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Home My WebLink AboutNC0071528_Compliance Evaluation Inspection_20221122ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Dale Norman Lake Norman Woods HOA PO Box 321 Sherrills Ford, NC 28673 SUBJECT: Notice of Deficiency Compliance Evaluation Inspection Lake Norman Woods WWTP NPDES Permit No. NC0071528 Catawba County Tracking #: NOD-2022-PC-0194 Dear Mr. Norman: NORTH CAROLINA Environmental Quality November 22, 2022 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on November 8, 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 failures to both properly maintain the wastewater treatment facility and have a properly designated operator perform the required visitations (several occasions) which 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 111.•rhworkt el G. rOrmloalal Oat,' 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 December 13, 2022, detailing the actions taken to address all violations that are discussed in more detail in the attached report. The response should also include the actions taken to address the aeration system and metal structure concerns. 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 DNORTH CAPOLI. _E 111.•rhworkt G. rOrmloalal Oat,' Sincerely, DocuSigned by: L4uI4tw11 Pcl414 F161FB69A2D84A3... Andrew H. Pitner, P.G. Acting 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 21 1 1 1 1 I5 I 1 NPDES yr/mo/day Inspection 3 I NC0071528 111 121 22/11/08 117 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 70I4 I 71IN I 72 I N I 731 I 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) Lake Norman Woods WWTP Marina Ln Sherrills Ford NC 28673 Entry Time/Date 09:55AM 22/11/08 Permit Effective Date 21/09/01 Exit Time/Date 11:10AM 22/11/08 Permit Expiration Date 25/04/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// David Thomas McDaniel//336-880-1115 / Todd Robinson/Area Manager// Other Facility Data Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Dale H Norman,PO Box 321 Sherrills Ford NC 28673//828-478-3179/ 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/ 11/22/2022 Wey '-A61696D90CC3437... Signature of M Andrew Pit (%@Reviewer Agency/Office/Phone and Fax Numbers Date eP's4" H P'4i°bWR/MRO WQ/704-663-1699 Ext.2180/ 11/22/2022 F161 FB69A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# 1 sI NPDES yr/mo/day NC0071528 111 121 22/11/08 I17 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 facility was not being operated/visited (on several occasions) by one of the designated backup ORCs following the resignation of the previous ORC in September 2022. Please be advised that the subject permit requires that either the designated ORC or backup ORC(s) must visit the facility five days per week excluding holidays [Permit Condition Reference: Part II, Section C(1) Certified Operator]. The Permittee must ensure one of the designated backup ORCs operate/visit the facility until a new ORC is designated (within 120 days). AERATION BASIN SECTION cont'd: The permittee had installed a PVC manifold system for the air distribution system due to leaks in the previous (metal) manifold system. Minimal aeration was being provided at the head of the aeration tank due to holes in the metal structure/wall between aeration basin and aerated sludge holding tank. Several areas throughout the internal metal structure also exhibited signs of severe rust and deterioration. The permittee must repair all applicable areas on the metal structure to ensure adequate structural integrity and allow for the proper operation of the aeration basin. In addition, the current air distribution system should be replaced with a permanent system that will ensure proper aeration and allow for maintenance to the diffusers. Page# 2 Permit: NC0071528 Inspection Date: 11/08/2022 Owner - Facility: Lake Norman Woods 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 ❑ ❑ •❑ 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 7/23/2020. The wastewater treatment plant is currently not restricted to the public. The wooden perimeter fence was deteriorated and in a poor condition including several missing sections. The perimeter fence must be either replaced or repaired to restrict access from the public and prevent potential liability issues. Please be advised that the subject permit requires the permittee to properly operate and maintain the facility at all times. 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? Is a copy of the current NPDES permit available on site? • ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ • ❑ Page# 3 Permit: NC0071528 Inspection Date: 11/08/2022 Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: The records reviewed during the inspection were organized and well maintained. Discharge Monitoring Reports (eDMRs) were reviewed from October 2021 through September 2022. Effluent BOD limit violations were reported in July 2022 (daily maximum), August 2022 (daily maximum) and September 2022 (daily maximum and monthly average). Effluent ammonia limit violations were reported in July 2022 monthly average), August 2022 (daily maximum and monthly average), and September 2022 (monthly average). A daily maximum effluent fecal coliform limit violation was also reported in July 2022. The Division has previously addressed these limit violations through the issuances of either NOVs or civil penalty assessments. 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, temperature and total residual chlorine) are performed under Environlink's field laboratory certification #5212. Statesville Analytical has also been contracted to perform analyses of all permit -required parameters except field. The facility staff must ensure that post calibration checks are performed (on all applicable meters) at the end of the day if these meters are used to perform effluent analyses at multiple facilities (Reference: NC Wastewater/Groundwater Laboratory Certification - Approved Procedure for the analyses of dissolved oxygen, pH and total residual chlorine). Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ ❑ IN ❑ 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. Page# 4 Permit: NC0071528 Inspection Date: 11/08/2022 Owner - Facility: Lake Norman Woods 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 MODE Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: There were operation and maintenance issues noted with the facilities structure and aeration basin. These issues will be discussed further in the Aeration Basin Section. Please be advised that the subject permit requires the permittee to properly operate and maintain all facilities and systems of treatment at all times [Permit Condition Reference: Part II Section C(2) Proper Operation & Maintenance]. Equalization Basins Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? Comment: Bar Screens 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • El • ❑ ❑ ❑ Comment: A majority of the screening is performed by the screening system in the equalization tank. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? • ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ El • El Page# 5 Permit: NC0071528 Inspection Date: 11/08/2022 Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Evaluation Aeration Basins Yes No NA NE 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? • ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ • Is the DO level acceptable?(1.0 to 3.0 mg/I) El ❑ El • Comment: The aeration basin appeared to have a very low biomass population. The 30-minute settleability test revealed a 50 ml/L result with a turbid supernate during the inspection. Although the aeration basin was not septic and the ambient temperatures are currently colder, this office is concerned with adequate oxygenation during the Spring and Summer months.See "Summary" Section for additional comments. 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 • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The permittee and facility staff must ensure the clarifier skimmers are properly positioned. Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? • ❑ ❑ ❑ Are the tablets the proper size and type? ■ El El El Number of tubes in use? 3 Is the level of chlorine residual acceptable? • El El El Is the contact chamber free of growth, or sludge buildup? • ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? • El El El Comment: Calcium hypochlorite tablets are used for disinfection. Page# 6 Permit: NC0071528 Inspection Date: 11/08/2022 Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Evaluation 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? • ❑ ❑ ❑ Comment: Are the tablets the proper size and type? ■ ❑ ❑ ❑ Are tablet de -chlorinators operational? • ❑ ❑ ❑ Number of tubes in use? 3 Comment: Sodium Sulfite tablets are used for dechlorination. The dechlorinated wastewater is conveyed to a post aeration tank prior to being discharged into the receiving stream. 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: Instantaneous flow measurements are currently performed by the bucket and stop watch method. 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 ❑ ❑ • ❑ • ❑ ❑ ❑ ❑ ❑ IN ❑ Comment: The effluent in the post aeration tank appeared slightly turbid with foam (entrained air). The effluent is pumped through a submerged outfall before discharging into the receiving stream. Aerobic Digester 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Page# 7 Permit: NC0071528 Inspection Date: 11/08/2022 Owner - Facility: Lake Norman Woods WWTP Inspection Type: Compliance Evaluation Aerobic Digester Yes No NA NE Comment: The facility is equipped with an aerated sludge holding tank. Wastewater solids are removed on an as -needed basis by Lentz Septic Tank Service. Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Was generator tested & operational during the inspection? Do the generator(s) have adequate capacity to operate the entire wastewater site? Is there an emergency agreement with a fuel vendor for extended run on back-up power? Is the generator fuel level monitored? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The permittee must ensure the backup generator is properly operated and maintained at all times. This should include periodic testing events and servicing according to the manufacturer's instructions. All future testing and servicing events should also be documented and available for review by the operations and/or DWR staff. The operations staff should also be given a copy of the operation & maintenance manual. Page# 8