NC0088684_Compliance Evaluation Inspection_20141209

ATA
NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, Ill
Governor Secretary
December 9, 2014
RECEIVEDIDENRIDWR
DEC .a52014
Mr. Peter Grimaldi, Director of Horticulture
Daniel Stowe Botanical Garden Water Quality
6500 South New hope Road Permitting Section
Belmont, North Carolina 28012
Subject: Compliance Evaluation Inspection
Daniel Stowe Botanical Garden WTP
NPDES Permit No. NC0088684
Gaston County
Dear Mr. Grimaldi:
Enclosed please find a copy of the Compliance Evaluation Inspection report for the inspection
conducted at the subject facility on December 3, 2014, by Ms. Marcia Allocco of this office. I thank
you for your assistance regarding the site visit/inspection.
As noted in the enclosed inspection report the Division is requesting amended discharge monitoring
reports (DMRs) for March, July, and August 2014 as noted in the Record Keeping and Summary
sections of the report. Please submit the amended DMRs to my attention using the mailing
address noted in the page footer by January 9, 2015.
The inspection report should be self-explanatory; however, should you have any questions
concerning the report, please do not hesitate to contact me at [phone] or
[e-mail].
Sincerely,
C. , •
Marcia Allocco, MS; Environmental Senior Specialist
Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch
MSC 1617 — Central files basement
MA
Mooresville Regional Office
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115
Phone:[phone] Fax:[phone]\Customer Service:1-877-623-6748
Internet:http://portal.ncdenr.org/web/wq
An Equal Opportunity t Affirmative Action Employer-30%Recycled/10%Post Consumer paper

United States Environmental Protection Agency
Form Approved.
E PA 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 LI 2 Li 3 I Nc0088684 111 12 ( 14/12/03 117 18[ ] 19 Li 201
21111111 1111111111111111111111111 11111111111 r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ---- Reserved
67 11.0 I 70 13
LJ 1 71 i„tyI 72 I N 731 1 I74 751 1 1 1 1 1 1 1l80
Section B:Facility Data J
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 11:39AM 14/12/03 12/06/01
Daniel Stowe Botanical Garden WTP
6500 S New Hope Rd Exit Time/Date Permit Expiration Date
01:15PM 14/12/03 15/08/31
Belmont NC 28012
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Kara Newport,6500 S New Hope Rd Belmont NC 2801211704-829-1254/
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
Marcia Allocco ,tom MRO WQ//704 663 1699 Ext.2204/ I,9 i
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

NPDES yr/mo/day Inspection Type (Cont.)
31 NC0088684 I11 121 14/12/03 117 18 IA
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Continued from the"Recordkeeping"section of the report:
-Only one pH concentration was reported for July and August of 2014 whereas the permit requires
twice per month monitoring. Please submit an amended DMR for both months with the missing values
(July 30th and August 26th.
-The March 2014 DMR does not note the failure of the whole effluent toxicity testing performed on
March 18,2014. Please submit an amended DMR with the missing toxicity testing.
-The copper and zinc concentrations on the July 2014 DMR were reported with the wrong units of
measure; please revise this data and submit an amended July 2014 DMR.
You are currently reporting flow using an incorrect EPA parameter code. Please revise your DMR
template for all future submissions;flow should be reported under EPA parameter code 50050 not
00059.
You have been reporting turbidity using units of measure of"mg/L"whereas the correct units of
measure are NTU; please revise your DMR template to reflect the correct units of measure.
The contracted analytical laboratory is noting a flow totalizer reading twice during each monitoring
month but only reporting one flow value as required by the permit. The NPDES Permit Standard
Conditions that apply to all NPDES permits(Part II of your permit that appears after Section A(3)) notes
the following in Section E. regarding Reporting Requirements. Specifically, Item 5 on monitoring
reports notes,"If the permittee monitors any pollutant more frequently than required by this permit using
test procedures approved under 40 CFR Part 136 and at a sampling location specified in this permit or
other appropriate instrument governing the discharge(e.g. a flow meter),the results of such monitoring
shall be included in the calculation and reporting of the data submitted on the DMR."Please ensure that
flow is reported for each day a totalizer reading is taken on future monthly DMRs.
Page# 2

Permit NC0088684 Owner-Facility: Daniel Stowe Botanical Garden WTP
Inspection Date: 12/03/2014 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 0 0 IN ❑
application?
Is the facility as described in the permit? • 0 0 ❑
#Are there any special conditions for the permit? • 0 0 0
Is access to the plant site restricted to the general public? • 0 0 0
Is the inspector granted access to all areas for inspection? • 0 0 0
Comment: The current permit was issued on May 4,2012,with an effective date of June 1,2012. The
permit exaires on August 31,2015 and as per the Standard Conditions of your permit(Part
II. Section B General Conditions, Item 10 Expiration of Permit you must submit a permit
renewal application 180 days prior to expiration:therefore the Division must receive your
renewal application by February 28,2015.The current permit contains a Whole Effluent
Toxicity Monitoring permit re-opener special condition.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • 0 0 0
Does the facility analyze process control parameters,for ex: MLSS,MCRT,Settleable 0 0 • 0
Solids, pH,DO, Sludge Judge, and other that are applicable?
Comment:
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting? • 0 0 0
Is flow meter calibrated annually? 0 0 I 0
Is the flow meter operational? • 0 0 0
(If units are separated)Does the chart recorder match the flow meter? 0 0 IN 0
Comment: The permit requires instantaneous flow monitoring but the permittee has historically used a
flow meter to provide estimated flow readings. The installed flow meter was inoperable so a
new meter and totalizer was installed by Clearwater, Inc. in May 2014. The flow meter was
calibrated during installation.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? 0 0 U 0
Is sample collected below all treatment units? • 0 0 ❑
Is proper volume collected? • ❑ 0 0
Is the tubing clean? 0 0 II 0
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • ❑ 0 ❑
Celsius)?
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Permit NC0088684 Owner-Facility: Daniel Stowe Botanical Garden WTP
Inspection Date: 12/03/2014 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency,sampling type • 0 0 0
representative)?
Comment: The permit requires grab samples for all required parameters,which are collected in the
manhole outside the orchid conservatory.All effluent samples and associated water quality
readings(pH)are collected by staff from the contracted analytical laboratory(K&W
Laboratories); staff from K&W Laboratories was not present during the inspection.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? • 0 0 0
Are the receiving water free of foam other than trace amounts and other debris? • 0 0 0
If effluent (diffuser pipes are required) are they operating properly? 0 0 • 0
Comment: There was no discharge of wastewater through the permitted outfall during the inspection.
The effluent discharges a small distance from the unnamed tributary to Catawba Creek.
The unnamed tributary was flowing for a short distance upstream of the outfall during the
site visit(noted as a"dry ditch"in last staff report prepared for permit renewal).
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? • 0 0 0
Are all other parameters(excluding field parameters)performed by a certified lab? • 0 0 0
#Is the facility using a contract lab? • 0 0 0
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • 0 0 0
Celsius)?
Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? 0 0 • 0
Incubator(BOD)set to 20.0 degrees Celsius+/-1.0 degrees? 0 0 • 0
Comment: K&W Laboratories(certification#559) has been contracted to provide analytical support
and subcontracts the whole effluent toxicity testing to Meritech. A review of the analytical
data attached to the monthly DMRs notes that the samples were placed on ice during
delivery to the analytical laboratory: COCs note that the receipt temperature met the 6
degrees Celsius unfrozen as per 40 CFR 136 Table II.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • 0 0 0
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? 0 U 0 0
Is the chain-of-custody complete? • 0 0 0
Dates,times and location of sampling •
Name of individual performing the sampling U
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•
° Daniel Stowe Botanical Garden WTP
Permit: NC0088684 Owner-Facility:
Inspection Date: 12/03/2014 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Results of analysis and calibration •
Dates of analysis •
Name of person performing analyses ❑
Transported COCs •
Are DMRs complete:do they include all permit parameters? U 0 0 0
Has the facility submitted its annual compliance report to users and DWQ? 0 0 • 0
(If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator 0 0 • 0
on each shift?
Is the ORC visitation log available and current? 0 0 • 0
Is the ORC certified at grade equal to or higher than the facility classification? 0 0 • 0
Is the backup operator certified at one grade less or greater than the facility classification? 0 0 • 0
Is a copy of the current NPDES permit available on site? 0 • 0 0
Facility has copy of previous year's Annual Report on file for review? 0 0 U ❑
Comment: A copy of the current permit was provided during the inspection. K&W Laboratories
(certification#559) has been contracted to provide analytical support and subcontracts the
whole effluent toxicity testing to Meritech. A review of the analytical data attached to the
monthly DMRs notes that the samples were placed on ice during delivery to the analytical
laboratory;COCs note that the receipt temperature met the 6 degrees Celsius unfrozen as
per 40 CFR 136 Table II.
Monthly discharge monitoring reports(DMRs)were reviewed for June 2013 through August
2014 for the inspection. No limit or monitoring violations were reported during the review
period but transcription errors were noted. Please refer to the additional information
provided in the°Summary°section of this report for additional information.
Page# 5