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HomeMy WebLinkAboutNC0021865_Compliance Evaluation Inspection_20210729DocuSign Envelope ID: FD411C05-E320-4EA4-A8CE-29BB0E4BF7D4 ROY COOPER Go- ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Certified Mail # 7018 1830 0000 9681 5999 Return Receipt Requested Jerome Chestnut Town of Chadbourn 602 N Brown St Chadbourn, NC 28431 SUBJECT: NOTICE OF VIOLATION a "`, STnTt 11 7 NORTH CAROLINA Environmental Quality August 16, 2021 Tracking Number: NOV-2021-PC-0414 Permit No. NCO021865 Chadbourn WWTP Columbus County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Chadbourn WWTP on July 29, 2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0021865. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Wilmington Regional Office. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Record Keeping No documentation of submittal of Annual Wastewater Reports in Division's database nor on its Laserfiche system. A Calendar Year or Fiscal Year report is required for the WWTP and for it collection system or a combined report. Aeration Basins The wastewater leak at the back -end of the original aeration basin is still leaking as was noted during the May 2019 inspection. The Town needs to hire a consultant to determine best way to evaluate and repair it. Remedial actions should have already been taken to correct these problems and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. D �� North Carolina Department of Envlronmmtal Quality l Divis Wion of water Resources ilmington Regional0— 1 2211-D 1rive Extension Wilmington. North Carolina 28G05 910.7961215 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215. Sincerely, P DocuEiu1-1utiSB Tom Tharrington, Asst. Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ ATTACHMENT Cc: WQS Wilmington Regional Office - Hunkele Upload to Laserfiche D �� North Carolina Department of Envlronmmtal Quality l Divis Wion of Water Resources ilmington RegionalI— 112111—lDrive Extion ensWilmington. North Carolina 28G05 910.7961215 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 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 I 2 u 3 I NCO021865 I11 121 21/07/29 I17 18I � I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 701L—I a I 71 [n LI 72 I n, I 71 I 74 79 I I I I I I I80 L-1 I I 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 Dermit Number) 10:15AM 21/07/29 21/03/01 Chadbourn WWTP 5275 Chadbourn Hwy Exit Time/Date Permit Expiration Date Chadbourn NC 28431 02:15PM 21/07/29 25/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Carl Steven Price/ORC/910-654-4148/ Daniel Clinton Ward/ORC/910-654-4148/ Jerome Chestnut//910-654-4148 / Steven Price//910-654-4148/9106544148 Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Steven Price,602 N Brown St Chadbourn NC 28431/Public Works Director/910-654-4148/9106544148 Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Compliance Schedules Effluent/Receiving Wate 0 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 Dean Hunkele Docu� DWR/WIRO WQ/910-796-7215/ 8/16/2021 E E1 D9294C4D3746E... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: Tom Tharrington DWR/WIRO WQ/ - - / 'Coµ 'THoRt���tcOA, 8/17/2021 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 NPDES yr/mo/day Inspection Type (Cont.) NCO021865 I11 12I 21/07/29 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Town is reminded to submit a formal letter indicating what was done to permanently seal the discharge from the surge basins (old polishing ponds) by end of August to meet Special Condition A(5). Also, the Town needs to have a manner to access file reports to compare to lab analysis reports during an inspection. This can be accessing the a-DMR on -site or having printed copies available. Below are the major issues that needs to be addressed and will be included on a Notice of Violation: 1. Town still has not been filing its Annual Wastewater Performance Reports to the Division. 2. The wastewater leak at the back -end of the original aeration basin is still leaking as was noted during the May 2019 inspection. The Town needs to hire a consultant to determine best way to evaluate and repair it. Page# DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 Permit: NCO021865 Owner -Facility: Chadbourn WWTP Inspection Date: 07/29/2021 Inspection Type: Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ ■ ❑ application? Is the facility as described in the permit? ❑ ■ ❑ ❑ # Are there any special conditions for the permit? ■ ❑ ❑ ❑ Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ■ ❑ ❑ ❑ Comment: Permit lists an influent flume which is part of the oriqinal sinqle basin system and no longer in use; not sure about the RAS flow meter listed. Permit has special conditions regarding use of surge basins & required freeboard and abandonment of the old outfall line from surge basins. Staff indicated they located a gravity return to treatment from surge basin closest to rest of facility, thus maintaining its freeboard should not be an issue. Compliance Schedules Is there a compliance schedule for this facility? Is the facility compliant with the permit and conditions for the review period? Yes No NA NE ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ Comment: Since last CEI in May 2019, the facility has had 3 limit violations and a toxicity failure with none resulting in penalties. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ ❑ ❑ ❑ Is all required information readily available, complete and current? ■ ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ■ ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ❑ ❑ ❑ ■ Is the chain -of -custody complete? ■ ❑ ❑ ❑ Dates, times and location of sampling ■ Name of individual performing the sampling ■ Results of analysis and calibration ■ Dates of analysis ■ Name of person performing analyses ■ Transported COCs ■ Are DMRs complete: do they include all permit parameters? ■ ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ■ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified ❑ ❑ ■ ❑ operator on each shift? Is the ORC visitation log available and current? ■ ❑ ❑ ❑ Page# 3 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 Permit: NCO021865 Owner -Facility: Chadbourn WWTP Inspection Date: 07/29/2021 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Is the ORC certified at grade equal to or higher than the facility classification? 0 ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility ■ ❑ ❑ ❑ classification? Is a copy of the current NPDES permit available on site? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ 0 ❑ ❑ Comment: No documentation of submittal of Annual Wastewater Reports in Division's database nor on its Laserfiche system. A CY or FY report is required for the WWTP and for it collection system or a combined report A review of the Town's website shows the CY 2018 report for WWTP dated June 2019 as the only report being available. This issue was pointed out following the last WWTP inspection in May 2019 and probably prompted creation of the report found. The issue was also pointed out after the collection system inspection in July 2019. Laboratory 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 less than or equal to 6.0 degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: Make sure a TRC meter calibration curve is completed for 2021; curves were available for 2019 & 2020. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ ❑ 0 ❑ Is sample collected above side streams? ■ ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 0 ❑ ❑ ❑ degrees Celsius)? Is sampling performed according to the permit? 0 ❑ ❑ ❑ Comment: Sample collected from gravity manhole inside fence and use effluent flow meter to signal collection. Temp at 6C so keep and eye on it as outside temps get hotter. Bar Screens Type of bar screen a.Manual Yes No NA NE Page# 4 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 Permit: NC0021865 Owner -Facility: Chadbourn WWTP Inspection Date: 07/29/2021 Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE b.Mechanical Are the bars adequately screening debris? ■ ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? 0 ❑ ❑ ❑ Is the wet well free of excessive grease? ■ ❑ ❑ ❑ Are all pumps present? ■ ❑ ❑ ❑ Are all pumps operable? ❑ ❑ ❑ Are float controls operable? ❑ ❑ ❑ Is SCADA telemetry available and operational? ❑ ❑ ❑ Is audible and visual alarm available and operational? ❑ ❑ ❑ Comment: SCADA monitored Grit Removal Yes No NA NE Type of grit removal a.Manual ❑ b.Mechanical Is the grit free of excessive organic matter? ❑ ❑ ❑ ■ Is the grit free of excessive odor? ❑ ❑ ❑ ■ # Is disposal of grit in compliance? ❑ ❑ ❑ Comment: System was repaired following last inspection, but now the auger motor is not functional and repair is being sought. 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? Yes No NA NE Ext. Air Diffused ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 Permit: NCO021865 Owner -Facility: Inspection Date: 07/29/2021 Inspection Type: Chadbourn WWTP Compliance Evaluation Aeration Basins Yes No NA NE Is the foam the proper color for the treatment process? ■ ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? ■ ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ ■ Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑ ■ Comment: Basin #1 is still leakinq as was seen durinq last inspection and initial attempts to seal from the outside have failed; liquid definitely has the appearance of wastewater from basin and is being pumped back into basin with a sump pump. Staff thinks that the bottom clay liner was damaged when solids removed prior to basin being renovated. Town needs to hire a consultant to determine best wav to evaulate/reaair it. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? ■ ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ■ ❑ ❑ ❑ Are weirs level? ■ ❑ ❑ ❑ Is the site free of weir blockage? ■ ❑ ❑ ❑ Is the site free of evidence of short-circuiting? ■ ❑ ❑ ❑ Is scum removal adequate? ■ ❑ ❑ ❑ Is the site free of excessive floating sludge? ■ ❑ ❑ ❑ Is the drive unit operational? ■ ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ■ ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? ■ ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) ❑ ❑ ❑ ■ Comment: Filtration (High Rate Tertiary) Yes No NA NE Type of operation: Cross flow Is the filter media present? ❑ ❑ ■ ❑ Is the filter surface free of clogging? ❑ ❑ ❑ ■ Is the filter free of growth? ❑ ❑ ■ ❑ Is the air scour operational? ❑ ❑ ❑ ■ Is the scouring acceptable? ❑ ❑ ❑ ■ Is the clear well free of excessive solids and filter media? ■ ❑ ❑ ❑ Comment: ORC stated that no diversion of excess flow to surge basins since last visit. Page# 6 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 Permit: NC0021865 Owner -Facility: Chadbourn WWTP Inspection Date: 07/29/2021 Inspection Type: Compliance Evaluation Disinfection -Gas Yes No NA NE Are cylinders secured adequately? ❑ ❑ ❑ ■ Are cylinders protected from direct sunlight? ■ ❑ ❑ ❑ Is there adequate reserve supply of disinfectant? ❑ ❑ ❑ ■ Is the level of chlorine residual acceptable? ❑ ❑ ❑ ■ Is the contact chamber free of growth, or sludge buildup? ■ ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ ■ Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. ❑ ❑ ■ ❑ 7782-50-5)? If yes, then is there a Risk Management Plan on site? ❑ ❑ ■ ❑ If yes, then what is the EPA twelve digit ID Number? (1000- If yes, then when was the RMP last updated? Comment: De -chlorination Yes No NA NE Type of system ? Gas Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ ■ Is storage appropriate for cylinders? ❑ ❑ ❑ ■ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ ❑ ■ Comment: Are the tablets the proper size and type? ❑ ❑ ■ ❑ Are tablet de -chlorinators operational? ❑ ❑ ■ ❑ Number of tubes in use? Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ ❑ ❑ ❑ Is flow meter calibrated annually? ■ ❑ ❑ ❑ Is the flow meter operational? ■ ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ■ ❑ Comment: Meter last calibrated in 2-2020, thus is past due. Need to make sure you get a report from the company that performs it. Effluent Sampling Is composite sampling flow proportional? Yes No NA NE ■ ❑ ❑ ❑ Page# 7 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 Permit: NCO021865 Owner -Facility: Chadbourn WWTP Inspection Date: 07/29/2021 Inspection Type: Compliance Evaluation Effluent Sampling Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Temp at 6C, thus keep an eve on it as outside temps increase. Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑ and sampling location)? Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? ❑ ❑ ❑ Is the mixing adequate? ❑ ❑ ❑ Is the site free of excessive foaming in the tank? ■ ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ 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? ❑ ❑ ❑ Page# 8 DocuSign Envelope ID: FD41 1 C05-E320-4EA4-A8CE-29BBOE4BF7D4 Permit: NC0021865 Owner -Facility: Chadbourn WWTP Inspection Date: 07/29/2021 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is there an emergency agreement with a fuel vendor for extended run on back-up ❑ ❑ ❑ power? Is the generator fuel level monitored? ❑ ❑ ❑ Comment: Effluent Pipe Yes No NA NE 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: Lagoons Yes No NA NE Type of lagoons? Facultative # Number of lagoons in operation at time of visit? 2 Are lagoons operated in? Parallel # Is a re -circulation line present? ❑ ❑ 0 ❑ Is lagoon free of excessive floating materials? ■ ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ ❑ 0 ❑ Are dike slopes clear of woody vegetation? ❑ 0 ❑ ❑ Are weeds controlled around the edge of the lagoon? ■ ❑ ❑ ❑ Are dikes free of seepage? ■ ❑ ❑ ❑ Are dikes free of erosion? 0 ❑ ❑ ❑ Are dikes free of burrowing animals? 0 ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ ■ ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? ❑ ❑ 0 ❑ Is the lagoon surface free of weeds? ❑ ❑ 0 ❑ Is the lagoon free of short circuiting? ❑ ❑ 0 ❑ Comment: Couple of larger trees at or near rear basin berm. Page# 9