WQ0004972_NOV-2022-PC-0382_20220719

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
July 18, 2022
CERTIFIED MAIL No. 7020 3160 0002 0860 7822
RETURN RECIEPT REQUESTED
George Gudgeon, Senior Vice President
MHC TT, L.P.
2 North Riverside Plaza — Suite 800
Chicago, Illinois
SUBJECT: Notice of Violation NOV-2022-PC-0382
Compliance Evaluation Inspection
Forest Lake Preserve WWTP
Permit No. WQ0004972
Davie County
Dear Mr. Gudgeon:
On June 29, 2022, Division of Water Resources staff Caitlin Caudle conducted a
compliance inspection. Glenn Price, ORC, was present for the review of the treatment
and irrigation facilities, and Tracy Overdurf, Resort Manager, was present during the
review of the collection system. A review of the records, treatment plant, storage pond,
irrigation field, monitoring wells, and lift stations was completed. This review reflected
noncompliance with the subject permit. The following violations were noted:
1. Per Permit Condition IV.10 and Attachment C, all groundwater monitoring wells
will be tested for the parameters listed at the frequency specified. Total phosphorus
and ammonia were added to the Attachment C with the newest permit dated
January 13, 2021. These parameters were not sampled for in July and November
of 2021, and March of 2022. This is a violation of the subject permit. Moving
forward please be sure that the wells are sampled as required in Attachment
C.
2. At the time of inspection debris was present in the trough and weir of the clarifier,
and on the ground beside the clarifier. Mr. Price stated that he cleaned the trough
of the clarifier and left the screenings on the ground. This is a violation of the
subject permit. Per Permit Condition 111.11, all residuals generated shall be
disposed or utilized in a Division approved manner. All screenings should
be cleaned up and disposed of as soon as possible.
NORTH caaouvnD_E
ueo.m.m oremronment W.i�
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

3. Pool tablets were being used for the purpose of disinfection. This is not an
approved method for disinfection in wastewater as they release chlorine too slowly
and can produce dangerous gases. Since November 2020, fecal coliform results
were reported as greater than 2,000 colonies/100mL. This demonstrates that
adequate disinfection is not taking place. This is a violation of Permit Condition
11.1 and Permit Condition 111.1 which requires that the system be operated and
maintained as a non -discharge system. Permit Condition 11.1 requires that
corrective actions be taken if the facility fails to perform satisfactorily. Please
provide a justification as to why proper chlorine tablets are not being used
within ten (10) days of receipt of this Notice. Moving forward, use proper
chlorine tablets to ensure that proper disinfection is taking place.
Other items that require your attention and action:
A. The resort has recently expanded and will continue to expand in stages. Several
lift stations have also been rebuilt, and new lift stations installed with the new
camping areas. As a result, the Division maps are out of date. Per Permit
Condition II.4.b a map of the collection system shall be developed and
maintained. Please provide an updated site map that shows the location of
the spray field, monitoring wells, treatment plant, storage pond, and lift
stations. As lift stations continue to be built with the resort expansion this
map will need to be updated.
B. Mr. Price stated that solids had been removed from the storage pond and
treatment plant, but he did not have any records available. Ms. Overdurf stated
that the records for residuals removal could be located. To date, these have not
been received. Please provide a record of residuals removal with required
information listed in Permit Condition IV.8.
C. A floating mat of pine needs and fats, oils, and greases was present around an
aerator in the equalization basin. As a result, it was unclear if the aerator was
operating correctly. Please remove this mat to ensure that the aerator is
operating correctly and make any necessary repairs.
D_E
NORTH CARCLINA
no arhnenl of Environmental quay
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105
336.776.9800

Please refer to the enclosed inspection report for additional comments and observations.
If you have any questions, please contact me or Caitlin Caudle at the letterhead address
and phone number, or by email at [e-mail] or [e-mail].
Please note the ten (10) day requirement to respond to this Notice as referenced in
Item 3.
Sincerely,
DocuSiiggned by:by�
t- . l . 5M k-
"- 145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Enc: Inspection Report
Cc: Glenn Price, ORC (electronic copy)
Tracy Overdurf, Resort Manager (electronic copy)
Davie County Environmental Health (electronic copy)
Laserfiche File WQ0004972
WSRO Electronic Files
D_E
NORTH CARCLINA
gaparMeM of Environment,/quay
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 W. Hanes Mill Rd, Suite 300 I Raleigh, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0004972 Effective: 04/01/21 Expiration: 10/31/27
SOC: Effective: Expiration:
County: Davie
Region: Winston-Salem
Contact Person: Henry Lue Title:
Directions to Facility:
Owner : Mhc Tt LP
Facility: Forest Lake Preserve WWTP
192 Thousand Trails Dr
Advance NC 27006
Phone: [phone]
From Winston travel 1-40 West to HWY 801 South. Travel 801 S to intersection with US 64 and turn Left.
is approx. 0.5 mile west of the Yadkin River on N. side of US 64
System Classifications: SI, WW2,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 06/29/2022
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Entry Time 10:OOAM
Exit Time: 01:OOPM
Enterance to campground
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wastewater Irrigation
Facility Status: ❑ Compliant Not Compliant
Question Areas:
▪ Treatment Flow Measurement -Effluent
▪ Treatment Flow Measurement -Water
Use Records
▪ Record Keeping
▪ Treatment Influent Pump Station
▪ Treatment Flow Measurement
(See attachment summary)
▪ Treatment Flow Measurement -Influent
▪ Treatment
▪ Treatment Activated Sludge
▪ Treatment Clarifiers
▪ Storage
•
•
Miscellaneous Questions
Treatment Barscreen
▪ End Use -Irrigation
▪ Treatment Disinfection
▪ Wells
Page 1 of 7

Permit: WQ0004972 Owner - Facility: Mhc Tt LP
Inspection Date: 06/29/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On June 29, 2022, Division of Water Resources staff Caitlin Caudle conducted a compliance inspection. Glenn Price, ORC,
was present for the review of the treatment and irrigation facilities, and Tracy Overdurf, Resort Manager, was present during
the review of the collection system. A review of the records, treatment plant, storage pond, irrigation field, monitoring wells,
and lift stations was completed. This review reflected noncompliance with the subject permit. The following violations were
noted:
1. Per Permit Condition IV.10 and Attachment C, all groundwater monitoring wells will be tested for the parameters listed at
the frequency specified. Total phosphorus and ammonia were added to the Attachment C with the newest permit dated
January 13, 2021. These parameters were not sampled for in July and November of 2021, and March of 2022. This is a
violation of the subject permit. Moving forward please be sure that the wells are sampled as required in Attachment C.
2. At the time of inspection debris was present in the trough and weir of the clarifier, and on the ground beside the clarifier.
Mr. Price stated that he cleaned the trough of the clarifier and left the screenings on the ground. This is a violation of the
subject permit. Per Permit Condition 111.11, all residuals generated shall be disposed or utilized in a Division approved
manner. All screenings should be cleaned up and disposed of as soon as possible.
3. Pool tablets were being used for the purpose of disinfection. This is not an approved method for disinfection in
wastewater as they release chlorine too slowly and can produce dangerous gases. Since November 2020, fecal coliform
results were reported as greater than 2,000 colonies/100mL. This demonstrates that adequate disinfection is not taking
place. This is a violation of Permit Condition 11.1 and Permit Condition 111.1 which requires that the system be operated and
maintained as a non -discharge system. Permit Condition 11.1 requires that corrective actions be taken if the facility fails to
perform satisfactorily. Please provide a justification as to why proper chlorine tablets are not being used. Moving forward, use
proper chlorine tablets to ensure that proper disinfection is taking place.
Other items that require your attention and action:
A. The resort has recently expanded and will continue to expand in stages. Several lift stations have also been rebuilt, and
new lift stations installed with the new camping areas. As a result, the Division maps are out of date. Per Permit Condition
11.4.b a map of the collection system shall be developed and maintained. Please provide an updated site map that shows the
location of the spray field, monitoring wells, treatment plant, storage pond, and lift stations. As lift stations continue to be
built with the resort expansion this map will need to be updated.
B. Mr. Price stated that solids had been removed from the storage pond and treatment plant, but he did not have any
records available. Ms. Overdurf stated that the records for residuals removal could be located. TO DATE THESE HAVE NOT
BEEN RECEIVED. Please provide a records of residuals removal with required information listed in Permit Condition IV.8.
C. A floating mat of pine needs and fats, oils, and greases was present around an aerator in the equalization basin. As a
result, it was unclear if the aerator was operating correctly. Please remove this mat to ensure that the aerator is operating
correctly and make any necessary repairs.
In a discussion with Ms. Overdurf about the expansion of the resort, it was noted that a new package plant is being built.
Please keep in mind that any changes to the existing treatment, storage, and irrigation facilities will require a permit
modification. Please contact Nathaniel Thornburg of the Non -Discharge Permitting Unit as soon as possible if not done so
already.
A follow-up inspection will be scheduled to review the cleanup of the screenings from the weirs and the state of the plant.
Other observations:
• Lift stations ❑ Bar Screen ❑ EQ Basin ❑ Aeration Basin ❑ Clarifier ❑ Chlorine contact chamber ❑ Storage ❑ Irrigation
OR Clarifier E Sludge Basin/Digestor
• The package plant did not appear to be operating correctly and the solids were not being handled properly.
• A residuals management plan was developed and available at the time of inspection, but was not provided to the Division
per Permit Condition 1.1.
• The spray head that was turned off during the last inspection is now working again. Another spray head is turned off and
in need of repair, it is marked on the map.
Page 2 of 7

Permit: WQ0004972 Owner - Facility: Mhc Tt LP
Inspection Date: 06/29/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
• The flowmeter broke in October of 2021. A note was left on all NDMRs since October. The flowmeter has recently been
replaced. Flow was being estimated by the volume that was irrigated each month. WSRO was not notified that the flowmeter
was broken.
• The ORC is not present during irrigation events. The ORC will turn the system on during clear days where no rain is
forecasted. The irrigation system has a timer and the ORC typically sets the timer to 5 hours. The ORC will allow 15-20
minutes for the irrigation system to run and walk the field to ensure all spray heads are operating correctly. Due to the age
of the system there is not a high -flow alarm or shut off if there happened to be a break in the spray field while the ORC was
not on site.
• Currently, there are 7 old lift stations and two in the new part of the resort. Additional lift stations may be built as the
resort continues to expand.
• There is a grease program in place and a flyer is provided with the check in packet for each camper.
• The facility was originally permitted before 2H was developed. As a result there are no setbacks for the facility but a
compliance boundary and a review boundary are still present.
• A sludge survey was completed in 2020. Residuals were removed from the storage pond and plant from 4/5/2021 to
4/28/2021 using a dredge.
• The irrigation system has not been calibrated. This must be completed by 10/31/2027.
• There is a small bar screen at the head of the package plant. The bar screen is almost inaccessible and has not been
cleaned. The bars are not spaced close enough to catch much debris.
• A new PVC line was installed from the new lift stations instead of tying into the existing system. This line empties
directly into the EQ basin.
• The EQ basin and aeration basin are aerated. They are timed to be on for 30 minutes and off for 30 minutes.
• The EQ basin is controlled by floats. There is a low water cut off float, a high water float to turn the pumps on, and a
high water alarm which has an audible and visual alarm. There is a splitter box between the EQ basin and aeration basin
that returns some flow to the EQ basin.
• The storage pond is clay lined and does not have aeration. Duckweed was present across the surface of the pond and
the color of effluent could not be determined.
• There are no alarms on the wet well for the irrigation pumps.
• No runoff was observed from the downslope end of the spray field.
• All monitoring wells were in good condition.
• The ORC stated that residuals are removed from the sludge basin about once per year.
• The ORC stated that there was an upset at some point and the treatment system is still trying to recuperate.
• Pine needles and other debris was visible in the trough of the clarifier.
• The ORC is placing tablets directly into the trough of the clarifier.
• The collection system was reviewed. All lift stations appeared to be well maintained and several have been rebuilt. A
map of the system was not reviewed. Lift stations are inspected every day. There are no high priority sewer lines. The entire
collection system is inspected at least twice a year. A grease control program is in place.
• The access gate to the spray fields has evidence of golf carts bypassing it. Additional measures may need to be taken
to prevent public access to the spray fields.
• The cap on MW1 is bent and prevents it from closing all the way. As a result the lock on the well cap will not close. The
ORC stated he will get a lock with a longer shank.
Page 3 of 7

Permit: WQ0004972 Owner - Facility: Mhc Tt LP
Inspection Date: 06/29/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Reuse (Quality)
Infiltration System
Lagoon Spray, LR
Single Family Spray, LR
Activated Sludge Spray, HR
Activated Sludge Drip, LR
Recycle/Reuse
Single Family Drip
Activated Sludge Spray, LR
Treatment
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
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:
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?
Comment:
Treatment Flow Measurement -Water Use Records
Yes No NA NE
IEI
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Yes No NA NE
Page4of7

Permit: WQ0004972 Owner - Facility: Mhc Tt LP
Inspection Date: 06/29/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Is water use metered?
Are the daily average values properly calculated?
Comment:
Treatment Flow Measurement -Effluent
Is flowmeter calibrated annually?
Is flowmeter operating properly?
Does flowmeter monitor continuously?
Does flowmeter record flow?
Does flowmeter appear to monitor accurately?
Comment:
Treatment Barscreen
Is it free of excessive debris?
Is disposal of screenings in compliance?
Are the bars spaced properly?
Is the unit in good condition?
Comment: See comments.
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:
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?
Comment:
Treatment Disinfection
Is the system working?
Do the fecal coliform results indicate proper disinfection?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
Page5of7

Permit: WQ0004972 Owner - Facility: Mhc Tt LP
Inspection Date: 06/29/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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: See comments.
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?
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?
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Page6of7

Permit: WQ0004972 Owner - Facility: Mhc Tt LP
Inspection Date: 06/29/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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?
Comment: See comments.
End Use -Irrigation
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?
Are GW monitoring wells properly constructed, including screened interval?
Are monitoring wells damaged?
Comment: MWs were in good condition.
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Yes No NA NE
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Page 7 of 7