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Home My WebLink AboutNC0046809_NOV2022PC0074_20220310ROY COOPER. Governor ELIZABETH S. BISER Secretary S. DANIEL SMITH Director Western NC Conference Center Attn:, Darrell Gaines P.O. Box 150 Browns Summit, NC 27214-0150 NORTH CAROLINA Environmental Quality March 10, 2022 SUBJECT: Compliance Evaluation Inspection & Notice of Violation: NOV-2022-PC-0074 Cornerstone Conference & Resource Center Wastewater Treatment Plant NPDES Permit Number NC0046809 Guilford County Dear Mr. Gaines: Mr. Ron Boone, of the NC Division of Water Resources (NCDWR), Winston-Salem Regional Office (WSRO), conducted a compliance evaluation inspection of the Cornerstone Conference and Resource Center's wastewater treatment plant, on February 23, 2022. Mr. Boone met with Ken Wahl, Todd Robinson, Josh Powers, and Dave McDaniel, all of Envirolink Inc., which currently operates the plant. Inspection findings are detailed in the attached Water Compliance Inspection Report and summarized below. Violations and deficiencies noted during the inspection include: 1. Plant shows many areas of heavy corrosion and/or need for maintenance. 2. There are no sludge removal records. 3. Permittee has no records of plant operation. This office is issuing a Notice of Violation for this inspection. Please be aware that the Division may take enforcement action against any permittee who fails to comply with any requirement of their permit. Pursuant to NC General Statute (NCGS) 143-215.6A, a civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed against any person who violates or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1. NORTH D E neo.rtm.m .f Envim.mo.t.i Ou.i` North Carolina Department of Environmental Quality Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 If you have any questions or concerns, please do not hesitate to contact Mr. Boone by phone at 336-776-9690, or by email at ron.boone@ncdenr.gov. Thank you in advance for your time and attention to this matter. Sincerely, Docu Signed by: L._0, 1. mlu- 145B49E225C94EA... Lon T. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: 1. Water Compliance Inspection Report 2. Envirolink Inc. 773 Sanford Ave Mocksville, NC 27028 cc: Laserfiche LD_E NORTH CAROLINA gapartmeM of Environmental quaky North Carolina Department of Environmental Quality j Division of Water Resources Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 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 Code I 2 IL NPDES yr/mo/day Inspection Type Inspector Fac I 3 I NC0046809 111 121 22/02/23 117 18 1 19 I S I 201 Type 21IIIIII IIIIIIIIIII IIIIIII I IIIIII IIIIIIIIIII P6 Inspection 671 Work Days Facility Self -Monitoring I 70I Evaluation Rating I 711 B1 1 72 QA I N I 73I I I I Reserved 74 71 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 Dermit Number) Cornerstone Conference and Resource Center WWTP 7545 US Hwy 29 N Browns Summit NC 27214 Entry Time/Date 12:30PM 22/02/23 Permit Effective Date 16/07/01 Exit Time/Date 02:OOPM 22/02/23 Permit Expiration Date 21/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Ronald Keith Wall/ORC/336-212-9305/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Darrell Gaines,PO Box 150 Browns Summit NC 272140150//336-656-7936/3366567554 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 Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date Ron Boone DWR/WSRO WQ/336-776-9690/ 1- DocuSigned by: onaecl Boon, 3/9/2022 B 29 Feeesr-2f t9de6... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date FDocuSigned by: L—o, TS . A,acr 3/9/2022 145B49E225C94EA... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 31 NPDES yr/mo/day N C0046809 111 121 22/02/23 I17 Inspection Type 18 [j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Ron Boone, of the NC Division of Water Resources (DWR), Winston-Salem Regional Office, met with Ron Wahl, Todd Robinson, Josh Powers, and Dave McDaniel, all of Envirolink Inc, which currently operates the wastewater treatment plant at the Cornerstone Conference Center, to perform a compliance evaluation inspection on 2/23/2022. Inspection findings are summarized below and in the following checklist. The operator stated he alternates blowers manually and tries to maintain the DO level in the mixed liquor at about 3.2mg/I. The flow is quite light due to a low number of people on site. Only half the plant is in operation. Operators brainstorming ideas to provide enough food to develop and maintain a viable bacterial population in the aeration basin. Based on previous success with it at other plants, Envirolink's Assistant Director of Operations, Dave McDaniel, is recommending feeding pure cane sugar into the plant for a carbon source. The condition of the mixed liquor at the time of the inspection is judged to have been slightly less than desirable due primarily to the lack of a sufficient food source, but it still appears to be good enough to produce a good quality effluent. No foul odors were noted in the plant. The water in the clarifier was a bit cloudy. The effluent looks clear and odorless and does not impart solids of any type or create a foam in the receiving stream. There are no records of sludge removal. Operators should be getting manifests, receipts, or invoices from septic haulers hired to pump sludge from the plant and keeping them on file for a minimum of three years. The permittee must also get copies of these records and keep them on file. Failure to do so is a violation of the permit as they are the actual permittee. If this is not done, and something suddenly happens to the operator(s), they may purposely or inadvertently take the records with them when they leave. They may even be destroyed. Likewise, the permittee must have copies of all treatment plant related records. The operator stated he alternates blowers manually and tries to maintain the DO level in the mixed liquor at about 3.2mg/I. Flow is quite light due to a low number of people on site.Only half the plant is in operation. Operators brainstorming ideas to provide enough food to develop and maintain a viable bacterial population in the aeration basin. Based on previous success with it at other plants, Envirolink's Assistant Director of Operations, Dave McDaniel, is recommending feeding pure cane sugar into the plant for a carbon source. The condition of the mixed liquor at the time of the inspection is judged to have been slightly less than desirable due primarily to the lack of a sufficient food source, but it still appears to be good enough to produce a good quality effluent. No foul odors were noted in the plant. The water in the clarifier was a bit cloudy. The effluent looks clear and odorless and does not impart solids of any type or create a foam in the receiving stream. The tank used for sludge is just a sludge waste tank, not a digester. Current operator (Envirolink) did not think there was a sludge waste tank at the plant and was therefore having a septic hauler simply pump sludge from the clarifier. On day of inspection, however, Envirolink's Assistant Director, Dave McDaniel, was there and identified a small tank at the inlet end of the package plant as a waste sludge tank. Minor plumbing modifications must be made to make it operational as a sludge waste tank and Ken Wahl, the ORC, said he should be able to get the center's maintenance people to install the necessary piping within a week or two. Housekeeping at the plant is fine. However, much of the plant structure is insufficiently maintained and heavily corroded, which if left unchecked could very well eventually result if catastrophic structural failure. The permittee must take action to repair damaged areas. Right now is also an ideal opportunity to do so given that one side of the plant is shut down and completely empty of wastewater. Page# 2 Permit: NC0046809 Inspection Date: 02/23/2022 Owner - Facility: Cornerstone Conference and Resource C 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: None 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 ❑ • ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ Page# 3 Permit: NC0046809 Inspection Date: 02/23/2022 Owner - Facility: Cornerstone Conference and Resource C Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: There are no records of sludge removal. Operators should be getting manifests, receipts, or invoices from septic haulers hired to pump sludge from the plant and keeping them on file for a minimum of three years. The permittee must also get copies of these records and keep them on file. Failure to do so is a violation of the permit as they are the actual permittee. If this is not done, and something suddenly happens to the operator(s), they may purposely or inadvertently take the records with them when they leave. They may even be destroyed. Likewise, the permittee must have copies of all treatment plant related records. 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: None Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ IN ❑ 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: None Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, MEI ❑ ❑ and sampling location)? Comment: None Flow Measurement - Effluent # Is flow meter used for reporting? Is flow meter calibrated annually? Yes No NA NE • ❑ ❑ ❑ ❑ • ❑ ❑ Page# 4 Permit: NC0046809 Inspection Date: 02/23/2022 Owner - Facility: Cornerstone Conference and Resource C Inspection Type: Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: Flow requirement is instantaneous. Measured by timing how long it takes to fill a bucket and then calculated. 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: Wire mesh used as bar screen. Yes No NA NE • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ 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? • ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ • Is the DO level acceptable?(1.0 to 3.0 mg/I) ❑ ❑ ❑ • Comment: Operator stated he alternates blowers manually and tries to maintain the DO level in the mixed liquor at about 3.2mg/I. Flow is quite light due to a low number of people on site.Only half the plant is in operation. Operators brainstorming ideas to provide enough food to develop and maintain a viable bacterial population in the aeration basin. Based on previous success with it at other plants, Envirolink's Assistant Director of Operations, Dave McDaniel, is recommending feedinq_pure cane sugar into the plant for a carbon source. The condition of the mixed liquor at the time of the inspection is judged to have been slightly less than desirable due primarily to the lack of a sufficient food source, but it still appears to be good enough to produce a good quality effluent. No foul odors were noted in the plant. The water in the clarifier was a bit cloudy. The effluent looks clear and odorless and does not impart solids of any type or create a foam in the receiving stream. Page# 5 Permit: NC0046809 Inspection Date: 02/23/2022 Owner - Facility: Cornerstone Conference and Resource C 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) Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • Comment: Water in clarifier slightly cloudy but solids separation appears good. No loss over weir. Skimmer appears effective. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? • ❑ ❑ ❑ Are the tablets the proper size and type? • ❑ ❑ ❑ Number of tubes in use? 2 Is the level of chlorine residual acceptable? ❑ ❑ El • Is the contact chamber free of growth, or sludge buildup? • ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ • ❑ Comment: None De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? El • ❑ ❑ Is storage appropriate for cylinders? • El El El # Is de -chlorination substance stored away from chlorine containers? • El ❑ ❑ Are the tablets the proper size and type? • El El El Comment: None Are tablet de -chlorinators operational? • El ❑ ❑ Number of tubes in use? 2 Comment: None Page# 6 Permit: NC0046809 Inspection Date: 02/23/2022 Owner - Facility: Cornerstone Conference and Resource C Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE Pumps-RAS-WAS Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Comment: Air lift pumps. 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: None Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Anaerobic Digester Yes No NA NE Type of operation: No cover Is the capacity adequate? El El El • # Is gas stored on site? El • El El Is the digester(s) free of tilting covers? ❑ ❑ • ❑ Is the gas burner operational? ❑ El • El Is the digester heated? El • El El Is the temperature maintained constantly? ❑ ❑ • ❑ Is tankage available for properly waste sludge? El • ❑ ❑ Comment: This is actually just a sludge waste tank, not a digester. Current operator (Envirolink) did not think there was a sludge waste tank at the plant and was therefore having a septic hauler simply pump sludge from the clarifier. On day of inspection, however, Envirolink's Assistant Director, Dave McDaniel, was there and identified a small tank at the inlet end of the package plant as a waste sludge tank. Minor plumbing modifications must be made to make it operational as a sludge waste tank and Ken Wahl, the ORC, said he should be able to get the center's maintenance people to install the necessary piping within a week or two. Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? El • El El 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? Page# 7 Permit: NC0046809 Inspection Date: 02/23/2022 Owner - Facility: Cornerstone Conference and Resource C Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Comment: Many parts of the plant structure are starting to corrode excessively. Immediate action should be taken to begin repairing corroded areas. The fact that only a single train is in use provides prime opportunity for such repairs. Unchecked corrosion will eventually result in structural failure. The director of the facility, Darrell Gaines, was briefed on these issues over the phone and also briefed on the possibility of plant replacement. Housekeeping at the plant is fine. However, much of the plant structure is insufficiently maintained and heavily corroded, which if left unchecked could very well eventually result if catastrophic structural failure. The permittee must take action to repair damaged areas. Right now is also an ideal opportunity to do so given that one side of the plant is shut down and completely empty of wastewater. Page# 8