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Home My WebLink AboutNC0070637_Compliance Evaluation Inspection_20231101ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Greg Dillinger Kurz Transfer Products LP 3200 Wood Park Blvd Charlotte, NC 28206 NORTH CAROLINA Environmental Quality November 1, 2023 Subject: Compliance Evaluation Inspection Report & Notice of Violation NOV Tracking #: NOV-2023-PC-0542 Kurz Transfer Products LP NPDES Permit No. NCO070637 Davidson County Dear Mr. Dillinger: On October 3, 2023, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO) staff Jesse Barnes conducted a routine compliance evaluation inspection at the Kurz Transfer Products WWTP in reference to NPDES permit NC0070637. ORC Todd Robinson was present during the inspection. A review of the permit, records, reports, data, operations, maintenance, treatment components, and structures was completed. This review reflected noncompliance with the subject permit. The determined permit violations and items of concern are listed below. Inspection findings are detailed in the attached Water Compliance Inspection Report. Permit Violations 1. The effluent flow meter used for monitoring and reporting purposes has not been calibrated or verified since its installation in 2019. Part II, Section D. (3.) of the subject permit requires that flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices shall be capable of measuring flows with a maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge volumes. 2. No standby power is present for the treatment system. Part II, Section C. (7.) of the subject permit requires the permittee to maintain adequate safeguards to prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means of alternate power sources, standby generators, or retention of inadequately treated effluent. Items of Concern 1. The laboratory certification number under which field parameters have been performed, #5212 — Envirolink Inc, has not been listed on discharge monitoring reports (DMRs). Mr. Robinson was advised to include this information on future DMRs. DffNorth Carolina Department of Environmental Quality I Division of Water Resources oan caaouNn Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 M336.776.9800 oep.m.m or em�nmen� Qualm 2. A data discrepancy was discovered upon review of the July 2023 DMR. The operator recorded effluent temperature of 26.2 °C on July 3, 2023, but 21.2 °C was reported on the DMR. The error appeared to be due to misinterpretation of handwritten records during transcription of data from the bench sheet to eDMR. The DMR was revised and corrected following the inspection. 3. There are no outdoor audio alarms on the control panel to indicate high water levels and mechanical failures within the treatment system tanks. An indoor alarm and telemetry are resent, but the visual alarm indicator light on the outdoor control panel is small and dim. a] The facility is as described in item 2 of the supplement to permit cover sheet, while also maintaining the 1,500-gallon septic tank listed in item 1. So, the facility components are as follows: (1.) 1,500-gallon septic tank (2.) 5,000-gallon recirculating tank (3.) 10,000-gallon septic tank (4.) Advantex AX100 Pod (5.) TCOM Telemetry Control Panel and (6.) flow meter. Please accurately report the facility components in the upcoming permit renewal application. Please be aware that the Division may take enforcement action against any individual who fails to comply with the requirements of all applicable permits, regulations, and/or statutes. Pursuant to NC General Statute (NCGS) 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, or applicable regulations, issued pursuant to G.S. 143-215.1. If you have any questions or concerns, please do not hesitate to contact Jesse Barnes by phone at 336-776-9701, or by email at iesse.barnes@deq.nc.gov. Thank you in advance for your time and attention to this matter. Sincerely, DocuSigned by: OD2D3CE3F167456... Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: 1. Water Compliance Inspection Report, NCO070637 REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly 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 NCO070637 I11 121 23/10/03 I17 18I � I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II r6 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I ni I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I LJ 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 Dermit Number) 10:15AM 23/10/03 19/08/01 Kurz Transfer Products LP 4939 NC Hwy 150 N Exit Time/Date Permit Expiration Date Lexington NC 27295 11:15AM 23/10/03 24/05/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Todd Franklin Robinson/ORC/704-881-4598/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Greg Dillinger,3200 Wood Park Blvd Charlotte NC 28206//336-397-1724/3363971705 No Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement Operations & Maintenar Records/Reports Self -Monitoring Progran 0 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 Jesse Barnes Docusg ned by: DWR/WSRO WQ/336-776-9701/ 01/ 10/31/2023 EY'417974'73D3194ED... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date by: FjDocusigned - DwR/wSRo 336-776-9695 11/1/2023 '-- OD2D3CE3F 197456_. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO070637 I11 12I 23/10/03 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On October 3, 2023, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO) staff Jesse Barnes conducted a routine compliance evaluation inspection at the Kurz Transfer Products WWTP in reference to NPDES permit NC0070637. ORC Todd Robinson was present during the inspection. A review of the permit, records, reports, data, operations, maintenance, treatment components, and structures was completed. This review reflected noncompliance with the subject permit. The following violations were noted: 1. The effluent flow meter used for monitoring and reporting purposes had not been calibrated or verified since its installation in 2019. Part II, Section D. (3.) of the subject permit requires that flow measurement devices shall be accurately calibrated at a minimum of once per year and maintained to ensure that the accuracy of the measurements is consistent with the accepted capability of that type of device. Devices shall be capable of measuring flows with a maximum deviation of less than 10% from the true discharge rates throughout the range of expected discharge volumes. 2. No standby power is present for the treatment system. Part II, Section C. (7.) of the subject permit requires the permittee to maintain adequate safeguards to prevent the discharge of untreated or inadequately treated wastes during electrical power failures either by means of alternate power sources, standby generators, or retention of inadequately treated effluent. The following items of concern were noted: 1. The laboratory certification number under which field parameters have been performed, #5212 — Envirolink Inc, has not been listed on discharge monitoring reports (DMRs). Mr. Robinson was advised to include this information on future DMRs. 2. A data discrepancy was discovered upon review of the July 2023 DMR. The operator recorded effluent temperature of 26.2 °C on July 3, 2023, but 21.2 °C was reported on the DMR. The error appeared to be due to misinterpretation of handwritten records during transcription of data from the bench sheet to eDMR. The DMR was revised and corrected following the inspection. 3. There are no outdoor audio alarms on the control panel to indicate high water levels and mechanical failures within the treatment system tanks. Also, an indoor alarm and telemetry are present but the visual alarm indicator light on the outdoor control panel is small and dim. 4. The facility is as described in item 2 of the supplement to permit cover sheet, while also maintaining the 1,500-gallon septic tank listed in item 1. So, the facility components are as follows: (1.) 1,500-gallon septic tank (2.) 5,000-gallon recirculating tank (3.) 10,000-gallon septic tank (4.) Advantex AX100 Pod (5.) TCOM Telemetry Control Panel and (6.) flow meter. Please accurately report the facility components in the upcoming permit renewal application. Other observations: NPDES permit NC0070637 became effective August 1, 2019 and will expire at midnight on May 31, 2024. Discharge monitoring reports and all other required records are maintained digitally on Envirolink servers and were available for review upon request. A copy of the subject permit was available on site during the inspection. The July 2023 DMR and bench sheets were reviewed for transcription accuracy and one error was found- see items of concern above. The DMR appeared to contain all required permit parameters. The chain of custody for commercial laboratory sample transportation on September 20, 2023 was reviewed and appeared to be complete. Field parameters are performed by Page# Permit: NCO070637 Inspection Date: 10/03/2023 Owner -Facility: Kurz Transfer Products LP Inspection Type: Compliance Evaluation NC certified lab #5212- Envirolink Inc. All other required parameters are performed by NC certified lab #440- Statesville Analytical. Mr. Robinson stated that the 1,500-gallon septic tank on the east side of the facility traps most of the solids coming into the system since it is the first treatment component, so it is pumped on a regular schedule of every six months to maintain appropriate solids levels. After the first 1,500-gallon septic tank, wastewater travels via gravity to the 10,000-gallon septic tank, which appears to function essentially as an equalization basin. Wastewater is then pumped via float controls to the Advantex Pod and recirculating tank for biological and mechanical filtration before passing through the flow meter and to the outfall. All components appeared to be operating properly during the inspection. High level alarms for the 10,000-gallon septic tank, recirculating tank, and Advantex Pod were tested and appeared to be operating properly- the telemetry system successfully notified staff, the control panel visual alarm illuminated, and the indoor audio alarm sounded. No outdoor alarm is present on the control panel. The outfall pipe was inspected, and effluent flow was observed during the inspection. The effluent appeared to be clear, and the receiving stream appeared to be free of foam and other debris. A backflow prevention valve was present on the end of the outfall pipe to prevent water from flowing into the treatment system during flood events. Page# Permit: NCO070637 Owner -Facility: Kurz Transfer Products LP Inspection Date: 10/03/2023 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 ❑ ❑ ❑ 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 facilitv is as described in item 2 of the supplement to permit cover sheet, while also maintaining the 1,500-gallon septic tank listed in item 1. So, the facility components are as follows: (1.) 1,500-gallon septic tank (2.) 5,000-gallon recirculating tank (3.) 10,000-gallon septic tank (4.) Advantex AX100 Pod (5.) TCOM Telemetry Control Panel and (6.) flow meter. Please accurately report the facility components in the upcoming permit renewal application. 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# 4 Permit: NCO070637 Inspection Date: 10/03/2023 Record Keeping Owner -Facility: Kurz Transfer Products LP Inspection Type: Compliance Evaluation Yes No NA NE Comment: Discharge monitoring reports and all other required records are maintained digitally on Envirolink servers and were available for review upon request. A copy of the subject permit was available on site during the inspection. The July 2023 DMR and bench sheets were reviewed for transcription accuracy and one error was found. The DMR appeared to contain all required permit parameters. The chain of custody for commercial laboratory sample transportation on September 20, 2023 was reviewed and appeared to be complete. A data discrepancy was discovered upon review of the July 2023 DMR. The operator recorded effluent temperature of 26.2 °C on July 3, 2023, but 21.2 °C was reported on the DMR. The error appeared to be due to misinterpretation of handwritten records during transcription of data from the bench sheet to eDMR. The DMR was revised and corrected following the inspection. 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 ❑ ❑ ❑ degrees Celsius)? Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees? ❑ ❑ ❑ Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees? ❑ ❑ ❑ Comment: The laboratory certification number under which field parameters have been performed, #5212 — Envirolink Inc, has not been listed on discharge monitoring reports (DMRs). Mr. Robinson was advised to include this information on future DMRs. Field parameters are performed by NC certified lab #5212- Envirolink Inc. All other required parameters are performed by NC certified lab #440- Statesville Analytical. 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 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: Septic Tank Yes No NA NE (If pumps are used) Is an audible and visual alarm operational? ■ ❑ ❑ ❑ Is septic tank pumped on a schedule? 0 ❑ ❑ ❑ Are pumps or syphons operating properly? ❑ ❑ ❑ Are high and low water alarms operating properly? 0 ❑ ❑ ❑ Page# 5 Permit: NCO070637 Inspection Date: 10/03/2023 Owner -Facility: Kurz Transfer Products LP Inspection Type: Compliance Evaluation Septic Tank Yes No NA NE Comment: Mr. Robinson stated that the 1,500-gallon septic tank on the east side of the facility traps most of the solids coming into the system since it is the first treatment component, so it is pumped on a regular schedule of every six months to maintain appropriate solids levels. Standby Power 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? Comment: No standby power is present for the treatment system. Flow Measurement - Effluent # 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? Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The effluent flow meter used for monitoring and reporting purposes had not been calibrated or verified since its installation in 2019. Effluent Sampling 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)? Comment: Effluent Pipe Yes No NA NE ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Yes No NA NE Page# 6 Permit: NC0070637 Inspection Date: 10/03/2023 Owner -Facility: Kurz Transfer Products LP Inspection Type: Compliance Evaluation 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 ❑ Comment: The outfall pipe was inspected, and effluent flow was observed during the inspection. The effluent appeared to be clear, and the receiving stream appeared to be free of foam and other debris. A backflow prevention valve was present on the end of the outfall pipe to prevent water from flowing into the treatment system during flood events. Page# 7