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Home My WebLink AboutNC0025381_Compliance Evaluation Inspection_20220725 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED July 25, 2022 Hank Perkins Email: whperkins@townoflakelure.com Town of Lake Lure SUBJECT: Compliance Inspection Report Lake Lure WWTP NPDES WW Permit No. NC0025381 Rutherford County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Lake Lure WWTP on 6/27/2022. The WWTP has been unable to sustain biological treatment due to severe collection system deficiencies and as such is unable to maintain consistence compliance with NPDES Permit # NC0025381. Per SOC WQ S20-004, the Town has committed to returning the system to compliance as part of the consent order with the Environmental Management Commission. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". If you should have any questions, please do not hesitate to contact Tim Heim or me at 828-296-4500. Sincerely, Mikal Willmer, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF DocuSign Envelope ID: C70F9D18-9218-4DFD-98B3-62BCD5DB573A EPA United States Environmental Protection Agency 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 NPDES yr/mo/day Inspection Type Inspector Fac Type 1 N 52 NC0025381 22/06/27 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) Lake Lure WWTP US Hwy 64/74 Lake Lure NC 28746 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 22/06/27 15/03/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Other Facility Data 03:00PM 22/06/27 18/08/31 Name, Address of Responsible Official/Title/Phone and Fax Number Hank Perkins,PO Box 255 Lake Lure NC 287460255//828-625-9983/8286258371 Contacted Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) (See attachment summary) Name(s) and Signature(s) of Inspector(s)Agency/Office/Phone and Fax Numbers Date Timothy H Heim DWR/ARO WQ/828-296-4665/ Mikal Willmer DWR/Division of Water Quality/828-296-4686/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: C70F9D18-9218-4DFD-98B3-62BCD5DB573A 7/25/2022 7/25/2022 7/25/2022 NPDES yr/mo/day 22/06/27 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer & Tim Heim, with the Asheville Regional Office (ARO), conducted a Compliance Evaluation Inspection of the Town of Lake Lure’s WWTP on June 27, 2022. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with Permit No. NC0025381. Julia Byrd and Logan Kluttz (ARO Division of Water Infrastructure) and Town of Lake Lure staff were also present for the inspection. Staff are operating the plant to the extent the current influent composition and onsite equipment will allow. The Town of Lake Lure has been unable to sustain biological treatment within the WWTP since before 1991 due to lake water infiltration. In 1991 the original activated sludge process was converted to a physical chemical plant to settle out sediment before being discharged to the Broad River. Due to the lack of biological treatment, the facility is unable to adequately remove ammonia. Due to historical issues, the Town has entered a Special Order by Consent with the Environmental Management Commission. The first phase of the project will only include minor changes to the WWTP (centrifuge to better process solids and some headworks modifications) as the collection system will be the primary focus. The modifications to the WWTP will improve solids handling in the short term but are not expected to greatly improve effluent values. Below is a summary of current operations. Chemical: The facility is in the process of converting the chemical feed to flow paced to improve dosing. Currently this is manually adjusted as needed with change in flows. Solids Handling: Staff have struggled to manage solids within the WWTP due to flow, lack of detention time, sediment, and degradation of the cast iron collection system. The facility does not have adequate solids handling equipment and storage capacity. The current digester has structural issues, which has reduced its capacity by approximately 50%. This requires hauling wet sludge on a frequent basis. A pilot study was conducted at the WWTP utilizing a centrifuge to improve the current solids handling process and provide the operators more flexibility with solids removal from the facility. The ORC, Mr. Dean Lindsay indicated the centrifuge will be installed next to the chemical building and will either discharge to a roll off or onto a covered concrete pad until hauled for final disposal at a certified landfill. The Town should also consider a Class A or Class B residuals permit as an alternative disposal option. This was discussed with the ORC at the end of inspection. Secondary Clarifier: The ORC reports they have attempted to keep the sludge blanket at 2-3’ in the clarifier and waste as needed. The depth is checked multiple times a day to avoid exceeding permit limits. It should be noted, it is not expected the Town will be able to convert the WWTP back to a biological process until there is significant reduction in lake water infiltration. The first phase of collection system improvements under the current SOC will not be placed into use until additional segments around the Lake perimeter are completed. NC0025381 17 (Cont.) Page#2 DocuSign Envelope ID: C70F9D18-9218-4DFD-98B3-62BCD5DB573A Permit:NC0025381 Inspection Date:06/27/2022 Owner - Facility: Inspection Type: Lake Lure WWTP 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 Solids, pH, DO, Sludge Judge, and other that are applicable? Utilize sludge judge to monitor need for wasting.Comment: Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new 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? Facility is under an SOC as of 2022.Comment: 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? 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? Page#3 DocuSign Envelope ID: C70F9D18-9218-4DFD-98B3-62BCD5DB573A Permit:NC0025381 Inspection Date:06/27/2022 Owner - Facility: Inspection Type: Lake Lure WWTP Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? ORC is still PC-I but has renewed temporary certification with Operator Certification.Comment: 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: Flow Measurement - Effluent Yes No NA NE # 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? Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Digester has structural damage. See summary for details.Comment: 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? Is the unit in good condition? Page#4 DocuSign Envelope ID: C70F9D18-9218-4DFD-98B3-62BCD5DB573A Permit:NC0025381 Inspection Date:06/27/2022 Owner - Facility: Inspection Type: Lake Lure WWTP Compliance Evaluation Bar Screens Yes No NA NE Older screen removes some debris, but in need of replacement.Comment: 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? 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 ¼ of the sidewall depth) Facility staff attempt to keep the blanket between 2-3'. See summary for details. Iron precipitate becomes an issue if blanket levels are elevated. Comment: Disinfection-Liquid Yes No NA NE 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: 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)? Page#5 DocuSign Envelope ID: C70F9D18-9218-4DFD-98B3-62BCD5DB573A Permit:NC0025381 Inspection Date:06/27/2022 Owner - Facility: Inspection Type: Lake Lure WWTP Compliance Evaluation Effluent Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type representative)? Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Comment: Chemical Feed Yes No NA NE Is containment adequate? Is storage adequate? Are backup pumps available? Is the site free of excessive leaking? New chemical feed building with adequate containment if HDPE containers leak.Comment: Page#6 DocuSign Envelope ID: C70F9D18-9218-4DFD-98B3-62BCD5DB573A