DEQ-CFW_00061042

y�NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
FAYETTEVILLE REGIONAL OFFICE
DIVISION OF WATER QUALITY
January 22, 1999
Ms. Janet Waters
E.I. Dupont
22828 NC Hwy. 87 West
Fayetteville, NC 28306
SUBJECT: Compliance Evaluation Inspection
E.I. Dupont de Nemours & Company, Inc
Wastewater Treatment Plant
NPDES Permit No. NC0003573
Bladen County
Dear Ms. Waters:
Enclosed is a copy of the Compliance Evaluation Inspection conducted
January 20, 1999.
As part of the inspection a tour of the Wastewater Treatment Plant was
conducted. All observations and recommendations are in Part D. Summary of
Findings/Comments of this inspection report. Please remember it is priority to
discharge a good quality effluent which will not pose any problems to the receiving
stream.
Please review the attached report. If you or your staff have any questions do
not hesitate to contact me at [phone].
Sincerely,
-j ens
Belinda S. Henson
Environmental Chemist
/bsh
Enclosures
225 GREEN STREET, SUITE 714, FAYETTEVILLE, NORTH CAROLINA 28301-5043
PHONE [phone] S41 FAX [phone]
AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/10% POST -CONSUMER PAPER
DEQ-CFW 00061042

NPDES COMPLIANCE INSPECTION REPORT
North Carolina Division of Water Quality
Fayetteville Regional Office -
Transaction Code: N NPDES NO. NC0003573 Date: 990120 Inspection Type: C
Inspector: S Facility Type: 2 Reserved:
Facility Evaluation Rating: 4 BI: N QA: N Reserved:
Name and Location of Facility Inspected:
E.I. Dupont de Nemours WWT P
Entry Time: 9:30am
Exit Time/Date: 12:30pm/990120
Name(s), Title(s) of On -Site Representative(s):
Permit Effective Date: 960901
Permit Expiration Date: 010531
Robert Geddie-(Certified Grade IV )-"ORC"
Kenneth Mark Hall -(Certified Grade IV) -"Backup Operator"
Murray Batton -(Certified Grade IV) -"Operator"
Phone Number(s): (910) 678- 1219
Name, Title and Address of Responsible Official:
Ms. Janet Waters
22828 NC Hwy. 87 West
Fayetteville, NC 28306
Contacted: yes
Section C• Areas Evaluated During Inspection
N = .qaticfactnrv_ M = Marginal_ I = IJnsatisfactorv. N = Not Evaluated. N/A = Not Annlicable)
Permit: S
Records/Reports: S
Facility Site Review: S
Flow Measurement: S
Laboratory: S
Effluent/Receiving Waters: S
Pretreatment: N/A
Compliance Schedule: N/A
Self -Monitoring Program: S
Operation & Maintenance: S
Sludge Disposal: S
Other:
DEQ-CFW 00061043

Section D. Summary of Findings/Comments:
1. Laboratory results were reviewed for the months October and November, 1998. All records were
neat and in order. -
2. Aqua -Tech Environmental Laboratories, Inc. is the commercial lab that analyzes all parameters
other than pH and temperature which are done in house. Calibration logs were on site for pH.
3. NPDES permit was available upon request.
4. The effluent flow meter was calibrated October 7, 1998 by Fisher &Porter. It is advisable that the
flow meter calibration document contain the % error before and after calibration in the future by the
technician.
astewater from the BCH Energy company because it no longer
5. This facility no longer receives w
exists.
6. The Predigester tank was out of service due to pipe replacement.
7. The Equalization Basin was operational.
8. Clarifier #1 appeared to have light floc passing over the weirs. The sludge depth was measured in
the clarifier at <(less than) 1 foot of solids.
9. Clarifier #2 appeared to have light floc passing over the weirs also. The sludge depth was measured
in the clarifier at >(greater than) 1 foot of solids.
10. Sludge is removed from the clarifiers to the "DAF" unit and from there to the sludge holding tank.
The sludge is then pressed, dewatered and dried and placed in bins to be delivered to `BFI" site in
Roseboro where it is disposed.
11. Maintenance records and schedules are on computer.
12. The effluent appeared to be visably clear.
13. The effluent outfall was easily accessible.
Name and Signature of Inspector
Belinda S. Henson
4waD 4. /Yk�
Name and Signature of Reviewer
Paul E. wl
Agency/Office/Telephone Date
DENR/Fayetteville/[phone]
Agency/Office/Telephone
DENR/Fayetteville/[phone]
Regulatory Office Use Only
Action Taken Compliance Status
_Noncompliance
_Compliance
i-2-ci-qg
Date
Date
DEQ-CFW 00061044

VERIFICATION, RECORDKEEPING, AND REPORTING EVALUATION CHECKLIST
A. PERMIT VERIFICATION
Mailing Address:
Brief Facility Description:
nLkk witoi seed 5ysiew 11QeYci/4i0t'1
`_ (�1�11� ��•�,x� C�G���-ieiS � e-���UP(1T� ��oi� r"VIFciSl�a�r�fr►Pc1� � 1-ir�t�
NE es' No
N/A
1.
Inspection observations verify information contained in permit.
NE Yes' No
N/A
2.
Current copy of permit on -site.
NE es' No
N/A
3.
Correct name and mailing address of permittee.
NE es,' No
NIA
4.
Facility as described in permit.
NE 'e� ; No
N/A
5.
Notification given to EPA/State of new, different, or increased discharges.
NE es No
N/A
6.
Accurate records of influent volume maintained, when appropriate.
NE Q' No
N/A
7.
Number and location of discharge points as described in permit.
NE No
NIA
8.
Name and location of receiving waters correct.
NE 'e ' No
NIA
9.
All discharges permitted.
NE Yes (moo..'
N/A
10.
Federal Construction Grant funds used to build plant.
DEQ-CFW 00061045

B. RECORDKEEPING AND REPORTING EVALUATION
NE
e
No
N/A
1.
Records and reports maintained as required by permit.
NE
e No
N/A
2.
All required information available, complete, and current.
NE C"e
No
N/A
3.
Information maintained for 3 years.
KE (XeD
No
N/A
4.
Analytical results consistent with data reported on DMRs.
5.
Sampling and analyses data adequate and include:
NE
(VvT
No
N/A
a. Dates, times, and location of sampling.
NE
'e
No
N/A
b. Name of individual performing sampling.
NE
a
No
N/A
C. Analytical methods and techniques.
NE
e)
No
N/A
d. Results of analyses and calibration.
NE
es,
No
N/A
e. Dates of analyses.
NE
No
N/A
L Name of person performing analyses.
NE
No
N/A
g. Instantaneous flow at grab sample stations.
6.
Monitoring records adequate and include:
NE
'e '
No
N/A
a. Flow, pH, DO, etc., as required by permit.
NE
Yes
No
N/A
b. Monitoring charts kept for 3 years.
NE
Ces
No
N/A
C. Flowmeter calibration records kept.
NE
�s
No
N/A
7.
Laboratory equipment calibration and maintenance records adequate.
8.
Plant records* adequate and include:
Yes
No
N/A
a. O & M Manual
Yes
No
N/A
b. "As -built" engineering drawings.
NE
�Vl
No
N/A
C. Schedules and dates of equipment maintenance repairs.
Yes
No
N/A
d. Equipment supplies manual.
NE
Yes
No
N/A
e. Equipment data cards.
* Required
only for facilities built with Federal Construction Grant Funds.
9.
Pretreatment records adequate and include inventory of industrial waste
contributors, including:
NE
Yes
No
N/AJ
a. Monitoring data
NE
Yes
No
N/A
b. Inspection records
NE
Yes
No
N/A
C. Compliance status records
NE
Yes
No
N/A
d. Enforcement actions
DEQ-CFW 00061046

C. COMPLIANCE SCHEDULE STATUS REVIEW
1.
Permittee is meeting compliance schedule.
NE Yes No
NE
Yes
No
N/A
2.
Permittee has obtained necessary approvals to begin construction.
NE
Yes
No
N/A
3.
Financing arrangements complete.
NE
Yes
No
N/A
4.
Contracts for engineering services executed.
NE
Yes
No
N/A
5.
Design plans and specifications completed.
NE
Yes
No
N/A
6.
Construction begun.
NE
Yes
No
N/A
7.
Construction on schedule.
NE
Yes
No
N/A
8.
Equipment acquisition on schedule.
NE
Yes
No
N/A
9.
Construction completed.
NE
Yes
No
N/A
10.
Startup begun.
NE
Yes
No
NIA
11.
Permittee requested an extension of time.
NE
Yes
No
N/A
12.
Permittee met compliance schedule.
DEQ-CFW 00061047

D. POTW PRETREATMENT REQUIREMNTS REVIEW
NE Yes No S/
THE FACILITY IS SUBJECT TO PRETREATMENT REQUIREMENTS
1. Status of POTW pretreatment program
NE Yes No N/A
a. The POTW pretreatment program has been approved by EPA.
(If not, is approval in progress? 1
NE Yes No N/A
b. The POTW is in compliance with the pretreatment program compliance
-
schedule. (If not, note why, what is due, and intent of the POTW to
remedy.)
2. Status of Compliance with Categorical Pretreatment Standards
NE Yes No N/A
a. How many industrial users of the POTW are subject to Federal or State
pretreatment standards?
NE Yes No N/A
b. Are these industries aware of their responsibility to comply with
application standards?
NE Yes No N/A
C. Have baseline monitoring reports (403.12) been submitted for these
industries?
i. Have categorical industries in noncompliance (on BMR reports)
submitted compliance schedules?
ii. How many. categorical industries on compliance shcedules are
meeting the schedule deadlines?
NE Yes No N/A
d. If the compliance deadline has passed, have all industries submitted 90-day
compliance reports?
NE Yes No N/A
e. Are all categorical industries submitting the required semi-annual report?
f. Are all new industrial discharges in compliance with new source
NE Yes No N/A
pretreatment standards?
g. Has the POTW submitted an annual pretreatment report?
h. Has the POTW taken enforcement action against noncomplying industrial
NE Yes No N/A
users?
NE Yes No N/A
i. Is the POTW conducting inspections of industrial contributors?
NE Yes No N/A
NE Yes No N/A
3. Are the industrial users subject to Prohibited Limits (403.5) and Local Limits more
stringent than EPA in compliance?
I
(If not, explain why, including need for revision of limits.)
J
Comments:
DEQ-CFW 00061048

. F_ FACILITY SITE REVIEW CHECKLIST
A. OPERATION AND MAINTENANCE EVALUATION
1.
Treatment units properly operated and maintained.
NE Wi No N/A
NE 'es
No
N/A
2.
Standby power or other equivalent provision provided. -
NE Yes
No
N/A
3.
Adequate alarm system for power or equivalent failures available.
4.
Sludge disposal procedures appropriate:
NE 'e`'
No
N/A
a. Disposal of sludge according to regulations.
NE Ye
No
N/A
b. State approval for sludge disposal received.
NE (Yel
No
N/A
5.
All treatment units, other than backup units, in service.
NE (Ne§
No
N/A
6.
Procedures for facility operation and maintenance followed.
NE ej�
No
N/A
7.
Sufficient sludge disposed of to maintain treatment process equilibrium.
Yes
No
N/A
8.
Organizational Plan (chart) for operation and maintenance provided.
NE ( Ue
No
N/A
9.
Operating schedules established.
Yes
No
N/A
10.
Emergency plan for treatment control established.
11.
Maintenance record system exists and includes
Yes
No
N/A
a. As -built drawings
Ln L Yes
No
N/A
b. Shop drawings
St Yes
No
N/A
C. Construction specifications
NE Ye
No
N/A
d. Maintenance history
NE Yes
No
N/A
e. Maintenance costs
NE (Yes
No
N/A
f. Repair history
NE Ti
No
N/A
g. Records of equipment repair and timely return to service
NE (Yei
No
N/A
12.
Adequate number of qualified operators on -hand.
Yes
No
N/A
13.
Established procedures available for training new operators.
TF Yes
No
N/A
14.
Adequate spare parts and supplies inventory maintained.
NE e ' No
N/A
15.
Instruction files kept for operation and maintenance of each item of major
equipment.
(St Yes
No
N/A
16.
Operation and maintenance manual available.
NE i('O-
No
N/A
17.
Regulatory agency notified of bypassing. (Dates 1
NE Yes (N-
N/A
18.
a. Hydraulic overflows and/or organic overloads experienced.
NE Yes
Q0
N/A
b. Untreated bypass discharge occurs during power failure.
NE Yes
(A
N/A
C. Untreated overflows occurred since last inspection.
,
Reason:
NE Yes
No.
N/A
NE (Sij
No
N/A
d. Flows observed in overflow or bypass channels.
NEI�ce
No
N/A
e. Checking for overflows performed routinely.
f. Overflows reported to EPA or to the appropriate State agency as
specified in the permit.
DEQ-CFW 00061049

B. SAFETY EVALUATION
(Any No answer will be discussed in the Comment section of the report.)
NE Yes <So
N/A
I.
Undiked oil/chemical storage tanks used at facility.
NE (gR
No
N/A
2.
Up-to-date equipment repair records maintained.
NE es
No
N/A
3.
Out -of -service equipment documented with DWQ.
NE es
No
N/A
4.
Routine and preventive maintenance scheduled/performed on time.
NE ' Sj
No
N/A
5.
Personal protective clothing provided (safety helmets, ear protectors,
goggles, gloves, rubber boots with steel toes, eyewashes in labs).
6.
Safety devices readily available:
Yes
No
N/A
a. Fire extinguishers
NE Yes
No
N/A
b. Oxygen deficiency/explosive gas indicator
NE Yes
No
N/A
C. Self-contained breathing apparatus near entrance to chlorine room
NE Yes
No
N/A
d. Safety harness
NE Yes
No
N/A
e. First aid kits
NE Yes
No
N/A
f. Ladders to enter manholes or wetwells (fiberglass or wooden for
electrical work)
NE Yes
No
N/A
g. Traffic control cones
NE Yes
No
N/A
h. Safety buoy at activated sludge plants
NE Yes
No
N/A
i. Life preservers for lagoons
NE Yes
No
N/A
j. Fiberglass or wooden ladder for electrical work
NE Yes
No
N/A
k. Portable crane/hoist
NE Ees No
N/A
7.
Plant has general safety structures such as rails around or covers over tanks,
pits, or wells.
NE) Yes
No
N/A
8.
Emergency phone numbers listed.
NE 'es No
N/A
9.
Plant is generally clean, free from open trash areas.
E? Yes
No
N/A
10.
Portable hoists, for equipment removal, available.
NJ Yes
No
N/A
11.
All plant personnel immunized for typhoid and tetanus.
NE 0
No
N/A
12.
Gas/explosion controls such as pressure -vacuum relief values, no smoking
signs, explosimeters, and drip traps present near anaerobic digesters,
enclosed screening or degritting chambers, and sludge -piping or gas -piping
structures.
NE O
No
N/A
13.
All electrical circuitry enclosed and identified.
NE Yes' No
N/A
14.
Personnel trained in electrical work to be performed as well as safety
procedures.
qE-' Yes
No
N/A
16.
Chlorine safety:
a. NIOSH-approved 30-minute air pack
b. All standing chlorine cylinders chained in place
C. All personnel trained in use of chlorine
d. Chlorine repair kit available
e. Chlorine leak detector tied into plant alarm system
DEQ-CFW 00061050

PERIVIITTEE SAMPLING INSPECTION CHECKLIST
A. PERMITTEE SAMPLING EVALUATION
NE 'e )No
N/A
1.
Samples taken at sites specified in permit. '
NE Ye No
N/A
2.
Locations adequate for representative samples.
(Sp Yes No
N/A
3.
Flow proportioned samples obtained when required by permit.
NE 'e No
N/A
4.
Sampling and analysis completed on parameters specified by permit.
NE es No
N/A
5.
Sampling and analysis done in frequency specified by permit.
NE C es ' No
N/A
6.
Permittee uses method of sample collection required by permit.
Required method(s): ( ) Grab ( ) Composite
If not, method used is: ( ) Grab ( ) Composite
7.
Sample collection procedures adequate:
NE (rei No
N/A
a. Samples refrigerated during composting
NE (&) No
N/A
b. Proper preservation techniques used
NE 'e No
N/A
C. Containers and sample holding times before analyses conform to 40
CFR Part 136.3
NE (De No
N/A
d. Samples analyzed in timeframe needed (same day, etc.)
NE Ye No
N/A
8.
Monitoring and analyses performed more often than required by permit. If
so, results reported in permittee's self -monitoring report.
NE Yes No
/
9.
Samples contain chlorine.
NE es' No
N/A
10.
Contract laboratory used for sample analysis.
NE Yes No
(NON
11.
POTW collects samples from industrial users in pretreatment program.
B. SAMPLING INSPECTION PROCEDURES AND OBSERVATIONS
NE i') No
N/A
1.
Grab samples obtained.
NE 'es No
N/A
2.
Composite sample obtained.
1< of
Composting frequency: N Preservation:
NE Yes No
N/A
3.
Sample refrigerated during compositing.
(KE Yes No
N/A
4.
Flow proportioned sample obtained.
NE 1I es% No
N/A
5.
Sample obtained from facility sampling device.
NE Ye No
N/A
6.
Sample representative of volume and nature of discharge.
Yes No
N/A
7.
Sample split with permittee.
NE es,; No
N/A
8.
Chain -of custody procedures employed.
NE Yes' No
N/A
9.
Samples collected in accordance with permit.
NE Yes Chi
N/A
10.
Excessive faun, grease, floating solids observed at the outfall.
DEQ-CFW 00061051

OPERATION EVALUATION (continued)
17.
Chlorination Basin, Feed and Storage Area
NE
Yes
No
(Po
a.
Sludge buildup in contact tank
NE
Yes
No
N/A
b.
Gas bubbles
NE
Yes
No
N/A
C.
Floating scum or solids _
NE
Yes
No
N/A
d.
Inadequate ventilation of chlorine feed room
NE
Yes
No
N/A
e.
NIOSH-approved 30-minute air pack
NE
Yes
No
N/A
f.
All standing chlorine cylinders chained in place
NE
Yes
No
N/A
g.
All personnel trained in the use of chlorine
18.
Aerobic Digester
NE
Yes
N/A
a.
Excessive foaming in tank
NE
Yes
(h@
N/A
b.
Noxious odor
NE
Yes
d�l
N/A
C.
Mechanical aeration failure
NE
Yes
N/A
d.
Clogging of diffusers
19.
Anaerobic Digester
NE
Yes
No
N%�
a.
Floating cover tilting
NE
Yes
No
/A
b.
Gas burner not burning
NE
Yes
No
N/A
C.
Supernatant has a sour odor
20.
Sludge Drying Beds
NE
Yes
No
(S }
a.
Poor sludge distribution on drying beds
NE
Yes
No
N/A
b.
Vegetation in drying beds
NE
Yes
No
N/A
C.
Dry sludge remaining in drying beds
NE
Yes
No
N/A
d.
Dry sludge stored on site
NE
1'es
No
N/A
21.
Sampling
a.
Are samples collected as specified in permits?
b.
Are refrigerated samples kept at 40" C?
C.
Samples shipped to certified labs are iced and kept at 400 C.
Comments:
t��c-f a -I °C A
be ��ia , r'1 ��c, :t �} u
DEQ-CFW 00061052

RECORDS AND REPORTING EVALUATION CHECKLIST
'e) No N/A NE 1. Are record and reports maintained as required by the permit/consent order?
es No N/A NE 2. Is a current copy of the permit/consent order on site?
— NE 3. What is the expiration date of their permit? %� l ,► C) 0
Yes �u N/A NE 4. Is the permittee on a compliance schedule and, if so, is the schedule being met?
No N/A NE 5. Are analytical results consistent with data reported on DMRs? (Select random
DMRs and compare results to bench sheets for possible discrepancies or
omissions even if reports are prepared using a computer.)
Yes No N/A
'e No N/A
NE
'�s No N/A
NE
CYONo N/A
NE
(jR No N/A
NE
Yes ('9' N/A
NE
Yes 6' N/A NE
6. Are strip chart recordings and DMRs maintained for three years and sludge use
and disposal activities maintained for five years?
7. Do sampling and laboratory analytical records clearly identify dates, times,
locations and names of individuals performing the sampling and analyses?
8. Are composite and/or grab samples being collected as required by the permit?
9. Are DMRs complete and include all parameters required by the permit?
10. Are the DAIRs signed by the ORC and the permittee?
11. If the limited inspection indicates omissions, laxity or discrepancies in the
preparation of records and data, an in-depth investigation should follow.
12. Is there evidence of falsification of data for DMR reports?
No N/A NE 13. Are laboratory equipment calibration and maintenance records adequate?
<Ts No N/A NE 14. Are detailed maintenance records kept for mechanical equipment such as
pumps, motors, aerators, etc.?
Yes No N/A' NE 15. Are pretreatment records adequate and include permits, monitoring data, and
inspection reports for industrial user activities?
es No N/A NE 16. Are flow meter calibration records kept and are accurate records maintained of
influent or effluent now volumes?
Yes No N/A 17. Are sludge use and disposal activity records maintained?
Des No N/A NE 18. Do operators meet certification requirements?
es No N/A NE 19. Does the permittee report noncompliance information to the regional office
within 24 hours?
(ye)V'No N/A NE 20. Is the laboratory certified for all parameters being analyzed?
's No N/A NE 21. Do operators keep required logs to document required visitation to the facility?
DEQ-CFW 00061053

5 �
y •r �
WASTEWATER TREATMENT PLANT INSPECTION CHECKLIST
Yes No N/A NE 1. Compliance status for all monitoring requirements contained in the permit
during the last 12 month.
No N/A NE 2. Compliance status with monthly and weekly averages/daily maximum limits
during the last 12 months.
'e No N/A NE 3. Toxicity tests submitted as required?
Yes No N/A N ; 4. Annual Priority Pollutants Analyses results submitted?
e0 No N/A NE 5. Are DMRs signed by the ORC and the permittee?
IN
SliNo N/A NE 6. Is the ORC certified at a level equal to or greater than the classification of
the facility?
Yes' N/A NE 7. Is the facility operating under an SOC or JOC? If so, address compliance
with schedule dates and limits. Include next milestone date contained in the
order.
Yes No &A NE 8. Is the BOD incubator temperature maintained at 20 +/-10 C and is the
temperature maintained in a log for every day of operation?
Yes No(S� NE 9. Is the fecal coliform incubator maintained at 44.5 +/-.0.2° C and is the
temperature maintained in a log for every dat of operation?
' s` No N/A NE 10. Is pH, conductivity, temperature, DO taken on -site? Are calibration logs
kept?
es' No N/A NE 11. Check at least one month of DMR data against the lab sheets or reports from
commercial labs for correctness.
es No N/A NE 12. Ask about the method of sampling, mixing, preservation and shipment.
Check the chain -of -custody procedures.
es No N/A NE 13. Appearance of effluent/receiving stream. ( (ea t
Yes No N/A NE 14. Method of sludge disposal.
Yes` No N/A NE 15. Flow meter calibration date (minimum of once per year). Perform
instantaneous readings if possible and comp re to meter. Must be less than
10% variation. to 0cL "; c'+' OF' nci QL
Yes No N/ NE 16. Compare flow reading to capacity of facility for the average of the last
calendar year. Greater than 80 to 90%? Include new regulation language if
applicable.
Yes No N/A NE 17. Check certification of laboratory performing the analyses.
Ye' , No N/A NE 18. Are ORC visitation logs available and current?
Yes No N/ NE 19. Is the facility meeting 24 hour, seven day per week operation requirement if
greater than 5 MGD? Is there a certified operator on each shift?
DEQ-CFW 00061054