NC0022497_Inspection_20181114

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14 November 2018
CERTIFIED MAIL #: 7016 1370 0000 2591 1711
RETURN RECEIPT REQUESTED
Ms. Donna Day, Manager
Cross Country Campground
6254 NC Hwy. 150 East
Denver, North Carolina 28037
Subject: Notice of Violation
Compliance Evaluation Inspection
Cross Country Campground WWTP
NPDES Permit No. NCO022497
Catawba County
Tracking #: NOV-2018-PC-0423
Dear Ms. Day:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspections conducted at the subject facility on
October 23 and November 8, 2018, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge
(ORC) of our findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the following:
- Effluent composite samples were not being collected throughout a 24-hr. period;
- Adequate laboratory controls were not being maintained (laboratory instrumentation used for field analyses not being
properly calibrated and/or verified);
- Discharge Monitoring Reports (eDMRs) from February 2018 through September 2018 had not been mailed in to the
Division.
All above -noted findings are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1
as detailed in the Effluent Sampling, Laboratory/Summary, and Record Keeping/Summary Sections of the attached
report. Please be advised that G.S. 143-215.6A provides for a civil penalty assessment of not more than twenty-five
thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing
nature, 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.
EQ.:>
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North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 301I Mooresville, North Carolina 28115
704.663.1699

Ms. Donna Day
Page Two
14 November 2018
It is requested that a written response be submitted to this Office by December 5, 2018, detailing the actions taken to
address all violations. In responding, please address your comments to the attention of Mr. Wes Bell. In addition, all DMRs
(paper copies) from February 2018 to September 2018 must be mailed in to the Division by December 14, 2018.
Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at [phone], or via
email at wes.bellkncdenr.gov.
Sincerely,
DocuSigned by:
A14CC681 AF27425...
W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report

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 I 2 15 I 3 I NCO022497 111 12 I 18/10/23 I17 18 I S I 19 I G I 201 I
211111 1 1 I I I I II I I I I I I I I I I I I 1 I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 70 71 [.. I 72 73 L_LJ74 751 I I I I I I I80
u u
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 oermit Number)
09:40AM 18/10/23
15/09/01
Cross Country Campground
6254 NC Hwy 150 E
Exit Time/Date
Permit Expiration Date
Denver NC 28037
11:25AM 18/10/23
20/04/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Gregory Alexander Trombello/ORC/704-989-0165/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Donna Day,6254 NC Hwy 150 E Denver NC
28037/Manager/704-483-5897/7044835801 Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters
Laboratory
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
ocuSigned by: 11/14/2018
Wes Bell MRO WQ//704-663-1699 Ext.2192/
e
E�D:),,
96D90=43T
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger Division of Water Quality//704-2'
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
11/14/2018
AtaccsatAFvazs... Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO022497 I11 121 18/10/23 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
RECORD KEEPING SECTION cont'd:
Records reviewed in the Manager's Office were organized; however, no August 2018 edmr was
available and the eDMR's from May 2018 through July 2018 were not signed by the ORC and
permittee/duly authorized representative.
The Division does not have the eDMR paper copies from January 2018 through September 2018.
Please be advised that the permittee is required to complete the eDMR submission by printing, signing,
and mailing one original and a copy of the computer -printed eDMR to the Division's address [Permit
Condition Reference: Part I, Section A (3)(1). Two eDMRs (original and copy) for each month from
February 2018 to September 2018 must be mailed to the Division. Although the permittee has
previously delegated signature authority to the ORC for eDMR signature, it is the permittee's ultimate
responsibility to ensure all eDMRs are received by the Division (via electronically and mail).
LABORATORY SECTION cont'd:
The following Laboratory issues were noted during the inspection:
- Dissolved oxygen (DO) meter was not being calibrated (according to the manufacturer's
instructions) prior to compliance monitoring;
- No annual curve had been performed on the total residual chlorine (TRC) meter;
- No annual verification had been performed on the gel standard;
- Temperature measuring device used for compliance monitoring on either the DO or pH meter had
not been verified against a NIST traceable thermometer.
Please be advised that the permittee is required to properly operate and maintain the facility at all times
which includes adequate laboratory controls and appropriate quality assurance procedures [Permit
Condition Reference: Part II, Section C(2) Proper Operation and Maintenance].
The ORC must ensure to perform post -analysis calibration checks on the dissolved oxygen, pH, and
total residual chlorine meters following field analyses at multiple sites. Post -analysis calibration checks
must be performed in accordance with the NC Wastewater/Groundwater laboratory certification
approved procedures for the analyses of dissolved oxygen, pH, and total residual chlorine.
The ORC must ensure units of measurement, lab analyst initials, etc. are properly documented
(calibration logs, operator visitation/field analyses log book) and effluent total residual chlorine values
are not reported below the lowest standard verified (during annual verification) on the total residual
chlorine meter.
Page#

Permit: NCO022497 Owner - Facility: Cross Country Campground
Inspection Date: 10/23/2018 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
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0
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application?
Is the facility as described in the permit?
0
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# Are there any special conditions for the permit?
0
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Is access to the plant site restricted to the general public?
0
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Is the inspector granted access to all areas for inspection?
0
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Comment: The equalization basin has been taken out of service for many years.
The last compliance evaluation inspection was performed at the facility
on 5/11/17 by DWR
staff.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
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0
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Is all required information readily available, complete and current?
0
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Are all records maintained for 3 years (lab. reg. required 5 years)?
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Are analytical results consistent with data reported on DMRs?
0
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Is the chain -of -custody complete?
0
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Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
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Has the facility submitted its annual compliance report to users and DWQ?
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
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on each shift?
Is the ORC visitation log available and current?
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Is the ORC certified at grade equal to or higher than the facility classification?
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Is the backup operator certified at one grade less or greater than the facility classification?
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Is a copy of the current NPDES permit available on site?
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Facility has copy of previous year's Annual Report on file for review?
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0
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Comment: Discharge Monitoring Reports (eDMRs) were reviewed for the period September 2017
through August 2018. No effluent limit violations were reported and all monitoring
frequencies were correct. See "Summary" Section for additional comments.
Page# 3

Permit: NCO022497 Owner - Facility: Cross Country Campground
Inspection Date: 10/23/2018 Inspection Type: Compliance Evaluation
Laboratory
Yes No NA NE
Are field parameters performed by certified personnel or laboratory?
0
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Are all other parameters(excluding field parameters) performed by a certified lab?
0
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# Is the facility using a contract lab?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
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0
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Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
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0
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Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
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0
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Comment: On -site field analvses (dissolved oxvaen. DH temperature. total residual chlorine) are
performed under Metwater, Inc.'s field laboratory certification #5615. Water Tech Labs
(Certification #50) has also been contracted to provide analytical support for all remaining
permit -required parameters (BOD, TSS, ammonia, fecal coliform, total nitrogen, total
phosphorus). See "Laboratory" Section for additional comments.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
0
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Is sample collected below all treatment units?
0
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Is proper volume collected?
0
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Is the tubing clean?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
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Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
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0
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representative)?
Comment: The subject permit requires composite and grab effluent samples.
The review of the sampler's program revealed that composite samples were not collected
throughout a 24-hr. period. The sampler was started at 10:30 am on 11/7/18 and had
stopped at 12:11 am on 11/8/18. Please be advised that composite samples are to be
collected over a 24-hr. period as required by the NPDES Permit (Permit Condition
reference: Part II, Section A Definitions — Composite Sample).
The ORC should continue to become familiarized with the programming and operation of
the sampler including aliquot verifications/calibrations, purge count adjustments (prevent
cross contamination in tubing), etc. In addition, the ORC must ensure that the start
date/time and the end date/time are documented for the composite sampling events to ver
compliance with the 24-hr. sampling period.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑
sampling location)?
Comment: Several steps leading to the downstream sampling location need to be replaced/repaired.
Page# 4

Permit: NCO022497 Owner - Facility: Cross Country Campground
Inspection Date: 10/23/2018 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 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: The wastewater treatment facilitv aooeared to be adeauatelv treatina wastewater at the time
of the inspection.
The ORC must ensure all process control measurements are documented. In addition, this
Office recommends increasing the frequecy of the process control measurements.
The facility is not equipped with a sludge holding tank. The ORC must ensure an adequate
sludge wasting program is being implemented.
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)
Yes No NA NE
Ext. Air
Diffused
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Comment: The facility is not equipped with a treatment unit (bar screen, etc.) to remove paper debris,
rags. etc. This Office recommends facility staff to inspect all aeration basin diffusers to
ensure that there are no blockages (from paper debris, raps, solids, etc.) in the diffuser
holes.
Secondary Clarifier
Is the clarifier free of black and odorous wastewater?
Is the site free of excessive buildup of solids in center well of circular clarifier?
Are weirs level?
Is the site free of weir blockage?
Is the site free of evidence of short-circuiting?
Is scum removal adequate?
Is the site free of excessive floating sludge?
Is the drive unit operational?
Is the return rate acceptable (low turbulence)?
Is the overflow clear of excessive solids/pin floc?
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
Yes No NA NE
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Page# 5

Permit: NC0022497 Owner - Facility: Cross Country Campground
Inspection Date: 10/23/2018 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
Comment:
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
0
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Are the tablets the proper size and type?
0❑
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Number of tubes in use?
1
Is the level of chlorine residual acceptable?
0
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Is the contact chamber free of growth, or sludge buildup?
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Is there chlorine residual prior to de -chlorination?
0
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Comment: Norweco tablets (calcium hypochlorite) are used for chlorination.
The chlorine contact chamber is not safelv accessible for evaluation.
De -chlorination
Yes No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
0 ❑
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Is storage appropriate for cylinders?
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0
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# Is de -chlorination substance stored away from chlorine containers?
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0
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Comment:
Are the tablets the proper size and type? 0 ❑ ❑ ❑
Are tablet de -chlorinators operational? 0 ❑ ❑ ❑
Number of tubes in use? 1
Comment: Norweco tablets (sodium sulfite) are used for dechlorination.
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
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Is flow meter calibrated annually?
0
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Is the flow meter operational?
0
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(If units are separated) Does the chart recorder match the flow meter?
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0
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Comment: The flow meter is calibrated annually and was last calibrated on 6/26/18 by Horizon
Engineering & Consulting, Inc.
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 ❑ ❑ ❑
Page# 6

Permit: NCO022497
Inspection Date: 10/23/2018
Owner - Facility: Cross Country Campground
Inspection Type: Compliance Evaluation
Effluent Pipe Yes No NA NE
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑
Comment: The effluent aDDeared clear with no floatable solids or foam. The effluent dissolved oxvaen
(DO), PH, and temperature were measured (during the inspection) at 7.4 mg/L (DO), 7.58
SU (PH), and 17.4 degrees Celsius (temperature).
The receiving stream did not appear to be negatively impacted at the time of the inspection.
Page#