NC0024881_NOD2018PC0034_20180218

ROY COOPER
Governor
MICHAEL S.REGAN
Secretary
Water Resources LINDA CULPEPPER
Environmental Quality Interim Director
February 27, 2018
David Bracken, Interim Director of Public Works
City of Reidsville
230 West Morehead Street
Reidsville, NC 27320 RECEIVED/DENRIDWR
Subject: Compliance Evaluation Inspection Report and Notice of Deficiency MAR 2018
Tracking Number NOD-2018-PC-0034 Water Resources
NPDES Permit NC0024881 permitting Section
Reidsville WWTP, Rockingham County
Dear Mr. Bracken:
On February 21, 2018, Paul DiMatteo of the Division of Water Resources ("Division"), Winston-Salem
Regional Office conducted a Compliance Evaluation Inspection of the above referenced wastewater treatment
system. The presence and cooperation of both Ben Bani, Operator in Responsible Charge (ORC), and Ralph
Potter, Pretreatment Coordinator,was greatly appreciated. The inspection was conducted in conjunction with
a site visit by Gary Perlmutter of the NPDES Complex Permitting to discuss permit renewal. This type of
inspection consists of two basic parts: an on-site inspection of the facility and a review of facility files and self-
monitoring data. Observations from each area of the inspection are summarized below.
Summary of Non-Compliance
The inspection identified noncompliance with the following permit conditions:
1. Part II Section A—Composite Sampling
Mr. Bani indicated that the effluent sampler was programmed to take one 120 mL aliquot every 15
minutes. The permit recognizes this method of compositing as "constant time/constant volume,"
and requires that use of this method receive prior approval by the Director. Mr. Bani said that he
currently lacked suitable flow data for flow proportional sampling, and would have the automatic
sampler correctly set sometime this year.
2. Part II Section C.7—Power Failures
Mr. Bani said that the emergency power source was not capable of powering the effluent pumps,
and had not been capable of doing so since before he became ORC. Mr. Bani also said that this was
a known issue and was high in their list of priorities.
- ::›Nothing Compares:,
State of North Carolina I Environmental Quality
450 W Hanes Mill Road,Suite 300,Winston-Salem,North Carolina 27105
Phone [phone] FAX [phone]

This Condition requires that the Permittee maintain adequate safeguards to prevent the discharge
of untreated or inadequately treated wastes during electrical power failures (see also 15A NCAC
02H .0124). In case of a power failure,the effluent pumps which carry finished wastewater nearly 8
miles to the Haw River outfall would not operate;thus, water would be discharged to Little
Troublesome Creek, Class WS-V, NSW in the Cape Fear River Basin. Such a discharge is not
authorized by this permit, and would also be considered a bypass as defined in Part II Section A.
Site Review
1. Permit
The current permit became effective on April 19, 2013 and expired on April 30, 2016. A renewal
application was submitted in November, 2015;the current permit is effective until an action is
made on the application. A copy of the current permit was available for review. Permitted
components include bar screens, aeration basin, secondary clarifiers, sand filtration, chlorine
disinfection, and dechlorination with final disposal to the Haw River, Class WS-V; NSW waters in the
Cape Fear River Basin.
2. Facility Site Review
The facility was as described in the permit. An Authorization to Construct was issued in September
2013, and completed Engineer's Certification submitted in January 2017,for modifications to an
aeration basin, new sludge handling equipment, new SCADA system, and other improvements. Mr.
Bani said that he was working with another engineering firm to develop additional necessary
improvements.The facility is permitted to discharge up to 7.5 million gallons per day (MGD) of
treated wastewater;typical daily discharges are about 2.2 MGD. All treatment components
appeared to be working properly.
An emergency generator was available that Mr. Bani said could power the entire plant except for
the final effluent pumps; an upgrade is on the list of upcoming projects.
3. Operation and Maintenance
Ben Bani.is the primary Operator in Responsible Charge (ORC), and Ralph Potter,Thomas Harris
and Patrick McDonald are the backup-ORCs. All operators are properly designated and hold
adequate certifications.The facility is operated 24 hours per day, 7 days per week. The facility was
very clean at the time of the inspection and appeared to be well operated and managed.
4. Flow Measurement
Effluent flow is measured using an ultrasonic device over a 24 inch Parshall flume. Flow is totalized
in the SCADA system. The flow meter's calibration was last checked by the Carolina Technical
Services, Inc on February 16, 2018.
5. Effluent/Receiving Waters
The effluent is discharged to the Haw River in the Cape Fear River basin.The outfall is located near
a bridge over the Haw River on NC-150. A path to the outfall was well maintained and the effluent
appeared clear with no visible solids or foam, and no visible impact to the receiving stream.

Documentation Review -
6. Records/Reports
Discharge Monitoring Reports (DMRs) and lab data are maintained according to the permit. DMRs
include all permit parameters. Copies of DMRs, operator visitation logs, daily operation sheets,
maintenance reports, lab reports and Chain-of-Custody forms were available for review during the
inspection.
7. Self-Monitoring Program
A review of DMRs from January, 2016 through December, 2017 showed actioned no violations, and
a comparison of submitted DMR data with bench records showed no errors or concerns.
8. Laboratory
The facility analyzes total suspended solids, carbonaceous biochemical oxygen demand,fecal
coliform,temperature, dissolved oxygen, pH,total residual chlorine, ammonia and total
phosphorus under certification #179. Other parameters are analyzed by Meritech, certification
#165. Copies of all laboratory documentation are kept on site. Procedures for analyzing field
parameters appeared acceptable.The pH meter is calibrated daily with three buffers.The DO
meter is also calibrated daily. Thermometers used for reporting are calibrated yearly—last
performed on July 27, 2017 by Precision Weighing.
Effluent composite sampling is conducted with a Hach AS950. Mr. Bani said that the sampler was
programmed to take one 120m1 aliquot every 15 minutes.
9. Sludge Handling Disposal
The 2013 Authorization to Construct included various new sludge handling equipment, including
two rotary drum thickeners and one dewatering screw press.The equipment was not running
during the inspection—the operators said they were still figuring out how to best operate it.The
City is permitted to land apply residuals under WQ0002376.

Requested Action
Please respond to this report within 30 calendar days of receipt. In your response, you should indicate
time frames for obtaining compliance with the items noted in the summary above.
We appreciate the efforts made to operate this facility. If you should have any questions, please do not
hesitate to contact Paul DiMatteo at [phone] or our office at [phone].
Sincerely,
/40„,v,„...."
` 1v: , '
Sherri V. Knight, P.E., Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Enclosures—Inspection Report and Summary
CC: WQS Winston-Salem Regional Office- Enforcement File
NPDES Compliance/Enforcement Unit- Enforcement File
Central Files

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 11_4_1 2 IS I 3 I NC0024881 111 12 1 18/02/21 117 18 LI 19 11.1 20I
21111111 1111111111111111111111111 ' III 1111I11 l66
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA – —Reserved I
671 I 70 L_I I 71 I I 72 I t N I 73I I 174 79 1 1 1 1 1 1 1l80
Section B FacilityData
Name and Location of Facility Inspected(For Industrial Users discharging to POTW,also include Entry Time/Date Permit Effective Date
POTW name and NPDES permit Number) 10 00AM 18/02/21 13/06/01
Reidsville WWTP
407 Broad St Exit Time/Date Permit Expiration Date
Reidsville NC 27320 03 OOPM 18/02/21 16/04/30
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Benjamin Assoumou BandORC/336-349-1102/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
D Kelly Almond,230 W Morehead St Reidsville NC 27320//336-349-1030/3363423649
Yes
Section C Areas Evaluated During Inspection(Check only those areas evaluated)
• Permit • Flow Measurement • Operations&Maintenance II Records/Reports
• Self-Monitoring Program II Sludge Handling Disposal • Facility Site Review El Effluent/Receiving Waters
• 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
Paul DiMatteo WSRO WQ//336-776-9691/
�, c,J SIzl zor8
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
Ai.v.I., �. 1 govis,
EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type (Cont.) 1
31 NC0024881 111 121 18/02/21 117 18 [al
I
Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
Mr. Bani explained that the replacement of surface aerators in one(the only one in use) aeration basin
with diffused air in June,2016 improved their ammonia treatment but reduced their nitrate-nitrite,total
nitrogen and phosphorus treatment due to a loss of biological nutrient reduction. He explained that
surface aerators provided more defined aerobic. anaerobic and anoxic zones than diffused air.The
upgrades were necessary to maintain compliance with Ammonia limits,which are set to decrease in
the next permit. This has led to the facility approaching (but not yet exceeding)its yearly loading limit
for Total Nitrogen, and an increase in its yearly Total Phosphorus load. Mr. Bani said he was
experimenting with turning off the blower in some zones during certain parts of the day and it has
helped. He said he's also working with another engineering company on further upgrades.
Page# 2

Permit. NC0024881 Owner-Facility: Reidsville WWTP
Inspection Date: 02/21/2018 Inspection Type Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? • 0 0 0
Does the facility analyze process control parameters,for ex:MLSS, MCRT,Settleable • ❑ 0 0
Solids,pH,DO,Sludge Judge,and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new • 0 0 0
application? •
Is the facility as described in the permit? • 0 0 0
#Are there any special conditions for the permit? 0 • 0 0
Is access to the plant site restricted to the general public? • 0 0 0
Is the inspector granted access to all areas for inspection? • 0 0 0
Comment: The current permit expired on April 30, 2016.A renewal application was submitted and is
currently under review.
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? • ❑ 0 0
Is all required information readily available,complete and current? • ❑ ❑ ❑
Are all records maintained for 3 years(lab.reg. required 5 years)? U 0 ❑ ❑
Are analytical results consistent with data reported on DMRs? • 0 0 0
Is the chain-of-custody complete? • 0 ❑ 0
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? • 0 0 ❑
Has the facility submitted its annual compliance report to users and DWQ? • 0 0 ❑
(If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator • ❑ ❑ 0
on each shift?
Is the ORC visitation log available and current? • 0 0 ❑
Is the ORC certified at grade equal to or higher than the facility classification? • ❑ 0 0
Is the backup operator certified at one grade less or greater than the facility classification? • ❑ 0 ❑
Is a copy of the current NPDES permit available on site? • ❑ 0 ❑
Page# 3

Permit. NC0024881 Owner-Facility. Reidsville WWTP
Inspection Date 02/21/2018 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Facility has copy of previous year's Annual Report on file for review? • 0 0 0
Comment:
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? • 0 0 0
Are the receiving water free of foam other than trace amounts and other debris? • 0 0 0
If effluent (diffuser pipes are required) are they operating properly? 0 0 • 0
Comment: Outfall is located on the Haw River near the bridge at NC 150.
Flow Measurement-Influent Yes No NA NE
#Is flow meter used for reporting? ❑ • 0 0
Is flow meter calibrated annually? • 0 0 0
Is the flow meter operational? • 0 0 0
(If units are separated)Does the chart recorder match the flow meter? 0 0 0 •
Comment Influent is measured with a 24"parshall flume with ultrasonic device.
Flow Measurement-Effluent Yes No NA NE
#Is flow meter used for reporting? U 0 0 0
Is flow meter calibrated annually? • 0 0 0
Is the flow meter operational? • 0 0 0
(If units are separated) Does the chart recorder match the flow meter? 0 0 0 U
Comment: Flow meter was last calibrated by Carolina Technical Services on 2/16/2018.
Aerobic Digester Yes No NA NE
Is the capacity adequate? • 0 0 0
Is the mixing adequate? • 0 0 0
Is the site free of excessive foaming in the tank? • 0 0 0
#Is the odor acceptable? • 0 0 0
#Is tankage available for properly waste sludge? • 0 0 0
Comment.
Bar Screens Yes No NA NE
Type of bar screen
Page# 4

Permit: NC0024881 Owner-Facility: Reidsville WVTP
Inspection Date: 02/21/2018 Inspection Type. Compliance Evaluation
Bar Screens Yes No NA NE
a.Manual •
b.Mechanical •
Are the bars adequately screening debris? • 0 0 0
Is the screen free of excessive debris? • 0 0 0
Is disposal of screening in compliance? • 0 0 0
Is the unit in good condition'? • 0 0 0
Comment Both mechanical and manual bar screens available.
Grit Removal Yes No NA NE
Type of grit removal
a.Manual 0
b.Mechanical - •
Is the grit free of excessive organic matter? • 0 0 0
Is the grit free of excessive odor? - • 0 0 0
#Is disposal of grit in compliance? • 0 0 0
Comment
Pump Station -Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? • 0 0 0
Is the wet well free of excessive grease'? • 0 0 0
Are all pumps present? • 0 0 0
Are all pumps operable'? 0 II 0 0
Are float controls operable? • 0 0 0
Is SCADA telemetry available and operational? • 0 0 0
Is audible and visual alarm available and operational'? 0 0 ❑ •
Comment: 3 of 4 influent pumps are in service.
Aeration Basins • Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Diffused
Is the basin free of dead spots'? • 0 0 0
Are surface aerators and mixers operational'? 0 0 I 0
Are the diffusers operational? • 0 0 0
Page# 5

Permit. NC0024881 Owner-Facility Reidsville WWTP
Inspection Date: 02/21/2018 Inspection Type Compliance Evaluation
Aeration Basins Yes No NA NE
Is the foam the proper color for the treatment process? • 0 0 0
Does the foam cover less than 25%of the basin's surface? • 0 0 0
Is the DO level acceptable? • 0 0 0
Is the DO level acceptable?(1 0 to 3 0 mg/I) • 0 0 0
Comment. The plant recently upgraded an aeration basin to diffused air.The other aeration basin has
surface aerators but is not in use.The DO probes set into the the aeration basins read. 0.21
mq/I (zone 1, closest to inlet), 0.39 (zone 2), 1.43 (zone 3, near outlet).
Secondary Clarifier Yes No NA NE
Is the clarifier free of black and odorous wastewater? • 0 0 0
Is the site free of excessive buildup of solids in center well of circular clarifier? • 0 0 0
Are weirs level? • 0 0 0
Is the site free of weir blockage? • 0 0 0
Is the site free of evidence of short-circuiting? • 0 0 0
Is scum removal adequate? • 0 0 0
Is the site free of excessive floating sludge? • 0 0 ❑ '
Is the drive unit operational? • 0 0 0
Is the return rate acceptable(low turbulence)? • 0 0 0
Is the overflow clear of excessive solids/pin floc? • 0 0 0
Is the sludge blanket level acceptable?(Approximately 1/4 of the sidewall depth) • 0 0 0
Comment Mr Bani said they try to keep the sludge blanket below 2 feet. It is read manually 3x/shift
(6x/day)and recorded on a rounds sheet.
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation Down flow
Is the filter media present? • 0 0 0
Is the filter surface free of clogging? • 0 0 0
Is the filter free of growth? • 0 0 0
Is the air scour operational? • 0 0 0
Is the scouring acceptable? • 0 0 0
Is the clear well free of excessive solids and filter media? 0 ❑ 0 0
Comment
Disinfection-Gas Yes No NA NE
Are cylinders secured adequately? • ❑ 0 0
Page# 6

Permit: NC0024881 Owner-Facility Reidsville WWTP
Inspection Date: 02/21/2018 Inspection Type: Compliance Evaluation
Disinfection-Gas Yes No NA NE
Are cylinders protected from direct sunlight? • 0 0 0
Is there adequate reserve supply of disinfectant? • 0 0 0
Is the level of chlorine residual acceptable? • 0 0 0
Is the contact chamber free of growth,or sludge buildup? • 0 0 0
Is there chlorine residual prior to de-chlorination? 0 0 0 •
Does the Stationary Source have more than 2500 lbs of Chlorine(CAS No.7782-50-5)? 0 0 U 0
If yes,then is there a Risk Management Plan on site? 0 0 • 0
If yes,then what is the EPA twelve digit ID Number?(1000- - )
If yes,then when was the RMP last updated"
Comment: Operators said they usually have at most 1350 lb total (150 lb tanks)chlorine gas cylinders
on site.
De-chlorination Yes No NA NE
Type of system? Liquid
Is the feed ratio proportional to chlorine amount(1 to 1)? • 0 0 0
Is storage appropriate for cylinders? • 0 0 0
#Is de-chlorination substance stored away from chlorine containers? • 0 0 0
Are the tablets the proper size and type? 0 0 I 0
Comment: Stored in separate sheds.
Are tablet de-chlorinators operational? 0 0 I 0
Number of tubes in use?
Comment: Sodium thiosulfate dechlorination.
Standby Power Yes No NA NE
Is automatically activated standby power available? • 0 0 0
Is the generator tested by interrupting primary power source? • 0 0 0
Is the generator tested under load? • 0 0 0
Was generator tested&operational during the inspection? 0 0 0 •
Do the generator(s)have adequate capacity to operate the entire wastewater site'? ❑ U 0 0
Is there an emergency agreement with a fuel vendor for extended run on back-up power? • 0 0 0
Is the generator fuel level monitored? • 0 0 0
Comment: Mr. Bani said that the onsite generator was capable of powering the entire plant except the
effluent pumps. He said they are hoping to upgrade the emergency power source.
Page# 7

Permit: NC0024881 Owner-Facility. Reidsville W WTP
Inspection Date- 02/21/2018 Inspection Type: Compliance Evaluation
Pumps-RAS-WAS Yes No NA NE
Are pumps in place? • 0 0 0
Are pumps operational? • 0 0 0
Are there adequate spare parts and supplies on site? • 0 0 0
Comment:
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory'? • 0 0 0
Are all other parameters(excluding field parameters)performed by a certified lab'? • 0 0 0
#Is the facility using a contract lab? 0 • 0 0
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • e 0 0 0
Celsius)?
Incubator(Fecal Conform)set to 44.5 degrees Celsius+/-0.2 degrees? • 0 0 0
Incubator(BOD)set to 20.0 degrees Celsius+/-1 0 degrees? 0 0 0 •
Comment. Fecal water bath was 44.5 C (according to built-in thermometer).
TSS oven was 101.0 C.
Influent Sampling Yes No NA NE
#Is composite sampling flow proportional'? 0 0 ❑ •
Is sample collected above side streams? • 0 0 0
Is proper volume collected? 0 0 0 •
Is the tubing clean? • 0 0 0
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees 0 0 0 •
Celsius)?
Is sampling performed according to the permit? • 0 0 0
Comment Influent samples are taken lust above the influent parashall flume.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? 0 • 0 0
Is sample collected below all treatment units? • 0 0 0
Is proper volume collected? • 0 0 0
Is the tubing clean? • 0 0 0
#Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • 0 0 0
Celsius)?
Is the facility sampling performed as required by the permit(frequency,sampling type 0 0 0 •
representative)?
Page# 8

Permit: NC0024881 Owner-Facility: Reidsville W WTP
Inspection Date: 02/21/2018 Inspection Type: Compliance Evaluation
Effluent Sampling Yes No NA NE
Comment: Mr. Bani said that the effluent composite sampler takes 1 —120 ml aliquot every 15 minutes.
Aliquot volume was not verified during the inspection.
Upstream/Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit(frequency,sampling type,and • 0 0 0
sampling location)?
Comment: Sampling is waived because Reidsville is a member of the Upper Cape Fear River Basin
Association.
Page# 9