NC0021717_Inspection Response_20200210

TOWN OF WILKESBORO
"%%izerei Phi ✓�Wwom, ✓Zegw,i'
P.O. Box 1056 • 203 West Main Street
Wilkesboro, North Carolina 28697
www.wilkesboronc.org
Phone [phone] • Fax [phone]
February 6, 2020
Lon Snider
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Dear Mr. Snider:
' _: �-�piar'tlYiSrit ll'
Environmental Quality
Received
Winston-Salem
Regional Office
In response to the Plant inspection on January 20, 2020, this letter will cover each violation and concern
according to the letter we received.
1. The inspectors observed floating scum and sludge prior to, and at the LIV system, which could
disrupt proper disinfection ultimately and make its way to the receiving stream if not contained
prior to discharge.
The foam itself has not caused any major interferences with regards to disinfection in the past. The
foam is forming in the pre-existing contact chamber because the outfall of the clarifier's pipe is
around a foot above the water level. The splashing of the water creates the foam. We have tried
several different ways to correct this. We currently have lowered the gate to the LIV channel below
the water level so the foam cannot reach the LIV system and stays in the old contact chamber. Also,
we have a water hose equipped with a nozzle that sprays over the foam to keep the amount down.
If this measure is effective, we will install this option permanently.
2. The influent sampler is currently setup to collect time -based samples. The permit requires flow
proportional sampling.
We recently installed a new Hach sample station, and in the past, we have used ISCO. With the new
samplerfrom a different manufacturer, there is an issue with the communication from the flow
meter to the sampler. We are currently working with Hach to get this resolved and anticipate it
being cleared up in the near future.
3. The facility does not have a backup method for disinfection on the premises. The deficiency was
also noted in the previous inspection.
The LIV Disinfection system has two banks of bulbs that have the ability to operate independently
from one another. Additionally, there is a second channel that is currently closed. When approved
and permitted, it was our understanding that this method met the standard of having a back-up in
MIKE INSCORE KENNETH D. NOLAND JAMES K. BYRD NELLIE ARCHIBALD JIMMY HAYES
Mayor Town Manager Town Clerk RUSSELL F. FERREE Mayor Pro Tem
[e-mail] ANDREW "ANDY" SOOTS
Council Members

place. The system has performed as designed and provided adequate alternate treatment when
necessary. However, we are in the process of selecting an engineering firm to provide a Preliminary
Engineering Report for a possible plant upgrade and this item will be reviewed and addressed during
this time. We anticipate a firm to be selected for this process and contract in place this spring.
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.
Previously, the temperature of the effluent composite sampler was to be monitored each morning
by the day shift operator. The morning of the inspection, the sampler temperature was checked and
recorded at 5 degrees Celsius. As a result of this finding, we have now implemented a new
procedure requiring the operator to check and notate the temperature three times per day to
ensure we are consistently between 0 and 6 degrees Celsius.
5. It was observed during the inspection that the PH 10 standards in the laboratory were expired.
We allowed the PH 10 standard to expire but immediately ordered one. It has been replaced. We
have also inventoried the lab and created a spreadsheet with all supplies and their expiration dates.
Procedurally, this will be checked monthly by staff to ensure we are ordering and replacing any
expired product before the expiration date.
6. When asked of the amount and frequency of sample pulled via the influent sampler the ORC
was unsure of how many gallons a pulse was. This was also a deficiency noted in the last
inspection
We had discussed with Justin this topic by email after the last inspection. This conversation is
available for review, if requested. Procedurally, a document has been placed at the sampler to
record and explain flow pacing.
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 11 and 2ntl. Please clarify this inconsistency and
resubmit the DMR immediately.
The missing July data,was due to the equation being unintentionally removed for the combined
influent weighted average on the formula sheet. We have corrected the DMR and immediately
resubmitted it.
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.
The influent screen had previously been ordered and we are still waiting for it to arrive. However,
the other functioning train is able to handle 8 MGD which is more than adequate to treat the
amount during normal flow periods.
We have made multiple attempts to repair the grit chamber. This topic is also being addressed in the
planned plant upgrade referenced earlier.
We have encountered multiple issues with the aerators, restricting us from continuously keeping
them all operational. Currently, after many attempts to repair and troubleshoot this problem, we

feel it is related to the power cables running to each aerator. We have new cable and are in the
process of getting it repaired in hopes this will resolve this issue.
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.
We will contact the permitting department of the DNER and verify what actions need to be taken to
ensure the bar screen and grit removal chamber processes will be added to the permit.
In closing, the Town feels as though we have addressed or are in the process of addressing these
areas of concerns and violation. It is also our near future goal to alleviate some of these issues
through a plant upgrade. We have already taken major steps towards this upgrade in the way of a
rate increase and the interviewing of various engineering firms for a Preliminary Engineering Report.
As a result of the actions steps listed previously, we would respectfully request your consideration
of revaluing this Notice of Violation as a Notice of Deficiency.
Please feel free to contact me directly should you have any need for further conversation.
Sincerely,
Ken bland
Town Manger
Town of Wilkesboro