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Home My WebLink AboutNC0029297_Compliance Evaluation Inspection_20201221ROY COOPER Governor MICHAEL S. REGAN Secretary S. DANIEL SMITH Director NORTH CAROLINA Environmental Quality December 21, 2020 CERTIFIED MAIL #: 7019 1120 0000 8361 1725 RETURN RECEIPT REQUESTED Robert Hoyle, Director of Construction & Maintenance Catawba County Schools PO Box 1010 Newton, North Carolina 28658 Subject: Dear Mr. Hoyle: Notice of Violation/Notice of Recommendation for Enforcement Compliance Evaluation Inspection Fred T. Foard High School WWTP NPDES Permit No. NCO029297 Catawba County Tracking #: NOV-2020-PC-0533 Enclosed is a copy of the Compliance Evaluation Inspection Report for the inspection conducted at the subject facility on December 2, 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)/Notice of Recommendation for Enforcement (NRE) due to the following: - High water alarm (audible and visual) did not properly operate (third consecutive inspection with this violation); - Flow measurements are not being performed properly (third consecutive inspection with this violation); - Inadequate disinfection during low flows (second consecutive inspection with this violation); - Filter bed sand was bound with solids and clay/dirt (second consecutive inspection with this violation); - Several lateral distribution sections were warped (second consecutive inspection with this violation). Please be advised that these continued failures to properly maintain the wastewater treatment facility and measure flow are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1 as detailed in the Sand Filter/Low Rate, Disinfection/Tablet and Flow Measurement 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 violations. �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 NOR7�CARCLINAI i �,"rJ J m Em^'m'"^e^ai Qmli /`� 704.663.1699 Mr. Robert Hoyle December 21, 2020 Page Two This letter is also to advise you that this Office is considering the initiation of an enforcement action for the violations of G.S. 143-215.1 and NPDES Permit No. NC0029297. If you have an explanation for the violations that you wish to present, please include it in the written response. The written response and any additional information (corrective actions, etc.) you wish to provide regarding these violations must be received by this Office by January 11, 2021. 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.bellgncdenr.gov. Sincerely, Docu Signed by: 4d4tV i1 PU4,f . for F161FB69A2D84A3... 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 NCO029297 I11 121 20/12/02 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) 12:46PM 20/12/02 20/09/01 Fred T. Foard High School 3407 Plateau Rd NCSR 2036 Exit Time/Date Permit Expiration Date Newton NC 28658 01:18PM 20/12/02 25/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Joshua Steven Greene/ORC/828-396-4444/ Morgan C Williams//828-464-3562 ext 403/8284654442 Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Hoyle,PO Box 1010 Newton NC 286581010/Director of Construction & Maintenance/828-464-3562/8284654442 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 signed by: DWR/MRO WQ/704-663-1699 Ext.2192/ 12/16/2020 2 re& E�Docu`,','�96D90=437 ... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Num erS Docusigned by: Date Andrew Pitner DWR/MRO WQ/704-663-1699 Ext.2180/ A".4" H Nuft 12.21.2020 F161FB69A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO029297 I11 12I 20/12/02 117 18 I c Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCO029297 Owner - Facility: Fred T. Foard High School Inspection Date: 12/02/2020 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 10/2/18. 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: NCO029297 Inspection Date: 12/02/2020 Record Keeping Owner - Facility: Fred T. Foard High School Inspection Type: Compliance Evaluation Yes No NA NE Comment: The records reviewed durina the insDection were oraanized and well maintained. Discharae Monitoring Reports (eDMRs) were reviewed for the period October 2019 through Septembel 2020. No effluent limit violations were reported and all monitoring frequencies were correct. The ORC had mixed up the arrival times and collection and analysis times during effluent sampling events. The ORC must ensure to properly document all self -monitoring data as required by the subject permit. In addition, the ORC must also ensure that all operation and maintenance activities (including activities performed by school staff) are documented. The April, May and June 2020 eDMRs were not completed correctly to reflect the no flow conditions at the facility during selected weeks/months. These eDMRs will be revised and 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: Effluent analyses (all permit -required parameters including field) are performed under Water Tech Labs' certification #50. 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. Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ 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? Page# 4 Permit: NCO029297 Owner - Facility: Fred T. Foard High School Inspection Date: 12/02/2020 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Comment: The facility was not being properly operated and maintained. Operational issues associated with the high level alarm system has been noted in the previous two inspections (5/3/17 and 10/2/18). The tablet chlorination system not providing adequate disinfection during low flow: was also noted in the previous inspection. The warped laterals and "spent" sand were also noted in the complaint investigation (and resulting Notice of Violation) on 9/26/2019. The permittee/School System has also failed to provide an adequate flow measurement device/method as has been requested in the previous two inspections. Please see Sand Filter/Low Rate, Disinfection/Tablet and Flow Measurement/Effluent Sections for additional comments. Septic Tank Yes No NA NE (If pumps are used) Is an audible and visual alarm operational? ❑ ❑ MEI Is septic tank pumped on a schedule? 0 ❑ ❑ ❑ Are pumps or syphons operating properly? M ❑ ❑ ❑ Are high and low water alarms operating properly? ❑ ❑ 0 ❑ Comment: The septic tank and recirculation tank are pumped out every summer by a contracted company (Leatherman's Septic Tank Service). Sodium bicarbonate is added at the school by custodial staff to maintain appropriate alkalinity/pH levels. Sand Filters (Low rate) Yes No NA NE (If pumps are used) Is an audible and visible alarm Present and operational? ❑ 0 ❑ ❑ Is the distribution box level and watertight? ❑ ❑ 0 ❑ Is sand filter free of ponding? ❑ ❑ ❑ Is the sand filter effluent re -circulated at a valid ratio? 0 ❑ ❑ ❑ # Is the sand filter surface free of algae or excessive vegetation? 0 ❑ ❑ ❑ # Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1) 0 ❑ ❑ ❑ Comment: The facility was not dosing at the time of the inspection. The audible alarm did not work when activated by the test button and the alarms (audible and visual) were not activated when the float was triggered. The alarm system must be repaired/replaced. Several laterals were warped and the sand was bound with solids and clay/dirt. All warped laterals must be replaced and all "spent" sand must be removed and replaced with appropriately sized sand. 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 Maintenancel. In addition, the ORC must become familiar with all treatment components (including floats, etc.) at this facility. 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 Page# 5 Permit: NCO029297 Inspection Date: 12/02/2020 Owner - Facility: Fred T. Foard High School Inspection Type: Compliance Evaluation Disinfection -Tablet Yes No NA NE Is the level of chlorine residual acceptable? ❑ 0 ❑ ❑ Is the contact chamber free of growth, or sludge buildup? M ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ 0 ❑ ❑ Comment: Calcium hvDochlorite tablets are used for disinfection. No chlorine residual was detected in the chlorine contact chamber. A two-inch gap was observed between the lowest tablet (in the sleeves) and wastewater flow which prevented adequate disinfection during the lower flow conditions. The facility must provide adequate disinfection during all flow conditions. 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]. 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 Comment: Sodium sulfite tablets are used for dechlorination. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ 0 ❑ ❑ Is flow meter calibrated annually? ❑ ❑ 0 ❑ Is the flow meter operational? ❑ ❑ 0 ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ MEI Comment: The flows reported on the eDMRs (Dast and Dresent) were not based on an aDDroved flow measurement device and/or method. Flows have been estimations and consistently reported as low as 0.00006 mqd (60 gallons per day) prior to the June 2020 eDMR. A new ORC was designated in June 2020 and the flows have been consistently estimated at 0.001 MGD (1,000 gallons per day). Please be advised that the permittee must select the appropriate flow measurement devices and methods consistent with accepted scientific practices to ensure the accuracy and reliability of measurements of the volume of monitored discharges [Permit Reference: Part Il, Section D(3) Flow Measurements]. Effluent Pipe Is right of way to the outfall properly maintained? Yes No NA NE ■ ❑ ❑ ❑ Page# 6 Permit: NC0029297 Inspection Date: 12/02/2020 Effluent Pipe Owner - Facility: Fred T. Foard High School Inspection Type: Compliance Evaluation 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: The effluent appeared clear with no floatable solids or foam. Yes No NA NE ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ Page# 7