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SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.
October 24, 2023
J Robert Boyette, City Manager
City of Marion
PO Drawer 700
Marion, NC 28752-0700
SUBJECT: NOTICE OF VIOLATION
Tracking Number: NOV-2023-PC-0527
Permit No. NC0031879
Corpening Creek WWTP
McDowell County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Corpening Creek WWTP
on August 15, 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. NC0031879. 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 violation(s) were noted during the inspection:
Inspection Area Description of Violation
__________________________________________________________________________________________________________________________________________________________________
Primary Clarifier The primary clarifiers are currently being operated as pass through
basins, which is not as the facility was originally permitted. If the City
of Marion intends to continue to operate the primary clarifiers as pass
through basins, they should apply for a Permit Modification with the
Division’s NPDES Municipal Permitting Unit. Additionally, the sludge
blankets were higher than a desirable level at 9 feet out of 13 feet.
_________________________________________________________________________________________________________________________________________________________________
DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
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, please respond in writing to this office
within 30 days upon your receipt of this Notice of Violation regarding your plans or measures to be taken
to address the indicated violations and other identified issues, if applicable.
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
DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
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 NC0031879 23/08/15 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)
Corpening Creek WWTP
3982 NC Hwy 226 S
Marion NC 28752
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 23/08/15 21/05/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
James T Horton/ORC/828-652-8843/
Other Facility Data
12:00PM 23/08/15 26/01/31
Name, Address of Responsible Official/Title/Phone and Fax Number
Brant Sikes,PO Drawer 700 Marion NC 287520700//828-652-4224/8286523843 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
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
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.
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DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
10/24/2023
10/24/2023
10/24/2023
10/25/2023
NPDES yr/mo/day
23/08/15
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 Corpening Creek WWTP on August 15, 2023. This
inspection was conducted to determine whether the facility is being operated and maintained in
compliance with NPDES Permit No. NC0031879. Mr. Tim Horton (ORC) and Mr. Dustin Saine (BORC)
were present and assisted with the inspection.
Overall, the facility is in need of several upgrades described below. Mr. Horton indicated that the City
of Marion has been working with Kimley-Horn and Associates on an engineering evaluation for
needed upgrades. Mr. Horton provided us with the draft Scope of Work at the time of the inspection.
The following items were noted during the inspection:
1) Operations and Maintenance: The consulting engineers have begun a Scope of Work for the
facility upgrades. Mr. Horton noted that the City of Marion had submitted for a grant for the needed
upgrades last fall and that was awarded in February of 2023. Overall, solids have become an issue
throughout the plant due to a local farmer no longer wanting to apply residuals to their field. The
facility is being added to the U.S. Biosolids permit in order to address the situation.
2) Primary Clarifiers: The primary clarifiers are essentially being used as pass-through basins.
Previous reports indicated that they were being used as EQ basins, however this is not the case. The
solids level is still very high as indicated on previous inspection reports and has black scum on the
surface. Both primary clarifiers have a sludge blanket level of approximately 9 ft out of 13 ft.
3) Secondary Clarifiers: The drive unit and sweep arm on secondary clarifier #1 was repaired in
2022. Secondary clarifier #2 will be evaluated for rehabilitation once the solids issues in the plant
have been resolved. Per the recommendation of the previous Compliance Evaluation Inspection in
2021, the weirs in #1 have been leveled, however not yet in #2. This will be completed upon the
rehabilitation of clarifier #2.
4) RAS-WAS Pumps: The RAS pump was replaced last year. They have kept the old one as a
backup, however it is still approximately 20 years old and they are planning to get another one to
have a newer backup RAS pump.
5) Tertiary Filters: The tertiary filters have been inoperable for many years, and the transversing
bridge on the unit is not functional. The rehabilitation for the tertiary filters is also under evaluation for
upgrades.
6) Aerobic Digester: Mr. Horton indicated that the wasting system from the digester to the thickener is
inoperable, and due to this they do not pump solids to the thickener at this time. They did a partial
cleanout of the digester last October, but they are now experiencing issues with high solids due to
some farmers no longer wanting to land apply. They are set to be permitted with U.S. Biosolids this
month and this should resolve the high solids issues.
7) Standby Power: The digital gauge reading was 0 at the time of the inspection, however the fuel
level was at approximately 50%. The digital gauge should be repaired so that accurate fuel level
readings may be available.
The following violations were noted during the inspection:
1) Primary Clarifiers: The primary clarifiers are currently being operated as pass through basins,
which is not as the facility was originally permitted. If the City of Marion intends to continue to operate
the primary clarifiers as pass through basins, they should apply for a Permit Modification with the
Division’s NPDES Municipal Permitting Unit. Additionally, the sludge blankets were higher than a
NC0031879 17 (Cont.)
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DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
Compliance Evaluation
desirable level at 9 feet out of 13 feet.
Page#3
DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
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?
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 control parameters analyzed include DO, alkalinity, pH, sludge blanket level,
and MLSS.
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: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
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. Horton noted that they are currenly working on upgrading their SCADA system. The
facility uses a transducer and has float controls as a back-up if needed.
Comment:
Influent Sampling Yes No NA NE
# Is composite sampling flow proportional?
Is sample collected above side streams?
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 sampling performed according to the permit?
Influent sampling is time-based. The sampler was last calibrated on March 23, 2023 by
the facility's lab supervisor. At the time of the inspection, the refrigerated sample was
-0.5 degrees Celcius. It is recommended that the thermometer be recalibrated due to
the negative temperature reading.
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?
Page#5
DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
Compliance Evaluation
Bar Screens Yes No NA NE
Is the unit in good condition?
Comment:
Grit Removal Yes No NA NE
Type of grit removal
a.Manual
b.Mechanical
Is the grit free of excessive organic matter?
Is the grit free of excessive odor?
# Is disposal of grit in compliance?
Mr. Horton indicated that a new grit pump was installed approximately one month prior
to the inspection. He also stated that the grit removal does not work as well as it
should, so it is recommended to get this evaluated.
Comment:
Primary 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 sludge blanket level acceptable?
Is the sludge blanket level acceptable? (Approximately ¼ of the sidewall depth)
The primary clarifiers are essentially being used as pass-through basins. Previous
reports indicated that they were being used as EQ basins, but this is not the case. Both
primary clarifiers have a sludge blanket level of approximately 9 ft out of 13 ft. The
primary clarifiers are currently under rehabilitation evaluation and upgrades planning.
See summary for details.
Comment:
Aeration Basins Yes No NA NE
Mode of operation Ext. Air
Type of aeration system Surface
Is the basin free of dead spots?
Page#6
DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
Compliance Evaluation
Aeration Basins Yes No NA NE
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)
At the time of the inspection, basin #2 was in use, but basin #1 was not operational. At
the time of the inspection, Mr. Saine measured the DO in basin #2 to be 1.43 mg/L. Mr.
Horton noted that DO is usually is around 1.0 mg/L in the summer and 2.0 mg/L in the
winter. He also indicated that MLSS is typically around 10,000-12,000 mg/L.
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)
At the time of the inspection, the sludge blanket level in clarifier #1 was 10 ft. out of 13
ft. In clarifier #2 the blanket level was 6 ft out of 13 ft. The drive unit and sweep arm on
secondary clarifier #1 was repaired in 2022. Secondary clarifier #2 will be evaluated for
rehabilitation once the solids issues in the plant have been resolved. The weirs in #1
have been leveled, however not yet in #2. 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?
The RAS pump was replaced last year. They have kept the old one as a backup. See
summary for details.
Comment:
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DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
Compliance Evaluation
Filtration (High Rate Tertiary)Yes No NA NE
Type of operation:
Is the filter media present?
Is the filter surface free of clogging?
Is the filter free of growth?
Is the air scour operational?
Is the scouring acceptable?
Is the clear well free of excessive solids and filter media?
The tertiary filter has been inoperable for many years and the Scope of Work that
details proposed upgrades for the plant indicated that other facility upgrades take
precedence. 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?
The facility is experiencing issues with high solids due to malfunction with the wasting
system from the digester to the thickener. They are also experiencing issues with high
solids because one of the permitted facilities that accepts their residuals under their
non-discharge permit has stopped accepting solids. To address this, they are
anticipated to be permitted with U.S. Biosolids by the end of August 2023 and this
should resolve the high solids issues. See summary for details.
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-____-____)
If yes, then when was the RMP last updated?
Page#8
DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
Compliance Evaluation
Disinfection-Gas Yes No NA NE
The facility keeps up to 1500 lbs of chlorine on-site. At the time of the inspection, the
sludge blanket in chlorine contact chamber #1 was 2 ft out of 6.5 ft and in #2 it was 1 ft
out of 6.5 ft.
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 flow meter was last calibrated in June 2023 by KDT Services Technologies.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)?
At the time of the inspection, the refigerated sample was -0.9 degrees Celcius.Comment:
Effluent Pipe Yes No NA NE
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DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C
Permit:NC0031879
Inspection Date:08/15/2023
Owner - Facility:
Inspection Type:
Corpening Creek WWTP
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 has the capacity to run everything in the WWTP except for the blowers
for the digester. See summary for details.
Comment:
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DocuSign Envelope ID: 6CF0A3FE-9321-495F-9B01-36F3B6CFE79C