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HomeMy WebLinkAboutNC0020737_Compliance_20200212ROY COOPER Govffn r MICHAEL S. REGAN Smwary S. DANIEL SMITH Dome ar FORTH CAROLINA Envimnmerrtaf Quality CERTIFIED MAIL # 7018 0360 0002 2099 1550 RETURN RECEIPT REQUESTED February 12, 2020 Mr. Ricky Duncan, Water Resources Director City of Kings Mountain P.O. Box 429 Kings Mountain, NC28086 Subject: Notice of Violation Compliance Evaluation Inspection NOV-2020-PC-0087 City of Kings Mountain NPDES Permit No. NCO020737 Cleveland County Dear Mr. Duncan: Enclosed is a copy of the Compliance Evaluation Inspection report for the inspection conducted at the subject facility on January 28, 2020 by Ori Tuvia. The cooperation of Richelle Meek and Kathy Moses during the site visit was much appreciated. Please advise the staff involved with this NPDES Permit by forwarding a copy of the enclosed report. Overall, the site is much improved. Previously noted lab issues had been addressed as well as the short-circuiting observed in clarifier #4 due to an uneven weir. The purchase of new SCADA system is also a welcomed forward step. The following areas of concern noted in prior inspection reports require your attention: 1. The weir in clarifier #3 showed signs of rusting. The ORC did indicate that the coming year's budget will include resources to repair the clarifier. 2. Dead spots were observed in all three (3) aeration basins, especially in aeration basin #1. Mixers, in addition to the existing diffusers, would potentially eliminate the observed dead spots. A plan to improve aeration and eliminate the dead spots is needed. ef5:fDEQ2�XzN State of North Carolina I Environmental Quality I Water Resources I Water Quality Regional Operations Mooresville Regional Office 1 610 East Center Avenue, Suite 3011 Mooresville, North Carolina 28115 704 663 1699 An additional concern observed during the inspection was that grit was observed in downstream treatment units including the chlorine contact chamber. A grit removal system would greatly improve treatment efficiency and significantly reduce the accumulation of grit in other treatment units. The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at ori.tuviagncdenr. gov. Sincerely, DocuSigned by: A14CC681 AF27425... W. Corey Basinger Regional Supervisor Mooresville Regional Office Division of Water Resources cc: NPDES, MRO files (Laserfiche) 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 2 15 1 3 I NCO020737 111 12 I 20/01/28 I17 18 I S I 19 I G I 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 ------------------- 67 1.0 70 71 [„ I 72 n 73 L_LJ74 751 u I I I I I I I80 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) 09:55AM 20/01/28 15/06/01 Pilot Creek WWTP 200 Potts Creek Rd Exit Time/Date Permit Expiration Date Kings Mountain NC 28086 11:40AM 20/01/28 18/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Kendrene Richelle Meek/ORC/704-739-7131/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Kim Teresa Moss,PO Box 429 Kings Mountain NC 280860429//704-739-7131/7047344528 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 DocuSigned by: Ori A Tuvia ----_- DWR/MRO WQ/704-663-1699/ 2/12/2020 ERR-057A?DF-017498 Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger DWR/Division of Water Quality/704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuSigned by: 2/12/2020 A14CC681 AF27425... Page# NPDES yr/mo/day Inspection Type NCO020737 I11 121 20/01/28 117 18 I C Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCO020737 Owner - Facility: Pilot Creek WWTP Inspection Date: 01/28/2020 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: New tiered Dermit was issued and became effective on 2/1/2020. The new Dermit has removed the Arsenic limit for the tiers under 6 MGD. The City implements an approved Industrial Pretreatment Program.The Division received a SOC application from the City on 12/29/15 due to the WWTP's inability to comply with the effluent thallium limits placed in the current permit (effective 6/1/15). SOC became effective July 18, 2016, removing the daily maximum limit for Thallium sampling and increasing the monthly average to 60.1 ug/L. 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? ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ Page# 3 Permit: NCO020737 Inspection Date: 01/28/2020 Record Keeping Owner - Facility: Pilot Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The records reviewed during the inspection were organized and well maintained. DMRs, COCs, ORC visitation log, Bench sheets, and calibration logs were reviewed for the period October 2019 through December 2019. 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? 0 ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? M ❑ ❑ ❑ Comment: Influent and effluent analyses are performed under the City's certified laboratory #222. Shealy Labs (metals, priority pollutants, total phosphorus, total nitrogen, oil & -grease, Thallium), and ETT, Inc.(toxicity) have also been contracted to provide analytical support. 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)? Is sampling performed according to the permit? 0 ❑ ❑ ❑ Comment: The subject permit requires influent composite BOD and TSS samples. The facility staff perform and document monthly aliquot verifications. Influent pH levels are continuously monitored by an in -line monitoring system. 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)? Page# 4 Permit: NCO020737 Inspection Date: 01/28/2020 Effluent Sampling Owner - Facility: Pilot Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The subiect Dermit reauires composite and arab effluent samDles. The facilitv staff Derform and document monthly aliquot verifications Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and 0 ❑ ❑ ❑ sampling location)? 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: The facility staff incorporate a comprehensive process control program with all measurements being properly documented and maintained on -site. Overall the waste treatment unit is continually improving. The faciltV has purchased a SCADA system and corrected the uneven weirs in clarifier #4. The following items still need to be addressed: 1.The weir in clarifier #3 showed advanced signs of rusting: 2.Dead spots were observed in all three (3) aeration basins. Mixers, in addition to the existing diffusers, would potentially eliminate the observed dead spots. 3.Grit was observed in downstream treatment units including the chlorine contact chamber. A grit removal system would greatly improve treatment and efficency significantly reduce the accumulation of grit in other treatment units. Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? 0 ❑ ❑ ❑ Is the wet well free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Is SCADA telemetry available and operational? 0 ❑ ❑ ❑ Is audible and visual alarm available and operational? ❑ ❑ 0 ❑ Comment: Both screw pumps were operational and inservice. Bar Screens Yes No NA NE Type of bar screen a.Manual ❑ b.Mechanical Page# 5 Permit: NCO020737 Owner - Facility: Pilot Creek WWTP Inspection Date: 01/28/2020 Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE 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: Screenings are disposed at the Cleveland County Landfill.Grit was observed in downstream treatment units including the chlorine contact chamber. A grit removal system would greatly improve treatment efficency and significantly reduce the accumulation of grit in other treatment units Flow Measurement - Influent 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: The influent flow meter is calibrated annually. 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? 0 ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ Comment: Dead spots were evident in all 3 aeration basins. Mixers, in addition to the existing diffusers, would potentially eliminate the observed dead spots. All three aeration basins were operational and inservice. Sodium hydroxide is added to the aeration basin influent to maintain appropriate alkalinity/pH levels. Chemical Feed Is containment adequate? Is storage adequate? Are backup pumps available? Is the site free of excessive leaking? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 6 Permit: NCO020737 Owner - Facility: Pilot Creek WWTP Inspection Date: 01/28/2020 Inspection Type: Compliance Evaluation Chemical Feed Yes No NA NE Comment: 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: 3 (1,3A) clarifiers were in service. The weir at the 3rd clarifier showed advanced signs of rusting. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? ❑ ❑ 0 ❑ Comment: Disinfection -Gas Yes No NA NE Are cylinders secured adequately? 0 ❑ ❑ ❑ Are cylinders protected from direct sunlight? 0 ❑ ❑ ❑ Is there adequate reserve supply of disinfectant? 0 ❑ ❑ ❑ Is the level of chlorine residual acceptable? 0 ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? 0 ❑ ❑ ❑ Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? 0 ❑ ❑ ❑ If yes, then is there a Risk Management Plan on site? 0 ❑ ❑ ❑ If yes, then what is the EPA twelve digit ID Number? (1000- Page# 7 Permit: NC0020737 Owner - Facility: Pilot Creek WWTP Inspection Date: 01/28/2020 Inspection Type: Compliance Evaluation Disinfection -Gas Yes No NA NE If yes, then when was the RMP last updated? Comment: De -chlorination Yes No NA NE Type of system ? Gas 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? ❑ ❑ 0 ❑ Number of tubes in use? 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? ❑ ❑ ❑ Comment: The flow meters (end of each chlorine contact chamber) are calibrated annually Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ❑ Comment: Did not examine the outfall 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 ❑ ❑ ❑ Page# 8 Permit: NC0020737 Owner - Facility: Pilot Creek WWTP Inspection Date: 01/28/2020 Inspection Type: Compliance Evaluation Aerobic Digester Yes No NA NE Comment: Both aerobic digesters were operational and in-service. Solids Handling Equipment Yes No NA NE Is the equipment operational? 0 ❑ ❑ ❑ Is the chemical feed equipment operational? 0 ❑ ❑ ❑ Is storage adequate? ❑ ❑ 0 ❑ Is the site free of high level of solids in filtrate from filter presses or vacuum filters? ❑ ❑ ❑ Is the site free of sludge buildup on belts and/or rollers of filter press? ❑ ❑ ❑ Is the site free of excessive moisture in belt filter press sludge cake? ❑ ❑ ❑ The facility has an approved sludge management plan? 0 ❑ ❑ ❑ Comment: The belt press was not running at time of the inspection. 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? ❑ ❑ ❑ 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: The facility is equipped with two backup generators. The smaller generator powers the blowers for aeration basin #3 and the larger generator powers the rest of the plant. Page# 9