NC0027286_Compliance Evaluation Inspection_20181203

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NORTH CAROJNA
ROY COOPER EnytrartatrreatQuaray
Governor
MICHAEL S. REGAN REC�iI/ED��i=I� �y�n
Secretory �D U R
LINDA CULPEPPER 'l y
Interim Director DEC d 2 2818
Water R'eSOUtCOu
CERTIFIED MAIL#7015-0640-0005-8164-0599 Permitting Section
RETURN RECEIPT REQUESTED
December 3, 2018
Ed Evans
Town of Blowing Rock
1036 Main St.
PO Box 47
Blowing Rock, NC 28605
SUBJECT: Compliance Evaluation Inspection and Notice of Violation •
NOV Tracking Number: NOV-2018-PC-0444
Blowing Rock WWTP
NPDES Permit No. NC0027286
Watauga County
Dear Mr. Evans,
On November 20, 2018, Kelli Park and Jenny Graznak, of this office, met with James Townsend
operator in responsible charge (ORC), and Trathen Greene to perform a Compliance Evaluation
Inspection at the Blowing Rock wastewater treatment plant (WVVTP). This type of inspection
consists of two basic parts: an in-office file review and an on-site inspection of the treatment
facility. The attached EPA inspection form details the areas that were evaluated for this inspection.
Violations and major areas of concern observed from the inspection are described below.
1. It is a permit requirement for the influent sample to be collected by a flow proportional
composite sampler, however there is no composite sampler and grab samples have been
taken for reporting water quality parameters. Please install and begin using an influent
composite sampler immediately.
2. The inspectors observed some solids at the discharge pipe in the effluent flow. According to
your permit, "there shall be no discharge of floating solids or visible foams in other than trace
amounts." Solids were potentially due to one of the clarifiers having a-seven-foot sludge
blanket. Please be aware of how deep the sludge blankets in the clarifiers are and adjust
sludge removal accordingly.
3. The effluent flow meter appeared to be in the wrong location. Please get this verified to ensure
accurate readings and send us a confirmation letter along with an explanation.
4. The 7 and 10 pH standards were expired. Please use up to date standards.
Page 1 of 2

Blowing Rock WWTP CEI November 20,2018
These issues represent deficiencies and violations of the facility's NPDES permit. Thus, this-letter
is being sent to you as a Notice of Violation. Please reply in writing to this letter within 10
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 10 calendar days of your receipt of this notice, we may draft
an enforcement case for the noted deficiencies/violations.
Your immediate attention is greatly appreciated. If you have any questions regarding the
inspection or this report, please contact Kelli Park or me at [phone] or by email at
kelli.park a[�ncdenr.gov or sherri.knightancdenr.gov.
Sincerely,
Az'`': y-. grA-A-P
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Enclosure: EPA Water Compliance Inspection Report
cc: Central Files
WSRO___^
'iVPDES Uni
•
Page 2 of 2

'r
United States Environmental Protection Agency Form Approved
E PA 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 LN ] 2 L .3 I NC0027286 111 121 18/11/20 117 18 I I 19 I s 2011 �6
21I I I I I I I I I I II 11 I I I I I I I I I I I I I I I I1 I I I I II I I I I l r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
67 I
I 70 I 1 71 I I 72 LJ,, 73I I I74 75IJ I I I I I I l80
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) 11 OOAM 18/11/20 16/07/01
Blowing Rock WWTP
Exit Time/Date Permit Expiration Date
US Hwy 321 Bypass N
01 OOPM 18/11/20 21/03/31
Blowing Rock NC 28605
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Marshall James Townsend/ORC/828-295-5226/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Ed Evans,1036 Main St Blowing Rock NC 28605/Town Manager/828-295-5200/
No
Section C Areas Evaluated During Inspection(Check only'those areas evaluated)
▪ Permit iiiFlow Measurement II Operations&Maintenance II Records/Reports
▪ Self-Monitoring Program In Facility Site Review 111 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(s)of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Jennifer F Graznak WSRO WQ//336-771-5000/
Kelli A Park iivit�ne.d.... WSRO WQ//336-776-9689/ z ��l �/17- ✓/CO t O
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

Ni
NPDES yr/mo/day Inspection Type (Cont.) 1
31 NC0027286 I11 121 y g/1 vzo 117 18 U
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
On November 11, 2018, Kelli Park and Jenny Graznak of this office met with James Townsend and
Trathen Greene to perform a Compliance Evaluation Inspection on the Blowing Rock wastewater
treatment system.This type of inspection consists of two basic parts: an in-office 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.
•
Page# 2

Permit: NC0027286 Owner-Facility: Blowing Rock VVWTP
Inspection Date: 11/20/2018 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 ❑ ❑ • 0
application?
Is the facility as described in the permit? s III ❑ ❑ 0
#Are there any special conditions for the permit? ❑ MI 0 ❑
Is access to the plant site restricted to the general public? 0 • ❑ 0
Is the inspector granted access to all areas for inspection? MI 0 ❑ ❑
Comment The fence going into the plant was damaged Please repair this as soon as possible.
I
Operations & Maintenance
Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • 0 ❑ 0
Does the facility analyze process control parameters, for ex MLSS, MCRT, Settleable • ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • ❑ ❑ ❑
Is all required information readily available, complete and current? • 0 ❑ ❑
Are all records maintained for 3 years(lab reg required 5 years)? IN ❑ ❑ 0
Are analytical results consistent with data reported on DMRs? • ❑ ❑ ❑
Is the chain-of-custody complete? • ❑ ❑ ❑
Dates, times and location of sampling II
Name of individual performing the sampling MI
Results of analysis and calibration •
Dates of analysis •
Name of person performing analyses •
Transported COCs •
Are DMRs complete do they include all permit parameters? • ❑ ❑ ❑
Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑
III
(If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ • 0
on each shift?
Is the ORC visitation log available and current? • ❑ ❑ ❑
Is the ORC certified at grade equal to or higher than the facility classification? • ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification? • ❑ ❑ ❑
Is a copy of the current NPDES permit available on site? • ❑ ❑ ❑
Page# 3

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Permit: NC0027286 Owner-Facility: Blowing Rock WWTP
Inspection Date: 11/20/2018 Inspection Type' Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review'? ❑ 0 i ❑
Comment ORC and backup ORC are both a grade 3. Marshall Townsend is the ORC, Douglas Lee is
the backup ORC. Water Tech Labs analyze the water samples.
Bar Screens Yes No NA NE
Type of bar screen
a.Manual 1111
b.Mechanical ❑
Are the bars adequately screening debris'? ❑ • ❑ ❑
Is the screen free of excessive debris'? • ❑ 0 ❑
Is disposal of screening in compliance'? • ❑ 0 ❑
Is the unit in good condition'? • ❑ ❑ ❑
Comment The bar screen is screening most debris, but there were some debris seen in the aeration
basin and clarifiers.This suggests the screen may not be fine enough.
Republix comes and takes the debris to the landfill.
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Diffused
Is the basin free of dead spots'? • 0 0 ❑
Are surface aerators and mixers operational'? • ❑ ❑ ❑
Are the diffusers operational'? • ❑ ❑ El
Is the foam the proper color for the treatment process'? • ❑ ❑ ❑
Does the foam cover less than 25%of the basin's surface'? ❑ • 0 ❑
Is the DO level acceptable'? • ❑ 0 ❑
Is the DO level acceptable9(1 0 to 3 0 mg/I) • 0 ❑ ❑
Comment. Foam covered about 33% of the aeration basins (basins 1 and 4). DO was reported to be
around 1 mq/L.The online basins has a good brown color, earthy odor, and there were no
dead spots
Aeration basins 1 and 4 were running, 2 and 3 were offline due to not needing the extra
space.There was some trash debris in all of the aeration basins.
Secondary Clarifier Yes No NA NE •
Is the clarifier free of black and odorous wastewater'? • ❑ ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier'? ❑ ❑ M ❑
Page# 4

Permit: NC0027286 Owner-Facility: Blowing RockWWTP
Inspection Date' 11/20/2018 Inspection Type: Compliance Evaluation
Secondary Clarifier Yes No NA NE
•
Are weirs level? MI ❑ ❑ ❑
Is the site free of weir blockage'? • ❑ ❑ 0
Is the site free of evidence of short-circuiting'? • ❑ 0 ❑
Is scum removal adequate'? • ❑ ❑ 0
Is the site free of excessive floating sludge'? • ❑ ❑ ❑
Is the drive unit operational? 0 0 • ❑
Is the return rate acceptable(low turbulence)? • 0 0 0
Is the overflow clear of excessive solids/pin floc'? • 0 0 ❑
Is the sludge blanket level acceptable'? (Approximately%4 of the sidewall depth) ❑ • 0 ❑
Comment' Pin floc was noticable in the clarifiers, along with some floating trash debris.The two
clarifiers are about 12 ft deep each. One of the clarifiers had a sludge blanket of 7ft, and
needs to be pumped immediatly. Please be more diligent about keeping the sludge blanket
less than 3 ft deep. The second clarifier had a sludge blanket less than a foot deep
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately'? • 0 -❑ 0
Are cylinders protected from direct sunlight'? • 0 0 0
Is there adequate reserve supply of disinfectant'? • 0 0 0
Is the level of chlorine residual acceptable'? 0 0 0
II
Is the contact chamber free of growth, or sludge buildup'? III 0 El ❑
Is there chlorine residual prior to de-chlorination? 0 0 ❑ •
Does the Stationary Source have more than 2500 lbs of Chlorine(CAS No.7782-50-5)2 0 El 0 •
If yes,then is there a Risk Management Plan on site? 0 ❑ 0
If yes,then what is the EPA twelve digit ID Number'?(1000- - )
If yes,then when was the RMP last updated'?
Comment About 4lbs of chlorine gas are used each day
De-chlorination Yes No NA NE
Type of system? Liquid
Is the feed ratio proportional to chlorine amount(1 to 1)2 • 0 0 ❑
Is storage appropriate for cylinders'? 0 0 • ❑
#Is de-chlorination substance stored away from chlorine containers'? ❑ 0 ❑
Are the tablets the proper size and type'? 0 ❑ • El
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VL
Permit: NC0027286 Owner-Facility: Blowing Rock wwTP •
Inspection Date: 11/20/2018 Inspection Type: Compliance Evaluation .
De-chlorination Yes No NA NE
• Comment Sodium meta-bisulphate is used.About 3 inches a day are used out of the 350 gallon
holding tank.
Are tablet de-chlorinators operational? ❑ ❑ I ❑
Number of tubes in use?
Comment.
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting? • ❑ ❑ ❑
Is flow meter calibrated annually? - • ❑ ❑ ❑
Is the flow meter operational? • ❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ •
Comment* The flow meter appeared to be in the wrong location. Please confirm that this is an accurate
placement.
Equalization Basins Yes No NA NE
Is the basin aerated? III ❑ ❑ ❑
Is the basin free of bypass lines or structures to the natural environment? M ❑ ❑ ❑
Is the basin free of excessive grease? • ❑ ❑ ❑
Are all pumps present? 111 0 0 ❑
Are all pumps operable? • ❑ 0 '❑
Are float controls operable? • ❑ ❑ ❑
Are audible and visual alarms operable? • ❑ 0 ❑
#Is basin size/volume adequate? • ❑ ❑ LI
Comment: The basin was not being aerated at the time of inspection, but can be when needed.
Effluent Pipe Yes No•NA NE
Is right of way to the outfall properly maintained'? • ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris'? • ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ • ❑
Comment. There was some pin floc in the effluent.
Standby Power Yes No NA NE
Is automatically activated standby power available? • ❑ ❑ ❑
Is the generator tested by interrupting primary power source? • ❑ ❑ ❑
Page# 6

Permit. NC0027286 Owner-Facility Blowing Rock VVWTP
Inspection Date: 11/20/2018 Inspection Type Compliance Evaluation
Standby Power Yes No NA NE
Is the generator tested under load? U ❑ 0 ❑
Was generator tested&operational during the inspection? U ❑ ❑ ❑
Do the generator(s) have adequate capacity to operate the entire wastewater site'? I 0 ❑ ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power'? 111 ❑ 0 0
Is the generator fuel level monitored'? El 0 ❑ ❑
Comment Appalachian Oil comes and checks the gas levels in the generator
Influent Sampling Yes No NA NE
#Is composite sampling flow proportional? ❑ • ❑ ❑
Is sample collected above side streams'? ❑ • ❑ ❑
Is proper volume collected'? ❑ • 0 ❑
Is the tubing clean'? ❑ • ❑ ❑
#Is proper temperature set for sample storage(kept at less than or equal to 6 0 degrees ❑ • ❑ 0
Celsius)?
Is sampling performed according to the permit'? ❑ • ❑ ❑
Comment: There is no influent composite sampler.Via the permit the influent samples should be
collected by a composite sampler Please get a sampler installed immediately. Contact Kelli
Park when this is completed
An influent flow meter is recommended
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional'? MOOD
Is sample collected below all treatment units'? EIDIND
Is proper volume collected'? • ❑ ❑ ❑
Is the tubing clean'? U ❑ ❑ ❑
#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 Ill ❑ ❑ ❑
representative)?
Comment. 100 mL are sampled per 10,000 gallons.The thermometer was reading 2 degrees Celsius
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory'? • ❑ ❑ ❑
Are all other parameters(excluding field parameters)performed by a certified lab'? MOOD
#Is the facility using a contract lab'? U ❑ ❑ ❑
Page# 7

Permit: NC0027286 Owner-Facility: Blowing Rock WWTP
Inspection Date: 11/20/2018 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees II ❑ 0 ❑
Celsius)'
Incubator(Fecal Conform)set to 44.5 degrees Celsius+/-0 2 degrees'? 0 0 I 0
Incubator(BOD)set to 20.0 degrees Celsius+/-1 0 degrees'? 0 0 • ❑
Comment: Lab certification#5542 pH and dissolved oxygen are analyzed here Other water quality
parameters are analyzed by Water Tech Labs.
Lab instraments were calibrated within the year on 10-2-2018. However,the 7 and 10 pH
standards had expired. Please use standards that are not expired, and be diligent in the
future about checking the expiration dates on the standards.
Upstream/ Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit{frequency,sampling type,and 1 0 0 0
sampling location)'
Comment
Page# 8