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HomeMy WebLinkAboutNC0075027_NOI_NOV2018PC0227_Response_20180809Bradley FlyntBradley Flynt Cainsway WWTP ORC CC Ron Boone Jenny Graznak 8467 Southard Rd. Stokesdale, NC 27357 08/09/2018 Sherri V. Knight, P.E. Regional Supervisor Water Quality Regional Operations Division of Water Resources 450 West Hanes Mill Road Winston-Salem, NC 27105 Dear Sherri V. Knight, P.E.: This letter is in response to the Compliance Evaluation conducted by Ron Boone on June 5, 2018. He found that the plant has gotten into poor and dilapidated condition due to corrosion which is an ongoing problem with a lot of privately owned package plants. I have spoken to the Homeowner's association President about this situation and he is willing to do whatever they can afford to start getting the plant in better shape. I immediately provided a piece of schedule 80 PVC to replace the leaking feed line to the aeration so corrosion will not be an issue with that line in the, future. The missing bar screen is in the process of being evaluated for replacement. The original design is too dangerous to be replaced like kind and we are in the talks with a contractor to build a stainless steel bar screen in the influent splitter box or in the manhole that feeds the influent pump station/EQ tank but is still easier to access than the EQ tank area. The floating solids were due to the final clarifier sludge collector mechanism breaking down and had just been repaired before the inspection so the old sludge that was trapped in the bottom of the final was be introduced back into the plant for treatment and made the clarifier cloudy. I ., Sherri V. Knight, P.E. 08/09/2018 Page 2 started wasting thesesolids out and was able to clear the final up which couldn't be done before the mechanism was fixed. The composite sampler was reading 79.8 degrees Celsius on the LED display which is not correct. I have installed a refrigerator thermometer to monitor temp and will see if display temp can be fixed. Daryl Cain, Homeowner Association President, has been notified about the crushing of the declor box will personally dig It up and fix himself within 30,days of this letter. Sludge pumping records has been requested from the Homeowner's secretary and will be on site soon and when I get them I will email a copy to Mr. Boone. If I can be of further assistance please feel free to contact me at (336)430-6262 Sincerely, Bradley Flynt Cainsway WWTP ORC CC Ron Boone Jenny Graznak - Water Resources Environmental Quality CERTIFIED MAIL 7015-0640.0005-8164.2357 RETURN RECEIPT REQUESTED July 10, 2018 Cains Way Homeowners Association Attn: Daryl Cain, Owner 2350 Huffine Mill Road McLeansville, NC 27301 Subject; Compliance Evaluation Inspection & Notice of Violation NOV Tracking #: NOV-2018-PC-0227 , Permittee: Cains Way Homeowners Association Facility: Cains Way Mobile Home Park NPDES Permit#: NCO075027 Forsyth County Dear Mr. Alphin: ROY COOPER Governor NUCHAEL S. REGAN Secretary LINDA CULPEPPER Interim Director Ron Boone, of the Winston-Salem Regional Office (WSRO) of the NC Division of Water Resources (DWR or the Division), conducted a compliance evaluation inspection (CEI) of the Cain's Way Mobile Home Park Wastewater Treatment Plant (WWTP) on June 5, 2018. The assistance and cooperation of Mr. Bradley Flynt, Operator in Responsible Charge (ORC), was greatly appreciated. An inspection checklist is attached for your records and inspection findings are summarized below. . , I. Permit The NPDES permit became effective April 1, 2017 and expires February 28, 2022. A copy of the permit was NOT available on site during the inspection. Please ensure you provide one to Mr. Flynt to keep on site at all times. II. Self -Monitoring Program A review of the monthly discharge monitoring reports (DMR) for the period June 2013 through June 2018 showed that the facility experienced 16 violations.during that time frame, all of which have already been addressed via separate correspondence. Flow Measurement Flow is measured using an ISCO 4230 bubbler flow meter that was last calibrated November 215t, 2017. The meter appeared to be functioning properly during the inspection according to Mr. Boone. IV. Operations and Maintenance Mr. Boone reports that the WWTP is in fair to poor condition. Many components throughout the treatment process are severely corroded and/or dilapidated. In fact, the pipe that conveys wastewater into the flow splitter box from the influent !/'Nothing Compares =�. State of North Carolina I Environmental Quality 450 W. Hanes Mill Road, Suite 300, Winston-Salem, North Carolina 27105 Phone: 336-776-98001 FAX: 336-776-9797 E pump station began leaking during the inspection due to severe corrosion. Cain's Way must consider doing some major repair work to this facility. Once corrosion gains a foothold and goes unchecked, it can spread rather quickly and eventually cause catastrophic failure. Plant condition is highly indicative of the amount of money and time invested into the proper operation and maintenance of the facility over the years. If nothing is done to address the dilapidation of the plant, we believe catastrophic failure is imminent, requiring significant investment from which to recover. V. Facility Site Review All components of this 0.04 million -gallon -per -day (MGD) facility appeared to be functional during the inspection, but Mr. Boone did observe the following additional issues: • The bar screen essentially came up missing at some time in the recent past. Mr. Flynt stated that it may have fallen into the influent pump tank. The bar screen must be replaced as soon as possible. It is a permitted part of the plant and allowing these solids to enter the rest of the plant can degrade the plaint's overall treatment capacity. • The dissolved oxygen (DO) level in the aeration basin was only 0.48 milligrams per liter (mg/1) during the inspection. The desired range is 1.0 to 3.0 mg/1. It is questionable whether the plant can sufficiently treat the waste load with this DO concentration. The planes aeration system may be insufficient. Please address this issue in your written response to this letter. • There were some floating solids in the clarifier, which were slowly making their way over the weir. This apparently hasn't affected effluent quality but is indicative of older sludge in the clarifier. It may be prudent to waste more sludge. • The composite sampler's temperature reading was 79.8 degrees Celsius. Mr. Flynt stated that the reading is inaccurate and that the temperature inside the sampler is, in fact, much lower and within proper range. He indicated that the device that reads the temperature has failed. This must be repaired immediately so the operator knows that samples are being stored at the proper temperature. It was noted in the 2016 inspection report that the sampler's outer casing was cracked. Mr. Boone didn't notice if this is still the case, but it could also be why the temperature is so high. Please indicate in your response letter whether a new sampler was acquired to replace the one with a crack in it noted in the 2016 inspection, as well as what you intend to do to repair it now. • Composite samples are not flow proportional, as required by the permit, but WSRO granted Cain's Way permission to use constant time/constant volume sampling by letter dated May 11, 2015. Please ensure Mr. Flynt has a legible copy of this letter on site and available for inspection at all times. • The dechlorination unit is being crushed by the soil it is buried in. The unit is still functional at this point but it may at some point in the future become inoperable. You should consider reinstalling the unit properly, i.e. in a container of some type, like a concrete vault, which provides protective structural support. • As stated above, the severe corrosion throughout the plant is seriously concerning. VI. Records/Reports According to existing records, all required effluent monitoring has been performed in accordance with the parameters and frequencies required by the NPDES permit. Chains of custody, operations and maintenance logs, operator's visitation logs, etc., were all available for inspection. Sludge records need to be improved. Not all sludge pumping records were available during the inspection. Please VII. Effluent/Receivina Waters Pin floc was flowing over the clarifier weir'troughs at the time of the inspection but none was seen in the effluent. Effluent flow was clear and free of foam and solids during the inspection. Upstream and downstream sampling points were visited and are clearly accessible. The plant discharges to Ader Creek, which is currently classified as Class C waters and is located in the Roanoke river basin. Please work with Mr. Flynt to correct the deficiencies noted above in paragraphs 1 and 4 through 7.Overall, the plant must be better maintained and more should be invested in the plant's proper upkeep. Please reply in writing to this letter within 30 business days of receiving it. You should also be able to provide the requested sludge pumping/hauling records. Your written reply should address each of the noted deficiencies and provide a corrective action plan along with an implementation/completion schedule to remediate them. Please be aware that violations of your NPDES permit, or the NC statutes and regulations under which it is promulgated, are subject to fines of up to $25,000 per day, per violation, as set forth in NC General Statute (NCGS) 143-215.6A, Enforcement Procedures, Civil Penalties. If we do NOT receive your written reply within 30 business days of your receipt of this notice, we may draft an enforcement case for the noted deficiencies/violations. If you have any questions regarding the inspection or this report, please contact Ron Boone or me at (336) 776-9800 Sincerely, 4Sherri V. Knight, P.E. /Regional Supervisor Water Quality Regional Operations Division of Water Resources Attachments: BIMS Inspection Report cc: Central Files AW NPDES Unit y J CERTIFIED MAILO REGEIF I Domestic Mail Only For delivery information, visit our website at www.usps.con, ". � a _p Certified Mall Fee ra $ Services SFees fcMckmc ediMasppmpab) ❑ReNn Receipt 0+artlwM/1 { O ❑Pos Reium Rxeio+(aecimdA i tmark [rl4 r 'i Mau Raa�cad omiwy i Hare ❑ra�rc Sgna:we Reeuue0 { p Postage r $ —0 Total Postage and $ Ig Daryl Cain un seat re Cains Way Homeowners Assn m s eefeneip o. 2350 Huffine Mill Road r.c:: i;a«i+ McLeansville, NC 27301 ■ Complete items 1, 2, and 3. •. Print your name and address on the reverse so that we can return the card to you. ■=Attach this card to the back of the mailpiece, or on the front if space permits. _ Daryl Cain Cains Way Homeowners Assn 2350 Huffine Mill Road McLeansville, NC 27301 oU-aors— 19C— A. nature �eI ^r%Aoerit Received by (P kited N -.. i.. h Bill �C l� / "j� la D. Is delivery address different from Rem 11 ❑ Yee If YES, enter delivery address below: ❑ No ice Priority II Inl'I IIII (II I II II II III i I I I II II' II III'I I III3. D ❑ Adult SSignature gnat reeRestricted Delivery ❑ Re4 s md Mal Rest"" 9590 9402 2546 6306 9696 44 Certified Mail® ❑ Certified Mal Restricted Delivery Return for Return n.. ❑ Collect on Delivery Collect on Delivery Restricted Deiivary M ❑ Signature Confirm h* 9 §� ems.—__��a-s_ _ 2, ,' ❑Signature Contirt�t ron 7015 6640 0005 8164 2357 emnCted Delivery Restricted Deliv PS Form 3811, July 2015 PSN 7530-02-000-9053 Domestic Refurn Receipt United States Environmental Protection Agency Form Approved. EPA Washington, D.C. 20480 OMB No. 2040-0057 Water Compliance Inspection Report Approval expires 8-31-96 Section A: National Data System Coding (i.e., PCS) Transaction Code NPDES yrlmo/day Inspection Type Inspector Fac Type 1 IN I 2 15 I 3 I N00075027 I11 12 18,06/05 17 18 I C I 19 (!-I 20 LJ 21111111 11111111 1111111111111111111111111111 1�6 Inspection Work Days Facility Self -Monitoring Evaluation Rating 31 CA Reserved 72 L.J 671 I 70ILJ 71LJ 73I74 75 80 Section B: FacilityData 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) 11:24AM 18/06/05 17/04/01 Conaway Mobile Home Park Exit TimelDate Permit Expiration Date Pinehall Rd 12:24PM 18/06/05 22/02/28 Walkertown NC 27051 Name(s) of Onsite Representative(s)frifles(s)/Phone and Fax Number(s) Other Facility Data /// Bradley Todd FtynUORC/336433-7262/ Name, Address of Responsible OfficiaVTitle/Phone and Fax Number Contacted Bradley Todd Ftynt,8467 Southerard Rd Stokesdale NC 27357//336433-7262/ No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit E Flow Measurement Operations & Maintenance Records/Reports Self -Monitoring Program E Sludge Handling Disposal Facility Site Review EfguenUReceiving 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 WO//336-776-9690/ J Signature of Management O A Reviewer Agency/Office/Phone and Fax Numbers // Dale EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# J NPDES yr/molday Inspection Type 31 NCo075027 I11 12I 18/06/05 117 18 I C 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Please refer to the attached inspection summary letter. Page# Permit: NC0075D27 Inspection Date: 06/05/2018 Owner -Facility: Cainsway Mobile Home Park Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Are records kept and maintained as required by the permit? ❑ 0 ❑ ❑ Is all required information readily available, complete and current? ❑ E ❑ ❑ Are all records maintained for 3 years (lab. reg. required 5 years)? ❑ E ❑ ❑ Are analytical results consistent with data reported on DMRs? E ❑ ❑ ❑ Is the chain -of -custody complete? 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 ❑ ❑ ❑ Has the facility submitted its annual compliance report to users and DWQ? ❑ ❑ 0 ❑ (If the facility is = or> 5 MGD permitted flow) Do they operate 24/7 with a certified operator ❑ N ❑ ❑ on each shift? Is the ORC visitation log available and current? 0 ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? E ❑ ❑ ❑ 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? ❑ E ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ 0 ❑ Comment: Permit not on site Sludge removal records incomplete. Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new ❑ ❑ E ❑ 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? -E ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? E ❑ ❑ ❑ Comment: Bar screen is no longer installed It is believed to have fallen into the influent pump tank. 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? ❑ ❑ ❑ Page# 3 Permit NCO075027 Inspection Date: 08/05/2018 Laboratory Owner -Facility: Coinsway Mobile Home Park Inspection Type: Compliance Evaluation Yes No NA NE # Is the facility using a contract lab? E ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ E ❑ ❑ Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ❑ E Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ❑ i Comment: The composite sampler must be fixed. Temperature indicator read 79.8 degrees Celsius during the inspection. Mr. Flynt said that this isn't correct and the temperature indicator/reader must be replaced. It must be replaced so we know that samples are being refrigerated to the proper temperature. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? ❑ E ❑ ❑ Is sample collected below all treatment units? E ❑ ❑ ❑ Is proper volume collected? _ ❑ ❑ ❑ Is the tubing clean? N ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees ❑ 0 ❑ ❑ Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type E ❑ ❑ ❑ representative)? Comment: The composite sampler must be fixed. Temperature indicator read 79.8 decrees Celsius during the inspection. Mr. Flynt said that this isn't correct and the temperature indicator/reader must be replaced. It must be replaced so we know that samples are being refrigerated to the proper temperature. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and E ❑ ❑ ❑ sampling location)? Comment: None Pump Station - Influent Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Inaudible and visual alarm available and operational? Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ E • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ E ❑ ❑ ■ ❑ ❑ ❑ Page# 4 t_ Permit: MCC075027 Inspection Date: 0810512018 Pump Station - Influent Owner - Facility: Cainsway Mobile Home Park Inspection Type: Compliance Evaluation Comment: Cannot see into the tank to assess amount of grease. 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 Yes No NA NE Ext. Air Diffused ❑ ❑ ❑ ❑ . ❑ E ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ Comment: Mixed liquor was dark with very litte foa and dissolved oxygen was only 0.48 mg/I. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? _ ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑/ Is the site free of weir blockage? E ❑ ❑ ❑ Is the site free of evidence of short-circuiting? ❑ ❑ ❑ Is scum removal adequate? E ❑ ❑ ❑ Is the site free of excessive floating sludge? E ❑ ❑ ❑ Is the drive unit operational? S ❑ ❑ ❑ Isthe return rate acceptable (low turbulence)? ❑ 0 ❑ ❑ Is the overflow clear of excessive solids/pin Floc? ❑ N ❑ ❑ Is the sludge blanket level acceptable? (Approximately Y. of the sidewall depth) ❑ ❑ ❑ Comment: There are some floating solids More sludge may need to be returned or wasted Pumps-RAS-WAS Yes No NA NE Are pumps in place? E ❑ ❑ ❑ Are pumps operational? E ❑ ❑ ❑ Are there adequate spare parts and supplies on site? 0 ❑ ❑ ❑ Comment: None Page# 5 Permit: NG0075027 Owner -Facility: Cainsway Mobile Home Park Inspection Date: 06/05/2018 Inspection Type: compliance Evaluation - Pumps-RAS-WAS Yes No NA NE Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? E ❑ ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? N ❑ ❑ ❑ ' (If units are separated) Does the chart recorder match the flow meter? E ❑ ❑ ❑ Comment: None Disinfection -Tablet Yes No NA NE Are tablet chlorinators operational? E ❑ ❑ ❑ Are the tablets the proper size and type?� E ❑ ❑ ❑ Number of tubes in use? 4 Is the level of chlorine residual acceptable? ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? E ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ E Comment: None De -chlorination Yes No NA NE Type of system ? Tablet Is the feed ratio proportional to chlorine amount (1 to 1)? ❑ ❑ ❑ E Is storage appropriate for cylinders? 0 ❑ ❑ ❑ # Is de -chlorination substance stored away from chlorine containers? 0 ❑ ❑ ❑ Are the tablets the proper size and type? E ❑ ❑ ❑ Comment: None Are tablet de -chlorinators operational? ❑ ❑ ❑ Number of tubes in use? 4 Comment: Dechlorinator is being crushed by soil it is buried in. It should be excavated and installed Properly inside some sort of protective container such as a concrete vault. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? E ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? E ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ S ❑ Page# 6 � z 4 Permit NCO075027 Inspection Date: 06/0512018 Effluent Pipe Comment: None 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: None Owner -Facility: Cainsway Mobile Home Park Inspection Type: Compliance Evaluation Operations & Maintenance Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: None Yes No NA NE Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ Page# 7