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Home My WebLink AboutNC0001899_Compliance Evaluation Inspection_20220603DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Mr. Kirk Bradley Eco Tip West, LLC PO Drawer 9 Sanford, NC 27331 NORTH CAROLINA Environmental Quality June 3, 2022 Subj ect: Compliance Evaluation Inspection Eco Tip West WWTP NPDES Permit No. NC0001899 Chatham County Dear Mr. Bradley: On March 11, 2022, Cheng Zhang of the Raleigh Regional Office (RRO) conducted a compliance evaluation inspection of the subject facility. The assistance provided by Ms. Amanda Grenier, the operator in responsible charge (ORC), was greatly appreciated as it facilitated the inspection process. The inspection report is attached. The following observations were made: Eco Tip West WWTP is permitted to discharge at a rate of 0.244 MGD of wastewater from Outfall 001 into Haw River, classified WS-IV waters in the Cape Fear River Basin, and stormwater, steam condensate, and overflow from two fire ponds from Outfall 002 into Shaddox Creek, classified WS-IV waters in the Cape Fear River Basin. 1. The current permit became effective on March 1, 2022. Many treatment components listed in the permit either are not present/demolished (such as sanitary bar screen, grinder, and lift station, coagulant addition system, conventional water treatment plant with chemical addition systems, and the 18500 gallons clarifier), or are abandoned and no longer in service (process wastewater lift station and 1,200 gallons mixing/neutralization chamber with automatic pH control). 2. The facility stopped production in 2015 and has been in the process of demolition since. There has been no process wastewater generated from the facility. There was a process cooling water (containing ethylene glycol and antimony) spill in March 2014, spilled material was contained in the stormwater pond. Discharge from the stormwater pond to Outfall 002 was stopped (valve at the discharge pipe was closed) since the spill. Water from the stormwater pond is pumped to the spill pond adjacent to the aeration basin. Water from the spill pond is treated in the following treatment units: aeration basin, secondary clarifier, polishing pond, contact chamber and discharged to Outfall 001. It was noted that the original effluent pipe has been clogged significantly (with capacity of less than 20 gallons/minute). When flow exceeds the capacity, effluent has to be pumped (with a portable pump) to the water intake station (using the existing water intake pipe) and then to Outfall 001 through layflat hose. It was noted that at the time of inspection the two surface aerators were not operable. There was hardly any activated sludge in the aeration basin. D_E Q 1 NORTH CAROLINA DeperhneM of Environmental Oual� 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:4987912B-DDE1-4C17-8E1F-21B80197D076 3. It was noted that monitoring at Outfall 002 resumed since January 2019. However, aluminum and zinc were analyzed only once (in January 2022) at the time of inspection. It was also noted that upstream and downstream monitoring at Outfall 001 has not been conducted since December 2017. 4. The ORC maintains a daily logbook. Lab results, chain -of -custody forms, and DMRs were complete and current, kept in good order and ready for review. July 2021 and January 2022 DMR data were compared to lab bench sheets; no data transcription errors were noted. Effluent flow meters were calibrated quarterly. Since CWT related process wastewater is no longer generated at the site, monitoring of parameters listed in Part I A. (2.) is not needed. 5. Field lab parameter (Certificate No. 5024) calibration and analysis records were reviewed during the inspection. 6. It appears that the main purpose to keep the facility in operation is to slowly mix/dilute the contaminated water contained in the stormwater pond with stormwater and let it discharge into the Haw River. Therefore, it is strongly recommended that the facility include antimony in the monthly monitoring at Outfall 001. Please respond in writing to RRO within 30 days of receipt of this letter regarding Items 2, 3, and 6. If you have any questions regarding the attached reports or any of the findings, please contact Cheng Zhang at: (919) 791-4200 (or email: cheng.zhang@ncdenr.gov). Attachments: Compliance Inspection Report Cc: Central Files w/attachment (Laserfiche) Raleigh Regional Office w/attachment Amanda Grenier, ORC (electronic copy only) D_E NORTH CARCLINA gaparhnanl of Environmental quality Sincerely, DocuSigned by: ittIA.t,SSa f. katA,ut,L B2916E6AB32144F... 6/7/2022 Vanessa E. Manuel, Assistant Regional Supervisor Water Quality Regional Operations Section Raleigh Regional Office Division of Water Resources North Carolina Department of Environmental Quality I Division of Water Resources 512 North Salisbury Street 11611 Mail Service Center I Raleigh, North Carolina 27699-1611 919.707.9000 DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 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 IIIIIIIIIIIIIIIIII NPDES yr/mo/day Inspection 3 I NC0001899 111 121 22/03/11 117 Type 18I I IIIIIIIIIII Inspector Fac Type 191 S I 2011 I IIIIII P6 Inspection Work Days 671 Facility Self -Monitoring Evaluation Rating B1 QA Reserved I 70I I 711 172 I N I 73I 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 oermit Number) Moncure Holdings West WWTP 338 Pea Rdg Rd New Hill NC 27562 Entry Time/Date 12:OOPM 22/03/11 Permit Effective Date 17/12/01 Exit Time/Date 02:30PM 22/03/11 Permit Expiration Date 21/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Amanda Dawn Grenier//919-356-6509 / Amanda Dawn Grenier/ORC/919-362-3002/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Jason Kaplan,PO Drawer 9 Sanford NC 27331//336-266-1254/ 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) Cheng Zhang of Inspector(s) Agency/Office/Phone and Fax Numbers Date �Docusignedby: DWR/RRO WQ/919-791-4200/ 6/3/2022 "- D6171508E1 EC41 F... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 6/7/2022 1 VatAA,ssa f. havuitd, EPA orm 356104:3 (Rev 9-94) Previous editions are obsolete. Page# 1 DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 sI NPDES yr/mo/day N C 0001899 111 121 22/03/11 I17 Inspection Type 18LI (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Current permit became effective on March 1, 2022. Many treatment components listed in the permit are either not present/demolished (such as sanitary bar screen, grinder, and lift station, coagulent addition system, conventional water treatment plant with chemical addition systems, and the 18500 gallons clarifier), or abandoned and no longer in service (process wastewater lift station and 1,200 gallons mixing/neutralization chamber with automatic pH control). Very small amount of sanitary sewage is generated on site (two toilets/sinks from the operation building and a modular building. It appears that the main purpose to operate the plant is to treat the contaminated water from the stormwater pond resulted from a process cooling water (containing thylene glycol and antimony) spill in March 2014. Water from the stormwater pond is pumped to the spill pond and mixed with stormwater, water from the spill pond is pumped to the aeration basin and then to the clarifier, effluent from the clarifier goes to the polishing pond, final effluent goes to the contact chamber, is either discharged by gravity or pumped to Outfall 001. The original effluent pipe has been clogged significantly (with capacity of less than 20 gallons/minute). When flow exceeds the capacity, effluent has to be pumped (with a portable pump) to the water intake station (using the existing water intake pipe) and then to Outfall 001 through layflat hose. It was noted that at the time of inspection both surface aerators were not operable. There were very little amount of biosolids/sludge in the aeration basin. Discharge from the stormwater pond was stopped (valve at the discharge pipe was closed) since the spill in March 2014. Upstream/downsteam monitoring at Outfall 001 has not been performed since December 2017. The flow meter attached to the effluent pump has not been calibrated annually. Page# 2 DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 Permit: NC0001899 Inspection Date: 03/11/2022 Owner - Facility: Moncure Holdings West 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 El Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Facility analyzes pH, COD, TSS, DO from contact chamber periodically. 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? • ❑ ❑ ❑ Comment: Many treatment components listed in the permit either are not present/demolished (such as sanitary bar screen, grinder, and lift station, coagulant addition system, conventional water treatment plant with chemical addition systems, and the 18500 gallons clarifier), or are abandoned and no longer in service (process wastewater lift station and 1,200 gallons mixing/neutralization chamber with automatic pH control). Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? ❑ ❑ ❑ • Is the wet well free of excessive grease? ❑ El ❑ • Are all pumps present? ❑ ❑ ❑ • Are all pumps operable? ❑ ❑ ❑ • Are float controls operable? ❑ ❑ ❑ • Is SCADA telemetry available and operational? ❑ El ❑ • Is audible and visual alarm available and operational? ❑ ❑ ❑ • Comment: The process wastewater lift station has been abandoned and not in service (no process wastewater has been generated since the plant production shutdown in November 2014). Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Surface Is the basin free of dead spots? ❑ ❑ • ❑ Are surface aerators and mixers operational? ❑ • ❑ ❑ Are the diffusers operational? ❑ ❑ • ❑ Page# 3 DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 Permit: NC0001899 Inspection Date: 03/11/2022 Owner - Facility: Moncure Holdings West WWTP Inspection Type: Compliance Evaluation Aeration Basins 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: Both surface aerators were not operable at the time of inspection. 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 • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The clarifier was not in service at the time of inspection. There was very little amount of biosolid in the system, therefore, sludge returning/wasting was not necessory. Lagoons Yes No NA NE Type of lagoons? Facultative # 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? El El • El Are dike slopes clear of woody vegetation? • El El El Are weeds controlled around the edge of the lagoon? • El ❑ ❑ Are dikes free of seepage? • El El El Are dikes free of erosion? • El El El Are dikes free of burrowing animals? • El El El Page# 4 DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 Permit: NC0001899 Inspection Date: 03/11/2022 Owner - Facility: Moncure Holdings West WWTP Inspection Type: Compliance Evaluation Lagoons Yes No NA NE # 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: Spill pond holds stormwater and water pumped from the stormwater pond; Polishing pond contains stormwater, effluent from the clarifier, and overflow from the two alum ponds. 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? Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ Comment: No chlorine has ever been used in the contact chamber. Flow from the polishing pond enters the chamber and go through the V-notch, final effluent is either discharged by gravity or pumped to Outfall 001. The oringinal effluent pipe has been clogged significantly (with capacity of less than 20 gallons/minute). When flow exceeds the capacity, effluent has to be pumped (with a portable pump) to the water intake station (using the existing water intake pipe) and then to Outfall 001 through layflat hose. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? • El El El Is sample collected below all treatment units? • El El El Is proper volume collected? • El El El Is the tubing clean? • ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 ■ El El El degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type • El El El representative)? Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, El • El El and sampling location)? Page# 5 DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 Permit: NC0001899 Inspection Date: 03/11/2022 Owner - Facility: Moncure Holdings West WWTP Inspection Type: Compliance Evaluation Upstream / Downstream Sampling Yes No NA NE Comment: Upstream/down stream sampling has not been performed since December 2017. 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: Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ 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? • El El El Is the chain -of -custody complete? • El El El 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? • El ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? El El • El (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? • El El El Is the ORC certified at grade equal to or higher than the facility classification? • El El El Is the backup operator certified at one grade less or greater than the facility • El El El classification? Is a copy of the current NPDES permit available on site? • El El El Facility has copy of previous year's Annual Report on file for review? El El • El Page# 6 DocuSign Envelope ID:4987912B-DDE1-4C17-8E1F-21B80197D076 Permit: NC0001899 Inspection Date: 03/11/2022 Owner - Facility: Moncure Holdings West WWTP Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: 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: Right of way to Outfall 001 and 002 were maintained, both outfalls were accessible. Discharge from the stormwater pond was stopped (valve closed) since the process cooling water (containing thylene glycol and antimony) spill in March 2014. 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 effluent flow meter was last calibrated on March 10, 2022. The flow meter attached with the effluent pump was a rental and not calibrated annually. 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? Comment: The drying bed has not been used since the production ended. Yes No NA NE • ❑ ❑ ❑ ❑ ❑ • ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Page# 7