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NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
FAYETTEVILLE REGIONAL OFFICE
April 27, 2000
The Honorable George T. Paris
Mayor, Town of Red Springs
217 South Main Street
Red Springs, NC 28377'
SUBJECT: Notice of Violation/
Compliance Evaluation Inspection
Town of Red Springs WWTP
NPDES Permit No. NC0025577
Robeson County
Dear Mr. Paris:
The subject inspection. was performed March 2, 2000 by several staff members
representing various regional offices of the Division of Water Quality. Conducting the
inspection were Belinda Henson and Don Register of the Fayetteville Regional Office, Pat
Durrett of the Wilmington Regional Office, and Jenne Sowell and Ted Cashion of the
Raleigh Regional Office. The cooperation of Leonard Green, Grade IV ORC, was
appreciated. As stated in the NPDES permit Part II Section C.2.Proper Operation and
Maintenance - "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." Based on the
inspection of this facility the findings concluded violation of the NPDES permit with the
above stated reason. Findings during the inspection included the following:
1. The 2.5 mgd treatment facility consists of a manual bar screen, mechanical bar
screen, grit chamber, grit cyclone, dual oxidation ditches, dual clarifiers, cascade
aeration, chlorine contact chamber, sludge digester, and 6 sludge drying beds.
2. The screen for the mechanical bar screen was broken on one side. This allows -large
objects to pass through and potentially cause damage to equipment in the plant.
This should be repaired to prevent problems.
3. Screenings were observed on the ground near the influent structure. These must be
removed and properly disposed of immediately if not already done so.
4. There was a noticeable chlorine odor, and a large amounts of suds observed in the
influent wastestream. This could cause treatment inefficiency and possible
violations of the permit. We recommend the Town implement pretreatment
requirements for Clayson Knitting to protect the Town's infrastructure, employees,
and prevent permit violations. Mr. Green stated that pumps had been clogged with
socks in the past.
-continued-
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5. There were rags collected on the bars above the parshall flume. Valves at the influent structure
appeared rusty and inoperable. The grit chamber was full of sand/grit and was not in service. Please
ensure these areas are cleaned and made to operate as designed.
6. The railings and other fixtures at the plant need to be scraped and painted. Please be advised that
failure to properly maintain the facility can lead to greater repair or replacement costs in the future.
Also chronic failure to properly maintain the facility can be viewed as a violation of your NPDES
permit.
7. As noted in the last inspection report dated August 31, 1999, the influent composite sampler
refrigerator does not work. As discussed during the inspection, this must be repaired/replaced
immediately. The temperature of the unit must be maintained at 0-4 Degrees C, without freezing.
The sample tubing must also be replaced or cleaned. Influent samples may be collected at no greater
than 20 minute intervals, with a minimum of 100 mis collected for each sampling event. Please
ensure the sampler is programmed to comply with this requirement.
8. The concrete under the valve behind the flume was crumbling. Repairs must be made as soon as
possible to prevent damage to the plant.
9. There was a valve located beside the grit chamber. It was unclear what the purpose of this valve was
for. Please investigate and respond what this valve is for and where the piping leads to.
10. There were exposed wires at the bottom to the pole beside the grit chamber. Please ensure that this
is inspected by an electrician and made safe. This is a potential safety hazard and should be
addressed immediately.
11. The grit cyclone was rusted and appeared inoperable. Please ensure this unit is made operable.
12. The emergency generator was in operating condition.
13. There were several teeth missing from the rotors for the aeration basins. These must be repaired
immediately to ensure that proper operation and treatment efficiency is maintained.
14. There were cracks on the outside walls on both aeration basins. As noted several times before we
urge the Town to have a professional engineer evaluate these conditions for integrity periodically.
15. The clarifiers showed signs of sludge denitrifying (old sludge). The sludge blankets were 4.5 feet
and 6 feet in the 2 clarifiers, both of which are 12 feet deep. It is recommended to have no more that
a 4 feet blanket in these clarifiers to prevent solids. washout. The weirs on both clarifiers were
uneven, causing solids to be carried over. The weirs must be leveled to prevent this from occurring,
and jeopardizing permit compliance. Please have the weirs adjusted immediately and notify this
office in writing within 10 business days of completion.
16. The 6 feet deep contact chamber had approximately 1 foot of sludge in the bottom. Sludge must be
removed periodically from this unit to prevent carryover of solids in the effluent. Please record in
your daily log each time the unit is cleaned.
17. Mr. Green stated that the effluent composite sampler was programmed to collect 250 milliliters of
sample every 30 minutes. A letter has been sent to this facility dated March 21, 2000 requiring this
facility to collect effluent samples flow proportionally by March 15, 2001. In the meantime proper
sampling would be at least 100 milliliters every 20 minutes.
-continued-
18. Mr. Green stated that the sludge digester was full. Currently, sludge is dried on 6 drying beds, then
disposed of at the county landfill. The Town must consider an alternative sludge disposal. The
Division does not consider landfill disposal an acceptable long term solution. Landfills are
increasingly not accepting sludge from treatment plants, except for top cover. Please contact our
office for guidance in this area.
19. The ORC logbook was reviewed and found to contain minimal information. As discussed with Mr.
Green, the logbook must contain all daily activities (operation and maintenance) that occur at the
plant. Please ensure detailed entries are made daily.
20. Laboratory calibration records were reviewed. As discussed, a minor amount of additional
documentation needs to be recorded on the logs.
21. Mr. Green stated that the Town has 7 pump stations, and that none have telemetry. The Division
recommends that the Town consider installing telemetry and if power outages have been a problem
to install an emergency generator at each pump station to prevent sanitary sewer overflows, and the
liability associated with such events. Please ensure that emergency telephone numbers are displayed
at each pump station.
22. A cursory review of DMR data and laboratory data showed consistent reporting of results.
23. A review of long term monitoring data showed cyanide and mercury levels above the State's water
quality standards for each of these parameters. The Town was required in the November 1998
inspection report to submit a study plan to isolate and remove these parameters. To date, this plan
has not been submitted. You are directed to contact this office immediately upon receipt of this
report to discuss this matter.
24. The Town has participated in a local Enterprise Zone/Enterprise Community package where 5 local
communities may be eligible for federal funding directed toward possible regionalization of
wastewater treatment and disposal. Please comment on the status of this project, and what efforts
the Town is pursuing toward possible regionalization.
25. The current permit expired December 31, 1999. You are to operate under the conditions of this
permit until the permit has been reissued.
26. The backup ORC is Gene Gooden, Grade II.
27. Please provide this office with an update of efforts undertaken to reduce inflow/infiltration (I/I) from
the collection system. Include in your response the amount of resources expended in 1999,
estimated amount of I/I removed in 1999, and what is planned for 2000 and 2001.
28. Test America and Burlington Research perform analyses for the Town.
-continued-
29. A review of DMR data submitted since the last inspection, July 1999 through December 1999,
showed the following:
a. Several fecal coliform values of > (greater than) were reported. Please instruct your
laboratory to set more dilutions in order to report an absolute number.
b. pH values of 8.4 and 8.2 were reported on December 29 and 30, 1999 respectively. No
explanation for these abnormally high values was offered. The industries in Town may have
been conducting cleaning operations at this time of the year. We recommend the Town
notify each industrial discharger of the potential problems associated with dumping
substances down the sanitary sewer line that may occur at the treatment plant.
c. Several low BOD and TSS influent values were reported. This is probably due to the
chlorine bleach discharged to the plant, and/or an indication of the I/I problems of the Town.
Both of these conditions may be detrimental to the treatment efficiency of the plant.
d. Fecal coliform violations were noted for the weeks of November 9, November 16, and
November 22, 1999. Comments on the DMR stated that the chlorine cylinder froze due to
cold weather, and that the ORC had informed the Superintendent that a shelter needed to be
built around the chlorine system earlier. Please comment as to what actions the Town has
taken to prevent this condition from re -occurring.
e. Fecal coliform violations were also reported for the week of October 18, 1999. DMR
comments include that excess rain caused these violations. The Town has a flow paced
chlorinator and should consider installing a dechlorination system, to lower the chlorine
concentration discharged.
30. The following Notice of Violations (NOVs) have been sent to this facility for the parameters in the
1999 year period:
January - Toxicity
April - Fecal Coliform
May - Fecal Coliform
June - Fecal Coliform
July - Toxicity
August - Toxicity
October - Fecal Coliform
31. The effluent at the time of the inspection had a slightly pink color, and contained some solids. No
effluent samples were taken during the inspection.
32. A compliance evaluation analysis report for the period February 1999 through December 1999
revealed monthly fecal violations for September and November. In July the toxicity analysis was
a violation for failure to pass.
Please respond in writing to items 2-11, 13-15, 17, 18, 23, 24, 27, and 29 detailing actions taken to
address these items. The Town has been notified previously concerning items 7, 13, 14, 15, and 23. Please
submit this response on or before May 31, 2000
Violations of permit conditions are subject to enforcement action by the U.S.
Environmental Protection Agency and this Division. Penalties of up to $25,000/day may be assessed for
each violation of the permit.
You are reminded that the Division's Technical Assistance and Certification Unit
is available upon request to provide technical assistance to the Town at no cost. You may contact Dwight
Lancaster, Supervisor of this Unit, at 919-733-0026.
If you or your staff have questions concerning this report, please contact Ms.
Henson at 910-486-1541.
Paul E. Rawls
Water Quality Regional Supervisor
/bsh
Enclosure
cc: Wayne Horne, Town Manager
Leonard Green, ORC Town of Red Springs WWTP
Koonce, Noble and Associates
Maurice Horsey, USEPA, Reg. IV
DWQ NPDES Compliance Unit
Dana Folley, DWQ Pretreatment
Ted Cashion, DWQ Raleigh Regional Office
Jenne Sowell, DWQ Raleigh Regional Office
Pat Durrett, DWQ Wilmington Regional Office
NPDES COMPLIANCE INSPECTION REPORT
North Carolina Division of Water Quality
Fayetteville Regional Office
Section A. National Data System Coding
Transaction Code: N NPDES NO. NC0025577 Date: 000302 Inspection Type: C
Inspector: S Facility Type: 1 Reserved:
Facility Evaluation Rating: 2 BI: N QA: N Reserved.
Section B: Facility Data
Name and Location of Facility Inspected:
Town of Red Springs WWTP
Entry Time: 10:00am Permit Effective Date: 950801
Exit Time/Date: 3:OOpm/000302 Permit Expiration Date: 991231
Name(s), Title(s) of On -Site Representative(s):
Leonard Green (Certified Grade IV Operator) - "ORC"
Phone Number(s): (910) 843-2654
Name, Title and Address of Responsible Official
Mr. George Paris, Mayor
217 South Main Street
Red Springs, NC 28377
Contacted: no
Section C: Areas Evaluated During Inspection
(S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated, N/A = Not Applicable).
Permit::
Records/Reports: S.
Facility Site Review:'1VI
Flow MeasurementS
Laboratory: S
Effluent/Receiving Waters:_S
:Pretreatinent:,
Compliance Schedule N/A
Self -Monitoring Program: S
Operation & MaintenanceIJ
Sludge Disposal: S
Other:
INSPECTION REPORT
UPDATE OPTION: TRX: 5IF KEY: NC0025577INSCEI 000302
SYSMSG: *** DATA ADDED SUCCESSFULLY ***
PERMIT--- NC0025577 REG/COUNTY-- 06 ROBESON
FACILITY-- RED SPRINGS (TOWN) - WWTP LOC--'RED SPRINGS
INS TYPE
CEI
NEXT PLANNED
INSPECTION INSPECTED BY:
DATE: 000302 CT
REPORT INSPECTION DMR RESPONSE RECEIVED
DATE STATUS STATUS DUE DATE DATE
000427 NC C 000531
COMMENTS:
INSPECTION WAS A JOINT EFFORT BY FRO AND RRO STAFF.