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HomeMy WebLinkAboutNC0003042_Compliance Evaluation Inspection_20210518ROY COOPER Governor DIONNE DELLI-GATTI Secretary S. DANIEL SMITH Director Thomas S. Warren, Assistant City Manager City of Roxboro PO Box 128 Roxboro NC 27573-0128 NORTH CAROLINA Environmental Quality May 18, 2021 Subject: Notice of Deficiency and Compliance Evaluation Inspection Case No.: NOD-2021-PC-0371 Roxboro Water Treatment Plant (Middle Creek) NPDES Permit No. NC0003042 Person County Dear Mr. Warren: On March 24, 2021, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a compliance evaluation inspection of the subject facility. The assistance provided by Mr. Arnold Oakley, Operator in Responsible Charge (ORC) was appreciated. The inspection report is attached. The following observations were made: 1. The facility is permitted to discharge treated wastewater into an unnamed tributary to Marlow Creek a Class-C water in the Roanoke River Basin. Current permit became effective on April 1, 2018 and will expire on March 31, 2023. 2. The plant is classified as a Grade 1 Physical and Chemical (PC-1) wastewater facility. Mr. Arnold Oakley is the ORC. Mr. Gregory Long is the backup ORC. Daily operation log books are kept on -site going back at least three years. 3. Field parameters are analyzed using meters calibrated by Roxboro WWTP staff (Field Lab Certification #191), residual chlorine is analyzed at Roxboro WWTP lab. Other parameters are analyzed by contract lab (Pace Analytical). Lab results, chain -of -custody forms, and DMRs were complete and organized and are kept for at least five years. February 2021 DMR data was compared to lab bench sheets; no data transcription errors were noted. 4. The treatment plant consists of the following units: • Lower Lagoon • Two Upper Lagoons • Pump Station • Two Sludge Drying Beds 5. Backwash from the wastewater treatment plant, including from an Ion Exchange System, flows via a gravity line to the lower lagoon. A pump station is located at the lower lagoon that can pump to the two higher lagoons. Sludge settles and is moved from the higher lagoons into the DE Q5NORTH CAROLINA n. wrynenl of en trm onengi pueiM North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office r 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 two drying beds. The water then flows back from the upper lagoons to the lower lagoon. The lower lagoon is pumped out and cleaned approximately every three months. Water is discharged from the lower lagoon to the discharge pipe through two gate valves. 6. A flow meter is present in a manhole on the effluent line before the effluent discharge to the unnamed tributary of Marlowe Creek. The flow meter is an Accuron 7200 Cartridge flow meter and was installed in July 2017. It was noted that the flow meter had not been calibrated since installation, which constitutes a permit condition violation. Part II Section D. 3. of NPDES Permit NC0003422 requires that flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. It was also noted that the temperature inside the effluent sampler was more than 6 °C. Please response in writing to RRO within 30 days regarding issues listed in Item 6. If you have any questions regarding the attached report, please contact Cheng Zhang at 919-791-4200 (or email: cheng. zhang@ncdenr. gov). Sincerely, EDocuSigned by: httAA,SSX e. Al.aaA.ttid, B2916E6AB32144F... Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources Attachments: Compliance Inspection Report Cc: Central Files w/attachment (Laserfiche) Raleigh Regional Office w/attachment Arnold Oakley, ORC (electronic copy only) North Carolina Department of Environmental Quality 1 Division of Water Resources Raleigh Regional Office 13800 Barrett Drive 1 Raleigh, North Carolina 27609 919.791,4200 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 1 Inl Code I 2 Li NPDES yr/mo/day Inspection Type Inspector Fac 3 I NC0003042 111 121 21/03/24 117 18I I 19I s I 2011 Type 21111111 1111111111I 1111111 I I 111111111111 66 1 Inspection 671 Work Days Facility Self -Monitoring 7° 1 I Evaluation Rating 711 1 B1 1 72 QA I N I 731 Reserved I 74 71 I I 1 1 1 1 1 1 1 1l80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Roxboro WTP 1599 Chub Lk Rd Roxboro NC 27573 Entry Time/Date 10:OOAM 21/03/24 Permit Effective Date 18/04/01 Exit Time/Date 11:30AM 21/03/24 Permit Expiration Date 23/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Arnold Dwayne Oakley/ORC/336-599-4906/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Thomas S Warren,PO Box 128 Roxboro NC 275730128/Assistant City Manager/336-322-6030/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Sludge Handling DispoE Facility Site Review Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) Cheng Zhang of Inspector(s) Agency/Office/Phone and Fax Numbers Date Docusignedby: DWR/RRO WQ/919-791-4200/ ej-.,,•b,2.4..... _ 5/18/2021 D6171508E1EC41F... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 5/18/2021 Vatn.t,SSa f. lAitzw l t , B2916E6AB32144F... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 31 NPDES yr/mo/day NC0003042 111 121 21/03/24 117 Inspection Type 18 Lir. (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Current permit became effective on April 1, 2018 and will expire on March 31, 2023. Backwash water and water decanted from the two holding ponds are sent to the lower lagoon, where effluent is discharged to the receiving stream. Sludge from the lower ponds is pumped to the two holding ponds to settle. Thickened slduge is sent to the two drying beds. Dried sludge is disposed of at local land fill. Field parameters (temperature, DO, and pH) were measured by staff using meters calibrated by the Wastewater Treatment Plant lab staff. Total residual chlorine is analyzed at WWTP lab. Other parameters are analyzed by the WWTP lab or by Pace. Temperature inside the sampler was more than 6 degree C at the time of inspection, the facility was not sampling though. Effluent flow meter(Accuron 7200 Cartridge flow meter) has not been calibrated since it was installed in July 2017. Page# 2 Permit: NC0003042 Owner - Facility: Roxboro WTP Inspection Date: 03/24/2021 Inspection Type: Compliance Evaluation Operations & Maintenance 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 (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? Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ Yes No NA NE ❑ ❑ • ❑ • ❑ ❑ ❑ El CI El El Comment: Current permit became effective on April 1, 2018 and will expire on March 31, 2023. 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 operatc 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? Yes No NA NE • ❑ ❑ ❑ • • ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 3 Permit: NC0003042 Owner - Facility: Roxboro WTP Inspection Date: 03/24/2021 Inspection Type: Compliance Evaluation Record Keeping Facility has copy of previous year's Annual Report on file for review? Comment: Yes No NA NE • ❑ ❑ ❑ 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: Accuron 7200 Cartridge flow meter has not been calibrated since it was installed in July 2017. Pump Station - Influent 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: Two pumps at the lower lagoon pump sludge to holding ponds. Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Lagoons Yes No NA NE Type of lagoons? Facultative # Number of lagoons in operation at time of visit? 3 Are lagoons operated in? Parallel # Is a re -circulation line present? ❑ ❑ • ❑ Is lagoon free of excessive floating materials? • ❑ ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ ❑ • ❑ Are dike slopes clear of woody vegetation? • ❑ ❑ ❑ Are weeds controlled around the edge of the lagoon? • ❑ ❑ ❑ Are dikes free of seepage? • ❑ ❑ ❑ Are dikes free of erosion? • ❑ ❑ ❑ Are dikes free of burrowing animals? • ❑ ❑ ❑ Page# 4 Permit: NC0003042 Owner - Facility: Roxboro WTP Inspection Date: 03/24/2021 Inspection Type: Compliance Evaluation Lagoons Yes No NA NE # 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? ❑ ❑ • ❑ Is the lagoon surface free of weeds? • ❑ ❑ ❑ Is the lagoon free of short circuiting? • El El El Comment: 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: Temperature, DO, and pH are measured using meters calibrated by the Wastewater Treatment Plant lab staff. Total residual chlorine is analyzed at WWTP lab. Effluent Sampling Is composite sampling flow proportional? 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)? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ Comment: Temperature inside the sampler was more than 6 degree C at the time of inspection, the facility was not sampling though. Standby 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? Yes No NA NE ❑ • ❑ ❑ • ❑ ❑ ❑ Page# 5 Permit: NC0003042 Owner - Facility: Roxboro WTP Inspection Date: 03/24/2021 Inspection Type: Compliance Evaluation Standby Power Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: Generator is tested under load monthly. 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: One of two drying beds was in use at the time of inspection. Yes No NA NE • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ El El El El Page# 6