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HomeMy WebLinkAboutNC0080098_NOV2017PC0460_20170717ly Certified Mail # 7016 1370 00016571 7594 Return Receipt Requested July 11, 2017 Dr. Andrew Price Linville Falls Club Property Association Inc 34 Blue Ridge Dr. North Marion, NC 28647 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking Number: NOV-2017-PC-0460 Permit No. NCO080098 Linville Falls Mountain Club and Preserve McDowell County Dear Permittee: Roy COOPER 002tgW MICHAEL S. REGAN drnry S. JAY ZI MERMAN Dfreetor RECEIVEDINCDEWWR JUL 17 2017 Water Quality Permitting Section The North Carolina Division of Water Resources conducted an inspection of the Linville Falls Mountain Club and Preserve on July 7, 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. NC0080098. 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 Composite sampler is not set up for flow proportional sampling. Also, the sampler is not capable of drawing correct aliquot volumes. An attempt at drawing a 100ml sample resulted in an aliquot of about 2-3 liters. Part IT A Composite Sample (4) Constant tim%onstant volume: Use of this method requires approval by the Director. This method may only be used in situations where effluent flow rates vary by less than IS percent, Additional Compliance Issue: Access to the effluent pipe is not being maintained. A fence has been erected where there was previously access to the outfall. State of North Carolina Environmental Quality Water Resources 2090 U S 70 Highway, Swannanoa, NC 28778 828-296-4500 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. 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 da res 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 nat 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 e9 P Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Cc: James & James Environmental/ORC WQS Asheville Regional Office - Enforcement File NPDES Compliance/Enforcement Unit - Enforcement File G \WR\WQ\McDowell\Wastewater\Minors\Linville Falls Blue Ridge Country Club 80098\NOV-2017-PC-0460 rtf 7 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 NCO080098 I11 12 17/07/07 17 18 I r l 19 I G I 201 I 21111111 1111111111111111111111111 11111111111 r6 I Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA --Reserve d 67 70 I 71 I I 72 L r, � 73 I 174 751 1 1 1 1 1 180 LJ JData LJ I I I Section B Facility 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 05PM 17/07/07 15/08/01 Linville Falls Mountain Club and Preserve Exit Time/Date Permit Expiration Date 17677 Hwy 221 N Marion NC 26752 03 40PM 17/07/07 19/12/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Andy Price, //828-756-4316/ Contacted Yes Section C Areas Evaluated During Inspection (Check only those areas evaluated) Permit E Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 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(Qs)) of Inspector(s) Agency/Office/Phone and Fax Numbers Date \ Daniel J Boss �U ARO WQ//828-296-4658/ 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# NPDES yr/mo/day Inspection Type (Cont) 31 NCODS0098 I11 12 17/07/07 17 18 C Section D Summary of Finding/Comments ;Attach additional sheets of narrative and checklists as necessary) On 7/7/2017, 1 (Daniel Boss) conducted an Inspection at Linville Falls Mountain Club and Preserve Juanita James and Dr Andrew Price were present for the Inspection This plant has had difficulty meeting permit limits for BOD & TSS in the last 16 months, but the plant seems to be operating well and in good condition Juanita said they mostly use the settleability test to control the activated sludge process, although occasionally they also run a IVLSS test She said the DO is kept around 7 0 mg/L The dechlorination tubes have been moved temporarily to try and get more BOD treatment from the tertiary filter The chlorinator and dechlorinator are both positioned prior to the tertiary filter now Whereas previously the chlorinator preceded the tertiary filtration and the dechlorinator was positioned beyond the tertiary filtration I think the treatment layout that makes the most sense is to position both the chlorinator and dechlorinator downstream of the tertiary filter to prevent any possible fecal coliform contamination of the wastewater from the tertiary filtration unit The effluent sampler is not working properly It's not wired to the effluent meter to allow for flow proportional composite sampling When the sampler is set up to take a 100 ml aliquot, it draws about 2-3 liters of effluent When it is setup to take a 10ml aliquot It still draws about 700-1000ml The access to the outfall Is not being properly maintained A fence has been erected blocking the old path to the outfall Possibly a gate could be placed in the corner of the fence nearest to the outfall, or vegetation could be cleared around the outside perimeter of the WWTP fence to gain access to the outfall Page# T Permit. NCO080098 Owner - Facility Linville Falls Mountain Club and Preserve Inspection Date 07/07/2017 Inspection Type Compliance Evaluation Yes No NA NE Permit Yes No NA NE (If the present permit expires in 6 months or less) Has the permittee submitted anew ❑ ❑ 0 ❑ application? ❑ ❑ Is the basin free of excessive grease? 0 Is the facility as described In the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ E ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the Inspector granted access to all areas for Inspection? N ❑ ❑ ❑ Comment ❑ N # Is basin size/volume adequate? 0 Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? N ❑ ❑ ❑ Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? ❑ ❑ ❑ E Are audible and visual alarms operable? ❑ ❑ ❑ N # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment Aeration Basins Yes No NA NE Mode of operation Ext Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? E ❑ ❑ ❑ 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? ❑ ❑ ❑ 0 Page# 3 Permit NCO080098 Owner - Facility Linville Falls Mountain Club and Preserve Inspection Date 07/07/2017 Inspection Type- Compliance Evaluation Aeration Basins Yes No NA NE Is the DO level acceptable?(1 0 to 3 0 mg/1) ❑ ❑ ❑ N Comment Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? E ❑ ❑ ❑ Is the site free of excessive buildup of solids In center well of circular clarifier? ❑ ❑ N ❑ Are weirs level? ❑ ❑ ❑ N Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? M ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ N ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) ❑ ❑ ❑ 0 Comment Filtration (High Rate Tertiary) Yes No NA NE Type of operation Down flow ❑ ❑ Is the filter media present? E ❑ ❑ ❑ Is the filter surface free of clogging? N ❑ ❑ ❑ Is the filter free of growth? 0 ❑ ❑ ❑ Is the air scour operational? ❑ ❑ 0 ❑ Is the scouring acceptable? ❑ ❑ N ❑ Is the clear well free of excessive solids and filter media? 0 ❑ ❑ ❑ Comment Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? E ❑ ❑ ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Number of tubes In use? 2 Is the level of chlorine residual acceptable? ❑ ❑ ❑ 0 Is the contact chamber free of growth, or sludge buildup? N ❑ ❑ ❑ Page# 4 I Permit. NCO080098 Owner - Facility. Linville Falls Mountain Club and Preserve Inspection Date. 07/07/2017 Inspection Type Compliance Evaluation Disinfection -Tablet Yes No NA NE Is there chlorine residual prior to de -chlorination? 0 ❑ ❑ ❑ Comment De -chlorination k Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)7 ❑ ❑ E ❑ Is storage appropriate for cylinders? ❑ ❑ 0 ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ ❑ 0 Comment Are the tablets the proper size and type? 0 ❑ ❑ ❑ Are tablet de -chlorinators operational? ❑ ❑ ❑ Number of tubes in use? 2 Comment 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? ❑ ❑ N ❑ Comment Access to the outfall is not being maintained. A fence has been erected where there used to ❑ be access to the outfall Is the tubing clean? N ❑ Effluent Samaling Yes No NA NE Is composite sampling flow proportional? ❑ E ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ❑ S ❑ ❑ Is the tubing clean? N ❑ ❑ ❑ # 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 ❑ S ❑ ❑ representative)? Comment Composite sampler is not set Up for flow proportional sampling Attempt at drawing 1 aliquot resulted in about 700-1000 ml draw Attempt at 100ml draw resulted in an aliquot of about 2-3 liters Page# 5