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Home My WebLink AboutNC0046426_Compliance Evaluation Inspection_20200224ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director CERTIFIED MAIL 7017-1450-0001-6450-0597 RETURN RECEIPT REQUESTED Mr. Tommy Spicer Wilkes County Schools 613 Cherry Street Wilkesboro, NC 28659 NORTH CAROLINA Environmental Quality February 24, 2020 SUBJECT: Compliance Evaluation Inspection and Notice of Violation NOV-2020-PC-0107 Trap Hill Elementary School WWTP NPDES Permit No. NCO046426 Wilkes County Dear Mr. Spicer, On February 19, 2020, Kelli Park, of this office, met with you, the Operator in Responsible Charge, to perform a Compliance Evaluation Inspection at the Trap Hill Elementary School wastewater treatment plant. 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 details the areas that were evaluated during this inspection. Violations noted during the inspection are outlined below: 1) One of the siphons in the dosing tank is out of order. This has nullified the alternation of the two sand filters to treat the wastewater as described in the permit. If treatment equipment will not be replaced, then a permit modification shall be requested to accurately describe the active treatment equipment and operations. This was a deficiency noted in a previous inspection. These issues represent violations of the facility's NPDES permit. Thus, this letter is being sent to you as a Notice of Violation. Please reply in writing to this letter within 10 calendar days of its receipt. Your written reply should address each of the noted violations 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, D � North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office [ 450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 NOh �HCARO UHA ^^ •^ �ku^m I u�•i` r 336.776.9800 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 Kelli Park or me at (336) 776-9800 or by email at kelli.park(a)_ncdenr.gov or lon.snider(a-)_ncdenr.gov. Sincerely, DocuSigned by: J� T SMder 145B49E225C94EA... Lon Snider Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report cc: WSRO 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 1 2 15 I 3 I NCO046426 111 12 I 20/02/19 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 73 I I 174 751 I I I I I I I80 u ty 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) 01:30PM 20/02/19 19/01/01 Traphill Elementary School WWTP 9794 Traphill Rd Exit Time/Date Permit Expiration Date Traphill NC 28685 02:30PM 20/02/19 23/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Thomas J Spicer/ORC/336-651-4010/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Ken Barfield,201 W Main St Wilkesboro NC 28697//336-957-2379/ 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/ tu: PA4 2/26/2020 E B4A41 DCE74C34139_. Signature of Management Q A Reviewer DocuSigned by: Agency/Office/Phone and Fax Numbers Date Lon Snider E-'i 'Sider 2/24/2020 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type (Cont.) NCO046426 I11 12, 20/02/19 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On February 19, 2020, Kelli Park, of this office, met with you, the Operator in Responsible Charge, to perform a Compliance Evaluation Inspection at the Trap Hill Elementary School wastewater treatment plant. 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 details the areas that were evaluated during this inspection. Violations noted during the inspection are outlined below: 1)One of the siphons in the dosing tank is out of order. This has nullified the alternation of the two sand filters to treat the wastewater as described in the permit. If treatment equipment will not be replaced, then a permit modification shall be requested to accurately describe the active treatment equipment and operations. This was a deficiency noted in a previous inspection. These issues represent violations of the facility's NPDES permit. Thus, this letter is being sent to you as a Notice of Violation. Please reply in writing to this letter within 10 calendar days of its receipt. Your written reply should address each of the noted violations 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 Kelli Park or me at (336) 776-9800 or by email at kelli.park@ncdenr.gov or lon.snider@ncdenr.gov. Page# Permit: NCO046426 Owner - Facility: Traphill Elementary School WWTP Inspection Date: 02/19/2020 Inspection Type: Compliance Evaluation 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: Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ ❑ 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 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: NCO046426 Owner - Facility: Traphill Elementary School WWTP Inspection Date: 02/19/2020 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 is a grade 2, bORC is a Grade 1 Calibration and post calibration records were available. Some days there was not a post calibration- please be sure to do post calibration checks EACH time the instrument is used. Flow Measurement - Influent # Is flow meter used for reporting? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? Comment: Flow is measured by the schools well water meter Septic Tank (If pumps are used) Is an audible and visual alarm operational? Is septic tank pumped on a schedule? Are pumps or syphons operating properly? Are high and low water alarms operating properly? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ MOM zFs►1cIIIIIIIIIIII►1=M ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ Comment: One of the syphons has been broken since the previous inspection, therefore one of the sand beds has not been used. This needs to be repaired, or the permit needs to be amended. Pumped once a year at the minimum, pumped as needed between yearly visit. Myers septic service is used for pumping, records are kept gravity fed Sand Filters (Low rate) (If pumps are used) Is an audible and visible alarm Present and operational? Is the distribution box level and watertight? Is sand filter free of ponding? Is the sand filter effluent re -circulated at a valid ratio? # Is the sand filter surface free of algae or excessive vegetation? # Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1) Comment: Minimal vegetation. Slightly uneven sand. There is no recirculation at this plant. The plant is raked weekly. Yes No NA NE Page# 4 Permit: NCO046426 Owner - Facility: Traphill Elementary School WWTP Inspection Date: 02/19/2020 Inspection Type: Compliance Evaluation Sand Filters (Low rate) Yes No NA NE Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? 0 ❑ ❑ ❑ Are UV bulbs clean? 0 ❑ ❑ ❑ Is UV intensity adequate? ❑ ❑ ❑ Is transmittance at or above designed level? ❑ ❑ ❑ Is there a backup system on site? 0 ❑ ❑ ❑ Is effluent clear and free of solids? 0 ❑ ❑ ❑ Comment: bulbs are checked weekly and changed yearly 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: Effluent outfall is far from the school. Ms. Park and the ORC were able to locate the pipe. 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)? Comment: Grab samples are taken from the wet well after UV disinfection Laboratory Are field parameters performed by certified personnel or laboratory? 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? Yes No NA NE ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ Page# 5 Permit: NCO046426 Inspection Date: 02/19/2020 Laboratory Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? Owner - Facility: Traphill Elementary School WWTP Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ■ ❑ Comment: Calibration and post calibration records were available. Some days there was not a post calibration- please be sure to do post calibration checks EACH time the instrument is used. The pH 10 standard expires this month. pH 4 expires in March 2020 Lab number 5406 Water Tech Labs is used for non -field parameters Pump Station - Effluent Is the pump wet well free of bypass lines or structures? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Is audible and visual alarm available and operational? Comment: Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Page# 6