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HomeMy WebLinkAboutNC0071242_NOV-2020-PC-0402_20200904ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality September 4, 2020 CERTIFIED MAIL #: 70191120 0000 8361 0520 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 Riverpointe WWTP NPDES Permit No. NCO071242 Mecklenburg County Tracking #: NOV-2020-PC-0402 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 following: - Failure to collect a minimum of 100 ml. per aliquot/grab sample on composite sampler (repeat violation); - Failure to perform all required facility visitations by either the designated ORC or Backup ORC during multiple weeks in June and July 2020. All are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Record Keeping/Summary and Effluent Sampling 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 violation. �� 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 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. 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, 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 NCO071242 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) 11:18AM 20/08/27 20/08/01 Riverpointe WWTP 15820 Alloway Ln Exit Time/Date Permit Expiration Date Charlotte NC 28278 01:08PM 20/08/27 25/06/30 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 cuSigned by: Wes Bell DWR/MRO WQ/704-663-1699 Ext.2192/ 9/3/2020 2 re& E�� 1696D90=437... 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 AiaccsatAFz7azs... Page# NPDES yr/mo/day Inspection Type NCO071242 I11 12I 20/08/27 117 18 I c (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, 6/28/20, 7/5/20 and 7/12/20. In addition, the permittee will need to updatE the current listing of designated Backup ORCs on file with the Division. Page# Permit: NCO071242 Owner -Facility: Riverpointe 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 last compliance evaluation inspection at this facility was performed by DWR staff on 5/14/19. 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)? ❑ ❑ ❑ 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 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? 0 ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Page# 3 Permit: NCO071242 Owner -Facility: Riverpointe 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 June 2020. All monitoring frequencies were correct. Daily maximum effluent violations were reported in July 2019 (TSS), August 2019 (fecal coliform), October 2019 (TSS), January 2020 (TSS) and March 2020 (TSS). A monthly average effluent TSS violation was also reported in January 2020. These violations will be separately addressed by the Division through the issuances of Notice of Violations (NOVs) and/or NOV/civil penalty assessments. See "Summary" Section for additonal 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. The dissolved oxygen meter calibration was not documented on the 6/30/20 effluent sampling event. Please be advised that the dissolved oxygen meter calibrations must be performed and documented each day the meter is used for effluent analyses (Reference: North Carolina Wastewater/Groundwater Lab Certification approved procedure for analysi of dissolved oxygen) 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)? Page# 4 Permit: NCO071242 Inspection Date: 08/27/2020 Owner -Facility: Riverpointe WWTP Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Comment: The subiect Dermit reauires composite and arab effluent samDles.The aliauot volume was initially well below 100 mis. during the on -site inspection; however, the ORC corrected the sampler program to ensure a minimum of 100 mis per aliquot will be collected during future sampling events. Note: The failure to collect a minimum of 100 mis. per aliquot was noted it the previous inspection. Please be advised that the subiect permit requires a minimum of 100 mis. per aliquot/grab sample (Permit Condition Reference: Part II, Section A Definitions — Composite Sample). Monthly (at a minimum) sampler aliquot checks should be performed and documented. 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 facilitv aDDeared to be DrODerIv 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. The telemetry type alarm system (Mission) was tested and operated properly during the inspection. 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: Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? 0 ❑ ❑ ❑ Page# 5 Permit: NCO071242 Owner -Facility: Riverpointe WWTP Inspection Date: 08/27/2020 Inspection Type: Compliance Evaluation Equalization Basins Yes No NA NE # Is basin size/volume adequate? 0 ❑ ❑ ❑ Comment: 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/1) 0 ❑ ❑ ❑ Comment: Lime is added (as -needed basis) to maintained appropriate alkalinity/pH levels. The powdered lime is added directly into the equalization tank. This office recommends the permittee to investigate the usage of a continuous feed system (aqueous) to provide a more consistent and uniform application of lime throughout the day. 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) Comment: Filtration (High Rate Tertiary) Type of operation: Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE Cross flow Page# 6 Permit: NCO071242 Inspection Date: 08/27/2020 Filtration (High Rate Tertiary) Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Comment: Disinfection - UV Are extra UV bulbs available on site? Are UV bulbs clean? Is UV intensity adequate? Is transmittance at or above designed level? Is there a backup system on site? Is effluent clear and free of solids? Owner -Facility: Riverpointe WWTP Inspection Type: Compliance Evaluation Comment: Liquid chlorination would be used as a backup. 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 ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The flow meter is calibrated twice per year and was last calibrated on 6/24/2020 by B.W. Allen Co. 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? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Is SCADA telemetry available and operational? ❑ ❑ 0 ❑ Is audible and visual alarm available and operational? 0 ❑ ❑ ❑ Comment: Page# 7 Permit: NC0071242 Owner -Facility: Riverpointe WWTP Inspection Date: 08/27/2020 Inspection Type: Compliance Evaluation 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? ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: The effluent appeared clear with no floatable solids or foam. The effluent is discharged into the receiving stream (Lake Wylie) via submerged outfall. Aerobic Digester Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Comment: Solids Handling Equipment Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Comment: The sludge dewatering box was operational and in service. The dewatering box is removed by 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 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ Page# 8 Permit: NC0071242 Inspection Date: 08/27/2020 Standby Power Owner -Facility: Riverpointe WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The backup generator is tested (automatically) under load weekly. A contracted company (Kraft Power) services the generator twice per year. Page#