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Home My WebLink AboutNC0022691_Compliance Evaluation Inspection_20180830 (2) 4acwYd NORTH CAROLINA ROY COOPER Environmental Quality Governor MICHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director • August 30, 2018 Mr. Andrew Luter RECEIVED/DENRIDWR YES AF Utilities Exp, LLC SEP 12 2018 1900 16th Street Denver, CO 80202 Water Kssources Permitting Section SUBJECT: Compliance Evaluation Inspection and Notice of Deficiency NOD Tracking Number: NOD-2018-PC-0282 Autumn Forest WWTP NPDES Permit No. NC0022691 Guilford County Dear Mr. Luter: On August 21, 2018, Jenny Graznak, of this office, met with Eric Wysong from Apex Companies, LLC and Anthony Montero, operator in responsible charge (ORC), to perform a Compliance Evaluation Inspection on the Autumn Forest wastewater 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.The findings and observations are outlined below: I. Permit The NPDES permit became effective October 1, 2016 and expires June 30, 2021. The facility had a copy of the current permit available during the inspection. The structures seen in the wastewater treatment system match those listed in the permit. II. Self-Monitoring Program A review of the monthly discharge monitoring reports (DMRs) for the period January 2017 through June 2018 showed that the facility was out of compliance with permit limits that resulted in the following violations of Biochemical Oxygen Demand (BOD), Fecal Coliform, Ammonia, and Total Phosphorus: Parameter Violation Date Violation type BOD January 5, 2017 Daily Maximum Exceeded BOD January 26, 2017 Daily Maximum Exceeded BOD January 2017 Monthly Average Exceeded BOD April 25, 2017 Daily Maximum Exceeded BOD April 30, 2017 Daily Maximum Exceeded BOD May 4, 2017 Daily Maximum Exceeded BOD May 25, 2017 Daily Maximum Exceeded • BOD May 30, 2017 Daily Maximum Exceeded BOD May 2017 Monthly Average Exceeded Fecal Coliform May 4, 2017 Daily Maximum Exceeded E11-*North Carolina Department of Environmental Quality!Division of Water Resources Winston-Salem Regional Office 1450 W.Hanes Mill Road,Suite 300 I Winston-Salem,North Carolina 27105 336-776-9800 Autumn Forest WWTP August 30,2018 Fecal Coliform October 5, 2017 Daily Maximum Exceeded Fecal Coliform March 14, 2018 Daily Maximum Exceeded Ammonia January 2017 Monthly Average Exceeded Total Phosphorus 2nd Quarter 2018 Quarterly Average Exceeded These violations were previously addressed in separate correspondence. Regarding the permit monitoring requirements, it was noted that all sampling was performed per the frequencies specified in the permit. Mr. Hal Young, the Back-Up ORC, does all sampling for the facility, and the laboratory analysis is performed by Statesville Analytical, Inc. III. Laboratory Mr. Montero and Mr. Young are both employees of Bell Enterprises, which holds field parameter certification _#5495. Mr. Young analyzes pH, dissolved oxygen, temperature, and Total Residual Chlorine at the facility. Meter calibrations for the pH and Total Residual Chlorine meters were documented in the operator log book. All other effluent parameters, except for Fecal Coliform, are collected with a refrigerated composite sampler. The sampler was set at approximately 0 degrees Celsius on the afternoon of the inspection. The tubing appeared to be clean. The operators deliver the samples to a courier for Statesville Analytical, Inc. The composite sampler is currently set up to collect constant time/constant volume samples instead of flow proportional samples as the permit requires. Use of the constant time/constant volume method requires prior approval by the Division Director, which has not been granted to this facility, according to our files. Therefore, this inspection letter is being sent as a NOTICE OF DEFICIENCY. Please take immediate action to start collection of flow proportional samples. IV. Records/Reports The visitation log was on site showing visitation times and plant conditions. Chain of custody forms from the laboratory were available for review. Ms. Graznak noted no data transcription discrepancies from bench sheets to DMRs during her documentation review. Four months of DMRs were missing during Ms. Graznak's inspection. The operator stated that he had misplaced them, and they were made available electronically immediately following the inspection. V. Flow Measurement Effluent flow is measured by an ISCO ultrasonic flow meter. The flow meter was calibrated June 11, 2018 by Carolina Technical Services, and documentation of the calibration was available during the inspection. VI. Operations and Maintenance A few issues were noted during the inspection regarding operation and maintenance.The equalization basin appeared to be full of solids. Mr. Montero stated that it had not been cleaned out in recent years. The equalization basin should be on a regular cleaning schedule to avoid a buildup of solids. In addition,the sludge blanket in the clarifier appeared to be very high. Mr. Montero did not have a sludge judge available to check the depth of the sludge blanket. A sludge judge should be kept on site for process control purposes. VII. Facility Site Review Only one train of the 0.082 million gallons per day plant is currently in use. The idle side is filled with stormwater.The effluent is disinfected with calcium hypochlorite tablets and dechlorinated with sodium 2 Autumn Forest WWTP August 30,2018 sulfite tablets. The effluent in the final trough appeared clear with no floating solids. The facility uses an aluminum chloride chemical feed for phosphorus reduction, as is described in the permit. VIII. Effluent/Receiving Waters The effluent from the facility was clear the day of the inspection. Effluent is discharged into an unnamed tributary to Reedy Fork, classified as Water Supply-V, Nutrient Sensitive Waters, in the Cape Fear River Basin. The effluent pipe could not be observed, because it discharges into a large stormwater pipe upstream of the tributary. No issues were noted in the receiving stream. IX. Sludge Maintenance and Handling Jenkins Waste Management pumps out the digester approximately twice per month. Records from this service were available for review. X. Requested Action In conclusion, please take immediate action to comply with your permit's requirement of flow proportional sampling. Additionally, the accumulated solids need to be removed from the equalization basin. Also, the sludge level in the clarifier should be evaluated. Please reply in writing to this letter within 30 calendar days of receiving it. 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.A review of your response will be considered along with any additional information provided. Your immediate attention is greatly appreciated. If you have any questions regarding the inspection or this report, please contact Ms. Graznak or me at (336) 776-9800 or by email at lennv.graznak@ncdenr.gov or sherri.knight@ncdenr.gov. Sincerely, c7,44.. mob Sherri V. Knight, P.E. Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: EPA Water Compliance Inspection Report cc: Central Files WSRO NPDES Unit 3 United States Environmental Protection Agency Form Approved. E PA 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 1,,,L 1 2 Li 3 I N00022691 111 12 I 18/08/21 117 18u, 19 I G 201 1 211111111 1111111111111111111111111 11111111111 f6 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA Reserved 671 I 70I I 71Li I 72 1 r, 1 73I 1 1' 75I1 1 1 1 1 1 1 180 I� Section B Facility Data L-1 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) 11 45AM 18/08/21 16/10/01 Autumn Forest MHC WWTP Exit Time/Date Permit Expiration Date 3700 Autumn Forest Dr 01 15PM 18/08/21 21/06/30 Browns Summit NC 27214 Name(s)of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data /// Anthony Oscar Montero/ORC/336-433-7221/ Name,Address of Responsible OfficiaVTitle/Phone and Fax Number Contacted Adam Motsinger,136 Fairview Rd Ste 125 Mooresville NC 28117//704-799-6390/ No Section C Areas Evaluated During Inspection(Check only those areas evaluated) El Permit • Flow Measurement • Operations&Maintenance II Records/Reports I. Self-Monitoring Program • Sludge Handling Disposal El Facility Site Review El Effluent/Receiving Waters 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 Jennifer-F raznak WSRO WQ//336-771-5000/ S/?A �jG,Ii Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date r (74314------0 2,_ e-e EPA Form 3560-3(Rev 9-94)Previous editions are obsolete Page# 1 NPDES yr/mo/day Inspection Type (Cont.) 1 31 N00022691 I11 12, 18/08/21 117 18 I„I Section D Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary) I. Permit The NPDES permit became effective October 1, 2016 and expires June 30, 2021.The facility had a copy of the current permit available during the inspection.The structures seen in the wastewater treatment system match those listed in the permit. II. Self-Monitoring Program A review of the monthly discharge monitoring reports (DMRs)for the period January 2017 through June 2018 showed that the facility was out of compliance with permit limits that resulted in the following violations of Biochemical Oxygen Demand (BOD), Fecal Coliform,Ammonia, and Total Phosphorus Parameter Violation Date Violation type . BOD January 5, 2017 Daily Maximum Exceeded BOD January 26, 2017D ally Maximum Exceeded BOD January 2017 Monthly Average Exceeded BOD April 25, 2017 Daily Maximum Exceeded BOD April 30, 2017 Daily Maximum Exceeded BOD May 4, 2017 Daily Maximum Exceeded BOD May 25, 2017 Daily Maximum Exceeded BOD May 30, 2017 Daily Maximum Exceeded BOD May 2017 Monthly Average Exceeded Fecal Coliform May 4, 2017 Daily Maximum Exceeded Fecal Coliform October 5, 2017 Daily Maximum Exceeded Fecal Coliform March 14, 2018 Daily Maximum Exceeded Ammonia January 2017 Monthly Average Exceeded Total Phos 2nd Quarter 2018 Quarterly Average Exceeded These violations were previously addressed in separate correspondence. Regarding the permit monitoring requirements, it was noted that all sampling was performed per the frequencies specified in the permit. Mr. Hal Young, the Back-Up ORC, does all sampling for the facility, and the laboratory analysis is performed by Statesville Analytical, Inc III Laboratory Mt. Montero and Mr.Young are both employees of Bell Enterprises,which holds field parameter certification#5495. Mr.Young analyzes pH, dissolved oxygen, temperature, and Total Residual Chlorine at the facility. Meter calibrations for the pH and Total Residual Chlorine meters were , documented in the operator log book.All other effluent parameters, except for Fecal Coliform, are collected with a refrigerated composite sampler.The sampler was set at approximately 0 degrees Celsius on the afternoon of the inspection. The tubing appeared to be clean.The operators deliver the samples to a courier for Statesville Analytical, Inc. The composite sampler is currently set up to collect constant time/constant volume samples instead of flow proportional samples as the permit requires. Use of the constant time/constant volume method requires prior approval by the Division Director,which has not been granted to this facility, according to our files.Therefore, this inspection letter is being sent as a NOTICE OF DEFICIENCY Please take immediate action to start collection of flow proportional samples. IV. Records/Reports The visitation log was on site showing visitation times and plant conditions. Chain of custody forms from the laboratory were available for review. Ms. Graznak noted no data transcription discrepancies Page# 2 Permit: NC0022691 Owner-Facility: Autumn Forest MHC WWfP Inspection Date: 06/21/2018 Inspection Type: Compliance Evaluation from bench sheets to DMRs during her documentation review. Four months of DMRs were missing ° during Ms. Graznak's inspection.The operator stated that he had misplaced them, and they were made available electronically immediately following the inspection. V. Flow Measurement Effluent flow is measured by an ISCO ultrasonic flow meter.The flow meter was calibrated June 11, 2018 by Carolina Technical Services, and documentation of the calibration was available during the inspection. VI. Operations and Maintenance A few issues were noted during the inspection regarding operation and maintenance.The equalization basin appeared to be full of solids. Mr. Montero stated that it had not been cleaned out in recent years. The equalization basin should be on a regular cleaning schedule to avoid a buildup of solids. In addition, the sludge blanket in the clarifier appeared to be very high. Mr. Montero did not have a sludge judge available to check the depth of the sludge blanket.A sludge judge should be kept on site for process control purposes. VII. Facility Site Review Only one train of the 0.082 million gallons per day plant is currently in use.The idle side is filled with stormwater.The effluent is disinfected with calcium hypochlorite tablets and dechlorinated with sodium sulfite tablets.The effluent in the final trough appeared clear with no floating solids.The facility uses an aluminum chloride chemical feed for phosphorus reduction, as is described in the permit. VIII. Effluent/Receiving Waters The effluent from the facility was clear the day of the inspection. Effluent is discharged into an unnamed tributary to Reedy Fork, classified as Water Supply-V, Nutrient Sensitive Waters, in the Cape Fear River Basin.The effluent pipe could not be observed, because it discharges into a large stormwater pipe upstream of the tributary. No issues were noted in the receiving stream. IX. Sludge Maintenance and Handling Jenkins Waste Management pumps out the digester approximately twice per month. Records from this service were available for review. X. Requested Action In conclusion, please take immediate action to comply with your permit's requirement of flow proportional sampling.Additionally,the accumulated solids need to be removed from the equalization basin.Also, the sludge level in the clarifier should be evaluated. Page# 3 Permit: NC0022691 Owner-Facility: Autumn Forest MHC WWTP Inspection Date: 06/21/2018 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping'? • 0 0 0 Does the facility analyze process control parameters,for ex MLSS, MCRT, Settleable 0 • 0 0 Solids, pH, DO, Sludge Judge,and other that are applicable? Comment. A sludge fudge was not available on site to determine the depth of sludge in the clarifier. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 0 0 • 0 application'? Is the facility as described in the permit'? • 0 0 0 #Are there any special conditions for the permit? 0 0 • 0 Is access to the plant site restricted to the general public? • 0 0 0 Is the inspector granted access to all areas for inspection'? • 0 0 0 Comment: Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? • 0 0 0 Is all required information readily available,complete and current? 0 I 0 0 Are all records maintained for 3 years(lab. reg. required 5 years)' • 0 0 0 Are analytical results consistent with data reported on DMRs' • 0 0 0 Is the chain-of-custody complete? • 0 0 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? • 0 0 0 Has the facility submitted its annual compliance report to users and DWQ? 0 0 I 0 (If the facility is=or>5 MGD permitted flow) Do they operate 24/7 with a certified operator 0 0 I 0 on each shift'? Is the ORC visitation log available and current'? • 0 0 0 Is the ORC certified at grade equal to or higher than the facility classification? • 0 0 0 Is the backup operator certified at one grade less or greater than the facility classification'? • 0 0 0 Is a copy of the current NPDES permit available on site'? • 0 0 0 Page# 4 } Permit: NC0022691 Owner-Facility: Autumn Forest MHC WWTP Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Facility has copy of previous year's Annual Report on file for review'? ❑ ❑ E ❑ Comment: Four months of DMRs were missing during Ms. Graznak's inspection.The operator stated that he had misplaced them, and they were made available electronically immediately following the inspection. Flow Measurement-Effluent Yes No NA NE #Is flow meter used for reporting'? • 000 Is flow meter calibrated annually? • 000 Is the flow meter operational'? • 000 (If units are separated)Does the chart recorder match the flow meter's 00110 Comment: The flow meter was calibrated June 11, 2018 by Carolina Technical Services Equalization Basins Yes No NA NE Is the basin aerated? • 000 Is the basin free of bypass lines or structures to the natural environment? • 000 Is the basin free of excessive grease'? ❑ E1 ❑ ❑ Are all pumps present? • 000 Are all pumps operable'? 000 • Are float controls operable'? 000 • • Are audible and visual alarms operable? • 000 #Is basin size/volume adequate'? • 000 Comment: The equalization basin appeared to be full of solids. Bar Screens Yes No NA NE Type of bar screen a.Manual U b.Mechanical ❑ Are the bars adequately screening debris'? 01100 • Is the screen free of excessive debris'? • ❑ ❑ ❑ Is disposal of screening in compliance'? U ❑ ❑ ❑ Is the unit in good condition'? • 000 Comment: The bar screen does not seem to be catching'all the debris, because it ends up in the equalization basin. Page# 5 i Permit: NC0022691 Owner-Facility: Autumn Forest MHC WWTP Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE ' Mode of operation Ext.Air Type of aeration system Diffused Is the basin free of dead spots'? • 0 0 0 Are surface aerators and mixers operational'? 0 0 • 0 , Are the diffusers operational'? • 0 0 0 Is the foam the proper color for the treatment process'? • 0 0 0 Does the foam cover less than 25%of the basin's surface'? • 0 0 0 Is the DO level acceptable'? 0 0 0 MI Is the DO level acceptable?(1 0 to 3.0 mg/I) 0 0 0 • Corn ment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater'? • 0 0 0 Is the site free of excessive buildup of solids in center well of circular clarifier'? 0 0 • 0 Are weirs level'? 0 • 0 0 Is the site free of weir blockage? • 0 0 0 Is the site free of evidence of short-circuiting'? • 0 0 0 Is scum removal adequate? • 0 0 0 Is the site free of excessive floating sludge? • 0 0 0 . Is the drive unit operational'? • 0 0 0 Is the return rate acceptable(low turbulence)? • 1:100 Is the overflow clear of excessive solids/pin floc'? • 0 0 0 Is the sludge blanket level acceptable?(Approximately Yi of the sidewall depth) 0 U 0 0 Comment. the sludge blanket in the clarifier appeared to be very high but there was no sludge judge on site to determine its depth. Disinfection-Tablet Yes No NA NE Are tablet chlorinators operational'? • 0 0 0 Are the tablets the proper size and type'? • 0 0 0 Number of tubes in use'? 4 Is the level of chlorine residual acceptable'? 0 0 0 • Is the contact chamber free of growth,or sludge buildup'? - • 0 0 0 Is there chlorine residual prior to de-chlorination'? ❑ 0 0 IN Page# 6 w • Permit: NC0022691 Owner-Facility: Autumn Forest MHC WVVTP Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation Disinfection-Tablet Yes No NA NE Comment: De-chlorination Yes No NA NE Type of system? Tablet Is the feed ratio proportional to chlorine amount(1 to 1)? 0 0 0 • Is storage appropriate for cylinders'? 0 0 • 0 #1s de-chlorination substance stored away from chlorine containers'? 0 0 • 0 Comment: Are the tablets the proper size and type'? • 0 0 0 Are tablet de-chlorinators operational? • 0 0 0 Number of tubes in use? 4 Comment' Aerobic Digester Yes No NA NE Is the capacity adequate'? • 0 0 0 Is the mixing adequate? • 0 0 0 Is the site free of excessive foaming in the tank? • 0 0 0 #Is the odor acceptable'? • 0 0 0 #Is tankage available for properly waste sludge'? • 0 0 0 Comment* Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained'? • 0 0 0 Are the receiving water free of foam other than trace amounts and other debris? • 0 0 0 If effluent (diffuser pipes are required) are they operating properly? 0 0 U 0 Comment: The effluent pipe could not be observed, because it discharges into a large stormwater pipe upstream of the tributary. No issues were noted in the receiving stream. Effluent Sampling Yes No NA NE Is composite sampling flow proportional'? 0 • 0 0 Is sample collected below all treatment units' • 0 0 0 Is proper volume collected'? 0 • 0 0 Is the tubing clean? • 0 0 0 Page# 7 w Permit: NC0022691 Owner-Facility: Autumn Forest MHC WWTP Inspection Date: 08/21/2018 Inspection Type: Compliance Evaluation • Effluent Sampling Yes No NA NE #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees • 0 0 0 . Celsius)' Is the facility sampling performed as required by the permit(frequency,sampling type • 0 0 0 representative)' Comment: The composite sampler is currently set up to collect constant time/constant volume samples instead of flow proportional samples as the permit requires. Use of the constant time/constant volume method requires prior approval by the Division Director, which has not been granted to this facility, according to our files Upstream/ Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit(frequency,sampling type,and • 0 0 0 sampling location)' Comment: • Page# 8