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HomeMy WebLinkAboutNC0080098_NOVNOI2021PC0633 & CEI Report_20220103 Certified Mail # 7020 1290 0001 1766 8859 Return Receipt Requested January 3, 2022 John Plain Linville Falls Club Property Association Inc 34 Blue Rdg Dr N Marion, NC 28752-7964 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2021-PC-0633 Permit No. NC0080098 Linville Falls Mountain Club and Preserve McDowell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Linville Falls Mountain Club and Preserve on December 14, 2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0080098. 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 _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Flow-proportional composite sampling is not being conducted. In order to continue using constant time/constant volume composite sampling, a formal request must be made. Part II. Section A. Composite Sample (4) - Constant time/constant volume: Use of this method requires approval by the Director. This method may only be used in situations where effluent flow rates vary by less than I5 percent. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64 A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility’s NPDES WW Permit. Pursuant to G.S. 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. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any additional information provided. You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. Remedial actions should have already been taken to correct this problem 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. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64 EPA United States Environmental Protection Agency 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 Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NC0080098 21/12/14 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Linville Falls Mountain Club and Preserve 17677 Hwy 221 N Marion NC 28752 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:15AM 21/12/14 20/07/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 12:15PM 21/12/14 24/12/31 Name, Address of Responsible Official/Title/Phone and Fax Number John Plain,34 Blue Rdg Dr N Marion NC 287527964//828-460-7377/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal Facility Site Review 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 Lauren E Armeni DWR/ARO WQ/828-296-4500/ Stephanie A Williams DWR/ARO WQ/828-296-4500/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64 1/3/2022 1/3/2022 DocuSign Envelope ID: FEF52A45-C294-4A04-BD71-0CA0C6243F94 1/3/2022 NPDES yr/mo/day 21/12/14 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni and Stephanie Williams, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Linville Falls Mountain Club and Preserve WWTP on December 14, 2021. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0080098. Juanita James (ORC) was present and assisted in the inspection. The system components consist of an influent flow meter, equalization tank, dual path aeration tanks and clarifiers run in parallel, tertiary filters, digester, chlorination and de-chlorination, and an effluent flow meter. The final permit issued July 1, 2020 does not list the digester as a component. Ms. James said this facility has always had a digester, so this component will need to be added to the list during the next permit renewal. During the inspection, Ms. James described some discrepancies with the well water usage and water entering the WWTP. This issue indicates a break in the water supply lines or collection system lines. Mr. Matt Lassiter came on the day of the inspection to calibrate the effluent flow meter and to determine if it was the issue. It was determined that the effluent flow meter was functioning properly. This issue also brings up the problem of not currently being able to locate all the sewer system manholes, as mentioned in the last inspection report for this deemed-permitted collection system. Ms. James said it was determined that the sewer lines were deeper than normal. It is recommended to locate the sewer system manholes and the cause of the flow discrepancy, whether it be water or wastewater related. Dechlorination: Following the second dechlorination, the treated wastewater enters a wet well until it triggers the float and is pumped through the effluent pipe to surface water. This wet well is equipped with an audible/visual alarm. The alarm could not be tested during the inspection because the lids were too heavy to lift by hand. Effluent Sampling: There was no thermometer in the effluent composite sampler at the time of the inspection. On December 29, 2021, Ms. James emailed Ms. Armeni a picture of a thermometer inside the sampler. Additionally, flow-proportional composite sampling has not been used since at least the last inspection in 2017, where an NOV/NOI and CPA were issued for the same reason. Instead, constant time/ constant volume composite sampling is being performed. A formal request to continue conducting constant time/constant volume composite sampling must be made to the Regional Supervisor and Assistant Regional Supervisor. The following violation was noted during the inspection: 1. Flow-proportional composite sampling is not being conducted. In order to continue using constant time/constant volume composite sampling, a formal request must be made. NC0080098 17 (Cont.) Page#2 DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64DocuSign Envelope ID: FEF52A45-C294-4A04-BD71-0CA0C6243F94 Permit:NC0080098 Inspection Date:12/14/2021 Owner - Facility: Inspection Type: Linville Falls Mountain Club and Preserve 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? # 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? The permit became effective on July 1, 2020 and expires on December 31, 2024. See summary for details regarding system components. Comment: Operations & Maintenance Yes No NA NE 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? Process controls used include settleability, pH, DO, as well as MLSS and a microscope for bacteria as needed. Comment: Record Keeping Yes No NA NE 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? Page#3 DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64DocuSign Envelope ID: FEF52A45-C294-4A04-BD71-0CA0C6243F94 Permit:NC0080098 Inspection Date:12/14/2021 Owner - Facility: Inspection Type: Linville Falls Mountain Club and Preserve Compliance Evaluation Record Keeping Yes No NA NE 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: Equalization Basins Yes No NA NE 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? The EQ basin does not have audible or visual alarms; however, Ms. James said the basin cannot overflow and that excess wastewater will pass through due to the design. Comment: 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/l) Settleability was at 28% after 30 minutes with visible pin floc in the supernatant. Ms. James said they were going to waste soon since this is an indication of old sludge. Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Page#4 DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64DocuSign Envelope ID: FEF52A45-C294-4A04-BD71-0CA0C6243F94 Permit:NC0080098 Inspection Date:12/14/2021 Owner - Facility: Inspection Type: Linville Falls Mountain Club and Preserve Compliance Evaluation Secondary Clarifier Yes No NA NE 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 ¼ of the sidewall depth) Clarifier #1 and #2 had a 3-foot sludge blanket in a 9-foot clarifier.Comment: Aerobic Digester Yes No NA NE 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? Sludge is wasted to the digester approximately every 5-6 weeks (every 4 weeks in the warmer months) for a period of 1-2 days. The digester is pumped approximately every 18 months. Comment: Filtration (High Rate Tertiary)Yes No NA NE Type of operation:Down flow Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? The tertiary filters could not be seen directly underwater and therefore could not be fully evaluated. The filters are backwashed every day and the backwash water goes into the adjacent mud well, which is then pumped to the headworks of the plant. Comment: Disinfection-Tablet Yes No NA NE Are tablet chlorinators operational? Page#5 DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64DocuSign Envelope ID: FEF52A45-C294-4A04-BD71-0CA0C6243F94 Permit:NC0080098 Inspection Date:12/14/2021 Owner - Facility: Inspection Type: Linville Falls Mountain Club and Preserve Compliance Evaluation Disinfection-Tablet Yes No NA NE Are the tablets the proper size and type? Number of tubes in use?4 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? Disinfection occurrs prior to tertiary filtration. The chlorine contact chamber is pumped out when the digester is pumped. Comment: De-chlorination Yes No NA NE Type of system ?Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? # Is de-chlorination substance stored away from chlorine containers? Are the tablets the proper size and type? Chlorination tablets are stored next to the de-chlorination tablets. It is recommended to store them away from each other. Comment: Are tablet de-chlorinators operational? Number of tubes in use?2 De-chlorination occurs before and after tertiary filtration. See summary for details.Comment: Flow Measurement - Effluent Yes No NA NE # 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? The effluent flow meter was last calibrated on September 13, 2021 by Laboratory Instrument Service. There is a chart recorder, but it is not connected to the flow meter. Flow is manually recorded daily. Comment: Effluent Pipe Yes No NA NE 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? Comment: Page#6 DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64DocuSign Envelope ID: FEF52A45-C294-4A04-BD71-0CA0C6243F94 Permit:NC0080098 Inspection Date:12/14/2021 Owner - Facility: Inspection Type: Linville Falls Mountain Club and Preserve Compliance Evaluation 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)? A new sampler was installed in June 2021. Constant time/constant volume composite sampling is being performed, as it has been in the past. There was no thermometer in the sampler at the time of the inspection. See summary for details. Comment: Standby Power Yes No NA NE 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? The generator is exercised weekly and under load when the plant is running at the same time. The facility has a service contract with a company that comes twice a year to assess and test the generator. When the propane tank is around 50%, a company is called to refill it. Comment: Page#7 DocuSign Envelope ID: A1849623-2B9F-4613-BFA9-F75A23FEAF64DocuSign Envelope ID: FEF52A45-C294-4A04-BD71-0CA0C6243F94