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HomeMy WebLinkAboutNC0086762_Compliance Evaluation Inspection_20120517 TEA NCDEF R North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Chuck Wakild, P.E. Dee Freeman Governor Director Secretary May 17, 2012 City of King Attn: John W. Cater, City Manager P.O. Box 1132 King, NC 27021-1132 Subject: Compliance Evaluation Inspections & Notice of Deficiency NOD #: NOD-2012-PC-0035 NPDES Permits NC0086762 City of King Water Treatment Plant Forsyth County Dear Mr. Cater: 1. Ron Boone of the Winston-Salem Regional Office of the NC Division of Water Quality (DWQ) conducted a compliance evaluation inspection (CEI) at the subject facility on May 15, 2012. The assistance and cooperation of Scott Barrow, Kenneth Gentry, and Ronnie Gallimore, was greatly appreciated. Inspection reports are attached for your records and the inspection findings are summarized below. General 2. The facility is located at 6949 Donnaha Road, in Tobaccoville, Forsyth County, North Carolina. The facility is authorized to discharge wastewater from the water treatment works through outfall 001, which is located at approximate coordinates 36.222555° by 80.427428°, to Old Richmond Creek, which is currently classified as Class WS-IV (water supply) waters in the Yadkin Pee-Dee River basin. The wastewater treatment system consists of one upgraded wastewater pump station, dechlorination equipment, a 300,000 gallon sludge decant thickening tank, and a filter belt press. The waste stream consists of decant from the combination of backwash water from the water treatment system's filters and sludge from the water treatment system's sedimentation basins. Documentation & Monitoring Review 3. All required records were reviewed. The following discrepancies were noted: a. The Discharge Monitoring Reports (DMR) are done in a Microsoft Excel spreadsheet with cell formats that have actually rounded off to zero some of the data. However, the corresponding totals, maximums, minimums, and averages at the bottoms of the DMRs appeared to be correct. Still, the Excel spreadsheet needs to be set to NOT round off these figures to zero, so the actual results appear in the appropriate cells. b. Plant personnel currently run the field laboratory parameters Total Residual Chlorine and pH, but the permittee does not hold a current Field Laboratory Certification from the Division's Laboratory Section. This must be corrected as soon as possible, as all sample results produced by the permittee without North Carolina Division of Water Quality,Winston-Salem Regional Office Location:585 Waughtown St.Winston-Salem,North Carolina 27107 One Phone:336-771-5000 FAX:336-771-4630 Customer Service:1-877-623-6748 North Carolina Internet:www.ncwaterquality.org Naturally An Equal Opportunity 1 Affirmative Action Employer City of King • Attn:John W.Cater,City Manager • Compliance Evaluation Inspection King WTP,NC0088897 5/17/2012,Page 2 of 3 Field Laboratory Certification are considered invalid. The permittee must obtain a Field Laboratory Certification. In the interim the permittee must use an outside laboratory to conduct these two analyses properly (Please note that they both have a 15 minute hold time). To begin the Field Laboratory Certification process, please contact Mr. Boone for guidance or simply proceed to Division's Laboratory Section's website, indicated below, to download the application form, fill it out, follow all instructions, and send it to the address indicated on the application. The Division's Laboratory website also contains other information regarding field lab certification and provides phone numbers for contacting them. http://portal.ncdenr.org/web/wq/lab/cert/field c. The laboratory records, chain of custody forms, and DMRs were in a bit of disarray. More effort should be put into filing all these records in a more organized manner to allow for easy access, especially during inspections. d. Plant personnel were unfamiliar with the NC State Regulations that cover Owners and Operators in Responsible Charge of water pollution control systems. These regulations can be accessed over the Web at the following URL: http://ncrules.state.nc.us/ncac.asp?folderName=\Title%2015A%20- %20Environment%20and%20Natural%20Resources\Chapter%2008%20- %20Water%20Pollution%20Control%20Svstem%20Operators%20Certification%20Commission It is highly suggested that the permittee and the ORC's/BORC's review these regulations in detail to learn their individual responsibilities regarding the proper operation of this water pollution control system. The specific NC Regulations covering this topic are 15A NCAC 08G.0101 through 15A NCAC 08G.1101. Site Review 4. The site was very clean and well maintained. The only discrepancy noted is that plant personnel are taking the effluent samples from the decant tank. These samples must be taken at the end of the discharge pipe, before the effluent mixes with the stream water. You must begin taking the samples at the end of the discharge pipe immediately. 5. During the inspection, Mr. Barrow inquired about the possibility of receiving a land application permit for the disposal of sludge residuals. Please contact Patrick Mitchell of the NC Division of Water Quality, Aquifer Protection Section, Winston-Salem Regional Office at 336-771-5285 for further information about how to apply for such a permit. 6. As part of the initial permit application process for the NDPES permit for this facility, the permittee was required to provide a Sludge Management Plan (SMP) along with its application for the NPDES permit. Review of the current SMP on file in Raleigh shows that it does NOT address, in any capacity, the permittee's sludge management activities. You must provide an updated SMP to the NPDES Unit in DWQ's Central Office in Raleigh that summarizes the permittee's sludge management practices. Please submit an updated SMP to the NPDES Unit in DWQ's Central Office no later than June 30, 2012. In your submittal, please ensure you refer to your NPDES permit number NC0088897. You may send the updated SMP to the address below: Division of Water Quality Surface Water Protection Section — NPDES Attn: Charles Weaver City of King Attn:John W.Cater,City Manager Compliance Evaluation Inspection King WTP,NC0088897 5/17/2012,Page 3 of 3 1617 Mail Service Center Raleigh, NC 27699-1617 7. During the inspection, Mr. Boone failed to address standby power facilities at the plant. Please inform us of the standby power capabilities at the plant, specifically regarding the waste treatment system, in your written reply to this letter. Specifically, we need to know if automatically activated standby power is available for the waste treatment system, and if so, whether it can power the entire waste treatment system. 8. Please correct all deficiencies noted above as soon as practical. Again, you should also provide the updated SMP to the NPDES Unit in DWQ's Central Office no later than June 30, 2012. Finally, please reply in writing to this Notice of Deficiency within 20 business days of receiving it. Your written reply should include proposed corrective action plans for each deficiency annotated in this letter along with corresponding estimated completion dates to correct each of the deficiencies. You response will be used to determine whether this office needs to take any further action to compel full permit compliance. 9. Should you have any questions regarding this letter, the inspection, or the correction of the deficiencies, please do not hesitate to contact Mr. Boone or me at (336) 771-5000. Sincerely, W. Corey Basinger Water Quality Regional Supervisor Winston-Salem Region Division of Water Quality Attachments: 1. BIMS Inspection Report cc: SWP—WSRO Central Files WS Unit, Attm abilees Weayer DWQ/APS, WSRO, Attn: Patrick Mitchell City of King Attn: Scott Barrow, City Engineer P.O. Box 1132 King, NC 27021-1132 United States Environmental Protection Agency EPA Washington,D.C.20460 Form Approved. OMB No.2040-0057 Water Compliance IncpACtinn 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 ILu2 (tu! 31 NC0088897 111 121 12/05/15 17 181_9_1 1912 20U Remarks 21111111111111 IIIIIIII11166 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ------- Reserved — 671 169 7°U 71 I I 72 I N�--�I 731 1 1 74 751 1 1 1 1 1 1 P° 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) 09:00 AM 12/05/15 10/08/01 King WTP 6949 Donnaha Rd Exit Time/Date Permit Expiration Date Tobaccoville NC 27050 12:00 PM 12/05/15 13/10/31 Name(s)of Onsite Representative(syTitles(s)/Phone and Fax Number(s) Other Facility Data /// Kenneth Ray Gentry/ORC/336-924-8363/ Name,Address of Responsible Official/Title/Phone and Fax Number Contacted John W Cater,P0 Box 1132 King NC 270211132//336-944-6888/ No Section C: Areas Evaluated During Inspection(Check only those areas evaluated) Permit Flow Measurement gi Operations&Maintenance Records/Reports Setf-Monitoring Program II Sludge Handling Disposal $Facility Site Review •Effluent/Receiving Waters "'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 WSRO WQ//336-771-4967/ �/' 7 I f Z Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date ��-- ke—toFi k — btd4 -asto o-14411( C- EPA Form 3560-3(Rev 9-94)Previous editions are obsolete. Page# 1 NPDES yr/mo/day Inspection Type 1 31 NC0088897 111 121 12/05/15 117 18L1 Section D: Summary of Finding/Comments(Attach additional sheets of narrative and checklists as necessary) Please refer to the attached inspection summary letter. Page# 2 Permit: NC0088897 Owner-Facility: King WTP Inspection Date: 05/15/2012 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? 0 0 • 0 Is the facility as described in the permit? ■ 0 0 0 #Are there any special conditions for the permit? 0 • 0 0 Is access to the plant site restricted to the general public? ■ 0 0 0 Is the inspector granted access to all areas for inspection? • 0 0 0 Comment: Please refer to the attached inspection summary letter. Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ■ 0 0 0 Is all required information readily available,complete and current? • 0 0 0 Are all records maintained for 3 years(lab.reg.required 5 years)? ■ 0 0 0 Are analytical results consistent with data reported on DMRs? ■ 0 0 0 Is the chain-of-custody complete? ■ 0 0 0 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? • 0 0 0 Has the facility submitted its annual compliance report to users and DWQ? 0 0 ■ 0 (If the facility is=or>5 MGD permitted flow)Do they operate 24/7 with a certified operator on each shift? ■ 0 0 0 Is the ORC visitation log available and current? ■ 0 0 0 Is the ORC certified at grade equal to or higher than the facility classification? ■ 0 0 0 Is the backup operator certified at one grade less or greater than the facility classification? • 0 0 0 Is a copy of the current NPDES permit available on site? ■ 0 0 0 Facility has copy of previous year's Annual Report on file for review? 0 0 ■ 0 Comment: DMRs, Lab Data, and Chains of Custody should be better organized to facility easier inspection. Please refer to the attached inspection summary letter. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ■ 0 0 Page# 3 - Permit: NC0088897 Owner-Facility: King WTP Inspection Date: 05/15/2012 Inspection Type: Compliance Evaluation Laboratory Yes No NA NE Are all other parameters(exciuding field parameters)performed by a certified lab? • 0 0 0 #Is the facility using a contract lab? ■ 0 0 0 #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? 0 0 ■ 0 Incubator(Fecal Coliform)set to 44.5 degrees Celsius+/-0.2 degrees? 0 0 ■ 0 Incubator(BOD)set to 20.0 degrees Celsius+/-1.0 degrees? 0 0 ■ 0 Comment: Please refer to the attached inspection summary letter. Pump Station-Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? ■ 0 0 0 Is the wet well free of excessive grease? ■ 0 0 0 Are all pumps present? • 0 0 0 Are all pumps operable? ■ 0 0 0 Are float controls operable? ■ 0 0 0 Is SCADA telemetry available and operational? ■ 0 0 0 Is audible and visual alarm available and operational? ■ 0 0 0 Comment: Please refer to the attached inspection summary letter. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 0 ■ 0 Is sample collected below all treatment units? 0 ■ 0 0 Is proper volume collected? ■ 0 0 0 Is the tubing clean? 0 0 IN 0 #Is proper temperature set for sample storage(kept at less than or equal to 6.0 degrees Celsius)? 0 0 ■ 0 Is the facility sampling performed as required by the permit(frequency,sampling type representative)? ■ 0 0 0 Comment: Please refer to the attached inspection summary letter. De-chlorination Yes No NA NE Type of system? Liquid Is the feed ratio proportional to chlorine amount(1 to 1)? 0 ■ 0 0 Is storage appropriate for cylinders? 0 0 ■ 0 #Is de-chlorination substance stored away from chlorine containers? ■ 0 0 0 Are the tablets the proper size and type? 0 0 ■ 0 Page# 4 Permit: NC0088897 Owner-Facility: King WTP Inspection Date: 05/15/2012 Inspection Type: Compliance Evaluation De-chlorination Yes No NA NE Comment: Sodium Thiosulfate used for dechlorination. Please refer to the attached inspection summary letter. Are tablet de-chlorinators operational? 0 0 • 0 Number of tubes in use? Comment: Please refer to the attached inspection summary letter. Equalization Basins Yes No NA NE Is the basin aerated? 0 • 0 0 Is the basin free of bypass lines or structures to the natural environment? ■ 0 0 0 Is the basin free of excessive grease? ■ 0 0 0 Are all pumps present? • 0 0 0 Are all pumps operable? • 0 0 0 Are float controls operable? 0 0 • 0 Are audible and visual alarms operable? 0 0 • 0 #Is basin size/volume adequate? ■ 0 0 0 Comment: This is actually a sludge decant tank. Please refer to the attached inspection summary letter. Pumps-RAS-WAS Yes No NA NE Are pumps in place? • 0 0 0 Are pumps operational? ■ 0 0 0 Are there adequate spare parts and supplies on site? • 0 0 0 Comment: These are actually sludge pumps that extract sludge from sludge decant tank and pump it to the filter belt press: Please refer to the attached inspection summary letter. Solids Handling Equipment Yes No NA NE Is the equipment operational? ■ 0 0 0 Is the chemical feed equipment operational? ■ 0 0 0 Is storage adequate? • 0 0 0 Is the site free of high level of solids in filtrate from filter presses or vacuum filters? ■ 0 0 0 Is the site free of sludge buildup on belts and/or rollers of filter press? • 0 0 0 Is the site free of excessive moisture in belt filter press sludge cake? ■ 0 0 0 The facility has an approved sludge management plan? ■ 0 0 0 Page# 5 Permit: NC0088897 Owner-Facility: King WTP Inspection Date: 05/15/2012 Inspection Type: Compliance Evaluation Solids Handling Equipment Yes No NA NE Comment: The sludge management plan, required as part of the initial permit application package by the NPDES Unit at the Division's Central Office in Raleigh, needs an updated Sludge Management Plan for the facility that actually addresses the facility's sludge management process. The current plan on file does NOT address sludge management in any capacity. Please refer to the attached inspection summary letter. Chemical Feed Yes No NA NE Is containment adequate? ■ 0 0 0 Is storage adequate? • 0 0 0 Are backup pumps available? • 0 0 0 Is the site free of excessive leaking? ■ 0 0 0 Comment: Please refer to the attached inspection summary letter. Flow Measurement-Effluent Yes No NA NE #Is flow meter used for reporting? ■ 0 0 0 Is flow meter calibrated annually? 0 0 0 • Is the flow meter operational? • 0 0 0 (If units are separated)Does the chart recorder match the flow meter? 0 0 • 0 Comment: The meter is an inline mag meter that transmits to the plants SCADA system. It was just installed in January, 2012. No calibration has yet been necessary. Please refer to the attached inspection summary letter. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? ■ 0 0 0 Are the receiving water free of foam other than trace amounts and other debris? ■ 0 0 0 If effluent (diffuser pipes are required) are they operating properly? 0 0 ■ 0 Comment: Please refer to the attached inspection summary letter. Operations&Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? ■ 0 0 0 Does the facility analyze process control parameters,for ex:MLSS,MCRT,Settleable Solids,pH, DO,Sludge ■ 0 0 0 Judge,and other that are applicable? Comment: Please refer to the attached inspection summary letter. Standby Power Yes No NA NE Is automatically activated standby power available? 0 0 0 ■ Page# 6 Permit: NC0088897 Owner-Facility: King WTP Inspection Date: 05/15/2012 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is the generator tested by interrupting primary power source? 0 0 0 ■ Is the generator tested under load? 0 0 0 ■ Was generator tested&operational during the inspection? 0 0 0 ■ Do the generator(s)have adequate capacity to operate the entire wastewater site? 0 0 0 • Is there an emergency agreement with a fuel vendor for extended run on back-up power? 0 0 0 • Is the generator fuel level monitored? 0 0 0 ■ Comment: Permittee should provide information on the availability of standby power for the facility in their response to this letter and inspection report. Please refer to the attached inspection summary letter. Page# 7