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Home My WebLink AboutNC0070394_NOVNOI2023PC0130 & CEI Report_20230405 (5)Certified Mail # 7022 0410 0002 1249 8279 Return Receipt Requested April 5, 2023 Max H Hopper Willowbrook Run Property Owners Association PO Box 182 Linville Falls, NC 28647-0182 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2023-PC-0130 Permit No. NC0070394 Willowbrook Run POA WWTP Macon County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Willowbrook Run POA WWTP on March 23, 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. NC0070394. 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 _________________________________________________________________________________________________________________________________________________________________________ Operations & Maintenance There are multiple deferred maintenance issues at the facility that pose safety hazards. [NC0070394 Part II. Standard Conditions - Section C. 2. Proper Operation & Maintenance - The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit.] _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 _________________________________________________________________________________________________________________________________________________________________________ Secondary Clarifier The line that goes from the clarifier to the chlorine contact chamber needs to be more thoroughly stabilized to prevent the line from breaking. [NC0070394 Part II. Standard Conditions - Section C. 2. Proper Operation & Maintenance - The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit.] _________________________________________________________________________________________________________________________________________________________________________ Disinfection-Tablet The chlorine contact chamber has a leak and treated wastewater is ponding on the ground. [NC0070394 Part II. Standard Conditions - Section C. 2. Proper Operation & Maintenance - The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit.] _________________________________________________________________________________________________________________________________________________________________________ Effluent Pipe The effluent pipe could not be located. [NC0070394 Part II. Standard Conditions - Section C. 2. Proper Operation & Maintenance - The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit.] _________________________________________________________________________________________________________________________________________________________________________ A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility’s NPDES WW Permit. Pursuant to G.S. 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. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A review of your response will be considered along with any additional information provided. You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. 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. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 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 Mark Teague (ORC, Environmental Inc.) DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 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 NC0070394 23/03/23 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) Willowbrook Run POA WWTP 17 McClure Mill Rd Franklin NC 28734 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 11:30AM 23/03/23 18/07/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Mark Fredrick Teague/ORC/828-586-5588/ Other Facility Data 01:00PM 23/03/23 22/11/30 Name, Address of Responsible Official/Title/Phone and Fax Number Max H Hopper,PO Box 182 Linville Falls NC 286470182//704-534-4500/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal 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: F1B3614A-3929-4647-9B71-E7C81F3C9942 4/5/2023 4/5/2023 4/5/2023 4/5/2023 NPDES yr/mo/day 23/03/23 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, Mara Chamlee, and Melanie Kemp, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of Willowbrook Run POA WWTP on March 23, 2023. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0070394. Mr. Mark Teague (ORC, Environmental Inc.) and Mr. Zach Story (BORC in-training, Environmental Inc.) were present and assisted in the inspection. The following items were noted during the inspection: Operations & Maintenance: Overall, the facility is in need of maintenance and repair. There is no ladder to get up to the aeration basin, clarifier, and digester. Some components are rusting and need to be painted. There are still missing and unstable rails around the aeration basin and secondary clarifier. The grates on top of the aeration basin and secondary clarifier are rusted and missing in some areas. Additionally, the ground adjacent to the secondary clarifier is eroded with pipe exposed. These issues pose safety hazards and need to be fixed and/or replaced. Secondary Clarifier: The line going from the secondary clarifier to the chlorine contact chamber is stabilized with a single bar and does not appear stable. This line should be more thoroughly stabilized to prevent it from breaking and causing a bypass to land and potentially surface water. Disinfection - Tablet: At the time of the inspection, a leak in the chlorine contact chamber was discovered, and treated wastewater was pooled on the ground. Mr. Teague indicated that the leak would be patched from the inside. This contact chamber is old and has been patched many times. The integrity of the contact chamber should be evaluated to determine if it should be replaced. Effluent Pipe: At the time of the inspection, the effluent pipe could not be located due to steep terrain and inaccessibility. Mr. Teague indicated that a gate should be installed to allow easier access to locate and maintain the effluent pipe. Per the permit, the right of way to the outfall needs to be maintained in order to evaluate the receiving waters and condition of the effluent pipe. The following violations were noted during the inspection: 1.Operations & Maintenance: There are multiple deferred maintenance issues at the facility that pose safety hazards. 2.Secondary Clarifier: The line that goes from the clarifier to the chlorine contact chamber needs to be more thoroughly stabilized to prevent the line from breaking. 3.Disinfection - Tablet: The chlorine contact chamber has a leak and treated wastewater is ponding on the ground. 4.Effluent Pipe: The effluent pipe could not be located. NC0070394 17 (Cont.) Page#2 DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 Permit:NC0070394 Inspection Date:03/23/2023 Owner - Facility: Inspection Type: Willowbrook Run POA WWTP Compliance Evaluation 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? The facility analyzes the following process controls: temperature, DO, pH, and MLSS. Overall, the facility is rusting and needs to be painted. Additionally, there are still broken and missing rails around the aeration basin and clarifier. The grates on top of these components are rusted and missing in some parts. There are several safety hazards 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? 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: Bar Screens Yes No NA NE Type of bar screen Page#3 DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 Permit:NC0070394 Inspection Date:03/23/2023 Owner - Facility: Inspection Type: Willowbrook Run POA WWTP Compliance Evaluation Bar Screens Yes No NA NE 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? Influent flow initially enters a pump station with a grinder pump. This pump station is maintained by Willowbrook Run POA. Return activated sludge from the clarifier goes through the bar screen prior to entering the aeration basin. 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, the DO was taken by Mr. Story and read 7.4 mg/L, which is higher than the desired range but has not affected the treatment. The blowers run for thirty minutes every hour during the day and fifteen minutes every hour at night. DO has been higher lately due to the warmer weather. Mr. Teague indicated that the basin needs a new header line because air is being lost. 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)? Page#4 DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 Permit:NC0070394 Inspection Date:03/23/2023 Owner - Facility: Inspection Type: Willowbrook Run POA WWTP Compliance Evaluation Secondary Clarifier Yes No NA NE Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth) At the time of the inspection, the sludge blanket was 1' out of a 7' deep clarifier. The line that goes from the clarifier to the chlorine contact chamber is stabilized by a single bar and should be further stabilized to prevent the line from breaking. See summary for details. Comment: Disinfection-Tablet Yes No NA NE Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use?1 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? At the time of the inspection, there was a leak in the chlorine contact chamber and wastewater pooling on the ground. The chamber is aboveground and old, and has been patched many times. Mr. Teague indicated that they would patch the leak from the inside of the chamber since in the past they have been patching the outside. 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? Comment: Are the tablets the proper size and type? Are tablet de-chlorinators operational? Number of tubes in use?1 Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? Page#5 DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 Permit:NC0070394 Inspection Date:03/23/2023 Owner - Facility: Inspection Type: Willowbrook Run POA WWTP Compliance Evaluation Flow Measurement - Effluent Yes No NA NE (If units are separated) Does the chart recorder match the flow meter? Flow is manually measured weekly.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? At the time of the inspection, the effluent pipe could not be located. Currently, there is not a very accessible way to get to the area where the effluent pipe is located due to a steep bank. Mr. Teague indicated that the facility needs a gate installed to access and maintain the effluent pipe. See summary for details. Comment: 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? There is a manual bar screen at the facility but it is not listed in the facility components list on the current permit; however, the permit is currently under renewal and this issue will be addressed. 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)? The permit requires grab sampling.Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? Page#6 DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942 Permit:NC0070394 Inspection Date:03/23/2023 Owner - Facility: Inspection Type: Willowbrook Run POA WWTP Compliance Evaluation Aerobic Digester Yes No NA NE Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Mr. Teague indicated that the digester has the capability of being aerated, but he is unable to get to the diffuser. He said the new header line would also fix this issue. 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? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? There is no permanent generator at the facility. Mr. Teague indicated that if the power were to go out, the well pump supplying water to the homes would also not work, and therefore no additional flow would go to the WWTP during this time. Comment: Page#7 DocuSign Envelope ID: F1B3614A-3929-4647-9B71-E7C81F3C9942