NC0022691_NOV2022PC0062_20220222

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
February 22, 2022
Yes Af Utilities Exp LLC
Attn:, Karen E. Hamilton, Operations Vice President
5050 South Syracuse Street, Suite 1200
Denver, CO 80237
SUBJECT: Compliance Evaluation Inspection & Notice of Violation: NOV-2022-PC-0062
Autumn Forest Wastewater Treatment Plant
NPDES Permit Number NC0022691
Guilford County
Dear Ms. Hamilton:
Mr. Ron Boone, of the NC Division of Water Resources (NCDWR), Winston-Salem Regional
Office (WSRO), conducted a compliance evaluation inspection of the Autumn Forest wastewater
treatment plant, on February 10, 2022. Mr. Boone met with Anthony Montero, Operator in
Responsible Charge. His assistance and cooperation were greatly appreciated. Inspection findings
are detailed in the attached Water Compliance Inspection Report and summarized below.
All permit required documentation was readily available, complete, and current. The plant itself
appeared clean but could use some maintenance to address ongoing natural degradation of the
plant and equipment.
This office is issuing a Notice of Violation for this inspection due to the utilization of an
unapproved sampling regime at the facility without proper authorization. The permit requires that
whenever composite samples are collected, flow proportional sampling must be used unless the
requirement is waived by the Division Director in writing. The facility currently employs a
constant time/constant volume (CT/CV) sampling regime. The Autumn Forest facility was also
inspected in August 2018, and this same finding was noted then. A Notice of Deficiency was issued
at that time for the same violation. Please contact Mr. Boone when the flow sampling regime has
been changed to flow proportional so a follow-up inspection can be scheduled. Yes should have
this requirement completed within 60 days of receipt of this letter.
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.
NORTH
D E
D.o.rtm.m of ln.im.mo.t.i Ou.i`
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

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,
LItH
uSigned by:by�
1.
B49E225C94EA...
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
2. Anthony Montero, Cardinal Water, Inc, via email
cc: Laserfiche
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 NC0022691 111 121 22/02/10 117 18110 19I S I 201
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
I
I I
Reserved
74 71
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 oermit Number)
Autumn Forest MHC WWTP
3700 Autumn Forest Dr
Browns Summit NC 27214
Entry Time/Date
09:15AM 22/02/10
Permit Effective Date
22/01/01
Exit Time/Date
10:15AM 22/02/10
Permit Expiration Date
26/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Anthony Oscar Montero/ORC/336-433-7221/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Shannon Zohn,5050 S Syracuse St Ste 1200 Denver CO 80237///
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) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boone DWR/WSRO WQ/336-776-9690/
1- DocuSigned by:
O01..a et Boone. 2/21/2022
RWnFRMSF7AMAII
Signature of Management
Q A Reviewer Agency/Office/Phone and Fax Numbers Date
FDocuSigned by:
L-eti T• SA,acr 2/21/2022
145B49E225C94EA...
EPA Form 3560-3 Rev 9-94) Previous editions are obsolete.
Page# 1

31
NPDES yr/mo/day
N C 0022691 111 121 22/02/10
117
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 NC Division of Water Resources (DWR), Winston-Salem Regional Office, met with
Anthony Montero, Operator in Responsible Charge of the Autumn Forest WWTP, to perform a
compliance evaluation inspection on February 10, 2022. His assistance and cooperation was greatly
appreciated.
The inspection findings are summarized below and in the following checklist.
The plant appears well operated by Mr. Montero. The plant is quite old and is in need of
update/reconditioning in many areas. The plant structure has a lot of corrosion and some of the
components, such as the aeration and return lines, seem haphazard or temporary in nature. They
are, however, performing their intended function.
Mr. Montero mentioned that the plant is scheduled to undergo limited reconditioning sometime soon.
We hope this effort improves operations and maintenance of the plant. Mr. Montero, as operator,
may not be required by his contract to perform the needed maintenance. Please bear this in mind in
the future, especially after the plant is reconditioned. The plant is constructed of metal and is, for the
most part, outside, constantly exposed to the elements. Yes may consider enlisting the help additional
personnel specifically responsible for plant maintenance.
Also, if reconditioning changes the plant's processes in any way, an authorization to construct (AtC)
permit may be required. Please contact us if you are uncertain if the AtC is required.
Mr. Montero's records of analytical monitoring, as well as operations, were complete and current.
Please also be aware the plant operational records must be kept for three years and analytical
records must be kept for 5 years. This is Yes's responsibility and Yes must have these records on file
for the stated time periods even if the operator changes.
Only one train of the plant is currently in operation. The only violation noted during the inspection is
that the effluent sampler is collecting samples based on a constant time/constant volume basis. Yes is
not authorized to use this sampling regime without a approval from the Division. Yes must either
request a waiver or immediately begin collecting flow proportional samples as specified by the permit.
The absence of flow proportional sampling was also noted in the previous inspection in 2018 and Yes
was then issued a Notice of Deficiency. Because this is the second time this issue was brought to
your attention and you were asked three years ago to begin sampling via flow proportional sampling,
we're now elevating this case to a Notice of Violation.
Mr. Montero presented sludge pumping records for the past year. This is another example of records
that Yes must also maintain in their possession.
No other deficiencies or violations were noted.
Page# 2

Permit: NC0022691
Inspection Date: 02/10/2022
Owner - Facility: Autumn Forest MHC WWTP
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 El El ❑
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: None
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: None
Influent Sampling
# Is composite sampling flow proportional?
Is sample collected above side streams?
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 sampling performed according to the permit?
Comment: No influent sampling required.
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ ❑ • ❑
❑ ❑ • ❑
Yes No NA NE
❑ • ❑ ❑
Page# 3

Permit: NC0022691
Inspection Date: 02/10/2022
Owner - Facility: Autumn Forest MHC WWTP
Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
# 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: Not flow proportional. Please remedy this as soon as possible or request a waiver in
writing.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, ■ El El El
and sampling location)?
Comment: None
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? • ❑ ❑ ❑
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: None
Page# 4

Permit: NC0022691
Inspection Date: 02/10/2022
Owner - Facility: Autumn Forest MHC WWTP
Inspection Type: Compliance Evaluation
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?
Comment: None
Yes No NA NE
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
• ❑ • ❑
• ❑ ❑ ❑
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 appears good quality. No offensive odors and well aerated and agitated.
Page# 5

Permit: NC0022691
Inspection Date: 02/10/2022
Owner - Facility: Autumn Forest MHC WWTP
Inspection Type: Compliance Evaluation
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'/4 of the sidewall depth)
Comment: None
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment: None
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ • ❑
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
Disinfection -Tablet Yes No NA NE
Are tablet chlorinators operational? • ❑ ❑ ❑
Are the tablets the proper size and type? • ❑ ❑ ❑
Number of tubes in use? 3
Is the level of chlorine residual acceptable? El El El •
Is the contact chamber free of growth, or sludge buildup? • El El El
Is there chlorine residual prior to de -chlorination? ❑ El ❑ •
Comment: None
De -chlorination Yes No NA NE
Type of system ? Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)? El • El El
Is storage appropriate for cylinders? ■ El El El
# Is de -chlorination substance stored away from chlorine containers? • ❑ ❑ ❑
Page# 6

Permit: NC0022691
Inspection Date: 02/10/2022
Owner - Facility: Autumn Forest MHC WWTP
Inspection Type: Compliance Evaluation
De -chlorination Yes No NA NE
Are the tablets the proper size and type? • ❑ ❑ ❑
Comment: None
Are tablet de -chlorinators operational? • ❑ ❑ ❑
Number of tubes in use? 2
Comment: None
Flow Measurement - Effluent
# 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: Meter and recorder is a single unit. Meter due for calibration March 2022.
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?
Comment: None
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ • ❑
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 MODE
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: None
Page# 7