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HomeMy WebLinkAboutNC0065242_Compliance Evaluation Inspection_20230411ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director CERTIFIED MAIL #: 7020 3160 0000 3283 0366 RETURN RECEIPT REQUESTED; The Honorable Roy Dyer, Mayor Town of Grover Post Office Box 189 Grover, NC 28073-0189 SUBJECT: Notice of Violation Compliance Evaluation Inspection Town of Grover WWTP NPDES Permit No. NCO065242 Cleveland County Tracking #: NOV-2023-PC-0134 Dear Mayor Dyer: NORTH CAROLINA Environmental Quality April 11, 2023 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on March 29, 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. This report is being issued as a Notice of Violation (NOV) due to the following: - The permit renewal application was not submitted no later than 180 days prior to the permit expiration date; - No dechlorination tablets were observed in the tablet dechlorinator; The effluent total residual chlorine value exceeded the permit effluent limit. Please be advised that the failures to both provide proper operation and maintenance and properly renew the NPDES Permit are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1. as discussed further in the Permit, Disinfection -Tablet and Dechlorination Sections of 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 26115 704.663.1699 It is requested that a written response be submitted to this Office by May 2, 2023, detailing the actions taken to address the above -noted violations and the additional issues discussed in the Influent Sampling, Laboratory, Bar Screen and Standby Power Sections in the attached report. 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. Sincerely, D/ocuSiiggnedd by: WPiY YJEGG A69696DWCC3437... for Andrew H. Pitner, P.G Acting Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Enclosure: Inspection Report Cc: NPDES Program Files - Laserfiche D Q� 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 26115 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 NCO065242 111 121 23/03/29 I17 18 I C I 19 LT I 20L] 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 2.0 70LJ 71 I„ I 72 L.71 74 79 I I I I 80 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) 09:50AM 23/03/29 18/09/01 Grover WWTP 1229 Bethlehem Church Rd Exit Time/Date Permit Expiration Date Grover NC 28073 12:15PM 23/03/29 23/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Charles Mark McDaniel//704-937-9986 / Isaac David McDaniel//704-692-0111 / Roy Dyer/Mayor/704-937-9986 / Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Roy Dyer,PO Box 189 Grover NC 280730189//704-937-9986/ Yes 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/ Be& 4/11/2023 E�D`,','�96D90=437 ... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO065242 I11 12I 23/03/29 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Permit Section cont'd: The Town has committed to cease the NPDES discharge and connect all wastewater to the new City of Kings Mountain WWTP that is currently in the process of being designed and permitted. Influent Sampling Section cont'd: The ORC should perform (and document) sampler aliquot verifications twice per month to ensure a minimum of 100 ml. aliquots are being collected per sample. In addition, the ORC must ensure that the maximum flow between the composited samples does not exceed 1/24 of the total daily expected flow. The sample container did not appear to be of sufficient size (volume) based on the sample frequency and volume. The ORC must ensure that the sample container is of sufficient size (volume) to store all samples collected during a 24-hour period with no over -filling. In addition, the Permittee should obtain a bigger refrigerator to allow for the usage of the larger sample container. Page# Permit: NCO065242 Owner -Facility: Grover WWTP Inspection Date: 03/29/2023 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 ❑ 0 ❑ ❑ application? Is the facility as described in the permit? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ 0 ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The subject permit expires on 8/31/2023; however, the Town has not submitted a permit renewal application to date. Please be advised that the subject Permit requires the submittal of a permit renewal application no later than 180 days prior to the expiration date f Permit Condition Reference: Part II, Section B (10) Expiration of Permit . The last compliance evaluation inspection at this facility was performed by DWR staff on 9/10/2020. See "Summary" Section for additional comments. Record Keeping 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Page# 3 Permit: NCO065242 Inspection Date: 03/29/2023 Record Keeping Owner -Facility: Grover WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The records reviewed durinq the inspection were orqanized and well maintained Discharge Monitoring Reports (eDMRs) were reviewed from March 2022 through February 2023. Effluent monthly average ammonia violations were reported in May 2022, September 2022 and October 2022. The Division has separately addressed these limit violations through the issuances of civil penalty assessments. The ORC must ensure that the Town has copies of all monitoring data (contracted laboratory analyses, chain of custody forms, etc.) for a period of three years as required by the Permit. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? 0 ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 ❑ ❑ 0 ❑ degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ 0 ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ■ ❑ Comment: On -site effluent analyses (PH, temperature, total residual chlorine) are performed under the Town's field laboratory certification #5497. Water Tech Labs (Certification #50) has also been contracted to perform all permit -required analyses (except field). The Town's total residual chlorine (TRC) meter had not been calibrated/verified annually (in 2022) as required by SM 4500 Cl -2011 and NC Wastewater/Groundwater Laboratory Certification Branch Approved Procedure for the Analysis of Total Residual Chlorine. The TRC meter must be calibrated/verified immediately and subsequently calibrated/verified every twelve (12) months. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected above side streams? 0 ❑ ❑ ❑ Is proper volume collected? M ❑ ❑ ❑ Is the tubing clean? ❑ 0 ❑ ❑ # 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? 0 ❑ ❑ ❑ Comment: The subiect permit requires influent BOD and TSS composite samples. The ORC was not sampling at the time of the inspection; however, the tubing will need to be replaced within the near future. The three thermometers inside the sampler refrigerator were not operational/measuring temperatures properly and need to be discarded. See "Summary" Section for additional comments. Page# 4 Permit: NCO065242 Inspection Date: 03/29/2023 Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Owner -Facility: Grover WWTP Inspection Type: Compliance Evaluation 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)? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: The subject permit requires composite and qrab effluent samples. The ORC should perform (and document) sampler aliquot verifications twice per month to ensure a minimum of 100 ml. aliquots are being collected per sample. In addition, the ORC must ensure that the maximum flow between the composited samples does not exceed 1/24 of the total daily expected flow. 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 facility was not properly treatinq wastewater at the time of the inspection as discussed further in the Disinfection -Tablet and Dechlorination Sections. 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 & Maintenancel. The ORC and staff need to initiate a consistent process control program to ensure the wastewater treatment plant is adequately treating wastewater at all times. All process control measurements (dissolved oxygen, pH, settleability tests, etc.) must also be documented and maintained on -site. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? ■ ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Page# 5 Permit: NCO065242 Inspection Date: 03/29/2023 Owner -Facility: Grover WWTP Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE Comment: The facility is equipped with a coarse bar screen and therefore, only the larger debris was being removed. Smaller debris was observed in the aeration basin and secondary clarifier. The ORC and staff should either increase the manual removal of the smaller debris or install a finer screening system. Screenings are placed in the dewatered sludge dumpster for disposal at a permitted I--.JF:I I Aeration Basins Mode of operation Type of aeration system Is the basin free of dead spots? Are surface aerators and mixers operational? 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/1) Yes No NA NE Ext. Air Diffused ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Comment: A new blower was installed last year to provide more oxvqen in the aeration basin to reduce effluent BOD and ammonia levels especially during the Spring/Summer Seasons. The belt for the new blower and motor unit appeared to be loose. The belt should be evaluated and appropriately tightened. 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 scum/floatable debris has to be manually removed by the wastewater staff. Page# 6 Permit: NCO065242 Owner -Facility: Inspection Date: 03/29/2023 Inspection Type: Grover WWTP Compliance Evaluation Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? 0 ❑ ❑ ❑ Are the tablets the proper size and type? 0 ❑ ❑ ❑ Number of tubes in use? 2 Is the level of chlorine residual acceptable? ❑ 0 ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? 0 ❑ ❑ ❑ Comment: No dechlorination tablets were observed in the tablet dechlorinator and the effluent total residual chlorine level exceeded the effluent Dermit limit. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ ❑ ❑ ❑ 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: The flow meter is calibrated annually and was last calibrated on 3/15/2023 by Experienced Water Solutions, Inc. De -chlorination Yes No NA NE Type of system ? Tablet 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 ❑ ❑ ❑ Comment: Are the tablets the proper size and type? ❑ ❑ ❑ Are tablet de -chlorinators operational? ❑ ❑ ❑ Number of tubes in use? 0 Comment: As discussed in the previous Disinfection -Tablet Section, no dechlorination tablets were observed in the tablet dechlorinator. Note: Dechlorination tablets were placed in the treatment unit by the on -site staff once the issue was observed. 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? ❑ ❑ 0 ❑ Page# 7 Permit: NC0065242 Inspection Date: 03/29/2023 Effluent Pipe Owner -Facility: Grover WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The effluent appeared slightly turbid with trace suspended solids and no foam. The receiving stream did not appear to be negatively impacted. 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? Comment: Drying Beds Is there adequate drying bed space? Is the sludge distribution on drying beds appropriate? Are the drying beds free of vegetation? # Is the site free of dry sludge remaining in beds? Is the site free of stockpiled sludge? Is the filtrate from sludge drying beds returned to the front of the plant? # Is the sludge disposed of through county landfill? # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: The facility is equipped with two sludge drying beds (both in -use). Dewatered sludge is placed into a dumpster (under cover) and disposed at a permitted landfill by a contracted company. Standby Power Yes No NA NE Is automatically activated standby power available? ❑ 0 ❑ ❑ Is the generator tested by interrupting primary power source? ■ ❑ ❑ ❑ Is the generator tested under load? ■ ❑ ❑ ❑ Was generator tested & operational during the inspection? 0 ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? 0 ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up ■ ❑ ❑ ❑ power? Is the generator fuel level monitored? ■ ❑ ❑ ❑ Page# 8 Permit: NC0065242 Inspection Date: 03/29/2023 Standby Power Owner -Facility: Grover WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The backup generator has to be manually activated. The switch pear system needs to be repaired and should be reDaired within the near future. The aenerator is automatically tested on a weekly basis. Page#