NC0029190_NOI_NOV2021PC0580_CEI_20211129

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
November 29, 2021
CERTIFIED MAIL
RETURN RECEIPT REQUESTED 7018 1130 0000 1612 5952
NC Department of Transportation
Attn: Michael A. Pettyjohn, Division 11 Engineer
P.O. Box 250
North Wilkesboro, NC 28659-0250
SUBJECT: Compliance Evaluation Inspection &
Notice of Violation with Intent to Enforce
Case #: NOV-2021-PC-0580
NC Individual NPDES Permit NC0029190
Surry County Rest Area
Surry County
Dear Mr. Pettyjohn:
Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office, met
with Jeremiah Harris, Backup Operator in Responsible Charge of the Surry County Rest Area
Wastewater Treatment Plant (WWTP), to perform a compliance evaluation inspection, on
November 9, 2021. Mr. Harris's assistance and cooperation are greatly appreciated. The attached
Water Compliance Inspection Report summarizes the findings of the inspection.
The inspection was prompted by missing discharge monitoring reports (DMR) dating back to
November 2020. Please note each missing DMR is a separate violation. In addition, there were
several other violations as enumerated in the attached inspection report.
Mr. Harris also indicated that the plant is about to undergo a major redesign/rehabilitation
project. He also indicated that the project should have already been completed but has been
delayed. Please note that an authorization to construct (AtC) permit may be required before this
project can be executed. Failure to obtain the necessary AtC permit is also a violation of the
permit. Please contact DWR's central office, NPDES permitting unit, to apply for and obtain all
required permits before executing this project. We cannot issue AtC permits from the regional
office.
NORTH
D E
Dopartmom of Envimnmomni au.i`
North Carolina Department of Environmental Quality Division of Water Resources
Winston-Salem Regional Office 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

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-
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. The Division is considering
taking enforcement action against NC DOT for the violations enumerated in this notice and the
accompanying inspection report.
Please reply to this notice in writing within 15 business days of receiving it. Your reply should
enumerate corrective actions, with implementation schedules and estimated completion dates,
for all violations listed in this notice and the accompanying inspection report. Failure to reply
within the specified time frame may result in enforcement action being taken.
If you have any questions or concerns, please do not hesitate to contact Mr. Boone by phone at
336-776-9690, or by email at [e-mail]. Thank you in advance for your time and
attention to this matter.
Sincerely,
DocuSiiggned by:by�
%A. l . c%n.idGf
145B49E225C94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Water Compliance Inspection Report
cc: 1. Laserfiche
2. NC DOT Division 11
Attn: Jamie Wood, Division 11 Roadside Engineer
P.O. Box 250
North Wilkesboro, NC 28659-0250
LD_E
NORTH CAROLINA
gapartmeM of Environmental quaky
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

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
Code
I 2
IL
NPDES yr/mo/day Inspection Type Inspector Fac
I 3 I NC0029190 111 121 21/11/09 117 1810I 19I S I 2011
Type
21IIIIII
IIIIIIIIIII
IIIIIII
I
IIIIII
IIIIIIIIIII
P6
Inspection
671
Work Days
Facility Self -Monitoring
I 70I
Evaluation Rating
I 711
B1
1
72
QA
I N I
73I
1
I I
Reserved
74 71
I
I I
I
I
I
180
Section B: Facility Data
Name
POTW
Surry
1-77
Mount
and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
name and NPDES Dermit Number)
County Rest Area
SE Of Lambsburg Va
Airy NC 27030
Entry Time/Date
09:OOAM 21/11/09
Permit Effective Date
19/06/01
Exit Time/Date
10:OOAM 21/11/09
Permit Expiration Date
24/02/29
Name(s)
///
Jeremiah
of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Claude Harris/ORC/336-903-9237/
Other Facility Data
Name,
Michael
Engineer//
Address of Responsible Official/Title/Phone and Fax Number
Contacted
A. Pettyjohn,PO Box 250 North Wilkesboro NC 286590250/Division 11
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)
Ron
r—DocuSigned
and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Boone DWR/WSRO WQ/336-776-9690/
by: 11/29/2021
Ori.aht YJOO,vei
Signature
B201-51JU51-2A34(iU
of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
FDocuSigned by:
L-e, T. SA,acr 11/29/2021
145B49E225C94EA...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page# 1

sI
NPDES yr/mo/day
NC0029190 111 121 21 /11 /09
I17
Inspection Type
18 [j
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Ron Boone, of the Winston-Salem Regional Office of the North Carolina Division of Water Resources
conducted a compliance evaluation inspection of the Surry County Rest Area wastewater treatment
plant on 11/9/2021. The assistance and cooperation of Jeremiah Harris, Backup ORC, was greatly
appreciated. The inspection findings are summarized below and within the following checklist:
According to Mr. Harris, and his boss, Jamie Woods, the former ORC for the plant abruptly retired
without warning or notice several months before the inspection and DOT was either not able to, or
not aware that they needed to, find and hire a new ORC to operate the plant and submit monitoring
reports. As such, no eDMRs for the facility have been submitted since November 2020. Mr. Harris
stated during the inspection that he had the former ORC's login and password for eDMR but did not
have appropriate authorizations/permissions to submit certified, completed eDMRs. Checking with
DWR's eDMR management post inspection, however, revealed that he does have the necessary
permissions for entering, certifying, and submitting eDMRs. However, he has not had any experience
doing so and his password for his account needed to be reset. DWR reset his password and he now
has permissions to load eDMRs as of 11/29/21.
The plant appeared to be operating well, although the inspector could not see inside the aeration,
settling, and digestion tanks well enough to evaluate the quality of the contents due to all tanks being
covered by grating that completely obscured view of the tank contents. Mr. Boone detected no
offensive odors or other trouble indicators and the plant appeared to be in fairly good condition. The
are four sand filters and the condition varied with regard to vegetation growth but none of the filters
were in operation at the time of the inspection. There was no ponding or offensive odors from the
filters, but two of the four filters had significant vegetation growth on them.
Laboratory records were not evaluated during the inspection due to there being no DMRs to evaluate
along side lab records. The backup ORC did indicate that the proper required samples have been
taken since the ORC departed. These records should be evaluated once the data is properly
submitted on eDMRs.
The outfall pipe is NOT accessible. It has not been accessed for a very long time (how long exactly is
unknown) and it is in a forest within very dense vegetation and would likely be very difficult to locate.
The effluent water appears to just dump onto the ground and travel over about 100' of land, which
may be wetland, before it reaches the receiving stream. The discharged water on the ground and the
stream itself appeared clean and of good quality. It was all clear and there were no offensive odors of
any kind.
Page# 2

Permit: NC0029190
Inspection Date: 11/09/2021
Owner - Facility: Surry County Rest Area
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 ❑ ❑ ❑
application?
Is the facility as described in the permit? • ❑ El El
# Are there any special conditions for the permit? El • El El
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑
Comment: None
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?
Yes No NA NE
❑ • ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
•
❑ • ❑ ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ • ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
Comment: There is currently no ORC assigned. eDMRs have not been submitted since November
2020 due to losing the ORC and failure to replace her.
Laboratory Yes No NA NE
Page# 3

Permit: NC0029190
Inspection Date: 11/09/2021
Owner - Facility: Surry County Rest Area
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?
Comment: Field laboratory certification needs verification.
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ • ❑
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ • ❑ ❑
Is sample collected below all treatment units? • ❑ ❑ ❑
Is proper volume collected? • ❑ El El
Is the tubing clean? • ❑ ❑ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 ■ El ❑ ❑
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type El El El •
representative)?
Comment: Records could not be fully evaluated during the inspection and eDMRs have not been
submitted since November 2020. Records will be reviewed once all missing eDMRs are
loaded in the system and inspector has access to finished eDMRs and laboratory
records.
Upstream / Downstream Sampling
Is the facility sampling performed as required by the permit (frequency, sampling type,
and sampling location)?
Comment: None
Flow Measurement - Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: Faciltiy water meter is used for flow estimation.
Yes No NA NE
• ❑ ❑ ❑
Yes No NA NE
❑ ❑ • ❑
Bar Screens Yes No NA NE
Page# 4

Permit: NC0029190
Inspection Date: 11/09/2021
Owner - Facility: Surry County Rest Area
Inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
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? ❑ ❑ El •
Is the unit in good condition? ❑ ❑ El •
Comment: There is a comminutor, not a bar screen. It appears to be in fairly good condition and
working properly.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Diffused
Is the basin free of dead spots? ❑ ❑ El •
Are surface aerators and mixers operational? El El El •
Are the diffusers operational? El El El •
Is the foam the proper color for the treatment process? El El El •
Does the foam cover less than 25% of the basin's surface? El El El •
Is the DO level acceptable? El El El •
Is the DO level acceptable?(1.0 to 3.0 mg/I) El El El •
Comment: Basins could not be completely evaluated due to being completely covered with grating
that obscured view of the contents. There were no odors or other indicators that the
basins were not operating properly.
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)?
Yes No NA NE
❑ ❑ ❑ •
❑ ❑ ❑ •
❑ ❑ ❑ •
Page# 5

Permit: NC0029190
Inspection Date: 11/09/2021
Owner - Facility: Surry County Rest Area
Inspection Type: Compliance Evaluation
Secondary Clarifier
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: Clarifiers could not be completely evaluated due to being completely covered with
grating that obscured view of the contents.
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
• ❑ ❑ ❑
Comment: There were no apparent operational issues with the sand filters. No adverse conditions
were noted and filters appear to be operating well.
Disinfection -Liquid
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
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: None
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ •
• ❑ ❑ ❑
❑ ❑ ❑ •
De -chlorination Yes No NA NE
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ El • El
Is storage appropriate for cylinders? ■ ❑ El ❑
# Is de -chlorination substance stored away from chlorine containers? • El El El
Are the tablets the proper size and type? • ❑ ❑ ❑
Comment: None
Are tablet de -chlorinators operational? • El El El
Number of tubes in use? 4
Page# 6

Permit: NC0029190
Inspection Date: 11/09/2021
Owner - Facility: Surry County Rest Area
Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
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: Discharge pipe is in the forest and heavily obscured by dense vegetation. It cvould not
be located. The discharge pipe should be located and the right-of-way to it properly
maintained in the future at all times, as required by the permit.
Aerobic Digester Yes No NA NE
Is the capacity adequate? ■ ❑ ❑ ❑
Is the mixing adequate? • ❑ El ❑
Is the site free of excessive foaming in the tank? • El El El
# Is the odor acceptable? ■ El ❑ ❑
# Is tankage available for properly waste sludge? ■ El El El
Comment: None
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • El El El
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable MI El ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: None
Page# 7