HomeMy WebLinkAboutNC0001121_Biomonitoring Inspection_20021230THIS PARCEL MAY BEOPENso'FOnPOSTAL INSPECTION
ZIA
NCDENR
North Carolina Department of Environment and Natural Resources
Michael F. Easley, Governor
December 30, 2002
Mr. David Martin, Facility Engineer
Veeder Root/Danaher Controls
P.O. Box 368
Elizabethtown, NC 28337
Subject: COMPLIANCE BIOMONITORING INSPECTION
Veeder Root/Danaher Controls WWTP
NPDES Permit No. NC0001121
Bladen County
Dear Mr. Martin:
kola_
William G. Ross, Jr., Secretary
Alan Klimek, Director
Division of Water Quality
Enclosed you will find a copy of the Compliance Biomonitoring Inspection report for the inspection conducted the
week of November 12, 2002. The inspection included the same objectives as that of a routine Compliance Evaluation
Inspection (conducted on November 12) plus an Aquatic Toxicity (AT) test to evaluate the biological effect of the
facility's discharge on test, organisms. As part of the inspection a tour of the Wastewater Treatment Plant was
conducted. All observations and recommendations are in Part D. Summary of Findings/Comments of this inspection
report. The Division of Water Quality (DWQ) collected effluent samples from the 24-hour Outfall 001 composite of
November 12 to November 13 for use in an acute Pimephales promelas pass/fail toxicity test. The DWQ aquatic
toxicity sample was sent to the Division of Water Quality (AT) Laboratory (located on Reedy Creek Road in Raleigh).
The sample resulted in a "Pass", indicating that the effluent waters would not be predicted to have water quality impacts
on the receiving water. The 004 composite sample was analyzed for the following parameters (which are currently in
Veeder Root's NPDES Permit): total suspended solids (TSS), cyanide, Cadmium, Chromium, Copper, Lead, Nickel,
Silver, and Zinc. The chemistry analyses were sent to the Division of Water Quality Chemistry Laboratory, located on
Reedy Creek Road in Raleigh. The results of all laboratory tests will be forwarded to you when they are completed.
Where recommendations and requirements are cited, we ask that you provide a written description of how each has
or will be addressed. We ask that your response and plan of action be forwarded to the Fayetteville Regional Office by
February 13, 2003. If you have any questions or comments concerning this report or require clarification on part(s) of
this report, please contact Dale Lopez at 910/486-1541.
Sincerely,
Dale Lopez
Environmental Specialist
/dl
Enclosure: Facility Site Review
Regional Field Inspectors Check List for Field Parameters
cc: Kevin Bowden, DWQ, ESB, ATU
Fayetteville Regional Office
225 Green Street — Suite 714, Fayetteville, North Carolina 28301-5043
Phone: 910-486-1541/FAX: 910-486-07071 Internet: w•ww.enr.state.nc.us`ENR
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper
Mr. Martin
Page 2of12
December 30, 2002
NPDES COMPLIANCE INSPECTION REPORT
North Carolina Division of Water Quality
Fayetteville Regional Office
Section A. National Data System Coding
Transaction Code: N NPDES NO. NC0001121
Inspector: S Facility Type: 2
Facility Evaluation Rating: 4 BI: D. QA: N
Section B: Facility Data
Name and Location of Facility Inspected:
Veeder Root/Danaher Controls WWTP
Entry Time/Date: 10:40 AM / 021112
Exit Time/Date: PM/021112
Name(s), Title(s) of On -Site Representative(s):
David Martin -(Cert. Grade II) - ORC/Facility Engineer
Phone Number(s): (910) 862-2511
Name, Title and Address of Responsible Official:
Mr. David Martin, Facility Engineer
P. O. Box 386
Elizabethtown, NC 28377
Section C: Areas Evaluated during Inspection
Date: 021112
Inspection Type: B
Reserved:
Reserved:
Permit Effective Date: 030101
(issued 12/13/02)
Permit Expiration Date: 061031
Contacted: Yes
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated, N/A = Not Applicable)
Facility Site:Revievv:
Laboratory:
:Pretreatment: N/
Self-1Vlonitoring Program:
Sludge Disposal: S
Records/Re. ports.i:
Flow Measurement:
Effluent/Receiving,Waters.
ompliance Schedule: N/A
Operation 84IV1 aintenanec:
Mr. Martin
Page 3 of 12
December 30, 2002
DESCRIPTION OF WWTP:
Veeder Root WWTP
BIOMONITORING EVALUATION INSPECTION performed on November 12, 2002
Contact personnel:
David Martin, Grade II (ORC)
Larry Smith, Grade IV (ORC Back-up)
SECTION D: SUMMARY OF FINDINGS/COMMENTS:
BRIEF DESCRIPTION OF Veeder Root WWTP---
Veeder Root had four outfalls: 001, 002, & 003 merge into one (004). Effluent 001 was the
process waste treatment effluent from the plating unit. Effluent 002 was the non -contact cooling
water that ran through the plastic molding machines. Effluent 003 was the remediated
groundwater (remedial action pumping for the NPDES permit). The final effluent was the
combined outfall of 001, 002, & 003. The 004 effluent flow was calculated by adding the total
flow measurements of the influent flows through the meters that supply water to the units that end
up in the effluents of 001 and 002 with the calculated flow based upon pumping rates of effluent
003. Wastewater from the plating department went to the wastewater treatment system. This
wastewater was grouped into three categories: the wastewater that needed to be treated for
cyanide, the wastewater that needed to be treated for chromate reduction (hexavalent chromium
was converted to trivalent chromium), and wastewater from the wet well. Betz Metclear 2405,
and pH adjustment with sodium hydroxide, followed by pH adjustment with sulfuric acid was
used to precipitate the metals in the wastewater from the wet well. Two cyanide tanks (37,500
gallons) are processed in one batch per week for cyanide reduction. Two chromium tanks
(15,000 gallons) are processed in two or three batches per week for chromium reduction. 15%
bleach, Klaroid CDP 1311, and Novus 2681 were added to the cyanide tank wastewater and
sometimes the chromium tank wastewater to cause flocculation. The wastewater from the
cyanide tanks, the chromium tanks, and from the wet well flow to the pumping station, then
pumped to the clarifier for settling. The plate and frame filter press dewatered the clarifier
underflow sludge. Clarifier overflow went to the Outfall 004 sampling station and to the Cape
Fear River.
Mr. Martin
Page 4of12
December 30, 2002
SECTION D: SUMMARY OF FINDINGS/COMMENTS:
PLANT TOUR— Please see the Facility Site Review, pages 4 through 8, and the Regional Field
Inspectors Check List for Field Parameters, pages 9 through 10. PPG Porter was used to coat the
tanks for the chromium reduction system.
RECOMMENDATIONS:
1. Recommend that annual calibration be performed on flow meters. According to
Veeder Root's NPDES Permit in SECTION D. MONITORING AND
RECORDS, (3.) Flow Measurements: "The devices shall be installed,
calibrated and maintained to ensure that the accuracy of the measurements
are consistent with the accepted capability of that type of device. Devices
selected shall be capable of measuring flows with a maximum deviation of
less than + 10% from the true discharge rates throughout the range of
expected discharge volumes. Once- through condenser cooling water
flow which is monitored by pump logs, or pump hour meters as specified
in Part I of this permit and based on the manufacturer's pump curves shall
not be subject to this requirement."
2. NIST annual calibration/crosscheck of all thermometers and temperature
measuring devices that are associated with results reported on the DMRs.
According to 15A NCAC 2H .0805 (a)(7)(0): "All thermometers must
meet National Institute of Standards and Technology (NIST)
specifications for accuracy or be checked against a NIST traceable
thermometer and proper corrections made."
3. Recommend that the temperature be tested with an immediate grab
reading of the Plant Outfall 004 effluent, as opposed to being collected
and transported to the laboratory for temperature measurement. Ref.:
40CFR Ch. 1 (7-1-95) p. 644 table II.
4. Recommend that a label be attached to the thermometer (after the
annual NIST thermometer crosscheck) with a note of the correction that is
needed.
5. Recommend that the Oil and Grease samples be collected directly into the
appropriate laboratory glass sample container (rather than into the plastic
sample dipper). As a reference, the Oil & Grease collection in Standard
Methods 18th Edition, page 5-25 states, in part: "Collect a representative
sample in a wide -mouth glass bottle that has been washed with soap,
rinsed with water, and finally rinsed with solvent to remove any residues
that might interfere with the analysis". Also, 40 CFR 136, Table II, states,
in part, that glass containers should be used to contain Oil and Grease
samples. Since plastic containers are not listed as containers that are
suitable for Oil and Grease samples, it is therefore recommended that the
Oil and Grease samples not be collected in plastic.
Mr. Martin
Page 5 of 12
December 30, 2002
REQUIREMENT:
Based upon the type of chemical process wastewater treatment system that
Veeder Root utilizes (see letter from the Technical Assistance and Certification
Unit dated November 14, 2002), a certified Operator in Responsible Charge
(ORC) and back-up operator must obtain the physical chemical certification for
the Grade 2 Physical Chemical System before December 31, 2003. This is in
accordance with Rule 15A NCAC 8G .0406(b).
Name anc]\Signature of Insp9C for Agency/Office/Telephone Date
Dale Lopez \• 1 ) -� NCDENR/Fayetteville/(910) 486-1541 December 30, 2002
Name and Signature o e�ie.�y_ r Agency/Office/Telephone Date
Paul Raw5/ J ( NCDENR/Fayetteville/(910) 486-1541
Action Taken
Regulatory Office Use Only
Compliance Status
_Noncompliance
_Compliance
D ate
Mr. Martin
Page 6 of 12
December 30, 2002
[Yes
FACILITY SITE REVIEW
No N/A 1. Treatment units properly operated and maintained.
Yes No N/A 2. Standby power or other equivalent provision provided.
Yes INo N/A 3. Adequate alarm system for power or equipment failure is available.
4. Sludge disposal procedures appropriate:
CP&L
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No N/A
No N/A
Sludge went to Clean Harbors ---Safety Kleen
a. Disposal of sludge according to regulations
b. State approval for sludge disposal received.
No N/A 5. Sufficient sludge disposed of to maintain treatment process equilibrium.
No N/A 6. The ORC and Backup Operator are officially designated with
NCDENR/DWQ Training and Certification Unit.
No N/A 7. Adequate spare parts and supplies inventory maintained.
No N/A 8. Plant has general safety structures such as rails around or covers over
tanks, pits, or wells.
No N/A 9. Plant is generally clean, free from open trash areas.
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
10. Screening:
a. Manual
b. Mechanical
c. Buildup of debris
d. Screenings properly disposed of.
11. Grit Removal:
a. Excessive organic content in the grit chamber
b. Excessive odors
c. Grit properly disposed of.
12. Primary clarifier:
a. Excessive gas bubbles
b. Black and odorous wastewater
c. Poor suspended solids removed
d. Excessive buildup of solids in center well of circular clarifier
e. Weirs level
f. Weir blockage
g. Evidence of short-circuiting
h. Lack of adequate scum removal
i. Excessive floating sludge
j. Broken sludge scraper.
Mr. Martin
Page 7 of 12
December 30, 2002
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
ME
Ufi
6s
N/A
N/A
13. Trickling Filter:
a. Trickling filter pounding (indicating clogged media)
b. Leak at center column of trickling filter's distribution arms
c. Uneven distribution of flow on trickling filter surface
d. Uneven or discolored growth
e. Excessive sloughing of growth
f. Odor
g. Clogging of trickling filter's distribution arm orifices
h. Filter flies, worms, or snails.
14. Activated Sludge Basins/Oxidation Ditches:
a. Dead spots
b. Failure of surface aerators
c. Air rising in clumps
d. Dark foam or bad color
e. Thick billows of white, sudsy foam
f. Air rising unevenly
g. Excessive air leaks in compressed air piping.
15. Stabilization Ponds/Lagoons:
a. Excessive weeds including duckweed in stabilization ponds
b. Dead fish or aquatic organisms
c. Buildup of solids around influent pipe
d. Excessive scum is on the surface.
16. Secondary Clarifier (Settling Basin):
Yes N N/A a. Excessive gas bubbles on surface
Yes N/A b. Level overflow weirs
Yes N/A c. Weir blockage
Yes o N/A d. Evidence of short-circuiting
Yes No N/A e. Excessive buildup of solids in center well of circular clarifier
Yes No N/A f. Pin floc in overflow
Yes No N/A g: Effective scum rake
Yes N/A h. Floating sludge on surface
Yes N/A i. Excessive high sludge blanket
Yes N/A j. Clogged sludge withdrawal ports on secondary clarifier.
Yes No
Yes No
Yes No
Yes No
Yes No
Yes No
N/A
N/A
N/A
N/A
N/A
N/A
17. Filtration:
a. Filter surface clogging
b. Short filter run
c. Gravel displacement of filter media
d. Loss of filter media during backwashing
e. Recycled filter backwash water in excess of 5 percent
f. Formation ofmudballs in filter media.
Mr. Martin
Page 8 of 12
December 30, 2002
8. Chlorination Unit:
Yes No N/A a. Sludge buildup in contact chamber
Yes No N/A b. Gas bubbles
Yes No c. Floating scum and/or solids
Yes No IIS d. Adequate ventilation of chlorine feeding room and storage area
Yes No IND e. NIOSH-approved 30 minute air pack
Yes No UM f. All standing chlorine cylinders chained in place
Yes No UR g. All personnel trained in the use of chlorine
Yes No OM h. Proper chlorine feed, storage, and reserves supply.
Yes No N/A] 19. Ultraviolet radiation disinfection present and in use.
20. Dechlorination:
Yes No IND a. Proper storage of sulfur dioxide cylinders
Yes No NM, b. Adequate ventilation of sulfur dioxide feeding room
Yes No NM c. Automatic sulfur dioxide feed or feedback control operating properly.
21. Aerobic Digester:
Yes No N/A a. Excessive foaming in tank
Yes No NM b. Noxious odor
Yes No F c. Mechanical aeration failure
Yes No Fs d. Clogging of diffusers.
22. Anaerobic Digester:
Yes No / a. Floating cover tilting
Yes No / b. Gas burner operative
23. Sludge Drying and/or disposal:
Yes No UM a. Poor sludge distribution on drying beds
Yes No ME b. Vegetation in drying beds
Yes No UM c. Dry sludge remaining in drying beds
Yes No OM d. Dry sludge stored on site
Yes No INfi e. Filtrate from sludge drying beds returned to front of plant
Yes No Ifffi f. Sludge disposal through county landfill.
Yes No N/A g. Sludge land applied.
24. Filter Press:
Yes No N/A a. High level of solids in filtrate from filter presses or vacuum filters
Yes No N/A b. Thin filter cake caused by poor dewatering
Yes No N/A c. Sludge buildup on belts and/or rollers of filter press
Yes No N/A d. Excessive moisture is in belt filter press sludge cake.
Not running at the time of the inspection
Yes No
Yes No
Yes No
N/A
N/A
N/A
25. Polishing Ponds or Tanks:
a. Objectionable odor, excessive foam, floating solids, or oil sheen on
water surface
b. Solids or scum accumulations in tank or at side of pond
c. Evidence of bypassed polishing ponds or tanks because of low capacity.
Flow Measurement:
a. Proper placement of flow measurement device
b. Flow meter calibrated
Recommend that each flow meter (001, 002) be calibrated annually
c. Buildup of solids in flume or weir
d. Broken or cracked flume or weir
e. Clogged or broken stifling wells
f. Weir plate edge corroded or damaged
g. Flow measurement error less than 10%.
28. Sampling:
No N/A a. Sampling and analysis completed on parameters specified by permit
Yes No N/A b. Composite sample temperatures maintained at 4 degrees Celsius or
less (but above freezing) during sampling
No N/A c. Contract laboratory used for sample analysis
Yes Na N/A d. Effluent composite samples obtained are tlow proportional.
Mr. Martin
Page 9 of 12
December 30, 2002
26. Plant Effluent:
Yes No N/A a. Excessive suspended solids, turbidity, foam, grease, scum, color, and
other macroscopic particulate matter present
Yes No N/A b. Potential toxicity (dead fish, dead plant at discharge)
Yes No N/A c. Outfall discharge line easily accessible.
27.
Yes No N/A
Yes No N/A
Yes No
Yes No
Yes No
Yes No
Yes No N/A
N/A
N/A
Yes
Yes
RECORDKEEPING AND REPORTING:
No N/A 1. Records and reports maintained as required by permit.
No N/A 2. All required infonnation is available, complete, and current.
No N/A 3. Records maintained for 3 years and all sludge records maintained for 5 years.
No N/A 4. Analytical results consistent with data reported on DMRs.
Yes
Yes
Yes
Yes
5. Sampling and analyses data adequate and include:
Yes No N/A a. Dates, times, and location of sampling
Yes No N/A b. Name of individual performing sampling
Yes No N/A c. Results of analyses and calibration
Yes No N/A d. Dates of analyses
Yes No N/A e. Name of person performing analyses.
6. Monitoring records adequate and includes:
Yes No N/A a. Monitoring charts kept for 3 years
Yes No N/A b. Flowmeter calibration records kept for 3 years.
Yes
No N/A 7. The pH meter is calibrated daily with two buffers and checked with a third buffer
and properly documented.
the temperature maintained in a log for every day of operation.
14. Plant records adequate and include:
No N/A a. 0 & M Manual
No N/A b. "As -built" engineering drawings
No N/A c. Schedules and dates of equipment maintenance repairs
Yes No NIA] d. Equipment data cards.
In Boiler Room
Yes No N/A 15.
Yes
Yes
Yes
Yes
Yes
Yes
Mr. Martin
Page 10 of 12
December 30, 2002
IYes
Yes
Yes
Yes
No N/A 8. Expiration dates of pH buffers adequate. pH 4 ( Aug 2004), pH 10 (Sept 2004),
and pH 6 (Feb 2004).
No
N/A 9. All thermometers used in NPDES permit reporting is calibrated annually with an
NIST certified thermometer or a traceable thermometer annually and
documented.
ORC said that thermometer will be in the future
No N/A 10. The following NPDES permit required parameters are analyzed on site:
pH, Temperature, and Chlorine Residual
No N/A 11. The NPDES pennit required parameter Total Chlorine Residual is
analyzed by approved method.
Yes No N/AI 12. BOD incubator temperature maintained at 20 +/- 1 Degrees Celsius
and the temperature maintained in a log for every day of operation.
Yes No N/AI 13. Fecal coliform incubator maintained at 44.5 +/- 0.2 Degree Celsius and
Yes
Yes
Yes
No N/A 16.
N/A 17.
No N/A 18.
No N/A 19.
No N/A 20.
No N/A 21.
Yes No N/A 22.
Yes No N/A 23.
Permittee is meeting compliance schedule.
DMRs complete and include all NPDES permit required parameters.
The facility has a permitted flow greater than 5 MGD and is required
to operate seven days per week 24 hours a day.
ORC visitation logs available and current.
ORC certified at a level equal to or greater than the classification of the
wastewater facility.
Backup Operator certified at one level less than the classification of the
wastewater facility or greater.
Current copy of the complete NPDES permit is on site.
Facility description verified as contained in NPDES permit.
Facility analyzes process control parameters for example:
. Yes No N/A 24. Industrial Waste Surveys (IWS) sent to all possible Significant Industrial Users
(SIUs) within the last five years (especially new industries).
Name and gig Lure of Insp�ect� r) Agency/Office/Telephone Date
Dale Lopez / /.-" NCDENR/Fayetteville/(910) 486-1541 December 27, 2002
1
Mr. Martin
Page 11 of 12 Regional Field Inspectors Check List for Field Parameters
December 30, 2002
Name of site to be Inspected:
Danaher Controls (Veeder-Root) Date: 11-12-02
Field certification # (if applicable): 10/18/02 application is in the process
Inspector: Dale Lopez
NPDES #: NC0001121
Region: FRO
I. Circle the parameter or parameters performed at this site.
'Residual Chlorine, Settleable Solids, 1pH, DO, Conductivity,
II. Instrumentation:
A. Does the facility have the equipment necessary to analyze field parameters as circled above?
1. A pH meter
Temperature
Measured in the Lab by Accumet pH meter 910
2. A Residual Chlorine meter
Measured in the Lab (no permit limit), measured once per week
3. DO meter
4. A Cone for settleable solids
5. A thermometer or meter that measures temperature.
Measured daily in the Lab by Accumet pH Meter 910
6. Conductivity meter
III. Calibration/Analysis:
1. Is the pH meter calibrated with 2 buffers and
Yes
Yes
No
Yes No
Yes No
Yes
Yes
No
No
checked with a third buffer each day of use? Yes No
2. For Total Residual Chlorine, is a check standard
analyzed each day of use?
2 mg/L standard was made up by Back-up ORC on a monthly basis
3. Is the air calibration of the DO meter performed
each day of use?
4. For Settleable Solids, is 1 liter of sample
settled for 1 hour?
5. Is the temperature measuring device calibrated
annually against a certified thermometer?
6. For Conductivity, is a calibration standard
analyzed each day of use?
Yes
No
Yes No
Yes No
No
Yes
Yes
Mr. Martin
Page 12 of 12
December 30, 2002
IV. Documentation:
1. Is the date and time that the sample was collected documented?
2. Is the sample site documented?
3. Is the sample collector documented?
4. Is the analysis date and time documented?
5. Did the analyst sign the documentation?
6. Is record of calibration documented?
7. For Settleable Solids, is sample volume and
1 hour time settling time documented?
8. For Temperature, is the annual calibration of
the measuring device documented?
ORC indicated that they will begin doing the annual calibration
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Please submit a copy of this completed form to the Laboratory Certification Program.
DWQ Lab. Certification
Chemistry Lab
Courier. # 52-01-01
FIELD INSPECTOR CHECKLIST REV. 04/23/2002
No
No
No
No
No
No
No
No
United States Environmental Protection Agency
EPA Washington, D.C. 20460
Water Compliance Inspection Report
Form Approved.
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
1 I rr l 2 w 3 I Nc0001121 I 11 12 I 02/11/12 I 17
LJ
Type Inspector Fac Type
I„ l/
18 u 19 u 20 IJ
•
IIII IIIIII166
LJ
Remarks
211.11.11111111111IIIIIIIIIIIIIIIIIIIIII
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA
67120.0 169 70 (, ( 71 I„ I 72 1,,, I
U LJ
731
1174
Reserved
7511
1 1 1 1 1 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Veeder Root Company
2100 West Broad St
Elizabethtown NC 28337
Entry Time/Date
10:40 AM 02/11/12
Permit Effective Date
96/11/01
Exit Time/Date
02:00 PM 02/11/12
Permit Expiration Date
01/10/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
David M. Martin/ORC/910-738-6179/
David Martin//910-862-2511/
David Martin//910-862-2511/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
David Martin,2100 West Broad St Elizabethtown NC 28337//910-862-2511/
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Miscellaneous Questions 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)
Recommend annual calibration of all flow meters that are associated with the DMR_ Please refer to
Veeder Root's NPDES permit SECTION D. MONITORING AND RECORDS, (3.) Flow Measurement.
Recommend annual NIST calibration/crosscheck of all thermometers and temperature measuring devices that
are associated with the results that are
(cont.)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Dale Lopez FRO WQ//910-468-1541/910-486-0707
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
NPDES yr/mo/day - Inspection Type
31 NC0001121 111 121 02/11/12 117 .18 U
(cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
reported on the DMRs. Please refer to 15A NCAC 2H .0805 (a)(7)(0).
Recommend that the temperature be tested with an immediate grab reading of the Plant Outfall 004
effluent, as opposed to being collected and transported to the laboratory for temperature measurement.
Please refer to 40 CFR Ch. 1 (7-1-95) p. 644 table II.
Recommend that a label be attached to the thermometer (after the annual NIST thermometer crosscheck) with
a note of the appropriate correction that is needed.
Recommend that the Oil and Grease be collected directly into the appropriate glass laboratory sample
container, rather than into a plastic sampling diper. Please refer to Standard Methods 18th Edition,
page 5-25. Also, please refer to 40 CFR 136 Table II. Since plastic containers are not listed as
containers that are suitable for Oil and Grease samples, it is recommended that the Oil and Grease
samples not be collected in plastic.
Requirement: Based upon the type of chemical process wastewater treatment system that Veeder Root
utilizes, and as per the notification letter from the Technical Assistance and Certification Unit, dated
November 14, 2002, a certified Operator in Responsible Charge (ORC) and back-up operator must obtain the
physical chemical certification for the Grade 2 Physical Chemical System before December 31, 2003.
Please refer to Rule 15A NCAC 8G .0406 (b).
;LIAR 2 4 2003
March 19, 2003
Mr. Dale Lopez, Environmental Specialist
North Carolina Department of Environment and Natural Resources
Fayetteville Regional Office
225 Green Street — Suite 714
Fayetteville, North Carolina 28301-5043
1 M9 2--
511 Keisler Drive, Suite 102
Cary, North Carolina 27511
Post Office Box 33366
Raleigh, North Carolina 27636
Phone: 919.858.9898
Fax: 919.858.9899
Reference: Responses to November 12, 2002, Compliance Biomonitoring Inspection
Wastewater Treatment Plant, NPDES No. NC0001121
Veeder-Root/Danaher Controls
Elizabethtown, Bladen County, North Carolina
Duncklee & Dunham Job No. 01900
Dear Mr. Lopez:
Duncklee & Dunham, P. C. (Duncklee & Dunham) has been requested- by Danaher Controls to
respond, to your December: 30,s 2002,, letter and copy of the November 12, 2002, Compliance
Biomonitoring Inspection Report. These responses address your list of "Recommendations" on page 4
and the "Requirement" on page 5 of the inspection report. Duncklee & Dunham appreciates your
discussion with us on some of the recommendation issues.
Our response to your recommendations and requirement format is to list a summary of your comment
first in italics, and then our response in normal type.
Responses to Recommendations
1 Recommend that annual calibration be performed on flow meters.
Danaher Controls will perform annual calibration on the flow meter-s DaitalleitE iititzlsii talking=tom
li.ffe endo• r�s about inline and other methods for calibrating the flow meters associated with the
discharges to and through the WWTP within the manufacturer's stated accuracy and the maximum
deviation off 10 percent of true discharge.
/% 2 NIST annual calibration/crosscheck of all thermometers and temperature measuring devices
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that are associatedwith results reported on the DMRs.
Danaher Controls has purchased a certified calibrated thermometer traceable to the National
Institute. of Standards and Technology (NIST). The certified thermometer will be used to
check all temperature measuring devices that are used in the reporting of temperatures on the
DMR forms. Temperature measuring devices that can be calibrated will be calibrated against
the certified thermometer annually or more often as needed, and measuring devices that can not
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Response to Compliance Biomonitoring Inspection
Veeder-Root NPDES No. NC0001121
Elizabethtown, Bladen County, NC
March 19, 2003
be calibrated will be checked against the certified thermometer and marked with a correction
factor annually, or more often if needed.
Recommend that the temperature be tested with an immediate grab reading of the Plant Outfall
004 effluent, as opposed to being collected and transported to the laboratory for temperature
measurement.
Danaher Controls has purchased a field thermometer and checked it against a NTIS traceable
thermometer (see Item 2 discussion). The field thermometer is labeled with any needed
correction factor (see_ Item 4 discussion). It will be used to measure the temperature of a grab
sample from Outfall 004. The sample will be collected from 004 with the dipper, placed on the
ground surface, and the temperature immediately measured with the field thermometer.
Recommend that a label be attached to the thermometer (after the annual NIST thermometer
crosscheck) with a note of the correction that is needed.
Danaher Controls has checked the field thermometer against the NTIS traceable thermometer
and has recorded the correction on a label attached to the field thermometer. The field
thermometer will be checked at a minimum annually. If a new thermometer is purchased to
replace the field thermometer it will check against the NTIS traceable thermometer before it is
put into use.
v 5 Recommend that the Oil and Grease samples be collected directly into the appropriate
laboratory glass sample container (rather than into the plastic sample dipper).
A dipper has been constructed to hold a 1,000 ml glass beaker. The glass beaker will be used
to collect the oil and grease sample from Outfall 004's effluent and then pour the sample into
the laboratory supplied glass sample collection bottle. This will be a grab sample collected
well under the 15-minute duration allowed for grab samples.
Response to the Requirement
Based upon the type of chemical process wastewater treatment system that Veeder-Root utilizes, a
certified Operator in Responsible Charge (ORC) and back-up operator must obtain the physical
chemical certification for Grade 2 Physical Chemical System before December 31, 2003.
Mr. David Martin completed the physical chemical training school for Grades 1 and 2 held in Raleigh
during February 4 through 7, 2003. He had previously completed the Field Parameters Environmental
Laboratory Certification course on October 9, 2002.
Mr. Martin completed the exam for Grade 1 Physical Chemical System on March 13, 2003. He will
take the Grade 2 Physical Chemical System exam this summer when it is offered.
Mr. Larry Smith, Grade IV operator completed the physical chemical training school for Grades 1 and
2 held in Raleigh during February 4 through 7, 2003. He will be taken the test this summer or he may
take the option of receiving conditional certification. Either way will put Mr. Smith in compliance and
maintain compliance for Danaher Controls.
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Response to Compliance Biomonitoring Inspection
Veeder-Root NPDES No. NC0001121
Elizabethtown, Bladen County, NC
March 19, 2003
If you have any questions, please call Mr. David Martin at (910) 862-5410 or Mr. Bryson Trexler at
(919) 858-9898.
Sincerely,
DUNCKLEE & DUNHAM, P. C.
Bryson D. Trexler, Jr., Ph.D., L.G.
Senior Project Manager
Senior Peer Review By
David L. Duncklee, L.G.
Senior Project Manager
cc: David Martin — Danaher Controls
P:/Danaher Controls/01900/Letters-Faxes/NPDES Permit/2003 Response to Compliance Biomonitoring-03076
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