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Home My WebLink AboutNC0058084_Compliance Evaluation Inspection_20220613ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director David Risley, President Gough Econ, Inc. Post Office Box 668583 Charlotte, NC 28266 SUBJECT: Notice of Deficiency Compliance Evaluation Inspection Gough Econ WWTP NPDES Permit No. NC0058084 Mecklenburg County Tracking #: NOD-2022-PC-0094 Dear Mr. Risley: NORTH CAROLINA Environmental Quality June 13, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on June 2, 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 Deficiency (NOD) due to the following: - The septic tank was not accessible for inspection; - The dosing tank was leaking into the sand filter; - The mushroom spray nozzles needed to be cleaned and/or replaced; - The concrete block perimeter wall needed to be repaired/resealed in several sections; - The facility failed to monitor the second effluent pH in December 2021; - All of the 2021 monitoring data was not available for review. Please be advised that the failures to monitor the effluent, maintain records, and provide proper operation and maintenance 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 o,.mwonmr..edo� 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 July 5, 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, 1—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 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 1 NPDES yr/mo/day Inspection I 3 I NC0058084 111 121 22/06/02 117 Type 18 i i I I 1 1 1 Inspector Fac Type 191 S I 201 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 70I3 I 71IN I 72 I N I 731 I 74 71 I I 1 I I I I I I 1l80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES oermit Number) Gough Econ WWTP 9400 N Lakebrook Rd Sr Charlotte NC 28214 Entry Time/Date 09:15AM 22/06/02 Permit Effective Date 20/10/01 Exit Time/Date 12:50PM 22/06/02 Permit Expiration Date 25/06/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Kellie H Hedrick//980-202-2377 / Kimberly Dawn Holt/ORC/980-202-2377/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted David P Risley,PO Box 668583 Charlotte NC 28266//704-399-2306/ 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 �Docusigned by: DWR/MRO WQ/704-663-1699 Ext.2192/ 6/13/2022 "-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: 6/13/2022 Page# 1 "-A14CC681AF27425... sI NPDES yr/mo/day N C 0058084 111 121 22/06/02 I17 Inspection Type 18 [j 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) RECORD KEEPING SECTION cont'd: The records reviewed during the inspection were organized and well maintained; however, the majority of the 2021 records (lab analyses, chain of custody forms, operation & maintenance records) were not available at the time of the inspection as required by the NPDES Permit [Permit Condition Reference: Part II, Section D(6) & D(7) Records Retention/Recording Results]. Page# 2 Permit: NC0058084 Inspection Date: 06/02/2022 Owner - Facility: Gough Econ WWTP 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 MODE application? Is the facility as described in the permit? • ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ El • El Is access to the plant site restricted to the general public? • ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑ Comment: Although the facility entrance is gated and there is a perimeter fence, the permittee should provide locks for the gates to the discharge outfall and fence for the septic tank/sandfilter. In addition, the access lids for the chlorination and dechlorination systems should also be secured. The last compliance evaluation inspection at this facility was performed by DWR staff on 3/12/2019. 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)? El • ❑ ❑ Are analytical results consistent with data reported on DMRs? • El El El Is the chain -of -custody complete? • 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 El El Has the facility submitted its annual compliance report to users and DWQ? ❑ El • ❑ (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified El El • El operator on each shift? Is the ORC visitation log available and current? • 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 ■ ❑ ❑ ❑ 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# 3 Permit: NC0058084 Inspection Date: 06/02/2022 Owner - Facility: Gough Econ WWTP Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: Discharge Monitoring Reports (eDMRs) were reviewed for the period May 2021 through April 2022. A daily maximum effluent fecal coliform violation was reported in January 2022. Monitoring violations were reported in January and February 2022. The Division has previously addressed the violations through the issuances of Notice of Violations (NOVs). Only one effluent pH (twice per month required) was performed in December 2021. This report will address this monitoring violation. In addition, the July and December 2021 and January and April 2022 eDMRs will be revised to correct transcription errors and flow values (including days with no flow). 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 are performed (as of February 2022) under Environmental Process Solution's field laboratory certification #5695. Statesville Analytical has been contracted to provide analytical support (all permit parameters except field). The ORC and staff must ensure all units of measurement is documented for all calibration and effluent values. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ 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 ❑ ❑ • ❑ degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type • El ❑ ❑ representative)? Comment: The subject permit requires effluent grab samples. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, NEED and sampling location)? Comment: Page# 4 Permit: NC0058084 Inspection Date: 06/02/2022 Owner - Facility: Gough Econ 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 Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: A new ORC and Backup ORC were designated in February 2022. The wastewater treatment facility appeared to be adequately treating the wastewater, however; accessibility and maintenance concerns were observed during the inspection. See "Septic Tank and Sand Filter Sections for additional comments. Septic Tank Yes No NA NE (If pumps are used) Is an audible and visual alarm operational? ❑ El • El Is septic tank pumped on a schedule? • ❑ El El Are pumps or syphons operating properly? • El El El Are high and low water alarms operating properly? ❑ El • ❑ Comment: The ORC indicated that the septic tank is pumped once per year. The septic tank is not accessible for inspection due to the heavy concrete lids. The permittee must either provide a lift system or replace the lids to allow access to inspect the septic tank. In addition, the NPDES Permit (Part II, Section D(8) Inspection & Entry) requires the permittee to allow inspection of any facilities and equipment required under this permit. 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: Although not excessive, all vegetation needs to be removed and any spent sand replaced with approved new sand. The dosing tank was leaking into the sand filter and the mushroom spray nozzles needed to be either replaced and/or cleaned (if possible). The sand filter's perimeter block wall also needed maintenance (new coating, etc.) in several locations. Please be advised that the subject NPDES Permit requires the permittee to properly operate and maintain the facility at all times [Permit Condition Reference: Part II, Section C(2) Proper Operation and Maintenance]. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? • El El El Are the tablets the proper size and type? • ❑ El El Number of tubes in use? 4 Page# 5 Permit: NC0058084 Inspection Date: 06/02/2022 Owner - Facility: Gough Econ WWTP Inspection Type: Compliance Evaluation Disinfection -Tablet Yes No NA NE 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: The permittee should provide a means to access the chlorination and dechlorination contact tanks (concrete lids) as discussed in the Septic Tank Section. The permittee must ensure that the new accessible lids (if installed) are sealed/elevated to prevent any stormwater from entering the treatment tanks. De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? • ❑ ❑ ❑ Is storage appropriate for cylinders? ❑ ❑ • ❑ # Is de -chlorination substance stored away from chlorine containers? El • ❑ ❑ Are the tablets the proper size and type? • El El El Comment: The chlorine and dechlor tablets should be stored separately and outside of the metal cabinet housing the recirculation timer to prevent corrosion and equipment deterioration. Are tablet de -chlorinators operational? Number of tubes in use? Comment: 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? • ❑ ❑ ❑ 2 Yes No NA NE ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ Comment: Flow calculations are based on the bucket and stop watch method. This Office recommends the permittee to investigate the installation of an in -line flow meter due to the infrequent effluent discharges. 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 Page# 6 Permit: NC0058084 Inspection Date: 06/02/2022 Owner - Facility: Gough Econ WWTP Inspection Type: Compliance Evaluation Effluent Pipe Yes No NA NE Comment: The facility was not discharging at the time of the inspection. The wastewater inside the chlorination and dechlorination tanks appeared clear with no floatable solids or foam. The receiving stream did not appear to be negatively impacted. Page# 7