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HomeMy WebLinkAboutNC0050610_Follow Up_20201215ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director Water Quality Utilities, Inc. Attn: Paul Isenhour, Owner P.O. Box 1167 Banner Elk, NC, 28604-1167 NORTH CAROLINA Environmental Quality December 15, 2020 SUBJECT: Follow -Up Compliance Evaluation Inspection The Ponds Wastewater Treatment Plant NPDES Permit #NC0050610 Watauga County Dear Mr. Isenhour: Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office (WSRO), visited The Ponds Wastewater Treatment Plant on December 1st, 2020, to perform a follow-up inspection to the Compliance Evaluation Inspection (CEI) that he conducted there in August, 2020, to evaluate your progress, thus far, in correcting the violations and discrepancies that he identified there during the August inspection. Your assistance and cooperation, as well as that of Brandon Hughes, Operator in Responsible Charge (ORC), was greatly appreciated. Details of the re -inspection are recorded on the attached EPA Water Compliance Inspection Report. You're reminded that, in accordance with NC General Statute 143-215.6A, failure to comply with all conditions of the permit subjects Water Quality Utilities, Inc. to civil penalties not to exceed $25,000.00 per violation, per day. Therefore, please keep this office up to date at all times regarding your progress in mitigating the issues identified at the facility. If you have any questions or require further assistance, please contact Mr. Boone by phone at 336-776- 9690, or by email at ron.boone@ncdenr.gov. You may also contact me by phone at 336-776-9700, or by email at lon.snider@ncdenr.gov. Sincerely, D Sg dby: L L —41 -T 15mgtr Lon14r"SfflW,"Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: EPA Water Compliance Inspection Report cc: Laserfiche E Q�� Office North Carolina Department of Environmental Quality I Division of Water Resources _ Winston-Salem Regional Oce 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CAROLINA oepadment of eeeimemeetai Quality 336.776.9800 United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20460 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 IN 1 2 IS I 3 I NC0050610 I11 121 20/12/01 I17 18 n 19 L G j 201 21111111111111111111111111111111111111111111 f6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 CA ---------------------- Reserved ------------------- 67 I 71 I I 72 L n, � 73 LLI74 71 I I I I I I I80 70 Iu ty LJ 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) 10:OOAM 20/12/01 17/12/01 The Ponds WWTP NC Hwy 105 Exit Time/Date Permit Expiration Date Banner Elk NC 28604 11:OOAM 20/12/01 22/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Brandon K Hughes/ORC/828-260-5213/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Jadd W Brewer,PO Box 1167 Banner Elk NC 286041167//828-898-6277/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Operations & Maintenar 0 Facility Site Review 0 Effluent/Receiving Wate 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 Ron Boone DWR/WSRO WQ/336-776-9690/ DocuSigned by: 12/15/2020 e,,aFd �aan� Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date �oocuSignedby: 12/15/2020 /,, l JMGft f— EPA Form 3560-3 (Rev 9-94) PreviouNdiRWiHIVbbsolete. 12/15/202POage# NPDES yr/mo/day Inspection Type (Cont.) 31 NCO050610 I11 12I 20/12/01 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mr. Boone reinspected the facility with operator Brandon Hughes on 12/1/2020. The findings of this follow up inspection are detailed below: PROBLEM: The plant description in the permit needs to be updated. There is no grit chamber or tertiary treatment. Please ensure the plant description is appropriately updated during the next permit renewal. CURRENT STATUS: This will have to be done at permit renewal. PROBLEM: The effluent composite sample is currently being collected from the aerated tank upstream of the UV. The permit requires that the effluent sample be taken downstream of all treatment units. Please reconfigure the sampler to comply with this requirement. CURRENT STATUS: The sampler has been moved to sample downstream of the UV unit. PROBLEM: The audible alarm did NOT work when the influent pump station's high level float was activated. The ORC found that the audible alarm horn's wires had come loose and the alarm worked correctly after he reattached them securely. The alarms should be checked daily to ensure constant operability. This should be a part of regular operations and maintenance (O&M) that should be documented as such. The pump station also has a telemetry system which was NOT tested during the inspection. It is noteworthy, however, that tripping the high level float to test the audible and visual alarms should have also activated the telemetry system, yet the ORC was not notified during the remainder of the inspection, of any problems at the pump station. The ORC was unsure who the system contacted in the event of an alarm condition. He said he thought it contacted Jadd Brewer, who would in turn, likely contact him. This system should be well known by the ORC and all backups. The telemetry system should also be tested regularly to ensure it operates properly. This should be documented as part of the regular O&M. CURRENT STATUS: The alarm and telemetry systems are fully functional and programmed to call the ORC and others until positive contact is achieved. PROBLEM: The EQ basin connects directly to the digester via a 4" metallic pipe. If the level of the EQ ever reache❑ that height the wastewater flows directly to the digester. Once the level of the digester gets to a certain height, it'll then flow into the aeration basin. The EQ basin does NOT have overflow detection systems or alarms. The permittee should consider installing them as another level of protection. The pipe that connects the EQ basin to the digester has a hole in it, caused by corrosion, which should be repaired. CURRENT STATUS: The hole has been repaired PROBLEM: The entire plant structure is heavily corroded and if allowed to continue unchecked will result in failure at some point. The corrosion should be corrected and prevented from reoccurring. CURRENT STATUS: The permittee continues to identify and repair areas of severe corrosion. This is an ongoing process. Some repairs have already been made. PROBLEM: The plant has three blowers, one of which is inoperable and does NOT have belts installed. The blower should be repaired as soon as possible. Page# Permit: NCO050610 Inspection Date: 12/01/2020 Owner - Facility: The Ponds WWTP Inspection Type: Compliance Evaluation CURRENT STATUS: The parts required to make all three blowers operational have been purchased. Some have already been received. PROBLEM: The ORC pulled a solids sample from the aeration basin about an hour prior to the inspector's arrrival on site. The ORC uses what appears to be just a one gallon plastic bottle with the top tapered portion cut off. He filled this with sample from the basin and after about one hour approximately the bottom 20 to 30 percent of the container contained solids. The solids content of plan - appears acceptable but the operator should be using an actual settleometer to run the test and should be recording the results of the test as part of regular O&M. CURRENT STATUS: A settleometer has been purchased and test results will be recorded. PROBLEM: The plant could use additional maintenance. There is a lot of corrosion and the plant has a lot of uncontrolled solids build-up in the clarifier baffle zones/troughs, overflow weir troughs, etc. The ORC said, and the OM Rs reflect, that he only spends about 30 minutes on site 5 days per week. This shows the minimal time invested in the proper O&M of the plant. CURRENT STATUS: The permittee has begun addressing corrosion throughout the plant. Solids management is constantly evaluated and adjusted as needed. The cause of the solids discharge that occurred in early October has been repaired and should not happen again. PROBLEM: The tertiary filter does NOT contain actual filter media. It contains plastic plates that the ORC called "bats". These "bats" are placed in the filter tank in series at an angle of about 15 degrees from horizontal. The water does NOT pass through the bats, according to the ORC, but rather just flows around them. The filter is therefore not actually filtering. If anything, it is only baffling the flow of water through the tank. There were solids (pin floe) flowing thru the filter and over the overflow weir of the filter. CURRENT STATUS: The permittee is investigating the possibility and cost of replacing the filter media and placing the unit back in service. If this is not done the permittee will need to update the permit's plant description as mentioned above. PROBLEM: The chart recorder pen appeared to be out of ink at the time of the inspection ... or nearly out. The ORC stated that he would replace it. CURRENT STATUS: The pen has been replaced and is functional. PROBLEM: Water Quality Utilities, Inc. currently has one mobile generator staged at its office in Banner Elk. It is currently intended to serve all plants owned/operated by Water Quality Utilities, Inc. It i therefore asserted that the reliability requirements for this type of facility, as stated in 15A NCAC 02H .0124, are NOT being met. The permittee needs to make a serious accurate assessment of whether it has sufficient backup equipment to facilitate continued uninterrupted and unaffected operations at all of its facilities in the event of a catastrophic failure to ensure it meets the intent of the reliability requirements in 15A NCAC 02H .0124. CURRENT STATUS: The permittee has received the switchgear necessary for the installation of a permanently mounted generator at this plant. The installation process continues. Page# Permit: NCO050610 Inspection Date: 12/01/2020 Owner - Facility: The Ponds WWTP Inspection Type: Compliance Evaluation Summary: The plant has improved since the first inspection in August and is in compliance with most requirements at this time; the generator still needs to be installed. Effluent monitoring has not demonstrated non-compliance since the inspection. The inspector is confident the permittee is committed to bring the plant up to compliance and keep it their for the long term. The permittee should keep the Division updated at all times as to its progress in improving the plant. Also, since Mr. Brewer has retired, the ownership affiliation information must be updated in our database. This is accomplished by downloading, filling out, and submitting a Name/Ownership Change form, which you can find here: "https:Hdeq.nc.gov/about/divisions/water-resources/water- quality-permitting/npdes-wastewater/npdes-compliance-and-0." You should submit the same form for each facility/permit held by Water Quality Utilities, Inc. Page# Permit: NCO050610 Inspection Date: 12/01/2020 Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Owner - Facility: The Ponds WWTP Inspection Type: Compliance Evaluation Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: None Permit (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: None Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 5