WQ0023580_Staff Report_20180822

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: [e-mail] Facility name: Cove Key Townhomes on Lake Norman WWTP
County: Iredell
From: [e-mail]
Mooresville Regional Office
Note: This form has been adapted from the non -discharge fg acili , 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: 08-10-2018
b. Site visit conducted by: Maria Schutte
c. Inspection report attached? ❑ Yes or ® No, Emailed separately, also in BIMS/Laserfiche
d. Person contacted: Brandon Long QRC) and their contact information: (704) 351 - 4049 ext.
e. Driving directions: From MRO travel to Hw 115 S (Main St); turn right onto Langtree Road; Cross over I-77
throujzh 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:
11. 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:
5. Is the proposed residuals management plan adequate? ❑ Yes ❑ No ❑ N/A
If no, please explain:
FORM: WQROSSR 04-14 Pagel of 5

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: Brandon Long Certificate #: SI991385 Backup ORC: Tim Bannister Certificate #: SI23910
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 pset 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:
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: The 5-daygpset pond is synthetically lined (not clay, 1�). The wet weather storage
lagoon proposed design called for a "Bentomat or equivalent' type liner. By design this type of liner cannot be
seen, so the lagoon appears to be clay lined. MRO will defer to CO permitting staff to determine how this should
be described in the permit. There is some degraded fabric at the top 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 liner material.
FORM: WQROSSR 04-14 Page 2 of 5

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
O l lI
O I II
O l lI
O I II
O / //
O / //
O / //
O / //
O l 11
O I //
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.
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.)
If the facility has had compliance problems during the permit cycle, please explain the status. Items noted in
previous deficiencies/violations have or are being addressed. Has the RO been working with the Permittee? Yes
Is a solution underway or in place? Yes, minor record keeping issues are being addressed.
Have all compliance dates/conditions in the existing permit been satisfied? ® Yes ❑ No ❑ N/A
If no, please explain:
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: NA
17. Pretreatment Program (POTWs only):
FORM: WQROSSR 04-14 Page 3 of 5

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
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
Deemed Collection System
Language as in permit #
WQ0015931
MRO wishes to eliminate permit WQCSDO0500 and unnecessary workload for
collection system staff for dual oversight of this small facility. The collection
system will continue to be inspected as part of this non -discharge permit and
adding the standard CS language to this ND permit will assist RO compliance
efforts.
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
DocuSigned by:
❑ Deny (Please state reasons: )
6. Signature of report preparer: Maria Schutte �--DocuSianed bv:a 1^
Signature of regional supervisor:
Date: 8/22/18
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FORM: WQROSSR 04-14 Page 4 of 5

V. ADDITIONAL REGIONAL STAFF REVIEW ITEMS
The plant ORC is currently in discussion with a contractor for quotes on a plant rehabilitation, as it is showing signs 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
facility appears necessary for many_years, as the Town of Mooresville recently denied their request to connect via an
adjacent, private collection system.
Jackie Weiner is no longer at this property and should be removed as a contact. MRO staff met with Chip Hawkins
(Manager of Cove Key Association, Inc.) and Brent Brower (current HOA President).
MRO staff recently updated field coordinates in BIMS for improved accuracy with division GIS maps. There are no
monitoring wells associated with this permit.
FORM: WQROSSR 04-14 Page 5 of 5