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Home My WebLink AboutNC0022098_CEI_NOV2021PC0353_20210719ROY COOPER Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director T3t Cranbrook LLC Attn: Michael Brown, Owner 1150 Hungry Nick Blvd, Suite C-359 Mount Pleasant, SC 29464 NORTH CAROLINA Environmental Quality July 19, 2021 SUBJECT: Compliance Evaluation Inspection & Notice of Violation Case #: NOV-2021-PC-0353 NC Individual NPDES Permit NC0022098 Cranbrook Village Community Randolph County Dear Mr. Brown: Ron Boone and Tricia Lowery, of the NC Division of Water Resources, Winston-Salem Regional Office, met with Paul Smith, Operator in Responsible Charge of the Cranbrook Community Wastewater Treatment Plant (WWTP), to perform a compliance evaluation inspection. You are listed as owner and discharge permit holder for the Cranbrook WWTP. The attached Water Compliance Inspection Report summarizes the findings of the inspection. The system is in extremely poor condition and we were pleased to learn that T3t has submitted an application for authorization to construct (AtC) a new treatment system that will replace the old one. Still, the conditions observed by the inspectors during the inspection resulted in this notice of violation. Despite T3t's efforts to replace the existing treatment system, you must still properly operate and maintain the existing facility in order to comply with the discharge permit. Failure to do so may result in enforcement action by the NC Division of Water Resources. Given that the application for AtC was just recently received by the Division in March, 2021, and the design and construction processes for these types of facilities are known to take a lengthy amount of time to complete, you are reminded that the existing plant must still operate and properly treat the wastewater generated by Cranbrook community until the new system is fully built, certified, and commissioned. The attached inspection report enumerates several current conditions that should be remediated as soon as possible, even though the facility is scheduled to be replaced. Please be aware that the Division may take enforcement action against any permittee who fails to comply with any requirement of their permit. Pursuant to NC General Statute (NCGS) 143- NORTH CAROLINAD E D.o.rtm.m of Envimnmomni OuoI . North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. If you have any questions or concerns, please do not hesitate to contact Mr. Boone or Ms. Lowery, by phone at 336-776-9800, or by email at ron.boone@ncdenr.gov or tricia.lowery@ncdenr.gov, respectively. Thank you for your time and attention to this matter. Attachments: 1. Water Compliance Inspection Report cc: Laserfiche Paul Smith P.O. Box 269 Reidsville, NC 27323-0269 LD_E NORTH CAROLINA Department of Environmental quaky Sincerely, DocuSiiggned by:by� %A. l . 5A,aC - "-145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality j Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 United States Environmental Protection Agency EPA Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction 1 IN 21IIIIII Code I 2 IL NPDES yr/mo/day Inspection I 3 I NC0022098 111 121 21/06/29 117 Type 18110 IIIIIIIIIII Inspector Fac Type 19 I S I 201 IIIIIIIIIII IIIIIII I IIIIII P6 Inspection 671 Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved I 7° I I 711 I 72 I N I 731 I 74 71 I I I I I I I I 180 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES Dermit Number) Cranbrook Village Community 4309 Liberty Rd Greensboro NC 27406 Entry Time/Date 09:OOAM 21/06/29 Permit Effective Date 16/10/01 Exit Time/Date 11:00AM 21/06/29 Permit Expiration Date 21/06/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Paul Matthew Smith/ORC/336-932-9347/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Paul Smith,4309 Old Liberty PI Greensboro NC 27407//336-932-9347/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Sludge Handling DispoFacility 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) Ron Boone Patricia Lowery of Inspector(s) Agency/Office/Phone and Fax Numbers Date r—DocuSigned by: osuaiel Boos,,, DWR/WSRO WQ/336-776-9690/ 7/23/2021 \--Dmigaso. DWR/WSRO WQ/336-776-9691/ 7/23/2021 twoeAl Signature of Mana a (Orin ewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 7/23/2021 ri....0, T. SA,�dcr EPA �orrri4Sg02S1RWW9-94) Previous editions are obsolete. Page# 1 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 31 NPDES yr/mo/day NC0022098 111 121 21/06/29 I17 Inspection Type 18LI (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Ron Boone and Tricia Lowery conducted a compliance evaluation inspection of the Cranbrook WWTP on 6/29/2021. The assistance and cooperation of Paul Smith, Operator in Responsible Charge, are greatly appreciated. The inspection revealed a wastewater treatment plant in extremely poor condition. The entire plant structure is very corroded and its structural integrity questionable. It is a severe safety hazard for any personnel who enter the plant grounds. The security fence surrounding the plant is also in very bad condition and it is doubtful that it effectively keeps anyone out. The amount of debris and trash inside the fence shows the plant is likely frequented by unauthorized personnel or they are simply throwing trash over the fence. The tubes for the chlorinator were broken and the operator used a bucket to cover them and protect the tablets for exterior moisture. The influent pump station must be checked 365 days a year because it has neither telemetry nor SCADA systems installed. The operator stated that he checks the station daily and could provide records of his inspections but did not provide them during the inspection or since. He also stated the park manager is responsible for checking it on the weekends but provided no records of that either. The pump station itself had to be cleared of significant overgrowth with a weed trimmer so inspectors could access it for inspection, which makes us question when the last time the station was actually checked. The pump station wet well was not covered and the audible alarm did not work. All discrepancies and violations noted above should be fixed/addresseed immediately. It is noted that the owners, T3t Cranbrook LLC, have submitted an authorization to contruct (AtC) permit application to the Division to allow them to design and build a new treatment system to replace this one. The Division wholeheartedly supports this effort and will do all within its power to facilitate the process. Please note that the violations observed during this inspection appear to be caused primarily by a lack of proper operation and maintanance over an extended period of time. All violations, however, should be immediately addressed and remediated. Failure to do so could result in enforcement action by the Division of Water Resources for failure to comply with your NPDES permit. Such violations subject the permittee/owner to civil penalties not to exceed $25,000 per day, per violation. These violations have resulted in Notice of Violation, case number NOV-2021-PC-0353. If you have any questions or wish to discuss any issues please contact Ron Boone or Tricia Lowery by phone at 336-776-9690 or 336-776-9691, respectively. Page# 2 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 Permit: NC0022098 Inspection Date: 06/29/2021 Owner - Facility: Cranbrook Village Community 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 MODE application? Is the facility as described in the permit? • ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ • ❑ ❑ Is access to the plant site restricted to the general public? ❑ • ❑ ❑ Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑ Comment: Security fence that surrounds the plant is in very poor condition and does NOT provide sufficient security or safety. Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? 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? Facility has copy of previous year's Annual Report on file for review? Comment: Operator visitation recorded on daily operation sheets. Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ Laboratory Yes No NA NE Page# 3 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 Permit: NC0022098 Inspection Date: 06/29/2021 Owner - Facility: Cranbrook Village Community Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • Comment: Field lab certification number 5169 for Smith Industries. Uses Pace Labs for non -field parameters. Effluent Sampling Yes No NA NE 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: 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 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ Comment: Pump station is in poor condition. The area had to be cleared of overgrowth to be accessed for inspection. The pump station wet well is not covered and the audible alarm does NOT work. These issues should be fixed immediately. Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ Page# 4 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 Permit: NC0022098 Inspection Date: 06/29/2021 Owner - Facility: Cranbrook Village Community Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ■ ❑ Comment: Operator calculates an instantaneous flow reading using the rate of flow at the time of measurement. 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? Yes No NA NE • • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ Comment: The bar screen is in poor condition...extremely bad corrosion. The entire structure is in very poor condition and is a major safety concern for anyone inside the plant fence. The plant should be immediately repaired or replaced. Replacement is probably the only viable option at this point due to the extremely poor condition of the plant. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? • ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ • ❑ Are the diffusers operational? • ❑ ❑ ❑ Is the foam the proper color for the treatment process? ❑ • ❑ ❑ Does the foam cover less than 25% of the basin's surface? • ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ • Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑ • Comment: Mixed liquor lacked any sign of a healthy mixed liquor (i.e. pleasant earthy odor and obvious separation of solids and supernate) and odors were completely absent. Operator stated he keeps mixed liquor settleable solids at around 350 mg/I, which seems very low although violation history does NOT demonstrate any issues indicative of a low MLSS. Secondary Clarifier Is the clarifier free of black and odorous wastewater? • Yes No NA NE ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 Permit: NC0022098 Inspection Date: 06/29/2021 Owner - Facility: Cranbrook Village Community Inspection Type: Compliance Evaluation Secondary Clarifier 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'/4 of the sidewall depth) Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ • Comment: Other than the extremely poor condition of the plant structure, no other issues were noted with the aeration basin and clarifier. Pumps-RAS-WAS Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: Air lifts pumps remove solids from clarifier using the plant's blower generated air supply. Only one blower was operational during the inspection. Both blowers should be operational at all times. Spare parts to facilitate this requirement should be readily available at all times. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? ❑ • ❑ ❑ Are the tablets the proper size and type? ■ ❑ ❑ ❑ Number of tubes in use? 2 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? ❑ ❑ ❑ • Comment: Chlorinator tubes were broken and not covered. Operator keeps a bucket over the tubes to keep water out and protect the tablets. De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ • ❑ ❑ Page# 6 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 Permit: NC0022098 Inspection Date: 06/29/2021 Owner - Facility: Cranbrook Village Community Inspection Type: Compliance Evaluation De -chlorination Is storage appropriate for cylinders? # Is de -chlorination substance stored away from chlorine containers? Are the tablets the proper size and type? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Some chemical was spilled on the ground at the bottom of the steps leading up to the walkway for the plant. All spilt chemicals should be completely cleaned up immediately. Are tablet de -chlorinators operational? Number of tubes in use? 2 Comment: None Effluent Pipe Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: There is considerable overgrowth surrounding the outfall and a large amount of trash litters the area. The way to the outfall should be better maintained, although we were able to access it with little effort. Aerobic Digester Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Yes • • • • • No NA NE El El El ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Comment: Sludge capacity was not evaluated although it is assumed that capacity is sufficient. The permit specifies an aerated digester but the unit it actually just a holding tank. The operator was asked to provide (post inspection) sludge pumping records for the last year. He only submitted three invoices as follows: one for March 21/2021 that indicated two loads were pumped, one for Jun 10/2021 that indicated one load was pumped, and one for June 28/2021 that indicated one load was pumped. Invoices do NOT all indicate the volume of a load but the June 28 invoice stated the load was 3,300 gallons. 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? Yes No NA NE ❑ II ❑ ❑ • ❑ ❑ ❑ Page# 7 DocuSign Envelope ID: BFD887DB-64A0-446B-A52D-46A5239A9649 Permit: NC0022098 Inspection Date: 06/29/2021 Owner - Facility: Cranbrook Village Community Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Comment: The plant was in extremely poor condition and not well kept. The structure, fence and grounds were all in very poor condition. The was a large amount of trash that was obviously thrown over the fence and left by unauthorized people who entered the plant through the fence that is in very poor condition. The operator indicated he performs setteable solids tests on the mixed liquor but recently lost his sample container in the aeration basin and hasn't gotten a new one. 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? Comment: There is no stand-by power. Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page# 8