NC0050610_Compliance Evaluation Inspection_20180723

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Water Resources
Permitting Section
CERTIFIED MAIL 7013-1710-0002-1922-2484
RETURN RECEIPT REQUESTED
July 23, 2018
Mr. Jadd Brewer
Water Quality Utilities, Inc.
P.O. Box 384
Banner Elk, NC 28605-0384
SUBJECT: Compliance Evaluation Inspection and Notice of Violation
NOV Tracking Number: NOV-2018-PC-0231
The Ponds WWTP
NPDES Permit No. NC0050610
Watauga County
Dear Mr. Brewer:
On June 27, 2018, Kelli Park and Gary Hudson, of this office, met with Brandon
Hughes, ORC, to perform a Compliance Evaluation Inspection on The Ponds wastewater
treatment system. This type of inspection consists of two basic parts: an in-office file
review and an on-site inspection of the treatment facility. The attached EPA inspection
form notes the areas that were evaluated for this inspection. The findings and
observations are outlined below:
I. Permit
The NPDES permit became effective December 1, 2017 and expires September 30,
2022. The facility had a copy of the current permit available during the inspection.
II. Self-Monitoring Program
A review of the monthly discharge monitoring reports (DMR) for the period January 2017
through November 2017 showed that the facility was in compliance with all permit limits
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beNiene
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27105
336 776 9800

The Ponds WWTP,NPDES Permit No.NC0050610 1,a
Compliance Evaluation Inspection July 11,2018
with the exception of one daily maximum Fecal Coliform violation on May 18, 2017 of
2,900 colonies per 100 milliliters, (#/100m1). Regarding the permit monitoring
requirements, it was noted that all sampling was performed per the frequencies specified
in the permit. Brandon Hughes does all sampling for the facility, and the laboratory
analysis is performed by Water Quality Utilities, Inc
III. Flow Measurement
The flow meter was calibrated in July of 2017. It needs to be calibrated before August 1,
2018. Please send Miss Park a copy of the meter's calibration certification immediately
upon completion
IV. Operations and Maintenance
The wastewater treatment plant appeared clean, however the walkways were rusted and
weak. Holes in the metal and rotted plywood were noted during the visit. Replacement or
reinforcement should be completed for safety purposes.
V. Facility Site Review
Most of the components of the 0.076 million gallons per day facility appeared to be
functioning properly. The aeration basin had a light brown color and a good earthy odor.
Although the dissolved oxygen (DO) wasn't measured during the inspection, Mr. Hughes
indicated the aeration basin (AB) normally runs at about 0.8 milligrams per liter (mg/I).
Please note a preferable range for DO in the AB is 1.0-3.0 mg/I. The effluent from the
treatment plant was clearly turbid and discharging solids into the stream. At the time of
the inspection the wastewater treatment plant appeared to have an overaccumulation of
solids, possibly due to the lack of proper solids management and not enough being
removed from the plant. Our office highly recommends pumping the digester more
frequently. The sludge blanket in the secondary clarifier (SC) was about half of the
sidewall depth. The acceptable level is approximately a quarter of the sidewall depth.
Solids were floating on the surface of the SC as well, leading to their discharge into the
stream. The ultra violet light (UV) intensity meter reading was flashing, suggesting that
the unit needs to be assessed for proper function. This could also be due to floating solids
in the effluent disrupting the reading.
VI. Records/Reports
The visitation log is on site showing visitation times and plant conditions. Chain of custody
forms and calibration records are in good order. All the required monitoring was
performed per the frequencies specified in the NPDES permit. When checking the DMRs
and bench sheets, Ms. Park found that three ammonia results were not properly
transcribed to the DMRs. These values are listed in the table below. While these numbers
are still in compliance, diligence should be used when reporting analyzed values.

The Ponds WWTP,NPDES Permit No.NC0050610
Compliance Evaluation Inspection July 11,2018
Date Bench Sheet (mg/I) Reported (mg/I)
August 17, 2017 1.16 1.12
August 24, 2017 4.99 2.43
August 29, 2017 9.13 4.13
VII. EffluentlReceivinq Waters
The effluent from the facility was not clear the day of the inspection. Turbid effluent and
solids were being discharged into the Watauga River, class B; trout; high quality waters
in the Watauga river basin.
Please work to correct the deficiencies in paragraphs 4 through 7. Overall, the plant must
be better maintained and more should be invested in the plant's proper upkeep.
Please reply in writing to this letter within 30 business days of receiving it. Your written
reply should address each of the noted deficiencies and provide a corrective action plan
along with an implementation/completion schedule to remediate them.
Please be aware that violations of your NPDES permit, or the NC statutes and regulations
under which it is promulgated, are subject to fines of up to$25,000 per day, per violation,
as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil
Penalties. If we do NOT receive your written reply within 30 business days of your receipt
of this notice, we may draft an enforcement case for the noted deficiencies/violations.
If you have any questions regarding the inspection or this report, please contact Kelli Park
or me at [phone].
Sincerely,
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: BIMS EPA Water Compliance Inspection Report
cc: Central Files
WSRO
NPDES Unit