NC0028746_NOV-2019-PC-0062_20190207

SWE ce
n3 • '.
ROY COOPER
N •':;
,� � Ji
('iOVCrnOf a
MICHAEL S.REGAN `
Secretary LINDA L1NDA CULPEPPER NORTH CAROLINA
Director Environmental Quality
FEB 14 2019
February 7, 2019 Water Resources
Permitting Section
CERTIFIED MAIL # 7013 1710 0002 1922 3580
RETURN RECEIPT REQUESTED
Mr. Shannon V. Becker
AQUA North Carolina, Inc.
202 MacKenan Ct.
Cary, NC 27511
•
Subject: Notice of Violation/Notice of Intent to Enforce - (NOV-2019-PC-0062)
Compliance Evaluation Inspection
Briarwood Subdivision WWTP
Permit No. NC0028746
Stokes County
Dear Mr. Becker:
A Compliance Evaluation Inspection was performed by Division of Water Resources, Winston
Salem Regional Office (WSRO), staff person Justin Henderson, on February 1, 2019. Mr. Sammy
Pegram, Back-up Operator in Responsible Charge (ORC), was present for this inspection. This
type of inspection consists of two basic parts: an in-office review of the facility files and self-
monitoring data and an on-site inspection of the facility. This inspection reflects non-compliance
with Permit No.NC0028746;the following violations require your immediate attention and action:
1) Discharge of floating solids in greater than trace amounts.Permit Condition Part I. (A.)
(1) states there shall be no discharge of floating solids or visible foam in other than trace
amounts.
2) Failure to maintain acceptable housekeeping of the facility. A significant amount of
leaf accumulation was observed throughout the facility, and also within several of the
facility's treatment units. Permit Condition Part II. Section (C.) (2) Proper Operation and
Maintenance, requires the Permittee to maintain all facilities and systems of treatment and
control which are installed or used by the Permittee to achieve compliance with the
conditions of the subject permit.
3) Failure to appropriately manage the facility's solids/sludge levels present within the
treatment units. An excessive amount of solids/sludge accumulation was observed in the
facility's clarifier's, chlorinator, chlorine contact chamber, de-chlorinator, and "effluent
ODE - 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
oec.tmod of EIVIVOMMINIMI aw� /'.4 336.776.9800

storage tank" associated with the old sand filters. (See enclosed site photos.). Permit
g
Condition Part II. Section (C.) (2) Proper Operation and Maintenance, requires the
Permittee to properly operate all facilities and system of treatment and control which are
installed or used by the Permittee to achieve compliance with the conditions of the subject
permit.
This is a repeat violation that was previously documented in a Notice of Violation, dated
October 30, 2017.
4) Failure to perform representative sampling. During this inspection, the Back-up ORC
admitted that the composite sampler's effluent storage vessel is not thoroughly mixed prior
to aliquoting the sample for the required effluent parameter analyses.Permit Condition Part
II. Section (D.) (1.) Representative Sampling, requires samples collected to be
representative of the permitted discharge.
The occurrence of this violation provides an explanation for why the facility's effluent
Total Suspended Solids (TSS) analysis results, are not representative of the solids/sludge
levels observed in the plant at the time of this inspection.
5) Failure to obtain an Authorization to Construct (AtC) permit, prior to construction
of wastewater treatment facilities. The facility's addition of a manual bar screen to the
treatment operations constitutes a violation of Permit Condition Part III. Section (A.) (a.)
which states the Permittee shall not commence construction of wastewater treatment
facilities, nor add to the plant's treatment capacity, nor change the treatment process(es)
utilized at the treatment plant unless the Division has issued an AtC permit.
This is a repeat violation that was previously documented in a Notice of Violation, dated
October 30, 2017, in which the Permittee was instructed to apply for Permit Modification
to request approval of the bar screen.
To date,the Division has yet to receive a permit modification request to resolve this matter.
Along with the above described violations, the following items of concern also require your
attention:
a) Secondary containers, being utilized for calibration standard storage, must be labeled with
the standard's lot number and expiration date at a minimum.
b) The Back-up ORC was unable to provide a description of the composite sampler's
operations, during the compositing period. Please submit a written description of this
process to demonstrate compliance with Permit Condition Part II. Composite Sample,
which requires flow proportional sample collection.
Please submit a written plan,detailing the corrective actions to be implemented and expected dates
of resolution for the violations described in this Notice. Your written response plan shall be
submitted within 15 days following receipt of this Notice. The written response shall also include
the following information:

1) An explanation for why aeration has been added to the influent sedimentation chamber,
which clearly impedes settling of solids.
2) An explanation for why the surface skimmer, associated with Clarifier #1, discharges to
the aeration basin as opposed to the digestor.
Our office is considering the pursuit of punitive sanctions for these violations. 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 no response is received in
this Office within the 15-day period, a civil penalty assessment may be prepared.
An unannounced follow-up inspection will be conducted, within 90-days of the date of this
correspondence, to evaluate your response to this Notice. Please be advised that these violations,
and any future violations are subject to civil penalty assessment of up to $25,000 per day, per
violation under authority of G.S. 143-215. Your timely action and attention to these matters is
appreciated. If you have any questions concerning this Notice, please contact Justin Henderson or
me at(336) 776-9800.
Sincerely,
e)41---
She i . Knight, PE—Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources,NC DEQ
enc: Inspection Report
Site Photos
cc: WSRO
Central Files
NPDES Unit

Briarwood Subdivision WWTP
NPDES Permit No. NC0028746
February 1, 2019 Site Photos
.4b -
fIII,kIIILL\ 414141:4416 I*44411k1:
'
Photo No. 1 shows floating solids Photo No. 2 shows accumulated solids
covering the surface of Clarifier#2. located in the facility's chlorine contact
chamber.
. ,___.
_--_ .� *-.... his..
h 7'
Photo No. 3 shows accumulation of fallen leaves throughout the facility. These leaves were also
observed within the treatment units, and were observed impeding the efficiency of the surface
skimmers located in the clarifiers.

--
40
- w
s
k
--,..,'-,;,, Amillr
Photo No. 4 show solids accumulation located in the facility's de-chlorination unit.
_
t _
- _ 4 .- .r- _--�_{-
. -
1 ,r
Photo No. 5 show solids accumulation in the "effluent storage tank" associated with the old sand
filters. Effluent leaving the clarifiers passes through this tank prior to disinfection.

United States Environmental Protection Agency
Form Approved.
Washington,D.C.20460
OMB No.2040-0057
EPAApproval expires 8-31-98
_ Water Compliance Inspection Report
Section A:National Data System Coding(i.e.,PCS)
yr/mo/day Inspection Type Inspector Fac Type
NPDES 17 18 I r-I 19 I S � 20 u
Transaction Code L:� t--�
1 2 L 3 I NCOo28746 I11 12 1 s/o2/o1
U 5 6
21 I I Inspection Work Days Facility Self-Monitoring Evaluation Rating 81 QA -------Reserved------
67 70 U N t I I
71 Li 72 73 I I 174 75 80
Section B:Facility Data
Effective Date
W
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include 09:30AM i9102101
17
Entry Time/Date Permit
/07/01
pOT name and NPDES permit Number)
Briarwood Subdivision WWTP Exit Time/Date Permit Expiration Date
12:OOPM
19/02/01 22/02/28
NC Hwy 66
King NC 27021
' Other Facility Data
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Samuel E.PegramlORCl704-489-9404/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Delbert H Likins, /Wastewater Supervisor Westl/ No
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
IIIIII Flow Measurement IIII Operations&Maintenance 111 Records/Reports
Permit Facili Site Review III Effluent/Receiving Waters
II Self-Monitoring Program � Sludge Handling Disposal IItY
II Laboratory
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Date
Name(s)and Signature(s)of Inspector(s) Agency/Office/Phone and Fax Numbers
WSRO WQ//336-776-9701/ Q`/] J 5 /
Justin L Henderson
fibIrk 1iiii.'.-/ L G—)
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

NPDES
3I yr/mo/day ....
w
NC0028746 11 12 17 Inspection Type
19/02/01 18
C (Cont.) 1
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The following violatons identified, during this inspection, require your attention and
1)Discharge of floating solids in greater than trace amounts. Permit Condition Pa action:
there shall be no discharge of floating solids or visible foam in other than trace amounts.
Part I. (A.) (1) states
2)Failure to maintain acceptable housekeeping of the facility.A significant amount of leaf
was observed throughout the facility, and also within several of the facility's treatment units.
Condition Part II. Section C. accumulation
( ) (2) Proper Operation and Maintenance, requires the Permittee to
maintain all facilities and systems of treatment and control which are installed or used by the Permittee
to achieve compliance with the conditions of the subject permit.
3)Failure to appropriately manage the facility's solids/sludge levels present within
An excessive amount of solids/sludge accumulation was observed in the facility's
chlorinator, chlorine contact chamber, de-chlorinator, and 'effluentthe treatment units.
old sand filters. (See enclosed site photos.). Permit Condition Part II. Sectionty s clarifiers,
old Maintenance, requires the Permitteehot .)o properly P II. ecti tank" (2) Proper
with Operatione
control which are installed or used by the Permittee to achieve compliance (C.) (2) Pro er
operate all facilities and with the n of treatment and
subject permit. the conditions of the
This is a repeat violation that was previously documented in a Notice of Violation,
2017.
n, dated October 30,
4)Failure to perform representative sampling. During this inspection, the B
the composite sampler's effluent storage vessel, is not thoroughly
for the required effluent parameter analyses. Permit Condition Part II. Sectionack-up ORC admitted that
forSa the , samples collected an lo be representative they mi. prior(Dal(1.) Representativeng the ample
of ( 1.)
The occurrence of this violation provides an explanation for wh permitted discharge.
Solids (TSS) analysis results, are not representative of the solids/sludge levels
y the facility's effluent Total Suspended
the time of this inspection.
the
in the plant at
5)Failure to obtain an Authorization to Construct(AtC) permit, prior to construction of wastewater
treatment facilities. The facility's addition of a manual bar screen to the treatment operations
(
constitutes a violation of Permit Condition Part III. Section A•
commence construction of wastewater treatment facilities, nor add to the plant's treat
nor change the treatment process(es) utilized at the tree
) (a.)which states the Permittee shall not
ment capacity,
AtC permit. tment plant unless the Division has issued an
This is a repeat violation that was previously documented in a Notice of Violation
ba screen.which the Permittee was instructed to apply for Permit Modification to re30,
20r 7, iw dated October f t
quest approval of the
To date, the Division has yet to receive a permit modification request to resolve
Along with the above described violations, the following items of concern also this matter.
a)Secondary containers, being utilized for calibration standard storage, require your attention:
must be labeled with the
standard's lot number and expiration date at a minimum.
Page# 2

owner-Facility:
Briarwood Subdivision V VVTP
• ' Permit: NC0028746 Compliance Evaluation
Inspection Type:
Inspection Date: 02/01/2019
b)The Back-up ORC was unable to provide a description of the composite sampler's
during the compositing period. Please submit a written description of this process
to demonstrate
Sample,which requiresflow proportional sample
compliance with Permit Condition Part U. Composite
collection.
•
Page# 3

Permit: NCO028746
Inspection Date: 02/01/29 owner-Facility: Briarwood Subdivision VVINTP +
Inspection Type: Compliance Evaluation
O erations & Maintenance
Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: 0 II 0
III 0 0 El
Solids, pH, DO, Sludge Ju„ge, aidother that are applicable? , MCRT, Settleable 0
MLSS
Comment: Fallen leaves were observed throu hout the lants. Fallen leaves w
im ededin flow of the surface skimir�crs located DO and settleable solids at the aeration basin forinroh Ess colnt olTherfac lite rved erforms H
Permit
(If the present permit expires in 6 months or less). Yes No
NA NE
application?
? ) Has the permittee submitted a new
Is the facility as described in the permit? 0 0 • 0
#Are there any special conditions for the permit? 0 0 0
Is access to the plant site restricted to the general public? 0 ElII 0
Is the inspector granted access to all areas for inspection? I 0
0 0
Comment: A bar screen has been constructed to the wastewater facilities. This c • 0 0 Cl
without re uestin an AtC ermit and Divison a royal. onstruction was
Aerobic Di ester
Is the capacity adequate? Yes No NA NE
0
Is the mixing adequate? II 0 0
Is the site free of excessive foaming in the tank? 11
❑ 0
#Is the odor acceptable? El
El 0 CI
#Is tankage available for properly waste sludge? I 0 Cl 0
Comment: ❑ ❑ Ell
Bar Sins
Type of bar screen Yes No NA NE
a.Manual
b.Mechanical I
Are the bars adequately screening debris? L_I
Is the screen free of excessive debris? ▪ 0 0 0
Is disposal of screening in compliance? ▪ 0 El 0
0
Is the unit in good condition? ▪ ❑ CI
Comment. A ermit modificaiton should be re uested for Division a royal o II El 0 0
the wastewater facilities. f the bar screen as art of
Page# 4

Owner-Facility:
Briarwood Subdivision wWTP
4 .— Permit: NC0026746 Inspection Type: Compliance Evaluation
Inspection Date: 02/01/2019
Y es No NA NE
Secondary Clarifier a ❑ 0 ❑
Is the clarifier free of black and odorous wastewater? 0 ■ CI 0
Is the site free of excessive buildup of solids in center well of circular clarifier? 0 II 0 0
Are weirs level? ❑ � ❑ ❑
Is the site free of weir blockage? CI ❑ II ❑
Is the site free of evidence of short-circuiting? CI ■ 0 CI
Is scum removal adequate? CIEl ❑
Is the site free of excessive floating sludge? 0 CI II 0
Is the drive unit operational? ■ CI ❑ ❑
Is the return rate acceptable(low turbulence)? 0 II El 0
Is the overflow clear of excessive solids/pin floc? El II CI CIIs the sludge blanket level acceptable?(Approximately Y.of the sidewall depth)
ischar
Comment Excessive floatin slude observed in Clarifieredin Unflow ove ual der weir in Clarifier#2ePin flocifier
#1 and#2. Fallen leaves and other debrision.
observed dischar in over weir in Clarifier
#mdurin this eded duelto b ocns tka e b fallent surface
scum resent in clarifiers surface skine
leaves±dam
Yes NA NE
Aeration Basins No Ext.Air
Mode of operation Diffused
Type of aeration system � ❑ El ❑
Is the basin free of dead spots? El ❑ II ❑
Are surface aerators and mixers operational? . 0 0 0
Are the diffusers operational? � ❑ ❑ CIIs the foam the proper color for the treatment process? . 0 ❑ ElDoes the foam cover less than 25%of the basin's surface? CI 0
El I
Is the DO level acceptable? ❑ ❑ CIIs the DO level acceptable?(1.0 to 3.0 mg/I)
II
Comment:
Yes No NA NE
De-chlorination Tablet
Type of system? E• CIl • ❑ ClIs the feed ratio proportional to chlorine amount(1 to 1)? ❑ El
storage appropriate for cylinders? ■ 0 0 ❑
#Is de-chlorination substance stored away from chlorine containers?
Page# 5

❑ ❑w ❑
❑ ❑ ❑ °❑ z
Z ❑ ❑ ❑ ❑° ° °
°° ° ° ° ❑Z ❑ Z C Z ❑a n
E -U } ■ ■ Z a
N a) �
N ■ ■ ❑ y a
> U Q) d
a m 0 N fU
z w'
c o c
a c ca
o° co o _ u) a)
co E Ilia)
- > E
m (j
co > c0 N a)
•F1�n a) Z 1 : 1.1
X u)`` o` W o m u f9 a) a
EU o) • E
X U o O g2 N
2
(o a) o U
o
• UO. Cco
O J
Is
co
C CI E p N
a) o a cc cn Lt ca
cr
a) rn
o a) iti m wE
U to .o . c a _C .0 a)
•
O) C c. a) _ca) C a)O w
a co
C a) a) a c [3 co co .o C • a
m a ca O O E �. 7 O CO (p
_ o
(Cp -O C N L U U C C 0 LT C O C 5
U 3 a) c.) o m a) m _ _ Q
a) C C C U O a c0 E a • O N
a .N • J a O a) a3 p) O N O m to
i
N. o OC C O R N j �O .O Oa 2.2 cn 73 N -O N
a CO 0. m a o m ID
a o c`a Z voi y o o �. a N 3 `° a o`E > E NE E
a c a) o > > o o ° N E ca o
O a 'O U C
O R N O U i C 0 G) C 1] 7 o) h •. lit
ca) 7 n : O c E �. a) o m 1I : I0I ,
al >al cu
p Q o a) E o Q Z U E E E o w a) a) m c
0 < Q Z p o m 8 m a ( E �v c
u, 2 0 W u) cn w 0 L-. a E y m a E
- * U u) N 8 . E 8