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Home My WebLink AboutNC0068918_NOV2024PC0155 & CEI Report_20240306 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. March 6, 2024 Brian Dorry, Director of Operations IPM Management Email: info@ipmhoa.com SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2024-PC-0155 Permit No. NC0068918 Cedar Hill WWTP Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Cedar Hill WWTP on February 29, 2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0068918. 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 _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Due to the older model flow meter, the meter cannot accommodate flow proportional sampling. Effluent composite sampling is required to be flow proportional. _________________________________________________________________________________________________________________________________________________________________________ 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, 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. DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 If you should have any questions, please do not hesitate to contact Daniel Boss with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche, Kenneth Rummel (ORC, RPB Systems) DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 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 NC0068918 24/02/29 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) Cedar Hill WWTP 1820 US Hwy 64 Cashiers NC 28717 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 24/02/29 22/12/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Kenneth Jason Rummel/ORC/828-785-3769/ Other Facility Data 12:00PM 24/02/29 27/08/31 Name, Address of Responsible Official/Title/Phone and Fax Number Brian Dorry,PO Box 580 Arden NC 287040580//828-650-6875/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 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 Mara G Chamlee 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: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 3/6/2024 3/6/2024 NPDES yr/mo/day 24/02/29 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mara Chamlee, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Cedar Hill WWTP on February 29, 2024. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0068918. Mr. Kenneth Rummel (ORC, RPB Systems) and Mr. Bob Barr (Owner, RPB Systems), and Mr. Jeffrey Moore (collection system operator) were present and assisted with the inspection. There are currently 20-30 homes connected to the collection system for the facility. Due to the seasonality of residents at this development, at the time of the inspection there was very low flow to the plant. This has caused there to be very low solids throughout the facility. The following items were noted during the inspection: Equalization Basins: It is recommended that an audible alarm be added to the equalization basin or that the EQ basin be connected to telemetry. Aeration Basins: The dissolved oxygen measurement at the time of the inspection was undesirably high with a measure of 12.73 mg/L. Pump Station-Effluent: An auto-dialer is installed on the effluent pump station, however it is recommended to check to ensure the telemetry service is still active. The following violation was found during the inspection: Effluent Sampling: Effluent composite sampling is required to be flow-proportional. At the time of the inspection, it was being performed as time-based due to the older model flow meter that does not accommodate flow proportional. It is recommended to replace the flow meter to a model that is able to accomodate flow proportional sampling. Additionally, it is recommended that a thermometer be placed in the sample storage refrigerator. NC0068918 17 (Cont.) Page#2 DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 Permit:NC0068918 Inspection Date:02/29/2024 Owner - Facility: Inspection Type: Cedar Hill 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? 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? At the time of the inspection, there were very low solids in the plant due to the low flow and seasonality of the residences connected to the collection system. Process controls analyzed include pH, DO, temperature, settleable solids, and MLSS as needed. 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? Is the ORC certified at grade equal to or higher than the facility classification? Page#3 DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 Permit:NC0068918 Inspection Date:02/29/2024 Owner - Facility: Inspection Type: Cedar Hill WWTP Compliance Evaluation Record Keeping Yes No NA NE 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? 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? There is a small manual bar screen at the head of the facility.Comment: Equalization Basins Yes No NA NE 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? At the time of the inspection, the visual alarm was working, however an audible alarm was not present. It is recommended that an audible alarm be added to the EQ basin. See summary for details. 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? Page#4 DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 Permit:NC0068918 Inspection Date:02/29/2024 Owner - Facility: Inspection Type: Cedar Hill WWTP Compliance Evaluation Aeration Basins Yes No NA NE 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) Due to the low flow entering the facility at the time of the inspection, there were very low solids in the plant. A settleability test was performed, but the low solids present may not have given an accurate representation of settleability. After thirty minutes, there were 4 mL of solids out of 1000 mL of water. The DO was undesirably high at the time of the inspection, it measured to be 12.73 mg/L. See summary for details. Comment: 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) Due to the low flow and solids in the plant, the sludge blanket level was very low. A sludge judge showed about three inches of solids out of ten feet of water in the clarifier at the time of the inspection. There was a layer of algae on top of the clarifier at the time of the inspection that the ORC states is very difficult to remove entirely. Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? The digester decants to aeration basins #1 and #2. The digester is pumped as needed by Mike's Septic Service and hauled to either Buncombe MSD or Brevard WWTP as accessible. Comment: Page#5 DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 Permit:NC0068918 Inspection Date:02/29/2024 Owner - Facility: Inspection Type: Cedar Hill WWTP Compliance Evaluation Aerobic Digester Yes No NA NE Disinfection-Tablet Yes No NA NE Are tablet chlorinators operational? Are the tablets the proper size and type? 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? The total residual chlorine is tested two times per week.Comment: De-chlorination Yes No NA NE Type of system ?Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? 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?2 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 flow meter is an older model that the ORC is not able to order new parts for or have serviced anymore. The flow recorder uses an ultrasonic sensor to measure flow. The flow meter is calibrated annually by KDT Service Technologies. The most recent calibration date sticker was not readable on the flow meter. Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Page#6 DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 Permit:NC0068918 Inspection Date:02/29/2024 Owner - Facility: Inspection Type: Cedar Hill WWTP Compliance Evaluation Effluent Sampling Yes No NA NE 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)? Due to the older model flow meter, the meter cannot accomodate flow proportional sampling. The composite sampler was last calibrated on August 4, 2024 by Tony Metcalf of RPB Systems. 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? The effluent pipe is located about 1/4 of a mile from the facility. In order to access the pipe, it is required to descend down a steep slope above the river. Comment: Pump Station - Effluent Yes No NA NE Is the pump wet well free of bypass lines or structures? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Is audible and visual alarm available and operational? An auto-dialer is installed on the effluent pump station, however it is uncertain if the telemetry service is still active. See summary for details. 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? Page#7 DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4 Permit:NC0068918 Inspection Date:02/29/2024 Owner - Facility: Inspection Type: Cedar Hill WWTP Compliance Evaluation Standby Power Yes No NA NE The generator is serviced by a contract agreement that the POA holds. The fuel level was 70% full at the time of the inspection. Comment: Page#8 DocuSign Envelope ID: FDBA9305-CDB3-4E80-9660-CF1AA66CF9E4