HomeMy WebLinkAboutWQ0004910_Compliance Evaluation Inspection_20240221DocuSign Envelope ID: F7A47862-0715-4C5C-BB96-7849B4771348
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
February 21, 2024
CERTIFIED MAIL #: 7020 3160 0000 4109 2588
RETURN RECEIPT REQUESTED
The Honorable Randy Beale
Town of Woodland
Post Office Box 297
Woodland, NC 27897-7161
NOTICE OF VIOLATION & INTENT TO ASSESS CIVIL PENALTY
Tracking Number: NOV-2024-PC-0129
Subject:
Compliance Evaluation Inspection
Permit # WQ0004910
Facility: Town of Woodland WWTF
Northhampton County
Mr. Beale,
On January 30, 2024, Jim Westcott from the Raleigh Regional Office visited your wastewater
treatment lagoon and spray irrigation system to evaluate compliance with the subject permit.
The assistance of Mr. Randy Eaton at the time of the inspection was appreciated.
The facility is permitted for the operation a .0 18 5 million gallon per day (MGD) wastewater
treatment and irrigation facility consisting of a Toshiba influent magmeter; a 6-acre primary
lagoon; a 4-acre storage lagoon; liquid sodium hypochlorite disinfection; a lift station with two
300 gallon per minute (GPM) pumps with standby power provisions and high water alarms;
approximately 12,440 linear feet (LF) of 8-inch force main; three 740 GPM pumps; a flow
measuring device; a 53 acre spray irrigation area with ten fields; and all associated piping,
valves, controls, and appurtenances with no discharge of wastes to surface waters.
The permit, which was issued June 21, 2021, is effective through October 31, 2027. Division
records indicate the required annual fee for the period ending August 31, 2024, due September
01, 2023, has been paid.
Inspection criteria consisted of the following:
Review of permit conditions.
Evaluation of facility information and wastewater collection and Lagoon system.
NORTH CAROLINA � �
North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 1 3800 Barrett Drive I Raleigh, North Carolina 27609
919.791.4200
DocuSign Envelope ID: F7A47862-0715-4C5C-BB96-7849B4771348
• Review of logbook, operation and maintenance (O&M) Plan, calibration records and
Non -Discharge Monitoring Report (NDMR) and Non -Discharge Application Report
(NDAR-1) .
• On -site inspection of lagoon wastewater system and distribution components.
Findings during the inspection were as follows:
The system is composed of a 6-acre primary lagoon where solids separation occurs and a 4-
acre storage lagoon and 10 spray fields. The flow from the primary lagoon discharges through a
screened intake line and transfers flow by gravity to the secondary lagoon where the treated
flow discharges from a submerged line to a chlorine contact chamber where an interlocked
peristaltic pump delivering a 0.125 solution of sodium hypochlorite which is added prior to
discharge to each field. Each zone contains 13 spray heads. Each spray field is controlled by a
Koyo Direct logic 06 controller programmed to discharge flow every 30 minutes at 13-18
thousand gallons per field. Discharge flows are recorded by a Greyline instruments doppler
flow meter. Three 750 Hp General Electrical Induction Motors/pumps supply flow to each
spray field.
The perimeter fencing surrounding the facility spray fields, storage lagoons and discharge
pump/contact tank was secured.
The freeboard level(s) in both the primary and secondary lagoon was -26". Lagoon freeboard
levels are measured daily as well as the required weekly pH and chlorine residual.
The three main collection priority lines are checked monthly. The four main lift stations contain
a daily log recording of run time hours and visual observations. Station # 1 records the flow
from the town. An engineering assessment of the town's wastewater collection system was
conducted in 2020. The Town of Woodland recently received a grant for improvements to the
collection system stemming from inflow and infiltration concerns. Additionally, the town
received a grant from the state for cleaning both lagoon(s) and the receiving station.
The primary lagoon has a large amount of visual material buildup at the Southeast corner and
the suspended intake lines have holes on the top of the pipe which need replacement.
The current operator in responsible charge (ORC) is Raymond Eaton, and the designated
backup is James Pridget.
The daily operations log and daily facility checkoff form(s) were complete.
An O&M manual and spill response plan was available at the time of inspection.
The main lift station was recently completely redesigned/rebuilt in 2023 containing a new
drywell and two new Gorman Rupp T Series influent pump(s).
A 35kW generator serves as backup power for the main collections lift station connected to a
telemetry system. The genset cycles each Monday.
A Toshiba influent Magnetic flow meter and a Greyline Instruments DFM-5.0 Doppler effluent
flow meter measures flow. The Toshiba inline magmeter was installed November 2023 and
effluent Doppler flowmeter was last calibrated in 2022.
Permit required lab analysis is conducted by Waypoint Analytical. Measurement of pH and
chlorine residual is conducted on site.
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly
DocuSign Envelope ID: F7A47862-0715-4C5C-BB96-7849B4771348
The Annual Standard Soils fertility analysis is conducted by the North Carolina Department of
Agriculture and Consumer service (NCDA & CS) and samples were last collected during 2022.
Records were not available for review.
The GW-59 analysis is conducted by Waypoint Analytical. Reports were not available at the
time of inspection.
Each of the ten spray field zones consist of a total of 13 - 2" spray heads operated for a total of
30 minutes intervals at a total flow +/- 1000 GPM. The field was in good condition and had no
signs of runoff or ponding.
Monitoring wells MW-1, MW-3, MW-6, MW-8, and MW-9 were located and secured. The last
samples drawn for analysis were in January 2024, by Waypoint Analytical.
No residuals have been removed from the facility on record since 1974.
NDMR and NDAR-1 reports have not been submitted as required during the year 2023.
IV. MONITORING AND REPORTING REQUIREMENTS
Condition IV.5 states the Permittee shall maintain records tracking the amount of effluent
irrigated [15A NCAC 02T.108C].
Condition IV. 7 states that three copies of all monitoring data (as specified in Conditions IV.3. and
IV.4.) on form NDMR for each PPI (as specified in Conditions IV 5 and IV.6.) on form NDAR-1 for
every site in attachment B shall be submitted on or before the last day of the following month. If
no activities occurred during the monitoring month, monitoring reports are still required
documenting the absence of the activity. [15A NCAC 02T.105(1)]. Within 30 dazes of receipt of
this letter, please submit the 2023 Non -Discharge monitoring reports and the Non -
Discharge Application Reports to this office.
Condition IV.8 states the Permittee shall maintain a record of all residuals removed from this
facility. This record shall be maintained for five years and be made available to the division
upon request. [15A NCAC 02T .0508(B)] Within 30 dazes of receipt of this letter, please
indicate the status and anticipated timeline for meeting this required permit condition
to ensure residuals are disposed of in accordance with [15A NCAC 02T.1100].
Condition IV.11 states two copies of the monitoring well sampling and analysis results shall be
submitted on a compliance monitoring form (GW-59), along with attached copies of laboratory
analyses, on or before the last working day of the month following the sample month.
Within 30 days of receipt of this letter, please provide the previous five years of GW-59
forms to this office. [15A NCAC 02T.0105(m)].
Condition IV.13 states an annual representative soils analysis (i.e., Standard Soil Fertility
Analysis) shall be conducted on each irrigation site listed in attachment B.
Within 30 days of receipt of this letter, please provide the previous five years of results
to this office. [15A NCAC 02T.0108 (c)].
Requested Response:
Within 30 days of the receipt of this letter, prepare a written plan providing a detailed
description of how you will bring the facility into compliance with the permit. This plan should
include a detailed schedule for completion for all the items listed below in addition to those
highlighted in bold in the previous section. Items that can be completed prior to submittal of
��� North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
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DocuSign Envelope ID: F7A47862-0715-4C5C-BB96-7849B4771348
this plan should be completed and documented within the compliance plan.
1. Develop and implement a program to regularly measure the accumulation of solids
within the treatment basin. If sediments are found to have reduced the storage
capacity of the basin below that specified within the permit, develop a corrective action
for removal and proper disposal of the solids.
2. Provide the Division of Water Resources inspector with the required documents listed in
the previous section, and make sure these are available on site.
A Notice of Violation/Intent to Issue Civil Penalty is being issued for the noted violations of
North Carolina General Statute (G.S.) 143-215.1 and the facility's Non -discharge Permit.
Pursuant to G.S. 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 issued pursuant
to G.S. 143-215.1.
If you wish to provide additional information regarding the noted violation, request technical
assistance, or discuss overall compliance please respond in writing within ten (10) business
days after receipt of this Notice. A review of your response will be considered along with any
information provided in support of this response. You will then be notified of any civil penalties
that may be assessed regarding the violations. If no response is received in this Office
within the 10-day period, a civil penalty assessment may be prepared.
Corrective action 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. If the violations are of a continuing nature, not
related to operation and/or maintenance problems, and you anticipate corrective action
activities, then you may wish to consider applying for a Special Order by Consent.
Please continue to periodically inspect and evaluate the wastewater spray irrigation system
components are properly maintained and operating as designed. Maintain all associated
operational records onsite for a period of fives as required by the subject permit.
If you have questions or comments about this inspection or the requirements to take corrective
action (if applicable), then please contact Jim Westcott at james.westcott(i ,ncdenr. og_v or 919-
791-4247.
Sincerely,
IA
CADocuSigned by:
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Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
Cc: Laserfiche
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
naparMeM of EmironmanW 9uallly
DocuSign Envelope ID: F7A47862-0715-4C5C-BB96-7849B4771348
REQ5 North Carolina Department ofEnvironmental Quality I Division ofWater Resources
512 North Salisbury Street 1 1611 Mail Service Center I Raleigh, North Carolina 27699-1611
NORTH CAROLINA 919.707.9000
onparhnem of EmironmanW 9uallly