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Home My WebLink AboutNC0084565_NOV-2020-PC-0383_20200825ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality August 25, 2020 CERTIFIED MAIL #: 70191120 0000 8361 0407 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 The Harbour Wells 1 & 2 WTP NPDES Permit No. NCO084565 Iredell County Tracking #: NOV-2020-PC-0383 Dear Mr. Konsul: Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on August 11, 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 failures to calibrate the flow meter annually (2018 and 2019), which are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143- 215.1 as detailed in the Flow Measurement/Effluent 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 15, 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 �,"rJ J m Em^'m'"^e^ai Qmli /`� 704.663.1699 Tony Konsul Page Two August 25, 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 NCO084565 111 121 20/08/11 I17 18 LC] I 19 I s I 20L] 21111I 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 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) 11:30AM 20/08/11 18/11/01 The Harbour - Wells 1 & 2 WTP Bay Harbour Rd Exit Time/Date Permit Expiration Date Mooresville NC 28117 11:45AM 20/08/11 23/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Charles Edward Wood/// Cory Austin Fred el1/0RC/704-922-4086/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Tony Konsul,PO Box 240908 Charlotte NC 28224/Director of Operations/704-525-7990/ 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/ 8/24/2020 2 re& A61696D90CC3437... 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. EDocuSigned by: �� 8/25/2020 AlaccsalAFvazs... Page# NPDES yr/mo/day Inspection Type NCO084565 I11 12I 20/08/11 117 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: On several occasions from October 2019 through February 2020, effluent values (lead, turbidity, TSS, copper, iron and ammonia) were not reported down to the analytical method's detection/reporting limit (a "0" was reported). 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 Procedures]. The effluent flows reported in October 2019 appeared high and should be reviewed and revised if the flows were not transcribed properly. In addition, the September 2019 eDMR should be revised to include the Backup ORC visitation not originally reported on 9/30/19. All eDMRs must be reviewed to ensure all units of measurement (UoM) are consistent with the UoMs listed in the permit (ex. all metals and salinity effluent results). Page# Permit: NCO084565 Owner - Facility: The Harbour - Wells 1 & 2 WTP Inspection Date: 08/11/2020 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? M ❑ ❑ ❑ Comment: Sodium metabisulfite is not used at this facility. The last compliance evaluation inspection at this facility was performed by DWR staff on ci110i11 o 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: NCO084565 Owner - Facility: The Harbour - Wells 1 & 2 WTP Inspection Date: 08/11/2020 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. Nc effluent limit violations were reported all monitoring frequencies were correct. Effluent chronic toxicity failures were reported in December 2019, March 2020 and June 2020; however, chronic toxicity is a monitoring only requirement. The chain of custody forms should be updated to show sample type and preservative (if applicable) for each parameter sampled and the time when samples were placed on ice. 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 analyses (dissolved oxygen, pH, temperature, total residual chlorine) are performed under Carolina Water Service's field laboratory certification #5228. Waypoint Analytical (all effluent parameters except field and toxicity), Environment 1 (salinity) and ETT Environmental (toxicity) have also been contracted to provide analytical support. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Is proper volume collected? Is the tubing clean? # 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 representative)? Comment: The subject permit requires effluent grab samples. Upstream / Downstream Sampling Is the facility sampling performed as required by the permit (frequency, sampling type, an( sampling location)? Yes No NA NE ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ■ ❑ Comment: The subject permit requires downstream monitoring; however, there has been no monitoring throughout the review period due to no instream (upstream) flows. Page# 4 Permit: NCO084565 Owner - Facility: The Harbour - Wells 1 & 2 WTP Inspection Date: 08/11/2020 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 filter backwash is conveyed through two settling tanks (operated in series) prior to discharge. The solids level measured in one of the tanks was approximately nine inches. The ORC and staff indicated that L&L Environmental would be contracted to remove the tank solids. The NPDES facilities appeared to be properly operated and well maintained. 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? Are the tablets the proper size and type? Yes No NA NE Liquid ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: Sodium bisulfite is used for dechlorination and only activated during each discharge event. Are tablet de -chlorinators operational? Number of tubes in use? Comment: 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 ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The flow meter was last calibrated in 2017 by GODher Utilities: however. no calibrations werE performed in 2018 and 2019. Please be advised that the subject permit requires flow measurement devices to be accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device (Permit Condition Reference: Part 11, Section D.3 Flow Measurements). 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? ❑ ❑ 0 ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Page# 5 Permit: NC0084565 Inspection Date: 08/11/2020 Effluent Pipe Owner - Facility: The Harbour - Wells 1 & 2 WTP Inspection Type: Compliance Evaluation Comment: The facility was not discharging at the time of the inspection. Yes No NA NE Page#