Loading...
HomeMy WebLinkAboutNC0006190_NOV-2022-PC-0213_20220420ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Certified Mail # 7020 3160 0000 3277 0792 Return Receipt Requested Everette Owens, Plant Manager South Fork Industries, Inc. Post Office Box 742 Maiden, NC 28650-0742 SUBJECT: Notice of Violation Compliance Evaluation Inspection South Fork Industries, Inc. WWTP NPDES Permit No. NC0006190 Catawba County Tracking #: NOV-2022-PC-0213 Dear Mr. Owens: NORTH CAROLINA Environmental Quality April 20, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on April 12, 2022, by Mr. Wes Bell of this Office. Please advise the facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding the enclosed report. This report is being issued as a Notice of Violation (NOV) due to the permittee's failure to provide proper operation and maintenance at the wastewater treatment system which led to the unpermitted discharges of oil into Clark Creek via effluent discharge. Please be advised that the failure to provide proper operation and maintenance and the unpermitted discharges of oil are violations of the subject NPDES Permit, North Carolina General Statute (G.S.) 143-215.1 and G.S. 143-215.83(a)/Unlawful Discharge of Oil. Please note that G.S. 143-215.6A provides for a civil penalty of not more than twenty-five thousand dollars ($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, 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 Pursuant to G.S.143-215.88A, any person who is deemed to be in violation of G.S. 143-215.83, or who fails to comply with the clean-up requirements of G.S. 143-215.84, shall incur, in addition to any other penalty provided by law, a penalty in an amount not to exceed five thousand dollars ($5,000.00) for each such violation. Penalties may also be assessed for any damage to surface waters of the State that may result from the violation. D_E o,.mworkt G.ed o � North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 This Office is also concerned with the facility's compliance record since December 2020. A significant number of permit effluent limitation violations have been reported including nine (9) chronic toxicity failures. The operation of this wastewater treatment poses significant challenges for the ORC and staff due to the minimal influent loading during the weekends/shut down periods, new products being produced, and aging equipment. Please be advised that the subject NPDES Permit [Part II, Section C(2)] requires the Permittee to properly operate and maintain all facilities and systems at all times. It is therefore requested that a written response be submitted to this Office by Mav 18, 2022, detailing the actions taken to address all of the operation and maintenance concerns and violations discussed in this report. This Office also requests that a Toxicity Identification Evaluation (TIE) be performed during the next effluent chronic toxicity sampling event as specified in the NPDES Permit [Part I, Section A(4) TIE] to assist in determining the causes of the toxicity failures. These results must be submitted to this Office no later than sixty (60) days following completion of the tests. In responding to this report, please address your comments to the attention of Mr. Wes Bell. Should you have any questions concerning this Notice, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.bell@ncdenr.gov. Enclosure: Inspection Report Pictures Cc: NPDES Program Files — Laserfiche D_E Sincerely, DocuSigned by: '—A14CC681 AF27425... W. Corey Basinger, Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue. Suite 301 1 Mooresville. North Carolina 28115 704.663.1699 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 Code 1 IN I 2 IL 21 1 1 1 1 NPDES yr/mo/day Inspection I 3 I NC0006190 111 121 22/04/12 117 Type 18 i i I I 1 1 1 Inspector Fac Type 191 S I 201 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 67I2.0 I 70I4 I 71IN I 72 I N I 73I I 74 751 I I 1 I I I I I I 180 l Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) South Fork Industries - Maiden Plant 100 W Pine St Maiden NC 28650 Entry Time/Date 09:10AM 22/04/12 Permit Effective Date 19/02/01 Exit Time/Date 01:10PM 22/04/12 Permit Expiration Date 23/05/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Donald A Burkey/ORC/704-736-8960/ James S. Rhyne//828-428-9920 / Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Everette J Owens,PO Box 742 Maiden NC 286500742/Plant Manager/704-732-6946/7047322352 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) Wes Bell of Inspector(s) Agency/Office/Phone and Fax Numbers Date DWR/MRO WQ/704-663-1699 Ext.2192/ 4/20/2022 DocuSigned by:L11)&3, Glit A61696D90CC3437... 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: 4/20/2022 "-A14CC681AF27425... Page# 1 3I NPDES yr/mo/day N C 0006190 111 121 22/04/12 I17 Inspection Type 18 [j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) OIL DISCHARGE: Oil was observed throughout a concrete driveway (adjacent to an air emission system) and discharging into a drain adjacent to the secondary containment structure for the brine storage tank, etc. This Office was later informed that the drain is connected to the wastewater treatment plant. The oil has negatively impacted the wastewater treatment plant and was observed entering the effluent discharge during the inspection. Please be advised that the NPDES Permit [Part II, Section C(2) Operation & Maintenance of Pollution Controls] requires the Permittee to properly operate and maintain the wastewater treatment facility at all times. In addition, the discharge of oil is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.83(a)/Oil Pollution & Hazardous Substances Control Act - Unlawful Discharges. The oil discharge must be ceased immediately and all affected areas properly cleaned up. BAR SCREEN SECTION cont'd: The dumpster housing the lint removed by the shakers continues to contain a significant amount of wastewater. No structural issues were noted on the containment berm around the dumpster. The permittee must evaluate options to ensure no wastewater is discharged either onto the concrete driveway during removal (by contracted company) or on the roadways during transportation to the landfill. Page# 2 Permit: NC0006190 Inspection Date: 04/12/2022 Owner - Facility: South Fork Industries - Maiden Plant 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 ❑ ❑•❑ application? Is the facility as described in the permit? • ❑ ❑ ❑ # Are there any special conditions for the permit? • ❑ ❑ ❑ Is access to the plant site restricted to the general public? • ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑ Comment: The Division was notified by the facility on 6/14/2021 that the production rate had increased above 58,900 lbs./day. The Division's database was updated to the applicable effluent limits and monitoring requirements (per Permit) as result of the increased production rate. Record Keeping Yes No NA NE 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? ❑ ❑ • ❑ Page# 3 Permit: NC0006190 Inspection Date: 04/12/2022 Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: The records reviewed during the inspection were organized and well maintained. Discharge Monitoring Reports (eDMRs) were reviewed for the period January 2021 through February 2022. No monitoring violations were reported; however, numerous effluent limit violations were reported. Daily maximum and monthly average effluent BOD violations were reported in February 2021 (7 total), March 2021 (2 total), May 2021 (2 total), June 2021 (1 daily maximum violation only), January 2022 (4 total) and February 2022 (3 total). A monthly average effluent COD violation was reported in April 2021 and two daily maximum effluent pH violations were reported in February 2022. Effluent chronic toxicity failures were reported in February 2021, March 2021, April 2021, December 2021, January 2022 and February 2022. All above -noted violations will be separately addressed by the Division through the issuances of either Notice of Violations (NOVs) and/or NOV/civil penalty assessments. 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 and temperature) are performed under laboratory certification #5302. Statesville Analytical (all permit parameters except field and toxicity) and Meritech, Inc. (toxicity) have been contracted to provide analytical support. 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 • ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The subject permit requires composite influent color samples. The facility has been previously granted a variance to perform time -based composite samples. Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Yes No NA NE Page# 4 Permit: NC0006190 Inspection Date: 04/12/2022 Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE 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. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, • El ❑ ❑ and sampling location)? Comment: 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 • ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The ORC and staff continue to deal with the challenges of operating the wastewater facility due to the lack of influent production flows throughout the weekend (Friday afternoon through Monday morning). Although staff provide nutrient additions during the weekends, the wastewater facility experiences treatment difficulties in dealing with the re -introduction of the high volume of production wastewater. In addition, the oil being discharged into the wastewater treatment system has also interfered with the treatment process including the discharge of oil into the effluent. See also Summary/Oil Discharge. 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? Yes No NA NE • • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Two of three shakers were operational and in service. The wastewater also flows through a manual bar screen prior to the aeration basins. See Summary Section for additional comments. Page# 5 Permit: NC0006190 Inspection Date: 04/12/2022 Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE Mode of operation Type of aeration system Surface Is the basin free of dead spots? El • El El Are surface aerators and mixers operational? • ❑ ❑ ❑ Are the diffusers operational? ❑ ❑ • ❑ Is the foam the proper color for the treatment process? ❑ El • El Does the foam cover less than 25% of the basin's surface? El • El El Is the DO level acceptable? • ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/I) • ❑ ❑ ❑ Comment: Both aeration basins were operational and in service. The surfaces of both aeration basins were covered with foam; however, no excessive foaming was observed in the clarifiers. One of the surface aerators was in process of being reinstalled following repairs. Supplements (microbial, nutrient, etc.) are added to the aeration basins. Secondary Clarifier Yes No NA NE 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? • El El El 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: Both clarifiers were operational; however, significant rust and deterioration (weirs, skimmer arms, etc.) were observed on both clarifiers. Oil was observed in the clarifier effluent. The clarifier effluents are combined prior to post aeration, flow measurement and outfall discharge. Pumps-RAS-WAS Are pumps in place? Are pumps operational? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 6 Permit: NC0006190 Inspection Date: 04/12/2022 Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation Pumps-RAS-WAS Are there adequate spare parts and supplies on site? Comment: Chemical Feed Is containment adequate? Is storage adequate? Are backup pumps available? Is the site free of excessive leaking? Yes No NA NE Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The polymers used for the color reduction have been significantly reduced. The polymers are added at both the aeration basin effluents and secondary clarifier center wells. 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: The flow meter is calibrated twice per year and was last calibrated on 2/23/22 by Clearwater, Inc. 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? Yes No NA NE ❑ ❑ ❑ • ❑ ❑ ❑ • Comment: The discharge appeared light purple with trace suspended solids and minimal foam. Oil was also observed in the effluent discharge (following post aeration). Lagoons Yes No NA NE Type of lagoons? # Number of lagoons in operation at time of visit? 1 Are lagoons operated in? # Is a re -circulation line present? ❑ ❑ • ❑ Is lagoon free of excessive floating materials? ❑ • ❑ ❑ # Are baffles between ponds or effluent baffles adjustable? ❑ ❑ • ❑ Are dike slopes clear of woody vegetation? • ❑ ❑ ❑ Page# 7 Permit: NC0006190 Inspection Date: 04/12/2022 Owner - Facility: South Fork Industries - Maiden Plant Inspection Type: Compliance Evaluation Lagoons Yes No NA NE Are weeds controlled around the edge of the lagoon? • ❑ ❑ ❑ Are dikes free of seepage? ❑ El • El Are dikes free of erosion? • ❑ ❑ ❑ Are dikes free of burrowing animals? • ❑ ❑ ❑ # Has the sludge blanket in the lagoon (s) been measured periodically in multiple ❑ ❑ • ❑ locations? # If excessive algae is present, has barley straw been used to help control the growth? El El El Is the lagoon surface free of weeds? ■ ❑ ❑ ❑ Is the lagoon free of short circuiting? • ❑ ❑ ❑ Comment: The wastewater sludge is land applied under Synagro's Land Application Permit. Page# 8 All photographs taken during April 12, 2022 Compliance Evaluation Inspection. PHOTO #1— Oil being discharged into drain that leads to wastewater plant. PHOTO #2 — Oil flowing down concrete driveway into drain that leads to wastewater treatment plant. PHOTO #3 — Oil discharging over the secondary clarifier weir.