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HomeMy WebLinkAboutNC0028037_Compliance Evaluation Inspection_20200211ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director Ronald S. Walser City of Lexington 28 W. Center St Lexington, NC 27292 NORTH CAROLINA Environmental Quality February 11, 2020 Subject: Compliance Evaluation Inspection Report NPDES Permit NCO028037 Lexington WTP #1 & 2, Davidson County Dear Mr. Walser: On January 14, 2020, Paul DiMatteo of the Division of Water Resources (Division), Winston- Salem Regional Office met with Ronald Walser, Operator in Responsible Charge (ORC), to conduct a Compliance Evaluation Inspection of the above referenced wastewater treatment plant. This inspection consists of (1) a review of the permit and accompanying documentation to determine compliance with permit conditions, and (2) an on -site inspection of several collection system components. The attached inspection form notes the areas that were evaluated for the inspection, with any notable findings outlined as follows. Item of Concern Mr. Walser explained that leachate from the residuals drying beds is designed to combine with the effluent rather than cycle back to the lagoons for settling and treatment. The Division is concerned that this arrangement could impact water quality, as this set up is not a typical design seen at other water treatment facilities. Therefore, the Division wishes to investigate this issue further via sampling inspections and discussion with the Water Quality Permitting Section. If you wish, you may provide any additional sampling results or other information related to the above for review. If you have any questions concerning this report, please contact Paul DiMatteo at (336) 776-9691 or me at (336) 776-9800. Sincerellv, Docuft ed by: A, l sMak L"L L49 gonal Supervisor cn mer,Ri Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Enclosures — Inspection Report CC: WSRO Laserfiche Files North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regiona[ Office 1 450 West Hanes Mill Road, Suite 300 1 Winston-Salem, North Carolina 27105 kORrHCA Den. add �o-­Ul Q,,I,Ly /^� 336.776.9800 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 NCO028037 111 12 I 20/01/14 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 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) 09:30AM 20/01/14 15/04/01 Lexington WTP #1 & 2 2979 Old Greensboro St Extension Exit Time/Date Permit Expiration Date Lexington INC 27292 10:45AM 20/01/14 20/02/29 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Ronald Stephen Walser/ORC/336-248-5820/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Ronald S Walser,28 W Center St Lexington NC 27292/Utility Plant Supervisor/336-248-3910/ 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 Paul DiMatteo �Docusigned by: DWR/WSRO WQ/336-776-9691/ 2/11/2020 4';M 1=4a F10C7C2E5BB34D4... Signature of Management Q A RevieLL1QdQ—'QQ— EPA Page# NPDES yr/mo/day Inspection Type NC0028037 I11 121 20/01/14 117 18 JCJ Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) During the inspection, the effluent looked rather turbid due to also carrying carbon dust. Carbon -rich sludge is stored in the drying beds and leachate is sent to the effluent. Operators said this typically happens during rain. He mentioned that they tested it some time ago and it wasn't over their turbidity limits. I tried to observe the receiving stream downstream of the outfall but it already looked turbid due to rain. Page# Permit: NCO028037 Owner - Facility: Lexington WTP #1 & 2 Inspection Date: 01/14/2020 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 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: The permit expires on 2/29/2020. The renewal application was received on 1/14/2020. Record Keeping Are records kept and maintained as required by the permit? Is all required information readily available, complete and current? Are all records maintained for 3 years (lab. reg. required 5 years)? Are analytical results consistent with data reported on DMRs? Is the chain -of -custody complete? 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? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 3 Permit: NCO028037 Inspection Date: 01/14/2020 Record Keeping Facility has copy of previous year's Annual Report on file for review? Owner - Facility: Lexington WTP #1 & 2 Inspection Type: Compliance Evaluation Yes No NA NE ■ ❑ ❑ ❑ Comment: In response to the previous inspection, ORC began keeping a binder containing all relavent visitation documents. Checked DMRs from 10/2018 and 8/2019. Lagoons Type of lagoons? # Number of lagoons in operation at time of visit? Are lagoons operated in? # Is a re -circulation line present? Is lagoon free of excessive floating materials? # Are baffles between ponds or effluent baffles adjustable? Are dike slopes clear of woody vegetation? Are weeds controlled around the edge of the lagoon? Are dikes free of seepage? Are dikes free of erosion? Are dikes free of burrowing animals? # Has the sludge blanket in the lagoon (s) been measured periodically in multiple locations? # If excessive algae is present, has barley straw been used to help control the growth? Is the lagoon surface free of weeds? Is the lagoon free of short circuiting? Yes No NA NE Facultative N Parallel ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Operator said the liner was replaced in 1 lagoon in the past year, and the other is to be replaced this year. De -chlorination Type of system ? Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? # 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? Yes No NA NE Liquid ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Page# 4 ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Page# 4 Permit: NCO028037 Inspection Date: 01/14/2020 De -chlorination Owner - Facility: Lexington WTP #1 & 2 Inspection Type: Compliance Evaluation Yes No NA NE Comment: Dechlor is only added when decanting from the lagoons, as operators said that leachate from the drying beds is not chlorinated. 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 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 ❑ ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type 0 ❑ ❑ ❑ representative)? Comment: DH. flow. chlorine. turbiditv and TSS run here. certification # 690: metals and toxicitv are analyzed by Cameron Testing. 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 viewed during the inspection due to area flooding/rain. Drying Beds Is there adequate drying bed space? Is the sludge distribution on drying beds appropriate? Are the drying beds free of vegetation? # Is the site free of dry sludge remaining in beds? Is the site free of stockpiled sludge? Is the filtrate from sludge drying beds returned to the front of the plant? • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ■ ❑ ❑ Page# 5 Permit: NC0028037 Inspection Date: 01/14/2020 Drying Beds # Is the sludge disposed of through county landfill? # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Comment: Leachate from drying beds goes to the outfall. Owner - Facility: Lexington WTP #1 & 2 Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 6