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Home My WebLink AboutNC0082949_Compliance Evaluation Inspection_20191204ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality Certified Mail # 70171450 0001 6450 1129 Return Receipt Requested December 4, 2019 Mr. Kenneth Gamble, Town Manager Town of Denton PO Box 306 Denton, NC 27239 Subject: Compliance Evaluation Inspection Report Notice of Violation & Intent to Issue Civil Penalty Denton Water Treatment Plant Wastewater Discharge NPDES Permit # NCO082949 Davidson County Dear Mr. Gamble: On November 6, 2019, Paul DiMatteo of the Division of Water Resources (Division), Winston- Salem Regional Office met with Heather Hicks, Operator in Responsible Charge (ORC), Troy Branch, Backup ORC, and you to conduct a Compliance Evaluation Inspection at the above referenced wastewater discharge facility. The inspection was prompted by an in -office review of submitted Discharge Monitoring Reports (DMRs) which appeared to be missing data. The primary purpose of the inspection was to review DMR and self -monitoring data. Summary of Non -Compliance The facility inspection and subsequent file review revealed the following monitoring and reporting violations from January 2016 through September 2019. 1. Effluent Limitations and Monitoring Requirements — Part I, Condition A.1 of the Permit requires the discharged effluent to be limited and monitored as stated in that Condition. a. Total Aluminum and Total Manganese not reported in 20 of the reviewed months. The Permit requires these parameters to be monitored monthly. b. Total Fluoride, Total Zinc, Total Copper and Total Iron not reported in 2 of the reviewed quarters. The Permit requires these parameters to be monitored quarterly. c. The Permit defines the measurement frequency "2/month" as "Samples are collected twice per month with at least ten calendar days between sampling events. [... ]". Improper separation between twice monthly sampling events was identified in 6 months of data. D North Carolina Department of Environmental Quality I Division of Water Resources EQ�p Winston-Salem Regional Office 1 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 NORTH CAROLINA � o•o•°"•mme""°"^•"vin"•i� /� 336.776.9800 d. The Permit requires quarterly metals (Fluoride, Copper, Zinc, and Iron) to be "collected concurrently with WET -test samples." Metals were not collected concurrently with WET samples in at least 5 quarters. 2. Reporting Requirements — Part II, Condition E.5 of the Permit requires that "(a). Monitoring results must be reported on a Discharge Monitoring Report (DMR)..." and that "(b). If the Permittee monitors any pollutant more frequently than required by this permit [... ], the results of such monitoring shall be included in the calculation and reporting of the data submitted on the DMR." a. Total Nitrogen (including Total Kjeldahl Nitrogen and NO2+NO3) and Total Phosphorus samples were analyzed but not reported in 36 separate instances. b. All quarterly metals were analyzed but not reported in 3 quarters c. Aluminum and manganese were analyzed but not reported in 5 months. d. Incorrect results were recorded in 7 instances. It was noted that in no case would the correct result have resulted in a violation of effluent limitations. 3. Missing Lab Data — Data was reported on the DMR without the accompanying laboratory data being provided during the review process for December 20, 2016 and November 9, 2017. Please note the following permit conditions: a. Records Retention — Part II, Condition D.5 requires that all monitoring information except sludge use and disposal be maintained for at least 3 years. b. Duty to Provide Information — Part II, Condition B.8 requires that the Permittee shall provide copies of records required by the Permit upon request. c. Falsification of Reports — Part II, Condition E.I I provides significant penalties for knowingly falsifying records or statements in relation to the Permit. Requested Response This Notice of Violation / Notice of Intent to Enforce (NOV/NOI) is being issued for the noted violations. Pursuant to G.S. 143 215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143 215.1. This office requests that you respond to this Notice, in writing, within 10 business days of its receipt. In your response, you should address the causes of non-compliance, remedial actions, and all other actions taken to prevent the recurrence of similar situations. The response to this correspondence will be considered in the enforcement process. If you have any questions concerning this report, please contact Paul DiMatteo at (336) 776-9691 or me at (336) 776-9800. Sincerely, cuSigned by: [�_"4 z SmJtr 9E22¢5 4EA... Lon T. Smder, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures — Inspection Report CC: WSRO Laserfiche Files 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 I 2 IF I 3 I NCO082949 111 12 I 19/11/06 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 131 QA ---------------------- Reserved ------------------- 671 70 I I 71 I I 72 I r I u I� 73 I I 174 751 I I I I I I I80 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) 10:30AM 19/11/06 14/05/01 Denton WTP 3049 Bringle Ferry Rd Exit Time/Date Permit Expiration Date Denton NC 27239 12:30PM 19/11/06 19/01/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Heather Hicks/ORC/336-859-3139/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Angel Jenkins,201 W Salisbury St Denton NC 27239//336-859-4231/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Records/Reports 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 Paul DiMatteo DocuSigned by: DWR/WSRO WQ/336-776-9691/ 4L 12/4/2019 F10C7C2E5BB34D4... Signature of Management Q A Reviewe by: Agency/Office/Phone and Fax Numbers Date Lcued S'ac, 12/4/2019 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO082949 I11 121 19/11/06 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCO082949 Owner - Facility: Denton WTP Inspection Date: 11/06/2019 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: 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 CM 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? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ Comment: Some DMR data was missing. Page# 3