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HomeMy WebLinkAboutNC0065358_NOI_NOV2022PC0647_20221013ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality CERTIFIED MAIL 7020 3160 0002 0860 8041 RETURN RECEIPT REQUESTED October 131h, 2022 S I P Hidden Forest LLC Attn: Sean Dyer, Owner 665 Hancock Street, Suite 3 Quincy, MA 02170-2868 Subiect: Compliance Evaluation Inspection & Notice of Violation with Intent to Enforce NOV Tracking #: NOV-2022-PC-0647 Hidden Forest Estates Wastewater Treatment Plant NPDES Permit: NCO065358 Randolph County Dear Mr. Dyer: Ron Boone of the North Carolina Division of Water Resources (NCDWR) Winston-Salem Regional Office (WSRO) conducted a compliance evaluation inspection of the Hidden Forest Estates Wastewater Treatment Plant on September 21st, 2022. Anthony Montero, Travis Sherrard, and Kyle Dimario were present for the inspection. The determined permit violations are listed below, and inspection findings are detailed in the attached Water Compliance Inspection Report. PERMIT VIOLATIONS 1. Composite sampling is NOT flow proportional. 2. Records pre -April 2022, when the current operator assumed operations, are not available. 3. Insufficient operation and maintenance: plant has severe corrosion, multiple components not in operation, and several temporary repair measures. 4. Only one operator is designated, and he no longer works there. 5. The outfall is completely inaccessible, and its location is unknown. 6. The plant's security fence is compromised, and it is not surrounding the entire facility. 7. The permanent onsite generator is NOT operational. Please be aware that the Division may take enforcement action against any individual who fails to comply with the requirements of all applicable permits, regulations, and/or statutes. 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 D North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 Moan caaouNn 336.776.9800 oep.m.m or em�nmen� Qualm, with the terms, conditions, or requirements of any permit, or applicable regulations, issued pursuant to G.S. 143-215.1. Please reply, in writing, to this notice of violation, with 10 days of receiving it. Your written response must address each violation listed above and in the attached compliance inspection report and provide your intended remedial actions, with estimated completion dates, for each violation. You will then be expected to make all the necessary corrective actions to achieve full compliance within 90 days of receiving the notice. Failure to do so will result in further enforcement actions. 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 ron.boone@ncdenrgov. Thank you in advance for your time and attention to this matter. Sincerely, DocuSiTgned by: %A. l . 5,,. Gr -4'ME225CMEA... 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, NCO065358 NORTH CAROLINAD E Q oeo+ro�.m m F,mro.��w n�si� North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 336.776.9800 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report 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 IN 1 2 u 3 I NC0065358 111 121 22/09/21 I17 18 LC] I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I ni I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Dermit Number) 01:OOPM 22/09/21 16/10/01 Hidden Forest Estates WWTP 6602 Holder Inman Rd Ext Exit Time/Date Permit Expiration Date Randleman NC 27317 04:OOPM 22/09/21 21/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Paul Matthew Smith,235 Richardson Rd Reidsville NC 27320//336-932-9347/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispo: Facility 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/ Docusigned by: 10/13/2022 �Ori.GCG,G�. YJOOfLPi F9BBr 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# NPDES yr/mo/day Inspection Type NCO065358 I11 12I 22/09/21 117 18 i c i (Cont.) 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 (WSRO), conducted a compliance evaluation inspection of the Hidden Forest Estates wastewater treatment plant on September 21st, 2022. Anthony Montero, Travis Sherrard, and Kyle DiMario, were present for the inspection. Inspection findings are detailed below and in the following inspection checklist: 1. Composite sampling is NOT flow proportional, as required. 2. Records for the facility only go back to April 2022, when the new operator took over operations. All records must be kept for a minimum of 3 years, but analytical records must be kept for a minimum of five years. The owner MUST keep all such records for the minimums specified above and MUST arrange for transfer of all records to him/herself for permanent storage. 3. The operators have NOT been properly designated as required. Gary Moore is the ONLY designated operator, but he is no longer operating the plant. 4. The plant is in poor condition. There is severe corrosion over the entirety of the plant and in some places it has compromised the structural integrity of the plant. In some areas the corrosion has eaten all the way through the structure, such as the round equalization basin. The holes in this tank would allow it to overflow onto the ground surface, and possibly to surface waters, before it reaches the tanks overflow rim. The walkway grates have very little support in several areas of the walkways, making them an extreme safety hazard. It appears that several holes have been repaired in pipes that connect components and processes throughout the plant using only temporary black rubber couplings. These repairs should be made permanent. The round clarifier's weir is severely corroded and is separating into layers. All such corrosion should be fully removed, and repairs properly made. Proper corrosion prevention should be installed to protect the entire plant structure. 5. The outfall was NOT visited during the inspection. Operators stated post inspection that they were told by the owner that the outfall is underwater somewhere but could NOT be specific where it is. On the other hand, historical permit and inspection records indicate the outfall is located somewhere west of 1-73. The outfall MUST be located and properly documented. 6. The security fence does NOT surround the entire facility. 7. The onsite permanent generator is NOT functional. 8. The equalization basin's pumps were both NOT operational during the inspection. The current operators rigged up a single airlift to convey wastewater to the plant from the equalization basin. The basin's level detection and alarm systems are NOT operational. Page# Permit: NCO065358 Inspection Date: 09/21/2022 Owner -Facility: Hidden Forest Estates WWTP Inspection Type: Compliance Evaluation Permit (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 fence does NOT completely surround the facility. 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 ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ EIN ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: Records for the facility only qo back to April 2022, when the new operator took over operations. All records must be kept for a minimum of 3 years, but analytical records must be kept for a minimum of five years. The owner MUST keep all such records for the minimums specified above and MUST arrange for transfer of all records to him/herself for permanent storage. Page# 3 Permit: NCO065358 Owner -Facility: Hidden Forest Estates WWTP Inspection Date: 09/21/2022 Inspection Type: Compliance Evaluation Laboratory Yes No NA NE 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 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: Composite sampling is NOT flow proportional. 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? ❑ ❑ ❑ ■ Comment: None 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? ■ ❑ ❑ ❑ Page# 4 Permit: NCO065358 Inspection Date: 09/21/2022 Bar Screens Is the unit in good condition? Comment: Severe corrosion. Owner -Facility: Hidden Forest Estates WWTP Inspection Type: Compliance Evaluation 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? Yes No NA NE ❑ ■ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ Comment: Severe corrosion. There are holes in the sides of the tank which would make it overflow before it got to the top. Not all pumps are operational. Level detection and alarms are NOT operational. Aeration Basins Mode of operation Type of aeration system 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/1) Comment: Severe corrosion. Not enough support for walkways. Extremely dangerous. 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? Yes No NA NE Ext. Air Diffused ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 5 Permit: NC0065358 Inspection Date: 09/21/2022 Owner -Facility: Hidden Forest Estates WWTP Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ 0 ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) ❑ ❑ ❑ Comment: Severe corrosion. Not enouqh support for walkways. Extremely danqerous. Weirs are separating into lavers. There are several temporary black rubber repair couplings installed in the plant connecting the various tanks and processes. A permanent repair should be made in place of these temporary couplings. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? 0 ❑ ❑ ❑ Comment: None Filtration (High Rate Tertiary) Type of operation: 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? Comment: Filters must recently placed back in operation by new operators. Disinfection - UV Are extra UV bulbs available on site? Are UV bulbs clean? Is UV intensity adequate? Is transmittance at or above designed level? Is there a backup system on site? Is effluent clear and free of solids? Yes No NA NE Up flow ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 6 Permit: NCO065358 Owner -Facility: Hidden Forest Estates WWTP Inspection Date: 09/21/2022 Inspection Type: Compliance Evaluation Disinfection - UV Yes No NA NE Comment: Chlorine and dechlorination tablets are backup disinfection source. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ 0 ❑ ❑ 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: Location of outfall is unknown. Aerobic Digester Yes No NA NE Is the capacity adequate? ■ ❑ ❑ ❑ Is the mixing adequate? ■ ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: None Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ Is the generator tested by interrupting primary power source? ❑ 0 ❑ ❑ Is the generator tested under load? ❑ ■ ❑ ❑ Was generator tested & operational during the inspection? ❑ 0 ❑ ❑ 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? ❑ ■ ❑ ❑ Comment: Generator is NOT operational. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: None Page# 7