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Home My WebLink AboutNC0086053_NOV2017PC0131_20170317Certified Mail # 7015 1520 0003 5463 2336 Return Receipt Requested March 7, 2017 Joey Cupp Pilot Travel Centers LLC 5508 Lonas Rd Knoxville, TN 37909-3221 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2017-PC-0131 Permit No. NCO086053 Pilot Travel Center #393 Haywood County Dear Permittee: C IV DIN10DE0011R tk,!.AIR 13 2017 Water Quality The North Carolina Division of Water Resources conducted an inspection of the Pilot Travel Center #393 on February 28, 2017. This inspection was conducted to determine if the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NCO086053 and to determine whether any steps have been taken..to address. the.failing system components. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. - The Follow -Up 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 Secondary Clarifier One of the two secondary clarifiers is still offline. At the time of the inspection, inspectors observed significant floating solids in the operable secondary clarifier, and the plant was discharging effluent with significant solids and turbidity. [NPDES Standard Permit Conditions Part 11 C,2. Operation and Maintenance of Pollution Controls. 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.] Operations & Maintenance The treatment units and facility components appear to be reaching the end of their useable life. The structural integrity of some of the concrete tanks is suspect and may present a safety hazard. [NPDES Standard Permit Conditions Part 11 C.2. Operation and Maintenance of Pollution Controls., 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.] State of North Carolina I Environmental Quality I Water Resources 2090 U.S. 70 Highway, Swannanoa, NC 28778 Flow Measurement - Effluent The ultrasonic sensor appeared to be operational, but the weir was significantly out of level and effluent flow was almost overtopping the v -notch weir. Overtopping and weir misalignment cause inaccurate flow measurements. [NPDES Standard Permit Conditions Part ll D.3 Flow Measurements. F/ow measurement devices shall be accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device,] 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. 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. If you should have any questions, please do not hesitate to contact Mikal Willmer 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: Inspection Report Cc: Joedavid Hall, ORC-Environmental Inc. WQS Asheville Regional Office Enforcement Eile NPDES Compliance/Enforcement Unit - Enforcement File 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 I NC0086053 I11 12 17/02/28 17 18 191 S I 201 I 211 1 1 I I I I I I I I I I I I I I I I 11- 1 1 1 1 1 1 1 1 1 1 1 1 1 11 I I I 1 1 r6 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA .Reserved 67 70 71 Li72 � ,,, � 73 I I 174 751 , I I I. I I I I80 LJ 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) 02:16PM 17/02/28 16/12/01 Pilot Travel Center #393 Exit Time/Date Permit Expiration Date NC Hwy 209 At 1-40 Waynesville NC 28766 02:45PM 17/02/28 21/01/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Joedavid Matthew Hall/ORC/828-586-5588/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Joey Cupp,PO Box 10146 Knoxville TN 379390146//865-5B8-7488/6654502809 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) �::Peirtit.,..:':•...:..,_. :_.::.® Flow Measurement _:. . ' _� Operations:&Maintenanc6 ::® Self-Monitoring Rrograrti• .:-'• . Facility Site Review Effluent/Receiving Waters Other 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 Timothy H Heim ARO WQH828-296-4665/ Mikal Willmar e�/ ( ARO WQH828-296-4686/ Signature of Management Q-A-Reviewer Agency/Office/Phone and Fax Numbers Date r'' EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) 1 31 NC0086053 I11 12 17/02/29 17 18 1 C Section D: Summaryof Finding/Comments (Attach additional �s Iheets of narrative and checklists as necessary) Inspectors, Mikal Willmer and Tim Heim with the Asheville Regional Office conducted a Follow -Up Inspection of the Pilot Travel Center's WWTP on February 28, 2017. ORC, Joedavid Hall with Environmental Inc, was present and assisted in the inspection. This inspection was conducted to check on the current operational status of the treatment facility and to determine whether any steps have been taken to address the failing system components since the last correspondence with Dynamis in November of 2016. According to Mr. Hall, the solids are still being wasted and hauled routinely. The pump station is being serviced as needed. There appears to be a continued problem with the pumps clogging in the lift station. Mr. Hall reported the water level in the EQ basin was running higher than normal (above the floats). This may be a possible issue with the float switch. The ORC stated the plant has been experiencing a surge in flow the past couple of days. Inspectors -observed floating solids within the secondary clarifier. ORC is uncertain of the cause at this time. This may be due to the composition of microorganisms within the secondary clarifier, preventing solids from properly settling. The RAS rate may need to be adjusted to reduce denitrification. Changes in weather and influent composition can also contribute to the growth of non -target organisms within the treatment system. The increase in floating solids appears to also be contributing to the presence of suspended solids in the effluent. During the inspection, inspectors observed turbid effluent and floating solids discharging, through the weir. Additionally, the ultrasonic flow meter may not be reading accurately as the effluent flow was almost overtopping the weir plate. The weir also appears to be significantly out of level. Inspectors understand that an engineering evaluation is planned to occur in the immediate future to assess the needs of the VWVfP. To date, the issue with the inoperable secondary clarifier has not been resolved. The effectiveness of the treatment system is not -optimal. The treatment plant was originally designed to utilize two secondary clarifiers, however, only one is operable. Most of the treatment=units appear to be reaching the end of their useable life. Pilot Travel's ultimate goal is to connect to Junaluska Sanitary District's. collection system in the future, however, the date of service availability has not been determined. Initial dates estimated by the end of 2017, but a sewer connection may be up to five years away. Issues from previous violation not addressed or partially resolved: Secondary Clarifier: One of the secondary clarifiers is still inoperable. The operable secondary clarifier does not seem capable of adequately treating the incoming daily flow. Excessive solids were observed in the operable clarifier. The permittee listed a potential corrective action to bring the -second clarifier back into operation, but to date the clarifier is still offline. Operation' & Maintenance: The ORC is conducting the required visits, however, many of the treatment components are still deteriorating. Safety and trip hazards are still present. Effluent: The effluent appeared turbid and, solids were entering the effluent channel. Page# Permit: NCO086053 Owner -Facility: Pilot Travel Center #393. Inspection Date: 02/28/2017 Inspection Type: 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 M ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The treatment units and facilitv components appear to be reachina the end of their useable life. At the time of the inspection, inspector observed significant floating solids in the and weir Operable secondary clarifier, and the plant was discharging effluent with significant solids .and turbidity. The structural integrity of some of the concrete tanks is suspect and may misalignment cause inaccurate flow measurements. present a safety hazard. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ 0 ❑ application? Yes No NA NE Is the facility as described in the permit? M ❑ ❑ ❑ # Are there any special conditions for the permit? 0 ❑ ❑ ❑ Is access to the plant site restricted to the general public? M ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The treatment system does not appear to be operating optimally. Floating solids are making 0 it through the treatment process to.the effluent channel and effluent is turbid. Several of the ❑ other treatment units appear to need replacement or repair (effluent weir is not level, EQ ❑ float switches not working properly at the time of the inspection, and the CIRC reports lift station pumps have continuous issues with clogging). - Other Comment: Flow Measurement - Effluent # 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? Yes No NA NE Yes No NA NE ❑ ❑ ❑ M ❑ ❑ ❑ M ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The ultrasonic sensor appeared to be operational, but the weir was significantiv out of level and effluent flow was almost overtopping the v -notch weir. Overtopping and weir misalignment cause inaccurate flow measurements. Pump Station - Effluent Yes No NA NE Is the pump wet well.free of bypass lines or structures? ❑ ❑ ❑ 0 Are all pumps present? ❑ ❑ ❑ 0 Are all pumps operable? ❑ ❑ ❑ M Page# 3 Permit: NCO086053 Owner -.Facility: Pilot Travel Center #393 Inspection Date: 02/28/2017 Inspection Type: Compliance Evaluation Pump Station - Effluent Yes No NA NE* Are float controls operable? ❑ ❑ ❑ M Is SCADA telemetry available and operational? ❑ ❑ ❑ A Is audible and visual alarm available and operational? ❑ ❑ ❑ 0 Comment: Inspectors did not visually inspect the lift station between the travel center and the, ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? wastewater plant. The ORC stated they continue to have problems with the pumps clogging. M ❑ Are weirs level? Equalization Basins 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? Yes No NA NE M ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ M ❑ ❑ ❑ ■ ❑ ❑ ❑ V Comment: During the inspection there appeared to be an issue with the float controls. The water level was above the high water float, potentially leading to weir overtopping and inaccurate effluent flow measurement. -, Secondary.Clarifier!:::,_..a:.... w_..... ,. _...:....:_ :`....,.: _Yes..No.;Nk ME.,: Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ M ❑ Are weirs level? 0 ❑ ❑• ❑ Is the site free of weir blockage? ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? ❑ 0 ❑ ❑ Is the drive unit operational? ❑ ❑ 0 ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ 0 Is the overflow clear of excessive solids/pin floc? M ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately %4 of the sidewall depth) ❑ ❑ ❑ M Comment: One of the two secondary clarifiers is still offline. Floating solids covered the surface of the active secondary clarifier. The CIRC reported issues recentiv with solids settling. Solids were observed passing through the clarifier to the effluent channel. Consider adjusting RAS rate to reduce denitrification or investigate FOG issues. Page# 4 Permit:. NCO086053 Owner - Facility: Pilot Travel Center #393 Inspection Date: 02/28/2017 Inspection Type: Compliance Evaluation Aeration Basins Mode of operation Type of aeration system 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/1) Comment: Yes No NA NE Ext. Air Diffused N ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ORC reported diffusers were working properly. Recently had solids remove from aeration basin. ORO stated MLSS was running between 5000 and 6000 mg/L. . Effluent Sampling 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)? Yes No NA NE ❑ ❑ 110 ❑ ❑ ❑ N ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ N ■ ❑ ❑ ❑ Comment: There were no limit violations in 2016, however, the system, in its current state, does not appear capable of providing consistent quality wastewater treatment. Page# 5