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Home My WebLink AboutNC0086304_NOV-2022-PC-0263_20220505ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Certified Mail # 7020 3160 0000 3277 0488 Return Receipt Requested Robert Hoyle, Director of Construction & Maintenance Catawba County Schools Post Office Box 1010 Maiden, NC 28658 SUBJECT: Notice of Violation Compliance Evaluation Inspection Mill Creek Middle School WWTP NPDES Permit No. NC0086304 Catawba County Tracking #: NOV-2022-PC-0263 Dear Mr. Hoyle: NORTH CAROLINA Environmental Quality May 5, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on April 26, 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 following: - The permittee failed to notify this office within twenty-four hours of the three pump failures (only one operational); - An unauthorized bypass system for the UV Disinfection and flow measurement systems had been installed. Please be advised that the failure to provide notification of the pump failures and the installation of an unauthorized bypass system are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1. 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. Penalties may also be assessed for any damage to surface waters of the State that may result from the violation. D_E 111.•rhworkt el G. rOrmloalal 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 It is requested that a written response be submitted to this Office by Mav 29, 2022, detailing the actions taken to address all violations and maintenance issues discussed in this report. In responding, 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 Cc: NPDES Program Files - Laserfiche D_E o,.mworkt G.ed o � Sincerely, DocuSigned by: A wNP,zfi F161FB69A2D84A3... fo r 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 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 I 21IIIIII NPDES yr/mo/day Inspection 3 I NC0086304 111 121 22/04/26 I17 Type 1810I IIIIIIIIIII Inspector Fac Type 19I S I 2011 IIIIIIIIIIIIIIIIII I IIIIII P6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA Reserved 67I2.0 I 70I4 I 71IN I 72 I N I 73I 1 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) Mill Creek Middle School 1041 Shiloh Rd Claremont NC 286109202 Entry Time/Date 11:34AM 22/04/26 Permit Effective Date 21/07/01 Exit Time/Date 01:OOPM 22/04/26 Permit Expiration Date 25/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Joshua Steven Greene/ORC/828-396-4444/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Robert Hoyle,PO Box 1010 Newton NC 286581010/Director of Construction & Maintenance/828-464-3562/8284654442 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran Sludge Handling Dispo: Facility 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 —Docusigned by: DWR/MRO WQ/704-663-1699 Ext.2192/ 5/5/2022 10e4, Bell "-A61696D90CC3437... nortu%kiiteyriewer Agency/Office/Phone and Fax Numbers Date Signature of ManaE4-41144, Andrew Pitne 11 P4/R/MRO WQ/704-663-1699 Ext.2180/ 5. 5. 22 F161FB69A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 sI NPDES yr/mo/day N C0086304 111 121 22/04/26 I17 Inspection Type 18 [j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) UV Disinfection Section cont'd: A sump pump was observed in the UV system vault to prevent the water level from rising above the flow measurement system (attached to bottom of effluent pipe). The pump discharges onto the ground outside of the perimeter fence. The ground was observed to be wet from previous discharges during the inspection; however, no surface waters would be affected. Wastewater from the recirculation tank was observed back flowing into the vault's bottom drain during the inspection. Although no discharges were observed from the vault pump during the inspection, the pump is an unauthorized bypass of the UV disinfection and flow measurement systems that are violations of the NPDES Permit [Part II, Section C(4)(c) Bypassing of Treatment Facilities]. Please be advised that any stormwater that combines with wastewater in the vault is wastewater and must be properly disposed. The vault pump system must be removed immediately to cease any future unpermitted wastewater discharges until all pumps (recirculation and discharge) have been replaced. Once the pumps are replaced and wastewater levels return to normal, the vault pump may be reinstalled as long as the drain is sealed off to prevent the backflow of wastewater from the recirculation tank. As previously discussed in the Sand Filter Section, a company should be contracted to periodically remove the wastewater to maintain appropriate wastewater levels in the recirculation tank water and prevent any future backups into the UV disinfection vault. Page# 2 Permit: NC0086304 Inspection Date: 04/26/2022 Owner - Facility: Mill Creek Middle School 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 last compliance evaluation inspection at this facility was performed by DWR staff on 12/2/2020. 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: NC0086304 Inspection Date: 04/26/2022 Owner - Facility: Mill Creek Middle School 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 March 2021 through February 2022. No effluent limit violations were reported. Monitoring violations {BOD, TSS, fecal coliform and pH) were noted in July 2021 and August 2021. The Division has separately addressed these violations through the issuances of either a Notice of Violation (NOV) or NOV/civil penalty assessment. The ORC must ensure to check the Non -Compliant box if any violations (limit and/or monitoring) occurred during the applicable month. The ORC must also ensure to separately document the sample collection times for both the contract lab and field parameters. 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: Effluent analyses (all permit -required parameters including field) are performed under Water Tech Lab's Certification #50. 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 effluent grab samples. 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 DOME Solids, pH, DO, Sludge Judge, and other that are applicable? Page# 4 Permit: NC0086304 Inspection Date: 04/26/2022 Owner - Facility: Mill Creek Middle School Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Comment: Although the School System has fixed the audible/visual alarm (high water) and installed a flow meter; however, operation and maintenance issues were noted with the sand filter and UV Disinfection systems. Please be advised that the subject NPDES Permit requires the permittee to properly operate and maintain the facility at all times jPermit Condition Reference: Part II, Section C(2) Proper Operation and Maintenance]. Septic Tank Yes No NA NE (If pumps are used) Is an audible and visual alarm operational? ❑ ❑ • ❑ Is septic tank pumped on a schedule? • ❑ ❑ ❑ Are pumps or syphons operating properly? • ❑ ❑ ❑ Are high and low water alarms operating properly? ❑ ❑ • ❑ Comment: The septic and recirculation tanks are pumped every summer by a contract company (Leatherman's Septic Tank Service). Custodial staff have previously added sodium bicarbonate at the school to maintain appropriate alkalinity/pH levels. The ORC should verify with school staff the frequency and volume of the sodium bicarbonate additions. Sand Filters (Low rate) (If pumps are used) Is an audible and visible alarm Present and operational? Is the distribution box level and watertight? Is sand filter free of ponding? Is the sand filter effluent re -circulated at a valid ratio? # Is the sand filter surface free of algae or excessive vegetation? # Is the sand filter effluent re -circulated at a valid ratio? (Approximately 3 to 1) Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: Three of the four pumps were not operable due to a suspected lightning strike. A recirculation pump was the only operational pump. The pumps have not been operable since early April 2022 and school staff have been manually recirculating the wastewater at timed intervals. The pumps must be replaced as soon as possible and the wastewater should be periodically removed (by a contracted company) due to the treatment system's inability to discharge and to prevent any potential overflows. The permittee failed to notify this office of the pump failures as required by the NPDES Permit [Part II, Section E(9)(b) Noncompliance Notification]. Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? • ❑ ❑ ❑ Are UV bulbs clean? ❑ ❑ ❑ • Is UV intensity adequate? ■ ❑ ❑ ❑ Is transmittance at or above designed level? ❑ ❑ ❑ • Is there a backup system on site? El ❑ • El Is effluent clear and free of solids? ❑ ❑ • ❑ Page# 5 Permit: NC0086304 Inspection Date: 04/26/2022 Owner - Facility: Mill Creek Middle School Inspection Type: Compliance Evaluation Disinfection - UV Yes No NA NE Comment: The "on/off' light on the UV system was not operational; however, the intensity measuring device was operational and in service. The permittee should have the UV system serviced by qualified personnel to ensure proper operation and initiate cleaning activities according to the manufacturer's instructions. See "Summary" Section for additional comments. 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: An inline flow meter was installed last year. The permittee must ensure the flow meter is calibrated annually as required by the NPDES Permit [Part II, Section D(3) Flow Measurements]. 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 facility was not discharging at the time of the inspection. Yes No NA NE ❑ ❑ ❑ • Page# 6