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HomeMy WebLinkAboutNCG551475_NOV2017PC0719_20171217Water Resources ENVIRONMENTAL QUALITY ROY COOPER Govei nor MICHAEL S. REGAN Secretary LINDA CULPEPPER Intet tm Directoi December 28, 2017 CERTIFIED MAIL RETURN RECEIPT REQUESTED RECEIPT # 7017 2680 0000 2219 2571 KENNETH LEE MCDOWELL UNITED ENERGY, INC. RALEIGH, NORTH CAROLINA 27608 Subject Notice of Violation and Notice of Intent to Enforce NOV-2017-PC-0719 NPDES Wastewater Treatment System Handee Hugo #96 6927 Buffalo Road, Raleigh COC No. NCG551475 Wake County Dear Mr. McDowell. On December 14, 2017 Cory Larsen, PE from Wake County Department of Environmental Services, on behalf of the Division of Water Resources, performed a follow-up compliance evaluation inspection of the subject NPDES wastewater treatment system. The purpose of the inspection was to evaluate the current status of the ultraviolet disinfection equipment following repair or replacement since the previous complaint inspection on June 14, 2017. The following permit condition violations were observed at your facility and require your prompt attention (also refer to the attached photographs and inspection report)• 1) The primary and backup ultraviolet disinfection bulbs were non -operational at the time of the inspection; the power supply cable to the secondary lamp was severed and the control panel switch was in the off position. The system was not producing an audible or visual alarm in either switch position This marks the third consecutive inspection where the UV system was not functioning. The faulty UV system components must be put back into service either by repair or replacement immediately. Item 1 constitutes a violation of Part I Permit Conditions (Operation & Maintenance) of General Permit NCG550000 which requires in part that, "All system components, including but not necessarily limited to, septic tanks, surface sand filters, other filter components, Division of Water Resources, Raleigh Regional Office, Water Quality Operations Section http //portal ncdenr org/web/wq/aps 1628 Mail Service Center, Raleigh, NC 27699-1628 Phone (919) 791-4200 Location: 3800 Barrett Drive, Raleigh, NC 27609 Fax (919) 788-7159 NOV-2017-PC-0719 December 20, 2017 Page 12 pump/recirculation tanks, controls and alarms, disinfection units, dechlorination apparatus, and the outfalls shall be maintained at all times and in good operating order " Failure to report the violations noted in Item 1 above is also a violation of Part II E. Twenty-four Hour Reporting which requires reporting of any noncompliance that potentially threatens public health or the environment (such as discharge of non -disinfected wastewater effluent as follows). Twenty-four Hour Reporting a. The Permittee shall report to the Director or the appropriate Regional Office any noncompliance the potentially threatens public health or the environment. Any information shall be provided orally wit hours from the time the Permittee became aware of the circumstances. A written submission shall a] provided within 5 days of the time the Permittee becomes aware of the circumstances. The written s shall contain a description of the noncompliance, and its cause; the period of noncompliance, incluc dates and times, and if the noncompliance has not been corrected, the anticipated time it is expected continue; and steps taken or planned to reduce, eliminate, and prevent reoccurrence of the noncomp CFR 122.41(1)(6)]. b. The Director may waive the written report on a case-by-case basis for reports under this section if tl report has been received within 24 hours. c. Occurrences outside normal business hours may also be reported to the Division's Emergency Resp personnel at (800) 662-7956, (800) 858-0368 or (919) 733-3300. Requested Response Please be advised that this office is considering recommendation of enforcement action to the Director of the Division of Water Resources. This office requests a written response addressing the repeated violations noted above within 30 days of receipt of this Notice. Your response should be directed to the address on the footer of page 1 and must address the following items: 1. Explain why the primary and backup ultraviolet disinfection bulbs were non -operational. 2. Also, clearly explain in your response why the power supply cable to the secondary lamp was severed and the control panel switch was in the off position. 3. Provide a summary of all work done on the ultraviolet disinfection system including receipts for repairs from 2016 to the present date and detail why the system continues to experience failures. 4. Provide a plan to prevent future occurrences of disinfection failures. You may include an increased operation and maintenance schedule as part of your response. NOV-2017-PC-0719 December 20, 2017 Page 13 Your response to this letter will be considered as a part of any civil penalty/enforcement recommendation. These violations and any future violations are subject to civil penalty assessment of up to $25,000.00 per day per violation. If you have any questions concerning this Notice, please contact Cory Larsen at 919-480-9998 or me at 9) 791- 0. S'ncerel Danny Smit ,Supervisor Water Quality Regional Operations Raleigh Regional Office Encl: DWR Inspection Report Photos from December 14, 2017 Inspection cc: Wake County Department of Environmental Services File RRO File Charles Weaver — NPDES Permitting Unit Dave Welch, ORC — Brantley and Sons (37 Pine Ridge Rd, Zebulon, NC 27597) NOV-2017-PC-0719 December 20, 2017 Page 14 Figure 1: Damaged UV lamp NOV-2017-PC-0719 December 20, 2017 Page 15 Figure 2: UV lamp switch in OFF position. No alarm active for either primary or secondary lamps when switched on. 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 1 3 I NGG551475 I11 12 I 17/12/14 117 18 L] 19 1 .s I 201 I 21111111111111111111111111111111111111111111 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --Reserved------ �i 1 67 70 71 I] 72 L-1 731 I X 174 751 1 1 1 1 1 1 180 I I 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) 10 OOAM 17/12/14 13/08/01 Handee Hugo #96 6927 Buffaloe Rd Exit Time/Date Permit Expiration Date Raleigh NC 27616 11 OOAM 17/12/14 18/07/31 Name(s) of Onsite Rep resentative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Kenneth Lee McDowell,3309 Drake Cir Raleigh NC 27607//919-606-77001 No Section C Areas Evaluated During Inspection (Check only those areas evaluated) ® 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 Cory Larsen RRO WQ//919-856-7443/ 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 1 31 NCG551475 111 121 17/12/14 117 18111 Section D Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) WCES conducted a followup Inspection on December 14, 2017 at the facility to check on the UV disinfection system which had been faulty during the last two earlier Inspections The unit was found to be damaged with wires separated from the head of the column Neither primary nor secondary lamp was operable No alarm was active the system may have been turned off manually to prevent further damage __ NOV will be drafted -- Page# Permit NCG551475 Inspection Date 12/14/2017 Other Owner - Facility Hendee Hugo #96 Inspection Type Complaint Comment UV disinfection was damaged and not operable at the time of the Inspection Yes No NA NE Page#