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Home My WebLink AboutNC0032131_Compliance Evaluation Inspection_20191029ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director n� NORTH CAROLINA Envi--tal Quality CERTIFIED MAIL # 7011-1570-8546-4839 RETURN RECEIPT REQUESTED July 10, 2019 Chris B. Robbins Tweetsie Railroad 300 Tweetsie Railroad Ln Blowing Rock, NC 28605 SUBJECT: Compliance Evaluation Inspection- Notice of Violation NOV-2019-PC-0506 Tweetsie Railroad WWTP NPDES Permit No. NCO032131 Watauga County Dear Mr. Robbins, On July 2, 2019, Kelli Park, Paul DiMatteo, and Mike Turner of this office, met with Dale Holman, ORC, and Darrell Young, backup ORC, to perform a Compliance Evaluation Inspection at the Tweetsie Railroad wastewater 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 observed from the inspection are described below. 1) The effluent sampler is currently set up to be a time proportional sample. According to the permit, composite samples must be flow proportional. Please get this fixed immediately. If flow proportional sampling is not feasible, a letter must be written to the Division explaining why and requesting exemption. 2) Your permit states that flow must be continuously recorded, however the plant does not have a chart recorder. Please install an instrument to continuously record the flow as soon as possible. 3) According to the permit the effluent pipe must be visible and a path to the pipe must be maintained. There was no path to the outfall, and the pipe was not easily located. Please maintain a path to the effluent pipe. Tweetsie Railroad WWTP CEI / NOV 7/2/19 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(a)_ncdenr.gov or Ion. snider(a)_ncdenr.gov. Sincerely, Docu Signed by: LJn. � JMdtt 1-.49E225C94EA... 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 1 2 15 I 3 I NCO032131 111 12 I 19/07/02 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 174 751 I I I I I I I80 u ty 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) 11:00AM 19/07/02 16/09/01 Tweetsie Railroad US Hwy 321 221s Boone Exit Time/Date Permit Expiration Date Blowing Rock NC 28605 12:30PM 19/07/02 21/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Danny D Holman/ORC/828-964-2239/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Chris B Robbins,300 Tweetsie Railroad Ln Blowing Rock INC 28605Np/828-264-9061/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance 0 Records/Reports Self -Monitoring Program 0 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 Kelli A Park WSRO WQ//336-776-9689/ Paul DiMatteo WSRO WQ//336-776-9691/ Signature of Management Q A Review cusigned by: Agency/Office/Phone and Fax Numbers Date -T Sti'der 7/11/2019 [�- .49E225C94EA... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO032131 I11 121 19/07/02 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On July 2, 2019, Kelli Park, Paul DiMatteo, and Mike Turner of this office, met with Dale Holman, ORC, and Darrell Young, backup ORC, to perform a Compliance Evaluation Inspection at the Tweetsie Railroad wastewater 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 observed from the inspection are described below. 1) The effluent sampler is currently set up to be a time proportional sample. According to the permit, composite samples must be flow proportional. Please get this fixed immediately. If flow proportional sampling is not feasible, a letter must be written to the Division explaining why and requesting exemption. 2) Your permit states that flow must be continuously recorded, however the plant does not have a chart recorder. Please install an instrument to continuously record the flow as soon as possible. 3) According to the permit the effluent pipe must be visible and a path to the pipe must be maintained. There was no path to the outfall, and the pipe was not easily located. Please maintain a path to the effluent pipe. 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: NCO032131 Owner - Facility: Tweetsie Railroad Inspection Date: 07/02/2019 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: A copy of the permit was available on site. 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: 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 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? ❑ ❑ ❑ Page# 3 Permit: NCO032131 Owner - Facility: Tweetsie Railroad Inspection Date: 07/02/2019 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Material is removed, dried, and disposed of in a landfill. Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? 0 ❑ ❑ ❑ # Is basin size/volume adequate? M ❑ ❑ ❑ Comment: 2 pumps, alarms were tested during the inspection. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Page# 4 Permit: NCO032131 Owner - Facility: Tweetsie Railroad Inspection Date: 07/02/2019 Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ 0 ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ 0 ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? M ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) 0 ❑ ❑ ❑ Comment: There was some algae build up in the weirs. It would be benefitial if it was cleaned more often. The sludge blanket was reported to be around 3ft. Filtration (High Rate Tertiary) Yes No NA NE Type of operation: Down flow Is the filter media present? ❑ ❑ ❑ Is the filter surface free of clogging? ❑ ❑ ❑ Is the filter free of growth? ❑ ❑ ❑ Is the air scour operational? ❑ ❑ ❑ Is the scouring acceptable? ❑ ❑ ❑ Is the clear well free of excessive solids and filter media? ❑ ❑ ❑ Comment: Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? 0 ❑ ❑ ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Number of tubes in use? 3 Page# 5 Permit: NCO032131 Inspection Date: 07/02/2019 Owner - Facility: Tweetsie Railroad Inspection Type: Compliance Evaluation Disinfection -Tablet Yes No NA NE Is the level of chlorine residual acceptable? ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ Comment: Tablets are checked daily and added as needed. De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? 0 ❑ ❑ ❑ Is storage appropriate for cylinders? 0 ❑ ❑ ❑ # Is de -chlorination substance stored away from chlorine containers? 0 ❑ ❑ ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Comment: Checked daily and added as needed. Are tablet de -chlorinators operational? 0 ❑ ❑ ❑ Number of tubes in use? 4 Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? M ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ M ❑ ❑ Comment: There is no chart reader or technology installed to record continuous flow. According to the permit this plant should have continuous recording. The Isco 3010 meter was last calibrated on 3/28/2019. 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)? Yes No NA NE ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ Page# 6 Permit: NCO032131 Inspection Date: 07/02/2019 Effluent Sampling Comment: Currently 200mL are pulled every 30 minutes. Owner - Facility: Tweetsie Railroad Inspection Type: Compliance Evaluation Yes No NA NE COmDOSIte samples must be taken flow DrODortionally unless permission for time based sampling is granted by the Division. Please either begin sampling based off flow or send us a letter explaining why you must sample via a time base. 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: The effluent pipe was not clearly visable. There must be a area around it must be clear. Pump Station - Influent Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Is audible and visual alarm available and operational? Comment: 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? h to the effluent Dipe. and the Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 7