NC0021181_Compliance Evaluation Inspection_20230306

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Bill Carroll, Public Works Director
City of Belmont
Post Office Box 431
Belmont, NC 28012
SUBJECT: Notice of Deficiency
Compliance Evaluation Inspection
City of Belmont WWTP
NPDES Permit No. NCO021187
Gaston County
Tracking #: NOD-2022-PC-0060
Dear Mr. Carroll:
NORTH CAROLINA
Environmental Quality
March 6, 2023
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject
facility on February 28, 2023, 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.
Although the ORC and staff have initiated commendable operational efforts, this report is being issued as a Notice of
Deficiency (NOD) due to the City's failure to properly operate and maintain WWTP which is a violation of the subject NPDES
Permit and North Carolina General Statute (G.S.) 143-215.1. Specifically, the City has not adequately maintained wastewater
solids (bio-solids disposal, etc.) to enable proper operation of the treatment processes as discussed further in the Aeration Basin,
Secondary Clarifier and Disinfection -Gas Sections in the attached report. 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.
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 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 March 27, 2023, detailing the City's actions to address
the violation including evaluations of alternate disposal options (portable belt press/landfill, etc.) to ensure the WWTP is
properly operated and maintained at all times. 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 [phone] or at
wes.bell&ncdenr. gov.
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
Sincerely,
Docu Signed by:
444W N P44,ft
F161FB69A2D84A3...
Andrew H. Pitner, P.G.
Assistant Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality [ Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663.1699

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 NCO021181 111 121 23/02/28 I17 18 LC] I 19 I s I 201
21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 701d I 71 I„ I 72 I r., I 71 I 74 79 I I I I I I I80
L—I ty L-1 I I
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 permit Number)
09:05AM 23/02/28
19/12/01
Belmont WWTP
298 Parkdale Rd
Exit Time/Date
Permit Expiration Date
Belmont NC 28012
12:30PM 23/02/28
24/06/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Tanya S Carter/ORC/704-825-3791/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Barry L Webb,PO Box 431 Belmont NC 280120431/Interim City
Manager/704-825-5586/7048250514 No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispo: 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
Wes Bell signed by: DWR/MRO WQ/704-663-1699 Ext.2192/ 3/3/2023
Be&
E�Docu`,','�96D90=437
...
Signature of Mana @000PRdbyiewer Agency/Office/Phone and Fax Numbers Date
Andrew Pitne X"{'" H P4"R/MRO WQ/704-663-1699 Ext.2180/ 3/6/2023
F161FB69A2D84A3...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NC0021181 I11 12I 23/02/28 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Influent Sampling Section cont'd:
The normal influent sampling location does not include side streams; however, the temporary
sampling location may include decant from the aerobic digesters due to the bar screen/grit chamber
bypass. The ORC and staff must ensure no side streams are discharged during long term sampling
events (Headworks development).
Operation & Maintenance Section cont'd:
The ORC and staff have initiated commendable efforts to operate the wastewater plant with a high
solids inventory due to the delays associated with the weather and land application events. Evidence
of high solids inventory were observed in the aeration basin (high settleability tests) and secondary
clarifiers (high sludge blankets) along with high sludge levels in the chlorine contact basin as a result
of the solids carry-over from the secondaries. 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].
Page#

Permit: NCO021181 Owner -Facility: Belmont WWTP
Inspection Date: 02/28/2023 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
❑
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application?
Is the facility as described in the permit?
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# Are there any special conditions for the permit?
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Is access to the plant site restricted to the general public?
■
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Is the inspector granted access to all areas for inspection?
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Comment: The City implements a Division -approved Industrial Pretreatment Program.
The last compliance evaluation inspection at this facility was performed by
DWR staff
on 2/8/2021.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
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Is all required information readily available, complete and current?
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Are all records maintained for 3 years (lab. reg. required 5 years)?
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Are analytical results consistent with data reported on DMRs?
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Is the chain -of -custody complete?
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Dates, times and location of sampling
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Name of individual performing the sampling
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Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
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Has the facility submitted its annual compliance report to users and DWQ?
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
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operator on each shift?
Is the ORC visitation log available and current?
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Is the ORC certified at grade equal to or higher than the facility classification?
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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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Page# 3

Permit: NCO021181
Inspection Date: 02/28/2023
Owner -Facility: Belmont WWTP
Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Comment: The records reviewed durinq the inspection were organized and well maintained.
Discharge Monitoring Reports (eDMRs) were reviewed from February 2022 through
January 2023. Effluent permit limit violations were reported in June 2022 (total residual
chlorine), August 2022 (chronic toxicity failure) and January 2023 (fecal coliform). The
above -noted violations will be separately addressed by the Division through the
issuances of either Notice of Violations (NOVs) or NOV/civil penalty assessments.
ORC visitation log, operation & maintenance records and process control
measurements were beina DroDerIv documented and maintained on -site.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
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Are all other parameters(excluding field parameters) performed by a certified lab?
0
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# Is the facility using a contract lab?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0
■
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degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
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■
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Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
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Comment: Pace Analytical Services has been contracted to perform Influent and effluent
(including field) analyses. ETT Environmental has also been contracted to
perform
effluent chronic toxicity tests.
Influent Sampling
# Is composite sampling flow proportional?
Is sample collected above side streams?
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 sampling performed according to the permit?
Yes No NA NE
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EIN ❑ ❑
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Comment: The subject permit requires BOD and TSS composite samples. The sampler tubing will
need to be replaced within the near future. In addition, the ORC and staff must ensure
the sampler strainer is collecting a well -mixed sample at the bar screen bypass
discharge location. See "Summary" Section for additional comments.
Effluent Sampling
Yes
No
NA NE
Is composite sampling flow proportional?
0
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Is sample collected below all treatment units?
M
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Is proper volume collected?
0
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Is the tubing clean?
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0
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Page# 4

Permit: NCO021181 Owner -Facility: Belmont WWTP
Inspection Date: 02/28/2023 Inspection Type: Compliance Evaluation
Effluent Sampling
Yes
No
NA NE
# Is proper temperature set for sample storage (kept at less than or equal to 6.0
0
❑
❑ ❑
degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
M
❑
❑ ❑
representative)?
Comment: The subject permit requires composite and grab effluent samples. The sampler
tubing
will need to be replaced within the near future.
Upstream / Downstream Sampling
Yes
No
NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type,
■
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and sampling location)?
Comment:
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?
Comment: The wastewater treatment facilitv appeared to be adequately treatinq wastewater
during the inspection: however, an excessive solids inventory was being maintained as
discussed further in the Aeration Basin, Secondary Clarifier and Disinfection -Gas
Sections. See "Summary" Section for additional comments.
Bar Screens
Yes
No
NA NE
Type of bar screen
a.Manual
b.Mechanical
Are the bars adequately screening debris?
■
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Is the screen free of excessive debris?
0
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Is disposal of screening in compliance?
0
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Is the unit in good condition?
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0
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Comment: The mechanical screen is currently
being bypassed due to scheduled repairs that will
be performed within the next two months. The manual bar (coarse) removes the larger
debris but the smaller screenings
pass through the treatment unit as observed in the
secondary clarifiers.
Grit Removal
Type of grit removal
a.Manual
b.Mechanical
Yes No NA NE
Page# 5

Permit: NCO021181
Inspection Date: 02/28/2023
Grit Removal
Owner -Facility: Belmont WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Is the grit free of excessive organic matter?
❑ 0
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Is the grit free of excessive odor?
■ ❑
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# Is disposal of grit in compliance?
0 ❑
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Comment: The grit system is also being bypassed
for scheduled repairs that will be performed
within the next two months. The debris that has accumulated in the grit chamber will
need to be removed and properly
disposed prior to the repairs (chain replacement).
Chemical Feed
Is containment adequate?
Is storage adequate?
Are backup pumps available?
Is the site free of excessive leaking?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
Comment: Sodium hydroxide is added into the influent prior to enterinq the aeration basin to
maintain appropriate alkalinity/pH levels. The sodium hydroxide storage tank is
double -walled and no leakages were observed.
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system
Surface
Is the basin free of dead spots?
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■
Are surface aerators and mixers operational?
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Are the diffusers operational?
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0
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Is the foam the proper color for the treatment process?
0
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Does the foam cover less than 25% of the basin's surface?
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0
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Is the DO level acceptable?
0
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Is the DO level acceptable?(1.0 to 3.0 mg/1)
0
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Comment: The facility is equipped with two aeration basins; however, one of the aeration basins
has been taken out of service for many years. Seven of the eight aerators are
operational and two aerator were operating during the inspection.
The 30-minute settleability tests have been consistently high (980 ml/L) and the ORC
and staff are challenged to run all needed aerators at one time due to the high solids
inventory. The foam appeared a darker brown due to higher solids inventory and
longer solids retention time.
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
• ❑ ❑ ❑
• ❑ ❑ ❑
Page# 6

Permit: NCO021181
Inspection Date: 02/28/2023
Secondary 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?
Owner -Facility: Belmont WWTP
Inspection Type: Compliance Evaluation
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
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Comment: The sludge blanket levels in both secondary clarifiers were not acceptable with the
on -site measurements being 9.5 ft. in both clarifiers. The current sludge blanket levels
pose a significant potential of being washed out during high flow events and the high
solids inventory being maintained in the treatment processes contributes to these high
levels. The unlevel weirs were not excessive and no short-circuiting was observed.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
0
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Are pumps operational?
0
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Are there adequate spare parts and supplies on site?
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Comment:
Disinfection -Gas
Yes
No
NA NE
Are cylinders secured adequately?
0
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Are cylinders protected from direct sunlight?
0
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Is there adequate reserve supply of disinfectant?
0
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Is the level of chlorine residual acceptable?
0
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Is the contact chamber free of growth, or sludge buildup?
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0
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Is there chlorine residual prior to de -chlorination?
0
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Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No.
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0
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7782-50-5)?
If yes, then is there a Risk Management Plan on site?
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0
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If yes, then what is the EPA twelve digit ID Number? (1000-
If yes, then when was the RMP last updated?
Page# 7

Permit: NCO021181
Inspection Date: 02/28/2023
Owner -Facility: Belmont WWTP
Inspection Type: Compliance Evaluation
Disinfection -Gas Yes No NA NE
Comment: The level of solids (5.5 ft.) measured in the chlorine contact chamber was excessive
during the on -site measurements. Approximately 1.5 ft. of clear water was observed on
top of the level of solids. The solids must be removed/properly disposed and should
be maintained at 1 ft. or less. The current level of solids measured in the chlorine
contact chamber poses a significant potential of being washed out during high flow
events and/or being re -suspended in the effluent due to denitrification (floating sludge
clumps).
De -chlorination
Yes
No
NA
NE
Type of system ?
Gas
Is the feed ratio proportional to chlorine amount (1 to 1)?
0
❑
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❑
Is storage appropriate for cylinders?
0
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❑
# Is de -chlorination substance stored away from chlorine containers?
0
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Comment:
Are the tablets the proper size and type? ❑ ❑ ❑
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use?
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
0
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Is flow meter calibrated annually?
0
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Is the flow meter operational?
0
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(If units are separated) Does the chart recorder match the flow meter?
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0
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Comment: The flow meter is calibrated quarterly and was last calibrated on 12/9/2022
Experienced Water Solutions, Inc.
Effluent Pipe
Yes
No
NA
NE
Is right of way to the outfall properly maintained?
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0
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Are the receiving water free of foam other than trace amounts and other debris?
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■
If effluent (diffuser pipes are required) are they operating properly?
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0
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Comment: The effluent appeared slightly turbid with trace suspended solids and no foam. The
effluent is discharge through a submerged outfall in the receiving waterbody.
Aerobic Digester
Is the capacity adequate?
Yes No NA NE
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Page# 8

Permit: NCO021181
Owner -Facility: Belmont WWTP
Inspection Date: 02/28/2023
Inspection Type: Compliance Evaluation
Aerobic Digester
Yes
No
NA
NE
Is the mixing adequate?
0
❑
❑
❑
Is the site free of excessive foaming in the tank?
0
❑
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# Is the odor acceptable?
0
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# Is tankage available for properly waste sludge?
0
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❑
Comment: The facility is equipped with two aerobic digesters
and a sludge holding tank. Bio-solids
are land applied by Southern Soil Builders under the authority of Permit No.
WQ0003281.
The level in the sludge holding tank is being
lowered to allow for the removal of the
tree/vegetation mats.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
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Is the generator tested under load?
■
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Was generator tested & operational during the inspection?
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Do the generator(s) have adequate capacity to operate the entire wastewater site?
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0
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Is there an emergency agreement with a fuel vendor for extended run on back-up
■
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power?
Is the generator fuel level monitored?
■
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Comment: The backup generator does not power the blowers (aerobic digesters) and three
aerators in the aeration basin.
The generator is tested weekly (automatically) under load. The City also participates
in Duke Power's load management program. City personnel services the generator
annually.
Page# 9