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HomeMy WebLinkAboutWQ0031396_Compliance Evaluation Inspection_20220726 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED July 26, 2022 Jack Minski Email: jack@futura-capital.com Lake Point Properties on Santeetlah LLC SUBJECT: Startup Compliance Inspection Report Santeetlah Lakeside WWTP Non-discharge Permit No. WQ0031396 Graham County Dear Permittee: The North Carolina Division of Water Resources conducted a startup inspection of the Santeetlah Lakeside WWTP on 7/19/2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0031396. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". There were multiple recordkeeping and operational issues identified during the startup inspection that need to be addressed prior to system startup. Priority items are outlined below: •Permit Condition I.1: Record an updated plat and submit to the Graham County Register of Deeds, delineating the recreational amenity as it relates to the responsibility of the HOA. •Permit Condition I.2: Submit a Declaration of Covenants and Bylaws to include information regarding the recreational amenity (walking path and vegetation) and information that includes the owner’s financial responsibility to maintain the amenity and treatment plant and how much each owner/resident will pay annually for that maintenance. •Permit Condition I.3: Submit an Engineering Certification with a minor modification request. •Submit an Operator Designation Form to designate an Operator in responsible charge and backup operator. This operator will need to possess a Surface Irrigation certification and WW-2 certification. This must be designated at least 60 days prior to wastewater being introduced into a new system. If you should have any questions, please do not hesitate to contact Melanie Kemp with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500 or via email at melanie.kemp@ncdenr.gov. DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Sincerely, Melanie Kemp Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Compliance Evaluation Inspection E.c.: LF Cc: Jose Rosado – Site Developer Tim Barbee William Fenner - Aquapoint DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Compliance Inspection Report Permit:WQ0031396 Effective:03/28/19 Expiration:07/31/24 Owner :Lake Point Properties on Santeetlah LLC SOC: Contact Person: Region: County: Directions to Facility: Graham Asheville Jack Minski Effective:Expiration:Facility:Santeetlah Lakeside WWTP 14 Marina Dr Lake Santeetlah NC 28771 Title:Phone:786-271-3850Managing Member Hwy.19 through the Nantahala Gorge. Turn right onto Hwy. 129 to Robbinsville. Continue on Hwy. 129 through Robbinsville to Lake Santeetlah.Turn left onto Thunderbird Mtn. Rd. Go past Santeetlah Marina. The facility is located on the left. Secondary ORC(s): Phone:Certification:Primary ORC: SI,WW2,System Classifications: On-Site Representative(s): Related Permits: Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 07/19/2022 11:30AM 01:30PM Melanie Kemp Mikal Willmer Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Other Reclaimed Water Reconnaissance Question Areas: Treatment Flow Measurement-Effluent Treatment Flow Measurement-Influent Miscellaneous Questions Treatment Flow Measurement-Water Use Records Treatment Treatment Filters Record Keeping Treatment Disinfection Treatment Flow Measurement Treatment Return pumps End Use-Reuse Standby Power (See attachment summary) Page 1 of 7 DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031396 07/19/2022 Reconnaissance Lake Point Properties on Santeetlah LLC Other Inspection Summary: On July 19, 2022 Melanie Kemp and Mikal Willmer from the Asheville Regional Office performed a startup inspection of the Santeetlah Lakeside WWTP (WQ0031396). Tim Barbee, William Fenner (Aquapoint representatives), and Jose Rosado (site developer) were on-site to assist with the inspection. A follow-up startup inspection will be performed after the issues highlighted in this inspection have been addressed. The current non-discharge permit for this reclaimed water generation and dedicated utilization facility was issued in March 2019. The permitted flow is based on use associated with construction of 26 bedrooms on 13 residential lots, a private bathhouse, and 1,500 square foot food stand and nutrient hydraulic uptake of the cover crop. The DEQ approved a daily sewerage flow reduction in December 2019. The treatment system, originally built in 2007, has not been utilized to-date since development has not occurred on site. The original development plans have changed since the permit was issued in 2019. Based on information provided by the site manager, Jose Rosado, new site development plans will likely alter the projected flow going through the system and connections to the facility. This alteration needs to be included on a minor permit modification request, submitted to the ARO. Moving forward, need to confirm that the drip irrigation system is intended to irrigate recreational use area. If so, vegetation needs to be maintained and the access path needs to be reestablished. If public use not intended adjust permit as necessary. This startup inspection is not deemed compliant based on several operational and recordkeeping items that need to be addressed prior to connection and startup. All components of the system were inspected including: influent flow device, one septic tank, one flow equalization tank with two pumps and associated high-water alarm, Bioclere two-stage trickling filter system with four dosing pumps, Bioclere clarifier and two sludge return pumps, one sand filter feed tank with two feed pumps and associated high-water alarm, two auto backwash sand filters, one filter backwash tank with two pumps, one chemical feed tank with mixer for pH adjustment, four UV disinfection banks, one turbidimeter, one standby generator, one effluent flow measuring device, four connected storage tanks, one dosing tank with two pumps and associated high-water alarms, two connected upset storage tanks with a return pump, drip irrigation system, and two newly-installed groundwater monitoring wells. It is recommended that the use and flow path of all system components be verified prior to system startup. Several maintenance items also need to be addressed including: -Ensure the backup generator is functional and receiving regular maintenance checks to supply backup power (Permit condition III.18). -Ensure turbidimeter is receiving power and calibrated for proper use (Permit condition III.17). -Check that the actuating valve diverting flow to the upset storage tank is calibrated and functional (Permit condition III.9 and III.19). -Recommended that all UV bulbs are operational and backup bulbs are stored on site. -Ensure flow meter is functional to report proper flow on NDMRs (Permit Condition IV.3). -Ensure sand filters and feed tank alarms are functional. Additionally, the following recordkeeping items need to be addressed prior to system startup: -Generate educational materials to handout to employees and homeowners related to system use (Permit condition III.21). -Post signs by drip irrigation area to inform public of reclaimed water (Permit condition II.7 and 8). -Update and provide a copy of O&M Plan to the ARO (Permit condition III.2) -Record updated plat with the Graham County Register of Deeds. Plat to include a delineation of recreational amenity and responsibilities of the HOA for managing the system, in addition to system features (Permit condition I.1). -Provide a declaration of covenants and bylaws to the ARO, related to recreational amenity and financial responsibility of system operation and maintenance (Permit condition I.2). -Submit engineering certification with minor modification request (Permit condition I.3). -Locate WPCSOCC of grade equivalent II or greater, with an SI certification as well, who will be on call 24-hours a day (Permit condition III.4). ORC must be identified and submitted via Operator Designation Form (Permit condition III.3). Two monitoring wells (MW-1 and MW-2) were installed in July 2022 in accordance with the 2019 permit rules. GW-1 forms were submitted by a licensed driller and the ARO is awaiting baseline groundwater results. The location of these two Page 2 of 7 DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031396 07/19/2022 Reconnaissance Lake Point Properties on Santeetlah LLC Other monitoring wells, as indicated on a figure/plat, needs to be submitted within 90 days of installation, per permit condition I.6. Page 3 of 7 DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031396 07/19/2022 Reconnaissance Lake Point Properties on Santeetlah LLC Other Type Yes No NA NE Infiltration System Lagoon Spray, LR Single Family Spray, LR Activated Sludge Spray, LR Activated Sludge Drip, LR Activated Sludge Spray, HR Recycle/Reuse Single Family Drip Reuse (Quality) 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.) Sand filter dosing tank alarms did not appear to be functional.Comment: 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? Ensure influent meter is functional (not leaking) and calibrated. While onsite, unclear if flow meter was working because system was not fully operational. Comment: Treatment Flow Measurement-Water Use Records Yes No NA NE Is water use metered? Are the daily average values properly calculated? Can use water-use records for flow reporting so long as it is metered.Comment: Treatment Flow Measurement-Effluent 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? Unknown - components appeared to be exercising at time of the inspection.Comment: Standby Power Yes No NA NE Page 4 of 7 DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031396 07/19/2022 Reconnaissance Lake Point Properties on Santeetlah LLC Other Is automatically activated standby power available? Is generator tested weekly by interrupting primary power source? Is generator operable? Does generator have adequate fuel? Generator is diesel-powered. Has not been operational for an undetermined period of time. Unknown if transfer switch works. Comment: Treatment Return pumps Yes No NA NE Are they in place? Are they operational? In place, but no slude to recycle during time of the inspection.Comment: Treatment Filters Yes No NA NE Is the filter media present? Is the filter media the correct size and type? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids? Is the mud well free of excessive solids and filter media? Does backwashing frequency appear adequate? Water appeared to be backwashing into backwash tank.Comment: 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 lbs 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-____-____) Page 5 of 7 DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031396 07/19/2022 Reconnaissance Lake Point Properties on Santeetlah LLC Other If yes, then when was the RMP last updated? UV bulbs likely need to be replaced, backups need to be kept on hand. Ensure UV system is functional during system startup. 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)? 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? Baseline groundwater monitoring results pending.Comment: End Use-Reuse Yes No NA NE 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? Page 6 of 7 DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0031396 07/19/2022 Reconnaissance Lake Point Properties on Santeetlah LLC Other 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? 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? Duplicate units not included in permit. Generator on site but operational status unknown. Acuating flow valve present but operational status unknown. When operational, redirected flow intended to go to headworks. Cover crop includes trees and other woody vegetation. Comment: Page 7 of 7 DocuSign Envelope ID: ABE18601-5D9F-4DB2-9E2F-5C576E844068