WQ0044044_Staff Report_20230220

State of North Carolina
Division of Water Resources

Water Quality Regional Operations Section
Staff Report

FORM: WQROSSR 04-14 Page 1 of 5

To: NPDES Unit Non-Discharge Unit Application No.: WQ0044044
Attn: [e-mail] Facility name: Tradition Golf Club -
County: Mecklenburg
From: [e-mail]
Mooresville Regional Office

Note: This form has been adapted from the non-discharge facility staff report to document the review of both non-
discharge and NPDES permit applications and/or renewals. Please complete all sections as they are applicable.

I. GENERAL AND SITE VISIT INFORMATION
1. Was a site visit conducted? Yes or No
a. Date of site visit: 02-10-2022.
b. Site visit conducted by: Maria Schutte.
c. Inspection report attached? Yes or No, NA, new permit for end-user.
d. Person contacted: Mr. Preston Buckman (Special Facilities Manager w/ Meck. Co. Parks and Recreation)
phone: [phone] or email: [e-mail].
FYI – Meck. Co. contracts with “Pinnacle” a third party to operate the Golf Course. The current course
Superintendent is Mr. Eric Ramirez. Contact information and phone was not requested, as Mr. Buckman
requested to be present for future inspections. The course superintendent would also be required for
knowledge to operate irrigation system.
e. Driving directions: From MRO travel to I-77 S; Take I-485 exit toward Matthews; Take Benfield Rd./
Prosperity Church Rd. exit; Golf club entrance will be on the left.
2. Discharge Point(s): NA – this is a non-discharge permit.
Latitude: Longitude:
Latitude: Longitude:
3. Receiving stream or affected surface waters:
Classification:
River Basin and Sub-basin No.
Describe receiving stream features and pertinent downstream uses:
II. PROPOSED FACILITIES: NEW APPLICATIONS NA – this is an existing Reclaimed Water end-user –
recent technicality / responsibility placed on Reclaimed water generator has resulted in this request for end-user
irrigation permit.
1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit)
Proposed flow:
Current permitted flow:
2. Are the new treatment facilities adequate for the type of waste and disposal system? Yes or No
If no, explain:
FORM: WQROSSR 04-14 Page 2 of 5
3. Are site conditions (soils, depth to water table, etc.) consistent with the submitted reports? Yes No N/A
If no, please explain:
4. Do the plans and site map represent the actual site (property lines, wells, etc.)? Yes No N/A
If no, please explain: But Laserfiche Pg.55 of irrigation network is poor quality, cannot zoom to view irrigation
network or read plan descriptions, and zone network identification is changed as stated in Section V.
5. Is the proposed residuals management plan adequate? Yes No N/A
If no, please explain:
6. Are the proposed application rates (e.g., hydraulic, nutrient) acceptable? Yes No N/A
If no, please explain: Are there any setback conflicts for proposed treatment, storage and disposal sites?
Yes or No
If yes, attach a map showing conflict areas.
7. Is the proposed or existing groundwater monitoring program adequate? Yes No N/A
If no, explain and recommend any changes to the groundwater monitoring program:
8. For residuals, will seasonal or other restrictions be required? Yes No N/A
If yes, attach list of sites with restrictions (Certification B)
Describe the residuals handling and utilization scheme:
9. Possible toxic impacts to surface waters:
10. Pretreatment Program (POTWs only):

III. EXISTING FACILITIES: MODIFICATION AND RENEWAL APPLICATIONS
1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A This is an
application for an existing end-user reclaimed water system permit, which does not require as designated operator
as it is associated with the Mallard Creek WWRF – Henry Eudy (980-214-5977 cell) is the ORC – NPDES Permit
NC0030210.
WWTP ORC: SI ORC: Certificate #:
BU-ORC: Certificate #:
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: Plant has the option to divert some effluent discharge to the Reclaimed Water
System for offsite irrigation at the Tradition Golf Course. Charlotte Water controls access to the vault
connections and reclaimed water flow to the distribution system.
Proposed flow:
Current permitted flow:
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.) Currently there is no reclaimed water distribution to the Golf Course irrigation system. The golf Course
was assessed for proper signage, the pump house and irrigation tracking software viewed. Recent rain created wet
conditions throughout the course, so MRO staff did not request operation of the spray irrigation system.
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: It has been several years since the reclaimed system was utilized, only (municipal) potable
water is currently used. The potential for a future groundwater system was discussed.
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:
FORM: WQROSSR 04-14 Page 3 of 5
5. Is the residuals management plan adequate? Yes or No NA to this end user. Residuals apply to the
source as noted below.
If no, please explain: The reclaimed permit does not generate additional residuals beyond the NPDES permit.
This plant is a source under Charlotte Waters’ RLAP permit WQ0000057. Charlotte Water also has a residuals
permit in SC.

6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? Yes or No
If no, please explain: NA – There are no established limits for end use. The irrigation sites are controlled by the
end user(s) with the intention of conserving potable water (and cost) by utilizing reclaimed water to maintain
course vegetation. Because this is an established conjunctive system, the MRO is not aware of hydraulic loading
limits placed on the end-user. Technically the only limit is to NOT create ponding or run-off issues; however, the
course Superintendent is also limited by the needs of specialized grasses throughout fairways and greens.
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 Technically NA –
but Yes, as written under the related WQ0013252 Mallard Creek Permit.
If no, please explain:
10. Were monitoring wells properly constructed and located? Yes No N/A
If no, please explain:
11. Are the monitoring well coordinates correct in BIMS? Yes No N/A
If no, please complete the following (expand table if necessary):
Monitoring Well Latitude Longitude
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
○ ′ ″ - ○ ′ ″
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: NA – under this conjunctive end-user permit, but
MRO staff did request to see the irrigation software and flow to individual zones can be determined.
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: Unwarranted violations continue to be generated by BIMS for this and other MRO
assigned WWI permits, that are only required to report an estimated monthly flow; or infrequently irrigate. It
appears some non-violations are related to how IPU enters the information (“no flow” vs “no data” checked
box) and in other cases may be related to “calculation” limitations/interpretations by the BIMS system (monthly
total w/o daily entries). Michele Scott (IPU) has addressed some of the “no flow” concerns per past email
communication; however, the MRO is open to suggestions, if CO staff has ideas on how to correct for these
ongoing (likely system and statewide) issues.
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.)
FORM: WQROSSR 04-14 Page 4 of 5
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?
Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A
If no, please explain: MRO received an O&M / spill plan for the WQ0013252 CW permit but will need separate
plans for each individual end-user permit. As stated by the engineer in the application – some historical plans for
the irrigation equipment are potentially lost and unavailable. This item is noted in Section IV.2.
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):
IV. REGIONAL OFFICE RECOMMENDATIONS
1. Do you foresee any problems with issuance/renewal of this permit? Yes or No
If yes, please explain:
2. 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
Better / Updated site map
of how irrigation system
zones relate to golf course
fairways, etc.
Per onsite discussion with course Superintendent, Original system Zones 1-7
are programmed differently in the irrigation system, which was connected to
telemetry a couple years ago. See MRO created table in section V. MRO will
leave for CO staff how to address this with the Permittee or Engineer.
Highlight in cover letter,
for reminder as O&M /
Spill plans can be
submitted separately to the
RO and do not need to
delay the permitting
process.
MRO received an O&M / spill plan for the WQ0013252 CW permit but will
need separate plans for each individual end-user permit. As stated by the
engineer in the application – some historical plans for the irrigation equipment
are potentially lost and unavailable. This item is noted in Section III.14.

3. List specific permit conditions recommended to be removed from the permit when issued:
Condition Reason

4. List specific special conditions or compliance schedules recommended to be included in the permit when issued:
Condition Reason
FORM: WQROSSR 04-14 Page 5 of 5

5. 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
Deny (Please state reasons: )
6. Signature of report preparer: Maria Schutte – February 17th, 2023
Signature of regional supervisor:
Date:
V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS

Zone Description in Original Map Zone Identification by Irrigation
Software *
Areas associated with each Zone
1 18 Fairway #18 tee to green, Driving Range,
Putting Practice green and Landscaping
areas.
2 11 Fairways 10, 11 & 12 (tee to green)
3 14 Fairways 13, 14 & 15 (tee to green)
4 16 Fairways 16 & 17 (tee to green)
5 6 Fairways 5, 6 & 7 (tee to green)
6 4 Fairways 2, 3 & 4 (tee to green)
7 9 Fairways 1 & 9 (tee to green)
*The zone identification is apparently now tied to the control (or communication ?) box for the separate irrigation systems.
2/20/2023