NC0021717_Compliance Evaluation Inspection_20200128

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Director
CERTIFIED MAIL 7017-1450-0001-6450-0702
RETURN RECEIPT REQUESTED
Mr. Kenneth D. Noland
Town Manager
Town of Wilkesboro
P.O. Box 1056
Wilkesboro, NC 28697
�ry
44,
NORTH CAROLINA
EnNlmnmrrtlnl Quality
January 28, 2020
SUBJECT: Compliance Evaluation Inspection and Notice of Violation
NOV-2020-PC-0053
Cub Creek WWTP
NPDES Permit No. NCO021717
Wilkes County
Dear Mr. Noland,
On January 16, 2020, Kelli Park and Jenny Graznak of this office met with Dustin Colburn,
Operator in Responsible Charge, to perform a Compliance Evaluation Inspection at the Cub
Creek wastewater treatment plant. 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 during this inspection. Violations and concerns noted during
the inspection are outlined below:
1) The inspectors observed floating scum and sludge prior to and at the UV system, which could
disrupt proper disinfection ultimately and make its way to the receiving stream if not contained
prior to discharge.
2) The influent sampler is currently set up to collect time -based samples. The permit requires
flow proportional sampling.
3) This facility does not have a backup method for disinfection on the premises. This deficiency
was also noted in the previous inspection.
4) The effluent composite sampler unit must be between 0 and 6 degrees Celsius for proper
sample preservation. At the time of inspection, it read 8 degrees Celsius.
5) It was observed during the inspection that the pH 10 standards in the laboratory were expired.
6) When asked of the amount and frequency of sample pulled via the effluent sampler the ORC
was unsure of how many gallons a pulse was. This was also a deficiency noted in the last
inspection.

7) During the DMR record review it was noted that there was no data for the required sampling
parameters for the influent on the days of July 15t and 2nd. Please clarify this inconsistency
and resubmit the DMR immediately.
8) Several treatment units were out of order at the time of inspection, including one train of the
mechanical bar screen, the mechanical grit removal, and a surface aerator.
9) It was noted in the previous inspection that the bar screen and grit removal were not listed in
the permit. Please ensure that this was noted in your recent permit application so that the next
issued permit reflects all processes in the plant.
These issues represent 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 its
receipt. Your written reply should address each of the noted violations and provide a corrective
action plan along with an implementation/completion schedule to remediate them.
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 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 Ion. snider(a)-ncdenr.gov.
Sincerely,
Doc uSigned by:
-4'ME225C94EA...
Lon Snider
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: EPA Water Compliance Inspection Report
cc: WSRO Laserfiche Files
Page 2 of 2

United States Environmental Protection Agency
Form Approved.
EPA 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 IN 1 2 15 I 3 I NC0021717 111 12 I 20/01/16 I17 18 I S J 19 L G] 201 I
211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
671
70 I I 71 I I 72 I r I 73 I I 174 751 I I I I I I I80
u ty I I i
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 oermit Number)
10:OOAM 20/01/16
16/02/01
Cub Creek WWTP
701 Snyder St
Exit Time/Date
Permit Expiration Date
Wilkesboro NC 28697
01:30PM 20/01/16
19/09/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Dustin Franklin Colburn/ORC/336-927-3785/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael R. Testerman,PO Box 1056 Wilkesboro NC
286971056/Superintendent/336-667-2391/ 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
Kelli A Park Docusigned by: DWR/WSRO WQ/336-776-9689/
Jennifer F Graznak PA4 DWR/WSRO WQ/336-776-9800/
E1/29/2020
B4A41 DCE74C34139_.
Signature of Management Q A Reviewer Docusigned by: Agency/Office/Phone and Fax Numbers Date
FLI T 1-5,dtc 1/28/2020
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NCO021717 111 121 20/01/16 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On January 16, 2020, Kelli Park and Jenny Graznak of this office met with Dustin Colburn, Operator in
Responsible Charge, to perform a Compliance Evaluation Inspection at the Cub Creek wastewater
treatment plant. 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 during this inspection. Violations and concerns noted during the inspection are outlined
below:
1) The inspectors observed floating scum and sludge prior to and at the UV system, which could
disrupt proper disinfection ultimately and make its way to the receiving stream if not contained prior to
discharge.
2) The influent sampler is currently set up to collect time -based samples. The permit requires flow
proportional sampling.
3) This facility does not have a backup method for disinfection on the premises. This deficiency was
also noted in the previous inspection.
4) The effluent composite sampler unit must be between 0 and 6 degrees Celsius for proper sample
preservation. At the time of inspection, it read 8 degrees Celsius.
5) It was observed during the inspection that the pH 10 standards in the laboratory were expired.
6) When asked of the amount and frequency of sample pulled via the effluent sampler the ORC was
unsure of how many gallons a pulse was. This was also a deficiency noted in the last inspection.
7) During the DMR record review it was noted that there was no data for the required sampling
parameters for the influent on the days of July 1 st and 2nd. Please clarify this inconsistency and
resubmit the DMR immediately.
8) Several treatment units were out of order at the time of inspection, including one train of the
mechanical bar screen, the mechanical grit removal, and a surface aerator.
9) It was noted in the previous inspection that the bar screen and grit removal were not listed in the
permit. Please ensure that this was noted in your recent permit application so that the next issued
permit reflects all processes in the plant.
These issues represent 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 its receipt. Your
written reply should address each of the noted violations and provide a corrective action plan along with
an implementation/completion schedule to remediate them.
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 you have any questions regarding the inspection or this report, please contact Kelli Park or me at
[phone] or by email at [e-mail] or [e-mail].
Page# 2

Permit: NCO021717
Inspection Date: 01/16/2020
Owner - Facility: Cub Creek WWTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Several treatment units were out of order at the time of inspection, including one train of the
mechanical bar screen, the mechanical -grit removal, and a surface aerator.
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?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: Bar screen and grit removal are not listed in the old permit.
Permit expired in september of 2019. The permit renewal application was sent in to DEQ on
April 2, 2020.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
❑
0
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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?
0
❑
❑
❑
(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?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Page# 3

Permit: NCO021717 Owner - Facility: Cub Creek WWTP
Inspection Date: 01/16/2020 Inspection Type: Compliance Evaluation
Record Keeping
Yes No NA NE
Is the backup operator certified at one grade less or greater than the facility classification?
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
0
❑
❑
❑
Comment: There was no data reported for influent parameters the first two days in July 2019.
ORC and bORC are both grade 4
Pump Station - Influent
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?
Is audible and visual alarm available and operational?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ■ ❑
■ ❑ ❑ ❑
Comment: There are 3 pumps, and they all work, however only 2 pumps are used consistently.
Flow Measurement - Influent
# 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: Calibrated 9/19
Influent Sampling
# 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?
Yes No NA NE
■ ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ ■ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
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Page# 4

Permit: NCO021717
Inspection Date: 01/16/2020
Owner - Facility: Cub Creek WWTP
Inspection Type: Compliance Evaluation
Influent Sampling Yes No NA NE
Comment: Influent sampling was not flow proportional. Via the permit composite samples must be flow
proportionate.
100ml/ hour
Bar Screens
Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
0
❑
❑
❑
Is the unit in good condition?
0
❑
❑
❑
Comment: There sare two trains on the bar screen. One is out of order.
Debris are taken to a landfill.
Grit Removal
Yes
No
NA
NE
Type of grit removal
a.Manual
❑
b.Mechanical
Is the grit free of excessive organic matter?
❑
❑
0
❑
Is the grit free of excessive odor?
❑
❑
0
❑
# Is disposal of grit in compliance?
❑
❑
0
❑
Comment: Grit removal train was out of order at the time of inspection.
Aeration Basins
Yes No NA NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
0 ❑
❑
❑
Are the diffusers operational?
❑ ❑
0
❑
Is the foam the proper color for the treatment process?
0 ❑
❑
❑
Does the foam cover less than 25% of the basin's surface?
0 ❑
❑
❑
Is the DO level acceptable?
0 ❑
❑
❑
Page# 5

Permit: NCO021717 Owner - Facility: Cub Creek WWTP
Inspection Date: 01/16/2020 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Is the DO level acceptable?(1.0 to 3.0 mg/1) 0 ❑ ❑ ❑
Comment: There are 7 surface aerators. One is out of order, one is typically not in use.
Secondary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
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?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
0
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
M
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth)
0
❑
❑
❑
Comment: There are four clarifiers. The sludge blankets were reported to be 100ft or less.
The water in the clarifiers was murkev and there was a lot of Din floc.
Disinfection - UV
Yes No NA NE
Are extra UV bulbs available on site?
0
❑
❑
❑
Are UV bulbs clean?
0
❑
❑
❑
Is UV intensity adequate?
❑
❑
❑
Is transmittance at or above designed level?
❑
❑
❑
Is there a backup system on site?
❑
0
❑
❑
Is effluent clear and free of solids?
❑
0
❑
❑
Comment: There was a lot of floating solids before and after the UV system. There is also a basin
before the UV system that the water flows into- it is most likely
catching solids and
potentially has a sludge blanket
There are automated wipers on the bulbs that clean them off multiple times a day.
2 parallel trains of UV bulbs
There is not a backup disinfection system on site, this was flagged in the previous
inspection
Page# 6

Permit: NCO021717 Owner - Facility:
Inspection Date: 01/16/2020 Inspection Type:
Cub Creek WWTP
Compliance Evaluation
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
0
❑
❑
❑
Comment: Calibrated on 7/19
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
0
❑
❑
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
0
❑
❑
❑
# 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
❑
❑
❑
representative)?
Comment: The temperature in the sampler was 8 dearees C
100ml are sampled per pulse. CIRC was unsure of what a pulse was- this was flagged
in
previous inspection and there was no responce when one was requested after the last
inspection.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
0 ❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
0 ❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑ ❑
0
❑
Comment: Effluent was murky
Laboratory
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?
Comment: pH 10 standards were expired
MUM ►[•7►/_M►1M
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• ❑ ❑ ❑
• ❑ ❑ ❑
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• ❑ ❑ ❑
Page# 7

Permit: NC0021717
Inspection Date: 01/16/2020
Owner - Facility: Cub Creek WWTP
Inspection Type: Compliance Evaluation
Aerobic Digester
Yes No NA NE
Is the capacity adequate?
0
❑
❑
❑
Is the mixing adequate?
0
❑
❑
❑
Is the site free of excessive foaming in the tank?
0
❑
❑
❑
# Is the odor acceptable?
0
❑
❑
❑
# Is tankage available for properly waste sludge?
0
❑
❑
❑
Comment:
Solids Handling Equipment
Yes No NA NE
Is the equipment operational?
0
❑
❑
❑
Is the chemical feed equipment operational?
0
❑
❑
❑
Is storage adequate?
0
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
0
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
0
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
0
❑
❑
❑
The facility has an approved sludge management plan?
❑
❑
❑
Comment:
Drying Beds
Yes No NA NE
Is there adequate drying bed space?
0
❑
❑
❑
Is the sludge distribution on drying beds appropriate?
❑
❑
0
❑
Are the drying beds free of vegetation?
0
❑
❑
❑
# Is the site free of dry sludge remaining in beds?
0
❑
❑
❑
Is the site free of stockpiled sludge?
0
❑
❑
❑
Is the filtrate from sludge drying beds returned to the front of the plant?
❑
❑
0
❑
# Is the sludge disposed of through county landfill?
❑
❑
0
❑
# Is the sludge land applied?
❑
❑
0
❑
(Vacuum filters) Is polymer mixing adequate?
❑
❑
0
❑
Comment: Drying beds are not in use
Equalization Basins
Yes No NA NE
Is the basin aerated?
0
❑
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Is the basin free of excessive grease?
0
❑
❑
❑
Page# 8

Permit: NC0021717
Inspection Date: 01/16/2020
Equalization Basins
Are all pumps present?
Are all pumps operable?
Are float controls operable?
Are audible and visual alarms operable?
# Is basin size/volume adequate?
Owner - Facility: Cub Creek WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
•
❑
❑
❑
•
❑
❑
❑
•
❑
❑
❑
❑
❑
■
❑
■
❑
❑
❑
Comment: Tvson is the main contributer of flow to this plant. There is so much flow there is a EQ
basin/lagoon set up up the hill from the plant before the domestic WW inflow. The basin
holds the flow exclusively from Tyson and is managed by Tyson. Inflow from Tyson sits up
in the basin before enteringthe plant, and flow into the plant is controlled as needed. There
are two sections to this basin, a highly aerated section and a moderate air section. Water is
very murky. There are no alarms. There is a combination of mixers and aerators.
Page# 9