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HomeMy WebLinkAboutWQ0004115_Staff Report_20181002State of North Carolina Department of Environmental Quality Division of Water Resources Water Quality Permitting Regional Staff Report FORM: APSRSR 04-10 Page 1 of 4 October 2, 2018 To: DWR Water Quality Permitting Section Central Office Application No.: WQ0004115 Attn: Erick Saunders Regional Login No.: From: Bev Price Asheville Regional Office I. GENERAL SITE VISIT INFORMATION 1. Was a site visit conducted? Yes or No a. Date of site visit: August 14, 2018 b. Site visit conducted by: Beverly Price & Dan Boss c. Inspection report attached? Yes or No d. Person contacted: Craig Galloway 828-696-1662 & Juanita James 828-674-8171 e. Driving directions: Hwy. 64 W to Church St. left. Right on Kanuga St. which changes to Kanuga Rd. Right on Price Rd. Left on Willow. Approx. 2 miles to Chattoga Run Rd. on rt. Next road to rt. (unmarked) to cart path to WWTP. II. PROPOSED FACILITIES FOR NEW AND MODIFICATION APPLICATIONS 1. Facility Classification: (Please attach completed rating sheet to be attached to issued permit) 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: 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) DocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 FORM: APSRSR 04-10 Page 2 of 4 III. EXISTING FACILITIES FOR MODIFICATION AND RENEWAL APPLICATIONS 1. Are there appropriately certified Operators in Charge (ORCs) for the facility? Yes No N/A ORC: Karl Griffiths Certificate #:SI/15613 Backup ORC: Juanita James Certificate #:SI/25034 ORC: Danielle Hunter Certificate #:WW-2/23477 Backup ORC: Juanita James Certificate #:WW-3/24074 Designated operators are not listed in BIMS under Permit Classification/Designation Tab 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: See the attached NOV. 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: 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: 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., NDMR, NDAR, GW)? Yes or No Please summarize any findings resulting from this review: The permittee exceeded the permit limit for Monthly Average for TSS in July and May 2018. 13. Are there any permit changes needed in order to address ongoing BIMS violations? Yes or No If yes, please explain: Example Violation: This screen shot only shows 12 of the 58 monitoring violations. This happens because the permittee also has an NPDES permit. The NPDES permit allows for discharge between November 1 – April 30 or any other time as needed. An NDMR could have data reflecting irrigation of effluent and also indicate no DocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 FORM: APSRSR 04-10 Page 3 of 4 effluent spray because they were discharging under the NPDES permit. BIMS does not recognize two permit requirements on the same form and therefore generates false violations. Some of the violations might be alleviated by entering zero in the Flow column. 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.) This NOV was for the Compliance Inspection conducted in August 2018. Only approximately one/half of the wastewater was going through the tertiary filter. The filter backwash was not functioning at the time of inspection. 15. Have all compliance dates/conditions in the existing permit been satisfied? Yes No N/A If no, please explain: 16. Are there any issues related to compliance/enforcement that should be resolved before issuing this permit? Yes No N/A If yes, please explain: 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 APS Central Office to obtain through an additional information request: Item Reason DocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 FORM: APSRSR 04-10 Page 4 of 4 Updated site map The most recent updated site map is not available. 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 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: Signature of APS regional supervisor: Date: V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS The non-discharge permit requires effluent not meeting reuse requirements be routed to the stream under the NPDES permit. Fecal coliform analytical results are not available for least 24 hours after sampling. As a result, it would be difficult to ensure that all effluent is properly routed. DocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 10/2/2018 DocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 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 5596 Return Receipt Requested August 21, 2018 Craig Galloway, Director of Grounds and Facilities Champion Hills Property Owners Association Inc 1 Hagen Dr Hendersonville, NC 28739 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2018-PC-0331 Permit No. WQ0004115 Champion Hills WWTP Henderson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Champion Hills WWTP on August 14, 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. WQ0004115. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Sampling 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 _________________________________________________________________________________________________________________________________________________________________________ Treatment Filters According to the ORC's only 1/2 of the flow is going through the tertiary filter. The filter cannot be backwashed. The #1 pump was not working at the time of inspection. The #2 pump needs a reverse thread coupling. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 North Carolina Department of Environmental Quality | Division of Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 828-296-4500 In addition, the issues below must also be addressed: Compliance Issue(s): 1. The composite sampler is set for time/volume sample collection. The sampler should be set for flow proportional sampling. 2. An acceptance letter from the wastewater treatment plant (WWTP) agreeing to accept residuals from Champion Hills WWTP should be included in the Residuals Management Plan, see permit condition III.20. 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. The results from the split sample with the contract operator will be forwarded to you when laboratory results have been verified. The WWTP ORC and the Spray Irrigation ORC should communicate prior to switching between pond and stream discharge to ensure monitoring is occurring at the proper time and location. Reminder: The spray irrigation equipment is required to be calibrated before the end of the permit cycle. 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: WQS ARO Server LF 20180821_WQ0004115_CSI.rtf DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Compliance Inspection Report Permit:WQ0004115 Effective:02/01/14 Expiration:01/31/19 Owner :Champion Hills Property Owners Association Inc SOC: Contact Person: Region: County: Directions to Facility: Henderson Asheville Craig Galloway Effective:Expiration:Facility:Champion Hills WWTP 111 W Chicory Crossing Hendersonville NC 28739 Title:Phone:828-696-1662Director of Grounds & Facility Maintenance From Hendersonville: Take Hwy. 64 W to Church St., turn rt on Kanuga St, Kanuga changes to Kanuga Rd SR 1127. From Kanuga turn rt on Price SR 1137, left on Willow, go approx 2 mi to Chattoga Run Rd on rt then next right (unmarked) to cart path to WWTP. Juanita Reed James 24074 828-697-0063 Secondary ORC(s): 828-697-0063Phone:23477Certification:Danielle Ann HunterPrimary ORC: System Classifications: 24 hour contact name Juanita R James 828-697-0063 On-site representative Craig Galloway 828-696-1662 On-site representative Juanita R James 828-697-0063 On-site representative Danielle Ann Hunter 828-697-0063 On-Site Representative(s): Related Permits: NC0087106 Champion Hills Property Owners Association Inc - Champion Hills WWTP Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 08/14/2018 09:15AM 01:00PM Beverly Price 828-296-4500 Daniel J Boss Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Reclaimed Water Compliance Sampling Question Areas: Treatment Flow Measurement-Effluent Treatment Flow Measurement-Influent Miscellaneous Questions Treatment Flow Measurement-Water Use Records Treatment Barscreen Treatment Filters Record Keeping Treatment Activated Sludge 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: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine Inspection Summary: The inspection was conducted by Beverly Price and Dan Boss of the Asheville Regional Office. Craig Galloway, Director of Grounds & Maintenance, Juanita James and Danielle Hunter of James & James Environmental Management, Inc. were present and assisted with the inspection. Lift Station #1(influent) floats and alarms (audible & visual) were inspected and were functioning properly. The Fats, Oils & Grease (FOG) notification can be added to the Reclaimed Education Program material. The word “non-potable” should be added to the reclaimed water use notification sign in the clubhouse. The dual submersible pumps in the EQ basin have been replaced with an air lift system. Ms. James indicated that they have decided to reinstall the submersible pumps and that both pumps are ready to be installed. The current method for collecting composite samples is time/volume based. Composite samples should be flow proportional. The WWTP ORC and the spray irrigation ORC should communicate prior to switching from irrigation pond discharge to stream discharge to ensure samples are collected at the proper time and location. The effluent meter was calibrated 1/29/18 by Laboratory Instrument Services. The effluent composite sampler temperature was 1-degree C. According to the ORC’s, the settleometer test is conducted once per week. The log book showed 60% on 8/13/18. Both clarifiers were high in solids at approximately 11 ft. Pin floc was observed flowing over the clarifier weirs. Solids were pumped by Mike’s Septic on 8/13/18; 6 loads were hauled to MSD. Mike's Septic was also on site at the time of inspection to pump out the tertiary filter tank. As a reminder, the irrigation system components are required to be calibrated once per permit cycle. This calibration should be completed by January 31, 2019. The chlorinator box has been repaired. A metal plate was added to hold the chlorinator tubes in place. According to the ORC’s, the tertiary filter is only partially functional. Approximately ½ of the effluent is run through the filter and it cannot be backwashed. Failure to document backwashing of the filters was noted in the 2016 inspection. Past inspections have shown that effluent was not being passed through the filter. The permittee did say that a contractor/bid has been submitted for replacing the filter motor and pump. The bid is to be approved by the Board on August 14th. New media (sand/anthracite) has been purchased and is ready to be installed. The following maintenance issues were noted: 1.Weirs need to be cleaned. 2.Two small grates over the EQ basin were rusted and need to be replaced. 3.There is a crack between the digester and EQ wall that needs to be repaired. 4.The tertiary filter was not fully operational. One of the pumps was down and one pump needs a reverse thread coupling. Field Parameters checked with inspector’s YSI meter: pH: 6.75 @ 21.1 degree C DO: 4.05 mg/l The split sample results will be forwarded to the permittee when results have been finalized. Irrigation was not occurring at the time of inspection. Page:2 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine A Notice of Violation will be issued for failure to have a fully functional tertiary filter. This has been noted in previous inspections. Page:3 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine Type Yes No NA NE Single Family Spray, LR Lagoon Spray, LR Infiltration System Activated Sludge Spray, LR Recycle/Reuse Activated Sludge Drip, LR Activated Sludge Spray, HR Single Family Drip Reuse (Quality) 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? SCADA/Telemetry is not required but this pump station has telemetry.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: 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 Page:4 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? The LED readout on the 3010 transmitter did not match the paper chart readout; the LED readout on the chart recorder did not match the paper chart, however both LED readouts were very close. The composite sampler is not set to collect flow proportional samples. 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 generator is automatically exercised every Monday. The generator fuel source is natural gas. 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? The bar screen has been replaced by a basket screening system.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? Settleometer results were 60% AB #1 - D.O.=2.02 mg/l; pH=6.76 AB#2 - D.O.=3.08 mg/l; pH=6.56 Comment: 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? Page:5 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine Is the sludge blanket at an acceptable level? Is the effluent from the clarifier free of excessive solids? Both clarifiers had approximately 11ft. of sludge. The weirs need to be cleaned more frequently; excessive algae. Comment: Treatment Return pumps Yes No NA NE Are they in place? Are they operational? 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? According to the ORC's only 1/2 of the flow is going through the tertiary filter. The filter cannot be backwashed. Pump #1 was not working at the time of inspection. Pump #2 needs a reverse thread coupling. The permittee has secured a bid for changing out the pump & motor for the tertiary filter. 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? 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-____-____) Page:6 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine If yes, then when was the RMP last updated? 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? No treatment units bypassed since last inspection? There was only partial flow through the tertiary filter.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? Page:7 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine 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? There was no documentation of turbidity meter calibration in the last 12 months; this is not a requirement in the current permit. This system was not originally designed to automatically divert off-specification effluent from the irrigation pond. When off-spec effluent is discovered it can be manually (open valve to stream discharge) diverted to discharge to the stream under the NPDES permit. Chlorine tablets could be added to the irrigaiton pond if effluent was found to exceed fecal coliform limits. The sprayfield is a golf course so irrigation is normally done when golfing is not occurring. A sign is posted in the clubhouse notifiying golfers of the use of reclaimed water; the term "non-potable" should be added to the notification sign. Irrigation was not occurring at the time of inspection. Comment: IRRIGATION POND - Storage Yes No NA NE Storage Type?Pond Storage amount? # At what point is side-stream wastewater returned to treatment?The system was not designed to divert off-spec effluent to the head of the WWTP. Page:8 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0 Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0004115 08/14/2018 Compliance Sampling Champion Hills Property Owners Association Inc Routine Is there a Spill Control Plan? Aerated or Mixed?AERATED 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 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? This system was not designed to return off-spec effluent wastewater to the WWTP. Effluent not meeting reclaimed standards is discharged to the stream under the NPDES permit. However, effluent not meeting the fecal coliform reclaimed criteria could be discharged to the irrigation pond as the results of fecal coliform analyses are not instantaneous. There are mature pine trees at the toe of the dam. These trees were evaluated by an engineer several years ago. At that ime, the engineer felt that if the roots were extending to the pond, they would have no detrimental impact to its operation There was no evidence of roots penetrating the liner at that time. The recommendation was to thoroughly inspect the liner during the winter months when the irrigaiton pond is empty to ensure proper operations. The operator should continue with this recommendation as the investigation was conducted several years ago. Comment: Page:9 DocuSign Envelope ID: 10154FF8-3707-45C4-8B86-E6C1F8F11CFEDocuSign Envelope ID: A3A24E50-4AE1-485E-8614-9F975B9AFAC0