NC0025453_Compliance Evaluation Inspection_20210917

DocuSign Envelope ID: 3E3ED9CA-F9C0-43AD-BB61-120FBA5F590F
ROY COOPER
(,ore, nor
ELIZABETH S. RISER
Secretary.
S. DANIEL SMI"(I-1 NORTH c_ArzoLINA
Ditecror Environmental Quality
September 17, 2021
Rich Cappola, Interim Town Manager
Town of Clayton
PO Box 879
Clayton, NC 27528
Subject: Compliance Evaluation Inspection
Town of Clayton Little Creek WRF
NPDES Permit NC0025453
Johnston County
Dear Mr. Cappola:
On Tuesday, August 31, 2021, Jason Robinson of the Raleigh Regional Office conducted a
compliance evaluation inspection of the treatment facilities located at the Little Creek WRF at
1,000 Durham Street Extension, Clayton. The purpose of this inspection was to ensure
compliance with the subject NPDES permit. During the inspection, the presence and
cooperation of Mr. William Simpson, Operator in Responsible Charge (ORC) was appreciated.
Findings during the pre -inspection file review were as follows:
1. The most recent NPDES permit was issued on February 1, 2021, and will expire on March
31, 2024.
2. The WW-4 facility is currently permitted and authorized to discharge 2.5 MGD of treated
wastewater through Outfall 001 into the Neuse River at a location approximately 2 miles
from the facility. The permit also authorizes future discharges of 6.0 and 10.0 MGD upon
the Division's receipt of Engineering Certifications of completion of the facility's expansion.
Clayton also currently has agreements in place to send up to 1.4 MGD of wastewater to
Johnston County and 1.0 MGD to Raleigh for treatment.
3. For the review period June 2019 — August 2021, the facility received a Notice of Deficiency
for not reaching the minimum limit for Dissolved Oxygen. Violations also occurred for this
in June 2021, The quarterly average limit for Total Phosphorus (as P) Concentration was also
exceed in June 2021. No actions had been taken on the two June monitoring violations as of
the date of this inspection. A civil penalty was assessed for a bypass at the treatment plant
that occurred at a broken Tine just after the influent pump station that resulted in
approximately 428,300 gallons of wastewater being discharged to surface waters on March
14, 2021. This resulted in a penalty of $2,500 (PC-2021-0027.
4. As required by North Carolina General Statute § 143-215.1 C(a), the City has prepared and
made available to its customers the wastewater annual report for fiscal year 2020-2021 in
North Carolina Department of t.nvirunn ental Quality I Division of Water Resources
Raleigh Regional Offlre i s800 Barrett Drive i Raleigh. North Carolina 27609
910 lql 4L00

DocuSign Envelope ID: 3E3ED9CA-F9C0-43AD-BB61-120FBA5F590F
August 2021. The report summarizes the performance of the City's collection and treatment
facilities, improvements that have been made, and the extent to which any permit
requirements have been violated.
Findings during the inspection were as follows:
5. The operator's log and supporting analytical documentation were consistent and up to date.
6. The inspector compared September 2020 and March 2021 eDMR data against the bench lab
data and the contract Tabs (Cameron & Meritech) analytical data. No discrepancies were
noted.
7. The on -site laboratory (certification number 348) is certified for and self -reports monitoring
data for some parameters. An inspection of the meter calibration logs, standards, buffer
expiration dates and incubator temperatures showed the laboratory to be compliant with
record -keeping requirements.
8. All units listed in the permit were observed and no issues were found.
9. The inspector and ORC traveled to the offsite effluent discharge pipe at the Neuse river
approximately 2 miles from the plant. The pipe was observed under the water. The effluent
observed was clear and free of solids and excess foam.
This facility was found to be compliant with NPDES permit conditions as a result of this
inspection. If you have any questions regarding the attached reports or any of the findings, please
contact Jason Robinson at Jason.t.robinson ancdenr.gov).
Sincerely,
DocuSigned by:
"—BCDA9DB25D4A46D.
Scott Vinson, icegwnai supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Attachments: EPA Water Compliance Inspection Report
Cc: wsimpson u,townofclavtonnc.org
RRO Files
DWR Laserfiche

DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F2OB3DB
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
1 IN I 2[ I
21IIIIII
NPDES yr/mo/day Inspection
3 I NC0025453 111 121 21/08/31 117
Type
18Li,
IIII
Inspector Fac Type
191 s 1 201 I
IIIIIIIII II III IIII I IIIIII
IIIIIII 166
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA --------Reserved-----------
671 I 701 171172 I N I 731 I 174 751 1
1I I I 1 1111I 180
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES permit Number)
Little Creek WRF
1000 Durham St
Clayton NC 27520
Entry Time/Date
01:OOPM 21/08/31
Permit Effective Date
21/02/01
Exit Time/Date
03:30PM 21/08/31
Permit Expiration Date
24/03/31
Name(s) of Onsite Representative(s)/Ttles(s)/Phone and Fax Number(s)
///
William R Simpson/ORC/919-553-1535/
Other Facility Data
Name, Address of Responsible Officialltle/Phone and Fax Number
Contacted
Steven
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement • Operations & Maintenar Records/Reports
Sludge Handling Dispos 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)
Jason T Robinson
of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Docusigned by: C DWR/RRO WQ/919-791 4200/
� .oh, O tlett.oh, 9/17/2021
8F93314C1 El?1zA9..
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
e--Docusigned by. 9/17/2021
'"" " llk.4an.
EPA Form 3560 `—BCDA9G825D4A46D lions are obsolete.
Page#

DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F20B3DB
31
NPDES
NC0025453
111 121
yr/mo/day
21/08/31
I17
Inspection Type
18 Li,
(Cont.)
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Findings during the pre -inspection file review were as follows:
1. The most recent NPDES permit was issued on February 1, 2021, and will expire on March 31,
2024.
2. The WW-4 facility is currently permitted and authorized to discharge 2.5 MGD of treated
wastewater through Outfall 001 into the Neuse River at a location approximately 2 miles from the
facility. The permit also authorizes future discharges of 6.0 and 10.0 MGD upon the Division's receipt
of Engineering Certifications of completion of the facility's expansion. Clayton also currently has
agreements in place to send up to 1.4 MGD of wastewater to Johnston County and 1.0 MGD to
Raleigh for treatment.
3. For the review period June 2019 —August 2021, the facility received a Notice of Deficiency for not
reaching the minimum limit for Dissolved Oxygen. Violations also occurred for this in June 2021, The
quarterly average limit for Total Phosphorus (as P) Concentration was also exceed in June 2021. No
actions had been taken on the two June monitoring violations as of the date of this inspection. A civil
penalty was assessed for a bypass at the treatment plant that occurred at a broken line just after the
influent pump station that resulted in approximately 428,300 gallons of wastewater being discharged
to surface waters on March 14, 2021. This resulted in a penalty of $2,500 (PC-2021-0027.
4. As required by North Carolina General Statute § 143-215.1C(a), the City has prepared and made
available to its customers the wastewater annual report for fiscal year 2020-2021 in August 2021.
The report summarizes the performance of the City's collection and treatment facilities, improvements
that have been made, and the extent to which any permit requirements have been violated.
Findings during the inspection were as follows:
5. The operator's log and supporting analytical documentation were consistent and up to date.
6. The inspector compared September 2020 and March 2021 eDMR data against the bench lab
data and the contract labs (Cameron & Meritech) analytical data. No discrepancies were noted.
7. The on -site laboratory (certification number 348) is certified for and self -reports monitoring data
for some parameters. An inspection of the meter calibration logs, standards, buffer expiration dates
and incubator temperatures showed the laboratory to be compliant with record -keeping requirements.
8. All units listed in the permit were observed and no issues were found.
9. The inspector and ORC traveled to the offsite effluent discharge pipe at the Neuse river
approximately 2 miles from the plant. The pipe was observed under the water. The effluent
observed was clear and free of solids and excess foam.
This facility was found to be compliant with NPDES permit conditions as a result of this inspection.
Page# 2

DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F20B3DB
Permit: NC0025453
Owner - Facility: Little Creek WRF
Inspection Date: 08/31/2021 Inspection Type: Compliance Evaluation
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 0
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 ❑ ❑ • 0
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? •❑ ❑ ❑
Comment:
Permit
(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?
Comment. Need to add eflluent pump station during next permit cycle
Laboratory
Are field parameters performed by certified personnel or laboratory?
Yes No NA NE
❑ ❑ ❑
• ❑ ❑ ❑
❑•❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
▪ ❑ ❑ ❑
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DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F20B3DB
Permit: NC0025453
Inspection Date: 08/31/2021
Owner - Facility: Little Creek WRF
Inspection Type: Compliance Evaluation
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:
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:
Bar Screens
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
Is the screen free of excessive debris?
Is disposal of screening in compliance?
Is the unit in good condition?
Comment:
Grit Removal
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Comment:
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
•
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
El
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
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DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F20B3DB
Permit: NC0025453
Inspection Date: 08/31/2021
Owner - Facility: Little Creek WRF
Inspection Type: Compliance Evaluation
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? ❑ ❑ ❑ ❑
Comment: Clarifier #1 currently used as EQ basin
Pump Station - Influent Yes No NA NE
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? ❑ ❑ ❑ ❑
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? MO ❑ ❑
Is the DO level acceptable? ❑ ❑ ❑
Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑ ■
Comment:
Secondary Clarifier Yes No NA NE
Page# 5

DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F20B3DB
Permit: NC0025453
Inspection Date: 08/31/2021
Owner - Facility: Little Creek WRF
Inspection Type: Compliance Evaluation
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:
Pumps-RAS-WAS
Are pumps in place?
Are pumps operational?
Are there adequate spare parts and supplies on site?
Comment:
Yes No NA NE
• 000
• 000
• 000
▪ ❑ ❑ ❑
• 000
• 000
■ ❑❑❑
• 000
■ ❑❑❑
■ ❑ ❑ ❑
11000
Yes No NA NE
• 000
• 000
• 000
Filtration (High Rate Tertiary) Yes No NA NE
Type of operation: Down flow
Is the filter media present? •000
Is the filter surface free of clogging? •000
Is the filter free of growth? ■ ❑ ❑ ❑
Is the air scour operational? E000
Is the scouring acceptable? ■ ❑ ❑ ❑
Is the clear well free of excessive solids and filter media? ■ ❑ ❑ ❑
Comment:
Disinfection - UV
Are extra UV bulbs available on site?
Are UV bulbs clean?
Is UV intensity adequate?
Yes No NA NE
▪ ❑ ❑ ❑
• ❑ OD
■ DOD
Page# 6

DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F20B3DB
Permit: NC0025453
Inspection Date: 08/31/2021
Owner - Facility: Little Creek WRF
Inspection Type: Compliance Evaluation
Disinfection - UV
Is transmittance at or above designed level?
Is there a backup system on site?
Is effluent dear and free of solids?
Comment:
Effluent Pipe
Is right of way to the outfall properly maintained?
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:
Yes No NA NE
• ❑ DO
• ❑ ❑ ❑
• ❑ ❑ ❑
Yes No NA NE
■ ❑❑❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Flow Measurement - Effluent Yes No NA NE
# Is flow meter used for reporting? MEI ❑ ❑
Is flow meter calibrated annually? ■ ❑ ❑ ❑
Is the flow meter operational? •❑ ❑ ❑
(If units are separated) Does the chart recorder match the flow meter? ■ ❑ ❑ ❑
Comment:
Pump Station - Effluent Yes No NA NE
Is the pump wet well free of bypass lines or structures? ❑ ❑ ❑ ❑
Are all pumps present? 111001=1
Are all pumps operable? • ❑ ❑ ❑
Are float controls operable? •❑ ❑ ❑
Is SCADA telemetry available and operational? 0 0 0 IN
Is audible and visual alarm available and operational? • ❑ ❑ ❑
Comment:
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?
Yes No NA NE
▪ ❑ OD
■ ❑❑❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
• ❑ ❑ ❑
Page# 7

DocuSign Envelope ID: 7EDED936-83F7-4BEO-ABE6-EAE68F20B3DB
Permit: NC0025453
Inspection Date: 08/31/2021
Owner - Facility: Little Creek WRF
Inspection Type: Compliance Evaluation
Standby Power
Is there an emergency agreement with a fuel vendor for extended run on back-up
power?
Is the generator fuel level monitored?
Comment:
Yes No NA NE
• ❑ ❑ ❑
▪ ❑ ❑ ❑
Page# 8