NC0026646_NOV-2020-PC-0545_20201218

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANI£L SMITH
Director
NORTH CAROLINA
Environmental Quality
December 21, 2020
CERTIFIED MAIL # 7018 1130 0000 1612 8144
RETURN RECEIPT REQUESTED
Mr. Ken Scott, ORC
Town of Pilot Mountain
124 West Main Street
Pilot Mountain, NC 27041
Subject: NOTICE OF VIOLATION — (NOV-2020-PC-0545)
Compliance Evaluation Inspection
Town of Pilot Mountain WWTP
NPDES Permit #NC0026646
Surry County
Dear Mr. Scott:
On December 15, 2020, North Carolina Division of Water Resources (DWR) staff persons Justin
Henderson and Alex Lowe performed a Compliance Evaluation Inspection of the subject facility.
Mr. Kent Scott, ORC, and Mr. Mark King, Back -Up ORC were present during this inspection.
This type of inspection consists of two basic parts: an in -office review of the facility files and self -
monitoring data and an on -site inspection of the facility. This inspection reflects non-compliance
with Permit No. NC0026646. The following violations require your attention and action:
1) An unreported bypass was discovered and ongoing during this inspection. Wastewater was
observed leaking from a crack located in the wall of the outer oxidation ditch. The observed
discharge point was located approximately 180 degrees adjacent to where the influent pump
station discharged into the oxidation ditch. This bypass persisted during the entire inspection,
and reportedly as of the date of this letter is still ongoing. The ORC reported that leakage from
this location had been noticed approximately six weeks prior to this inspection. Permit
Condition Part IL Section C (4.) (c) (1) states: bypass from the treatment facility is prohibited
and the Permit Issuing Authority may take enforcement action against a Permittee for bypass.
2) Failure to report the occurrence of an unanticipated bypass within 24-hour notice. Permit
Condition Part IL Section C. (4) (b) (2) states The Permittee shall submit notice of an
unanticipated bypass as required in Part II.E.6. (24-hour notice). As noted above, the ORC
acknowledged that a bypass had been observed occurring at this location as early as six weeks,
prior to the inspection that was conducted on December 15, 2020.
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North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105
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3) Failure to conduct appropriate maintenance with respect to the oxidation ditch to prevent the
growth of excessive vegetation. Woody vegetation was consistently present and overgrown in
the outer ring of the oxidation ditch. Permit Condition Part 11. Section C. (2.) states: the
permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control which are installed or used by the Permittee to achieve compliance with the
conditions of this permit.
4) Failure to conduct flow proportional composite sampling (both influent and effluent) in
accordance with Permit Condition Part IL Composite Sampling. Mr. Scott, ORC indicated that
composite samples currently were being collected via the constant time/constant volume
method. However, use of this method requires prior approval by the Director, and may only be
used in situations where effluent flow rates vary less than 15 percent.
5) Failure to ensure the composite sample is maintained at or below six (6) degrees Celsius during
the entire compositing period per CFR part 136.3 Table IL There were no thermometers present
in either the effluent or influent composite samplers nor were any records available to
demonstrate the sample compartment cooling was maintained in accordance with CFR part
136.3. The current influent composite sampler was not capable of mechanical cooling, and the
ORC acknowledged that the sample is not cooled with ice during the compositing period.
6) The effluent composite sampler was collecting aliquots prior to final treatment of effluent.
Permit Condition Part II. Section D (1.) states: samples collected, and measurements taken
shall be representative of the permitted discharge. All samples shall be taken at the monitoring
points specified in the permit.
7) Failure to maintain appropriate quality assurance procedures associated with the pH meter
calibration requirements. The high range pH buffer (pH 10 buffer), utilized to calibrate the pH
meter for per event sampling, had been expired since March 2020. Permit Condition Part II. C
states: proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures.
8) Failure to maintain records of sewage sludge removal for a period of at least five years. Permit
Condition Part 11. Section D (6) states: records of the Permittee's sewage sludge use and
disposal activities shall be retained for a period of at least five years (or longer as required by
40 CFR 503).
9) Failure to conduct and/or maintain documented logs for the calibration of meters utilized to
monitor and report effluent temperature analysis in accordance with Permit Condition Part II.
Section C (2.), Permit Condition Part II Section D. (6.), and the North Carolina
Wastewater/Groundwater Laboratory Certification Approved Procedures.
10)Failure to properly maintain the clarifier's surface scum basin to prevent the discharge of
floating solids. The scum basin within the one operating clarifier was clogged to the degree
that floating solids/trash was observed discharging across the clarifier's weir, during this
inspection. Permit Condition Part IL Section C. (2.) states: The Permittee shall at all times
properly operate and maintain all facilities and systems of treatment and control.

11) Failure to properly maintain the "brush" rotors and their associated motors, designed to provide
aeration within the oxidation ditch to promote nitrification. Three of the five "brush" rotors
were inoperable. Two were missing motors altogether and the other motor had fallen into the
oxidation ditch. Permit Condition Part II_ Section C. (2.) states: The Permittee shall at all times
properly operate and maintain all facilities and systems of treatment and control.
Along with the above described violations the following items of concern warrant your attention:
a) The clarifier weir appeared to be unlevel, as various rates of discharges were observed at
multiple locations along the weir. Design specifications would be expected to call for uniform
discharge rates across the entire weir.
b) The facilities treatment equipment included the presence of 2 clarifiers, however only one of
the two clarifiers is currently operable. The "out of service" clarifier reportedly has been off-
line in excess of three years and significant rust was present on nearly all mechanical
components of the treatment unit. Permit Condition Part II_ Section C. (2.) states: The
Permittee shall at all times properly operate and maintain all facilities and systems of treatment
and control. Should the Permittee allege that treatment equipment is unnecessary to achieve
compliance with the subject permit, based upon an engineering design evaluation, then the
equipment deemed unnecessary should be requested to be removed from the Permittee's
treatment equipment description contained in the permit.
c) Permit Condition Part II_ Section C (7.) states: The Permittee is responsible for maintaining
adequate safeguards (as required by 15A NCAC 02H .0124) to prevent the discharge of
untreated or inadequately treated wastes during electrical power failures either by means of
alternate power sources, standby generators, or retention of inadequately treated effluent. The
facility had an on -site generator that was only capable of providing power to the influent pump
station. Reportedly, the facility does not have the capacity, nor any effluent storage equipment
present to ensure retention of inadequately treated effluent should the facility be subject to an
extended period of power failure.
d) The effluent pump station was observed as part of this inspection. While not listed as part of
the treatment equipment authorized by this permit, it was noted that effluent pump 92 had a
significant leak and needed maintenance/repair.
Required Response:
1) Immediately implement repair measures to abate the ongoing bypass and ensure that future
reoccurrence is prevented. Submit the 5-day notification in accordance with Permit Condition
Part II_ Section E. (6.) which states: A written submission shall also be provided within 5 days
of the time the Permittee becomes aware of the circumstances. The written submission shall
contain a description of the noncompliance and its cause; the period of noncompliance,
including exact dates and times, and if the noncompliance has not been corrected, the
anticipated time it is expected to continue; and steps taken or planned to reduce, eliminate, and
prevent the reoccurrence of the noncompliance [40 CFR 122.41(1)(6)].

2) Submit a written response that contains a description of the corrective actions that will be
implemented to remediate the violations described within this Notice. This written response
shall also contain the projected schedule for each described violation to be addressed. This
written response shall be received by this Office no later than 15-days post receipt of this
Notice.
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 the NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties.
Please refer to the enclosed inspection report for additional observations and comments. A follow-
up inspection to evaluate the effectiveness of the corrective actions implemented to address the
above violations is planned to be conducted within the next 90 days. If you have questions
concerning this correspondence, please contact Justin Henderson or me at [phone].
Sincerely,
EDocuSigned by: 1
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Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resource, NCDEQ-WSRO
enc: Inspection Report
cc: Laserfiche Files (electronic copies)