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Home My WebLink AboutNC0029297_NOV-2022-PC-0262_20220505ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Certified Mail # 7020 3160 0000 3277 0488 Return Receipt Requested Robert Hoyle, Director of Construction & Maintenance Catawba County Schools Post Office Box 1010 Maiden, NC 28658 SUBJECT: Notice of Violation Compliance Evaluation Inspection Fred T. Foard High School WWTP NPDES Permit No. NC0029297 Catawba County Tracking #: NOV-2022-PC-0262 Dear Mr. Hoyle: NORTH CAROLINA Environmental Quality May 5, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on April 26, 2022, by Mr. Wes Bell of this Office. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding the enclosed report. This report is being issued as a Notice of Violation (NOV) due to the following: - The filter bed sand was bound with solids and clay/dirt; - Several lateral distribution sections were warped; - The back perimeter block wall for the sand beds needed repair and height extended; - The excessive amount of leaves, grass, etc. had not been removed out of the chlorine contact chamber; - The flow meter was not operating and located properly. Please be advised that the failure to provide proper operation and maintenance is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1. Please note that G.S. 143-215.6A provides for a civil penalty of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, 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. Penalties may also be assessed for any damage to surface waters of the State that may result from the violation. D_E 111.•rhworkt el G. rOrmloalal o � North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 It is requested that a written response be submitted to this Office by Mav 29, 2022, detailing the actions taken to address all violations and maintenance issues discussed in this report. In responding, please address your comments to the attention of Mr. Wes Bell. Should you have any questions concerning this Notice, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell@ncdenr.gov. Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche D_E o,.mworkt G.ed o � Sincerely, -DocuSigned by: Al+014a4V H Pap.e4 F161 FB69A2D84A3... fo r W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 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 1 IN I 2 IL 21IIIIII I NPDES yr/mo/day Inspection 3 I NC0029297 111 121 22/04/26 117 Type 18 i i IIIIIIIIIII Inspector Fac Type 19 I S I 201 IIIIIIIIIIIIIIIIII I IIIIII P6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67I2.0 I 70I4 I 71IN I 72 I N I 73I I 74 751 I I 1 I I I I I I 180 l Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Fred T. Foard High School 3407 Plateau Rd NCSR 2036 Newton NC 28658 Entry Time/Date 09:48AM 22/04/26 Permit Effective Date 20/09/01 Exit Time/Date 10:32AM 22/04/26 Permit Expiration Date 25/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Joshua Steven Greene/ORC/828-396-4444/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Hoyle,PO Box 1010 Newton NC 286581010/Director of Construction & Maintenance/828-464-3562/8284654442 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) Wes Bell of Inspector(s) Agency/Office/Phone and Fax Numbers Date —Docusigned by: DWR/MRO WQ/704-663-1699 Ext.2192/ 5/5/2022 'ioe eh' "-A61696D90CC3437... Signature of Man Andrew Pitn crew"tsta,@ald�viewer Agency/Office/Phone and Fax Numbers Date ' H P4411WR/MRO WQ/704-663-1699 Ext.2180/ 5.5.22 F161FB69A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 NPDES yr/mo/day 31 NC0029297 111 121 22/04/26 I17 Inspection Type 18 [j 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# 2 Permit: NC0029297 Inspection Date: 04/26/2022 Owner - Facility: Fred T. Foard High School 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 El El ❑ application? Is the facility as described in the permit? • El El El # Are there any special conditions for the permit? El El • El Is access to the plant site restricted to the general public? • ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? • El El El Comment: The last compliance evaluation inspection at this facility was performed by DWR staff on 12/2/2020. Record Keeping 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? Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ Comment: The records reviewed during the inspection were organized and well maintained. Discharge Monitoring Reports (eDMRs) were reviewed for the period March 2021 through February 2022. No effluent limit and/or monitoring violations were reported. The ORC must ensure to separately document the sample collection times for both the contract lab and field parameters. Page# 3 Permit: NC0029297 Inspection Date: 04/26/2022 Owner - Facility: Fred T. Foard High School Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE 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: Effluent analyses (all permit -required parameters including field) are performed under Water Tech Lab's Certification #50. The ORC must ensure to report effluent total residual chlorine (TRC) values down to the lowest standard verified on the TRC meter during the annual meter verification. 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? El ❑ • ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 El El • El degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type • ❑ El El representative)? Comment: The subject permit requires effluent grab samples. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? • El El El Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable El El El Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Although the School System has fixed the audible/visual alarm (high water) and installed a flow meter, operation and maintenance issues were noted with the sand filter, chlorine contact chamber and flow measurement. Please be advised that the subject NPDES Permit requires the permittee to properly operate and maintain the facility at all times [Permit Condition Reference: Part II, Section C(2) Proper Operation and Maintenance]. Septic Tank (If pumps are used) Is an audible and visual alarm operational? Yes No NA NE Page# 4 Permit: NC0029297 Inspection Date: 04/26/2022 Owner - Facility: Fred T. Foard High School Inspection Type: Compliance Evaluation Septic Tank Is septic tank pumped on a schedule? Are pumps or syphons operating properly? Are high and low water alarms operating properly? Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: The septic and recirculation tanks are pumped every summer by a contract company (Leatherman's Septic Tank Service). Custodial staff have previously added sodium bicarbonate at the school to maintain appropriate alkalinity/pH levels. The ORC should verify with school staff the frequency and volume of the sodium bicarbonate additions. Sand Filters (Low rate) (If pumps are used) Is an audible and visible alarm Present and operational? Is the distribution box level and watertight? Is sand filter free of ponding? Is the sand filter effluent re -circulated at a valid ratio? # Is the sand filter surface free of algae or excessive vegetation? # Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1) Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The School System had replaced the sand, gravel and warped laterals on one of the two sand filter beds; however, several laterals were warped and the sand was bound with solids and clay/dirt in the second sand bed. In addition, the perimeter block wall along the back section of the entire sand filter needed to be repaired and the height increased to prevent any stormwater from entering the sand filter beds. The permittee must also replace all warped laterals and the "spent" sand must be removed and replaced with appropriately sized sand. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? • ❑ ❑ ❑ Are the tablets the proper size and type? ■ ❑ ❑ ❑ Number of tubes in use? 4 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? • ❑ ❑ ❑ Comment: An excessive accumulation of leaves, grass, etc. were observed in the chlorine contact chamber. The leaves, etc. must be removed and the maintenance crew should be informed to not blow leaves, grass, etc. into the chlorine contact chamber during future maintenance activities. This debris can potentially degrade effluent quality due to the organic decomposition. In addition, the permittee/School System should provide a netting to prevent leaves, grass, etc. from entering the chlorine contact chamber. De -chlorination Type of system ? Yes No NA NE Tablet Page# 5 Permit: NC0029297 Inspection Date: 04/26/2022 Owner - Facility: Fred T. Foard High School Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE 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 # 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? ❑ ❑ • ❑ • ❑ ❑ ❑ 4 Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: An inline flow meter had been installed after the tablet dechlorination unit last year; however, the pipe that the flow meter was connected to was not level with the adjoining pipe that discharged effluent onto the cascade step aeration unit. The uneven piping appeared to cause wastewater to pool at the flow meter location. In addition, the flow meter was registering elevated flow rate measurements that did not reflect the volume being discharged at the time of the inspection. The piping system should be leveled to ensure the flow meter is operating properly with accurate flow measurements. The NPDES Permit requires the permittee to install, calibrate (minimum once per year) and maintain the flow measurement device to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device [Permit Condition Reference: Part II, Section D(3) Flow Measurement]. Effluent 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? Yes No NA NE ❑ ❑ ❑ • ❑ ❑ ❑ • Comment: The effluent appeared clear with no floatable solids or foam. The cascade step aeration unit contained an abundant accumulation of leaves. The permittee should remove the leaves and provide a netting for this treatment unit to prevent future leave accumulations. Page# 6