NC0021865_NOV2017PC0117_20170217

ROY COOPER
Governor
e,s,.
;_¢ MIC.HAEL S. REGAN
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Seavtary
Wate
y Resortes S. JAY ZIMMERMAN
6PtafRd}lfl4 NTAL QUALrTY Uftc1COt'
Certified Mail # 7013 2630 0002 1133 7577
Return Receipt Requested '`� (a� ';; U1 f 1141J1!;(1) 1..1
February 21, 2017 . 1.'13 %83 ?ri181,
l'7
Patricia Garrell ,. Atzs,.,
tartn
Town of Chadbourn
602 N Brown St
Chadbourn, NC 28431 ,
SUBJECT: NOTICE OF VIOLATION &INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2017-PC-0117
Permit No. NC0021865
Chadbourn WWTP
Columbus County
Dear Permittee:
The North Carolina Division of Water Resources conducted a site inspection of the Chadbourn WWTP on February
8, 2017. This inspection was conducted to verify that the facility is operating in compliance with the conditions
and limitations specified in NPDES WW Permit No. NC0021865. A summary of the findings and comments noted
during the inspection are provided in the enclosed copy of the inspection report.
The Reconnaissance inspection was conducted by Division of Water Resources staff from the Wilmington
Regional Office. The following violation(s) were noted during the inspection:
Inspection Area Description of Violation
Effluent Sampling Facility is using a portable sampler to sample from manhole where pond's flow ties to outfall
line, but of course not flow proportional. Regional Office not notified.
Filtration (High Rate Tertiary) Filter off-line; Regional Office not notified.
Aeration Basins The center aerator in the newer, upper basin was missing with the motor sent off for repair;
Regional Office not notified.
Secondary Clarifier The original clarifier was off-line; Regional Office not notified. The online unit's skimmer is
missing its rubber seals on each end allowing a significant amount of the captured floatables
to bypass around it and not get removed.
Standby Power Unit down; Regional Office not notified.
State of North Carolina I Environmental Quality I Water Resources
127 Cardinal Drive Extension,Wilmington,North Carolina 28405
910-796-7215

Inspection Area Description of Violation
Lagoons Using in unapproved manner and discharging from them; Regional Office not notified.
Disinfection-Gas Using old system; Regional Office not notified.
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violation of North Carolina General
Statute (G.S.) 143-215.1 and the facility's NPDES Permit. Pursuant to G.S. 143-215.6A, a civil penalty of not
more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails
to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S.
143-215.1.
If you wish to provide additional information regarding the noted violation, request technical assistance, or
discuss overall compliance please respond in writing within ten (10) business days after receipt of this Notice. A
review of your response will be considered along with any information provided on the submitted Discharge
Monitoring Report(s). You will then be notified of any civil penalties that may be assessed regarding the
violations. If no response is received in this Office within the 10-day period, a civil penalty
assessment may be prepared.
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. If the violations are of a continuing nature, not related to operation and/or maintenance problems,
and you anticipate remedial construction activities, then you may wish to consider applying for a Special Order by
Consent.
Reminder: Pursuant to Permit Condition 6 in Section E, the Permittee is required to verbally notify the Regional
Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at
the facility including limit violations, bypasses of, or failure of a treatment unit. A written report may
be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or
potential problems due to planned maintenance activities, taking units off-line, etc.
If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water Quality
Regional Operations Section in the Wilmington Regional Office at 910-796-7215.
Sincerer
•
Morella—Si Wee -King, Assistant Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS
Cc: WQS Wilmington Regional Office - Enforcement File
NPDES Compliance/Enforcement Unit - Enforcement File •
Central Files, WQS
State of North Carolina I Environmental Quality I Water Resources
127 Cardinal Drive Extension,Wilmington,North Carolina 28405
910-796-7215

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
I 2 15 I 3 I N00021865 111 12 1 17/02/08 117 18I ]I 19 I S I 201
21I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 1 I I I I II I I I I I I6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
67 I 70 LI I 71 ID
I 72 I N I 731 1 174 751 1 1 1 1 1 1 180
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 oermit Number) 10:15AM 17/02/08 15/01/01
Chadbourn WWTP
5275 Chadbourn Hwy Exit Time/Date Permit Expiration Date
04:15PM 17/02/08 19/08/31
Chadbourn NC 28431
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
/1/
John Brian Stephens/ORC/910-643-2256/
Patrice E Garrell//910-654-4148/
Steven Price/Director Public Works//
Steven Price/Director Public Works/910-654-4148/9106544148
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Steven Price,602 N Brown St Chadbourn NC 28431/Public Works
Director/910-654-4148/ Yes
Section C:Areas Evaluated During Inspection(Check only those areas evaluated)
• Flow Measurement ® Operations&Maintenance 0 Self-Monitoring Program ® Sludge Handling Disposal
® Facility Site Review
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
Dean Hunkele- WIRO WQ//910-796-7215/
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Morella Sanchez-King WIRD WQ//910-796-7218/
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete.
Page# 1

NPDES yr/mo/day Inspection Type (Cont.)
31 NC0021865 I11 121 17/02/08 1 17 18 [ j
Section D:Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
This visit was a follow-up after our regional staff consultant visited the facility the previous week when
asked to go meet with the new operator that started January 1st to discuss the facility's operation
probably in connection with the findings that day and covered in this report. This visit had several Town
officials and their upgrade consulting team present, but not the new contract operator.
The facility has lots of current issues all that were not reported to the regional office as they should
have and are discussed in detail within the report. To complicate the situation, the facility is getting
ready to start construction to add or replace treatment units or equipment starting in May or June based
on approval granted in July 2016. This will be the first upgrade of the facility since it was hydraulically
doubled in size in 1998-99.
A Notice of Violation with Intent to Assess is being sent based on these findings and lack of notification.
Following this visit and discussions onsite the following actions were required by the regional office via
email notification on 2-9-17:
1. Effective next week, we are requiring 5x/week Fecal and TRC monitoring until further notice. No
other increases at this time.
2. Please advise when polymer is in use. We would expect in to be in place by March 6th. • -
3. Please advise when flow meter and proportional sampling is in place. We would expect this to be in
place and use by the 20th.
4. Please advise about back-up power ASAP, but by end of the month with timetable to implement.
During the upgrades and after the new filters are online, any use of the pond will require same
sampling as normal route with an increased fecal &TRC most likely and maybe more depending on
what is being discharged to the ponds. That data will need to be filed here locally using the old DMR
forms as we do not want to amend the permit/database for a 2nd outfall to file via e-DMR. Your
reported effluent flow would additive.
Lastly, the MLSS looked very thin in both basins and especially in the upper basin with the aerator
down. Once that is back in use (I would hope over the weekend), you need to start tracking MLSS
using the Royce portable TSS meter on-site and calibrate a reading for each using a MLSS sample
sent to the lab from each. Calibration should be done every 4-6 months.
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Page# 2

Permit: NC0021865 Owner-Facility: Chadbourn WWTP
Inspection Date: 02/08/2017 Inspection Type: Reconnaissance
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris? ❑ ❑ ❑
Is the screen free of excessive debris? ❑ ❑ ON
Is disposal of screening in compliance? ❑ ❑ ❑
Is the unit in good condition? ❑ ❑ 0111
Comment: The facility had removed the automatic inclined screening unit at some point and the
regional office was not aware'of it. The planned upgrades at the facility include replacement
of this unit.
Grit Removal Yes No NA NE
Type of grit removal
a.Manual 0
b.Mechanical
Is the grit free of excessive organic matter? ❑ ❑ E ❑
Is the grit free of excessive odor? ❑ ❑ ® ❑
# Is disposal of grit in compliance? ❑ ❑ ® ❑
Comment: The unit installed lust prior to entering the aeration basins was off-line and apparently has
been for some time, but regional office was not aware of it. The planned upgrades at the
facility include replacement of this unit. Hopefully new unit will be installed prior to the
influent pumps to minimize pump degradation and settling of material in the wetwell.
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Surface
Is the basin free of dead spots? ❑ ® ❑ ❑
Are surface aerators and mixers operational? 01100
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? 1110 ❑ ❑
Is the DO level acceptable? ❑ ❑ 01111
Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑
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Permit: NC0021865 Owner-Facility: Chadbourn WWTP
Inspection Date: 02/08/2017 Inspection Type: Reconnaissance -
Aeration Basins Yes No NA NE
Comment: The center aerator in the newer, upper basin was missing with the motor sent off for repair.
The regional office was not made aware of this fact as the last report of aerator failure was
from late June 2016 when one was lost in each basin resulting in limit violations. The mixed
liquor appeared very thin so either it has settled in the center area with the missing aerator
or it has been overwasted. The lower basin also appeared to be thinner than expected.
MLSS should be monitored in each basin and prior& after wasting.
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? 7'1 El ❑ ❑
Is the site free of excessive buildup of solids in center well of circular clarifier? ESI ❑ El El
Are weirs level? El El El
Is the site free of weir blockage? El El ❑ ❑
Is the site free of evidence of short-circuiting? %F.. El El ❑
Is scum removal adequate? El ® ❑ ❑
Is the site free of excessive floating sludge? h., ❑ El ❑
Is the drive unit operational? ® ❑ El El
Is the-return rate acceptable(low turbulence)? ® ❑ ❑ ❑
Is the overflow clear of excessive solids/pin floc? ® ❑ El El
Is the sludge blanket level acceptable?(Approximately'A of the sidewall depth) El 0 El 131
Comment: The original clarifier was off-line and had apparently been so since before the beginning of
2017; replacement parts are being fabricated and should be ready in about a month.
Regional office was not notifed of this failure. Flow from both aeration basins are using the
newer clarifier. Effluent was very cloudy with visibility of less than 6 inches. The online
unit's skimmer is missing its rubber seals on each end allowing a signifciant amount of the
captured floatabtes to bypass around it and not get removed. Use of polymer was
recommended while other clarifier is offline.
Aerobic Digester Yes No NA NE
•
Is the capacity adequate? El El ❑
Is the mixing adequate? ❑ El El 1111
Is the site free of excessive foaming in the tank? ❑ El El
# Is the odor acceptable? ❑ ❑ ❑
# Is tankage available for properly waste sludge? ❑ Si ❑ ❑
•
Comment: The volume of these units were nbt inspected on this day, but consultant indicated they were •
both full with no room to dewater the previous week. Town confirms that no sludge has
been hauled from the facility since some time in 2015. However, they are making
arrangements to have McGill dewater and haul it to their composting facility, but have yet to
sample it as required by McGill to proceed. Apparently, they will begin using them in lieu of
their own permit to dispose of it based on economic cost and staff evaluation.
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Permit: NC0021865 Owner-Facility: Chadbourn WWTP
Inspection Date: 02/08/2017 Inspection Type: Reconnaissance
Aerobic Digester Yes No NA NE
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation: Down flow
Is the filter media present? ❑ ❑ ® ❑
Is the filter surface free of clogging? ❑ ❑ RI ❑
Is the filter free of growth? 00010
Is the air scour operational? ❑ ❑ ® 0
Is the scouring acceptable? ❑ ❑ B ❑
Is the clear well free of excessive solids and filter media? 0 ❑ ± ❑
Comment: The traveling bridge filter was off-line due to piping failures below the media bed. The unit
has been off-line for about a month. Once again the regional office was not notified. •
Lagoons Yes No NA NE
Type of lagoons? Facultative
#Number of lagoons in operation at time of visit? 2
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? 0 ❑ ® 0
Are dike slopes clear of woody vegetation? ® ❑ ❑ ❑
Are weeds controlled around the edge of the lagoon? ® ❑ ❑ ❑
Are dikes free of seepage? ❑ ❑ 0 III
Are dikes free of erosion? ❑ ❑ ❑
Are dikes free of burrowing animals? ❑ ❑ ❑ MI
#Has the sludge blanket in the lagoon(s)been measured periodically in multiple ❑ 0 ® ❑
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? ❑ ❑ MI ❑
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Permit: NC0021865 Owner-Facility: Chadbourn WWTP
Inspection Date: 02/08/2017 Inspection Type: Reconnaissance ,
Lagoons Yes No NA NE
Comment:. Flow has been diverted to the two old emergency ponds following the filter failure and are
now discharging from them through the old outfall line without notifying the regional office.
The polishing ponds had been removed from the permit after the filter was added during
hydraulic expansion of the facility in 1998-99, but were put back into the permit in the 2014
renewal after it was discovered they were using them when flows to the filter exceeded its
capability and was being discharged without proper sampling and perhaps disinfection.
However, use now requires regional office notification and requires its return for treatment
and discharge through the officially permitted structures and outfall.
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately? ❑ ❑ ❑
Are cylinders protected from direct sunlight? ❑ ❑ ❑ ,-;
Is there adequate reserve supply of disinfectant? 00012
Is the level of chlorine residual acceptable? 000EI
Is the contact chamber free of growth, or sludge buildup? ❑ ❑ ❑ E
Is there chlorine residual prior to de-chlorination? 00011
Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? 000111
If yes,then is there a Risk Management Plan on site? ❑ ❑ ❑ Z!
If yes,then what is the EPA twelve digit ID Number? (1000- -
If yes,then when was the RMP last updated?
Comment: The facility has placed its old disinfection system back online at the emergency ponds and
using its old contact chamber. The regional office was not notifed of this.
De-chlorination Yes No NA NE
Type of system? Gas
Is the feed ratio proportional to chlorine amount(1 to 1)? 00011
Is storage appropriate for cylinders? 00011
#Is de-chlorination substance stored away from chlorine containers? 00011
Comment:
Are the tablets the proper size and type? ❑ ❑ E ❑
Are tablet de-chlorinators operational? ❑ ❑ ■ ❑
Number of tubes in use?
Comment: The facility is introducing this into a manhole from the ponds and prior to its connection on
the outfall line.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ ® ❑ ❑
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Permit: NC0021865 Owner-Facility: Chadbourn WWTP
Inspection Date: 02/08/2017 Inspection Type: Reconnaissance
Effluent Sampling Yes No NA NE
Is sample collected below all treatment units? 41 ❑ ❑ 0
Is proper volume collected? 0 0 ❑ N
Is the tubing clean? 0 0 0 111
#Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees 0 ❑ 0
Celsius)?
Is the facility sampling performed as required by the permit(frequency, sampling type 0 0 0 El
representative)?
Comment: Facility is using a portable sampler to sample from manhole where pond's flow ties to outfall
line. but of course not flow proportional.
Standby Power Yes No NA NE
Is automatically activated standby power available? IN ❑ ❑ ❑
Is the generator tested by interrupting primary power source? ❑ ❑ ❑
Is the generator tested under load? ❑ ❑ ® 0
Was generator tested &operational during the inspection? ❑ ❑ ® ❑
Do the generator(s)have adequate capacity to operate the entire wastewater site? CI ❑ ❑ ❑
Is there an emergency agreement with a fuel vendor for extended run on back-up power? ❑ ❑ ❑ II
Is the generator fuel level monitored? ❑ ❑ ❑ le
Comment: Staff was informed that the current generator has a blown head gasket which allows water
to mix with the oil. While it may operate following loss of commercial power, how long
before the engine seizes from oil contamination is unknown. The Town had rented a
portable generator prior to Hurricane Matthew to cover them for the storm, but it was
returned afterwards. The regional office was again not notified of this issue. At least the •
facility is now monitored for power loss or influent pump station failure through an auto-dialer
installed several years following its failure and the resulting SSO in town from the
surcharged sewer system since staff had no idea power was out. Upgrade includes a new
generator.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ ❑ ❑ ■
Does the facility analyze process control parameters,for ex: MLSS, MCRT, Settleable ❑ ❑ OH
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Town was instructed to start monitoring MLSS once the aerators were back online. Doubtful
much process control was being done otherwise.
Flow Measurement - Effluent Yes No NA NE
#Is flow meter used for reporting? ® ❑ 0 ❑
Is flow meter calibrated annually? ❑ ❑ ❑ Ell
Page# 7

Permit: NC0021865 Owner-Facility: Chadbourn WWTP
Inspection Date: 02/08/2017 Inspection Type: Reconnaissance
Flow Measurement - Effluent Yes No NA NE
Is the flow meter operational? ❑ ❑ ® ❑
(If units are separated) Does the chart recorder match the flow meter? ❑ 0 El El
Comment: The effluent flow is not being measured nor recorded since it is being discharged from the
ponds versus the proper location which has flow measurement following chlorination. They
were using the old influent flow meter that only measures flow to the original aeration basin
assuming an even split and also has RAS entry. The town does not have influent
measurement due to facility layout and depth of the incoming gravity sewer line. No idea
when this meter was last calibrated.
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