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SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED
April 19, 2023
Wade Anderson
Email: wade.anderson@lassonde.com
SUBJECT: Compliance Inspection Report
Clement Pappas WWTF
Non-discharge Permit No. WQ0004797
Henderson County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Clement Pappas WWTF
on 4/11/2023. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in Non-discharge Permit No. WQ0004797. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report
entitled "Compliance Inspection Report".
There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.
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.
Sincerely,
Melanie Kemp, Environmental Specialist
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Inspection Report
EC: LF
CC: Dale Wolf, ORC
Compliance Inspection Report
Permit:WQ0004797 Effective:09/01/20 Expiration:07/31/26 Owner :Clement Pappas NC LLC
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Henderson
Asheville
Dale Irvin Wolfe
Effective:Expiration:Facility:Clement Pappas WWTF
125 Industrial Park Rd
Hendersonville NC 28792
Title:Phone:828-693-0711
From I-26E take exit 44 to US Hwy 25S. Travel 2.5 miles to Industrial Park Rd, turn left. Facility is loacted 1 mile on the left. To
spray field, continue past Industrial Park Rd to Brookside Camp Rd, turn left, go 1.5 miles, fields are on left.
Secondary ORC(s):
828-693-0711Phone:987551Certification:Dale Irvin WolfePrimary ORC:
SI,System Classifications:
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
04/11/2023 09:30AM 10:30AM
Melanie Kemp
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Wastewater Irrigation
Compliance Evaluation
Question Areas:
Treatment Flow Measurement-Effluent Treatment Flow Measurement-Influent Miscellaneous Questions
Treatment Flow Measurement-Water
Use Records
Treatment Record Keeping
Treatment Lagoons End Use-Irrigation Treatment Flow Measurement
Wells
(See attachment summary)
Page 1 of 6
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004797
04/11/2023 Compliance Evaluation
Clement Pappas NC LLC
Routine
Inspection Summary:
Melanie Kemp, with the Asheville Regional Office, conducted a compliance evaluation inspection of Clement Pappas
wastewater treatment facility. This inspection was conducted to determine whether the facility is being operated and
maintained in compliance with non-discharge permit WQ0004797. Dale Wolf was present and assisted with the inspection.
Overall, the facility appeared to compliant with the permit.
Wastewater from plant operations flows into two settling basins within the WWTP. From there it goes through two
hydrasieves before flowing into the vault/septic tank. Solids from the WWTP are pumped into a holding tank where they are
removed by VLS and properly disposed of. All effluent flows to the aerated lagoon prior to being utilized for irrigation or being
diverted to the Hendersonville WWTP. Clement Pappas has constructed a tie-in to the MSD line as well, but effluent has not
been routed there yet. Once they are fully permitted, the facility expects to divert to MSD on an as-needed basis within the
next few months. If effluent cannot be used for irrigation due to wet or cold weather, it is pumped back to the WWTP where it
goes through a DAF unit before being diverted to Hendersonville WWTP or MSD. An in-line digital flow meter captures
effluent flow from the DAF and is recorded on NDARs as needed. The facility hasn’t needed to send effluent off-site since
2020 due to a drop in production.
All five pumps are aerating the lagoon full-time. Freeboard records were available, and levels are consistently within permit
limits. Staff must trap burrowing moles that live in the lagoon embankments. Embankments are vegetated and free of trees
and other woody vegetation.
The irrigation heads are calibrated by site staff. They were last calibrated in February of 2021 (required to do so once per
permit cycle). All flow meters are calibrated twice each year and are due for another calibration in May 2023.
Irrigation wasn’t occurring during the inspection due to recent rain. The field were recently re-seeded (in February) and some
bare patches were visible due to new growth still being established. Most fields appeared to have a healthy stand of fescue.
The crop is still being cut, bailed, and donated to local farmers. Mr. Wolfe reports there is still limited use of some fields due
to consistently wet conditions.
Staff last collected field composites for the annual soil fertility analysis in June 2022. ESP values were within recommended
guidelines and staff will continue to monitor zinc levels in Field 1. The 2021 soil fertility analysis for field 1 showed the Zn-I at
1376 and 2022 values were around 844. The NCDA recommends no longer applying nutrients to fields when zinc levels
surpass 2000. Staff should also continue to monitor the P-I of the soils since very high indices (>100) increase P mobility
and can lead to micronutrient deficiencies and phosphorus loss from soils to ground and surface waters. Staff have not
amended fields in about 2 years, and do not apply lime to avoid pH issues.
After determining that monitoring well MW-7R has been damaged by plant root infiltration, Clement Pappas plans to have a
new well installed in this area in May 2023. They expect to sample and report the results in May as well. It has been
determined that VOC concentrations in background well MW-5 are associated with offsite contamination.
Page 2 of 6
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004797
04/11/2023 Compliance Evaluation
Clement Pappas NC LLC
Routine
Type Yes No NA NE
Reuse (Quality)
Infiltration System
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Spray, HR
Activated Sludge Drip, LR
Recycle/Reuse
Single Family Drip
Lagoon Spray, LR
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.)
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?
Two influent flow meters (one for redundancy), measure digitial flow. Calibrated twice a year,
due again in May 2023.
Comment:
Treatment Flow Measurement-Water Use Records Yes No NA NE
Is water use metered?
Are the daily average values properly calculated?
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?
Facility monitores all flow from lagoon, and keeps track of flow from DAF unit (that goes to MSD
or Hendersonville WWTP).
Comment:
Page 3 of 6
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004797
04/11/2023 Compliance Evaluation
Clement Pappas NC LLC
Routine
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?
See Summary for details.Comment:
End Use-Irrigation Yes No NA NE
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?
Page 4 of 6
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004797
04/11/2023 Compliance Evaluation
Clement Pappas NC LLC
Routine
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?
Groundwater is monitored for more than effluent and the facility has no effluent limits. MW-7R
is damaged and is scheduled to be replaced in May 2023.
Comment:
AERATED LAGOON -
Treatment Lagoons Yes No NA NE
Lagoon Type Aerated
Primary/Secondary Primary
Influent structure
Banks/berms (seepage and erosion)
Vegetation (excessive vegetation on banks/berms)
Liner
Liner Type Full, clay
Baffles/curtains
Freeboard Marker
Required freeboard 2
Feet
Actual freeboard 3.5
Feet
Are increments clearly marked on gauge at adequate intervals?
Has the water level gauge been surveyed w/ respect to lowest point on dike? wall?
No Evidence of overflow
Acceptable color
Floating mats
Excessive solids buildup
Page 5 of 6
Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0004797
04/11/2023 Compliance Evaluation
Clement Pappas NC LLC
Routine
Aerators/mixers
Effluent structure
Lagoon cover
Page 6 of 6