NC0004626_NOV2018PC0322_20180810

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
LINDA CULPEPPER
Interim Director
NORTH CAROLINA
Environmental Quality
Certified Mail # 7013 1710 0002 1922 2118
Return Receipt Requested
August 10, 2018
Alan Toney
Electric Glass Fiber America LLC
473 New Jersey Church Road
Lexington, NC 27293
SUBJECT: Compliance Evaluation Inspection and Notice of Violation
NOV Tracking Number NOV-2018-PC-0322
Electric Glass Fiber America LLC WWTP
NPDES Permit No. NC0004626
Davidson County
Dear Mr. Toney:
On July 25, 2018, Paul DiMatteo and Kelli Park of this office met with Darrell Horner, operator in
responsible charge (ORC), Brigette Tinsley, backup ORC, and Terry Taylor to perform a Compliance
Evaluation Inspection on the subject wastewater treatment facility. Chris McHugh of the US
Environmental Protection Agency was also present to perform an oversight inspection of this office. A
follow-up inspection was performed by Paul DiMatteo on July 31, 2018. 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
inspection form notes the areas that were evaluated for this inspection. The findings and observations
are outlined as follows.
I. Permit
The permit became effective on January 1, 2018 and will expire on May 31, 2022. A copy of the
current permit was available during the inspection. The facility was as described in the permit.
II. Self -Monitoring Program
A review of discharge monitoring reports (DMRs) from July 2016 through May 2018 showed the
following actioned violation, which was addressed through previous correspondence from this office:
��D_
nta1an11oaiYenYI.! Q
North Carolina Department of Environmental Quality I Division of Water Resources
Winston-Salem Regional Office 1 450 Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27103
336.776.9800

Electric Glass Fiber America WWTP, 7/25/2018
NOV-2018-PC-0322
PARAMETER
VIOLATIONDATE
VIOLATION TYPE
VIOLATION ACTION
Fecal Coliform
09/14/2017
Daily Maximum Exceeded
Proceed to NOD
Sampling is being conducted at the location and frequency specified by the permit.
The facility analyzes field parameters under its in-house laboratory, certification # 5460. Effluent
toxicity analysis is performed by R&A Labs (# 34) and other analysis is performed by Pace Analytical
(# 40). Copies of all laboratory documentation were readily available. Procedures for analyzing field
parameters including required calibration appeared acceptable.
A portion of finished effluent is continuously diverted to a sink in a nearby room. Effluent grab
samples are taken from this line. In -situ measurements are taken in the sink. An ISCO 5800 composite
sampler is set to take composite samples.
During the sampling review the 10-liter sample jug was full and overflowing. The operators said
that the sample had been started only 3 hours prior to that time. Further investigation revealed that the
composite sampler was programmed to take a 50-milliliter (ml) sample every 600 gallons of flow, or 45
liters of sample per day.
Please note that Part II Section D.1 of the Permit requires that samples collected be
representative of the permitted discharge. A composite sample taken such that the sample is
overflowing after only 3 hours is not representative of the permitted discharge. Furthermore, Part II
Section A of the Permit requires that samples taken for variable time/constant volume flow proportional
compositing be at least 100 ml in volume and that the volume interval between samples be no greater
than 1/24 of the expected total daily flow. Failure to take representative samples for an
undetermined amount of time has resulted in this Notice of Violation. Mr. Horner said he would
work to set up the sampler correctly and would call for reinspection. He also said that he would not
send this sample for analysis and would start again the next day.
III. Records/Reports
Copies of DMRs, operator visitation logs, daily operation sheets, maintenance reports, lab
reports and chain -of -custody forms were available for review during the inspection. DMRs and lab data
are maintained according to the permit. DMRs include all permit parameters. A comparison of submitted
data with bench sheets revealed no errors or concerns.
IV. Flow Measurement
Effluent flow is measured using a Siemens Sitrans F M Magflo® Mag5000 electromagnetic flow
meter. The meter was calibrated by Fortech on July 7, 2018. The facility is permitted to discharge a
monthly average of 0.6 million gallons per day (mgd); typical daily discharge is about 0.54 mgd.
V. Operations and Maintenance
The plant is operated as required. All operators are properly designated and hold adequate
certifications. The facility appeared to be well operated and managed.
Page 2 of 4

Electric Glass Fiber America WWrP, 7/25/2018
NOV-2018-PC-0322
VI. Facilitv Site Review
All components appeared to be operating properly. Corrosion was visible on the chlorine contact
chamber's baffles. The operators said that they recognized it will eventually need to be repaired, but
that they thought they would try to remove their disinfection step first as they thought they would be
able to meet fecal coliform standards without it. The operators said that a standby power source capable
of powering the entire plant is available and tested under load regularly.
VII. Effluent/Receiving Waters
Treated effluent is discharged to North Potts Creek, class C waters in the Yadkin -Pee Dee River
Basin. Effluent in the sampling equipment appeared clear. The outfall was not observed during the
inspection due to wet conditions and time constraints. Please be sure to keep the outfall line's easement
cleared such that the outfall is accessible for inspection and in case of need for emergency
maintenance.
Vill. Sludge Handlina/Disposal
All sludge is dewatered and hauled to a landfill as needed. Removed water is returned to the
head of the facility.
IX. Compliance Schedule
The 2018 permit renewal included a new effluent limit and compliance schedule for total fluoride.
DMRs showed a significant decrease in fluoride concentration since March 2018. The operators
explained that fluoride was used as an additive in the boiler system, but that the system was rebuilt in
March and fluoride is no longer used. They said they hoped this alone would bring them in compliance
with the limit.
Please note that a written status report is due by March 15, 2019, as specified in Part I A(3) of
the Permit.
X. Follow-up Inspection
Mr. Horner called to say that he evaluated the composite sampling equipment and had ensured
it was set up correctly. A follow up inspection was performed on July 31, 2018 to verify the setup. The
sampler was set to take 115 ml of sample every 11,300 gallons, to average 48 aliquots per composite.
Sample volume was verified using a graduated cylinder.
Mr. Horner said that he encountered additional issues with the sampling equipment: firstly, that
the sampler would not correctly calibrate the volume taken, so that he was consistently getting twice
the volume the sampler was programmed to take; and secondly, that in investigating the first issue he
discovered that the sampler tubing was installed in reverse. He said he corrected the tubing installation
and that solved the volume issue. Mr. Horner said that he had not modified the sampler since becoming
ORC.
XII. Conclusions
After follow-up, the compliance evaluation inspection is satisfactory. Please continue to ensure
that all effluent composite samples are taken in the manner specified by the permit and that the
Page 3 of 4

Electric Glass Fiber America WWfP, 7/25/2018
NOV-2018-PC-0322
sample produced is representative of the discharge. 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
$26,000 Per day, per violation, as set forth in NC General Statute 143-215.6A, Enforcement
Procedures, Civil Penalties.
If you have any questions regarding the inspection or this report, please contact Paul DiMatteo
at [phone] or me at [phone].
Sincerely,
r� ?herdV. ight, P.E.
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
Attachments: BIMS EPA Water Compliance Inspection Report
cc: WSRO
NPDES Unit
Central Files
Chris McHugh, by email at mchugh.christopheraepa.00v
Page 4 of 4

■ Complete.items 1, 2, and 3, A. S(gnature
■ -Print your name and address on the reverse X yy�n `f � Agent
so that we can return the card to you. ❑ oDel
■ Attach this card to the back of the mailplece, B. Received'by(Printed Name) "ate of Del
or on the front if space permits. r De fr� f
1. Article Addressed to: D: Is el �rylDess 1? ❑yes
If yES, enter I below: ❑ No
Alan Toney
Electric Glass Fiber America LLC
473 New Jersey Church Road
Lexington, NC 27293
9590 9402 2546 6306 9697 12
2. Ali'.a
17013 1710 0002 1922 211
PS Form.3811., July 2016 PSN 7530-02-000-9053
AU3 2 7 2013
Winston-Salem
S. Service Type
❑ Priority Mall Express®
❑ Adult Signature
❑ Adult Signature Restricted Delivery
❑ Registered Mail*M
❑ Registered Mall Restricted
Certified Mall®
Delivery I
Certified Mail Restricted Delivery
❑ Return Receipt for
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❑ Collect on Delivery Restricted Delivery
Merchandise.
FI Signature Confirmation-
0 Insured Mail,
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❑ Insured Mall Restricted Delivery
Restricted Delivery
(over$500)
Domestic Return Receipt i
Postal
CERTIFIED MAILT. RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
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Div., Postage $ I� , /J Uv 2-0
Certified Fee b�j'yy
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C3 (Endorsement Required)
O Restricted Delivery Fee
(Endomement Required)
C3
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rq Electric Glass Fiber America LLC
Sent To
m 473 New Jersey Church Road
:- Streef, Apt. No.;
0 orPOBMIVO. Lexington, NC 27293

United States Environmental Protection Agency
Farm 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
Fee Type
1 IN 1 2 h I 3 I NCO004626 I11 121 18/07/25 117 18 1 c I 19 I T l
201 I
21IIIIII IIIIIIIIIII IIIIIII I IIIIII IIIII111I
II f6
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 CA — Reserved
72 L.J 73I 174 75
71 L_j
67 L........... 70 L.I
I I80
Section 8: 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 permit Number)
10:OOAM 18/07/25
18/01/01
PPG Industries Fiber Glass Products
473 New Jersey Church Rd
Exit Time/Date
Permit
Expiration Date
Lexington NC 27293
02:OOPM 18/07/25
22/05/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
1/1
Darrell Horner/ORC/910-428-90521
Name, Address of Responsible Officialfritle/Phone and Fax Number
Contacted
Alan Toney,473 New Jersey Church Rd Lexington NC 27293//336-357-8151/
,
Yes
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenance Records/Reports
Self -Monitoring Program Sludge Handling Disposal Facility Site Review Compliance Schedules
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 WSRO WQ//336-776-9689/
Paul DfMatteo _ i�7� 0441 v WSRO WQ//336-776-9691/
rdi l0 it (y
0
Signature ofManagement Q A Reviewer Agency/Office/Phone and Fax Numbers
Date
1
J
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPIDES yr/mo/day Inspection Type
31 Nc0004626 11 12 18/07/25 17 18 t C l
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

Permit: NC0004626 Owner -Facility: PPG Industries Fiber Glass Products
Inspection Date: 07/25/2018 Inspection Type: Compliance Evaluation
Compliance Schedules Yes No NA NE
Is there a compliance schedule for this facility? 0 ❑ ❑ ❑
Is the facility compliant with the permit and conditions for the review period? 0 ❑ ❑ ❑
Comment: 2018 permit renewal added a limit and compliance schedule for fluoride. Since March, their
concentration has dropped significantly. The operators explained that fluoride was used in
the boiler system, but that the system was rebuilt in March and no longer uses fluoride. They
hoped this would bring them in compliance with the limit.
Please note that a written status report is due by March 15. 2019, as specified in Part I A(3)
of the Permit.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? - M ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable 0 ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment:
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?
M
❑
❑
❑
# 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
❑
❑
❑
( • r�I]i1Pda M
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?
M
❑
❑
❑
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
Page# 3

Permit: NC0004626 Owner -Facility: PPG Industries Fiber Glass Products
Inspection Date: 07/25/2018 Inspection Type: Compliance Evaluation
Record Keeping
Yes No NA NE
Transported COCs
Are DMRs complete: dothey include all permit parameters?
0
❑
❑
❑
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?
0
❑
❑
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
M
❑
Comment: Checked 5/2018 and 7/2017 QMRs. No issues were noted.
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: Outfall was not observed during the inspection due_ to hea rain and access concerns
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?
M
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
0
❑
❑
❑
Comment: Facility uses a Siemens Sitrans F M Magflo type MAG 5000 flow meter at the effluent. The
meter appears to capture all effluent flow before discharge. The meter was calibrated by
Fortech on 7/7/2018.
Solids Handling Equipment
Yes No NA NE
Is the equipment operational?
N
❑
❑
❑
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?
0
❑
❑
❑
Is the site free of sludge buildup on belts and/or rollers of filter press?
0
❑
❑
❑
Is the site free of excessive moisture in belt filter press sludge cake?
0
❑
❑
❑
Page# 4

Permit: NC0004626
Inspection Date: 07/25/2018
Solids Handling Equipment
The facility has an approved sludge management plan?
Comment:
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Comment:
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Owner -Facility: PPG Industries Fiber Glass Products
Inspection7ype: Compliance Evaluation
Yes No NA NE
❑ ❑ ❑ ■
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ ■
❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Comment: Facility uses 2 screening devices. One fine Hydrosieve Screen is used to filter glass fibers,
and one traditional bar screen captures larger debris. Hydrosieve
Screen is run manually on
a schedule.
Grit Removal
Yes No NA NE
Type of grit removal
a.Manual
❑
b.Mechanical
Is the grit free of excessive organic matter?
❑
❑
❑
Is the grit free of excessive odor?
0 ❑
❑
❑
# Is disposal of grit in compliance?
N ❑
❑
❑
Comment:
Equalization Basins
Yes
No NA NE
Is the basin aerated?
❑
❑
0
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Page# 5

Permit: NC0004626
inspection Date: 07/25/2018
Owner -Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Equalization Basins
Yes No NA NE
Is the basin free of excessive grease?
0
❑
❑
❑
Are all pumps present?
0
❑
❑
❑
Are all pumps operable?
M
❑
❑
❑
Are float controls operable?
0
❑
❑
❑
Are audible and visual alarms operable?
0
❑
❑
❑
# Is basin size/volume adequate?
0
❑
❑
❑
Comment:
Primary Clarifier
Yes No NA NE
Is the clarifier free of black and odorous wastewater?
M
❑
❑
❑
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?
M
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the sludge blanket level acceptable?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately %of the sidewall depth)
M
❑
❑
❑
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?
M
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
M
❑
❑
❑
Is the overflow clear of excessive solids/pin floc?
0
❑
❑
❑
Is the sludge blanket level acceptable? (Approximately Y. of the sidewall depth)
0
❑
❑
❑
Page# 6

Permit: NC0004626
Inspection Date: 07/25/2018
Secondary Clarifier
Owner -Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: Sludge blanket measured at approximately 0.75 feet today. Operators said they try to keep
to about 3 feet.
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:
Filtration (High Rate Tertiary)
Yes No NA NE
Type of operation:
Down flow
Is the filter media present?
0 ❑
❑
❑
Is the filter surface free of clogging?
❑ ❑
❑
Is the filter free of growth?
❑ ❑
❑
Is the air scour operational?
❑ ❑
0
❑
Is the scouring acceptable?
❑ ❑
0
❑
Is the clear well free of excessive solids and filter media?
❑ ❑
0
❑
Comment: 2 activated carbon filtration chambers. Operators said they replaced media in one chamber
recently, and plan to do the next one sometime in August.
Disinfection -Liquid
Yes
No NA NE
Is there adequate reserve supply of disinfectant?
0
❑
❑
❑
(Sodium Hypochlorite) Is pump feed system operational?
N
❑
❑
❑
Is bulk storage tank containment area adequate? (free of leaks/open drains)
0
❑
❑
❑
Is the level of chlorine residual acceptable?
❑
❑
❑
Is the contact chamber free of growth, or sludge buildup?
0
❑
❑
❑
Is there chlorine residual prior to de -chlorination?
❑
❑
❑
0
Comment:
Page# 7

Permit: NC0004626
Inspection Date: 07/25/2018
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
Owner -Facility: PPG Industries Fiber Glass Products
Inspection Type: Compliance Evaluation
# Is de -chlorination substance stored away from chlorine containers?
Comment:
Are the tablets the proper size and type?
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Is proper volume collected?
Is the tubing clean?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
representative)?.
Yes No NA NE
Liquid
•
❑
❑
❑
•
❑
❑
❑
■
❑
❑
❑
❑
❑
M
❑
❑
❑
M
❑
Yes No NA NE
❑ ■ ❑ ❑
■ ❑ ❑ ❑
❑ ■ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
Comment: During the inspection we discovered that the effluent composite sampler was not setu
correctly and the sample jug was overflowing. The operators said that the sample was
started at around 8:00 am that morning and the sample iug held approximately 10 litres.
Composite sampler was set to take a 50 ml sample every 6 pulses, but the operators did
not know how many gallons constituted one pulse. Operators said they would contact
Siemens to help determine the pulse volume, and that they would set the sampler correctly.
They also said that they would not analyze the sample from that day: that they would start
the composite sampler again the next day.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, and ■ ❑ ❑ ❑
sampling location)?
Comment: Operators reported that the upstream sampling point was at Sam Sharpe Road.
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? ■ ❑ ❑ ❑
Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑
Page# 8

Permit: NC0004626 - Owner - Facility: PPG Industries Fiber Glass Products
Inspection Date: 07/25/2018 Inspection Type: Compliance Evaluation
Laboratory
Yes No NA NE
# 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
❑
❑
❑
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:
Standby Power
Yes No NA NE
Is automatically activated standby power available?
M
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
M
❑
❑
❑
Was generator tested & operational during the inspection?
❑
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Do the generator(s) have adequate capacity to operate the entire wastewater site?
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Is there an emergency agreement with a fuel vendor for extended run on back-up power?
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Is the generator fuel level monitored?
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