NC0024252_Compliance Evaluation Inspection_20231114

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
CERTIFIED MAIL #: 7020 3160 0000 3283 0786
RETURN RECEIPT REQUESTED;
Brian Bradshaw, Public Utilities Director
City of Conover
Post Office Box 549
Conover, NC 28613-0549
SUBJECT: Notice of Violation
Compliance Evaluation Inspection
City of Conover/Northeast WWTP
NPDES Permit No. NCO024252
Catawba County
Tracking #: NOV-2023-PC-0561
Dear Mr. Bradshaw:
NORTH CAROLINA
Environmental Quality
November 15, 2023
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject
facility on November 8, 2023, by Mr. Wes Bell of this Office. This Office would like to thank all WWTP staff for their
cooperation and assistance that was provided throughout this inspection. Please advise the facility's Operator -in -Responsible
Charge (ORC) of our findings by forwarding the enclosed report.
This report is being issued as a Notice of Violation (NOV) due to the City's failure to collect flow proportional influent
composite samples which is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1.
Please note that G.S. 143-215.6A provides for a civil penalty of not more than twenty-five thousand dollars ($25,000.00), or
twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, against any person who violates
or fails to act in accordance with the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
Penalties may also be assessed for any damage to surface waters of the State that may result from the violation.
It is requested that a written response be submitted to this Office by December 4, 2023, detailing the actions taken to
address the violation as discussed in this report. In responding, please address your comments to the attention of Mr. Wes Bell.
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663,1699

As discussed in the inspection report, the City may submit a variance request to the Division to collect time -based (constant
time/constant volume) influent composite samples only if the daily flow rates do not vary by more than 15%. The request
should include a week's worth of daily flow charts, listing of any equalization facilities, flow description throughout the
wastewater facility and any other supplemental information that could assist in the Division's decision. Please submit the
variance request to the attention of Mr. Bell.
Should you have any questions concerning this Notice, please do not hesitate to contact Mr. Bell at [phone] or at
wes.bellkdeq.nc. gov.
Enclosure: Inspection Report
Cc: NPDES Program Files - Laseriiche
Sincerely,
Docu Signed by:
4014 w H PZUt4
F161 FB69A2D84A3...
Andrew H. Pitner, P.G.
Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.6631699

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 NCO024252 I11 121 23/11/08 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
2.0 70LJ 71 I„ I 72 L.71 74 79 I I I I
80
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 permit Number)
09:15AM 23/11/08
23/01/01
Northeast WWTP
3680 Hillview Dr
Exit Time/Date
Permit Expiration Date
Conover NC 28613
12:OOPM 23/11/08
27/11/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Andrew Scott Andreas Evans/ORC/828-879-2131/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Thomas Hart,PO Box 549 Conover NC 286130549H828-464-4808/
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar Records/Reports
Self -Monitoring Progran 0 Sludge Handling Dispo: 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
Wes Bell Signedby: DWR/MROWQ/704-235-2192/ 11/14/2023
2 re&
E�D`,','�96D90=437
...
Signature of Mana erBenC AdReviewer Agency/Office/Phone and Fax Numbers Date
ocu i ne by.
Andrew Pitn r A4,t, w E/ P44,04NR/MRO WQ/704-663-1699 Ext.2180/ 11/15/2023
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO024252 I11 12I 23/11/08 117 18 i c i
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Page#

Permit: NCO024252 Owner -Facility: Northeast WWTP
Inspection Date: 11/08/2023 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: City staff indicated that the upgrades to the headworks facilities and aeration system
are projected to be started by the Summer of 2024.
The City implements a Division -approved Industrial Pretreatment Program.
The last compliance evaluation inspection (Bioassay) at this facility was performed
by
DWR staff on 6/9/2022.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
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Is all required information readily available, complete and current?
■
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Are all records maintained for 3 years (lab. reg. required 5 years)?
■
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Are analytical results consistent with data reported on DMRs?
■
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Is the chain -of -custody complete?
■
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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?
■
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Has the facility submitted its annual compliance report to users and DWQ?
■
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
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■
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operator on each shift?
Is the ORC visitation log available and current?
■
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Is the ORC certified at grade equal to or higher than the facility classification?
■
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❑
Is the backup operator certified at one grade less or greater than the facility
■
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classification?
Is a copy of the current NPDES permit available on site?
■
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Facility has copy of previous year's Annual Report on file for review?
■
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Page# 3

Permit: NCO024252
Inspection Date: 11/08/2023
Record Keeping
Owner -Facility: Northeast WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: The records reviewed durinq the inspection were orqanized and well maintained.
Discharge Monitoring Reports (eDMRs) were reviewed for the period October 2022
through September 2023. The Division has previously addressed these limit violations
through the issuances of either a Notice of Deficiency (NOD) or civil penalty
assessment.
Facility staff must ensure to update the internal chain of custody form to document the
times influent samples are placed into the refrigerator (sample storage) to show that
the samples were being properly preserved within 15-minutes of collection.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
■
❑
❑
❑
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: Effluent field analyses (dissolved oxvqen, pH, temperature, total residual chlorine) are
performed under the City's field laboratory certification #5904. Water Tech Labs and
Meritech (metals and toxicity) have also been contracted to provide analytical support.
Facility staff must ensure that the annual calibration/verification curve on the total
residual chlorine meter is performed every 12 months. In addition, facility staff must
ensure that a post calibration check is performed on the dissolved oxygen meter when
upstream, downstream and effluent sampling/analyses are performed on the same day
(Reference: NC Wastewater/Groundwater Laboratory Certification Branch —Approved
Procedure for the Analysis of Dissolved Oxygen).
Influent Sampling Yes No
NA NE
# Is composite sampling flow proportional? ❑ 0
❑ ❑
Is sample collected above side streams? 0 ❑
❑ ❑
Is proper volume collected? ■ ❑
❑ ❑
Is the tubing clean? ■ ❑
❑ ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 0 ❑
❑ ❑
degrees Celsius)?
Is sampling performed according to the permit? ❑ ■
❑ ❑
Comment: The subject permit requires influent composite BOD and TSS samples. Time based
composite samples were being collected; however, the subject permit requires flow
proportional. Please be advised that flow proportional influent composite must be
collected as required by the by the subject Permit (Part II, Section A. Composite
Sample). The Division may grant a variance to collect time -based composite samples
only if the daily flow rates do not vary by more the 15%. A variance request has not
been submitted and/or received by the Division.
Page# 4

Permit: NCO024252
Inspection Date: 11/08/2023
Effluent Sampling
Is composite sampling flow proportional?
Is sample collected below all treatment units?
Owner -Facility: Northeast WWTP
Inspection Type: Compliance Evaluation
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
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• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
■ ❑ ❑ ❑
Comment: The subject permit requires composite and grab effluent samples. The Division has
previously approved a variance to collect time -based effluent composite samples.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑
and sampling location)?
Comment:
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: The wastewater treatment facility appeared to be properly operated and well
maintained. The facility staff incorporate an in-depth process control program with all
measurements being documented and maintained on -site. The facility is equipped
with a SCADA system to assist the wastewater staff in treatment operations. There are
multiple SCADA stations locationed at the facility. The operations staff also have
access to a phone that is connected to the telemetry type alarm notification system.
Bar Screens
Type of bar screen
Yes No NA NE
a.Manual
❑
b.Mechanical
Are the bars adequately screening debris?
❑
0
❑
❑
Is the screen free of excessive debris?
■
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Is disposal of screening in compliance?
0
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Is the unit in good condition?
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■
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Comment: The headworks (including grit removal and screening
processes) will be upgraded
within the near future.
Page# 5

Permit: NCO024252
Inspection Date: 11/08/2023
Grit Removal
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?
Owner -Facility: Northeast WWTP
Inspection Type: Compliance Evaluation
Comment: Screenings and grit are transported and disposed at the County Landfill.
Flow Measurement - Influent
# 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
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Yes No NA NE
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Comment: The ORC must ensure that a copy of the actual calibration (including instantaneous
measurements/verifications) is provided by the contracted company.
Pump Station - Influent
Yes
No
NA
NE
Is the pump wet well free of bypass lines or structures?
■
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Is the wet well free of excessive grease?
■
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Are all pumps present?
■
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Are all pumps operable?
■
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Are float controls operable?
■
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Is SCADA telemetry available and operational?
■
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Is audible and visual alarm available and operational?
■
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Comment:
Sequencinq Batch Reactors
Yes
No
NA NE
Type of operation:
Quadraplex
Is the reactor effluent free of solids?
■
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Does minimum fill time correspond to the peak hour flow rate of the facility?
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■
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Is aeration and mixing cycled on and off during fill?
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■
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The operator understands and can explain the process?
■
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Page# 6

Permit: NCO024252
Inspection Date: 11/08/2023
Owner -Facility: Northeast WWTP
Inspection Type: Compliance Evaluation
Sequencing Batch Reactors Yes No NA NE
Comment: The facility is equipped with four SBRs; however, two were currently in service due to
low influent flows. The SBR decant was free of excessive solids. The City is planning
on cleaning out all SBRs and installing new diffusers and blowers in 2024.
Pumps-RAS-WAS
Yes
No
NA
NE
Are pumps in place?
■
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Are pumps operational?
■
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Are there adequate spare parts and supplies on site?
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■
Comment:
Filtration (High Rate Tertiary)
Yes
No
NA
NE
Type of operation:
Down flow
Is the filter media present?
■
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Is the filter surface free of clogging?
■
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Is the filter free of growth?
■
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Is the air scour operational?
■
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Is the scouring acceptable?
■
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Is the clear well free of excessive solids and filter media?
■
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Comment: All five tertiary filters were operational and in service.
Disinfection -Liquid
Yes
No
NA
NE
Is there adequate reserve supply of disinfectant?
■
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(Sodium Hypochlorite) Is pump feed system operational?
■
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Is bulk storage tank containment area adequate? (free of leaks/open drains)
■
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Is the level of chlorine residual acceptable?
■
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Is the contact chamber free of growth, or sludge buildup?
■
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Is there chlorine residual prior to de -chlorination?
■
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Comment: One of the two chlorine contact chamber trains were in service due to low influent
flows. No settleable solids were measured in the chlorine contact chamber (in service)
during the on -site test.
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? ❑ ❑ ■ ❑
Page# 7

Permit: NC0024252 Owner -Facility:
Inspection Date: 11/08/2023 Inspection Type:
Northeast WWTP
Compliance Evaluation
De -chlorination
Yes
No
NA
NE
# Is de -chlorination substance stored away from chlorine containers?
0
❑
❑
❑
Are the tablets the proper size and type?
❑
❑
❑
Comment: Aqueous sodium bisulfite is added for dechlorination.
Are tablet de -chlorinators operational?
❑
❑
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Number of tubes in use?
Comment:
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?
❑
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■
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Comment: The effluent appeared clear with no floatable solids or foam.
Solids Handling Equipment
Yes
No
NA
NE
Is the equipment operational?
0
❑
❑
❑
Is the chemical feed equipment operational?
0
❑
❑
❑
Is storage adequate?
0
❑
❑
❑
Is the site free of high level of solids in filtrate from filter presses or vacuum filters?
■
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Is the site free of sludge buildup on belts and/or rollers of filter press?
■
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Is the site free of excessive moisture in belt filter press sludge cake?
0
❑
❑
❑
The facility has an approved sludge management plan?
0
❑
❑
❑
Comment: The facility is equipped with a qravitv belt thickener and two aerated sludqe storaqe
tanks (1 — waste activated sludge and 1 - thickened sludge). Approximately two loads
per week of thickened sludge is transported (by City staff) to the Regional Compost
Facility for additional processing and disposal (compost). The City also hauls
approximately four loads per week of thickened sludge from a dedicated tank located
at the City of Newton's Clark Creek WWTP to the Regional Compost Facility. The
gravity belt thickener is typically placed into service once a week.
Standby Power
Yes
No
NA
NE
Is automatically activated standby power available?
0
❑
❑
❑
Is the generator tested by interrupting primary power source?
0
❑
❑
❑
Is the generator tested under load?
M
❑
❑
❑
Was generator tested & operational during the inspection?
M
❑
❑
❑
Do the generator(s) have adequate capacity to operate the entire wastewater site?
0
❑
❑
❑
Page# 8

Permit: NC0024252 Owner -Facility: Northeast WWTP
Inspection Date: 11/08/2023 Inspection Type: Compliance Evaluation
Standby Power Yes
No
NA
NE
Is there an emergency agreement with a fuel vendor for extended run on back-up 0
❑
❑
❑
power?
Is the generator fuel level monitored? 0
❑
❑
❑
Comment: The backup generator is tested (automatically) once a month under load. City staff
perform the general maintenance on the generator.
Page#