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Home My WebLink AboutNC0021849_Inspection_20210224March 11, 2021 Pamela Hurdle Town of Hertford 324 W Grubb St Hertford, NC 27944 SUBJECT: Compliance Inspection Report Hertford WWTP NPDES WW Permit No. NC0021849 Perquimans County Dear Mrs. Hurdle: The North Carolina Division of Water Resources conducted an inspection of the Hertford WWTP on 2/24/2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0021849. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". Please respond in writing to this office within 30 days of your receipt of this letter regarding your plans or measures to be taken to address the following issues: During the inspection on 02/24/2020 one of the two automatic disk filters described in NPDES permit #NC0021849 was not operational and was also down during the previous inspection on 08/19/2020. The automatic disk filter that was operational during the inspection was being heavily bypassed. This is a violation of permit conditions: Section C Condition 2, Section C Condition 4.C, Section E Condition 6 and Section E Condition 9. An unauthorized bypass of unknown quantity was found nearby the aerobic digestors during the inspection. A sludge strip was observed that was roughly 100ft in length and loft across at its widest point. The ORC stated that the unauthorized bypass took place on 11/19/2020 during the last sludge haul. The bypass was never reported to WARO and was required to be reported to WARO within 24 hours as required by NPDES permit #NC0021849. This is a violation of the following permit conditions: Section B Condition 2, Section E Condition 6 and Section E condition 9. If you should have any questions, please do not hesitate to contact Paul Mays with the Water Quality Regional Operations Section in the Washington Regional Office at 252-946-6481 or via email at paul.mays@ncdenr.gov. Sincerely, ATTACHMENTS Cc: Laserfiche PSI glitzy Paul Mays, Environmental Specialist I Water Quality Regional Operations Section Washington Regional Office Division of Water Resources, NCDEQ P rtmx tE a:E 3 SyLs, .a 25_$6£ 451 st United States Environmental Protection Agency E PA Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yr/mo/day Inspection 1 IN I 2 15 I 3 I NC0021849 111 121 21/02/24 117 Type 181r�I u1 1I Inspector Fac Type 191S I 20I 21IIII I I 1II III I I I I I 1 i i i i i I 1 1 mil III I I I I r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67 [ I 70 I I 711 1 72 I N I 731 I 1741 799 I I I I I I I80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES oermit Number) Hertford WWTP 114 W Grubb St Hertford NC 27944 Entry Time/Date 10:OOAM 21/02/24 Permit Effective Date 18/07/01 Exit Time/Date 11:15AM 21/02/24 Permit Expiration Date 22/12/31 Name(s) of Onsite Representative(s)rtles(s)/Phone and Fax Number(s) /// Charles Anderson Jones/ORC/252-333-6948/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Pamela Hurdle,324 W Grubb St Hertford NC 27944/Town Manager/252-426-1969/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 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 Robert E Bullock DWR/Division of Water Quality/252-948-3924/ Paul M Mays DWR/WARO WQ/252-948-3940/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 NPDES yr/mo/day Inspection Type 3I Nc0021849 in 12I 21/02/24 117 18 r` I (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On 0/24/2021 Paul Mays and Robert Bullock with the Water Quality Regional Office Operations Sectior from the Washington Regional Office conducted an inspection of Hertford WWTP. The facility was found to be noncompliant with permit #NC0021849. Below are the findings during the inspection. Permit expires 12/31/2022 September 2020 eDMR was spot checked with no discrepancies. The 2020 annual compliance report will be submitted in March 2021. The 2019 annual compliance report and 2018 annual compliance report was reviewed during the inspection. Sludge hauling records were also reviewed with the ORC. The ORC stated that the facility tried to haul once a year. The last time the facility hauled sludge was on 11/19/2020 where 189,000 gallons of sludge was hauled by Granville Farms Inc. The high-water alarm Influent pump station was working and tested during inspection. However, the staff told the inspectors that SCADAwas down. The influent composite sampler is set to collect 170m1 samples every 15 minutes. The tubing had algae growing in it and was not clean. The ORC stated the tubing would be replaced soon. Influent flowmeter was calibrated on 02/11/2021 by Delta Systems Environmental. The duel mechanical bar screens were not being used at the time of inspection and the manual bar screens were being used. The ORC stated that the motors in the mechanical bar screens need to be replaced and that the facility was in a process of acquiring new motors for the mechanical bar screen. An unauthorized bypass of unknown quantity was found near the aerobic digestors during the inspection. A strip of sludge that was approximately 100ft in length and 10ft across at its widest point was noted. The ORC stated the bypass took place on November 19, 2020 during the last sludge haul. It is also worth noting that the bypass was not reported to WARO within 24 hours as required by NPDES permit #NC0021849. This is a violation of the following permit conditions Section B Condition 2, Section E Condition 6 and Section E condition 9 The generator was tested during the inspection and was found to be completely operational. The ORC stated that the generators have the capacity to only run 80% of the plant. This includes all major components of the wastewater plant except the blowers in the oxidation ditch or the pumphouse. Both clarifiers seemed to be in good working order at the time of inspection. However, some pin floc could be seen going over the weirs in both clarifiers. The ORC was asked to use the sludge judge to measure the sludge blanket in both clarifiers. The clarifier closest to the aerobic digestor had a sludge blanket of 3ft and the other clarifier had a sludge blanket of approximately 2.5ft. The facility has two automatic disk filters. One filter was not functioning at the time of inspection. The disk filter that was functioning was being heavily bypassed at the time of inspection. This is a violation of permit conditions Section C Condition 2, Section C Condition 4.C, Section E Condition 6 and Sectior E Condition 9. The effluent in the chlorine contact chamber was cloudy and the bottom could not be seen. The ORC was requested to use a sludge judge in the chlorine contact chamber. There was a blanket of sludge approximately 8inches close to the tertiary filter in the chlorine contact chamber. There was sludge found at the bottom near the effluent pump station. Page# 2 Permit: NC0021849 Owner - Facility: Hertford W WTP Inspection Date: 02/24/2021 Inspection Type: Compliance Evaluation De -chlorination is feed in a greater ratio than 1 to 1. This is due to potable water being used to introduce gaseous chlorine to the effluent. Effluent meter was calibrated on 02/11/2021 by Delta Systems Environmental. The ORC stated that each sample by the effluent composite samples are each over 100m1. Sampling is not flow proportional and samples are obtained in 15-minute increments. Page# 3 Permit: NC0021849 Owner - Facility: Hertford WWTP Inspection Date: 02/24/2021 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 ❑ ❑•❑ application? Is the facility as described in the permit? •❑ ❑ ❑ # Are there any special conditions for the permit? MOOD Is access to the plant site restricted to the general public? •❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ❑ ❑ ❑ Comment: Permit expires 12/31/2022 Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? •❑ ❑ ❑ Is all required information readily available, complete and current? MOOD Are all records maintained for 3 years (lab. reg. required 5 years)? M ❑ ❑ ❑ Are analytical results consistent with data reported on DMRs? •❑ ❑ ❑ Is the chain -of -custody complete? • ❑ ❑ ❑ Dates, times and location of sampling 0 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? 11000 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? • DOD Is the ORC certified at grade equal to or higher than the facility classification? MOOD 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? • ODD Facility has copy of previous year's Annual Report on file for review? •❑ ❑ ❑ Comment: September 2020 eDMR was spot checked with no discrepancies. The 2020 annual compliance report will be submitted in March 2021. The 2019 annual compliance report and 2018 annual compliance report was reviewed during the inspection. Sludge hauling records were also reviewed with the ORC. The ORC stated that the facility tried to haul once a year. The last time the facility hauled sludge was on 11/19/2020 where 189,000 gallons of sludge was hauled by Granville Farms Inc. Page# 4 Permit: NC0021849 Inspection Date: 02/24/2021 Owner - Facility: Hertford wwTP Inspection Type: Compliance Evaluation Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Pump Station - Influent Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Is audible and visual alarm available and operational? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑• Yes No NA NE ▪ ❑ ❑ ❑ ❑ ❑ ❑• • ❑ ❑ ❑ MOOD ■ ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ Comment: The high-water alarm Influent pump station was working and tested during inspection. However, the staff told the inspectors that SCADA was down. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑•❑ ❑ Is sample collected above side streams? •❑ ❑ ❑ 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 sampling performed according to the permit? MODE Comment: The influent composite sampler is set to collect 170m1 samples every 15 minutes. The tubing had algae growing in it and was not clean. The ORC stated the tubing would be replaced soon. Grit Removal Type of grit removal a.Manual b. Mechan ical Is the grit free of excessive organic matter? Is the grit free of excessive odor? # Is disposal of grit in compliance? Yes No NA NE • • • ❑ ❑ ❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ Page# 5 Permit: NC0021849 Owner -Facility: Hertford WWTP Inspection Date: 02/24/2021 Inspection Type: Compliance Evaluation Grit Removal Yes No NA NE Comment: The duel mechanical bar screens were not being used at the time of inspection and the manual bar screens were being used. The ORC stated that the motors in the mechanical bar screens need to be replaced and that the facility was in a process of acquiring new motors for the mechanical bar screen. 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? Yes No NA NE MO DO i•❑ ❑❑ • ❑ ❑ ❑ ▪ ❑ ❑ ❑ • ❑ ❑ ❑ Comment: An unauthorized bypass of unknown quantity was found near the aerobic digestors during the inspection. A strip of sludge that was approximately 100ft in length and 10ft across at its widest point was noted. The ORC stated the bypass took place on November 19, 2020 during the last sludge haul. It is also worth noting that the bypass was not reported to WARC within 24 hours as required by NPDES permit #NC0021849. Drying Beds Is there adequate drying bed space? Is the sludge distribution on drying beds appropriate? Are the drying beds free of vegetation? # Is the site free of dry sludge remaining in beds? Is the site free of stockpiled sludge? Is the filtrate from sludge drying beds returned to the front of the plant? # Is the sludge disposed of through county landfill? # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ i• ❑❑ • ❑ ❑ ❑ 11000 ❑ ❑ ❑i• • ❑ ❑ ❑ i•❑ ❑❑ ❑ ❑ ❑• Comment: An unauthorized bypass of unknown quantity was found near the aerobic diqestors during the inspection. A strip of sludge that was approximately 100ft in length and 10ft across at its widest point was noted. The ORC stated the bypass took place on November 19, 2020 during the last sludge haul. It is also worth noting that the bypass was not reported to WARC within 24 hours as required by NPDES permit #NC0021849. Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Yes No NA NE • ❑ ❑ ❑ ❑ • ❑ ❑ i•❑ ❑❑ Page# 6 Permit: NC0021849 Owner - Facility: Hertford W WTP Inspection Date: 02/24/2021 Inspection Type: Compliance Evaluation Standby Power 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 • ❑ ❑ ❑ ❑•❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The generator was tested during the inspection and was found to be completely operational. The ORC stated that the generators have the capacity to only run 80% of the plant. This includes all major components of the wastewater plant except the blowers in the oxidation ditch or the pumphouse. Oxidation Ditches Are the aerators operational? Are the aerators free of excessive solids build up? # Is the foam the proper color for the treatment process? Does the foam cover less than 25% of the basin's surface? Is the DO level acceptable? Are settleometer results acceptable (> 30 minutes)? Is the DO level acceptable?(1.0 to 3.0 mg/I) Are settelometer results acceptable?(400 to 800 ml/I in 30 minutes) Comment: 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 1/4 of the sidewall depth) Yes No NA NE • ❑ DO • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ O DOM ❑ ❑ ❑• ❑ ❑ ❑• Yes No NA NE ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ Page# 7 Permit: NC0021849 Owner - Facility: Hertford WWTP Inspection Date: 02/24/2021 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Comment: Both clarifiers seemed to be in good working order at the time of inspection. However, some pin floc could be seen going over the weirs in both clarifiers. The ORC was asked to use the sludge fudge to measure the sludge blanket in both clarifiers. The clarifier closest to the aerobic digestor had a sludge blanket of 3ft and the other clarifier had a sludge blanket of approximately 2.5ft. Pumps-RAS-WAS Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Comment: Filtration (High Rate Tertiary) Type of operation: 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑• Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑•❑ DEMO • ❑•❑ Comment: The facility has two automatic disk filters. One filter was not functioning at the time of inspection. The disk filter that was functioning was being heavily bypassed at the time of inspection. Disinfection -Gas Are cylinders secured adequately? Are cylinders protected from direct sunlight? Is there adequate reserve supply of disinfectant? 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? Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? If yes, then is there a Risk Management Plan on site? If yes, then what is the EPA twelve digit ID Number? (1000- If yes, then when was the RMP last updated? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑•❑ ❑ • ❑ ❑ ❑ ❑•❑ ❑ ❑ ❑ ❑• Page# 8 Permit: NC0021849 Inspection Date: 02/24/2021 Owner - Facility: Hertford W WTP Inspection Type: Compliance Evaluation Disinfection -Gas Yes No NA NE Comment: The effluent in the chlorine contact chamber was cloudy and the bottom could not be seen. The ORC was requested to use a sludge judge in the chlorine contact chamber. There was a blanket of sludge approximately flinches close to the tertiary filter in the chlorine contact chamber. There was sludge found at the bottom near the effluent pump station. 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 ❑•❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ U ❑ Comment: De -chlorination is feed in a greater ratio than 1 to 1. This is due to potable water being used to introduce gaseous chlorine to the effluent. Are tablet de -chlorinators operational? Number of tubes in use? Comment: N/A 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? • ❑•❑ 0 Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑• Comment: Effluent meter was calibrated on 02/11/2021 by Delta Systems Environmental. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑•❑ ❑ Is sample collected below all treatment units? 1.1000 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 M000 Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ ❑ ❑ representative)? Comment: The ORC stated that each sample by the effluent composite samples are each over 100m1. Sampling is not flow proportional and samples are obtained in 15-minute increments. Page# 9 Permit: NC0021849 Inspection Date: 02/24/2021 Owner - Facility: Hertford wwrP Inspection Type: Compliance Evaluation Pump Station - Effluent Yes No NA NE Is the pump wet well free of bypass lines or structures? •❑ ❑ ❑ Are all pumps present? • ❑ ❑ ❑ Are all pumps operable? •❑ ❑ ❑ Are float controls operable? ❑ ❑ ❑ Is SCADA telemetry available and operational? ❑•❑ ❑ Is audible and visual alarm available and operational? ❑ ❑ ❑• Comment: SCADA was down at the time of inspection. Page# 10