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Home My WebLink AboutNC0034304_NOVNOI-2024-PC-0455_20240731 (2) Certified Mail # 9589 0710 5270 0475 7190 77 Return Receipt Requested July 31, 2024 Matthew Knauer Young Life Ministries 120 Coles Crove Rd Weaverville, NC 28787 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2024-PC-0455 Permit No. NC0034304 Windy Gap Camp WWTP Buncombe County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Windy Gap Camp WWTP on June 27, 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. NC0034304. 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 Analytical results are not consistent with the data that is being reported on DMR’s. _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling Composite sampling is not flow proportional. _________________________________________________________________________________________________________________________________________________________________________ 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. Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B 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 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 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, Gary Kuykendall (ORC) Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B 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 NC0034304 24/06/27 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) Windy Gap Camp WWTP 2000 Lowery St Weaverville NC 28787 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 09:30AM 24/06/27 20/12/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Gary Dean Kuykendall/ORC/828-645-7187/ Other Facility Data 11:00AM 24/06/27 25/10/31 Name, Address of Responsible Official/Title/Phone and Fax Number Gary D Kuykendall,120 Coles Cove Rd Weaverville NC 28787/Maintenace Tech/828-645-7187/ 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 Melanie Kemp DWR/ARO WQ/ - - / 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: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B NPDES yr/mo/day 24/06/27 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Melanie Kemp with the Asheville Regional Office conducted a Compliance Evaluation Inspection of the Windy Gap Camp WWTP on June 27, 2024. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0034304. Gary Kuykendall, ORC, was present and assisted with the inspection. Overall the facility was operating well and no major issues were noted. Recordkeeping review of DMRs and associated lab reports indicates there are over 60 limits violations that have been incorrectly reported on DMRs going back to 1/1/2021. During the inspection, the following issue was noted: •The DO level (0.66 mg/L) in the steel plant was not within the acceptable range (1.0 – 3.0 mg/L). During the inspection, the following violations were noted: •Analytical results are not consistent with the data that is being reported on DMR’s. •Composite sampling is not flow proportional. The ORC will need to revise and resubmit all incorrect DMRs. NC0034304 17 (Cont.) Page#2 Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B Permit:NC0034304 Inspection Date:06/27/2024 Owner - Facility: Inspection Type: Windy Gap Camp WWTP Compliance Evaluation 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? The ORC analyzes for settlable solids 2x/day, pH daily, DO 2x/week, and sludge judge 2x/week. 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? 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? There are over 60 falsely reported results that violate permit limits for fecal, BOD, TSS, and ammonia results going back to 1/1/2021. Comment: 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? Page#3 Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B Permit:NC0034304 Inspection Date:06/27/2024 Owner - Facility: Inspection Type: Windy Gap Camp WWTP Compliance Evaluation Permit Yes No NA NE # 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: 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? Manual bar screen is cleaned daily.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? Low/normal flow goes directly into the aeration basin and the EQ basin serves as a surge tank. It should be noted that there are plans for the EQ tank to be replaced with a new one of the same size. 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? Page#4 Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B Permit:NC0034304 Inspection Date:06/27/2024 Owner - Facility: Inspection Type: Windy Gap Camp WWTP Compliance Evaluation Aeration Basins Yes No NA NE 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 steel plant (above) is often turned off in the winter when flows are lower. Steel plant: settability 55%, DO 0.66 mg/L. Concrete plant: settleability 80%, DO 3.75 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) Sludge blanket 5.5/15 feet at concrete plant clarifier and 5/10 ft at steel plant clarifier.Comment: De-chlorination Yes No NA NE Type of system ?Chlorine 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: Disinfection-Tablet Yes No NA NE Page#5 Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B Permit:NC0034304 Inspection Date:06/27/2024 Owner - Facility: Inspection Type: Windy Gap Camp WWTP Compliance Evaluation Disinfection-Tablet Yes No NA NE Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use?4 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 contact chamber is pumped 2x/year.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? Flow meter last calbirated 3/27/24.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)? Composite sampling is not flow proportional. All grab samples are collected from the effluent pipe and compostite samples are pulled from a manhole below all treatment units. Comment: Page#6 Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B Permit:NC0034304 Inspection Date:06/27/2024 Owner - Facility: Inspection Type: Windy Gap Camp WWTP Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Upstream samples are collected next to the shop and downstream are collected near the gate bridge. 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? There are two digesters. The concrete plant wastes to either and the steel plant wastes to the larger/lower digester only. About one load is pumped from the digesters weekly. Air is only added to the smaller digester on occasion. Comment: Page#7 Docusign Envelope ID: DF3B3A4E-8308-42A8-AC47-79BC3BC6627B