NC0046043_NOV2015PC0139_20150615

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NCDETIR
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R. van der Vaart
Governor Secretary
June 2, 2015
CERTIFIED MAIL
RETURN RECEIPT REQUESTED RECEIVED/DENR/DWR
7009.2250.0004.1083-6111 JUN 0 4 2015
Pruitthealth—Highpoint LLC Water Quality
Attn: Neil L. Pruitt, Jr., Owner Permittinq Sectior
1626 Jeurgens Court
Norcross, GA 30093
Subject: Compliance Sampling Inspection 8r Notice of Violation/Recommendation for
Enforcement,Case#NOV-2015-PC-0139
Permit No. NCO046035
UPAC High Point Wastewater Treatment Plant
Forsyth County
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Dear Mr. Pruitt:
Corey Basinger and Ron Boone, of the Winston-Salem Regional Office (WSRO)of the NC Division
of Water Resources (DWR), performed a compliance sampling inspection (CSI) of the UPAC High Point
Wastewater Treatment Plant on May 13th, 2015. This inspection was prompted by a call we received on
May 12th, 2015 from the City of High Point. A stormwater pipe that they were working on was conveying
water that was very heavily-laden with solids and they thought the water was coming from the UPAC plant.
Mr. Boone actually responded to the phone call on May 12#1 to verify the condition of the water
flowing through the stormwater pipe and determine for certain where it was coming from. At that time Mr.
Boone determined through field investigation that the water was coming from the UPAC plant, as he also
knew from previous knowledge that the UPAC plant discharges into the pipe in question. An examination of
the effluent from the plant revealed that the water being discharged was heavily laden with sewage solids.
A subsequent examination of the stream at the discharge point also revealed sludge and/or sewage solids
had accumulated at the discharge point and that sludge worms had formed. Mr. Boone then took samples
of the plant effluent which were taken to Research and Analytical (R&A) Laboratories, in Kemersville, NC,
for analysis and determination of Fecal Coliform, biochemical oxygen demand (BOD), total suspended
solids (TSS), and Ammonia-Nitrogen concentrations.
North Carolina Division of Water Resources,Winston-Salem Regional Office
Location:450 West Hanes Mill Road,Suite#300,Winston-Salem,North Carolina 27105
Phone:[phone] l FAX:[phone] Customer Service;1.877-623-6748
Internet:www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer

Mr. Basinger and Mr. Boone then visited the plant again on May 13th and performed the CSI. The
Fecal Coliform samples from May 13th were also taken to R&A Labs in order to meet sample holding times. A
The remainder of the samples for BOD, TSS, and Ammonia-Nitrogen, were sent to DWR's lab in Raleigh,
NC. The stream was in the same condition it was the previous day with a considerable amount of sewage
solids/sludge and sludge worms. The following table lists the results of the analyses of all samples taken
compared against effluent limitations contained in NPDES Permit NCO046035:
Permit Sample Dates and Locations
Parameters Daily 05/12/2015 05113/2015
Maximum Effluent Effluent Upstream Downstream
Limit
Fecal Coliform 4001100 ml >12,000/100 ml 8,000/100 ml 1281100 ml 9401100 ml
Biochemical
Oxygen 45.0 mg/I 496 mg/I 13,000 mg/I - -
Demand
Total
Suspended 45.0 mg/I 2,180 mg/i 870 mg/I - -
Solids
Ammonia- N/A 19.7 mg/I 17 -Nitrogen
The following photos of the discharge point(#1) and the stream (#2) were taken on May 13th:
#I -This is a photo of the
discharge point into Rich Fork,
a Class C stream in the Yadkin
t. Pee Dee river basin.The dark
-oar red spots are the sludge worms.
._y You cannot see the sludge in
this photo due to the lighting,
but you can see it in the next
photo.
sl
Approximate coordinates of
discharge point are:36.014612,
-80.050641
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This is it photo ofthe stream approximately 12� feet do,,Fn treant of the discharge point. The
brownish substance blanketine the bottom of the creek is the sludge. Approximate coordinates
of this point are: 36.0 14236, -80.OW90
In addition to the violations of NPDES Permit NC0046035, the above outlined conditions also
constitute the following violations of State law:
(1) 15A NCAC 028.0211(1) Best Usage of Waters: aquatic life propagation and maintenance of
biological integrity (including fishing and fish), wildlife, secondary recreation, agriculture, and
any other usage except for primary recreation or as a source of water supply for drinking,
culinary, or food processing purposes;
(2) 15A NCAC 026.0211(2) Conditions Related to Best Usage: the waters shall be suitable for
aquatic life propagation and maintenance of biological integrity, wildlife, secondary recreation,
and agriculture. Sources of water pollution that preclude any of these uses on either a
short-term or long-term basis shall be considered to be violating a water quality standard;
(3) 15A NCAC 026.0211(8) Floating solids, settleable solids, or sludge deposits: only such
amounts attributable to sewage, industrial wastes, or other wastes as shall not make the water
unsafe or unsuitable for aquatic life and wildlife or impair the waters for any designated uses;
This Notice of Violation/Notice of Recommendation for Enforcement(NOWNRE) is being issued for
the noted violation(s) of North Carolina General Statute (G.S.) 143-215.1, NC regulations, and NPDES
Permit NC0046025. Pursuant to G.S. 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 issued pursuant to G.S. 143-215.1. If you wish to
provide additional information regarding the noted violation(s), request technical assistance, or discuss
overall compliance, please respond in writing within ten (10)days after receipt of this Notice.A review
of your response will be considered and you will then be notified of any civil penalties that may be assessed
regarding the violation(s). If no response is received in this office within the 10-day period, a civil
penalty assessment may be prepared.
Remedial actions, if not already implemented, should be taken to correct any problems. The
Division of Water Resources may pursue enforcement actions for this and any additional violation(s). If the

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violation(s) are of a continuing nature, not related to operation'andlor maintenanceproblems, or you
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anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
c. Consent.
If you have questions concerning this matter, please do not hesitate to contact Ron Boone or me at
[phone].
a
Sincerely,
W. Corey Basinger
Regional Supervisor '
Water Quality Regional Operations
Division of Water Resources
Attachments:
1. BIMS Inspection Report
y
cc: Point Source Branch
SWP—Central Files
WSRO Files
Bell Enterprises
Attn: Randy Bell
P.O. Box 1291 {
Clemmons, NC 27012
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V 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 u 2 15 1 3 I NCO046035 111 12 15/05/13 17 18 L S J 19 G 201 I �6
r. ,. 21 _J1 1 1 1 1 I I I I I 1 1 1 1 I I I I I I l I I I I l I I I I I I I I 6
t` Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -------Reserved--- ---
67 70 U 71 Lj 72 I N I 73 IL I I 174 751 III I I I I80
Section B:Facility Data I
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
t POTW name and NPDES oermit Number) 10 15A 15/05/13 14/08/01
UPAC High Point
Exit Time/Date Permit Expiration Date
r- 3830 N Main St
High Point NC 27265 11:15AM 15/05/13 19/04/30
Name(s)of Onsite R epresentative(s)/TiUes(s)/P hone and Fax Number(s) Other Facility Data
Randall Keith Bell/ORC/336-373-7514/
Name,Address of Responsible OfficiaUTitle/Phone and Fax Number
-� Contacted
Kim Lapointe,3830 N Main St High Point NC 27265/1336-869-3524/
No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
Operations&Maintenance N Sludge Handling Disposal E Facility Site Review � Effluent/Receiving Waters
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
William C Basinger WSRO WQ//336-776-9688/
Ron Boone WSRO WQ/1336-776-96901
Signature of Management Q A Reviewer Agency/OfficelPhone and Fax Numbers Date
Alt, 24 4ore ZA(3—
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
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NPDES yr/mo/day Inspection Type
31 NC0046035 I11 12I/ 15/05/13 117 18 '$
F Section D:Summary of Finding/Comments(Attach additional llss Iheets of narrative and checklists as necessary)
Please refer to the attached letter and enforcement case.
Samples taken (Note:All samples are effluent unless otherwise noted):
v
5112115 5113/15 '
Fecal Effluent >12,000 per 100 ml 8,000 per 100 ml
Fecal Upstream - 128 per 100 ml
Fecal Downstream - 940 per 100 ml -
BOD 496 mg/I 13,000 mg/l
TSS 2,180 mg/l 870 mg/I
Ammonia Nitrogen 19.7 mg/l 17 mg/l
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