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Home My WebLink AboutNC0000639_Compliance Evaluation Inspection_20231108ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Arnold Eugene Allred Sapona Yarns LLC 3309 Walker Store Rd Franklinville, NC 27248-8375 NORTH CAROLINA Environmental Quality November 8, 2023 Subject: Compliance Evaluation Inspection & Notice of Violation NOV Tracking #: NOV-2023-PC-0556 Sapona Manufacturing Company NPDES Permit No. NC0000639 Randolph County Dear Mr. Allred: On November 1, 2023, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO) staff Jesse Barnes conducted a routine compliance evaluation inspection at the Sapona Manufacturing Company in reference to NPDES permit NC0000639. ORC Arnold Allred was present during the inspection. A review of the subject permit, records, data, laboratory, treatment components, sampling methods, outfall area, operations, and maintenance 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. Mr. Allred estimates and reports influent flow of incoming domestic waste based on a meter that totals influent pump run hours. This totalizer has not or cannot be calibrated and/or verified annually. Part II, Section D. (3.) requires flow measurement devices to be calibrated at a minimum of once per year. 2. Effluent total ammonia (NH3-N) samples have been taken from the clarifier effluent before chlorination and de -chlorination. Part I, Section A. (1.) of the subject permit requires two monthly grab samples of effluent wastewater to be analyzed for total ammonia (NH3-N) and reported to DWR. Part II, Section A. of the subject permit defines Axeffluent" as wastewater discharged following a// treatment processes (this includes disinfection and de -chlorination). Part II, Section D. (1.) of the subject permit requires all samples to be taken at the monitoring points specified in the subject permit. Items of Concern 1. Field parameters for domestic waste treatment have been performed by NC certified field laboratory #5408, Town of Franklinville, but this lab has not been listed on discharge monitoring reports (DMRs). NoanicaaouNn oep.m.m or em�.nmen� Qualm North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 2. The subject permit states that the facility utilizes sodium bisulfate de -chlorination for domestic waste treatment, but calcium thiosulfate was observed in use during the inspection. 3. The exact location of outfall 001 is unknown. 4. De -chlorination tablet tubes at outfall 002 may not sufficiently contact all effluent wastewater. Water was observed traveling around the tubes during the inspection. 5. Permit ownership and contact information in the DWR database is no longer correct. Please use the attached change of ownership form to update permit ownership and contact information. 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. Please reply, in writing, to this notice of violation within ten (10) business days after receipt. Your written response should address each violation listed above and provide your intended remedial actions, with estimated completion dates, for each violation. Failure to make the necessary corrective actions to achieve full compliance within a reasonable time may result in further enforcement actions. If you have any questions or concerns, contact Jesse Barnes by phone at 336-776-9701 or by email at jesse.barnes@deq.nc.gov. Thank you in advance for your time and attention to this matter. Sincerely, Docu Signed by: OD2D3CE3F1B7456... 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, NC0000639 2. Permit Name/Ownership Change Form NORTH CAROLINAD E Q North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Raleigh, North Carolina 27105 336.776.9800 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 NC0000639 I11 121 23/11/01 I17 18I � I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I I 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) 11:00AM 23/11/01 22/10/01 Sapona Manufacturing Company 2478 Cedar Falls Rd Exit Time/Date Permit Expiration Date Cedar Falls NC 27230 12:OOPM 23/11/01 26/09/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Arnold Eugene Allred/ORC/336-824-6440/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Arnold Eugene Allred,3309 Walker Store Rd Franklinville NC 272488375//336-672-0892/ 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 [DocuSgned Jesse Barnes iby: DWR/WSRO WQ/336-776-9701/ ane 5 11/7/2023 41797473D3194ED... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: 11/8/202 3 DwR/wslto 336-776-9695 EPA Form 3560�F�ev ��)�0revious editions are obsolete. Page# NPDES yr/mo/day Inspection Type NC0000639 I11 12I 23/11/01 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On November 1, 2023, Division of Water Resources (DWR) Winston-Salem Regional Office (WSRO) staff Jesse Barnes conducted a routine compliance evaluation inspection at the Sapona Manufacturing Company in reference to NPDES permit NC0000639. ORC Arnold Allred was present during the inspection. A review of the subject permit, records, data, laboratory, treatment components, sampling methods, outfall area, operations, and maintenance 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. Mr. Allred estimates and reports influent flow of incoming domestic waste based on a meter that totals influent pump run hours. This totalizer has not or cannot be calibrated and/or verified annually. Part II, Section D. (3.) requires flow measurement devices to be calibrated at a minimum of once per year. 2. Effluent total ammonia (NH3-N) samples have been taken from the clarifier effluent before chlorination and de -chlorination. Part I, Section A. (1.) of the subject permit requires two monthly grab samples of effluent wastewater to be analyzed for total ammonia (NH3-N) and reported to DWR. Part ll, Section A. of the subject permit defines "effluent' as wastewater discharged following all treatment processes (this includes disinfection and de -chlorination). Part II, Section D. (1.) of the subject permit requires all samples to be taken at the monitoring points specified in the subject permit. Items of Concern 1. Field parameters for domestic waste treatment have been performed by NC certified field laboratory #5408, Town of Franklinville, but this lab has not been listed on discharge monitoring reports (DMRs). 2. The subject permit states that the facility utilizes sodium bisulfate de -chlorination for domestic waste treatment, but calcium thiosulfate was observed in use during the inspection. 3. The exact location of outfall 001 is unknown. 4. De -chlorination tablet tubes at outfall 002 may not sufficiently contact all effluent wastewater. Water was observed traveling around the tubes during the inspection. 5. Permit ownership and contact information in the DWR database is no longer correct. Please use the attached change of ownership form to update permit ownership and contact information. Other observations: NPDES permit NC0000639 became effective October 1, 2022, and will expire at midnight on September 30, 2026. The facility is permitted for and operates two separate treatment processes: domestic wastewater discharged at outfall 001 and cooling water/blowdown discharged at outfall 002. Access to the facility is restricted by a locked fence. Bench sheets, laboratory reports, chains of custody, ORC visitation log, and the DMR for August 2023 were reviewed and appeared to be complete with no errors. A copy of the subject permit was available during the inspection at the Town of Franklinville maintenance shop, where all required records are stored. All records appeared to be kept and maintained as required by the subject permit. Domestic Waste Treatment: The aeration basin contains two blowers located at one end of the basin, near the surface, which run constantly and appeared to agitate the basin sufficiently with no dead spots. Moderate algal growth was observed on the secondary clarifier weirs but was not excessive and did not appear to significantly impact treatment. Page# Permit: NC0000639 Inspection Date: 11/01/2023 Owner -Facility: Sapona Manufacturing Company Inspection Type: Compliance Evaluation Power to the treatment plant is connected to the manufacturing facility, which has a generator that operates the entire facility during outages. Disinfection is achieved via liquid bleach pump system, carrier water, and baffled contact chamber. De -chlorination is achieved via liquid calcium thiosulfate. The effluent flow meter is a Pulsar Measurement Greyline OCF 6.1 model unit that measures flow via sonar -detected water level, but it is only used for process control and not used for reporting. Cooling Water/Blowdown The outfall 002 right of way was properly maintained and easily accessible during the inspection. Effluent flow was observed at the outfall and appeared to be clear with no foam or other debris visible in the receiving stream. Page# Permit: NC0000639 Owner -Facility: Sapona Manufacturing Company Inspection Date: 11/01/2023 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? ❑ ■ ❑ ❑ # 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: Permit ownership and contact information in the DWR database is no longer correct Please use the attached change of ownership form to update permit ownership and contact information. The subject permit states that the facility utilizes sodium bisulfate de -chlorination for domestic waste treatment, but calcium thiosulfate was observed in use during the inspection. Special Biocide Condition of the permit states, "There shall be no chromium, zinc, or copper added to the treatment system except as pre -approved additives to biocidal compounds." 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? Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ■ ❑ Page# 4 Permit: NC0000639 Inspection Date: 11/01/2023 Record Keeping Comment: Owner -Facility: Sapona Manufacturing Company Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # 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? Yes No NA NE Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Comment: Field parameters for domestic waste treatment have been performed by NC certified field laboratory #5408, Town of Franklinville, but this lab has not been listed on discharge monitoring reports (DMRs). 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: Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? 0 ❑ ❑ ❑ 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: Mr. Allred estimates and reports influent flow of incoming domestic waste based on a meter that totals influent pump run hours. This totalizer has not or cannot be calibrated and/or verified annually. Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? ❑ ❑ ❑ Page# 5 Permit: NC0000639 Inspection Date: 11/01/2023 Bar Screens Is the unit in good condition? Comment: Owner -Facility: Sapona Manufacturing Company Inspection Type: Compliance Evaluation 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) Comment: 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) Comment: Standby Power Is automatically activated standby power available? Is the generator tested by interrupting primary power source? Is the generator tested under load? Yes No NA NE ❑ ❑ ❑ Yes No NA NE Ext. Air Jet ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Page# 6 Permit: NC0000639 Owner -Facility: Sapona Manufacturing Company Inspection Date: 11/01/2023 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE 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: Disinfection -Liquid Yes No NA NE Is there adequate reserve supply of disinfectant? 0 ❑ ❑ ❑ (Sodium Hypochlorite) Is pump feed system operational? 0 ❑ ❑ ❑ Is bulk storage tank containment area adequate? (free of leaks/open drains) 0 ❑ ❑ ❑ Is the level of chlorine residual acceptable? ❑ ❑ ❑ Is the contact chamber free of growth, or sludge buildup? 0 ❑ ❑ ❑ Is there chlorine residual prior to de -chlorination? ❑ ❑ ❑ Comment: De -chlorination Yes No NA NE Type of system ? Liquid 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? 0 ❑ ❑ ❑ Are the tablets the proper size and type? ❑ ❑ 0 ❑ Comment: Outfall 001 utilizes liquid de -chlorination (calcium thiosulfate). Are tablet de -chlorinators operational? 0 ❑ ❑ ❑ Number of tubes in use? 3 Comment: Outfall 002 (cooling water/blowdown) utilizen de -chlorination tablet tubes. De -chlorination tablet tubes at outfall 002 may not sufficiently contact all effluent wastewater. Water was observed traveling around the tubes during the inspection. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ❑ 0 ❑ ❑ Is flow meter calibrated annually? ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ 0 ❑ Page# 7 Permit: NC0000639 Inspection Date: 11/01/2023 Flow Measurement - Effluent Owner -Facility: Sapona Manufacturing Company Inspection Type: Compliance Evaluation Yes No NA NE Comment: The effluent flow meter is a Pulsar Measurement Greyline OCF 6.1 model unit that measures flow via sonar -detected water level, but it is only used for process control and not used for reporting. 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)? Yes No NA NE ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ Comment: Effluent total ammonia (NH3-N) samples have been taken from the clarifier effluent before chlorination and de -chlorination. 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 exact location of outfall 001 is unknown. Page# 8