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HomeMy WebLinkAboutNC0065358_NOI_NOV2022PC0647_20230705 (2)ROY 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 ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ El El ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ 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 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ 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 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ 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 ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ 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 ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Comment: Generator was not operational during the previous inspection of 9/2023. It is now operational. Page# 8