WQ0023580_Staff Report_20230731

State of North Carolina
Division of Water Resources
Water Quality Regional Operations Section
Environmental Staff Report
Quality
To: ❑ NPDES Unit ® Non -Discharge Unit Application No.: WQ0023580
Attn: Leah.Parentendeq.nc. og_v Facility name: Cove Key Townhomes on Lake Norman WWTP
County: Iredell
From: Maria. Schutte(oDdeq.nc.gov
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: 07-17-2023
b. Site visit conducted by: Maria Schutte
c. Inspection report attached? ❑ Yes or ® No, Follow-up site visit anticipated. BIMS to be completed.
d. Person contacted: Brian Stephens (ORC) and their contact information: (980) 339 - 1105 ext.
Also met with Permittee, current HOA — President: A. Brent Brower contact information:
abrentbrowerkjzmail.com.
e. Driving directions: From MRO travel to Hwy 115S (Main St); turn right onto Langtree Road, Cross over I-77
through roundabout to Mecklynn Road. The WWTP is on the right past Cove Way.
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
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:
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:
FORM: WQROSSR 04-14 Pagel of 5

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:
7. Are there any setback conflicts for proposed treatment, storage and disposal sites? ❑ Yes or ❑ No
If yes, attach a map showing conflict areas.
8. 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:
9. 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:
10. Possible toxic impacts to surface waters:
11. 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
ORC: Brian Stephens Certificate #: SI1008005 Backup ORC: Brandon Long Certificate #: SI991385
2. Are the design, maintenance and operation of the treatment facilities adequate for the type of waste and disposal
system? ® Yes or ❑ No The WWTP operation has historical challenges related to low system flow.
If no, please explain:
Description of existing facilities: 5 manhole collection system to 1 pump station to the WWTP, with 1 application
field, a wet -weather lagoon and 5-day Lipset pond, as is standard with reclaimed systems.
Proposed flow: Same
Current permitted flow: 7,200 gpd
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.) See comments under section V.
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:
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:
5. Is the residuals management plan adequate? ® Yes or ❑ No
If no, please explain: Residuals storage and 5-day upset pond need pumping.
6. Are the existing application rates (e.g., hydraulic, nutrient) still acceptable? ® Yes or ❑ No
If no, please explain:
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
If no, please explain: The 5-day upset pond is synthetically lined. The wet weather storage lagoon proposed
design called for a "Bentomat or equivalent" type liner. By design this tyke of liner cannot be seen, so the la.og_on
appears to be clay lined. In the current permit CO staff described this lagoon as "Synthetically Lined" also, but
FORM: WQROSSR 04-14 Page 2 of 5

this appears to be some type of fabric, with degradation now noted at the top and sides of the lagoon berm. It is
unclear to current MRO staff and all who service the system now, if that was just for bank stabilization (or edges
of the Bentomat?), as it does not appear to be a typical (synthetic) liner material. Either way, with the liner
degradation and need for vegetation removal (trees and brush), the MRO has recommended Permittee and ORC
consult with an Engineer to determine liner / lagoon integrity, as well as WWTP assessment for repair /
replacement needs and cost analysis.
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 followinQ (expand table if necessarv):
Monitoring Well
Latitude
Longitude
O / //
O / //
O / //
O / //
O / //
O / 11
O l 11
O l 11
Offf
o , „
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:
Provide input to help the permit writer evaluate any requests for reduced monitoring, if applicable.
MRO staff would support removal of Total Nitrogen, TKN and Phosphorus analyses added to the Attachment A
at the last permit renewal. The data collected over the past permit cycle show these parameters at minimal
concentrations, no need for requiring PAN calculations and there is no established Phosphorus limit.
13. Are there any permit changes needed in order to address ongoing BIMS violations? ❑ Yes or ® No
If yes, please explain:
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.)
The morning of the most recent inspection, the ORC noted the system would not allow irrigation and instead was
rerouting flow to the head of the plant. To maintain plant volume, the reclaimed water is being diverted to the
wet -weather lagoon. Parts are on order and ORC will contact MRO staff upon repair, to continue inspection of
gpplication fields and irrigationquipment.
If the facility has had compliance problems during the permit cycle, please explain the status. Data exceedances
for Fecal Coliform and Monthly Total Ammonia Nitrogen were reported in the March 2023 NDMR . Has the RO
been working with the Permittee? Yes
Is a solution underway or in place? Yes, Permittee and ORC in communication with Engineer for options,
potential upgrade for this aging system. The HOA is looking at funding and hopes to have a plan in place over
the next year.
ORC informed MRO of the data exceedances, UV bulbs were replaced, the housing cleaned and April resampling
showed Fecal Coliform returned to passing_.
Have all compliance dates/conditions in the existing permit been satisfied? ❑ Yes ® No ❑ N/A
If no, please explain: Purchased water level gauge(s) have not been installed.
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: This is a Non -Discharge, Reclaimed water permit. There should be no
discharge to surface waters. Impacts of Reclaimed water release would be minimal to non-existent when
FORM: WQROSSR 04-14 Page 3 of 5

treatment meets compliance. The ,greater threat to surface water is from the individual homes and collection
system, as that infrastructure is closest to the lake and is raw wastewater — Nutrients, fecal coliform and solids
would be of potential concern.
17. Pretreatment Program (POTWs only):
IMA:90144[MIRW13yIM1;1102;71[K/lu1u111►1IMIY[11M
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
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
Age of system. WWTP shows heavy rust in most compartments. Due to low
Require assessment of
flows, they have not utilized the 2'train. It does not appear to MRO staff that
treatment works and wet-
train would function properly w/o leaks / short-circuiting between units. These
weather lagoon.
issues may be present in the train utilized but not visible. And reference 111.9.
above for comments / concerns related to the wet weather lagoon.
Keep Attachment C or
incorporate deemed
collection system language
Okay with whichever option CO staff determines is most appropriate.
into the permit as with the
recent WQ0015931 permit.
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
FORM: WQROSSR 04-14 Page 4 of 5

❑ Deny (Please state reasons: )
6. Signature of report preparer: Maria Schutte July 315t, 2027
Signature of regional supervisor:
Date: 7/31/2023
ADDITIONAL REGIONAL STAFF REVIEW ITEMS
by:
61 FB69A2D84A3...
MRO staff met with Chip Hawkins (Manager of Cove Key Association, Inc.) and Brent Brower (current HOA
President). They are the current contacts. Mr. Hawkins is with a new company and that information may need to
be updated in BIMS.
The comments below were noted in the previous permit renewal and left for CO information as they still accurately
describe plant conditions, show the HOA is slow to make changes and now, point to the need for a permit condition to
move the inevitable process along. At the time of those comments, the information MRO received was that the Town of
Mooresville denied connection to their collection system (as stated below). However, during this most recent inspection,
MRO staff was informed by Mr. Brower that they could have connected to a pump station, but the Town of Mooresville
required annexation, so the HOA opted not to take that route.
The plant ORC is currently in discussion with a contractor for quotes on a plant rehabilitation, as it is showing
si ng s of age and weathering, with rust and paint chipping from components. MRO staff suggested the HOA
consider a cost comparison of repairs vs. a system upgrade with newer technology, and discuss with their ORC
for the best long-term management. This facilitgppears necessary for many years, as the Town of Mooresville
recently denied their request to connect via an adjacent, private collection system.
FORM: WQROSSR 04-14 Page 5 of 5