NC0020931_NOI_NOV2020PC0155_&_NOV2019OV0003_20200331

Boonvd[e
Crossroads of the Yadkin Valley
March 31, 2020
Lon T Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Dear, Lon T Snider
NC Department of
Environmental Quality
Received
APR 0 3 2020
Winston-Salem
Regional Office
Toam of Boonville
PO Box 326
110 N. Carolina Avenue
Boonville, North Carolina 27011
On behave of the Town of Boonville, I am writing a response to the Letter we received from your office
dated March 17, 2020.
Currently the Town of Boonville uses Mission Communication for our monitoring. We have only used it
for High flow alarms along with power outages. Since we have had some miss calculations with our flow
data, I have contacted Mission to see if we could add a totalizer. Mission is going to add a totalizer so I
will receive it with my daily report. With this in place, we will have a back to double check our
calculation.
Us not having a backup ORC on record is an over sight. About 18 months ago, the Town sent Steve
Hutchens to Waste treatment operator class. When he received his operator certification, he filled out
the forms to be assigned to our backup ORC list. We assumed that is was documented with the State of
North Carolina. Since this was brought to our attention, we found out he was not listed and since, we
have resubmitted his paperwork to the State of North Carolina and faxed a copy to the Winston Salem
Regional office.
Town of Boonville received a SRF loan in 2017 for our waste treatment plant upgrades. During the
construction, Plant #2 floated out of the ground. After the floating of Plant #2, the town board fired the
engineer, Municipal Engineering, and hired WithersRavenal to finish the project. We also had an
Attorney looking into litigation. Since January 2020, the contractor has been on site working to finish the
plan set in place by WithersRavenal. The most current schedule is for the project to be completed by
the end of April 2020.
During Ron's first visit, we found out that our Effluent sampler was over sampling. Since his last visit, we
worked on getting it calibrated and found that the hose was cut the wrong length. We replaced the hose
to the right length, which got us very close (120ml = 150ml), but not 100% right. I contacted Eric with
Clearwater about our problem. When he got on site, we started looking over the sampler to find that
the liquid detector was not enabled. Once we turned that on, we ran 6 samples to find it 100% accurate.
During the beginning of Construction, Plant #1 floated also, but nowhere near as bad as Plant #2. At the
time, we put Plant #1 back into service the weirs of Plant #1 and Plant #2 were with in 100t6 of each
Ph:336.367.7941 Fax:[phone] boonvillenc.com
Nlapor: Vaughn Benton;
Commissioners: William Paul Bairy, Monica Craver, Richard Lasky, Justin Phillips, Tony Reece

other. I assume that over the last couple of years the tank has settled a little more, which has gotten the
weir level off. By the end of April, our plan is to have the weirs leveled up. I talked with our engineer
about the rake arms on Plant #1, and what a possible means to address the efficiency seen by our
inspector. After our discussion, the plant was designed to have the arms clear from the center to the
skimmer box that is positioned on the other edge of the clarifier. The engineer did recommend that we
replace the rubber flaps on the arms themselves. We should be able to do all that work at the same time
we are making the changes to the weirs.
If you have any questions, please do not hesitate to contact me at [e-mail] or my cell
336.466.0887.
Thank you for your time,
j
Director / ORC

r _�
ROy:COOPER
Governor
MICKNE4.5. RECZAN
SecettiPy
S. DAMEL SM171H
Director
NORTH,CAROLINA
,Ertviiomnentci QudJhr
CERTIFIED MAIL #7017 1450 0001 6450 1211
RETURN RECEIPT REQUESTED
Vaughn Benton, Mayor
Town of Boonville
P.O. Box 326
Boonville, NC 27011
(� _ 26 Zo -6o 35
SUBJECT: Notice of Continuing Violation of NOV-2019-OV-0003; &
Additional Notice of Violation/Notice of Intent to Enforce: NOV-2020-PC-0155
Permit # NCO020931
Yadkin County
Dear Mr. Benton:
On March 5, 2020, Mr. Ron Boone, from the Division of WaterResources' Winston-Salem Regional
Office (WSRO), performed a follow-up inspection regarding the Notice of Violation (NOV72019-OV-0003)
sent August 23, 2019. During the inspection, WSRO staff noted several continued violations of NOV-
2019-OV-0003, as well as additional new violations. Copies of the follow-up inspection reports are
included for your records. While onsite, the following additional violations were noted by WSRO staff
and,may be included in any future enforcement action against,your facility:
New Violations
1. Review of the October through December 2019 DMRs revealed several data collection/recordation
errors forthe flow parameter.
Corrective action: Immediately begin an in-depth examination of all flow data and the collection and
calculation methods used to ascertain daily flow values to determine the extent and cause of the
errors and then develop and implement corrective procedures to rectify the cause(s).
Continued Violations/Additional Observations:. 1
2. None of the currently designated six backup operators work at the facility. There is therefore no
backup operator properly designated as required by the permit. i
y°I r b75rD
Corrective action: Immediately designate at least one properly certified backup operator for the plant.
3. The second treatment train, which floated out of the ground about 2'to 3 years ago when it was
drained to facilitate maintenance and resurfacing, has still not been reset and placed back in service.
10"Department ofEnvirmunental
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336.716.9000

Corrective action: Immediately make all necessary repairs to this treatment train and place it back in
service. or
4. The effluent sampler is not properly programmed or set up to collect the proper size iquots for the
24-hour flow proportional composite sampling regime for which it is being used. Accordin o the
operator, it draws approximately twice the amount needed for each aliquot it pulls.
Corrective action: Immediately reprogram the sampler and/or make all necessary changes to it
installation to enable it to begin pulling the correct size aliquots.s o�
5. The overflow weir on the secondary clarifier of the first treatment train is not level and the scum \
skimmer arm in ineffective, or at best, minimally effective.
Corrective action: Immediately take the necessary steps to begin repairs to the first treatme t train's
secondary clarifier to level the weir and repair the scum skimmer arm./ on -
Written
Please respond in writing to our office within 10 days of your receipt of this Notice describing the
actions you have already taken, or propose to take, to address the violations described 'above. Your
response should be sent to my attention at the address listed in the footer on page one.
If you have questions or concerns regarding this Notice, please contact Ron Boone by phone at (336)
776-9690 or by email at [e-mail]. You may also contact me by phone at [phone]
or by email at [e-mail].
Sincerely,
Lon T. Snider
Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Attachments:
1. BIMS Water Compliance Inspection Report
cc: Laserfiche

United. States Environmental Protection Agency
Form Approved.
EPA 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
I
1 IN ( , 2 IS I 3 I N00020931 I11 12 20/03/05 17 18 LCj 191 c I 201 I
21II11II IIlIIIIlIlI IIIIIII I IIIIII IIIIIIIIIII I6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -------Reserved------
I 72 I N 73II I 174 75� I I I I I I I80
67L .......... j 701 LJ I 711 liL
JI I I
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Dale
POND name and NPDES permit Number)
09:OOAM 20/03/05
19/01/01
Boonville WWTP '
Exit Time/Dale
Permit Expiration Date
110 Carolina Ave -
Boonville NC 27011
12:00PM 20/03/05
23/12/31
Name(s) of Onsite Representative(s)lTtles(s)/Phone and Fax Number(s)
Other Facility Data
Jeffrey Eugene Jones/ORC/252-639-7544/
Name, Address of Responsible OffcialRtle/Phone and Fax Number
Robert Gardner,PO Box 326 Boonville NC 270110326//336-367-7941/3363674205 Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Prograr 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) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boone DWRNVSRO WQ1336-776-9690/
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#

NPDES yr/mo/day Inspection Type (Cont.)
31 NCO020931 I11 1 20/03/05 17 18 i C i
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This is a follow up inspection from the August 2019 inspection which resulted in a Notice of Violation
with Intent to Enforce.
Data collection, reporting, and maintenance appears to have improved somewhat with the assistance
the Town has received from the DWR Laboratory certification unit However, during this inspection Mr.
Boone noted several erroneous flow meter readings on the DMRs from October thru December 2019.
The erroneous data appears to be either calculation or transcription errors. This is a vioilation.
The ORC reported to Mr. Boone during this inspection that the effluent sampler is still not pulling the
required amount of sample for each aliquot. The ORC stated the sampler still pulls about twice as
much sample as needed for each aliquot. The ORC indicated he just has not been able to get it fixed
yet. Given the fact that this was also a violation noted during the August 2019 inspection, this is a
continuing vioilation.
The plant description lists a comminutor but there isn't one installed. The plant description should be
updated to correct this mistake. The Division will not reopen a permit to update one minor errant
component in the plant description, but the Town should make sure this change is made during the
next permit rewrite.
As was also noted during the August 2019 inspection, none of the currently assigned six backup
operators work at the plant. Mr. Jones stated that Mr. Steve Hutchins is his backup operator but he is
not so designated in DWR's database. Therefore the plant does NOT have a designated backup
operator. This constitutes a continuing violation.
It was noted during the August 2019 inspection that the overflow weir on the first treatment train's
clarifier is not level and the scum skimmer arm appears ineffective, or minimally effective. The ORC
stated during this inspection that nothing has been done to address these issues as of yet, which
constitutes a continuing violation.
This plant consists of three individual treatment trains; one circular (100K GPD), and two rectangular
(50K GPD,each). One of the rectangular units floated approximately 2 to 3 years ago when it was
emptied to facilitate maintenance and resurfacing. Unfortunately, the unit has not been reset and
placed back in service yet, in part due to difficulties the town has experienced with the first contractor
that was hired to do the work. A new contractor has now been hired. This is a continuing violation.
Many components throughout the treatment process are old and quite dilapidated, and possibly as a
result, ineffective, or partially so. For example the clarifier's skimmer on treatment train #1, appears
minimally effective, but it's effect on the plant's overall effectiveness is unknown. As such the skimmer
should be repaired to attain its maximum effectiveness as it was intended when first installed.
Otherwise the unit should be removed from the treatment process, following the procedures and
protocol established by DWR in approving NPDES permits.
Facility dependability is questionable at this point
Page#

Permit: NCO020931
Inspection Date: 03/05/2020
Owner -Facility: BoonvillevwvTP
Inspection Type: Compliance Evaluation
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 operato
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 atone 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
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M
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M
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Comment: Data collection and recordation of field laboratory data seems to have improved since the
August 2019 inspection. However, review of the October thru December 2019 DMRs during
this inspection revealed several errors on the data collection and recordation of flow. This
process should be reviewed and refined to prevent such flow reporting errors. This is a
violation.
Also, none of the six currently designated backup operators work at the facility. There is
currently no backup operator officially designated, as was also noted during the August 2019
inspection This is a continuing violation.
Permit
Yes
No
NA
NE
(If the present permit expires, in 6 months or less). Has the pennittee submitted a new
❑
❑
0
E
application?
Is the facility as described in the permit?
❑
0
❑
❑
# Are there any special conditions for the permit?
❑
M
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❑
Is access to the plant site restricted to the general public?
0
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❑
Page# 3
I

Y
Permit: NCO020931 Owner -Facility: BoonvillewWTP
Inspection Date: 03105/2020 Inspection Type: compliance Evaluation
Permit Yes No NA NE
Is the inspector granted access to all areas for inspection? ❑ ❑ ❑
Comment: Permit says there's a comminutor but there isn't.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
M
❑
❑
❑
# Is the facility using a contract lab?
0
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# 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?
❑
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N
Incubator (BOD) set to 20.0 degrees Celsius +/-1.0 degrees?
❑
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❑
Comment: None
Influent Sampling
Yes
No
NA NE
# Is composite sampling flow proportional?
0
❑
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Is sample collected above side streams?
0
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Is proper volume collected?
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0
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Is the tubing clean?
N
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
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❑
❑
Celsius)?
Is sampling performed according to the permit?
0
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Comment: Influentlflow proportional composite samples are taken paced on effluent flow. Effluent
sampler is not taking the correct size aliquots since at least the last inspection in August
2019. It is therefore also likely that the influent sampler is not taking the correct size aliquots
Effluent Sampling
Yes
No
NA NE
Is composite sampling flow, proportional?
M
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Is sample collected below all treatment units?
0
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Is proper volume collected?
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0
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Is the tubing clean?
M
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
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❑
M
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
M
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representative)?
Page# 4

Permit: NCO020931 Owner -Facility: Boonville Vw\ rP
r
Inspection Date: 0310512020 Inspection type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Comment: Effluent sampler is not takinq correct size aliquots since at least the last inspection in Auaust
2019. Operator stated he has gotten the effluent sampler to collect less sample per aliquot
but it still collects about twice the amount it should per aliquot. He is still working on the
issue. This is a continuing violation.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, anc N ❑ ❑ ❑
sampling location)?
Comment: None
Flow Measurement - Influent
Yes
No
NA NE
# Is flow meter used for reporting?
E
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Is flow meter calibrated annually?
N
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Is the flow meter operational?
0
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(If units are separated) Does the chart recorder match the flow meter?
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E
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Comment: None
Bar Screens Yes No NA -NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
0
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Is the screen free of excessive debris?
0
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Is disposal of screening in compliance?
0
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Is -the unit in good condition?
0
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Comment: Manual barscreen in use at time of inspection
due to power being disconnected.from
mechanical bar rake to facilitate ongoing
construction to reset treatment train #2.
Aeration Basins
Mode of operation
Type of aeration system
Is the basin free of dead spots?
Are surface aerators and mixers operational?
Are the diffusers operational?
Is the foam the proper color for the treatment process?
Yes No NA NE
Ext. Air
Diffused
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E
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Page# 5
I

Permit: NCO020931 - Owner -Facility:
Inspection Date: 0310512020 Inspection Type:
eocnville VWVTP
Compliance Evaluation
Aeration Basins
Yes
No
NA NE
Does the foam cover less than 25% of the basin's surface?
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0
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Is the DO level acceptable?
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M
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Is the DO level acceptable?(1.0 to 3.0 mg/1)
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0
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Comment: As was also noted during the Auqust 2019 inspection, the second treatment train is still out
of the ground (it floated approximately 2 to 3 years ago when it was drained for
maintenance). According to the ORC resetting the treatment train and placing it back in
service has been delayed by difficulties with contractors and lawyers. This is a continuing
violation.
Secondary Clarifier
Yes
No
NA NE
Is the clarifier free of black and odorous wastewater?
0
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Is the site free of excessive buildup of solids in center well of circular clarifier?
0
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Are weirs level?
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M
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Is the site free of weir blockage?
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Is the site free of evidence of short-circuiting?
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0
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Is scum removal adequate?
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0
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Is the site free of excessive floating sludge?
0
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Is the drive unit operational?
M
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Is the return rate acceptable (low turbulence)?
0
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Is the overflow clear of excessive solids/pin floc?
0
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Is the sludge blanket level acceptable? (Approximately Y. of the sidewall depth)
0
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Comment: As was also noted during the August 2019 inspection,
the weirs on the clarifier of the 1 st
treatment train are not level and the scum scraper
arm is minimally effective. This is a
continuing violation.
Pumps-RAS-WAS
Yes
No
NA NE
Are pumps in place?
0
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Are pumps operational?
0
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Are there adequate spare parts and supplies on site?
0
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Comment: None
Flow Measurement- Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
M
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Is flow meter calibrated annually?
M
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Is the flow meter operational?
M
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(If units are separated) Does the chart recorder match the flow meter?
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Page# 6

Permit: NC0020931 Owner -Facility: Boonville wvvTP
Inspection Date: 03/0512020 Inspection Type: Compliance Evaluation
Flow Measurement 'Effluent Yes No NA NE
Comment: Calibrated 11/2019.
Disinfection - UV
Yes
No
NA NE
Are extra UV bulbs available on site?
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Are UV bulbs clean?
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Is UV intensity adequate?
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Is transmittance at or above designed level?
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Is there a backup system on site?
0
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Is effluent clear and free of solids?
0
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Comment: Effluent appears clear and free of solids. The permittee should indicate in their written
response to this report what the backup
disinfection system is in case the UV lights fail.
Effluent Pipe
Yes
No
NA NE
Is right ofway to the outfall properly maintained?
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Are the receiving water free of foam other than trace amounts and other debris?
1-1
El
El
If effluent (diffuser pipesare required) are they operating properly?
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Comment: None
Drying Beds
Yes
No
NA NE
Is there adequate drying bed space?
0
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Is the sludge distribution on drying' beds appropriate?
M'
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Are the drying beds free of vegetation?
M
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# is the site free of dry sludge remaining in beds?
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Is the site free of stockpiled sludge?
0
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Is the filtrate from sludge drying beds returned to the front of the plant?
E
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# Is the sludge disposed of through county landfill?
M
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# Is the sludge land applied?
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M
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(Vacuum filters) Is polymer mixing adequate?
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M
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Comment: None
Operations & Maintenance Yes No NA NE
Page# 7
I
i

Permit: NCO020931
Inspection Date: 03/05/2020
Owner -Facility: Boonville WJVTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ 0 ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable M ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are.applicable?
Comment: The plant is currently under construction to reset the second treatment train in the ground.
of time. The Division is concerned about the plant's future ability to effectively treat the
town's wastewater to within permit limits.
Standby Power
Yes
No
NA NE
Is automatically activated standby power available?
0
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Is the generator tested by interrupting primary power source?
0
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Is the generator tested under load?
0
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Was generator tested & operational during the inspection?
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0
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Do the generator(s) have adequate capacity to operate the entire wastewater site?
M
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Is there an emergency agreement with a fuel vendor for extended run on back-up power?
0
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Is the generator fuel level monitored?
0
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Comment: None
Page# 8