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Home My WebLink AboutNCG500671_Compliance Evaluation Inspection_20180821 .6,4sTATEf4i..„ 443(4,1,16 I f ROY COOPER NORTH CAROLINA Governor Environmental Quality MICHAEL S.REGAN Secretary LINDA CULPEPPER Interim Director CERTIFIED MAIL 7013-1710-0002-1922-2460 RETURN RECEIPT REQUESTED August 21, 2018 Ms. Allison Kemp-Sullivan Miles Annas Cooling Tower 438 Academy Street, BB Dougherty Administration Boone, NC 28608 SUBJECT: Compliance Evaluation Inspection and Notice of Deficiency NOD Tracking Number: NOD-2018-PC-0263 Miles Annas Cooling Tower (Appalachian State University) NPDES Permit No. NCG500671 Watauga County Dear Ms. Kemp-Sullivan, On August 1, 2018, Kelli Park and Gary Hudson, of this office, met with Daniel Gryder, Appalachian State Engineer, to perform a Compliance Evaluation Inspection on the Milles Annas Cooling Tower. This type of inspection consists of two basic parts: a file review and an on-site inspection of the treatment facility. The attached Environmental Protection Agency inspection form notes the areas that were evaluated for this inspection. The findings and observations are outlined below: I. Permit The NPDES permit became effective December 16, 2014. The annual fee was paid each year since then, and is currently not due again until November 30, 2018. The facility did not have a copy of the permit available during the inspection, however Mr. Gryder emailed Miss Park a copy of the Certificate of Coverage and permit after the inspection. It is required that a copy of the Certificate of Coverage as well as the permit is available on site. Q North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27103 336.776.9800 Miles Annas Cooling Tower,August 2,2018 II. Self-Monitoring Program • According to the General Permit, the facility should be monitoring the flow of the discharge from the plant, temperature, total residual chlorine, oil and grease, pH, and chemical oxygen demand semi-annually. This monitoring is not being done. Steps need to be made to begin monitoring these parameters as soon as possible. Once they have been measured please send a copy of the results to Miss Park. III. Records/Reports , Mr. Gryder emailed Miss Park the recent conductivity, pH, and hardness data that the plant has monitored for from May 2018 to July 2018. Conductivity and hardness do not have limits specified in the permit. pH, however, was in compliance with the permit limits. IV. Flow Measurement The flow is intermittent out of the plant and is discharged from the basin of the cooling tower. The basin is drained and rinsed with fresh water 3-5 times a year. Discharge typically occurs at the end of cooling season, typically in the fall/winter once there,is no more air conditioning use. All other drainage is blowdown discharge done by the mechanical room and discharged into a sanitary sewer. These drainages are typically much smaller than at the end of cooling season. The engineers are considering ways to reroute the waste discharge to the sanitary sewer in the future. There is no flow measurement out of the plant. In accordance with the permit, the flow needs to be estimated and reported semi-annually. V. Operations and Maintenance The cooling tower and mechanical building appeared to be well maintained and operated. Operators are not required to maintain the Miles Annas Cooling Tower, as specified in the permit. Mechanics keep it operational. VI. Facility Site Review The cooling tower is located next to a small parking lot behind the Student Union building on Appalachian State University's campus. The general public could walk up to the cooling tower. There is a control/mechanical room nearby the cooling tower that has restricted access. 2 Miles Annas Cooling Tower,August 2,2018 3 VII. Effluent/Receiving Waters The effluent from the facility was not seen the day of inspection. Effluent is,discharged into an unnamed tributary to Boone Creek, class C; trout waters in the New River basin. The effluent is discharged underground from the plant to the receiving stream, but it was reported to be consistently clear. VIII. Conclusions Please work to correct the deficiencies in sections 1 and 2. If you wish to provide additional information regarding the noted violations, request technical assistance, or discuss overall compliance please respond in writing within 10 business days after receipt of this Notice. Please reply in writing to this letter within 30 calendar days of receiving it. Your written reply should address each of the noted deficiencies and provide a corrective action plan along with an implementation/completion schedule to remediate them. A review of your response will be considered along with any additional information provided. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to$25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 30 calendar days of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations. Sincerely, Sherri V. Knight, P.E. Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: BIMS EPA Water Compliance Inspection Report cc: Central Files WSRO CNPDES-tiff 3 United States Environmental Protection Agency Form Approved E PA Washington,D C 20460 OMB No 2040-0057 Water Compliance Inspection Report Approval expires 6-31-98 Section A National Data System Coding(i.e,PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector - Fac Type 1 [ 2 I� I 3 I NCG500671 I11 , 12 I 18/08/02 117 18 I L I 19 s 201 I 2111/1111 1111111111111111111111111 11111111111 166 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA -Reserved- 67 I Reserved-671 I 70I I 71 I I 72 LJ 731 I 174 751 1 1 1 1 1 1 180 Section B Facility Data LJ 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 30AM 18/08/02 16/04/26 Miles Annas cooling tower ' Exit Time/Date Permit Expiration Date 614 Howard St 12 30PM 18/08/02 20/07/31 Boone NC 286082050 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 Contacted Allison Kemp-Sullivan,438 Academy St Boone NC 28608//828262662/8282627200 No Section C Areas Evaluated During Inspection(Check only those areas evaluated) • Permit • Operations&Maintenance El Records/Reports El Facility Site Review 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 i Q Kelli A Park ' WSRO WQ//336-776-9689/ 11K1 `C.� 4a../ecItt,e__________ 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# 1 v NPDES yr/mo/day Inspection Type 1 31 NCG500671 111 121 18/08/02 I17 18 LI Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary) Page# 2 Permit. NCG500671 Owner-Facility. Miles Annas cooling tower Inspection Date: 08/02/2018 Inspection Type: Compliance Evaluation 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 0 ❑ • El Solids, pH, DO, Sludge Judge, and other that are applicable? Comment _ Permit Yes No NA NE (If the present permit expires in 6 months or less) Has the permittee submitted a new El ❑ • El application? Is the facility as described in the permit? • 0 0 0 #Are there any special conditions for the permit? • ❑ ❑ El Is access to the plant site restricted to the general public? ❑ • El El Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑ Comment Daniel Gryder(engineer) sent Kelll their data monitoring for hardness, pH, and conductivity. The general permit was sent as well Cooling tower stucture is on campus and the public can go up to it, however the mechanical room has restricted access Page# 3