HomeMy WebLinkAboutNC0026646_NOV-2020-PC-0545_20201218 (2)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 15 1 3 I NC0026646 I11 121 20/12/15 I17 18 n 19 L G j 201
2111111�-1111111111111111111111111111111111111 f6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 CA ---------------------- Reserved -------------------
67
I 71 I I 72 L n, � 73 LLI74 71 I I I I I I I80
70 Iu ty LJ
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:OOAM 20/12/15
20/12/01
Pilot Mountain WWTP
Lynchburg Rd
Exit Time/Date
Permit Expiration Date
Pilot Mountain NC 27041
01:OOPM 20/12/15
25/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Edwin K Scott/ORC/336-368-4041/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Michael Boaz,124 W Main St Pilot Mtn NC 27041//336-444-3000/3363689532
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 Dispos 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
Justin L Henderson Docusigned by: DWR/WSRO WQ/336-776-9701/ 12/18/2020
US{tta hu' t,Vs&'
1
5F352596F81B496...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
ocusigned by:
- -T Snicttr 12/21/2020
EL
-145B49t22SC:94EA-.
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#
NPDES yr/mo/day Inspection Type (Cont.)
31 NCO026646 I11 12I 20/12/15 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
On December 15, 2020, North Carolina Division of Water Resources (DWR) staff persons Justin
Henderson, and Alex Lowe performed a Compliance Evaluation Inspection of the subject facility. Mr.
Kent Scott, ORC, and Mr. Mark King, Back -Up ORC were present during this inspection. This type of
inspection consists of two basic parts: an in -office review of the facility files and self -monitoring data
and an on -site inspection of the facility. This inspection reflects non-compliance with Permit No.
NC0026646. The following violations require your attention and action:
1) An unreported bypass was discovered and ongoing during this inspection. Wastewater was
observed leaking from a crack, located in the wall of the outer oxidation ditch. The observed discharge
point was located approximately 180 degrees adjacent to where the influent pump station discharged
into the oxidation ditch. This bypass persisted during the entire inspection, and reportedly as of the dat(
of this letter is still ongoing. The ORC reported that leakage from this location had been noticed
approximately six weeks prior to this inspection. Permit Condition Part II. Section C (4.) (c) (1) states:
bypass from the treatment facility is prohibited and the Permit Issuing Authority may take enforcement
action against a Permittee for bypass.
2) Failure to report the occurrence of an unanticipated bypass within 24-hour notice. Permit Condition
Part II. Section C. (4) (b) (2) states The Permittee shall submit notice of an unanticipated bypass as
required in Part II.E.6. (24-hour notice). As noted above, the ORC acknowledged that a bypass had
been observed occurring at this location as early as six weeks, prior to the inspection that was
conducted on December 15, 2020.
3) Failure to conduct appropriate maintenance with respect to the oxidation ditch to prevent the growtr
of excessive vegetation. Woody vegetation was consistently present and overgrown in the outer ring of
the oxidation ditch. Permit Condition Part II. Section C. (2.) states: the permittee shall at all times
properly operate and maintain all facilities and systems of treatment and control which are installed or
used by the Permittee to achieve compliance with the conditions of this permit.
4) Failure to conduct flow proportional composite sampling (both influent and effluent) in accordance
with Permit Condition Part II. Composite Sampling. Mr. Scott, ORC indicated that composite samples
currently were being collected via the constant time/constant volume method however, use of this
method requires prior approval by the Director, and may only be used in situations where effluent flow
rates vary less than 15 percent.
5) Failure to ensure the composite sample is maintained at or below six (6) degrees Celsius during
the entire compositing period per CFR part 136.3 Table II. There were no thermometers present in
either the effluent or influent composite samplers nor were any records available to demonstrate the
sample compartment cooling was maintained in accordance with CFR part 136.3. The current influent
composite sampler was not capable of mechanical cooling, and the ORC acknowledged that the
sample is not cooled with ice during the compositing period.
6) The effluent composite sampler was collecting aliquots prior to final treatment of effluent. Permit
Condition Part II. Section D (1.) states: samples collected, and measurements taken shall be
representative of the permitted discharge. All samples shall be taken at the monitoring points specified
in the permit.
7) Failure to maintain appropriate quality assurance procedures associated with the pH meter
calibration requirements. The high range pH buffer (pH 10 buffer), utilized to calibrate the pH meter for
per event sampling, had been expired since March 2020. Permit Condition Part II. C states: proper
Page#
Permit: NCO026646
Inspection Date: 12/15/2020
Owner -Facility: Pilot Mountain WWTP
Inspection Type: Compliance Evaluation
operation and maintenance also includes adequate laboratory controls and appropriate quality
assurance procedures.
8) Failure to maintain records of sewage sludge removal for a period of at least five years. Permit
Condition Part II. Section D (6) states: records of the Permittee's sewage sludge use and disposal
activities shall be retained for a period of at least five years (or longer as required by 40 CFR 503).
9) Failure to conduct and/or maintain documented logs for the calibration of meters utilized to monitor
and report effluent temperature analysis in accordance with Permit Condition Part II. Section C (2.),
Permit Condition Part II Section D. (6.), and the North Carolina Wastewater/Groundwater Laboratory
Certification Approved Procedures.
10) Failure to properly maintain the clarifier's surface scum basin to prevent the discharge of floating
solids. The scum basin within the one operating clarifier was clogged to the degree that floating
solids/trash was observed discharging across the clarifier's weir, during this inspection. Permit
Condition Part II. Section C. (2.) states: The Permittee shall at all times properly operate and maintain
all facilities and systems of treatment and control.
11) Failure to properly maintain the "brush" rotors and their associated motors, designed to provide
aeration within the oxidation ditch to promote nitrification. Three of the five "brush" rotors were
inoperable. Two were missing motors altogether and the other motor had fallen into the oxidation ditch.
Permit Condition Part II. Section C. (2.) states: The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control.
Along with the above described violations the following items of concern warrant your attention:
a) The clarifier weir appeared to be unlevel, as various rates of discharges were observed at multiple
locations along the weir. Design specifications would be expected to call for uniform discharge rates
across the entire weir.
b) The facilities treatment equipment included the presence of 2 clarifiers, however only one of the tw(
clarifiers is currently operable. The "out of service" clarifier reportedly has been off-line in excess of
three years and significant rust was present on nearly all mechanical components of the treatment unit.
Permit Condition Part II. Section C. (2.) states: The Permittee shall at all times properly operate and
maintain all facilities and systems of treatment and control. Should the Permittee allege that treatment
equipment is unnecessary to achieve compliance with the subject permit, based upon an engineering
design evaluation, then the equipment deemed unnecessary should be requested to be removed from
the Permittee's treatment equipment description contained in the permit.
c) Permit Condition Part II. Section C (7.) states: The Permittee is responsible for maintaining
adequate safeguards (as required by 15A NCAC 02H .0124) to prevent the discharge of untreated or
inadequately treated wastes during electrical power failures either by means of alternate power
sources, standby generators, or retention of inadequately treated effluent. The facility had an on -site
generator that was only capable of providing power to the influent pump station. Reportedly, the facility
does not have the capacity nor any effluent storage equipment present to ensure retention of
inadequately treated effluent should the facility be subject to an extended period of power failure.
d) The effluent pump station was visited as part of this inspection. While not listed as part of the
treatment equipment authorized by this permit, it was noted that effluent pump #2 had a significant leak
and needed maintenance/repair.
Page#
Permit: NCO026646 Owner -Facility: Pilot Mountain WWTP
Inspection Date: 12/15/2020 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: Proper maintenance of all facilities has been neglected to the point that excessive vegetativE
growth was present in the oxidation ditch. Brush rotor motors were missing and had not
been replaced. One motor had fallen into the oxidation ditch and been allowed to remain
there.
Permit
(If the present permit expires in 6 months or less). Has the permittee submitted a new
application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
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:
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?
Comment:
Aerobic Digester
Is the capacity adequate?
Is the mixing adequate?
Is the site free of excessive foaming in the tank?
# Is the odor acceptable?
Yes No NA NE
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Page# 4
Permit: NCO026646
Inspection Date: 12/15/2020
Aerobic Digester
# Is tankage available for properly waste sludge?
Owner -Facility: Pilot Mountain WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
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Comment: Reportedly the facility has not wasted any solids in over two years as all solids are
"recycled" in the plant. The ORC attributed this operation to the low influent TSS values
received by the Dalnt due to the decreased flows.
Pump Station - Effluent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
0
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Are all pumps present?
0
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Are all pumps operable?
0
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Are float controls operable?
❑
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Is SCADA telemetry available and operational?
❑
0
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Is audible and visual alarm available and operational?
❑
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Comment: SCADA is not available. Effluent Pump #2 had a significant leak and was needed
maintenance/repair.
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
0
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Is the wet well free of excessive grease?
0
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Are all pumps present?
0
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Are all pumps operable?
0
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Are float controls operable?
0
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Is SCADA telemetry available and operational?
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0
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Is audible and visual alarm available and operational?
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Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
❑
Are the bars adequately screening debris?
❑
0
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Is the screen free of excessive debris?
0
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Is disposal of screening in compliance?
0
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Is the unit in good condition?
0
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Comment: trash and solids that had bypassed
this screeninq unit was seen in the clarifier.
Page# 5
Permit: NCO026646
Inspection Date: 12/15/2020
Owner -Facility: Pilot Mountain WWTP
Inspection Type: Compliance Evaluation
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
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Comment: Scum basin was clogged prevent adequate removal of floating solids. Trash and other solids
were observed crossing the weir. Varying rates of discharge was oberved at muiltiple
locations along the weir sugguesting that the weir is unlevel or that blockage is not prevente(
as is necessary.
Oxidation Ditches
Yes
No
NA
NE
Are the aerators operational?
❑
0
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Are the aerators free of excessive solids build up?
0
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# Is the foam the proper color for the treatment process?
0
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Does the foam cover less than 25% of the basin's surface?
0
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Is the DO level acceptable?
0
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Are settleometer results acceptable (> 30 minutes)?
❑
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Is the DO level acceptable?(1.0 to 3.0 mg/I)
0
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Are settelometer results acceptable?(400 to 800 ml/I in 30 minutes)
❑
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Comment: 3 of the 5 brush rotors are inoperable due to failure to repair/replace/maintain the motors.
Aeration is only provided by the two remaining operable rotors.
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?
Yes No NA NE
Gas
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Page# 6
Permit: NCO026646
Inspection Date: 12/15/2020
De -chlorination
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Owner -Facility: Pilot Mountain WWTP
Inspection Type: Compliance Evaluation
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
Was generator tested & operational during the inspection?
Do the generator(s) have adequate capacity to operate the entire wastewater site?
Is there an emergency agreement with a fuel vendor for extended run on back-up power?
Is the generator fuel level monitored?
Yes No NA NE
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Yes
No
NA
NE
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Comment: The stand-by generator is only capapble of providing power to the influent
pump station. Thi:
generator provides notification of power failure to the ORC, but requires manual activiation
during power failures.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
0
❑
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Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
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# Is the facility using a contract lab?
0
❑
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
❑
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?
❑
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0
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Comment: Influent composite sample is not maintained at proper temperature as it is not cooled unitl
after collection per the ORC. The effluent composite sampler did not have a thermometer to
confirm cooling was properly achieved during entire compositing period.
Disinfection -Liquid
Is there adequate reserve supply of disinfectant?
(Sodium Hypochlorite) Is pump feed system operational?
Is bulk storage tank containment area adequate? (free of leaks/open drains)
Is the level of chlorine residual acceptable?
Is the contact chamber free of growth, or sludge buildup?
Is there chlorine residual prior to de -chlorination?
Yes No NA NE
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Page# 7
Permit: NCO026646
Inspection Date: 12/15/2020
Disinfection -Liquid
Comment:
Influent Sampling
# Is composite sampling flow proportional?
Is sample collected above side streams?
Is proper volume collected?
Is the tubing clean?
Owner -Facility: Pilot Mountain WWTP
Inspection Type: Compliance Evaluation
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
Celsius)?
Is sampling performed according to the permit?
Yes No NA NE
Yes
No
NA
NE
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Comment: Sampler does not include mechanical coolinq and per ORC is not cooled by any other
means during the compositinq period. Sample collection is not flow proportionally collected.
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)?
Yes
No
NA
NE
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Comment: Effluent composite sampler was not collected sample below all treatment. Effluent
composite sampler did not have a thermometer. Tubing was discolored and needed to be
replaced.
Page# 8