NC0034207_NOV2017PC0097_20170217

A,
Certified Mail # 7015 1520 0003 5463 2046
Return Receipt Requested
February 16, 2017
Todd Holden
Madison County Board of Education
5738 US Hwy 26/70
Marshall, NC 28753 .
SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2017-PC-0097
Permit No. NCO034207
Laurel Elementary School WW-rP
Madison County
Dear Dr. Holden:
RECEIVEDINCDEODWR
FEB 2 3 2017
VllaterQuality
Permitting Section
The North Carolina Division of Water Resources conducted an inspection of the Laurel Elementary School WWTP
on February 14, 2017. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in NPDES WW Permit No. NC0034207. 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
Operations & Maintenance Plant is not being run, only pumped out as tanks fill up. Aeration basin is still 1/2 filled with
Part II. Section C.2 solids despite receiving a NOV about this issue from our office on 12/15/2015. The Permittee shall at all
times provide the operation and maintenance resources necessary to operate the existing facility at
optimum efficiency.
Effluent Sampling Sampling and monitoring is not taking place even though a discharge was observed during the
Part II. Section D.1,2,3 inspection. Representative sampling and monitoring, including flow measurement is a permit
requirement.
A previous inspection conducted on 15 December, 2015 found the facility to be non-compliant and the facility was issued a
Notice of Violation (NOV-2015-PC-0322) requiring removal of solids from the aeration basin.
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

In addition, the issues below must also be addressed:
• Pumping out all waste from your system without any treatment is only permissible with a Pump and Haul permit.
Pump and Haul isnot intended to be a permanent method of waste treatment. A Pump and Haul permit is
generally issued for a 6 -month time period. Please submit your application (which you will find enclosed with
this report) as soon as possible.
• Submit a. plan for a permanent solution to operate compliant with permit NCO034207 or close and remove the
facility to eliminate the discharge. An engineering evaluation of existing conditions and proposed changes shall
be included as necessary.
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 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 days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Discharge
Monitoring Report(s). 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.
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.
Additionally and if you have not already done so, you may wish to consider registering to use the Division's new
e -DMR system for the completion and electronic submittal of monthly Discharge Monitoring Reports (DMRs).
For more information, please visit the eDMR Website at the following address:
http //aortal ncdenr org/web/wq/admin/bog/ipu/edmr
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

If you should have any questions, please do not hesitate to contact Daniel Boss with the Water Quality
Regional Operations Section in the Asheville Regional Office at 828-296-4500.
Sincerely,
G. Landon Davidson, P.G., Regional Supervisor
Water Quality Regional Operations Section
Asheville Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Asheville Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File
G:\WR\WQ\Madison\Wastewater\Minors\Laurel Elementary 34207\CEI.2.15.2017\CEI.2.15.2017 NOV-2017-PC-0097.Rtf
State of North Carolina I Environmental Quality I Water Resources
2090 U.S. 70 Highway, Swannanoa, NC 28778
828-296-4500

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 15 I 3-1 NCO034207 - I11 12 17/02/14 17 18 I,,I 19 L!I' 201 I
2111111111IIIIIIIIIIIIIIIIIIIIIII I I I I I I I I I I I �6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
67 70 u 71 I I 72 LL N C 73 I 174 751 I I I I � �80
_I
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 permit Number)
11:00AM 17/02/14
15/10/01
Laurel Elementary School WWTP
1255.NC Hwy 212
Exit Time/Date
Permit Expiration .Date
Marshall NC 28753
11:45AM 17/02/14
20/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Randy A Joseph/ORC/828-622-7591/
Name, Address of Responsible Of iicial/Title/Phone and Fax Number
Contacted
Woody Ammons, 115 Blannahassett Is Marshall NC 28753//828-649-9276/
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit ... ® Operations & Maintenanc6 ® Self.-Monitoring Program ® 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
Daniel J Boss jig ARO WQ//828-2964658/
Signature of Manageme eviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day. Inspection Type (Cont.)
31 NC0034207 I11 12 17/02/14 17 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets,of narrative and checklists as necessary)
I (Dan Boss) conducted a follow up inspection at Laurel Elementary School on 2/14/2017. Randy
Joseph (ORC) was present for the inspection. Randy said that the gravel had not been removed from
the aeration tank as was requested at the last inspection on 12/14/2015. Randy said he has been
pumping the tanks down as they fill up (about once every 3 months). This is not a permittable method
of treating wastewater long term, and requires a pump and haul permit even in temporary or
emergency circumstances.
When I arrived on site, the effluent pipe had a small discharge coming from it and the wastewater tanks
were completely full. There was a strong smell of sewage and some solids floating at the surface.
Randy believed that the tanks filled up from rain water, but there had been little rain in the period since
he had last visited on 1/26/2017. The water to the school is shut off, but there is another building on the
property that is still being used 4 days per week as the Shelton Laurel Nutrition Site for Madison
County. Randy was unsure if that building was connected to the same wastewater system as the
elementary school or if it had it's own septic tank and drainfield. I spoke with Joe Davis on 2/15/2017;
and he confirmed that the Shelton Laurel Nutrition Site's sewer is connected to the Laurel Elementary
School WWTP. Consequently this plant needs to be restarted to properly treat this wastewater. The
aeration basin will first need to have the sand/gravel removed before the system is restarted.
Page#

Permit: NCO034207 Owner - Facility: Laurel Elementary School WWfP
Inspection Date: 02/14/2017 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or le -ss). Has the permittee submitted a new
❑
❑
M.
❑
application?
❑
❑
❑
Is the facility as described in the permit?
0
❑
❑
❑
# 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?
0
❑
❑
❑
Comment: Permit is active, though the facility is not operating.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ M ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Plant is not being run properly, the tanks are merely being pumped out as they fill up.
Aeration basin is full of gravel, and has been for over a year.
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are.the.:bars..adequatelyScreening debris?.
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment: Could not see bar screen.
Yes - No NA NE
Secondary Clarifier
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?
Yes No. NA NE
❑ M ❑ ❑
0 ❑ ❑ ❑
❑ ❑ ❑ ■
❑ 0 ❑ ■
❑ ❑
❑ ■ ❑ ❑
❑ ■ ❑ ❑
❑ ❑ ❑ .0
Page# 3
El
❑
❑
❑
M
❑
❑
❑
❑
❑
❑
■
Secondary Clarifier
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?
Yes No. NA NE
❑ M ❑ ❑
0 ❑ ❑ ❑
❑ ❑ ❑ ■
❑ 0 ❑ ■
❑ ❑
❑ ■ ❑ ❑
❑ ■ ❑ ❑
❑ ❑ ❑ .0
Page# 3

Permit: NCO034207 Owner - Facility:
Laurel Elementary School wVV7P
Is composite sampling flow proportional?
❑
Inspection Date: 02/14/2017 Inspection Type:
Compliance Evaluation
❑
Is sample collected below all treatment units?
Secondary Clarifier
Yes No NA NE
Is the return rate acceptable (low turbulence)?
❑ ❑
❑
'M
Is the overflow clear of excessive solids/pin floc?
❑ ❑
❑.
0
Is the sludge blanket level acceptable? (Approximately % of the. sidewall depth)
❑ ❑
❑
0
Comment: Plant is not being run.
❑
❑
0
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air.
Type of aeration system
Diffused
0
❑
Is the basin free of dead spots?
❑
❑
❑
Are surface aerators and mixers operational?
❑ ❑
❑
0
Are the diffusers operational?
❑ M
❑
❑
Is the foam the proper color for the treatment process?
0 ❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑
❑
❑
Is the DO level acceptable?
❑ 0
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/1)
❑ M
❑
❑
Comment: Aeration basin is not_being run and is still 1/2 full of gravel/sand.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
❑
❑'
M
❑
Is proper volume collected?
❑
❑
0
❑
Is the tubing clean?
❑
❑
M
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
❑
0
❑
❑
representative)?
Comment: Samplinq is not taking place.
Effluent Pipe
Yes No' NA NE'
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: Very small discharge from effluent pipe during the inspection.
Page# 4