Loading...
HomeMy WebLinkAboutNC0001384_Regional Office Historical File Pre 2016AZ NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor April 13, 2015 Mr. Michael Durham, CEO Burlington Technologies — Williamsburg Plant 5928 NC Highway 87 North Gibsonville, North Carolina 27249 Donald R. van der Vaart Secretary SUBJECT: Response to Notice of Violation and Recommendation for Enforcement NOV-2015-PC-0030 — Compliance Evaluation Inspection NPDES Permit No. NC0001384 Burlington Technologies — Williamsburg Plant WWTP (aka `se7en, LLC') Caswell County Dear Mr. Durham: Thank you for taking the time to compose a detailed response to the Notice of Violation and Recommendation for Enforcement dated February 27, 2015. Your response was received on March 30, 2015. Your demonstrated willingness to make the changes necessary to bring Burlington Technologies' Williamsburg Plant (aka `se7en') into compliance is very much appreciated. The Division does not plan on pursuing any further action at this time. Please understand however, that this was not an easy decision. Your ability to demonstrate and maintain the improvements you promise going forward will be essential for justifying our decision. Expect an unannounced inspection at any time in the future, with increased scrutiny of the following areas in particular: • Proper use of approved chemicals and/or treatment systems at outfalls 002 and 003. • Up-to-date and accurate record of visitation, operations and maintenance, as performed by the ORC and plant staff. • Proper operations and maintenance, as evidenced by the conditions of the wastewater treatment plant and the outfalls. • Proof of written communication between Burlington Technologies — Williamsburg Plant and the operator when improvements are needed/requested . Should you have any questions regarding this matter, please contact me at (336) 776-9696 or at Sherri. Knight@ncdenr.gov. Sincerely, Sherri V. Knight, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NC DENR cc: DWR Central Files WSRO Files Marc W. Nault (4490 Crews Ln; Walkertown, NC 2 705 1) Meritech, Inc. (Attn: David Merritt; P.O. Box 27; Reidsville, NC 27323) Mona Cunningham O' Bryant (Smith Moore Leatherwood LLP; 300 N. Greene St Suite 400, Greensboro, NC 27401) 450 W Hanes Mill Rd., Suite 300, Winston-Salem, NC 27105 Phone: 336-776-98001 Internet: www.ncdenr.gov An Equal opportunity 1 Affirmative Action Employer — Made in part by recycled paper .AI NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald R. van der Vaart Governor Secretary March 31, 2015 Mr. Michael Durham, CEO Burlington Technologies- Williamsburg Plant 5928 Highway 87 North Gibsonville, North Carolina 27249 Subject: Request for Permit Modification NPDES Permit NC0001384 Burlington Technologies/Williamsburg Caswell County Dear Mr. Durham: The Division received a request for permit modification on January 30, 2015 from your consultant Leonhardt Environmental. This request is to add a new process wastewater discharge of approximately 100 gallons per day to be discharged along with the current domestic wastewater discharge via Outfall 001. After reviewing this request, the Division is unable to support this permit modification for the following reasons: 1. Outfall 001 discharges treated domestic wastewater to an unnamed tributary to Buttermilk Creek, which is classified as a water supply waterbody (WSII-NSW, HQW). For waters classified as WS-II, new domestic and industrial discharges of treated wastewater are not allowed in the entire watershed in accordance with 15A NCAC 2B.0214(2). 2. The NPDES Compliance Evaluation inspection conducted for this facility on 1/7/2015 indicated continuing problems with the plant's operations, maintenance, and compliance with permit conditions. If you would like to discuss this decision by the Division, feel free to contact me at 919-807-6390 or via email at tom.belnickgncdenr.gov. aeSirely, Belnick, Supervisor NPDES Complex'Permitting Unit, DWR Cc: NPDES Permit File, Central File, H. Derr Leonhardt II, PE Ecopy: WSRO/Jennifer Carter 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 , 11�.' Phone: 919-807-63001 Internet: www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer— Made in part by recycled paper SMITHMOORE LEATHERWOOD A T T O R N E Y S -. March 27, 2015 VIA FEDERAL EXPRESS Ms. Sherri V. Knight Assistant Regional Supervisor Water Quality Regional Operation Section NC DENR Division of Water Resources 450 W. Hanes Mill Road, Suite 300 Winston-Salem, North Carolina 27105 Dear Sherri: RECEIVED rN.C. Dept of ENR .,MAR 3 0 2015 WINSTON-SALEM REGIONAL OFFICE Re: Burlington Technologies - Williamsburg Plant NPDES Permit No. NC0001384 Response to NOV-2015-PC-0030 300 N. Greene Street Suite 1400 Greensboro, NC 27401 I am writing on behalf of my client Burlington Technologies, Inc. (BTI) in connection with a Notice of Violation and Recommendation for Enforcement dated February 25, 2015. Due to weather issues, the Notice of Violation (NOV) was actually received by BTI on March 3, 2015, although an effort was made to deliver on February 28, 2015. The NOV and Recommendation for Enforcement arise out of a January 7, 2015 inspection of the wastewater treatment plant (WWTP) located at BTI's Williamsburg facility (also referred to as Se7en, LLC). Before addressing the specific issues raised in the NOV individually, BTI wants to emphasize that it is taking and will continue to take any and all steps required to bring the WWTP into full compliance. As you will see throughout the responses below, significant action is underway and processes and procedures are being put in place to ensure that the WWTP meets and continues to maintain compliance. Throughout the inspection, Jenifer Carter of your office was accompanied by Marc Nault, who is an employee of Meritech, Inc. BTI currently contracts with Meritech to operate the WWTP at the Williamsburg facility and Mr. Nault is the designated Operator in Responsible Charge (ORC). Although BTI recognizes that it is ultimately responsible for the compliance of its facility, BTI relies on Meritech for its expertise and performance of the contracted ORC responsibilities. Some of the information contained in this report was obtained from Mr. Nault, who handles the day to day operation of the WWTP, and others at Meritech. BTI is committed to environmental protection and full compliance with its NPDES permit and North Carolina laws and regulations, and acknowledges its error in failing to oversee the contracted ORC adequately and counting on the ORC to maintain compliance. In addition to taking steps to remedy any non-compliance concerns, the company will closely monitor and evaluate its relationship with Meritech or any other third party vendor supplying ORC services as it continues to strive for consistent compliance. Direct: 336.378.5237 1 Fax: 336.433.74691 .nona.o'bryant@smithmoorelaw.com I www.smithmoorelaw.com ATLANTA I CHARLESTON I CHARLOTTE I GREENSBORO I GREENVILLE I RALEIGH I WILMINGTON Ms. Sherri V. Knight March 27, 2015 Page 2 For ease of reference, this response will follow the numbered items listed at the bottom of page 4 of your February 25 letter. 1) Please submit Plans for approval of a dechlorination system to be installed at or along the discharge pipe to outfall 002. Response: Cascade, a water systems company, has supplied chemicals to treat the plant's discharges in the past. While plant maintenance personnel have attempted to manage both the needed chemicals for dechlorination and the apparatus to disperse such chemicals, BTI realizes that its employees do not have the required expertise, and an internal decision has been made to contract with Cascade or another appropriate vendor to provide these services and recommendations going forward. BTI will rely on Cascade or another water systems company for recommendations of pre -approved chemicals and systems and for an implementation plan of such recommendations once the chemicals are approved by the State. These approved recommendations for dechlorination will be implemented for any and all flows going into outfalls 001, 002 & 003. BTI has been having discussions with Cascade regarding this decision, and a preliminary meeting was held on March 27, 2015 to allow Cascade to present its findings and recommendations to BTI personnel. BTI also has talked with and plans to engage Bensinger & Garrison to review the Cascade recommendations and to provide any additional recommendations. The critical nature of these chemical applications, the repercussions of any non-compliance, and the lack of full-time qualified in-house personnel makes it necessary to contract these services going forward. However, BTI will closely monitor the work done by Cascade and/or Bensinger and Garrison and document that the terms of BTI's NPDES permit and its contract with the vendor are met. BTI expects to present an action plan based on the vendor's recommendations to the State no later than April 10, 2015 for approval. 2) If any biocides and/or chemicals are to be used in the Cooling Tower that will be present in the discharge at outfall 003, prior approval must be obtained from the Division. Response: Biocides are not currently being used and were not in use at the time of the inspection in January 2015. All biocides have been removed from the premises, and no biocides will be present on the premises until BTI receives approval from your office. The biocides that were questioned by the inspector during the 2014 inspection were supplied by outside companies and were being used at the plant when BTI took over ownership and operation of the facility. BTI did not understand that they had not been previously approved and believed them to be appropriate based on their historical use. Following receipt of the 2014 inspection report questioning whether or not the biocides were appropriate, BTI mistakenly understood that the need to conduct toxicity testing was the concern. BTI employees made multiple unsuccessful attempts to complete the worksheets that get loaded into the State's on-line toxicity pass/fail algorithm. When employees were not able to satisfactorily complete the forms, BTI brought in both Meritech and Cascade to help in filling out the worksheets appropriately. Once the Ms. Sherri V. Knight March 27, 2015 Page 3 worksheets were completed and loaded into the State's on-line system, it was BTI's understanding that one of the biocides, Cascade's A102, failed toxicity. BTI received this information on July 9, 2014. While it appears that BTI utilized biocides during the summer of 2014, following the July 9 receipt of the toxicity finding, A102 was immediately replaced with Cascade's S I OOL. This change was made based on a recommendation made jointly by Meritech and Cascade. An SOP specifying the new biocide and quantity to be used was created on July 9. While BTI was definitely not complacent in its actions and believed that it was taking the proper action, the company clearly had a misunderstanding and there was a failure to get prior approval from the State. BTI now understands the specific requirements of the NPDES permit and recognizes that they were not in compliance. The plant chiller operator's recollection is that the chiller ran through the summer using the new biocide, and was then shut down. The chiller has not run since that time. Although a plan was not in place at that time for dechlorination of the discharge to outfall 003, the chiller operator did monitor chlorine during the early use of STOOL, which revealed that chlorine levels leveled out at or below .05 mg/liter, which is well below the facility's drinking water standard. No biocides, including the S I OOL, will be used by BTI during the Chiller/Cooling Tower operation until the biocides and their method of application are pre - approved by the State. Cascade or another firm will provide their recommendations for biocides and the method of dispersing any such biocides that could impact outfalls 001, 002 or 003, which will be presented to the State for formal approval before implementation (see action plan identified in response # 1 above). 3) Please discuss plans to address the following: a. Failure to visit the plant at the frequency required by the ORC Response: BTI has a service agreement with Meritech that provides that the Meritech ORC will visit the WWTP each weekday (excluding holidays) as required by NPDES Permit No. NC0001384. While BTI recognizes that it is ultimately responsible for compliance with the permit, the company of necessity must rely on Meritech for some of the information surrounding the issues raised in the NOV. We are informed by Meritech that Marc Nault, the ORC, does generally visit the WWTP daily and that David Merritt serves as the backup ORC. It is our understanding that while information was not recorded correctly in the records, specifically for December 10, 2014, either Mr. Nault or Mr. Merritt visited the WWTP each weekday during the referenced period except for the Christmas holiday. Although Meritech has suggested that weekday visits that are missed due to sickness or weather, etc. can be made up on a weekend day, BTI will emphasize to its contracted ORC company the need to have sufficient backups in place to ensure that an authorized person visits the WWTP as required. Ms. Sherri V. Knight March 27, 2015 Page 4 BTI has started and will commit to ongoing weekly visits to the WWTP by the plant engineer. This visit will coincide with one of the ORC's visits to the WWTP each week and will be documented. BTI is also working on a checklist that will identify the issues to be evaluated during the visits and assign responsibility for the various NPDES permit and maintenance requirements. The visit will ensure that BTI maintains eyes on the WWTP and is able to identify and address any concerns on a timely basis. This should help to ensure that the WWTP is operated and maintained as required by the permit and laws/regulations, but also provide the opportunity for real time repairs and maintenance that may be needed. BTI has also confirmed with Meritech that there are two certified ORCs within Meritech in addition to Mr. Nault, and that those individuals will be available as backup ORCs. BTI will ensure that any vendor that provides ORC services in the future has sufficient backup capability. b. Failure to property operate and maintain the plant Response: Communication appears to be a significant source of these concerns. BTI realizes now that it relied too heavily on its service provider to communicate about maintenance needs at the WWTP. Routine oversight by BTI has already been implemented. We are informed by Meritech that there has been a historic misunderstanding with BTI personnel regarding the water pressure to the WWTP. The NOV was BTI's first knowledge of this issue. To the extent that turning certain pumps on for the ORC's site visit can improve the operation of the WWTP, BTI commits to take this action and will coordinate with its contracted ORC to ensure that there is adequate communication on this issue. BTI management personnel inspected the WWTP following receipt of the NOV and now understand that things were in disarray. Although BTI understood that the ORC would inform BTI of needed maintenance, the company will be proactive about these issues and is already moving forward with several cleanup projects that should address multiple issues. A list of the action steps with the targeted completion date of each step, along with some before and after pictures, is shown on Attachment 1. The noted skimmer issues were attributed to a loose hose clamp, the lack of adequate cleaning of the skimmer by the ORC on a regular basis, and improper trash being flushed in the potable water system. The issue of improper disposal through restroom discharges was addressed by our plant superintendent with employees on March 151h & 16'h. The loose hose clamp was repaired on March 13, 2015. The weekly BTI visit and meeting with the ORC described above will help to ensure that all maintenance issues are identified and addressed in a timely fashion. In addition to the items listed on Attachment 1, some other specific steps have been taken since the inspection. The WWTP was seeded with activated sludge that was delivered from Jenkins Waste Management on February 19, 2015. A good mixed liquor and Ms. Sherri V. Knight March 27, 2015 Page 5 volatile suspended solids has been reestablished within the aeration basin. Also, as regular communication and meetings are established, BTI personnel can be more aware of when grass within the WWTP fenced area needs to be mowed and when weeds need to be pulled. If this work is done on a more consistent basis, it will improve the appearance of the WWTP and also prevent large clumps of grass from collecting around the WWTP or blowing into the basin. The contracted ORC has committed to maintain adequate amounts of appropriate chemicals at the WWTP and to inform the plant maintenance manager if supplies run "low" rather than waiting until supplies are "out." BTI's weekly inspections will also ensure maintenance of a proper supply level. The ORC will keep daily records of the amounts of the products used and will keep documentation of this information as well as other daily operational parameters available at the WWTP. Again, the weekly BTI meeting with the ORC will ensure that this process is followed and that required chemicals are maintained in adequate amounts on site. Finally, the contracted ORC has committed to better document communication with BTI personnel, either through notation of verbal communication or with copies of electronic communication, and BTI will insist on the creation and maintenance of this communication. Maintenance issues also will be addressed in the log book and completion of tasks will be noted. c. Failure to keep adequate, and accurate, records (calibrations, operations, PM, etc.) Response: BTI and its ORC commit to adequately and accurately keep all required records and to have these records available at the WWTP at all times. Although we understand from Meritech that the ORC believed that only certain records were requested by the inspector, regardless of what an inspector specifically mentions as needed for the inspection, those records will be maintained and available during an inspection. BTI will check all logs and other documentation during the weekly visit to ensure that proper records are created and maintained. d. Failure to monitor/sample as required Response: BTI has re-emphasized to its contracted ORC that the required samples must be taken and that the required monitoring must be conducted and documented. To assist in this effort, BTI is working to better clear the sampling and monitoring locations and has installed new signage (replacing existing, but worn signage) to make these locations clear. BTI understands that the ORC has been conducting the required sampling and monitoring regularly since the inspection and that the ORC will report and note "no discharge," but only when such notation is clearly appropriate. The unnamed tributary Ms. Sherri V. Knight March 27, 2015 Page 6 will continue to be monitored in the required locations on a weekly basis. The required sampling and monitoring will be confirmed in the weekly meetings discussed above. e. Lack of communication between the ORC and owner of the facility Response: Meritech has committed to communicate as needed using e-mail to the appropriate BTI personnel. Please see the discussion above of the weekly BTI visit and meeting with the ORC. This weekly meeting will enhance the communication efforts to which Meritech has committed. Appropriate logs will be maintained and all communications will be documented. Although BTI understood that BTI employees would be informed by the ORC when actions by BTI were needed, the company understands that its failure to be more proactive contributed to the lack of communication. The weekly visits have already been implemented and BTI will closely monitor its responsibilities. 4) Discuss how the above items (a-e) will be prevented from occurring again in the future. Response: Please see the individual responses to items (a-e). As you can see from the discussion above, BTI has assumed responsibility for its failure to more closely monitor the activity of its contracted ORC and to properly maintain the WWTP. BTI has taken immediate and affirmative action to bring the WWTP into compliance and will continue in these endeavors. The company has spent or committed to spend in excess of $15,000 to address the various maintenance and upkeep issues raised in the NOV and will continue to be diligent in bringing the WWTP into compliance. As Attachment 1 and other information in this letter indicate, BTI is working diligently to both achieve compliance and improve the appearance and maintenance of the WWTP. BTI requests that DENR take these actions into account in considering enforcement and that BTI be allowed to use its financial resources to achieve and maintain consistent compliance. I look forward to hearing from you. With best regards, I am Very truly yours, Smith Moore Leatherwood LLP Mona Cunningham O'Bryant cc: Michael R. Durham ATTACHMENT I BTI WWTP & Area — Proiect List 1. Outfalls: Clear outfall locations and install new signage at all three outfall locations — Complete 2. Mow, Trim and Tree Removal: a. Clean out weeds near and around waterway creek to outfalls and clean a clear pathway to access outfall 003 — Complete b. Mow and trim inside of WWTP - Complete c. Mow a pathway on the back side of the WWTP to access creek for testing creek water (keep area mowed) - Complete d. Cut up and remove trees around waste treatment plant and well #3 in woods down from elevated water tower — Ongoing — BTI has met with Matkins Landscaping to discuss this work 3. Load of gravel put down in road bed going to WWTP — Complete 4. WWTP upgrade appearance & functionality — to be complete by 3-31-15 a. Clean out WWTP building of all trash b. Install shelves inside building for properly storing items c. Paint WWTP area, including, fence, gates and all around WWTP d. Paint all metal around sump, hand rails and blower motor covers e. Paint building and door 5. Paint Elevated Water Tower near WWTP: a. Preferred Tank and Tower to give quote on painting of water tower and to do interior and exterior inspection of tank b. Contract signed 3-20-15 6. Repair/replace various equipment needed for proper operation of WWTP: a. Well #2 pump motor to be replaced — pump has been ordered/all other work complete b. Gate valve for well # 1 — valve has been ordered c. Repair of aerator - Complete 7. BTI Maintenance PMs - BTI started on 3-15-2015 for the month of March to train one additional employee to perform the maintenance/PM of the WWTP motor, blower pumps, etc. 8. Air washer drains impact on outfalls — BTI to insert dye tablets week of 3-23-15 to identify each of the 1-4 air washers' impact on each of the outfalls so as to aid Cascade's recommendations on the proper method to monitor and treat air washer flows 9. Create & Keep List of all chemicals used to treat all water — Complete Carter, Jenifer From: Marc Nault <marcwnault@yahoo.com> Sent: Tuesday, March 24, 2015 11:35 AM To: Knight, Sherri; Carter, Jenifer; Reid, Steve; Hudson, Gary Subject: Fw: Response to Section 3 and 4 listed on page 4 of 5. On Tuesday, March 24, 2015 10:51 AM, Marc Nault <marcwnault(cDyahoo.com> wrote: 3) a. Failure to visit the plant at the frequency required by the ORC ORC will develop better communications with backup ORC's and properly communicate with them when they are needed to backup ORC. If neither ORC or Backup ORC is not able to make a site visit, then proper explanation will be given in writing and annotated on the DMR. Also if needed, a site visit will be made on Sunday if there is an anticipation of a weekday needing to be filled in for that week where neither the ORC or backup ORC can make site visit on that anticipated day. Likewise if unforeseen circumstances occur where the plant visit is missed during a weekday, Saturday will be used as a makeup day for that week. b. Failure of to properly operate and maintain the plant Potable water pressure is being addressed at the wastewater treatment plant. it has recently been discovered that no water pressure is due towards a well pump being down. A plumber has been called to check out the well pump and electrical system for the well in question pertaining to water pressure. Good water pressure will be the most valuable keys to maintaining the appearance and quality of treatment at the waste water plant. Up to date March 24: it was found out with information from the engineer of Burlington technologies recently,the other wells have to be turned on by hand with water going to tower and with some of the water diverted with a valve to the wastewater treatment plant. Orc or backup Orc will call ahead of time before arrival to waste water treatment facility to have water turned on. If there is any problems with operating water system or wastewater plant the Orc now has direct contact with the engineer of Burlington technologies, and will share this phone number with both back up Orc's. Dog food will be kept in storage house at wastewater treatment plant and plant maintenance manager will be notified when chemicals or dog food is needed at wastewater facility via email. if a problem arises and no dog food is provided to the O, the O will purchase the dog food himself and this will be done with his own funds for reimbursement later. Daily records will be kept of the exact amounts of chlorine tablets, biomass tablets, soda ash and dog food that are used at wastewater facility daily. A proper Process Control Sheet, DMR, Calibration sheets will all be kept at said facility with amounts of all chemicals used and amounts of wasting, sludge depth, etc. Also a proper field sheet will be left at facility with all required field parameters prevalent for that day and week. also up to date March 24th: the one single diffuser in the aeration basin has been replaced and four additional stainless steel aeration diffusers that were totally inoperable were replaced also. Skimmer has has not been addressed up to date and client will be emailed. c.Failure to keep adequate, and accurate, records (calibrations, operations, PM, etc) As previouly discussed in part c., all proper field sheets with data etc, will all be posted by Orc with all field parameters for the day and week. He will adamantly demand that all logbooks from this point forward will be left at facility so that detailed comments or annotations can be made by ORC or backup ORC at any given point in time in reference to any concerns or operational issues dealing with waste water facility. d. failure to monitor / sample as required Wastewater treatment plant has been taken off long duration timers so as to create a consistent effluent flow. This will prevent surges and non discharges from occurring on a timed schedule. ORC has been taking samples at regular basis as of January this year, but also will continue to report no discharge when appropriate. Unnamed tributary has and will continually be monitored on a weekly basis. e. Lack of communication between Orc an owner of the facility Communications between the ORC and the facilities manager and engineer will be done via email and also a email will be sent to David Merritt @ Meritech Inc. so as to have a record of correspondence with all concerned. Sending emails directly to clients sometimes will have to be approved by the president of Meritech David Merritt. ORC and facility maintenance manager and have made a pledge to improve all communications involving operation of the waste water facility. Note: please excuse any typos this was all done on a telephone and some with voice recognition. MERITECH, INC. NVIR NMENTAL LABORATORIES A Division of Water Technology and Controls, Inc. March 2, 2015 Ms. Sherri V. Knight Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NC DENR In reply to: NOV-2015-PC-0030 Compliance evaluation Inspection: Burlington Technologies- Williamsburg Plant WWTP- Se7en Dear Ms Knight, I have received and reviewed the referenced NOV (dated February 25) for the inspection on January 7, 2015. We will work with Se7en to correct Points 1 &2. At this time we are gathering information so we may address point 3, a-e. Until we have addressed the issues of the letter in question with DWR, we will be closely monitoring the ORC and the facility to verify that we are on the right path to ensure these issues are resolved and will not resurface at future inspections. For the meantime, the facility will be visited once a week as well, by the backup operators, Patrick or David Merritt to be sure this is being done. We will ensure that Meritech's procedures for proper documentation and operation of wastewater facilities are being done according to DENR guidelines. Please note this is not a response to the NOV at Burlington Technologies WWTP, Merely to acknowledge the receipt of the NOV and the immediate course of action If you have any questions or need additional information, please do not hesitate to call. Regards, David Merritt Vice President Meritech, Inc. FFPV F *_ WA NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Donald R. van der Vaart Governor Secretary February 25, 2015 CERTIFIED MAIL #7011 1570 00018546 0541 RETURN RECEIPT REQUESTED Mr. Michael Durham, CEO Burlington Technologies — Williamsburg Plant 5928 NC Highway 87 North Gibsonville, North Carolina 27249 SUBJECT: Notice of Violation and Recommendation for Enforcement NOV-2015-PC-0030 — Compliance Evaluation Inspection NPDES Permit No. NC0001384 Burlington Technologies — Williamsburg Plant WWTP (aka `se7en, LLC') Caswell County Dear Mr. Durham: Jenifer Carter of this office performed a Compliance Evaluation Inspection of the wastewater treatment facility located at Burlington Industries' weaving and dying facility in Caswell County on Wednesday, January 7, 2015. Marc Nault, Operator in Responsible Charge (ORC), was present for the inspection. The following is a summary of the findings from the inspection: Record Keeping Operations, maintenance and visitation logs were requested during the inspection. The following was provided: ➢ A spiral maintenance to bg ook, stored in a shed at the plant. Mr. Nault stated that there is an agreement with Joey Jordon (of se7en) to perform maintenance at the plant. The book showed what appeared to be monthly preventative maintenance records, with the last entry noted on June 14, 2014, almost 7 months prior to the inspection. (photos 1 and 2) ➢ A bound visitation logbook. December 2014 and January 2015 records had entries for each day. Dates, time of arrival on site, and the notation 'OP/CK' each day, were the only items written in the logbook. The ORCs initials and duration of visit were not noted anywhere, though duration is noted on the corresponding Discharge Monitoring Report (DMRs). Mr. Nault clarified that he, and not a back-up operator, had visited the site each day as noted in December, and January, having only taken time off for the Christmas Holiday. (photos 3, 4 & 5) Our database shows that Mr. Nault attended a continuing education class titled 'Customer Service for Water & Wastewater Utilities on December 10, 2014 at 8:30 a.m., in Hickory, NC. Mr. Nault's presence at the class, which ended at 4:00 p.m, was verified and witnessed by NC DENR staff. The visitation log and the December DMR both indicate that Mr. Nault visited se7en at 12:10 p.m. on December 10, 2015, while he was in class. (screen capture 1) 450 W Hanes Mill Rd., Suite 300, Winston-Salem, NC 27105 Phone: 336-776-98001 Internet: www.ncdenr.gov An Equal Opportunity 1 Affirmative Action Employer —Made in part by recycled paper Michael Durham Williamsburg Plant — se7en February 25, 2015 Page 2 of 5 ➢ `Meritech Operations Log' sheet. The undated and unsigned sheet had two days' worth of TRC, Temperature, Time -in and Time-out data that were recorded. (photo 6) Effluent Sampling ➢ Outfall 001: Mr. Nault said he has not been sampling outfall 001 because there is `usually just a trickle'. There was more than a trickle during the inspection, which Mr. Nault said was unusual and possibly due to the time of day. 1. He said he didn't normally visit during that time of day, but Discharge Monitoring Reports (DMRs) indicate otherwise. 2. Even if there is only a `trickle', Mr. Nault agreed that it takes very little volume to measure field parameters, which is the only requirement on most days. On days when other samples need to be pulled, it may take several more minutes to collect a large enough sample, but an attempt should be made. Mr. Nault agreed and said he would begin sampling `next week'. 3. It was suggested during the inspection that Mr. Nault pull samples since there was a discharge, but he said he didn't have what he needed to sample with him. ➢ Outfall 002: Mr. Nault said he had not been sampling 002 because he didn't believe it to be a representative discharge since it is 'just creek water', even though: 1. The permit defines the discharge as being made up partly of storm water, and 2. Mr. Nault has been placing dechlorination tablets to combat an unknown source of chlorine at the discharge, which suggests that he understands the discharge to be more than creek water. Last year's inspection report, dated January 15, 2014 required that se7en investigate the source of chlorine at outfall 002 prior to the next inspection. This has not been done. Mr. Nault stated the placement of dechlorination tablets at the outfall to neutralize the chlorine is not sufficient since they get washed away during rain events. He said he had not notified the owner in writing of the need for a modification. ➢ Outfall 003: Last year's inspection revealed the unauthorized use of biocides and other chemicals in the flow stream leading to this discharge. Biocide worksheets were submitted to our Aquatic Toxicity Unit, and the biocide failed the test. Joey Jordan, of se7en, stated on 4/29/2014 that se7en would consider a chlorine/dechlorination system, 'nothing physical, just adding the chemicals' to the discharge stream. He was told to submit plans in writing prior to utilizing any new chemicals. This has not been done yet. Upstream/Downstream Sampling There is data on the DMRs, but no bench sheets were provided to verify the validity, meter calibrations, etc. as recommended in last year's inspection report. There is data recorded on the December DMR, signed by Mr. Nault, at times and a day (12:15 p.m. upstream and 12:20 p.m. downstream on 12/10/2014) when Mr. Nault was known to be in a class. Aeration Basin This plant is chronically underfed and therefore lacking the ideal nutrient load for the most effective treatment. As is common practice, Mr. Nault `feeds' the system dog food periodically to address the lack of nutrients, though he could not recall the last time he put dog food in the plant, and said he forgot to notate the last time he did so in his logbook when asked to provide record of it. owmam iamsburg Plant — se7en February 25, 2015 Page 3 of 5 Secondary Clarifier ➢ The majority of the clarifier was covered with solids, due in part to a blocked return. It is not uncommon to battle floating solids in underfed plants, though Mr. Nault could not recall the last time he measured sludge in the clarifier, stating that it was 'a long time ago', but he was confident that there was `nothing in there'. ➢ The weir trough was covered in duckweed. Mr. Nault said it wasn't that bad `the last time he was there', at which time he was reminded that he had supposedly been there the day before. He then said there was not enough water pressure to be able to clean out the trough effectively (with a hose). With the dimensions of the trough being approximately 10 feet x 1 foot, at ground level, it should be easy to remove and/or control the duckweed by hand or with a rake, especially if done regularly. Chlorination and Dechlorination There were no chlorine or dechlorination tablets in the chlorinator or dechlorinator. Mr. Nault explained that they had `just run out'. Accordingly, the January 7, 2015 inspection and file reviews reveal the ORC and/or facility to be in violation of the following North Carolina Administrative Code and NPDES permit (NC0001384) conditions: 15A.NCAC 08G .0204 RESPONSIBILITIES OF AN OPERATOR INRESPONSIBL'E CHARGE (ORC) An Operator in Responsible Charge (ORC) of a water pollution control system must: (2) visit the system as often as is necessary to insure the proper operation of the system but in no case less frequently than specified in the following schedule, unless otherwise specified in permit: (b) biological grade II, III and IV systems...... five days per week, excluding holidays; (3) operate and maintain the system efficiently and attempt to insure the compliance of the system with any permit(s) issued for the system as well as any other applicable local, state, and federal environmental permitting and regulatory requirements. (4) certify, by signature, as to the validity of all monitoring and reporting information performed on the system as prescribed in any permit issue for the system and provide the owner a copy; (5) document the operation, maintenance, and all visitation of the system in a daily log that must be maintained at the system. (7) notes the owner, in writing, of the need for any system repairs and modifications that may be necessary to insure the compliance of the system with all local, state, and federal environmental permitting and regulatory requirements. NPDES Permit Conditions Part I Section A(1), AQ & A(3). Effluent Limitations and Monitoring Requirements a. During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall... ... Such discharges shall be limited and monitored by the Permittee as specified... Michael Durham Williamsburg Plant — se7en February 25, 2015 Page 4 of 5 Part II Section C-2. Proper Operations and Maintenance The Permittee shall at all times properly operate and maintain all facilities and system of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit...... Properly and officially designated operators are fully responsible for all proper operation and maintenance of the facility, and all documentation required thereof, whether acting as a contract operator [subcontractor] or a member of the Permittee's staff. Part II Section D Monitoring and Records 1. Representative Sampling Samples collected and measurements taken, as required herein, shall be representative of the permitted discharge. Samples collected at a frequency less than daily shall be taken on a day and time that is representative of the discharge for the period the sample represents... [40 CFR 122.410)]. 6. Records Retention ... the Permittee shall retain records of all monitoring information, including: all calibration and maintenance records... for a period of at least 3 years from the date of the sample, measurement, report or application. Part II Section E Reporting Requirements 11. Penalties for Falsification of Reports The CSA provides that any person who knowingly makes any false statement, representation, or certification in any record or other document submitted or required to be maintained under this permit, including monitoring reports or reports of compliance or noncompliance shall, upon conviction, be punished by a fine of not more than $25, 000 per violation, or by imprisonment for not more than two years per violation, or by both [40 CFR 122.41]. Please respond to this letter in writing within 30 days of receipt. Your response should be sent to my attention at the letterhead address, and it should at least address the following items: 1) Please submit Plans for approval of a dechlorination system to be installed at or along the discharge pipe to outfall 002. 2) If any biocides and/or chemicals are to be used in the Cooling Tower that will be present in the discharge at outfall 003, prior approval must be obtained from the Division. 3) Please discuss plans to address the following: a. Failure to visit the plant at the frequency required by the ORC b. Failure of to properly operate and maintain the plant c. Failure to keep adequate, and accurate, records (calibrations, operations, PM, etc) d. Failure to monitor/ sample as required e. Lack of communication between the ORC and owner of the facility 4) Discuss how the above items (a-e) will be prevented from occurring again in the future. continued... rha,n Fpi,arnsburg Plant — se7en ary 25, 2015 Page 5 of 5 Thank you for your attention to this matter. Please understand the severity of the violations detailed above, which put surface waters and the public health at risk. This office requires that these violations be abated immediately. Please note that these violations and any future violations are subject to civil penalty assessments of up to $25,000.00 per day, per violation. Your response to this correspondence will be considered in this process. Should you have any questions regarding this matter, please contact Jenifer Carter at (336) 776-9691. Sincerely, 4'Y-, /�—p Sherri V. Knight, Assistant Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NC DENR attachment: inspection report and photos cc: DWR Central Files WSRO Files Marc W. Nault (4490 Crews Ln; Walkertown, NC 27051) Meritech, Inc. (Attn: David Merritt; P.O. Box 27; Reidsville, NC 27323) 7�� 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 2 15 1 3 I NC0001384 I11 12 15/01/07 17 18 Li 19 L Gj 201I 21111 1 1� 1 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 131 QA Reserved 671 70 71 JI�, � 72 L N J 731 I 174 751 I I I I I I I80 LJ LJ I I 1 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 permit Number) 08:55AM 15/01/07 13/11/01 Williamsburg Plant 5928 Hwy 87 N Exit Time/Date Permit Expiration Date Gibsonville NC 27249 11:29AM 15/01/07 16/05/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Marc W Naultt/336-342-4748 / Name, Address of Responsible Officialfritle/Phone and Fax Number Robert Fariole,PO Box 691 Burlington NC 272150691/Plant Engineer/336-584-1166/ 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 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 Jenife er WSRO WQ//336-771-5000/ / D/S OF Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date -K. )V4 �'/a s/�s EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) 1 31 NC0001384 I11 12 15/01/07 17 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The following comments are in addition to what is detailed throughout the following pages of this report: RECORD KEEPING: A maintenance log book was provided, having been stored in the shed at the plant. When Mr. Nault handed it to me, he said that Joey Jordon performs maintenance at the plant. The book showed what appeared to be monthly preventative maintenance records, with the last entry noted on June 14, 2014, over 6 months prior to the inspection. No other maintenance records were provided (i.e. addition of dog food, QA/QC, meter calibration records, clearing of weir trough, addition of chlor/dechlor tablets, etc.) A bound visitation log was provided for review. December 2014 and January 2015 records appeared up to date. Dates and 'time arrived on site' plus 'OP/CK' next to each day were the only items noted. The ORCs initials and duration of visit were not notated anywhere. Mr. Nault was asked to clarify that he himself had visited the site on each day as noted in December, and not a back-up ORC. He said that that was correct, that the only days he got off were for the Christmas holiday. Our database shows that Mr. Nault attended a continuing education class titled'Customer Service for Water & Wastewater Utilities. The class began at 8:30 and was over at 4:00 on December 10, 2014. Mr. Nault's presence at the class was verified and witnessed by DENR staff. The visitation log and the DMR indicate that Mr. Nault visited se7en during those hours on that day. The DMR also has upstream and downstream field parameter recordings for that day. An undated and unsigned Meritech log sheet was observed in the shed with two days of TRC, Temperature, Time -in and Time-out data for two days (month unknown... if for current month, missing at least two days' worth of entries.). EFFLUENT SAMPLING: Mr. Nault says he has not been sampling 001 because there is always 'just a trickle' at the discharge pipe. This is unacceptable, as it doesn't require much volume to measure field parameters, which is the only requirement on most days. On days when other samples need to be pulled, it may take several more minutes to collect a sample when there is 'just a trickle', but that is not an excuse for not pulling samples at all. I suggested that Mr. Nault pull samples during the inspection (which was scheduled to coincide with his regular daily visit), but he said he hadn't brought what he needed to sample. Mr. Nault said he had not been sampling 002 because he didn't believe it to be a representative discharge since it is'just creek water', even though 1.) the permit clearly defines the discharge as being partly made up of storm water and 2.) Mr. Nault has been placing dechlorination tablets to combat an 'unknown' source of chlorine at the discharge. Last year's inspection reported required that se7en investigate the source of chlorine at 002 prior to this inspection. This has not been done. Mr. Nault stated that the tablets get washed away during high flow events, SO: PLEASE SUBMIT PLANS FOR PRE -APPROVAL OF A FORMAL DECHLORINATION SYSTEM TO BE INSTALLED AT DISCHARGE 002. 003: Last year's inspection revealed the unauthorized use of a biocide and several other chemicals in the flow stream leading to this discharge point (003). Biocide worksheets were submitted to our Aquatic Toxicity Unit, and at least the biocide failed the test. Mr. Joey Jordan, of se7en, stated on 4/29/2014 that se7en would consider a chlorine/dechlorination system, 'nothing physical, just adding Page# OFFIr Permit: NC0001384 Owner - Facility: Williamsburg Plant Inspection Date: 01/07/2015 Inspection Type: compliance Evaluation the chemicals to the system'. He was told to submit plans in writing prior to utilizing any new chemicals. THERE CAN BE NO DISCHARGE OF COOLING TOWER BLOWDOWN UNTIL A PRE -APPROVED TREATMENT METHOD IS IN PLACE. SECONDARY CLARIFIER The clarifier was approximately 80% covered with solids, due in part to a blocked return. It is not uncommon to battle floating solids in underfed plants such as this one, though Mr. Nault could not recall the last time he measured sludge in the clarifier, stating that it was 'a long time ago' but that 'there is nothing in there'. The weir trough was covered in duckweed. Mr. Nault said it'wasn't that bad' the last time he was there which, I reminded him, was supposedly the day before. He said there was not enough water pressure to be able to clean out the trough effectively. With the dimensions of the trough being approximately 10 feet x 1 foot at ground level, it should be easy to remove the duckweed by hand, especially if done regularly. Page# 3 "NRM Permit NC0001384 Owner - Facility: Williamsburg Plant Inspection Date: 01/07/2015 Inspection Type: Compliance Evaluation Permit Yes No NA NE' (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ M ❑ 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: 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? ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ 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 ❑ ❑ M ❑ 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 ❑ ❑ ❑ 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? M ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: see comments in Summary Section Effluent Samialina Yes No NA NE Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected below all treatment units? ❑ ❑ 0 ❑ Page# 4 FFPV Permit: NC0001384 Owner -Facility: V\AlliamsburgPlant Inspection Date: 01/07/2015 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE 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)? Comment: see comments in summary section Upstream / Downstream Sampling Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ANIVENIVE Yes No NA NE ■ ❑ ❑ ❑ Comment: There is data on DMRs, but no bench sheets to verify the validity, as suggested in last year's inspection report. Flow Measurement - Effluent # 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 limit only at 001. Flow estimated using a ruler in the effluent trough. Operations & Maintenance 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: - Bar Screens 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? Yes No NA NE Yes No NA NE ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ Yes No NA NE Page# 5 Permit NC0001384 Inspection Date: 01/07/2015 Owner -Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE Comment: There was some trash (sanitary_pad) in the secondary clarifier Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? E ❑ ❑ ❑ Are surface aerators and mixers operational? 0 ❑ ❑ ❑ 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/1) ❑ ❑ ❑ Comment: Sludge appeared young, as is typical for this plant that is chronically underfed. Mr. Nault could not recall the last time he put dog food in the plant, and said he thinks he forgot to notate the last time he did put dog food in the plant in his maintenance log. 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? N ❑ ❑ ❑ Is the site free of weir blockage? ❑ 0 ❑ ❑ Is the site free of evidence of short-circuiting? ❑ 0 ❑ ❑ Is scum removal adequate? ❑ E ❑ ❑ Is the site free of excessive floating sludge? ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ 0 ❑ Is the return rate acceptable (low turbulence)? E ❑ ❑ ❑ Is the overflow clear of excessive solidstpin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) ❑ ❑ ❑ Comment: see comments in summary section Aerobic Digester Yes No NA NE Is the capacity adequate? ❑ ❑ ❑ Is the mixing adequate? ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ Page# 6 NPOV Permit NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 01/07/2015 Inspection Type: Compliance Evaluation Aerobic Digester Yes No NA NE # Is the odor acceptable? M ❑ ❑ ❑ # Is tankage available for properly waste sludge? M ❑ ❑ ❑ Comment: Due to the plant being fed, the sludge is thin, but very old. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? 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? Comment: There were no tablets in the chlorinator. Mr. Nault said the had just run out'. De -chlorination Type of system ? 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? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ 4 ❑ M ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ ❑ Yes No NA NE Tablet ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: There were no tablets in the dechlorinator. Mr. Nault said they had 'lust run out', like the chlorine tablets. Are tablet de -chlorinators operational? M ❑ ❑ ❑ Number of tubes in use? 2 Comment: 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? ❑ ❑ M ❑ Comment: Page# 7 Photo 1 Photo 2 1 � v � 'r 4 v�, f '� 1 � ���. ,' d' �, ,. f € i€ F ����`�_Slx �� � F� ��^� �k `� r x.�.t �c _ _ _ ti � ri _ _ _ t 5t i _ Photo A&WA NCDENR North Carolina Department of Environment and Natural Resources Pat McCrory Governor August 15, 2015 Michael Durham, CEO Burlington Technologies 5928 Hwy 87 N Gibsonville, NC 27249 Subject: NOTICE OF VIOLATION NOV-2015-LV-0519 Permit No. NC0001384 Williamsburg Plant Caswell County Dear Mr. Durham, CEO: Donald R. van der Vaart Secretary A review of Williamsburg Plant's monitoring report for April 2015 showed the following violation: Parameter Date Limit Value Reported Value Limit Type Coliform, Fecal MF, M-FC Broth,44.5C 4/10/2015 400.000 #/100ml 600.000 #/100ml Daily Maximum Exceeded Remedial actions, if not already implemented, should be taken to correct the above noncompliance problem. Please be aware that violations of your NPDES permit could result in enforcement action by the Division of Water Resources for this and any additional violations of State law. If you should have any questions, please do not hesitate to contact Jenifer Carter at (336) 776-9691. cc: DWR — Central Files WSRO Files Sincerely, W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NC DENR 450 W. Hanes Mill Rd, Suite 300; Winston-Salem, NC 27105 Phone: 336-776-98001 Internet: www.ncdenr.gov An Equal Opportunity1 Affirmative Action Employer— Made in part by recycled paper PV w jq% NCDENR North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Regional Operations Pat McCrory Thomas A. Reeder Governor Director January 15, 2014 Mr. Michael Durham, CEO Burlington Technologies — Williamsburg Plant 5928 NC Highway 87 North Gibsonville, North Carolina 27249 SUBJECT: Compliance Evaluation Inspection NPDES Permit No. NC0001384 Burlington Technologies — Williamsburg Plant WWTP (aka `se7en; LLC') Caswell County Dear Mr. Durham: John E. Skvarla, III Secretary Jenifer Carter of this office performed a Compliance Evaluation Inspection of the wastewater treatment, air washer and HVAC cooling tower discharges located at Burlington Industries' weaving and dying facility in Caswell County January 14, 2014. Marc Nault, Operator in Responsible Charge (ORC), was present for the inspection. This type of inspection consists of two basic parts: a review of facility files and an on -site inspection of the treatment plant, air washer, cooling tower and related discharges. File Review • Lab data and ORC visitation records correctly correlated with information submitted on the monthly Discharge Monitoring Reports (DMRs). It was recommended that field sheets should_ be maintained consistently for field parameters in order to back up hand-written data on the DMRs. Wastewater Treatment Plant (Domestic) • Waste in the aeration basin appeared on the thin/young side, as in previous inspections. Mr. Nault says the system is chronically underfed, and uses dog food to combat the problems associated with an underfed system. • Unusually cold temperatures caused some ice build-up in the secondary clarifier and aerobic digester, which appeared to be impeding the sludge return to some degree. • The effluent was clear during the inspection, with no impacts to surface waters observed. Outfall 002 (air washer blowdown and stormwater) • Mr. Nault has had to start placing dechlorination tablets on the concrete pad at the end of the discharge pipe in order to neutralize chlorine being detected. Plant Manager, Joey Jordan, claimed after the inspection that he does not know the source of chlorine. The plant utilizes on -site well water, which he said is not chlorinated. Please investigate and identify the source of chlorine before next year's inspection. • The discharge during the visit appeared clear, with no noticeable odor. North Carolina Division of Water Resources, Winston-Salem Regional Office Location: 585 Waughtown Street, Winston-Salem, NC 27107 Phone: (336) 771-50001 Fax: (336) 77146301 Customer Service: 1-877-623-6748 Internet: hftp:/twww.ncwater.org An Equal Opportunity 1 Affirmative Action Employer continued on reverse... NorthCarolina Naturally dl 4 Outfall 003 (AC/HVAC cooling tower condensate/blowdown) • This system is utilized during warmer months, and was not discharging during the inspection. "IN • It was discovered during the inspection that 6 (six) different chemicals are being added to the system to prevent corrosion, rust, mold, etc. Part I A.(3.) of the permit requires the permittee to obtain authorization from the Division prior to utilizing biocides/additives, which was not done. Mr. Jordan was provided with a biocide/chemical additive worksheet to fill out for each chemical. Please submit these forms to the Divisions Aquatic Toxicity Unit by February 17, 2014, to the address provided on the form. Your cooperation in maintaining compliance with your NPDES permit to discharge is appreciated. It is imperative that plant personnel coordinate their efforts with the ORC in order for him to properly monitor and maintain waste treatment facilities and plant discharges as he has been hired to do. Please refer to the attached report for further details from the inspection. If you have any questions concerning this report, please contact Ms. Carter at (336) 771-4957. Sincerely, W. Corey Basinger Regional Supervisor Water Quality Regional Operations Section Division of Water Resources cc: DWR Central Files DWR Regional Office Files Joey Jordan (same address) United States Environmental Protection Agency Form Approved. Washington, D.C. 20460 EPA 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 INI 2 5I 31 NC0001384 111 121 14/01/09 117 181 C I 191 c I 201!_ I != Remarks 211111IIII IIII11111111 IIIIIIIIIIIIIIII IIIIIII11116 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA — ---------- -- Reserved----------------- 671 169 70) I 71 LI 721 73 74 751 I I I I I 1180 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 permit Number) Williamsburg Plant 01:40 PM 14/01/09 13/11/01 Exit Time/Date Permit Expiration Date 5928 Hwy 87 N Gibsonville NC 27249 02:45 PM 14/01/09 16/05/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Marc W Nault//336-341-8971 / Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Fariole,PO Box 691 Burlington NC 272150691/Plant Engineer/336-584-1166/ 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 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 Jenifer Carter WSRO WQ//336-771-5000/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date TKO.OR,- (`c.1�^ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 "IN NPDES yr/mo/day Inspection Type (cont.) 1 3I NC0001384 I11 12) 14/01/09 17 18Id Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mr. Nault said the package plant (001) chronically underloaded. He adds dog food to the system. The water in the AB did appear thin/young, as in the last inspection. Mr. Nault has started adding dechlorination tablets at outfall 002 since the last inspection, but has been unable to determine the source of chlorine. Plant staff (Joey Jordan) not sure of the source either and claims that the well water is not chlorinated. The inability to identify the source of chlorine by plant staff is perplexing. Please investigate and identify the source of chlorine (and anything else being added unkowingly) before next year's inspection. During the insepection, it was discovered that chemicals are being added to the AC/HVAC Cooling Tower to prevent corrosion, rust, etc. This system discharges to outfall 003 during the warmer months. The permit requires that the Division be notified PRIOR to the use of any such chemicals. Biocide/chemical additive worksheets were provided to Joey Jordan after the inspection. Please make sure one is filled out for each of the six chemicals being added and return them to the address provided on the form by February 17, 2014. Page # 2 Permit: NC0001384 Owner - Facility: Williamsburg Plant Inspection Date: 01/09/2014 Inspection Type: 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? ■ n n ❑ Is the inspector granted access to all areas for inspection? MOD 0 Comment: Discharge to outfall consists of chemically treated condensate/blowdown water from an AC/HVAC Cooling Tower combination unit during warmer months. Use of the chemicals being added was not pre -approved by the Division as required in the permit. 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)? ■ 00 n Are analytical results consistent with data reported on DMRs? ■ 013 n 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? ■ n n n 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? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? ■ n n n 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? ■ n n ❑ Facility has copy of previous year's Annual Report on file for review? n n n ■ Page # 3 Permit: NC0001384 Inspection Date: 01/09/2014 Owner - Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: Field parameter data sometimes recorded on field data sheets and on DMR, sometimes only on the DMR. Regular use of field data sheets is recommended in order to provide a means to back up hand written data on the DMR. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? n n ■ n Is sample collected below all treatment units? ■ n n n Is proper volume collected? ■ n n n Is the tubing clean? n n ■ n # 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)? ■ n n n Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? n■nn nn■n ❑❑■n (If units are separated) Does the chart recorder match the flow meter? n n ■ n Comment: Weekly flow is estimated using a ruler at the weir in the effluent trough. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ n n n Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n ❑ n Judge, and other that are applicable? Comment: Mr. Nault says he uses the sludge judge to measure sludge levels. Bar Screens Yes No NA NE Type of bar screen a.Manual ■ b.Mechanical n Are the bars adequately screening debris? ■ n n n Is the screen free of excessive debris? ■ n f=1 0 "IN Page # 4 Permit: NC0001384 Owner - Facility: Williamsburg Plant Inspection Date: 01/09/2014 Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE' Is disposal of screening in compliance? ■ ❑ ❑ ❑ Is the unit in good condition? ■ ❑ ❑ ❑ Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? ■ ❑ ❑ ❑ Are surface aerators and mixers operational? ■ ❑ ❑ ❑ Are the diffusers operational? ■ ❑ n n Is the foam the proper color for the treatment process? ■ ❑ n ❑ 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/1) ❑ ❑ ❑ ■ Comment: Very thin/ young sludge. Mr. Nault said the system is generally underfed, and that he overwasted by accident recently. He has been using dog food to feed the system. 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? ■ n ❑ ❑ Is the site free of excessive floating sludge? ■ n ❑ ❑ Is the drive unit operational? ❑ ❑ ■ ❑ Is the return rate acceptable (low turbulence)? ■ n n n Is the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'% of the sidewall depth) ■ ❑ ❑ ❑ Comment: Some ice build-up in the clarifier due to recent cold temperature. Aerobic Digester Yes No NA NE Page # 5 "NN Permit: NC0001384 Owner - Facility: Williamsburg Plant Inspection Date: 01/09/2014 Inspection Type: Compliance Evaluation Aerobic Digester Yes No NA NE Is the capacity adequate? ■ ❑ ❑ ❑ Is the mixing adequate? n ■ o o Is the site free of excessive foaming in the tank? ■ ❑ ❑ ❑ # Is the odor acceptable? ■ ❑ ❑ ❑ # Is tankage available for properly waste sludge? ■ ❑ ❑ ❑ Comment: Ice formed on the digester appeared to be impeding the sludge return pipe to some degree. The digester was not being aerated during the inspection. Mr. Nault has never had sludge removed from the digester. Since the system is chronically underloaded, sludge levels remain lower. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? ■ ❑ ❑ ❑ Are the tablets the proper size and type? ■ n n n Number of tubes in use? 4 Is the level of chlorine residual acceptable? ■ n n n Is the contact chamber free of growth, or sludge buildup? ❑ ■ ❑ ❑ Is there chlorine residual prior to de -chlorination? ■ ❑ n ❑ Comment: Mr. Nault said there was —6 inches in the contact chamber, though none of it appeared to be leaving the contact chamber. Mr. Nault had to start adding dechlorination tablets at outfall 2, though Joey Jordan (industry staff) claims to not know the source of chlorine. The industry uses well water, which Mr. Jordan claims is not chlorinated. There is no good reason why the source should not be able to be identified. Investigate and identify the source of chlorine before the next inspection. De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ n ■ ❑ Is storage appropriate for cylinders? ❑ ❑ ■ ❑ # Is de -chlorination substance stored away from chlorine containers? ■ n n n Are the tablets the proper size and type? ■ n n n Comment: At outfall 002, chlorine tablets are placed on the concrete pad at the end of the discharge pipe. While not an ideal treatment system, it is effective at neutralizing the chlorine being discharged. Page # 6 Permit: NC0001384 Inspection Date: 01/09/2014 Owner - Facility: Williamsburg Plant Inspection Type: Compliance Evaluation De -chlorination Are tablet de -chlorinators operational? Number of tubes in use? Comment: Effluent Pipe 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: Yes No NA NE ■❑❑0 ■000 ■000 Page # 7 Nco North Carolina Department of Environment and Natural Resources Division of Water Resources Water Quality Programs Pat McCrory Thomas A. Reeder John E. Skvarla, III Governor Director Secretary August 21, 2013 Mr. Earl Wrenn Plant Engineering Williamsburg Plant 5926 Highway 87 North Gibsonville, North Carolina 27249 Subject: Draft Renewal of Permit No. NC0001384 Williamsburg Plant Caswell County Class II WWTP Dear Mr. Wrenn: Enclosed with this letter is a copy of the draft renewal permit for your facility. Please review the draft carefully to understand the conditions, measurement units, and requirements. This draft permit has the following changes from your current permit: 1. The Owner's name will be changed to Burlington Technologies - Williamsburg Plant, from Tietec Interiors. 2. On the Supplement to Permit Cover Page, tablet dechlorination is added to the facility description for Outfall 001. Equipment listing for Outfall 002 has been updated to delete all unused equipment, eliminating air compressors, cooling towers, boilers and water softeners. Outfall 002 now consists of air washer blowdown and stormwater. 3. On page A.(1.) for Outfall 001: • Total Suspended Residue (TSR) is changed to Total Suspended Solids (TSS). • The TRC footnote is updated in accordance with current permitting strategy, which states that analytical values reported as less than 50 µg/ L are considered to be in compliance with the permit requirements. • pH monitoring and limits have been moved up into the table, and the footnote removed. 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 Fax: 919-807-6489 Internet:: www.ncwaterauality.org An Equal OpportunityMrma6ve Action Employer Addressee Date Page 2 of 2 4. On pages A.(2.) and A.(3.) for Outfalls 002 and 003: • The list of equipment and processes discharging to Outfall 002 has been revised in accordance with the current process arrangement, eliminating air compressors, cooling towers, boilers and water softeners, leaving air washer blowdown and stormwater only. • Instream monitoring for temperature for Outfall 002 has been removed because of process changes. • The TRC footnote has been updated to the current permitting strategy. • pH monitoring and limits have been moved up into the table, and the footnote removed. • References to "Division of Water Quality" have been changed to "Division of Water Resources" in accordance with recent reorganization within DENR. 5. The Permit Map is updated to show actual discharge locations. Concurrent with this notification, the Division is publishing a notice in the newspaper having circulation in the general Caswell County area, soliciting public comments on this permit draft. Please provide any comments you may have regarding this draft to DENR — DWR, NPDES Program no later than 30 days after receiving this draft permit. Following the 30-day public comment period, the Division will review all pertinent comments and take appropriate action prior to issuing a final permit. If you have questions concerning the draft for your facility, please call me at (919) 807-6404 or by email al James.McKay@ncdenr.gov. If no adverse comments are received from the public or from you, this permit will likely be issued in October, with an effective date of December 1, 2013, expiring on May 31, 2016. Sincerely, Jim McKay Complex NPDES Permitting Attachments: NC0001384 Draft Renewal CC: Winston-Salem Regional Office/ Attn: Corey Basinger - via email Winston-Salem Regional Office, PWS / Attn: Lisa Edwards with application and Signoff Sheet NPDES File Steve Reid - via email 11 Permit NC0001384 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER RESOURCES 17;7-11-N8»l.1ul0� TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Burlington Technologies - Williamsburg Plant is hereby authorized to discharge wastewater from a facility located at the Burlington Technologies - Williamsburg Plant 5928 Highway 87 North Gibsonville Caswell County to receiving waters designated as unnamed tributary to Buttermilk Creek and unnamed tributary to Grays Branch in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other applicable conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective. This permit and authorization to discharge shall expire at midnight on May 31, 2016. Signed this day. DRAFT Thomas A. Reeder, Director Division of Water Resources By Authority of the Environmental Management Commission Permit NC0001384 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Burlington Technologies - Williamsburg Plant is hereby authorized to: 1. Continue to discharge wastewater from Outfalls 001, 002, and 003. The discharge of treated domestic wastewater occurs from Outfall 001 to UT to Buttermilk Creek and requires operation of an existing 0.025 MGD package treatment facility consisting of a bar screen, aeration basin, integral sludge digester, clarifier, tablet chlorination, contact chamber, tablet dechlorination, step aeration and sludge thickener/digester. Wastewater discharged from Outfall 002 to UT to Buttermilk Creek consists of air washer blowdown and stormwater. The discharge from Outfall 003 to UT to Grays Branch consists of cooling tower blowdown. All Outfalls discharge from facilities located at Burlington Technologies - Williamsburg Plant, 5928 Hwy 87 North, Gibsonville, Caswell County. 2. Discharge from said treatment works at the location specified on the attached map into an unnamed tributary to Buttermilk Creek and into an unnamed tributary to Grays Branch, which are both classified WSII-NSW, HQW waters in the Cape Fear River Basin. Page 2 of 6 Permit NC0001384 PART A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS a. During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 001 — TREATED DOMESTIC WASTEWATER. Such discharges shall be limited and monitored by the Permittee as specified below: Footnotes: l . Sample Locations: Upstream — Upstream 50 feet from outfall, Downstream — Downstream 50 feet from outfall. 2. Limit and monitoring apply only if chlorine or chlorine derivatives are used for disinfection. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L. 3. The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/ L. b. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 3 of 6 Permit NC0001384 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS a. During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 002 — AIR WASHER BLOWDOWN AND STORMWATER. Such discharges shall be limited and monitored by the Permittee as specified below: Footnotes: 1. Limit and monitoring apply only if chlorine or chlorine derivatives are used for disinfection. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L. b. There shall be no Chromium, Zinc, or Copper added to the air washer water except as pre -approved additives to biocidal compounds. c. The permittee shall obtain authorization from the Division of Water Resources prior to utilizing any biocide in the air washer water. d.. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 4 of 6 AA Permit N00001384 A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS a. During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 003 — COOLING TOWER BLOWDOWN. Such discharges shall be limited and monitored by the Permittee as specified below: Footnotes: 1. Limit and monitoring apply only if chlorine or chlorine derivatives are used for disinfection. The Division shall consider all effluent TRC values reported below 50 µg/L to be in compliance with the permit. However, the Permittee shall record and submit all values reported by a North Carolina certified laboratory (including field certified), even if these values fall below 50 µg/L. b. There shall be no Chromium, Zinc, or Copper added to the cooling water except as pre -approved additives to biocidal compounds. c. The permittee shall obtain authorization from the Division of Water Resources prior to utilizing any biocide in the cooling water. d. There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 5 of 6 ACTT 7A 'F' pp x f> Permit NC0001384 �11 / r.,,.al xr1 =a `+, � r / _ s awMtw><a►•.wnw�i ">+S l 9 9uAbOxTsdmwbg6w- wg L� � Facility 3 IS +� WIS'19r vau-ww.BQW Location 79`3tYs 27 smodugAWL mumd 3xv157fT bVA&MI cCMk LgnbAdft 79`3M7' mdGur Renck 1 Y �%'� j 1tPD S P+ ►itWO. NW00084 MM(IODWO 030 OMM h op*wm ACmuty Page 6 of 6 DENR/DWR FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0001384 Faeft information ApplicarrW ility Name: NC0001384 — Burlington Technologies — Williamsburg Plant A licani Aftess: Mr. Earl Wrenn/ 5928 Highway 87 North, Gibsonville, NC 27242 acili A NC H 87 North, Gibsonville, NC Permitted Flow 001 — 0.025 MGD; 002 and 003 are not flow limited Type of Waste: 001: Sanitary Wastewater 002: Air washer blowdown and stormwater 003: Cooling tower blowdown f4cilitiXrnit Status:' Active; Expired/ Renewal Colmitv.Caswell iseellanto Receiving Stream: UT to Buttermilk Regional f?i' ce: Winston-Salem Creek and Grays Branch stream C1a fication: WSII —NSW, State rid, 11SG5 Quad: 1320SE/Williamsburg HOW - Both BACKGROUND: Burlington Technologies purchased the Williamsburg Plant in late 2009 from Tietex Interiors, who had purchased in on July 11, 2005 from Burlington Industries. The Williamsburg Plant for Burlington Technologies weaves yarn into cloth, though no process wastewater is discharged from any of the outfalls. The facility has three permitted Outfalls, 001, 002 and 003. Outfall 001 discharges domestic wastewater after treatment by a package plant. Air Washer blowdown and stormwater are discharged through Outfall 002. Cooling Water blowdown is discharged through Outfall 003. Outfalls 001 and 002 discharge to an unknown tributary (UT) to Buttermilk Creek. Outfall 003 discharges to a UT to Grays Branch. Both are considered zero flow streams in the Cape Fear River Basin. In 1997, the facility was required to perform an Engineering Alternatives Analysis (EAA) in order to assess the present value cost (PVC) of reducing the impact on the receiving streams, both of which are zero flow streams. After discussions with the Winston-Salem Regional Office (WSRO), it was agreed that the most feasible alternative, an upgrade to the existing treatment plant, would only be implemented if the facility began to have difficult meeting the limits specified by the NPDES permit. Fact Sheet NI'DES NC0001384 Draft RenexNal Page I APPLICATION REVIEW: The renewal application describes the treatment works as follows: Outfall 001: Domestic waste treated through a package system consisting of a bar screen, aeration basin, sludge digestion, clarifier, tablet chlorination system (includes chlorine contact chamber), tablet dechlorination and step aeration. Outfall 002: Air washer blowdown and stormwater, treated with sodium thiosulfate as needed for dechlorination. Outfall 003: Cooling Tower blowdown, treated with sodium thiosulfate as needed. DMR Review: DMRs from January 2010 to December 2012 were reviewed for all outfalls. Average monthly data for 001 is compiled in Table 1 below. Domestic flow from 001 averaged 0.0019 MGD with a maximum flow of 0.004 MGD. This flow was approximately the same as the discharge through 002 and 003, which averaged 0.0018 MGD each, and had a maximum value of 0.0050 and 0.0070 MGD respectively. Discharge from both 002 and 003 was usually consistent in volume from month to month, however, at the very low operating rate, the facility can go for months with one or more outfalls having no discharge. TRC from 002 and 003 is almost always below detection level. Outfall 002 had one reading of 15 µg/ L, which is below both the 17 µg/ L permit limit and the 50 µg/ L compliance level. Table 1: Summary of monthly average data for Outfall 001. Data extracted from DMRs from January 2010 to December 2012. Parameter Average Value Maximum Value Minimum Value Flow (MGD) 0.0019 0.004 0.0001 Temperature (°C) 15 29 4 TRC(m ) <10 <10 <10 BOD m L) 3.7 7.9 0.9 NH3-N m ) 1.6 11.0 0.1 DO (m ) 7.0 11.0 6.3 Total Suspended Solids m L) 10.3 103 2.0 Total Nitrogen m L) 31.3 46.6 12.0 Total Phosphorus m L) 1 3.9 1 8.2 1 1.9 Instream Data Review: The impact of the domestic waste discharge from 001 is assessed through instream monitoring of temperature and DO. Upstream/Downstream data for the unnamed tributary to Buttermilk Creek is summarized in Table 2. Data shows that downstream DO is less than upstream DO 73% of the time, even when Outfall 001 has not discharged for as long as 5 months. There was only one occasion on which the downstream DO value was lower than the instream DO standard of 5 mg/ L. On September 19, 2012 the downstream DO was 4.6 mg/ L., which is below the instream standard. However, this occurred during an extended period when there was no discharge from any outfall all month. The average change in temperature between the upstream and downstream portions of the stream was -0.4 °C. The average DO change was -0.4 mg/ L. 1-act sheet N11D1:S NC0001384 Draft ReneNNal 1'agc 2 Table 2: Summary of monthly average data for Instream Data, UT to Buttermilk Creek. Data extracted from DMRs from January 2010 to December 2012. Parameter Average Average Percent Change Upstream Value Downstream ((D — U)/U) * 100% Value Temperature (°C) 15.6 15.2 -2.56 Dissolved Oxygen 7.9 7.5 -5.06 (mg/L) Reasonable Potential Analysis: Reasonable Potential Analysis was not appropriate for any of the pollutants monitored through this permit. Compliance: Compliance Evaluation Inspections have been conducted annually from 2008-2012. During the past 5 years (2008 - 2012), the facility received 7 NOVs for various problems: One Late/ Missing DMR violation in August 2010, TRC Reporting Frequency in August and September 2011, Flow Reporting Frequency in August and September 2011 and Fecal Coliform Daily Maximum violations in October 2008 and November 2012. PERMITTING STRATEGY: 1997 correspondence from the facility and recent discussions with the WSRO indicate that the facility will not yet be required to implement any of the upgrades specified by the 12/97 EAA. The facility was permitted and in operation when the receiving waters were reclassified as HQW, so it is Grandfathered at the original conditions. If the facility develops problems meeting the DO instream requirements, it can be required to upgrade treatment facilities as per the 12/97 EAA. Waste Load Allocation (WLA): The last waste load allocation was performed in 1992. It indicates that the only positive flow measurement is the average flow: 0.075-cfs. BOD, TSS, ammonia nitrogen, DO, fecal coliform and TRC are all limited in the present permit. Monitoring requirements are for temperature, total nitrogen and Total Phosphorus. No changes are proposed in the renewal permit. Zero Flow Policy: As per NPDES policy, the facility was required to perform an EAA in 1997. They were also given NH3- N limits of 2 mg/L for summer and 4 mg/L for winter. Unless the facility begins to violate the stream DO standard, more stringent BOD limits will not be implemented. The current limits on BOD and TS S are 3 0/3 0. SUMMARY OF PROPOSED CHANGES: 1. . The Owner's name will be changed to Burlington Technologies - Williamsburg Plant, from Tietec Interiors. 2. On the Supplement to Permit Cover Page, tablet dechlorination is added to the facility description for Outfall 001. Equipment listing for Outfall 002 has been updated to delete all unused equipment, eliminating air compressors, cooling towers, boilers and water softeners. . Outfall 002 now consists of air washer blowdown and stormwater. 3. The Permit Map is updated to show actual discharge locations. 4. On page A.(1.) for Outfall 001: • Total Suspended Residue (TSR) is changed to Total Suspended Solids (TSS). Nact Sheet NPDFS N(:0001194 Draft Renewal Page 3 • The TRC footnote is updated in accordance with current permitting strategy, which states that analytical values reported as less than 50 µg/ L are considered to be in compliance with the permit requirements. • pH monitoring and limits have been moved up into the table, and the footnote removed. 5. On pages A.(2.) and A.(3.) for Outfalls 002 and 003: • The list of equipment and processes discharging to Outfall 002 has been revised in accordance with the current process arrangement, eliminating air compressors, cooling towers, boilers and water softeners, leaving air washer blowdown and stormwater only. • Instream monitoring for temperature for Outfall 002 has been removed because of process changes. • The TRC footnote has been updated to the current permitting strategy. • pH monitoring and limits have been moved up into the table, and the footnote removed. • References to "Division of Water Quality" have been changed to "Division of Water Resources" in accordance with recent reorganization within DENR. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: Permit Scheduled to Issue: Permit Effective Date: NPDES UNIT CONTACT: August, 2013 October, 2013 December 1, 2013 If you have questions regarding any of the above information or on the attached permit, please contact Jim McKay at (919) 807-6404. NAME: DATE: REGIONAL OFFICE COMMENTS NAME: DATE: SUPERVISOR: DATE: Fact Sheet NPDFS NC000 13,84 Draft Rcnev al Page 4 4 NCDEE North Carolina Department of Environment and Natural Resources Pat McCrory Governor Mr. Marvin Gaines Burlington Manufacturing Services 1305 Graham St Burlington, NC 27215 Subject: NOTICE OF VIOLATION NOV-2013-LV-0135 Permit No. NC0001384 Williamsburg Plant Caswell County Dear Mr. Gaines: Division of Water Quality Charles Wakild, P.E. Director February 22, 2013 John E. Skvarla, III Secretary A review of Williamsburg Plant's monitoring report for November 2012 showed the following violation: Parameter Date Limit Value Reported Value Limit Type Coliform, Fecal MF, M-FC Broth,44.5C 11/30/12 400 #/100ml 520 #/100m1 Daily Maximum Exceeded Remedial actions, if not already implemented, should be taken to correct the above noncompliance problem. Please be aware that violations of your NPDES permit could result in enforcement action for this by the Division of Water Quality for this and any additional violations of State law. If you should have any questions, please do not hesitate to contact Jenifer Carter at (336) 771-4957. cc: SWP — Central Files WSRO Files North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-77146301 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity i Affirmative Action Employer Sincerely, W. Corey Basinger Surface Water Regional Supervisor Winston-Salem Regional Office Division of Water Quality Nne orthCarolina ,atumllbl Carter, Jenifer From: Mckay, James Sent: Wednesday, January 02, 2013 10:44 AM To: Carter, Jenifer Cc: Corporon, Joe�,/� Subject: RE: permit NCO001384 Jennifer: I do have the assignment to renew this minor industrial permit. However, due to staff shortages and priorities, I have not been able to get to it yet. I am hoping to renew this permit this year, I cannot tell exactly when. I hope you also have a Happy New Year! Jim McKay, Environmental Engineer NC DENR / Division of Water Quality / Surface Water Protection Section Point Source Branch 1617 Mail Service Center, Raleigh, NC 27699-1617 919/807-6404 (work). 919/807-6489 (fax) "Please note, my email address has changed to.lames.McKay(q�nedenngov E-mail correspondence to andfrom this address may be subiect to the North Carolina Public Records law and may be disclosed to third parties. From: Carter, Jenifer Sent: Wednesday, January 02, 2013 9:25 AM To: Mckay, James Cc: Corporon, Joe Subject: RE: permit NC0001384 Jim, I'm checking on the status of the permit NC00001384. I see in RIMS that they have an application 'In Review' by you. It was received on December 9, 2010, and acknowledged on December 13, 2010. The current permit expired on May 31, 2011. Happy New Year! Jenifer Carter Before printing this ernail, please Consider your budget and the environment. If you must print, please print only what you need and save ink with the free Eco-Font. NC DENR Winston-Salem Regional Office Division of Water Quality 585 Waughtown Street Winston-Salem, NC 27107 Voice: (336) 771-4957 FAX: (336) 771-4630 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Corporon, Joe Sent: Friday, December 28, 2012 3:26 PM To: Carter, Jenifer Subject: RE: permit NC0001384 Jenifer — our latest appears to be 2006 (see attached (PDF). PPPFP NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Charles Wakild, P.E. Governor Director December 21, 2012 Mr. Mark Morgan, Plant Manager Burlington Technologies — Williamsburg Plant 5928 NC Highway 87 North Gibsonville, North Carolina 27249 SUBJECT: Compliance Evaluation Inspection — NPDES Permit No. NC0001384 Burlington Technologies — Williamsburg Plant WWTP Caswell County Dear Mr. Morgan: Dee Freeman Secretary Jenifer Carter of this office performed a Compliance Evaluation Inspection of the wastewater treatment facility at Tietex Interiors — Williamsburg Plant wastewater treatment plant in Caswell County on December 5, 2012. Marc Nault (ORC) was present for the inspection. This type of inspection consists of two basic parts: a review of facility files and an on -site inspection of the facility. Marc Nault is the new ORC of this plant since May 31, 2011. Facility files are maintained as required, including maintenance and ORC visitation logs. Lab data correctly correlated with data submitted on the monthly Discharge Monitoring Reports (DMRs). Waste in the aeration basin appeared on the thin/young side, and there were some solids and pin floc observed in the secondary clarifier. Since the clarifier appeared cloudy, Mr. Nault measured the sludge blanket depth after the inspection and decided that he should have sludge in the clarifier and chlorine contact chamber pumped out, and will have the digester decanted as well. The plant was discharging during the inspection. The effluent was clear and free of solids and foam. It is often noted on the monthly DMRs that there is no discharge at each of the three outfalls. All three outfalls were -- -- --- — discharging during the inspection. Care should be taken that data submitted on the D R is s representative of what typically occurs at the plant. Burlington Technologies staff is responsible for electrical and mechanical maintenance at the plant. It has been noted several years in a row now that herbicides have been used at the small creek where the effluent is discharged. This is ill-advised as it has caused severe erosion, and could contaminate samples taken for compliance purposes. More frequent mowing is recommended instead of the use of herbicides. Please refer to the attached report for further details from the inspection. If you have any questions concerning this report, please contact Ms. Carter at (336) 771-4957. 131 cc: WSRO — SWP Central Files — SWP North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St, Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-771-46301 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org 111� W. Corey Basinger Regional Supervisor Surface Water Protection Sincerely, tV4i�\ , Nne orthCarolina Natura!!rf An Equal Opportunity 1 Affirmative Action Employer PPF Pppp- United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Complianre Insppntoon 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 2 I s I 3 I NC0001384 111 121 12/12/05 117 18I � I 191 c( 201 LJ J != l J Remarks 2111 II 111111111111 11111111 1111 11111111 1111 1111 1116 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA —------------- —---------- Reserved —--------- --- — --- — 67 I 169 701 2 j 71(N 72 73 � 74 751 I I ( I I I 180 ---- !� 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 permit Number) Williamsburg Plant 12:50 PM 12/12/05 06/07/01 Exit Time/Date Permit Expiration Date 5928 Hwy 87 N Gibsonville NC 27249 02:15 PM 12/12/05 11/05/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Marc W Nault/ORC/336-341-8971/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Fariole,PO Box 691 Burlington NC 272150691/Plant Engineer/336-584-1166/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit N Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program N Sludge Handling Disposal Facility Site Review 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 Jenifer Carter WSRO WQ//336-771-5000/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previou itions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type 3 NC0001384 11 12, 12/12/05 17 18U (cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The Discharge Monitoring Reports indicate that the WWTP does not discharge often. The was a discharge occuring at all three outfalls during the inspection. Be sure representative discharges are being monitored as required. As a reminder, it is a permit condition that no chromium, zinc or copper be added to cooling tower water (sometimes added to biocides to keep algal growth down). Mr. Nault was adviced to periodically check with staff at the Williamsburg Plant to verify that these are still not being used. The discharges all appeared to be clear and free of foam or solids. Overall, the plant appeared to be operated and maintained sufficiently, though more frequent testing of sludge depth/age may be recommended. Please refer to each section of this inspection for more detail. Page # 2 ppppp- Permit: NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 12/05/2012 Inspection Type: 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? ■ ❑ ❑ ❑ 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? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ ■ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ ■ ❑ Page # 3 Permit: NC0001384 Inspection Date: 12/05/2012 Owner - Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Effluent Sampling 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)? Yes No NA NE ■n❑❑ ■n❑❑ ❑❑■❑ ❑ ❑ ■ ❑ Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n ❑ ❑ Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ ❑ ❑ ❑ 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? ❑ ❑ ■ ❑ Comment: Weekly flow is estimated using a ruler at the weir in the effluent trough. 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: Mr. Nault said he performs settleability tests on occasion. 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? Comment: The bar screen only screens out very large debris. Aeration Basins ■ n ■ ❑ ❑ ■000 ■ ❑ ❑ ❑ ■nn■ Yes No NA NE Page # 4 pppppp- Permit: NC0001384 Inspection Date: 12/05/2012 Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? 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? Owner - Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Is the DO level acceptable?(1.0 to 3.0 mg/1) Comment: The aeration basin appeared very thin and/or young. Secondary Clarifier 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''/4 of the sidewall depth) Comment: The secondary clarifier was cloudy with some pin floc. Mr. Nault measured the Judge blanket level after the inspection and found it to be approximately 1/3 the sidewall depth. He said he had never had it pumped out since operating the plant, but we make plans to have it done soon. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? Yes No NA NE Ext. Air Diffused Yes No NA NE Yes No NA NE Page # 5 Permit: NC0001384 Inspection Date: 12/05/2012 Disinfection -Tablet 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? Owner - Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Yes No NA NE Comment: Some sludge build-up was observed. Mr. Nault said he planned to have this pumped out at the same time that the sludge in the secondary clarifiers is removed. De -chlorination Yes No NA NE Type of system ? 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: Effluent Pipe 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: Herbicide use along the channel that the effluent discharges to has caused severe erosion. More frequent mowing is preferable to the use of herbicides near the effluent discharge. Tablet ■❑❑❑ ■ ❑ ❑ ❑ 2 Solids Handling Equipment Yes No NA NE Is the equipment operational? ❑ ❑ ■ ❑ Is the chemical feed equipment operational? ❑ ❑ ■ ❑ Is storage adequate? ❑ ❑ ■ ❑ Is the site free of high level of solids in filtrate from filter presses or vacuum filters? ❑ ❑ ■ ❑ Is the site free of sludge buildup on belts and/or rollers of filter press? ❑ ❑ ■ ❑ Is the site free of excessive moisture in belt filter press sludge cake? ❑ ❑ ■ ❑ The facility has an approved sludge management plan? ❑ ❑ ■ ❑ Page # 6 Permit: NC0001384 Inspection Date: 12/05/2012 Solids Handling Equipment Comment: Aerobic Digester Is the capacity adequate? Owner - Facility: Williamsburg Plant Inspection Type: Compliance Evaluation 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? Comment: Mr. Nault said he plans to decant the digester soon. Yes No NA NE Yes No NA NE Page # 7 NCDENR North Carolina Department of Environment and Natural Resources Beverly Eaves Perdue Governor Mr. Marvin Gaines Burlington Manufacturing Services 1305 Graham St Burlington, NC 27215 Subject: NOTICE OF DEFICIENCY NOD-2012-MV-0040 Permit No. NC0001384 Williamsburg Plant Caswell County Dear Mr. Gaines: Division of Water Quality Charles Wakild, P.E. Director July 18, 2012 Dee Freeman Secretary A review of Williamsburg Plant's monitoring report for March 2012 showed the following violation for outfall # 001: Parameter Week Ending Required Frequency Violation Temperature 03/03M 5 X/ week temperature reported for only 4 of 5 days discharge reported Failure to provide timely and accurate DMRs is a violation of your NPDES permit. If this violation is due to a transcription error, and certifiable data are available to rectify the noncompliance, we ask that you please submit an amended DMR(s) to the Division of Water Quality. Send a copy of the amended report to: Central Files and Winston Salem Regional Office Division of Water Quality Division of Water Quality — Surface Water 1617 Mail Service Center 585 Waughtown St. Raleigh, NC 27699-1617 Winston-Salem, NC 27107 Unresolved violations may lead to the issuance of a Notice of Violation and/or assessments of civil penalties. Violations are subject to a civil penalty assessment of up to $25,000.00 per day for each violation. Any efforts undertaken to bring the facility back into compliance are not an admission of culpability. Your above - mentioned corrective actions, the degree and extent of harm to the environment, and the duration and gravity of the violation(s) will be considered in any future actions undertaken. North Carolina Division of Neater Quality, Winston-Salem Regional Office Location: 585 W'aughtown St. Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-77*146301 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org continued on reverse... NorthCarolina Naturally An Equal Opporiunity�.. Affirmative Action Employer If you have any questions or require any additional information, please contact Jenifer Carte or myself at (336) 771-5000. Sincerely, W. Corey Basinger Regional Office Supervisor Surface Water Protection Section Winston-Salem Regional Office cc: WSRO SWP Files SWP Central Files PKAA ,Ohl= AMN� NCDENR North Carolina Department of Environment and Natural Resources Beverly caves Perdue Governor Mr. Marvin Gaines Burlington Manufacturing Services 1305 Graham St. Burlington, NC 27215 Division of Water Quality Coleen H. Sullins Director December 21, 2011 Subject: NOTICE OF VIOLATION NOV-2011-MV-0208 (August) and NOV-2011-MV-0209 (September) Permit No. NC0001384 Williamsburg Plant Caswell County Dear Mr. Gaines: A review of Williamsburg Plant's monitoring report for August 2011 showed the following violations: Dee Freeman Secretary Parameter Date Required Frequency Violation Flow, outfall 002 08/31/11 Monthly Not Monitored Chlorine, Total Residual, outfall 001 Week ending 08/20/11 2 X week Monitored only 1 X A review of Williamsburg Plant's monitoring report for September 2011 showed the following violations: Parameter Date Required Frequency Violation Flow, outfall 002 09/30/11 Monthly Not Monitored Chlorine, Total Residual, outfall 001 Week ending 09/03/11 2 X week Monitored only 1 X Flow, outfall 003 09/30/11 Monthly Not Monitored Remedial actions, if not already implemented, should be taken to correct the above noncompliance problem. Similar violations in subsequent months may result in a civil penalty assessment. These violations of your NPDES permit, and any additional violation of State law, can result in enforcement action by the Division of Water Quality. If you should have any questions, please do not hesitate to contact Jenifer Carter at (336) 771-4957. Sincerely, _,dam cc: SWP — Central Files WSWFiles North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 Phone: 336-771-5000 \ FAX: 336-771-4630 \ Customer Service: 1-877-623.6748 Internet: www.ncwaterquality.org W. Corey Basinger Surface Water Regional Supervisor Winston-Salem Regional Office Division of Water Quality NorthCarofina Naturally An Equal Opportunity � Affirmative Action Employer ppplr� IkF_"� NCDENR North Carolina Department of Environment and Natural Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director July 29, 2011 Mr. Mark Morgan, Plant Manager Burlington Technologies —Williamsburg Plant 5928 NC Highway 87 North Gibsonville, North Carolina 27249 Resources Dee Freeman Secretary SUBJECT: Compliance Evaluation Inspection — NPDES Permit No. NC0001384 Burlington Technologies — Williamsburg Plant WWTP Caswell County Dear Mr. Morgan: Jenny Graznak of this office performed a Compliance Evaluation Inspection of the wastewater treatment facility at Tietex Interiors — Williamsburg Plant wastewater treatment plant in Caswell County on July 27, 2011. Marc Nault (ORC) and Patrick Merritt (Back -Up ORC) of Meritech and Earl Wrenn of Williamsburg Plant were present for the inspection. This type of inspection consists of two basic parts: an in -office review of facility files and self -monitoring data and an on -site inspection of the facility. This particular inspection evaluated nine (9) areas, and observations from each area are addressed below: 1. Permit The new permit became effective July 1, 2006 and expired May 31, 2011. The new permit has not been received yet, so you should continue to operate according to the previous permit's requirements. This facility was recently purchased by Burlington Technologies and is no longer named Tietex Interiors. Therefore, if you have not already, you should complete a Name/Ownership Change Form, which is attached to this letter. 2. Self -Monitoring Program A review of the monthly Discharge Monitoring Reports (DMRs) from June 2010 through May 2011 showed no limit violations. However, there was a violation of monitoring requirements in April 2011 when pH was not measured at any of the three outfalls for the time period of March 26 through April 7. This issue of noncompliance was addressed in separate correspondence from our office. 3. Laboratory Meritech, Inc. manages all wastewater analysis for the treatment plant. Field parameter lab certification number for Meritech, Inc. is 165. ORC Marc Nault performs the following field parameter tests at this facility: temperature, pH, dissolved oxygen, and total residual chlorine. 4. Flow Measurement The plant does not have a flow meter. Weekly effluent flow is estimated in gallons per minute using a ruler at the weir in the effluent trough. 5. Facility Site Review The plant includes an aeration basin, a secondary clarifier, digester, tablet chlorination, dechlorination, and step aeration at the effluent. The aeration basin has two blowers. The chlorinator has four (4) tubes. The dechlorination system has two tubes, which require sodium sulfite North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 One Phone: 336-771-50001 FAX: 336-77146301 Customer Service:1-877-623-6748 NorthCarolina Internet: www.ncwaterquality.org ;Vatura!!ff An Equal Opportunity 1 Affirmative Action Employer tablets. Dechlorination equipment has not been added to the Outfalls 002 and 003 (cooling tower blowdown) because testing determined that the effluent meets the chlorine limit requirements already. 6. Operations & Maintenance Marc Nault is the new ORC of this plant since May 31, 2011. Some solids were observed floating on the surface of the clarifier. A few tadpoles were also observed in the clarifier during the inspection. Burlington Technologies staff is responsible for electrical and mechanical maintenance at the plant, including motors, oil, filters, compressor, and bearings. A record of this maintenance work, performed on a monthly basis, is kept in the shed inside the plant fence. Ms. Graznak noted that once again, herbicides have been used at the small creek where the effluent is discharged. 7. Records/Reports The Discharge Monitoring Reports (DMRs) and lab data were available for review during the inspection. Field parameter data and meter calibration information was available during the inspection from the ORC in the form of scratch notes. A daily operators log is maintained in the shed at the plant. 8. Effluent/Receiving Waters The effluent is discharged into unnamed tributaries to Buttermilk Creek and Grays Branch (WS-II, NSW) in the Cape Fear River Basin. The effluent appeared clear with no traceable solids. Upstream sample is collected 50 feet upstream of discharge, and downstream sample is collected 50 feet downstream of discharge — posts mark the exact spots. 9. Sludge Handling Disposal Due to low flow, the operating staff reports that wasting occurs infrequently. Billingsly Septic Tank Service provides sludge disposal. The contents of the sludge digester are transported to City of Greensboro's North Buffalo Wastewater Treatment Plant. No sludge has been removed in the last few year due to such low flow at the plant. Please refer to the attached report for further details from the inspection. If you have any questions concerning this report, please contact Ms. Graznak or me at (336) 771-5000. Sincerely, J16t?111 Elie 11-/' /� W. Corey Basinger Regional Supervisor Surface Water Protection cc: WSRO — SWP Central Files — SWP 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 20! I 1 NI 2 Ls 3I NC0001384 111 121 11/07/27 ( 17 18I CI 19I SI J Remarks 211111IIIIIIIIIIIIIIIIIIII IIIIIIIIIIIIIIIIIIIIIII6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA-----------Reserved-- - - 67 I 169 7013 � 71 I I 72I N j 73 W 74 751 I I I I I I 180 —� Section B: FacilityData Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 11:30 AM 11/07/27 06/07/01 Williamsburg Plant 5928 Hwy 87 N Exit Time/Date Permit Expiration Date Gibsonville NC 27249 12:30 PM 11/07/27 11/05/31 Name(s) of Onsite Representative(s)fritles(s)/Phone and Fax Number(s) Other Facility Data David R. Merritt//336-342-4748 /3363421522 Earl Wrenn//336-343-4569 /3362277696 Name, Address of Responsible Officiallritle/Phone and Fax Number Robert Fariole,PO Box 691 Burlington NC 272150691/Plant Contacted Engineer/336-584-1166/ 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 Jennifer F Graznak WSRO WQ//336-771-5000/ Signature f Management Q A Reviewer and Fax Numbers Date - (Aggency/Office/Phone a"04,U D J14,kj EPA Form 3560-3 IRev 9-94) Pr l ious editions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type 3I NC0001384 I11 12I 11/07/27 ( 17 18ICI (cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Jenny Graznak of this office performed a Compliance Evaluation Inspection of the wastewater treatment facility at Tietex Interiors — Williamsburg Plant wastewater treatment plant in Caswell County on July 27, 2011. Marc Nault (ORC) and Patrick Merritt (Back -Up ORC) of Meritech and Earl Wrenn of Williamsburg Plant were present for the inspection. This type of inspection consists of two basic parts: an in -office review of facility files and self -monitoring data and an on -site inspection of the facility. This particular inspection evaluated nine (9) areas, and observations from each area are addressed below: 1. Permit The new permit became effective July 1, 2006 and expired May 31, 2011. The new permit has not been received yet, so you should continue to operate according to the previous permit's requirements. This facility was recently purchased by Burlington Technologies and is no longer named Tietex Interiors. Therefore, if you have not already, you should complete a Name/Ownership Change Form, which is attached to this letter. 2. Self -Monitoring Program A review of the monthly Discharge Monitoring Reports (DM Rs) from June 2010 through May 2011 showed no limit violations. However, there was a violation of monitoring requirements in April 2011 when pH was not measured at any of the three outfalls for the time period of March 26 through April 7. This issue of noncompliance was addressed in separate correspondence from our office. 3. Laboratory Meritech, Inc. manages all wastewater analysis for the treatment plant. Field parameter lab certification number for Meritech, Inc. is 165. ORC Marc Nault performs the following field parameter tests at this facility: temperature, pH, dissolved oxygen, and total residual chlorine. 4. Flow Measurement The plant does not have a flow meter. Weekly effluent flow is estimated in gallons per minute using a ruler at the weir in the effluent trough. 5. Facility Site Review The plant includes an aeration basin, a secondary clarifier, digester, tablet chlorination, dechlorination, and step aeration at the effluent. The aeration basin has two blowers. The chlorinator has four (4) tubes. The dechlorination system has two tubes, which require sodium sulfite tablets. Dechlorination equipment has not been added to the Outfalls 002 and 003 (cooling tower blowdown) because testing determined that the effluent meets the chlorine limit requirements already. 6. Operations & Maintenance Marc Nault is the new ORC of this plant since May 31, 2011. Some solids were observed floating on the surface of the clarifier. A few tadpoles were also observed in the clarifier during the inspection. Burlington Technologies staff is responsible for electrical and mechanical maintenance at the plant, including motors, oil, filters, compressor, and bearings. A record of this maintenance work, performed on monthly basis, is kept in the shed inside the plant fence. Ms. Graznak noted that once again, herbicides have been used at the small creek where the effluent is discharged. 7. Records/Reports The Discharge Monitoring Reports (DMRs) and lab data were available for review during the inspection. Page # 2 Permit: NC0001384 Inspection Date: 07/27/2011 Owner -Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Field parameter data and meter calibration information was available during the inspection from the ORC in the form of scratch notes. A daily operators log is maintained in the shed at the plant. 8. Effluent/Receiving Waters The effluent is discharged into unnamed tributaries to Buttermilk Creek and Grays Branch (WS-Il, NSW) in the Cape Fear River Basin. The effluent appeared clear with no traceable solids. Upstream sample is collected 50 feet upstream of discharge, and downstream sample is collected 50 feet downstream of discharge — posts mark the exact spots. 9. Sludge Handling Disposal Due to low flow, the operating staff reports that wasting occurs infrequently. Billingsly Septic Tank Service provides sludge disposal. The contents of the sludge digester are transported to City of Greensboro's North Buffalo Wastewater Treatment Plant. No sludge has been removed in the last few year due to such low flow at the plant. Page # 3 Permit: NC0001384 Inspection Date: 07/27/2011 Owner -Facility: Williamsburg Plant Inspection Type: 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 ■ n n n 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? ■ ❑ n ❑ 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? ■ n n n Is all required information readily available, complete and current? ■ Cl ❑ ❑ 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? ■ n n n 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? ■ n n n Has the facility submitted its annual compliance report to users and DWQ? n n n ■ (if the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n ■ ❑ Is the ORC visitation log available and current? ■ ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ■ n ri ❑ Is the backup operator certified at one grade less or greater than the facility classification? ■ n n n Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑ Page # 4 pppp-pr, Permit: NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 07/27/2011 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? ❑ 0 I] ■ Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? n ■ n Are the receiving water free of foam other than trace amounts and other debris? ■ n n n If effluent (diffuser pipes are required) are they operating properly? ❑ n ■ 0 Comment: Ms. Graznak noted that once again, herbicides have been used at the small creek where the effluent is discharged. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ ■ ❑ n Is flow meter calibrated annually? Q 0 ■ n Is the flow meter operational? 00 ■ n (If units are separated) Does the chart recorder match the flow meter? 00 ■ Comment: The plant does not have a flow meter. Weekly effluent flow is estimated in gallons per minute using a ruler at the weir in the effluent trough. Aerobic Digester Yes No NA NE Is the capacity adequate? ■ n n Is the mixing adequate? ■ Q Q n Is the site free of excessive foaming in the tank? ■ n # Is the odor acceptable? ■ n n n # Is tankage available for properly waste sludge? ■ Q n Q Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual ■ b. Mechanical n Are the bars adequately screening debris? 0 moo Is the screen free of excessive debris? ■ 0 Q n Is disposal of screening in compliance? ■ ❑ Q n Is the unit in good condition? ■ Cl n n Comment: The slats of the bar screen are too large to catch small materials. Page # 5 Permit: NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 07/27/2011 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? ■ Cl ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? n ■ n n Are weirs level? ❑ ■ ❑ ❑ Is the site free of weir blockage? ■ n n n Is the site free of evidence of short-circuiting? ■ n n n 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 dear of excessive solids/pin floc? ❑ ■ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) ❑ ❑ ❑ ■ Comment: Some solids were observed floating on the surface of the clarifier. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? ■ ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ ■ ❑ 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? ❑ n ❑ ■ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ ■ Comment: The aeration basin was churned up and dark in color (more than usual) on day of inspection. De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ ■ Is storage appropriate for cylinders? ■ n n n # Is de -chlorination substance stored away from chlorine containers? ■ ❑ 00 Comment: Page # 6 Permit: NC0001384 Inspection Date: 07/27/2011 De -chlorination Are the tablets the proper size and type? Are tablet de -chlorinators operational? Number of tubes in use? Comment: Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? 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? Comment: Some sludge buildup was observed. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Owner -Facility: Williamsburg Plant Inspection Type: Compliance Evaluation 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)? Comment: there was a violation of monitoring requirements in April 2011 when pH was not measured at any of the three outfalls for the time period of March 26 through April 7. Yes No NA NE ■ ❑ ❑ ❑ ■❑❑❑ 2 Yes No NA NE ■n❑❑ ■❑❑❑ 4 ❑❑❑■ ❑ ■ ❑ ❑ ❑000 Yes No NA NE n❑■❑ ■❑❑❑ ■❑❑❑ ❑❑■❑ ❑❑CIE ❑■❑❑ Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ❑ ■ ❑ ❑ Comment: there was a violation of monitoring requirements in April 2011 when pH was not measured at any of the three outfalls for the time period of March 26 through April 7. Page # 7 ALTI-WYWA NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary July 22, 2011 Mr. Mark Morgan Tietex Interiors — Williamsburg Plant 5928 NC Highway 87 North Gibsonville, North Carolina 27249 SUBJECT: Notice of Violation —Monitoring Violations (APRIL 2011) NPDES Permit No. NC0001384 Tietex Interiors: Williamsburg Plant WWTP Caswell County Dear Mr. Morgan: A review of the self -monitoring report for the month of April 2011 revealed the following violation of permit monitoring requirements: Parameter Required Monitoring Actual Monitoring Frequency Frequency pH Weekly None from Mar 26 — Apr 7 (Outfalls 001, 002, 003) Remedial actions, if not already implemented, should be taken to correct the above noncompliance problem. Please be aware that violations of your NPDES permit could subject you to enforcement action by this Division with the possible assessment of civil penalties of up to $25,000 per day per violation. Should you have any questions, please contact Jenny Graznak or me at (336) 771-5000. Sincerely, W. Corey Basinger ./ Regional Supervisor Surface Water Protection Section cc: Central Files — SWP WSRO — SWP North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-771-46301 Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org Nne orthCarohna ,Naturally An Equal Opportunity 1 Affirmative Action Employer North Carolina Beverly Eaves Perdue Governor WIA NCDENR Department of Environment and Natural Resources Division of Water Quality Coleen H. Sullins Dee Freeman Director Secretary July 30, 2010 Mr. Mark Morgan Tietex Interiors —Williamsburg Plant 5928 NC Highway 87 North Gibsonville, North Carolina 27249 SUBJECT: Compliance Evaluation Inspection — NPDES Permit No. NC0001384 Tietex Interiors: Williamsburg Plant WWTP — Caswell County Dear Mr. Morgan: Jenny Graznak and Mike Thomas of this office performed a Compliance Evaluation Inspection of the wastewater treatment facility at Tietex Interiors — Williamsburg Plant wastewater treatment plant in Caswell County on July 28, 2010. Patrick Merritt (ORC) was present for the inspection. This type of inspection consists of two basic parts: an in -office review of facility files and self -monitoring data and an on -site inspection of the facility. This particular inspection evaluated ,nine (9) areas, and observations from each area are addressed below: 1. Permit The new permit became effective July 1, 2006 and expires May 31, 2011. You must submit a permit renewal application within the next year. 2. Self -Monitoring Program A review of the monthly self -monitoring reports from June 2009 through May 2010 showed no limit violations. All parameters were sampled at the frequency required by the permit. 3. Laboratory Meritech, Inc. manages all wastewater analysis for the treatment plant. Field parameter lab certification number for Meritech, Inc. is 165. ORC Patrick Merritt performs the following field parameter tests at this facility: temperature, pH, dissolved oxygen, and total residual chlorine. 4. Flow Measurement Weekly effluent flow is estimated in gallons per minute using a ruler at the weir in the effluent trough. 5. Facility Site Review The plant includes an aeration basin, a secondary clarifier, dechlorination, and step aeration at the effluent. The aeration chlorinator has four (4) tubes. The dechlorination system has tw sulfite tablets. Dechlorination equipment has not been added (cooling tower blowdown) because testing determined that the e requirements already. North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-771-46301 Customer Service: 1-877-623-6748 Internet www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer digester, tablet chlorination, basin has two blowers. The o tubes, which require sodium to the Outfalls 002 and 003 ffluent meets the chlorine limit Nne orthCarolina Kati rallry b. Uperations & Maintenance Tietex staff is responsible for electrical and mechanical maintenance at the plant, including motors, oil, filters, compressor, and bearings. A record of this maintenance work, performed on a monthly basis, is kept in the shed inside the plant fence. Ms. Graznak noted that once again, herbicides have been used at the small creek where the effluent is discharged. Excessive use of such treatments in and around a stream could lead to a violation of water quality standards. Please relay this information to your lawn maintenance staff. 7. Records/Reports The Discharge Monitoring Reports (DMRs) and lab data were available for review during the inspection. However, field parameter data and meter calibration information was not available during the inspection. Please make sure that this data is available for DWQ inspectors upon request. A daily operators log is maintained by the ORC. 8. Effluent/Receivinq Waters The effluent is discharged into unnamed tributaries to Buttermilk Creek and Grays Branch (WS- II, NSW) in the Cape Fear River Basin. The effluent appeared clear with no traceable solids. Upstream sample is collected 50 feet upstream of discharge, and downstream sample is collected 50 feet downstream of discharge — posts mark the exact spots. 9. Sludge Handling Disposal Due to low flow, the operating staff reports that wasting occurs infrequently. Billingsly Septic Tank Service provides sludge disposal. The contents of the sludge digester are transported to City of Greensboro's North Buffalo Wastewater Treatment Plant. No sludge has been removed in the last year due to such low flow at the plant. Please refer to the attached report for further details from the inspection. If you have any questions concerning this report, please contact Ms. Graznak or me at (336) 771-5000. Sincerely, Steve W. Tedder Regional Supervisor Surface Water Protection CC' Patrick Merritt, Meritech, Inc. WSRO — SWP Central Files — SWP 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 INI 2 15I 31 NC0001384 Ill 121 10/07/28 117 18ICI 19ISI 20I I Remarks 211111111IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------- --------Reserved-------------- 671 169 70131 711 I 721 N I 73 L Lj 74 751 I I I I I I 180 Section & 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 permit Number) 10:00 AM 10/07/28 06/07/01 Williamsburg Plant Exit Time/Date Permit Expiration Date 5928 Hwy 87 N Gibsonville NC 27249 11:00 AM 10/07/28 11/05/31 Name(s) of Onsite Representative(s)/fitles(s)/Phone and Fax Number(s) Other Facility Data Patrick A Merritt/ORC/336-342-4748/ Name, Address of Responsible Official/Title/Phone and Fax Number Robert Fariole,PO Sox 691 Burlington NC 27215/Plant Contacted No Engineer/336-584-1166/ 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 Jennifer F Graznak WSRO WQ//336-771-5000/ /q-_ n , �y. Signature of Managemen Q A Review Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rv 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type 3I NC0001384 I11 121 10/07/28 117 18IC1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) 1. Permit The new permit became effective July 1, 2006 and expires May 31, 2011. You must submit a permit renewal application within the next year. 2. Self -Monitoring Program A review of the monthly self -monitoring reports from June 2009 through May 2010 showed no limit violations. All parameters were sampled at the frequency required by the permit. 3. Laboratory Meritech, Inc. manages all wastewater analysis for the treatment plant. Field parameter lab certification number for Meritech, Inc. is 165. ORC Patrick Merritt performs the following field parameter tests at this facility: temperature, pH, dissolved oxygen, and total residual chlorine. 4. Flow Measurement Weekly effluent flow is estimated in gallons per minute using a ruler at the weir in the effluent trough. 5. Facility Site Review The plant includes an aeration basin, a secondary clarifier, digester, tablet chlorination, dechlorination, and step aeration at the effluent. The aeration basin has two blowers. The chlorinator has four (4) tubes. The dechlorination system has two tubes, which require sodium sulfite tablets. Dechlorination equipment has not been added to the Outfalls 002 and 003 (cooling tower blowdown) because testing determined that the effluent meets the chlorine limit requirements already. 6. Operations & Maintenance Tietex•staff is responsible for electrical and mechanical maintenance at the plant, including motors, oil, filters, compressor, and bearings. A record of this maintenance work, performed on a monthly basis, is kept in the shed inside the plant fence. Ms. Graznak noted that once again, herbicides have been used at the small creek where the effluent is discharged. Excessive use of such treatments in and around a stream could lead to a violation of water quality standards. Please relay this information to your lawn maintenance staff. 7. Records/Reports The Discharge Monitoring Reports (DMRs) and lab data were available for review during the inspection. However, field parameter data and meter calibration information was not available during the inspection. Please make sure that this data is available for DWQ inspectors upon request. A daily operators log is maintained by the ORC. 8. Effluent/Receiving Waters The effluent is discharged into unnamed tributaries to Buttermilk Creek and Grays Branch (WS-II, NSW) in the Cape Fear River Basin. The effluent appeared clear with no traceable solids. Upstream sample is collected 50 feet upstream of discharge, and downstream sample is collected 50 feet downstream of discharge — posts mark the exact spots. 9. Sludge Handling Disposal Due to low flow, the operating staff reports that wasting occurs infrequently. Billingsly Septic Tank Service provides sludge disposal. The contents of the sludge digester are transported to City of Greensboro's North Buffalo Wastewater Treatment Plant. No sludge has been removed in the last year due to such low flow at Page # 2 NC0001384 07/28/2010 Owner -Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ O O 0 Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n IF, Judge, and other that are applicable? Comment: Yes No NA NE Permit (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Cl n ■ ❑ Is the facility as described in the permit? ■ n n n # Are there any special conditions for the permit? n n ■ n Is access to the plant site restricted to the general public? ■ n n n Is the inspector granted access to all areas for inspection? ■ n n n Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? n ■ n n Is all required information readily available, complete and current? n ■ n n Are all records maintained for 3 years (lab. reg. required 5 years)? n ■ n n Are analytical results consistent with data reported on DMRs? ■ ❑ In n Is the chain -of -custody complete? ■ n n In 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? ■ n n n Has the facility submitted its annual compliance report to users and DWQ? n ■ n n (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n ■ n Is the ORC visitation log available and current? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? ■ n n n Is the backup operator certified at one grade less or greater than the facility classification? ■ n n n Is a copy of the current NPDES permit available on site? ■ n n In Page # 4 Permit: NC0001384 Inspection Date: 07/28/2010 Owner -Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Record Keeping Tes no NA n Facility has copy of previous year's Annual Report on file for review? 0000 Comment: Annual Report for 2009 has not been recieved by DWQ as of yet. Field parameter data and meter calibration information was not available during the inspection. Please make sure that this data is available for DWQ inspectors upon request. Effluent Pipe Tes no NA n Is right of way to the outfall properly maintained? n ■ Cl n Are the receiving water free of foam other than trace amounts and other debris? n ■ n n If effluent (diffuser pipes are required) are they operating properly? n n ■ n Comment: Ms. Graznak noted that once again, herbicides have been used at the small creek where the effluent is discharged. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? n ■ n n Is flow meter calibrated annually? n n ■ n Is the flow meter operational? n ❑ ■ n (If units are separated) Does the chart recorder match the flow meter? n n ■ n Comment: Weekly effluent flow is estimated in gallons per minute using a ruler at the weir in the effluent trough. Aerobic Digester Yes No NA NE Is the capacity adequate? ■ n n n Is the mixing adequate? ■ n n n Is the site free of excessive foaming in the tank? ■ n n n # Is the odor acceptable? ■ n n n # Is tankage available for properly waste sludge? ■ n n n Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual ■ b. Mechanical n Are the bars adequately screening debris? n ■ n n Is the screen free of excessive debris? ■ n n n Is disposal of screening in compliance? ■ n n n Page # 5 NC0001384 07/28/2010 Owner -Facility: Williamsburg Plant Inspection Type: Compliance Evaluation Bar Screens Is the unit in good condition? Comment: The slats of the bar screen are too large to catch small materials. Secondary Clarifier 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'/. of the sidewall depth) Comment: Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? 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/1) Comment: Type of system ? Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? Yes No NA NE ■ n n n ■ ❑ n ❑ ■nnn ■ n n n ■ n n n ■nnn ■nnn ■ n n n ■nnn ■nnn n n n ■ Yes No NA NE Ext. Air Diffused ■ n n n nn■o ■ n n n ■nnn ■ n n n n n n ■ ❑ ❑ ❑ ■ Tablet nnn■ nn■o Page # 6 Permit: NCO001384 Inspection Date: 07/28/2010 Owner -Facility: Williamsburg Plant Inspection Type: Compliance Evaluation # Is de -chlorination substance stored away from chlorine containers? ■ n n n Comment: Are the tablets the proper size and type? ■ n n n Are tablet de -chlorinators operational? ■ n n n Number of tubes in use? 2 Comment: Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? ■ n n n Are the tablets the proper size and type? ■ n n n Number of tubes in use? 4 Is the level of chlorine residual acceptable? n n n ■ Is the contact chamber free of growth, or sludge buildup? ■ n n n Is there chlorine residual prior to de -chlorination? n n n ■ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? n n ■ n Is sample collected below all treatment units? ■ n n n ■ n n n Is proper volume collected? n Cl ■ n Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n n ■ Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n n n Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ n n n Comment: Page # 7 A NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Governor MARK MORGAN PLANT MANAGER BURLINGTON TECHNOLOGIES WILLIAMSBURG PLANT 5928 HWY 87 NORTH GIBSONVILLE NC 27249 Dear Mr. Morgan: Coleen H. Sullins Director December 13, 2010 RECEIVED N.C. Dect. r,: FNR DEC 17 2010 !! Dee Freeman Secretary Subject: Receipt of permit renewal application NPDES Permit NC0001384 Williamsburg Plant Caswell County The NPDES Unit received your permit renewal application on December 9, 2010. A member of the NPDES Unit will review your application. They will contact you if additional information is required to complete your permit renewal. You should expect to receive a draft permit approximately 30-45 days before your existing permit expires. If you have any additional questions concerning renewal of the subject permit, please contact Jeff Poupart at (919) 807-6309. Sincerely, Dina Sprinkle Point Source Branch cc: CENTRAL FILES Winston-Salem Regional Office/Surface Water Protection gpn"n 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Ralegh, North Carolina 27604 Phone: 919-807-6300 \ FAX: 919-807-6492 \ Customer Service: 1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer No thCarolina Naturvily rpl NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director September 23, 2010 [TRECEIVED CERTIFIED MAIL RETURN 7009-1680-0002-2464-7828 o�ol� RECEIPT REQUESTED 010 Mr. Marvin Gaines Regional Ca e Regional O" ce Burlington Manufacturing Services 1305 Graham Street Burlington, North Carolina 27215 Subject: NOTICE OF VIOLATION Williamsburg Plant NPDES Permit NC0001384 Caswell County NOV-2010-LR-0064 Dear Mr. Gaines: Dee Freeman Secretary This is to inform you that the Division of Water Quality did not received your monthly monitoring report for June 2010 until August 24. Also, the July 2010 report was not received until September 20, 2010. This is in violation of Part H, condition D(2) of the NPDES permit, as well as 15A NCAC 2B .506(a), which requires the submittal of Discharge Monitoring Reports no later than the last calendar day followingthe he reporting period. Failure to submit reports as required will subject the violator to the assessment of a civil penalty of up to $25,000 per violation. Additionally, this letter provides notice that this office will recommend the assessment of civil penalties if future reports are not received within the required time frame during the next twelve (12) reporting months. The Division must take these steps because timely submittal of discharge monitoring reports is essential to the efficient operation of our water quality programs. We appreciate your assistance in this matter. If you have any questions about this letter or discharge monitoring reports, please contact me at 919-807-6388. Sincerely, Maureen Scardina cc: Maureen Scardina, NPDES Unit DWQ Winston-Salem Regional Office Supervisor, Surface Water Protection Central Files 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807-63001 FAX: 919-807-64921 Customer Service:1-877.623.6748 Internet: http://portal.nodenr.org/web/Wq/home An Equal Opportunity 1 Affirmative Action Employer NorthCarolina Naturally moppr /2010 12:46 3363421522 #0013 P.001/006 -ERIT'ECH INC- ENVIRONMENTAL LABORATORIES A DIWSION OF WATER TECHNOLOGYAND CONTROLS, INC FACSIMILE TRANSMITTAL SHEET TO: �RaM: � C�ro,z ngk pad M . LaMrnxv: DATE: 1 l7 FAX NVMDER: TOTAL NO. OF PAGE$ TNCLVDING COVER: PHONE NVMDER: SENDER'S REFERENCE NVMDER: RE: YOVR REFERENCE NVMDER: 0 URGENT RIFOR REVIEW Ca PLEASE COMMENT Q PI!CASE REPLY 0 FLEASE RECYCLE NOTES/COMMENTS: � - VN2 Y,^ow I 15 yo V wtr z- ) o'-k� C . yoo ry4-V. (2)s-p— 642 TAMCO ROAD, REIDSVILLE NORTH CAROLINA 27320 PHONE 336-342.4748 - FAX 336-342-1522 E-MAIL: WTCLABGBIrLLSOUTFI.NET P�20�1012:46 3363421522 #0013 P.002/006 pH Meter Calibration and Analysis Thermo, Russell Portable RL 060P Calibrate the meter daily. 1 Press U (ON) 2 Rinse the probe with Type I water. Shake and gently blot it dry, 3 Immerse the probe in pH 4 buffer and gently stir. Press , - to begin the calibration. 4 Allow the reading to stabilize, and then press ENTER. S Rinse and dry the probe. ��-- 6 Immerse in the pH 10 buffer and then press L� . 7 Allow the reading to stabilize, and then press ENTER. 8 Rinse and dry the probe. 9 To verify the calibration, immerse the probe in the pH 7 buffer. When it stabilizes, record the reading. It must be within + 0.1 S.U. If not, repeat calibration. 10 Press MODE to view the temperature. Record the temperature. 11 Press MODE to see mV. Press MODE again to return to reading pH.. ANALYST DATE TIME TEMP. SUFFER READING ^'� '7 �3 ✓J Q'r 3 $ % PH 4.00 Lj.D I PH 10.00 j O •0'J. PH 7.00 1 .01 Meter verification and samples I At the time of sample collection, recheck and record the 7.00 buffer. Rinse the probe. 2 Pour well mixed sample into two beakers. 3 Stir gently with the electrode. 4 When the reading is stable, record the temp. and pH, each to 1 decimal place. S A duplicate must be run each day, and every other sample must also be duplicated. 6 Record both the time of collection and the time of analysis ANALYST DATE SAMPLE TIME (callcct) TIME (analysis) pH TEMP. M 151,ro PH 7.00 S o 1.01 ay 4"- s 1640 .� ace Gov'tV ,ex-, 01a.)is S ca ,.41 1at,ttIs 1*Ob loll sky^ N. Ilia i 15 b. b 4(o clot W 1z 4ao Lo .O 4G N 12a1 1 1400 1, . o aco L.WA 111306 Pp pp' P012010 P12 46 3363421522 ODYSSEY Total Chlorine Curve - LL Analysis Date: Analyst: Residual Chlorine f _ne 00101imew Wavelength: 515 nm 0.000 0 0,01 0.0w 0.02 0.017 0.05 0,034 011 0.06a 0.2 0.138 0.5 0.32 o,602= 0.003075598 0-999$55401 0,999710822 #0013 P.003/006 Curve Date 12/14/09 JAS Total Chlorine Curve 0.350.1 ..... . . ... __­...­W&=laA9th415-njU ..............._.,...........__._.....I........... 0.300 5 0,250 0.200 0,150 - a 0 w 0.050 0,000 0 0.05 0.1 0.15 0.2 0.25 0.3 0,35 0.4 0,45 0.5 Standard (mg/L) Elm MEN= �R_ /2010 1247 3363421522 #0013 P.004/006 ..WWP Field Data Sheet Initial Colib on Lea Date: Analyst: o 5< DO Meter Cellbratlon Time 1 Co %DO 00 MOA iCAL U1150 sr� E7 1 -1. a 1 '% .IS 16 DO Result (mgn) Eff U Down 00►w,It Q� �.5q 6� GZA Temp PH C411bragon PH Result O O cli muftwawc MEN MUM Opp �� ;eltoo �• • i �® • • ® • 1 DO-1 } } , } Meritech 012efratians Log Yearoa D 8� sS 4 iJlib2 {?. On TJms�..Fkw . PH'a T. wwaS�_C <r Temp Oown lime on Slte FhwTed PK CIS D.O. Temp. D.O. Temp. D.O. �sCy e-L� T emp P lPT_4a Ei1Eff Eff Eif U U Down Dwln DayMr. 1Mfaak 1 lNe k 2rWeek 11Weak 1flM1�eek 1=0* 1flNeok 1/Waek I a3a 1 a a 2 n1 vas 3 ao o Q.00 I 1a- tp,R C,o 6,140 1 po ODa 051t. gqg tro oo3 tilt q4j uo 4 e Pen x a t 11a,> r l4 C, PL la VAO 6.00-3 IS tD.e Lao .6.0a 1-7 ra u o i3 b /,to 14 ; 11 12 13 Ft-,N 13 15 11joa 13 16rti 17 j'�''t aim �\,i0 D 00-a i3 U. t,io $.t�ti .�.o .. �,�a. -f s . b ��. LM9 Ll 4 10. .. 18 19 20 PPO ijilp tanLLL 21 ft,5 t�tp ilkcw jp IZ I'l O b!4 CID 22 M+ T30 -74. f 3 23 Y) kjDW pol -a 24 FtA i 16b a..a 3 t 4 .9 0 11 b KQ ! 5 c /o 4", 25 26 27 alto '.lL 15o 1t. 28 1-7 c10 29 I'm V&56s oo L-1 30 M cD 1'7 31 0 w CD P N CJ1 N 0 0 m ppppppp NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary May 15, 2009 Mr. Mark Morgan Tietex Interiors — Williamsburg Plant 5928 NC Highway 87 North Gibsonville, NC 27249 SUBJECT: Compliance Evaluation Inspection — NPDES Permit No. NCO001384 Tietex Interiors: Williamsburg Plant WWTP — Caswell County Dear Mr. Morgan: Jenny Graznak of this office performed a Compliance Evaluation Inspection of the wastewater treatment facility at Tietex Interiors — Williamsburg Plant wastewater treatment plant in Caswell County on May 13, 2009. Patrick Merritt (ORC) was present for the inspection. This type of inspection consists of two basic parts: an in -office review of facility files and self - monitoring data and an, on -site inspection of the facility. This particular inspection evaluated nine (9) areas, and observations from each area are addressed below: 1. Permit The new permit became effective July 1, 2006 and expires May 31, 2011. 2. Self -Monitoring Program A review of the monthly self -monitoring reports from March 2008 through February 2009 showed one violation of the daily Fecal Coliform limit in October 2008. This violation was assessed through prior correspondence from our office. 3. Laboratory Meritech, Inc. manages all wastewater analysis for the treatment plant. Field parameter lab certification number for Meritech, Inc. is 165. ORC Patrick Merritt performs the following field parameter tests at this facility: temperature, pH, dissolved oxygen, and total residual chlorine. 4. Flow Measurement Weekly effluent flow is estimated in gallons per minute at weir in the effluent trough. 5. Facility Site Review The plant includes an aeration basin, a secondary clarifier, digester, tablet chlorination, and step aeration at the effluent. The aeration basin has two blowers. The chlorinator has four (4) tubes. This permit includes a new limit for Total Residual Chlorine (TRC). The new TRC limit is 17 micrograms/liter (0.017 milligrams/liter) and took effect on December 1, 2007. Therefore, a dechlorination system was installed at the facility. The system has two tubes, which requires sodium sulfite tablets. Dechlorination equipment has not been added to the Outfalls 002 and 003 because testing determined that the effluent meets the chlorine limit requirements already. North Carolina Division of Water Quality, Winston-Salem Regional Office Location: 585 Waughtown St Winston-Salem, North Carolina 27107 Phone: 336-771-50001 FAX: 336-771.46301 Customer Service:1-877-623-6748 Internet: www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer NorthCarolina Naturally 6. Operations & Maintenance The sidewalls in of the clarifier need to be routinely cleaned to avoid sludge buildup, which could inhibit proper settling of sludge. Actual flow at the plant is still well below the permitted flow due to minimal activity at the facility. Ms. Graznak noted that herbicides have been used around the plant and also at the small creek where the effluent is discharged. Spraying herbicides so close to a wastewater treatment plant could have an ill effect on the plant processes. You should take great care when using herbicides and pesticides around surface waters. Excessive use of such treatments in and around a stream could lead to a violation of water quality standards. Please replay this information to your lawn maintenance staff. 7. Records/Reports The Discharge Monitoring Reports (DMRs), files, and lab data are maintained according to the permit. A copy of this data was available for review during the inspection. A daily operators log is maintained by the ORC. Staff from Tietex are responsible for electrical and mechanical maintenance at the plant, including motors, oil, filters, compressor, and bearings. A record of this maintenance work, performed on a monthly basis, is kept in the shed inside the plant fence. 8. Effluent/Receiving Waters The effluent is discharged into unnamed tributaries to Buttermilk Creek and Grays Branch .(WS- II, NSW) in the Cape Fear River Basin. The effluent appeared clear with no traceable solids. Upstream sample is collected 50 feet upstream of discharge, and downstream sample is collected 50 feet downstream of discharge - posts mark the exact spots. 9. Sludge Handling Disposal Due to low flow, the operating staff reports that wasting occurs infrequently. Billingsly Septic Tank Service provides sludge disposal. The contents of the sludge digester are transported to City of Greensboro's North Buffalo Wastewater Treatment Plant. No sludge has been removed in the last year due to such low flow at the plant. Please refer to the attached report for further details from the inspection. If you have any questions concerning this report, please contact Ms. Graznak or me at (336) 771-5000. Sincerely, Steve W. Tedder Regional Supervisor Surface Water Protection cc: Patrick Merritt, Meritech, Inc. WSRO — SWP, Central Files — SWP ppppppp— 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 I NI 2 15I 31 NC0001384 111 121 09/05/13 117 18I CI 191 SI 20III Remarks 21111111111111111111111111111111111111111111111116 Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA --------Reserved--------- 67I 169 70131 711 I 721 NJ 73 LU 74 751 I I I I I I 180 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 permit Number) Williamsburg Plant 10:00 AM 09/05/13 06/07/01 Exit Time/Date Permit Expiration Date NC Hwy 87 At NCSR 1100 Rocky Mount NC 27804 11.00 AM 09/05/13 11/05/31 Name(s) of Onsite Representative(s)/Titles(s)/.Phone and Fax Number(s) Other Facility Data Patrick A Merritt/ORC/336-342-4748/ � so Name, Address of Responsible Official/Title/Phone and Fax Number Robert Fariole,PO Box 691 Burlington NC 27215/Plant Contacted Engineer/336-584-1166/ 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 Jennifer F Graznak WSRO WQ//336-771-5000/ Signature of anagement A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 Permit: NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 05/13/2009 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ n n n Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ n n n 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? n n ■ n Is the facility as described in the permit? ■ n n n # Are there any special conditions for the permit? n ■ n n Is access to the plant site restricted to the general public? ■ n n n Is the inspector granted access to all areas for inspection? ■ n n n Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ n n n Is all required information readily available, complete and current? ■ n n n Are all records maintained for 3 years (lab. reg. required 5 years)? ■ n n Cl Are analytical results consistent with data reported on DMRs? ■ n n n Is the chain -of -custody complete? ■ n n n 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? ■ n n n Has the facility submitted its annual compliance report to users and DWQ? ■ 0 n n (If the facility is = or > 5 MGD permitted flow) Do they operate 2417 with a certified operator on each shift? n n ■ n Is the ORC visitation log available and current? ■ n n n Is the ORC certified at grade equal to or higher than the facility classification? ■ n n n Is the backup operator certified at one grade less or greater than the facility classification? ■ n n n Is a copy of the current NPDES permit available on site? ■ n n n Page # 4 ppppppp- Permit: NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 05/13/2009 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? n ■ n n Comment: Mr. Merritt will fax a copy of the latest annual report to DWQ. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? n ■ n n Are the receiving water free of foam other than trace amounts and other debris? ■ n n n If effluent (diffuser pipes are required) are they operating properly? n n ■ n Comment: Ms. Graznak noted that herbicides have been used around the plant and also at the small creek where the effluent is discharged. Spraying herbicides so close to a wastewater treatment plant could have an ill effect on the plant processes. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ ■ 00 Is flow meter calibrated annually? n n ■ n Is the flow meter operational? n n ■ n (If units are separated) Does the chart recorder match the flow meter? n n ■ n Comment: Weekly effluent flow is estimated in gallons per minute at weir in the effluent trough. Aerobic Digester Yes No NA NE Is the capacity adequate? ■ n n n Is the mixing adequate? ■ n n n Is the site free of excessive foaming in the tank? ■ n fl n # Is the odor acceptable? ■ ❑ ❑ ❑ # Is tankage available for properly waste sludge? ■ ❑ ❑ 0 Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual ■ b. Mechanical n Are the bars adequately screening debris? n ■ n n Is the screen free of excessive debris? ■ n n n Is disposal of screening in compliance? ■ ❑ n n Is the unit in good condition? ■ El n ❑ Page # 5 Permit: NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 05/13/2009 Inspection Type: Compliance Evaluation r�__ c•______ V.. IJn NA NF Comment: The bar screen has very wide bars that would not catch small materials. However, ORC noted that very few solids make it in to the plant. Secondary Clarifier 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 % of the sidewall depth) Comment: The sidewalls in of the clarifier need to be routinely cleaned to avoid sludge buildup, which could inhibit proper settling of sludge. Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? 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/1) Comment: De -chlorination Type of system ? Is the feed ratio proportional to chlorine amount (1 to 1)? ■ n n n nn■n ■■nn ■ n n n ■nnn n■nn ■nnn ■nnn ■nnn ■nnn nn■n Ext. Air Diffused ■nnn 0 0 E 0 ■nnn ■ n n n ■nnn n n n ■ nnn■ Yes No NA NE Tablet ■nnn Page # 6 ppppppp- Permit: NCO001384 Owner -Facility: Williamsburg Plant Inspection Date: 05/13/2009 Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE Is storage appropriate for cylinders? ■ n 00 # Is de -chlorination substance stored away from chlorine containers? n ■ n n Comment: Are the tablets the proper size and type? ■ n n n Are tablet de -chlorinators operational? ■ n 00 Number of tubes in use? 2 Comment: Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ n n n Are all other parameters(excluding field parameters) performed by a certified lab? ■ n .❑ n # Is the facility using a contract lab? ■ n n n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ■ n n n Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ■ n n n Incubator (BOD) set to 20.0 degrees.Celsius +/- 1.0 degrees? ■ n n n Comment: Meritech is the contract lab for the facility. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? ■ ❑ n n Are the tablets the proper size and type? ■ n DO Number of tubes in use? 4 Is the level of chlorine residual acceptable? nnn■ Is the contact chamber free of growth, or sludge buildup? ■ n n n Is there chlorine residual prior to de -chlorination? n n n ■ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? nn■0 Is sample collected below all treatment units? ■ n n n Is proper volume collected? ■ n n n Is the tubing clean? n n ■ n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? n n n ■ Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n n n Page # 7 Permit: NC0001384 Owner -Facility: Williamsburg Plant Inspection Date: 05/13/2009 Inspection Type: Compliance Evaluation Effluent Sampling Comment: V-- Ll- W A MU Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? ■ 0 Q ❑ Comment: Page # 8 I A4NNREC�IVEQ N.C, Deot. of?NR ' NCDENR OCT 0 2 2009 North Carolina Department of Environment and Natural Resources Winston-Salem Regional Offime Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Dee Freeman Governor Director Secretary September 25, 2009 Marvin Gaines Tietex Interiors 1305 Graham Street Burlington, North Carolina 27215 Subject: Notification of Jordan Lake Nutrient Requirements NPDES Permit NC0001384 Williamsburg Plant Caswell County Dear Mr. Gaines: Governor Bev Perdue recently signed legislation to complete passage of rules for the Jordan Lake Nutrient Management Strategy. The Strategy includes a Wastewater Discharge rule (T15A NCAC 02B .0270) that applies to your wastewater treatment facility. Pursuant to Sub -Item (6)(d) of the rule, I am writing to notify you of the nutrient allocations assigned to your facility. This letter addresses only certain provisions of the Jordan Lake Wastewater Discharge rule. I encourage you to familiarize yourself with the remainder of this rule. Nutrient Allocations. The Wastewater Discharge rule establishes the maximum loads of nitrogen and phosphorus that can be released from wastewater treatment facilities into the Jordan Lake watershed. The rule provides that these wasteload allocations are to be divided among the existing facilities in proportion to (with specific exceptions) their 2001 permitted flows. It also provides that facilities permitted to discharge 100,000 gpd or more are to receive nitrogen and phosphorus limits equivalent to their individual allocations. Your facility has been assigned nitrogen and phosphorus allocations. The allocations are expressed as annual mass loadings delivered to the lake. Due to foreseeable losses between the discharge point and the lake, they are also expressed as the equivalent discharge loads at the point of discharge. The delivered and the corresponding discharge allocations assigned to your facility are as follows: NC0001384 Delivered Allocation (lb/yr) Transport Factor (%) Discharge Allocation (lb/yr) Total Nitrogen 438 48 913 Total Phosphorus 72 47 152 2001 Permitted Flow: 0.025 MGD 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Location: 512 N. Salisbury St. Ralegh, North Carolina 27604 One Phone: 919-807-6300 \ FAX: 919.807-6492 \ Customer Service:1-877-623-6748 NorthCarol.ina Internet: www.ncwaterqualiiy.org � //� 4n Equal Opportunity \ Affirmative Action Employer � �/ '}�?�tii[/Nl Marvin Gaines Notification of Jordan Lake Nutrient Requirements September 25, 2009 Nutrient Limits. Your facility will not receive new nutrient limits at this time. However, any nutrient limits already in your NPDES permit will remain in effect. If the facilities permitted for less than 100,000 gpd, as a group, approach their allocations for nitrogen or phosphorus, the Division will consider whether nutrient limits are necessary to protect water quality at that time. In the event that nutrient limits become necessary, the limits would equal your facility's discharge allocations. Nutrient Trading. The rule provides that, when one utility connects to another, the allocations held by the closing facility are transferred to the remaining facility. The rule also provides for the trading of allocations among dischargers within each of the major Jordan subwatersheds. Be sure to consult with the Division's NPDES staff before you consider selling allocation: transactions can have profound implications for your facility and its permit. If you have any questions regarding these allocations, please contact me at (919) 807-6402 or at mike. templeton@ncdenr.gov. Sincerely, / \ Coleen H. Sullins cc: Mark Morgan - Tietex Interiors, 2928 Hwy 87 N, Gibsonville, NC 27249 Winston-Salem Regional Office NDPES Files Central Files K RECEIVED N.C. Deot of HNR MAY 19 2009 1 t'� MERITE Cff,--iNC- ENVIRONMENTAL LABORATORIES A Division of Water Technology and Controls, Inc. 'ED Annual Performance Repo 15 2ppg Tietex Williamsburg WWTP MAC Year January 1, — December 31, 2008 DEN?' , WA CE B CN P MAI 50v0 I. General Information Facility/System Name: Responsible Entity: Person in Charge/Contact: Applicable Permit(s): Tietex Industries Williamsburg WWTP Mark Morgan 5928 Highway 87 N Gibsonville NC 27320 Mark Morgan WWTP NC0001384 Description of Collection System or Treatment Process: A Grade II Wastewater treatment plant consisting of bar screen, activated sludge basin, clarifier and chlorination systems treats waste that is collected throughout by a collection system. II. Performance Text Summary of System Performance for Year 2008 The systems operated with no bypasses or system overflows during this period. Office: 106-A South Walnut Circle P.O. Box 8808 Greensboro, NC 27419 (336) 852-0802 Laboratory: 642 Tamco Road Reidsville, NC 27320 (336) 342-4748 FP The Following Violations Occurred During 2008. October, Fecal Coliform Daily Violation. Notification A copy of this report will be made available to all system users. III. Certification I certify under penalty of law that this report is complete and accurate to the best of my knowledge. I further certify that this report has been made available to the users or customers of the named system and that those users have been notified of its availability. /V &�Mi Responsible Pers n: n"J' /' y" Title: 5-//�oq Date: Office: 106-A South Walnut Circle P.O. Box 8808 Greensboro, NC 27419 (336) 852-0802 Laboratory: 642 Tamco Road Reidsville, NC 27320 (336) 342-4748 PP-072 W AT �9pG Ir'1 >_ 1 L.J_W` =I January 20, 2009 Mr. Mark Morgan Tietex Interiors —Williamsburg Plant 5928 NC Highway 87 North Gibsonville, NC 27249 Subject: NOTICE OF VIOLATION — Effluent Limitations NPDES Permit No. NC 0001384 Tietex Interiors: Williamsburg Plant WWTP Caswell County Dear Mr. Morgan: Beverly Eaves Perdue, Governor Dee Freeman, Secretary North Carolina Department of Environment and Natural Resources Coleen Sullins, Director Division of Water Quality A review of the self -monitoring report for the month of October 2008 revealed the following violation of permit limits: Parameter Date Limit Value Reported Value Limit Type Fecal coliform 10/29/2008 400 # / 100 ml 760 # / 100 ml Daily Limit Remedial actions, if not already implemented, should be taken to correct the above noncompliance problem. Please be aware that violations of your NPDES permit could subject you to enforcement action by this Division with the possible assessment of civil penalties of up to $25,000 per day per violation. Should you have any questions, please contact Jenny Graznak or me at (336) 771-5000. Sincerely, Steve W. Tedder Regional Supervisor Surface Water Protection Section cc: Central Files — SWP WSRO — SWP Noe Carolina ;Vaturalibl North Carolina Division of Water Quality 585 Waughtown Street Winston Salem, NC 27107 Phone (336) 771-5000 Customer Service Internet: hltp://h2o.enr.state.nc.us FAX (336) 771-4630 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Ppr Cover Sheet from Staff Member to Regional Supervisor DMR Review Record Q Facility:QS Permit/Pipe No.:�`f Month/Year. Monthly Average Violations Parameter Permit Limit DMR Value % Over Limit Weekl ail Violations Date 10 Z�j Parameter Permit Limit/Tv e Ib0 r�_ DMR Value % Over Limit Monitoring Frequency Violations Date Parameter Permit Frequencv Values Reported # of Violations Other Violatio s N� Uiora--hey s in Las-f Ia} wvys Completed by: Date: Z° d Regional Water Q lity Supervisor Signoff: Date: MONITORING REPORT(MR) VIOLATIONS for: Report Date: 01/16/09 Page. 1 of 7 Permit: % MRs Between: 10-2008 and 10-2008 Region: Winston-Salem Violation Category: Limit Violation Program Category: NPDES WW Facility Name: % Param Name: % County: % Subbasin: % Violation Action: None Major Minor: % PERMIT: NC0001384 FACILITY: Tietex Interiors - Williamsburg Plant COUNTY: Caswell REGION: Winston-Salem Limit Violation MONITORING OUTFALL / VIOLATION UNIT OF CALCULATED REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE VIOLATION TYPE VIOLATION ACTION 10-2008 001 Effluent Coliform, Fecal MF, M-FC 10/29/08 Weekly #/loom] 400 760 Daily Maximum Exceeded None Broth,44.5C PERMIT: NCO055786 FACILITY: City of Lexington - Lexington Regional WWTP COUNTY: Davidson REGION: Winston-Salem Limit Violation MONITORING OUTFALL / VIOLATION UNIT OF CALCULATED REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE VIOLATION TYPE VIOLATION ACTION 10 -2008 001 Effluent BOD, 5-Day (20 Deg. C) 10/31/08 5 X week mg/I 5 5.61 Monthly Average Exceeded None PERMIT: NCO059536 FACILITY: Hilltop Living Center - Hilltop Living Center COUNTY: Davidson REGION: Winston-Salem Limit Violation MONITORING OUTFALL / VIOLATION UNIT OF CALCULATED REPORT PPI LOCATION PARAMETER DATE FREQUENCY MEASURE LIMIT VALUE VIOLATION TYPE VIOLATION ACTION 10 -2008 001 Effluent Nitrogen, Ammonia Total (as 10/31/08 2 X month mg/I 2 3.59 Monthly Average Exceeded None W Arrcod K-W&T T �RQG Mr. Mark Morgan Tietex International, Inc. 5928 Hwy 87 Gibsonville, North Carolina 28249 Dear Mr. Morgan: ?OY Michael F. Easley, Governor William G. Ross Jr., Secretary North Carolina Department of Environment and Natural Resources Coleen H. Sullins, Director Division of Water Quality October 29, 2007 RECEIVED N.C. Dent. of ENR NOV 0 2 2W Winston-Salem Reglcnal Off"ce SUBJECT: Authorization to Construct A to C No. 001384AOI Tietex International, Inc. Williamsburg Plant WWTP Dechlorination Facilities Caswell County A fast track application for Authorization to Construct dechlorination facilities was received on October 26, 2007, by the Division. Authorization is hereby granted for the construction of modifications to the existing Williamsburg Plant WWTP, with discharge of treated wastewater effluent into unnamed tributary to Buttermilk Creek in the Cape Fear River Basin. This authorization results in no increase in design or permitted capacity and is awarded for the construction of the following specific modifications: Installation of a dechlorination system utilizing sodium sulfite pursuant to the fast track application received on October 26, 2007, and in conformity with the Minimum Design Criteria for Dechlorination Facilities. This Authorization to Construct is issued in accordance with Part III, Paragraph A of NPDES Permit No. NC0001384 issued June 5, 2006, and shall be subject to revocation unless the wastewater treatment facilities are constructed in accordance with the conditions and limitations specified in Permit No. NC0001384. In the event that the facilities fail to perform satisfactorily, including the creation of nuisance conditions, the Permittee shall take immediate corrective action, including those as may be required by this Division, such as the construction of additional or replacement wastewater treatment or disposal facilities. The Winston-Salem Regional Office, telephone number (336) 771-5000 shall be notified at least forty-eight (48) hours in advance of operation of the installed facilities so that an on site Nye Carolina Atura!!y North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: www.ncwateraualitv.org 512 N. Salisbury St. Raleigh, NC 27604 FAX (919) 733-2496 1-877-623-6748 An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper Mr. Morgan October 29, 2007 Page 2 inspection can be made. Such notification to the regional supervisor shall be made during the normal office hours from 8:00 a.m. until 5:00 p.m. on Monday through Friday, excluding State Holidays. Pursuant to 15A NCAC 2H .0140, upon completion of construction and prior to operation of these permitted facilities, the completed Engineering Certification form attached to this permit shall be submitted to the address provided on the form. Upon classification of the facility by the Certification Commission, the Permittee shall employ a certified wastewater treatment plant operator to be in responsible charge (ORC) of the wastewater treatment facilities. The operator must hold a certificate of the type and grade at least equivalent to or greater than the classification assigned to the wastewater treatment facilities by the Certification Commission. The Permittee must also employ a certified back-up operator of the appropriate type and grade to comply with the conditions of T15A:8G.0202. The ORC of the facility must visit each Class I facility at least weekly and each Class 11, HI and IV facility at least daily, excluding weekends and holidays, must properly manage the facility, must document daily operation and maintenance of the facility, and must comply with all other conditions of T I5A:8G.0202. A copy of the approved plans and specifications shall be maintained on file by the Permittee for the life of the facility. During the construction of the proposed additions/modifications, the pennittee shall continue to properly maintain and operate the existing wastewater treatment facilities at all times, and in such a manner, as necessary to comply with the effluent limits specified in the NPDES Permit. You are reminded that it is mandatory for the project to be constructed in accordance with the North Carolina Sedimentation Pollution Control Act, and, when applicable, the North Carolina Dam Safety Act. In addition, the specifications must clearly state what the contractor's responsibilities shall be in complying with these Acts. Prior to entering into any contract(s) for construction, the recipient must have obtained all applicable permits from the State. Failure to abide by the requirements contained in this Authorization to Construct may subject the Permittee to an enforcement action by the Division of Water Quality in accordance with North Carolina General Statute 143-215.6A to 143-215.6C. The issuance of this Authorization to Construct does not preclude the Permittee from complying with any and all statutes, rules, regulations, or ordinances which may be imposed by other government agencies (local, state, and federal) which have jurisdiction. 11 Mr. Morgan October 29, 2007 Page 3 If you have any questions or need additional information, please do not hesitate to contact Cecil G. Madden, Jr., P.E. at telephone number (919) 715-6203. Sincerely, FcZ Col en H. Sullins AR/cgm cc: Gary S. MacConnell, P.E., MacConnell & Associates, P.C., Morrisville Caswell County Health Department DWQ Winston-Salem Regional Office, Surface Water Protection Technical Assistance and Certification Unit Daniel Blaisdell, P.E. Point Source Branch, NPDES Program Cecil G. Madden, Jr., P.E. Anita Reed, E.I. ATC File Tietex International, Inc. A To C No. 001384A01 Issued October 29, 2007 Engineer's Certification I, , as a duly registered Professional Engineer in the State of North Carolina, having been authorized to observe (periodically/weekly/full time) the construction of the modifications and improvements to the Williamsburg Plant WWTP, located on Hwy 87 in Caswell County for Tietex International, Inc., hereby state that, to the best of my abilities, due care and diligence was used in the observation of the following construction: Installation of a dechlorination system utilizing sodium sulfite pursuant to the fast track application received on October 26, 2007, and in conformity with the Minimum Design Criteria for Dechlorination Facilities. I certify that the construction of the above referenced project was observed to be built within substantial compliance and intent of the approved plans and specifications. Signature Date Registration Send to: Construction Grants & Loans DENR/DWQ 1633 Mail Service Center Raleigh, NC 27699-1633 cc: Charles Weaver, NPDES Unit Central Files WSRO SOC PRIORITY PROJECT: Yes No X If Yes, SOC No. To: Permits and Engineering Unit Surface Water Protection Section Attention: Bob Guerra Date: November 3, 2005 NPDES STAFF REPORT AND RECOMMENDATION Caswell County Permit No. NC0001384 PART I - GENERAL INFORMATION 1. Facility and Address: Tietex Interiors - Williamsburg Plant (formerly Burlington Industries LLC - Williamsburg Plant) 5928 NC Highway 87 North Gibsonville, NC 27249 2. Date of Investigation: October 28, 2005 3. Report Prepared by: Jenny Freeman 4. Persons Contacted and Telephone Number: Patrick Merritt, ORC - Meritech, Inc. Phone: (336) 342-4748 S. Directions to Site: From Burlington travel Highway 87 North into Caswell County. The plant is located on the right side of the road just past the Caswell County line at the intersection of NC 87 and Kerr's Chapel Road. 6. Discharge Point(s), List for all discharge points: Latitude: 36 05' 18" Longitude:79 30' 58" U.S.G.S. Quad No. B20SE U.S.G.S. Quad Name Williamsbur 7. Site size and expansion area consistent with application? X Yes No If No, explain: P-9 0 10 Topography (relationship to flood plain included): Located above the flood plain. Location of nearest dwelling: >1000 feet Receiving stream or affected surface waters: UT to Buttermilk Creek. a. Classification: WS-II, NSW b. River Basin and Subbasin No.: 03-06-02 C. Describe receiving stream features and pertinent downstream uses: Agricultural/Residential Part II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. r a. Volume of Wastewater to be permitted: 0.025 MGD b. What is the current permitted capacity of the Waste Water Treatment facility? 0.025 MGD C. Actual treatment capacity of the current facility? 0.025 MGD d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years. N/A e. Please provide a description of existing or substantially constructed wastewater treatment facilities: Bar screen, aeration basin, clarifier, tablet chlorination with contact chamber, sludge digester, and step aeration. f. Please provide a description of proposed wastewater treatment facilities. N/A g. Possible toxic impacts to surface waters: Unknown h. Pretreatment Program (POTWs only): N/A in development approved should be required not needed X Residuals handling and utilization/disposal scheme: a. If residuals are being land applied, please specify DEM Permit No. Residuals Contractor NPDES Permit Staff Report Telephone No. b. Residuals stabilization: PSRP PFRP Other c. Landfill: d. Other disposal/utilization scheme: Sludge removed by Busick Septic Tank Service and transported to City of Greensboro N. Buffalo WWTP. 3. Treatment plant classification (attach completed rating sheet). Class II 4. SIC Code(s): 2221 Primary: 01 (Domestic) Secondary: 02 (Industry) Main Treatment Unit Code: 0 5 0 X 7 PART III - OTHER PERTINENT INFORMATION 1. Is this facility being constructed with Construction Grant Funds or are any public monies involved. (municipals only)? N/A 2. Special monitoring or limitations (including toxicity) requests: N/A 3. Important SOC, JOC or Compliance Schedule dates: (Please indicate) N/A n -. 4- Submission of Plans and Specifications Begin Construction Complete Construction 4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available. Please provide regional perspective for each option evaluated. Spray Irrigation: N/A Connection to Regional Sewer System: N/A Subsurface: N/A Other disposal options: N/A "NN NPDES Permit Staff Report 5. Other Special Items: PART IV - EVALUATION AND RECOMbENDATIONS Note the name change from Burlington Industries to Tietex Interiors. Treatment system is a small package plant with aging parts. The plant discharges into a small dry ditch on the company's property. WSRO recommends reissuance of this permit in accordance with Division policy. Regional staff Regional Supervisor Ic p— Date / 3�os Date 0 9 31' 0.0 7 ' 1' 0. 0' 0.0 " 7 ° 0' 0. 0' Name: WILLIAMSBURG Location: 036° 15' 15.89" N 079° 30' 44.52" W Date: 10/28/2005 Caption: NC0001384 Tietex Interiors (Burlington Ind.) WWTP Discharge Scale: 1 inch equals 1333 feet (C) 1998, Maptech, Inc. LFIVIn IRCVIUVV Recoru Facility;1 1 e Permit No.: WC OO f�, y Pipe No.. Month/Year: - _) Monthly Ayerage Violations Parameter Permit Limit DMR Value % Over Limit Action Weekly/Daily Violations Date Parameter ( Permit Limit Limit Type �111 I wt DMR Value % Over Limit Action Monitoring Frequency Violations Date Parameter Permit Frequency Values Reported # of Violations Action Violations/Staff Remarks: C Lk Supervisor Remarks: l wV NOV— X 15_ LU U519 Completed by: J P_l/,- Assistant Regional Supervisor Sign Off: Regional Supervisor Sign Off: Date: S' Z I Date: Date: Cover Sheet from Staff Member to Regional Supervisor DMR Review Record Facility. Permit/Pipe No.: i 66001� Month/Year ro U 2 D Monthly Average Violations Parameter Permit Limit DMR Value % Over Limit Weekly6;�Violations Date Parameter Permit LimitlTvpe DMR Value % Over Limit 11 o (--CC'a 400 Illoo mL 020 o Monitoring Frequency Violations Date Parameter Permit Frequency Values Reported # of Violations Other Violations Z4 51 !2 /y7O44 6. yoy 0?0 I ( / 1 U N fo r) 'h 4 A I r q?Ula / In (w 1, � U r, 11 Completed by: �G' �' �' Date: / 13 Regional Water Quality 3 Supervisor Sianoff: Date: ��U Cover Sheet from t4 0 D— 20 IZ — �� QO Staff Member to Regional Supervisor DNIR Review Record Facility 6rt�' Permit/Pipe No.: A1,'000 U 9l Month/Year Vc h 2042 Monthly Average Violations Parameter Permit Limit DMR Value % Over Limit Date Parameter s DMR Value % Over Limit Monitoring Frequency Violations Weekly/Daily Violation Permit Lirnitll'vpe Date Parameter Permit Frequency Values Reported # of Violations Other Violations !L No e/IGr&~tr NO Vs , �u a � S!,� aoll NOD N'o(f � ? 0 ) I �lh ran 1 P, 00 A 11f 00-7 � Old 3 Completed by: jrr',L°w Date: 2/z -7 �/ Regional Water Quality Supervisor Signoff: Date: �YL Cover Sheet from 1 Staff Member to Regional Supervisor D:NZR Review Record Facility* Pem� t[Pipe No.: 13 Month/Year 1--- Monthly Average Violations Permit Limit —D Value %Over Limit parameter --------- Weekly/Daily Violations Date Parameter Permit L'imitlCvpe DMR_ 010Over Limit Monitoring Frequency Violations Date Parameter Permit Freauencv Values Rep rted # of Violations cam-- -� Other Violations A'�',Vibus I2 m v h s � ��ll �b c�ri7 � r/l�ct✓ �/I Nov5 -6 (�h& cry `�s Vt6iCti�tl lVJ CQ/h�°I' 11. Date: Completed by: Regional Water Quality Date: Super\'isor Signoff: 1` Cover Sheet from N OV -dO j' — MV _v00" Staff Member to Regional Supervisor DMR Review Record Facility: /L �CX / U� Permit[Pipe No.: C VOL3 Month/Year 02011 Monthly Average Violations Parameter Pemvt Limit DMR Value % Over Limit Date Parameter Date Parameter Weekly/Daily Violations Permit LimitlTvDe DMR Value % Over Limit Monitoring Frequency Violations Values Reported # of Violations Other Violas ons ©�2 S 8 / aS� �� %yl((Y� S� (Cc J CpI� Date: 0Z�7�Ll Completed by: y� Regional Water Quality Date: Super\7isor Signoff: JG� NCover Sheet from Staff Member to Regional Supervisor MIR Review Record 333 Facility: �� { Bch T �r t�' PermitfPipe No.: Ivy DD ° �% Month/Year Monthly Average Violations Parameter Permit Limit DMR Value % Over Limit Weekly/Daily Violations Date Parameter Permit LimitlTvpe DNS Value % Over Limit Monitoring Frequency Violations Date Parameter 6u+ JI, 001 -8 20 TC ott+(W r_ ,er Violations Permit Frequency C . Values Reported # of Violations --_ --� --� LAA V �u Completed by: I � � Date: (� I Regional Water Quality Date: 7-0 1 Supervisor Signoff: ni Cover Sheet from Staff Member to Regional Supervisor D'MR Review Record Facility: f,e- zX` Permit/Pipe No.: W-0001-3 Nlonth/Year Monthly Average Violations Parameter Permit Limit DMR Value Over Limit Weekly/Dally Violations Date Parameter Permit Limitgvpe DMR Value IT Over Limit Monitoring Frequency Violations Date Parameter Permit Frequency Values Reported # of Violations weeJOW Other Violations Completed by: J YZLU1a_�-- Date: Z� f Regional Water Quality L_�% Supervisor SiQnoff: Dater d-- , *40 j 1—" s e en~ December 1, 2010 Mrs. Dina Sprinkle NC DENR / DWQ / Point Source Branch 1617 Mail Service Center Raleigh, NC 27699-1617 Subject: Burlington Technologies — Williamsburg Plant Permit No. NC0001384 — Renewal Application Dear Mrs. Sprinkle: RECEIVED N.C. Dert c"` DEEC 17 2010 Winstcn S, Reofcna.' " _ Burlington Technologies — Williamsburg Plant operates a textile weaving and inspection facility located in Matkins, North Carolina. The facility operates under existing NPDES permit No. NC0001384. This permit is set to expire on May 31, 2011. This cover letter and attached NPDES Permit Application — Short Form C — Minor Industrial serves as the renewal application. Since the last permit, the treatment area has added a tablet dechlorination system. The facility was previously owned by Tietex and was purchased by Burlington Technologies over a year ago. There have been no additions to the facility that would modify the wastewater streams. The facility mainly discharges sanitary wastewater and utility wastewater. The wastewater treatment operation on the sanitary wastewater creates a small amount of sludge. The sludge handled using the following process. The sludge is initially treated on -site using aerobic digestion. Infrequently, every 1 to 2 years, the sludge is removed from the treatment system and shipped off -site for disposal. If you have any questions regarding this renewal application, I can be contacted at (336) 585- 2320. Sincerely, X�< Mark Morgan Plant Manager Williamsburg Plant NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. Mail the complete application to: N. C. Department of Environment and Natural Resources Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 NPDES Permit Number INCO001 M Please print or type. 1. Contact Information: Owner Name Facility Name Mailing Address City State / Zip Code Telephone Number Fax Number e-mail Address Burlington Technologies Williamsburg Plant 5928 Hwy 87 North Gibsonville NC 27249 (336) 585 - 2320 mmorgan@se7enusa.com 2. Location of facility producing discharge: Check here if same as above X❑ Street Address or State Road City State / Zip Code County 3. Operator Information: Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the Operator in Responsible Charge or ORC) Name Meritech Mailing Address 642 Tamco Road City Reidsville State / Zip Code NC 27320 Telephone Number (336) 342 - 4748 Fax Number 4. Ownership Status: Federal ❑ State ❑ Private X❑ Public ❑ Page 1 of 5 C-MI 10/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. S. Standard Industrial Classification (SIC) code(s): 2299 . 2259 6. Number of employees: 54 7. Describe the treatment system List all installed waste treatment components with capacities, describe the processes that generate wastewaters. If the space provided is not sufficient attach a separate sheet of paper with the system description. The facility has three outfalls. Outfall 001 is sanitary waste. This outfall averages 3000 gpd flow and has somewastewater treatment prior to the outfall. The treatment consists of aeration and settling with aerobic sludge digestion. The water then goes through a chlorine disinfection and plus dechlorination stage prior to be release to receiving stream. Outfall 002 consists of air washer blowdown, compressor condensate, compressor cooling tower blowdown and water softener backwash. This outfall averages 3000 gpd flow and has no wastewater treatment. Outfall 003 consists only of cooloing tower blowdown. This outfall averages 2000 gpd and has no wastewater treatment. S. Is facility covered under federal effluent limitation guidelines? No X❑ Yes ❑ If yes, specify the category? 9. Principal product(s) produced: Woven Textiles Principal raw material(s) consumed: Polyester and cotton yarns Briefly describe the manufacturing process(es): Weaving and inspection of textile fabric Page 2 of 5 C-MI 10/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 10. Amount of principal product produced or raw material consumed (List specific amounts consumed and/or units of production over the last three nears) Product Produced or Raw Material Consumed AVERAGE Product Produced or Raw Material Consumed PEAK per Day 5,400 yards 12,000 yards per Month 113,400 yards 252,000 yards per Year 11,360,800 yards 13,024,000 yards 11. Frequency of discharge: Continuous X❑ If intermittent: Days per week discharge occurs: Intermittent ❑ Duration: 12. Types of wastewater discharged to surface waters only Discharge Flow GALLONS PER DAY Sanitary - monthly average 3,000 gal/day Utility water, etc. - monthly average 5,000 gal/day Process water - monthly average 0 Stormwater - monthly average Inc in SW permit Other - monthly average Explain: Monthly Average total discharge (all types) 13. Number of separate discharge points: 3 Outfall Identification number(s) 001,002,003_ 14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including latitude and longitude 001 and 002 to unnamed tributary to Buttermilk Creek 003 to unnamed tributary to Grays Branch Page 3 of 5 C-MI 10/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 15. Effluent Data [for new or proposed discharges] Provide data for the parameters listed. Temperature and pH shall be grab samples, for all other parameters 24-hour composite sampling shall be used. If more than one analysis is reported, report daily maximum and monthly average. If only one analysis is reported, report as daily maximum. NOTE: Permittees requesting renewal should complete the table ONLY for the parameters currently monitored. Summarize the past 3 years of e uent data Parameter Daily Maximum Monthly Average Units of Measurement Biochemical Oxygen Demand (BOD5) 12.1 2.7 milligrams/Liter Chemical Oxygen Demand (COD) - _ _ Total Organic Carbon - _ _ Total Suspended Solids 21 7 milligrams/Liter Ammonia as N 3.9 0.2 milligrams/Liter Temperature (Summer) 26 21 Degree Celsius Temperature (Winter) 17 10 Degree Celsius pH 7.2 6.7 Standard Units Fecal present) hform (If sanitary waste is 760 1 Colonies/ 100ml, Total used Residual Chlorine (if chlorine is 10 10 Micrograms/Liter 16. List all permits, construction approvals and/or applications (check all that apply and provide permit numbers or check none if not applicable): Type Permit Number Type Permit Number Hazardous Waste (RCRA) UIC (SDWA) NPDES i NC0001384 PSD (CAA) Non -attainment program (CAA) NESHAPS (CAA) Ocean Dumping (MPRSA) Dredge or fill (Section 404 or CWA) Other SW NCG 170000 17. List any chemicals that may be discharged (Please list and explain source and potential amounts.) Dechlorinator chemical Sodium Sulfite Page 4 of 5 C-MI 10/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial ` Minor industrial, manufacturing and commercial facilities. 18. Is this facility located on Indian country? (check one) Yes ❑ No X❑ 19. Applicant Certification I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. LAbMri-4 P�Mjf Printed name of Person ftning Title Z Signature of pp icant Date North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) Page 5 of 5 C-MI 10/08 FA +� -W-ME— �r 0 ki Williamsburg Plant WWTP State Grid: Williamsburg Outfall001: Latitude W 1618' N Longitude 79'30' 58' W Permitted Flow: 0.025 MGD Outfall 002, Latitude 3e 15' 19' N Longitude 79*30' 58' W Orainaae Basin: Cape Fear River Basin WWI 003: Latitude 36' IT 27' N Longitude 79� 31' 00' W Sub -Basin: 03-06-02 Strum Class: WSII-NSW Reeehrina Streams: Outlalis 001 / 002 UT to Men* Creek Outfall 003 to UT Grays Branch r Stormwater Outfall Upstream Sampling Point Downstream Sampling Point Facility Location Ador not to scale North NPDES Permit No. NCO0O1384 Caswell County DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0001384 Facility Information Applicant/Facility Name: NC0001384 - Burlington Industries - Williamsburg Plant Applicant Address: Mr. Terry Fripp; P.O. Box 21207, Greensboro, NC 27420 Facility Address: NC Hwy 87; Matkins, NC Permitted Flow 001 - 0.025 MGD; 002 is not limited Type of Waste: 001: Sanitary Wastewater; 002: Air washer blowdown, compressor condensate, compressor cooling tower blowdown, water softener backwash. 003: Cooling tower blowdown Facility/Permit Status: Active; Renewal County: Caswell Miscellaneous Receiving Stream: UT to Buttermilk Creek and Grays Branch Regional Office: Winston-Salem Stream Classification: WSII - NSW State Grid / USGS Quad: B20SE/Williamsbur 303(d) Listed? No Permit Writer: Natalie Sierra Subbasin: 03-06-02 Date: 4/9/01 Drainage Area (mi2): 0.07 ANOW 001: Lat. 360 IS' 18" N Long. 79° 30'58" W 002: Lat. 36° 15' 19" N Long. 79° 30'58" W 003: Lat. 360 15' 27" N Long. 79° 31'W' W Summer 7Q10 (cfs) 0 Winter 7Q10 (cfs): 0 30Q2 (cfs) 0 Average Flow (cfs): 0.075 IWC (%): 100% BACKGROUND The Williamsburg Plant for Burlington Industries weaves yarn into cloth, though no process wastewater is discharged from any of the outfalls. Non -contact cooling water from various parts of the plant is discharged through 002 and 003. Outfall 001 discharges domestic wastewater from the facility after treating it in a package plant system. In 1997, the facility was required to perform an Engineering Alternatives Analysis (EAA) in order to assess the present value cost (PVC) of reducing the impact on the receiving streams, both of which are zero flow streams. After discussions with the Winston-Salem Regional Office (WSRO), it was agreed that the most feasible alternative, an upgrade to the existing treatment plant, would only be implemented if the facility began to have difficult meeting the limits specified by the NPDES permit. FILE REVIEW The renewal application describes the treatment works as follows: 001: Domestic waste treated through a package system consisting of a bar screen, aeration basin, sludge digestiop tablet chlorination system (includes chlorine contact chamber), and step lorinatio 002 and 003: Non -contact cooling water from boilers and compressors treated with sodium thiosulfate as needed. Effluent from 001 and 002 discharges to an unnamed tributary (UT) to Buttermilk Creek. Water form 003 is discharged to an UT to Grays Branch. Fact Sheet NPDES NC000138 4 Renewal Page I DMR Review: DMRs dating from January 1998 to February 2001 were reviewed for all outfalls. Average monthly data for 001 is compiled in Table 1 below. Domestic flow from 001 averaged 0.0059 MGD with a maximum flow of 0.0095 MGD. This flow was less than that of the cooling water discharged through 002, which averaged 0.023 MGD and had a maximum value of 0.0284. Discharge from both 002 and 003 was usually consistent in volume from month to month. Average flow from 003 was 0.0046 with a maximum of 0.01036 MGD. TRC from 002 and 003 is always below detection level. Parameter Average Value Maximum Value Minimum Value Flow (MGD) 0.0059 0.0095 0.0035 Temperature (°C) 20.66 28.9 11.5 TRC (mg/L) 1.37 1.52 1.2 BOD (mg/L) 1.67 3.75 0.0 NH3 N (mg/L) 1.12 10.5 0.03 DO (mg/L) 3.01 11.8 0.33 Total Suspended Residue (mg/L) 7.30 8.8 6.0 Total Nitrogen (mg/L) 24.47 42.5 3.0 Total Phosphorus (mg/L) 6.88 24.4 2.43 Table 1 Summary of monthly average data for outfall 001. Data culled from DMRs dating from January 1998 to February 2001 Instream Data Review The impact of the domestic waste discharge from 001 is assessed through instream monitoring of temperature, DO, fecal coliform and conductivity. Upstream/Downstream data for the upper tributary to Buttermilk Creek is summarized in Table 2. There was only one occasion on which the discharge caused a violation of the instream DO standard. No flow was recorded upstream of the 002 discharge. Temperature data was recorded for flow upstream and downstream of 003. The average change in temperature between the upstream and downstream portions of the stream was 2.10C. Parameter Average Average Percent Change Upstream Downstream (D - U/D) * 100 Value Value Temperature (°C) 21.73 19.11 -13.71 Dissolved Oxygen 7.61 8.10 6.05 (mg/l-) Fecal Coliform 200.67 31.97 - 5.28 (#/100) Conductivity 953.13 714.34 - 33.42 Reasonable Potential Analysis: Reasonable Potential Analysis was not appropriate for any of the pollutants monitored through this permit. Correspondence Fact sheet \I'D S N00001384 Renewal Page 2 Compliance EV___1tion Inspections have been con(_ ed annually from 1996- 2000. During this time, the facility received some NOVs for failure to report certain parameters as specified in the NPDES permit. The facility is otherwise reported as well operated and maintained. In 2000, the facility received two NOVs. The first, given in August of 2000, was assessed for violation of the permit monthly limits for ammonia nitrogen. A civil penalty of $1056 was paid. The second violation was assessed in October 2000 for violation of the ammonia nitrogen monthly limit and two failures to monitor BOD. The $1, 167 fine was paid. PERMITTING STRATEGY 1997 correspondence from the facility and recent discussions with the WSRO indicate that the facility will not yet be required to implement any of the upgrades specified by the 12/97 EAA. Waste Load Allocation (WLA). The last waste load allocation was performed in 1992. It indicates that the only positive flow measurement is the average flow - 0.075-cfs. BOD, ammonia nitrogen, DO, TSS, fecal coliform are all limited. Monitoring requirements are recommended for temperature, total phosphorus, total nitrogen and temperature. Zero Flow Policy As per NPDES policy, the facility was required to perform an EAA during the last permitting cycle. They were also given NH3-N limits of 2 mg/L for summer and 4 mg/L for winter. Unless the facility begins to violate the stream DO standard, more stringent BOD limits will not be implemented. The current limits on BOD and TSR are 30/30. Note: The permittee should be alerted via cover letter that failure to meet NPDES permit requirements will result in re -opening of the permit and action towards implementation of the findings of the EAR. SUMMARY OF PROPOSED CHANGES A review of the instream data for the facility at the current monitoring locations indicates that the discharge may not have much impact in terms of oxygen consuming wastes. The impact of the effluent with respect to nutrient loading of the receiving stream is unclear. The receiving streams are likely to be impacted by non -point sources (the 2000 basin plan for the Cape Fear River Basin indicates that approximately 35% of nutrient loading in the basin is due to non -point sources). Although this discharge is small with average nutrient loadings to the receiving stream, we may wish to alert them to the fact that the receiving waters are NSW and in the future, limits may be imposed. Otherwise, no changes to the existing permit are proposed. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: Permit Scheduled to Issue: NPDES DIVISION CONTACT April 25, 2001 June 8, 2001 If you have questions regarding any of the above information or on the attached permit, please contact Natalie Sierra at (919) 733-5083 ext. 551. NAME: DATE: I��ic� tihc�t NCY)001 ,84 Rcnc\vad N 1-c . REGIONAL OFFICE COMMENTS NAME: DATE: SUPERVISOR: DATE: I a�i Sli��t ,70, W T �RQ C r 5 -i O Niii� 'C Mr. Terry Fripp Burlington Industries, Inc. PO Box 21207 Greensboro, North Carolina Dear Mr. Fripp: Michael F. Easley Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Kerr T. Stevens, Director Division of Water Quality April 18, 2001 Subject: Draft NPDES Permit Permit NC0001384 Williamsburg Plant Caswell County Enclosed with this letter is a copy of the draft NPDES permit for the above referenced facility. I encourage you to review the draft carefully to ensure thorough understanding of the information, conditions, and requirements contained therein. Please note that the receiving streams (Buttermilk Creek and Grays Branch) to which your facility discharges are classified "nutrient sensitive." Although the current permit requires monitoring of nutrients only, the Division of Water Quality (Division) reserves the right to reopen your permit at any time to impose nutrient limits on the effluent. You should also be aware of the potential discharge requirements for your facility as a result of House Bill 515. In 1997 the Clean Water Responsibility Act (House Bill 515) was enacted, with the intent to strengthen the control of nutrients from all discharges to NSW waters. Facilities permitted to discharge greater than 500,000 gallons per day, and any new or expanding facilities, will be subject to nutrient limitations for total nitrogen and total phosphorus according to House Bill 515 requirements. Since modifications to treatment systems are expensive and time consuming, it is highly recommended that you begin planning for this possibility now if a future expansion is anticipated. Your facility has also recently received two Notices of Violations (NOVs) for failure to meet the permit requirements. Although you have not been required to implement any plant upgrades as per the December 1997 EAA performed for you facility, continued failure to comply with the NPDES permit requirements may result in forced implementation of the such upgrades. As regards your Discharge Monitoring Reports (DMRs), please note that reporting "0" for a total residual chlorine (TRC) value is not acceptable. If laboratory analyses indicate non -detection of TRC, you must report it as "<" followed by the detection level for that analysis. Please submit any comments or questions concerning this draft permit no later than N. C. Division of Water Quality / NPDES Unit Phone: (919) 733-5083 1617 Mail Service Center, Raleigh, NC 27699-1617 fax: (919) 733-0719 Internet: h2o.enr.state. nc.us DENR Customer Service Center: 1 800 623-7748 thirty (30) days following receipt of this letter. Comments should be sent to: Ms. Natalie Sierra NCDENR - DWQ -NPDES Unit 1621 Mail Service Center Raleigh, North Carolina 27699-1617 If you have any questions or comments concerning this draft permit, please contact me at 919-733-5083 extension 551 or via e-mail at: Natalie.Sierra@ncmail.net. Sincerely, Natalie V. Sierra NPDES Unit cc: Winston-Salem Regional Office/Water Quality Section NPDES Unit NC-DEH PPPPFP' Permit NC0001384 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Burlington Industries, Inc. is hereby authorized to discharge wastewater from a facility located at the Burlington Industries Williamsburg Plant Intersection of NC Highway 87 and NCSR 1100 Matkins Caswell County to receiving waters designated as unnamed tributaries to Buttermilk Creek and Grays Branch in the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective July 1, 2001. This permit and authorization to discharge shall expire at midnight on May 31, 2006. Signed this day Kerr T. Stevens, Director Division of Water Quality By Authority of the Environmental Management Commission Permit NC0001384 SUPPLEMENT TO PERMIT COVER SHEET Burlington Industries, Inc. is hereby authorized to: 1. Continue to discharge wastewater from outfalls 001, 002, and 003. The discharge of treated domestic wastewater occurs from outfall 001 and requires operation of an existing 0.025 MGD package treatment facility consisting of a bar screen, aeration basin, integral sludge digester, clarifier, tablet chlorination, contact chamber, step aeration and sludge thickener/digester. Wastewater discharged from 002 consists of air washer blowdown, compressor condensate, compressor cooling tower blowdown and water softener backwash. The discharge from 003 consists of cooling tower blowdown. All outfalls discharge from facilities located at Burlington Industries, Inc., Williamsburg Plant, intersection of NC Hwy 87 and NCSR 1100, Matkins, Caswell County, and 2. Discharge from said treatment works at the location specified on the attached map into unnamed tributaries to Buttermilk Creek and Grays Branch, which are both classified WSII-NSW waters in the Cape Fear River Basin. Permit NC0001384 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - DRAFT During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from outfall 001 - DOMESTIC WASTEWATER. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement F uenc Sample Type Sample Location' Flow 0.025 MGD Weekly Instantaneous Influent or Effluent BOD5 — 20oC 30.0 m L 45.0 m L Weekly Grab Effluent Total Suspended Residue 30.0 m L 45.0 m L Weekly Grab Effluent NH3-N (April 1— October 31 2.0 m L Weekly Grab Effluent NH3-N November 1— March 31 4.0 m L Weekly Grab Effluent Temperature (°C) Weekly Grab Upstream, Downstream Temperature °C Daily Grab Effluent Dissolved Oxygen2 Weekly Grab Effluent, Upstream, Downstream Fecal Coliform (geometric mean) 200/100mL 400/100mL Weekly Grab Effluent, Upstream, Downstream Total Residual Chlorine 2/Week Grab Effluent Conductivity Weekly Grab Effluent, Upstream, Downstream Total Nitrogen NO2 + NO3 + TKN Quarterly Grab Effluent Total Phosphorus Quarterly Grab Effluent The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored weekly at the effluent by grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. 1 Sample Locations: Upstream - Upstream 50 feet from outfall, Downstream - Downstream 50 feet from outfall. 2 The daily average dissolved oxygen effluent concentration shall not be less than 6.0 mg/L. Permit NC0001384 A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - DRAFT During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from outfall 002 - AIR WASHER BLOWDOWN, COMPRESSOR CONDENSATE, COMPRESSOR COOLING TOWER BLOWDOWN AND WATER SOFTENER BACKWASH. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT LIMITS MONITORING REQUIREMENTS CHARACTERISTICS Monthly Average Daily Maximum Measurement Sample Type Sample Frequency Location' Flow Monthly Instantaneous Effluent Temperature, OV Monthly Grab Effluent, Upstream, Downstream Total Residual Chlorine' Monthly Grab Effluent THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE COOLING WATER EXCEPT AS PRE APPROVED ADDITIVES TO BIOCIDAL COMPOUNDS The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored monthly by grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. ' The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.80C and in no case cause the ambient water temperature to exceed 32°C. 2 Monitoring requirements only apply if chlorine is added to the treatment system. The permittee shall obtain authorization from the Division of Water Quality prior to utilizing any biocide in the cooling water. Permit NC0001384 A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - DRAFT During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge from outfall 003 - COOLING TOWER BLOWDOWN. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Monthly Avers a Daily Maximum Measurement Frequency Sample Type Sample Location Flow Monthly Instantaneous Effluent Temperature, OCI Monthly Grab Effluent, Upstream Downstream Total Residual Chlorine2 MonthlyGrab Effluent THERE SHALL BE NO CHROMIUM, ZINC, OR COPPER ADDED TO THE COOLING WATER EXCEPT AS PRE -APPROVED ADDITIVES TO BIOCIDAL COMPOUNDS The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored monthly by grab sample. There shall be no discharge of floating solids or visible foam in other than trace amounts. ' The temperature of the effluent shall be such as not to cause an increase in the temperature of the receiving stream of more than 2.80C and in no case cause the ambient water temperature to exceed 32°C. 2 Monitoring requirements only apply if chlorine is added to the treatment system. The permittee shall obtain authorization from the Division of Water Quality prior to utilizing any biocide in the cooling water. Subject: Re: NC0001384 Date: Mon, 09 Apr 2001 15:06:35 -0400 From: Mike Mickey <mike.mickey@ncmail.net> Organization: NC DENR Water Quality To: Natalie Sierra <Natalie.Sierra @ncmai1.net> Hi Natalie, Thanks for the info. I have one correction ,one comment and two requests. 1) Correction: On the front page of the fact sheet (under file review) it should read step "aeration" and not step chlorination. 2) Comment: On page #2 of the fact sheet (under Instream Data Review for 001) you mention that "the discharge caused a violation of the instream DO standard." Based on my observations at the site, I would find it hard to agree with that. The #001 discharge is into a dry ditch and not a stream. The upstream flow comes from outfall #002 so the ditch is not really surface waters. In many cases the ORC has to sample pooled stagnant water at the downstream site for #001. The low DO's are more likely due to stagnant warm water than to oxygen depletion from the organic load, especially since the effluent BOD values are consistently <2.0. Now, to my soap box (just ask Dave G., he has heard it before). I was surprised to see that conductivity measurements (E,U,D) were required. I did not think we were requiring conductivity monitoring for 100% domestic flows. Especially, since this is only 0.025 MGD. Can this be deleted from the permit? Current laboratory rules now require that conductivity samples be performed in a laboratory and not with field instruments on site. This is approximately 12 samples per month that B.I. must pay for that are basically inconclusive. The same goes for fecal coliform U & D monitoring. Fecal coliform compliance is not an issue for this facility. The flow in the ditch is 100% effluent from outfall #001 and #002. The stream data for the year 2000 does not indicate any fecal coliform problems. Can this U & D fecal monitoring also be deleted? 1oQ� Thanks for your consideration. I this does not seem combative. It is just my opinion that the upstream and downstream data in this instance (and many others) is pretty much inconclusive and seldom useful. If the shoe was on the other foot and I was the permittee, I know I would not want to pay for this data. Thanks again, Mike. Mike Mickey <mike.mickey@ncmail.net> Environmental Specialist II North Carolina Department of Environment and Natural Resources Division of Water Quality 1 of 2 4/9/2001 3:08 PM pp"17urg Subject: Re: B.I. Williamsburg Date: Wed, 11 Apr 2001 13:46:34 -0400 From: Natalie Sierra <Natalie.Sierra@ncmail.net> Organization: NC DENR DWQ To: Mike Mickey <mike.mickey@ncmail.net> Hmmm, maybe your e-mail is toying with you .... I rec'd the e-mail all appropriate changes before it goes to public notice (at which get a hard copy of it). thanks for your input, Natalie Mike Mickey wrote: and will make time you'll > Hi Natalie, > I sent you a wordy e-mail on Monday concerning the B.I. facility in > Caswell County. For some reason it showed up in my e-mail inbox today. > Did you get it? > Thanks, Mike. > ------------------------------------------------------------------------ > Name: mike.mickey.vcf > mike.mickey.vcf Type: VCard (text/x-vcard) > Encoding: 7bi t > Description: Card for Mike Mickey 1 of 1 4/11/2001 2:13 PM Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Mr. Michael Durham, CEO Burlington Technologies 5928 NC ;;ighway 87 North Gibsonville, NC 27249 A. X 0 B. Fie ei d by (Printed Name) C. Djate.qj Delivery Vif/. i D. Is delivery address different from item 14 11 Yes If YES, enter delivery address below: ❑ No 3. Servi ype ertified Mail° ❑ Priority Mail Express" ❑ Registered ❑ Insured Mail O Return Receipt for MerchandlSe ❑ Collect on Delivery n..:..i,. -. _.. - 7011 1570 0001 854L 0541 4. Restricted Delivery? (Extra Fee) ❑ Yes 3 Form :3611 1, July 2013 Domestic Return Receipt ;? -- C;: y c./ UNITED STATED, FFOq f ERVICE First -Class Mail �'�� �"�iwjrs `t`+W� USPSge &Fees Paid P.1;} Z_ Permit No. G-10 • Sender: Please print your name, address, and ZIP+4° in this box* DIVISION OF WAIILK KtwUKLtb Water Quality Regional Operations 450 West Hanes MM Read, suite 300 Winston-Salem, NC 27105