HomeMy WebLinkAboutNC0025861_Compliance Evaluation Inspection_20220208ROY COOPER
Gorerrror
ELIZABETH S_ RISER
S. DANIEL SMITH
nrmcror
NORTH CAROLINA
Environmental gel Wily
February 8, 2022
Mr. Thomas Shrewsbury
Public Works Director
101 West First Street
Lowell, NC 28098
Subject: Notice of Deficiency
NOD-2022-PC-0019
Compliance Inspection
Lowell WWTP
NPDES Permit No. NC0025861
Gaston County
Dear Mr. Shrewsbury:
Enclosed is a copy of the Compliance Inspection report for the inspection conducted at the
subject facility on January 25, 2022, by Ori Tuvia. Ron Haynes' and Daniel Dougherty's
cooperation during the site visit was much appreciated. Please advise the staff involved with this
NPDES Permit by forwarding a copy of the enclosed report.
Overall, the facility appeared to be properly operated and well maintained. However, at the
time of the inspection, it was noted that residuals handling capability appeared to be limited.
During the inspection, the following observations indicated potential inadequate wasting: (1) foam
level observed in the aeration basin; (2) floating solids observed in the secondary clarifier; and (3)
low rate of settleability (reached about 600m1 after 30 minutes). At the time of the inspection, the
drying beds were full and there was no space for additional residuals. It is highly recommended
that the facility request Technical Assistance to explore options related to solids and/or residuals
management.
In addition, there was evidence of stormwater erosion around the influent pump station.
Stormwater control measures (such as riprap) should be placed along the side and entrance to the
influent pump station to prevent erosion damage and to prevent stormwater from flowing into the
pump station wet well.
You are requested to respond to this Notice in writing within thirty (30) days of receipt
indicating your Plan of Action to ensure future compliance.
North Carolina Department of Euviranmenial Quality I Division of Water Resources
Mooresville RegoaiaiOFFIet I.610 East Center Avenue, Sutte 301 I Mooresville, North Carolina 28115
704.bfi3.1691
The report should be self-explanatory; however, should you have any questions
concerning this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at
ori. tuvia@ncdenr. gov.
Sincerely,
DocuSigned by:
A14CC681AF27425...
W. Corey Basinger
Regional Supervisor
Mooresville Regional Office
Division of Water Resources
Cc: DWR Laserfiche
United States Environmental Protection Agency
EPA 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
1 IN I
21 1 1 1
Code NPDES yr/mo/day Inspection
2 L 3 I NC0025861 111 121 22/01/25 117
Type
1810I
I I 1 1 1
Inspector Fac Type
191 S I 2011
1 1 1 1 1 1 11 1 1 1 I I I 1 1 1 1 1 1 I I I I I
1 11
1 1 1 I 1 P6
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved
67I1.0 I 70I3 I 71IN I 72 I N I 731 1 74 71
I I 1
I I I I I I 1l80
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
POTW name and NPDES Dermit Number)
Lowell WWTP
NCSR 2380
Lowell NC 28098
Entry Time/Date
09:30AM 22/01/25
Permit Effective Date
20/07/01
Exit Time/Date
11:OOAM 22/01/25
Permit Expiration Date
25/01/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Daniel James Dougherty/ORC/704-477-5514/
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Daniel J Dougherty,Saxony Dr Lowell NC 28098/ORC/704-477-5514/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran Sludge Handling DispoFacility Site Review 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
Ori A Tuvia
aiSug.sg grin gc or(s) Agency/Office/Phone and Fax Numbers
Date
2/8/2022
�� DW R/M RO WQ/704-663-1699/
`— BB057A2DE017498...
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
W. Corey Basinger DWR/Division of Water Quality/704-235-2194/
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
DocuSigned by:
2/8/2022
Page# 1
"-A14CC681AF27425...
NPDES yr/mo/day
31 NC0025861 111 121 22/01/25
I17
Inspection Type
18 [j
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page# 2
Permit: NC0025861
Inspection Date: 01/25/2022
Owner - Facility: Lowell WWTP
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 El El ❑
application?
Is the facility as described in the permit? • El El El
# Are there any special conditions for the permit? El • El El
Is access to the plant site restricted to the general public? • ❑ ❑ ❑
Is the inspector granted access to all areas for inspection? • El El El
Comment: The subject permit expires on 1/31/2025
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?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
•
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
• ❑ ❑ ❑
Comment: The records reviewed during the inspection were organized and well maintained.
DMRs, COCs, Calibration logs and ORC logs were reviewed for the period April 2021
through June 2021.
Page# 3
Permit: NC0025861
Inspection Date: 01/25/2022
Owner - Facility: Lowell WWTP
Inspection Type: Compliance Evaluation
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?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ • ❑
Comment: On -site field analyses (dissolved oxygen, pH, temperature, total residual chlorine) are
performed under the City's field laboratory certification #5082. PAR Labs, Inc. has
been contracted to perform influent and effluent analyses. K&W Labs, Inc. has also
been contracted to perform the chronic toxicity analyses. The laboratory
instrumentation used for field analyses appeared to be properly calibrated/verified and
documented
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?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
II ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: The subject permit requires composite biochemical oxygen demand (BOD) and TSS
influent samples.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? • ❑ ❑ ❑
Is sample collected below all treatment units? • ❑ ❑ ❑
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 the facility sampling performed as required by the permit (frequency, sampling type • ❑ ❑ ❑
representative)?
Comment: The subject permit requires composite and grab effluent samples.
Operations & Maintenance Yes No NA NE
Page# 4
Permit: NC0025861
Inspection Date: 01/25/2022
Owner - Facility: Lowell WWTP
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ❑ • ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable El El El
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Overall the facility appeared to be properly operated and well maintained. However, at
the time of the inspection, it was noted that residuals handling capability appeared to
be limited. During the inspection, the following observations indicate potential
inadequate wasting: (1) foam level observed in the aeration basin; (2) floating solids
observed in the secondary clarifier; and (3) low rate of settleability (reached about
600m1 after 30 minutes). At the time of the inspection, the drying beds were full and
there was no space for additional residuals. It is highly recommended that the facility
request Technical Assistance to explore options related to solids and/or residuals
management. Additionally at the time of the inspection, there was evidence of
stormwater erosion around the influent pump station
Bar Screens Yes No NA NE
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? ■ ❑ El El
Is the unit in good condition? • El El El
Comment: The facility is equipped with mechancial and manual bar screens (coarse).
Flow Measurement - Influent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: Flow meter is calibrated/verified annually
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Pump Station - Influent Yes No NA NE
Is the pump wet well free of bypass lines or structures? • El El ❑
Is the wet well free of excessive grease? • El El El
Are all pumps present? • ❑ El El
Are all pumps operable? • El El El
Are float controls operable? • El El El
Page# 5
Permit: NC0025861
Inspection Date: 01/25/2022
Owner - Facility: Lowell WWTP
Inspection Type: Compliance Evaluation
Pump Station - Influent
Is SCADA telemetry available and operational?
Is audible and visual alarm available and operational?
Yes No NA NE
• ❑ • ❑
Comment: SCADA is not available however, there is an auto dialer to contact the ORC in case of
power outage. At the time of the inspection, there was evidence of stormwater erosion
around the influent pump station. Stormwater control measures (such as riprap)
should be placed along the side and entrance to the influent pump station to prevent
erosion damage and stormwater flowing into the pump station wet well.
Aeration Basins Yes No NA NE
Mode of operation
Type of aeration system Diffused
Is the basin free of dead spots? • ❑ ❑ ❑
Are surface aerators and mixers operational? ❑ El • El
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? ❑ ❑ El •
Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ El •
Comment: The facility uses the contact stabilization treatment process. Sodium Hydroxide is
added. The foam level observed at the inspection is estimated at around 40%.
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)
Yes No NA NE
• ❑ ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
❑ • ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: At the time of the inspection, most of the clarifier surface was observed to be covered
by floating sludge.
However, no scum was observed to pass through the weir.
Page# 6
Permit: NC0025861
Inspection Date: 01/25/2022
Owner - Facility: Lowell WWTP
Inspection Type: Compliance Evaluation
Secondary Clarifier
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?
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: About 900 Ibs. of chlorine stored on site.
De -chlorination
Type of system ?
Is the feed ratio proportional to chlorine amount (1 to 1)?
Is storage appropriate for cylinders?
# Is de -chlorination substance stored away from chlorine containers?
Are the tablets the proper size and type?
Yes No NA NE
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ • ❑ ❑
❑ ❑ • ❑
Yes No NA NE
Gas
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
Comment: The chlorination and dechlorination cylinders are stored together inside a building
equipped with ventilation and a leakage detection system.
Are tablet de -chlorinators operational?
Number of tubes in use?
Comment:
Flow Measurement - Effluent
# Is flow meter used for reporting?
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: Flow meter is calibrated/verified annually
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 7
Permit: NC0025861
Inspection Date: 01/25/2022
Owner - Facility: Lowell WWTP
Inspection Type: Compliance Evaluation
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: The effluent appeared clear
Drying Beds
Is there adequate drying bed space?
Is the sludge distribution on drying beds appropriate?
Are the drying beds free of vegetation?
# Is the site free of dry sludge remaining in beds?
Is the site free of stockpiled sludge?
Is the filtrate from sludge drying beds returned to the front of the plant?
# Is the sludge disposed of through county landfill?
# Is the sludge land applied?
(Vacuum filters) Is polymer mixing adequate?
Yes No NA NE
• ❑ ❑ ❑
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: Dewatered sludge is transported to landfill. At the time of the inspection, the drying
beds were full and there was no space for additional residuals. It is highly
recommended that the facility request Technical Assistance to explore options for solids
and/or residuals management.
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
• ❑ ❑ ❑
• ❑ ❑ ❑
▪ ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: The standby generator is tested (automatically) once per week. The City/Permittee
contracts a company to service the generator twice per year.
Page# 8