NC0023604_Wilderness_Lumber_CEI_Letter_20240327

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Wilderness NC, Inc
Attn: Ronnie Bolt, Owner/President
P.O. Box 2136
Lexington, NC 27293
NORTH CAROLINA
Environmental Quality
March 28, 2024
SUBJECT: Compliance Evaluation
Wilderness — NC Lumber Plant
NPDES Permit Number: NCO023604
Davidson County
Dear Mr. Bolt:
On March 25, 2024, Division of Water Resources staff, Ron Boone, conducted a routine compliance
evaluation inspection at the Wilderness — NC Lumber Plant , NPDES permit NC0023604. Operator in
Responsible Charge (ORC), David Perdue, was present during the inspection. A review of records, data,
treatment components, structures, and the outfall was completed. This inspection reflected non-
compliance with the subject permit.
The following issue was documented during the inspection:
1. There is no backup operator in responsible (ORC) charge designated for the plant.
The following items of concern were also noted:
1. The entire plant structure is becoming badly corroded in many areas.
Please designate a backup ORC within 60 days of receiving this letter and notify this office when this is
complete.
Please feel free to contact Mr. Boone by phone at 336.776.9690, or by email at [e-mail],
with any questions or concerns you may have.
Attachments:
Water Compliance Inspection Report
Sincerely,
[D­B,"Sign,d by:
49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
NoanicaaouNn
oep.m.m a emranmenua Qualm,
336.776.9800

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 NC0023604 111 121 24/03/25 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 24/03/25
23/10/01
Wilderness -NC Lumber Plant
7578 US Hwy 64 E
Exit Time/Date
Permit Expiration Date
Lexington NC 27292
11:30AM 24/03/25
28/05/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
David Wayne Perdue/ORC/336-474-2314/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Shannon Floyd,7578 US Hwy 64 E Lexington NC 27292//336-474-2314/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispo: 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
Ron Boone Docusigned by: DWR/WSRO WQ/336-776-9690/
ad 2300.,.e' 4/2/2024
E-,-
0F8DD5F2A3460...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by: 3/28/2024
- -T. Sti�olcr
FL
145B49E225C94EA...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO023604 I11 12I 24/03/25 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On March 25, 2024, Division of Water Resources staff, Ron Boone, conducted a routine
compliance evaluation inspection at the Wilderness — NC Lumber Wastewater Treatment Plant,
NPDES permit NC0023604. The permittee is Wilderness NC Inc. Operator in Responsible Charge
(ORC), David Perdue, was present during the inspection. A review of records, data, treatment
components, structures, and the outfall was completed. This inspection reflected non-compliance with
the subject permit.
According to our database, there is currently no backup operator in responsible charge (BORC)
assigned. This needs to be addressed immediately. If you require assistance in designating a BORC,
please contact Mr. Boone.
The permit was last issued in August 2023, and expires in May 2028. There are two separate outfalls
covered by this permit. Outfall 001 is for domestic and boiler blowdown wastewater, and it discharges
to Flat Swamp Creek, a Class C water body in the Yadkin -Pee Dee River Basin. Outfall 002 is for kiln
condensate, and it also discharges to Flat Swamp Creek. Outfall 001 is permitted a maximum 30-day
average of 0.0125 million gallons per day. Outfall 002 has no flow limit imposed at this time.
Flow comes into the plant through a 12" steel pipe. There is a bar screen and comminutor at the
head of the plant but the bar screen is severely corroded and 6 of its 11 bars are completely eroded
away while the other five are getting close to also completely corroding away. Mr. Perdue indicated
that he never uses the comminutor. The bar screen should be repaired or replaced. Corrosion if
quite advanced throughout the plant. There is a hole eaten completely through the eastern wall of
the plant structure and the clarifier's water surface level is just 2" to 4" below the hole. This hole
should be repaired as soon as possible.
Mr. Perdue stated that he normally uses visual inspection of the mixed liquor to determine when
sludge should be wasted. He said that he does have a Sludge Judge that he uses from time to time
but normally just relies on visual inspection. There didn't appear to be any problems with the sludge
but the mixed liquor does look thin, with a rather weak biomass. Test results, however, demonstrate
the plant is operating well. There has been no violations the BOD limit since 2019, ammonia since
2002, and total suspended solids since 2011.
Mr. Perdue stated he only has to have sludge removed about once per year. He keeps records of
sludge removal by keeping the pumper invoices on file. Mr. Perdue stated that the digester was just
pumped last week.
The clarifier was not overflowing at the time of the inspection but the weirs appear level and the
skimmer appears to be in good condition. As mentioned earlier, the clarifier does have significant
corrosion.
Water flows to the 54-day pond from the clarifier. The pond appears to be in good shape. Water from
the pond is pumped to a pump tank where it is then pumped up onto the surface sand filter. The filter
itself appears to be functional and in good condition. Two of the blowout line inlets were broken and
two diffuser caps were misaligned or broken during the inspection. These should be repaired as soon
as possible.
The plant uses a two -tube tablet chlorinator and a two -tube tablet dechlorinator. Both units were
using both tubes and both tubes had at least one tablet in them during the inspection. Mr. Perdue
stated he does not like putting a lot of tablets in there because they absorb moisture and begin to
disintegrate, resulting in caked up tablets that clog the tubes. This is fine as long as each tube always
has at least one tablet in it. There have been no violations of the 50 microgram chlorine limit.
The outfall is accessible and was inspected during the inspection. There were no issues noted. There
were no solids or foam in the stream. The effluent was much clearer than the receiving stream.
Page#

Permit: NCO023604
Inspection Date: 03/25/2024
Owner -Facility: wilderness -NC Lumber Plant
Inspection Type: Compliance Evaluation
Mr. Boone also examined Mr. Perdue's paperwork. All required paperwork including the discharge
monitoring reports (DMR) and lab documentation, the field lab certification, operator's visitation log,
and operation and maintenance logbook were readily available for inspection. Mr. Boone noted no
issues with Mr. Perdue's paperwork. Mr. Perdue stated that he has never gotten rid of any
operational records and that all are still on file since the plant started up. DMRs and lab
documentation for January 2022 and October 2023 were reviewed and no mistakes or discrepancies
were noted. Mr. Perdue stated that he takes his field readings and annotates them on inspection tags
which he them brings back to the office and transfers the readings to a handwritten DMR. The
handwritten DMR, once completed, is then given to administrative staff who then fill out and submit
the eDMR.
The plant appears to be well operated and maintained. Several units are showing their age and the
existing corrosion needs to be repaired before it results in failure.
If you have any questions or concerns, please contact Ron Boone by phone at 336.776.9690, or by
email at [e-mail].
Page#

Permit: NCO023604
Inspection Date: 03/25/2024
Owner -Facility: wilderness -NC Lumber Plant
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
❑
❑
■
❑
application?
Is the facility as described in the permit?
❑
■
❑
❑
# Are there any special conditions for the permit?
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■
❑
❑
Is access to the plant site restricted to the general public?
■
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❑
❑
Is the inspector granted access to all areas for inspection?
■
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❑
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Comment: Plant description should be updated and reconciled with what is actually on site.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
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Is all required information readily available, complete and current?
■
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Are all records maintained for 3 years (lab. reg. required 5 years)?
■
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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
■
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?
■
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Has the facility submitted its annual compliance report to users and DWQ?
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■
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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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■
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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?
■
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Facility has copy of previous year's Annual Report on file for review?
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■
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Comment: No backup ORC is designated.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? ■ ❑ ❑ ❑
Page# 4

Permit: NCO023604 Owner -Facility: wilderness -NC Lumber Plant
Inspection Date: 03/25/2024 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
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# 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
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❑
❑
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: None
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
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0
❑
Is sample collected below all treatment units?
0
❑
❑
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Is proper volume collected?
■
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Is the tubing clean?
❑
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0
❑
# 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
■
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representative)?
Comment: None
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑
and sampling location)?
Comment: None
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
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0
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Is the screen free of excessive debris?
0
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❑
Is disposal of screening in compliance?
0
❑
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Is the unit in good condition?
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0
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Comment: Very corroded. Only 5 of 11 bars remain. The other six have disintegrated.
Page# 5

Permit: NCO023604 Owner -Facility: wilderness -NC Lumber Plant
Inspection Date: 03/25/2024 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0
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Are surface aerators and mixers operational?
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0
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Are the diffusers operational?
0
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Is the foam the proper color for the treatment process?
0
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Does the foam cover less than 25% of the basin's surface?
0
❑
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Is the DO level acceptable?
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Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
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Comment: None
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?
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0
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Are weirs level?
0
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Is the site free of weir blockage?
0
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Is the site free of evidence of short-circuiting?
0
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Is scum removal adequate?
0
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Is the site free of excessive floating sludge?
■
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Is the drive unit operational?
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0
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Is the return rate acceptable (low turbulence)?
0
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Is the overflow clear of excessive solids/pin floc?
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Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
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■
Comment: Clarifier was not overflowing at the time of the inspeciton.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
■
❑
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Are pumps operational?
■
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Are there adequate spare parts and supplies on site?
0
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Comment: None
Sand Filters (Low rate) Yes No NA NE
(If pumps are used) Is an audible and visible alarm Present and operational? ❑ 0 ❑ ❑
Page# 6

Permit: NCO023604 Owner -Facility: wilderness -NC Lumber Plant
Inspection Date: 03/25/2024 Inspection Type: Compliance Evaluation
Sand Filters (Low rate)
Yes
No
NA
NE
Is the distribution box level and watertight?
❑
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Is sand filter free of ponding?
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0
❑
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Is the sand filter effluent re -circulated at a valid ratio?
0
❑
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❑
# Is the sand filter surface free of algae or excessive vegetation?
0
❑
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❑
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1)
0
❑
❑
❑
Comment: Two blowout lines were broken and two dispersion caps were either misaligned,
broken, or missing. All should be repaired as soon as possible.
Disinfection -Tablet
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Number of tubes in use?
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?
Yes
No
NA
NE
•
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•
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2
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Comment: There's not really a contact chamber, must the pipe between the chlorinator and
dechlorinator. About 200' of pipe.
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
❑
❑
❑
Are the tablets the proper size and type?
■
❑
❑
❑
Comment: None
Are tablet de -chlorinators operational? 0 ❑ ❑ ❑
Number of tubes in use? 2
Comment: None
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
❑
❑
0
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
0
❑
Page# 7

Permit: NCO023604
Inspection Date: 03/25/2024
Flow Measurement - Effluent
Comment: Flow estimated instantaneously.
Owner -Facility: wilderness -NC Lumber Plant
Inspection Type: Compliance Evaluation
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: None
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
# Is tankage available for properly waste sludge?
Comment: None
Yes No NA NE
Yes
No
NA
NE
■
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■
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■
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Yes
No
NA
NE
■
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■
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■
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■
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Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ■ ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Plant is starting to corrode severely in several areas and steps should be taken to halt
and repair the damage.
Page# 8