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Home My WebLink AboutNC0044253_Compliance Evaluation Inspection_20220714ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director CERTIFIED MAIL #: 7018 3090 0001 2322 8611 RETURN RECEIPT REQUESTED; Tammy Thomas North Carolina Lions Foundation, Inc. Post Office Box 39 Sherrills Ford, NC 28673-0039 SUBJECT: Notice of Violation Compliance Evaluation Inspection Camp Dogwood WWTP NPDES Permit No. NC0044253 Catawba County Tracking #: NOV-2022-PC-0379 Dear Ms. Thomas: NORTH CAROLINA Environmental Quality July 14, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on July 6, 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 aeration basin did not have an adequate biomass population; - The tablet dechlorination unit was not installed in the correct location; - Excessive wastewater solids observed in the clarifier; - Tablet chlorination unit did not have a lid or second sleeve; - Incorrect flow measurements (estimations) were being performed; - Restricted access had not been provided for the chlorination and dechlorination systems. Please be advised that the failures to both provide proper operation and maintenance and properly monitor the flow 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 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 F161 FB69A2D84A3... 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 E PA 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 L 21 1 1 1 1 1 NPDES yr/mo/day Inspection 3 I NC0044253 111 121 22/07/06 117 Type 1810I I I 1 1 1 Inspector Fac Type 191 S I 2011 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 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) Camp Dogwood WWTP NCSR 1849 Sherrills Ford NC 28673 Entry Time/Date 11:20AM 22/07/06 Permit Effective Date 20/08/01 Exit Time/Date 11:45AM 22/07/06 Permit Expiration Date 24/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Dustin Kyle Metreyeon/ORC/704-506-4255/ Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Tammy Thomas,PO Box 39 Sherrills Frd NC 28673//828-244-4342/ 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 -Docusiyned by: DWR/MRO WQ/704-663-1699 Ext.2192/ 1,J, Bdi 7/14/2022 "-A61696D90CC3437... Signature of Ma instentiaAiReviewer Agency/Office/Phone and Fax Numbers Date Andrew Pitn rA4.01.4e4v H P * 1WR/MRO WQ/704-663-1699 Ext.2180/ 7/14/2022 F161F869A2D84A3„ EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 3I NPDES yr/mo/day N C 0044253 I11 121 22/07/06 17 Inspection Type 18 [j (Cont.) 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) RECORD KEEPING SECTION cont'd: The ORC maintains visitations and operational data for multiple facilities in one notebook. The ORC must document all visitations and operation and maintenance activities in a log book that is kept at the system as required by 15A North Carolina Administrative Code (NCAC) 8G .0204(5). The ORC must also ensure to notify the system owners of any system repairs and/or modifications that may be necessary to achieve compliance of the system with all local, State, and federal environmental permitting and regulatory requirements as required by 15A NCAC 8G .0204(7). The permittee must ensure that all maintenance activities performed by on -site staff are documented and accessible for review by the ORC and Division personnel. Page# 2 Permit: NC0044253 Inspection Date: 07/06/2022 Owner - Facility: Camp Dogwood 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? • ❑ ❑ ❑ Is access to the plant site restricted to the general public? ❑ • ❑ ❑ Is the inspector granted access to all areas for inspection? • ❑ ❑ ❑ Comment: The last compliance evaluation inspection at this facility was performed by DWR staff on 10/22/18. The tablet chlorination and dechlorination units and the chlorine contact chamber were not restricted from public access. The permittee should restrict public access (fencing, locked lids, etc.) to these treatment units to prevent unauthorized entry and potential liability issues. 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 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 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 ■ ❑ ❑ ❑ 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: NC0044253 Inspection Date: 07/06/2022 Owner - Facility: Camp Dogwood WWTP Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: Discharge Monitoring Reports (eDMRs) were reviewed for the of May 2021 through April 2022. No effluent limit violations were reported. The December 2021 and January through March 2022 eDMRs were submitted late. The Division has previously addressed these violations through the issuances of a Notice of Deficiency (NOD), Notice of Violation (NOV) and NOV/civil penalty assessments. Please see "Summary" Section for additional comments. 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, TRC, temperature) are performed under Metwater, Inc.'s field laboratory certification #5615. Water Tech Labs has been contracted to provide analytical support for all permit -required parameters except field. Post calibration checks on the dissolved oxygen, pH and total residual chlorine meters had not been performed. The ORC must ensure that post calibration checks are performed at the end of the day if these meters are used to perform effluent analyses at multiple facilities. 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 ❑ El El Solids, pH, DO, Sludge Judge, and other that are applicable? Page# 4 Permit: NC0044253 Inspection Date: 07/06/2022 Owner - Facility: Camp Dogwood WWTP Inspection Type: Compliance Evaluation Operations & Maintenance Yes No NA NE Comment: Process control measurements have been performed in the past; however, not frequently. The ORC and staff should initiate (and document) a consistent process control program (settleability tests, pH, dissolved oxygen, etc.) to ensure proper facility operation at all times. Operation and maintenance issues were noted with the aeration basin, secondary clarifier, and dechlorination 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]. Bar Screens Yes No NA NE 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? ❑ El El Is the unit in good condition? • El El El Comment: The coarse bar screen would not be very effective in screening all debris (mainly larger objects). Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? • El ❑ ❑ Are surface aerators and mixers operational? El El • El 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? • El ❑ ❑ Is the DO level acceptable? • El El El Is the DO level acceptable?(1.0 to 3.0 mg/I) • El ❑ ❑ Comment: Approximately no biomass was observed in the aeration basin. The settleability test performed during the inspection was 0 mL/L (should be in range of typically 300 — 600 ml/L). The aeration basin should be reseeded with activated sludge as soon as possible. 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? Yes No NA NE ME OE Page# 5 Permit: NC0044253 Inspection Date: 07/06/2022 Owner - Facility: Camp Dogwood WWTP Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE 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? El • El El Is the drive unit operational? ❑ El • El 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) ❑ ❑ El • Comment: A thick layer of wastewater solids was observed on top of the clarifier's surface that was attributed to the return activated sludge (RAS) system not operating properly. The skimming system was also completely covered in the solids layer. The sludge must be removed from the clarifier's surface and the RAS and skimming systems returned to proper operation. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? 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: The tablet chlorinator did not have the second sleeve (for tablets) and a cover (prevent leaves, etc. from entering unit). The permittee must provide a second sleeve and cover for the tablet chlorinator as soon as possible to ensure adequate operation of the tablet chlorination system. Note: The ORC also had to place chlorine tablets in the clarifier trough to ensure adequate contact with the chlorine tablets. 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 ❑ • ❑ Comment: Are the tablets the proper size and type? Are tablet de -chlorinators operational? ❑ ❑ ❑ Page# 6 Permit: NC0044253 Inspection Date: 07/06/2022 Owner - Facility: Camp Dogwood WWTP Inspection Type: Compliance Evaluation De -chlorination Yes No NA NE Number of tubes in use? 1 Comment: The tablet dechlorination unit was installed in the correct location. The tablet dechlorination unit must be removed and re -installed after the chlorine contact chamber. 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 subject permit requires instantaneous flow measurements; however, the flows being reported on the monitoring reports (eDMRs) have been estimations. The permittee and ORC must incorporate an approved instantaneous flow measurement device/method such as a bucket and stop watch, staff gauge and primary flow device (weir, etc.) and/or an actual flow meter. Please be advised that the permitttee must select the appropriate flow measurement devices and/or methods consistent with accepted scientific practices to ensure the accuracy and reliability of measurements of the volume of monitored discharges [Permit Reference: Part II, Section D(3) Flow Measurement'. Effluent Pipe Yes No NA NE 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 effluent appeared slightly turbid with no floatable solids. The effluent is discharged into the receiving stream via submerged outfall. Page# 7