NC0035904_Inspection-NOV_20050516

Michael F. Easley, Govemor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
May 16, 2005
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
William N. Stovall
NC Department of Correction
4216 Mail Service Center
Raleigh, NC 27699
SUBJECT: NOTICE OF VIOLATION
Compliance Evaluation Inspection
NC Department of Correction
McCain Correctional Hospital WWTP
Permit No: NC0035904
Hoke County
Dear Mr. Stovall:
Enclosed please find a copy of the Compliance Evaluation Inspection Report from the inspection
conducted on May 11, 2005 by Mike Lawyer of the Fayetteville Regional Office. The time and assistance
provided by Mr. Darrel Cockman, ORC, was greatly appreciated. As part of the inspection, an interview
was conducted with Mr. Cockman concerning the operation and maintenance of the McCain Hospital
WWTP. The following item,, as ascertained during this .interview, is addressed as a violation of your
NPDES permit (NC0035904):
1) According to Mr. Cockman, the facility is without any form of standby power. Please refer to Section
C, Item 7 of your NPDES permit (NC0035904), which states: The Permittee is responsible for
maintaining adequate safeguards (as required by 154 NCAC 2H..0124-Reliability) to prevent the
discharge of untreated or inadequately treated wastes during electrical power failures either by
means of alternate power sources, standby generators or retention of inadequately treated effluent.
As a response to this Notice of Violation, you are asked to submit a written Plan of Action (POA)
concerning the above item to this office on or before June 15, 2005. This POA should address a specific
method of power reliability as well as a specific date in which you will be in compliance with the
aforementioned permit condition.
NorthCarolina
Naturally
North Carolina Division of Water Quality 225 Green Street — Suite 714 Fayetteville, NC 28301-5043 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us FAX [phone]
An Equal opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper

Stovall
Page 2
May 16,_2005
Please refer to the enclosed inspection report for additional observations and comments. If you or your
staff has any questions, please call Mike Lawyer or myself me at 910-486-1541.
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH: ML/ml
cc: Darrel C Cockman, ORC
Central Files
Fayetteville Files

United States Environmental Protection Agency
EPA Washington, D.C. 20460
�-+ Water Compliance Inspectiori''-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 IJ 2 "LI.' . 3 I NC0035904 111 121 05/05/11 117 --
Type Inspector • FacType
18 LI' 19 U 20 U,
I I I [1.1 .I I I I I I I I I I 166
Remarks
11 I I I I -I I I I 11.1 I I I I I I 11 I I 1 I I I' I I I I I
Inspection Work Days Facility Self -Monitoring Evaluation Rating ' B1 QA . — --- -Reserved----____-_ ---- —__
67 I 3.0 f 69 70 IJ 71 Li • 72 LI 73 I . I- 174 751- I , I 1 I I 1180
Section B'. Facility Data
Nanie and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
McCain Correctional Hospital WWTP
NC Hwy 211
Raleigh NC 276994216
•
,Entry Time/Date
10:00 AM 05/05/11
Permit Effective Date
-
04/09/01"
'.
Exit Time/Date -
12:30'PM 05/05/11
Permit Expiration Date
09/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Darrel C Cockman/ORC/910-944-2351/
Thomas Luther Criscoe/ORC/910-281-3161/
Other Facility Data
-
Name, Address of Responsible Official/Title/Phone and -Fax Number
Con
William NStovall, PE,4216 Mail Service Ctr Raleigh NC 27699/Directacted
torNo
of Engineering/919-716-3424/9197163978
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
Mike Lawyer FRO WQ///
// -6/0� •
Signature of Management Q A Reviewer
c
.. Agency/Office/Phone and -Fax Numbers Date -
04. 0S
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.

NPDES yr/mo/day Inspection Type
31 NC0035904 111 121 05/05/11 117 18
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
A records review was conducted whereby lab reports from the facility's contract lab, Research & Analytical Labs
in Kernersville, NC, along with the facility's bench sheets for field parameters were compared to the Discharge
Monitoring Reports from July 2004 through March 2005. No transcription errors were discovered. The DMR's from
July 2004 and August 2004 showed effluent limit violations for fecal conform. No other violations were noted.
After the documentation review was completed, a physical inspection of the facility was conducted. .All
treatment units were found to be in good working order, however, it was relayed by Mr. Cockman that the
facility does not have any source of alternate power in the event of an emergency. This is a violation of
Section C, Item 7 of the facility's NPDES permit.

Permit Yes No NA NF
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? 00.0
Is the facility as described in the permit? • 0 0 0
Are there any special conditions for the permit? 0.00
Is access to the plant site restricted to the general public? 0 0 0
Is the inspector granted access to all areas for inspection? II0- 0 0
Comment
Operations & Maintenance Yes No NA NF
Is the plant generally clean with acceptable housekeeping? 1.000
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, •0 0 0
and other that are applicable?
Comment:
Bar Screens Yes No NA NF
Type of bar screen
a.Manual - U
b.Mechanical •
Are the bars adequately screening debris? • 0 0 .0
Is the screen free of excessive debris? - 111000
Is disposal of screening in compliance? • 0_ 0 0
Is the unit in good condition? 11000
Comment:
Primary Clarifier. Yes No NA NF
Is the clarifier free of black and odorous wastewater? stoop
Is the site free of excessive buildup of solids in center well of circular clarifier? • 0 0 0
Are weirs level? - 111000
Is the site free of weir blockage? • 0 0 0
Is the site free of evidence of short-circuiting? • 0 0 0
Is scum removal adequate? - • 0. 0 0
Is the site free of excessive floating sludge? 0 0 0
Is the drive unit operational? ■ 0 0 0
Is the sludge blanket level acceptable? 0 0 0
Is the sludge blanket level acceptable? (Approximately 'A of the sidewall depth) -Doom
Comment: The sludge blanket level could not be measured because at the time of inspection the facility's sludge judge
was broken. According to Mr. Cockman, a replacementhas been ordered. -
Secondary Clarifier Yes No NA NF
Is the clarifier free of black and odorous wastewater? •0 0 0
Is the site free of excessive buildup of solids in center well of circular clarifier? • .0 0 0
Are weirs level? ■ ' 0 0 0
Is the site free of weir blockage? 1 0 0 0
Is the site free of evidence of short-circuiting? •0 0 0
Is scum removal adequate? - •0 0 0
Is the site free of excessive floating sludge? •0 0 0
Is the drive unit operational? • 0 0 0
Is the sludge blanket level acceptable? 0- 0 0 •
Is the return rate acceptable (low turbulence)? 0 0 0 •
Is the overflow clear of excessive solids/pin floc? •- 0 0 0

Secondary Clarifier
Is the surface free of bulking ?
Is the sludge blanket level acceptable? (Approximately'% of the sidewall depth)
Comment:
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
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?
Are settleometer results acceptable?
Is the DO level acceptable?(1.0 to 3.0 mg/I)
Are settelometer results acceptable?(400 to 800 mill in 30 minutes)
Comment: Aeration basin contains three surface aerators.
Disinfection - UV
Are extra UV bulbs available on site?
Are UV bulbs clean?
Is UV intensity adequate?
Is transmittance at or above designed level?
Is effluent clear?
Is there a backup system on site?
Is effluent clear and free of solids?
Comment: As backup, facility has chlorine tablets and dechlor tablets on site.
tandby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Comment: Facility does not have an alternate power source.
I sboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
Is the facility using a contract lab?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
Yes No NA NF
■ 000
O 0011
Yes No NA NF
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑•
Yes No NA NF
Surface
11000
111000
O 0110
■ 000
1 ❑ ❑ ❑
O 0011
❑ ❑ 0 ■
O 00.
O 0011
Yes No NA NF
11000
■ ❑ ❑ 0
11000
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
❑ ■ ❑ ❑
O O ❑ ■
❑ O O ■
O 0011
❑ ❑ ❑ •
❑ ❑ ❑ •
O 0011
Yes No NA NF
■ ❑ 0 ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
O 0011

Laboratory Yes No NA NF
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 110
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees? ❑ ❑ E ❑
Comment Facility's contract lab is Research and Analytical Labs in Kernersville, NC.
Flow Measurement - Fffluent Yes No NA NF
Is flow meter used for reporting? ' U ❑ ❑ ❑
Is flow meter calibrated annually? • 0 0 0
Is the flow meter operational? • 0 0 0
(If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 1 ❑
Comment:
Record Keeping
YPs No NA NF
Are records kept and maintained as required by the permit? • ❑ ❑ ❑
Is all required information readily available, complete and current? • 0 0 0
Are all records maintained for 3 years (lab. reg. required 5 years)? 0 0 0
Are analytical results consistent with data reported on DMRs? 1 ❑ ❑ ❑
Is the chain -of -custody complete? .000
O&M Manual 1
As built Engineering drawings
Schedules and dates of equipment maintenance and repairs
Dates, times and location of sampling •
Name of individual performing the sampling
Results of analysis and calibration • `
Dates of analysis . 1
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? ❑ ❑ ❑ E
(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? 0 ❑ 0 1
Is the ORC certified at grade equal to or higher than the facility classification? 1 ❑ ❑ ❑
Is the backup operator certified at one grade less or greater than the facility classification? 1 ❑ ❑ ❑
Is a copy of the current NPDES permit available on site? 1 ❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review? ❑ 0 ❑ 1
Comment: Annual compliance report is compiled and submitted by the Department of Corrections office with a copy
sent to the facility. •
Effluent Sampling Yes No NA NF
Is composite sampling flow proportional? ❑ ❑ E ❑
Is sample collected below all treatment units? 1 ❑ ❑ ❑
Is proper volume collected? ❑ ❑ ❑•
Is the tubing clean? 0 0 0 •
Is proper temperature set for sample storage (keptat 1.0 to 4.4 degrees Celsius)? ❑ ❑ ❑ E
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? 0 0 0
Comment Facility's contract lab brings.and sets up their own sampling device. No sampling Was being performed at
the time of inspection so tubing and collected volumes could not be verified.
Upstream / Downstream Sampling. Yes No NA NF
Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? •❑ ❑ ❑
Comment:

Aerobic Digester
Is the capacity adequate?
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:
Drying Beds
Is there adequate drying bed space?
Is the sludge distribution on drying beds appropriate?
Are the drying beds free of vegetation?
Is the site free of dry sludge remaining in beds?
Is the site free of stockpiled sludge?
Is the filtrate from sludge drying beds returned to the front of the plant?
Is the sludge disposed of through county landfill?
Is the sludge land applied?
(Vacuum filters) Is polymer mixing adequate?
Comment:
Fffluent 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 NF
• ❑ ❑ ❑
• 000
MOOD
• 000
❑ ❑ • ❑
Yes No NA NF
• 000
• 000
11000
11000
• ❑ ❑ ❑
• 000
O 0010
■ ❑ ❑ ❑
❑ ❑ • ❑
Yes No NA NF
• 000
• 000
O 0.0

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RECEIVED
JUN 13 2005
DENR= FAYETTEVILLE REGIONAL OFFICE
North Carolina Department of Correction
CENTRAL ENGINEERING DIVISION
2020 Yonkers Road ° 4216 MSC ° Raleigh, NC 27699-4216
Michael F. Easley, Governor
June 8, 2005
Ms. Belinda Henson
Department of Environment and Natural Resources
Division of Water_Quality._.
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
Re: Notice of Violation Received June 3, 2005
McCain Correctional Hospital WWTP
Permit No.: NC0035904
Hoke County
Dear MS: Henson:
Theodis Beck, Secretary
The Department of Correction has received -the above identified Notice of Violation (NOV) dated May .
16, 2005 and received in our office on Jurie 3; 200.5. The Department'does'not dispute that the McCain
WWTP should be equipped with a source of emergency power.. However, we would also like to point
out that to date the WWTP. has never experienced the release of untreated or partially treated wastewater •
due to electrical power interruption. Also, we find the permit stipulation cited in the NOV somewhat
vague and open to interpretation. The WWTP does. in fact Maintain the ability to hold untreated
wastewater in its aeration basin; the length of time that basin would -provide emergency storage may be a
more germane question. The cited permit clause does not specify alength of time for a hypothetical •
power outage. An outage of several hours could be tolerated; an outage of several 'days could not. We
would appreciate clarification on the required duration of a power outage before -we can conclude that
our reserve storage volume is inadequate and we are in fact in violation -of our permit.
Regardless of the precise difference between a power failure and a generalstate of emergency, DOC has
in fact already determined to install an emergency generator(as defined by statute) at the WWTP. This
installation would have occurred already except for, the severe budgetary constraints imposed on the
Department through the last few budget cycles.
DOC_ would also'like to -request an extension on your stated deadline of June .15, 2005 to July 15, 2005
for -submission of a Plan of Action (POA). • We request this extension due to the fact that your letter took
three weeks to reach the Department, and we are unsure of our ability to locate adequate funding for this
generator by the June 15 deadline.
Telephone [phone] °Fax [phone]
An Equal Opportunity / Affirmative Action Employer

Ms. Belinda Henson
Notice of Violation Received June 3, 2005
McCain Correctional Hospital WWTP
Permit No.: NC0035904
Hoke County
June 8, 2005 page 2
In the meantime, the Department will endeavor to find adequate funds and update the design of this.
emergency generator to meet the current load requirements of the WWTP. • Finally, we would appreciate
clarification on whether or not the addition of the emergency generator will require an Authorization to
Construct (ATC) issued by your office, since this generator could be construed as an addition of process
equipment to the plant. We will need that determination in order to prepare the POA. Please feel free to
give me a call to discuss this issue at your convenience at [phone]. Thank you for your attention
to this matter.
Regards,
dj/Ap
Matthew Harbert, PE
Environmental Engineering Supervisor
cc: . WNS/GJF/MGH/R File/

June 23, 2005
Michael F. Easley, Governor
North Carolina Department of EnvirWilliam G. Ross Jr., Secret
onment and
Natural R' sources
Alan W. Klimek, P.E., Director
Division of Water Quality
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Matthew Harbert, PE
Department of Correction >
Central Engineering Division
4216 Mail Service Center
Raleigh, NC 27699-4216
SUBJECT: Receipt of Notice of Violation Response Letter
McCain Hospital WWTP
PermitNo: NC0035904
Hoke County
Dear Mr. Harbert:
Our office received your NOV response letter on June 13, 2005. First, we apologize for the delayed time that it
took for you to receive the NOV. The NOV was sent to your office by certified mail on May 17, 2005. Thank
you for responding in such a quick manner after receipt of the NOV. Based on the information you provided in
your letter, we offer the following:
➢ We understand that the McCain WWTP has the capability of retaining untreated waste for a relatively
short amount of time. We are asking for a Plan of Action should there be a power outage for longer
periods of time, i.e. 1-2 days or more. As determined during the Compliance Evaluation Inspection
conducted on May 11, 2005 and based on your letter, "An outage of several hours could be tolerated; an
outage of several days could not." the McCain WWTP is not prepared for such an event.
> Your extension request to submit, a written Plan of Action (POA) to this office on or before 15,
2005 is accepted. _ July
> The addition of an emergency generator is not considered as process equipment and therefore would not
require an Authorization to Construct (ATC).
If you or your staff has any questions, please feel free to contact Mike Lawyer or myself
Y y if at 910-486-1541.
BSH: ML/ml
cc: William Stovall
Tommy Criscoe, Backup-ORC
North Carolina Division of Water Quality
Internet: h2o.enr.state.nc.us
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper
Sincerely,
1342,60
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
Nne
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DENR-FRO
JUL 2 0 2005
DWQ
North Carolina Department of .Correction
CENTRAL ENGINEERING DIVISION
4216 MSC • Raleigh, NC 27699-4216
Michael F. Easley, Governor Theodis Beck, Secretary
July 15, 2005
Ms. Belinda S. Henson, Regional Supervisor
Surface Water Protection Section
NCDENR Division of Water Quality
225 Green Street, Suite 714
Fayetteville, NC 28301-5043
RE: 05/16/2005 NOV McCain Correctional Hospital WWTP
Permit No: NC0035904
Dear Ms. Henson:
Department of Correction offers the following Plan of Action (POA) to address the requirement for
stand-by power at the McCain Correctional HospitalWWTP as stated in your letters of May 1.6 and June
23, 2005. The method of power reliability that we propose is an appropriately sized standby generator
that will adequately power the WWTP for an indefinite period of electrical service interruption.
We are currently in the process of identifying funding for this project. We anticipate beginning the
design and procurement processes in November 2005. This design timeline has been influenced by the
recent loss of staff across several engineering sections, including my supervisor, Matthew Harbert, with
whom you have been communicating regarding this matter.
Once the bidding and award processes for the equipment are complete, it has been our experience that
delivery of_a.generator of this type requires from three to five months. We hope to have the installation
complete and the unit operational by April 30, 2006. You stated that we would not require an
Authorization to Construct notice from your office, since this will not be considered a piece of process
equipment.
I hope this plan satisfies the NOV request for information. If you have any further questions or
comments, please do not hesitate to give me a call at 91.9-716-3433 or email me at
[e-mail] at your convenience.
Res.: tfully,
Kenneth G. Hart, CM
Facility Engineering Specialist
pc: WNS/GJF/RLT/JLI/KGH/McCain Unit File/R
- Telephone 9f9-716-3400 • Fax [phone]
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