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Home My WebLink AboutWQ0002378_Compliance Evaluation Inspection_20181210Ploy COOPER Cmww MICHAEL S. REGAN see-q-y L. NDA CULPEPPER Infer Dbwur Mr. David Treme Director of Public Utilities Post Office Box 878 Mooresville, North Carolina 28115 Dear Ms. Treme: NORTH CAROLINA Empfronraental Quarrry December 10, 2018 Subject: Compliance Inspection Report Permit No. WQ0002378 Surface Disposal of Solids (503) Mooresville, Iredell County Mooresville Regional Office (MRO) staff, performed a compliance evaluation inspection on December 5, 2018, for permit WQ0002378. The MRO would like to extend its appreciation to Mr. Jamie Levis and is crew for their time and assistance during this site visit. Enclosed you will find the report for the compliance inspection. Guidance was provided, for the following item that should be addressed to maintain compliance: • Monitoring well sampling techniques were reviewed. The MRO has made recommendations regarding monitoring well sampling techniques to aid in the improvement of sample collection. The report should be self-explanatory. Should you have any questions regarding this report, feel free to contact Edward Watson at edward.watson(a-)ncdner.gov, or 704-235-2198. Sincerely, DocuSigned by: F161FB69A2D84A3... Andrew H. Pitner, P.G., Assistant Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources Attachment: Compliance Inspection Report CC: Jamie Levis, Town of Mooresville (via email) North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115 704.663.1699 Compliance Inspection Report Permit: WQ0002378 SOC: County: Iredell Region: Mooresville Effective: 01/25/17 Expiration: 05/31/21 owner: Town of Mooresville Effective: Expiration: Facility: Rocky River WWTP 369 Johnson Dairy Rd Contact Person: David Treme Title: Public Utilities Director Directions to Facility: From MRO take Carpenter Ave turn Rt onto Hwy 3 turn Rt onto Johnson Dairy Rd. System Classifications: Primary ORC: Certification: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 12/05/2018 Entry Time: 09:30AM Primary Inspector: Edward Watson Secondary Inspector(s): Reason for Inspection: Routine Permit Inspection Type: Surface Disposal of Residual Solids (503) Facility Status: Compliant ❑ Not Compliant Question Areas: Miscellaneous Questions Record Keeping Wells (See attachment summary) Mooresville NC 28115 Phone: 704-662-3188 Phone: Exit Time: 12:15PM Phone: Inspection Type: Compliance Evaluation Sampling Page: 1 Permit: WQ0002378 Owner - Facility: Town of Mooresville Inspection Date: 12/05/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Inspection Summary: On December 5, 2018, Edward Watson and Maria Schutte of the MRO performed a Compliance Evaluation Inspection (CEI) for Monofil permit W00002378. During the site visit, it was discovered that groundwater(gw) sampling from the permit associated monitoring wells has been being performed by using bailers to collect the gw water samples. While using bailers is an approved method for the collection of gw samples, the improper use of bailers can create turbidity in the sample. The increased turbidity can produce false positive analytical results and indicate elevated metals being present in the gw well samples. This was an issue previously addressed by the MRO. Sampling wells using a low flow sampling method and a multimeter that has the ability to detect turbidity and would provide better accuracy during the sampling event. This method would also reduce the possibility of false positive results for the presence of metals in the gw samples. When performing the gw sampling event, samples should be collected once three wells volumes have been removed from the well or the multimeter indicates that parameters have stabilized to be able to collect the gw samples. The objective of this sampling method is to allow the sampling of water present in the formation, rather than sampling the water present in the well. It was also suggested that the sampling crew also use dedicated tubing for the monitoring wells. The dedicated tubing would provide a cost saving and reduce the requirements for performing decontamination procedures between the different wells being sampled. Page: 2 Permit: WQ0002378 Owner - Facility: Town of Mooresville Inspection Date: 12/05/2018 Inspection Type : Compliance Evaluation Reason for Visit: Routine Type Yes No NA NE Distribution and Marketing ❑ Land Application Record Keeping Yes No NA NE Is GW monitoring being conducted, if required? ❑ ❑ ❑ Are GW samples from all MWs sampled for all required parameters? ❑ ❑ ❑ Are there any GW quality violations? ❑ ❑ ❑ Is GW-59A certification form completed for facility? ❑ ❑ ❑ Is a copy of current permit on -site? ❑ ❑ ❑ Are current metals and nutrient analysis available? ❑ ❑ ❑ Are nutrient and metal loading calculating most limiting parameters? ❑ ❑ ❑ a. TCLP analysis? ❑ ❑ ❑ b. SSFA (Standard Soil Fertility Analysis)? ❑ ❑ ❑ Are PAN balances being maintained? ❑ ❑ ❑ Are PAN balances within permit limits? ❑ ❑ ❑ Has land application equipment been calibrated? ❑ ❑ ❑ Are there pH records for alkaline stabilization? ❑ ❑ ❑ Are there pH records for the land application site? ❑ ❑ ❑ Are nutrient/crop removal practices in place? ❑ ❑ ❑ Do lab sheets support data reported on Residual Analysis Summary? ❑ ❑ ❑ Are hauling records available? ❑ ❑ ❑ Are hauling records maintained and up-to-date? ❑ ❑ ❑ ❑ # Has permittee been free of public complaints in last 12 months? ❑ ❑ ❑ Has application occurred during Seasonal Restriction window? ❑ ❑ 0 ❑ Comment: Material continues to be removed from the Monofil. Monitoring sampling techniques were reviewed the plant staff. Recently reported GW analytical data indicates elevated metals being present in several wells. During the site visit, the MRO discovered that the wells were being sampled using bailers. If bailers are not used properly, sediments in the well will increase the turnbidity of the water being collected. The increased trubidity may produce analytical results indicating false positives for metals. The MRO staff suggested the return to low -flow sampling for the collection of groundwater samples from the monitoring wells associated with the monofil. Sampling Yes No NA NE Page: 3 Permit: WQ0002378 Owner - Facility: Town of Mooresville Inspection Date: 12/05/2018 Inspection Type : Compliance Evaluation Describe sampling: Dedicating sample tubing may be used for the individual wells. As the permit only requires semi-annual well sampling be performed, the tubing life would be extended thereby providing a cost savings. A multimeter with trubidity could be used to aid with knowing when the sample should be collected. The lower the turbidity of the water, the better the sample will be. Reason for Visit: Routine As it is desirable to collect formational water, information was also provided on how to determine the water is of a formational nature, rather than water that is from the well column. Is sampling adequate? ❑ 0 ❑ ❑ Is sampling representative? ❑ 0 ❑ ❑ Comment: The recent method being used to collect groundwater samples is not adequate to obtain a truly representative groundwater sample. The sampling method discussed during the site visit will aid in the collection of a representative groundwater sample. Page: 4