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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