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HomeMy WebLinkAboutWQ0029346_Notice of Deficiency_20240417 (2)ROY COOPER Governor ELIZABETH S. BISER Secretary RICHAM E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality April 17, 2024 Delivered electronically via email to: mwestphal(a)brmountainclub.com Mark Westphal, President Blue Ridge Mountain Club Property Owners Association Inc. P.O. Box 1727 Blowing Rock, NC 28605 SUBJECT: NOTICE OF DEFICIENCY (NOD-2024-PC-0070) Compliance Evaluation Inspection Blue Ridge Mountain Club WWI Permit No. WQ0029346 Watauga County Dear Mr. Westphal: On February 20, 2024, Division of Water Resources staff Kristen Potwora and Caitlin Williams conducted a scheduled routine compliance inspection of the Blue Ridge Mountain Club Wastewater Treatment Plant (WWTP) and the collection system. Travis Thomas (Lead Operator), R. Neil Reece (Area Manager) and Patrick Warren (VP of Development) were present for the inspection of the WWTP. Mr. Thomas and Mr. Warren were present for the inspection of the collection system. A review of the treatment system, storage facility, irrigation system, available records, and two lift stations was completed. This review reflected non-compliance with the subject permit. The following deficiencies were noted: 1. A soil report could not be located for the 2023 calendar year. Per Condition IV.14 of the permit, "an annual representative soils analysis shall be conducted on each irrigation site listed in Attachment B." Please be reminded that you must collect a soil sample each calendar year. 2. Irrigation Pump A has been broken since fall of 2023, and the gasket around the irrigation flowmeter was leaking. Per Condition V.1, "the permittee shall perform inspections and maintenance to ensure proper operation of the wastewater treatment and irrigation facilities." The leaking gasket was also noted in correspondence dated June 20, 2023. DWR staff was informed during the D � ��� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NOMlH naouNa 336.776.9800 inspection that the gasket should be replaced within the next 60 days. However there has been no communication on when Pump A will be fixed. The following item of concern was noted: • An updated Operation and Maintenance Plan and Spill Response Plan was not available on site during the inspection. However, an updated version was sent electronically to DWR staff on March 6, 2024. Moving forward, ensure a hard copy is on site per Permit Condition 111.2. Please refer to the enclosed inspection report for additional comments and observations. If you have any questions, please contact me or Kristen Potwora at the letterhead address and phone number 336-776-9697, or by email at or kristen. potwora(a)deq. nc.gov Sincerely, DocuSigned by: 87 OD2D3CE3F1416... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ-WSRO Enc: Inspection Report Cc: Travis Thomas (ORC) R. Neil Reece (Backup ORC) Patrick Warren, Engineer (electronic copy) NORTH CAROLINAD � R_ North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 336.776.9800 Comaliance Insaection Resort Permit: WO0029346 Effective: 11/14/22 Expiration: 02/28/29 Owner: Blue Ridge Mountain Club Property Owners Association Inc SOC: Effective: Expiration: Facility: Blue Ridge Mountain Club WWTP County: Watauga 493 Triplett Rd Region: Winston-Salem Ferguson NC 28624 Contact Person: Mark Westphal Directions to Facility: System Classifications: SI, WW3., Primary ORC: Travis Shane Thomas Secondary ORC(s): On -Site Representative(s): Title: President Certification: 1013753 Phone: 828-295-8667 Phone: 828-559-6032 Related Permits: WQCSD0751 Blue Ridge Mountain Club Property Owners Association Inc - Blue Ridge Mountain Club Wastewater Collection System Inspection Date: 02/20/2024 Entry Time 11:OOAMM Exit Time: 02:OOPM Primary Inspector: Kristen Potwora /12edt2yL i'dtGv62Cc. Phone: 336-776-9800 Secondary Inspector(s): Caitlin Caudle Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Wastewater Irrigation Facility Status: ❑ Compliant Not Compliant Question Areas: Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions Treatment Flow Measurement -Water Treatment Treatment Barscreen Use Records Record Keeping Treatment Lagoons Treatment Activated Sludge Treatment Sludge Storage/Treatment End Use -Irrigation Treatment Influent Pump Station Treatment Clarifiers Treatment Disinfection Treatment Flow Measurement Treatment Return pumps Storage Standby Power Wells (See attachment summary) Page 1 of 7 Permit: WQ0029346 Owner -Facility: Blue Ridge Mountain Club Property Owners Association Inc Inspection Date: 02/20/2024 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On February 20, 2024, Division of Water Resources staff Kristen Potwora and Caitlin Williams conducted a scheduled routine compliance inspection of the Blue Ridge Mountain Club Wastewater Treatment Plant (WWTP) and the collection system. Travis Thomas (Lead Operator), R. Neil Reece (Area Manager) and Patrick Warren (VP of Development) were present for the inspection of the WWTP. Mr. Thomas and Mr. Warren were present for the inspection of the collection system. A review of the treatment system, storage facility, irrigation system, available records, and two lift stations was completed. This review reflected non-compliance with the subject permit. The following deficiencies were noted: 1. A soil report could not be located for the 2023 calendar year. Per Condition IV.14 of the permit, "an annual representative soils analysis shall be conducted on each irrigation site listed in Attachment B." Please be reminded that you must collect a soil sample each calendar year. 2. Irrigation Pump A has been broken since fall of 2023, and the gasket around the irrigation flowmeter was leaking. Per Condition V.1, "the permittee shall perform inspections and maintenance to ensure proper operation of the wastewater treatment and irrigation facilities." The leaking gasket was also noted in correspondence dated June 20, 2023 . DWR staff was informed during the inspection that the gasket should be replaced within the next 60 days. However there has been no communication on when Pump Awill be fixed. The following item of concern was noted: • An updated Operation and Maintenance Plan and Spill Response Plan was not available on site during the inspection However, an updated version was sent electronically to DWR staff on March 6, 2024. Moving forward, ensure a hard copy is on site per Permit Condition 111.2. Other Observations: • Carolina Water Service of North Carolina took over the operation of the WWTP in August 2023. • The treatment facility currently has close to 300 connections . New connections will occur soon as 6 new homes are being built as well as new townhomes that were just completed. • Starting March 11th, they will begin the work necessary to install the two new drip zones. • An updated Spill Plan and Operation and Maintenance Plan were sent to DWR on 3/6/24. • Holes in the lagoon liner were fixed (this was noted as a deficiency during last inspection). • According to documentation, the flowmeter was calibrated on 5/26/2023. • Irrigation did not occur during the time of the inspection due to low water levels in the lagoon. • Anoxic pump was fixed (this was noted as a deficiency during last inspection). • Floats and High-water alarms were untangled during the inspection. They are considering moving the float tree to ensure that there are no further entanglements. • Staff gauge was clearly marked. • The Clarifier was in operation, however it was still very cloudy. • Irrigation equipment hasn't been calibrated this permit cycle yet. • There is a V-notch weir in the chlorine contact chamber. • Lift Station 45 — pumps and alarms were operational and sent out text alerts. • Lift Station 64 - pumps and alarms were operational and sent out text alerts. Page 2 of 7 Permit: WQ0029346 Inspection Date: 02/20/2024 Owner - Facility: Blue Ridge Mountain Club Property Owners Association Inc Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Reuse (Quality) ❑ Lagoon Spray, LR ❑ Infiltration System ❑ Single Family Spray, LR ❑ Activated Sludge Spray, HR ❑ Activated Sludge Drip, LR ❑ Recycle/Reuse ❑ Single Family Drip ❑ Activated Sludge Spray, LR Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ ❑ ❑ Do all treatment units appear to be operational? (if no, note below.) 0 ❑ ❑ ❑ Comment: Treatment Influent Pump Station Yes No NA NE Is the pump station free of bypass lines or structures? ❑ ❑ ❑ Is the general housekeeping acceptable? ❑ ❑ ❑ Are all pumps present? ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are floats/controls operable? ❑ ❑ ❑ Are audio and visual alarms available? ❑ ❑ ❑ Are audio and visual alarms operational? ❑ ❑ ❑ # Are SCADA/Telemetry alarms required? ❑ ❑ ❑ Are SCADA/Telemetry available? ❑ ❑ ❑ Are SCADA/Telemetry operational? ❑ ❑ ❑ Comment Treatment Flow Measurement -Influent Yes No NA NE Is flowmeter calibrated annually? ❑ ❑ ❑ Is flowmeter operating properly? ❑ ❑ ❑ Does flowmeter monitor continuously? ❑ ❑ ❑ Does flowmeter record flow? ❑ ❑ ❑ Does flowmeter appear to monitor accurately? ❑ ❑ ❑ Comment Treatment Flow Measurement -Water Use Records Yes No NA NE Page 3 of 7 Permit: WQ0029346 Owner - Facility: Blue Ridge Mountain Club Property Owners Association Inc Inspection Date: 02/20/2024 Inspection Type : Compliance Evaluation Reason for Visit: Routine Is water use metered? ❑ 1:10 ❑ Are the daily average values properly calculated? ❑ ❑ 0 ❑ Comment: Treatment Flow Measurement -Effluent Yes No NA NE Is flowmeter calibrated annually? ❑ ❑ ❑ Is flowmeter operating properly? ❑ ❑ ❑ Does flowmeter monitor continuously? ❑ ❑ ❑ Does flowmeter record flow? ❑ ❑ ❑ Does flowmeter appear to monitor accurately? ❑ ❑ ❑ Comment Standby Power Yes No NA NE Is automatically activated standby power available? ❑ ❑ ❑ Is generator tested weekly by interrupting primary power source? ❑ ❑ ❑ Is generator operable? ❑ ❑ ❑ Does generator have adequate fuel? 0 ❑ ❑ ❑ Comment: Treatment Barscreen Yes No NA NE Is it free of excessive debris? ❑ ❑ ❑ Is disposal of screenings in compliance? ❑ ❑ ❑ Are the bars spaced properly? ❑ ❑ ❑ Is the unit in good condition? ❑ ❑ ❑ Comment Treatment Activated Sludge Yes No NA NE Is the aeration mechanism operable? ❑ ❑ ❑ Is the aeration basin thoroughly mixed? ❑ ❑ ❑ Is the aeration equipment easily accessed? ❑ ❑ ❑ Is Dissolved Oxygen adequate? ❑ ❑ ❑ Are Settleometer results acceptable? ❑ ❑ ❑ Is activated sludge an acceptable color? ❑ ❑ ❑ Comment Treatment Clarifiers Yes No NA NE Are the weirs level? ❑ ❑ ❑ Are the weirs free of solids and algae? ❑ ❑ ❑ Is the scum removal system operational? ❑ ❑ ❑ Is the scum removal system accessible? ❑ ❑ ❑ Page 4 of 7 Permit: WO0029346 Owner -Facility: Blue Ridge Mountain Club Property Owners Association Inc Inspection Date: 02/20/2024 Inspection Type : Compliance Evaluation Reason for Visit: Routine Is the sludge blanket at an acceptable level? 0 ❑ ❑ ❑ Is the effluent from the clarifier free of excessive solids? 0 ❑ ❑ ❑ Comment: Treatment Return pumps Yes No NA NE Are they in place? 1111011 Are they operational? 1111011 Comment: Treatment Sludge Storage/Treatment Yes No NA NE Is the aeration operational? ❑ ❑ ❑ Is the aeration pattern even? ❑ ❑ ❑ If required, are Sanitary "Ts" present in tankage? ❑ ❑ ❑ Comment: Treatment Disinfection Yes No NA NE 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? ❑ ❑ ❑ 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 Yes No NA NE Is a copy of current permit available? ❑ ❑ ❑ Are monitoring reports present: NDMR? ❑ ❑ ❑ NDAR? ❑ ❑ ❑ Page 5 of 7 Permit: WQ0029346 Owner - Facility: Blue Ridge Mountain Club Property Owners Association Inc Inspection Date: 02/20/2024 Inspection Type : Compliance Evaluation Reason for Visit: Routine Are flow rates less than of permitted flow? 0 ❑ ❑ ❑ Are flow rates less than of permitted flow? 0 ❑ ❑ ❑ Are application rates adhered to? 0 ❑ ❑ ❑ 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? ❑ ❑ 0 ❑ Do effluent concentrations exceed GW standards? ❑ ❑ 0 ❑ Are annual soil reports available? ❑ 0 ❑ ❑ # Are PAN records required? ❑ ❑ ❑ # Did last soil report indicate a need for lime? ❑ ❑ ❑ If so, has it been applied? ❑ ❑ ❑ Are operational logs present? 0 ❑ ❑ ❑ Are lab sheets available for review? 0 ❑ ❑ ❑ Do lab sheets support data reported on NDMR? 0 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Is a copy of the SOC readily available? ❑ ❑ 0 ❑ No treatment units bypassed since last inspection? 0 ❑ ❑ ❑ Comment: Soil Analysis hasn't been completed since 12/16/2022. The O&M and Spill Plan were not onsite and not updated. End Use -Irrigation Yes No NA NE 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? ❑ ❑ ❑ Page 6 of 7 Permit: WO0029346 Owner -Facility: Blue Ridge Mountain Club Property Owners Association Inc Inspection Date: 02/20/2024 Inspection Type : Compliance Evaluation Reason for Visit: Routine Are any supply wells within 250' of the CB? 0 ❑ ❑ ❑ How close is the closest water supply well? ❑ ❑ 0 ❑ Is municipal water available in the area? ❑ ❑ 0 ❑ # Info only: Does the permit call for monitoring wells? 0 ❑ ❑ ❑ Are GW monitoring wells located properly w/ respect to RB and CB? 0 ❑ ❑ ❑ Are GW monitoring wells properly constructed, including screened interval? 0 ❑ ❑ ❑ Are monitoring wells damaged? 0 ❑ ❑ ❑ Comment: Irrigation Pump A has been broken since fall of 2023 and the gasket has been leaking/ not workinq properly since at least 6/2023. 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