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Home My WebLink AboutNC0057193_Regional Office E-File Scan Up To 1/19/2021From: Lance Ingram To: Price, Bev Subject: [External] Alarm float/Composite Sampler Date: Monday, March 25, 2019 12:05:20 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov<mailto:rcl2ort.sl2am&nc.gov nc.gov> Hi Bev, I was able to make the influent pump high water alarm work. Apparently it was a dirty contact on a relay. I was able to order the complete motor and gear assembly for the sampler for a meager $703 plus overnight and expedited fees ordered! I'm trying to get it here by Wednesday eve so I can sample in time for the lab, they need it by Thursday afternoon. The only issue is that normally there is a one week lead time. So hopefully we will have a composite sample this week and prevent another violation. My supervisor (Bob Ellyson) came by the plant on Wednesday after your inspection so I could brief him on the issues. I actually showed him the problem with the float switch and the alarm worked! I'll keep you aware of progress with the issues we discussed. Thanks, Lance DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 E8DFAF ROY COOPER Governor K41C IAEL S. R.EGAN serrErary LIN DA CU LPE PPER arr "tor Certified Mail # 7017 2620 0000 9759 1093 Return Receipt Reauested NORTH CAROLINA Environmental Quafid April 11, 2019 J. William Irving Nantahala Outdoor Center LLC P.O. Box 2629 Asheville, NC 28802 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2019-PC-0253 Permit No. NCO057193 Nantahala Outdoor Center Swain County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Nantahala Outdoor Center on March 20, 2019. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0057193. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Flow Measurement The effluent flow meter is calibrated but not documented. Effluent Sampling The effluent sampler was not working. All samples collected on March 19th were grab samples. The permit requires composite samples for BOD & TSS. Effluent Sampling The sampler is set for constant time/constant volume. Flow proportional sampling is not being conducted. North CaroiinsDepsrtmentof -EnvironmentaIQualrty I Division of Wster Resou roes AshevO— Reg?onalOffsce 1 2090 U.S. 70Hthxray I Swannanos, North Csroiam 23773 ^"•.i«:"u'c: �rueor., 823T96-45DO DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 E8DFAF In addition, the issues below must also be addressed: 1. Assess solids handling & storage — see comments on page 2 of Inspection Summary. 2. Assess disinfection method — see comments on page 2 of the Inspection Summary. Remedial actions should have already been taken to correct these problems and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Beverly Price with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, DocuSigned by: 7E617A38285848C... G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Robert Ellyson Lance Ingram WQS ARO Server LF G:\WR\WQ\Swain\Wastewater\Minors\Nantahala Outdoor Center 57193\Inspections\March 20, 2019 CEI\20190411_NC0057193_NOV2019PCO253 North CaroiinaDepsrtnientof -Environmenta;Quai!ty I D;usionofWsterResouroes Ashev;;�- RegnnalOffsce 1 2090 U.S. ?ON gh -W I Swannanos, North Csro:ina 23773 DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 EBDFAF 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 NC0057193 111 12 I 19/03/20 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 I� 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) 10:30AM 19/03/20 17/12/01 Nantahala Outdoor Center 13077 US Hwy 19 Exit Time/Date Permit Expiration Date Bryson City NC 287139114 12:OOPM 19/03/20 22/10/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Lance A Ingram//828-488-7195 / Lance Alan Ingram/ORC/828-488-7195/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Lance Alan Ingram,13077 Hwy 19 W Bryson City NC 287139114//828-488-2175/ Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance 0 Records/Reports Self -Monitoring Program 0 Sludge Handling Disposal 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 Beverly Price Dsn ARO WQ//828-296-4500/ i Signature of Management Q A Rev, bocusigned by: Agency/Office/Phone and Fax Numbers Date 4/11/2019 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 EBDFAF NPDES yr/mo/day Inspection Type (Cont.) NCO057193 I11 121 19/03/20 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The inspection was conducted by Beverly Price of the Asheville Regional Office. Mr. Lance Ingram was present and assisted with the inspection. The following issues were noted during the inspection: Flow meter calibration is not documented. The calibration should show a maximum deviation of less than 10% from the true discharge rates. A more reliable measuring (ruler/yard stick) device is recommended to ensure accuracy of the calibration. The composite sampler was not working at the time of inspection. As a result, all samples collected on March 19th were grab; BOD, TSS and Ammonia are required to be composite. Flow proportional sampling is not being conducted. Constant time/constant volume is being used: Use of this method requires prior approval. All maintenance and process control checks should be documented in the log book. Solids pumping should be documented. The audible/visual alarms were not working on the influent pump station/EQ basin. Safety: The following are potential safety issues for the operator: 1. The ORC uses extension ladders to access the reactor for sludge judge measurement. 2. The ORC uses a hose to remove foam from the reactor. The hose extends across the walkway between the SBR and the digester. Recommendations: 1. Plywood extensions have been added to the chlorine contact basin baffles to prevent short circuiting. The ORC reports that this was done due to elevated fecal coliform levels in the past. The system should be evaluated to determine if there is short-circuiting and if so, why. Also, possibly evaluate whether a liquid chlorine feed would be more appropriate for this system or add additional chlorine tablets. The system currently uses chlorine tablets. 2. Assess solids management in the facility. Settleable solids test showed approximately 850ml-900ml (settling was uneven) of solids. More frequent pumping of solids may be required. Perform a MLSS test to determine the amount of solids in the reactor. There was an excessive amount of foam in reactor #1. The ORC reports that Nocardia is the cause. Nocardia can be associated with longer Solids Residence Time (SRT). Verify filamentous growths by conducting a microscopic examination of the foam and the mixed liquor. Filamentous growth can cause Nocardia. Excessive grease is also a known cause of Nocardia. Restaurant grease traps may need to be pumped more frequently. Wasting may need to be increased. Foam may need to be physically removed with a vacuum truck. 3. Evaluate the capacity of the digester. The ORC reports hauling 2000-4000 gallons approximately every two weeks. Page# DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 E8DFAF Permit: NCO057193 Owner - Facility: Nantahala Outdoor Center Inspection Date: 03/20/2019 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: The Dermit cover letter shows this as a Class I facilitv. The database and Drevious permit letter indicate a Class 2 facility; this is a Class 2 facility. The permit description does not show a standby generator. The facility uses a Kohler generator. 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: Sludge judge - for reactor Settleable solids 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: There were a lot of solids on the bar screen. 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# 3 DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 E8DFAF Permit: NCO057193 Owner - Facility: Nantahala Outdoor Center Inspection Date: 03/20/2019 Inspection Type: Compliance Evaluation Pump Station - Influent Yes No NA NE Is audible and visual alarm available and operational? ❑ 0 ❑ ❑ Comment: Audible & visual alarms were not working. 2 spare pumps were on -site. The ORC reports that grease does not seem to be an issue in the influent pump station and grease traps for restaurants at the facility are pumped approximately once per month during the season. Grease traps are pumped approximately every six weeks during the Sequencing Batch Reactors Yes No NA NE Type of operation: Duplex Is the reactor effluent free of solids? 0 ❑ ❑ ❑ Does minimum fill time correspond to the peak hour flow rate of the facility? ❑ ❑ ❑ Is aeration and mixing cycled on and off during fill? ❑ ❑ ❑ The operator understands and can explain the process? ❑ ❑ ❑ Comment: The reactors are always mixina but air valves are set on timers. There was an excessive amount of foam in reactor #1. The ORC reports that Nocardia is a problem and it is removed via a hose that stays connected to the reactor. The ORC checks solids levels in the reactor to determine when to waste to the digester. If supernate is less than 4 ft from the sludge blanket, solids are wasted to the digester. Aerobic Digester Yes No NA NE Is the capacity adequate? ❑ 0 ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? M ❑ ❑ ❑ # Is tankage available for properly waste sludge? ❑ 0 ❑ ❑ Comment: The ORC reports that 2000-4000 gallons of sludge is pumped approximately every 2 weeks and that pumping is more frequent than expected. 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? Yes No NA NE ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Page# 4 DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 E8DFAF Permit: NCO057193 Inspection Date: 03/20/2019 Equalization Basins # Is basin size/volume adequate? Owner - Facility: Nantahala Outdoor Center Inspection Type: Compliance Evaluation Yes No NA NE ■ ❑ ❑ ❑ Comment: Post EQ Basin - New pump was on -site and ready to be placed in the EQ Basin. Any solids that accumulate are pumped back to the digester. Chlorine tabs are used to control alaae. The basin contains diffusers but thev are not used. 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? 1 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? ❑ ❑ ❑ Comment: Plywood extensions had been added to the concrete baffles to prevent short circuiting according to the ORC. This was done due to elevated fecal coliform results in the past. De -chlorination Yes No NA NE Type of system ? Liquid 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: Chlorination is accomplished using tablets. Are tablet de -chlorinators operational? ❑ ❑ 0 ❑ Number of tubes in use? Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ 0 ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # 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 ❑ 0 ❑ ❑ representative)? Page# 5 DocuSign Envelope ID: AC813FED-F50E-4044-A210-6C9FB1 E8DFAF Permit: NCO057193 Inspection Date: 03/20/2019 Effluent Sampling Owner - Facility: Nantahala Outdoor Center Inspection Type: Compliance Evaluation Yes No NA NE Comment: The sampler is set for constant time/constant volume. The composite sampler was not working at the time of inspection. The motor and controls had stopped working. The sample collected on March 19th was a grab sample because the sampler was down. 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: Calibration is done by the ORC but is not beina documented. The meter has a striD chart but it is not connected. 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: 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? Is the generator fuel level monitored? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: The permittee maintains a service contract and fuel levels are checked by the ORC. The generator was turned on and was operational but was no tested under load during the inspection. Fuel level indicated 3/4 full. Page# 6 Certificate Of Completion Docu5�". 6 S E C U R E D Envelope Id: AC813FEDF50F4044A2106C9FB1E8DFAF Status: Completed Subject: Please DocuSign: 20190411_NC0057193_NOV2019PCO253.docx, 20140411_NC0057193_NOV2019PCO253_Draft. pdf Source Envelope: Document Pages: 8 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 1 Beverly Price AutoNav: Enabled 217 W. Jones Street Envelopeld Stamping: Enabled Raleigh, NC 27699 Time Zone: (UTC-08:00) Pacific Time (US & Canada) Bev.Price@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original 4/11/2019 9:08:39 AM Holder: Beverly Price Bev.Price@ncdenr.gov Signer Events Signature Beverly Price EDSbev.price@ncdenr.gov North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None) Signature Adoption: Pre -selected Style Using IP Address: 149.168.204.10 Electronic Record and Signature Disclosure: Not Offered via DocuSign G. Landon Davidson landon.davidson@ncdenr.gov Asheville Regional Office, Regional Supervisor DEQ, Division of Water Resources, Water Quality Regional Operatoins Security Level: Email, Account Authentication (None) Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Editor Delivery Events Agent Delivery Events Intermediary Delivery Events Certified Delivery Events Carbon Copy Events Notary Events Envelope Summary Events EDI-Sign1d by' 7E617A38285848C... Signature Adoption: Uploaded Signature Image Using IP Address: 149.168.204.10 Signature Status Status Status Status Status Signature Status Location: DocuSign Timestamp Sent: 4/11/2019 9:10:20 AM Viewed: 4/11/2019 9:10:27 AM Signed: 4/11/2019 9:10:46 AM Freeform Signing Sent: 4/11/2019 9:10:46 AM Viewed: 4/11/2019 9:14:15 AM Signed: 4/11/2019 9:43:59 AM Freeform Signing Timestamp Timestamp Timestamp Timestamp Timestamp Timestamp Timestamp Timestamps Envelope Sent Hashed/Encrypted 4/11/2019 9:10:47 AM Certified Delivered Security Checked 4/11/2019 9:14:15 AM Signing Complete Security Checked 4/11/2019 9:43:59 AM Completed Security Checked 4/11/2019 9:43:59 AM Payment Events Status Timestamps May 21, 2019 G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ Re: NOV-2019-PC-0253 Dear Sir: In response to Notice of Violation 2019-PC-0253 the following corrective actions have been implemented and others are ongoing: Flow measurement - The flow meter is now calibrated and documented as required. Effluent Sampling -The effluent composite sampler was repaired and operational by March 27th 2019. Effluent Sampling -The composite sampler is currently operating in constant time/constant volume mode. The flow meter cannot interface with the sampler. A memo has been sent to John Hennessy to determine if permission to operate in the current configuration is possible. We have started the process of requesting price quotations in the event that the flow meter must be replaced. If a replacement is necessary the meter could be installed as soon as the components could be sourced. The following issues were noted in the inspection report: A ruler is recommended for flow meter calibration. A ruler or other method to accurately measure the head level in the V-notch weir will be used. All maintenance and process control checks should be documented in the log book. Solids pumping should be documented. All maintenance, process control checks, and solids pumping is now being documented in the log book. The audible/visual alarms were not working on the influent and post equalization pump stations. The influent alarms are operating as required. The post equalization pump control requires additional equipment to make the alarms operational, the operator is in the process of ordering and installing that equipment. The repairs will be performed as soon as the materials are delivered and time permits. Safety: 1. The ORC uses an extension ladder to access the reactor for sludge judge measurement. The operator will use the approved ladder to access the reactor for all 0&M purposes. 2. The ORC uses a hose to remove foam from the reactor. The hose extends across the walkway between the reactor and the digester. The operator will make improvements to the foam removal system to prevent safety hazards. Recommendations: 1. Plywood extensions have been added to the chlorine contact basin baffles to prevent short circuiting. The existing chlorine contact chamber operates well. It may perform adequately without the plywood baffles that were installed in 2000. The facility management approved replacement of the plywood baffles with aluminum plate prior to the inspection because the plywood is deteriorated. The present arrangement allows the facility to operate in compliance with a minimum of chlorine and de -chlorinating chemicals. We can replace the baffles with aluminum plate or completely remove the baffles. 2. Assess solids management in the facility, settleable solids test showed approximately 850ml-900m1. The facility has a high percentage of flow from restaurants. The system experienced unusually high traffic for the winter season resulting in more than usual flow from the restaurant. Nocardia bacteria was responsible for the slow settleable solids test. A sludge judge test showed that the solids in the reactor were well within acceptable levels before discharge. The inspector observed a discharge for the SBR reactor that was well within compliance. The grease trap pumping program was increased in March from every 6 weeks to every 4 weeks. The plant was operating well during the seasonal transition period where flow and temperature are changing. Since the inspection Nocardia foaming has decreased. 3. Evaluate the capacity of the digester. The digester capacity is 20,000 gallons. High organic loading in peak season requires that we pump concentrated solids often. Approximately 4000 gallons of sludge is removed every two weeks. This pumping rate decreases throughout the late summer and fall and increases in the mid spring. The ORC will be working with the regional staff to bring the facility into and maintain compliance. The unresolved issue of the flow meter/sampler interface should be resolved as soon as we hear from Mr. Hennessy. Until that time the ORC will continue to address the above issues in an expedient manor. Sincerely, Lance Ingram SRC Nantahala Outdoor Center CC:illiam Irving ev Price JcSEhn Hennessy Cranford, Chuck From: Berry, Ron Sent: Friday, December 07, 2012 12:46 PM To: Cranford, Chuck Subject: Update on question about Nantahala Outdoor Center Chuck, Did a quick check of our file, impairment list, and latest basin plan. Currently the facility is permitted to discharge 0.04 MGD to a class B, Tr stream (Nantahala River). The 0.04 MGD flow was an expansion approved in 1988 and was modeled and no limit changes were required. A new model would need to be run to ultimately determine if expanding to 0.12 MGD would impact BOD, NH3-N, and DO requirements. Typically we are requiring the Permittee to provide new USGS stream data (data used in model) for new /expansion to reflect the recent droughts, which seems to reduce stream flows 20-30%. The table below is a calculation and comparison of IWC between current and 0.12 MGD: Permitted Flow 7 10 s iW-L s 7 10 w IWC w 0.04 MGD 85.2 cfs 0.07% 122.3 cfs 0.06% 0.12 MGD 69 cfs* 0.28% 97 cfs* 0.19% '* assumed 25 % reduction is stream flow Do not know what impact the 0.28% IWC would have on permit. There are currently no stream impairments and no permit -based strategy listed in basin plan. Ron Ron Berry ron.berry@ncdenr.gov Engineer I DWQ/Point Source/NPDES Complex Permitting Unit NCDENR Phone: (919) 807-6396 Fax: (919) 807-6489 Office: Archdale Building Room 925Y Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties unless the content is exempt by statute or other regulation. vt;k ;e am I14 ', . g a, '::Y j �. �1... IL Er 400 milk 9k «�.a�� N �,.:.� � .. �;� t � r �, _ '� _:` :';. ..� � _ �j Ir� A A E� + �. I i 'i � � � ?v'� � may. -n,kµ �r + aY k �.. i r"fb+ �. "� � u�� ' a ��.• �# �S � t ,y .tit �' E Mtn. 4.. .�.1:• `�`.:.�I � I � �� i'� .� r 2 iar1491 �f+.A t"��b 1d� 7 m 1"i � / �w'�� .: �* � '� t \ � } � its.. SR�bi V � t .lit � �y � � tiV �.,a � ,� �, �. .. 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Regional Supervisor — Asheville Regional Office Water Quality Regional Operations Section NCDEQ — Division of Water Resources 828 296 4680 office 828 230 4057 mobile Landon.Davidson@ncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28711 Subscribe to Collection System & Sewer Permitting Updates NC DEQ permits handbook Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties -----Original Message ----- From: Hennessy, John Sent: Thursday, May 23, 2019 1:40 PM To: Davidson, Landon <landon.davidson@ncdenr.gov> Cc: Price, Bev <bev.price@ncdenr.gov> Subject: RE: [External] Flow meter issue I'm fine with your approach. I agree. If I have learned one thing over the years, it is not to respond to regulator shopping without talking to other internal staff. Also, since I have no idea what the facility looks like, I don't feel like I am in a position to tell these folks what they need to do. Every facility has its unique issues. I am happy to get back to these folks and tell them they need to do flow proportional. John Hennessy Supervisor, Compliance & Expedited Permitting Branch Division of Water Resources Department of Environmental Quality (919) 707-3615 office john.hennessy@ncdenr.gov 512 N. Salisbury Street (Archdale Building), Suite 925-13, Raleigh, NC 27604 1617 Mail Service Center, Raleigh, NC 27699-1617 -----Original Message ----- From: Davidson, Landon Sent: Thursday, May 23, 2019 1:30 PM To: Hennessy, John <john.hennessy@ncdenr.gov> Cc: Price, Bev <bev.price@ncdenr.gov> Subject: RE: [External] Flow meter issue Their permit requires flow proportional. If they want a variance, they can ask and I believe ROS are delegated authority although I've never reviewed one and there is no existing guidance that I'm aware of although the need for it was kicked around a few years back. They are permitted flow over 30K. I don't see a pathway based on many other facilities we have forced to do flow proportional in this region in the last two years. Happy as always to have a productive discussion on the topic. L G. Landon Davidson, P.G. Regional Supervisor — Asheville Regional Office Water Quality Regional Operations Section NCDEQ — Division of Water Resources 828 296 4680 office 828 230 4057 mobile Landon.Davidson@ncdenr.gov 2090 U.S. Hwy. 70 Swannanoa, N.C. 28711 Subscribe to Collection System & Sewer Permitting Updates NC DEQ permits handbook Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. -----Original Message ----- From: Hennessy, John Sent: Thursday, May 23, 2019 1:25 PM To: Davidson, Landon <landon.davidson@ncdenr.gov> Subject: FW: [External] Flow meter issue I am in no position to answer his question. I do not know the facility. Who is the inspector on this one? John Hennessy Supervisor, Compliance & Expedited Permitting Branch Division of Water Resources Department of Environmental Quality (919) 707-3615 office john.hennessy@ncdenr.gov 512 N. Salisbury Street (Archdale Building), Suite 925-B, Raleigh, NC 27604 1617 Mail Service Center, Raleigh, NC 27699-1617 -----Original Message ----- From: Lance Ingram <Lance.Ingram@noc.com> Sent: Tuesday, May 21, 2019 10:03 AM To: Hennessy, John <john.hennessy@ncdenr.gov> Subject: [External] Flow meter issue CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov<mailto:report.snam&nc.gov> John, I'm following up on my call regarding our recent inspection and violation. The issue is that we cannot interconnect our composite sampler with the existing flow meter for flow paced sampling. Our inspector (Bev Price) indicated that you are the appropriate contact to decide if we can continue to use the existing flow meter. Currently the sampler operates separately in a fixed time/quantity mode. The flow meter is in excellent condition but cannot interface with the sampler. We are a seasonal resort with our maximum flows in July. Our permit flow limit is 40,000 GPD. A typical peak flow in July is 22,000 GPD with a typical winter minimum flow of approximately 5,000 GPD. Thank you for any assistance on this issue. Regards, Lance Ingram ORC Nantahala Outdoor Center 13077 HWY 19-West Bryson City NC 28713