NC0087556_NOVNOI2024PC0124 & CEI Report_20240226

Certified Mail # 9589 0710 5270 0731 8003 58
Return Receipt Requested
February 26, 2024
Steve Reynolds
Ledgestone Property Owners Association
28 Ledgestone Drive
Fairview, NC 28730
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2024-PC-0124
Permit No. NC0087556
Ledgestone Subdivision WWTP
Buncombe County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Ledgestone Subdivision WWTP
on February 13, 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. NC0087556. 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 was noted during the inspection:
Inspection Area Description of Violation
_________________________________________________________________________________________________________________________________________________________________________
Operations & Maintenance The solids continue to be high throughout the plant.
[NC0087556 Part II. Standard Conditions - Section C. 2. Proper Operation &
Maintenance - The Permittee shall at all times properly operate and maintain all
facilities and systems of treatment and control (and related appurtenances) which
are installed or used by the Permittee to achieve compliance with the conditions of
this permit.]
_________________________________________________________________________________________________________________________________________________________________________
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
DocuSign Envelope ID: 518D6CB9-246D-464E-8514-2ECDEACFD084
overall compliance please respond in writing within ten (10) business days 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 Lauren Armeni with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4667.
Sincerely,
Daniel Boss, Assistant Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: Inspection Report
Ec: Laserfiche
Juanita James (BORC, James & James Environmental)
Hannah Turner (General Manager, James & James Environmental)
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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 NC0087556 24/02/13 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)
Ledgestone Subdivision WWTP
Miller Rd
Fairview NC 28730
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:30AM 24/02/13 21/02/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Juanita Reed James/ORC/828-697-0063/
Other Facility Data
10:30AM 24/02/13 25/12/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Juanita Reed James,PO Box 1354 Mountain Home NC 287581354//828-697-0063/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 Facility Site Review 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
Lauren E Armeni 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.
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2/26/2024
2/26/2024
NPDES yr/mo/day
24/02/13
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of
the Ledgestone Subdivision WWTP on February 13, 2024. This inspection was conducted to
determine whether the facility is being operated and maintained in compliance with NPDES Permit
No. NC0087556. Juanita James (BORC, James & James Environmental), Hannah Turner (General
Manager, James & James Environmental), and Leif Clontz (Maintenance Technician, James & James
Environmental) were present and assisted in the inspection.
Permit: The permit components list is missing the equalization basin, secondary clarifier, and digester.
These components will be added to the list during the next permit renewal.
Recordkeeping: Shannon James is listed as the ORC, but Jim Davis is the current ORC. Please
submit an Operator Designation form so our system can be updated with the correct ORC.
Operations & Maintenance: The solids are high throughout the plant. At the time of the inspection,
settleability was 2%, the sludge blanket in the secondary clarifier was 10' out of 12' of water, and the
sludge blanket in the chlorine contact chamber was 1' out of 2' of water. Solids were also high
throughout the plant during the 2019 inspection. There is a digester and additional sludge holding
capacity since train #2 is being used as an extra digester, so there are currently no limits on wasting
sludge. Solids need to be better managed throughout the plant.
Equalization Basin: At the time of the inspection, the high level alarms (both audible/visual) were not
working. Ms. Turner emailed Ms. Armeni a video of the audible/visual alarms working on February 14,
2024.
Secondary Clarifier: At the time of the inpsection, there was excess grease built up on some areas of
the weirs. This grease should be removed. Ms. James indicated that FOG information is distributed to
customers on the required basis.
Standby Power: At the time of the inspection, the propane tank that fuels the generator was low and
needs to be refilled.
The following violation was noted during the inspection:
1. Operations & Maintenance: The solids continue to be high throughout the plant.
NC0087556 17 (Cont.)
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Permit:NC0087556
Inspection Date:02/13/2024
Owner - Facility:
Inspection Type:
Ledgestone Subdivision 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?
The current permit components list does not reflect all of the components at the facility.
See summary for details.
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?
Process controls analyzed include settleable solids, pH, DO, and using a sludge judge
to measure the sludge blanket. There are two trains at the facility and only one train is
used as intended - the other train is used as a sludge holding tank. Solids are high
throughout the facility. See summary for details.
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?
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Permit:NC0087556
Inspection Date:02/13/2024
Owner - Facility:
Inspection Type:
Ledgestone Subdivision 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?
See summary for details.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?
The basin is continuously aerated. At the time of the inspection, the high level
audible/visual alarms were not working. 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?
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)
The blowers are set to automatically come on for 30 minutes, then off for 30 minutes.
At the time of the inspection, settleability was 2%, indicating that the solids were very
high throughout the plant.
Comment:
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater?
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Permit:NC0087556
Inspection Date:02/13/2024
Owner - Facility:
Inspection Type:
Ledgestone Subdivision WWTP
Compliance Evaluation
Secondary Clarifier Yes No NA NE
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)
At the time of the inspection, the sludge blanket was 10' out of 12' of water. Ms. James
indicated they waste to the digester once every two weeks. See summary for details.
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?
Sludge from the digester is pumped to the second train as needed. Mike's Septic Tank
Service pumps the sludge from the second train as needed, as well as sludge from the
chlorine contact chamber and digester. Sludge from these three places was last
pumped out on June 29, 2022.
Comment:
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?
At the time of the inspection, the sludge blanket in the contact chamber was 1' out of 2'
of water, further showing the high solids throughout the plant. Sludge from the contact
chamber should be pumped out.
Comment:
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Permit:NC0087556
Inspection Date:02/13/2024
Owner - Facility:
Inspection Type:
Ledgestone Subdivision WWTP
Compliance Evaluation
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 2019 report indicated that the effluent flow meter had not been calibrated. During
this inspection, it was confirmed that the flow meter was last calibrated on January 30,
2024 by Laboratory Instrument Service.
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?
Comment:
Effluent Sampling Yes No NA NE
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)?
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Permit:NC0087556
Inspection Date:02/13/2024
Owner - Facility:
Inspection Type:
Ledgestone Subdivision WWTP
Compliance Evaluation
Effluent Sampling Yes No NA NE
The permit requires grab samples only. Grab samples are collected after
dechlorination in the effluent chamber.
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?
At the time of the inspection, the propane tank that fuels the generator was 42% full. It
is recommended to refill the propane tank. The generator is serviced annually by
Carolina Energy, and it automatically exercises twice a week for 15 minutes. See
summary for details.
Comment:
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