NC0021717_Compliance Evaluation Inspection_20180820

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ROY COOPER NORTi,CAROLINA
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MICHAEL S.BEGAN
Secretary water FtesourceS
LINDA CULPEPPER Permitting Section
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CERTIFIED MAIL 7013 1710 0002 1922 1579
RETURN RECEIPT REQUESTED
August 20, 2018
Mr. Kenneth D. Noland, Town Manager
Cub Creek WWTP
Town of Wilkesboro
PO Box 1056
Wilkesboro, NC 28697
SUBJECT: Compliance Evaluation Inspection and Notice of Deficiency
NOD-2018-PC-0266
Cub Creek WWTP
NPDES Permit No. NC0021717
Wilkes County
Dear Mr. Noland:
On August 17, 2018, Justin Henderson, of this office, met with Dustin Colburn, operator
in responsible (ORC), to perform a Compliance Evaluation Inspection on Cub Creek
wastewater treatment plant (WWTP). This type of inspection consists of two basic parts:
an in-office file review and an on-site inspection of the treatment facility. The attached
EPAinspection form notes the areas that were evaluated for this inspection. The
findings and observations are outlined below:
I. Permit
Your NPDES permit became effective February 1, 2016, and expires on September 30,
2019. The facility was unable to provide a complete copy of the current permit for
review, during this inspection. An application for permit renewal shall be submitted no
later than 180 days prior to expiration of the current permit as required by Permit
Condition Part II. Section B. (10). Please be sure to summarize and submit results of
your Mercury Minimization Plan (MMP) along with your permit renewal application as
required by Permit Condition Part I. A. (5). The screening and grit removal equipment
employed in the facility's treatment path, is not included the current permit's treatment
equipment description. Please update the plant's description with the missing
components at permit renewal.
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Dawfmantof Owl nmantal ILt3t3ty
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North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1450 Hanes Mill Road,Suite 300 Winston-Salem,North Carolina 27103
336.776.9800

NOD-2018-PC-0266 v
II. Self-Monitoring Program
The monthly self-monitoring reports were reviewed for the period of June 2017 through
May 2018 as part of this inspection. While there were no effluent limit nor frequency
violations documented during this review period, the facility did report the occurrence of
seven bypass/spill events since December 2017. Several of these bypass/spill events
were a result of reported operator error and/or negligence. Bypassing of treatment
equipment constitutes a violation of Permit Condition Part II. Section C.(4.).
III. Laboratory
The facility has an on-site laboratory (certification #163), and performs the following
analyses: fecal, Bio-chemical Oxygen Demand (BOD), Dissolved Oxygen (DO), pH,
Total Suspended Solids (TSS), and temperature. The facility contracts with Meritech
Labs to perform the remaining parameters required to be analyzed by the current permit
including: Ammonia (NH3), Total Nitrogen, Total Phosphorus, Chronic Toxicity, Oil &
Grease, and total hardness. In stream monitoring requirements are waived as long as
the Permittee maintains membership in the Yadkin-Pee Dee River Basin Association
(YPDRBA). This office requests that the Permittee supply proof of YPDRBA ,
membership.
IV. Records/Reports
The chain of custody forms, lab reports, and operation and maintenance logs were
available for review during this inspection, and were in good order. While checking the
DMRs and bench sheets, Mr. Henderson found that one result was not properly
transcribed to the DMRs. The observed discrepancy is listed in the table below. While
there is currently not an effluent limit for total phosphorus, diligence should be used to
ensure accurate reporting occurs.
Parameter _ Date Bench Sheet Reported
Total Nitrogen April 4, 2018 19.6 mg/I 19.92 mg/I
V. Flow Measurement
Effluent flow is continuously monitored and reported on DMRs. The flow meter was last
calibrated on June 20, 2018. Effluent sample collection is achieved by a composite
sampler that operates proportional to flow. The ORC 'was unable to describe the exact
process by which this is performed, other than 40 pulses make up the composite period.
This office request that you submit a detailed description of the effluent composite
process, including the following information: effluent composite start time, effluent
composite end time, gallons per pulse, total pulses occurring within the composite period,
and aliquot volume in milliliters (mL) collected per pulse.
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NOD-2018-PC-0266 v
VI. Operations and Maintenance
Excessive vegetation, including woody species, was observed growing on the earthen
embankments surrounding the aeration basin. This constitutes a violation of Permit
Condition Part II. Section C. (2)which states 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. Excessive vegetation may compromise the integrity
of the earthen embankments which could result in seepage.
Installation of an additional clarifier was ongoing at the time of this inspection.
Dustin Colburn, ORC, James Fletcher and Jeremiah Shumate, Back-up ORCs each hold
an active Wastewater Grade-IV certification, and are appropriately certified to perform
these duties for the subject facility.
VII. Facility Site Review
A hole was observed in the sludge auger equipment, transferring sludge from the screw
press, to the sludge transfer vehicle. The sludge was temporarily being caught and
contained in a spare bobcat bucket, and dumped into the transfer vehicle as necessary.
The ORC reported that a purchase order had been approved to replace the auger
equipment, and repairs will be completed as soon as possible (ASAP). Please notify this
office upon completion of the sludge auger equipment replacement.
Effluent disinfection is achieved via ultraviolet (UV) disinfection equipment. The ORC
reported that the facility does not currently have a backup disinfection procedure nor
equipment, should the UV equipment fail. Please be aware that Permit Condition Part II.
Section C. (3) states it shall not be a defense for a Permittee, in an enforcement action,
that it would have been necessary to halt or reduce the permitted activity in order to
maintain compliance with the conditions of this permit [40 CFR 122.41(c)].
Additional toxicity testing requirements for municipal permit renewal as authorized by
Permit Condition Part I. A. (4) have not yet been performed, according to the ORC at the
time of this inspection.
VIII. Effluent/Receiving Waters
The facility's effluent discharge, during this inspection, appeared free of floating solids
and visible foam in greater than trace amounts. Effluent was being discharged into the
Yadkin River, Class C Waters: (Aquatic Life, Secondary Recreation, Fresh Water) in the
Yadkin-Pee Dee River Basin. The outfall was being maintained to provide unimpeded
accessibility.
Page 3 of 4

NOD-2018-PC-0266 v
IX. Sludge Maintenance and Handling
The facility employs a sludge screw press to dewater sludge from the aerated digesters.
A polymer is added to encourage increased settling of the solids fraction. The dewatered
sludge is then transferred by a sludge auger into one of two designated sludge transfer
vehicles. Once the sludge vehicle is completely loaded,the sludge is hauled to the landfill
for disposal. Sludge removal records, tracking the volume (tons)-and date of sludge
removal, were available for review during this inspection.
X. Conclusions/Requested Actions
This inspection reflects noncompliance with the subject permit. Please work to correct the
deficiencies described in sections II. and VI. If you wish to provide additional information
regarding the noted deficiencies, request technical assistance, or discuss overall
compliance please respond in writing within thirty (30) business days after receipt of this
Notice. At a minimum, the requested information in sections III. and V. shall be submitted
within 30 days after receipt of this Notice. Information requested in section VII. shall be
submitted within 120 days after receipt of this Notice.
Please be aware that violations of your NPDES permit, or the NC statutes and regulations
under which itis promulgated, are subject to fines of up to$25,000 per day, per violation,
as set forth in the NC General Statute (NCGS) 143-215.6A, Enforcement Procedures,
Civil Penalties.
Sincerely,
;� _ 1-1--
,
Sherri V. Knight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: BIMS EPA Water Compliance Inspection Report
cc: Central Files
WSRO
r NPDES Unit
Page 4 of 4

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 L 2 [ I 3 I N00021717 111 12 I 18/08/17 117 18 LI 19 I c k 201
911111 1111111111111111111 111111 11111111111 r6
Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved
671 1 70L]
I 71 Li 72 I N I 7311
1 174 75I 1 1 1 1 1 1 180
L Section B:Facility Data L—I J
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) 09:25AM 18/08/17 16/02/01
Cub Creek WWTP
Exit Time/Date Permit Expiration Date
701 Snyder St
12 30PM 18/08/17 19/09/30
Wilkesboro NC 28697
Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data
///
Dustin Franklin Colburn/ORC/336-927-3785/
Name,Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael R.Testerman,PO Box 1056 Wilkesboro NC
286971056/Supenntendent/336-667-2391/ No
Section C.Areas Evaluated Dunng Inspection(Check only those areas evaluated)
II Permit • Flow Measurement II Operations&Maintenance MI 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
Justin L Henderson WSRO WQ//336-776-9701/
hliti (4112A4)4,0C----) SI e-OP gfr
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers / Date
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EPA Form 3560-3(Rev 9-94)Previous editions are obsolete
Page# 1

NPDES yr/mo/day Inspection Type (Cont.) 1
31 NC0021717 111 121 18/08/17 117 18 u
Section D.Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary)
The following deficiencies requiring your attention and action were observerd during this inspection:
1) excess vegetation growing on the dikes/embankments of aeration basin.
2)7 bypass events reported to have occured at facility since December 2017. Several resulting from
operator error and/or negligence.
The following information was requested to be submitted ASAP at the time of this inspection:
1) Submit a detailed description of the effluent composite sample collection process including: same
start time; sample end time; number of total pulses in the composite period; gallson per pulse, and
minimum aliqot volume (mL).
FYI,your current permit is set to expire on September 30, 2019. Please submit a permit renewal
application at least 180 days preceeding the expiration date. Be sure to include a summary of the
results for the facility's Mercry Minimization Plan as required by Permit Condtion Part I.A.(5).
Ensure additional toxicity testing requirements for municipal permit renewal are conducted in
' compliance with Permit Condition Part I.A.(4).
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Permit: NC0021717 Owner-Facility: Cub Creek WWTP
Inspection Date: 08/17/2018 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 0
Solids,pH, DO, Sludge Judge, and other that are applicable?
Comment. The plant analyzes pH in the aerated digesters, and for the mixed liquour; MLSS in the
areratlon basin; DO in the aeration basin as process control for plant operations.
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? U 0 0 0
Is the inspector granted access to all areas for inspection? • 0 0 0
Comment: The screening and grit removal equipment is not described by the current permit.Additional
toxicixty tesstinq requirements for municipal permit renewal are described in Permit
Condition Part I.A. (4). The ORC indidcated these additional requirements had not been
performed as of the date of this inspection.
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 II 0
Comment:
Aerobic Digester Yes No NA NE
Is the capacity adequate? • 0 0 0
Is the mixing adequate? • ❑ 0 0
Is the site free of excessive foaming in the tank'? • 0 ❑ 0
#Is the odor acceptable'? • 0 0 0
#Is tankage available for properly waste sludge? • 0 0 0
Comment:
Drying Beds Yes No NA NE
Is there adequate drying bed space? 0 0 II 0
Is the sludge distribution on drying beds appropriate? 0 0 II 0
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Permit: NC0021717 Owner-Facility: Cub Creek wwTP
Inspection Date: 08/17/2018 Inspection Type: Compliance Evaluation
Drying Beds Yes No NA NE
Are the drying beds free of vegetation? 00 • 0
#Is the site free of dry sludge remaining in beds? ❑ ❑ 1E ❑
Is the site free of stockpiled sludge? • 000
Is the filtrate from sludge drying beds returned to the front of the plant? • 000
#Is the sludge disposed of through county landfill? • 000
#Is the sludge land applied'? 00 • 0
(Vacuum filters) Is polymer mixing adequate? ❑ ❑ U' ❑
Comment: The sludge drying beds are not currently utilized by the plant.
Solids Handling Equipment Yes No NA NE
Is the equipment operational'? III 000
Is the chemical feed equipment operational? • 000
Is storage adequate? • 000
Is the site free of high level of solids in filtrate from filter presses or vacuum filters'? ❑ ❑ E ❑
Is the site free of sludge buildup on belts and/or rollers of filter press? • 000
Is the site free of excessive moisture in belt filter press sludge cake'? • 000
The facility has an approved sludge management plan? • 000
Comment: The sludge auger equipment, transferring sludge from the screw press to the transfer
vehicle, is in need of repair.
_ Pump Station -Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? • ❑ ❑ ❑
Is the wet well free of excessive grease? • 000
Are all pumps present? • 000
Are all pumps operable? • 000
Are float controls operable? • 000
Is SCADA telemetry available and operational'? 001110
Is audible and visual alarm available and operational'? 000I
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a Manual •
b.Mechanical 0
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Permit: NC0021717 Owner-Facility: Cub Creek WWTP
Inspection Date: 08/17/2018 Inspection Type: Compliance Evaluation
Bar Screens Yes No NA NE
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: The screening equipment is not included in the permit description for treatment equipment.
Grit Removal Yes No NA NE
Type of grit removal
a.Manual ❑
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: The grit removal equipment is not included in the permit description for treatment equipment.
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? • ❑ ❑ ❑
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 Y4 of the sidewall depth) • 0 0 0
Comment: Sludge blanket typically exceeds 1/4 of the sidewall depth.
Aeration Basins Yes No NA NE
Mode of operation Ext.Air
Type of aeration system Surface
Is the basin free of dead spots? • 0 0 0
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Permit: NC0021717 Owner-Facility: Cub Creek WWTP
Inspection Date: 08/17/2018 Inspection Type: Compliance Evaluation
Aeration Basins Yes No NA NE
Are surface aerators and mixers operational? • 000
Are the diffusers operational'? 00 • 0
Is the foam the proper color for the treatment process? • 000
Does the foam cover less than 25%of the basin's surface? • 000
Is the DO level acceptable? • 000
Is the DO level acceptable9(1 0 to 3.0 mg/I) • 000
Comment:
Disinfection -UV Yes No NA NE
Are extra UV bulbs available on site? • 000
Are UV bulbs clean? 00011
Is UV intensity adequate? • 000
Is transmittance at or above designed level? • 000
Is there a backup system on site? ❑ ■ ❑ ❑
Is effluent clear and free of solids'? • 000
Comment: The ORC reported that there was no backup system for disinfection on-site.
Lagoons Yes No NA NE
Type of lagoons? Aerated
#Number of lagoons in operation at time of visit? 1
Are lagoons operated in?
#Is a re-circulation line present? ❑ ❑ E ❑
Is lagoon free of excessive floating materials'? • 000
#Are baffles between ponds or effluent baffles adjustable? 00110
Are dike slopes clear of woody vegetation? ❑ E ❑ ❑
Are weeds controlled around the edge of the lagoon? • 000
Are dikes free of seepage'? • 000
Are dikes free of erosion'? • ❑ ❑ ❑
Are dikes free of burrowing animals'? • 000
#Has the sludge blanket in the lagoon(s)been measured periodically in multiple 00 • 0
locations'?
#If excessive algae is present, has barley straw been used to help control the growth'? 00110
Is the lagoon surface free of weeds'? • 000
Is the lagoon free of short circuiting'? • 000
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Permit: NC0021717
Owner-Facility: Cub Creek WWTP
Inspection Date: 08/17/2018 Inspection Type: Compliance Evaluation
Lagoons Yes No NA NE
Comment: Woody vegetation and excessive weed growth was observed on the dikes/embankments
associated with the aeration basin.
•
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