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murape
26 January 2010—
Certified Mail
Return Receipt Requested
FEB - 4 2010
2 :0
Annual System Performance Report
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 276994617
Subject: Annual System Performance Report — CY2009- .
NPDES Permit No fN 007�66y4--
Shurtape Technologies — Stony Point Plant
Alexander County
Q
D
FEB 2 2010
DENR-WATER QUALM
POINT SOURCE BRANCH
Attached please find the annual performance report for the subject facility owned by
Shurtape Technologies. Please be advised that this report has been prepared in accordance with
the format suggested in Kerr T. Stevens' 19 October 1999 letter.
I. General Information
a. Name of Regulated Entity: Shurtape Technologies
b. Contact: Mark E. Hawes, P.E.
PO Box 1530
Hickory, NC 28603-1530
Phone: 828-322-2700, extension 4428
e-mail: mhawes@shurtape.com
C. Permit: NCO072664
d. Description of treatment process: Shurtape Technologies operates a 10,000 gpd
extended aeration type WWTP to treat domestic wastewater generated by
Shurtape's Stony Point Tape Plant. The extended aeration plant consists of an
inlet. bar screen, aeration basin, hopper -type clarifier with a v-notch type weir,
tablet -type chlorination, tablet de -chlorination, and an aerated sludge holding
tank. Discharge of the treated wastewater is into Third Creek in the Yadkin -Pee
Dee River Basin. To optimize the operation of the WWTP, Shurtape conducts
process testing of MLSS, MLVSS,and settleability in.the aeration basin.
H. Performance
a. Description of overall 12-month performance: The previous twelve
months performance was reviewed with the ORC, Mr.. Travis
Brannon, Certificate No. 990808. Review of the system
performance consisted of reviewing the operator's logbook,
process control equipment calibration logbooks, sludge removal
records, and DMR's from January 2009 through December 2009. During this
time period, no effluent violations occurred. During this time period, all process
Shurtape Technologies, LLC 8510 NC Hwy 90 E Stony Point, NC 28678 www.shurtape.com
Nwual System Performance Report
26 January 2010
Page 2-of 4
control monitoring equipment was found to have met calibration checks unless
further described herein. Buffer solutions used for pH meter calibrations were
valid; and all sampling results have attached chain of custody forms. The
operator logbooks verified that the system had been attended as required with
maintenance activities performed., During 2009, there were no events noted in
the logbook that would cause the facility to operate in a non -compliant manner.
The facility operated in compliance.
b. During the time period of January 2009 through December 2009 no effluent
violations occurred. Upon review of the November 2009 DMR, it was found that
one pH reading was errantly reported as 9.09, which is above the allowable 6 — 9
pH range. However, the log book indicated that the correct reading was 7.09.
An amended DMR was subsequently submitted.
Likewise, on September 14, 2009, low-level chlorine was not reported on the
DMR. Also on this same DMR, the number of hours that the ORC was on -site
were not reported. A corrected DMR has been submitted.
Additionally, the following were identified during the annual review:
On February 16, 2009, the vendor invoice indicates that 2,000 gallons of
sludge were pumped and disposed. The ORC appears to have errantly
written this sludge pumping event down as happening on February 17,
2009.
• During the period of April 13 - 15, 2009, discrepancies were noted
between the log book, daily check sheets, and the DMR for low-level
chlorine.
o The April 1 P DMR reported a low-level chlorine of 21 ug/L,
which agreed with the log book, but disagreed with the daily
check sheet. The daily check sheet indicated 31 ug/L.
o The April 14`h DMR reported <20 ug/L as the low-level chlorine,
which agreed with the daily check sheet, but disagreed with the
log book. The log book indicated 31 ug/L on this day.
o On April 15f, the DMR did not report a low-level chlorine.
Likewise, there was no calibration of the low-level meter on this
day, and the daily check' sheet does not indicate a low-level
chlorine sample for this date. However, the log book indicates
<20 ug/L for low-level chlorine.
These discrepancies were reported to NCDENR, and NCDENR and
Shurtape, both agreed that an amended DMR was not necessary.
Regardless of the discrepancies, all results were below the 50 ug/L
compliance limit.
• On May 6, 2009, Dissolved Oxygen (DO) concentrations were reported
on the DMR; however, verification of the calibration of the DO meter
was not- documented. Calibration records indicate that the DO meter
calibration was verified on May 7, 2009. The DO meter was calibrated
on April 28, 2009 by Water Tech Labs, and the May 7, 2009 calibration
verification indicated that the meter was working properly. An amended
DMR was not submitted.
iinual System Performance Report
26 January 2010
Paae 3 of 4
On August 12, 2009, calibration of the low-level chlorine meter was not
documented. All previous and post calibrations of the low-level meter
indicate that the meter was performing properly. An amended DMR was
not submitted.
C. Description of any known environmental impacts of violations:
N/A — No known violations of effluent limitations.
d. Description of corrective actions taken to address violations or deficiencies: No
known violations existed for the reporting period. Section (b) above describes
several events where no action was necessary, and two events where DMRs were
amended:
• The September DMR was amended to address not reporting the ORC hours
on one day and a low-level chlorine that was not reported.
The November DMR was amended to address the pH, which was errantly
reported as 9.09 on November 24`h, when the correct pH was 7.09.
Shurtape has met the requirements to conduct analysis of field parameters on site
through Lab Certification Procedures.
Lab Certification No. 5087; EPA Lab ID No. NC01311
Proficiency testing was completed during August and September 2009. The
initial submittal for. low-level chlorine was not within the allowable range. A
second submittal later in September resulted in acceptable results. The approval
report issued 30 September 2009.
g. Notification: Shurtape's WWTP serves the manufacturing facility at Stony
Point. There are no other users connected to the system. Therefore, Shurtape is
the only user of the system. A copy of this report is sent to the Vice President of
Manufacturing and the Executive Vice President.
III. Certification
I certify, under penalty of law, that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my
knowledge and belief, true; accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and
imprisonment for knowing violations.
David Neff Date
Plant Manager
nual System Performance Report
26 January 2010
Page 4 of 4
Upon review of this report, should any questions arise, please contact Mark Hawes at
(828) 325-5428 or via e-mail at mhawes@shurtape.com.
Respectfully Submitted,
Jerry Eplin, P.E.
Environmental & Process Engineer
cc:
Wayne Helton.
Stephen Shuford
David Neff
Mark Hawes
Matt Moore
Doug Hall
Travis Brannon
1 Check List for Annual WWTP Certification for DWQ.xis
2664
Shurtape Technologies, LLC
Stony Point - Plant # 31
Date: 26-Jan-10
Reviewed by:
Certified by:
ORC:
DMR Review:
January
OK
February
OK
March
OK
April
See below
May
See below
June
OK
name - • - I. , signature
Environmental
Plant Manager
Travis Brannon
Sample Results Reviewed for each Week and the
Attached Chain of Custody Forms
July
OK
January
OK
July
OK
August
See below
February
OK
August
OK
September
See below
March
OK
September
OK
October
OK
April
OK
October
OK
November
see below
I
May
OK
November
OK
December
OK
June
OK
December
OK
Sludge Records Reviewed: 21 Jan 2009 - 2000 gal; 16 Feb 2009 - 2000 gal; 09 April 2009 - 2000 gal; 29 April 2009 - 4000 gal; 25 Jun
2009 - 2000 gal; 15 Sep 2009 - 2000 gal; 20 Nov 2009 - 2000 gal; 10 Dec 2009 - 2000 gal - . i
pH Buffers Checked: 4 Exp Date: Oct-13 pH / Temp. Meter External Meter 220875:1 01/05/2009; 08/10/09;
Calibration Dates: Meter 226683: 01/05/2009;
DO / Temp. Meter External Meter 08A100904: 01/05/09; 05/23/09;
7 Exp Date: Sep-11 Calibration Date: 08/10/09
Meter 0913100202: 04/28/09
Spectrophotometer External Low Level:'01/05/2009; 08/10/09"
Calibration Date: 12/28/09
10 Exp Date: Apr-10 High Level: 01/05/2009; 12/28/09
NIST Traceable 02/21/09; 08/10/09
pH, Residual CIz, y _ a ML55, MLV55
Parameters samples for Dissolved Oxygen o o E pH, & DO
On -Site:
Temperature o a. 30 Minute Settleability Frequency of Calibration
Corning 313 5/N 226683 - pH d Temperature
Corning 313 S/N 220875 - pH & Temperature rn
0
Meters YSI 550A 5/N 08A100904 - DO 4 Temperature
c Minimum of annual external calibrations,
Used On YSI 550A S/N 09D1o0202 - DO di Temperature 5 Yes - all meters calibrated. see above for dates.
Site: HACH 2400 5/N 05000007985 Spectrophotometer cd
m 2
HACH Pocket Colorimeter II 5/N 040200010597 U
ERTCO NIST Traceable Thermometer 5/N 3037
Summary of ORC Log Book Review:
-ogbook is up to date with appropriate notations of actions by ORC and back-up ORC. Logbook appears to contain all operational information required to
iemonstrate compliance. Dates and times appear to be noted correctly. Information in logbook corresponds to that recorded on the DMRs submitted
:hroughout CY2009, with the exception of the following:
- On February 16, 2009, vendor records/invoice indicates 2,000 gallons of sludge were pumped and disposed; however, the log book indicates that this
)ccurred on February 17th, 2009. It is suspected that the ORC wrote the entry down on the wrong line of the log book.
- On April 13 - 15, 2009, low level chlorine readings recorded in the log book, on daily check lists, and on the DMR did not all agree. None of the readings
mere above the 50 ug/L compliance level.
- On May 6, 2009, DO calibration was not documented.
- On August 12, 2009, calibration of the low level chlorine meter was not documented.
- On September 14, 2009, low level chlorine was not reported on the DMR. A corrected DMR has since been submitted.
- On September 15, 2009, the submitted DMR did not document the numbers of hours that the ORC was on -site. A corrected DMR has since been
- On November 24, 2009, the DMR incorrectly reported a pH as 9.09, when the correct reading was 7.09. A corrected DMR has since been submitted.
NOTE that for low level chlorine readings and the DO readings reported above, all prior and post QC checks were satisfactory, and the equipment was within
calibration dates, so the readings should be accurate.
1 Check List for Annual WWTP Certification for DWQ.xls Shurtape Technologies, LLC
72664 Stony Point - Plant # 31
Summary of Review:
Annual Performance Test for Field Parameters: pH: Method 4500 H+B & TRC: Method 4500 CIG
Corning pH & YSI DO meters both have correction factors noted'on meters (current factor is 110").
Modified DMRs were submitted to address the issues described above for September and November.
On April 13-15, 2009, discrepancies existed between the low level chlorine records as recorded in the log book, in daily check sheets -
and on the DMR. The April 13th DMR reported low level chlorine of 21 ug/L, which agreed with the log book. However, both of
these disagreed with the daily check sheet, where 31 ug/L was recorded. On April 14th, the DMR reported <20 ug/L as the low level
chlorine concentration, which agreed with the daily check sheet. However, the log book indicated 31 ug/L on this day. Lastly, the
log book indicated <20 ug/L low level chlorine concentration on April:15th, however, the DMR, daily check sheet, and calibration
records indicate that no reading was obtained on April 15th. Since none of the possible readings were greater than the 50 ug/L
compliance level, Shurtape and DENR both agreed that a modified DMR was not required.
On February 16th; vendor records/invoice indicates that 2000 gallons of sludge were pumped and disposed. However, the log book
records this as happening on the 17th; instead of the 16th. It is suspected that the ORC wrote the event down on the wrong line.
Initial review was performed on January 8 and 9, 2010. Final review was completed on January 26, 2010
after submittal of the amended Wks.
Field Parameters Lab Certification No.: 5087 EPA Lab Code: NCO1311
Annual Performance Audit Completed: 8, 9, and 26 Jan 2010