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Home My WebLink AboutNC0049620_CEI_NOV2023PC0521_20230927DocuSign Envelope ID: 644DB280-8749-4738-B1F0-62FE9D5886F7 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director stnrea NORTH CAROLINA Environmental Quality SENT VIA ELECTRONIC MAIL ONL Y.- NO HARD COPY WILL BE MAILED October 18, 2023 Abigail Norton, Mayor Town of Hot Springs Email: mayor@townofhotsprings.org SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2023-PC-0521 Permit No. NCO049620 Hot Springs Housing Authority WWTP Madison County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Hot Springs Housing Authority WWTP on September 27, 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. NC0049620. 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 Sand Filters (Low rate) At the time of the inspection, the sand filter had excessive ponding and algae growth. 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. 4_ D 2� Norlfi Carolina Depar[merrtaf Environmental Qualrcylolvlsbnaf Wazer Reaourees Ashrellle Regional OA5ce1209013�5. Hlghrray 701 Swannanoa, Noah CsroRna 2ft778 62&296 Me DocuSign Envelope ID: 644DB280-8749-4738-B1F0-62FE9D5886F7 To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Mara Chamlee with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, EPDocuSigned by: aLut,�, i°jbSS E397192DABFB4FF... Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Jeremy Trantham (ORC) Juanita James (BORC, James & James Environmental) D � � North Carolina Depar[merrt of Environmental Qualrcy I uwlsbnafw—Reap — -/ Asheville Regional Office 12O9005.Hlghway7C 15—nna—Noah Caro1ha28775 62&296 Me DocuSign Envelope ID: 644DB280-8749-4738-B1F0-62FE9D5886F7 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 NCO049620 I11 121 23/09/27 I17 18I � I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I n, 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 permit Number) 11:30AM 23/09/27 21/02/01 Hot Springs Housing Authority WWTP Paint Rock Rd Exit Time/Date Permit Expiration Date Hot Springs NC 28743 12:30PM 23/09/27 25/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Juanita Reed James/ORC/828-697-0063/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Randy A Joseph,PO Box 218 Hot Springs NC 287430218//828-622-7591/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar 0 Records/Reports Self -Monitoring Progran 0 Facility Site Review Effluent/Receiving Wate 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 10/18/2023 Mara G Chamlee A�ma C6+Lu, DWR/ARO WQ/828-296-4500/ Rachel Rose �gwgq— DWR/ARO WQ/828-296-4500/ 10/18/2023 C qg— Daniel J Boss iRPAMP. DWR/ARO WQ/828-296-4658/ 10/18/2023 auuU eSS Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date 10/18/2023 [a�i� Bess EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: 644DB280-8749-4738-B1F0-62FE9D5886F7 NPDES yr/mo/day Inspection Type (Cont.) NCO049620 I11 12I 23/09/27 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mara Chamlee, Rachel Rose, and Daniel Boss, with the Asheville Regional Office (ARO), met with Juanita James (BORC, James & James Environmental), Hannah Turner (General Manager, James & James Environmental), Jeremy Trantham (ORC, Town of Hot Springs), and Justin Wood (Town of Hot Springs) for a Compliance Evaluation Inspection of the Hot Springs Housing Authority WWTP on September 27, 2023. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0049620. The following items were noted during the inspection: Permit: There was no restricted access to the general public. It is recommended to install a fence around the WWTP to restrict access to the general public. Operations & Maintenance: The current system is failing, which led to high BOD and solids issues throughout the plant. Plans and funding are in place to repair this facility. Septic Tanks: Potential solutions for grease control are regular pumping of the septic tank, installing a grease trap prior to the septic tank, or educating the users of the system in proper grease disposal. Disinfection: There was visible signs of grease buildup in the contact chamber. There is discussion with the Town to create a grease trap prior to the septic tank. The following deficiency was noted during the inspection: Sand Filters: At the time of the inspection, the sand filter had excessive ponding and algae growth, and the sand was in need of replacing. There are plans and funding in place to replace the sand in the sand bed. It is recommended to rake and weed the sand bed regularly, especially when the sand is replaced. Page# DocuSign Envelope ID: 644DB280-8749-4738-B1F0-62FE9D5886F7 Permit: NCO049620 Inspection Date: 09/27/2023 Owner -Facility: Hot Springs Housing Authority WWTP 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 ■ ❑ ❑ ❑ 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? ■ ❑ ❑ ❑ Comment: There was no restricted access to the general public. See summary for details. Operations & Maintenance 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? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The system is failing, which is leading to high BOD and solids issues throughout the plant. See summary for details. 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? Page# 3 DocuSign Envelope ID: 644DB280-8749-4738-B1F0-62FE9D5886F7 Permit: NCO049620 Inspection Date: 09/27/2023 Record Keeping Owner -Facility: Hot Springs Housing Authority WWTP Inspection Type: Compliance Evaluation 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: Septic Tank (If pumps are used) Is an audible and visual alarm operational? Is septic tank pumped on a schedule? Are pumps or syphons operating properly? Are high and low water alarms operating properly? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ M ❑ Yes No NA NE ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The septic tank is pumped once every 2-3 months. The tank was last pumped on September 14. 2023. See summary for details. Sand Filters (Low rate) Yes No NA NE (If pumps are used) Is an audible and visible alarm Present and operational? ❑ ❑ ■ ❑ Is the distribution box level and watertight? ❑ ■ ❑ ❑ Is sand filter free of ponding? ❑ 0 ❑ ❑ Is the sand filter effluent re -circulated at a valid ratio? ❑ ❑ 0 ❑ # Is the sand filter surface free of algae or excessive vegetation? ❑ ■ ❑ ❑ # Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1) ❑ ❑ ■ ❑ Comment: At the time of the inspection, the sand filter had excessive pondinq and algae growth and the distribution box did not seem watertight. See summary for details. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? 0 ❑ ❑ ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Number of tubes in use? 2 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? ❑ ❑ ❑ Comment: The chlorine contact chamber was closed off not allowinq a full examination of the chamber. The section of the chamber that was visible had signs of grease buildup. See summary for details De -chlorination Yes No NA NE Type of system ? Tablet Page# 4 DocuSign Envelope ID: 644DB280-8749-4738-B1F0-62FE9D5886F7 Permit: NCO049620 Inspection Date: 09/27/2023 De -chlorination Is the feed ratio proportional to chlorine amount (1 to 1)? Owner -Facility: Hot Springs Housing Authority WWTP Inspection Type: Compliance Evaluation 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? Comment: Effluent Pipe 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 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)? Comment: The permit requires grab samples. 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: The flow is measured with a bucket and timer. Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ N Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Page# 5