NC0061425_Compliance Evaluation Inspection_20191211

ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
CERTIFIED MAIL 7017-1450-0001-6450-4960
RETURN RECEIPT REQUESTED
December 11, 2019
Mr. Jadd Brewer
Water Quality Utilities, Inc.
P.O. Box 1167
Banner Elk, NC 28604-1167
SUBJECT: Compliance Evaluation Inspection and Notice of Violation
NOV Tracking Number: NOV-2019-PC-0768
Willow Valley Resort WWTP
NPDES Permit No. NCO061425
Watauga County
Dear Mr. Brewer,
On December 4, 2019, Kelli Park, of this office, met with Brandon Hughes, Operator in
Responsible Charge (ORC), to perform a Compliance Evaluation Inspection at the Willow Valley
Resort wastewater treatment plant. This type of inspection consists of two basic parts: an in -
office file review and an on -site inspection of the treatment facility. The attached EPA inspection
form details the areas that were evaluated during this inspection. Violations that were noted during
the inspection are outlined below:
1) The ultraviolet radiation system was not operational at the time of inspection. Please get
the system repaired immediately. Once the repair is completed please contact Ms. Park.
2) Via the effluent limitations page in the permit it this plant is required to have a chart
recording of the continuous flow. These permits should also be retained for three years
(Part II, Section D, #6). Please install a meter that incorporates a chart recorder or modify
the current meter to incorporate one. Once the repair is completed please contact Ms.
Park.
3) A section of the fencing surrounding the plant is broken. Please repair the fence
immediately. Once the repair is completed please contact Ms. Park.
These issues represent deficiencies and violations of the facility's NPDES permit. Thus, this letter
is being sent to you as a Notice of Violation. Please reply in writing to this letter within 10
calendar days of receiving it. Your written reply should address each of the noted
violations/deficiencies and provide a corrective action plan along with an
NORTHCARCL1` D ���
DWrb M W Erntronm ,W Qualify
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27103
336.776.9800

implementation/completion schedule to remediate them. A review of your response will be
considered along with any additional information provided.
Please be aware that violations of your NPDES permit, or the NC statutes and regulations under
which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth
in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do
NOT receive your written reply within 10 calendar days of your receipt of this notice, we may draft
an enforcement case for the noted deficiencies/violations.
If you have any questions regarding the inspection or this report, please contact Kelli Park or me
at [phone] or by email at kelli.park(aD-ncdenr.gov or Ion. snider(a-)-ncdenr.gov.
Sincerely,
DocuS�igfned<by:
Jti l Smder
145B49E225C94EA...
Lon Snider
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: EPA Water Compliance Inspection Report
cc: WSRO
2

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 IN I 2 IF I 3 I NCO061425 111 12 I 19/12/04 I17 18 I S J 19 L G] 201 I
211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
671
70 I I 71 I I 72 I r I 73 I I 174 751 I I I I I I I80
u I� I I i
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES oermit Number)
11:30AM 19/12/04
18/02/01
Willow Valley Resort WWTP
Bairds Creek Rd
Exit Time/Date
Permit Expiration Date
Boone INC 28607
12:15PM 19/12/04
22/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Brandon K Hughes/ORC/828-260-5213/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jadd W Brewer,PO Box 1167 Banner Elk NC 286041167H828-898-6277/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance 0 Records/Reports
Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Kelli A Park DocuSigned by: DWR/WSRO WQ/336-776-9689/
PA4 12/12/2019
B4A41 DCE74C34139_.
Signature of Management Q A Review[:cuSigned by: Agency/Office/Phone and Fax Numbers Date
? ':5'acc 12/11/2019
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO061425 I11 121 19/12/04 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On December 4, 2019, Kelli Park, of this office, met with Brandon Hughes, Operator in Responsible
Charge (ORC), to perform a Compliance Evaluation Inspection at the Willow Valley Resort wastewater
treatment plant. This type of inspection consists of two basic parts: an in -office file review and an
on -site inspection of the treatment facility. The attached EPA inspection form details the areas that
were evaluated during this inspection. Violations that were noted during the inspection are outlined
below:
1) The ultraviolet radiation system was not operational at the time of inspection. Please get the
system repaired immediately. Once the repair is completed please contact Ms. Park.
2) Via the effluent limitations page in the permit it this plant is required to have a chart recording of the
continuous flow. These permits should also be retained for three years (Part II, Section D, #6). Please
install a meter that incorporates a chart recorder or modify the current meter to incorporate one. Once
the repair is completed please contact Ms. Park.
3) A section of the fencing surrounding the plant is broken. Please repair the fence immediately. Once
the repair is completed please contact Ms. Park.
These issues represent deficiencies and violations of the facility's NPDES permit. Thus, this letter is
being sent to you as a Notice of Violation. Please reply in writing to this letter within 10 calendar days of
receiving it. Your written reply should address each of the noted violations/deficiencies and provide a
corrective action plan along with an implementation/completion schedule to remediate them. A review
of your response will be considered along with any additional information provided.
Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which
it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General
Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your
written reply within 10 calendar days of your receipt of this notice, we may draft an enforcement case
for the noted deficiencies/violations.
If you have any questions regarding the inspection or this report, please contact Kelli Park or me at
[phone] or by email at [e-mail] or [e-mail].
Page#

Permit: NCO061425 Owner - Facility: Willow Valley Resort WWTP
Inspection Date: 12/04/2019 Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
❑
0
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: A section of fence was down, please fix immediately
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
❑
❑
❑
Is a copy of the current NPDES permit available on site?
❑
❑
❑
Page# 3

Permit: NCO061425 Owner - Facility: Willow Valley Resort WWTP
Inspection Date: 12/04/2019 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑
Comment: ORC is a grade 2, backup is a grade 3
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment: debris are taken to a landfill
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
❑ ❑
0
❑
Are the diffusers operational?
N ❑
❑
❑
Is the foam the proper color for the treatment process?
0 ❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑
❑
❑
Is the DO level acceptable?
0 ❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
0 ❑
❑
❑
Comment: DO was reported to be around 2.5mg/I
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
❑
❑
0
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
0
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Page# 4

Permit: NCO061425 Owner - Facility:
Inspection Date: 12/04/2019 Inspection Type:
Willow Valley Resort WWTP
Compliance Evaluation
Secondary Clarifier
Yes No NA NE
Is the drive unit operational?
❑
❑
0
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
0
❑
❑
❑
Comment: Sludge blanket was reported to be around 2ft
Disinfection - UV
Yes No NA NE
Are extra UV bulbs available on site?
❑
❑
❑
Are UV bulbs clean?
❑
0
❑
❑
Is UV intensity adequate?
❑
0
❑
❑
Is transmittance at or above designed level?
❑
0
❑
❑
Is there a backup system on site?
0
❑
❑
❑
Is effluent clear and free of solids?
0
❑
❑
❑
Comment: UV system is down, it has been down since the previous inspection in Aug 2018
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
0
❑
❑
❑
Are the tablets the proper size and type?
0
❑
❑
❑
Number of tubes in use?
0
Is the level of chlorine residual acceptable?
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
Comment: Tablets are places in the weirs
De -chlorination
Yes No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
0 ❑
❑
❑
Is storage appropriate for cylinders?
0 ❑
❑
❑
# Is de -chlorination substance stored away from chlorine containers?
0 ❑
❑
❑
Comment:
Are the tablets the proper size and type? 0 ❑ ❑ ❑
Are tablet de -chlorinators operational? 0 ❑ ❑ ❑
Number of tubes in use? 0
Page# 5

Permit: NCO061425
Inspection Date: 12/04/2019
De -chlorination
Comment: Tablets are placed in a contact chamber
Owner - Facility: Willow Valley Resort WWTP
Inspection Type: Compliance Evaluation
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: There is no chart recorder, it is a permit requirement to have a chart recorder for a
continuous flow measurement requirement.
Yes No NA NE
Yes No NA NE
■
❑
❑
❑
❑
❑
❑
■
❑
❑
❑
❑
■
❑
❑
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
0
❑
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
❑
❑
❑
representative)?
Comment: Grab samples are taken from a holding box before being discharged.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: effluent was clear the day of inspection
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑
sampling location)?
Comment:
Page# 6