WQ0015491_NOD-PC-2022-0029_20220307

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
Darren A. Hackett, Heir
Russel Harrison Hackett Heirs
2518 Race Track Road
Sophia, NC 27350
NORTH CAROLINA
Environmental Quality
March 7, 2022
SUBJECT: Notice of Deficiency (NOD-2022-PC-0029)
Compliance Evaluation Inspection
Permit No. WQ0015491
Caraway Speedway WWTF
Randolph County
Dear Mr. Hackett:
On February 22, 2022, Division of Water Resources staff person Caitlin Caudle
conducted a schedule compliance inspection of the subject facility. Darren Hackett, ORC,
was present during the entire inspection. A review of records, treatment system, and
irrigation fields was completed. The irrigation system had been winterized and was not
viewed in operation. This review reflected noncompliance with the subject permit.
DWR correspondence Notice of Violation and Notice of Intent to Enforce dated August
30, 2021 (tracking number NOV-2021-PC-0437 and NOV-2021-PC-0435) was hand
delivered after being returned to the Office. The Civil Penalty Assessments issued to date
were discussed, and the most recent Notice of Violation and Notice of Intent to Enforce.
The following deficiency was noted:
1. Per Permit Condition IV.9 "an annual representative soil analysis ... shall be
completed on each irrigation site listed in Attachment B." A soil analysis was not
completed for the 2020 calendar year. This is a violation of the subject permit.
NORTH
D E
Dopartmem of ln.imnmomni au.i`
North Carolina Department of Environmental Quality Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Please review the attached inspection report for additional comments and observations.
If you have any questions regarding this notice please contact me or Caitlin Caudle at the
letterhead address or phone number, or by email at lon.sniderncdenr.gov or
caitlin.caudle©ncdenr.gov.
Sincerely,
DocuSiiggned by:
145B49E225C94 EA
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Enc: Inspection Report
Cc: Randolph County Environmental Health (electronic copy)
WSRO Electronic Files
Laserfiche File WQ0015491
LD_E
NORTH CAROLINA
Department of Environmental quaky
North Carolina Department of Environmental Quality j Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0015491 Effective: 06/19/18 Expiration: 04/30/22 Owner : Russell Harrison Hackett Heirs
SOC: Effective: Expiration: Facility: Caraway Speedway WWTF
County: Randolph
Region: Winston-Salem
Contact Person: Darren A Hackett Title: Heir Phone:
Directions to Facility:
Rt. 52. to Rt. 64E through Lexington, to old Lexington Rd. Left at Carraway sign left at green farm Rd. straight across stop sign onto
old country farm Rd. to Race track Rd. left
System Classifications: SI,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 02/22/2022
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Entry Time 10:05AM Exit Time: 12:15PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Wastewater Irrigation
Facility Status: E Compliant Not Compliant
Question Areas:
▪ Miscellaneous Questions
▪ Record Keeping
▪ Storage
(See attachment summary)
▪ Treatment Treatment Filters
▪ End Use -Irrigation Treatment Disinfection
Page 1 of 6

Permit: WQ0015491 Owner - Facility: Russell Harrison Hackett Heirs
Inspection Date: 02/22/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On February 22, 2022, Division of Water Resources staff person Caitlin Caudle conducted a schedule compliance inspection
of the subject facility. Darren Hackett, ORC, was present during the entire inspection. A review of records, treatment
system, and irrigation fields was completed. The irrigation system had been winterized and was not viewed in operation. This
review reflected noncompliance with the subject permit.
DWR correspondence Notice of Violation and Notice of Intent to Enforce dated August 30, 2021 (tracking number
NOV-2021-PC-0437 and NOV-2021-PC-0435) was hand delivered after being returned to the Office. The Civil Penalty
Assessments issued to date were discussed, and the most recent Notice of Violation and Notice of Intent to Enforce.
The following deficiency was noted:
1. Per Permit Condition IV.9 "an annual representative soil analysis ... shall be completed on each irrigation site listed in
Attachment B." A soil analysis was not completed for the 2020 calendar year. This is a violation of the subject permit.
The following items of concern were noted:
A. Mr. Hackett stated that the irrigation had not been calibrated this permit cycle. Per Permit Condition 111.6 "all irrigation
equipment shall be tested and calibrated at least once per permit cycle. Calibration records shall be maintained at the
facility for a period of no less than five years, and shall be made available to the Division upon request." Ms. Caudle
recommended that the irrigation system be calibrated as soon as possible.
B. The current designated back-up ORC has not completed the required continuing education hours or paid the license
renewal fee. Per Permit Condition 111.2 "... the Permittee shall designate and employ a certified operator in responsible
charge (ORC) and one or more certified operator(s) as back-up ORC(s)." Per 15A NCAC 08G .0200 a new back-up operator
must be designated within 120 days of a position vacancy.
C. A few trees were down in the irrigation zones and several large holes and breaks in drip lines were present during the
inspection. This was also noted in the 2019 compliance inspection. Permit Condition 11.1 states "the subject non -discharge
facilities shall be effectively maintained and operated at all times..." Please repair the drip lines before first use this year and
conduct regular inspections to ensure the drip lines are maintained properly.
D. The lab results for effluent monitoring listed nitrate (NO3) as nitrate + nitrite (NO2+NO3). The work order for analysis
lists NO3 only and Attachment A requires NO3 be analyzed. Ms. Caudle recommended that Mr. Hackett contact the testing
company to ensure that the proper analysis is being completed.
Other observations:
• Solids have never been removed from the septic tank, but it is checked once a year when the system is prepared for
seasonal use. Mr. Hackett stated that since the system has been installed residuals have not been removed from the septic
tank.
• An Operations and Maintenance Plan and Spill Plan were in the office and at the pump house.
• A chainlink fence surrounds the irrigation field and treatment system.
• The lab report were reviewed for 12/2020, 4/2021, 7/2021, and 11/2021. The ND values reported were reviewed. Ms.
Caudle recommended that Mr. Hackett report ND values as <reporting limit. For example, the reporting limit for ammonia is
0.10 mg/L. If the lab results report ammonia as ND, ammonia would be reported on the NDMR as <0.10.
• The system is always run in manual mode. A computer is used to operate the system and it is not stored in the pump
house.
• The system is completely off unless someone is at the pump house. High water alarms are present on the storage
tanks and mixing tank that will send a call out, but only if the computer is connected to the system.
• The system will send a warning when there is 20% high flow in a system, and cut off when there are 50% high flows.
• Wastewater will be treated when the septic tanks is approximately half full, and irrigation will occur when there is
Page 2 of 6

Permit: WQ0015491 Owner - Facility: Russell Harrison Hackett Heirs
Inspection Date: 02/22/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
enough effluent in the storage tanks. At the time of inspection the low water float was visible.
• This system only serves the office building and bathrooms that serve part of the grandstand.
• The infield restrooms are served by a subsurface septic system.
• The system was winterized and shut off on 12/2/2021.
• Mr. Hackett will check the system before and after an event.
• All provided monitoring reports were sent to [e-mail] by Ms. Caudle on 2/23/2022.
• The two 12,000 gallon tanks are the connected storage tanks. The tanks are underground.
• All wastewater gravity feeds to the septic tank, which gravity feeds into the dose/mixing tank.
• The 2018 and 2019 soils reports were reviewed.
• A water meter is not present to measure the influent that enters the system. Mr. Hackett measures the volume in the
recirculation/sand filter dose tank before and after events at the facility.
Page 3 of 6

Permit: WQ0015491 Owner - Facility: Russell Harrison Hackett Heirs
Inspection Date: 02/22/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Reuse (Quality)
Infiltration System
Lagoon Spray, LR
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Spray, HR
Single Family Drip
Recycle/Reuse
Activated Sludge Drip, LR
Treatment
Are Treatment facilities consistent with those outlined in the current permit?
Do all treatment units appear to be operational? (if no, note below.)
Comment: System was winterized and did not see it in operation.
Treatment Filters
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?
Comment:
Treatment Disinfection
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?
Yes No NA NE
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Yes No NA NE
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Yes No NA NE
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Page 4 of 6

Permit: WQ0015491 Owner - Facility: Russell Harrison Hackett Heirs
Inspection Date: 02/22/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
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 Ibs 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-
If yes, then when was the RMP last updated?
Comment:
Record Keeping
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?
Comment: Soil samples were not collected in 2020.
End Use -Irrigation
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Yes No NA NE
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Yes No NA NE
Page 5 of 6

Permit: WQ0015491 Owner - Facility: Russell Harrison Hackett Heirs
Inspection Date: 02/22/2022 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Are buffers adequate?
Is the cover crop type specified in permit?
Is the crop cover acceptable?
Is the site condition adequate?
Is the site free of runoff / ponding?
Is the acreage specified in the permit being utilized?
Is the application equipment present?
Is the application equipment operational?
Is the disposal field free of limiting slopes?
Is access restricted and/or signs posted during active site use?
Are any supply wells within the CB?
Are any supply wells within 250' of the CB?
How close is the closest water supply well?
Is municipal water available in the area?
# Info only: Does the permit call for monitoring wells?
Are GW monitoring wells located properly w/ respect to RB and CB?
Are GW monitoring wells properly constructed, including screened interval?
Are monitoring wells damaged?
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Page 6 of 6