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Home My WebLink AboutNC0020214_NOD2023PC0211_20230801 August 1, 2023 Daniel Manring Tuckaseigee Water and Sewer Authority Email: dmanring@twsanc.us SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2023-PC-0211 Permit No. NC0020214 TWSA WWTP#2 Jackson County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the TWSA WWTP#2 on June 26, 2023. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0020214. 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 Asheville Regional Office. The following deficiency(s) was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Standby Power The generator is only connected to the pump station on site at the facility. It is recommended that electrical upgrades be conducted at the facility in order to connect the entirety of the plant to back-up power. _________________________________________________________________________________________________________________________________________________________________________ Secondary Clarifier The skimmer arm on the secondary clarifier was broken at the time of the inspection. It is recommended that this be repaired or replaced as soon as possible. Due to the age of the plant, there is corrosion occuring in the discharge trough of the clarifier, which could lead to holes allowing for MLSS to seep out. _________________________________________________________________________________________________________________________________________________________________________ Aerobic Digester There was an excessive amount of floating debris in the digester, due to inadequate bar screens and grit removal components in the facility. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 In addition, the issues below must also be addressed: Compliance Issue(s): Inspection Area Description of Compliance Issue _________________________________________________________________________________________________________________________________________________________________________ Grit Removal The grit removal unit is not operational and is causing excess grit to be present throughout the plant, causing wear on the pumps. It was noted in the 2018 CEI report that the components should be evaluated for repair or replacement. Since that time, upgrades have not been evaluated. _________________________________________________________________________________________________________________________________________________________________________ Bar Screen The bar screen is not adequately screening debris and it is recommended that a smaller width screen be installed. _________________________________________________________________________________________________________________________________________________________________________ Aeration Basins Only one of the two blowers on site functions properly, and it needs to run continuously in order to maintain the plant. Remedial actions should have already been taken to correct this problem and prevent further occurrences in the future. The Division of Water Resources may pursue enforcement action for this and any additional violations of State law. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Mara Chamlee with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4500. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Ben Henson (ORC) DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 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 N 52 NC0020214 23/06/26 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) TWSA WWTP#2 114 Hometown Pl Rd Sylva NC 28779 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 09:30AM 23/06/26 23/05/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Ben L Henson/ORC/828-586-5189/ Other Facility Data 11:30AM 23/06/26 27/10/31 Name, Address of Responsible Official/Title/Phone and Fax Number Joe Cline,1246 W Main St Sylva NC 28779//828-586-5189/Contacted No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters 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 Lauren E Armeni DWR/ARO WQ/828-296-4500/ Mara G Chamlee DWR/ARO WQ/828-296-4500/ Rachel Rose DWR/ARO WQ/828-296-4500/ 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#1 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 8/1/2023 8/1/2023 8/1/2023 NPDES yr/mo/day 23/06/26 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mara Chamlee, Lauren Armeni, and Rachel Rose with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of the TWSA #2 WWTP on June 26, 2023. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0020214. Mr. Ben Henson (ORC) was present and assisted with the inspection. The following items were noted during the inspection: 1) Operations & Maintenance - Overall, this facility is very old and experiencing many issues due to aging and wear. There was significant corrosion under the grating that is accessible at the top of the aeration basins and clarifier units. This represents a saftey hazard and it is recommended that the grating be replaced to address safety concerns. 2) Bar Screens - The bar screen is not adequately screening debris. This was noted in the 2018 CEI Report and has not been addressed. Additionally, the bar screen is not easily accessible as it requires climbing down into a confined space, and this poses a safety concern. Mr. Henson noted that they have applied for an ATC to install a new bar screen. 3) Aeration Basins - Only one of the two blowers on site functions properly, and it has to run continuously in order to maintain the plant. 4) Secondary Clarifier - The sludge blanket was undesirably high at the time of the inspection. The sludge judge showed 6 feet of solids out of 12 feet. Some floating solids were visible in the clarifier. The skimmer arm on the secondary clarifier was broken at the time of the inspection. 5) Aerobic Digester - Due to only having the electrical capacity to operate one of the two blowers on site, the aerobic digester is used as a facultative digester. 6) Standby Power - The generator is only connected to the pump station on site at the facility, electrical upgrades are needed. This was also mentioned in the 2018 inspection report. The following compliance issues were noted during the inspection: 1) Grit Removal - The grit removal unit is not operational and is causing excess grit to be present throughout the plant, causing wear on the pumps. It was noted in the 2018 CEI report that the components should be evaluated for repair or replacement. Since that time, upgrades have not been evaluated. 2) Bar Screen - The bar screen is not adequately screening debris and it is recommended that a smaller width screen be installed. 3) Aeration Basins - Only one of the two blowers on site functions properly, and it needs to be run continuously in order to maintain the plant. The following deficiencies were noted during the inspection: 1) Secondary Clarifier - The skimmer arm on the secondary clarifier was broken at the time of the inspection. It is recommended that this be repaired or replaced as soon as possible. Due to the age of the plant, there is corrosion occuring in the discharge trough of the clarifier, which could lead to holes allowing for MLSS to seep out. 2) Aerobic Digester - There was an excessive amount of floating debris in the digester, due to NC0020214 17 (Cont.) Page#2 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 Permit:NC0020214 Inspection Date:06/26/2023 Owner - Facility: Inspection Type: TWSA WWTP#2 Compliance Evaluation inadequate bar screens and grit removal components in the facility. 3) Standby Power - The generator is only connected to the pump station on site at the facility. It is recommended that electrical upgrades be conducted at the facility in order to connect the entirety of the plant to back-up power. Page#3 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 Permit:NC0020214 Inspection Date:06/26/2023 Owner - Facility: Inspection Type: TWSA WWTP#2 Compliance Evaluation Permit Yes No NA NE (If the present permit expires in 6 months or less). Has the permittee submitted a new application? Is the facility as described in the permit? # Are there any special conditions for the permit? Is access to the plant site restricted to the general public? Is the inspector granted access to all areas for inspection? The permit was renewed in May 2023.Comment: Operations & Maintenance Yes No NA NE 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? Process controls analyzed include settleability, pH, DO, and MLSS. The grating is rusting and there is significant corrosion throughout the plant. See summary for details. Comment: Record Keeping Yes No NA NE 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? Page#4 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 Permit:NC0020214 Inspection Date:06/26/2023 Owner - Facility: Inspection Type: TWSA WWTP#2 Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? Comment: Pump Station - Influent Yes No NA NE 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? Is audible and visual alarm available and operational? Mr. Henson indicated that they use a transducer to read flow levels and that SCADA is not available at this facility. He also stated that during periods of heavy flow, the influent can be diverted to TWSA #1, but the heavy flows can overwhelm the downstream pump station. Comment: 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? Is disposal of screening in compliance? Is the unit in good condition? The bar screen was orignially installed as mechanically operated, however it has not functioned properly since installment. Mr. Henson inidcated that TWSA had sent an AtoC application to the DEQ to install a new bar screen. It was noted in the 2018 report as well that a new bar screen should be installed. See summary for details. Comment: Grit Removal Yes No NA NE Type of grit removal a.Manual b.Mechanical Is the grit free of excessive organic matter? Page#5 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 Permit:NC0020214 Inspection Date:06/26/2023 Owner - Facility: Inspection Type: TWSA WWTP#2 Compliance Evaluation Grit Removal Yes No NA NE Is the grit free of excessive odor? # Is disposal of grit in compliance? The grit removal has not been properly operational since it was installed in 1992. See summary for details. Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Fixed 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/l) Settleability was 65% at the time of the inspection. Mr. Henson indicated that only one of the two blowers functions properly and that it must be running continuously in order to maintain DO levels. Mr. Henson said that DO levels are usually around 0.5 mg/L. See summary for details. Comment: 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? 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 ¼ of the sidewall depth) Page#6 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 Permit:NC0020214 Inspection Date:06/26/2023 Owner - Facility: Inspection Type: TWSA WWTP#2 Compliance Evaluation Secondary Clarifier Yes No NA NE At the time of the inspection, the sludge judge showed the sludge blanket level to be 6ft. out of 12 ft. There were some floating solids visible in the clarifier. Mr. Henson indicated that the skimmer was broken, therefore the scum removal was not adequate. He also noted that the clarifier is wasted to the digester when the MLSS is over 2500 mg/L. It was observed that there is corrosion in the discharge trough, which could cause holes for MLSS to seep out. See summary for details. Comment: Aerobic Digester Yes No NA NE 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? There was an excessive amount of floating debris present in the digester. The digester is not being aerated, and Mr. Henson noted that this is because all of the power from the one functional blower is needed for the aeration basins. Therefore, it is being used as a facultative digester. The digester is mixed in preparation to haul off solids to TWSA #1, which occurs 2-3 times per week. The decant returns to the influent. See summary for details. Comment: Pumps-RAS-WAS Yes No NA NE Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Comment: Disinfection-Gas Yes No NA NE Are cylinders secured adequately? Are cylinders protected from direct sunlight? Is there adequate reserve supply of disinfectant? Is the level of chlorine residual acceptable? Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de-chlorination? Does the Stationary Source have more than 2500 lbs of Chlorine (CAS No. 7782-50-5)? If yes, then is there a Risk Management Plan on site? If yes, then what is the EPA twelve digit ID Number? (1000-____-____)n/a If yes, then when was the RMP last updated? Page#7 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 Permit:NC0020214 Inspection Date:06/26/2023 Owner - Facility: Inspection Type: TWSA WWTP#2 Compliance Evaluation Disinfection-Gas Yes No NA NE The initial contact basin is located prior to the effluent discharge trough. There is a post-aeration tank located before the outfall that also serves as a chlorine contact chamber. Comment: De-chlorination Yes No NA NE Type of system ?Gas Is the feed ratio proportional to chlorine amount (1 to 1)? Is storage appropriate for cylinders? # Is de-chlorination substance stored away from chlorine containers? 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? Is flow meter calibrated annually? Is the flow meter operational? (If units are separated) Does the chart recorder match the flow meter? The meter was last calibrated on September 20, 2022 by Instrumentation Services, Inc.Comment: Effluent Sampling Yes No NA NE Is composite sampling flow proportional? Is sample collected below all treatment units? 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)? Sampling has been changed to flow proportional. At the time of the inspection, the composite sampling fridge temperature was 4.5 degrees Celsius. Comment: Page#8 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512 Permit:NC0020214 Inspection Date:06/26/2023 Owner - Facility: Inspection Type: TWSA WWTP#2 Compliance Evaluation Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? Are the receiving water free of foam other than trace amounts and other debris? If effluent (diffuser pipes are required) are they operating properly? Comment: Standby Power Yes No NA NE Is automatically activated standby power available? Is the generator tested by interrupting primary 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 monitored? The generator auto-exercises once per month. The fuel level was 60% at the time of the inspection. Due to needed electrical upgrades, the generator is only connected to the pump station. Mr. Henson incidcated that TWSA has a portable air compressor if needed to run the blowers in the event of an extended power outage. See summary for details. Comment: Page#9 DocuSign Envelope ID: 4C30CB85-4314-4FE3-B2E3-2025D7463512