WQ0002829_NOV-2006-PC-0335_20660818

�0F W ATFRQ Michad F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environn=t and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
DIVISION OF WATER QUALITY
Aquifer Protection Section
August 18, 2006
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7006 0100 0000 8379 5345
Mr. George E. Goodrich — Managing Partner
KDHWWTP, LLC
Post Office Box 3629
Kill Devil Hills, North Carolina 27948
SUBJECT: August 10, 2006 Compliance Inspection
and
Notice of Violation
KDHWWTP, LLC
Permit No: WQ0002829
Dare County
NOV-2006-PC-0335
190=5=436l1i6M11
On June 16, 2006, the KDHWWTP, LLC was issued Permit No. WQ0002829 for the continued operation of a
wastewater- treatment facility and disposal system The treatment and disposal facilities are located in Kill Devil
Hills, Dare County. The Division of Water Quality (the Division) Aquifer Protection Section is responsible for
conducting compliance inspections on non -discharge wastewater facilities and associated disposal areas. Ms.
Analee Harris, Mr. Buster Thompson, and Mr. Robert Tankard of the Washington Regional Office conducted a
scheduled compliance evaluation on August 10, 2006. -Mr. Bill Freed and Mr. Jimmy Bliven assisted DiN ision
staff during the inspection. Their assistance was very helpful and greatly appreciated.
Overall the treatment facility appears to be well -maintained and operated. The low rate infiltration and reuse
irrigation system has not yet been certified and therefore was not in use at the time of the inspection: All of the
wastewater was being disposed of in the high rate infiltration spray beds. Several items were found not to be
compliant with Permit No. WQ0002829: Enclosed is a completed copy of the inspection checklist. The Division
is issuing this Notice of Violation for the following permit violations:
1. Failure to maintain sprayfield in a manner that prohibits the growth of vegetation.
Permit conditions H (9) and (10) require the vegetative growth to be kept out of the high rate infiltration
spray beds at all times. The vegetation must be removed manually and twice.weekly during the summer
months and once weekly during the winter months. Raking should be recorded in the maintenance log.
In the future, please keep vegetation out of the high rate infiltration spray beds.
North Carolina Division of Water Quality Internet h2o.enrstatem-us
943 Washington Square Mall Phone: [phone]
Washington, NC 27989 FAX [phone]
An Equal Opportunity/Affirmative Acton Employer- 50% Recyded110% Post Consumer Paper
NoAhCarolina
,Ilaturally

Mr. Goodrich
WQ0002829
Compliance Inspection
August 18, 2006
2. Failure to report settleable solids (prior to February 2006) and turbidity (ongoing) on the Non -Discharge
Monitoring Report (NDMR).
'i- Permit conditions III (4)(a) and (b) describes the parameters for effluent testing at the facility.
Monitoring data indicates the turbidity and settleable solids are not being reported every month. In
addition, two separate NDMRs should be submitted each month one for the high -rate infiltration spray
beds and one for the low rate reclaimed infiltration pond(s). In the future, please ensure a complete report
by including turbidity, settleable solids, and separate forms for each type of disposal.
We appreciate your attention and prompt response in the non -compliant issues listed above. Within thirty (30)
days of receipt of this Notice, please submit a written response describing proposed corrective actions, including a
timeframe for completion, by KDHWWIT, LLC.
In addition to the permit requirements, several other items were noted during the inspection:
Our database still indicates Mr. Freed is the ORC at the facility. During the inspection, Mr. Freed indicated
that Mr. Bliven should be the ORC, and Mr. Roberson should be the Backup-ORC. Please complete the
attached ORC Designation Form and submit by fax or mail to the address on the form.
2. Please ensure that a staff gauge is installed in the pond prior to use for disposal. Additionally, adequate
(permanent) signage should be installed around the ponds and all areas to be irrigated by reuse water.
3. Because of a removal of the chlorine disinfection system, you will no longer be required to monitor effluent
for residual chlorine. This will be corrected in the permit at its next renewal or modification.
4. During. the inspection, the operators requested for the triannual effluent sampling months to coincide arith the
sampling months for the groundwater monitoring wells (January, April, and September). This should be no
problem to change, however it will require a minor modification request for the permit. 1%,finor modifications
do not require fees. In this case, a letter requesting the change should suffice. This letter should be sent to the
Central Office staff at DENR-DWQ, APS-LAU, 1636 MSC, Raleigh, NC 27699-1636.
If you or your operators should have any questions, please do not hesitate to contact Analee Harris. Buster
Thompson, or me at [phone].
Sincerely,
David May
Aquifer Protection Section Supervisor
q uP
Washington Regional Office
Attachments
cc: Mr. Bill Freed
Mr. Jimmy Bliven
Central Office File
X Washington Regional Office File

Compliance Inspection Report
Permit WQ0002829 Effective: 06/16/D6 Expiration: 05/31/09 Owner. KDHWWTP L L C
SOC: Effective: Expiration: Facility: KDHWWTP
County, Dare PO Box 3629
Region: Washington
Kill Devil Hills NC 27M
Contact Person: George E Goodrich Phone: [phone]
Directions to Facility:
Primary ORC: James Keith Bliven
Secondary ORC(s):
William Galen Freed
On -Site Representative(s):
Related Permits:
Certification: 987715
Certfflcation: 14856
Inspection Date: 08/10/2006 Entry Time: 09:45 AM Exit Time: 11:00 PM
Primary Inspector. Analee Harris
Secondary Inspector(s):
Robert B Tankard
Buster Thompson
Reason for Inspection: Routine
Permit Inspection Type: High -Rate Infiltration
Facility Status: Q Compliant ■ Not Compliant
Question Areas:
■ Treatment Flow ■ Treatment Flow
Measurement -Effluent Measurement -Influent
Treatment E Treatment Barscreen
Treatment Activated Sludge■ Treatment Sludge
Storage/Treatment
Treatment Disinfection End Use -Infiltration
End Use -Reuse Standby Power
(See attachment summary)
Phone: [phone]
Phone: [phone]
Phone:
Phone: [phone] ExL233
Phone:
Inspection Type: Compliance Evaluation
Miscellaneous Questions
ETreatmentFlow
Measurement -Water Use
_
Records
Treatment Filters
Record Keeping
E End Use -Irrigation
■ Treatment Clarifiers
■ Treatment Flow
Measurement
■ Treatment Return pumps
Coastal Requirements
Page: 1

Permit: W00002829 Owner - Facility: KDHWWTP L L C
Inspection Date: 08/10/2006 Inspection Type: Compliance Evaluation Rsaaon for Visit: Routine
Inspection Summary:
Treatment system is in good condition. Effluent flow meter is calibrated annually, and generator is automatically tested
weekly. Residuals are hauled by/to Atlantic Sewage about 4 times a year.
Infiltration pond(s) is not yet in use, nor is the reuse irrigation system. It is almost ready to be certified. Signs are needed
around all areas to be irrigated upon with reuse water (grass, pond, etc.) Signage was not present at the time of the site
visit, but the signs were ready to be installed. Painting signs on sidewalks may be more effective than signs around the
grass areas as signs could be removed and/or run -over by mowers. In addition, a staff gauge should be installed in the
pond prior to usage.
The HR-Infiltration beds need to be raked twice weekly as required by permit Several fields had vegetation growing in
field. Several spray heads not spraying. Overall, though, the fields seem to be working property, no ponding or runoff
was evident
Current permit was kept on site. NDMRs sometimes have not reported settleable solids, and never have reported
turbidity. ORC needs to submit an NDMR for each of the disposal types (one for when discharge is to HR-Inf, one for
when discharge is to LR-Inf-pond). This is because LR-Inf-pond has additional limits and parameters for testing. Turbidity
should be reported with the NDMR for the LR-Inf-pond.
ORC indicates documentation has been sent to DWO-Tech. Certification to update ORC and Backup ORC. At this time,
BIMS is incorrect (Freed ORC). Correct should be Bliven ORC, Roberson B-ORC.
ORC requested to change triannual sampling months to coincide with GW monitoring months (Jan, Apr, Sept). This will
need to be formally requested (minor modification) in a letter to the central office.
Page: 2

Permit WO0002829 Ovvner - Faculty ITP L L C
Inspection Date: 08/10/2006 Inspection Type: Compliance Evaluation
Reason for Visit Routine
Type
Yes
No
NA
NE
Lagoon Spray, LR
❑
Single Family Spray, LR
❑
Activated Sludge Drip, LR
❑
Recycle/Reuse
❑
Single Family Drip
❑
Reuse (Quality)
■
Infiltration System
■
Activated Sludge Spray, HR
■
Activated Sludge Spray, LR
■
Treatment
Yes
No
NA
NE
Are Treatment facilities consistent with those outlined in the current permit?
■
❑
❑
❑
Do all treatment units appear to be operational? (If no, note below.)
■
❑
❑
❑
Comment: Infiltration ponds are not yet in use, nor is the reuse irrigation system.
However, it is near certification and should be ready to operate shortly.
Treatment Flow Measurement -Influent
Yes
No
NA
NE
Is flowmeter callbrated annually?
❑
❑
■
❑
Is flowmeter operating property?
❑
❑
■
❑
Does flowmeter monitor continuously?
❑
❑
■
❑
Does flowmeter record flow?
❑
❑
■
❑
Does flowmeter appear to monitor accurately?
OOMO
Comment: there is not an influent flow meter.
Treatment Flow Measurement -Water Use Records
Yes
No
NA
NE
Is water use metered?
❑
❑
■
❑
Are the daily average values property calculated?
❑
❑
■
❑
Comment: water use is not metered.
Treatment Flow Measurement -Effluent
Yes
No
NA
NE
Is flowmeter calibrated annually?
■
❑
❑
❑
Is flowmeter operating properly?
■
❑
❑
❑
Does flowmeter monitor continuously?
■
❑
❑
❑
Does flowmeter record flow?
■
Cl
❑
Cl
Page: 3

Permtt: WOD 02829 Owner - Facitit3r 10Hw L L C
Inspection Date: 08l10/2006 ' Inspectlon Type: Cortpance Evaluation Reason for Vises Routine
Does flowmeter appear to monitor accurately?
■ ❑
❑
❑
Comment: Effluent flow meter calibrated on June.28, 2006 and records flow in gallons
per minute.
Standby Power
Yes No
NA
NE
Is automatically activated standby power available?
■ ❑
❑
❑
Is generator tested weekly by interrupting primary power source?
0000
Is generator operable?
■ ❑
❑
❑
Does generator have adequate fuel?
■ ❑
❑
❑
Comment Generator tests automatically every monday at gam. During the
inspection, Mr. Bliven flipped the breaker, and the generator tumed on immediately.
Treatment Barscreen
Yes No
NA
NE
Is it free of excessive debris?
■ ❑
❑
❑
Is disposal of screenings in compliance?
■ ❑
❑
❑
Are the bars spaced properly?
■ ❑
❑
❑
Is the unit In good condition?
00110
Comment: Screenings disposed of into dumpster. There were many flies around the
barscreen.
Treatment Activated Sludge
Yes No
NA
NE
Is the aeration mechanism operable?
■ ❑
❑
❑
Is the aeration basin thoroughly mixed?
■ ❑
❑
❑
Is the aeration equipment easily accessed?
■ ❑
❑
❑
Is Dissolved Oxygen adequate?
■ ❑
❑
❑
Are Settleometer results acceptable?
■ ❑
❑
❑
Is activated sludge an acceptable color?
■ ❑
❑
❑
Comment: DO = 5.15 mg/L, 29.8 deg. C
Treatment Clarifiers
Yes No
NA
NE
Are the weirs level?
■ ❑
❑
❑
Are the weirs free of solids and algae?
■ ❑
❑
❑
Is the scum removal system operational?
■ ❑
❑
❑
Is the scum removal system accessible?
■ ❑
❑
❑
Is the sludge blanket at an acceptable level?
■ ❑
Cl
❑
Is the effluent from the clarifier free of excessive solids?
■ ❑
Cl
❑
Page: 4

Permit W00002M Owner - Faci9qy. MHwWTP L L C
Inspection DaW: 0& 10=W Inspection Type: Compliance Evaluation
Reason for Visit; Routine
Comment: ' Clarifiers appeared to be clean and clear.
Treatment Return pumps
Yes No
NA
NE
Are they in place?
■ ❑
❑
❑
Are they operational?
■ ❑
❑
❑
Comment:
Treatment Filters
Yea No
NA
NE
is the fitter media present?
■
❑
❑
❑
Is the fitter media the correct size and type?
■
❑
❑
❑
Is the air scour operational?
■
❑
❑
❑
Is the scouring acceptable?
■
❑
❑
❑
Is the clear well free of excessive solids?
MOOO
Is the mud well free of excessive solids and fitter media?
■
❑
❑
❑
Does backwashing frequency appear adequate?
E.0
❑
❑
Comment: Anthracite is the filter media. Operator tested scour, appears to work well.
Treatment Sludge Storage/Treatment
Yes
No
NA
NE
Is the aeration operational?
■
Cl
❑
❑
Is the aeration pattern even?
■
❑
❑
❑
If required, are Sanitary 'Ts" present In tankage?
❑
❑
❑
■
Comment:
Treatment Disinfection
Yea
No
NA
NE
Is the system working? _
■
❑
❑
❑
Do the fecal coliform results Indicate proper disinfection?
■
❑
❑
❑
Is there adequate detention time (>=30 minutes)?
■
❑
❑
❑
Is the system properly maintained?
■
❑
❑
❑
If gas, does the cylinder storage appear safe?
❑
❑
■
❑
Is the fan in the chlorine feed room and storage area operable?
❑
❑
■
❑
Is the chlorinator accessible?
❑
❑
■
❑
If tablets, are tablets present?
❑
❑
■
❑
Are the tablets the proper size and type?
Cl
❑
■
❑
Is contact chamber free of sludge, solids, and growth?
❑
❑
■
❑
Page: 5

Permit W00002B29 Owner - FacMty: KDHWWTP L L C
Inspection Date: 08/10/2006 Inspection Type: Compliance Evaluation
Reason for Visa Routine
If W, are extra W bulbs available?
■
❑ ❑
❑
if W, Is the UV intensity adequate?
■
❑ ❑
❑
# Is it a dual feed system?
■
❑ ❑
❑
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 77t32-50-5)?
❑
❑ ■
❑
If yes, then is there a Risk Management Plan on site?
❑
❑ ■
❑
If yes, then what Is the EPA twelve digit ID Number? (1000- -__)
If yes, then when was the RMP last updated?
Comment:
Record Keeping
Yes
No NA
NE
is a copy of current pemvt available?
■
❑ ❑
❑
Are monitoring reports present NDMR?
■
❑ ❑
❑
NDAR?
■
❑ ❑
❑
Are flow rates less than of permitted flow?
■
❑ ❑
❑
Are flow rates less than of pem>ttted flow?
■
❑ ❑
❑
Are application rates adhered to?
■
❑ ❑
❑
Is GW monitoring tieing conducted, If required (GW-59s submitted)?
■
❑ ❑
❑
Are all samples analyzed for all required parameters?
■
❑ ❑
❑
Are there any 2L GW quality violations?
❑
■ ❑
❑
Is GW-59A certification form completed for facility?
❑
❑ ❑
■
Is effluent sampled for same parameters as GW?
■
❑ ❑
❑
Do effluent concentrations exceed GW standards?
❑
■ ❑
❑
Are annual soil reports available?
❑
❑ ■
❑
# Are PAN records required?
❑
■ ❑
❑
# Did last soil report Indicate a need for lime?
❑
❑ ■
❑
If so, has it been applied?
❑
❑ ■
❑
Are operational logs present?
■
❑
❑
Are lab sheets available for review?
❑
■ ❑
❑
Dolab sheets support data reported on NDMR?
❑
❑ ❑
■
Do lab sheets support data reported on GW-59s?
❑
❑ ❑
■
Are Operational and Maintenance records present?
■
❑ ❑
❑
Page: 6

Permtt W00002829 Owrwr - Facility: KDHWWTP L L C
Inspection Date: 08/1012D08 Inspection Type: Compliance Evaluation
Reason for Vlstt Routine
Were Operational and Maintenance records complete?
■
❑
❑
❑
Has permittee been free of public complaints In last 12 months?
■
❑
❑
❑
Is a copy of the SOC readily available?
❑
Q
■
❑
No treatment units bypassed since last inspection?
■
❑
❑
❑
Comment: A copy of the current permit was on site. Average daily flow for June 2006
was 171,000 GPD (permitted for 500,000). Lab sheets were not onsite, as they are kept
at the Envirotech office in Currituck Co. NDMRs sometimes have not reported settable
solids and never report turbidity as required by the permit.
End Use -Irrigation
Are buffers adequate?
Is the cover crop type specified in permit?
Is the crop cover acceptable?
Is the site condition adequate?.
Is the site free of runoff / ponding?
Is the acreage specified in the permit being utilized?
Is the application equipment present?
Is the application equipment operational?
Is the disposal field free of limiting slopes?
is access restricted and/or signs posted during active site use?
Are any supply wells within the CB?
Are any supply wells within 250' of the CB?
How dose is the closest water supply well? -
Is municipal water available in the area?
# Info only: Does the permit call for monitoring wells?
Are GW monitoring wells located property w/ respect to RB and CB?
Are GW monitoring wells property constructed, including screened interval?
Are monitoring wells damaged?
Comment 'Irrigation system not running yet.
End Use-Infiltratlon
# Is the application High Rate or Low Rate?
Are buffers maintained?
Yes No NA NE
High Rate
■❑❑❑
Page: 7

Permit WQ0002829 Owner- Faciltty: KDHWWTP L L C
Inspection Date: 08/102006 Inspection Type: Compliance Evaluation Reason for Visa Routine
Are any supply wells within the CB?
❑
■
❑
❑
Are any supply wells within 250' of the CB?
❑
■
❑
❑
Is municipal water available in the area?
■
❑
❑
❑
Are GW monitoring wells required?
■
❑
❑
❑
Are GW monitoring wells located property w/ respect to RB and CB?
■
❑
❑
❑
Are GW monitoring wells property constructed, including screened Interval?
❑
❑
❑
■
Is a usable green area maintained?
■
❑
❑
❑
Is the disposal site acceptable?
❑
■
❑
❑
Is the distribution equipment acceptable?
❑
■
❑
❑
Is the disposal site free of ponding?
■
❑
❑
❑
Is the disposal site free of breakout?
■
❑
❑
❑
Are the disposal sites free of solids, algae, etc.?
■
Q
❑
Q
Do the records show that the fields are properly maintained?
❑
■
❑
❑
Are the disposal sites free of vegetation?
❑
■
❑
❑
Do any surface water features appear to be adversely impacted by GW discharge?
❑
■
❑
❑
No chemicals or rototiller used to eliminate vegetation, solids, algae, etc.?
■
❑
❑
❑
Comment: both high rate (sand beds) and low rate (pond) is available at this site. At
the time of the inspection, the pond was not being used for disposal yet. Several of the
high rate beds have vegetation growing in them, and records indicate they are not raked
in accordance with the permit: Bed 1A and 1B- not used, not raked. Bed 3- Blew air
(no water sprayed), not raked. Bed 4 - Many heads not spraying, not raked. Bed 5-
sprays ok, little vegetation, not raked. Bed 6: little vegetation, not raked. Bed 7A & 7B-
little vegetation, not raked.
End Use -Reuse Yes No NA NE
Is the acreage in the permit being utilized?
❑
■ ❑
❑
Does the acreage specified in the permit correspond to the measured acreage at the site?
■
❑ ❑
❑
Are all essential units provided in duplicate?
■
❑ ❑
❑
Is an automatically activated standby power source available?
■
❑ Q
❑
Is the equalization capacity adequate?
■
❑ ❑
❑
Is aerated flow equalization present?
■
❑ Q
❑
Has the turbidity meter been calibrated in the last 12 months?
❑
❑ ❑
■
Does the turbidity meter have recording capabllities?
❑
❑ ❑
■
Page: 8

1 �
Permit WO0002829 Owner - FacUky: KDHWWTP L L C
Inspection Date: 08/10/2006 Inspection Type: Compliance Evakretion Reason for Visit Routine
is all flow diverted at the appropriate times?
❑ ❑
❑
■
is all upset wastewater diverted from reuse storage unit?
❑ ❑
■
❑
Is all upset wastewater treated, retreated, or disposed of acceptably?
❑ ❑
❑
■
Is upset wastewater treated prior to discharge to irrigation storage?
❑ ❑
■
❑
Is public access restricted from irrigation area during active site use?
❑ ❑
❑
■
ff golf course, Is a sign posted in plain sight on the dub house?
❑ ❑
■
❑
Is the cover crop acceptable?
■ ❑
❑
❑
Are buffers adequate?
■ ❑
❑
❑
Is the site free of ponding/runoff?
■ ❑
❑
❑
Is the acreage In the permit being utilized?
❑ ■
❑
❑
Is the application equipment acceptable?
■ ❑
❑
❑
Is the application area free of limiting slopes?
■ ❑
❑
❑
How close is the closest water supply well?
❑ ❑
■
❑
Are any supply wells within the CB?
❑ ■
❑
❑
Are any supply wells within 250' of the CB?
❑ ■
❑
❑
Is municipal water available in the area?
■ ❑
❑
❑
Are GW monitoring wells required?
❑ ■
❑
❑
Are GW monitoring wells located property w/ respect to RB and CB?
❑ ❑
■
❑
Are GW monitoring wells properly constructed, including screened interval?
❑ ❑
■
❑
Comment: the reuse system is not in operation at this time. the plant is producing
reuse quality water, but is not disposing of it in to reuse -permitted areas. all disposal at
this time is into the high rate beds.
Coastal Requirements
Yes No
NA
NE
Are essential treatment units provided In duplicate?
■ ❑
❑
❑
Is an adequately sized aerated equalization basin present?
■ ❑
❑
E
If so, is it operable?
■ ❑
❑
❑
If present, are diffusers cleaned regularly?
■ ❑
❑
❑
Is the equalization capacity adequate?
■ ❑
❑
❑
Comment:
Page: 9
61