HomeMy WebLinkAboutNC0051969_Compliance Evaluation Inspection_20210825DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
ROY COOPER
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G—or
1
ELIZABETH S. BISER
�
Secretary
���ss.
S. DANIEL SMITH
NORTH CAROLINA
Director
Environmental Quality
September 01, 2021
Vaughn Dagenhart
Castle Hayne Health Holdings LLC
PO Box 2568
Hickory, NC 28603-2568
SUBJECT: Compliance Inspection Report
Castle Creek Memory Care WWTP
NPDES WW Permit No. NCO051969
New Hanover County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Castle Creek Memory
Care WWTP on August 25, 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. NC0051969. The
findings and comments noted during this inspection are provided in the enclosed copy of the inspection
report entitled "Compliance Inspection Report".
There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required.
If you should have any questions, please do not hesitate to contact Dean Hunkele with the Water
Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215 or via email at
dean. hunkele(a)ncdenr.gov.
Sincerely,
DocuSigned by:
I ONE �Aarrl OA,
7F141 E73B6F3456...
Tom Tharrington, Asst. Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
ATTACHMENT
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ANorlhGmlina Departmem of Environmental QualRy I Division of Water Resources
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DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
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 I 2 u 3 I NCO051969 111 121 21/08/25 I17 18 LC] I 19 I s I 20L]
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
701L� J I 71 [n LI 72 I Lni I 71 I 74 79 I I I I I I I80
-1 I I
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)
01:45PM 21/08/25
17/05/01
Castle Creek Memory Care WWTP
4724 Castle Hayne Rd
Exit Time/Date
Permit Expiration Date
Castle Hayne NC 28429
03:OOPM 21/08/25
22/01/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Andrew Thomas Mulvey/ORC/910-798-4453/
Kevin K Woodward//910-622-4848 /
Kevin Kiehle Woodward/ORC/910-798-4458/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Vaughn Dagenhart,PO Box 2568 Hickory NC 286032568/Facilities
Director/828-322-5535/ Yes
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 Compliance Schedules
Effluent/Receiving Wate 0 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
Dean Hunkele DocuSignedby'. DWR/WIRO WQ/910-796-7215/
9/1/2021
v_
LE1D9294C4D3746E
...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
Tom Tharrin tooµ -�� �DWR/WIRO WQ/ - - / 9/1/2021
'--- 7F141 E73B6F3456...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#
DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
NPDES yr/mo/day Inspection Type (Cont.)
NCO051969 I11 12I 21/08/25 117 18 i c i
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
The facility continues to look and function better than in the past years. The facility has been able to
reduce the amount of chlorides used in the water system which sends less to the wastewater
treatment plant plus they have added a yard drain to allow up to 300 gallons to be discharged onto
the ground surface for it to evaporate & infiltrate. These actions have allowed the facility to become
compliant with the chloride limits since February 2021.
Under the 9-2020 compliance/settlement agreement the facility is now testing the last trial chemical
addition to the water system in an attempt to coat the facility's internal piping to reduce the amount of
Copper leaching into the raw wastewater. Early results show it appears to be having a positive
impact on influent levels once pH was adjusted, but the treatment facility's activated sludge contains a
considerable amount which will take some time to waste out of the system before an effluent
reduction can occur.
On June 18, 2021 the Permittee requested at least a 2-month extension of the agreement's current
end of year deadline due to early delays by Permittee and COVID pandemic in implementing the
requirements of the agreement. The extension of the agreement would give them more time to
evaluate the last chemcial trial and have time to get approval & install equipment on the back end of
the treatment plant should it still be necessary. To date, DWR's NPDES Unit has yet to weigh in on
the request.
Lastly the faility's permit (NC0051969) expires on 1-31-2022, thus its renewal application is due now
as its required to be submittted 6 months prior to expiration. Thus, it should be submitted soon and
definitely prior to expiration,
Page#
DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
Permit: NCO051969 Owner -Facility: Castle Creek Memory Care WWTP
Inspection Date: 08/25/2021 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
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application?
Is the facility as described in the permit?
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# Are there any special conditions for the permit?
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Is access to the plant site restricted to the general public?
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Is the inspector granted access to all areas for inspection?
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Comment: Current permit expires on 1-31-2022, thus the renewal application should be
forthcoming soon as its due within 180 days prior to expiration. Some changes have
recently occurred at the facility with more to possibly come in accordance with the
Settlement/Compliance Agreement from 9-2020 to deal with compliance with Copper &
Chloride limits that were placed in the last permit renewal and were under a 3-year
compliance schedule that the Permittee failed to attempt to meet. Some of the system
changes may need to be added to the permit on next renewal.
Compliance Schedules
Yes
No
NA
NE
Is there a compliance schedule for this facility?
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Is the facility compliant with the permit and conditions for the review period?
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Comment: There was a compliance schedule in current permit that has expired, but now under a
compliance/settlement agreement . Since last inspection in 9-2016 the facility has had
multiple limit violations with most being Copper & Chlorides; no action has been taken
on the covered parameters since discussions were initiated for the agreement.
Record Keeping
Yes
No
NA NE
Are records kept and maintained as required by the permit?
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Is all required information readily available, complete and current?
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Are all records maintained for 3 years (lab. reg. required 5 years)?
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Are analytical results consistent with data reported on DMRs?
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Is the chain -of -custody complete?
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Dates, times and location of sampling
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Name of individual performing the sampling
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Results of analysis and calibration
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Dates of analysis
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Name of person performing analyses
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Transported COCs
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Are DMRs complete: do they include all permit parameters?
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Has the facility submitted its annual compliance report to users and DWQ?
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Page# 3
DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
Permit: NCO051969
Inspection Date: 08/25/2021
Owner -Facility: Castle Creek Memory Care WWTP
Inspection Type: Compliance Evaluation
Record Keeping
(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?
Is a copy of the current NPDES permit available on site?
Facility has copy of previous year's Annual Report on file for review?
Yes No NA NE
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Comment: Records were not reviewed in order to review facility as the operator needed to
off samples to lab.
Laboratory
Are field parameters performed by certified personnel or laboratory?
Are all other parameters(excluding field parameters) performed by a certified lab?
# Is the facility using a contract lab?
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
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
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Yes No NA NE
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Comment: The audible alarm needs to be replaced with a louder unit to attract attention of staff in
the event of an issue. Ideally telemetry should be installed on the station to call
someone in the event of an alarm condition to minimize or avoid a spill.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system
Fixed
Page# 4
DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
Permit: NCO051969
Inspection Date: 08/25/2021
Aeration Basins
Owner -Facility: Castle Creek Memory Care WWTP
Inspection Type: Compliance Evaluation
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/1)
Yes No NA NE
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Comment: The mixed liquor had the proper consistency but appeared to be a little weak which can
be expected based on a majority of the facility's patients and was discolored by the iron
from the water treatment discharge.
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'/4 of the sidewall depth)
Comment: Iron coloration much reduced in unit.
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?
Comment:
Yes No NA NE
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Yes No NA NE
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Page# 5
DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
Permit: NCO051969 Owner -Facility:
Inspection Date: 08/25/2021 Inspection Type:
Castle Creek Memory Care WWTP
Compliance Evaluation
Filtration (High Rate Tertiary)
Yes
No
NA
NE
Type of operation:
Down flow
Is the filter media present?
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0
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Is the filter surface free of clogging?
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Is the filter free of growth?
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Is the air scour operational?
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Is the scouring acceptable?
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Is the clear well free of excessive solids and filter media?
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Comment:
Disinfection - UV Yes No NA NE
Are extra UV bulbs available on site?
0
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Are UV bulbs clean?
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Is UV intensity adequate?
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Is transmittance at or above designed level?
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Is there a backup system on site?
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0
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Is effluent clear and free of solids?
0
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Comment: Surprisingly the iron is not carrying forward, but if it should it could cause disinfection
issues due to interference with UV light transmittance.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
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0
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Is sample collected below all treatment units?
0
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Is proper volume collected?
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Is the tubing clean?
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degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
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representative)?
Comment:
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑
and sampling location)?
Comment:
Page# 6
DocuSign Envelope ID: 1B2DA64D-D922-4190-BA12-99033D1FC7EE
Permit: NCO051969
Inspection Date: 08/25/2021
Owner -Facility: Castle Creek Memory Care WWTP
Inspection Type: Compliance Evaluation
Standby Power
Is automatically activated standby power available?
Is the generator tested by interrupting primary power source?
Is the generator tested under load?
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
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Comment: The entire facility does not have a back-up -generator which is surprising given the
potential for power loss due to tropical storms that commonly impact the area. Without
power, then the facility will have no potable water and thus no new wastewater input.
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?
Comment: The water system building is quite crowded inside especially with chemical and salt
storage making it very tight to work on system, thus adding additional storage for these
items is recommended.
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