NCG590017_Compliance Evaluation Inspection_20180629 (2)

Water Resources 4
Environmental Quality
June 29, 2018
Mr. Steven Drew, Director
Water Resources Department
City of Greensboro
P.O. Box 3136
Greensboro, NC 27402-3136
SUBJECT: Compliance Evaluation Inspection
Lake Townsend Water Treatment Plant
General Permit No. NCG590017
Guilford County
Dear Mr. Drew:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
On June 25, 2018, Jenny Graznak and Kelli Park of this office met with Earl Green, Dell Harney, Larry
Nance, and Ali Khan to perform a Compliance Evaluation Inspection on the permitted wastewater
discharge from the Lake Townsend Water Treatment Plant (WTP). The inspection findings are detailed
below and an inspection checklist is attached.
1. Permit
The individual permit for this facility (NC0081671) was rescinded in July 2017 and replaced with the
general permit for water treatment plants (NCG590017). Please note that the general permit requires
annual Whole Effluent Toxicity testing, using an effluent concentration of 90%.
2. Self -Monitoring Program
The Discharge Monitoring Reports (DMRs) were reviewed for the period of May 2017 through April
2018. It was noted that all sampling was performed per the frequencies specified in the permit. There
were multiple violations during this period, which were addressed in separate correspondence from
this office. A comparison of the July 2017 DMR with the facility's laboratory data for temperature,
pH, total residual chlorine, turbidity, and TSS showed that these parameters were transcribed
accurately. Meritech handles the Whole Effluent Toxicity, metals, fluoride, total nitrogen, and
ammonia testing for the facility.
3. Flow Measurement
The permit requires continuous effluent flow recording and annual calibration of the flow measuring
device. The daily effluent flow values reported on the DMRs are measured using an ultrasonic meter
and rectangular weir at the discharge structure. The meter is calibrated every six months by City of
Greensboro staff. The meter was last calibrated on April 6, 2018.
4. Sludge Handling and Disposal
Solids were removed from the settling lagoon October 2017 through March 2018 by a private
contractor (Synagro) using a portable centrifuge. This removal event caused the elevated TSS levels
r^' Nothing Compares'=-,..
State of North Carolina I Environmental Quality
450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105
Phone: [phone] FAX: [phone]

that led to the violations that are listed in one of the attachments. Greensboro will construct a second
settling lagoon to address this recurring noncompliance issue.
5.Operations and Maintenance
The Operator in Responsible Charge (ORC) for this facility is Earl Green. The facility was competently
operated and maintained. No problems or concerns were noted.
6. Facility Site Review
Wastewater from this plant is generated from filter backwash, which is clarified in the settling lagoon,
and then discharged. The wastewater handling system consists of the following: mixing basin for
dechlorination addition, settling lagoon, ultrasonic flow meter, and effluent outfall. Construction is
ongoing at this facility for upgrades.
7. Effluent/Receiving Waters
The system discharges into Reedy Fork, classified as WS-V; NSW waters in the Cape Fear River Basin.
The effluent was observed to be clear on the day of inspection.
Should you have any questions concerning this report, please contact Jenny Graznak or me at (336)
776-9800.
Sincerely,
Zia
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
Attachments: Inspection Report
Monitoring Report Violations
cc: Earl Green <[e-mail]>
NPDES Unit
Central Files
WSRO

United State. Environmental Protection Agency
Form Approved,
EPA Washington, D.C.20460
OMB No. 2040-0057
Water Compliance Inspection Report
Approval expires8-31-98
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 1 3 I NCG590017 I11 121 18/06/25 117 18ICI 19 I c I 201 I
�6
211 I I I I I I I I I 11 l U l l l l l l l l l l I I I I I I I I I LII I I I I I f6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA Reserved
67
I I 70 Lj 71 L 72 73I 74 75L_J_L_I_I
J
80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry TimelDate
Permit Effective Date
POTW name and NPDES permit Number)
12:00PM 18/06/25
17/07/01
Lake Townsend WTP
Exit Time/Date
Permit Expiration Date
6268 Bryan Park Rd
01:30PM 18/06/25
19/07/31
Greensboro NC 27402 -
Names) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
H/
Earl Clayton Green/ORC/336-383-9882/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Lewis Walker,2503 White St Greensboro NC 27405//336-373-7662/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program 0 Sludge Handling Disposal Facility Site Review Etnuent/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!(ss))�,yy✓nq'�Agency/Office/Phone and Fax Numbers
II /j-Date
JennifG
er Graznak �J%� J WSRO WQ//336-771-5000/ /Z4?PiD(
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
v
EPA Form 3580-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPOES yr/mo/day Inspection Type
31 NCG590017 I11 12 18/06/25 17 18 ICI
1. Permit
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The individual permit for this facility (NC0081671) was rescinded in July 2017 and replaced with the
general permit for water treatment plants (NCG590017). Please note that the general permit requires
annual Whole Effluent Toxicity testing, using an effluent concentration of 90%.
2. Self -Monitoring Program
The Discharge Monitoring Reports (DMRs) were reviewed for the period of May 2017 through April
2018. It was noted that all sampling was performed per the frequencies specified in the permit. There
were multiple violations during this period, which were addressed in separate correspondence from
this office. A comparison of the July 2017 DMR with the facility's laboratory data for temperature, pH,
total residual chlorine, turbidity, and TSS showed that these parameters were transcribed accurately.
Meritech handles the Whole Effluent Toxicity, metals, fluoride, total nitrogen, and ammonia testing for
the facility.
3. Flow Measurement
The permit requires continuous effluent flow recording and annual calibration of the flow measuring
device. The daily effluent flow values reported on the DMRs are measured using an ultrasonic meter
and rectangular weir at the discharge structure. The meter is calibrated every six months by City of
Greensboro staff. The meter was last calibrated on April 6, 2018.
4. Sludge Handling and Disposal
Solids were removed from the settling lagoon October 2017 through March 2018 by a private
contractor (Synagro) using a portable centrifuge. This removal event caused the elevated TSS levels
that led to the violations that are listed in one of the attachments. Greensboro will construct a second
settling lagoon to address this recurring noncompliance issue.
5. Operations and Maintenance
The Operator in Responsible Charge (ORC) for this facility is Earl Green. The facility was competently
operated and maintained. No problems or concerns were noted.
6. Facility Site Review
Wastewater from this plant is generated from filter backwash, which is clarified in the settling lagoon.
The wastewater handling system consists of the following: mixing basin for dichlorination addition,
settling lagoon, ultrasonic flow meter, and effluent outfall. Construction is ongoing at this facility for
upgrades.
7. Effluent/Receiving Waters
The system discharges into Reddy Fork, classified as WS-V; NSW waters in the Cape Fear River
Basin. The effluent was observed to be clear on the day of inspection.
Page#

Permit: NCG59OD17 Owner -Facility: Lake Townsend WrP
Inspection Date: 06/25/2018 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: The Operator in Responsible Charge (ORC) for this facility is Earl Green. The facility was
competently operated and maintained. No problems or concerns were noted.
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑
0
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
#.Are there any special conditions for the permit?
❑
M
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment:
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)?
M
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
M
❑
❑
❑
Is the chain -of -custody complete?
M
❑
❑
❑
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?
M
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
M
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator
❑
❑
M
❑
on each shift?
Is the ORC visitation log available and current?
M
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
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
❑
❑
❑
Page#
3

Permit: NCG590017 Owner -Facility: Lake TownsenowrP
Inspection Date: 06/25/2016 Inspection Type: Compliance Evaluation
Record Keepin9 Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑
Comment:
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
M
❑
❑
❑
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?
❑
❑
M
❑
Comment:
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
M
❑
❑
❑
Is the flow meter operational?
0.
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
M
❑
Comment:
De -chlorination
Yes No NA NE
Type of system ?
Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑ 0
❑
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
❑ ❑
M
❑
Comment:
Are the tablets the proper size and type? ❑ ❑ M ❑
Are tablet de -chlorinators operational? ❑ ❑ 0 ❑
Number of tubes in use?
Comment: Sodium thiosulfate is added for dechlorination, and caustic is used for off adjustment.
Page# 4

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