NC0029297_Inspection_20181010

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MICHAEL S. REGAL
Secr�rary
LfNDA CULPEPPER
In redm D,'rsctor
10 October 2018
Mr. Rick Sain
Director of Construction and Maintenance
Catawba County Schools
Post Office Box 1010
Newton, North Carolina 28658
Subject: Notice of Deficiency
Compliance Evaluation Inspection
Fred T. Foard High School WWTP
NPDES Permit No. NCO029297
Catawba County
Tracking #: NOD-2018-PC-0299
Dear Mr Sain:
Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on
October 2, 2018, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our
findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Deficiency (NOD) due to following:
- Inoperable audible high water alarm on the recirculation tank as was noted in the previous inspection
performed on May 3, 2017 (report issued on May 16, 2017);
- Improper operation of the tablet chlorinator during lower flow conditions;
- Dissolved Oxygen meter not operable;
- Incorrect gel check standard being used for total residual chlorine meter verifications.
All above -noted finding are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.'
as detailed in the Laboratory, Sand Filters (Low Rate), and Disinfection/Tablet Sections of the attached report. Please be
advised that G.S. 143-215.6A provides for a civil penalty assessment of not more than twenty-five thousand dollars
($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, 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. Penalties may also be assessed for any damage to surface waters of the State that may result from the
violation.
EQ.:>
`_=r
North Carolina Department of Environmental Quality I Division of Water Resources
610 East Center Avenue I Suite 301I Mooresville, North Carolina 28115
704.663.1699

Mr. Rick Sain
Page Two
10 October 2018
It is requested that a written response be submitted to this Office by October 31, 2018, detailing the actions taken to
address these violations and the issues noted in the Record Keeping and Flow Measurement Sections in the attached report.
In responding, please address your comments to the attention of Mr. Wes Bell.
Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at [phone], or via
email at wes.bellkncdenr.gov.
Sincerely,
DocuSigned by:
A#%* . H Nuft
F 161 FB69AMMA3...
for W. Corey Basinger, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosure:
Inspection Report

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 15 I 3 I NCO029297 111 12 I 18/10/02 I17 18 I S i 19 i G i 201 I
211111 I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 70 71 [.. I 72 73 L_LJ74 751 I I I I I I I80
u
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)
09:15AM 18/10/02
15/08/01
Fred T. Foard High School
3407 Plateau Rd NCSR 2036
Exit Time/Date
Permit Expiration Date
Newton NC 28658
01:27PM 18/10/02
20/07/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
David P McCorkle/ORC/828-217-0362/
Morgan C Williams//828-464-3562 ext 403/8284654442
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Rick Sain,PO Box 1010 Newton NC 28658//828-464-3562/8284654442
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
EDocuSigned by:
Wes Bell D� MRO WQ//704-663-1699 Ext.2192/ 10/10/2018
A61696D90CC3437...
Signature of MaCe i�4ft`4'W"ewer Agency/Office/Phone and Fax Numbers Date
H P
Andrew Pitn4•�"
RO WQ//704-663-1699 Ext.21 10/10/2018
1`161 FB69AMUA3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
NC0029297 I11 121 18/10/02 117 18 JCJ
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
RECORD KEEPING SECTION cont'd:
The ORC was not performing post -analysis calibration checks on the dissolved oxygen, pH, and total
residual chlorine meters following field analyses at multiple sites. Post -analysis calibration checks
must be performed in accordance with the NC Wastewater/Groundwater laboratory certification
approved procedures for the analyses of dissolved oxygen, pH, and total residual chlorine.
Note: The technical guidance documents developed by the Division's Laboratory Certification Unit
detailing these approved laboratory procedures have been emailed to the Catawba County School's
Health & Environmental Coordinator.
The dissolved oxygen (DO) meter displayed an error code and did not operate properly during the
inspection. The DO meter must be repaired/replaced to ensure proper operation. In addition, the ORC
was not using both the correct gel check standard during the TRC meter verifications (prior to effluent
analyses) and fresh pH standards for pH meter calibrations (prior to effluent analyses). Please be
advised that the subject permit requires the permittee to properly operate and maintain the facility
which includes adequate laboratory controls and appropriate quality assurance procedures [Permit
Condition Reference: Part II, Section C(2) Proper Operation and Maintenance].
Page#

Permit: NCO029297 Owner - Facility: Fred T. Foard High School
Inspection Date: 10/02/2018 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
❑
❑
0
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
0
❑
Is access to the plant site restricted to the general public?
0
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment: The last compliance evaluation inspection was performed at the facility on 5/3/17 by DWR
staff.
Record Keeping
Yes No NA NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
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 COCs
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?
0
❑
❑
❑
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?
❑
❑
❑
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

Permit: NCO029297
Inspection Date: 10/02/2018
Record Keeping
Owner - Facility: Fred T. Foard High School
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The records reviewed durina the inspection were oraanized and well maintained. Discharae
Monitoring Reports (eDMRs) were reviewed for the period August 2017 through July 2018.
No effluent limit violations were reported.
The ORC and staff must ensure the following is clearly reported in the on -site
documentation: lab analyst initials; units of measurement (effluent results and calibration
data); all operation and maintenance activities at each wastewater facility; and the gel check
standard value (verified at lab).
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
❑
❑
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? ❑ ❑ 0 ❑
Comment: On -site field analyses (dissolved oxygen, pH, temperature, total residual chlorine,) are
performed under the Catawba County School System's field laboratory certification #5409.
Water Tech Labs (Certification #50) has also been contracted to perform all remaining
Permit -required analyses (BOD, TSS, ammonia, fecal coliform). See "Summary" Section for
additional comments.
Effluent Sampling
Yes No NA NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
0
❑
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
❑
❑
❑
representative)?
Comment: The subiect Dermit reauires effluent arab samDles. The ORC must ensure that fecal
coliform samples are collected into a sterilized container if samples are not collected directly
into the fecal coliform sample bottle/bag.
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 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Page# 4

Permit: NCO029297
Inspection Date: 10/02/2018
Operations & Maintenance
Owner - Facility: Fred T. Foard High School
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: Overall, wastewater treatment facility appeared to be adequately treating the wastewater;
however, concerns were noted at the tablet chlorinator/chlorine contact chamber. See
"Disinfection/Tablet" for additional comments. The permittee must ensure the vegetation
around all treatment units is properly maintained at all times.
Septic Tank
(If pumps are used) Is an audible and visual alarm operational?
❑
❑
0
❑
Is septic tank pumped on a schedule?
0
❑
❑
❑
Are pumps or syphons operating properly?
❑
❑
0
❑
Are high and low water alarms operating properly?
❑
❑
0
❑
Comment: The septic tanks and recirculation tank are pumped out every
summer by a contracted
company (Leatherman Septic Tank Service).
Sand Filters (Low rate)
Yes No NA NE
(If pumps are used) Is an audible and visible alarm Present and operational?
❑
0
❑
❑
Is the distribution box level and watertight?
❑
❑
0
❑
Is sand filter free of ponding?
0
❑
❑
❑
Is the sand filter effluent re -circulated at a valid ratio?
0
❑
❑
❑
# Is the sand filter surface free of algae or excessive vegetation?
0
❑
❑
❑
# Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1)
❑
❑
0
❑
Comment: The audible alarm (hiah water level) in the recirculation tank was not operational at the time
of the inspection. The audible alarm must be repaired/replaced. Please be advised that the
subject permit requires the permittee to properly operate and maintain the wastewater
facility at all times (Permit Condition Reference: Part II, Section C(2) Proper Operation and
Maintenancel. An inoperable audible alarm was noted during the previous Compliance
Evaluation Inspection performed on 5/3/17 (inspection report dated 5/16/17). The ORC and
staff must initiate (and document) the testing of the visual and audible alarms on multiple
occasions throughout the calendar year to ensure proper operation.
Disinfection -Tablet
Yes No NA NE
Are tablet chlorinators operational?
0
❑
❑
❑
Are the tablets the proper size and type?
0
❑
❑
❑
Number of tubes in use?
2
Is the level of chlorine residual acceptable?
❑
0
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
0
❑
❑
Page# 5

Permit: NCO029297
Inspection Date: 10/02/2018
Disinfection -Tablet
Owner - Facility: Fred T. Foard High School
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The chlorine tablets inside the sleeve (closest to contact chamber) did not appear to be
coming in contact with the waste stream during the observed lower flow conditions. In
addition, no total residual chlorine was detected (via test strips) in the chlorine contact
chamber during the inspection. The wastewater must be in contact with the chlorine tablets
at all times (including lower flow conditions) to ensure adequate disinfection. Note: A new
tablet sleeve had been fabricated when the previous sleeve bottom broke off. Please be
advised that the subject permit requires the permittee to properly operate and maintain the
facility which includes adequate laboratory controls and appropriate quality assurance
procedures [Permit Condition Reference: Part II, Section C(2) Proper Operation and
Maintenancel.
De -chlorination
Yes No NA NE
Type of system ?
Tablet
Is the feed ratio proportional to chlorine amount (1 to 1)?
0 ❑
❑
❑
Is storage appropriate for cylinders?
❑ ❑
0
❑
# Is de -chlorination substance stored away from chlorine containers?
❑ ❑
0
❑
Comment:
Are the tablets the proper size and type? 0 ❑ ❑ ❑
Are tablet de -chlorinators operational? 0 ❑ ❑ ❑
Number of tubes in use? 2
Comment:
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: The effluent flow values beina measured/reported tvDically ranae from fortv to sixtv aallons
Per day. These flow values do not appear to be correct following the observation of the
effluent flow rate during the inspection. Facility staff must re-evaluate the daily
discharge
flows to ensure accurate flow values are being measured and reported.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
0
❑
Comment: The effluent appeared clear with no floatable solids or foam.
Page# 6

Permit: NC0029297
Inspection Date: 10/02/2018
Owner - Facility: Fred T. Foard High School
Inspection Type: Compliance Evaluation
Page#