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HomeMy WebLinkAboutNC0022497_Compliance Evaluation Inspection_20220719ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director CERTIFIED MAIL #:7018 3090 0001 2323 0461 RETURN RECEIPT REQUESTED; Donna Day, Manager Cross Country Campground 6254 NC Hwy. 150 East Denver, NC 28037 SUBJECT: Notice of Violation Compliance Evaluation Inspection Cross Country Campground WWTP NPDES Permit No. NC0022497 Catawba County Tracking #: NOV-2022-PC-0384 Dear Ms. Day: NORTH CAROLINA Environmental Quality July 19, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on July 6, 2022, by Mr. Wes Bell of this Office. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding the enclosed report. This report is being issued as a Notice of Violation (NOV) due to the following: - The composite sampler refrigerator was not operating properly; - Excessive wastewater solids observed in the influent manhole prior to aeration basin; - Excessive wastewater solids (including denitrification) observed in clarifier; - Excessive wastewater solids (including denitrification) observed in chlorine contact chamber; - Diffusers in aeration basins needed repair/replacement. Please be advised that the failure to provide proper operation and maintenance is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1. Please note that G.S. 143-215.6A provides for a civil penalty of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, 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. Penalties may also be assessed for any damage to surface waters of the State that may result from the violation. D_E 111.•rhworkt el G. rOrmloalal o � North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 As discussed in the inspection report, the permittee has never placed into operation a flow equalization tank. In addition, the permittee would have to initiate substantial construction activities to convey all wastewater into the equalization tank. Therefore, the permittee must either submit a request to the Division to remove the flow equalization tank from the Permit or place the equalization tank into service with all influent flows being initially conveyed into this treatment unit. This Office is concerned with the wastewater treatment plant's listed design/flow capacity (0.065 MGD) if the flow equalization tank is removed as a treatment unit. If it is the permittee's intent to remove the flow equalization tank as a treatment unit, then this Office requests that the permittee contract a professional engineer licensed in North Carolina to evaluate the design/flow capacity of the wastewater treatment facility without flow equalization. Once this evaluation is performed and submitted, this Office will review the documentation and provide you with additional guidance. It is requested that a written response be submitted to this Office by August 9, 2022, detailing the actions taken to address all violations and maintenance issues discussed in this report. The response should also include the decision that will be made on the flow equalization tank. If an engineering evaluation is performed to determine the facility's design/flow capacity without flow equalization, then the evaluation should be submitted to this Office by October 31, 2022. In responding, please address your comments to the attention of Mr. Wes Bell. Should you have any questions concerning this Notice, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell@ncdenr.gov. Sincerely, ,—DocuSigned by: `—A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche 'D_EQ� North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 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 Code 1 IN I 2 I5 21 1 1 1 1 NPDES yr/mo/day Inspection I 3 I NC0022497 111 121 22/07/06 117 Type 18 i i I I 1 1 1 Inspector Fac Type 191 S I 201 1 1 1 1 1 11 1 1 1 I I I 1 1 1 1 1 1 I I I I I 1 11 1 1 1 I 1 P6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67I2.0 I 70I4 I 71IN I 72 I N I 731 I 74 751 I I 1 I I I I I I 180 l Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES oermit Number) Cross Country Campground 6254 NC Hwy 150 E Denver NC 28037 Entry Time/Date 10:OOAM 22/07/06 Permit Effective Date 21/01/01 Exit Time/Date 11:10AM 22/07/06 Permit Expiration Date 25/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Dustin Kyle Metreyeon/ORC/704-506-4255/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Donna Day,6254 NC Hwy 150 E Denver NC 28037//704-483-5897/ 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) Wes Bell of Inspector(s) Agency/Office/Phone and Fax Numbers Date �Docusigned by: DWR/MRO WQ/704-663-1699 Ext.2192/ 1oer Bat7/19/2022 "-A61696D90CC3437... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger DWR/Division of Water Quality/704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuSigned by: 7/19/2022 "-A14CC681AF27425... Page# 1 3I NPDES yr/mo/day N C 0022497 I11 121 22/07/06 17 Inspection Type 18 [j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) RECORD KEEPING SECTION cont'd: The ORC maintains visitations and operational data for multiple facilities in one notebook. The ORC must document all visitations and operation and maintenance activities in a log book at the system as required by 15A North Carolina Administrative Code (NCAC) 8G .0204(5). The ORC must also ensure to notify the system owners of any system repairs and/or modifications that may be necessary to achieve compliance of the system with all local, State, and federal environmental permitting and regulatory requirements as required by 15A NCAC 8G .0204(7). The permittee must ensure that all maintenance activities performed by on -site staff are documented and are accessible for review by the ORC and Division personnel. Page# 2 Permit: NC0022497 Inspection Date: 07/06/2022 Owner - Facility: Cross Country Campground 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? • ❑ ❑ ❑ # 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: The last compliance evaluation inspection at this facility was performed by DWR staff on 10/23/18. Overall, the facility is adequately described in the permit except for the listed flow equalization tank. Although constructed, the flow equalization tank has never been placed into service and would require substantial construction activities to convey all wastewater into the equalization tank. 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? ❑ ❑ • ❑ Page# 3 Permit: NC0022497 Inspection Date: 07/06/2022 Owner - Facility: Cross Country Campground Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: Discharge Monitoring Reports (eDMRs) were reviewed for the of May 2021 through April 2022. No effluent limit violations were reported. The December 2021 and January through March 2022 eDMRs were submitted late. The Division has previously addressed these violations through the issuances of a Notice of Deficiency (NOD), Notice of Violation (NOV) and NOV/civil penalty assessments. Please see "Summary" Section for additional comments. 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: On -site field analyses (dissolved oxygen, pH, TRC, temperature) are performed under Metwater, Inc.'s field laboratory certification #5615. Water Tech Labs has been contracted to provide analytical support for all permit -required parameters except field. Post calibration checks on the dissolved oxygen, pH and total residual chlorine meters had not been performed. The ORC must ensure that post calibration checks are performed (and documented) at the end of the sampling day if these meters are used to perform effluent analyses at multiple facilities. 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: The subject permit requires composite and grab effluent samples. The refrigeration unit used for composite sampling was not operating properly (not cooling) at the time of the inspection. The refrigeration unit must be either repaired or replaced to ensure samples are being properly preserved throughout the 24-hr. period at less than or equal to six degrees Celsius. The ORC should perform and document periodic sampler verifications (recommend weekly) to ensure a minimum of 100 ml. per aliquot is being collected. Upstream / Downstream Sampling Yes No NA NE Page# 4 Permit: NC0022497 Inspection Date: 07/06/2022 Owner - Facility: Cross Country Campground Inspection Type: Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, • ❑ ❑ ❑ and sampling location)? 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? Comment: Process control measurements have been performed in the past; however, not frequently. The ORC and staff should initiate (and document) a consistent process control program (settleability tests, pH, dissolved oxygen, etc.) to ensure proper facility operation at all times. Operational issues were noted during the inspection as discussed further in the Aeration Basin, Secondary Clarifier and Disinfection -Tablet Sections. Please be advised that the subject NPDES Permit requires the permittee to properly operate and maintain the facility at all times [Permit Condition Reference: Part II, Section C(2) Proper Operation and Maintenance]. 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? • 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 Is the DO level acceptable?(1.0 to 3.0 mg/I) • El El El Comment: The influent manhole prior to the aeration basins contained an excessive mat of wastewater solids. The wastewater solids should be removed and properly disposed. The settleability test performed during the inspection was 200 mL/L with a turbid supernate. The results of the settleability test and the dark brown appearance of the aeration basins are indicative of an older biomass. The ORC and permittee must ensure an adequate wasting program is implemented and documented. Multiple diffusers appeared to need repair and/or replacement. All diffusers should be evaluated and repaired and/or replaced if needed. 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? Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ Page# 5 Permit: NC0022497 Inspection Date: 07/06/2022 Owner - Facility: Cross Country Campground Inspection Type: 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? El • El El Is the drive unit operational? ❑ El • El 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) El El El • Comment: Excessive floating sludge (and denitrification) was observed in the clarifier. The skimming system also has had periodic operational issues. The permittee and ORC must ensure that the return activated sludge (RAS) and skimming systems are properly operated and maintained at all times. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? 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? Yes No NA NE • ❑ ❑ ❑ II ❑ ❑ ❑ 1 • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Excessive floating wastewater solids (and denitrification) was occurring the chlorine contact chamber. The wastewater solids should be monitored in the chlorine contact chamber and removed to prevent this condition from recurring. 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? El El • ❑ # Is de -chlorination substance stored away from chlorine containers? El El • El Comment: Are the tablets the proper size and type? • ❑ ❑ ❑ Are tablet de -chlorinators operational? ■ El El El Number of tubes in use? 1 Page# 6 Permit: NC0022497 Inspection Date: 07/06/2022 Owner - Facility: Cross Country Campground Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE Comment: 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ Comment: The flow meter is calibrated annually and was last calibrated on 6/13/22 by Horizon Engineering & Consulting, Inc. 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: The effluent appeared clear with no floatable solids or foam. The receiving stream was turbid due to previous rainfall event and therefore, no evaluations of the stream were performed. Page# 7