WQ0033097_NOD-2019-PC-0103_20190425

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
LINDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
April 25,2019
Eric Rifkin,Assistant Vice President
Eaton's Crossing NC LP
56 Hunter Street, Suite 110
Apex,NC 27502
Subject: NOD-2019-PC-0103
Compliance Evaluation Inspection
Eaton's Crossing
Wastewater Irrigation System
Permit Number WQ0033097
Warren County
Mr. Rifkin,
On April 25,2019,Rick Trone of the Raleigh Regional Office conducted a compliance evaluation
inspection of the wastewater irrigation system at Eaton's Crossing. The purpose of this inspection was to
ensure compliance with the subject permit and inspect the facility for permit renewal.During the
inspection,the cooperation and assistance of Mr. Dennis Wilson was helpful and appreciated.
This compliance evaluation inspection consisted of the following:
• Review of the permit;
• Review of the owner/facility information;
• Review of ORC logbooks, calibration documentation,Non-discharge wastewater monitoring
reports(NDMR),Non-discharge application reports(NDAR),and;
• On-site inspection of treatment components and irrigation fields
The current permit was issued May 31,2013 and expired on April 30,2018. Permit renewal documents
were received by this office on March 22, 2019.
Flow recorded at the facility is significantly below permit limits.This is due to the slow build-out of
homes at Eaton's Crossing. The community is primarily seasonal use and flow will likely continue to be
well below permitted limits.
Components of the wastewater system appeared to be well-maintained. The facility is fenced in and
public access is restricted.Currently, only one train of the dual train package plant is in operation.
Wastewater moving through the system is of the correct color with minimal foam.The ultraviolet lights
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

were operational, and spare bulbs were available.The visual and audible alarms at the effluent pump
station operated satisfactorily when tested.The on-site generator is tested weekly and was tested on the
day of the inspection and found to be in good operating order.The flowmeters have not been calibrated,
however Mr. Wilson explained that the Rosemount magnetic flowmeters do not need regular calibration.
A review of the reference manual for the flowmeter confirms this. According to the manual,the meter is
wet calibrated at the factory and does not need further calibration unless a problem is suspected.The
facility keeps thorough records of maintenance and activities involving the system.
NDMR and NDAR forms are submitted as required with all information. Effluent sampling is analyzed
by Meritech Labs.Lab results for November 2018 and January 2019 were compared against values
reported on form NDMR and no discrepancies were noted.The facility has a history of compliance issues
involving Total Nitrogen and Total Phosphorous.A Notice of Deficiency(NOD)was issued on February
20,2019 for limit exceedances for those two parameters.Mr. Wilson explained that he believes the very
low flow at the facility is a contributing factor.
The inspector noticed that 12-month floating totals on form NDAR did not appear correct.Please ensure
these values are calculated as required.
The facility maintains numerous spray fields totaling about 10.77 wetted irrigation acres. During the
inspection,portions of the spray system(Zone 1)were activated. Spray patterns appeared to be uniform
with plenty of pressure.Mr.Wilson explained that twice per year the fields are cleared of vegetation
growing near ground level. On the day of the inspection,the spray fields appeared to be in good condition
with no evidence of runoff or ponding. All fields are enclosed by fencing which includes warning
signage. A representative soil analyses for spray fields has not been completed(see deficiency below).
The storage lagoon appeared to be free of solids and well maintained. Plenty of freeboard was available.
The area around the lagoon was free of woody vegetation and mowed.
The following permit condition deficiencies were noted during the April 25,2019 compliance
inspection and records review:
M. Operation and Maintenance Requirements
Condition 10 which states that, "An annual representative soil analysis(i.e., Standard Soil Fertility
Analysis) shall be conducted on each irrigation site listed in Attachment B."It is unknown when, if ever,
a representative soil analysis was last conducted on the irrigation areas.Please ensure this analysis is
conducted as soon as possible.Please submit a copy of the soil analysis results to this office.
This office requests that you respond to this letter in writing within 30 days of receipt. Your
response should be sent to this office at the letterhead address.Your response should address the
following items as noted above. Please include in your response all corrective actions already taken and a
schedule for completion of any corrective actions not addressed.
If you have any questions about this inspection or this letter,please contact Rick Trone at
[e-mail] or 919-7914257.

If you have any questions about this inspection or this letter,please contact Rick Trone at
rick.trone_na.ncdenr.gov or 919-791-4257.
Sincerely,
Rick Bolich,L.G.
Assistant Regional Supervisor
Water Quality Regional Operations
Raleigh Regional Office
Attachments: EPA Water Compliance Inspection Report
cc:
Central Files
RRO Files