NC0025071_NOD-2019-PC-0223_20191011

October 11, 2019

Mr. Brad Corcoran, City Manager
City of Eden
PO Box 70
Eden, NC 27289-0070

Subject: Compliance Evaluation Inspection Report and Notice of Deficiency
NOD Tracking No. NOD-2019-PC-0223
NPDES Permit NC0055271
Eden Mebane Bridge WWTP, Rockingham County
Dear Mr. Corcoran:
On September 13, 2019, Paul DiMatteo of the Division of Water Resources (Division), Winston-
Salem Regional Office met with Melinda Ward, Operator in Responsible Charge (ORC), and Chris
Powell, Backup ORC, to conduct a Compliance Evaluation Inspection of the above referenced
wastewater treatment plant.
This inspection consists of (1) a review of the permit and accompanying documentation to
determine compliance with permit conditions, and (2) an on-site inspection of several collection
system components. The attached inspection form notes the areas that were evaluated for the
inspection, with any notable findings outlined as follows:
Summary of Non-Compliance
Facility collects both influent and effluent composite samples using a constant time/constant
volume method. Please note that the Permit requires facilities utilizing this method of composite
sampling to be approved by the Director. If you have such an approval, please provide a copy to
this office for review. You may request approval to utilize this method by responding to this letter.
Note, however, that the Permit provides that “this method may only be used in situations where
effluent flow rates vary less than 15 percent.” Therefore, please include daily flow charts for
review with your request.
Otherwise, the Permit specifies that composite samples may only be obtained by the following
methods (please see the definition of “Composite Sample” under Part II, Section A):
1. Continuous – a “drip” of sample is collected continuously over a 24 hour period
2. Constant time/variable volume – a volume of sample at least 100 mL is collected at fixed time
intervals, and the volume is increased based on the instantaneous flow at that moment
3. Variable time/constant volume – a volume of sample at least 100 mL is collected at fixed volume
intervals.

Proper set up of the sampler for flow proportional sampling generally requires connecting an
interface between the sampler and flow meter. Care must be taken to ensure samples are
representative of the discharge for that period. The inspector noted that the chlorine contact
chambers already had flow meters installed, and encourages the operators to consult their
equipment manuals to determine how appropriate composite sampling can be achieved.
Requested Response
Within 30 days of receipt of this letter, please submit either:
a. A previous letter from the Division authorizing use of constant time/constant volume sampling,
b. Your request, with sufficient accompanying documentation, to utilize constant time/constant
volume sampling for review, or
c. Your plan, including a timeline, to gain compliance with the flow proportional sampling
requirement.
If you have any questions concerning this report please contact Paul DiMatteo at [phone]
or Lon Snider at [phone].
Sincerely,

Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ

Enclosures – Inspection Report

CC: WSRO Laserfiche Files
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 NC0025071 19/09/13 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)
Mebane Bridge WWTP
204 Mebane Bridge Rd
Eden NC 27288
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
11:00AM 19/09/13 15/03/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Melinda Sessoms Ward/ORC/336-627-1009/
Other Facility Data
01:00PM 19/09/13 18/04/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Brad Corcoran,PO Box 70 Eden NC 272890070/City
Manager/336-623-2110/3366232726
Contacted
No
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
Paul DiMatteo DWR/WSRO WQ/336-776-9691/
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
10/11/2019
10/11/2019
NPDES yr/mo/day
19/09/13
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On flow proportional sampling - Permittee should submit a request for timed-based sampling, produce
a letter previously granted by the Division, or set up the system for proper floow proportional sampling.
Note that constant time/constant volume sampling may only be used when the effluent flow rate varies
less than 15%; thus, Permittee should submit daily flow charts with their proposal.
NC0025071 17
Page#2
Permit:NC0025071
Inspection Date:09/13/2019
Owner - Facility:
Inspection Type:
Mebane Bridge WWTP
Compliance Evaluation
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?
Comment:
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?
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?
Are all records maintained for 3 years (lab. reg. required 5 years)?
Are analytical results consistent with data reported on DMRs?
Is the chain-of-custody complete?
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?
Has the facility submitted its annual compliance report to users and DWQ?
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
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
Permit:NC0025071
Inspection Date:09/13/2019
Owner - Facility:
Inspection Type:
Mebane Bridge WWTP
Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review?
DMR Note - Reviewed the DMR for 9/18/2019 and noted that Effluent Zinc was reported as
kg/day, and not mg/l. No conversion was made, thus this is simply a unit error. The DMRs
with this fault should be corrected and resubmitted. This appears to have been present in
DMRs since 6/2016.
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?
The outfall was not observed due to access issues. The operators said that they tried to get
the lines crew to clear the outfall ROW but due to the time of year it was not directly
accessible.
Comment:
Flow Measurement - Influent 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:
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?
Flow meters are installed on the effluent sides of the 3 chlorine contact chambers and they
are calibrated but not connected to SCADA and not used for flow reporting or flow
proportioning. Operators said that they were suspicious of the accuracy of the meters
despite them being calibrated quarterly.
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Page#4
Permit:NC0025071
Inspection Date:09/13/2019
Owner - Facility:
Inspection Type:
Mebane Bridge WWTP
Compliance Evaluation
Bar Screens Yes No NA NE
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Grit Removal Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
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?
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 ¼ of the sidewall depth)
Two of four clarifiers are in service due to low flow. Measured the sludge depth in 1 clarifier
at ~1.5 feet.
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Page#5
Permit:NC0025071
Inspection Date:09/13/2019
Owner - Facility:
Inspection Type:
Mebane Bridge WWTP
Compliance Evaluation
Aeration Basins Yes No NA NE
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/l)
DO in aeration basin 5.74 according to meter set near the end of the basin. Operators said
they try to keep it above 2. Only one aeration basin is in service. Operations said they
installed "solar bees," a solar-powered mixers that keep the basin in suspension near the
end of the basin. They planned to install more.
Comment:
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
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?
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-____-____)
If yes, then when was the RMP last updated?
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?
Comment:
Are the tablets the proper size and type?
Are tablet de-chlorinators operational?
Number of tubes in use?
Comment:
Page#6
Permit:NC0025071
Inspection Date:09/13/2019
Owner - Facility:
Inspection Type:
Mebane Bridge WWTP
Compliance Evaluation
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?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
DO and pH calibration records appeared acceptable. Thermometer calibration also
appeared acceptable.
Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?
Is sample collected above side streams?
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 sampling performed according to the permit?
Sample volume is checked by staff 3x/day, was not verified during the inspection. Facility
was not sampling during the inspection.
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)?
Sample volume is checked by staff 3x/day, was not verified during the inspection. Facility
was not sampling during the inspection. Operators said they did not perform flow
proportional sampling at the effluent due to difficulty in hooking the influent meter up to the
effluent sampler and because, although they have effluent flow meters on each of the
chlorine contact chambers, they did not believe the readings were accurate.
Comment:
Upstream / Downstream Sampling Yes No NA NE
Page#7
Permit:NC0025071
Inspection Date:09/13/2019
Owner - Facility:
Inspection Type:
Mebane Bridge WWTP
Compliance Evaluation
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and
sampling location)?
Comment:
Page#8