NC0034452_Compliance Evaluation Inspection_20240111

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Shannon V. Becker
Aqua North Carolina Inc.
202 Mackenan Dr
Cary, NC 27511
NORTH CAROLINA
Environmental Quality
January 11, 2024
SUBJECT: COMPLIANCE EVALUATION INSPECTION & NOTICE OF VIOLATION
Tracking Number: NOV-2024-PC-0009
Permit No. NCO034452
Willow Creek WWTP
Davidson County
Dear Mr. Becker:
On December 8, 2023, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO) staff Jesse
Barnes conducted a routine compliance evaluation inspection at the Willow Creek WWTP in reference to NPDES
permit NC0034452. ORC Ryan Smith was present during the inspection. A review of the subject permit, records,
data, laboratory, treatment components, sampling methods, outfall area, operations, and maintenance was
completed. This review reflected noncompliance with the subject permit. The determined permit violations and
items of concern are listed below. Inspection findings are detailed in the attached Water Compliance Inspection
Report.
The following violation(s) were noted during the inspection:
Inspection Area
Description of Violation
Effluent Sampling
The effluent composite sampler was programmed to collect constant volume aliquots at a
constant time interval, regardless of flow rate. Part II, Section A. of the subject permit
requires composite samples to be collected in a manner that is proportional to the rate of
flow.
In addition, the following
item(s) of concern were noted during the inspection:
Inspection Area
Item of Concern
Secondary Clarifiers
The secondary clarifiers appeared to have unequal flow across the overflow weirs, possibly
due to the weirs not being level and/or the observed moderate accumulated scum.
Secondary Clarifiers
The sludge blanket within the secondary clarifiers appeared to be within a few feet of the
surface.
Effluent Pipe
At the outfall, the effluent pipe and discharge were not visible due to vegetation. Please
North Carolina Department of Environmental Quality 1 Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mitl Road, Suite 300 1 Winston-Salem. North Carolina 27105
336,776.9600

maintain the outfall area so it can be easily inspected.
The indicated permit violation(s) must be corrected to achieve compliance with the subject permit. Measures should
be taken to address the indicated item(s) of concern. Please be aware that the Division may take enforcement
action against any individual who fails to comply with the requirements of all applicable permits, regulations, and/or
statutes. Pursuant to NC General Statute (NCGS) 143-215.6A, a civil penalty of not more than twenty-five thousand
dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms,
conditions, or requirements of any permit, or applicable regulations, issued pursuant to G.S. 143-215.1.
If you have questions, contact Jesse Barnes by phone at 336-776-9701 or by email at [e-mail].
Thank you for your time and attention to this matter.
Sincerely,
DocuSigned by:
OD2D3CE3F1B7456...
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Water Compliance Inspection Report, NCO034452
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 West Hanes Mitl Road, Suite 300 1 Winston-Salem. North Carolina 27105
336,776.9600

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 1 2 u 3 I NC0034452 111 121 23/12/08 I17 18 LC] I 19 I s I 20L]
21111I 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 r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I ni I 71 I 74 79 I I I I I I I80
701 I 71 I LL -1 I I
LJ
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 Dermit Number)
10:OOAM 23/12/08
19/06/01
Willow Creek WWTP
Dorado Dr
Exit Time/Date
Permit Expiration Date
High Point NC 27262
11:30AM 23/12/08
24/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Ryan M Smith/ORC/336-996-2841/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Harold White,1730 N Main St High Point NC 27262//336-881-1422/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Facility Site Review Effluent/Receiving Wate Laboratory
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
Jesse Barnes Docusigned by: DWR/WSRO WQ/336-776-9701/
1/9/2024
5 Ba4~4'
41797473D3194ED...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Docusigned by: DWR/WSRO 336-776-9695 1/11/2024
EPA Form 3560-3 ReORP6c4E" r-e ous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO034452 I11 12I 23/12/08 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On December 8, 2023, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO)
staff Jesse Barnes conducted a routine compliance evaluation inspection at the Willow Creek WWTP
in reference to NPDES permit NC0034452. ORC Ryan Smith was present during the inspection. A
review of the subject permit, records, data, laboratory, treatment components, sampling methods,
outfall area, operations, and maintenance was completed. This review reflected noncompliance with
the subject permit. The determined permit violations and items of concern are listed below. Inspection
findings are detailed in the attached Water Compliance Inspection Report.
Permit Violations
1. The effluent composite sampler was programmed to collect constant volume aliquots at a
constant time interval, regardless of flow rate. Part II, Section A. of the subject permit requires
composite samples to be collected in a manner that is proportional to the rate of flow.
Items of Concern
1. The secondary clarifiers appeared to have unequal flow across the overflow weirs, possibly due
to the weirs not being level and/or the observed moderate accumulated scum.
2. The outfall pipe and effluent discharge were not visible due to vegetation. Please maintain the
outfall area so it can be easily inspected.
3. The sludge blanket within the secondary clarifiers appeared to be within a few feet of the surface.
Other observations:
NPDES permit NC0034452 became effective June 1, 2019, and will expire April 30, 2024. At the time
of inspection, a permit renewal application has been submitted and is in review. Facility access is
restricted by a locked fence.
All required records were available for review during the inspection. Mr. Smith keeps digital copies of
archival records, and they were accessible via tablet. Laboratory data, chains of custody, and
discharge monitoring reports were available digitally during the inspection. A hard copy of the subject
permit was present at the facility during the inspection.
Field parameters are performed by Aqua NC LLC, certified lab #5035. Non -field parameters are
performed by Water Tech Labs Inc, certified lab #50.
According to the operator, the automatic standby power generator is tested once per month for thirty
minutes under load and by interrupting the primary power source. A record of generator testing was
available during the inspection.
The high-level alarm at the influent pump station was tested by pulling a float control. Both audible
and visible alarms were successfully triggered, and the telemetry phone system notified Mr. Smith.
The power failure alarm was also tested and triggered successfully.
The bar screen is an automatic mechanical Huber Technology "corkscrew" type model, and it
appeared to be operating properly during the inspection.
The treatment plant is divided into three separate trains with each train consisting of an aeration
basin and a secondary clarifier. Flow to each train is controlled by a splitter box after the equalization
basin before traveling to the aeration basins.
Some excessive floating sludge was observed in the secondary clarifiers. Mr. Smith was asked to
measure the sludge blanket depth but the sludge judge on site was not long enough to reach the
bottom of the clarifier, so a definitive measurement could not be made. Mr. Smith stated that he
typically monitors the sludge quality via settleability tests. The sludge blanket appeared to be within a
Page#

Permit: NCO034452
Inspection Date: 12/08/2023
few feet of the surface during the inspection.
Owner -Facility: willow Creek WWTP
Inspection Type: Compliance Evaluation
The gravity sand filter was in use during the inspection and appeared to be operating properly. Mr.
Smith stated that typically only a small portion of the plant flow is filtered due to issues with clogging
and the need to be frequently backwashed. The filter is kept operational and in use in case it is
needed to remove excessive solids.
Both tablet disinfection and de -chlorination systems utilized two contact boxes, each containing 4
tablet tubes for a total of 8 tubes in each system. The disinfection and de -chlorination systems
contained appropriate tablets and appeared to be operating properly during the inspection.
A Teledyne ISCO Signature model flow meter was in use and appeared to be operating properly
during the inspection. The flow meter was last calibrated by Mr. Smith on January 27, 2022.
An ISCO 5800 composite sampler was in use to collect effluent composite samples. Mr. Smith stated
that the sampler was programmed to collect 96 aliquots of 600 mL at a constant time interval across a
24-hour period, which would not be proportional to the rate of flow. If that is accurate, the total sample
size would be 57.6 liters and overflow the sample container. Please verify the sampler programming
and see violation #1 above concerning flow proportionality.
Effluent sample temperature is analyzed with a combination dissolved oxygen/thermometer probe.
Calibration records for the thermometer feature were available for review during the inspection and
appeared complete.
The in -stream sampling locations were verified by Mr. Smith but were not visually inspected due to
time constraints.
Page#

Permit: NCO034452 Owner -Facility: willow Creek WWTP
Inspection Date: 12/08/2023 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
0
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❑
❑
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:
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
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❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
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Are analytical results consistent with data reported on DMRs?
❑
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Is the chain -of -custody complete?
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Dates, times and location of sampling
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Name of individual performing the sampling
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Results of analysis and calibration
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Dates of analysis
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Name of person performing analyses
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Transported COCs
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Are DMRs complete: do they include all permit parameters?
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Has the facility submitted its annual compliance report to users and DWQ?
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0
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
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0
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operator on each shift?
Is the ORC visitation log available and current?
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Is the ORC certified at grade equal to or higher than the facility classification?
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Is the backup operator certified at one grade less or greater than the facility
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classification?
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
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Comment:
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑
Page# 4

Permit: NCO034452 Owner -Facility: willow Creek WWTP
Inspection Date: 12/08/2023 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
■
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0
❑
❑
❑
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
❑
Comment:
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
■
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Was generator tested & operational during the inspection?
❑
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Do the generator(s) have adequate capacity to operate the entire wastewater site?
0
❑
❑
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Is there an emergency agreement with a fuel vendor for extended run on back-up
❑
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❑
■
power?
Is the generator fuel level monitored?
0
❑
❑
❑
Comment:
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:
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
0
❑
❑
❑
Is the wet well free of excessive grease?
0
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❑
❑
Are all pumps present?
0
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❑
Are all pumps operable?
❑
❑
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Are float controls operable?
0
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Is SCADA telemetry available and operational?
0
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❑
❑
Is audible and visual alarm available and operational?
0
❑
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❑
Page# 5

Permit: NCO034452 Owner -Facility: willow Creek WWTP
Inspection Date: 12/08/2023 Inspection Type: Compliance Evaluation
Pump Station - Influent Yes No NA NE
Comment:
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:
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Is the basin free of excessive grease?
■
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❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
0
❑
❑
❑
Are float controls operable?
❑
❑
❑
Are audible and visual alarms operable?
❑
❑
❑
■
# Is basin size/volume adequate?
0
❑
❑
❑
Comment:
Aeration Basins
Yes
No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
■
❑
❑
❑
Are surface aerators and mixers operational?
❑
❑
■
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Are the diffusers operational?
0
❑
❑
❑
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?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
❑
❑
Page# 6

Permit: NC0034452
Inspection Date: 12/08/2023
Aeration Basins
Comment:
Owner -Facility: Willow Creek WWTP
Inspection Type: Compliance Evaluation
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
Yes No NA NE
Yes
No
NA
NE
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Comment: The secondary clarifiers appeared to have unequal flow across the overflow weirs
Possibly due to the weirs not being level and/or the observed moderate accumulated
scum. Some excessive floating sludge was observed in the secondary clarifiers. Mr.
Smith was asked to measure the sludge blanket depth but the sludge fudge on site was
not long enough to reach the bottom of the clarifier, so a definitive measurement could
not be made. Mr. Smith stated that he typically monitors the sludge quality via
settleability tests. The sludge blanket appeared to be within a few feet of the surface
during the inspection.
Disinfection -Tablet
Yes
No
NA
NE
Are tablet chlorinators operational?
0
❑
❑
❑
Are the tablets the proper size and type?
■
❑
❑
❑
Number of tubes in use?
8
Is the level of chlorine residual acceptable?
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
■
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
Comment:
De -chlorination Yes No NA NE
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑
Is storage appropriate for cylinders? ❑ ❑ 0 ❑
Page# 7

Permit: NCO034452
Inspection Date: 12/08/2023
De -chlorination
Owner -Facility: willow Creek WWTP
Inspection Type: Compliance Evaluation
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
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:
Effluent Pipe
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
If effluent (diffuser pipes are required) are they operating properly?
Comment:
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?
Yes
No
NA NE
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•
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8
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# 8

Permit: NCO034452
Inspection Date: 12/08/2023
Effluent Sampling
Owner -Facility: willow Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The effluent composite sampler was programmed to collect constant volume aliquots at
a constant time interval, regardless of flow rate. Part II, Section A. of the subject permit
requires composite samples to be collected in a manner that is proportional to the rate
of flow. An ISCO 5800 composite sampler was in use to collect effluent composite
samples. Mr. Smith stated that the sampler was programmed to collect 96 aliquots of
600 mL at a constant time interval across a 24-hour period, which would not be
proportional to the rate of flow. If that is accurate, the total sample size would be 57.6
liters and overflow the sample container. Please verify the sampler programming and
see violation #1 concerning flow proportionality.
Upstream / Downstream Sampling
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
Comment:
Yes No NA NE
■ ❑ ❑ ❑
Page#