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Home My WebLink AboutWQ0012690_NOV-2024-PC-0393_CEI_20240613 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED June 13, 2024 Robert McGraw Park Superintendent, Mount Mitchell State Park Email: Robert.mcgraw@ncparks.com SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2024-PC-0393 Permit No. WQ0012690 Mount Mitchell State Park WWTF Yancey County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Mount Mitchell State Park WWTF on May 28, 2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in Non-discharge Permit No. WQ0012690. 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 violations were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Record Keeping There is no Operations & Maintenace plan for the site (permit condition III.2). _________________________________________________________________________________________________________________________________________________________________________ Record Keeping The permittee will need to submit a minor modification to proceed with plumbing changes needed to ensure backwash water does not enter the subsurface supply line (permit condition III.12). _________________________________________________________________________________________________________________________________________________________________________ End Use-Irrigation The sand filter needs to be covered to ensure rainwater is not collected and discharged through the drip irrigation lines and the cover should not restrict air circulation above the lined sand filter (permit condition III.15). According to the original design the tubing and emitters need to be covered by 4” of gravel. _________________________________________________________________________________________________________________________________________________________________________ End Use-Irrigation The ORC indicated that the totalizer isn’t properly recording total dosing quantities for some of the drip field zones (permit condition IV.5). _________________________________________________________________________________________________________________________________________________________________________ Record Keeping The maintenance log at the facility needs to be kept up-to-date with the pertinent information (permit condition IV.8). DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F 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. If you should have any questions, please do not hesitate to contact Melanie Kemp 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: Compliance Evaluation Inspection Report Ec: LF, Shane Felts (NC Parks), Todd Robinson (ORC, NC Parks) DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F Compliance Inspection Report Permit:WQ0012690 Effective:10/01/20 Expiration:09/30/26 Owner :State of NC - Division of Parks & Recreation SOC: Contact Person: Region: County: Directions to Facility: Yancey Asheville Kevin Bischof Effective:Expiration:Facility:Mount Mitchell State Park WWTF 2388 NC 128 Burnsville NC 28714 Title:Phone:828-675-4611Superintendent From ARO take the BRP North to Mt. Mitchell State Park. The maintenance shop is on the right approximately 2 miles from the park entrance. Secondary ORC(s): 704-881-4598Phone:1006252Certification:Todd Franklin RobinsonPrimary ORC: SI,System Classifications: On-Site Representative(s): Related Permits: Secondary Inspector(s): Primary Inspector: Inspection Date:Exit Time:Entry Time: Phone: 05/28/2024 11:00AM 12:15PM Melanie Kemp Facility Status: Permit Inspection Type: Reason for Inspection:Inspection Type: Not CompliantCompliant Routine Wastewater Irrigation Compliance Evaluation Question Areas: Miscellaneous Questions Treatment Treatment Filters Record Keeping End Use-Irrigation Treatment Influent Pump Station Treatment Disinfection Standby Power (See attachment summary) Page 1 of 6 DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0012690 05/28/2024 Compliance Evaluation State of NC - Division of Parks & Recreation Routine Inspection Summary: Melanie Kemp, with the Asheville Regional Office, met with EnviroLink staff (Matt Huckill, Todd Robinson, Kyle Callahan, and David Rogers) and Mt. Mitchell State Park staff (Tim Robinson and Kevin Cox) at Mt. Mitchell State Park on May 28, 2024, to conduct a Compliance Evaluation Inspection of the Mt. Mitchell State Park WWTF, to ensure it was operating in compliance with non-discharge permit WQ0012690. Wastewater from the campground and maintenance area flows into a septic tank where it is seasonally (May 15 – October 15) routed through the non-discharge wastewater treatment and irrigation system. The wastewater from the septic tank flows to a dosing tank where it is chlorinated and fed through the Perc-Rite system. The system doses the sand filter bed at 45-minute intervals at the rate of 225 gallons per dose (32 cycles per day, a total of 7,200 gallons maximum). From there it is fed to the drip fields, rotating between fields 1 and 2, which are dosed at 3-hour intervals at the rate of 225 gallons/dose. Throughout the day there are 8 dosing cycles. The drip field and sand filter lines are flushed back to the septic tank. Compliance samples are collected from the maintenance shed. Repairs: In May 2023, all drip lines and solenoid valves were replaced. Brush and low branches were removed from the field as well. The lines were re-inspected at the beginning of 2024. The flow meter to the drip field was replaced by EnviroLink prior to the 2024 season. After the inspection, the cover was removed from the sand filter and all tubing and emitters were exposed for inspection. Tim Robinson indicated that he in investigating replacing the tubing and emitters, as needed. Plumbing modifications: Based on inspection in 2022, it was recommended that the field/sand-filter flush line be plumbed into the headworks flush line and both be disconnected from the the pressure manifold supply line (with check valves installed) to ensure that backwash water does not enter the subsurface system supply line. Engineering plans were shared with the ARO by McGill & Associates in November 2023, but a final permit modification application has not been submitted and the plumbing work has not been completed. Violations noted during the inspection: •There is no Operations & Maintenace plan for the site (permit condition III.2). •The permittee will need to submit a minor modification to proceed with plumbing changes needed to ensure backwash water does not enter the subsurface supply line (permit condition III.12). •The sand filter needs to be covered to ensure rainwater is not collected and discharged through the drip irrigation lines and the cover should not restrict air circulation above the lined sand filter (permit condition III.15). According to the original design the tubing and emitters need to be covered by 4” of gravel. •The ORC indicated that the totalizer isn’t properly recording total dosing quantities for some of the drip field zones (permit condition IV.5). •The maintenance log at the facility needs to be kept up-to-date with the pertinent information (permit condition IV.8). Page 2 of 6 DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0012690 05/28/2024 Compliance Evaluation State of NC - Division of Parks & Recreation Routine Type Yes No NA NE Reuse (Quality) Infiltration System Lagoon Spray, LR Single Family Spray, LR Activated Sludge Spray, LR Activated Sludge Spray, HR Activated Sludge Drip, LR Single Family Drip Recycle/Reuse Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? Do all treatment units appear to be operational? (if no, note below.) Comment: Treatment Influent Pump Station Yes No NA NE Is the pump station free of bypass lines or structures? Is the general housekeeping acceptable? Are all pumps present? Are all pumps operable? Are floats/controls operable? Are audio and visual alarms available? Are audio and visual alarms operational? # Are SCADA/Telemetry alarms required? Are SCADA/Telemetry available? Are SCADA/Telemetry operational? High-water alarm was tested and operational during the inspection.Comment: Standby Power Yes No NA NE Is automatically activated standby power available? Is generator tested weekly by interrupting primary power source? Is generator operable? Does generator have adequate fuel? The diesel generator that supplies power to the WWTF is located next to the maintenance building, and is connected to multiple other buildings on-site. Park staff check and top off the fuel (67% full during inspection) and a contractor performs quarterly maintenance. The generator automatically exercises weekly. Comment: Page 3 of 6 DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0012690 05/28/2024 Compliance Evaluation State of NC - Division of Parks & Recreation Routine Treatment Filters Yes No NA NE Is the filter media present? Is the filter media the correct size and type? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids? Is the mud well free of excessive solids and filter media? Does backwashing frequency appear adequate? The sand filter was covered during the inspection, but the cover was removed and photos were provided to the ARO shortly after. Park staff plan on inspecting and replacing the tubing and emitters. These components will need to be covered by gravel and a breathable cover will need to be placed over the sand filter. Comment: Treatment Disinfection Yes No NA NE Is the system working? Do the fecal coliform results indicate proper disinfection? Is there adequate detention time (>=30 minutes)? Is the system properly maintained? If gas, does the cylinder storage appear safe? Is the fan in the chlorine feed room and storage area operable? Is the chlorinator accessible? If tablets, are tablets present? Are the tablets the proper size and type? Is contact chamber free of sludge, solids, and growth? If UV, are extra UV bulbs available? If UV, is the UV intensity adequate? # Is it a dual feed system? Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? If yes, then is there a Risk Management Plan on site? If yes, then what is the EPA twelve digit ID Number? (1000-____-____) If yes, then when was the RMP last updated? There are two chlorine tablet tubes and one was being utilized during the inspection.Comment: Record Keeping Yes No NA NE Is a copy of current permit available? Are monitoring reports present: NDMR? NDAR? Are flow rates less than of permitted flow? Are flow rates less than of permitted flow? Page 4 of 6 DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0012690 05/28/2024 Compliance Evaluation State of NC - Division of Parks & Recreation Routine Are application rates adhered to? Is GW monitoring being conducted, if required (GW-59s submitted)? Are all samples analyzed for all required parameters? Are there any 2L GW quality violations? Is GW-59A certification form completed for facility? Is effluent sampled for same parameters as GW? Do effluent concentrations exceed GW standards? Are annual soil reports available? # Are PAN records required? # Did last soil report indicate a need for lime? If so, has it been applied? Are operational logs present? Are lab sheets available for review? Do lab sheets support data reported on NDMR? Do lab sheets support data reported on GW-59s? Are Operational and Maintenance records present? Were Operational and Maintenance records complete? Has permittee been free of public complaints in last 12 months? Is a copy of the SOC readily available? No treatment units bypassed since last inspection? Lab sheets, NDMR's, and soil fertility results were provided by the ORC (EnviroLink) after the inspection. Operation & Maintenance logs are not being kept up-to-date with complete information. See summary for details. Comment: End Use-Irrigation Yes No NA NE Are buffers adequate? Is the cover crop type specified in permit? Is the crop cover acceptable? Is the site condition adequate? Is the site free of runoff / ponding? Is the acreage specified in the permit being utilized? Is the application equipment present? Is the application equipment operational? Is the disposal field free of limiting slopes? Is access restricted and/or signs posted during active site use? Are any supply wells within the CB? Are any supply wells within 250' of the CB? How close is the closest water supply well? Page 5 of 6 DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F Inspection Date: Permit: Inspection Type : Owner - Facility: Reason for Visit: WQ0012690 05/28/2024 Compliance Evaluation State of NC - Division of Parks & Recreation Routine Is municipal water available in the area? # Info only: Does the permit call for monitoring wells? Are GW monitoring wells located properly w/ respect to RB and CB? Are GW monitoring wells properly constructed, including screened interval? Are monitoring wells damaged? Vegetation in the irrigation area is regularly maintained and in acceptable condition during the inspection. All drip tubing and solenoid valves were replaced in 2023. Comment: Page 6 of 6 DocuSign Envelope ID: 95337D72-20E2-43A5-ABA3-3CAAD023F41F