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Home My WebLink AboutNC0021211_Compliance Evaluation Inspection_20180530±_ a Water Resources Environmental Quality May 30, 2018 Mr. Victor Ray Quick City of Graham P.O. Drawer 357 Graham, NC 27253-0357 Subject: Compliance Evaluation Inspection Report NPDES Permit NCO021211 City of Graham, Alamance County Dear Mr. Quick: ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director JUN 0 6.2098 Water Resources Permitting Section On May 16, 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. Cris Routh, Operator in Responsible Charge (ORC) was present for the inspection. 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. Site Review 1. Permit The current permit became effective on July 1, 2013 and expired on May 31, 2016. A renewal application was submitted to the Division and is currently under review. A copy of the current permit was available for review. Permitted components include an automatic bar screen, primary and secondary clarifiers, aeration basin, and chlorine gas disinfection, 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 with the following caveats: - One aeration basin is not in use. Mr. Routh said that he planned to bring the second basin back online within the next few months after some critical parts are replaced. - The permit includes sand filtration, but there is no operational filtration unit in the treatment works. Mr. Routh said that the trickling filters have been offline since the 1980s and that the sand filtration unit has been offline since the early 2000s and the unit has deteriorated to the point that it probably could not be brought back online. "Nothing Compares!":.-_ State of North Carolina I Environmental Quality 450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105 Phone: 336-776-98001 FAX: 336-776-9797 The facility is permitted to discharge 3.5 million gallons per day (MGD); typical daily discharge is about 1.7 MGD. All other components appeared to be working properly. Two emergency generators are available. One generator is capable of powering the entire plant, and the second generator powers only the influent pumps. 3. Operation and Maintenance The plant is operated 24 hours per day, 7 days per week. Crispian Routh is the primary Operator in Responsible Charge (ORC), and Tonya Mann and Shelby Smith are backup ORCs. All operators are properly designated and hold adequate certifications. The facility appeared to be well operated and managed. 4. Flow Measurement Influent flow is measured using an ultrasonic device over a 2 -foot Parshall flume. The ultrasonic device's calibration is checked quarterly by Instrument Services, Inc.; the last calibration was performed on April 23, 2018. 5. Effluent/Receiving Waters The effluent is discharged to Haw River in the Cape Fear River Basin. 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 September, 2016 through April, 2018 showed one Notice of Deficiency issued for a January, 2018 Ammonia violation. A comparison of submitted DMR data with bench records showed inaccuracies in the December 2017 DMR. The inspector noted that results for Total Hardness, Mercury, Nickel, Selenium and Zinc were not recorded correctly. Further review revealed that the results were mistakenly copied from the November headworks sampling event. Mr. Routh said that he would submit a revised DMR; this mistake did not seem to indicate any intentional falsification. 8. Laboratory The facility analyzes BOD, total residual chlorine, fecal coliform, conductivity, dissolved oxygen, ammonia nitrogen,.total phosphorus, pH, total suspended solids, turbidity and temperature at its on-site laboratory under certification #240. Other analysis is performed by Meritech, certification #165. Copies of all laboratory documentation were readily available. Procedures for analyzing field parameters including required calibrations appeared acceptable. Mr. Routh said that both composite samplers were programmed to perform variable time/constant volume flow proportional sampling. However, an aliquot pulled from the effluent sampler measured approximately 80 mL. Please note that the Permit requires that grab samples collected for compositing be at least 100 mL (see Standard Conditions, Part II, Section A, defining a composite sample as "a sample collected over a 24-hour period by continuous sampling or combining grab samples of at least 100 mL in such a manner as to result in a total sample representative of the wastewater discharge during the sample period."). The inspector recommended that the sampler be calibrated regularly to ensure an adequate volume is taken. 9. Sludge Handling Disposal Residuals are land applied under permit WQ0003824. The residuals handling equipment appeared to be in good condition. Requested Action Within.30 days of receiving this letter, please either (a) contact Paul DiMatteo at (336) 776-9691 or by email at Paul.dimatteo@ncdenr.gov to confirm that the composite samplers' volumes have been correctly set, or (b) provide a written response indicating your plan to adjust the volumes. We appreciate the efforts made to effectively operate and maintain this treatment facility. If you should have any questions, please do not hesitate to contact Paul DiMatteo at (336) 776-9691 or our office at (336) 776-9800. Sincerely, 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 Central Files United States Environmental Protection Agency Form Approved. E P e Washington, D.C. 20460 1 !l 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 15 1 3 I NCO021211 I11 121 18/05/16 I17 18 I S I 19 I c I 201 211 1 1 1 1 1 1 1 1 1 11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 11 1 1 1 1 1 166 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---Reserved- 67 70 LI J ( 71 1 ilI 72 L N j 73 � 74 751 • I V I I I 180 LJ Section B: Facility 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) 09:15AM 18/05/16 13/07/01 Graham WWTP 1204 E Gilbreath St Exit Time/Date Permit Expiration Date Graham NC 27253 01:15PM 18/05/16 16/05/31 Name(s) of Onsite Representatives)/Titles(s)/Phone and Fax Number(s) Other Facility Data Crispian T. Routh/ORC/336-570-6721/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Victor Ray Quick,PO Drawer 357 Graham NC 272530357//336-570-6700/3365135502 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program Sludge Handling Disposal Facility Site Review 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/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date l �_.. , -S-12- 71 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type 31 NCO021211 111 121 18/05/16 I17 18 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCO021211 Inspection Date: '06116/2018 Owner - Facility: Graham WWTP 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: Process control analysis includes pH DO and ammonia colorimetry several times per day. Plant is operated 24 hours per day, 7 days per week. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 0 ❑ ❑ ❑ application? Is the facility as described in the permit? M ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ 0 ❑ ❑ Is,access to the plant site restricted to the general public? M ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ❑ ❑ ❑ Comment: Permit renewal is currently under review. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? M ❑ ❑ ❑ Is all required information readily available, complete and current? M ❑ ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? M ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ❑ ❑ ❑ Is the chain -of -custody complete? 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 CDCs Are DMRs complete: do they include all permit parameters? 0 ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? 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? ■ ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? 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: NCO021211 Inspection Date: 05116/2018 Owner - Facility: Graham WWTP Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? 0 ❑ ❑ ❑ Comment: A copy of the annual report is available on the City of Graham's website. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? M ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? N ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Outfall is located at 36.046121 N, -79.368080 E. Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? N ❑ ❑ ❑ Is the flow meter operational? N ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ M Comment: Primary device appears to be a 2' Parshall flume. Ultrasonic transmitter device appeared to be in the correct position: flow measuring equipment is beneath a grate. The meter is calibrated quarterly by ISI. Last calibration was on 4/23/2018. Influent Sampling Yes No NA NE it Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected above side streams? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ 0 Is the tubing clean? M ❑ ❑ ❑ # 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: Thermometer inside influent sampler read 1.8 C. 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? 0 ❑ ❑ ❑ Page# 4 Permit: NC0021211 Inspection Date: 05/16/2018 Bar Screens Is disposal of screening in compliance? Is the unit in good condition? Owner - Facility: Graham WWTP Inspection Type: Compliance Evaluation Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Manual bar screen is available as a backup but the operator said that they haven't had to use the backup for years. Grit Removal Yes No NA NE Type of grit removal ❑ ❑ ❑ 0 a.Manual ❑ ❑ ❑ M b.Mechanical ❑ ❑ ❑ ❑ Is the grit free of excessive organic matter? 0 ❑ ❑ ❑ Is the grit free of excessive odor? M ❑ ❑ ❑ # Is disposal of grit in compliance? 0 ❑ ❑ ❑ Comment: Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? ❑ ❑ ❑ 0 Is the wet well free of excessive grease? ❑ ❑ ❑ M 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: Primary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular -clarifier? 0 ❑ ❑ ❑ Are weirs level? ❑ ❑ ❑ Is the site free of weir blockage? M ❑ ❑ ❑ Is the site free of evidence of short-circuiting? M ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? M ❑ ❑ ❑ Is the sludge blanket level acceptable? ❑ ❑ ❑ M Page# 5 Permit: NCO021211 Owner - Facility: Graham WWTP Inspection Date: 05/16/2018. Inspection Type: Compliance Evaluation Primary Clarifier Yes No NA NE Is the sludge blanket level acceptable? (Approximately 1/4 of the sidewall depth) ❑ ❑ ❑ N Comment: Pumps -RAS -WAS Yes No NA NE Are pumps in place? Ext. Air ❑ ❑ ❑ Are pumps operational? ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ❑ ❑ ❑ N Comment: 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? ❑ ❑ ❑ Are the diffusers operational? ❑ ❑ E ❑ Is the foam the proper color for the treatment process? E ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? E ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ 0 Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ E Comment: DO and pH are measured manually every 4 hours by the shift operators. Only one of the two aeration basins is in use. Mr. Routh said he planned to get the second basin operational within the next few months and hoped that this would help gain compliance with their nitrogen limits. 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? Yes No NA NE N ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ N ❑ ❑ ❑ Page# 6 Permit: NCO021211 Owner - Facility: Graham WWTP Yes No NA NE Are cylinders secured adequately? N ❑ Inspection Date: 05/16/2018 Inspection Type: Compliance Evaluation ❑ Are cylinders protected from direct sunlight? N ❑ Secondary Clarifier Yes No NA NE Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? E ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately 1/4 of the sidewall depth) ❑ ❑ ❑ ❑ Comment: Mr. Routh said that thev try to keep the sludge blanket depth to about 2-3 feet. Measurement in clarifier #3 read approximately 5.5 feet, total depth approximately 13 feet. Mr. Routh said this may indicate that the pumps are starting to go. Operator logs for the day also indicated that clarifier #2 read about the same depth, and Mr. Routh said that the sludge pump was offline for this clarifier for maintenance. Mr. Routh said that clarifier weirs are cleaned weekly with a high pressure water jet. Disinfection -Gas Yes No NA NE Are cylinders secured adequately? N ❑ ❑ ❑ Are cylinders protected from direct sunlight? N ❑ ❑ ❑ Is there adequate reserve supply of disinfectant? 0 ❑ ❑ ❑ Is the level of chlorine residual acceptable? ❑ ❑ ❑ E Is the contact chamber free of growth, or sludge buildup? ❑ ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ 0 Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? ❑ ❑ N ❑ If yes, then is there a Risk Management Plan on site? ❑ ❑ 0 ❑ If yes, then what is the EPA twelve digit ID Number? (1000----) If yes, then when was the RMP last updated? Comment: Mr. Routh said they usually have at most 1500 lbs of chlorine gas on site and that they're in the early stages of making a switch to liquid bleach. De -chlorination Yes No NA NE Type of system ? Gas Is the feed ratio proportional to chlorine amount (1 to 1)? E ❑ ❑ ❑ Is storage appropriate for cylinders? N ❑ ❑ ❑ # Is de -chlorination substance stored away from chlorine containers? 0 ❑ ❑ ❑ Are the tablets the proper size and type? ❑ ❑ N ❑ Comment: Chlorination/dechlorination feed building has 2 separate rooms. Are tablet de -chlorinators operational? ❑ ❑ 0 ❑ Number of tubes in use? Comment: Page# 7 Permit: NCO021211 Owner - Facility: Graham WWTP generator is checked - Inspection Date: 05/16/2018 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is automatically activated standby power available? M ❑ ❑ ❑ Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑ Is the generator tested under load? 0 ❑ ❑ ❑ Was generator tested & operational during the inspection? 0 ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? M ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up power? ❑ ❑ ❑ Is the generator fuel level monitored? N ❑ ❑ ❑ Comment: There are two generator systems on site. One larqe generator is able to power the entire plant and a smaller generator powers only the influent pumps. Mr. Routh explained that this way if the large generator were to fail, the influent pumps would be run, and wastewater would be able to receive some amount of treatment as it passes by gravity through the rest of the treatment plant, rather than simply overflow at the influent. The large generator is checked monthly by hand. The smaller generator is checked - automatically every other Wednesday. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? M ❑ ❑ ❑ # 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 0 ❑ ❑ ❑ Celsius)? . Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? 0 ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ❑ M Comment: Thermometer in fecal water bath read 44.8 C. Thermometer calibration checked annually against the municipal lab's NIST -traceable thermometer. The NIST -traceable thermometer itself is calibrated by a third party periodically. Last calibration was 9/28/2017. Calibrations for pH DO chlorine and conductivity are conducted daily. PH is calibrated with 4 & 10 buffers and checked with 7. TRC measured with a Hach 3800 and calibrated every morning. Field parameters are analyzed within 2 hours of calibration or else a post -sampling check is conducted Temperature is checked in-situ; others are analyzed within 15 minutes of collection. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? M ❑ ❑ ❑ Is proper volume collected? ❑ 0 ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ Page# 8 Permit: NCO021211 Owner - Facility: Graham WWTP Inspection Date: 05/16/2018 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees M ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type M ❑ ❑ ❑ representative)? Comment: Thermometer inside the sampler read 3.4 C. There was a graduated cylinder in the influent sampler, but one was not available at the effluent sampler. We used the grab sample lug to try to measure the aliquot volume. The iug had approximate volumes marked on it but these may be inaccurate, however, the sampler appeared to pull an approx. 80 mL aliquot. I discussed sample volume calibration with Mr. Routh and suggested the volume be checked every time the tubing is changed. Aerobic Digester Yes No NA NE Is the capacity adequate? ® ❑ ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming in the tank? M ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: Chemical Feed Yes No NA NE Is containment adequate? ❑ ❑ 0 ❑ Is storage adequate? ❑ ❑ 0 ❑ Are backup pumps available? ❑ ❑ M ❑ Is the site free of excessive leaking? ❑ ❑ M ❑ Comment: Anaerobic Digester Yes No NA NE Type of operation: No cover Is the capacity adequate? M ❑ ❑ ❑ # Is gas stored on site? ❑ ❑ ❑ Is the digester(s) free of tilting covers? ❑ ❑ ❑ Is the gas burner operational? ❑ ❑ 0 ❑ Is the digester heated? ❑ ❑ 0 ❑ Is the temperature maintained constantly? ❑ ❑ ❑ 0 Page# 9 Permit: NCO021211 Owner - Facility: Graham WWTP Inspection Date: 05/16/2018 Inspection Type: Compliance Evaluation Anaerobic Digester Yes No NA NE Is tankage available for properly waste sludge? Comment: Trickling Filter Is the filter free of ponding? Is the filter free of leaks at the center column of filter's distribution arms? Is the distribution of flow even from the distribution arms? Is the filter free of uneven or discolored growth? Is the filter free of sloughing of excessive growth? Are the filter's distribution arms orifices free of clogging? Is the filter free of excessive filter flies, worms or snails? ❑ ❑ ❑ ■ Yes No NA NE .❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ ❑ ❑ M ❑ ❑ ❑ N ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: Mr. Routh said that the trickling filters have been offline since about the 1980s and they have no plans to bring them back online. Filtration (High Rate Tertiary) Type of operation: Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ ❑ ❑ N ❑ ❑ ❑ N ❑ ❑ ❑ N ❑ Comment: Mr. Routh said that the tertiary filters have been offline since the early 2000s and the building has deteriorated to the point that they probably could not bring the system back online. i Page# 10