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Home My WebLink AboutNC0057193_NOV-2019-PC-0253_20190411 Certified Mail # 7017 2620 0000 9759 1093 Return Receipt Requested April 11, 2019 J. William Irving Nantahala Outdoor Center LLC P.O. Box 2629 Asheville, NC 28802 SUBJECT: NOTICE OF VIOLATION Tracking Number: NOV-2019-PC-0253 Permit No. NC0057193 Nantahala Outdoor Center Swain County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Nantahala Outdoor Center on March 20, 2019. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0057193. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation _________________________________________________________________________________________________________________________________________________________________________ Flow Measurement The effluent flow meter is calibrated but not documented. _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling The effluent sampler was not working. All samples collected on March 19th were grab samples. The permit requires composite samples for BOD & TSS. _________________________________________________________________________________________________________________________________________________________________________ Effluent Sampling The sampler is set for constant time/constant volume. Flow proportional sampling is not being conducted. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF In addition, the issues below must also be addressed: 1. Assess solids handling & storage – see comments on page 2 of Inspection Summary. 2. Assess disinfection method – see comments on page 2 of the Inspection Summary. Remedial actions should have already been taken to correct these problems and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Beverly Price with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, G. Landon Davidson, P.G., Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Robert Ellyson Lance Ingram WQS ARO Server LF G:\WR\WQ\Swain\Wastewater\Minors\Nantahala Outdoor Center 57193\Inspections\March 20, 2019 CEI\20190411_NC0057193_NOV2019PC0253 DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 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 N 52 NC0057193 19/03/20 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Nantahala Outdoor Center 13077 US Hwy 19 Bryson City NC 287139114 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:30AM 19/03/20 17/12/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Lance A Ingram//828-488-7195 / Lance Alan Ingram/ORC/828-488-7195/ Other Facility Data 12:00PM 19/03/20 22/10/31 Name, Address of Responsible Official/Title/Phone and Fax Number Lance Alan Ingram,13077 Hwy 19 W Bryson City NC 287139114//828-488-2175/Contacted 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 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 Beverly Price ARO WQ//828-296-4500/ 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 DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF 4/11/2019 NPDES yr/mo/day 19/03/20 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The inspection was conducted by Beverly Price of the Asheville Regional Office. Mr. Lance Ingram was present and assisted with the inspection. The following issues were noted during the inspection: Flow meter calibration is not documented. The calibration should show a maximum deviation of less than 10% from the true discharge rates. A more reliable measuring (ruler/yard stick) device is recommended to ensure accuracy of the calibration. The composite sampler was not working at the time of inspection. As a result, all samples collected on March 19th were grab; BOD, TSS and Ammonia are required to be composite. Flow proportional sampling is not being conducted. Constant time/constant volume is being used: Use of this method requires prior approval. All maintenance and process control checks should be documented in the log book. Solids pumping should be documented. The audible/visual alarms were not working on the influent pump station/EQ basin. Safety: The following are potential safety issues for the operator: 1. The ORC uses extension ladders to access the reactor for sludge judge measurement. 2. The ORC uses a hose to remove foam from the reactor. The hose extends across the walkway between the SBR and the digester. Recommendations: 1. Plywood extensions have been added to the chlorine contact basin baffles to prevent short circuiting. The ORC reports that this was done due to elevated fecal coliform levels in the past. The system should be evaluated to determine if there is short-circuiting and if so, why. Also, possibly evaluate whether a liquid chlorine feed would be more appropriate for this system or add additional chlorine tablets. The system currently uses chlorine tablets. 2. Assess solids management in the facility. Settleable solids test showed approximately 850ml-900ml (settling was uneven) of solids. More frequent pumping of solids may be required. Perform a MLSS test to determine the amount of solids in the reactor. There was an excessive amount of foam in reactor #1. The ORC reports that Nocardia is the cause. Nocardia can be associated with longer Solids Residence Time (SRT). Verify filamentous growths by conducting a microscopic examination of the foam and the mixed liquor. Filamentous growth can cause Nocardia. Excessive grease is also a known cause of Nocardia. Restaurant grease traps may need to be pumped more frequently. Wasting may need to be increased. Foam may need to be physically removed with a vacuum truck. 3. Evaluate the capacity of the digester. The ORC reports hauling 2000-4000 gallons approximately every two weeks. NC0057193 17 (Cont.) Page#2 DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF Permit:NC0057193 Inspection Date:03/20/2019 Owner - Facility: Inspection Type: Nantahala Outdoor Center Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? The permit cover letter shows this as a Class I facility. The database and previous permit letter indicate a Class 2 facility; this is a Class 2 facility. The permit description does not show a standby generator. The facility uses a Kohler generator. Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Sludge judge - for reactor Settleable solids Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? There were a lot of solids on the bar screen.Comment: Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Page#3 DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF Permit:NC0057193 Inspection Date:03/20/2019 Owner - Facility: Inspection Type: Nantahala Outdoor Center Compliance Evaluation Pump Station - Influent Yes No NA NE Is audible and visual alarm available and operational? Audible & visual alarms were not working. 2 spare pumps were on-site. The ORC reports that grease does not seem to be an issue in the influent pump station and grease traps for restaurants at the facility are pumped approximately once per month during the season. Grease traps are pumped approximately every six weeks during the off-season. Comment: Sequencing Batch Reactors Yes No NA NE Type of operation:Duplex Is the reactor effluent free of solids? Does minimum fill time correspond to the peak hour flow rate of the facility? Is aeration and mixing cycled on and off during fill? The operator understands and can explain the process? The reactors are always mixing but air valves are set on timers. There was an excessive amount of foam in reactor #1. The ORC reports that Nocardia is a problem and it is removed via a hose that stays connected to the reactor. The ORC checks solids levels in the reactor to determine when to waste to the digester. If supernate is less than 4 ft from the sludge blanket, solids are wasted to the digester. Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? The ORC reports that 2000-4000 gallons of sludge is pumped approximately every 2 weeks and that pumping is more frequent than expected. Comment: Equalization Basins Yes No NA NE Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? Page#4 DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF Permit:NC0057193 Inspection Date:03/20/2019 Owner - Facility: Inspection Type: Nantahala Outdoor Center Compliance Evaluation Equalization Basins Yes No NA NE # Is basin size/volume adequate? Post EQ Basin - New pump was on-site and ready to be placed in the EQ Basin. Any solids that accumulate are pumped back to the digester. Chlorine tabs are used to control algae. The basin contains diffusers but they are not used. Comment: Disinfection-Tablet Yes No NA NE Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use?1 Is the level of chlorine residual acceptable? Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de-chlorination? Plywood extensions had been added to the concrete baffles to prevent short circuiting according to the ORC. This was done due to elevated fecal coliform results in the past. Comment: De-chlorination Yes No NA NE Type of system ?Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? # Is de-chlorination substance stored away from chlorine containers? Are the tablets the proper size and type? Chlorination is accomplished using tablets.Comment: Are tablet de-chlorinators operational? Number of tubes in use? Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Page#5 DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF Permit:NC0057193 Inspection Date:03/20/2019 Owner - Facility: Inspection Type: Nantahala Outdoor Center Compliance Evaluation Effluent Sampling Yes No NA NE The sampler is set for constant time/constant volume. The composite sampler was not working at the time of inspection. The motor and controls had stopped working. The sample collected on March 19th was a grab sample because the sampler was down. 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? Calibration is done by the ORC but is not being documented. The meter has a strip chart but it is not connected. Comment: 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: Standby Power Yes No NA NE Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? The permittee maintains a service contract and fuel levels are checked by the ORC. The generator was turned on and was operational but was no tested under load during the inspection. Fuel level indicated 3/4 full. Comment: Page#6 DocuSign Envelope ID: AC813FED-F50F-4044-A210-6C9FB1E8DFAF Certificate Of Completion Envelope Id: AC813FEDF50F4044A2106C9FB1E8DFAF Status: Completed Subject: Please DocuSign: 20190411_NC0057193_NOV2019PC0253.docx, 20140411_NC0057193_NOV2019PC0253_Draft.pdf Source Envelope: Document Pages: 8 Signatures: 2 Envelope Originator: Certificate Pages: 2 Initials: 1 Beverly Price AutoNav: Enabled EnvelopeId Stamping: Enabled Time Zone: (UTC-08:00) Pacific Time (US & Canada) 217 W. Jones Street Raleigh, NC 27699 Bev.Price@ncdenr.gov IP Address: 149.168.204.10 Record Tracking Status: Original 4/11/2019 9:08:39 AM Holder: Beverly Price Bev.Price@ncdenr.gov Location: DocuSign Signer Events Signature Timestamp Beverly Price bev.price@ncdenr.gov North Carolina Department of Environmental Quality Security Level: Email, Account Authentication (None)Signature Adoption: Pre-selected Style Using IP Address: 149.168.204.10 Sent: 4/11/2019 9:10:20 AM Viewed: 4/11/2019 9:10:27 AM Signed: 4/11/2019 9:10:46 AM Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign G. Landon Davidson landon.davidson@ncdenr.gov Asheville Regional Office, Regional Supervisor DEQ, Division of Water Resources, Water Quality Regional Operatoins Security Level: Email, Account Authentication (None) Signature Adoption: Uploaded Signature Image Using IP Address: 149.168.204.10 Sent: 4/11/2019 9:10:46 AM Viewed: 4/11/2019 9:14:15 AM Signed: 4/11/2019 9:43:59 AM Freeform Signing Electronic Record and Signature Disclosure: Not Offered via DocuSign In Person Signer Events Signature Timestamp Editor Delivery Events Status Timestamp Agent Delivery Events Status Timestamp Intermediary Delivery Events Status Timestamp Certified Delivery Events Status Timestamp Carbon Copy Events Status Timestamp Notary Events Signature Timestamp Envelope Summary Events Status Timestamps Envelope Sent Hashed/Encrypted 4/11/2019 9:10:47 AM Certified Delivered Security Checked 4/11/2019 9:14:15 AM Signing Complete Security Checked 4/11/2019 9:43:59 AM Completed Security Checked 4/11/2019 9:43:59 AM Payment Events Status Timestamps