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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 L 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 1 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. 2 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 3