need to be maintained and that reclaimed water distribution amounts need to be recorded on form NDMR and submitted monthly. Mr. Parrish has been hired since the last permit issuance, so this was the first opportunity to discuss reporting requirements with him. He has followed up with this office since the inspection and is making efforts to bring the facility into compliance with its permit conditions. Despite insufficient freeboard the storage pond appeared to be in good condition. Some algal treatment/control is required during warm months. The pumps appeared to be in good condition and well maintained and the aerators appeared to be functioning properly. Pipes and appurtenances were properly marked and colored and a map of the system was available during the inspection. Signage notifying the public is posted at the pond/maintenance shop, club house, 1st and 10th tees, golf cart road crossings, etc. Most areas of the golf course are currently irrigated using potable water. Mr. Parrish indicated that the quality of the reclaimed water was not always sufficient for greens maintenance, so the course does not use as much as initially intended. DocuSign Envelope ID: 6C5311D4-615E-4611-A83A-AE88226B375A North Carolina Department of Environmental Quality Division of Water Resources -Raleigh Regional Office 3800 Barrett Drive Raleigh, North Carolina 27609 If you have any questions about this inspection or this letter, please contact Chris Smith at chris.smith@ncdenr.gov or 919-791-4200. Sincerely, Vanessa Manuel Assistant Regional Supervisor Water Quality Regional Operations Raleigh Regional Office Attachments: EPA Water Compliance Inspection Report cc: Laserfiche DocuSign Envelope ID: 6C5311D4-615E-4611-A83A-AE88226B375A