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HomeMy WebLinkAboutWQ0033406_CEI & NOV-2020-PC-0022_20200109ROY COOPER Governor MICHAEL S. REGAN Secretory LINDA CULPEPPER Director NORTH CAROLINA Environmental Quality January 9, 2020 CERTIFIED MAIL 7017 2680 0000 2235 8755 RETURN RECEIPT REQUESTED Dr. Phillip Price VP of Administrative Services Chatham County and Central Carolina Community College 1105 Kelly Drive Sanford, NC 27330 Subject: NOTICE OF VIOLATION NOV-2020-PC-0022 Compliance Evaluation Inspection Central Carolina Community College Reclaimed Water Generation & Conjunctive Water Utilization System Permit Number WQ0033406 Chatham County Dr. Price, On January 8, 2020 Rick Trone of the Raleigh Regional Office conducted a compliance evaluation inspection of the reclaimed water generation and conjunctive water utilization system located at Central Carolina Community College. The current permit allows for the facility to generate reclaimed water to be used for drip irrigation on 0.30 acres with the remaining to be used for toilet flushing. Additionally, the system is designed so that wastewater from the school can instead be diverted to the sanitary sewer system. The purpose of this inspection was to ensure compliance with the subject permit. During the inspection, the cooperation of Mr. Ronnie Measamer, Mr. Darren Fincher, and John Poteat, ORC was helpful and appreciated. This compliance evaluation inspection consisted of the following: • Review of the permit; • Review of the owner/facility information; • Review of calibration documentation, Non -discharge wastewater monitoring reports (NDMR), employee education program, Operation and Maintenance plan, and; • On -site inspection of treatment and storage components The current permit was issued February 16, 2017 and expires on January 31, 2022. North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional office 1 3800 Barrett Drive I Raleigh, North Carolina 27609 ++�\ 919.791,4200 The reclaimed water generation system at Central Carolina Community College is currently not operational and has not been for quite some time. Mr. Measamer explained that a pipe is broken in the lower dosing tank. The College has paid for a contractor to examine the issue and it was explained that the contractor was not able to fix the issue. The design of the system allows for the schools' wastewater to be sent to the sanitary sewer after the septic tank, which is how the school currently disposes of its wastewater. Therefore, at this time, the system is not generating any reuse water and all water used in the toilets is city water. The other components of the system appear to be well maintained. Components of the reclaimed system were properly color -coded and marked for identification. The facility does not have an Operation and Maintenance Plan. This violation was also noted in a Notice of Violation issued in February 2016. The facility does not provide notification to employees regarding the use of reclaimed water nor does the facility appear to have any training program as required by the current permit. The school has a contractor, Aqualine, calibrate meters on a regular basis. The latest calibration was in December 2019, but documents provided for review indicate the turbidimeter was not calibrated because the reclaimed water generation system is not in use. This meter should be calibrated on an annual basis and must be calibrated prior to bringing the reuse generation system back into operation. Effluent sampling for BOD, Fecal Coliform, Ammonia Total Nitrogen (as N), Total Suspended Solids, and Turbidity is not taking place. Because the reclaimed water generation system is inoperative, sampling of generated reclaimed water is impossible. The ORC has failed to indicate on form NDMR as to why sampling of these parameters is not occurring. The facility however, is reporting values for pH and Total Residual Chlorine. When asked how it was possible to sample for pH and TRC, the ORC indicated that he was taking samples of the potable city water being used in the toilets. This is of course not correct or representative of sampling reuse water. Because the system is not in operation and there is no effluent to sample, no monitoring results should be reported on form NDMR, including Flow. If no reclaimed water is generated, indicate "No Flow" on form NDMR. The facility is reporting PPI02 (Reclaimed Water Distributed for Conjunctive Utilization) on form NDAR-I. This is incorrect according to the footnote in Attachment B of the current permit. This PPI is an estimate of reclaimed water used for drip irrigation and toilet flushing. PPI02 should be reported on a separate NDMR than that of PPI01. If no reclaimed water is utilized, indicate "No Flow" on form NDMR. The following permit condition violations were noted during the January 8, 2020 compliance inspection and records review: III.Oneration and Maintenance Reauirements Condition 1 which states that, "The reclaimed water generation and utilization facilities shall be properly maintained and operated at all times." Please explain in detail how the non -discharge system came to be inoperative, all actions taken to correct the problem, and when the facility plans to restore the system to operating condition. If the facility intends to never use the system and cannot adequately maintain it, rescinding the permit may be one possible option to discuss with this office. Condition 2, which states that, "The Permittee shall maintain and Operation and Maintenance Plan..." it was noted on a previous inspection that the facility did not have an Operation and Maintenance Plan for the non -discharge system. Please explain why the school still lacks this required Plan and please provide a copy of the Plan to this office when one is created. Condition 2 under Operation and Maintenance Requirements lists the required components of an O&M plan. Condition 15, which states that, "The Permittee shall develop and implement an education program to inform users (including employees) about the proper use of reclaimed water" The facility did not appear to have an education program as required. In your response, please explain why no such program exists and explain how and when this requirement will be met when the facility is once again generating reclaimed water. Condition 17, which states that, "The Permittee shall develop and maintain a training and certification program about the use of reclaimed water for toilet flushing for maintenance employees and appropriate contracted personnel who will be involved in plumbing repairs." The facility did not appear to have a training and certification program as required. In your response, please explain why no such program exists and explain how and when this requirement will be met when the facility is once again generating reclaimed water. IV. Monitoring and Reporting Requirements Condition 4, which states that, "The Permittee shall monitor the reclaimed water from the generating facility at the frequencies and locations for the parameters specified in Attachment A." This office understands the reclaimed water generation system is not in operation, however, upon which time the system becomes operational, please ensure the facility reports BOD, Fecal Coliform, Nitrogen Ammonia, pH, Flow, Turbidity, Total Residual Chlorine, and Total Suspended Solids for PPI 01 on form NDMR. On a sesarate NDMR, the facility should report `No Flow' for PPI 02 if no reclaimed water is being utilized. When, and if, the facility resumes generating reclaimed water, the facility must sample for the parameters in Attachment A and report these results on form NDMR. A separate NDMR form for reclaimed water distributed should be submitted with nothing more than an estimate of reclaimed water distributed. Even though the system is not in operation, the facility is still required to submit a NDMR form for each PPI with the box for `No Flow' checked. The ORC should indicate in detail on form NDMR as to why monitorina is not beine conducted. Please also ensure the forms are si ned by both the ORC and the Permittee. Currently, these forms are being submitted without the Permittee's sienature. Please respond in writing to this office within 30days upon your receipt of this Notice of Violation regarding your plans or measures to be taken to address the indicated violations and other identified issues, if applicable. Please include in your response all corrective actions already taken and a schedule for completion of any corrective actions not addressed. It should be noted that the facility should not use, or attempt to use, the system until such time as all needed repairs are made. Please inform the Raleigh Regional Office at the number below prior to restarting the reclaimed generation system. If you have any questions about this inspection or this letter, please contact Rick Trone at rick.trone(&ncdenr.gav or 919-791-4200. Sincerely, mw Scott Vinson, Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Attachments: EPA Water Compliance Inspection Report cc: Central Files Laserfche RRO Files Compliance Inspection Report Permit: W00033406 Effective: 02/16/17 Expiration: OV31122 Owner: Central Carolina Community College SOC: Effective: Expiration: Facility: Central Carolina Community College County: Chatham 764 West St Region: Raleigh Pittsboro NC 27312 Contact Person: Matthew Garrett Title: Phone: 919-542-8200 Directions to Facility: System Classifications: WW1, Primary ORC: Secondary QRC(s): On -Site Representative(s): Related Permits: NC0020354 Town of Pittsboro - Pittsboro WWTP Inspection Date: 01/08/2020 EntryTime: 10:OOAM Primary Inspector: Rick V Trone Secondary Inspector(s): Certification: Phone! Exit Time: 11:15AM Phone: 919-79142OU Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Reclaimed Water Facility Status: ❑ Compl:anl Not Compliant Question Areas: Miscellaneous Questions Treatment Treatment Filters Record Keeping Treatment Disinfection End Use -Reuse (See attachment summary) Page 1 of 6 permit: W00033406 owner - Facility: Central Carolina Community College Inspection Date: 01108/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: On January 8, 2020 Rick Trone of the Raleigh Regional Office conducted a compliance evaluation inspection of the reclaimed water generation and conjunctive water utilization system located at Central Carolina Community College. The current permit allows for the facility to generate reclaimed water to be used for drip irrigation on 0.30 acres with the remaining to be used for toilet flushing. Additionally, the system is designed so that wastewater from the school can instead be diverted to the sanitary sewer system. The purpose of this inspection was to ensure compliance with the subject permit. During the inspection, the cooperation of Mr. Ronnie Measamer, Mr. Darren Fincher, and John Poteat, ORC was helpful and appreciated. This compliance evaluation inspection consisted of the following: -Review of the permit; -Review of the owner/facility information; -Review of calibration documentation, Non -discharge wastewater monitoring reports (NDMR), employee education program, Operation and Maintenance plan, and; -On-site inspection of treatment and storage components The current permit was issued February 16, 2017 and expires on January 31, 2022. The reclaimed water generation system at Central Carolina Community College is currently not operational and has not been for quite some time. Mr. Measamer explained that a pipe is broken in the lower dosing tank. The College has paid for a contractor to examine the issue and it was explained that the contractor was not able to fix the issue. The design of the system allows for the schools' wastewater to be sent to the sanitary sewer after the septic tank, which is how the school currently disposes of its wastewater. Therefore, at this time, the system is not generating any reuse water and all water used in the toilets is city water. The other components of the system appear to be well maintained. Components of the reclaimed system were properly color -coded and marked for identification. The facility does not have an Operation and Maintenance Plan. This violation was also noted in a Notice of Violation issued in February 2016. The facility does not provide notification to employees regarding the use of reclaimed water nor does the facility appear to have any training program as required by the current permit. The school has a contractor, Aqualine, calibrate meters on a regular basis. The latest calibration was in December 2019, but documents provided for review indicate the turbidimeter was not calibrated because the reclaimed water generation system is not in use. This meter should be calibrated on an annual basis and must be calibrated prior to bringing the reuse generation system back into operation. Effluent sampling for SOD, Fecal Coliform, Ammonia Total Nitrogen (as N), Total Suspended Solids, and Turbidity is not taking place. Because the reclaimed water generation system is inoperative, sampling of generated reclaimed water is impossible. The ORC has failed to indicate on form NDMR as to why sampling of these parameters is not occurring. The facility however, Is reporting values for pH and Total Residual Chlorine. When asked how it was possible to sample for pH and TRC, the ORC indicated that he was taking samples of the potable city water being used in the toilets. This is of course not correct or representative of sampling reuse water. Because the system is not in operation and there is no effluent to sample, no monitoring results should be reported on form NDMR, including Flow. If no reclaimed water is generated, indicate "No Flow" on form NDMR. The facility is reporting PPI02 (Reclaimed Water Distributed for Conjunctive Utilization) on form NDAR-1, This is incorrect according to the footnote in Attachment B of the current permit. This PPI is an estimate of reclaimed water used for drip irrigation and toilet flushing. PPI02 should be reported on a separate NDMR than that of PPI01. If no reclaimed water is utilized, Indicate "No Flow" on form NDMR. The following permit condition violations were noted during the January 8, 2020 compliance inspection and records review: III. Operation and Maintenance Requirements Condition 1 which states that, "The reclaimed water generation and utilization facilities shall be properly maintained and operated at all times." Please explain in detail how the non -discharge system came to be inoperative, all actions taken to correct the problem, and when the facility plans to restore the system to operating condition. If the facility intends to never Page 2 of 6 Permit: W00033406 Owner - Facility: Central Carolina Community College Inspection Date: 01/08/2020 Inspection Type • Compliance Evaluation Reason for Visit: Routine use the system and cannot adequately maintain it, rescinding the permit may be one possible option to discuss with this office. Condition 2, which states that, "The Permitee shall maintain and Operation and Maintenance Plan..." it was noted on a previous inspection that the facility did not have an Operation and Maintenance Plan for the non -discharge system. Please explain why the school still lacks this required Plan and please provide a copy of the Plan to this office when one is created, Condition 2 under Operation and Maintenance Requirements lists the required components of an O&M plan. Condition 15, which slates that. "The Permiltee shall develop and implement an education program to inform users (including employees) about the proper use of reclaimed water" The facility did not appear to have an education program as required. In your response, please explain why no such program exists and explain how and when this requirement will be met when the facility is once again generating reclaimed water. Condition 17, which states that, "The Permiltee shall develop and maintain a training and certification program about the use of reclaimed water for toilet flushing for maintenance employees and appropriate contracted personnel who will be involved in plumbing repairs." The facility did not appear to have a training and certification program as required. In your response, please explain why no such program exists and explain how and when this requirement will be met when the facility is once again generating reclaimed water. IV. Monitoring and Reporting Requirements Condition 4, which states that, "The Permiltee shall monitor the reclaimed water from the generating facility at the frequencies and locations for the parameters specified in Attachment A." This office understands the reclaimed water generation system is not in operation, however, upon which time the system becomes operational, please ensure the facility reports BOO, Fecal Coliform, Nitrogen Ammonia, pH, Flow, Turbidity, Total Residual Chlorine, and Total Suspended Solids for PPI 01 on form NDMR. On a separate NDMR, the facility should report'No Flaw' for PPI 02 if no reclaimed water is being utilized. When, and if, the facility resumes generating reclaimed water, the facility must sample for the parameters in Attachment A and report these results on form NDMR. A separate NDMR form for reclaimed water distributed should be submitted with nothing more than an estimate of reclaimed water distributed. Even though the system is not in operation, the facility is still required to submit a NDMR form for each PPI with the box for'No Flow' checked. The ORC should indicate, in detail, on form NDMR as to why monitoring is not being conducted. Please also ensure the forms are signed by both the ORC and the Permiltee. Currently, these forms are being submitted without the Permittee's signature. Page 3 of 6 permit: W00033406 Owner - Faculty: Central Carolina Community College Inspection Date.• 01/08/2020 Inspection Type : Compliance Evaluation Reason for Visit: Rout ne Type Yes No NA NE Infiltration System ❑ Lagoon Spray. LR ❑ Reuse (Quality) ❑ Activated Sludge Spray, LR ❑ Single Family Spray, LR ❑ Activated Sludge Drip, LR ❑ Activated Sludge Spray, HR ❑ Single Fam'ly Drip ❑ RecyclelReuse ❑ Treatment Yes No NA NE Are Treatment facilities consistent with those outlined in the current permit? M ❑ ❑ ❑ Do all treatment units appear to be operational? (if no, note below.) 0000 Comment: A pipe is broken in the lower dosinci tank. All wastewater enerated by the school is diverted to the sanitary sewer. Treatment Filters Yes No NA NE Is the filter media present? 0 ❑ ❑ ❑ Is the filter media the correct size and type? N ❑ ❑ ❑ Is the air scour operational? ❑ ❑ 0 ❑ Is the scouring acceptable? ❑ ❑ M ❑ Is the clear well free of excessive solids? ❑ ❑ 0 ❑ Is the mud well free of excessive solids and filter media? ❑ ❑ M ❑ Does backwashing frequency appear adequate? ❑ ❑ M ❑ Comment: Treatment Dislnfectlon Yes No NA NE Is the system working? ❑ ❑ ❑ 0 Do the fecal coliform results Indicate proper disinfection? ❑ ❑ ❑ M Is there adequate detention time (>=30 minutes)? ❑ ❑ ❑ 0 Is the system property maintained? ❑ M ❑ ❑ If gas, does the cylinder storage appear safe? ❑ ❑ 0 ❑ Is the fan in the chlorine feed room and storage area operable? ❑ ❑ 0 ❑ Is the chlorinator accessible? ❑ ❑ 0 ❑ If tablets, are tablets present? ❑ ❑ 0 ❑ Are the tablets the proper size and type? ❑ ❑ 0 ❑ Is contact chamber free of sludge, solids, and growth? M ❑ ❑ ❑ Page 4 of 6 permit: WC10033406 Owner - Facility: Central Carolina Community College Inspection pate: 01/08/2020 Inspection Type: Compliance Evaluation Reason for Visit: Routine If UV, are extra UV bulbs available? 0 0 If UV, is the UV Intensity adequate? 110 00 # Is it a dual feed system? No00 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? Comment: System Is not operational. Record Keeping Yes No NA NE Is a copy of current permit available? 00 ❑ Are monitoring reports present: NDMR7 0❑ 00 NDAR? 0 ❑ 0 ❑ Are flow rates less than of permitted flow? ■ Are flow rates less than of permitted Row? Are application rates adhered to? 0 13 0 0 Is GW monitoring being conducted, if required (GW-59s submitted)? Are all samples analyzed for all required parameters? El 0 0 ❑ Are there any 2L GW quality violations? Is GW-59A certificalion form completed for facility? Is effluent sampled for same parameters as GW? Do effluent concentrations exceed GW standards? 0 Are annual soil reports available? 0 0■ ri # Are PAN records required? # Did last soil report indicate a need for lime? 0 If so, has it been applied? 0 0s Are operational logs present? 0 E00 Are lab sheets available for review? ❑ 0 0 ❑ Do lab sheets support data reported on NDMR? ❑ 0 Do lab sheets support data reported on GW-59s? 0 00 Are Operational and Maintenance records present? El ■ Were Operational and Maintenance records complete? ❑ . ❑ ❑ Has permittee been free of public complaints in last 12 months? 0 ❑ ❑ Is a copy of the SOC readily available? 0 ClM No treatment units bypassed since last inspection? ❑ Comment: System is not operational and no samples have been taken no effluent generated). Facility lacks an O&M plan. Page 5 of 6 Permit' WQ003W6 Owner - Facility: Central Carolina Community College Inspection Date: O1r0812020 Inspection Type: Compliance Evaluation Reason for Visit: Routine End Use -Reuse You No NA NE Is the acreage in the permit being utilized? ❑ 0 ❑ ❑ Does the acreage specified :n the permit correspond to the measured acreage at the site? ❑ ❑ M ❑ Are all essential units provided in duplicate? ❑ ❑ M ❑ Is an automatically activated standby power source available? ❑ ❑ M ❑ Is the equalization capacity adequate? ❑ ❑ M ❑ Is aerated flow equalization present? ❑ ❑ M ❑ Has the turbidity meter been calibrated in the last 12 months? ❑ M ❑ ❑ Does the turbidity meter have recording capabilities? ❑ ❑ ❑ N Is all flow diverted at the appropriate times? ❑ ❑ 0 ❑ Is all upset wastewater diverted from reuse storage unit? 0 ❑ ❑ ❑ Is all upset wastewater treated, retreated, or disposed of acceptably? M ❑ ❑ ❑ Is upset wastewater treated prior to discharge to irrigation storage? ❑ ❑ M ❑ Is public access restricted from irrigation area during active site use? ❑ ❑ 0 ❑ If golf course, is a sign posted in plain sight on the club house? ❑ ❑ N ❑ Is the cover crop acceptable? M ❑ ❑ ❑ Are buffers adequate? ■ ❑ ❑ ❑ Is the site tree of pondinglrunoff? N ❑ ❑ ❑ Is the acreage in the permit being utilized? ❑ 0 ❑ ❑ Is the application equipment acceptable? ❑ ❑ ❑ Is the application area free of limiting slopes? M ❑ ❑ ❑ How close is the closest water supply well? ❑ ❑ ❑ 0 Are any supply wells within the CB? ❑ ❑ ❑ ■ Are any supply wells within 250' of the CB? ❑ ❑ ❑ 0 Is municipal water available in the area? N ❑ ❑ ❑ Are GW monitoring wells required? ❑ ❑ 0 ❑ Are GW monitoring wells located properly wt respect to RB and CB? ❑ ❑ 0 ❑ Are GW monitoring wells properly constructed, including screened interval? ❑ ❑ 0 ❑ Comment: System is not being used Page 6 of 6