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HomeMy WebLinkAboutNC0069761_Compliance Evaluation Inspection_20191029ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director �ry 44, NORTH CAROLINA EnNlmnmrrtlnl Quality CERTIFIED MAIL # 7017-1450-0001-6450-4403 RETURN RECEIPT REQUESTED July 17, 2019 Mr. Robert Heaton Director of Infrastructure Town of Beech Mountain 403 Beech Mountain Parkway Beech Mountain, NC 28604 SUBJECT: Compliance Evaluation Inspection- Notice of Violation NOV-2019-PC-0515 Pond Creek WWTP NPDES Permit No. NCO069761 Watauga County Dear Mr. Heaton, On July 10, 2019, Kelli Park, of this office, met with Gary Tipton, operator in responsible charge (ORC), and Randy Horney, backup ORC, to perform a Compliance Evaluation Inspection at the Pond Creek wastewater treatment plant. This type of inspection consists of two basic parts: an in -office file review and an on -site inspection of the treatment facility. The attached EPA inspection form details the areas that were evaluated during this inspection. Violations of permit requirements determined from the inspection are described below. 1) The influent sampler is currently setup to be a time proportional sample. According to the permit, composite samples must be flow proportional. Please get this fixed immediately. If flow proportional sampling is not feasible, a letter must be written to the Division explaining why and requesting exemption. 2) Currently 70mL of sample are being pulled during each sampling event at the influent and the effluent. According to the permit, the minimum sampling amount is 100mL per sample. Please correct this immediately. These issues described above represent violations of the NPDES permit. Therefore, this inspection report is being sent as a Notice of Violation. Please reply in writing to this Notice of Violation within 10 business days of receiving it. Your written reply should Pond Creek WWTP CEI / NOV 7/10/19 address each of the noted violations and provide a corrective action plan along with an implementation/completion schedule to remediate them. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 30 business days of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations. If you have any questions regarding the inspection or this report, please contact Kelli Park or me at (336) 776-9800 or by email at kelli.park(a)_ncdenr.gov or lon.snider(c_ncdenr.gov. Sincerely, DocuS�igfned<by: Jti l c. mAr 145B49E225C94EA... Lon Snider Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report cc: WSRO Page 2 of 2 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 NCO069761 111 12 I 19/07/10 I17 18 I S J 19 L G] 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 ------------------- 671 70 I I 71 I I 72 I r I 73 I I 174 751 I I I I I I I80 u ty I I i 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) 11:30AM 19/07/10 18/07/01 Pond Creek WWTP 364 Locust Ridge Rd Exit Time/Date Permit Expiration Date Banner Elk NC 28604 12:30PM 19/07/10 22/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Gary M. Tipton/ORC/828-387-4724/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Mitchell Heaton,PO Box 342 Roan Mountain TN 37687//704-387-4724/ 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 Kelli A Park WSRO WQ//336-776-9689/ usigned by: Agency/Office/Phone and Fax Numbers Date Signature of Management Q A Revie[L�il ? 1-5,, cc 7/17/2019 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO069761 I11 121 19/07/10 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On July 10, 2019, Kelli Park, of this office, met with Gary Tipton, operator in responsible charge (ORC), and Randy Homey, backup ORC, to perform a Compliance Evaluation Inspection at the Pond Creek wastewater treatment plant. This type of inspection consists of two basic parts: an in -office file review and an on -site inspection of the treatment facility. The attached EPA inspection form details the areas that were evaluated during this inspection. Violations of permit requirements determined from the inspection are described below. 1) The influent sampler is currently set up to be a time proportional sample. According to the permit, composite samples must be flow proportional. Please get this fixed immediately. If flow proportional sampling is not feasible, a letter must be written to the Division explaining why and requesting exemption. 2) Currently 70mL of sample are being pulled during each sampling event at the influent and the effluent. According to the permit, the minimum sampling amount is 100mL per sample. Please correct this immediately. These issues described above represent violations of the NPDES permit. Therefore, this inspection report is being sent as a Notice of Violation. Please reply in writing to this Notice of Violation within 10 business days of receiving it. Your written reply should address each of the noted violations and provide a corrective action plan along with an implementation/completion schedule to remediate them. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 30 business days of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations. If you have any questions regarding the inspection or this report, please contact Kelli Park or me at (336) 776-9800 or by email at kelli.park@ncdenr.gov or lon.snider@ncdenr.gov. Page# Permit: NCO069761 Owner - Facility: Pond Creek WWTP Inspection Date: 07/10/2019 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: 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? Comment: 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? ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ ❑ ❑ on each shift? Is the ORC visitation log available and current? ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ 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? ❑ ❑ ❑ Page# 3 Permit: NCO069761 Owner - Facility: Pond Creek WWTP Inspection Date: 07/10/2019 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review? 0 ❑ ❑ ❑ 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: Meter was calibrated on 12/27/2018 Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: Small amount of foam in the recievinq stream. 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 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ 0 ❑ ❑ representative)? Comment: Only 70mL / 1,000 gal is being sampled. The minimum that can be sampled at one time is 100mL. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ 0 ❑ ❑ Is sample collected above side streams? 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)? Page# 4 Permit: NCO069761 Inspection Date: 07/10/2019 Influent Sampling Is sampling performed according to the permit? Owner - Facility: Pond Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE ❑ ■ ❑ ❑ Comment: Currently sample is being pulled on a time base. The permit states that composite samples must be flow proportional. Only 70mL / 1,000 gal is being sampled. The minimum that can be sampled at one time is 100mL. Bar Screens Yes No NA NE Type of bar screen a.Manual ❑ b.Mechanical Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Debris are taken to the landfill. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? ❑ 0 ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ Comment: Foam covered the entire basin. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ 0 ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? 0 ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Page# 5 Permit: NC0069761 Inspection Date: 07/10/2019 Secondary Clarifier Owner - Facility: Pond Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? ❑ 0 ❑ ❑ Is the drive unit operational? 0 ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? M ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) 0 ❑ ❑ ❑ Comment: There was a significant amount of floating sludge in the inner and outer circular clarifier rings in the second clarifier (farthest from aeration basin) The sludge blanket was reported to be around 1 ft in both clarifiers. Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? 0 ❑ ❑ ❑ Are UV bulbs clean? 0 ❑ ❑ ❑ Is UV intensity adequate? ❑ ❑ ❑ Is transmittance at or above designed level? ❑ ❑ ❑ Is there a backup system on site? 0 ❑ ❑ ❑ Is effluent clear and free of solids? 0 ❑ ❑ ❑ Comment: Some pin floc in the effluent. Chlorine tablets on site as a backup. Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑ Is the generator tested under load? 0 ❑ ❑ ❑ Was generator tested & operational during the inspection? 0 ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? 0 ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up power? 0 ❑ ❑ ❑ Is the generator fuel level monitored? 0 ❑ ❑ ❑ Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and ❑ ❑ ❑ sampling location)? Page# 6 Permit: NCO069761 Owner - Facility: Pond Creek WWTP Inspection Date: 07/10/2019 Inspection Type: Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Comment: 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? ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ❑ Comment: Certification number 5120 Water Tech Labs is used for non -field parameters. DO meter was calibrated on 2/13/19 and the pH meter was calibrated on 2/15/19. pH standards were up to date. Aerobic Digester Yes No NA NE Is the capacity adequate? 0 ❑ ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: Page# 7