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Home My WebLink AboutNC0023281_NOD2023PC0191 & CEI Report_20230626 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. June 26, 2023 Oneil Khosa Vos3 LLC Email: oneilrk@gmail.com SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2023-PC-0191 Permit No. NC0023281 Tapoco Lodge & Village WWTP Graham County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Tapoco Lodge & Village WWTP on June 13, 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. NC0023281. 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 deficiency was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Standby Power There is no permanent or portable generator at the WWTP. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 30DF86D7-691E-4093-8891-6C5304E60624 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, 02T.0403 Deemed-permitted Rules Ec: Laserfiche Lamar Williams (ORC) DocuSign Envelope ID: 30DF86D7-691E-4093-8891-6C5304E60624 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 NC0023281 23/06/13 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) Tapoco Lodge & Village WWTP 14981 Tapoco Rd Robbinsville NC 28771 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:45AM 23/06/13 18/06/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Everette Lamar Williams/ORC/828-479-3250/ Other Facility Data 12:00PM 23/06/13 22/10/31 Name, Address of Responsible Official/Title/Phone and Fax Number Oneil Khosa,14981 Tapoco Rd Robbinsville NC 28771//828-498-2800/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 Lauren E Armeni DWR/ARO WQ/828-296-4500/ Mara G Chamlee DWR/ARO WQ/828-296-4500/ Rachel Rose 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: 30DF86D7-691E-4093-8891-6C5304E60624 6/26/2023 6/27/2023 6/27/2023 6/27/2023 NPDES yr/mo/day 23/06/13 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, Mara Chamlee, and Rachel Rose, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Tapoco Lodge & Village WWTP on June 13, 2023. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0023281. Lamar Williams (ORC) was present and assisted in the inspection. The following items were noted during the inspection: Permit: The permit components list will be updated during the current permit renewal. The facility does not have an aerated sludge holding tank, and the list is missing a bar screen and additional secondary clarifier. Operations & Maintenance: As the last inspection indicated, the internal components of the facility continue to rust. Painting is recommended; however, the facility does not have a duplicate train that can be used if the plant were to be painted. The access panel on the underside of the facility has a door, but it has come off and needs to be secured back on. There is still only a hand rail on one side of the plant, and for safety reasons both sides should have a hand rail. There is still no access to water at the WWTP to wash down treatment components. Secondary Clarifier: Sludge in the clarifiers is returned to two different locations in the aeration basin. Since there is no sludge holding tank, sludge in the clarifiers is pumped out every three months. Excess moss on the weirs was an issue in the last inspection, but Mr. Williams has addressed this issue and keeps them clear. Standby Power: There is no permanent or portable generator at the WWTP. Since there is a permanent generator at the Lodge, in the event of a power outage, flow would still enter the WWTP but there would be no power there. Mr. Williams indicated this isn't an issue short-term, but if the power were out for multiple days this could negatively impact the WWTP. It is recommended to purchase a portable generator in order to prevent an upset or bypass at the WWTP during a power outage. Deemed-permitted Collection System: As mentioned in the previous report, Tapoco Lodge & Village has a deemed-permitted collection system and is required to operate and maintain the system in compliance with 15A NCAC 02T.0403. The Lodge should take steps to assess and repair the collection system as needed. The 02T.0403 Rules are attached for your records. The following deficiency was noted during the inspection: 1. Standby Power: There is no permanent or portable generator at the WWTP. NC0023281 17 (Cont.) Page#2 DocuSign Envelope ID: 30DF86D7-691E-4093-8891-6C5304E60624 Permit:NC0023281 Inspection Date:06/13/2023 Owner - Facility: Inspection Type: Tapoco 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 road the WWTP is on is also used for local trails; however, the WWTP is locked and fenced in. The permit does not list a manual bar screen or two secondary clarifiers. Ms. Armeni contacted the permit writer in order to revise the current draft permit components list. 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? Mr. Williams indicated that he does not perform process controls. The internal components of the facility continue to show signs of corrosion from rusting, and only one side of the WWTP has a hand rail. 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? Page#3 DocuSign Envelope ID: 30DF86D7-691E-4093-8891-6C5304E60624 Permit:NC0023281 Inspection Date:06/13/2023 Owner - Facility: Inspection Type: Tapoco Lodge & Village WWTP Compliance Evaluation Record Keeping Yes No NA NE 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? A few discrepancies were noted when reviewing the lab data with the eDMRs; however, these discrepancies did not result in any missed violations. Ms. Armeni sent the discrepancies to Mr. Williams and the eDMRs were revised. A copy of the NPDES permit was not available on site but it was emailed to Mr. Williams. 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 rusted and it is recommended to paint it.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) Aeration is cycled on and off throughout the day. The blowers are set on a timer and are on for thirty minutes and off for fifteen minutes. Mr. Williams adjusts the timer settings throughout the year as needed. At the time of the inspection, settleability was 58%. Comment: Secondary Clarifier Yes No NA NE Page#4 DocuSign Envelope ID: 30DF86D7-691E-4093-8891-6C5304E60624 Permit:NC0023281 Inspection Date:06/13/2023 Owner - Facility: Inspection Type: Tapoco Lodge & Village WWTP Compliance Evaluation 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 facility has two hopper style clarifiers. At the time of the inspection, the first clarifier had a sludge blanket of 4 feet out of 8.5-foot deep clarifier, and the second clarifier had a sludge blanket of 2 feet deep out of an 8-foot deep clarifier. The sludge blanket was high in the first clarifier, but Mr. Williams indicated it was probably due to flow entering this clarifier first. 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 effluent flow meter was last calibrated on Decemer 16, 2022 by Horizon Engineering & Consulting. 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: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Page#5 DocuSign Envelope ID: 30DF86D7-691E-4093-8891-6C5304E60624 Permit:NC0023281 Inspection Date:06/13/2023 Owner - Facility: Inspection Type: Tapoco Lodge & Village WWTP Compliance Evaluation Effluent Sampling Yes No NA NE 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 facility is only required to test for BOD, TSS, and temperature. Earth Environmental Services is contracted for sampling and parameter analysis. 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 or portable generator at the WWTP. The Lodge has a generator, but it does not power the WWTP. See summary for details. Comment: Page#6 DocuSign Envelope ID: 30DF86D7-691E-4093-8891-6C5304E60624