HomeMy WebLinkAboutNC0065358_NOI_NOV2022PC0647_20230705ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
CERTIFIED MAIL 7020 3160 0002 0860 6283
RETURN RECEIPT REQUESTED
S I P Hidden Forest Estates, LLC
Attn: Sean Dyer, Owner
665 Hancock St, Ste 3
Quincy, MA 02170-2868
NORTH CAROLINA
Environmental Quality
July 5, 2023
SUBJECT: Compliance Evaluation Inspection & Notice of Continuing Violation &
Recommendation for Enforcement; NOV Tracking #: NOV-2022-PC-0647
Hidden Forest Estates WWTP
NPDES Permit #: NCO065358
Randolph County
Dear Mr. Dyer:
On May 15, 2023, Division of Water Resources/Winston-Salem Regional Office (NCDWR/WSRO) staff inspected the
Hidden Forest Estates Wastewater Treatment Plant. Operator, Travis Sherrard, was present for the inspection. This
was a follow-up to the last inspection in September 2022. The following violations remain ongoing since the 2022
inspection and are detailed below. This inspection reflects continuing non-compliance with NPDES permit
NC0065358.
The following continuing violations were noted:
1. The sampler currently pulls constant time/constant volume effluent samples. Using a constant
time/constant volume sampling regime for compliance samples without written approval from the Division
of Water Resources is a violation of Part 11, Section A, of the permit.
2. Records for operations and laboratory analyses prior to April 2022 were not available at the time of either
inspection. The permittee is required to have all operational records dating back three years and all
analytical records dating back five years. Failure to have the required records is a violation of Part II, Section
D, paragraph 6, of the permit.
3. Examination of the plant in detail reveals that the facility has received substandard operation and/or
maintenance for an extended period. Severe uncontrolled corrosion is ubiquitous throughout the plant and
in some instances the corrosion has completely negated the function of the affected component:
a. The circular equalization basin has holes eaten all the way through the sidewall, allowing
wastewater to escape the basin whenever the water level reaches that depth.
b. The circular clarifier's weir is so badly corroded it has begun to separate into layers.
c. The angle iron, which supports the walkways above the plant components, is so badly corroded in
several areas that one can see them flex and give way when you step on them.
d. Several pipes throughout the facility show evidence of corrosion and several temporary repair
couplings have been used to make repairs to pipes that either sprang a leak or completely broke
due to the corrosion.
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NoanicaaouNn
oep.m.m or em�nmen� Qualm,
336.776.9800
All the above demonstrate violations of Part II, Section C, Paragraph 2 of the permit.
The currently designated operator in responsible charge (ORC) is Gary L. Moore. However, Mr. Moore no
longer works at this plant. Therefore, the plant has no properly designated ORC or backup ORC. This is a
violation of Part II, Section C, Paragraph 1, of the permit.
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 with the terms, conditions, or requirements of any permit, or
applicable regulations, issued pursuant to G.S. 143-215.1.
As such, you must take immediate steps to correct the violations noted above. Please reply in writing to this notice
within 10 days of receiving it. Your written response should detail the corrective actions you have taken and/or plan
to take to correct each of the listed violations. Failure to reply in writing, as directed, or to satisfactorily correct the
listed violations, may result in a recommendation by this office to proceed with the above -mentioned enforcement
procedures.
you have any other questions, you may contact Mr. Boone by phone at 336.776.9690 or by email at
ron.boone@deg.nc.gov.
Sincerely,
DocuSigned by:
OD2D3CE3F1 B7456...
Jennifer F. Graznak, Assistant Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
Water Compliance Inspection Report
REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105
NORTH CAROLINA 336.776.9800
naparMeM of EmironmanW 9uallly
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 23/05/15 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)
12:OOPM 23/05/15
16/10/01
Hidden Forest Estates WWTP
6602 Holder Inman Rd Ext
Exit Time/Date
Permit Expiration Date
Randleman NC 27317
02:OOPM 23/05/15
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 Compliance Schedules
Effluent/Receiving Wate 0 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 Docusigned by: DWR/WSRO WQ/336-776-9690/
osiaecl 7/5/2023
B20F8DD5F2A3460...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
'_6Docusigned by: DWR/WSRO 336-776-9695 7/5/2023
if, 4.
"-0D2D3 E F1 B7456 .
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#
NPDES yr/mo/day Inspection Type
NCO065358 I11 12I 23/05/15 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On May 15, 2023, Division of Water Resources/Winston-Salem Regional Office (NCDWR/WSRO)
staff inspected the Hidden Forest Estates Wastewater Treatment Plant. Operator, Travis Sherrard,
was present for the inspection. This was a follow-up to the last inspection in September 2022. The
following violations remain ongoing since the 2022 inspection and are detailed below. This inspection
reflects continuing non-compliance with NPDES permit NC0065358.
The following continuing violations were noted:
1. The sampler currently pulls constant time/constant volume effluent samples. Using a constant
time/constant volume sampling regime for compliance samples without written approval from the
Division of Water Resources is a violation of Part II, Section A, of the permit.
2. Records for operations and laboratory analyses prior to April 2022 were not available at the time
of either inspection. The permittee is required to have all operational records dating back three years
and all analytical records dating back five years. Failure to have the required records is a violation of
Part II, Section D, paragraph 6, of the permit.
3. Examination of the plant in detail reveals that the facility has received substandard operation
and/or maintenance for an extended period. Severe uncontrolled corrosion is ubiquitous throughout
the plant and in some instances the corrosion has completely negated the function of the affected
component:
a. The circular equalization basin has holes eaten all the way through the sidewall, allowing
wastewater to escape the basin whenever the water level reaches that depth.
b. The circular clarifier's weir is so badly corroded it has begun to separate into layers.
c. The angle iron, which supports the walkways above the plant components, is so badly corroded in
several areas that one can see them flex and give way when you step on them.
d. Several pipes throughout the facility show evidence of corrosion and several temporary repair
couplings have been used to make repairs to pipes that either sprang a leak or completely broke due
to the corrosion.
All the above demonstrate violations of Part II, Section C, Paragraph 2 of the permit.
4. The currently designated operator in responsible charge (ORC) is Gary L. Moore. However, Mr.
Moore no longer works at this plant. Therefore, the plant has no properly designated ORC or backup
ORC. This is a violation of Part II, Section C, Paragraph 1, of the permit.
Page#
Permit: NCO065358 Owner -Facility: Hidden Forest Estates WWTP
Inspection Date: 05/15/2023 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
0
❑
❑
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: Fence repaired from last inspection in 9/2022.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# 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?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: None
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
■
❑
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
# 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: Sampler pulls constant time/constant volume effluent samples. Operators submitted
request via email, post -inspection, requesting an exemption from using
flow
proportional sampling.
Compliance Schedules
Yes
No
NA
NE
Is there a compliance schedule for this facility?
❑
0
❑
❑
Is the facility compliant with the permit and conditions for the review period?
❑
0
❑
❑
Comment: None
Page# 3
Permit: NCO065358
Inspection Date: 05/15/2023
Owner -Facility: Hidden Forest Estates WWTP
Inspection Type: Compliance Evaluation
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
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El
El
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Comment: Records for operations prior to April 2022 are not available. The permittee should have
all required records. Only one operator is currently designated as operator in
responsible charge (ORC) and he no longer works there. There is no backup ORC
designated. The operators who currently operate the plant have not been properly
designated as required.
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?
Comment: None
Equalization Basins
Yes No NA NE
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• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ■ ❑
Yes No NA NE
Page# 4
Permit: NCO065358
Inspection Date: 05/15/2023
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
•
❑
❑
❑
•
❑
❑
❑
•
❑
❑
❑
•
❑
❑
❑
•
❑
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❑
•
❑
❑
❑
❑
❑
❑
■
■
❑
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❑
Comment: Entire plant has severe corrosion. Several of the walkways are unsafe and other plant
components are corroded so badly that they have holes eaten through them, which
would allow wastes to spill out if it gets to that level. The weir on the circular secondary
clarifier is so badly corroded that it is separating into lavers. Several temporary repair
couplings have been used throughout the plant. Permanent repairs should be made.
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
❑
0
❑
❑
Comment: Bar screen also has severe corrosion.
Aeration Basins
Yes
No
NA NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
0
❑
❑
❑
Are surface aerators and mixers operational?
❑
❑
0
❑
Are the diffusers operational?
0
❑
❑
❑
Is the foam the proper color for the treatment process?
■
❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑
❑
❑
■
Page# 5
Permit: NC0065358
Inspection Date: 05/15/2023
Aeration Basins
Owner -Facility: Hidden Forest Estates WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The entire plant has severe corrosion. Several of the walkways are unsafe and other
plant components are corroded so badly that they have holes eaten through them,
which would allow wastes to spill out if it gets to that level. The weir on the circular
secondary clarifier is so badly corroded that it is separating into lavers. Several
temporary repair couplings have been used throughout the plant. Permanent repairs
should be made in place of these temporary repairs.
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?
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'/4 of the sidewall depth)
Yes No NA NE
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Comment: This plant has a rectangular and a circular clarifier. The circular clarifier is not in
service so weirs could not be assessed for levelness or whether there was any weir
blockage or short circuiting. The weir on the circular clarifier suffers from extreme
corrosion and is separating into lavers. The entire plant has severe corrosion. Several
of the walkways are unsafe and other plant components are corroded so badly that
they have holes eaten through them, which would allow wastes to spill out if it gets to
that level. The weir on the circular secondary clarifier is so badly corroded that it is
separating into lavers. Several temporary repair couplings have been used throughout
the plant. Permanent repairs should be made in place of these temporary repairs.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
■
❑
❑
❑
Are pumps operational?
0
❑
❑
❑
Are there adequate spare parts and supplies on site?
0
❑
❑
❑
Comment: None
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation: Down flow
Is the filter media present? ■ ❑ ❑ ❑
Page# 6
Permit: NCO065358 Owner -Facility:
Inspection Date: 05/15/2023 Inspection Type:
Hidden Forest Estates WWTP
Compliance Evaluation
Filtration (High Rate Tertiary)
Yes
No
NA
NE
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: These are enclosed media filters and the media could not be evaluated.
Disinfection - UV
Yes
No
NA
NE
Are extra UV bulbs available on site?
0
❑
❑
❑
Are UV bulbs clean?
0
❑
❑
❑
Is UV intensity adequate?
■
❑
❑
❑
Is transmittance at or above designed level?
0
❑
❑
❑
Is there a backup system on site?
0
❑
❑
❑
Is effluent clear and free of solids?
0
❑
❑
❑
Comment: Chlorine tablets would be used in the event the UV system fails.
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: Outfall is allegedly underwater in Randleman Lake and cannot be seen.
It's exact
location is unknown.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
0
❑
❑
❑
Is the site free of excessive foaming in the tank?
■
❑
❑
❑
# Is the odor acceptable?
■
❑
❑
❑
# Is tankage available for properly waste sludge?
0
❑
❑
❑
Comment: None
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Page# 7
Permit: NCO065358
Inspection Date: 05/15/2023
Owner -Facility: Hidden Forest Estates WWTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: None
Standby Power
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?
Yes
No
NA
NE
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■
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■
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■
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■
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■
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■
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Comment: Generator was not operational during the previous inspection of 9/2023. It is now
operational.
Page# 8