NC0020834_NOV-2022-PC-0043_20220210

February 10, 2022

CERTIFIED MAIL 7014 3490 0001 8820 9303
RETURN RECEIPT REQUESTED

Town of Warrenton
Attn: Robert Davie
PO Box 281
Warrenton, NC 27589

Subject: Notice of Violation
NOV-2022-PC-0043
Compliance Sampling Inspection
Warren County WWTP
NPDES Permit No. NC0020834
Warren County

Dear Mr. Davie:

On February 8, 2022, Stephanie Goss and Dorothy Robson of the Raleigh Regional Office
(RRO) conducted an inspection at the subject facility. The cooperation of William Perkinson,
operator in responsible charge (ORC), Kenny Champion (back-up ORC) and Theresa Harris,
Laboratory Supervisor, was greatly appreciated. Findings during the inspection were as follows:

1. The current NPDES permit was issued effective May 1, 2021 and will expire on October
31, 2025.

2. The 2.0 MGD treatment plant consists of an influent pump station, mechanically cleaned
bar screen, vortex grit chamber, dual oxidation ditches, two secondary clarifiers, four
tertiary sand filters, gas chlorination, dechlorination with sulfur dioxide, effluent flow
measurement, cascade post aeration, two aerobic digestors, and two stand-by generators.

3. The plant discharges to Fishing Creek, which is classified as Class C, Nutrient Sensitive
Waters (NSW) in the Tar-Pamlico River Basin.

4. One oxidation ditch was in operation at the time of the inspection with one rotor in use.
Foam was observed on approximately 30% of the surface of the oxidation ditch. The
foam and wastewater in the oxidation ditch appeared black. Mr. Perkinson stated it is
black due to the dye used for the industry International Paper.

5. The second oxidation ditch had excessive vegetation and trees growing in it which
prevent it from being used as designed. In Compliance Evaluation Inspection letter dated
July 29, 2020, it stated the oxidation ditch had excessive trees and other vegetation
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growing in it preventing it from being used as designed. The letter stated that the
vegetation must be removed from the oxidation ditch (See photo of the trees and
vegetation in the oxidation ditch taken on February 8, 2022).

6. Mr. Perkinson stated that both clarifiers are approximately twelve feet deep. The
overflow weirs appeared to be level and free of algae. A sludge judge on clarifier #1
showed the sludge depth to be approximately one and a half feet deep and on clarifier #2
the sludge depth was approximately two and a half feet deep.

7. The cascade aeration basin appeared to be operating satisfactorily. The effluent was clear
and free of excess solids.

8. The influent composite sampler is programmed to collect 100 ml every 20 minutes and is
time based. The refrigerated unit was maintained at the proper temperature, < 6 degrees
C.

9. The effluent composite sampler is programmed to collect 200 ml every 10,000 gallons
and is flow proportionate. The refrigerated unit was maintained at the proper
temperature, < 6 degrees C.

10. The effluent flow meter was calibrated on August 2, 2021 by Chadwick Instrumentation.

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11. The facility has two aerobic digestors and Mr. Perkinson stated the aerobic digestors are
approximately 120,000 gallons each. One aerobic digestor was empty and the second
digestor was full and decanting during the time of the inspection.

12. Mr. Perkinson stated that their sludge is hauled every sixty days by Granville Farms
where the sludge is processed.

13. Mr. Perkinson stated that the facility’s chemical feed system for chlorine is used daily
and is added into the chlorine contact basins.

14. Mr. Perkin stated that the facility uses sulfur dioxide for dechlorination, and it is added
below the chlorine contact basin before the effluent reaches the cascade post aeration.

15. Mr. Perkinson stated both onsite diesel generators are tested under load weekly and diesel
is kept onsite.

16. A review of discharge monitoring report (DMR) data for the period December 2019
through January 2021 showed all required monitoring was performed. There were no
violations during this time.

17. A cursory review of laboratory and DMR data for April 2021 showed consistent
reporting of results. It was noticed in the DMR data for September 2021, Thallium was
reported on the wrong week and the DMR has been corrected as of the date of this letter.

18. A cursory review of calibration logs showed acceptable calibration for the on-site
parameters.

19. Mr. Perkinson stated there are two industries in the Town of Warrenton which is
International Paper and Purdue Hatchery.

20. The effluent discharge appeared free of excess solids. No detrimental impacts to Fishing
Creek was observed.

21. A daily operator logbook is kept online which details daily operations, problems and
when the plant conducts wasting of the sludge. Additional logbooks maintained include
weekly, monthly, semi-annual, and annual preventive maintenance, and a generator
maintenance log.

The site inspection revealed the following violation of NPDES permit conditions (NC0020834)
which states the following:

NPDES Permit NC0020834 Part II. Section C.2. Proper Operation and Maintenance
The permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the permittee to
achieve compliance with the conditions of this permit.

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Within 30-days of receipt of this letter, please respond in writing describing the actions the
Town of Warrenton will take or have taken to resolve the violation indicated in item 4
above.

Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars
($25,000.00) may be assessed against any person who violates or fails to act in accordance with
the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.

If you have questions concerning this report, please contact Stephanie Goss at 919-791-4256 or
[e-mail].

Sincerely,

Vanessa E. Manuel, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ

cc: Laserfiche
RRO files

DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
EPA
United States Environmental Protection Agency
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 Type Inspector Fac Type
1 N 52 NC0020834 22/02/08 C S31112171819 20
21 66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved-------------------
N67707172 73 74 75 80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Warrenton WWTP
615 US Hwy 401 S
Warrenton NC 27589
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
09:45AM 22/02/08 21/05/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Kenneth Wayne Champion/ORC/252-257-1776/
Other Facility Data
12:45PM 22/02/08 25/10/31
Name, Address of Responsible Official/Title/Phone and Fax Number
C. Wayne Mitchell,PO Box 281 Warrenton NC 275890281//252-257-1776/Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenance Records/Reports
Self-Monitoring Program 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
Stephanie Goss DWR/RRO WQ/919-791-4200/
Dorothy M Robson DWR/RRO WQ/919-791-4241/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#1
2/10/2022
DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
2/10/2022
NPDES yr/mo/day
22/02/08
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
NC0020834 17
Page#2
DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
Permit:NC0020834
Inspection Date:02/08/2022
Owner - Facility:
Inspection Type:
Warrenton WWTP
Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping?
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
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:
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?
Is the ORC certified at grade equal to or higher than the facility classification?
Is the backup operator certified at one grade less or greater than the facility
classification?
Page#3
DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
Permit:NC0020834
Inspection Date:02/08/2022
Owner - Facility:
Inspection Type:
Warrenton WWTP
Compliance Evaluation
Record Keeping Yes No NA NE
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
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:
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:
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures?
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:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Page#4
DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
Permit:NC0020834
Inspection Date:02/08/2022
Owner - Facility:
Inspection Type:
Warrenton WWTP
Compliance Evaluation
Bar Screens Yes No NA NE
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
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:
Primary 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 sludge blanket level acceptable?
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
Comment:
Oxidation Ditches Yes No NA NE
Are the aerators operational?
Are the aerators free of excessive solids build up?
# 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 (> 30 minutes)?
Page#5
DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
Permit:NC0020834
Inspection Date:02/08/2022
Owner - Facility:
Inspection Type:
Warrenton WWTP
Compliance Evaluation
Oxidation Ditches Yes No NA NE
Is the DO level acceptable?(1.0 to 3.0 mg/l)
Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes)
The foam covered approximately 30% of the ditch. The second oxidation ditch had
excessive vegetation and trees growing in it which prevent it from being used as
designed.
Comment:
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 lbs 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:
Standby Power Yes No NA NE
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Page#6
DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
Permit:NC0020834
Inspection Date:02/08/2022
Owner - Facility:
Inspection Type:
Warrenton WWTP
Compliance Evaluation
Standby Power Yes No NA NE
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?
The ROC stated fuel is kept onsite.Comment:
Filtration (High Rate Tertiary)Yes No NA NE
Type of operation:Down 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:
Laboratory Yes No NA NE
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?
Comment:
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
Page#7
DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A
Permit:NC0020834
Inspection Date:02/08/2022
Owner - Facility:
Inspection Type:
Warrenton WWTP
Compliance Evaluation
Effluent Sampling Yes No NA NE
# 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:
Pumps-RAS-WAS Yes No NA NE
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
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DocuSign Envelope ID: 40EE7DD2-C7AF-4732-8C53-17AD541F475A