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HomeMy WebLinkAboutNC0062961_NOD2021PC0403 & CEI Report_20210722 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. July 22, 2021 Judith Schwebke RCS Properties Email: samwotell@gmail.com SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2021-PC-0403 Permit No. NC0062961 Tynecastle WWTP Avery County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Tynecastle WWTP on July 7, 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. NC0062961. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency(s) was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Operations & Maintenance Excessive grease throughout the treatment plant is affecting multiple treatment units. _________________________________________________________________________________________________________________________________________________________________________ In addition, the issues below must also be addressed: Compliance Issue(s): See summary of inspection report for details. DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4 Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Stephanie Williams with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Brandon Hughes (ORC) DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4 EPA United States Environmental Protection Agency 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 Type Inspector Fac Type 1 N 52 NC0062961 21/07/07 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Tynecastle WWTP NC Hwy 105 Banner Elk NC 28604 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:30AM 21/07/07 18/01/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 12:30PM 21/07/07 22/09/30 Name, Address of Responsible Official/Title/Phone and Fax Number Judith Schwebke,4501 Tynecastle Hwy Banner Elk NC 28604//828-898-6246/8288986256 Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters 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 Lauren E Armeni DWR/ARO WQ/828-296-4500/ Stephanie A Williams DWR/ARO WQ/828-296-4500/ 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 DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4 7/22/2021 7/22/2021 7/22/2021 NPDES yr/mo/day 21/07/07 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Stephanie Williams and Lauren Armeni, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the Tynecastle WWTP on July 7, 2021. This inspection was conducted to determine if the system is being operated and maintained in compliance with NPDES permit no. NC0062961. Brandon Hughes (ORC) was present during the inspection. The wastewater treatment plant consists of an equalization basin, anoxic zone, dual train aeration basin with secondary clarifiers, and UV disinfection. There was a heavy load of grease and foam throughout the treatment plant; it appears that the collection system is not being properly maintained. Grease control is a requirement per 15 NCAC 02T .0403 (a)(8), and a program should be put in place to reduce the grease delivered to the WWTP. ORC: The current ORC is listed in our system as a backup ORC. An ORC designation form needs to be submitted. Security: The plant is in a parking lot of a popular restaurant and is approximately 50% surrounded by a privacy fence. Portions of the plant are not covered by grates, leaving basins partially open. Lack of adequate fencing in conjunction with open basins presents a safety issue that needs to be addressed. The plant should be entirely fenced in. Influent: The primary influent line is an aerial line and discharges into the EQ basin through the bar screen. There is a secondary pipe that delivers return water to the EQ basin from the splitter box. There appears to be an additional influent pipe tied into this pipe. Mr. Hughes was unsure where this secondary influent pipe comes from, but thought it may be tied into a residential property up on the hill. This influent pipe is not screened, and therefore a bar screen should be added to this influent. An investigation should be conducted to determine locations of all connections that discharge to the Collection System, including the source of this secondary influent pipe. Equalization Basin: At the time of the inspection, there was an excessive buildup of grease in the equalization basin, covering more than 25% of the surface. Inspectors recommended cleaning the grease from the basin and keeping the floats clean to preserve proper function. Mr. Hughes stated that he would have the grease pumped from all system components following the inspection. Secondary Clarifiers: Neither Clarifier had an obvious sludge blanket. Clarifier 1 had no clear supernatant and Clarifier 2 had a couple feet of clear supernatant. Most of the column on both Clarifiers appeared to consist of a mixture of grease and sludge. The surface of Clarifier 1 was covered approximately 80% by greasy foam; inspectors observed sheets of grease flowing over the weir and into the pipe that discharges into the UV system. Clarifier 2 was not in operation at the time of the inspection, and nearly 100% of the surface was covered in thick greasy foam. Disinfection: The UV disinfection consists of 4 bulbs which are cleaned every 2 weeks. The UV intensity and transmittance cannot be evaluated as the display does not work. It is recommended that the existing display be fixed, or a working display be installed. Extra bulbs are kept at the nearby office. Inspectors strongly recommend turning the system off prior to removing the bulbs for cleaning. Record Keeping: Inspectors did not find sufficient documentation of process controls. Proper record keeping would allow operators to track operational changes that are effective at maintaining the wastewater treatment plant. NC0062961 17 (Cont.) Page#2 DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4 Permit:NC0062961 Inspection Date:07/07/2021 Owner - Facility: Inspection Type: Tynecastle WWTP 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? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? The plant is not properly fenced. See summary for details.Comment: Operations & Maintenance Yes No NA NE 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? Basins are not adequately covered. The operator stated that process controls are measured, however no records were found reflecting this. See summary for details. Comment: 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? 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 operator 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? Page#3 DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4 Permit:NC0062961 Inspection Date:07/07/2021 Owner - Facility: Inspection Type: Tynecastle WWTP Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Comment: Equalization Basins Yes No NA NE Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? More than 25% of the surface was covered in grease. See summary for details.Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? Are surface aerators and mixers operational? Are the diffusers operational? 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? Is the DO level acceptable?(1.0 to 3.0 mg/l) Settleable solids in Aeration Basin 1 were measured at 83% after 30 minutes. Dissolved oxygen was measured at 4.6 mg/L in basin 1 and 5.1 mg/L in basin 2. Excessive foam was noted in both basins. Comment: Secondary Clarifier Yes No NA NE 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? Page#4 DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4 Permit:NC0062961 Inspection Date:07/07/2021 Owner - Facility: Inspection Type: Tynecastle WWTP Compliance Evaluation Secondary Clarifier Yes No NA NE 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 ¼ of the sidewall depth) Both clarifiers contained excessive foam and grease and had unacceptable sludge blanket levels. See summary for details. Comment: Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? Are UV bulbs clean? Is UV intensity adequate? Is transmittance at or above designed level? Is there a backup system on site? Is effluent clear and free of solids? UV intensity and transmittance cannot be evaluated because the display is broken. See summary for details. In the event of UV system failure the operator intends to use chlorination and dechlorination tablets which are available in the office near the WWTP. Comment: Aerobic Digester Yes No NA NE 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? The operator stated he wastes from clarifier 2 once per month. Wasting from Clarifier 1 must be done manually. The digester was nearly full and was not aerated at the time of the inspection to allow the sludge to settle in order to be removed. Comment: Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? Page#5 DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4 Permit:NC0062961 Inspection Date:07/07/2021 Owner - Facility: Inspection Type: Tynecastle WWTP Compliance Evaluation Effluent Pipe Yes No NA NE If effluent (diffuser pipes are required) are they operating properly? The effluent pipe discharges into a storm drain which has a discharge point in the stream across the road. Comment: Effluent Sampling Yes No NA NE 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)? At the time of the inspection, samples were not collected below all treatment units, the tubing was not clean, and there was no thermometer in the sampler. The operator fixed these issues the following week. The sampler was not set for flow proportional sampling at the time of the inspection, and Mr. Hughes fixed this while inspectors were on site. Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Comment: Page#6 DocuSign Envelope ID: E69F32FA-3EB8-4B54-A536-93C14C0B41C4