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HomeMy WebLinkAboutNC0035866_Compliance Evaluation Inspection_20191108ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director Dan J. LaMontagne, County Manager Chatham County PO Box 1809 Pittsboro, NC 27312-1809 NORTH CAROLINA Environmental Quality November 8, 2019 Subject: Compliance Evaluation Inspection Bynum WWTP NPDES Permit NCO035866 Chatham County Dear Mr. LaMontagne: On Thursday, October 31, 2019, Vanessa Manuel of the Raleigh Regional Office conducted a compliance evaluation inspection of the treatment facilities located at Bynum Wastewater Treatment Plant (WWTP). The purpose of this inspection was to ensure compliance with the subject NPDES permit. During the inspection, the presence and cooperation of Wayme Marsh, Operator in Responsible Charge (ORC), were helpful and appreciated. The Bynum WWTP is Iocated at 214 Bynum Church Road in Pittsboro, North Carolina. The facility is a Grade II Biological Water Pollution Control System with an as -built flow of 0.025 MGD that treats domestic wastewater. Through NPDES permit NC0035866, Chatham County, hereinafter referred to as the County, is authorized to discharge the treated wastewater through outfall 001 to receiving waters designated as the Haw River, a waterbody classified as WS-IV Nutrient Sensitive Waters within the Cape Fear River Basin. This NPDES compliance evaluation inspection consisted of the following: • Review of the NPDES permit; • Review of the owner/facility information; • Review of September 2017 — August 2019 monitoring and compliance data; • On -site inspection of the wastewater treatment units; and • On -site inspection of the discharge outfalI. Findings during the pre -inspection rile review were as follows: 1. The current NPDES permit was issued effective January 1, 20I7, and will expire April 30, 2021. The County will need to request permit renewal at least 180 days prior to expiration in order to maintain authorization to discharge after the expiration date. 2. As listed in the subject permit, the treatment components include influent bar screen, caustic feed system, five aeration basins, aerobic digester, clarifier, effluent chlorinator & chlorine DE QQ North Carolina Department of Environmental Quatty I Division of Water Resources _ Raleigh Regional Off9ce 1 3600 Barrett Drive I Raleigh, North Carolina 27609 My.... ' __\ �� 919 791.4200 Chatham County, NPDES Permit NC003SB66 November 8, 2019 Page 2 of 4 contact chamber, tablet dechlorination, continuous flow monitoring and recording and standby power. 3. Beginning December 21, 2016, EPA's NPDES Electronic Reporting Rule requires permittees to submit their discharge monitoring reports (DMRs) electronically, instead of on paper. The first DMR the Division received electronically from the County for the subject plant was for August 2016. As of October 7, 2019, all NPDES discharge monitoring reports submitted in the eDMR system: are accepted with electronic signature and signed hardcopies are no longer required to be mailed to the Division of Water Resources. This applies to any monitoring report submitted after October 7, 2019, including revisions to past reports. To learn more about the eDMR system, please visit the Division's eDMR website at https::'.'deg.ne.aoviabout/divisions'%,�-ater-resources 'edmr. 4. The subject NPDES permit requires the permittee to monitor and record flow continuously and to report the data electronically using the Division's eDMR system. As reflected in the table below, flow was not reported as required because "No Visitation — Holiday" was selected as a "No Reporting Reason" within the eDMR system, which applied to all parameters for the selected day. No values can be reported for any parameter as long as the "No Reporting Reason" is selected in the eDMR system. When monitoring is required for some parameters such as flow (continuous recording) and a flow value is reported for a recognized holiday, then an "H" must be entered as the value for the other parameters that were not monitored on that day. Failure to report flow is a violation of the subject NPDES permit. Please ensure flow is monitored and reported as required. Days the County failed to report Flow electronically through the eDMR System: 1019 ... 2018 .2017 Jan. 1 Jan. i Jan. I Jan.21 Mar.30 Jan.2 Apr. 19 July 4 Jan. 16 May 27 Se .3 Apr. 14 July 4 Nov. 12 July 4 Sep. 2 Nov.22 Nov. 10 Nov.23 Nov.23 Dec.25 Nov.24 Dec.26 Nov.25 5. For the review period September 2017 through August 2019, the following violations were detected and addressed by the Division: exceedance of the Fecal Coliform weekly geometric mean limit on November 25, 2017 and January 13, 2018 (these violations resulted in the Division issuing the County civil penalty assessments); failure to monitor Total Residual Chlorine as required for the week ending September 22, 2018 (no enforcement action taken due to the severe weather event from the hurricane); failure to monitor Ammonia Nitrogen as required during May 2019 (this violation resulted in the Division issuing the County a Notice of Violation). Chatham County, NPDE5 Permit NCO035866 November 8, 2019 Page 3 of 4 Findings during the inspection were as follows: 6. As required by the North Carolina Administrative Code T15A Subchapter 08G Section .0204, the ORC has maintained a daily log documenting the operation, maintenance, and visitation of the treatment system. 7. The laboratory at Bynum WWTP is field certified for the following parameters (certification number 5608): pH, temperature and total residual chlorine. Records of instrument calibration of the pH and total residual chlorine meters were documented and available for inspection. The pH calibration standards were within the expiration dates. The ORC uses the pH meter (Hach HQ 11 d) to measure temperature. The ORC stated the thermometer on the pH meter is checked periodically against an NIST certified thermometer located at the Chatham County WTP. Documentation of the thermometer calibration checks were not recorded in the County's analytical bench logbook. As required by T15A 02H .0805(g)(3), certified field laboratories shall record and document instrument calibrations. T15A 02H .0805(g)(9) requires a Reference Temperature -Measuring Device to meet NIST specifications or requires all non -Reference Temperature -Measuring Devices to be verified every twelve months against a Reference Temperature -Measuring Device. Please ensure the requirements of the above regulations are stet for the thermometer on the pH ureter. B. The inspector compared the April 2018 eDMR data against the ORC's bench lab data and analytical results from Environmental Conservation Laboratories, Inc (certification number 591). ENCO performs the analyses for all parameters except field parameters pH, temperature and total residual chlorine, which are analyzed onsite by the treatment plant operator. No discrepancies were noted. 9. The observed treatment units were as described in the subject NPDES permit. 10. The inspector noted the following observations of the treatment components: a) Preliminary Treatment. The manual bar screen was in operation and did not appear to have any issues that would affect proper operation. After drying, the screenings are disposed in an onsite container and taken to a landfill. The area around these units was clean and well maintained. b) Secondary Treatment. The 5-cell aeration basin was operational the day of the inspection. The inspector did not observe any dead spots within the system at the time of the inspection. There was less than 25% foam cover on the basins' surface and no dead zones. The two blower motors typically rotate operation every 30 minutes, but can run simultaneously if needed. The clarifier unit was operational. The weirs appeared level and appeared to have equal weir overflow rates. Some clumps of solids were observed in the clarifier trough. The ORC informed the inspector the clarifier is about 12-feet deep. The ORC measured the sludge depth of the clarifier at 6.5 feet. The sludge level within the clarifier should be maintained at less than 25% of the depth of the clarifier to help prevent washout of the solids. The County should take the necessary actions to significantly reduce the level of solids in the clarifier. c) Disinfection. The facility disinfects the treated wastewater prior to discharge using a tablet chlorination/dechlorination disinfection system. No issues of concern were observed with the disinfection system. Chatham County, NPDES Permit NCO035866 November 8, 2019 Page 4 of 4 d) Flow Measurement. The ultrasonic flow meter is calibrated quarterly and was last calibrated by Richard Brown, a private consultant, on August 7, 2019. Flow measuring devices are required to be calibrated at least annually and shall be capable of measuring flow with a maximum deviation of less than 10 percent from true discharge volumes. No issues of concern were observed with the flow measuring device. 11. The ORC informed the inspector that the effluent sample collection location for all parameters, except Total Residual Chlorine (TRC), has been from the chlorine contact chamber, prior to dechlorination. Samples collected for TRC analyses have been taken from a manhole after dechlorination treatment. As defined in North Carolina Administrative Code T15A 02B .0503(12), "Effluent means wastewater discharged following all treatment processes from a water pollution control facility..." Please ensure all effluent samples collected for self -monitoring are collected after all treatment, which is after the dechlorination treatment unit. 12.Out of safety concerns with collecting grab samples from the discharge outfall location at the Haw River, the operator collects grab samples from the manhole upstream of the discharge outfall pipe. The manhole is located after the dechlorination unit. 13. The right-of-way to the outfall was properly maintained. The inspector observed the effluent discharge to the Haw River via the outfall pipe to be clear with no observable solids or foam. No detrimental impacts to the Haw River from the effluent discharge were observed. Within 45-days receipt of this letter, please subunit a written response to this office indicating actions the County has taken or will take to comply with or resolve the issues noted in items 4, 7,10b, and 11 above. If you have questions or comments about the inspection, this report or the requirements to take corrective action (if applicable), please contact Vanessa Manuel at 919-791-4255 or via email at Vanessa. Manuel'dvncdenr. gov. Sincerely, S. Jay, #merman, F.G., Chief Water Quality Regional Operations Section Attachments: EPA Water Compliance Inspection Report Cc: RROISWP Files Wayme Marsh, ORC - via Laserfiche link Laserfiche Un tad =tato s Env r9nme-tal Protection Agarcy Form Approved, EPA Washinglor, 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/molday Inspection Type Inspector Fac Type 1 lu I 2 15 I 3 NC003sB66 Ill 12 19/10/31 17 18 I C I 19 I g j 201 I U U Ll L_! LJ 21 6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 81 OA Reserved 67 70 L( J { 71 Lj 72 (ti ( 731 I 174 75 80 LJ I I I Section 6: Facility Data Name and Location of Facility Inspected (For Industrial Users dts-harging to POTW, also include Entry Time/Date Permit Effective Date POTW name and NPDES permit Number) 10 05AM 19/10/31 17101/01 Bynum WWTP Exit TimelDate Permit Expiration Date 214 Bynum Church Rd Pittsboro NC 27312 12 35PM 19/10131 21/04130 Name(s) of Onsite Representahve(s)1Tides(s;-Phone and Fax N_mber(s) Other Facility Data X Wayme Andre Marshl0RCr919-542-82701 Name, Address of Responsible Ofricial/ritlelPhone and Fax Number Larry D Bridges PO Box 1809 Pittsboro NC 273121Public Utilities Contacted Director1919-542-82351 Yes Section C. Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement E Operations & Maintenance 0 Records/Reports Self -Monitoring Program Sludge Handling Disposal N Facility Site Review 0 Effluent/Receiving Waters Section D. Summary of Finding/Comments (Attach additional sheets of naratwe and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Vanessa E Manuel �J DWRIRRO WO1919-79142oo1 Signature of nage ent O A Reviewer AgencyfONicelPhone and Fax Numbers Date t r EPA�ojmh5f>b-3 (Rev 9.94) Previous editions are obsolete. Page# NPOES yrlmolday Inspection Type 3} NC0035866 1 12 is/ 0/31 17 IS ICI Section D. Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) See attached inspection report. Page# Permit NC0035a66 Owner - Facility: Bynum VVVWP Inspection pate: 10/31/2019 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 ❑ ❑ M ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? M ❑ ❑ ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The Permit re uires the oemnittee to submit discharge monitoring reports electroniall using_ the Division's eDMR system. The germittee has met this requirement beginning with the August 2016 DMR. Record Keening Yes No NA NE Are records kept and maintained as required by the permit? 0 ❑ ❑ ❑ Is all required information readily available, complete and current? M ❑ ❑ [] Are all records maintained for 3 years (lab. reg. required 5 years)? 0 ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? ❑ ❑ ❑ Is the chain -of -custody complete? ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWO? ❑ ❑ M ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24f7 with a certifed operator ❑ ❑ 0 ❑ 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 avaslable on site? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ M ❑ Comment. The ORC Wa me Marsh has a WW-2 certification and the Backup ORCs Ronnie Autry and Donnie Brafford each has a WW-1 certification. The Bynum WWTP is classified as a Grade II Biological Water Pollution Control Treatment System. Page# 3 Permic NCO035866 Owner-Faclfty BynumV*WP Inspection Date: 10131/2019 Inspection Type: Comp) ante Evaluation 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 .fudge, and other that are applicable? Comment: Bar Screens Type of bar screen Yes No NA NE a,Manual N b.Mechanical ❑ Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? N ❑ ❑ ❑ Is the unit in good condition? E ❑ ❑ ❑ Comment: Screenings are transferred to the dum ster after drying and trans orted to the landfill by a waste disposal company. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? N ❑ ❑ ❑ Are surface aerators and mixers operational? E ❑ ❑ ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? N ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? N ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mgll) , ❑ ❑ ❑ 0 Comment: The treatments stem consists of a 5-cell aeration basin with 2 blower motors. The blower motors !yRically rotate o eralion but can run simultaneously if needed. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? E ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ ❑ Are weirs level? ❑ ❑ ❑ Is the site free of weir blockage? E ❑ ❑ ❑ Is the site free of evidence of short-circuiting? N ❑ ❑ ❑ Page# 4 Permit: NCO035866 Owner - Facility: Bynum VwVTP Inspection Date: 1013112019 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is scum removal adequate? M❑ ❑ ❑ Is the site free of excessive floating sludge? M ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ ❑ Is the return rate acceptable (low turbulence)? ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? M ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately % of the sidewall depth) Cl M ❑ ❑ Comment: The inspector observed some solids in the clarifier weir. As measured by the ORC durin the inspection, the sludge depth was approximately 6.5 feet. The ORC stated the clarifier is approximately 12 -15 feet deep. Based on the level of sludge measured and the depth of the clarifier, the sludge blanket level is greater than 114 of the sidewall depth. The nermittee should take needed steps to reduce the volume of sludge in the clarifier. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? M El❑ ❑ Are the tablets the proper size and type? M ❑ ❑ [] Number of tubes in use? 2 Is the level of chlorine residual acceptable? ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ Comment: De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? 0 ❑ ❑ ❑ Is storage appropriate for cylinders? ❑ ❑ 0 ❑ # Is de -chlorination substance stored away from chlorine containers? 0 ❑ ❑ ❑ Comment: Are the tablets the proper size and type? 0 ❑ ❑ ❑ Are tablet de -chlorinators operational? M ❑ ❑ ❑ Number of tubes in use? 2 Comment: Standby Power Yes No NA NE Is automatically activated standby power available? M ❑ ❑ ❑ Page# 5 Permit NCO035866 Owner • Facility: Bynum VwVrP Inspection Date: 10/3112019 inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑ Is the generator tested under load? M ❑ ❑ ❑ Was generator tested & operational during the inspection? ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? M ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up power? ❑ ❑ ❑ Is the generator fuel level monitored? 0 ❑ ❑ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ M ❑ is sample collected below all treatment units? ❑ E ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ 0 ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type M ❑ ❑ ❑ representative)? Comment: The effluent sample collection location for all parameters. except Total Residual Chlorine TRC has been from the chlorine contact chamber, rior to dechlorination. Samples collected for TRC analysis has been taken from a manhole after dechlorination treatment. As defined in North Carolina Administrative Code T15A 0213,0503 12 "Effluent means wastewater discharcied following all treatment Processes from a water Pollution control facility..." Please ensure all effluent samples collected for self -monitoring and reporting are collected after all treatment which is the dechlorination treatment unit. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ ❑ ❑ Is flow meter calibrated annually? ❑ ❑ ❑ Is the flow meter operational? ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? M ❑ ❑ ❑ Comment: The flow meter is calibrated quarterly and was last calibrated on Au ust 7 2019 by Richard Brown a private consultant. Effluent Pie Yes No NA NE Is right of way to the outfall properly maintained? M ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? N ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ❑ Page# 6 Permit: NC0035866 Owner -Fact ty: Bynum WWrP Inspection Date: 10l3 /2019 Inspection Type: Compliance Evaluatran Effluent Pipe Yes No NA NE Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? ❑ ❑ ❑ Is the mixing adequate? ❑ ❑ ❑ Is the site free of excessive foaming in the tank? M❑ Cl M # Is the odor acceptable? M Cl 11 ❑ # Is tankage available for properly waste sludge? 0 Cl El 0 Comment: Sludge is hauled by Clark Septic_ Frequency of slud a hauling is approximately once per quarter. Chemical Feed Yes No NA NE Is containment adequate7 M ❑ ❑ Is storage adequate? . Are backup pumps available? Is the site free of excessive leaking? M Comment: Sodium Hydroxide is used for DH control and is added to the influent waste stream prior to the bar screen. PAYS-, 7