NC0050610_NOV2020PC0413_20200914

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
S. DANIEL SMITH
Director
Water Quality Utilities, Inc.
Attn: Jadd Brewer, Owner
P.O. Box 1167
Banner Elk, NC 28604-1167
NORTH CAROLINA
Environmental Quality
September 14, 2020
SUBJECT: Compliance Evaluation Inspection & Notice of Violation
NOV Tracking #: NOV-2020-PC-0413
The Ponds Wastewater Treatment Plant
NPDES Permit #NC0050610
Watauga County
Dear Mr. Brewer:
Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office (WSRO),
visited The Ponds wastewater treatment plant on August 11th, 2020, to perform a Compliance Evaluation
Inspection (CEI). The assistance and cooperation of Brandon Hughes, Operator in Responsible Charge (ORC),
was greatly appreciated. Details of the inspection are recorded on the attached EPA Water Compliance
Inspection Report.
You're reminded that, in accordance with NC General Statute 143-215.6A, failure to comply with all
conditions of the permit subjects the Water Quality Utilities, Inc. to civil penalties not to exceed $25,000.00 per
violation, per day.
As there were several deficiencies and violations that Mr. Boone noted during his inspection, please
respond in writing to this notice within 15 business days of receiving it. Your response should address each
issue individually and provide a proposed corrective action with implementation schedule for each
deficiency/violation. Your written response will, in part, determine whether DWR will pursue any further
action against Water Quality Utilities, Inc. regarding the deficiencies/violations contained herein.
If you have any questions or require further assistance, please contact Mr. Boone by phone at 336-776-
9690, or by email at ron.booneRricdenngov. You may also contact me by phone at 336-776-9700, or by email
at [e-mail].
Sincerely,
DocuSigned by:
Lon'�'.B§WiRer,%gional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. EPA Water Compliance Inspection Report
cc: Laserfiche
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 r H CAROI.IN/+
Den I, 6,1 m �ku­�I o�a� /"� 336.776.9800

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 u 3 I NC0050610 I11 121 20/08/11 I17 18I � I 19 I s I 201 I
211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I ni I 71 I 74 79 I I I I I I I80
701 I 71 I LL -1 I I
LJ
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 Dermit Number)
10:OOAM 20/08/11
17/12/01
The Ponds WWTP
NC Hwy 105
Exit Time/Date
Permit Expiration Date
Banner Elk NC 28604
01:OOPM 20/08/11
22/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Brandon K Hughes/ORC/828-260-5213/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Jadd W Brewer,PO Box 1167 Banner Elk NC 286041167//828-898-6277/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate
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
Ron Boone DWR/WSRO WQ/336-776-9690/
Docusigned by: 9/11/2020
�Ori.GCG,G�. YJOOfLPi
FBBBr
Signature RffcNM9 ag�ment Q A Reviewer Agency/Office/Phone and Fax Numbers Date
rL-u,,, -T Sti,du 9/11/2020
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO050610 I11 12I 20/08/11 117 18 i c i
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The plant description in the permit needs to be updated. There is no grit chamber or tertiary treatment.
Please ensure the plant description is appropriately updated during the next permit renewal.
The effluent composite sample is currently being collected from the aerated tank upstream of the UV.
The permit requires that the effluent sample be taken downstream of all treatment units. Please
reconfigure the sampler to comply with this requirement.
The audible alarm did NOT work when the influent pump station's high level float was activated. The
ORC found that the audible alarm horn's wires had come loose and the alarm worked correctly after he
reattached them securely. The alarms should be checked daily to ensure constant operability. This
should be a part of regular operations and maintenance (O&M) that should be documented as such.
The pump station also has a telemetry system which was NOT tested during the inspection. It is
noteworthy, however, that tripping the high level float to test the audible and visual alarms should have
also activated the telemetry system, yet the ORC was not notified during the remainder of the
inspection, of any problems at the pump station. The ORC was unsure who the system contacted in
the event of an alarm condition. He said he thought it contacted Jadd Brewer, who would in turn, likely
contact him. This system should be well known by the ORC and all backups. The telemetry system
should also be tested regularly to ensure it operates properly. This should be documented as part of
the regular O&M.
The EQ basin connects directly to the digester via a 4" metallic pipe. If the level of the EQ ever reaches
that height the wastewater flows directly to the digester. Once the level of the digester gets to a certain
height, it'll then flow into the aeration basin. The EQ basin does NOT have overflow detection systems
or alarms. The permittee should consider installing them as another level of protection.
The pipe that connects the EQ basin to the digester has a hole in it, caused by corrosion, which should
be repaired.
The entire plant structure is heavily corroded and if allowed to continue unchecked will result in failure
at some point. The corrosion should be corrected and prevented from reoccurring.
The plant has three blowers, one of which is inoperable and does NOT have belts installed. The blower
should be repaired as soon as possible.
The ORC pulled a solids sample from the aeration basin about an hour prior to the inspector's arrrival
on site. The ORC uses what appears to be just a one gallon plastic bottle with the top tapered portion
cut off. He filled this with sample from the basin and after about one hour approximately the bottom 20
to 30 percent of the container contained solids. The solids content of plant appears acceptable but the
operator should be using an actual settleometer to run the test and should be recording the results of
the test as part of regular O&M.
The plant could use additional maintenance. There is a lot of corrosion and the plant has a lot of
uncontrolled solids build-up in the clarifier baffle zones/troughs, overflow weir troughs, etc. The ORC
said, and the DMRs reflect, that he only spends about 30 minutes on site 5 days per week. This shows
the minimal time invested in the proper O&M of the plant.
The clarifier's weirs and overflow trough were quite dirty. Some pin floc was definitely apparent in the
overfllow, although the water looked clear.
Page#

Permit: NCO050610
Inspection Date: 08/11/2020
Owner -Facility: The Ponds WWTP
Inspection Type: Compliance Evaluation
The tertiary filter does NOT contain actual filter media. It contains plastic plates that the ORC called
"bats". These "bats" are placed in the filter tank in series at an angle of about 15 degrees from
horizontal. The water does NOT pass through the bats, according to the ORC, but rather just flows
around them. The filter is therefore not actually filtering. If anything, it is only baffling the flow of water
through the tank. There were solids (pin floc) flowing thru the filter and over the overflow weir of the
filter.
The chart recorder pen appeared to be out of ink at the time of the inspection... or nearly out. The ORC
stated that he would replace it.
The flow meter was last calibrated in July, 2020.
Spare UV bulbs are kept at Water Quality Labs' main office in Banner Elk. The effluent appeared clear
and free of solids but flow was heavy and of very high velocity so it would be very difficult to see any
solids unless they were very large or of very high concentration.
Overall impression is that not enough time is spent operating and maintaining this plant. Although it
appears to consistently meet permit effluent limitations, it is not well maintained. It displays a large
amount of superficial and more severe corrosion all over the plant. The plant is NOT very well kept and
contains excessive solids (i.e. bar screenings, scum in the clarifier's baffle troughs, etc). It is also a
safety hazard as many of the steel grate walkways are missing and/or structurally unsound. As
previously stated, the ORC, Brandon Hughes, spends only about 30 minutes per day at the plant. Mr.
Hughes stated that he currently operates six differnent plants, all of which are owned by Water Quality
Utilities, Inc. He also stated that one of the two owners, Jadd Brewer, who also operates some of their
plants, will retire soon, at which point Mr. Hughes will become responsible for three more plants, for a
total of nine plants. It's very questionable whether Mr. Hughes will be able to effectively manage the
proper O&M of nine different treatment plants.
Water Quality Utilities, Inc. currently has one mobile generator staged at its office in Banner Elk. It is
currently intended to serve all plants owned/operated by Water Quality Utilities, Inc. It is therefore
asserted that the reliability requirements for this type of facility, as stated in 15A NCAC 02H .0124, are
NOT being met. The permittee needs to make a serious accurate assessment of whether it has
sufficient backup equipment to facilitate continued uninterrupted and unaffected operations at all of its
facilities in the event of a catastrophic failure to ensure it meets the intent of the reliability requirements
in 15A NCAC 02H .0124.
Page#

Permit: NCO050610 Owner -Facility: The Ponds WWTP
Inspection Date: 08/11/2020 Inspection Type: Compliance Evaluation
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 operatc
❑
❑
❑
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?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: None
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: Plant description in permit needs to be updated. There is no grit chamber or tertiary
treatment.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑
Page# 4

Permit: NCO050610 Owner -Facility: The Ponds WWTP
Inspection Date: 08/11/2020 Inspection Type: Compliance Evaluation
Laboratory
Yes
No
NA
NE
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# 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
❑
❑
❑
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: Refrigerator only turned on when a sample is being collected. It was not on at the time of the
inspection.
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: Sample collected above UV.
Upstream / Downstream Sampling
Is the facility sampling performed as required by the permit (frequency, sampling type, an(
sampling location)?
Comment: None
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?
Yes No NA NE
■ ❑ ❑ ❑
❑ ■ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
Yes No NA NE
❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ ■
■ ❑ ❑ ❑
Page# 5

Permit: NCO050610
Inspection Date: 08/11/2020
Owner -Facility: The Ponds WWTP
Inspection Type: Compliance Evaluation
Pump Station - Influent Yes No NA NE
Comment: Audible alarm did NOT initiallv work when the station's hiah level float was activated. ORC
found that the audible alarm horn's wires had come loose and the alarm worked correctly
after he reattached them securely. Alarms should be checked daily to ensure constant
operability. This should be a part of regular operations and maintenance that should be
documented as such. The pump station also has telemetry which was not tested during the
inspection. The permittee needs to also test the telemetry system weekly to ensure
operability . The permittee needs to verify operability and who the telemetry system notifies
of a malfunction and report the results to DWR.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment: None
Equalization Basins
Is the basin aerated?
Is the basin free of bypass lines or structures to the natural environment?
Is the basin free of excessive grease?
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ■ ❑
❑ ❑ ❑ ■
Comment: EQ basin connects directly to diaester via 4" metallic pipe. If the level of the EQ ever
reaches that height the wastewater flows directly to the digester. Once the level of the
digester gets to a certain height, it'll then flow into the aeration basin. The EQ basin does
NOT have overflow detection systems or alarms. The permittee should consider installing
them as another level of protection. The pipe that connects the EQ basin to the digester has
a hole in it, caused by corrosion, which should be repaired.
Aeration Basins
Mode of operation
Type of aeration system
Yes No NA NE
Ext. Air
Diffused
Page# 6

Permit: NCO050610 Owner -Facility: The Ponds WWTP
Inspection Date: 08/11/2020 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
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?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/I)
❑
❑
❑
Comment: The entire Dlant structure is heavilv corroded and if allowed to continue unchecked will result
in failure at some point. The corrosion should be corrected and prevented from reoccurring.
The plant has three blowers, one of which is inoperable and does NOT have belts installed.
The blower should be repaired as soon as possible. The ORC pulled a solids sample from
the aeration basin about an hour prior to the inspector's arrival on site. The ORC uses what
appears to be lust a one gallon plastic bottle with the top tapered portion cut off. He filled thiE
with sample from the basin and after about one hour approximately the bottom 20 to 30
percent of the container contained solids. Solids content of plant appears acceptable.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
Yes No NA NE
■ ❑ ❑ ❑
❑ ❑ ■ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ■ ❑ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
❑ ■ ❑ ❑
❑ ❑ ❑ ■
Comment: The Dlant could use additional maintenance. There is a lot of corrosion and the Dlant has a
lot of uncontrolled solids build-up in the clarifier baffle zones/troughs, overflow weir troughs,
etc. The ORC said, and the DMRs reflect, that he only spends about 30 minutes on site 5
days per week. This shows the minimal time invested in the proper operation and
maintenance of the plant. The clarifier's weirs and overflow trough were quite dirty. Some pir
floc was definitelv aDDarent in the overfllow. althouah the water looked clear.
Pumps-RAS-WAS
Are pumps in place?
Yes No NA NE
■ ❑ ❑ ❑
Page# 7

Permit: NCO050610
Inspection Date: 08/11/2020
Pumps-RAS-WAS
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment: Air lift pumps.
Owner -Facility: The Ponds WWTP
Inspection Type: Compliance Evaluation
Sand Filters (Low rate)
(If pumps are used) Is an audible and visible alarm Present and operational?
Is the distribution box level and watertight?
Is sand filter free of ponding?
Is the sand filter effluent re -circulated at a valid ratio?
# Is the sand filter surface free of algae or excessive vegetation?
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1)
Yes
No
NA
NE
•
❑
❑
❑
•
❑
❑
❑
Yes No NA NE
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
❑ ■ ❑ ❑
❑ ❑ ■ ❑
❑ ❑ ■ ❑
Comment: The tertiary filter does NOT contain actual filter media. It contains Dlastic plates that the
ORC called "bats". These "bats" are placed in the filter tank in series at an angle of about 15
degrees from horizontal. The water does NOT pass through the bats, according to the
ORC, but rather just flows around them. The filter is therefore not actually filtering. If
anything, it is only baffling the flow of water through the tank. There were solids (pin floc)
flowing thru the filter and over the overflow weir of the filter.
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?
❑
❑
❑
Comment: The chart recorder pen appeared to be out of ink at the time of the inspecction... or nearly
out. The ORC stated that he would replace it. The meter was last calibrated in July. 2020.
Disinfection - UV
Yes
No
NA NE
Are extra UV bulbs available on site?
❑
0
❑
❑
Are UV bulbs clean?
0
❑
❑
❑
Is UV intensity adequate?
0
❑
❑
❑
Is transmittance at or above designed level?
❑
❑
❑
Is there a backup system on site?
❑
❑
❑
Is effluent clear and free of solids?
0
❑
❑
❑
Comment: Spare UV bulbs are kept at Water Quality Labs' main office in Banner Elk. The effluent
appeared clear and free of solids but flow was heavy and of very high velocity so it would be
very difficult to see any solids unless they were very large or of very high concentration.
Page# 8

Permit: NCO050610 Owner -Facility: The Ponds WWTP
Inspection Date: 08/11/2020 Inspection Type: Compliance Evaluation
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: There is a separate aeration tank in the plant, just after the filter.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
❑
❑
❑
Is the mixing adequate?
0
❑
❑
❑
Is the site free of excessive foaming in the tank?
0
❑
❑
❑
# Is the odor acceptable?
0
❑
❑
❑
# Is tankage available for properly waste sludge?
❑
❑
❑
Comment: There is no additional waste sludge storage tank. The ORC said Triple T Septic hauls their
sludge about every 1.5 to 2 weeks.
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: Overall imaression is that not enouah time is spent ODeratina and maintainina this Dlant.
Although it appears to consistently meet permit effluent limitations, It is not well maintained.
displays a large amount of superficial and more severe corrosion all over the plant. The plan
is NOT very well kept and contains excessive solids (i.e. bar screenings, scum in the
clarifier's baffle troughs, etc). It is also a safety hazard as many of the steel grate walkways
are missing and/or structurally unsound. As previously stated, the ORC, Brandon Hughes,
spends only about 30 minutes per day at the plant. Mr. Hughes stated that he currently
operates six differnent plants, all of which are owned by Water Quality Utilities, Inc. He also
stated that one of the two owners, Jadd Brewer, who also operates some of their plants, will
retire soon, at which point Mr. Hughes will become responsible for three more plants, for a
total of nine plants.
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?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Yes No NA NE
❑ ■ ❑ ❑
❑ ❑ ■ ❑
❑ ■ ❑ ❑
❑ ■ ❑ ❑
❑ ❑ ❑ ■
❑ ❑ ❑ ■
Page# 9

Permit: NCO050610 Owner -Facility: The Ponds WWTP
Inspection Date: 08/11/2020 Inspection Type: Compliance Evaluation
Standby Power Yes No NA NE
Is the generator fuel level monitored? ❑ ❑ ❑
Comment: Water Quality Utilities, Inc. currently has one mobile generator staged at its office in Banner
Elk. It is currently intended to serve all plants owned/operated by Water Quality Utilities, Inc.
It is therefore asserted that the reliability requirements for this type of facility, as stated in 15
NCAC 02H .0124, are NOT being met. The permittee needs to make a serious accurate
assessment of whether it has sufficient backup equipment to facilitate continued
uninterrupted and unaffected operations at all of its facilities in the event of a catastrophic
failure to ensure it meets the intent of the reliability requirements in 15A NCAC 02H .0124.
Page# 10