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HomeMy WebLinkAboutNC0020931_NOI_NOV2019OV0003_20190823`lLOYtCOQki GoiamoP� G►>sn,.ui b 1 UNDDf'~+rE1L1'l2F Ek .ci�Yri0.'.•S� Certified Mail # 70111570 Return Receipt Requested, August 23, 2019 Russell Hunter, IV Town of Boonville PO Box 326 Boonville, NC' 27011-0326 SUBJECT: NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY Tracking, Number: NOV-2019-OV-0003. Permit No: NCO020931 Boonville WWTP Yadkin County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of;the Boonville ,WWTP on August 15, 2019. This Inspection was conducted to verify.that the facifity is operating'in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0020931. A summary of the findings and comments noted during the inspection are provided in the enclosed, copy of the 'inspection report The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Winston-Salem Regional Offlce. The following violation(s) were noted during the inspection: Inspection Area Description of Violation Permit Current permit not available on site, Effluent Sampling Effluent sampleraliquotwas not as programmed (442% more than programmed): Laboratory Feld lab certification notion site. Operations & Maintenance Many components; dilapidated and in poor condition. Facility dependability is questionable. Operations & Maintenance None of the currently designated backup operators work at the facility. No backup. ORC is assigned. Secondary Clarifier Scum skimmer on operational rectangular treatment train's, clarifier ineffective. Laboratory Several: data points on the DMRs reviewed during the inspection (May - July 2018) were erroneous, and, also, several other data points on the DMRs reviewed did not have matching data points on the lab bench sheets, or anvwhere else: as source data: Inspection Area Description;ofViolation Operations 8r Maintenance Themiddlerectangular treatmenttrain floated, abdUt2 years ago and remains inoperable. Secondary Clarifier Weir on operational reetangplar treatment train's clarifier not level. A Notice of ViolationJIntent to Issue Civil Penalty is being issued, for the noted violations; of North'Caralina General -Statute (G.S.) 143-215.1 and the facility's NPDES WW Permit. Pursuant to G.S.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. 143215'.i. If you wish to provide additional information regarding the noted violations, request technical assistance, of discuss overall compliance plea e-respond in writing within ten (10) business days after recelpt of this Notice; A review, of your response will be considered along, with any additional information provided, You will then be notified oCany civil penalties that may be assessed regarding the violations. If no response is received in this office -within the 10-day periodr a civil penalty, assessment may be prepared. 'Where possible, remedial actions should have already been takentocorrect these problems a_nd prevent further occurrences in the future. The Division. of Water Resources may pursue enforcement action for this and any additional viola#ions of State law. If the violations. are, of a continuing nature, not related to operation and/or maintenance problems, and you' anticipate remedial construction activities, then you may, wish to consider applying, for a Special Order by Consent. Reminder! Pursuant to Permit Condition 6 in Section E, the Permittee'is required to verbally, notify the. Regional Office as soon as possible, not to exceed 24 hours, from first knowledge of any non-compliance at the facility including limit violations, bypasses of, or failure of a treatment unit: A written report: may be required within 5 days if directed by Division staff. Prior notice should be given for anticipated or potential problems due to planned .maintenance activities, taking units off ---line, etc. If you should have any questions, please do not hesitate to contact Ron Boone with the Water Quality_ Regional Operations Section in the Regional Office at336-776-5800. Sincerely,. Ueeuswp.aM(: ��--1,4W9E225ce4F _ LonT. Snider, Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ ATTACHMENTS 1. EPA Water Compliance Inspection Report cc, WQS Winston-Salem Regional Office - Enforcement File United StatssEnvWnmentalPiatacdanAgeiuy I Form Approved, EPA WashinoW. UZ,20460 OM6 No. 44"057 Water Compliance. Insgection Report Sedori,k National Data System Codingirt.91. PGSJ TransactioA Code NPDES ydnio/day Inspection Type Inspecicir Fac TYpa 1 3 1 KRUM31 1111 121 IWQ8119 17 is UG 191 �j 20L] 21 InSLIedon WoridDays Facifty 9eiWonliodrig- Evaluation Rating E(If -QA. -Reserjocf- EITL .......... 1 70 Lj 71 Ljj �2, [.!j 7311 j_j!4 75L_LLL_L_LLf.Q • Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW. also Include SWY :,Me[Dafq permit Effective Date POTW ilame,and NPDES'Ddrftt Numberl. 10*14 19101(0I Boomme MvrP jjqCaroffnaAve� Eklt-�=OJDafe PeftitEWration'Date, BoonvilfoNC27011 12'.GDPM With !i 23fl2/31 Name(s) of Onsite Repmentative(syTities(syPhone.and Fax Number(s) Other Facility Date Jeffrey Eugene Jones/OR,C/25Z.639-75441 •Name, Address of Responsible OfficlatiTidelPhonq and'Fax Number Contacted Robed GafidnerPO Box 326 Boonville NG 2701103261133&367-794113363674205 No Section C: Areas Evalutated.During Inspection (Check only those areas evaluated) Permit Flow'Measurement operations 8 Maintenance ReccirdslReports Self -Monitoring. Program Facility -Site Review EffluentlReoeiving Waters Laboratory Section b: Summary of Finding/Comments (Attach additional sheets Of narrative and checklists as necessary) (See attachment summary) Name(s) and Sigriature(s)..af Inspector(s) Agency/0111ce/Phone and Fax Numbers Date Ron Soon. VVSR0 WQ11336WO-46001 8/21t2019 S(gratureofManagemenrOAReviewer Agency/OfficeiPhone and FiixNurnbers Date i r 8/23/2019 i G-1453,19FUSCNEA— I EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yrlmoloay inspection: Type 3� Ncoo2ogal I11 12 191DanS 17 18 ICI - (Cont.) Section D: Summary of. FlndinglCommentS (Attach:additional sheets ofnarradve:and chedoists-as necessary) The, Boonville plant is certified to run pH; AO, and temperature with NC field: lab certificafe number 66M However, there were se,verali issues. as follows: 1.'The operator; Jeff Jones, did not have the 2019.certificate atthe plan. t,.Mr. Boone called the lab cart unitafter the. inspection to verify their 2019 certification. Mr..Jones must find: his certificate or call the, lab cert unit.fo. regWsGa replacement: in the future Mr. Jones must take better care to receive and properly care fortheir new certificate each.year, Mr. Boone -examined the 2015 ano:2018 certificates and accompanying letters.and parameter lists. Both letters were dated in May of,each respective year; but when Mr, Boone spoke with lab cent personnel, they, informed hint thaf new. certllcates, are mailed in December of each, year, so, it is unknown, at this point, Why Boonvill&q letters were dated May, 'In your response letter please provide an updated status of your field laboratory certification. 2. In comparing lab bench sheets;_ which also serve to record other Items such as dateftime, operator name, flow meter readings, etc, with the final 'version .of the bMRs, several DMR data,points were either erroneous, to.varying extents, or matching bench sheet data did not exist for some DMR data polnts..Mt. Boone expressed concerti over the errors butalso told the operator that the missing bench sheet dafa was of even more concern, because, it is potentially indicative of falsified data. Mr. Jones explained the data gathering process used at the plant as follows: Operators take meters from the lab/plant building to take the, needed readings: and return to.the lab/plant building and write their. on a dry erase board that is just inside the door.. From there the data is supposed to be transferred to the bench sheets, although it is unclear who isresponsible for the transfer and within what time frame the data shouldi be. transferred. It is also unclear how the data: is recorded whilethe operator is in the field: beforeit is transferred to the dry erase board. From the bench sheetthe data is transferred;toa draft DMR' and then finally the data is transferred to eDMR for finalization. Mr. Boone informed Mr. Jones that the process, needs to be improved and streamlined to ore-ventfurther errors and missing data points in the future. Mr. Jones could not explain the missing data points but.acknowledged the seriousness of the issue. *In your response letter please: answer the following questions in detail: a. Please, explain how operators record data collected in the field, before it is placed on the dry erase board, b. Who is responsible for transferring the data from the: dry erase board to: the benchsheets and within What time frame are theyrequired'4o do so? c. Is it verified that dry erase board data has been fransferred to thebench sheets before it is destroyed? cl : Please explain in detail. your plan to improve the data collectionfrecordatlon process to guarantee future violations of this type are averted completely: 3. Data exists -on the bench sheets that is not reported' on DMRs. Although the data is aboveand beyond what is required by the permit, it muststill'be recordedfreported on the DMRs. Mr. Jones.must begin "reporting all acquired data.. 'In your response letter please explain in. detail your plan to improve the datacollection/recordation process to guarantee the future reporting of all data. collected by plant staff. 4. The tubing on the influent sampler should be replaced. The influent sampler was nottested during, the inspection but the effluent sampler was and did not sample according; to its program; irs programmed to pull 120 milliliters every 40 pulses but it pulled 530 milliliters. Mr. Boone asked Mr.. Page# P m it; NCO020931 owner-F_aclllty: 'B.WWiaWVV)? 4m:pectlori Date: 081152019 InspeNon Type. 'Ccmpliance livahlalion Jones to investigate and correcttthis discrepancy: Given the significant discrepancy on the effluent sampler,: the influent sampler should be.verifed as well. In your response letter please answer'the:following questions in detQl; a. Please tell us'when'the influent sampler's tubing will be replaced. b. Please tell us the influent samplers flow: regime and whether it is sampling according to its program: c. if it is not sampling according to its program, please telLuswhen this will be corrected. 5. The effluent sampler -was tested and did not sample according to its program; it's programmed to pull 120 milliliters every 40 pulses but it pulled 530 milliliters for the first aliquot -when the sampling. regime was initiated. Mr. Boone asked Mr. Jones to investigate and correct this discrepancy: Given the significant discrepancy on the effluent sampler; the influent sampler should be verified as well. *In your response letter please answer the following questions in deta'ih a. Please tell us -when the effluent sampler will be repaired and 'reprogrammed to sample, properly. b.: Please tell us why the effluent sampler wasn'tsampling properly; 6. The plant description lists a comminutor but tfiere Isn't one installed. Tfie plant description should be updated, to correctthis: mistake. 'No. actionis required until the next permit renewal Pleasecorrectth'e plantdescription atthat,time,. 7. None of the currently assignedbackup operators currently work at the plant. Mr. Jones stated that Mr. Steve Hutchins is his backup operator but he is notso designated. in QWR's database. Mr. Jones - must properly designate the backup ORC(s) by submitting the.necessary paperwork. *In your response letter please answer the fdllowing.questions in detail: a. Please tell, us why no appropriately certified. backup operators are assigned. b. Please tell us, your timeline to. have appropriately certified operators property designated as backup operators, 8. The: plant has temporaquiobiie frao tanks on site for the purpose of d vertinglexcess flow as needed. A temporary diesel' pump transfers excess, water to the frac tanks and comes on automatically using a float sensor when the, level in the influent splitter box gets too high. 'No action, is required at this time. 9. There is no infiuentmeter. Both the influent and effluent samplers are connected to the effluent meter for flow proportional, sampling. So; influent flow proportional composite samples are paced: off the Effluent flow. 'No action is required at. this:time. 10. The barscreenings are placed on the old drying beds, the underdrains.of which are still connected to the plants influent Ilne: The screenings are then hauled to landfill. Wet sludges is applied'to one of five Page# Pe ft NCO020931 owner-F_acllity: aconviiiewwTP Insp¢ctiori Date: 08/1552019 ComplianmEvahfaoa drying beds. and dried sludge is stockpiled in the same old drying beds that bar screenings.are placed in and also landfilled. `No action: is required at this time: 11. The mixed liquor in both operational aeration basins;looked very good and imparted a pleasant earthy'cdor. Aeration looked good with no dead spots; short circuiting, etc, Mr. Jones stated they keep the DO at about 4. mgAwith no,problems. Diffused aeration appeared very effective- DO was not tested during the: inspection. *Na action is required at this time. 12. The sludge blanket in the operational rectangular units clarifier was:about 2'. The overflow was very clear with very little pin.floc. However; the weir on this: unit'is slightly off level and morwwastewater flows dyer the eastern side of the Weir. Although it did not appear to be causing short circuiting, which'. may have been because of a relatively low flow rate:at the time, the weir should be level to best guarantee proper -operation and treatment..Also, the skimmer on this: unit is ineffective. and should be repaired/replaced. 'In your response letter please answer the following questions in detail! a. Please indicate whether short!circuiting ever -occurs in this clar(fer. b. Please indicate what the town's plans are to level the weir. c. Please indicate what the town's plans are to repair this clarifier's scum'skinimer. 13. The UV disinfection unit appeared well marntained'and:effective. The effluent was very clear. `In your response letter please tell us what backup disinfection system the plantemploys. 14. This plant consists of three individual package trains; one circular (100K GPD); and two rectangular (50K GPD.each). One of the rectangular units floated approximately 2 years ago when it was emptied to facilitate. maintenance and resurfacing. Unfortunately, the unit has notbeen reset and placed back in service.yet, in part due to difficulties the town has experienced with'the first contractor that was hired to do the work. A new contractor has now been hired. `In your response letter please answer, in detail, the following questions - a. Why the tank has,NOT been reset andplaced back.in service: b, Wherethe. town is in -the process of getting the tank reset and, placed back in service: c. What needs to be done to make this happen.as well as, the town's plan to make it happen as quickly as possible. 15. Several components are quite dilapidated, are inefficient, or don't even exist; such as, a. The Parshall flume (concrete.cracked and spalling); b. The floated freatmeni train' (no explanation required); c Grit and/or grease removal (non-existent);, d. Permanent flow' equalization (non-existent); e. Haphazardly constructed guard rails, as Well as many other plant components (no explanation required); Page# Permit; NC0020931. Oamer-FadOty: BoorW6vwrP Inspection Date: OB1152019 Inspectlon:Type: 'cemoanmEvaluation f:. Two treatment units still need resurfacing[ and mainteriancet (no explanation required); g. Walk ways on the circular treatment train are, made from.wood. that looks very old and weak and therefore:very unsafe. (no. explanation required);, 0 Facility dependability is questionable. The town needs to'beg ininvesting significant time 'and capital's in the plant in order to maintain whats there in safe. and efficient working condition and)oe to replace; what's currently there. This is the onlyway.to guarantee future compliance wittr the town's NPDES permit. 16. Mr. Jones indicated that the generator tuns automatically under load for approximately 15 minutes every Wednesday morning. 'In.your response letter, please answer the following questions; a. Please. indicate whether,this test is initiated by interrupting the primary powersource, or by simply flipping'the switch. b.Please' indicate how the operators monitor the generators fuel level, c. Please.tell-us whether there currently exists an emergency fuel supply agreement/contract with: a dependable fuel vendor: Page# 5' PwrrdL N00020931 owner. Facility- BoonwTe VJVM Inspec0onpam: 08/1512019 rnepecUvnTWer CompilancaEvalua0on Laboratory Yes No -NA NE, Are :field parameters performed by certified personnel or laboratory? IM, ❑ ❑ ❑ o Are:all`otherparameters(excludingfield parameters) performedlbyacertified lab? ❑I ❑ 11 # Is the facility using a contract lab? ❑ ❑ ❑ # Is proper temperature set forsamplestorage.(kept at less than or equal to 6:0,degrees ❑ ❑ ❑ 0 Celsius)? Incubator (Fecal Cbliform) set to44.5 degrees Cefsius+/-0t2 degrees? ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +A 1.0 degrees? ❑ ❑ ❑ Comment: Please'refer to the inspection summary section_ Influent Sampling Yes No NA NE' # Is composite sampling flow proportional? M ❑ ❑ El Is sample collected above side streams? j ❑. ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? ❑, a ❑ ❑ # Is proper temperature set forsarpple.storage (kept at less than or equal to 6:0 degrees ❑ ❑ ❑ Celsius)? Is sampling performed according to the permit? M ❑ ❑ ❑ Comment: Please refer to the inspection summary section EffluentSampling Yes No NA NE Is composite sampling flow proportional' M ❑ ❑ 11 Is sample collected below all treatment units?' 'N. '❑ ❑ 11 Is proper volume collected? I❑ 0 ❑ 11 Is the tubing clean? E ❑ ❑ ❑ Is proper temperature seffor sample storage -(kept at less than or equal to:6.0 degrees E ❑ ❑ Celsius)? Is the facility sampling performed as required by the pernit(frequency, sampling type M ❑ ❑ ❑ representative)?. Comment: .Please refer to the inspection summary section. Upstream I Downstream Sampling Yes No NA NE. Is the facility sampling performed as required by the pernit,(frequency, sampling type, and E..❑ ❑ 11 sampling location)? Comment: None Page# 6 Parma: NCO020931! Owner.Facility: liocnvilleww.rp Inspection 08/1512019 InspecOon:Type: 'ComplianmEvaluai Permit '_Yes No NA NE Of the present permitexpires in 6:months orless). Has the permittea submitted a new Q. ❑ application? is the facility, as described inthe•permit? ❑ MI, ❑ # Are there any special conditions for the permit? 'Q M ❑ El Is access to the plant site restricted to the general public? 10 ❑I ❑ El Is the Inspector granted access to all areas for inspection? 'Eli ❑ Q 'Comment: The plant description lists a comminuter but there isn't one, installed. The plant description should be updated to correct this mistake. Record Keeping. Yes No NA NE. Are: records.keptiandmaintained as required bythe permit? ❑ ❑ fs all required information readily available„ complete and current? I❑ K ❑ ❑ Are:all,records:maintained fora years (lab. reg. required 5 years)? M Q ❑ El Are analytical results consistent with data reported on DMRO' Q M, ❑ El Is the chain-ofcustody complete? ;�❑.' ❑ Dates; times anidlocaf on of sampling Name of individual performing the sampling Results of analysis and calibration Dates of analysis .�. Name of person performing analyses Transported Gli Are DMRs complete: do they Include all permit parameters? I Q ❑ ❑ Has . fadlitysubmitted its,ennual compliance report to usersand.DWO? Q Qi (if the facility is = or 5- 5' MGD permitted flow) Do they operate 24f7 with a certified operator ❑ ❑ on each shift? Is the ORC.visitation log available and current? M QI ❑ ❑ Is the ORC certified at grade equal toorhigherrthan,lhe facility classification? 0 Q ❑ 11 Is the backup operator certified atone grade less or greater thart the facility classification? ❑ ❑ Is a copy of the current NPDES permit available on,site? :11 N ❑ 11 Facility has copy of previous year's Annual Report on file for review? ❑ Ell ❑ Comment: Please refer to,ttle inspection surrtmary secfion Equalization Basins Yes No NA NE Is the basin aerated? ❑ A ❑ Page# 7 i Permlt• NCO020931 Owner-Faclity: Boonville WWTP Inspection Date: 09115r2019 Inspection Type: COMP93ntOEvaluaUcry Equalization Basins 'Yes No NA NE 'Is ttre, basin free of bypass lines or structures to the natural environment? 1111 ❑ Is the basin, free of excessive..grease? ❑'❑.' ❑ Are -all. pumps present? E ❑ El 0 Are ail'pumpsoperable? ❑ ❑ ❑ E Are,float controls operable? El ❑. ❑ 0 Are audible andvisualalarms. operable? ❑ ❑ ❑ # Is basin sizelvolume adequate? ❑ ❑ ❑ Comment: Please refer to the inspection summary section. Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? l ❑ ❑ N Is flow meter calibrated annually? ❑ ❑ ❑ Is the. flow meteroperatiOnal? ❑ ❑_ ❑ 0. (it ur its.are separated) Doesthe chart recorder match the flow meter? ❑ ❑ [� Comment: There is no influent meter: Both the influent and effluent samplers are connected to the effluent meterfor flow[or000rtional sampling. Bar Screens Type of bar screen Yes No 14A NE a.Manual ❑ b.Mechanical� Are,the bars adequately screening debris? 0', ❑ ❑ Is the screen free of excessive debris? 10 ❑. ❑ ❑ Is disposal of screening in compliance?' 0, ❑ ❑ Is the unit in good condition? 0 0 ❑ ❑ Comment: Screenings are placed on old drvino beds: the underdrains of which are still connected to the plant's influent line. The screenings are then hauled to landfill. Aeration Basins Yes No NA NE, Mode of operation Ext. Air Type of aeration system Diffused Is the basin free. of dead spots? N ❑. ❑ 11 Are.surface aerators and mixers operaflonai? ❑ ❑ S ❑ Are the diffusers operational? E ❑ ❑ ❑ Page# 6 P&MIL' NC0020931i owrver.Facillty: AwrwillOWYM. 0811512019 Aerarton Basins Yes No NA N Is the foam the proper bolCirfor, the treatment process! IN: IJ IJ 13 Does the foam rover less than 25% of the basin's surfacel A [Ji 1:1 0 It the DO, level acceptable? El 01 El 0 is the DO level 8cceptabIe?(1.'0 to 3.Q higg) 11 0 El M Comment: test it durinct the inspection. Secondary Clarifier Is the clarifier free of black and',odorous wastewaters' is the site free -of excessive buildup pf'so.lids in q.qRter-WqII of circular clarifier? Are weiro. tevel? is We sR@,f.r6e(jfweir blockage? Is the site free of evidence dishort-circuiting? Is scum removal adeq uate? Is the site f a floof free of excessiv ling slUdg.e? is the dekVO unit operational? Is the return rate accaptable,(IoW turbulence)?, Is the: overflow clear of eXcessive.splidsApin flor:7 Is the, sludge blanW level accelptable'?,(ApproAmately YA " of the sidewall depth). Comment, Please refer to the inspection summary section: P . U s-RAS-WAS Are pumps in. place? ace? Ate. pumps operational? Aregnare adequate spare partsend supplies on'site? Yes No NA NE' M' El -11 0 M, El E] 11 IN El El 11 E-1 91111 E1:W El 11 in 0 1113 It El El 11 a El [� P �M El Q El 0 0 El [1 Yes No NA NE ME]: El El El Comnient Please indicate what spare parts/pumps are kept on hand in your response letter., Disinfection - UV Are.extra'UV bulbs. -available an sitel Are: UV bulbs clean? is UV intensity adequate? Is transmittance at or above designed levei? is there a backup system onsitel Yes No NA NE Page# a I 3 Permit: NC0020931: owner.Fecllity: PoormileWWTP Inepacaen:Dater 06/15/2019 InspeWouType: Compliancet;valUallen Disinfection - UV Yes No NA NE Is effluentclear and free of solids? ❑ [] Comment: Please indicate in your response letter the,transmittance level and what the backu disinfection systemisc Flow Measurement - Effluent Yes No NA -NE 9 Is flow;meter used for reporting? ❑: ❑ El Is flbw' meter calibrated annually? A 0 ❑ Is the flow meter operational? 0 ❑ ❑ (If units,are,separated) Does the chart recorder match the flow meter? ❑'; ❑ Comment: Meter last calibrated in November 20 6' Effluent Pipe Is iightof way to the qutfall proparly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (d'dfuser pipes are required); are they operatin$'properly? Comment- None. Operations & Maintenance Is the plant generaily'cleanwith acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRTi Settleable Solids, pH, DO, Sludge Judge and other that are applicable? Comment: Please .refer to the inspection.summary section Standby: Power Is automaticallyactivated standby power available? Is the generator tested by interrupting pdmary 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 monitorerh Comment,. Please refer to the inspection summary section. Yes No NA NE' 0❑❑❑ ❑❑ ■o Yes No NA NE ❑' ❑ El Yes No NA NE' ■❑'!❑❑ ❑ ❑ ❑ ■ M ❑ ❑ 11 ❑E❑❑ ■❑ El El 'El ❑❑■ E ❑ ❑ El Page# 10