The URL can be used to link to this page

Home My WebLink AboutWQ0015931_Compliance Evaluation Inspection_20220927ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality September 27, 2022 Mr. Cory Head, General Manager via Email Trump National Golf Club Charlotte, LLC 120 Meeting House Square Mooresville, North Carolina 28117 Subject: Non -Discharge Permit Inspection TNGC - Permit No.: WQ0015931 Reclaimed Water Irrigation Iredell County Dear Mr. Head: Division of Water Resources (DWR) staff from the Mooresville Regional Office (MRO) and Asheville Regional Office (ARO) conducted a site visit on September 81h, 2022, primarily to discuss the proposed major modification to replace the aging WWTP. A partial joint compliance inspection was also conducted. The DWR would like to thank your Operator in Responsible Charge (ORC), Mr. Brian Stephens, additional TCW Wastewater staff, your maintenance staff and Contract Project Engineer for their time during the visit. The deemed collection system, WWTP, storage lagoons and some records were reviewed. The following items were noted to return to or maintain overall program compliance. Please contact the MRO when repairs are completed, if not already made. Deemed Collection System A recently discovered plumbing design flaw that allowed a kitchen sink to bypass the grease trap was rectified and to the best of your maintenance and TCW staff knowledge there are no other grease trap bypasses. Amount of grease noted appears to warrant pumping to clear lines. There may also be a blockage as there was uneven distribution of flow and grease once the lines split. The upgradient manhole nearest the pump station also needs to be assessed for blockage, as the water level was too high to view flow. Additional FOG education is needed to inform kitchen staff to place as much grease as possible in appropriate solid waste containers for proper handling and to keep it out of the collection system. The same may be warranted for any foreign materials (numerous plastic bottle caps were noted) getting into the sinks and collection system. The down gradient manhole nearest the pump station was inaccessible due to the shrub growth and needs to be cleared. The pump stations' back-up generator has a broken fuel gauge slated for repair. The WWTP Critical equipment and structural supports show signs of deterioration from corrosion and presently the system cannot be operated as a dual train as TCW staff are utilizing viable parts to keep one train functioning properly until the plant replacement (originally planned in 2018) is completed. NORTH CAROLINAD_ E oan+ro�em or enwronmwntzA ou.i� North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1601 East Center Avenue, Suite 301 I Mooresville, NC 28115 704.663.1699 NORTH C CUNA oep.i or Environmental uusim The primary reason for DWR staff visit was to discuss the proposed major permit modification for a new WWTP utilizing current design and technology. Questions specific to this permit modification may be directed to lauren.plummer@ncdenr.gov, our Central Office permitting staff assigned to this project. The in -line turbidity meter is due for calibration in September 2022. TCW staff noted floating solids after the aeration basin as a seasonal occurrence at most of their plants. Floating solids are to be skimmed and disposed appropriately. Potential cause may be biological die -off due to warm temperatures, decreased dissolved oxygen and competition for food source per discussion with additional MRO staff, Wes Bell (NPDES Compliance). The Irrigation System and Records Distribution could not be assessed due to line damage discovered that morning and suspected to be from cart / vehicle traffic. Only authorized vehicles for maintenance should be allowed in the drip fields. Additional signage and education may assist. Due to time constraints limited records were reviewed. Laboratory data was reviewed on -site via ORC cell phone to confirm elevated Total Suspended Solids reported in June were accurate. This item was managed in separate communication on September 22nd, 2022, for the resulting NOV-2022-LV-0659. Additional items of Interest TCW Wastewater received field lab certification for pH and Total Residual Chlorine. Meters, calibration standards and documentation reviewed appeared to be in order at the time of inspection. A notation on the side of the field pH meter references a calibration date of 12/21 and warrants discussion with the manufacturer to determine unit requirements beyond your manual standards calibration. Please contact Maria Schutte by email maria.schutte@ncdenr.gov or phone (704-235-2184) should you have questions. Sincerely, DocuSigned by: ,444uw H P4444 F161FB69A2D84A3... Andrew H. Pitner, P.G., Assistant Regional Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachments: WQ0015931 Inspection Report CC: Brian Stephens and Brandon Long, TCW Wastewater (Email) Melanie Kemp, DWR-ARO (Email) Lauren Plummer, DWR-CO (Email) DEQ North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1601 East Center Avenue, Suite 301 I Mooresville, NC 28115 704.663.1699 Compliance Inspection Report Permit: WQ0015931 Effective: 06/01/18 SOC: Effective: County: Iredell Region: Mooresville Contact Person: Gavin Arsenault Directions to Facility: System Classifications: SI, WW2, Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 09/08/2022 Primary Inspector: Maria Schutte Secondary Inspector(s): Expiration: 05/31/23 Expiration: Title: General Manager Entry Time 10:33AM Reason for Inspection: Routine Permit Inspection Type: Reclaimed Water Facility Status: ❑ Compliant Not Compliant Question Areas: ▪ Treatment Flow Measurement -Effluent II Treatment Flow Measurement -Water Use Records ▪ Treatment Filters ▪ Treatment Activated Sludge ▪ Treatment Clarifiers ▪ Treatment Return pumps ▪ Standby Power (See attachment summary) Certification: Owner : Tngc Charlotte LLC Facility: Trump National Golf Club Charlotte WWTP 1954 Brawley School Rd Mooresville NC 28117 Exit Time: 01:12PM Phone: Phone: Phone: 704-663-1699 Inspection Type: Compliance Evaluation ▪ Treatment Flow Measurement -Influent Miscellaneous Questions ▪ Treatment Treatment Barscreen ▪ Record Keeping ▪ End Use -Irrigation ▪ Treatment Disinfection ▪ Storage ▪ Treatment Lagoons ▪ Treatment Influent Pump Station ▪ Treatment Flow Measurement ▪ End Use -Reuse Page 1 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: Division of Water Resources (DWR) staff from the Mooresville Regional Office (MRO) and Asheville Regional Office (ARO) conducted a site visit on September 8th, 2022, primarily to discuss the proposed major modification to replace the aging WWTP. A partial joint compliance inspection was also conducted. The DWR would like to thank your Operator in Responsible Charge (ORC), Mr. Brian Stephens, additional TCW Wastewater staff, your maintenance staff and Contract Project Engineer for their time during the visit. The deemed collection system, WWTP, storage lagoons and some records were reviewed. The following items were noted to return to or maintain overall program compliance. Please contact the MRO when repairs are completed, if not already made. Deemed Collection System A recently discovered plumbing design flaw that allowed a kitchen sink to bypass the grease trap was rectified and to the best of your maintenance and TCW staff knowledge there are no other grease trap bypasses. Amount of grease noted appears to warrant pumping to clear lines. There may also be a blockage as there was uneven distribution of flow and grease once the lines split. The upgradient manhole nearest the pump station also needs to be assessed for blockage, as the water level was too high to view flow. Additional FOG education is needed to inform kitchen staff to place as much grease as possible in appropriate solid waste containers for proper handling and to keep it out of the collection system. The same may be warranted for any foreign materials (numerous plastic bottle caps were noted) getting into the sinks and collection system. The down gradient manhole nearest the pump station was inaccessible due to the shrub growth and needs to be cleared. The pump stations' back-up generator has a broken fuel gauge slated for repair. The WWTP Critical equipment and structural supports show signs of deterioration from corrosion and presently the system cannot be operated as a dual train as TCW staff are utilizing viable parts to keep one train functioning properly until the plant replacement (originally planned in 2018 is completed. The primary reason for DWR staff visit was to discuss the proposed major permit modification for a new WWTP utilizing current design and technology. Questions specific to this permit modification may be directed to lauren.plummer@ncdenr.gov, our Central Office permitting staff assigned to this project. The in -line turbidity meter is due for calibration in September 2022. TCW staff noted floating solids after the aeration basin as a seasonal occurrence at most of their plants. Floating solids are to be skimmed and disposed appropriately. Potential cause may be biological die -off due to warm temperatures, decreased dissolved oxygen and competition for food source per discussion with additional MRO staff, Wes Bell (NPDES Compliance). The Irrigation System and Records Page 2 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Distribution could not be assessed due to line damage discovered that morning and suspected to be from cart / vehicle traffic. Only authorized vehicles for maintenance should be allowed in the drip fields. Additional signage and education may assist. Due to time constraints limited records were reviewed. Laboratory data was reviewed on -site via ORC cell phone to confirm elevated Total Suspended Solids reported in June were accurate. This item was managed in separate communication on September 22nd, 2022, for the resulting NOV-2022-LV-0659. Additional items of Interest TCW Wastewater received field lab certification for pH and Total Residual Chlorine. Meters, calibration standards and documentation reviewed appeared to be in order at the time of inspection. A notation on the side of the field pH meter references a calibration date of 12/21 and warrants discussion with the manufacturer to determine unit requirements beyond your manual standards calibration. Please contact Maria Schutte by email maria.schutte@ncdenr.gov or phone (704-235-2184) should you have questions. Page 3 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type 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 IEI IEI IEI IEI • Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: System is aging and shows signs of extensive corrosion. This site visit was conducted primarily for the proposed major modification for plant replacement; also noted in summary section and cover letter. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Comment: Telemetry is not required for this deemed permitted collection system but is connected to alleviate pressure of daily visitations. Weekly visitations are required when telemetry is operating / daily when it is down. The collection system required assessment for pumping, blockage, etc. at the time of inspection. See detailed comments in Summary Section and Cover Letter. Treatment Flow Measurement -Influent Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 4 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Does flowmeter record flow? Does flowmeter appear to monitor accurately? • ❑•❑ ❑ ❑ ❑ ❑ Comment: Flow meter readings are taken and recorded manually. The meter is due for calibration in September 2022. Treatment Flow Measurement -Water Use Records Is water use metered? Are the daily average values properly calculated? Comment: There is a potable water supply at the adjacent maintenance building. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Effluent flow is the irrigation to each field, and is recorded by the irrigation computer system. 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? Comment: Fuel gauge at the pump station is slated for repair. manages the pump station and plant, but generator contract company. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Per previous inspection reports, TCW maintenance is managed by another Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The bar screen is currently functioning. As noted in the previous inspection, there is significant corrosion in the support system for the bar screen. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page 5 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine Is activated sludge an acceptable color? • ❑ ❑ ❑ Comment: See floating solids related comments in Summary Section and Cover letter. Fixtures were borrowed from the unused train to repair the operational train until full replacement. The WWTP currently does not have a functioning back-up (redundancy) as originally designed. 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 • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ Comment: Also noted in previous inspection(s) fats, oil and grease (FOG) are present at the WWTP and collect at the weir. The WWTP replacement cannot fix FOG in the system. The facility needs to eliminate FOG at the sources (kitchen and meeting facilities) prior to the collection system. Treatment Return pumps Are they in place? Are they operational? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Per previous inspection report when 5-day upset pond pump is not operable volume can be returned using the WWTP pumps to create reverse flow, which is not an ideal situation. A plant upgrade is in the works with this permit modification. 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? Is the clear well free of excessive solids? Is the mud well free of excessive solids and filter media? Does backwashing frequency appear adequate? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: While system may appear adequate, there was a recent (June NDMR) exceedance of Total Suspended Solids, which could be related to FOG and / or other floating solids in the system (see Summary Section). This warrants continued operator assessment / investigation to maintain effluent quality until WWTP replacement. Treatment Disinfection 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Page 6 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine 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: Per previous inspection report a potential UV replacement unit was to be installed but now the entire WWTP replacement / upgrade is proposed. 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? Do lab sheets support data reported on GW-59s? Are Operational and Maintenance records present? ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ ❑ ❑ Page 7 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine 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 in Summary Section and Cover Letter. An unknown kitchen sink bypass was found and repaired at the grease trap for the collection system. Due to time constraints records were not assessed in the detail planned. MRO staff hasd NDMRs and NDARs on -site and the ORC was able to access a requested lab report via his cell phone. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Comment: Operator discovered that morning, line damage preventing irrigation to the fields. Per previous reports the area is served by a community well approximately 800 feet from the reclaimed system. 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? Yes No NA NE ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ Page 8 of 9 Permit: WQ0015931 Owner - Facility:Tngc Charlotte LLC Inspection Date: 09/08/2022 Inspection Type : Compliance Evaluation Reason for Visit: Routine 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? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ Comment: Drip fields are utilized, the spray field is not but is maintained for use as needed. The drip system was not assessed due to a damaged line at the time of inspection. See additional comments in Summary Section and Cover Letter. Page 9 of 9