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NC0085812_Inspection Response_20211026
P ( 704.984.9605 F 704.984.9606 NORTH CAROL NA Wat ,4 /curd, dpp©eta4, www.albemarlenc.gov PO Box 190 144 North Second Street Albemarle, NC 28002-0190 RECEIVED/NCDEQ/DWR Public Utilities Department NOV -1 2Li WQROS 10/26/21 MOORESVILLE REGIONAL OFFICE Mr. Corey Basinger Regional Supervisor, Mooresville Regional Office Division of Water Resources, NCDEQ (Sent via email) Re: Long Creek WWTP Compliance Inspection Report dated September 9, 2021 Dear Mr. Basinger: We are in receipt of the September 9th, 2021 Compliance Inspection Report for the City's Long Creek WWTP. We have discussed this issue with you and your staff on multiple occasions including an in -person meeting on September 28th, 2021 also attended by Adam Kiker with LKC Engineering. Albemarle acknowledges the discharge of alum sludge from the US52 Water Treatment Plant into the City's sanitary sewer system causes systemic problems both in the collection system and at the Long Creek WWTP. This has always been a challenge; however, recent changes in the City's sewer flow profile, namely losing the City's largest industrial discharger with elevated biological strength, have augmented the problem caused by the alum sludge. This is especially observable during dry and low -flow conditions as present during the August 25th, 2021 inspection. The City is committed to resolving this issue, and it is possible the resolution will take the form of a solids handling facility at the water treatment plant. Capital improvements to correct the problem are on a list of top priority projects for the City in the coming years, and we are evaluating a potential funding application pending clarity on state and federal infrastructure bills expected later this year. Please note the City has several high -priority projects that need consideration in the next few years, including resolution to the subject of this letter. We are evaluating the best funding solution and a schedule for implementation of each project. As we have more clarity on which project is implemented in what year, we will gladly share this information with your group. Please do not hesitate to contact me at (704) 984-9608 or by email at dworl@albemarlenc.gov if you have any questions. Sincerely, Dan Worl ROY COOPER Governor ELIZABETH S. BISER Searrlot} S. DANIEL SMITH Dircetor NORTH CAROLINA Environmental Quality Certified Mail #7018 0360 0002 2099 8849 Return Receipt Requested September 9, 2021 Michael J Ferris City of Albemarle PO Box 190 Albemarle, NC 28002-0190 SUBJECT: Compliance Inspection Report Long Creek WWTP NPDES WW Permit No. NC0024244 Stanly County Mr. Ferris: The North Carolina Division of Water Resources conducted an inspection of the Long Creek WWTP on 8/25/2021. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES Permit #NC0024244. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". During the inspection it was noted that the Highway 52 Water Treatment Plant (WTP) is discharging backwash water and alum sludge to the Long Creek WWTP. It appears that this discharge is resulting in turbid effluent being discharged into Long Creek and Total Suspended Solid (TSS) violations of NPDES Permit Limits and SOC modified limits. It is therefore required to respond in writing to this Office within 30 days of your receipt of this letter regarding your plans or measures to be taken to address the discharge of alum sludge to Long Creek WWTP. If you should have any questions, please do not hesitate to contact Roberto Scheller with the Water Quality Regional Operations Section in the Mooresville Regional Office at 704-663-1699 or via email at roberto.schellerOncdenr.gov. Sincerely, --DoeuSigned by: Al4I zl, H Pa .e4 '—F161F869A2D84A3... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS Cc: WQS Mooresville Regional Office - Enforcement File NPDES Compliance/Enforcement Unit - Enforcement File for 1 North ar0Nn Ile p l r n of Lo,Ii.trr-ilal gni Y i Dxivian of Water N. -rces Reqianal0ll*'e MO Cast Center Avenue 5 o101I4 ;Ile Yn. 11trr.Vina 2N111 l0a1 3I610 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Section A: National Data System Coding (i.e., PCS) Form Approved. OMB No. 2040-0057 Approval expires 8-31-98 Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 1 11.1 2 [ I 3 ( NC0024244 111 121 21/08/25 117 1819I 19I Li 2011 21111111 1111111111111111(11111111 11111111111 �66 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved l 71 LJ 72 I N I 73� 1 f74 71 1 1 1 1 1 1 [80 671 1 7013 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) Long Creek WWTP 1040 Coble Ave Extension Albemarle NC 28002 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Brandon Wesley Plyler/ORC/704-984-9630/ Name, Address of Responsible Officialifitle/Phone and Fax Number Michael J Ferris,PO Box 190 Albemarle NC 280020190/City M anager/704-984-9410/7049849406 Contacted No Entry Time/Date 09:49AM 21/08/25 Exit Time/Date 11:22AM 21/08/25 Other Facility Data Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Self -Monitoring Progran Effluent/Receiving Wate Permit Effective Date 18/12/01 Permit Expiration Date 22/02/28 Flow Measurement Operations & Maintenar Records/Reports Sludge Handling Dispo5 Facility Site Review Compliance Schedules Laboratory Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signatur bb}f„�r, I {{pcJr(s) Agency/Office/Phone and Fax Numbers Roberto Scheller 76h-1-'t-®- tS- DWR/MRO WQ/707-235-2204/ 91C2A667838943E... Date 9/8/2021 Signature of ManameRi' IVIgWewer for Agency/Office/Phone and Fax Numbers Date (� Aw H P W. Corey Basi ger ' /Division of Water Quality/704-235-2194/ 9.9.21 F161F869A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 NPDES yr/mo/day 31 NC0024244 111 12J 21/08/25 17 Inspection Type 181r1 (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) The NPDES Permit (NC0024244) became effective December 1, 2018 and expires on February 28, 2022. Please be advised that in accordance with your current NPDES Permit #NC0024244, Part II, Section B (10.) Expiration of Permit; The Permittee is not authorized to discharge after the expiration date. In order to receive automatic authorization to discharge beyond the expiration date, the Permittee shall submit such information, forms, and fees as are required by the agency authorized to issue permits no later than 180 days prior to the expiration date unless permission for a later date has been granted by the Director. Flows for the calendar year 2020 were caculated with a yearly average flow of 6.247 MGD or 52.05% of the 12 MGD permitted flow. Compliance history for reported violations: 11/2020 TSS 11/2020 TSS 11/2020 TSS 10/2020 TSS 09/2020 TSS 09/2020 TSS 09/2020 TSS 09/2020 TSS 04/2021 the period August 2020 through July 2021 was reviewed with the following Monthly Average Limit Violation Weekly Average Limit Violation Weekly Average Limit Violation Weekly Average Limit Violation Monthly Average Limit Violation Weekly Average Limit Violation Weekly Average Limit Violation Weekly Average Limit Violation Total Ammonia as Nitrogen Limit Violation 5.1 % 26.5% Over Permit Limit 4% " 32.8% 9.6% 79.2% 30.7% 12.9% 33.3% Annual report for fiscal year 2020/2021 has not been prepaired. Please note that Annual reports must be submitted within 60 days of the end of the applicable 12-month review period. Customers and users are to be provided access to the report. The subject facility is under Special Order by Consent (EMC SOC WQ S19-007) with modified permit parameters for BOD (Summer/Winter), Ammonia Nitrogen (Summer/Winter), and TSS. Please note that in accordance with your SOC (SOC WQ S19-007) Item 2. (d), No later than fifteen (15) calendar days after any date identified for accomplishment of any activity listed in 2(a) above, table of Scheduled Activity, the City shall submit to the Water Quality Regional Operations Section Regional Supervisor written notice of compliance or noncompliance therewith. Please also note that quarterly progress reports detailing the work and activities undertaken and completed on the upgrades to the collection sustem are to be submitted. At time of inspection records and required information appeared to be well kept and readily available for review. At time of insepction it was noted that effluent was turbid. Effluent passes through 10 micron filters before being discharged. The Highway 52 Water Treatment Plant (WTP) reported discharging 313,000 gallons of filter backwash water to Long Creek WWTP the day of inspection. Alum sludge from the WTP is also reported being disposed of by discharging to the WWTP. The Long Creek WWTP reported TSS violations on 11/2020, 10/2020, 09/2020 and 4/2021. Violations under SOC have been addressed with stipulated penalty SP-2020-0010 and SP-2021-0001. The discharge of Alum Sludge into the sewer collection system is adversely affecting effluent discharge into Long Creek by introducing turbidity (Total Suspended Soilds) into receiving waters. Please be advised that in accordance with the Highway 52 Water Tereatment Plant NPDES Permit #0044024, Part II, Section B, 2. Duty to Mitigate, the Permittee shall take all reasonable steps to minimize, to prevent any discharge, or sludge use, or disposal in violation of this permit with a Page# 2 Permit: NC0024244 Owner - Facility: Long Creek VwVTP Inspection Date: 08/25/2021 Inspection Type: Compliance Evaluation reasonable like►ihood of adversely affecting human health or the environment. Also in accordance with NPDES Permit #0044024, Part II, Section C, 6. Removal Substances, Solids, sludge, 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. It is therefore required that the City of Albemarle submit a written plan for alternative disposal of alum sludge from Highway 52 Water Treatment Plant to the Mooresville Regional Ofice. A written response is to be sent within 30 days of receipt of inspection report. Page# 3 Permit: NC0024244 Inspection Date: 08/25/2021 Owner - Facility: Long Creek VWVTP 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 = 0 0 0 application? Is the facility as described in the permit? 0 0 ❑ # Are there any special conditions for the permit? ❑ 0 0 Is access to the plant site restricted to the general public? 0 ❑ ❑ Is the inspector granted access to all areas for inspection? ❑ 0 ❑ Comment: The current NPDES Permit NC0024244 became effective December 1, 2018 and expires on February 28, 2022. The permit is for the discharge of treated wastewater into Long Creek in the Yadkin -Pee Dee River Basin. Record Keeping 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 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 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: Annual report for 20/21 is in process. Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ El El El ❑ = ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 4 Permit: NC0024244 Inspection Date: 08/25/2021 Owner - Facility: Long Creek WNTP Inspection Type: Compliance Evaluation 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: Compliance Schedules Is there a compliance schedule for this facility? Is the facility compliant with the permit and conditions for the review period? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ Comment: The subject facility is under SOC WQ S19-007 and has not been in compliance with relaxed permit limits. Violation for TSS are noted in summary section of inspection. 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: 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 Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE Page# 5 Permit: NC0024244 Inspection Date: 08/25/2021 Owner - Facility: Long Creek WVVTP Inspection Type: Compliance Evaluation Grit Removal 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 ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? ❑ 0 0 Is flow meter calibrated annually? "n 0 0 0 Is the flow meter operational? ❑ 0 0 (If units are separated) Does the chart recorder match the flow meter? ❑ 0 0 Comment: Influent flow meter was last calibrated on June15, 2021 by Fortech. Influent Sampling # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? Is the tubing clean? # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is sampling performed according to the permit? Comment: At time of inspection sampler was recorded at 4 degrees Celsius. 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? Comment: Influent pump station consist of 4 screw lift pumps. Yes No NA NE ❑ ❑ ❑ ❑ Cl ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 6 Permit: NC0024244 Inspection Date: 08/25/2021 Owner - Facility: Long Creek WvVTP 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? 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? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Comment: Second lift station consist of 4 screw lift pumps located at secondary treatment.. 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? Is the DO level acceptable?(1.0 to 3.0 mg/I) Comment: Secondary Clarifier Is the clarifier free of black and odorous wastewater? Yes No NA NE Ext. Air Surface ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ Page# 7 Permit: NC0024244 Inspection Date: 08/25/2021 Owner - Facility: Long Creek WWTP Inspection Type: Compliance Evaluation Secondary Clarifier 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: Effluent from secondary clarifiers turbid. Pumps-RAS-WAS Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Comment: Filtration (High Rate Tertiary) Type of operation: Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Comment. Effluent turbid Disinfection -Gas Are cylinders secured adequately? Are cylinders protected from direct sunlight? Is there adequate reserve supply of disinfectant? Is the level of chlorine residual acceptable? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Yes No NA NE ❑ ❑ ❑ ❑ El El El 0 Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ _ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 8 Permit: NC0024244 Inspection Date: 08/25/2021 Inspection Type: Compliance Evaluation Owner - Facility: Long Creek VWVfP Disinfection -Gas Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de -chlorination? Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No. 7782-50-5)? If yes, then is there a Risk Management Plan on site? If yes, then what is the EPA twelve digit ID Number? (1000- - ) If yes, then when was the RMP last updated? Comment: Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ 1000-0012-3092 De -chlorination Yes No NA NE Type of system ? Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? 0 0 ❑ Is storage appropriate for cylinders? 0 0 0 # Is de -chlorination substance stored away from chlorine containers? 0 0 0 Are the tablets the proper size and type? 0 0 ❑ Comment: Sodium Bisulfite used for dechlorination Are tablet de -chlorinators operational? 0 0 0 Number of tubes in use? Comment: Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? 0 0 0 Is flow meter calibrated annually? 0 0 0 Is the flow meter operational? ❑ 0 0 (If units are separated) Does the chart recorder match the flow meter? 0 0 ❑ Comment: Effluent flow meter last calibrated 6/15/2021 by Fortech. Solids Handling Equipment Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ N ❑ Page# 9 Permit: NC0024244 Inspection Date: 08/25/2021 Owner - Facility: Long Creek WWTP Inspection Type: Compliance Evaluation Solids Handling Equipment Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ Comment: Bio-soilds are thickened and removed for disposal at Rocky River WWTP incinerator. Page# 10