WQ0034715_Staff Report_20220401

DocuSign Envelope ID: 6C531 1 D4-615E-461 1 -A83A-AE88226B375A
;s State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit
Attn: Poorva Mokashi
From: Chris Smith
Raleigh Regional Office
Application No.: WQ0034715
Facility name: The Club at 12 Oaks
Reclaimed Water
Note: This form has been adapted from the non -discharge facilily staff report to document the review of both non -
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are gpplicable.
I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? ® Yes or ❑ No
a. Date of site visit: March 22, 2022
b. Site visit conducted by: Chris Smith
c. Inspection report attached? ® Yes or ❑ No
d. Person contacted: John Parrish (Facility Superintendent) and their contact information: [phone]
e. Driving directions: 700 Ivy Arbor Way, Holly Springs, NC 27540
2. Discharge Point(s): N/A
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters: N/A
Classification:
River Basin and Subbasin No.
Describe receiving stream features and pertinent downstream uses:
FORM: WQROSSR 04-14 Page 1 of 5

DocuSign Envelope ID: 6C531 1 D4-615E-461 1 -A83A-AE88226B375A
III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? ❑ Yes ❑ No ® N/A
ORC: Certificate 9: Backup ORC: Certificate 9:
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No
If no, please explain:
Description of existing facilities: Influent flow meter; 3,156,000 gallon unlined reclaimed water storage pond
with dual 550 gallon per minute (GPM) vertical turbine reclaimed water utilization pumps and dual 3, 250
cubic feet per minute (CFM) blowers; weather station; reclaimed water distribution flow meter;
approximately 69.8 acres of golf course reclaimed utilization area and all associated piping, valves,
controls, and appurtenances.
Proposed flow:
Current permitted flow: 400,000 gallons per day (GPD)
Explain anything observed during the site visit that needs to be addressed by the permit, or that may be important
for the permit writer to know (i.e., equipment condition, function, maintenance, a change in facility ownership,
etc.) This permit needs a change of ownership.
3. Are the site conditions (e.g., soils, topography, depth to water table, etc) maintained appropriately and adequately
assimilating the waste? ® Yes or ❑ No
If no, please explain:
4. Has the site changed in any way that may affect the permit (e.g., drainage added, new wells inside the compliance
boundary, new development, etc.)? ❑ Yes or ® No
If yes, please explain:
5. Is the residuals management plan adequate? ❑ Yes or ❑ No ®N/A
If no, please explain:
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
7. Is the existing groundwater monitoring program adequate? ❑ Yes ❑ No ® N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. Are there any setback conflicts for existing treatment, storage and disposal sites? ❑ Yes or ® No
If yes, attach a map showing conflict areas.
9. Is the description of the facilities as written in the existing permit correct? ® Yes or ❑ No
If no, please explain:
10. Were monitoring wells properly constructed and located? ❑ Yes ❑ No ® N/A
If no, please explain:
FORM: WQROSSR 04-14 Page 2 of 5

DocuSign Envelope ID: 6C531 1 D4-615E-461 1 -A83A-AE88226B375A
11. Are the monitoring well coordinates correct in BIMS? ❑ Yes ❑ No ® N/A
If no, please complete the followina (expand table if necessarv):
Monitoring Well
Latitude
Longitude
C , „
C , rr
C , „
C , rr
C , „
C , rr
C , „
C , rr
12. Has a review of all self -monitoring data been conducted (e.g., DMR, NDMR, NDAR, GW)? ® Yes or ❑ No
Please summarize any findings resulting from this review: The facility is required to submit reclaimed water
distribution data on form NDMR as an Estimated Monthly Total. No NDMR forms have been submitted
by this facility since the issuance of the last permit (June 2018). The current permittee is no longer the
property owner.
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
14. Check all that apply:
❑ No compliance issues ❑ Current enforcement action(s) ❑ Currently under JOC
❑ Notice(s) of violation ❑ Currently under SOC ❑ Currently under moratorium
Please explain and attach any documents that may help clarify answer/comments (i.e., NOV, NOD, etc.)
1. If the facility has had compliance problems during the permit cycle, please explain the status. Has the RO been
working with the Permittee? Is a solution underway or in place? See Additional Regional Staff Review Items.
2. Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ® No ❑ N/A
If no, please explain: See Additional Regional Staff Review Items.
15. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit?
❑Yes❑No❑N/A
If yes, please explain:
16. Possible toxic impacts to surface waters:
17. Pretreatment Program (POTWs only):
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DocuSign Envelope ID: 6C531 1 D4-615E-461 1 -A83A-AE88226B375A
IV. REGIONAL OFFICE RECOMMENDATIONS
3. Do you foresee any problems with issuance/renewal of this permit'? ❑ Yes or ® No
If yes, please explain: See Additional Regional Staff Review Items.
4. List any items that you would like the NPDES Unit or Non -Discharge Unit Central Office to obtain through an
additional information request:
Item Reason
5. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason
6. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition
Reason
IIL13. — Freeboard Gauge
Permit requires weekly freeboard levels to be recorded. The reclaimed
water storage pond is currently equipped with a gauge to monitor
reclaimed water levels, but it is unclear whether this gauge also serves to
indicate freeboard.
7. Recommendation: ❑ Hold, pending receipt and review of additional information by regional office
❑ Hold, pending review of draft permit by regional office
❑ Issue upon receipt of needed additional information
® Issue
DocuSigned by:
❑ Deny (Please state reasons: ) �S (..A
8. Signature of report preparer:
Signature of regional supervisor: I vava'ss
Date:
3/ 31/ 2 0 2 2 B2916 HAB32144F...
1 D427000DBE94E9...
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DocuSign Envelope ID: 6C531 1 D4-615E-461 1 -A83A-AE88226B375A
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The current owner and operator of this facility does not appear to be familiar with the permit requirements for
the facility. The current owner is not the current permittee.
At the time of the March 22, 2022 inspection the storage pond freeboard level was estimated to be 8 inches.
This is much less than the minimum freeboard required by the permit (24 inches) and may be a threat to the
structural integrity of the storage pond. The acting operator was informed that the water level needed to be
lowered immediately to bring the facility back into compliance with permit conditions. It is not clear whether
the storage pond depth gauge also serves as a minimum freeboard marker due to the water level being much
higher than the minimum freeboard level. It is possible that the storage pond depth gauge has a minimum
freeboard mark that was under water during the inspection. The facility operator has not been keeping
freeboard level records as required by the permit.
Monthly reclaimed water distribution totals are required to be reported on form NDMR each month. No
NDMR forms have been submitted since the last permit renewal (June 2018). This is also about the time the
new owner purchased the property where this facility is located and operated.
No annual permit renewal fees have been paid since 2018.
FORM: WQROSSR 04-14 Page 5 of 5