NC0039420_Virginia_DOT_I-77_Rest_Area_CEI_NOV_Letter_20240404

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Virginia DOT
Attn: Allen Campbell
1401 East Broad Street
Richmond, VA 23219
NORTH CAROLINA
Environmental Quality
April 4, 2024
SUBJECT: Compliance Evaluation Inspection & Notice of Violation
NOV Tracking Number: NOV-2024-LC-0001
Virginia DOT/1-77 Rest Area Wastewater Treatment Plant
NPDES Permit Number: NCO039402
Surry County
Dear Mr. Campbell:
On March 28, 2024, Division of Water Resources staff Ron Boone, conducted a routine
compliance evaluation inspection at the Virginia DOT/1-77 Rest Area Wastewater Treatment
Plant, NPDES permit NC0039420. Operator in Responsible Charge (ORC) Chris Marion was
present for the inspection. A review of records, data, treatment components, structures, and the
outfall was completed.
This inspection reflected non-compliance with the subject permit. Mr. Boone noted the following
violations:
1. The permittee does NOT possess a current field laboratory certification as required by Part
II, Section D, Paragraph 4, of the permit.
2. Effluent composite sampling is NOT collected flow proportionally as required by Part 11,
Section A, of the permit.
You can find the inspection details in the attached Water Compliance Inspection report.
Other than these two violations the plant appears to be run very well by the operators. The
effluent quality appears to be excellent.
Please take immediate action to correct the two violations listed above. Mr. Boone has already
initiated the process of correcting the missing laboratory certification by contacting our
laboratory certification branch and including Mr. Marion in the email conversation. As far as flow
proportional sampling is concerned, Virginia DOT should take the necessary steps to make the
Moan D_'E'
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
336.776.9800

effluent composite sampling flow proportional or request an official waiver from this
requirement. We expect that you should be able to have both violations corrected, or at a
minimum, corrective actions identified and initiated, no later than 90 days after receiving this
notice.
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.
Sincerely,
DocuSigned by:
OD2D3CE3F167456_.
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
Water Compliance Inspection Report
cc: Chris Marion, Operator in Responsible Charge, via email
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
naparMeM of EmironmanW 9uallly

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 NC0039420 111 121 24/03/28 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 1166
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 24/03/28
19/03/01
Virginia DOT/1-77 Rest Area
1-77 NC-Va State Line Car
Exit Time/Date
Permit Expiration Date
Pine Hall NC 27042
12:OOPM 24/03/28
24/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Christopher S Marion/ORC/336-786-3597/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Allen Campbell,1401 E Broad St Richmond VA 23219//804-786-0668/8047860652
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/
Ostia& Boone, 4/4/2024
B20FSDD5F2A3460...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Docusigned by:
_D- "-4. DWR/WSRo 336-776-9695 4/4/2024
Fj
'--OD2D3CE3F1B7456.-
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO039420 I11 12I 24/03/28 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On March 28, 2024, Division of Water Resources staff, Ron Boone, conducted a routine compliance
evaluation inspection at the Wastewater Treatment Plant for the Virginia DOT/1-77 Rest Area, NPDES
permit NC0039420. Operator in Responsible Charge (ORC), Chris Marion, 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 permit was issued in December 2018 and expired in February 2024. The permit renewal
application was received by the Division in November 2023 and is currently under review for
reissuance. Outfall 001 for this plant discharges to Naked Run, a Class WS-IV, trout stream in the
Yadkin -Pee Dee River Basin.
Flow enters the plant passing first through the solids screening basket, which is emptied by hand.
The basket appears to be in good condition.
Flow then goes to the aeration basins. Only one of three treatment trains is currently in operation.
The others are used for storage as needed. The operators are currently using heat blankets to cover
all treatment processes, which entraps heat to improve treatment and also protects the units from
exterior falling matter, such as leaves. It was difficult to see the mixed liquor but what was observed
looked good and had a healthy activated sludge odor.
From the aeration basins, the wastewater flows to the secondary clarifiers. The overflow of the
clarifier was very clear, with no solids and very little foam. The weirs appeared level and scum
removal appeared adequate. No apparent mechanical issues were noted with any of the aeration
basins and clarifiers.
Wastewater then flows from the clarifier(s) to the UV system and backup chlorination and
dechlorination units. All units are currently in use because the UV system's intensity sensor is down,
and operators are unable to determine whether UV disinfection is sufficient without it. The intensity
sensor has been ordered, according to operators. The chlorine/dechlori nation systems are tablet
type. The proper tablets are being used, and two chlorine tubes and three dechlorination tubes are
currently in use.
Effluent flow is measured with a Siemens Milltronics OCM III meter/recorder, which was last calibrated
3/27/2024. Effluent composite sampling is NOT currently flow proportional. This must be corrected
immediately or you must request a waiver from the Division from using flow proportional composite
sampling.
The right of way to the outfall is completely clear and fully accessible. The discharge of treated
wastewater to Naked Run is very clear with no solids or foam formation.
All required records were evaluated during the inspection including laboratory results and chains of
custody along with matching discharge monitoring reports, visitation logs, operation and maintenance
logs, sludge records, etc. No discrepancies were noted, however the facility is not currently certified
as a field laboratory. Therefore, all field measurements are technically invalid at this point. Please
work with the NC Laboratory Certification Branch to obtain the required certification.
Wet sludge is pumped and hauled to Mount Airy for disposal.
The plant can be operated entirely using the on -site permanent diesel driven generator. The
generator is inspected regularly by the operators and receives annual maintenance via contractor.
The fuel level is monitored. The generator automatically runs every Tuesday for exercise and to
ensure operability.
Page#

Permit: NCO039420
Inspection Date: 03/28/2024
Owner -Facility: Virginia DOT/1-77 Rest Area
Inspection Type: Compliance Evaluation
This plant seems very well operated and maintained. The operators appear to be doing an excellent
job. The issues for flow proportional sampling and the field lab certification must be immediately
addressed. 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: NCO039420
Inspection Date: 03/28/2024
Owner -Facility: Virginia DOT/1-77 Rest Area
Inspection Type: Compliance Evaluation
Permit
(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?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment: Plant actually has a screening basket, rather than a bar screen.
Record Keeping
Are records kept and maintained as required by the permit?
Is all required information readily available, complete and current?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain -of -custody complete?
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?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
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Yes No NA NE
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Comment: The operators have several loqs they use to annotate O&M and visitation. Mr. Marion
asked Mr. Boone during the inspection whether the logbook was necessary and
whether it could be eliminated considering the other logs that they use. Mr. Boone told
him he thought the logbook could be eliminated and that they would still be meeting the
requirements of the permit using the remaining means of documentation.
Page# 4

Permit: NCO039420
Inspection Date: 03/28/2024
Owner -Facility: Virginia DOT/1-77 Rest Area
Inspection Type: Compliance Evaluation
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# 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?
Yes No NA NE
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Comment: None. The facility does not currently have a field laboratory certification. The operator
informed Mr. Boone that they are working with Michael Cumbus, with DWR, to obtain
the required certification. Mr. Boone emailed Mr. Cumbus on 4/4/24 to get an update
on that effort.
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)?
Comment: Composite sampling is not flow proportional.
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Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑
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?
0
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Is the screen free of excessive debris?
0
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Is disposal of screening in compliance?
■
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Is the unit in good condition?
0
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Page# 5

Permit: NCO039420 Owner -Facility: Virginia DOT/1-77 Rest Area
Inspection Date: 03/28/2024 Inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
Comment: This is a screeninq basket, not a bar screen.
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
0
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Is the basin free of bypass lines or structures to the natural environment?
0
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Is the basin free of excessive grease?
■
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Are all pumps present?
■
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Are all pumps operable?
0
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Are float controls operable?
0
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Are audible and visual alarms operable?
■
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# Is basin size/volume adequate?
■
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Comment: None
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?
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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: Operators were using heat blankets over all the units during the inspection to entrap
heat inside the treatment process, so, the mixed liquor couldn't be evaluated very well.
The small area that could be seen looked good though and no noxious odors were
present.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
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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?
E
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Is the site free of evidence of short-circuiting?
0
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Page# 6

Permit: NCO039420
Inspection Date: 03/28/2024
Owner -Facility: Virginia DOT/1-77 Rest Area
Inspection Type: Compliance Evaluation
Secondary Clarifier
Yes
No
NA
NE
Is scum removal adequate?
0
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Is the site free of excessive floating sludge?
0
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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?
E
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Is the sludge blanket level acceptable? (Approximately'/4
of the sidewall depth) ❑
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Comment: Aqain, heat blankets were beinq used here too but Mr. Boone could see the weirs and
the overflow. The weirs appear level and the overflow was very
clear and free of solids.
Pumps-RAS-WAS
Yes
No NA
NE
Are pumps in place?
0
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Are pumps operational?
0
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Are there adequate spare parts and supplies on site?
0
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Comment: None
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
0
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Is the mixing adequate?
0
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Is the site free of excessive foaming in the tank?
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# Is the odor acceptable?
0
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# Is tankage available for properly waste sludge?
0
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Comment: Records of sludge removal appeared to be complete. Sludqe is hauled to Mount Airy's
wastewater treatment plant for disposal.
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: Meter was last calibrateed 3/27/2024.
Disinfection -Tablet
Are tablet chlorinators operational?
Are the tablets the proper size and type?
Yes No NA NE
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Yes No NA NE
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Page# 7

Permit: NC0039420 Owner -Facility:
Inspection Date: 03/28/2024 Inspection Type:
Virginia DOT/1-77 Rest Area
Compliance Evaluation
Disinfection -Tablet
Yes
No
NA NE
Number of tubes in use?
2
Is the level of chlorine residual acceptable?
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Is the contact chamber free of growth, or sludge buildup?
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Is there chlorine residual prior to de -chlorination?
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Comment: None
Disinfection - UV
Yes
No
NA
NE
Are extra UV bulbs available on site?
0
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Are UV bulbs clean?
0
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Is UV intensity adequate?
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Is transmittance at or above designed level?
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Is there a backup system on site?
0
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Is effluent clear and free of solids?
0
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Comment: UV was in operation during inspection but the intensity sensor is broken and on order
so the operators are currently using chlorination and dechlorination simultaneously
with the UV to ensure complete disinfection occurs.
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Are the tablets the proper size and type?
Comment: None
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment: None
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
Yes No NA NE
Tablet
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3
Yes
No
NA
NE
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Page# 8

Permit: NCO039420
Inspection Date: 03/28/2024
Owner -Facility: Virginia DOT/1-77 Rest Area
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: None
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Is the generator fuel level monitored?
Comment: Generator runs automatically every Tuesday for a short period of exercise.
Yes
No
NA
NE
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Page# 9