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Home My WebLink AboutNC0077615_Compliance Evaluation Inspection_20200730ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality July 30, 2020 CERTIFIED MAIL #: 7018 0360 0002 2099 1130 RETURN RECEIPT REQUESTED Mr. Brian Foor, Operations Manager Origin Food Group, LLC PO Box 7621 Statesville, North Carolina 28687-7621 Subject: Notice of Violation Compliance Evaluation Inspection Origin Food Group, LLC WWTP NPDES Permit No. NCO077615 Iredell County Tracking #: NOV-2020-PC-0326 Dear Mr. Foor: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on July 13, 2020, by Mr. Wes Bell of this Office. Please inform the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report. This report is being issued as a Notice of Violation (NOV) due to the following: - Flow equalization blower/motor unit not operational; - Check valve for aeration blower/motor unit not operating properly; - Clarifier drive not operational; - Pump switch and alarms (audible/visual) not operational; - Grating on clarifier needed replacement due to rust/corrosion; Divider wall between aeration basin and digester had structural issues (significant rust/corrosion and severely bowed in middle). Please be advised that the failure to properly maintain the wastewater treatment facility is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Influent Pump Station, Flow Equalization, Aeration Basins and Secondary Clarifier Sections of the attached report. Please be advised that G.S. 143-215.6A provides for a civil penalty assessment of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. Penalties may also be assessed for any damage to surface waters of the State that may result from the violations. D_;� North Carolina Department of Environmental Quality I Division of Water Resources EMooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NOR7H ORROLINA i NW-1 m EnNromi W -'; � 704.663.1699 Mr. Brian Foor July 30, 2020 Page Two It is requested that a written response be submitted to this Office by August 21, 2020, detailing the actions taken to address all violations. In responding, please address your comments to the attention of Mr. Wes Bell. Should you have any questions concerning this letter, please do not hesitate to contact Mr. Bell at (704) 235- 2192, or via email at wes.bell@ncdenr.gov. Sincerely, EDocu Signed by: �z 4tW H P",Uft for F161FB69A2D84A3... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Division of Water Resources, NCDEQ Enclosure: Inspection Report 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 u 3 I NCO077615 I11 121 20/07/16 I17 18I � I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 2.0 701d I 71 I„ I 72 I r., I 71 I 74 79 I I I I I I I80 L—I ty L-1 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 permit Number) 10:48AM 20/07/16 19/04/01 Origin Food Group, LLC 306 Stamey Farm Rd Exit Time/Date Permit Expiration Date Statesville NC 28677 12:15PM 20/07/16 24/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Dennis W Murdock/ORC/828-238-4659/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Brian Foor,PO Box 7621 Statesville NC 28687//704-768-9000/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispo: Facility Site Review Effluent/Receiving Wate 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 Wes Bell Docusigned by: DWR/MRO WQ/704-663-1699 Ext.2192/ 7/29/2020 Z(Jra Be& A61696D90CC3437... Signature of Man�gemeftpP McViewer Agency/Office/Phone and Fax Numbers Date Andrew Pitn � H DWR/MRO WO/704-663-1699 Ext.2180/ 7.30.2020 F161FB69A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NC0077615 I11 12I 20/07/16 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On -Site Representatives: The following Envirolink personnel were in attendance during the inspection: Josh Powers, Chip White and Dennis Murdock. Page# Permit: NCO077615 Owner -Facility: Origin Food Group, LLC Inspection Date: 07/16/2020 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: The last compliance evaluation inspection at the facility was performed by DWR staff on 8/31 /18. 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 operatc 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? IY411111111►[•7►/M►1M • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The records reviewed durina the insDection were oraanized and well maintained. Discharae Monitoring Reports (eDMRs) were reviewed for the period June 2019 through May 2020. N( effluent limit violations were reported and all monitoring frequencies were correct. Facility staff must ensure that the effluent total nitrogen value is calculated properly r(NO2+NO3) + TKNI. The April 2020 total nitrogen value must be revised and resubmitted. Page# 3 Permit: NCO077615 Owner -Facility: Origin Food Group, LLC Inspection Date: 07/16/2020 Inspection Type: Compliance Evaluation 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? ❑ ❑ 0 ❑ Comment: On -site field analvses (dissolved oxvaen. DH. temDerature. total residual chlorine) are performed under Envirolink's field laboratory certification #5212. Statesville Analytical (Certification #440) has also been contracted to provide analytical support. The ORC must ensure to perform post -analysis calibration checks on the pH meter and total residual chlorine meter (if no mid -range checks are performed at each site) if these field analyses are performed at multiple sites throughout a day. Post -analysis calibration checks must be performed in accordance with the NC Wastewater/Groundwater laborator certification approved procedures for the analyses of PH and total residual chlorine. 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)? Comment: The subject permit requires effluent grab samples. 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 M ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The facilitv continues to receive very low influent flows and the wastewater is treated and discharged on a batch basis. The wastewater treatment facility was not being properly maintained as discussed further in the influent pump station, equalization basin, aeration basin, and clarifier sections of this report Please be advised that the subject permit requires the permittee to properly operate and maintain the facility at all times [Permit Condition Reference: Part II, Section C(2) Proper Operation and Maintenance]. Pump Station - Influent Yes No NA NE Page# 4 Permit: NCO077615 Inspection Date: 07/16/2020 Pump Station - Influent Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? 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? Owner -Facility: Origin Food Group, LLC Inspection Type: Compliance Evaluation Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ Comment: The second pump switch and high water alarm (audible and visual) were not operational during the inspection and must be repaired/replaced. In addition, the pump station was not being visited seven (7) days per week (5 days per week if no production on weekends) as required by 15A NCAC 2T .0403. Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? Yes No NA NE ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The motor/blower unit that provides aeration was not operational and needs repair/replacement. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ 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: Aeration Basins Yes No NA NE Page# 5 Permit: NCO077615 Inspection Date: 07/16/2020 Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? Are the diffusers operational? Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Is the DO level acceptable?(1.0 to 3.0 mg/1) Owner -Facility: Origin Food Group, LLC Inspection Type: Compliance Evaluation Yes No NA NE Ext. Air Diffused • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The biomass is very low and the settleabilitv test (30-minute) was less than 50 ml/L with a cloudy supernate. The check valve for one of the blower/motor units was not operational and needs repair/replacement. Both air filters for these blower/motor units needed cleaning and/or replacement. Secondary Clarifier Is the clarifier free of black and odorous wastewater? Is the site free of excessive buildup of solids in center well of circular clarifier? Are weirs level? Is the site free of weir blockage? Is the site free of evidence of short-circuiting? Is scum removal adequate? Is the site free of excessive floating sludge? Is the drive unit operational? Is the return rate acceptable (low turbulence)? Is the overflow clear of excessive solids/pin floc? Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) Yes No NA NE ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: The clarifier drive unit was not operational and needs to be repaired. Sections of grating appeared severely rusted and deteriorated at and around the secondary clarifier. All grating must be evaluated for structural integrity and replaced at all appropriate locations. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? 0 ❑ ❑ ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Number of tubes in use? 3 Is the level of chlorine residual acceptable? 0 ❑ ❑ ❑ Page# 6 Permit: NCO077615 Inspection Date: 07/16/2020 Disinfection -Tablet Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de -chlorination? Owner -Facility: Origin Food Group, LLC Inspection Type: Compliance Evaluation Comment: Calcium Hypochlorite is used for disinfection. 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? Comment: Sodium Sulfite is used for dechlorination. Flow Measurement - Effluent # 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? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE Tablet ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ 2 Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ M ❑ Comment: Instantaneous flow measurements are based on tank volume calculations due to the batch discharge process. The ORC and staff must ensure to measure flow during the collection of effluent samples (BOD. TSS. ammonia. etc.). Effluent Pipe 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: The effluent appeared clear with no floatable solids or foam. Aerobic Digester Is the capacity adequate? Is the mixing adequate? Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 7 Permit: NC0077615 Owner -Facility: Origin Food Group, LLC Inspection Date: 07/16/2020 Inspection Type: Compliance Evaluation Aerobic Digester Yes No NA NE Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: The wall between the digester and aeration basin was severely rusted and deteriorated and did not appear to be structurally sound (significant bow). The appropriate corrective actions must be implemented to address all structural issues (rust/deterioration, wall bowing, etc.). Page# 8