NC0085553_Compliance Evaluation Inspection_20231212

DocuSign Envelope ID: 3930C3C3-782E-4D45-A1 FF-670296DO4869
ROr COOPER
ELIZABETH S. BISER
RICHARD E. ROGERS, JR.
NORTH CAROLINA
Director
Environmental Quality
December 12, 2023
Joseph P. McCann
Village of Bald Head Island
PO Box 3009
Bald Head Island, NC 28461-3009
SUBJECT: Compliance Inspection Report
Bald Head Island WTP
NPDES WW Permit No. NCO085553
Brunswick County
Dear Permittee:
The North Carolina Division of Water Resources conducted an inspection of the Bald Head Island WTP
on 12/08/2023. This inspection was conducted to verify that the facility is operating in compliance with
the conditions and limitations specified in NPDES WW Permit No. NC0085553. The findings and
comments noted during this inspection are provided in the enclosed copy of the inspection report
entitled "Compliance Inspection Report".
There were no significant issues or findings noted during the inspection and therefore, a response to this
inspection report is not required. If you should have any questions, please do not hesitate to contact Bryan
Lievre with the Water Quality Regional Operations Section in the Wilmington Regional Office at 910-796-7215
or via email at [e-mail].
Sincerely, DocuSigned by:
CSad-6,
8554BOF62D ED464...
Morelia Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Wilmington Regional Office
Division of Water Resources, NCDEQ
Attachment
Cc: Nathan Lindsay (via email [e-mail])
Upload to Laserfiche
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`�J$ W'rlmington Regional Oflire 112I CaMlnal prlve Eelenslan Wilmington North Carolina 28495
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DocuSign Envelope ID: 3930C3C3-782E-4D45-A1 FF-670296DO4869
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 15 1 3 I NCO085553 I11 121 23/12/08 I17 18 I,- I 19 I G I 201
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 CA ---------------------- Reserved -------------------
67
I 71 I I 72 I n, I 73 LLI74 71 I I I I I I I80
70 Iu ty 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 permit Number)
09:45AM 23/12/08
18/01/01
Bald Head Island WTP
256 Edward Teach Extension
Exit Time/Date
Permit Expiration Date
Bald Head Island NC 28461
11:15AM 23/12/08
22/11/30
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Not Required/ORC/919-807-6353/
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
David A Suther,PO Box 3009 Bald Head Island NC
284613009/Operator/910-457-7352/9104577353 Yes
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( -q` i�oeiat�rs,�(O:: and Fax Numbers Date
,Q L Agency/Office/Phone
Ann M Baxter UVJA, t'�'t-A44- 1/A?,rfLDWR/WIRO WQ/910-796-4215/
DocuSi ned by:
Bryan Lievre z�aE�C8C5ss4CC... DWR/WIRO WQ/910-796-7215/ 12/11/2023
"4C
Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date
DocuSigned by:
Morella Sanchez -King DWR/WIRO WQ/910-796-7218/ (ZVtt('0 _ 12/12/2023
`— 85 54 B O F62 D E D 464...
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

DocuSign Envelope ID: 3930C3C3-782E-4D45-A1 FF-670296DO4869
NPDES yr/mo/day Inspection Type (Cont.)
31 NCO085553 I11 12I 23/12/08 117 18 ICI
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
A routine compliance inspection of the Bald Head Island Reverse Osmosis Water Treatment Plant
(WTP), was performed on December 8, 2023. The purpose of the inspection was to verify that the
facility is operating in compliance with the conditions and limitations specified within Permit
NC0085553. Nathan Lindsay, facility Operator in Responsible Charge (ORC), as well as Bryan
Lievre and Ann Marie Baxter, both with the Division of Water Resources, were present during the
inspection.
The facility is currently permitted to discharge wastewater from the water treatment plant (WTP).
Structures associated with the WTP (in order), include:
o 16 active groundwater supply wells;
o Three (3) sand filters, set up in parallel;
o One (1) anti-scalant injection system (phosphoric/phosphonic aid) with three (3) chemical
metering injection pumps (1 for each RO system);
o Two (2) primary reverse osmosis (RO) systems at 0.101 mgd each with reject -water totalizer;
o One (1) polishing RO system at 0.086 mgd with reject -water flow totalizer;
o Gas chlorine and gas ammonia disinfection systems;
o One (1) potable water storage tank at 0.400 million gallons; and,
o Appurtenant piping to the outfall and effluent sample point.
A review of monitoring records indicates that the system has had nine (9) Notice of Violations issued
during this permit period (i.e., since 1/1/2018) for exceeding daily and or monthly average limits for
arsenic. It should be noted that results of samples obtained on 7/12/2022 indicated the presence of
10 pg/L total copper; however, no actions were required as a result of these levels although the daily
limit was 5.80 pg/L. No enforcement actions have been taken since prior to the issuance of the prior
permit.
Although not required, it is recommended that an operator obtain certification for a physical/chemical
wastewater certification. It is also recommended that the container(s) of anti-scalant be placed within
a secondary containment vessel to prevent impacts of accidental release(s).
The operator was very knowledgeable of the facility and the facility seemed to be well maintained.
Records were reviewed and found to be detailed and complete. The facility is compliant with the
terms and conditions of the permit. Please review the comment sections of the inspection report for
more details.
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DocuSign Envelope ID: 3930C3C3-782E-4D45-A1 FF-670296DO4869
Permit: NCO085553 Owner - Facility: Bald Head Island WTP
Inspection Date: 12/08/2023 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
0
❑
❑
❑
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 current permit was issued 12/8/2017, became effective 1/1/2018 and expired
11/30/2022. The system submitted a renewal application on November 28, 2022. A
draft version of the permit was issued 12/6/2023. Conditions of the permit include
sampling the effluent for metals, quarterly acute toxicity sampling and upstream and
downstream sampling. The draft permit no longer has daily and monthly average limits
for total copper nor total zinc. Please refer to the summary for a list of structures within
the facility.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
0
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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?
0
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
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DocuSign Envelope ID: 3930C3C3-782E-4D45-A1 FF-670296DO4869
Permit: NCO085553 Owner - Facility: Bald Head Island WTP
Inspection Date: 12/08/2023 Inspection Type: Compliance Evaluation
Record Keeping
Yes No NA NE
Comment: On-line DMRs as well as printed DMRs were viewed prior to and durinq the inspection
respectively. Also reviewed were 10/24/23 chronic toxicity sampling records, field
instrument calibration records, bench sheets and a daily log book. All required logs
were found to be comprehensive and complete. The system is classified as PCNC
(Physical/Chemical Not Classified) and does not require a certified operator. However,
it is recommended that a person with the system obtain this certification to obtain
training for these processes.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other pa ra mete rs(exclud ing 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
❑
❑
0
❑
degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment: Bald Head Island holds Field Certification #5301 for screeninq of total residual chlorine
PH, temperature and dissolved oxygen. Remaining required analyses are performed by
Envirochem. Samples are obtained by system staff, placed in sealed containers and
cooler, labeled and taped for security, placed on the ferry and then picked up on the
mainland by lab staff. The system staff continue to investigate other options for
ensuring secured methods of transporting samples to the lab for analysis. All sampling
associated with the current and draft permits are grab samples.
Flow Measurement - Effluent
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: The effluent flow meter, which is located prior to the effluent sample port was calibrated
by J. S. Dismuke Co., Inc. on 11/14/2023. Flow has averaged
—0.05 mqd since 2022
and —0.033 mqd during the cooler months during the same
period. Flow has generally
increased approximately 5% each year since 2015.
Effluent Sam plinq
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
❑
0
❑
Is sample collected below all treatment units?
0
❑
❑
❑
Is proper volume collected?
0
❑
❑
❑
Is the tubing clean?
❑
❑
0
❑
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DocuSign Envelope ID: 3930C3C3-782E-4D45-A1 FF-670296DO4869
Permit: NCO085553 Owner - Facility: Bald Head Island WTP
Inspection Date: 12/08/2023 Inspection Type: Compliance Evaluation
Effluent Sam plinq Yes No NA NE
# 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: All sampling with the prior and draft permit are grab samples. The effluent sampling
location is a spigot along the reject discharge line within the RO building.
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?
❑
❑
■
❑
Comment: The effluent pipe leads from the WTP, follows street riqht-of-ways and discharqes at a
bulkhead wall within the Bald Head Marina basin channel. The pipe was visible during
the inspection and liquid emanating from the pipe appeared clear with no visible solids
or foam.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑
and sampling location)?
Comment: The current and draft permits require upstream and downstream sampling. Upstream
and downstream samples are required to be grab samples and are obtained with a
Dole to obtain further from the bank of the channel.
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?
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ■ ❑ ❑
■ ❑ ❑ ❑
❑ ❑ ❑ ■
❑ ❑ ❑ ■
Comment: The system has a generator to provide stand-by power to both the WTP and the
WWTF. The generator is tested under loaded condition by system staff weekly. The
system reportedly contracts with Power Pro Tech to perform regular maintenance to the
generator.
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Page# 5

DocuSign Envelope ID: 3930C3C3-782E-4D45-A1 FF-670296DO4869
Permit: NCO085553 Owner - Facility: Bald Head Island WTP
Inspection Date: 12/08/2023 Inspection Type: Compliance Evaluation
Operations & Maintenance
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: No comment.
Yes No NA NE
❑ ❑ ■ ❑
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