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Home My WebLink AboutNC0072729_NOV2024PC0304 & CEI Report_20240516 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. May 16, 2024 James Grant, Chief of Maintenance & Engineering DOI National Park Services Email: jim_grant@nps.gov SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2024-PC-0304 Permit No. NC0072729 Mt. Pisgah Lodge & Recreation Area WWTP Haywood County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Mt. Pisgah Lodge & Recreation Area WWTP on May 7, 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. NC0072729. 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 Effluent composite sampling is not flow-proportional. _________________________________________________________________________________________________________________________________________________________________________ In addition, the issues below must also be addressed: Compliance Issue(s): 1. Disinfection – UV: The UV intensity panel display is not correctly reading the intensity. 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. DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F 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 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 Wayne Arnold (ORC) Joseph Herring (BORC) DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F 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 NC0072729 24/05/07 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) Mt. Pisgah Lodge & Recreation Area WWTP Blue Rdg Pkwy Milepost 407 Canton NC 28716 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 24/05/07 21/04/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Wayne Starr Arnold/ORC/828-456-8829/ Other Facility Data 11:30PM 24/05/07 26/01/31 Name, Address of Responsible Official/Title/Phone and Fax Number Wayne S Arnold,Blue Ridge Pkwy Mile Post 407 Canton NC 28716/Utility System Operator/828-648-5610/ 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. Page#1 DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F 5/16/2024 5/16/2024 NPDES yr/mo/day 24/05/07 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 Mt. Pisgah Lodge & Recreation Area WWTP on May 7, 2023. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0072729. Mr. Wayne Arnold (ORC) and Mr. Joseph Herring (BORC) were present and assisted in the inspection. The facility is seasonal - it opens April 1st and closes at the end of October. The facility has two trains and only the B train is used, except the digester is used in both trains. At the time of the inspection, the inn was open, but the campgrounds and picnic area don't open until the Friday before Memorial Day. The following items were noted during the inspection: 1. Operations & Maintenance: Solids were high throughout the plant. Settleable solids were 720 mL after 30 minutes and the sludge blanket was 7' out of 11.25' of water. Mr. Herron indicated that sludge is wasted to the digester for five minutes a day. Sludge should be wasted for a longer period each day to reduce the amount of solids in the plant. 2. Equalization Basins: At the time of the inspection, the audible and visual alarms did not work when the high level float was lifted. On May 9, 2024, Mr. Herron sent Ms. Armeni a video showing that the audible and visual alarms on the high level float were working. The issue was a loose wire. 3. Disinfection - UV: The UV intensity panel was not working. This panel will need to be fixed. 4. Effluent sampling: Effluent composite sampling is not flow-proportional. Mr. Herron indicated that staff is working with Laboratory Instrument Service to fix the composite sampler and connect it to the flow meter. The following violation was noted during the inspection: 1. Effluent sampling: Effluent composite sampling is not flow-proportional. The following compliance issue was noted during the inspection: 1. Disinfection - UV: The UV intensity panel display is not correctly reading the intensity. NC0072729 17 (Cont.) Page#2 DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F Permit:NC0072729 Inspection Date:05/07/2024 Owner - Facility: Inspection Type: Mt. Pisgah Lodge & Recreation Area 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? Process controls anaylzed include MLSS, settleable solids, pH, DO, and measuring the sludge blanket with a sludge judge. It would be beneficial for staff to have confined space training in order to clean out basins. At the time of the inspection, solids were high throughout the plant. 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? Page#3 DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F Permit:NC0072729 Inspection Date:05/07/2024 Owner - Facility: Inspection Type: Mt. Pisgah Lodge & Recreation Area 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: 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? When the high level float was lifted, the audible and visual alarms did not work. Mr. Herring indicated that the floats had recently been replaced. The floats are checked monthly. See summary for details. 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? The bar screen is raked multiple times per day. Debris is dried and placed into a trash can. 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: 1B99D3D3-69BC-49F4-B522-D3E637F0512F Permit:NC0072729 Inspection Date:05/07/2024 Owner - Facility: Inspection Type: Mt. Pisgah Lodge & Recreation Area 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) The blowers automatically turn on for 15 minutes every hour. The sludge return is on when the blowers are on. Prior to the inspection, process controls taken were settleable solids, DO and MLSS. Settleable solids were 720 mL after 30 minutes, DO was 3.9 mg/L and MLSS was 2,830. DO is generally kept around 3 mg/L. 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) At the time of the inspection, the sludge blanket was 7' out of 11.25' of water and there was some excess algae on the weirs. The previous report indicated that bleach was added to the weir area to remove algae buildup. Mr. Herron said that they scrub the weirs with a mixture of bleach and water when needed. Comment: Filtration (High Rate Tertiary)Yes No NA NE Type of operation:Cross flow Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Page#5 DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F Permit:NC0072729 Inspection Date:05/07/2024 Owner - Facility: Inspection Type: Mt. Pisgah Lodge & Recreation Area WWTP Compliance Evaluation Filtration (High Rate Tertiary)Yes No NA NE The cloth media filters sit below water level. Filters are checked during manual backwashes, and they are backwashed around two to three times per day. Filter backwash goes to the EQ basin. The filters are replaced every two to three years, and were replaced this year. 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? Both A and B train digesters are used and are constantly aerated. Sludge is wasted to the digesters for five minutes every day. Supernate is decanted to the EQ basin, and Mike's Septic pumps the digesters out as needed. Mike's Septic takes sludge to Buncombe MSD as needed, generally two to three times per season. Comment: Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? Are UV bulbs clean? Is UV intensity adequate? Is transmittance at or above designed level? Is there a backup system on site? Is effluent clear and free of solids? Both UV banks are now used. Bulbs are cleaned once a week. The UV intensity panel was not working, but Mr. Herron indicated that they had gotten it fixed but it still wasn't working. Chlorination/dechlorination tablets are kept on site for backup. See summary for details. 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 was last calibrated on May 7, 2024 by Laboratory Istrument Service.Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Page#6 DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F Permit:NC0072729 Inspection Date:05/07/2024 Owner - Facility: Inspection Type: Mt. Pisgah Lodge & Recreation Area WWTP Compliance Evaluation Effluent Pipe Yes No NA NE 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)? Composite sampling is not flow proportional. The sampling fridge thermometer was 2.5 degrees Celcius. 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? The generator is exercised under load monthly and is connected to a diesel fuel tank on site. Mr. Herron indicated that they usually have monthly power outages. The facility's machanic annually services the generator. A stick is used to check the tank's fuel level. At the time of the inspection, the tank was 3/4 full. Comment: Page#7 DocuSign Envelope ID: 1B99D3D3-69BC-49F4-B522-D3E637F0512F