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HomeMy WebLinkAboutNC0062383_NOV-2020-PV-0401_20200904ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality September 4, 2020 CERTIFIED MAIL #: 70191120 0000 8361 0513 RETURN RECEIPT REQUESTED Mr. Tony Konsul Carolina Water Service, Inc. of NC Post Office Box 240908 Charlotte, North Carolina 28224 Subject: Notice of Violation Compliance Evaluation Inspection Queens Harbor WWTP NPDES Permit No. NCO062383 Mecklenburg County Tracking #: NOV-2020-PC-0401 Dear Mr. Konsul: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on August 27, 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 failures to perform all required facility visitations by either the designated ORC or Backup ORC during multiple weeks in June and July 2020, which are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Record Keeping/Summary Section 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 violation. It is requested that a written response be submitted to this Office by September 24, 2020, detailing the actions taken to address these violations. In responding, please address your comments to the attention of Mr. Wes Bell. �� Office Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NOR7H ORROLINA i �,"r1 J m Em^'m'"^e^ai Qmli /`� 704.663.1699 Tony Konsul Page Two September 4, 2020 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(a-),ncdenr.gov. Sincerely, DocuSigned by: A14CC681 AF27425... 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 NCO062383 I11 121 20/08/27 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 70LJ 71 I„ I 72 L71 74 79 I I I I 80 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 Dermit Number) 09:15AM 20/08/27 15/07/01 Queens Harbor WWTP 13818 Queens Harbor Rd Exit Time/Date Permit Expiration Date Charlotte NC 28278 11:08AM 20/08/27 20/06/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Charles Edward Wood/ORC/704-621-9204/ Danny Lemont Hoyle//704-922-4086 / Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Tony Konsul,PO Box 240908 Charlotte NC 282240908/Director of Operations/704-525-7990/7045258174 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 c uSigned by: c DWR/MRO WQ/704-663-1699 Ext.2192/ 9/3/2020 Wes Bell E�: 96D90CC3437... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date W. Corey Basinger DWR/Division of Water Quality/704-235-2194/ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. DocuSigned by: 9/4/2020 e Page# A14CC681AF27425... NPDES yr/mo/day Inspection Type NCO062383 I11 12I 20/08/27 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) RECORD KEEPING SECTION cont'd: The chain of custody form (CoC) is in the process of being updated to show sample type and preservative (if applicable) for each parameter sampled and the time when samples were placed on ice. Note: An updated CoC (draft) has been recently submitted to this Office for review. The facility is currently classified as a Grade 2 Biological water pollution control treatment system (WPCTS). The subject NPDES Permit (Part 11, Section C(1) Certified Operator) requires Grade 2 Biological WPCTS to be visited by either the designated ORC or one of the designated Backup ORCs five days per week excluding holidays. The treatment facility did not meet these visitation requirements during the weeks of 6/14/20, 6/21/20, 6/28/20, 7/5/20 and 7/12/20. In addition, the permittee will need update the current listing of designated Backup ORCs on file with the Division. Page# Permit: NCO062383 Owner -Facility: Queens Harbor WWTP Inspection Date: 08/27/2020 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 Division received the permit renewal package on 12/11/19. The last compliance evaluation inspection at this facility was performed by DWR staff on G/I A/-1n 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ Page# 3 Permit: NCO062383 Owner -Facility: Queens Harbor WWTP Inspection Date: 08/27/2020 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: The records reviewed during the inspection were organized and well maintained. Discharge Monitoring Reports (eDMRs) were reviewed for the period July 2019 through July 2020. All monitoring frequencies were correct. Daily maximum effluent total residual chlorine (TRC) fecal coliform and total suspended solids (TSS) violations were reported in July 2019 (TRC), August 2019 (fecal coliform) and January 2020 (fecal coliform and TSS). These violations will be separately addressed by the Division through the issuances of Notice of Deficiencies (NODs), Notice of Violations (NOVs) and/or NOV/civil penalty assessments. See "Summary" Section for additional comments. 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. TRC) are Derformed under Carolina Water Service of NC's field laboratory certification #5228. K&W Laboratories (Certification #559) has also been contracted to provide analytical support for all effluent analyses except field. On several occasions in July and August 2019, effluent TRC values were not reported down to the lowest standard verified on the TRC meter (annual curve). Please be advised that the subject permit requires that all data generated must be reported down to the minimum detection or lower reporting level of the test procedure [Permit Condition Reference: Part II Section D (4) Test Proceduresl. The eDMRs for both months will be revised and resubmitted. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? M ❑ ❑ ❑ 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: The subject permit requires composite and grab effluent samples. Monthly (at a minimum) sampler aliquot checks should be performed and documented. Page# 4 Permit: NCO062383 Owner -Facility: Queens Harbor WWTP Inspection Date: 08/27/2020 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: The wastewater treatment facility appeared to be properly operated and well maintained. Process control measurements were being documented and maintained on -site. This Office recommends in the incorporation of periodic MLSS and MLVSS testing in the aeration basins to assist the operations staff in maintaining the proper solids inventory. 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 ❑ ❑ ❑ . NTOWITT'ii� 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/I) 0 ❑ ❑ ❑ Comment: Both aeration basins were in service. Lime is added (as -needed basis) to maintained appropriate alkalinity/pH levels. 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? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Page# 5 Permit: NCO062383 Owner -Facility: Queens Harbor WWTP Inspection Date: 08/27/2020 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE 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? 0 ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ 0 ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? 0 ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) 0 ❑ ❑ ❑ Comment: Both clarifiers were in service. 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? 2 Is the level of chlorine residual acceptable? 0 ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? 0 ❑ ❑ ❑ Comment: Only one chlorine contact chamber train was in service. De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? 0 ❑ ❑ ❑ Is storage appropriate for cylinders? ❑ ❑ 0 ❑ # Is de -chlorination substance stored away from chlorine containers? ❑ ❑ 0 ❑ Comment: Are the tablets the proper size and type? 0 ❑ ❑ ❑ Are tablet de -chlorinators operational? 0 ❑ ❑ ❑ Number of tubes in use? 2 NOT, T11017-2 in Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Page# 6 Permit: NCO062383 Owner -Facility: Inspection Date: 08/27/2020 Inspection Type: Queens Harbor WWTP Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Comment: The flow meter is calibrated twice Der vear and was last calibrated on 6/24/2020 by B.W. Allen Co. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ❑ ❑ N ❑ Are the receiving water free of foam other than trace amounts and other debris? ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: The effluent appeared clear with trace suspended solids and no foam. The effluent is discharged into the receiving stream (Lake Wylie) via submerged outfall. Pump Station - Effluent Yes No NA NE Is the pump wet well free of bypass lines or structures? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? M ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Is SCADA telemetry available and operational? ❑ ❑ 0 ❑ Is audible and visual alarm available and operational? ❑ 0 ❑ ❑ Comment: The visual alarm was not operational. The visual alarm must be reaaired and Dlaced back into service. 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]. Note: The telemetry type alarm system (Mission) for the high water alarm did operate properly during the on -site test. Aerobic Digester Yes No NA NE Is the capacity adequate? 0 ❑ ❑ ❑ Is the mixing adequate? M ❑ ❑ ❑ 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: Wastewater solids are removed by a contracted company (L&L Environmental Services Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑ Page# 7 Permit: NC0062383 Owner -Facility: Queens Harbor WWTP Inspection Date: 08/27/2020 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is the generator tested under load? 0 ❑ ❑ ❑ Was generator tested & operational during the inspection? 0 ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? 0 ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up power? 0 ❑ ❑ ❑ Is the generator fuel level monitored? M ❑ ❑ ❑ Comment: The backup generator is tested (automatically) under load weekly. A contracted company (Kraft Power) services the generator twice per year. Page# 8