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HomeMy WebLinkAboutWQ0021734_Compliance Evaluation Inspection_20181002ROY COOPER COV"? r MICHAEL S. RECAN 54hT ary LINDA CULPEPPER lrrrerfrn &'rea w NORTH CAROLINA ErrrtrOrlm#rrr&� Quality October 2, 2018 Ms. Jacqueline A. Jarrell, P.E., via Email CW Environmental Management Director Charlotte Mecklenburg Utilities Department 4222 Westmont Drive Charlotte, North Carolina 28217 Subject: Non -Discharge Permit Inspection Franklin Water Treatment Plant Bulk Distribution of Reclaimed Water Permit No. WQ0021734 Mecklenburg County Dear Ms. Jarrell: Staff of the Mooresville Regional Office (MRO) conducted a compliance inspection at the referenced facility on September 20th, 2018. The MRO would like to thank Donna Duckworth and Terry Crowe for their time during the inspection. The following items should be addressed to maintain compliance: All meters related to the Reclaimed Water System need calibration and documentation. Per permit condition 111.1. "The reclaimed water bulk distribution facilities shall be properly maintained and operated at all times." ...applies to in -line metering instrumentation and calibrations. During this site visit labels posted on the meters were dated in 2016 and 2010. Ms. Duckworth confirmed her records show the flow meter calibration was completed on March 1, 2017 but did not have records for additional meters (turbidity, etc. as applicable). Permit Conditions IV.5.a&b reference required documentation of calibrations. Utilize most current reporting spreadsheets for NDMR monthly submittals as the requirements changed with the last permit renewal. MRO staff confirmed with North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 301 I Mooresville, North Carolina 28115 704.663.1699 Ms. Duckworth the new spreadsheet forms were received. Any questions or concerns related to these forms may be directed to our Central Office Non - Discharge Branch Supervisor Nathan iel.Thornburg(a ncdenr.gov. MRO staff recognizes this system has remained inactive for several years; however, with an active permit, all components of the system, including meters, must be maintained in operational condition and documented. Charlotte Water has the option to request a permit rescission should they determine this permit is no longer necessary. The inspection report should be self-explanatory; however, I may be reached by phone (704-235-2184) or email (maria.schutte(ab-ncdenr.gov) with questions. Sincerely, DocuSigned by: A�ww N P44,t. F161FB69A2D84A3... Andrew H. Pitner, P.G., Regional Assistant Supervisor Mooresville Regional Office Water Quality Regional Operations Section Division of Water Resources, NCDEQ Attachment: WWQ0021734 Inspection Report CC: Terry Crowe, Supervisor, Franklin WTP, Charlotte Water (email) Donna Duckworth, Franklin WTP, Charlotte Water (email) Shannon Sypolt, Charlotte Water (email) State of North Carolina Department of Environmental Quality Division of Water Resources Roy Cooper, Governor Michael S. Regan, Secretary Linda Culpepper, Interim Director NON -DISCHARGE COMPLIANCE INSPECTION SURFACE IRRIGATION GENERAL INFORMATION City/Town/Owner: Charlotte Water Permit No.: WQ0021734 Issuance Date: 03/24/2016 Permittee Contact: Jaqueline Jarrell Phone: 704-336-4460 WTP Contact: Terry Crow (PC-1 #27854) Cell: 704-201-3857 WTP Contact: Donna Duckworth (PC-1 #1000743) Ph: 704-399- County: Mecklenburg Project Name: Franklin WTP Expiration Date: 04/30/2021 Email: jjarrell(a-,ci.charlotte.nc.us Email: tcrowe(ai)ci.charlotte.nc.us ?426 Email: dduckworthgci.charlotte.nc.us Reason for Inspection X ROUTINE COMPLAINT FOLLOW-UP OTHER Type of Inspection Collection System Spray Irrigation Sludge X Other Inspection Date(s): September 20, 2018 Inspection Summary: (additional comments may be included on attached pates) This inspection included a records review and tour of the WTP reclaimed system. The bulk reclaimed plumbing appears well maintained. Monthly NDMRs received continue to indicate no activity of the system; however, there a couple of items to address related to reporting forms and meter calibration records highlighted below and in the cover letter. The residuals processing and storage areas were also viewed, since this facility is a source under Charlotte Water's Residuals permit # WQ0000057. A separate report was sent to Jean Creech for the residuals inspection. Please note: All meters associated with the Reclaimed system need updated calibrations, records and visible "calibration date" labels. The NDMR reporting forms changed with the last permit renewal. Per our discussion, Ms. Duckworth received a copy of the most recent customized reporting forms and will utilize them starting with the next reporting period. The MRO should be informed of any changes to the contact information noted above. Is a follow-up inspection necessary? yes, X no Inspector Name/Title: Maria Schutte, Environmental Specialist Telephone No.: 704-663-1699 Fax No. 704-663-6040 Date of Inspection: 09/20/2018 Bulk Reclaimed Water Distribution pg. 2 WQ0021734 Charlotte Water — Franklin WTP - Mecklenburg County Type Wastewater Recycle Reclaimed Water for Irrigation X Reclaimed Water (Bulk Distribution) Other Y-yes N-no N/A -not applicable N/E-not evaluated Treatment The reclaimed water is treated under NPDES permit NC0084549. Y Are treatment facilities consistent with those outlined in the current permit. Y Do all treatment units appear to be operational? If no, note below. Disinfection Y Is the system working? Y Is the system properly maintained? Tablets Gas Y Liquid UV If tablets, proper size? Present in Cylinder(s)? *NE If gas/liquid, does cylinder/tank storage seem safe? If bulbs, are replacement bulbs on hand? Is contact chamber free of sludge, solids and growth? Comment: * Per previous inspection, the Chlorine storage is currently regulated by Mecklenburg County; althouzh, at times it has been regulated by NCDEQ Air Quality. RM#100000047987 for Chlorine. Flow Measurement — Effluent Y Is the flowmeter calibrated annually? But past due (Mar 1, 2017) and no information on the turbidity meter. Per conversation with Jean Creech, annual meter calibrations are also a requirement for internal audits. NE Is the flowmeter operating properly? Y Does the flowmeter monitor continuously? NE Does the flowmeter appear to monitor accurately? The permittee submits required monthly NDMRs reflecting no flow/distribution. However, recently received, customized forms will need to be utilized for future reporting as the forms reflect changes made during the last permit renewal. Recordkeeping Y Is permit available upon request? Y Are flow rates less than permitted flow? Y Are monitoring reports present: Y NDMR NA Are operational logs present? Complete? NA Are lab sheets available for review? NA Do lab sheets support data represented on NDMR or NDAR? NA Are all samples analyzed for the required parameters? NE Is the operation and maintenance manual present? Complete? NA Is the material for the educational program available for review? NA Is the list of companies and drivers approved to transport reclaimed water available? NA Are records tracking reclaimed water distribution available for review? N Has DWQ received any complaints regarding the facility in the last 12 months? Comment: There has been no distribution; therefore, many program requirements are currently not applicable. Address items noted in the cover letter. The WTP residuals are a source under Charlotte Water's permit #W00000057 for land application. Compliance Inspection Report Permit: WQ0021734 Effective: 05/01/16 Expiration: 04/30/21 owner: Charlotte Water SOC: Effective: Expiration: Facility: Franklin WTP County: Mecklenburg 5200 Brookshire Blvd Region: Mooresville Charlotte NC 28216 Contact Person: Bill Deal Title: Phone: 704-399-5454 Directions to Facility: From 1-77, take 1-85 south to exit 36. Exit Rigth onto Brookshire Blvd. (NC 16 North). Travel approx. 1 mile. The complex is on the right. The WTP is the second building. System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NC0084549 Charlotte Water - Franklin WTP Inspection Date: 09/20/2018 Entry Time: 09:32AM Primary Inspector: Maria Schutte Secondary Inspector(s): Exit Time: 11:45AM Phone: 704-663-1699 Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Reclaimed Water Facility Status: Compliant ❑ Not Compliant Question Areas: Treatment Flow Measurement -Effluent Treatment Flow Measurement -Influent Miscellaneous Questions Treatment Flow Measurement -Water Treatment Record Keeping Use Records Treatment Disinfection Treatment Flow Measurement (See attachment summary) Page: 1 Permit: WQ0021734 Owner - Facility: Charlotte Water Inspection Date: 09/20/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: This inspection included a records review and tour of the WTP reclaimed system. The bulk reclaimed plumbing appears well maintained. Monthly NDMRs received continue to indicate no activity of the system; however, there a couple of items to address related to reporting forms and meter calibration records highlighted below and in the cover letter. The residuals processing and storage areas were also viewed, since this facility is a source under Charlotte Water's Residuals permit # WQ0000057. A separate report was sent to Jean Creech for the residuals inspection. Please note: • All meters associated with the Reclaimed system need updated calibrations, records and visible "calibration date" labels. • The NDMR reporting forms changed with the last permit renewal. Per our discussion, Ms. Duckworth received a copy of the most recent customized reporting forms and will utilize them starting with the next reporting period. • The MRO should be informed of any changes to the contact information noted above. MRO staff recognizes this system has remained inactive for several years; however, with an active permit, all components of the system, including meters, must be maintained in operational condition and documented. Charlotte Water has the option to request a permit rescission should they determine this permit is no longer necessary. Page: 2 Permit: WQ0021734 Owner - Facility: Charlotte Water Inspection Date: 09/20/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Activated Sludge Drip, LR ❑ Recycle/Reuse ❑ Single Family Drip ❑ Infiltration System ❑ Lagoon Spray, LR ❑ Single Family Spray, LR ❑ Activated Sludge Spray, LR ❑ Activated Sludge Spray, HR ❑ Reuse (Quality) Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? 0 ❑ ❑ ❑ Do all treatment units appear to be operational? (if no, note below.) 0 ❑ ❑ ❑ Comment: Bulk reclaimed water distribution is currently not utilized. Treatment Flow Measurement -Influent Yes No NA NE Is flowmeter calibrated annually? ❑ 0 ❑ ❑ Is flowmeter operating properly? 0 ❑ ❑ ❑ Does flowmeter monitor continuously? 0 ❑ ❑ ❑ Does flowmeter record flow? 0 ❑ ❑ ❑ Does flowmeter appear to monitor accurately? 0 ❑ ❑ ❑ Comment: System has not been utilized for several years. Most recent flow meter calibraton was Mar. 1, 2017 and there is no data on additonal meters (turbidity, pH, Cl as applicable). This item is highlighted in the cover letter for attention. CW could rescind this permit if it is no longer needed. Treatment Flow Measurement -Water Use Records Is water use metered? Are the daily average values properly calculated? Comment: The permittee submits required monthly NDMRs reflecting no flow/distribution. However, recently received, customized forms will need to be utilized for future reporting as the forms reflect changes made during the last permit renewal. Treatment Flow Measurement -Effluent Is flowmeter calibrated annually? Is flowmeter operating properly? Does flowmeter monitor continuously? Does flowmeter record flow? Does flowmeter appear to monitor accurately? Yes No NA NE Yes No NA NE ❑■❑❑ ■❑❑❑ Page: 3 Permit: WQ0021734 Owner - Facility: Charlotte Water Inspection Date: 09/20/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Comment: System has not been utilized for several years. Most recent flow meter calibraton was Mar. 1, 2017 and there is no data on additonal meters (turbidity, PH, CI as applicable). This item is highlighted in the cover letter for attention. Per conversation with Jean Creech (on -site for residuals permit inspection), annual meter calibrations are also a requirement for internal audits. Treatment Disinfection Yes No NA NE Is the system working? 0 ❑ ❑ ❑ Do the fecal coliform results indicate proper disinfection? ❑ ❑ ❑ Is there adequate detention time (-30 minutes)? ❑ ❑ ❑ Is the system properly maintained? ❑ ❑ ❑ If gas, does the cylinder storage appear safe? ❑ ❑ ❑ Is the fan in the chlorine feed room and storage area operable? ❑ ❑ ❑ Is the chlorinator accessible? ❑ ❑ ❑ If tablets, are tablets present? ❑ ❑ ❑ Are the tablets the proper size and type? ❑ ❑ ❑ Is contact chamber free of sludge, solids, and growth? ❑ ❑ ❑ If UV, are extra UV bulbs available? ❑ ❑ ❑ If UV, is the UV intensity adequate? ❑ ❑ ❑ # Is it a dual feed system? ❑ ❑ ❑ Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? ❑ ❑ ❑ If yes, then is there a Risk Management Plan on site? 0 ❑ ❑ ❑ If yes, then what is the EPA twelve digit ID Number? (1000--) 100000047987 If yes, then when was the RMP last updated? Comment: Per previous inspections, the Chlorine storage is currently regulated by Mecklenburg County: although, at times is has been regulated by NCDEQ Air Quality. Record Keeping Yes No NA NE Is a copy of current permit available? ❑ ❑ ❑ Are monitoring reports present: NDMR? ❑ ❑ ❑ NDAR? ❑ ❑ ❑ Are flow rates less than of permitted flow? ❑ ❑ ❑ Are flow rates less than of permitted flow? ❑ ❑ ❑ Are application rates adhered to? ❑ ❑ ❑ Is GW monitoring being conducted, if required (GW-59s submitted)? ❑ ❑ ❑ Are all samples analyzed for all required parameters? ❑ ❑ ❑ Are there any 2L GW quality violations? ❑ ❑ ❑ Is GW-59A certification form completed for facility? ❑ ❑ ❑ Is effluent sampled for same parameters as GW? ❑ ❑ ❑ Do effluent concentrations exceed GW standards? ❑ ❑ ❑ Page: 4 Permit: WQ0021734 Owner - Facility: Charlotte Water Inspection Date: 09/20/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Are annual soil reports available? # Are PAN records required? # Did last soil report indicate a need for lime? If so, has it been applied? Are operational logs present? Are lab sheets available for review? Do lab sheets support data reported on NDMR? Do lab sheets support data reported on GW-59s? Are Operational and Maintenance records present? Were Operational and Maintenance records complete? Has permittee been free of public complaints in last 12 months? Is a copy of the SOC readily available? No treatment units bypassed since last inspection? Comment: The permittee submits required monthly NDMRs reflecting no flow/distribution. However, recently received, customized forms will need to be utilized for future reporting as the forms reflect changes made during the last permit renewal. Page: 5