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Home My WebLink AboutWQ0024694_Compliance Evaluation Inspection_20180727 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 Certified Mail # 7017 2620 0000 9759 4834 Return Receipt Requested July 27, 2018 Shannon V Becker Aqua North Carolina Inc 202 Mackenan Ct Cary, NC 27511 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2018-PC-0282 Permit No. WQ0024694 Bright's Creek Golf Club Polk County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Bright's Creek Golf Club on June 28, 2018. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0024694. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Storage 5-Day Upset pond: The northeast slope of the dam has areas of moderate to sev ere erosion. The dam does not have suitable grass cover. Areas of the dam continue to erode and form small gullies. This is a violation of permit condition III.16. (Operation & Maintenance) _________________________________________________________________________________________________________________________________________________________________________ Storage The Operation & Maintenance Plan (including the Spill Response Plan) has not been generated. This is a violation of permit condition III. 2. (Operation & Maintenance) _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ End Use-Reuse Water supply wells are located within the Compliance Boundary of the irrigation sites. This is a violation of permit condition II.10. (Performance Standards) _________________________________________________________________________________________________________________________________________________________________________ In addition, the issues below must also be addressed: Compliance Issue(s): The permit shows Aqua North Carolina, Inc. as the owner of the irrigation Fields A -F in the permit Attachment B. The Polk County property records indicate Alianza Trinity Development Group as the owner of the golf course. This is a violation of permit condition VI.5. (change of ownership) Remedial actions 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. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Beverly Price with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Lori Ison, Aqua North Carolina WQS ARO LF 20180727_WQ0024694_CEI.rtf DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Compliance Inspection Report Permit:WQ0024694 Effective:01/27/14 Expiration:12/31/18 Owner :Aqua North Carolina Inc SOC: Contact Person: Region: County: Directions to Facility: Polk Asheville Laurie Ison Effective:Expiration:Facility:Bright's Creek Golf Club Regan Jackson Rd Mill Spring NC 28756 Title:Phone:704-489-9404 Ext.57234Area Manager-Western NC I-26 E to Hwy 74 E. Take Mill Spring Ext (Hwy. 108) to intersection of Hwy 9. Turn lft on 9, next left on Silver Crk Rd for approx. 7 mi. Left on Palmer Rd. to guard house- rt on Deep Gap Rd, then rt on Reagon Jackson Rd to WWTP on left Dana A Bixby 990487 704-507-3359 Rickie Daniels 1005667 704-866-8701 Secondary ORC(s): 828-289-9380Phone:992372Certification:Kenneth M DeaverPrimary ORC: SI,WW2,System Classifications: 24 hour contact name Rickie Daniels On-site representative Rickie Daniels On-Site Representative(s): Related Permits: Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 06/28/2018 09:00AM 11:15AM Beverly Price 828-296-4500 Mikal Willmer Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Reclaimed Water Compliance Evaluation Question Areas: Treatment Flow Measurement-Effluent Treatment Flow Measurement-Influent Miscellaneous Questions Treatment Flow Measurement-Water Use Records Treatment Treatment Barscreen Treatment Filters Record Keeping Treatment Activated Sludge Treatment Sludge Storage/Treatment Treatment Influent Pump Station Treatment Clarifiers Treatment Disinfection Treatment Flow Measurement Treatment Return pumps Storage End Use-Reuse Standby Power (See attachment summary) Page:1 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine Inspection Summary: The inspection was conducted by Beverly Price and Mikal Willmer of the Asheville Regional Office. Rickie Daniels assisted with the inspection. Mr. Daniels indicated that he uses dissolved oxygen, settleability and pH readings for WWTP process controls as well as the effluent pH, chlorine and turbidity readings. pH: 4.56 in the Aeration basin – measured with ARO field meter Dissolved Oxygen: 5.4 mg/l – measured with the ARO field meter The turbidity meter was not calibrated in 2017. The current permit does not require calibration but it is recommended. Turbidity read 1.39 NTU’s. The effluent flow meter (ISCO Model 4210) was calibrated on 12/13/17 by Billy Fisher with Clearwater, Inc. The effluent sampler thermometer read 3 degrees celsius and was calibrated by Tony Gragg (Water Tech) on 4/17/17. The sampler is set to collect 100 mls of sample and is set for time composite rather than flow proportional. The automatically activated generator needs a new control panel according to the ORC. In the interim, a portable generator has been installed. Please recall permit condition III.10. which states, “if a generator is employed as an alternate power supply, it shall be tested weekly by interrupting the primary power source”. The tertiary filter is backwashed once per week. This facility services a vacation/second home community and as a result the system is under loaded. The lack of influent makes optimum WWTP operation difficult. Activated sludge is very light in color and solids removal has not been needed so far. Even though the system is under utilized and sludge has not been pumped from the facility, it is recommended that a sludge judge be kept on site to periodically check the solids levels in the clarifier. The sludge return junction box needs to be evaluated for a seal/cover; sludge was splashing out onto the ground. A copy of the permit should be kept at the facility. The Influent Lift Station is fenced and contains emergency contact information. A standby gas powered generator is on site and is automatically activated weekly. A spare pump is on site. Log books appeared to be complete. Irrigation was not occurring at the time of inspection. The following operation /maintenance items were not compliant: 1. Erosion was observed on the northeast slope of the 5-day upset pond. 2.The Operation and Maintenance Plan was not available. The following Performance Standard was not compliant: A permit (Attachment B)/file review shows that Aqua North Carolina, Inc. is the owner of the irrigation fields (132.8 acres) for Bright’s Creek Golf Club. The Polk County property records indicate Alianza Trinity Development Group as the owner of the golf course (irrigation fields). This is a violation of permit condition VI. 5. (Change of Ownership needed). A permit/file review shows that water supply wells (WSW) labeled U, V and W as shown on the 2007 as-built map appear to be located within the Compliance Boundary (CB). This is a violation of permit condition II.10. Page:2 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine Type Yes No NA NE Single Family Spray, LR Reuse (Quality) Infiltration System Single Family Drip Activated Sludge Spray, LR Lagoon Spray, LR Activated Sludge Spray, HR Activated Sludge Drip, LR Recycle/Reuse 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.) The permit shows Aqua North Carolina, Inc. as the owner of the the irrigaiton Fields A-F on Attachment B. The Polk County tax records show Alianza Trinity Development Group as the property owner. Comment: Treatment Influent Pump Station Yes No NA NE 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? 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? Comment: Page:3 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine 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? Comment: Standby Power Yes No NA NE Is automatically activated standby power available? Is generator tested weekly by interrupting primary power source? Is generator operable? Does generator have adequate fuel? The permanent standby generator needs a new control panel. A portable generator is on site. The ORC would be notified by the telemetry system if the standby generator is needed. The approximate travel time for the ORC is 1 hour to arrive on site. Comment: Treatment Barscreen Yes No NA NE Is it free of excessive debris? Is disposal of screenings in compliance? Are the bars spaced properly? Is the unit in good condition? Comment: Treatment Activated Sludge Yes No NA NE 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? Is activated sludge an acceptable color? The D.O. measured at the time of inspection was 5.4 mg/l - ARO D.O. meter was used. This WWTP is under utilized as this is a second/vacation home development. The developement is not built out. The activated sludge is light brown in color due to the lack of wastewater coming into the plant. Comment: Page:4 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine Treatment Clarifiers Yes No NA NE 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? Comment: Treatment Return pumps Yes No NA NE Are they in place? Are they operational? The sludge return junction box should be evaluated as sludge splashes out and onto the ground.Comment: Treatment Filters Yes No NA NE 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? Comment: Treatment Sludge Storage/Treatment Yes No NA NE Is the aeration operational? Is the aeration pattern even? If required, are Sanitary "Ts" present in tankage? Comment: Treatment Disinfection Yes No NA NE 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? Is the fan in the chlorine feed room and storage area operable? Is the chlorinator accessible? If tablets, are tablets present? Page:5 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine 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 lbs 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? NDMR review showed fecal coliform exceedances in July, November and December 2017. Adjustments were made to the sample collection point (the operator was collecting too close to the tablet chlorinator). Comment: 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? Page:6 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine No treatment units bypassed since last inspection? Permit not on site. PAN records are not required. The effluent is monitored for nitrate nitrogen. There is no permit limit for nitrate. Nitrate results are consistently above the 2L Standard for groundwater. Comment: End Use-Reuse Yes No NA NE 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? 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? Page:7 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine The permanent standby generator needs a new control panel. A portable generator is on site. The turbidity meter has not been calibrated in the last 12 months; calibration is not required in the current permit. The turbidity reading was 1.39 NTU's. Effluent not meeting the reclaimed turbidity standard of 10 NTU's is automatically diverted to the 5-day upset pond where it can then be rerouted back to the head of the treatment plant. Effluent not meeting the fecal coliform standard would not automatically be routed to the 5-day pond as the sample result is not instantaneous. The receiver site is a golf course so public access is not restricted, however, irrigation is not usually occurring when golfing is occurring. The golf course is currently closed; there was no access to the clubhouse to determine if a reclaimed notification sign is located there. Water supply wells appear to be located within the Compliance Boundary. Comment: 5-DAY UPSET POND - Storage Yes No NA NE Storage Type?5-day detention pond Storage amount?171552 Cubic Feet # At what point is side-stream wastewater returned to treatment?The ORC uses the freeboard marker and WWTP conditions to determine when to re-route side-stream effluent back to the WWTP for re-treatment. Is there a Spill Control Plan? Aerated or Mixed?NONE If aeration is present, is it adequate? If present, are diffusers cleaned regularly? Is influent structure acceptable? Are banks/berms free of seepage and erosion? Are banks/berms free of excessive vegetation? Is pond lined? Liner Type Full, synthetic Is liner acceptable? Are baffles/curtains acceptable? Does the pond have a freeboard marker? Required freeboard?2 Feet Actual freeboard?3 Feet Page:8 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine Is there suitable grassed vegetation? Is the vegetation maintained? Is the area free of excessive weeds and/or woody species? Is the area free from signs of overflow? Is color acceptable? Are floating mats acceptable? No excessive buildup of solids? Are aerators/mixers acceptable? Is effluent structure acceptable? If present, is pond cover acceptable? The northeast slope of the dam has areas of moderate to severe erosion. The dam does not have suitable grass cover. Areas of the dam continue to erode and form small gullies. The Spill Response Plan should be incorporated in the Operation & Maintenance Plan. Comment: WET WEATHER STORAGE - Storage Yes No NA NE Storage Type?Pond Storage amount?1089969 Cubic Feet # At what point is side-stream wastewater returned to treatment?This is not a side stream pond. Is there a Spill Control Plan? Aerated or Mixed?NONE If aeration is present, is it adequate? If present, are diffusers cleaned regularly? Is influent structure acceptable? Are banks/berms free of seepage and erosion? Are banks/berms free of excessive vegetation? Is pond lined? Liner Type Full, synthetic Is liner acceptable? Are baffles/curtains acceptable? Does the pond have a freeboard marker? Required freeboard?2 Feet Actual freeboard?5 Feet Is there suitable grassed vegetation? Page:9 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0024694 06/28/2018 Compliance Evaluation Aqua North Carolina Inc Routine Is the vegetation maintained? Is the area free of excessive weeds and/or woody species? Is the area free from signs of overflow? Is color acceptable? Are floating mats acceptable? No excessive buildup of solids? Are aerators/mixers acceptable? Is effluent structure acceptable? If present, is pond cover acceptable? The Spill Response Plan should be incorporated in the Operation & Maintenance Plan.Comment: Page:10 DocuSign Envelope ID: 593E8A1A-91FB-499E-999C-8FDDF663FE74