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HomeMy WebLinkAboutNC0036692_NOD2023PC0044 & CEI Report_20230131 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. January 31, 2023 Larry Spelts, Member Mid Century Revitalization LLC Email: lspelts@theindigoroad.com SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2023-PC-0044 Permit No. NC0036692 Skyline Lodge & Village WWTP Macon County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Skyline Lodge & Village WWTP on January 17, 2023. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0036692. 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 deficiencies were noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Permit There is not a lock on the clasp to the door housing the aeration basin and se condary Clarifier; therefore, access is not restricted to the general public. It is recommended that the clasp be locked to restrict access. _________________________________________________________________________________________________________________________________________________________________________ Disinfection-Tablet The chlorine contact chamber cover is cracked, and it is recommended that it be repaired or replaced as it is currently a safety hazard. Additionally, it is not fenced in and is therefore accessible to the general public. It is recommended that the chlorine contact chamber be fenced in. _________________________________________________________________________________________________________________________________________________________________________ Sand Filters (Low rate) At the time of the inspection, excessive water was present on the surface of the sand filter. Additionally, the structural support for one of the filter distributor arms has failed, which was noted in the 2018 inspection report and was never addressed. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 In addition, the issues below must also be addressed: Compliance Issues: 1. Operations and Maintenance: The excessive grease throughout the system causes issues throughout the treatment process. 2. Aeration Basin: The old access point on the outside deck of the restaurant is unsealed and located directly above the aeration basin, which poses a significant safety hazard. It is recommended that this be sealed as soon as possible. 3. De-chlorination: It is recommended to cover the open de-chlorination tube. 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, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. 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 Travis Farmer (ORC, Environmental Inc.) DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 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 NC0036692 23/01/17 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) Skyline Lodge & Village WWTP NCSR 1544 Highlands NC 28741 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 11:45AM 23/01/17 18/07/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Paul Travis Farmer/ORC/828-586-5588/ Other Facility Data 01:00PM 23/01/17 22/11/30 Name, Address of Responsible Official/Title/Phone and Fax Number Larry Spelts,80 Line St Charleston SC 29403//843-297-8385/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 Melanie Kemp DWR/ARO WQ/ - - / Lauren E Armeni DWR/ARO WQ/828-296-4500/ Mara G Chamlee 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: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 1/31/2023 1/31/2023 1/31/2023 1/31/2023 NPDES yr/mo/day 23/01/17 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, Melanie Kemp, and Mara Chamlee, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Skyline Lodge & Village WWTP on January 17, 2023. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0036692. Mr. Travis Farmer (Environmental Inc., ORC) and Mr. Tyler Easterly (Environmental Inc., Operator-in-training) were present and assisted in the inspection. The collection system is entirely gravity-fed and therefore there are no pump stations. The restaurant and lodge are the only two buildings connected to the WWTP. Below the deck of the lodge patio is an enclosed space with a low ceiling which houses the aeration basin and clarifier with sludge return. The enclosed nature of the listed components made these difficult to access. Outside the enclosed area and directly adjacent are the tablet chlorinator and the chlorine contact chamber. Outside and down the hill are the tablet dechlorination unit, holding tank with dual dosing siphon bell, and the sand filter (with no recirculation). The following items were noted during the inspection: 1. Permit: Mr. Farmer indicated that there is not a lock on the clasp to the door of the enclosed space that houses the aeration basin and clarifier; therefore, access to the plant site is not restricted to the general public. It is recommended that a lock be placed on this door. Additionally, the tablet chlorinator and chlorine contact chamber are not fenced in. These are both safety issues and should be addressed. 2. Operations & Maintenance: Mr. Farmer indicated that the restaurant at the lodge causes significant issues with grease throughout the plant, and this issue was prevalent throughout the inspection. The current grease trap is not large enough for the grease to settle out. The grease was previously pumped out monthly along with the sludge, but Mr. Farmer indicated that starting this year they are now pumping both twice a month. If they continue to have issues with grease, Mr. Farmer indicated that they would install a larger grease trap. Additionally, Mr. Farmer stated that Civil Design Concepts of Asheville, NC will come to provide recommendations to address issues with grease. 3. Aeration Basin: Due to excessive grease in the system, the settleometer reading was undesirably high. Grease was floating at the top of the settleometer and caused the solids to have a fluffy appearance. It was very hard to assess the aeration basin because it was in the back of the enclosed area, and the inspectors did not feel safe entering. 4. Disinfection: The chlorine contact chamber cover is cracked. This issue was previously mentioned in the 2018 inspection report. It is recommended that it be repaired or replaced due to safety concerns, especially since it is right next to the lodge and residents can access it. Additionally, the chlorine contact chamber is not fenced in and is accessible to the general public which also poses a safety concern. 5. Sand Filter: At the time of the inspection, excessive water was present on the surface of the sand filter. Additionally, the structural support for one of the filter distributor arms has failed, which was noted in the 2018 inspection report and was never addressed. It is recommended that the failed distributor arm be repaired or replaced. When the sludge and grease are pumped out twice a month, excess water is pumped out of the sand filter and the sand filter is raked. The sand filter was constructed in 1930, and Mr. Farmer indicated that he has spoken with the owners about having a new one constructed because the current one is not properly functioning. NC0036692 17 (Cont.) Page#2 DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 Permit:NC0036692 Inspection Date:01/17/2023 Owner - Facility: Inspection Type: Skyline Lodge & Village WWTP Compliance Evaluation The following compliance and safety issues were noted during the inspection: 1. Operations and Maintenance: Excessive grease throughout the system causes issues throughout the treatment process. 2. Aeration Basin: The old access point on the outside deck of the restaurant is unsealed and located directly above the aeration basin, which poses a significant safety hazard. It is recommended that this be sealed as soon as possible. 3. De-chlorination: It is recommended to cover the open de-chlorination tube. The following deficiencies were noted during the inspection: 1. Permit: There is not a lock on the clasp to the door housing the aeration basin and secondary clarifier; therefore, access is not restricted to the general public. It is recommended that the clasp be locked to restrict access. 2. Disinfection: The chlorine contact chamber cover is cracked, and it is recommended that it be repaired or replaced as it is currently a safety hazard. Additionally, it is not fenced in and is therefore accessible to the general public. It is recommended that the chlorine contact chamber be fenced in. 3. Sand filter: At the time of the inspection, excessive water was present on the surface of the sand filter. Additionally, the structural support for one of the filter distributor arms has failed, which was noted in the 2018 inspection report and was never addressed. Page#3 DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 Permit:NC0036692 Inspection Date:01/17/2023 Owner - Facility: Inspection Type: Skyline Lodge & Village 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 permit expired in August 2022; however, the renewal application has been submitted, and the current permit remains in effect until the Permitting Unit issues another one. There are several safety issues at this facility. See summary for details. 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, temperature, and chlorine residual. Mr. Farmer indicated that the restaurant affiliated with the lodge causes issues with exessive grease throughout the plant. See summary for details. 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#4 DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 Permit:NC0036692 Inspection Date:01/17/2023 Owner - Facility: Inspection Type: Skyline Lodge & Village WWTP 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: 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) At the time of the inspection, DO was 1.4. As previously indicated, there is excessive grease throughout the plant from the lodge restaurant and possible issues with the grease trap. There was excessive grease present and floating in the aeration basin. The settleometer reading was undesirably high, around 62%. 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) Page#5 DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 Permit:NC0036692 Inspection Date:01/17/2023 Owner - Facility: Inspection Type: Skyline Lodge & Village WWTP Compliance Evaluation Secondary Clarifier Yes No NA NE Sludge was previously pumped out once a month, but Mr. Farmer indicated that they have increased the frequency to twice a month. Environmental Inc. has a pump truck and the sludge is transported to a nearby WWTP. Comment: Disinfection-Tablet Yes No NA NE Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use?2 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? The chlorine contact chamber cover is cracked and needs replacement or repair. See summary for details. Comment: Sand Filters (Low rate)Yes No NA NE (If pumps are used) Is an audible and visible alarm Present and operational? Is the distribution box level and watertight? Is sand filter free of ponding? Is the sand filter effluent re-circulated at a valid ratio? # Is the sand filter surface free of algae or excessive vegetation? # Is the sand filter effluent re-circulated at a valid ratio? (Approximately 3 to 1) The sand filter acts as a tertiary filter. There was significant water pooling on the filter at the time of inspection. Mr. Farmer noted that the pooling is often due to excess flow. Additionally, a support for one of the distributor arms has failed, and it is recommended that it be repaired or replaced. See summary for details. 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? At the time of inspection, the dechlorination tube was uncovered, and it is recommended that it be covered. Comment: Are tablet de-chlorinators operational? Number of tubes in use?1 Page#6 DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 Permit:NC0036692 Inspection Date:01/17/2023 Owner - Facility: Inspection Type: Skyline Lodge & Village WWTP Compliance Evaluation De-chlorination Yes No NA NE 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? Mr. Farmer indicated that they do not have a flow meter and that flow is estimated. He stated that an influent flow meter will be installed this year. 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? When accessing the effluent pipe, the area is thick with rhododendrons and somewhat difficult to access. 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)? Grab samples are required per the permit.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? Page#7 DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54 Permit:NC0036692 Inspection Date:01/17/2023 Owner - Facility: Inspection Type: Skyline Lodge & Village WWTP Compliance Evaluation Standby Power Yes No NA NE Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Mr. Farmer indicated that there is not a back-up generator on-site; however, they are able to rent a portable generator if the need arises. Comment: Page#8 DocuSign Envelope ID: 3EB03C94-5465-4191-B7E4-F7A6F2B38C54