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Home My WebLink AboutNC0088099_Compliance Evaluation Inspection_20190717ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director �ry 44, NORTH CAROLINA EnNlmnmrrtlnl Quality CERTIFIED MAIL # 7017-1450-0001-6450-4427 RETURN RECEIPT REQUESTED July 17, 2019 Mr. Robert Heaton Director of Infrastructure Town of Beech Mountain 403 Beech Mountain Parkway Beech Mountain, NC 28604 SUBJECT: Compliance Evaluation Inspection- Notice of Violation NOV-2019-PC-0517 Buckeye Lake WTP NPDES Permit No. NCO088099 Watauga County Dear Mr. Heaton, On July 10, 2019, Kelli Park, of this office, met with Ronnie McKinney, operator in responsible charge (ORC), to perform a Compliance Evaluation Inspection at the Buckeye Lake water treatment plant. 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 details the areas that were evaluated during this inspection. Violations and observations from the inspection are described below. 1) The permit requires continuous flow recording. It has been reported, however, that the meter gets clogged and will not record flow for periods of time. Please get this fixed immediately. 2) The flow meter has not been calibrated in the past year. The permit requires that flow meters be calibrated at least on an annual basis. Please get this done immediately. 3) The facility did not have sludge hauling records available for review during the inspection. These records should be maintained at the facility and record how much is pumped. 4) The lab at the water plant had expired pH standards. Please get updated standards immediately. Buckeye Lake WTP CEI / NOV 7/10/19 These issues described above represent violations of the NPDES permit. Therefore, this inspection report is being sent as a Notice of Violation. Please reply in writing to this Notice of Violation within 10 business days of receiving it. Your written reply should address each of the noted violations 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 (336) 776-9800 or by email at kelli.parkC@,ncdenr.gov or lon.snider(q-).ncdenr.gov. Sincerely, Docu SiTgnedl�by: •��. l 945B49E225C94EA... Lon Snider Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report cc: WSRO Page 2 of 2 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 I 2 IF I 3 I NC0088099 111 12 I 19/07/10 I17 18 I S J 19 L G] 201 I 211111 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 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 671 70 I I 71 I I 72 I r I 73 I I 74 75I I I I I I I I80 u I� I I 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 oermit Number) 02:OOPM 19/07/10 18/01/01 Buckeye Lake WTP 208 Grassy Gap Creek Rd Exit Time/Date Permit Expiration Date Beech Mountain NC 28604 03:OOPM 19/07/10 22/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Ronnie Dale McKinney/ORC/828-387-9368/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Mitchell Heaton,PO Box 342 Roan Mountain TN 37687//704-387-4724/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 Facility Site Review Effluent/Receiving Waters 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 Kelli A Park WSRO WQ//336-776-9689/ Signature of Management Q A Review Docusiyned ay: Agency/Office/Phone and Fax Numbers Date �" ? S" je, 7/17/2019 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO088099 I11 121 19/07/10 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On July 10, 2019, Kelli Park, of this office, met with Ronnie McKinney, operator in responsible charge (ORC), to perform a Compliance Evaluation Inspection at the Buckeye Lake water treatment plant. 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 details the areas that were evaluated during this inspection. Violations and observations from the inspection are described below. 1) The permit requires continuous flow recording. It has been reported, however, that the meter gets clogged and will not record flow for periods of time. Please get this fixed immediately. 2) The flow meter has not been calibrated in the past year. The permit requires that flow meters be calibrated at least on an annual basis. Please get this done immediately. 3) The facility did not have sludge hauling records available for review during the inspection. These records should be maintained at the facility and record how much is pumped. 4) The lab at the water plant had expired pH standards. Please get updated standards immediately. These issues described above represent violations of the NPDES permit. Therefore, this inspection report is being sent as a Notice of Violation. Please reply in writing to this Notice of Violation within 10 business days of receiving it. Your written reply should address each of the noted violations 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 (336) 776-9800 or by email at kelli.park@ncdenr.gov or lon.snider@ncdenr.gov. Page# Permit: NCO088099 Owner - Facility: Buckeye Lake WTP Inspection Date: 07/10/2019 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 ❑ ❑ 0 ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ❑ 0 ❑ ❑ Is all required information readily available, complete and current? 0 ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? 0 ❑ ❑ ❑ Is the chain -of -custody complete? 0 ❑ ❑ ❑ 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 CM 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? ❑ ❑ 0 ❑ Comment: No records are being kept of how much sludge is pumped from the lagoons. Please start maintaining records of how much sludge is pumped, who pumps it, and when it is pumped. Water Tech Labs is used. Page# 3 Permit: NCO088099 Inspection Date: 07/10/2019 Owner - Facility: Buckeye Lake WTP Inspection Type: Compliance Evaluation Operations & Maintenance 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: Disinfection -Gas Are cylinders secured adequately? Are cylinders protected from direct sunlight? Is there adequate reserve supply of disinfectant? 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? 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? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: about 5 Ibs are used each day. The chlorine evaporates out of the water while being held in the lagoons. Chlorine tablets are available for backup if needed. Lagoons Yes No NA NE Type of lagoons? Facultative # Number of lagoons in operation at time of visit? 2 Are lagoons operated in? Parallel # Is a re -circulation line present? ❑ 0 ❑ ❑ Is lagoon free of excessive floating materials? 0 ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ 0 ❑ ❑ Are dike slopes clear of woody vegetation? 0 ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? 0 ❑ ❑ ❑ Are dikes free of seepage? 0 ❑ ❑ ❑ Are dikes free of erosion? 0 ❑ ❑ ❑ Are dikes free of burrowing animals? 0 ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple 0 ❑ ❑ ❑ locations? Page# 4 Permit: NCO088099 Inspection Date: 07/10/2019 Owner - Facility: Buckeye Lake WTP Inspection Type: Compliance Evaluation Lagoons Yes No NA NE # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑ Is the lagoon surface free of weeds? 0 ❑ ❑ ❑ Is the lagoon free of short circuiting? 0 ❑ ❑ ❑ Comment: Sludge from lagoons is pumped out and taken to the Pond Creek WWTP drying beds. The sludge blanket is around 1 ft in the left (looking up from the flow meter) lagoon and 4 ft in the right lagoon (it is being pumped soon). Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: 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: grab samples 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? Yes No NA NE ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ rims ►Sz0E-IMzIM ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ Comment: It is a permit requirement to have continuous recoridnq of flow. The current flow meter is alitchv and does not constantly record flow. This needs to be fixed as soon as oossible. The flow meter has not been calibrated in the past year. Flow meters must be calibrated annually. Please get this done immediately. SCADA records the flow. Page# 5 Permit: NCO088099 Owner - Facility: Buckeye Lake WTP Inspection Date: 07/10/2019 Inspection Type: Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑ sampling location)? Comment: Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑ Is the generator tested under load? 0 ❑ ❑ ❑ Was generator tested & operational during the inspection? 0 ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? 0 ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up power? 0 ❑ ❑ ❑ Is the generator fuel level monitored? 0 ❑ ❑ ❑ Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? M ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ ❑ ❑ 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: pH standards were expired in the lab at the WTP. Please get up to date standards. Use Gary Tipton's (ORC of Grassy Gap and Pond Creek) certification number 5120. Grassy Gap is right next to Buckeye Lake WTP. They are not paying Gary in order to use his number. Page# 6