WQ0019755_BIMS Report_20190131

Compliance Inspection Report
Permit:WQ0019755 Effective:12/04/15 Expiration:11/30/20 Owner :JPC Utilities LLC
SOC:
Contact Person:
Region:
County:
Directions to Facility:
Guilford
Winston-Salem
Philip M Cooke
Effective:Expiration:Facility:Oak Ridge Commons WWTP
2200 NC 68
Oak Ridge NC 27310
Title:Phone:[phone]
From Winston-Salem, take I-40 East to Route 68 North. Proceed to the intersection of Route 68 and Route 150. The facility is
situated in the northwrst corner of the crossroads.
Bradley Todd Flynt 27171 336-433-7262
Secondary ORC(s):
919-260-7301Phone:23928Certification:Kenneth Chad LeinbachPrimary ORC:
WW2,SI,System Classifications:
On-site representative Doug Smith
On-Site Representative(s):
Related Permits:
Secondary Inspector(s):
Primary Inspector:
Inspection Date:Exit Time:Entry Time:
Phone:
01/31/2019 01:10PM 03:00PM
Rebecca D Chandler 336-776-9692
Facility Status:
Permit Inspection Type:
Reason for Inspection:Inspection Type:
Not CompliantCompliant
Routine
Reclaimed Water
Compliance Evaluation
Question Areas:
Treatment Flow Measurement-Effluent Treatment Flow Measurement-Influent Miscellaneous Questions
Treatment Flow Measurement-Water
Use Records
Treatment Treatment Barscreen
Record Keeping End Use-Irrigation Treatment Influent Pump Station
Treatment Clarifiers Treatment Disinfection Treatment Flow Measurement
End Use-Reuse Standby Power
(See attachment summary)
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Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
Inspection Summary:
Final inspection followup from initial site visit in Sept. 2018
Some previous concerns/violations have been abated and conditions are much improved.
Still concern for lower parts of Zones 2 and 3. Could not observe spray irrigation during this inspection due to weather
conditions, but still noted evidence of runoff and ponding from some sprayheads and ground cover is unsuitable. Plans are
made to plant grass seed when weather conditions are appropriate and try switching some (less than 5) impact sprinkler
heads for wobblers. Final plan if that does not work to reduce runoff is to permanently cap those sprayheads. Final solution
will require permit modification and engineer certification. Temporary measurement to replace impact with wobblers should
be laid out in written request to WSRO.
Flow meter's previous concern and not properly totalizing flow for irrigation events has been resolved. Facility suspects an
adjustment to motherboard of meter by the calibration technician caused the error. Calibration was completed mid-August
2018 so irrigation event data from that date to the fix is likely inaccurate. Facility is also tracking each irrigation event by
time dosed and dividing by design specs for system as backup to flow totalizer.
Residuals were removed on 10/28/18 and 1/29/19 by Overbys. Grease traps are routinely pumped.
Somewhat high fecal results in effluent sampling results, ensure proper contact is made within chlorination chamber and that
no buildup of tablet residue or algal growth is impeding contact.
Soil sampling results indicate lime needs for the reclaimed fields. WSRO suggested sampling each zone, though this is not
required by the permit. It may reduce the amount of lime needed as a whole and provide more detailed insight to soils in
zones of concern.
Backup ORC is completing all of the 5-day a week required visits
On January 31, 2019 staff from the North Carolina Division of Water Resources (DWR) performed an announced, routine
compliance inspection of the Reclaimed Water System (hereby referred to as Reclaim) and Wastewater Irrigation system
(hereby referred to as Upset) operating under Permit WQ0019755. This inspection was conducted as follow-up to a previous
inspection completed on August 28, 2018 and was completed by DWR staff person Rebecca Chandler. DWR staff would
like to thank all present during the inspection for their time and attention. While many previously noted concerns and
violation have been abated since the August 2018 inspection, this follow-up reflected continued non-compliance with Permit
No. WQ0019755.
Accordingly, the following violations and continued violations were noted which require your attention and action:
1.Permit Condition III.5 states that “a suitable year-round vegetative cover shall be maintained on irrigation sites at all
times, such that crop health is optimized, allows for even distribution of effluent, and allows inspection of the irrigation
system.” It was determined during the onsite inspection and subsequent follow-up that vegetative cover in Zones 2 and 3 of
the Reclaim system is not suitable. Much of the ground surface was noted with many ruts present beginning at system
sprayheads. Bare soil without any vegetative cover was noted throughout many of the Zones.
Please ensure that adequate year-round vegetative cover is established in all Zones, particularly in the Zones adjacent to the
onsite stream (Zones 2, 3, 4, and 8). Provide the plans to establish and maintain this vegetative cover to this office.
2.Permit Condition III.6 states that “adequate measures shall be taken to prevent effluent ponding in or runoff from the
irrigation sites.” At the first evidence of ponding and/or runoff from any of the Zones for either the Upset or Reclaim systems,
irrigation should be ceased until the issue is corrected. There was evidence of chronic ponding and runoff observed,
particularly in Zones 2 and 3 of the Reclaim system.
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Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
Explain plans to repair the existing rutting and erosion in Zones 2 and 3, as well as how future violations of this condition will
be abated.
3.Permit Condition III.7 states that “irrigation shall not be performed during inclement weather or when the ground is in a
condition that will cause ponding or runoff.” During the August 28, 2018 onsite inspection, the ground was immensely
saturated with ponding and pooling throughout the Reclaim system Zones. It was clear that the ground was unable to
assimilate effluent but had been recently been irrigated on. Additionally, Non-Discharge Application Reports (NDARs)
indicate that irrigation was conducted throughout the month of December 2018, including prior to, during, and after the 12
-inch snow event that was recorded in the area. It should be noted that the 12” snow event was not reported on the NDARs.
Irrigation events recorded throughout the late Fall and Winter months are concerning as the area saw an exceptional amount
of rainfall and wet weather conditions such that wastewater irrigation at other facilities within the Winston-Salem Region was
prevented.
While this office understands that rain sensors are installed on the system, please understand that this is not a fail-proof
method to ensure irrigation does not occur when the soil condition is not suitable to assimilate the effluent. The Permit
prohibits irrigation when the soil is saturated, frozen, or snow-covered.
More adequate inspection frequency of the sprayfields prior to irrigation will prevent future violations of this Permit Condition.
4.15A NCAC 08G .0204 states that “An Operator in Responsible Charge (ORC) of a water pollution control system must
visit the system as often as is necessary to ensure the proper operation of the system but in no case less frequently than
(the specified schedule).” Please be reminded that the sprayfields for both the Upset and Reclaimed systems are an
important part of the wastewater irrigation system and should be regularly inspected for suitability of irrigation prior to
irrigation events, and for runoff or ponding during irrigation events. It was determined during the onsite inspection that
numerous sprayheads and lines were broken and leaking throughout the Zones. Evidence of chronic failure of the
sprayheads in Zones 2 and 3 was noted with large ruts and debris line flows from the areas downslope of the sprayheads,
towards an onsite stream.
Routine inspection of the entire system is expected so that repairs may be made in a timely manner.
The following operations violations were noted during an in-office review of the self-monitoring data covering the period of July
2017 to December 2018:
5.15A NCAC 08G .0205 states that “the Back-up Operator in Responsible Charge (Back-up ORC) may act as surrogate
for the Operator in Responsible Charge (ORC), if he/she possesses a valid certificate of the appropriate type and grade for
the system, for a period…not to exceed 40 percent of the system visitations required per calendar year…” It has been noted
consistently that the Back-up ORC for the facility is completing a majority of the 5-day a week minimum required visits for
the Reclaim system. A review of on-site bench sheets showed that Back-up ORC Bradley Flynt performed all the site visits
for August and September 2018. It is the understanding of DWR staff that Mr. Flynt conducts all the site visits for the
Reclaim system while ORC Chad Leinbach conducts the once-weekly minimum required visits of the Upset system.
If you wish to continue this arrangement, Mr. Flynt must be appointed as the Primary ORC for the system. Otherwise, it is
to be expected that Mr. Leinbach will perform 60% or greater of the minimum required 5-day a week onsite inspections going
forward.
6.Permit Condition IV.3 states that “the Permittee shall install and maintain an appropriate flow measurement device to
ensure the accuracy and reliability of flow measurement…” It was noted during the initial inspection that the flow totalizer for
the Reclaim irrigation pump was recording negative values (at approximately -22 gallons per minute (gpm) during the onsite
inspection) and therefore improperly operating. This should have been detected during daily inspections and immediately
fixed – at the very least, irrigation events using the inaccurate totalizer should have been ceased until the error could be
resolved.
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Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
Onsite representatives indicated that the issues were a result of improper calibration of the flow meter on August 8, 2018,
however self-monitoring data submitted prior to August 2018 is inconclusive to prove that. In addition, a subtraction from the
irrigation totalizer can be noted on the August 2018 Operator bench sheets from August 1, 2018 up until the date of
calibration (August 8, 2018), so it is very likely that it was already improperly operating. It can be deduced that all irrigation
events from at least the date of calibration (August 8, 2018) to the date of repair are also inaccurate and that there is no true
record of how much was irrigated during that time. As a result, the 12-month floating total for the Reclaim system NDARs
will continue to be inaccurate until one year after the flow meter issue was resolved. It is the understanding of this office that
the flow meter is now accurately recording the irrigation event totals and that a back-up method of recording has been
implemented as well.
Provide explanation for the inaccurate totalizer, the nature of the defect, and evidence as to when it first became inaccurate.
Explain in detail the irrigation regime that was in place prior to November 2018 and how the reported data was generated.
7.Permit Condition IV.5 states that “The Permittee shall maintain adequate records tracking the amount of effluent
irrigated…At a minimum, these records shall include the following information for each irrigation site listed…: b. Volume of
effluent irrigated; g. Weather Conditions.” Inaccurate flow meter records have resulted in improperly tracking the amount of
effluent irrigated to the Reclaim system sprayfields. Additionally, weather codes are repeatedly missing from all irrigation
events of the Upset or the Reclaim system. In addition, the October 2018 NDAR was missing any/all precipitation events.
This is a repeat violation that was noted as Item #6 on the Notice of Deficiency (NOD-2015-PC-0155) issued to the facility on
June 16, 2015.
Ensure that weather conditions are included for every irrigation event included on NDARs as required by the Permit. Check
the accuracy of all self-monitoring data prior to submittal to the Division.
8.Permit Condition IV.11 states that “The Permittee shall report by telephone to the Winston-Salem Regional Office
(WSRO) as soon as possible but in no case more that 24-hours, or on the next working day following the occurrence or first
knowledge of the occurrence of any of the following: …d. Any time self-monitoring indicates the facilities permitted have
gone out of compliance with the limitations contained in this permit; e. Ponding in or runoff from the irrigation sites. WSRO
did not receive notification of any of the noted exceedances from the self-monitoring data, nor received any information
regarding the chronic ponding and runoff issues noted in Zones 2 and 3. This is a repeat violation that was noted as Item #5
on the Notice of Deficiency (NOD-2015-PC-0155) issued to the facility on June 16, 2015 and Item #5 on the Notice of
Violation (NOV-2016-PC-0653) issued to the facility on December 19, 2016.
Please provide future notification to WSRO for any future non-compliance in either the system operations or within the
self-monitoring data.
9.Attachment A of the Permit lists the monthly average flow limit for the Reclaim system as 36,000 gallons per day (gpd)
and 12,094 gpd for the Upset system. Monthly average flow limit has been inaccurately reported at the bottom of
Non-Discharge Monitoring Reports (NDMRs) for both the Upset and Reclaim systems.
Immediately correct this error on both NDMRs to ensure proper tracking of system flows.
10.Permitted effluent limits for the following constituents were exceeded as listed on the NDMRs for the Reclaim system:
BOD in December 2017; total suspended solids in August 2017, December 2017, January 2018, and March 2018; fecal
coliform in October 2018 and November 2018.
11.Permitted effluent limits for the following constituents were exceeded as listed on the NDMRs for the Upset system:
monthly average flow in September 2018.
Additional concerns:
1.The most recent soil sampling results indicated the agronomist recommended lime application to the Reclaim system
sprayfield. While it is not required by the Permit, DWR staff recommends pulling a sample for each Zone to identify a
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Inspection Date:
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Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
smaller area requiring lime. Please take care when sampling to ensure a representative composite sample is collected for
each Zone.
2.Calibration of both irrigation systems is required once per permit cycle and still needs to be completed for both
systems.
The following previously-noted violations have been already been addressed:
1.During the August 28, 2018 inspection, most of the required onsite records were missing and no spill plan had been
developed for the system. This has since been corrected and all records were available onsite during the follow-up
inspection. A suitable spill plan was developed and is maintained onsite.
2.The alarm connected to the wet-well floats was not operating properly during the August 28, 2018 inspection. This had
been corrected during the follow-up inspection.
3.Housekeeping in the main Reclaim system pump house was unmaintained making it difficult to reach central processes
and operation panels. This had been corrected during the follow-up inspection.
4.During the August 28, 2018 inspection, DWR staff made a recommendation to attach Spanish-language restriction signs
to the reclaimed system sprayfield as Hispanic workers could be employed in the shopping center. Management has since
attached these signs below the already existing English-language signs.
5.Three sprayheads within the sand filter were clogged and improperly operating during the August 28, 2018 inspection.
This had been corrected by the follow-up inspection.
6.Previously noted sprayheads located within the 50-foot setback to the shopping center expansion had not y
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Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
Type Yes No NA NE
Activated Sludge Drip, LR
Recycle/Reuse
Single Family Drip
Infiltration System
Single Family Spray, LR
Activated Sludge Spray, LR
Activated Sludge Spray, HR
Reuse (Quality)
Lagoon Spray, LR
Treatment Yes No NA NE
Are Treatment facilities consistent with those outlined in the current permit?
Do all treatment units appear to be operational? (if no, note below.)
Comment:
Treatment Influent Pump Station Yes No NA NE
Is the pump station free of bypass lines or structures?
Is the general housekeeping acceptable?
Are all pumps present?
Are all pumps operable?
Are floats/controls operable?
Are audio and visual alarms available?
Are audio and visual alarms operational?
# Are SCADA/Telemetry alarms required?
Are SCADA/Telemetry available?
Are SCADA/Telemetry operational?
Comment:
Treatment Flow Measurement-Influent Yes No NA NE
Is flowmeter calibrated annually?
Is flowmeter operating properly?
Does flowmeter monitor continuously?
Does flowmeter record flow?
Does flowmeter appear to monitor accurately?
Comment:
Treatment Flow Measurement-Water Use Records Yes No NA NE
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Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
Is water use metered?
Are the daily average values properly calculated?
Comment:
Treatment Flow Measurement-Effluent Yes No NA NE
Is flowmeter calibrated annually?
Is flowmeter operating properly?
Does flowmeter monitor continuously?
Does flowmeter record flow?
Does flowmeter appear to monitor accurately?
See summary.Comment:
Standby Power Yes No NA NE
Is automatically activated standby power available?
Is generator tested weekly by interrupting primary power source?
Is generator operable?
Does generator have adequate fuel?
Comment:
Treatment Barscreen Yes No NA NE
Is it free of excessive debris?
Is disposal of screenings in compliance?
Are the bars spaced properly?
Is the unit in good condition?
Comment:
Treatment Clarifiers Yes No NA NE
Are the weirs level?
Are the weirs free of solids and algae?
Is the scum removal system operational?
Is the scum removal system accessible?
Is the sludge blanket at an acceptable level?
Is the effluent from the clarifier free of excessive solids?
Comment:
Treatment Disinfection Yes No NA NE
Is the system working?
Do the fecal coliform results indicate proper disinfection?
Is there adequate detention time (>=30 minutes)?
Is the system properly maintained?
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Inspection Date:
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Inspection Type :
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Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
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 lbs of Chlorine (CAS No. 7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000-____-____)
If yes, then when was the RMP last updated?
See summaryComment:
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?
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?
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Inspection Date:
Permit:
Inspection Type :
Owner - Facility:
Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
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?
See summaryComment:
End Use-Irrigation Yes No NA NE
Are buffers adequate?
Is the cover crop type specified in permit?
Is the crop cover acceptable?
Is the site condition adequate?
Is the site free of runoff / ponding?
Is the acreage specified in the permit being utilized?
Is the application equipment present?
Is the application equipment operational?
Is the disposal field free of limiting slopes?
Is access restricted and/or signs posted during active site use?
Are any supply wells within the CB?
Are any supply wells within 250' of the CB?
How close is the closest water supply well?
Is municipal water available in the area?
# Info only: Does the permit call for monitoring wells?
Are GW monitoring wells located properly w/ respect to RB and CB?
Are GW monitoring wells properly constructed, including screened interval?
Are monitoring wells damaged?
See summaryComment:
End Use-Reuse Yes No NA NE
Is the acreage in the permit being utilized?
Does the acreage specified in the permit correspond to the measured acreage at the site?
Are all essential units provided in duplicate?
Is an automatically activated standby power source available?
Is the equalization capacity adequate?
Is aerated flow equalization present?
Has the turbidity meter been calibrated in the last 12 months?
Does the turbidity meter have recording capabilities?
Is all flow diverted at the appropriate times?
Is all upset wastewater diverted from reuse storage unit?
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Reason for Visit:
WQ0019755
01/31/2019 Compliance Evaluation
JPC Utilities LLC
Routine
Is all upset wastewater treated, retreated, or disposed of acceptably?
Is upset wastewater treated prior to discharge to irrigation storage?
Is public access restricted from irrigation area during active site use?
If golf course, is a sign posted in plain sight on the club house?
Is the cover crop acceptable?
Are buffers adequate?
Is the site free of ponding/runoff?
Is the acreage in the permit being utilized?
Is the application equipment acceptable?
Is the application area free of limiting slopes?
How close is the closest water supply well?
Are any supply wells within the CB?
Are any supply wells within 250' of the CB?
Is municipal water available in the area?
Are GW monitoring wells required?
Are GW monitoring wells located properly w/ respect to RB and CB?
Are GW monitoring wells properly constructed, including screened interval?
See summary.Comment:
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