NC0021211_Compliance Evaluation Inspection_20220830

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
City of Graham
Attn: Frankie Maness, City Manager
P.O. Drawer 357
Graham, NC 27253-0357
NORTH CAROLINA
Environmental Quality
August 30, 2022
Subject: Compliance Evaluation Inspection
City of Graham Wastewater Treatment Plant
NPDES Permit Number: NCO021211
Alamance County
Dear Mr. Maness:
Ron Boone and Seren Homer, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water
Resources (DWR), conducted a compliance evaluation inspection (CEI) of the City of Graham's
Wastewater Treatment Plant (WWTP) on August 24t", 2022. Operator in responsible charge, Crispian
Routh, was present for the inspection. Inspection findings are detailed in the attached water
compliance inspection report.
Please be aware that the Division may take enforcement action against any permittee who fails to
comply with any requirement of their permit. Pursuant to NC General Statute (NCGS) 143-215.6A, a
civil penalty of not more than twenty-five thousand dollars ($25,000.00) may be assessed 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.
If you have any questions or concerns, please do not hesitate to contact Mr. Boone by phone at 336-
776-9690, or by email at [e-mail]. Thank you in advance for your time and attention to
this matter.
Sincerely,
EDocuSigned by:
Loti T. 5m1tr
945B49EUK94EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Winston-Salem Regional Office
Division of Water Resources, NCDEQ
Attachments:
1. Water Compliance Inspection Report
cc: Crispian Routh, 1204 Gilbreath Street, Graham, NC 27253
DffNorth Carolina Department of Environmental Quality I Division of Water Resources
oan caaouNn
Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105
M336.776.9800
oep.m.m or em�nmen� Qualm

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
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 IN 1 2 u 3 I NC0021211 I11 121 22/08/24 I17 18I � I 19 I s I 201 I
211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
I 72 I ni I 71 I 74 79 I I I I I I I80
701 I 71 I LL -1 I I
LJ
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES Dermit Number)
10:OOAM 22/08/24
22/04/01
Graham WWTP
1204 E Gilbreath St
Exit Time/Date
Permit Expiration Date
Graham NC 27253
12:OOPM 22/08/24
26/05/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Crispian T. Routh/ORC/336-570-6721/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Victor Ray Quick,PO Drawer 357 Graham NC 272530357//336-570-6700/3365135502
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 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) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Ron Boone DWR/WSRO WQ/336-776-9690/
Ser��HS9 eHrby: DWR/WSRO WQ/336 776 9698/ 8/31/2022
osua� YJOOn.P/
F�O
WB$ %ement Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by: 8/30/2022
EF WSW-'�':Nev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO021211 I11 12I 22/08/24 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Ron Boone, of the NC Division of Water Resoureces, Winston-Salem Regional Office, conducted a
compliance evaluation inspection of the City of Graham's WWTP on 8/24/2022. ORC, Crispian Routh,
was present for the inspection. Inspection findings are detailed below:
The current permit is maintained on site and it just renewed in March 2022.
The influent flow meter is used for reporting and is due for calibration in 10/2022.
The mechanical bar screen is operational and but has a broken part that forces manual removal of
screenings from the unit. Replacement parts should arrive soon.
The mechanical grit removal system is operational and in good condition.
The primary clarifiers are both in operation and looked good during the inspection.
The aeration basins (AB) appear to be in good condition and the mixed liquor appears healthy. The
basins timed surface aeration. No concerns were noted.
The secondary clarifiers also appear in good condition and operating properly. The weirs appear to
be level and no short circuiting was noticed in the clarifiers.
The plant uses sodium hypochlorite and sodium bisulfite for disinfection and dechlorination,
respectively. No issues were noted with these systems.
The plant has two generators that supply power in the event of a power outage. There is an 800KW
and a 400KW generator. Generators are automatically activated upon power loss. The 400KW
generator exercises every other Wednesday, not under load. The 800KW exercises for 30 minutes
underload once per month.
The effluent appeared excellent. It was very clear and there is no odor. There was no foam or floating
solids.
The inspector has the following recommendations: Develop an emergency contingency with a fuel
supplier for generators for priority supply during extended outages.
No permit deficiencies or violations were noted during the inspection. Keep up the good work!
Page#

Permit: NCO021211 Owner -Facility: Graham WWTP
Inspection Date: 08/24/2022 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
❑
❑
■
❑
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: None
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
■
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❑
classification?
Is a copy of the current NPDES permit available on site?
■
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❑
Facility has copy of previous year's Annual Report on file for review?
■
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Comment: None
Laboratory Yes No NA NE
Are field parameters performed by certified personnel or laboratory? ■ ❑ ❑ ❑
Page# 3

Permit: NCO021211 Owner -Facility: Graham WWTP
Inspection Date: 08/24/2022 Inspection Type: Compliance Evaluation
Laboratory Yes No NA NE
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: None
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected above side streams?
■
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Is proper volume collected?
■
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Is the tubing clean?
■
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
■
❑
❑
❑
degrees Celsius)?
Is sampling performed according to the permit?
■
❑
❑
❑
Comment: None
Effluent Sampling
Yes
No
NA NE
Is composite sampling flow proportional?
■
❑
❑
❑
Is sample collected below all treatment units?
■
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Is proper volume collected?
■
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Is the tubing clean?
■
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# 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: None
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑
and sampling location)?
Comment: Facility is member of Upper Cape Fear River Basin Association.
Page# 4

Permit: NCO021211
Inspection Date: 08/24/2022
Owner -Facility: Graham WWTP
Inspection Type: Compliance Evaluation
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
0
❑
❑
❑
Is the wet well free of excessive grease?
0
❑
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❑
Are all pumps present?
0
❑
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❑
Are all pumps operable?
0
❑
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❑
Are float controls operable?
0
❑
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❑
Is SCADA telemetry available and operational?
0
❑
❑
❑
Is audible and visual alarm available and operational?
❑
■
❑
❑
Comment: None
Flow Measurement - Influent
Yes
No
NA
NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
0
❑
❑
❑
Comment: Calibration due 10/2022.
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
0
❑
❑
❑
Is the screen free of excessive debris?
0
❑
❑
❑
Is disposal of screening in compliance?
■
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Is the unit in good condition?
0
❑
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Comment: None
Grit Removal
Yes
No
NA NE
Type of grit removal
a.Manual
❑
b.Mechanical
Is the grit free of excessive organic matter?
■
❑
❑ ❑
Is the grit free of excessive odor?
■
❑
❑ ❑
# Is disposal of grit in compliance?
0
❑
❑ ❑
Page# 5

Permit: NCO021211 Owner -Facility: Graham WWTP
Inspection Date: 08/24/2022 Inspection Type: Compliance Evaluation
Grit Removal Yes No NA NE
Comment: None
Equalization Basins
Yes
No
NA
NE
Is the basin aerated?
❑
0
❑
❑
Is the basin free of bypass lines or structures to the natural environment?
0
❑
❑
❑
Is the basin free of excessive grease?
❑
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0
❑
Are all pumps present?
0
❑
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❑
Are all pumps operable?
0
❑
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❑
Are float controls operable?
0
❑
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❑
Are audible and visual alarms operable?
0
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❑
❑
# Is basin size/volume adequate?
■
❑
❑
❑
Comment: One aeration basin can be used for EQ. Only one is currently in use.
Primary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
❑
❑
❑
Is the site free of excessive buildup of solids in center well of circular clarifier?
■
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❑
Are weirs level?
0
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❑
Is the site free of weir blockage?
0
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Is the site free of evidence of short-circuiting?
0
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❑
Is scum removal adequate?
■
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❑
Is the site free of excessive floating sludge?
0
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❑
Is the drive unit operational?
0
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❑
Is the sludge blanket level acceptable?
■
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❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
N
❑
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❑
Comment: None
Aeration Basins
Yes No
NA NE
Mode of operation
Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
0 ❑
❑
❑
Are surface aerators and mixers operational?
0 ❑
❑
❑
Are the diffusers operational?
❑ ❑
0
❑
Is the foam the proper color for the treatment process?
0 ❑
❑
❑
Page# 6

Permit: NCO021211 Owner -Facility:
Inspection Date: 08/24/2022 Inspection Type:
Graham WWTP
Compliance Evaluation
Aeration Basins
Yes
No
NA
NE
Does the foam cover less than 25% of the basin's surface?
0
❑
❑
❑
Is the DO level acceptable?
0
❑
❑
❑
Is the DO level acceptable?(1.0 to 3.0 mg/I)
0
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❑
Comment: None
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?
0
❑
❑
❑
Are weirs level?
0
❑
❑
❑
Is the site free of weir blockage?
0
❑
❑
❑
Is the site free of evidence of short-circuiting?
■
❑
❑
❑
Is scum removal adequate?
0
❑
❑
❑
Is the site free of excessive floating sludge?
0
❑
❑
❑
Is the drive unit operational?
0
❑
❑
❑
Is the return rate acceptable (low turbulence)?
■
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❑
Is the overflow clear of excessive solids/pin floc?
0
❑
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❑
Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
0
❑
❑
❑
Comment: None
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
0
❑
❑
❑
Are pumps operational?
0
❑
❑
❑
Are there adequate spare parts and supplies on site?
■
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❑
❑
Comment: None
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: None
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■ ❑ ❑ ❑
❑ ❑ ❑ ■
■ ❑ ❑ ❑
❑ ❑ ❑ ■
Page# 7

Permit: NCO021211 Owner -Facility: Graham WWTP
Inspection Date: 08/24/2022 Inspection Type: Compliance Evaluation
Disinfection -Liquid Yes No NA NE
De -chlorination
Yes
No
NA
NE
Type of system ?
Liquid
Is the feed ratio proportional to chlorine amount (1 to 1)?
❑
0
❑
❑
Is storage appropriate for cylinders?
0
❑
❑
❑
# Is de -chlorination substance stored away from chlorine containers?
0
❑
❑
❑
Are the tablets the proper size and type?
❑
❑
0
❑
Comment: None
Are tablet de -chlorinators operational? ❑ ❑ 0❑
Number of tubes in use?
Comment: None
Effluent Pipe
Yes
No
NA NE
Is right of way to the outfall properly maintained?
0
❑
❑ ❑
Are the receiving water free of foam other than trace amounts and other debris?
0
❑
❑ ❑
If effluent (diffuser pipes are required) are they operating properly?
M
❑
❑ ❑
Comment: None
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
0
❑
❑
❑
Was generator tested & operational during the inspection?
M
❑
❑
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
M
❑
❑
❑
Is there an emergency agreement with a fuel vendor for extended run on back-up
0
❑
❑
❑
power?
Is the generator fuel level monitored?
0
❑
❑
❑
Comment: None
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Page# 8

Permit: NCO021211
Inspection Date: 08/24/2022
Operations & Maintenance
Comment: None
Owner -Facility: Graham WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Page#