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:
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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
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Yes No NA NE
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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
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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
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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
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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
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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
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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
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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
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Yes No NA NE
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El El El El
Page# 6