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Home My WebLink AboutNC0086550_Inspection_20110203Beverly Eaves Perdue Governor Blake Proctor Town Manager Town of Fairmont 421 South Main Street Fairmont, North Carolina 28340 krI NCDENR North Carolina Department of Environment and Natural Res ources Division of Water Quality Coleen H. Sullins L :Dee Freeman Director Secretary February 3, 2011 Subject: COMPLIANCE EVALUATION INSPECTION and TECHNICAL ASSISTANCE Fairmont Regional Wastewater Treatment Facility NPDES Permit Number NC0086550 Robeson County Dear Mr. Proctor: Enclosed please find the Compliance Evaluation Inspection report for the inspection and technical assistance conducted January 21, 2011. I would like to thank Mr. Johnny Britt ORC and Mr. Ronnie Seals, Public Works Director for time taken to participate in the inspection and discussion of NPDES Permit related items. The inspection revealed that the Town of Fairmont is in general compliance with NPDES Permit NC0086550. Please note the following comments. 1. Mercury, Section A. (5) CONDITIONAL MONITORING FOR MERCURY of your current permit states the following: "After the first 12 consecutive monitoring data values have been submitted on DMRs, the Permittee can petition the Division to (1) re-evaluate the mercury chronic compliance limits, (2) determine the reasonable potential for the effluent to exceed the applicable mercury compliance limits, and if no reasonable potential is shown (3) remove the limit and reduce the measurement frequency to quarterly, if the Permittee petitions the Division and a new compliance limit is determined then the new compliance limit will be applied in the permit. These modifications can be done by letter from the Division without having to :reopen the permit. Provisional Limits for Mercury take effect 24 months from the effective date of this permit if not removed" 225 Green St., Suite 714, Fayetteville, NC 28301-5043 Phone: 910-433-3300 l FAX: 910-486-0707 Internet: httpi/portal.ncdenr.orq/web/wq No thCarohna haturaIII An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper Mr. Proctor February 3, 2011 Page 2 of 3 As the effective date of your permit was November 1, 2009 and the above noted condition called for mercury monitoring a review of available sampling data for mercury was performed during the inspection. Effluent values provided ranged from a low of 2.67 ng/L to a high of 26.3 ng/L, six of which were greater than 12 ng/L. Please note that your NPDES permit states that if the Division has not removed the limits for mercury then a compliance limit of 12 ng/L will become effective November 11, 2011. Under the current compliance and enforcement structure followed by the Division of Water Quality the Town of Fairmont can be evaluated for possible enforcement action to include civil penalties once a limit is effective. Based on the above you are urged to immediately begin investigating possible sources of mercury. Such sources can be, but not necessarily limited to, industrial waste contributions, schools, dentist offices, photography processors, pumped and hauled waste and in your case other municipalities. Also mercury can become trapped in the sludge in your wastewater treatment facility causing intermittent spikes in sample results. You and your staff are urged, if you have not already done so, to begin review of available information pertaining to mercury. As noted above the mercury limit outlined in your current permit, once effective, will be 12 ng/L (12 nanograms per liter) a very small concentration. During the inspection Mr. Britt indicated that municipal staff have been trained in "Clean Hands Dirty Hands" sample techniques. As with any sampling it is vitally important that samples are taken in a manner as to not cause false positives. At the concentrations noted even the slightest departure from proper sampling techniques can cause false positives resulting in the unnecessary testing costs and potential action by the Division of Water Quality. You are asked to provide to this office on or before May 1, 2011 what effort, if any, that has been put forth to address mercury. You are asked to include in your response, at a minimum, sample quality assurance and control techniques, method(s) to identify possible sources, method(s) to eliminate/reduce mercury contributions and the legal authority the Town has to prevent the introduction of mercury into the municipal sewer system. Please note that this matter was discussed at length with Mr. Britt during the inspection and assistance was offered. If you would like assistance in addressing this matter please do not hesitate to contact me at (910) 433-3300. 2. Flow Monitoring. A review of Discharge Monitoring Reports (DMRs) for the period November 2009 to November 2010 revealed effluent flow values ranging from 0.2 MGD to 9.7 MGD. Your current flow limit has been set at 1.75 MGD (1.75 million gallons per day). As discussed with Mr. Britt you are asked to review effluent flow data from the effective date of your current permit, November 1, 2009, to present and if appropriate submit corrected DMRs. Revised DMRs should be forwarded to this office on or before May 1, 2011. Flow data can reveal the presence of Infiltration/Inflow (I/I). As you may already know I/I is the undesirable introduction of surface or groundwater into a wastewater collection system. I/I can enter the system from cracked or degraded piping and manholes, cracked or missing cleanout plugs, low Mr. Proctor February 3, 2011 Page.3 of 3 manholes, combined sewers (stormwater and sanitary sewers connected) or the intentional connection of roof or yard drains just to name a few. Significant I/I can lead to increased operation and maintenance cost, increased power consumption, sanitary sewer overflows (SSOs) and violations of NPDES permit limits. This office is aware that the Town of Fairmont has performed significant work to reduce I/I in the past but as a regional facility you may need to require such efforts on the part of communities that are now tributary to your facility. You are urged to continue efforts such as smoke testing and where possible TV inspection of sewers. We ask that you keep detailed records of sewer inspections, replacement and /or rehabilitation in your collection system records. This record keeping is required as part of your collection system permit and may assist you in obtaining grants or loans. 3. #1 Clarifier. During the tour of the facility it was noted that no flow was leaving the #1 Clarifier over the perimeter weir. This can cause short-circuiting and solids drag out from the unit. The Town is asked to repair the unit as soon as possible and notify this office in writing when repairs are complete. 4. Wastewater Treatment Facility (WWTF) General Condition. The WWTF and grounds were found to be clean and neat in appearance. 5. Record Keeping. Please continue todocument all maintenance activities at the WWTF that include but not necessarily limited to changing/adding lubricants, changing/cleaning filters, replacing belts, preventative maintenance and testing of standby generator, ORC/Back-up ORC visitation and process control activities. If you have questions, comments, or would like further assistance, please do not hesitate to contact me at (910) 433-3300. Sincerely, Paul E. Rawls Environmental Program Consultant PER/pr Enclosure: Inspection Report cc: Johnny Britt, ORC, Fairmont WWTF FRO,l ices (Mark Branticy) DWQ Central Files United States Environmental Protection Agency Washington, D.C. 20960 E PA 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 -TI NI 2 15I 31 N00086550 111 121 11/01/21 117 Type Inspector Fac Type 18I CI 191 SI 20I II 1 1 1 1 11 166 Remarks 2111111111111111 111111 11 11 11111111111 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 671 169 701 I 711 I 721 I 731 I 174 75I I I I I I I 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) Fairmont Regional WWTP 0ff US Hwy 79 Fairmont NC 28340 Entry Time/Date 08:30 AM 11/01/21 Permit Effective Date 09/11/01 Exit Time/Date 12:01 PM 11/01/21 Permit Expiration Date 14/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Johnny J Britt/ORC/910-628-0064/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Johnny J Britt, PO Box 298 Fairmont NC 283400248/Superintendent/910-628-0064/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit ■ Flow Measurement • Operations & Maintenance Records/Reports Self -Monitoring Program • Facility Site Review 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 �._ Paul E Rawls Division of Water Quality//919 1 - ✓✓✓✓cccc//// Date U.-3-20t1 88-3-/ Cj t o 433 330e Signature of Management Q A viewer Agency/Office/Phone and Fax Numbers �D}ate t�� Belinda S Henson j(<n w 0 ,% Ii� FRo WQ//910-433-3300 Ext.726/ O-) +' L 8 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page # 1 NPDES yr/mo/day Inspection Type 3, NC0086550 111 121 11/01/21 1 17 181 d (cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) 1. Mercury, Section A. (5) CONDITIONAL MONITORING. FOR MERCURY of your current permit states the following: "After the first 12 consecutive monitoring data values have been submitted on DMRs, the Permittee can petition the Division to (1) re-evaluate the mercury chronic compliance limits, (2) determine the reasonable potential for the effluent to exceed the applicable mercury compliance limits, and if no reasonable potential is shown (3) remove the limit and reduce the measurement frequency to quarterly, if the Permittee petitions the Division and a new compliance limit is determined then the new compliance limit will be applied in the permit. These modifications can be done by letter from the Division without having to reopen the permit. Provisional Limits for Mercury take effect 24 months form the effective date of this permit if not removed." As the effective date of your permit was November 1, 2009 and the above noted condition called for mercury monitoring a review of available sampling data for mercury was performed during the inspection. Effluent values provided ranged from a low of 2.67 ng/L to a high of 26.3 ng/L, six of which were greater than 12 ng/L. Please note that your NPDES permit states that if the Division has not removed the limits for mercury then a compliance limit of 12 ng/L will become effective November 11, 2011. Under the current compliance and enforcement structure followed by the Division of Water Quality the Town of Fairmont can be evaluated for possible enforcement action to include civil penalties once a limit is effective. Based on the above you are urged to immediately begin investigating possible sources of mercury. Such sources can be, but not necessarily limited to, industrial waste contributions, schools, dentist offices, photography processors, pumped and hauled waste and in your case other municipalities. Also mercury can become trapped in the sludge in your wastewater treatment facility causing intermittent spikes in sample results. You and your staff are urged, if you have not already done so, to begin review of available information pertaining to mercury. As noted above the mercury limit outlined in your current permit, once effective, will be 12 ng/L (12 nanograms per liter) a very small concentration. During the inspection Mr. Britt indicated that municipal staff have been trained in "Clean Hands Dirty Hands" sample techniques. As with any sampling it is vitally important that samples are taken in a manner as to not cause false positives. At the concentrations noted even the slightest departure from proper sampling techniques can cause false positives resulting in the unnecessary testing costs and potential action by the Division of Water Quality. You are asked to provide to this office on or before May 1, 2011 what effort, if any, that has been put forth to address mercury. You are asked to include in your response, at a minimum, sample quality assurance and control techniques, method(s) to identify possible sources, method(s) to eliminate/reduce mercury contributions and the legal authority the Town has to prevent the introduction of mercury into the municipal sewer system. Please note that this matter was discussed at length with Mr. Britt during the inspection and assistance was offered. If you would like assistance in addressing this matter please do not hesitate to contact me at (910) 433-3300. 2. Flow Monitoring. A review of Discharge Monitoring Reports (DMRs) for the period November 2009 to November 2010 revealed effluent flow values ranging from 0.2 MGD to 9.7 MGD. Your current flow limit has Page # 2 Permit: NC0086550 Inspection Date: 01/21/2011 Owner - Facility: Fairmont Regional WWTP Inspection Type: Compliance Evaluation been set at 1.75 MGD (1.75 million gallons per day). As discussed with Mr. Britt you are asked to review effluent flow data from the effective date of your current permit, November 1, 2009, to present and if appropriate submit corrected DMRs. Revised DMRs should be forwarded to this office on or before May 1, 2011. Flow data can reveal the presence of Infiltration/Inflow (I/I). As you may already know I/1 is the undesirable introduction of surface or groundwater into a wastewater collection system. I/1 can enter the system from cracked or degraded piping and manholes, cracked or missing cleanout plugs, low manholes, combined sewers (stormwater and sanitary sewers connected) or the intentional connection of roof or yard drains just to name a few. Significant I/1 can lead to increased operation and maintenance cost, increased power consumption, sanitary sewer overflows (SSOs) and violations of NPDES permit limits. This office is aware that the Town of Fairmont has performed significant work to reduce I/1 in the past but as a regional facility you may need to require such efforts on the part of communities that are now tributary to your facility. You are urged to continue efforts such as smoke testing and where possible TV inspection of sewers. We ask that you keep detailed records of sewer inspections, replacement and /or rehabilitation in your collection system records. This record keeping is required as part of your collection system permit and may assist you in obtaining grants or loans. 3. #1 Clarifier. During the tour of the facility it was noted that no flow was leaving the #1 Clarifier over the perimeter weir. This can cause short-circuiting and solids drag out from the unit. The Town is asked to repair the unit as soon as possible and notify this office in writing when repairs are complete. 4. Wastewater Treatment Facility (WWTF) General Condition. The WWTF and grounds were found to be clean and neat in appearance. 5. Record Keeping. Please continue to document all maintenance activities at the WWTF that include but not necessarily limited to changing/adding lubricants, changing/cleaning filters, replacing belts, preventative maintenance and testing of standby generator, ORC/Back-up ORC visitation and process control activities. If you have questions, comments, or would like further assistance, please do not hesitate to contact Paul Rawls at (910) 433-3300. Page # 3 Permit: NC0086550 Owner - Facility: Fairmont Regional WWTP Inspection Date: 01/21/2011 Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? 0 ❑ Q ❑ Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ■ 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 ■ n Is the facility as described in the permit? ■ n n n # Are there any special conditions for the permit? ■ n ❑ ❑ Is access to the plant site restricted to the general public? ■ ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? ■ n n n Comment: Pump Station - Effluent Yes No NA NE Is the pump wet well free of bypass lines or structures? ■ El Are all pumps present? ■ n n n Are all pumps operable? ■ n ❑ n Are float controls operable? - ■ ❑ ❑ ❑ Is SCADA telemetry available and operational? ■ ❑ ❑ ❑ - Is audible and visual alarm available and operational? 1 n n n Comment: Audible/Visual alarms were check and functional at the time of the inspection. - Bar Screens Yes No NA NE Type of bar screen a.Manual ■ b.Mechanical ■ Are the bars adequately screening debris? ■ ❑ f_l Is the screen free of excessive debris? ■ ❑ ❑ n Is disposal of screening in compliance? ■ El Is the unit in good condition? • . n n n Comment: WWTF is equiped with both mechnical and manual bars screens as well a a automatic unit at old the old WWTF in the Town of Fairmont. Grit Removal Yes No NA NE Page # 4 Permit: NC0086550 Owner - Facility: Fairmont Regional WWTP Inspection Date: 01/21/2011 Inspection Type: Compliance Evaluation 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: 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: See Summary Section of this report. Aeration Basins Mode of operation Type of aeration system 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? Yes No NA NE n ■ ■ nnn ■ n n n ■ nnn Yes No NA NE ■ nnn ■ n n n ■ n n n ■ nnn n ■nn ■ nnn ■ nnn ■ nnn n nnn n nnn ■ nnn Yes No NA NE Ext. Air Diffused ■ nnn n n■n ■ nnn ■ nnn ■ nnn ■ nnn Page # 5 Permit:-.N00086550 Inspection Date: 01/21/2011 Owner - Facility: Fairmont Regional WWTP Inspection Type: Compliance Evaluation Aeration Basins ;'- Yes No NA NE Is the DO level .acceptable?(-1::0to 3.0 mg/I) ■ n n n Comrneht Disinfection -Liquid Yes No NA NE Is there adequate reserve supply of disinfectant? ■ ❑ ❑ ❑ (Sodium Hypochlorite) Is pump feed system operational? ■ n n n Is bulk storage tank containment area adequate? (free of leaks/open drains) ■ n n n Is the level of chlorine residual acceptable? • ❑ n n Is the contact chamber free of growth, or sludge buildup? • n n n Is there chlorine residual prior to de -chlorination? n ❑ ❑ ■ Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ■ ❑ ❑ ❑ Is sample collected below all treatment units? ■ n n n Is proper volume collected? ■ n n n Is the tubing clean? ■ n n n # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? • n n n Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ■ n ❑ n Comment: Standby Power Yes No NA NE Is automatically activated standby power available? ■ ❑ ❑ ❑ Is the generator tested by interrupting primary power source? ■ n n n Is the generator tested under load? Er -Inn Was generator tested & operational during the inspection? ■ n n ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? ■ n Is there an emergency agreement with a fuel vendor for extended run on back-up power? Finn. Is the generator fuel level monitored? ■ n n n Comment: - Page # 6