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Home My WebLink AboutNC0025461_NOVNOI2024PC0189_CEI_Report_20240318DocuSign Envelope ID: 6DED3754-1FD8-4BOE-B26B-89E100E58OA3 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director s STATE, NORTH CAROLINA Environmental Quality Certified Mail # 9589 0710 5270 0731 8011 19 Return Receipt Requested March 18, 2024 Charles Vines, Mayor Town of Bakersville PO Box 53 Bakersville, NC 28705 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2024-PC-0189 Permit No. NCO025461 Bakersville WWTP Mitchell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Bakersville WWTP on February 26, 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. NC0025461. 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 Sequencing Batch Reactors Each SBR tank holds only 100,000 gallons; therefore, both SBR tanks need to be operational to be in accordance with the permitted flow (0.200 MGD; see Section A. [1 j). �..tiE'µD IwrlhCarolina OeM,, 1n200U S. High-1 Qua1 DivlskmN.rth Cr Resources Ashc+llk Rc9knal Officc 205p U.S. Hlghv+ay 70 Swannanoa, North Camllna 28776 62&2%4500 DocuSign Envelope ID: 6DED3754-1FD8-4BOE-B26B-89E100E58OA3 A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S. 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 issued pursuant to G.S. 143-215.1. If you wish to provide additional information regarding the noted violation, request technical assistance, or discuss overall compliance please respond in writing within ten (10) business day after receipt of this Notice. A review of your response will be considered along with any additional information provided. You will then be notified of any civil penalties that may be assessed regarding the violations. If no response is received in this Office within the 10-day period, a civil penalty assessment may be prepared. 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. If the violations are of a continuing nature, not related to operation and/or maintenance problems, and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by Consent. Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned maintenance activities, taking units off-line, etc. If you should have any questions, please do not hesitate to contact Rachel Rose with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, EPDocuSigned by: ou�,tt,(, �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 Paul Isenhour (ORC, Water Quality Labs & Operations) Robby Woody (BORC, Town of Bakersville) CaRc91 Degartm I Z09 .0 5.HNhw Qaal Swonna SnonNorthC RRna2 7 Rshev�pe Rc9ional Office 2U9p U.S. Highway 9U Swannanoa.Norlh Camlma 28TT6 62&296.4AO DocuSign Envelope ID: 6DED3754-1FD8-4BOE-B26B-89E100E58OA3 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 NCO025461 111 121 24/02/26 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 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 Dermit Number) 10:OOAM 24/02/26 20/06/01 Bakersville WWTP 306 S Mitchell Ave Exit Time/Date Permit Expiration Date Bakersville NC 28705 11:00AM 24/02/26 25/02/28 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Paul E. Isenhour/ORC/828-898-6277/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Charles Vines,PO Box 53 Bakersville NC 28705/Mayor/828-688-2113/ Yes 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 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 Rachel Rose Docusigned by: DWR/ARO WQ/828-296-4500/ E'v 3/15/2024 5ACE19D3940C494... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date D 5'g 11,: 3/15/2024 bbss E Atn.tt,( EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: 6DED3754-1FD8-4BOE-B26B-89E100E580A3 NPDES yr/mo/day Inspection Type (Cont.) NC0025461 I11 12I 24/02/26 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Rachel Rose, with the Asheville Regional Office (ARO), met with Robby Woody (BORC, Town of Bakersville), Paul Isenhour (ORC, Water Quality Labs & Operations) and Jamison Burleson (Maintenance Director, Town of Bakersville) to conduct a Compliance Evaluation Inspection on February 26, 2024 of the Town of Bakersville WWTP. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0025461. The following items were noted during the inspection: 1. Equalization Basin: There was a fair amount of grease in the EQ basin. The Town has an enforceable grease control program, mails out FOG brochures annually, and has FOG education information available through their website. It is suggested to continue with and add on to the current grease education program to help reduce the amount of grease reaching the WWTP. Additionally, the circulation pump was broken at the time of the inspection. The circulation pump needs to be fixed to ensure proper functionality of the EQ basin. 2. Disinfection - UV: Some of the indicator lights were not accurate at the time of the inspection. It is suggested to replace the broken bulbs and ensure the indicator lights are fully functioning for accurate reading of the UV system. 3. Sequencing Batch Reactors: The ORC indicated that repairs for the broken SBR tank are in the works. The following violations were noted during the inspection: 1. Sequence Batch Rectors: With one SBR tank being broken, there is no backup system and the designed treatment system cannot be performed. High flow events cause inadequate treatment of the flow due to the inability to hold flow more than 100,000 gallons. Each SBR tank holds only 100,000 gallons; therefore, both SBR tanks need to be operational to be in accordance with the permitted flow (0.200 MGD; see Section A. [1]). Page# DocuSign Envelope ID: 6DED3754-1FD8-4BOE-B26B-89E100E58OA3 Permit: NCO025461 Owner -Facility: Bakersville WWTP Inspection Date: 02/26/2024 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: 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? Comment: The process controls analyzed are pH, settleable solids, and temperature. 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: 6DED3754-1FD8-4BOE-B26B-89E100E580A3 Permit: NC0025461 Owner -Facility: Inspection Date: 02/26/2024 Inspection Type: Bakersville WWTP Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: 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: The bar screen is located within the EQ basin and moderately screens for debris. Equalization Basins Yes No NA NE Is the basin aerated? ❑ 0 ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? ■ ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? 0 ❑ ❑ ❑ # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment: The EQ basin includes alternating dual influent pumps and telemetry which allows it to serve as the influent pump station. There was a fair amount of -grease in the EQ basin. See summary for details. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ 0 ❑ ❑ Is sample collected above side streams? ❑ ❑ 0 ❑ 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)? Page# 4 DocuSign Envelope ID: 6DED3754-1FD8-4BOE-B26B-89E100E58OA3 Permit: NCO025461 Inspection Date: 02/26/2024 Influent Sampling Is sampling performed according to the permit? Comment: Sequencing Batch Reactors Type of operation: Is the reactor effluent free of solids? Owner -Facility: Bakersville WWTP Inspection Type: Compliance Evaluation Does minimum fill time correspond to the peak hour flow rate of the facility? Is aeration and mixing cycled on and off during fill? The operator understands and can explain the process? Yes No NA NE ■ ❑ ❑ ❑ Yes No NA NE Duplex ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Comment: Only one side of the dual SBR system was operational at the time of the inspection. See summary for details. Aerobic Digester Yes No NA NE Is the capacity adequate? ■ ❑ ❑ ❑ Is the mixing adequate? ■ ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: The aerobic digesters are converted from the prior package plant's aeration basins. Two out of three basins were being used at the time of the inspection. Four loads are pumped out of the digesters quarterly. Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? 0 ❑ ❑ ❑ Are UV bulbs clean? ❑ ❑ ❑ ■ Is UV intensity adequate? 0 ❑ ❑ ❑ Is transmittance at or above designed level? 0 ❑ ❑ ❑ Is there a backup system on site? 0 ❑ ❑ ❑ Is effluent clear and free of solids? ■ ❑ ❑ ❑ Comment: The UV bulbs are cleaned once every three months and were last cleaned in January 2024. Chlorinator and de -chlorinator tablets are available through Water Quality Labs as needed for a backup system. See summary for details. Flow Measurement - Effluent # Is flow meter used for reporting? Yes No NA NE ■ ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: 6DED3754-1FD8-4BOE-B26B-89E100E580A3 Permit: NC0025461 Owner -Facility: Bakersville WWTP Inspection Date: 02/26/2024 Inspection Type: Compliance Evaluation Flow Measurement - Effluent 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 meter was calibrated on July 18, 2023 by Water Qualitv Labs. 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: 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: 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 ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: The generator has no fuel gauge, but the fuel level is monitored with a ruler. The town has an emergency service agreement with Youngs Fuel Service. The generator is automatically exercised weekly. 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