WQ0002838_Compliance Evaluation Inspection_20240220

DocuSign Envelope ID: 30CFBC66-DA22-44DF-8889-79CF72671EE8
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
February 20, 2024
CERTIFIED MAIL #: 7020 3160 0000 4109 4711
RETURN RECEIPT REQUESTED
Yes Companies Exp Wfc LLC
Karen E. Hamilton
5050 S. Syracuse Street
Suite 1200
Denver, CO 80237
Subject: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2024-PC-0126
Compliance Evaluation Inspection
Permit # WQ0002838
Facility: Deerhurst MHP WWTF
Wake County
Ms. Hamilton,
On January 23, 2024, Jim Westcott from the Raleigh Regional Office visited your wastewater
treatment lagoon and spray irrigation system to evaluate compliance with the subject permit.
The assistance of Mr. Frank Dantonio and Anthony Branch at the time of the inspection was
appreciated.
The facility is permitted for the operation a .019229 million gallon per day (MGD) wastewater
collection, treatment and irrigation facility consisting of approximately 15,500 Linear feet (LF)
of 6-inch gravity sewer; a 0.9 million gallon (MG) primary stabilization lagoon; a 1.8 MG
polishing/storage lagoon with access dock and custom fabricated 12-inch screened intake
pipe; a tablet chlorinator; a 5000 gallon chlorine contact tank; a primary 340 gallon per minute
(GPM) non -submersible irrigation pump with an audible high-water alarm; and a backup 350
GPM, 20 horsepower (hp) 3-stage non -submersible irrigation pump; a totalizing meter; an
11.47 acre spray irrigation area; and all associated piping, valves, controls, and appurtenances
with no discharge of wastes to surface waters.
The permit, which was issued September 11, 2019, is effective through November 30, 2025.
Division records indicate the required annual fee for the period ending June 30, 2024, due July
01, 2023, has been paid.
Inspection criteria consisted of the following:
• Review of permit conditions.
• Evaluation of facility information and wastewater collection and lagoon system.000
NORTH CARCLINA � �
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200

DocuSign Envelope ID: 30CFBC66-DA22-44DF-8889-79CF72671 EE8
• Review of logbook, operation and maintenance plan (O&M), calibration records and
Non -Discharge Monitoring Report (NDMR) and Non -Discharge Application Report
(NDAR-1) .
• On -site inspection of lagoon wastewater system and distribution components.
Findings during the inspection were as follows:
The system is composed of 125 service connections and 55 septic systems to the main 0.9 MG
primary lagoon where solids separation occurs. A tie in at the center between the 7.8 MG
stabilization/storage lagoon is connected to a submerged screened intake line which draws
treated effluent into a .005 MG chlorine contact tank.
The perimeter fencing surrounding the facility spray fields, storage lagoons and discharge
pump/contact tank was secured.
The freeboard level(s) in each pond were -35" respectively. lagoon freeboard levels are measured
3 times/week along with the required pH and Chlorine residual.
The current operator in responsible charge (ORC) is Anthony Branch, and the designated
backup is Williamm Lamm.
The daily operations log and daily facility checkoff form(s) were complete.
An O&M manual was not available at the time of inspection.
A map of the collection system was not available at the time of inspection.
A grease control program was not implemented or available at the time of inspection.
Chlorine tablets were not evident in the chlorination tubes at the time of inspection. The
correct supply of tablets were available on site. Additionally, the contact chlorine tank lids were
not present/secured and the tank open to atmosphere.
The Siemens Sitrans F M Mag 5000 influent magnetic flowmeter was last calibrated on July 27,
2023, by Delta Systems Environmental.
Permit required lab analysis is conducted by Envirochem Laboratories. Effluent sample
analysis was not available.
The Annual Standard Soils fertility analysis is conducted by the North Carolina Department of
Agriculture and Consumer Services (NCDA & CS) and samples were last collected in October
2022. Records were not available for review.
The GW-59 reports were not available at the time of inspection. Envirochem collects the
compliance samples and forwards the results to a compliance officer at Envirolink. The
November 2023 samples were analyzed for volatile organic compounds (VOC) as required.
Each of the four spray field zones (A, B, C, D) consist of a total of 130 spray heads individually
isolated with a ball valve(s) and are operated for a total of 20 minutes each at a total flow of
180 gpm. Each zone is isolated with a manual valve to ensure even distribution in each zone.
Field C and D had a total of 12 spray heads isolated due to the potential for ponding and
runoff.
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly

DocuSign Envelope ID: 30CFBC66-DA22-44DF-8889-79CF72671 EE8
Monitoring wells MW-1, MW-2, MW-3, and MW-4 were located and secured. The last samples
drawn for analysis were on November 3, 2023, by Envirochem Laboratories.
No residuals have been removed from the facility on record beginning in 1983.
No deficiencies were noted in the NDMR documents.
III. OPERATION AND MAINTENANCE REQUIREMENTS
Condition 1.1,1.2 states "The permittee shall effectively operate and maintain the subject
facilities as a non -discharge system to prevent the discharge of any wastewater resulting from
the operation of this facility. [15A NCAC 02T. 0500]. The permittee shall maintain an Operation
and Maintenance Plan, which at a minimum shall include operations functions, maintenance
schedules, safety measures and a spill response plan." Within 30 dgys of receipt of this
letter, please provide a written Operations and Maintenance plan.
IV. MONITORING AND REPORTING REQUIREMENTS
Condition IV.8 states the Permittee shall maintain a record of all residuals removed from this
facility. This record shall be maintained for five years and be made available to the division
upon request. [15A NCAC 02T .0508(B)]
Within 30 dgus of receipt of this letter, please indicate the status anticipated timeline
for meeting this required permit condition to ensure residuals are disposed of in
accordance with [15A NCAC 02T.1100].
Condition IV. 11 states two copies of the monitoring well sampling and analysis results shall be
submitted on a compliance monitoring form (GW-59), along with attached copies of laboratory
analyses, on or before the last working day of the month following the sample month.
Within 30 daus of receipt of this letter, please provide the previous of 2021 of GW-59 forms to
this office. [15A NCAC 02T.0105(m)].
Condition IV.13 states an annual representative soils analysis (i.e., Standard Soil Fertility
Analysis) shall be conducted on each irrigation site listed in attachment B.
Within 30 dgys of receipt of this letter, please provide the previous five years of results
to this office. [15A NCAC 02T.0108 (c)].
Section X.13. requires "The Permittee shall report to the Raleigh Regional Office, telephone
number [phone], within 24 hours of first knowledge of the following:... Any process unit
failure (e.g., mechanical, electrical, etc.) rendering the facility incapable of adequate wastewater
treatment.... Any time self -monitoring indicates the facility has gone out of compliance with its
permit limitations." [15A NCAC 02T .0108(B)(1)(A)].
Wastewater is applied to four separate fields, both of which receive the same volume of water
during each application, according to non -discharge application reports (NDAR) submitted for
this facility. Field D encompasses 2.58 acres, 32 spray heads and field C has 2.46 acres with 32
spray heads. At the time of inspection, a total of 12 spray heads were not operating between the
two fields and had been abandoned. Within 30 dgUs of receipt of this letter, please provide
documentation that the abandoned spray heads have been replaced and are in proper
working order and distributing flow equally to this office. [15A NCAC 02T.0108 (c)].
Section 11. 6. requires that "Application rates, whether hydraulic, nutrient, or other pollutant shall
not exceed those specified in Attachment B. [15A NCAC .02T .0108(b)(1)(A)].
��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
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DocuSign Envelope ID: 30CFBC66-DA22-44DF-8889-79CF72671 EE8
This reduction in the application area was not reported to the Division of Water Resources, nor
was it accounted for in the NDAR reports submitted for the site. Because of this omission, it is
possible that NDAR reports are inaccurate, and wastewater has been over -applied to the
irrigation field.
Requested Response:
Within 30 days of the receipt of this letter, prepare a written plan providing a detailed
description of how you will bring the facility into compliance with the permit. This plan should
include a detailed schedule for completion for all the items listed below in addition to those
highlighted in bold in the previous section. Items that can be completed prior to submittal of
this plan should be completed and documented within the compliance plan.
1. Develop and implement a grease control program for the facility. This should include a
plan for removal and proper disposal of the grease and other debris accumulated on the
surface of the storage lagoon.
2. Develop and implement a program to regularly measure the accumulation of solids
within the treatment/storage basin. If sediments are found to have reduced the storage
capacity of the basin below that specified within the permit, develop a corrective action
for removal and proper disposal of the solids.
3. Repair the broken and abandoned spray heads so that the application area as well as
the hydraulic and nutrient loading rates match those in the permit.
4. Verify that there is no pooling or runoff of irrigated sewage. If pooling or runoff occurs,
prepare a corrective action plan and submit this to the Division of Water Resources
inspector.
5. Provide the Division of Water Resources inspector with the required plans and
documents listed in the previous section, and make sure these are available on site.
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violations of
North Carolina General Statute (G.S.) 143-215.1 and the facility's Non -discharge Permit.
Pursuant to G.S. 143-215.6A, a civil penalty of Not more than twenty-five thousand
dollars ($25,000.00) may be assessed against any person who violates or fails to act in
accordance with the terms, conditions, or requirements of any permit issued pursuant
to G.S. 143-215.1.
If you wish to provide additional information regarding the noted violation, request technical
assistance, or discuss overall compliance please respond in writing within ten (10) business
days after receipt of this Notice. A review of your response will be considered along with any
information provided in support of this response. You will then be notified of any civil penalties
that may be assessed regarding the violations. If no response is received in this Office
within the 10-day period, a civil penalty assessment may be prepared.
Corrective action should have already been taken to correct this problem and prevent further
occurrences in the future. The Division of Water Resources may pursue enforcement action for
this and any additional violations of State law. If the violations are of a continuing nature, not
related to operation and/or maintenance problems, and you anticipate corrective action
activities, then you may wish to consider applying for a Special Order by Consent.
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly

DocuSign Envelope ID: 30CFBC66-DA22-44DF-8889-79CF72671 EE8
Please continue to periodically inspect and evaluate the wastewater spray irrigation system
components are properly maintained and operating as designed. Maintain all associated
operational records onsite for a period of five years as required by the subject permit.
If you have questions or comments about this inspection or the requirements to take corrective
action (if applicable), then please contact Jim Westcott at james.westcott64,)ncdenr.gov or 919-
791-4247.
Sincerely,
AD.o'c'u.Siwgneld by:
UI.�.l� Na
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Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Laserfiche
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly