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Home My WebLink AboutNC0025836_NOV2022PC0137 & CEI Report_20220321 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. March 21, 2022 Abigail Norton, Mayor Town of Hot Springs Email: mayor@townofhotsprings.org SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2022-PC-0137 Permit No. NC0025836 Hot Springs WWTP Madison County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Hot Springs WWTP on March 1, 2022. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0025836. 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 _________________________________________________________________________________________________________________________________________________________________________ Disinfection and de-chlorination Chemicals are stored outside with no secondary containment. _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Effluent sampling is not flow proportional. _________________________________________________________________________________________________________________________________________________________________________ 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. 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. DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD If you should have any questions, please do not hesitate to contact Stephanie Williams with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Juanita James (ORC) DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD 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 NC0025836 22/03/01 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) Hot Springs WWTP Bridge St Hot Springs NC 28743 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 09:30AM 22/03/01 21/06/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 12:00PM 22/03/01 25/09/30 Name, Address of Responsible Official/Title/Phone and Fax Number Randy A Joseph,PO Box 218 Hot Springs NC 287430218//828-622-7591/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program 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: 585F0123-F68F-4203-A5CF-46F9060812DD 3/21/2022 3/21/2022 3/21/2022 NPDES yr/mo/day 22/03/01 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Stephanie Williams and Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Hot Springs WWTP on March 1, 2022. This inspection was conducted to determine if the system is being operated and maintained in compliance with NPDES permit no. NC0025836. Juanita James (ORC), Jeremy Trantham (maintenance/BORC), and Cody Fisher (maintenance) were present during the inspection. The WWTP is permitted for a flow of 80,000 GPD and consists of a manual influent bar screen, a large aeration basin, a secondary clarifier, and liquid chlorination and dechlorination. The town recently contracted James and James Environmental to take over operations following the retirement of the previous ORC. James and James took over operations of both the WWTP and the Collection System on January 14th and have since made several operational changes. Operations & maintenance: James and James serviced the motors and blowers in the plant. Aeration Basin: The 30-minute settleability was 49% on the right side of the aeration basin and 39% on the left side. Historically, this WWTP has had problems with the return lines splashing sludge into the air and onto the carwalk. Since take over operations, James and James has weighted the valves on the return line, which prevents sludge from splashing into the air. The air header on the left side of the aeration basin has been changed and new valves were added on the right side. Secondary Clarifier: In an 11-foot clarifier there was a 2.5-foot blanket and 7.5 feet of clear supernatant. Two loads of sludge have been pumped from the clarifier since the middle of January. Chlorination and Dechlorination: The existing chemical storage building needs repair and is not suitable for storing chemicals. Ms. James is planning on repairing the chemical storage building. Chemicals are stored outside in the meantime. No secondary containment was noted. Additionally, since taking over operations, Ms. James has significantly increased the dechlorination dosage to match the chlorine dose. Flow Meter: The flow meter was out of calibration when James and James took over operations of the plant, and the meter has since been changed and calibrated. Effluent sampling: James and James repaired the composite sampler after taking over operations. The sampler was previously not in use, and it is unclear how long the sampler had not been in use. Effluent sampling is currently time-based. According to Ms. James, the sampler is wired for flow proportional sampling, but the sampler seems to not be pulling the aliquot correctly. She stated that they would change to flow proportional sampling when they connect the sampler to the flow meter. The following violations were noted during the inspection: 1. Chlorination and Dechlorination: Chemical storage is inadequate. 2. Effluent sampling: Effluent sampling is not flow proportional. NC0025836 17 (Cont.) Page#2 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Permit:NC0025836 Inspection Date:03/01/2022 Owner - Facility: Inspection Type: Hot Springs WWTP 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 current permit became effective on 6/1/2021 and expires on 9/30/2025.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 analyzed include pH and DO.Comment: 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? Is the unit in good condition? The bar screen is cleaned daily.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? Page#3 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Permit:NC0025836 Inspection Date:03/01/2022 Owner - Facility: Inspection Type: Hot Springs WWTP Compliance Evaluation Aeration Basins Yes No NA NE Is the DO level acceptable?(1.0 to 3.0 mg/l) Ms. James stated that on average the DO is kept at 2.8 mg/L on average. The 30-minute settleability was 49% on the right side of the aeration basin and 39% on the left side. An air header and some valving has been changed in the aeration basin, and the return valves have been weighted shut. See summary for details. 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? 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) The sludge blanked was 2.5 feet with 7.5 feet of clear supernatant in an 11 foot clarifier. See summary for details. Comment: Disinfection-Liquid Yes No NA NE 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? Chemicals are stored outside with no secondary containment. See summary for details.Comment: De-chlorination Yes No NA NE Type of system ?Liquid 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? Page#4 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD Permit:NC0025836 Inspection Date:03/01/2022 Owner - Facility: Inspection Type: Hot Springs WWTP Compliance Evaluation De-chlorination Yes No NA NE Comment: Are the tablets the proper size and type? Are tablet de-chlorinators operational? Number of tubes in use? Chemicals are temporarily being stored outside with no secondary containment. The ORC anticipates rebuilding the chemical storage area in order to store the chemicals indoors. Since James and James took over operations, staff has significantly increased dechlorination feed to match the chlorine feed. 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 flow meter was out of calibration when James and James took over operations. A new flow meter has been installed and calibrated. Comment: 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)? Effluent sampling is not flow proportional. See summary for details.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#5 DocuSign Envelope ID: 585F0123-F68F-4203-A5CF-46F9060812DD