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Home My WebLink AboutNC0044423_Compliance Evaluation Inspection_20200121ROY COOPER Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Director n� NORTH CAROLINA Envi--tal Quality CERTIFIED MAIL 7017-1450-0001-6450-0696 RETURN RECEIPT REQUESTED January 21, 2020 Mr. Patrick Brittain Appalachian State University 438 Academy St Boone, NC 28608 SUBJECT: Notice of Deficiency: Compliance Evaluation Inspection NOD-2020-PC-0011 Appalachian State WTP NPDES Permit No. NCO044423 Watauga County Dear Mr. Brittain, On January 8, 2020, Kelli Park, Jenny Graznak, and myself met with you and Jeremy Johnson, operator in responsible charge (ORC), to perform a compliance evaluation inspection on the Appalachian State University (ASU) water treatment system. 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 notes the areas that were evaluated for this inspection. Deficiencies and concerns noted during the inspection are outlined below: 1. It was determined during the inspection that your facility does not hold a Field Parameter Certification. You are required to complete the certification process as soon as possible. You can find information regarding this here: https://deq.nc.gov/about/divisions/water-resources/water-resources-data/water- sciences-home-page/laboratory-certification-branch/field-lab-certification 2. It was determined during a pre -inspection file review that your facility is not using eDMR as is currently required by our Division. We understand that you are in the process of completing this task. 3. Ms. Park observed during the inspection that the pH 10 standards were expired as of February 2019. Please obtain and use current standards. These issues represent deficiencies of the facility's NPDES permit. Thus, this letter is being sent to you as a Notice of Deficiency. Please reply in writing to this letter within 10 calendar days of its receipt. Your written reply should address each of the noted deficiencies 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 you have any questions regarding the inspection or this report, please contact Ms. Park or me at (336) 776-9800 or by email at kelli.park(a)_ncdenr.gov or Ion. snider(a)_ncdenr.gov. Sincerely, EDocu SiTgnedl�by: l��. l 145B49FKK94EA... Lon Snider Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report CC' WSRO Laserfiche Files Jeremy Johnson, ORC, via email 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 I 2 IF I 3 I NC0044423 111 12 I 20/01/09 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 I� 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 20/01/09 17/04/01 Appalachian State WTP Physical Plant Division Exit Time/Date Permit Expiration Date Boone INC 28608 12:OOPM 20/01/09 21/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Jeremy Allen Johnson/ORC/828-262-3197/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Larry Bordeaux,265 Dale St Boone NC 28608/Director/828-262-3190/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program 0 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 DocuSigned by: DWR/WSRO WQ/336-776-9689/ E: PA4 1/21/2020 DCE74C34139_. Signature of Management Q A Reviewer ocuSigned by: Agency/Office/Phone and Fax Numbers Date Lon T. Snider -r Snider 1/21/2020 7L- EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO044423 I11 121 20/01/09 117 18 ICI Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On January 8, 2020, Kelli Park, Jenny Graznak, and myself met with you and Jeremy Johnson, operator in responsible charge (ORC), to perform a compliance evaluation inspection on the Appalachian State University (ASU) water treatment system. 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 notes the areas that were evaluated for this inspection. Deficiencies and concerns noted during the inspection are outlined below: 1. It was determined during the inspection that your facility does not hold a Field Parameter Certification. You are required to complete the certification process as soon as possible. You can find information regarding this here: https:Hdeq. nc.gov/abouVdivisions/water-resources/water-resources-data/water-sciences-home-page/I aboratory-certification-branch/field-lab-certification 2. It was determined during a pre -inspection file review that your facility is not using eDMR as is currently required by our Division. We understand that you are in the process of completing this task. 3. Ms. Park observed during the inspection that the pH 10 standards were expired as of February 2019. Please obtain and use current standards. These issues represent deficiencies of the facility's NPDES permit. Thus, this letter is being sent to you as a Notice of Deficiency. Please reply in writing to this letter within 10 calendar days of its receipt. Your written reply should address each of the noted deficiencies 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 you have any questions regarding the inspection or this report, please contact Ms. Park or me at (336) 776-9800 or by email at kelli.park@ncdenr.gov or Ion.snider@ncdenr.gov. Page# Permit: NCO044423 Owner - Facility: Appalachian State WTP Inspection Date: 01/09/2020 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: NCO044423 Owner - Facility: Appalachian State WTP Inspection Date: 01/09/2020 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: ORC and BORC are both PC1 eDMR has not been used by this plant, however steps are being made towards getting set up and utilizing eDMR in the near future. 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 ❑ ❑ ❑ 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)? ❑ ❑ 0 ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/ of the sidewall depth) 0 ❑ ❑ ❑ Comment: Water in the clarifier was very turbid at the time of inspection. 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: effluent flow is estimated usina a aeneral flow meter within the plant that measures the inflow and backwash. Flow is recorded and maintained on the SCADA system. 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: Page# 4 Permit: NCO044423 Owner - Facility: Appalachian State WTP Inspection Date: 01/09/2020 Inspection Type: Compliance Evaluation 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 0 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? 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? ❑ ❑ ❑ # Is the facility using a contract lab? ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ ❑ ❑ 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: Field parameters have been performed and recorded without proper lab certification. A field parameter certification must be obtained immediately. The pH 10 standards were expired (2/2019). Water Quality Labs is used for analyses other than field parameters. ETS is used for toxicity. Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Comment: The generator is tested every Monday. Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 5 Permit: NC0044423 Owner - Facility: Inspection Date: 01/09/2020 Inspection Type: Appalachian State WTP Compliance Evaluation De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ Is storage appropriate for cylinders? M ❑ ❑ ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Comment: Chlorine is not added. Are tablet de -chlorinators operational? 0 ❑ ❑ ❑ Number of tubes in use? 4 Comment: Dechlorination only occurs 3 or 4 times a Vear. The residual chlorine is continually monitored, and dechlorination is only used when the level of residual is too high to be discharged. Page# 6