NC0056561_Report_20190403

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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o ATLANTA FEDERAL CENTER
o 61 FORSYTH STREET
'441k PROOE0 ATLANTA, GEORGIA 30303-8960
APR 0 3 2019
CERTIFIED MAIL 7017 1450 0000 7913 0544
RETURN RECEIPT REQUESTED fiFoRr�d�e
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Mr. Jay Zimmerman ��� 2019
Division Director
North Carolina Department of Environmental Quality vatusll
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1611 Mail Service Center Environmental Quality W 00"tingSectlaa
Raleigh,North Carolina 27699
RECEIVED/NCDEQ/DWR
Re: Overview Evaluation of the North Carolina Department of Environmental Quality,
Asheville Regional Office MAY 15 2019
Water Quality
Dear Mr. Zimmerman: Permitting Section
The purpose of this letter is to transmit the National Pollutant Discharge Elimination System (NPDES)
Overview Evaluation of the North Carolina Department of Environmental Quality, Asheville Regional
Office, which was conducted by staff from Region 4 of the U.S. Environmental Protection Agency's
Science and Ecosystem Support Division on February 11-12, 2019. The overall NPDES evaluation was
determined to be satisfactory. A report documenting the overview evaluation is enclosed for your
review.
Should you have any further questions, please contact Mr. Namon Mathews at [phone] or via
email at [e-mail].
Sincerely,
M Bragan, ch Chief
NPDES Permitting and Enforcement Branch
Water Protection Division
Enclosure
cc: Mr. Landon Davidson Regional Supervisor
North Carolina Department of Environment and Natural Resources
Internet Address(URL)•http•//www.epa.gov
Recycled/Recyclable•Printed with Vegetable Oil Based Inks on Recycled Paper(Minimum 30%Postconsumer)

Project ID: 19-0130 #ccED SrATFs
NPDES Program Overview Evaluation e' '�
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North Carolina Department of
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Asheville Regional Office
2090 US 70 Highway
Swannanoa, North Carolina 28778
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Project Date: February 11-12, 2019
Report Date: March 11, 2019
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Project Leader: Chris McHugh
Environmental Engineer, EIT
Enforcement Section
Field Services Branch
Science & Ecosystem Support Division -
USEPA—Region 4
980 College Station Road -�-
Athens, Georgia 30605-2720
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The activities depicted in this report are accredited under the US EPA Region 4 Science and ED
Ecosystem Support Division ISO/IEC 17025 accreditation issued by the ANSI-ASQ National
Accreditation Board.Refer to certificate and scope of accreditation AT-1644.

NPDES Program Overview Evaluation
North Carolina Department of Environmental Quality
Asheville Regional Office
Introduction
During the week of February 11, 2019, Chris McHugh of the United States Environmental
Protection Agency (USEPA) conducted a National Pollutant Discharge Elimination System
(NPDES) Program Overview Evaluation of the North Carolina Department of Environmental
Quality (NCDEQ) Asheville Regional Office. The overview was conducted as part of the
Memorandum of Agreement (MOA) with the USEPA Region 4 Water Protection Division. The
overview was conducted to determine if the Asheville Office was meeting its NPDES inspection
requirements. The overview included the following:
• Interviewing office personnel responsible for scheduling, planning, and conducting
NPDES inspections;
• Reviewing records regarding: (a) NPDES program personnel, (b) personnel training and
qualifications,(c)NPDES self-monitoring equipment,and(d)equipment maintenance and
storage;
• Observing office personnel conduct one NPDES Compliance Evaluation Inspection(CEI);
• Providing NPDES sampling and flow measurement training during a joint EPA-State lead
Compliance Sampling Inspection(CSI).
Summary
The NPDES self-monitoring program was evaluated and found to be satisfactory. As part of the
overview, two inspections were conducted. The USEPA provided flow-composite sampling
training during the CSI. Table 1 below highlights the general inspection information for the
inspections conducted as part of this overview.
Table 1—NPDES Compliance Inspections
Inspection Type Field Facility Name and Inspector Date
Office NPDES Permit Number
Compliance
Sampling Asheville Hunter's Glen WWTP Dan Boss 2/11-12/2019
Inspection NC0067288
(CSI)*
Compliance
Evaluation Maggie Valley WWTP Mikal
Inspection Asheville NC0056561 Willmer 2/12/2019
(CEI)
* USEPA provided training and sampling equipment to the Asheville Regional Office NPDES inspectors.
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The following comments and recommendations are provided to enhance the overall NPDES
inspection program:
• The inspectors demonstrated excellent communication skills explaining compliance issues
with facility personnel and evaluating the facilities. During the CSI at the Hunter's Glen
WWTP, the inspectors performed a thorough walkthrough of the plant and a satisfactory
review of the facility's self-monitoring records. It was determined that flow measurement
system was not calibrated to primary weir device and the sampling setup was not properly
collecting a representative composite sample. Steps were taken to address the flow
measurement setup during the inspection to correct the problems identified. The Asheville
Regional Office plans to follow up with the operator to ensure the sampling setup is
corrected.
• During the CEI at the Maggie Valley WWTP,the NCDEQ inspectors thoroughly inspected
the facility. It was found that the facility was collecting composite samples based on time
compositing instead of the required flow compositing. Based on the findings at both
inspections,NCDEQ should continue to check the flow measurement setup and composite
sampling setup to ensure that facilities are properly collecting representative NPDES
samples.
• The state inspectors wrote satisfactory inspection reports that documented the findings and
observations of the inspections conducted as part of the NPDES Program Overview.
• Due to the lack of available sampling equipment, the Asheville Office conducts
Compliance Sampling Inspections (CSIs) by splitting samples using the facility's
equipment. The Office should seek to obtain the necessary equipment to conduct NPDES
sampling. Performing CSIs will enhance the Asheville Office's NPDES inspection
program by providing an additional cross-check of the facility's reported self-monitoring
data. The Asheville Office sampling activities would be independent from the facility,thus
making the sampling data more defensible in cases of non-compliance.
• The regional office should continue seeking NPDES inspector training opportunities for its
inspectors.Additional training helps inspectors improve the technical skills and regulatory
knowledge required to perform NPDES inspections. NCDEQ may request NPDES
Inspector training from the USEPA Region 4. Other training opportunities such as the
North Carolina Wastewater Operator Certification, self-study, and online courses taught
by the Sacramento State University Office of Water and Wastewater are also training
options for inspectors.
•
Regional Field Office Program
1. Staffing Review
Table 2 lists the NPDES personnel, their position, educational background, and the years of
experience in the environmental program. The Asheville Office is staffed with experienced
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t inspectors with a diverse background. Inspectors are given a list of assigned facilities to inspect
each year and are responsible for completing the list by the end of the fiscal year.
Table 2—Asheville Regional Office NPDES Personnel
Personnel Position Education Experience
(Years)
Landon BS/MS Geological Science;
Davidson Regional Supervisor NC P.G. 23/5*
BS Environmental Resource Mgt.
Tim Heim Regional Engineer MS Environmental Engineering; 15/4*
NC P.E.
Bev Price Environmental BA Environmental Studies 14/9*
Senior Specialist*
Linda Wiggs Environmental BS Environmental Conservation 29
Senior Specialist
Janet Cantwell Environmental BS Ecology 27
Specialist BS Environmental Biology
Environmental BS Biology
Mikal Willmer 7.5/2.5*
Specialist MS Environmental Policy and Mgt.
Dan Boss Environmental BS Natural Resource Mgt. 10/2*
Specialist NC Grade IV WW Certification
*NPDES specific
2. Fiscal Year 2018 Completed Workload:
The staff scheduled and conducted inspections on a timely basis to complete their yearly
assignments. As shown in Table 3, the Asheville Office covers 531 NPDES facilities throughout
19 counties in western North Carolina. Table 4 highlights the NPDES workload of the Asheville
Office during the 2018 fiscal year. The Asheville Regional Office commits to inspecting major
facilities every other year or 50%of the time and minor facilities every 5 years or 20%of the time.
Based on the completed workload,the office met its NPDES inspection commitments for the 2018
fiscal year, and it is on track to meet commitments for the 2019 fiscal year.
Table 3—Asheville Regional Office NPDES Facilities
Activities . District Office Work
Total Permitted NPDES Facilities in District(All) 531
Number of Counties in District Office Jurisdiction 19
Discharging 100%Domestic< 1 MGD (Residential only) * 153
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Fish Farms, Packing and Rinsing Wastewater Discharge COC 23
Groundwater Remediation Wastewater Discharge COC 1
Industrial Process & Commercial Wastewater Discharge* 26
Municipal Wastewater Discharge, < 1 MGD (Minor)* 27
Municipal Wastewater Discharge, > 1 MGD (Major)* 20
Non-contact Colling, Boiler Blowdown Wastewater Discharge COC . 28
Pesticide General Permit COC 7
Sand Dredging Operations Wastewater Discharge COC 20
Single Family Domestic Wastewater Discharge COC 179
Water Plants and water Conditioning Discharge 18
Water Treatment Plant Dischargers—Backwash Wastewater from 2
Green Sand and Conventual Water Treatment Facilities
Major and minor NPDES permitted facilities subject to inspection limits set forth in the North Carolina
memorandum of agreement(MOA)with the USEPA:Majors inspected every other year and minors inspected every
five years.
• Table 4—Asheville Regional Office Fiscal Year 2018 Completed Workload Activities
Number of Inspections Completed FY 2018
Inspection Type Completed % Completed out of
Regional Facilities
Compliance Evaluation Inspections (CEI)— 45
100%Domestic
39.9%
Compliance Sampling Inspections (CSI)— 16
100%Domestic
Compliance Evaluation Inspections (CEI)— 8
Minor Municipal< 1 MGD
29.6%
Compliance Sampling Inspections (CSI)— 0
Minor Municipal< 1 MGD
Compliance Evaluation Inspections (CEI)— 11
Major Municipal> 1 MGD
' 55%
Compliance Sampling Inspections (CSI)— 0
Major Municipal> 1 MGD
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•
Compliance Evaluation Inspections (CEI)— 6 majors
Industrial Process and Commercial Wastewater 4 minors
38.5%
Compliance Sampling Inspections (CSI)— 0
Industrial Process and Commercial Wastewater
Reconnaissance Inspections (RIs) 5 -
Pretreatment Compliance Inspections (PCIs) 6 -
Pretreatment Audit Inspections 4 -
Performance Audit Inspections (PAIs) 0* -
Other types of inspections (Technical 11 -
Assistance,Bioassay)
Complaints 1 -
*‘PAIs are performed by NCDEQ Headquarters in Raleigh.
3. Fiscal Year 2019 Completed Workload
Table 5—Asheville Regional Office Fiscal Year 2019 Workload Activities
Number of Inspections Completed FY 2019
Compliance Evaluation Inspections (CEI)— 100%Domestic 8
Compliance Sampling Inspections (CSI)— 100%Domestic 3
Compliance Evaluation Inspections(CEI)—Minor Municipal< 1 0
MGD
Compliance Sampling Inspections(CSI)—Minor Municipal< 1 1
MGD
Compliance Evaluation Inspections (CEI)—Major Municipal> 1 1
MGD
Compliance Sampling Inspections (CSI)—Major Municipal> 1 0
MGD
Compliance Evaluation Inspections (CEI)—Industrial Process and 1
Commercial Wastewater
Compliance Sampling Inspections(CSI)—Industrial Process and 1
Commercial Wastewater
Reconnaissance Inspections (RIs) 3
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Pretreatment Compliance Inspections (PCIs) 2
Pretreatment Audit Inspections 0
Performance Audit Inspections (PAIs) 0*
Other types of inspections (Technical Assistance, Bioassay) 2
Complaints 1
*PAIs are performed by NCDEQ Headquarters in Raleigh.
4. Training
Initial training for the Asheville Office NPDES inspectors consisted of in-house and on-the-job
(OJT) activities. Inspectors attend additional training when possible such as the USEPA NPDES
Basic Inspector Training that was offered in 2017 for the state of North Carolina NPDES
personnel. Additional training offered by the North Carolina Department of Water Resources and
wastewater operator training have also been completed by inspectors, as needed.
5. Inspection Procedures
Generally, NPDES inspections are announced a few days in advance to ensure that essential
facility personnel are present during inspections to facilitate facility self-monitoring records review
and when the site has periodic discharge or other special circumstances. The inspectors were
familiar with all aspects of conducting an NPDES inspection. Inspection notes are recorded on
state checklists that were developed out of the NCDEQ Regional Office in Raleigh, North
Carolina. The Compliance Evaluation Inspection procedures consisted of the following
components:
• opening conference •
• plant walkthrough
• records review
• closing conference
• reporting
When conducting Compliance Sampling Inspections,the office typically splits samples with the
facility using the facility's sampling equipment.
6. Reports
The inspectors write up inspection reports based on the state of North Carolina inspection
checklist.Reports are submitted to management for review and approval before they are submitted
to NCDEQ Regional office located in Raleigh, North Carolina and to the inspected facility. The
inspectors' reports accurately documented the observations and findings of the Hunter's Glen
WWTP CSI and Maggie Valley WWTP CEI.
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7. Sampling and Laboratory Analysis
The Asheville Regional Office collects NPDES samples during Compliance Sampling
Inspections. Sample analysis is performed at the Asheville Regional Office Laboratory.
Samples that cannot be analyzed at the Asheville Office's laboratory such as volatiles are shipped
to the North Carolina State Central Laboratory in Raleigh,NC for analysis.
8. Equipment
•
Table 6 shows the equipment that the Asheville Office uses for its inspections. The office has
vehicles that can be used for NPDES inspections.
Equipment Quantity Model Number
YSI Professional Series Pro Plus 5 600
Multiparameter Meters
ISCO Composite'Sampler 2 3700
ISCO Flow Meter 2 4230
Vehicles 6 Numerous i
9. Work Area/Storage Space
The Asheville Office has adequate office space and equipment storage space. Table 7 details the
equipment and storage space available. Each employee has a designated workspace (typically an
individual office) and adequate storage space for their personal protective equipment (PPE) and •
other field gear.
Table 7—Asheville Regional Office Work Area/Storage Space
Area Space(sq. ft)
Equipment 308
Sample Preparation Room 300
Personnel Offices —100 each
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Attachments
Hunter's Glen WWTP—NPDES Permit Number: NC0067288
Compliance Inspection Report 7 Pages
Hunter's Glen WWTP—NPDES Permit Number: NC0067288
Notice of Deficiency 2 Pages
Maggie Valley WWTP—NPDES Permit Number: NC0056561
Compliance Inspection Report 8 Pages
Maggie Valley WWTP—NPDES Permit Number:NC0056561
Notice of Deficiency 2 Pages
END OF REPORT
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