WQ0023580_Compliance Evaluation Inspection_20211018

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Kelly Hawkins
Cove Key Association Inc.
Main Street Managers
PO Box 1329
Cornelius, NC 28031
Dear Ms. Hawkins:
via Email
NORTH CAROLINA
Environmental Quality
October 18, 2021
Subject: Non -Discharge Permit Inspection
Cove Key Townhomes on Lake Norman WWTP
Permit No. WQ0023580
Reclaimed Water Irrigation
Iredell County
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on September 23rd,
2021, which included the reclaimed water treatment, irrigation sites and a records review.
The MRO 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.
Assessment for plant upgrade (newer technology) vs. repair is recommended and will be highlighted
with future inspections and the next permit renewal.
• Lab data reviewed, supported entry in the corresponding NDMRs for most parameters; but, there are
consistent errors (omissions and/or misreporting) for Phosphorus that have resulted in Deficiencies
or Violations, which need to be corrected to avoid future violations. 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.).
• The splitter box needs repair for corrosion. The flow rate at this facility historically has been low
and currently is managed in one train; however, per discussion with Mr. Long (ORC), the corrosion
at the splitter box would likely create a bypass issue if the second train were used. This item needs
to be addressed as soon as possible.
• Most tanks need rehabilitation for rust removal, potential repairs and repainting; as well as general
cleaning for residuals and algae build-up. Per previous inspections/conversation the operators
discussed complete plant replacement/upgrade with Cove Key HOA, and continued repairs are
likely if costs are less and spread out over time. 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.
NOmm DE �/
Doparb CAPOLJNA
of Envi.m onto) Ou.utr\
North Carolina Department of Environmental Quality j Division of Water Resources
Mooresville Regional Office 1610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115
704.663.1699

Left: Corrosion at Splitter Box.
Right: Shows corrosion, peeling paint at end of plant.
Additional items to address to maintain overall compliance:
• All plant tanks and lagoons need to be assessed for solids and pumped as needed.
• The wet -weather storage lagoon liner should be assessed by an engineer for integrity/repair as
needed. And, potential resizing of structure adequate to facility needs based on historically low
flow. This is noted here to plan appropriately as MRO staff will highlight this item during the
next renewal.
• The irrigation field needed typical maintenance for a couple of dripline breaks and pressure
assessment to determine if flow is sufficient to the end of each run, to utilize acreage permitted.
And, downed trees, uprooted stumps and underbrush need removal and holes filled.
• TCW is nearing completion of the field lab certification for pH analysis. 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. For additional assistance, 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-branch/certified-laboratory-listings

The deemed collection system and pump station (WQCSD0500) was inspected by Mr. Tony Parker
of the MRO earlier this year, so was not viewed during this site visit.
You may contact Maria Schutte via email ([e-mail]) or phone [phone]) with any
questions about this report or your permit.
Sincerely,
DocuSigned by:
,4s4uw H P444.4
F161FB69A2D84A3...
Andrew H. Pitner, P.G., Assistant Regional Supervisor
Mooresville Regional Office
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Attachment: WQ0023580 Compliance Inspection Report
CC: Mr. Brandon Long, TCW (Email)
Mr. Brian Stephens, TCW (Email)
Mr. Brent Brower, Cove Key HOA President (Email)

Compliance Inspection Report
Permit: WO0023580
SOC:
County: Iredell
Region: Mooresville
Effective: 01/01/19 Expiration: 11/30/23
Effective: Expiration:
Contact Person: Chip Hawkins Title:
Owner : Cove Key Association Inc
Facility: Cove Key Townhomes on Lake Norman WWTF
105 S Cove Key Ln
Mooresville NC 28117
Phone: [phone]
Directions to Facility:
From 1-77 and Langtree Rd (exit 31), travel south on SR 1205 (Mecklyn Rd). The facility is approx. 2 miles on the right.
System Classifications: SI, WW2,
Primary ORC: Charles Brandon Long Certification: 991385 Phone: [phone]
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
WQCSD0500 Cove Key Association Inc - Cove Key Townhomes on Lake Norman WWTP
Inspection Date: 09/23/2021 Entry Time 09:11AM
Primary Inspector: Maria Schutte
Secondary Inspector(s):
Reason for Inspection: Routine
Permit Inspection Type: Reclaimed Water
Facility Status: Compliant ❑ Not Compliant
Question Areas:
▪ Treatment Flow Measurement -Effluent
▪ Treatment Flow Measurement -Water
Use Records
▪ Record Keeping
▪ Treatment Clarifiers
▪ Treatment Return pumps
▪ Standby Power
(See attachment summary)
Exit Time: 11:46AM
Phone: [phone]
Inspection Type: Compliance Evaluation
▪ Treatment Flow Measurement -Influent
▪ Treatment
▪ Treatment Lagoons
▪ Treatment Disinfection
▪ Storage
▪ Miscellaneous Questions
▪ Treatment Filters
▪ Treatment Activated Sludge
▪ Treatment Flow Measurement
▪ End Use -Reuse
Page 1 of 7

Permit: WQ0023580 Owner - Facility: Cove Key Association Inc
Inspection Date: 09/23/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection on September 23rd, 2021, which included
the reclaimed water treatment, irrigation sites and a records review.
The MRO 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. Assessment for plant upgrade (newer technology) vs. repair is
recommended and will be highlighted with future inspections and the next permit renewal.
* Lab data reviewed, supported entry in the corresponding NDMRs for most parameters; but, there are consistent errors
(omissions and/or misreporting) for Phosphorus that have resulted in Deficiencies or Violations, which need to be corrected
to avoid future violations. 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.).
* The splitter box needs repair for corrosion. The flow rate at this facility historically has been low and currently is managed
in one train; however, per discussion with Mr. Long (ORC), the corrosion at the splitter box would likely create a bypass
issue if the second train were used. This item needs to be addressed as soon as possible.
* Most tanks need rehabilitation for rust removal, potential repairs and repainting; as well as general cleaning for residuals
and algae build-up. Per previous inspections/conversation the operators discussed complete plant replacement/upgrade with
Cove Key HOA, and continued repairs are likely if costs are less and spread out over time. 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. (See photos in cover letter)
Additional items to address to maintain overall compliance:
* All plant tanks and lagoons need to be assessed for solids and pumped as needed.
* The wet -weather storage lagoon liner should be assessed by an engineer for integrity/repair as needed. And, potential
resizing of structure adequate to facility needs based on historically low flow. This is noted here to plan appropriately as
MRO staff will highlight this item during the next renewal.
* The irrigation field needed typical maintenance for a couple of dripline breaks and pressure assessment to determine if flow
is sufficient to the end of each run, to utilize acreage permitted. And, downed trees, uprooted stumps and underbrush need
removal and holes filled.
* TCW is nearing completion of the field lab certification for pH analysis. 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. For additional assistance, 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-I:
ranch/certified-laboratory-listings
The deemed collection system and pump station (WQCSD0500) was inspected by Mr. Tony Parker of the MRO earlier this
year, so was not viewed during this site visit.
Page 2 of 7

Permit: WQ0023580 Owner - Facility: Cove Key Association Inc
Inspection Date: 09/23/2021 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, LR ❑
Activated Sludge Spray, HR ❑
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
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: See Summary Section comments about corrosion and second train. Intensity display unit for
the UV system was problematic from installation and is not utilized. The UV is connected to
telemetry.
Treatment Flow Measurement -Influent 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? • ❑ ❑ 0
Comment: Determined from pump station.
Treatment Flow Measurement -Water Use Records
Is water use metered?
Are the daily average values properly calculated?
Comment. In plant water use from a separate potable source, not the plant.
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Treatment Flow Measurement -Effluent Yes No NA NE
Is flowmeter calibrated annually? • 0 0 0
Is flowmeter operating properly? • ❑ ❑ ❑
Does flowmeter monitor continuously? • 0 0 0
Does flowmeter record flow? • 0 0 0
Does flowmeter appear to monitor accurately? • 0 0 0
Comment: This is the flow meter to irrigation.
Page 3 of 7

Permit: WQ0023580 Owner - Facility: Cove Key Association Inc
Inspection Date: 09/23/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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
❑ • ❑ ❑
❑ • ❑ ❑
❑ ❑ ❑ •
❑ ❑ ❑ •
Comment: Per previous inspection report, generators are not tested by TCW staff for safety reasons.
The HOA has a generator contractor for those inspections.
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: See Summary Section for comments on corrosion throughout system and age of plant
necessitating need to replace or repair.
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
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Yes No NA NE
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Comment: See Summary Section for comments on corrosion throughout system and age of plant
necessitating need to replace or repair. Sludge was at about 2/3 and recommended
assessment and pumping throughout system. Also residuals and algae growth on fixtures to
be addressed w/ system repair or replacement.
Treatment Return pumps
Are they in place?
Are they operational?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: No return pump from 5 day upset pond. Operator has to manually place a pump to move water
to head of the plant.
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?
Yes No NA NE
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• ❑ ❑ ❑
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• ❑ ❑ ❑
Page 4 of 7

Permit: WQ0023580 Owner - Facility: Cove Key Association Inc
Inspection Date: 09/23/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Is the clear well free of excessive solids?
Is the mud well free of excessive solids and filter media?
Does backwashing frequency appear adequate?
Comment: See Summary Section for comments on corrosion throughout system and age of plant
necessitating need to replace or repair. Solids in mud well at 2/3rds of sludge judge. MRO
recommended solids assessment throughout plant and lagoons and pumping as needed.
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
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: Facility recently received an NOV for high fecal in June 2021, but response indicated operator
thought that was a bottle issue from the lab, per response. Upon resampling with typical bottle,
the fecal results returned to normal, <1 colony/100mis.
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?
Yes No NA NE
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❑ ❑•❑
❑ ❑•❑
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Page 5 of 7

Permit: WQ0023580 Owner - Facility: Cove Key Association Inc
Inspection Date: 09/23/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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?
❑ ❑•❑
❑ ❑•❑
❑ ❑ ❑
❑ ❑ ❑
❑ ❑•❑
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Comment: Data and Monitoring Reports are maintained electronically. MRO staff requested a sampling of
lab reports by email. It was noted that a Phosphorus result was erroneously reported, as there
was no sample collected. See comments in Summary Section related to the need to improve
Phosphorus data collection and reporting, as it has resulted in unnecessary Notices.
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?
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?
Yes No NA NE
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Page 6 of 7

Permit: WQ0023580 Owner - Facility: Cove Key Association Inc
Inspection Date: 09/23/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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: See comments in the Summary Section on typical maintenance of the field site and driplines.
Some zones have more undergrowth than others. MRO staff also discussed potential option at
renewal to revert to WWI system, if the existing drip nes meet setback requirements, etc. This
would relax current effluent Iimits,but could also require MWs, so may not be feasible option.
Page 7 of 7