NC0081281_NOV-2011-PC-0521_20110927

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NCDENR — DIVISION WATER QUALITY
ATTN: PAUL RAWLS
225 GREEN STREET, SUITE 714=,;�;, q,_ FAYETTEVILLE NC 28301-5043 L�J`�u `'� irk)
SEP3 0 2011
in
OwQ
17ili I I i 111,1111; 11111 11111 Il i 111111 Ii 111111 ij 511 i iii 111 1 i{

Beverly Eaves Perdue
Governor
VA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Coleen H. Sullins
Director
September 27, 2011
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
7008 1300 0001 1492 2583
Bryan Land, Public Works Director
County of Richmond
Post Office Box 504
Rockingham, North Carolina 28380
SUBJECT: Notice of Violation and Compliance Evaluation Inspection (NOV-2011-PC-0521)
Richmond County Water Treatment Plant
NPDES Permit No: NC0081821
Richmond County
Dear Mr. Land:
This letter conveys a Notice of Violation and Compliance Evaluation Inspection report for the inspection
conducted September 22, 2011 by Paul Rawls of my staff. The time and effort put forth by Mr. Locklear,
Operator in Responsible Charge (ORC), during the inspection is greatly appreciated. The following items
represent violations of your permit as well as other comments pertaining to the inspection. Requested action
should be taken as indicated and the County is asked to provide a written response on or before October 10,
2011.
Improper Operation and Maintenance of PollutionControls.
During the inspection it was noted that there was visible solids in the receiving stream, an unnamed tributary to
the Pee Dee River. The solids were believed to have originated from the County Water Treatment Plant located
at 326 Old Charlotte Highway, Richmond County. This matter was discussed with Mr. Locklear at the time of
the inspection and is considered a violation of NPDES Permit No. NC0081821 (Permit).
Discharge of wastewater solids in a manner that covers part or the entire stream bed is considered a violation of
Part II, (Operation and Maintenance of Pollution Controls), Section C (Operation and Maintenance of Pollution
Controls), Number 2 of your Permit states:
The Permittee shall at all times provide the operation and maintenance resources necessary to operate the existing facilities
at optimum efficiency. The Permittee shall at all times properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with
225 Green St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone] FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity i Affirmative Action Employer
NorthCarolina
Naturally

Mr. Land
September 27, 2011
Page 2 of 3
the conditions of this permit. Proper operation and maintenance also includes adequate laboratory controls and
appropriate quality assurance procedures. This provision requires the Permittee to install and operate backup or auxiliary
facilities only when necessary to achieve compliance with the conditions of the permit [40,CFR 122.41 (e)].
and can also be a violation of 15A NCAC 02B .0211 (2) Fresh Surface Water Quality Standards for Class C
Waters which states:
"Conditions Related to Best Usage: the waters shall be suitable for aquatic life propagation and maintenance of biological
integrity, wildlife, secondary recreation, agriculture and agriculture. sources of water pollution which preclude any of
these uses on either a short-term basis shall be considered to be violation a water quality standard;"
The County is asked to review and modify as necessary the operation and maintenance of wastewater treatment
facility to prevent further discharges of solids that can cause impacts to the receiving stream. The County is
further asked to provide a plan -of -action that will insure proper operation and maintenance of wastewater
facilities to maintain compliance and protect surface waters.
Also observed during the inspection was wastewater solids being stored in a uncovered area adjacent to the belt
press building. The solids were being stored in a manner that could be washed into a nearby storm drain in the
event of rain. Mr. Locklear was asked to address the matter immediately and he indicated the material would be
placed container and/or covered that day. The storage of wastewater solids as described is considered to be a
violation Part II, Section C , Number 6 and Part II, Section C, Number 2 of your Permit (both of these permit
conditions are described in detail in other parts of this report).
Visible Solids In The Receiving Stream.
As noted above during the inspection it was noted that there was visible solids in the receiving stream an
unnamed tributary to the Pee Dee River. As noted before this matter was discussed with Mr. Locklear at the
time of the inspection and is considered a violation your Permit.
Part II (Standard Conditions For NPDES Permits), Section C (Operation and Maintenance of Pollution
Controls), Number 6 (Removed Substances) of your permit states:
00714
Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in the course of treatment or control of wastewaters shall be
utilized/disposed of in accordance with NCGS 143-215.1 and in a manner such as to prevent any pollutant from such
materials from entering waters of the State or navigable waters of the United States. The Permittee shall comply with all
existing Federal regulations governing the disposal of sewage sludge. Upon promulgation of 40 CFR Part 503, any permit
issued by the Permit Issuing Authority for the utilization/disposal of sludge may be reopened and modified, or revoked
and reissued, to incorporate applicable requirements at 40 CFR 503. The Permittee shall comply with applicable 40 CrR
503 Standards for the Use and Disposal of Sewage Sludge (when promulgated) within the time provided in the regulation,
even if the permit is not modified to incorporate the requirement. The Permittee shall notify the Permit Issuing Authority
of any significant change in its sludge use or disposal practices.
Solids were observed to be confined to the immediate channel of the stream and ranged in depth from zero to
several inches. During the discussion Mr. Locklear indicated that removal of the solids may cause more damage
to the stream system than natural attenuation. The County is asked to perform a survey of the receiving stream
from the point of discharge downstream to a point that solids are no longer visible. The survey should include
225 Green St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone]FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
NorthCarolina
Naturally

Mr: Land''
September 27, 2011
Page3of3
but not necessarily be limited to, a map depicting the route of the stream, points where solids are observed from
the point of discharge downstream to a point that solids are no longer visible, the depth of solids and in the
opinion of the County if at any point solids removal could be performed without further damage to the stream
system.
Please note that the Division of Water Quality cannot grant the County access to private property. The County
should obtain permission from each property owner prior to entering the property to conduct the survey.
Total Residual Chlorine Monitoring/Reporting
It was noted that Total Residual Chlorine monitoring results were on many occasions reported as <17 ug/1. It
was learned that that the < (less than value) was being used as on many occasions the results from onsite testing
yielded a value of <17 ug/1, the limit for Total Residual Chlorine. This matter was discussed with Mr. Locklear.
Specifically number 2 of the Notes: at the bottom of A.(1.) Effluent Limitation and Monitoring Requirements
page of your permit states, in part, "However, the Permittee shall continue to record and submit all values
reported by North Carolina certified field and lab test methods, if the values fall below." We ask that the County
report values above the established curve for the test as the actual value obtained and utilize the < value only
when results are recorded below the established test curve. This matter is not considered a violation of your
permit but the County should correctly report test values in the future. Also in lieu of providing
revised/corrected Discharge Monitoring Reports (DMRs) please keep a copy of this report with your bench
notes should this matter be discussed in future inspections.
All other areas of the permit, records and site review covered during the inspection were found compliant.
Again, the County is asked to take action as indicated and to provided a written response on or before October
10, 2011.
Please refer to the enclosed inspection report for additional observations and comments. If you or your staff has
questions or comments pertaining to the inspection please do not hesitate to contact Mr. Paul Rawls at (910)
433-3300.
Sincerely,
Belinda S. Henson
Regional Supervisor
Surface Water Protection Section
BSH/per/per
Enclosure: Inspection Report
cc: Matthew Locklear , ORC Richmond County Water Treatment Plant
1 ° U OVILF0 11413a3 W
DWQ Central Files
225 Green St., Suite 714, Fayetteville, NC 28301-5043
Phone: [phone]FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity l Affirmative Action Employer
NorthCarolina
Naturally

•
United States Environmental Protection Agency
EPA 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 I NI 2 151 31 NC0081281 111 121 11/09/22 117
Type Inspector Fac Type
18I CI 191sI 201
11111111111111166
Remarks
2111111111 1111111111111111.1111 1111
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA ---Reserved------ ------ ------
671 169 _7° 121 71 11 721 N I 731174 751 1 1 1 1 1 1 180
1
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Richmond County WTP
326 Old Charlotte Hwy
Rockingham NC 28379
Entry Time/Date
10:05 AM 11/09/22
Permit Effective Date
09/04/01
Exit Time/Date
12:25 PM 11/09/22
Permit Expiration Date
14/02/28
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Matthew Locklear/ORC/910-997-8339/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Todd Tillis,PO Box 504 Rockingham NC Contacted
28380/Superintendent/910-997-8339/9109978340 No'
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Operations & Maintenance Records/Reports Self -Monitoring Program
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
Paul E Ra .caJ - Division of Water Quality//919-733-5083/ -.2L"1LZ;t
Signature of Management Q AReview/rr��} //� �}i/, Agency/Office/Phone and Fax Numbers Date / J
Belinda S Henson f ,/./'L/�/!!�.' .X%./ `r l,Lil'I rY `-' FRO WQ//910-433-3300 Ext.726/ �� — 27 - l 1
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

NPDES yr/mo/day Inspection Type
31 NC0081281 /11 121
11/09/22 117 181 C I
(cont.) 1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
This letter/report conveys a Notice of Violation and Compliance Evaluation Inspection report for the
inspection conducted September 22, 2011 by Paul Rawls of the Division of Water Quality Fayetteville
Regional Office.
The time and effort put forth by Mr. Locklear, Operator in Responsible Charge (ORC), during the inspection
is greatly appreciated.
The following items represent violations of the permit as well as other comments pertaining to other areas of
the inspection.
Requested action should be taken as requested and the County is asked to provide a written response on
or before October 10, 2011.
Improper Operation and Maintenance of Pollution Controls.
During the inspection it was noted that there was visible solids in the receiving stream, an unnamed tributary
to the Pee Dee River. The solids were believed to have originated from the County Water Treatment Plant
located at 326 Old Charlotte Highway, Richmond County. This matter was discussed with Mr. Locklear at
the time of the inspection and is considered a violation of NPDES Permit No. NC0081821 (Permit).
Discharge of wastewater solids in a manner that covers part or the entire stream bed is considered a
violation of Part II, (Operation and Maintenance of Pollution Controls), Section C (Operation and
Maintenance of Pollution Controls), Number 2 of your Permit states:
The Permittee shall at all times provide the operation and maintenance resources necessary to operate the
existing facilities at optimum efficiency. The Permittee shall at all times properly operate and maintain all
facilities and systems of treatment and control (and related appurtenances) which are installed or used by
the Permittee to achieve compliance with the conditions of this permit. Proper operation and maintenance
also includes adequate laboratory controls and appropriate quality assurance procedures. This provision
requires the Permittee to install and operate backup or auxiliary facilities only when necessary to achieve
compliance with the conditions of the permit [40 CFR 122.41 (e)].
and can also be a violation of 15A NCAC 02B .0211 (2) Fresh Surface Water Quality Standards for Class C
Waters which states:
"Conditions Related to Best Usage: the waters shall be suitable for aquatic life propagation and
maintenance of biological integrity, wildlife, secondary recreation, agriculture and agriculture. sources of
water pollution which preclude any of these uses on either a short-term basis shall be considered to be
violation a water quality standard;"
The County is asked to review and modify as necessary the operation and maintenance of wastewater
treatment facility to prevent further discharges of solids that can cause impacts to the receiving stream. The
County is further asked to provide a plan -of -action that will insure proper operation and maintenance of
wastewater facilities to maintain compliance and protect surface waters.
Also observed during the inspection was wastewater solids being stored in a uncovered area adjacent to the
belt press building. The solids were being stored in a manner that could be washed into a nearby storm
drain in the event of rain. Mr. Locklear was asked to address the matter immediately and he indicated the
material would be placed container and/or covered that day. The storage of wastewater solids as described
is considered to be a violation Part II, Section C , Number 6 and Part II, Section C, Number 2 of your Permit
(both of these permit conditions are described in detail in other parts of this report).
Visible Solids In The Receiving Stream.
As noted above during the inspection it was noted that there was visible solids in the receiving stream an
unnamed tributary to the Pee Dee River. As noted before this matter was discussed with Mr. Locklear at the
time of the inspection and is considered a violation your Permit.
Page # 2

Permit: NC0081281 Owner - Facility: Richmond County WTP
Inspection Date: 09/22/2011 Inspection Type: Compliance Evaluation
Part II (Standard Conditions For NPDES Permits), Section C (Operation and Maintenance of Pollution
Controls), Number 6 (Removed Substances) of your permit states:
Removed Substances Solids, sludges, filter backwash, or other pollutants removed in the course of
treatment or control of wastewaters shall be utilized/disposed of in accordance with NCGS 143-215.1 and in a
manner such as to prevent any pollutant from such materials from entering waters of the State or navigable
waters of the United States. The Permittee.shall comply with all existing Federal regulations governing the
disposal of sewage sludge. Upon promulgation of 40 CFR Part 503, any permit issued by the Permit Issuing
Authority for the utilization/disposal of sludge may be reopened and modified, or revoked and reissued, to
incorporate applicable requirements at 40 CFR 503. The Permittee shall comply with applicable 40 CFR
503 Standards for the Use and Disposal of Sewage Sludge (when promulgated) within the time provided in
the regulation, even if the permit is not modified to incorporate the requirement.The Permittee shall notify
the Permit Issuing Authority of any significant change in its sludge use or disposal practices.
While visible the solids observed were confined to the immediate channel of the stream and ranged in depth
from zero to several inches. During the discussion Mr. Locklear indicated that removal of the solids may
cause more damage to the stream system than natural attenuation. The County is asked to perform a
survey of the stream from the point of discharge downstream to a point that solids are no longer visible. A
written report should be furnished to this office to include a map depicting the route of the stream and points
where solids are observed to include the depth of solids. Also, the report should outline in the opinion of the
County if at any point solids removal could be performed without further damage to the stream system.
Please note that the Division of Water Quality cannot grant the County access to private property. The.
County should obtain permission from each property owner prior to entering the property.
Total Residual Chlorine Monitoring/Reporting
It was noted that Total Residual Chlorine monitoring results were on many occasions reported as <17 ug/I. It
was learned that that the < (less than value) was being used as on many occasions the results from onsite
testing yielded a value of <17 ug/I, the limit for Total Residual Chlorine. This matter was discussed with Mr.
Locklear. Specifically number 2 of the Notes: at the bottom of A.(1.) Effluent Limitation and Monitoring
Requirements page of your permit states, in part, "However, the Permittee shall continue to record and
submit all values reported by North Carolina certified field and lab test methods, if the values fall below." We
ask that the County report values above the established curve for the test as the actual value obtained and
utilize the < value only when results are recorded below the established test curve. This matter is not
considered a violation of your permit but the County should correctly report test values in the future. Also in
lieu of providing revised/corrected Discharge Monitoring Reports (DMRs) please keep a copy of this report
with your bench notes should this matter be discussedin future inspections.
All other areas of the permit, records and site review covered during the inspection were found compliant.
Records were available upon request.
If there are questions or comments pertaining to the inspection please do not hesitate to contact Mr. Paul
Rawls at [phone].
Page # 3

Permit: NC0081281 Owner - Facility: Richmond County WTP
Inspection Date: 09/22/2011 . Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Are records kept and maintained as required by the permit? ■ n n n
Is all required information readily available, complete and current? ■ n n n
Are all records maintained for 3 years (lab. reg. required 5 years)? ■ n n n
Are analytical results consistent with data reported on DMRs? n ■ n n
Is the chain -of -custody complete? ■ n ❑ n
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 n
Transported COCs ■
Are DMRs complete: do they include all permit parameters? ■ n n n
Has the facility submitted its annual compliance report to users and DWQ? ❑ n ■ n
(If the facility is.= or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift? n n • El
Is the ORC visitation log available and current? • n n n
Is the ORC certified at grade_equal to or higher than the facility classification? • n n n
Is the backup operator certified at one grade less or greater than the facility classification? • n n n
Is a copy of the current NPDES permit available on site? • n n n
Facility has copy of previous year's Annual Report on file for review? n n ■ ❑
Comment: See Summary Section of this report, Total Residual Chlorine
Monitoring/Reporting -_
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ n n n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n n • n
Judge, and other that are applicable?
Comment:
Permit Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application? n n ■ ❑
Is the facility as described in the permit? • ❑ n n
# Are there any special conditions for the permit? n n • n
Page # 4

4'
Permit: NC0081281 Owner - Facility: Richmond County WTP
Inspection Date: 09/22/2011 ,Inspection Type: Compliance Evaluation
Permit
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment:
Pump Station - Effluent
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:
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?
Comment: Tablet dechiorination is accomplished using a basket lowered into the
effluent wetwell with numerous tablets kept in the basket at all time.
Are tablet de -chlorinators operational?
Number of tubes in use?
• Comment:
Yes No NA NE
■ nnn
■ nnn
Yes No NA NE
■ nnn
■ nnn
■ nnn
■ nnn
nn■n
nnn■
Yes No NA NE
Tablet
El El
n ■ n
nn■n
■ nnn
■ nnn
Page # 5