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Home My WebLink AboutNC0021717_NOV2023PC0489_202309CEI_20230928ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Town of Wilkesboro Attn: Kenneth Nolan, Town Manager PO BOX 1056 Wilkesboro, NC 28697-1056 NORTH CAROLINA Environmental Quality September 26, 2023 SUBJECT: Compliance Evaluation Inspection & Notice of Continuing Violations NOV Tracking #: NOV-2023-PC-0489 Cub Creek Wastewater Treatment Plant NPDES Permit Number: NCO021717 Wilkes County Dear Mr. Noland: On September 81", 2023, Division of Water Resources staff, Tricia Lowery, conducted a routine compliance evaluation inspection at the Cub Creek Wastewater Treatment Plant, NPDES permit NC0021717. Operator in Responsible Charge (ORC), Glenn Clark, was present during the inspection. A review of records, data, treatment components, structures, and the outfall was completed. This inspection reflected non-compliance with the subject permit. The following violations were documented during the inspection: 1. Many components of the POTW are out of service, and some of these components have been out of service since 2020 according to previous inspection reports. This represents a violation of Part II, Section C (2) "Operations and Maintenance of Pollution Control" of permit NC0021717. These are repeat violations, as they were also documented in NOV- 2020-PC-0053 dated February 6, 2020. 2. Floating solids and scum were present in the pre -UV effluent channel. This is a repeat violation and documented in NOV-2020-PC-0053 dated February 6, 2020. This is a violation of Part II, Section (C) (2) "Operations and Maintenance of Pollution Control" of permit NC0021717. Other item of concern from the inspection are as follows: Moan D_,E, North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 1. The facility appears to have a buildup of debris throughout multiple components of the WWTP. DWR staff noted debris making it past the bar screens and into the rest of the treatment components. According to Part II, Section (C)(2) "Operations and Maintenance of Pollution Controls" of the permit, "The Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit.". Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, please respond in writing to this office within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. Please feel free to contact me at 336.776.9700, or by email lon.snider@deg.nc.gov with any questions or concerns you may have. Sincerely, DocuSigned by: 145B49E225CMEA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: 1. Water Compliance Inspection Report REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly D North Carolina Department of Environmental Quality I Division of Water Resources ✓ Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CAROLINA 336.776.9800 onparhnem of EmironmanW 9uallly DocuSign Envelope ID: 170F5E6C-9B54-40F9-8AAB-239878CE222A 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 1 IN 1 2 u 3 I NC0021717 I11 121 23/09/08 I17 18I � I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I n, I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES Dermit Number) 10:OOAM 23/09/08 16/02/01 Cub Creek WWTP 701 Snyder St Exit Time/Date Permit Expiration Date Wilkesboro NC 28697 12:OOPM 23/09/08 19/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Bryan Russell Johnson/ORC/336-452-7657/ Glenn Owen Clark/ORC/336-667-6228/ James D Fletch er/ORC/336-667-2391/ Kenneth Ross Johnson/ORC// Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Dustin Colburn,PO Box 1056 Wilkesboro NC 286971056/ORC/336-981-1078/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 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 Patricia Lowery DWR/WSRO WQ/336-776-9691/ by: 9/21/202 3 LDocuSigned ct�V'iCia (,owt,V't� Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 9/27/2023 FL' T. 5,,o r EPA Form. *WY( 45-t4) Previous editions are obsolete. Page# DocuSign Envelope ID: 170F5E6C-9B54-4OF9-8AAB-239878CE222A NPDES yr/mo/day Inspection Type (Cont.) NCO021717 I11 12I 23/09/08 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On 9/8/2023, Division of Water Resources staff Tricia Lowery conducted a routine compliance inspection at Cub Creek WWTP (NC0021717). Glenn Clark and Amber Garwood were present during the inspection. A review of records, data, treatment components, structures, fields, etc. was completed. This review reflected non-compliance with the subject permit. The following items of concern were noted: 1. Many components of the POTW are out of service and have been for —3 years. (One mechanical bar screen, the grit system, a surface aerator, digester, clarifier) 2. Overall the WWTP is having difficulty screening solids at headworks. The buildup of debris can be seen past bar screen process. Ineffective screening can and will have impacts on post headwork processes of WWTP. 3. Ongoing issues with DO levels in the aeration basin. DO readings are below 1.0 mg/I 4. Floating solids and scum in the pre -UV channel. POTW is using water hose to disperse scum. However, the effluent is clear with no floating solids. The use of the water hose was noted during the last inspection. Notes: 1. Records were in excellent order. No issues found. 2. The laboratory was very clean with no issues found. 3. Recent personnel changes. New ORC — Glenn Clark. 4. The facility is in planning stage of upgrades. This POTW is in critical need of upgrades. Page# DocuSign Envelope ID: 170F5E6C-9B54-4OF9-8AAB-239878CE222A Permit: NCO021717 Owner -Facility: Cub Creek WWTP Inspection Date: 09/08/2023 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 ■ ❑ ❑ ❑ 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? ■ ❑ ❑ ❑ Comment: Permit expired 9/2019. They are in process of getting all requirements, plans, and AtCs in order to upgrade facility. They are still operating at 4.9 MGD. The future expansion is looking to increase flow to 7-10 MGD. Record Keeping Yes No NA NE 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? ■ ❑ ❑ ❑ Page# 3 DocuSign Envelope ID: 170F5E6C-9B54-4OF9-8AAB-239878CE222A Permit: NCO021717 Owner -Facility: Cub Creek WWTP Inspection Date: 09/08/2023 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: Records are in good order. Inspector was able to find all information without difficulty. Inspector reviewed October 2022 and April 2023 DMRs against laboratory bench sheets. All data entered correctly with no errors. ORC and BORCS are certified at proper grade for facility. Recent change in ORC for facility. Dustin Colburn is no longer at facility. POTW complied with 08G rules in designating new ORC/BORC. 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? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ Comment: Metals and Organics are sent to Meritech. Conventional parameters are conducted at POTW lab. Lab is clean and organized. No expired standards/reagents. Temperatures of incubators at proper temperatures. 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? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ Comment: Process controls are analyzed (SS, microscopic microorganism evaluation). Loq is kept of results. There are several operational units that have been out of service for 3 years (mechanical bar screen, grit removal, surface aerators, clarifiers, digestor). ORC stated Darts are scarce/hard to aet or non existent due to the outdated units. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Comment: Influent pumps: 1. One is owned and maintained by Tyson. 2. 3 for POTW (2 are used alternatively and 1 back up). Page# 4 DocuSign Envelope ID: 170F5E6C-9B54-4OF9-8AAB-239878CE222A Permit: NCO021717 Owner -Facility: Cub Creek WWTP Inspection Date: 09/08/2023 Inspection Type: Compliance Evaluation Flow Measurement - Influent # 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? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: No issues found during inspection. Piedmont Automation conducts calibrations. Calibrated 7/7/2023. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? 0 ❑ ❑ ❑ Comment: No issues found during inspection. Piedmont Automation conducts calibrations. Calibrated 7/7/2023. Influent Sampling # Is composite sampling flow proportional? Is sample collected above side streams? 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 sampling performed according to the permit? Comment: -3 C temp in sampler. Flow proportionate. 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)? Comment: ~4 C temp in sampler. Flow proportionate. Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: 170F5E6C-9B54-4OF9-8AAB-239878CE222A Permit: NCO021717 Owner -Facility: Cub Creek WWTP Inspection Date: 09/08/2023 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Bar Screens Yes No NA NE Type of bar screen a.Manual ❑ b.Mechanical Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? ■ ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? ❑ 0 ❑ ❑ Comment: One channel is out of service and has been for —3 years. The unit is not in good condition. Again, POTW is in the process of upgrades. Bar screen is an auger/screw press. It adequately screens most solids, but having one down increases stress on other screens. Debris is properly disposed and taken to landfill. Grit Removal Type of grit removal a.Manual b.Mechanical Is the grit free of excessive organic matter? Is the grit free of excessive odor? # Is disposal of grit in compliance? Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: Grit system has been out of service for —3 years. Grit is not being properly screened. Overall the WWTP is having difficulty screening solids at headworks. Build up of debris can be seen past bar screen process. Ineffective screening can and will have impacts to post headwork processes of WWTP. Equalization Basins Yes No NA NE Is the basin aerated? ❑ ❑ 0 ❑ Is the basin free of bypass lines or structures to the natural environment? ❑ ❑ 0 ❑ Is the basin free of excessive grease? ❑ ❑ 0 ❑ Are all pumps present? ❑ ❑ 0 ❑ Are all pumps operable? ❑ ❑ ■ ❑ Are float controls operable? ❑ ❑ 0 ❑ Are audible and visual alarms operable? ❑ ❑ 0 ❑ # Is basin size/volume adequate? ❑ ❑ 0 ❑ Page# 6 DocuSign Envelope ID: 170F5E6C-9B54-4OF9-8AAB-239878CE222A Permit: NCO021717 Owner -Facility: Cub Creek WWTP Inspection Date: 09/08/2023 Inspection Type: Compliance Evaluation Equalization Basins Yes No NA NE Comment: This is owned and operated by Tyson. Tyson allows POTW to utilize basin if needed. 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? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/I) Yes No NA NE Ext. Air Surface ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ Comment: 6 surface aerators in use / 1 out of service. Proper odor (earthy) and no unusual color. DO levels have been on ongoing issue in the basin. DO readings are <1 mg/I. Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: One clarifier out of service. Little clarity in basins. Evidence of solids as liquid is still heavily brown in color. Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? 0 ❑ ❑ ❑ Are UV bulbs clean? 0 ❑ ❑ ❑ Is UV intensity adequate? 0 ❑ ❑ ❑ Page# 7 DocuSign Envelope ID: 170F5E6C-9B54-4OF9-8AAB-239878CE222A Permit: NCO021717 Owner -Facility: Cub Creek WWTP Inspection Date: 09/08/2023 Inspection Type: Compliance Evaluation Disinfection - UV Yes No NA NE Is transmittance at or above designed level? 0 ❑ ❑ ❑ Is there a backup system on site? ❑ 0 ❑ ❑ Is effluent clear and free of solids? 0 ❑ ❑ ❑ Comment: Continuing to use water hose - spraying pre UV channel to disperse scum and floating solids. Still an issue after 3 inspections. The effluent past UV channel is clear of floating solids and scum. The sprayer seems to be effective, however no floating solids are scum should be in this channel. Aerobic Digester Yes No NA NE Is the capacity adequate? ❑ ❑ ❑ ❑ Is the mixing adequate? ❑ ❑ ❑ ❑ Is the site free of excessive foaming in the tank? ❑ ❑ ❑ ❑ # Is the odor acceptable? ❑ ❑ ❑ ❑ # Is tankage available for properly waste sludge? ❑ ❑ ❑ ❑ Comment: One digester is down. The operational digester has adequate mixing and the capacity seems to handle inflow. No foul odor or excessive foaming. Solids Handling Equipment Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Yes No NA NE ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Comment: Screw press to landfill. Was not running during inspection, therefore the inspection was limited and could not fully examine. Drying Beds Yes No NA NE 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? ❑ ❑ ❑ Page# 8 DocuSign Envelope ID: 170F5E6C-9B54-40F9-8AAB-239878CE222A Permit: NC0021717 Owner -Facility: Cub Creek WWTP Inspection Date: 09/08/2023 Inspection Type: Compliance Evaluation Drying Beds # Is the sludge disposed of through county landfill? # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Comment: Drying beds are not in use. 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? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: No issues found during inspection. Yes No NA NE ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑ and sampling location)? Comment: Permittee maintains membership with Yadkin/Pee Dee River basin which conducts monitoring. Page# 9