NC0025526_Compliance Evaluation Inspection_20200302

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
March 2, 2020
CERTIFIED MAIL NUMBER 7017 1450 0001 6450 1013
RETURN RECEIPT REQUESTED
Mr. Bobby Miller, Town Manager
Town of Walnut Cove
P.O. Box 130
Walnut Cove, NC 27052
Subject: Notice of Violation — (NOV-2020-PC-0000)
Compliance Evaluation Inspection
Town of Walnut Cove WWTP
NPDES Permit #NC0025526
Stokes County
Dear Mr. Miller:
On February 26, 2020 North Carolina Division of Water Resources (DWR) staff person Justin
Henderson performed a Compliance Evaluation Inspection of the subject facility. Mr. Mark
Bowman, ORC was present during this inspection. This type of inspection consists of two basic
parts: an in -office review of the facility files and self -monitoring data and an on -site inspection of
the facility. This inspection reflects non-compliance with Permit No. NC0025526. The following
violations require your attention and action:
1) Failure to conduct flow proportional composite sampling (both influent and effluent) in
accordance with Permit Condition Part II. Composite Sampling_ Mr. Bowman, ORC
indicated that composite samples currently were being collected via the constant
time/constant volume method however, use of this method requires prior approval by the
Director, and may only be used in situations where effluent flow rates vary less than 15
percent.
2) Failure to ensure the composite sample is maintained at or below six (6) degrees Celsius
during the entire compositing period per CFR part 136.3 Table II. There were no
thermometers present in either the effluent or influent composite samplers nor were any
records available to demonstrate the sample compartment cooling was maintained in
accordance with CFR part 136.3.
D � North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
NOh �HCARO UHA
^^ •^^ma^� u�•i` r 336.776.9800

This is a repeat violation that was previously documented in a Notice of Deficiency,
dated August 1, 2018 issued by this Office.
3) Failure to designate a Back-up ORC within 120 days of a vacancy in the position in
accordance with Permit Condition Part II. Section C. (1.) (b.) & (c.) and 15A NCAC
08G .0201.
4) Failure to document or maintain an ORC log of the operation, maintenance, and all
visitation of the system in accordance with Permit Condition Part II. Section C. (1.) and
15A NCAC 08G .0204 (5). Officially designated operators are responsible for all proper
operation and maintenance of the facility, and all documentation required thereof.
5) Failure to conduct and/or maintain documented logs for the per event/analysis calibrations,
on the meters utilized to analyze Total Residual Chlorine (TRC) and Dissolved Oxygen
(DO) in accordance with Permit Condition Part II. Section C (2.) and the North Carolina
Wastewater/Groundwater Laboratory Certification Approved Procedures.
6) Failure to provide and Annual Performance Report to the Division and to the
users/customers served by the Permittee in accordance with Permit Condition Part II.
Section E. (12.) and NC G.S. 143-215.1C. This report shall summarize the performance of
the treatment system, as well as the extent to which the facility was compliant with
applicable Federal or State laws, regulations, and rules pertaining to water quality. The
report shall be provided no later than sixty (60) days after the end of the calendar year.
This is a repeat violation that was previously documented in a Notice of Deficiency, dated
August 1, 2018, issued by this Office.
Along with the above described violations the following item of concern warrants your attention:
a) The dikes/dams surrounding the facultative lagoons were overgrown with woody
vegetation. Proper maintenance for earthen embankments includes the removal and
prevention of woody vegetation, to protect the integrity of the embankment, liner, and to
reduce the potential for seepage. The office strongly recommends that all earthen
embankments be properly maintained to protect the structure's integrity and to reduce the
attractiveness of a burrowing animal habitat.
This is a repeat concern that was initially documented in a Notice of Deficiency, dated
August 1, 2018, issued by this Office.
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 the NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. This
office request that you respond in writing within 30 days of receipt of this Notice. Your response
should include a description of corrective actions to be implemented to address the above described
violations, as well as the projected schedule for each violation to be addressed.

Please refer to the enclosed inspection report for additional observations and/or comments. If you
have questions concerning this correspondence, please contact Justin Henderson or me at (336)
776-9800.
Sincerely,
Docu S,ggned by:
�_ l JtiljC'
on
iiUZF,ggional Supervisor
Water Quality Regional Operations Section
Division of Water Resource, NCDEQ-WSRO
enc: Inspection Report
cc: Mark Bowman, ORC- pwdwalnutcovelggmail.com
Laserfiche Files (electronic copies)

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 NC0025526 111 12 I 20/02/26 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)
10:OOAM 20/02/26
17/03/01
Walnut Cove WWTP
First St
Exit Time/Date
Permit Expiration Date
Walnut Cove NC 27052
12:30PM 20/02/26
22/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Mark Anthony Bowman/ORC/336-591-4809/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Kim Greenwood,PO Box 130 Walnut Cove NC 27052/Town Manag er/336-591-4809/
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
Justin L Henderson Dousigned by: DWR/WSRO WQ/336-776-9701/
t,tshv, ('��,IWt,k,V 6V' 3/2/2020
D5F352596F81B496...
Signature of Management Q A Revie EL
Docusigned by: Agency/Office/Phone and Fax Numbers DateLon Snider , T 5^�ac, 3/3/2020
145B49E225C94EA...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO025526 I11 121 20/02/26 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On February 26, 2020 North Carolina Division of Water Resources (DWR) staff person Justin
Henderson performed a Compliance Evaluation Inspection of the subject facility. Mr. Mark Bowman,
ORC was present during this inspection. This type of inspection consists of two basic parts: an
in -office review of the facility files and self -monitoring data and an on -site inspection of the facility. This
inspection reflects non-compliance with Permit No. NC0025526. The following violations require your
attention and action:
1) Failure to conduct flow proportional composite sampling (both influent and effluent) in accordance
with Permit Condition Part II. Composite Sampling. Mr. Bowman, ORC indicated that composite
samples currently were being collected via the constant time/constant volume method however, use of
this method requires prior approval by the Director, and may only be used in situations where effluent
flow rates vary less than 15 percent.
2) Failure to ensure the composite sample is maintained at or below six (6) degrees Celsius during the
entire compositing period per CFR part 136.3 Table II. There were no thermometers present in either
the effluent or influent composite samplers nor were any records available to demonstrate the sample
compartment cooling was maintained in accordance with CFR part 136.3.
This is a repeat violation that was previously documented in a Notice of Deficiency, dated August 1,
2018 issued by this Office.
3) Failure to designate a Back-up ORC within 120 days of a vacancy in the position in accordance with
Permit Condition Part II. Section C. (1.) (b.) & (c.) and 15A NCAC 08G .0201.
4) Failure to document or maintain an ORC log of the operation, maintenance, and all visitation of the
system in accordance with Permit Condition Part II. Section C. (1.) and 15A NCAC 08G .0204 (5).
Officially designated operators are responsible for all proper operation and maintenance of the facility,
and all documentation required thereof.
5) Failure to conduct and/or maintain documented logs for the per event/analysis calibrations, on the
meters utilized to analyze Total Residual Chlorine (TRC) and Dissolved Oxygen (DO) in accordance
with Permit Condition Part II. Section C (2.) and the North Carolina Wastewater/Groundwater
Laboratory Certification Approved Procedures.
6) Failure to provide and Annual Performance Report to the Division and to the users/customers
served by the Permittee in accordance with Permit Condition Part 11. Section E. (12.) and NC G.S.
143-215.1 C. This report shall summarize the performance of the treatment system, as well as the
extent to which the facility was compliant with applicable Federal or State laws, regulations, and rules
pertaining to water quality. The report shall be provided no later than sixty (60) days after the end of the
calendar year.
This is a repeat violation that was previously documented in a Notice of Deficiency, dated August 1,
2018, issued by this Office.
Along with the above described violations the following item of concern warrants your attention:
a) The dikes/dams surrounding the facultative lagoons were overgrown with woody vegetation. Proper
maintenance for earthen embankments includes the removal and prevention of woody vegetation, to
protect the integrity of the embankment, liner, and to reduce the potential for seepage. The office
Page#

Permit: NCO025526
Inspection Date: 02/26/2020
Owner - Facility: Walnut Cove WWTP
Inspection Type: Compliance Evaluation
strongly recommends that all earthen embankments be properly maintained to protect the structure's
integrity and to reduce the attractiveness of a burrowing animal habitat.
This is a repeat concern that was initially documentedin a Notice of Deficiency, dated August 1, 2018,
issued by this Office.
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 the NC
General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties.
Page#

Permit: NCO025526 Owner - Facility: Walnut Cove WWTP
Inspection Date: 02/26/2020 Inspection Type: Compliance Evaluation
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:
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
❑
❑
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:
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:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
0
❑
❑
❑
Comment:
Pump Station - Influent
Yes No NA NE
Is the pump wet well free of bypass lines or structures?
❑
0
❑
❑
Is the wet well free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
❑
0
❑
❑
Are float controls operable?
0
❑
❑
❑
Is SCADA telemetry available and operational?
❑
❑
0
❑
Page# 4

Permit: NCO025526
Inspection Date: 02/26/2020
Pump Station - Influent
Is audible and visual alarm available and operational?
Owner - Facility: Walnut Cove WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
❑ ❑ ■ ❑
Comment: One of the influent pumps was in need or repair and the other had just been serviced. There
was two bypass pumps present at the time of this inspection that had been utilized to
Prevent spillage/bypass from occuring while the influent pump was being serviced. These
pumps should be removed except when used for essential maintenace.
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:
Disinfection -Gas
Yes No NA NE
Are cylinders secured adequately?
0
❑
❑
❑
Are cylinders protected from direct sunlight?
0
❑
❑
❑
Is there adequate reserve supply of disinfectant?
0
❑
❑
❑
Is the level of chlorine residual acceptable?
0
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
0
❑
❑
❑
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:
De -chlorination
Yes No NA NE
Type of system ?
Gas
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
❑
❑
❑
Page# 5

Permit: NCO025526 Owner - Facility: Walnut Cove WWTP
Inspection Date: 02/26/2020 Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Comment:
Are the tablets the proper size and type? ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use?
Comment:
Lagoons
Yes No NA NE
Type of lagoons?
Facultative
# Number of lagoons in operation at time of visit?
2
Are lagoons operated in?
Series
# 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?
# If excessive algae is present, has barley straw been used to help control the growth?
❑
❑
0
❑
Is the lagoon surface free of weeds?
M
❑
❑
❑
Is the lagoon free of short circuiting?
0
❑
❑
❑
Comment: Excessive woody vegetation is present on all dikes observed surrounding the lagoons. No
seepage was observed during this inspection. A sludge survey is recommended to be
performed to evaluated the sludge accumulation levels.
Influent Sampling
Yes No NA NE
# Is composite sampling flow proportional?
❑
0
❑
❑
Is sample collected above side streams?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
0
❑
❑
Celsius)?
Page# 6

Permit: NCO025526
Inspection Date: 02/26/2020
Owner - Facility: Walnut Cove WWTP
Inspection Type: Compliance Evaluation
Influent Sampling Yes No NA NE
Is sampling performed according to the permit? ❑ 0 ❑ ❑
Comment: Composite sampling is not collected in accordance with the permit. The composite sample
is not maintained at or below 6 degrees Celsius during the entire compositing periodl. There
were no thermometers observed in either the influent or effluent composite samplers.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
0
❑
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
0
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
0
❑
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
0
❑
❑
representative)?
Comment: Composite samDlina is not collected in accordance with the permit. The composite sample
is not maintained at or below 6 degrees Celsius during the entire compositing periodl. There
were no thermometers observed in either the influent or effluent composite samplers.
Composite tubing needs replacing.
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:
Page# 7