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Home My WebLink AboutNC0020061_Compliance Evaluation Inspection_20220504DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director NORTH CAROLINA Environmental Quality May 4, 2022 Certified Mail 7017 2680 0000 2235 8663 Return Receipt Requested James Buddy Gwaltney, Mayor Town of Spring Hope PO Box 87 Spring Hope, NC 27882 Subject: Notice of Violation NOV-2022-PC-0258 Compliance Evaluation Inspection Town of Spring Hope WWTP NPDES Permit No. NC0020061 Nash County Dear Mr. Gwaltney: On March 23, 2022, Colleen Cohn and Mitchell Hayes of the Raleigh Regional Office (RRO) conducted an inspection at the subject facility. The cooperation of William Lamm of Envirolink Inc., Operator in Responsible Charge (ORC) of the facility, was greatly appreciated. Findings during the inspection were as follows: 1. The current NPDES permit was issued effective on August 1, 2020 and will expire on October 31, 2024. A copy of the current NPDES permit was not available on -site. A copy of the previous NPDES permit, which expired October 31, 2019, was available. Please ensure that a copy of the current NPDES permit is available on -site. 2. The 0.40 MGD wastewater package treatment plant consists of mechanical and manual bar screens, manual grit removal, influent ultrasonic flow meter, two (2) aeration chambers, two (2) circular clarifiers, one (1) aerobic digester, two (2) tertiary clarifiers, liquid chlorination and contact chambers, cascade aeration, and liquid de -chlorination and contact chambers. 3. The plant discharges to the Tar River which is classified as WS-V; NSW waters in the Tar -Pamlico River Basin. 4. Envirolink, Inc. is contracted to operate the WWTP. The primary ORC is William Lamm. The ORC logbook was readily available for review and up to date. NORTH CAROLINA E, Department of M Environmental Quality North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Town of Spring Hope WWTP NPDES Permit No. NC0020061 Nash County Page 2 of 4 5. The mechanical bar screen was not operable at the time of the inspection and a moderate amount of debris buildup was observed on the bar screens. Our records indicate that the mechanical bar screen was also not operable during the inspections conducted on April 22, 2015 and November 14, 2018. Additionally, the motor for the mechanical bar screen appeared to have been removed. Within 30-days receipt of this letter, please submit a written response to this office outlining the schedule you will take or have taken to repair the mechanical bar screen and bring it back into operation. 6. The influent flow meter was calibrated on September 15, 2021, by Chadwick Instrument Service. During the inspection, the chart recorder was not recording due to a dropped pen. Mr. Lamm replaced the pen during the inspection. 7. At the time of the inspection, the high-level float in the influent flow channel was not operational. Mr. Lamm stated that this high-level float failure attributed to the March 17, 2022, Sanitary Sewer Overflow (SSO) for the Spring Hope Collection System, (Collection System Permit Number #WQCS00206) at the manhole outside of the wastewater treatment facility when the pump tripped out. The total volume of the SSO was reported as 500 gallons, with 100 gallons reaching surface waters at Hendricks Creek. Mr. Lamm stated that an electrician was scheduled to return to complete repairs to the high-level float. Within 30-days receipt of this letter, please submit a written response to this office outlining the schedule you will take or have taken to repair the high-level float. 8. Both secondary clarifiers operate at a depth of approximately 15 feet. Mr. Lamm stated that he did not know the depth of the sludge blanket and did not have a sludge judge. Mr. Lamm stated that he performs settleability tests and operates the clarifiers at approximately 350 ml. The Division highly recommends having a sludge judge readily available. 9. Grease and duckweed were observed in the two tertiary clarifiers. Mr. Lamm stated that the pumps for grease removal were not operational. Within 30-days receipt of this letter, please provide a written response to this office outlining the schedule you will take or have taken to repair the grease removal pumps. 10. The liquid chlorination system appeared to be operating satisfactorily. 11. The liquid de -chlorination system appeared to be operating satisfactorily. 12. The effluent at Outfall 001 could not be observed during the inspection as the Tar River was too high and the outfall pipe was underwater. Observation of the disinfection contact chambers and cascade aeration indicate that effluent was clear and free of excess solids. NORTHCAROLINA Department of Environmental Deal North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Town of Spring Hope WWTP NPDES Permit No. NC0020061 Nash County Page 3 of 4 13. As stated by the operator, the fecal coliform samples are collected offsite at a manhole located prior to the outfall, while the composite sampler is located within the facility. All effluent samples (composite and grab) should be taken at the same effluent location. 14. The refrigerated effluent composite sampler was not operational at the time of the inspection. Mr. Lamm stated that a portable composite sampler is being used. The portable composite sampler was not on site during the inspection. Within 30-days receipt of this letter, please provide a written response to this office indicating the Standard Operating Procedures (SOPs) for collecting samples using the portable composite sampler and ensuring the sample is maintained at or below 6° C. 15. Mr. Lamm stated that Granville Farms hauls sludge from the facility twice per year. 16. Mr. Lamm stated the two onsite diesel generators are tested weekly and sometimes tested under load. The generators appeared to be operating satisfactorily during the inspection. 17. The field parameters performed by the operator are pH, Temperature, and Dissolved Oxygen. Meritech, Inc. (Certified Lab #165), performs analysis for all other permitted parameters. Envirolink, Inc. (Certified Lab #5212) conducts the field parameter sampling required by the permit. 18. A cursory review of laboratory data and discharge monitoring report (DMR) data for February 2021 and June 2021 showed compliance with the permit limits 19. A cursory review of discharge monitoring report (DMR) data for January 2021 to present was performed. Average flow data between January and February 2022 ranged from a high of 0.30 MGD in February 2021 as low as 0.04 MGD in November 2021. Within 30 days receipt of this letter, please provide a written response detailing the fluctuation in the flow data. 20. A review of DMR data for January 2021 to present showed three DMR violations. In May 2021, the operator failed to add a weekly Total Nitrogen and Total Phosphorus result to the DMR, which was revised in August 2021. In both October 2021 and December 2021, the second monthly ammonia (NH3) sample required by the permit was not collected. Mr. Lamm stated that they are now sampling for ammonia weekly. 21. The field parameter calibration logs for the months of February 2021 and June 2021 were not available onsite for inspection and review. Mr. Lamm stated that the Operators Logs containing the field parameters are turned in to Envirolink monthly for DMR submittal and storage. Within 30-days receipt of this letter, please provide the field parameter calibration logs for the months of February 2021 and June 2021. 22. Mr. Lamm stated that the pH vessels containing the pH standards 4.0, 7.0 and 10.0 are poured up weekly. Only pH 4.00 and 10.00 buffers were available on site, and the buffers £ D_E NORTHCAROLINA Department of Environmental Deal North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Town of Spring Hope WWTP NPDES Permit No. NC0020061 Nash County Page 4 of 4 were both expired. A portion of the standard buffer is not to be used for more than one calibration. The used buffer portions must be discarded after each use. Also, when performing analyses at multiple sample sites, a post -analysis verification using the check standard buffer must be analyzed at the end of the run. Within 30-days receipt of this letter, please provide in writing the Standard Operating Procedures (SOPs) for calibrating the pH meter and collecting pH samples. As required by Part II, Section C.2 of the subject NPDES permit, "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." Please respond in writing to items 1, 5, 7, 8, 9,14,19, 21, and 22 within 30 days of receipt of this letter describing how these items have been resolved. If you have questions concerning this report, please contact Colleen Cohn or Mitchell Hayes with the Division of Water Resources staff of the Raleigh Regional Office at (919 791- 4200) or via email at colleen.cohn@ncdenr.gov or mitch.hayes@ncdenr.gov. Sincerely, DocuSigned by: Fhwu-ssa f. AtatAltd, B2916E6AB32144F... Vanessa Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources, NCDEQ Attachment : EPA Compliance Inspection Report cc: Laserfiche Rebecca Manning, Envirolink Inc (via email) £ D_E NORTHCAROLINA Department of Environmental Deal North Carolina Department of Environmental Quality I Division of Water Resources Raleigh Regional Office I 3800 Barrett Drive I Raleigh, North Carolina 27609 919.791.4200 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD 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 21IIIIII NPDES yr/mo/day Inspection I 3 I NC0020061 111 121 22/03/23 117 Type 18 1 IIIIIIIIIII Inspector Fac Type 19 I S I 201 IIIIIIIIIII IIIIIII I IIIIII P6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 671 I 70I I 711 172 I N I 731 I 74 71 I I 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 permit Number) Spring Hope WWTP NC Hwy 581 S Spring Hope NC 27882 Entry Time/Date 10:10AM 22/03/23 Permit Effective Date 20/08/01 Exit Time/Date 12:OOPM 22/03/23 Permit Expiration Date 24/10/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// William Edward Lamm/ORC/252-235-4900/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted James Buddy Gwaltney,PO Box 87 Spring Hope NC 27882/Mayor/252-478-5186/2524787131 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) Mitchell S Hayes Colleen Cohn of Inspector(s) �DocuSignedby: Mod f1 'iu - D8128262D292430... Agency/Office/Phone and Fax Numbers Date DWR/RRO WQ/919-791-4200/ 5/2/2022 ,-Docusignedby: DWR/RRO WQ/919-791-4258/ /,, ,4 /�� 5/2/2022 GDCg9277G02911 D_.. Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date iTDocuSigned by: hIAWSX f oVtaAA.IAd 5/3/2022 EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD NPDES yr/mo/day 31 NC0020061 111 121 22/03/23 I17 Inspection Type 18LI 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# 2 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Permit: NC0020061 Inspection Date: 03/23/2022 Owner - Facility: Spring Hope WWTP Inspection Type: Compliance Evaluation 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: Complete records are maintained offsite with Envirolink, Inc. and were not readily available for staff review. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ El • ❑ 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: Permit was effective August 1, 2020, and expires on October 31, 2024. Flow Measurement - Influent Yes No NA NE Page# 3 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Permit: NC0020061 Inspection Date: 03/23/2022 Owner - Facility: Spring Hope WWTP Inspection Type: Compliance Evaluation 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ • ❑ ❑ Comment: At the time of the inspection, the pen for the chart recorder had fallen off. Pen was replaced by the operator during the inspection. 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: 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: The mechanical bar screen was not operational. The motor appears to have been removed. Note: In the last two inspections (April 22, 2015, and November 14, 2018) staff indicated that the mechanical bar screen was not operational during those inspections. Grit Removal Type of grit removal a.Manual 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 • • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 4 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Permit: NC0020061 Inspection Date: 03/23/2022 Owner - Facility: Spring Hope WWTP Inspection Type: Compliance Evaluation 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: Aeration Basins are located under the building and are accessible via a hatch. It was difficult to access the operation of the aeration basins. Primary 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 sludge blanket level acceptable? ❑ ❑ El • Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) ❑ ❑ El • Comment: The operator did not have a sludge judge available to measure the sludge depth. 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? • ❑ El ❑ Are weirs level? • El El El Is the site free of weir blockage? • El ❑ ❑ Is the site free of evidence of short-circuiting? ■ ❑ ❑ ❑ Is scum removal adequate? El • ❑ ❑ Is the site free of excessive floating sludge? • El El El Page# 5 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Permit: NC0020061 Inspection Date: 03/23/2022 Owner - Facility: Spring Hope WWTP Inspection Type: Compliance Evaluation Secondary Clarifier 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: Grease and duckweed were observed in the two tertiary clarifiers. The operator stated that the pumps for grease removal were not operational. The operator did not have a sludge judge available to measure the sludge depth. Note: Called tertiary clarifiers in the permit. Disinfection -Liquid Is there adequate reserve supply of disinfectant? (Sodium Hypochlorite) Is pump feed system operational? Is bulk storage tank containment area adequate? (free of leaks/open drains) 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? Comment: Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ De -chlorination Yes No NA NE Type of system ? Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? • ❑ ❑ ❑ Is storage appropriate for cylinders? • ❑ El El # Is de -chlorination substance stored away from chlorine containers? • El El El Comment: Are the tablets the proper size and type? El El • El Are tablet de -chlorinators operational? El El • El Number of tubes in use? Comment: 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 6 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Permit: NC0020061 Inspection Date: 03/23/2022 Owner - Facility: Spring Hope WWTP Inspection Type: Compliance Evaluation Standby Power 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: There are two onsite diesel generators One operates blowers only, and the other operates the rest of the facility. The operator stated that both are tested weekly and are sometimes tested under load. The generators appeared to be operating satsifactorily during the inspection. Grease Removal # Is automatic grease removal present? Is grease removal operating properly? Comment: Grease removal pumps on tertiary clarifiers were not operational. 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 • ❑ ❑ ❑ ❑ • ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ • ❑ ❑ • ❑ ❑ ❑ • ❑ Comment: Envirolink, Inc. (Certified Lab #5212) conducts field parameter testing for pH, Temperature, and Dissolved Oxygen. Meritech, Inc. (Certified Lab #165) conducts analysis for all other permitted parameters. pH buffers on site were expired (4.00 expired December 2021 and 10.00 expired October 2021). Stationary effluent composite sampler was not operational, and a portable composite sampler is being used. The portable composite sampler was not on -site at the time of the inspection. 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 Tar River was high during the inspection, and inspectors were unable to see the outfall pipe. Effluent Sampling Is composite sampling flow proportional? • Yes No NA NE ❑ ❑ ❑ Page# 7 DocuSign Envelope ID: 6779F84A-3E89-4F69-88BA-B542D4FCODDD Permit: NC0020061 Inspection Date: 03/23/2022 Owner - Facility: Spring Hope WWTP Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is sample collected below all treatment units? • ❑ ❑ ❑ Is proper volume collected? ❑ ❑ El • 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: Stationary effluent composite sampler was not operational, and a portable composite sampler is being used. The portable composite sampler was not on -site at the time of the inspection. As stated by the operator, the fecal coliform samples are collected offsite at a manhole located prior to the outfall, while the composite sampler is located within the facility. Page# 8