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HomeMy WebLinkAboutNC0003875_Compliance Evaluation Inspection_20240222DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 ROr COOPER ELIZABETH S. BISER RICHARD E. ROGERS, JR. NORTH CAROLINA Director Environmental Quality February 23, 2024 Mr. Matt Hamburg American Chrome and Chemicals 5480 Holly Shelter Rd Castle Hayne, NC 28429 SUBJECT: Compliance Inspection Report Castle Hayne Plant NPDES WW Permit No. NC0003875 New Hanover County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Castle Hayne Plant on 2/22/2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0003875. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled "Compliance Inspection Report". Please respond in writing to this office within 60 days of your receipt of this letter regarding your plans or measures to be taken to address the following issues: o Verification that the pumps within the domestic wastewater treatment plant influent pump station have been replaced; o Verification that the tubing leading to the composite sampler for Outfall 001 has been replaced; o Verification that the weirs in the clarifiers for the domestic wastewater system have been cleaned; and o A plan to address corrosion of structures within the domestic wastewater system. It should be noted that as a result of the prior inspection performed on 4/1/2019, it was recommended to provide corrosion coating to treat some of these areas to avoid/delay further damage (see copy of 4/1/2019 inspection report attached). 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 bryan.lievre@deq.nc.gov. Attachments cc: Sean Coury, PE (via email) Upload to Laserfiche Sincerely, DocuSigned by: IM6A2KE126A9394M... Vt, & S&AtG c/Lj—�Ci" Morelia Sanchez -King, Regional Supervisor Water Quality Regional Operations Section Wilmington Regional Office Division of Water Resources, NCDEQ Nwth Carolina Pepao—t orEnvlronmenlal Qa Ilty I [AMsion J Watee Rew—s Wilmington Reglanalow-I 12ICaMIna1D,1,e Eetenslan I W.Wng10 North Ca 11l a25495 91619b ]215 DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 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 IS I 3 I NC0003875 I11 121 24/02/22 I17 18 n 191 G I 201 6 21111111111111111111111111111111111111111111 J 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) 08:30AM 24/02/22 17/09/01 Castle Hayne Plant 5408 Holly Shelter Rd Exit Time/Date Permit Expiration Date Castle Hayne NC 28429 11:40AM 24/02/22 22/08/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Sean T Coury/ORC/910-685-3662/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Kyle Earley, /HSE Manager/910-675-7222/ Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit 0 Flow Measurement 0 Operations & Maintenar Records/Reports Self -Monitoring Progran 0 Sludge Handling Dispos 0 Facility Site Review Effluent/Receiving Wate Laboratory 0 Storm Water 0 Other 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 DocuSigned by: Bryan Lievre $ "zt DWR/VVIRO WQ/910-796-7215/ ,r„�� 2/23/2024 BAF550231BDD428... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: Morella Sanchez -King DWR/WIRO WQ/910-796-7218/ 2/23/2024 tMOVt,�.A. S —�Ct EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. `—A2KE126A9394A6... Page# DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 NPDES yr/mo/day Inspection Type (Cont.) 31 NC0003875 I11 12I 24/02/22 117 18 U Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) A routine compliance inspection of the Castle Hayne Plant was performed on February 22, 2024. The purpose of the inspection was to verify that the facility is operating in compliance with the conditions and limitations specified within Permit NC0003875. Facility staff present during the inspection were Dean Riggs, ORC for the domestic wastewater system as well as Sean Coury, contracted ORC for the Process Wastewater system. The facility is currently permitted for a 0.785 million gallons per day (mgd) process wastewater treatment facility (Process System), a domestic wastewater treatment facility (Domestic System) and a 0.576 mgd quarry supernatant (Quarry System). The Process System discharges at Outfall 001 and includes: - A waste collection storage tank - Six (6) batch reactors - A recirculation/equalization tank - Three (3) hydrocyclones - Three (3) polymer feed systems/thickeners and - Three (3) clarifiers, set up in series - Two (2) pressure sand filters - Optional sulfur dioxide feed The Domestic System has discharges at Internal Outfall 002 (to the Process System waste collection tank) and includes: - A submerged influent duplex pump station with liquid level floats and alarms - A submerged aerated equalization basin with liquid level floats - A flow splitter box - Submerged dual train extended aeration package plants with o Two (2) 10,000 gpd aeration basins o Two (2) clarifiers - A submerged collection tank with pumps - An above ground recirculation tank - Four (4) sand filters (785,000 gpd per 3/7/22 application) - UV disinfection / Tablet chlorination The Quarry System discharges at Outfall 003 and has a pressure sand filter, similar to the two within the Process System. It should be noted that although Outfalls 001 and 003 have the same location on the permit, this is only because flows eventually merge into one pipe downgradient of all treatment and monitoring stations before discharging into the Northeast Cape Fear River. Average Daily flow from Outfall 001 was approximately 0.65 mgd during 2023 and this is also the average daily flow circa 2010. Average daily flow for Outfall 002 was approximately 4,200 gpd during 2023. Discharges from Outfall 003 are intermittent; whereas in 2023, discharges were only reported during the months of January through June with an average daily flow of approximately 0.35 mgd over this period. Since last inspection of 4/1 /2019, the system was issued a Notice of Violation (NOV) for failing to take quarterly sample for total phosphorous and nitrogen at Outfall 003 in March 2021 and two (2) NOVs for failing Whole Effluent Toxicity in August 29021 and May 2022. The staff were very knowledgeable of the facility operations and with the exception of a few items noted herein, the facility seemed to be well maintained. Records were reviewed and found to be detailed, well organized and complete. The facility is generally compliant with the terms and conditions of the permit. Please review the comment sections of the inspection report for more details. Page# DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 Permit: NC0003875 Owner - Facility: Castle Hayne Plant Inspection Date: 02/22/2024 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 8/17/2017, became effective 9/1/2017 and expired 8/31/2022. It should be noted that a renewal application was received 3/7/2022 and on 4/20/2023 the Division approved of a name change from Elementis Chromium to American Chrome and Chemicals. Within the name change it was stated that although the current permit is expired, it has been administratively extended. Although the permit does not list Special Conditions, the permit conditions do require Whole Effluent Toxicity (WET) quarterly sampling of Outfalls 001 and 003. 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 Domestic System was in need of attention, but the Process and Supernatant Systems seemed to be operating and maintained well. The Domestic System showed evidence of corrosion on railings, piping and some of the structures to support walkway grates. The pumps in the influent pump station also need to be replaced in the Domestic System. 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? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Page# 3 DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 Permit: NC0003875 Owner - Facility: Castle Hayne Plant Inspection Date: 02/22/2024 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE (If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified ❑ ❑ 0 ❑ operator on each shift? Is the ORC visitation log available and current? 0 ❑ ❑ ❑ Is the ORC certified at grade equal to or higher than the facility classification? 0 ❑ ❑ ❑ Is the backup operator certified at one grade less or greater than the facility 0 ❑ ❑ ❑ 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 ❑ Comment: On-line DMRs were viewed prior to the inspection and a check was performed of information retained on -site. Electronic copies of greater than 5 years of records are maintained in electronic format. Select random months of lab reports and operator log books were viewed while on -site. The facility has an assigned classification of Physical/Chemical 1 (PC-1). Sean Coury is assigned as the ORC with a PC-1 certification (#991805) and the BORCs for the facility are George Stanley Hansley and Dean B. Riggs who both also maintain a PC-1 certification (#'s 986459 & 995468, respectively). Dean Riggs is the ORC for the Domestic System. 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: The facility has an Industrial lab certification (#208) and is certified to perform tests for chloride, dissolved oxygen, PH, temperature, dissolved, suspended and total residue, hexavalent chromium, total chromium, copper, iron and nickel. The facility utilizes outside laboratories for other analyses such as BOD, ammonia, chronic toxicity, quarterly metals, low level mercury, etc. Temperature within the sample storage compartment for the composite sampler at Outfall 001 was approximately 3°C. Laboratory staff records were readilv available and very well organized. Standby Power Yes No NA NE Is automatically activated standby power available? ❑ ❑ ❑ Is the generator tested by interrupting primary power source? ■ ❑ ❑ ❑ Is the generator tested under load? 0 ❑ ❑ ❑ Was generator tested & operational during the inspection? ❑ 0 ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? ❑ ❑ ❑ Page# 4 DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 Permit: NC0003875 Owner - Facility: Castle Hayne Plant Inspection Date: 02/22/2024 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 ❑ ❑ ❑ power? Is the generator fuel level monitored? ❑ ❑ ❑ Comment: The Domestic System has a dedicated diesel -powered generator which was reportedly capable of operating this entire system. The facility is also equipped with nine other generators for various operations. Each of the generators are maintained by an outside company with quarterly and more thorough yearly maintenance inspections. It should be noted however, that the facility can shut down in severe weather conditions. Other Yes No NA NE Comment: No comment Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? 0 ❑ ❑ ❑ Is the wet well free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? ❑ 0 ❑ ❑ Are all pumps operable? ❑ ■ ❑ ❑ Are float controls operable? ❑ ❑ ❑ Is SCADA telemetry available and operational? 0 ❑ ❑ ❑ Is audible and visual alarm available and operational? ❑ ❑ ❑ Comment: The Domestic System has a submerqed duplex influent pump station with hiqh level alarms. During the inspection both of the pumps were inoperative and the system had installed a separate submersible pump with temporary hosing leading to the EQ basin. Since power had been deactivated to the pumps, the high levels alarms were unable to be tested during the inspection. The ORC indicated that althouqh replacement pumps have been purchased, they had not been installed. Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? 0 ❑ ❑ ❑ Is the basin free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? ■ ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? ❑ ❑ ❑ # Is basin size/volume adequate? ❑ ❑ ❑ Page# 5 DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 Permit: NC0003875 Owner - Facility: Castle Hayne Plant Inspection Date: 02/22/2024 Inspection Type: Compliance Evaluation Equalization Basins Yes No NA NE Comment: The Domestic System has a submerged aerated equalization (EQ) basin with high liquid level floats. The high level floats are connected to a controls system which is manned 24 hours/day, 7 days a week. The Process System has a large waste collection tank at the headworks which also receives effluent from the Domestic System. 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) Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ Comment: The Domestic System has a flow splitter box which is located above the EQ basin and diverts flow to either of the two submerged clarifiers. These clarifier weirs needed to be cleaned of solids and corrosion was observed on some of the metal surfaces. The Process System has three secondary clarifiers set up in series. These weirs appeared to have very little solid buildup. Waste from these clarifiers is sent to the quarry. Filtration (High Rate Tertiary) Type of operation: Is the filter media present? Is the filter surface free of clogging? Is the filter free of growth? Is the air scour operational? Is the scouring acceptable? Is the clear well free of excessive solids and filter media? Yes No NA NE Down flow ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Comment: The Domestic System has four sand filters set up in parallel. The system is set up so that the liquid is continuously recirculated with the recirculation tank, sand filters and UV system. These sand filters are backflushed with backwash water going to the Influent Pump Station. The Process System has two large pressure sand filters and the Quarry System also has a large pressure sand filter. Page# 6 DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 Permit: NC0003875 Inspection Date: 02/22/2024 Owner - Facility: Castle Hayne Plant Inspection Type: Compliance Evaluation Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? 0 ❑ ❑ ❑ Are UV bulbs clean? ❑ ❑ ❑ Is UV intensity adequate? ❑ ❑ ❑ Is transmittance at or above designed level? ❑ ❑ ❑ Is there a backup system on site? 0 ❑ ❑ ❑ Is effluent clear and free of solids? 0 ❑ ❑ ❑ Comment: The Domestic System is equipped with UV disinfection which continuously recirculates from the above -ground recirculation tank, UV system and sand filters. The UV system has four bulbs and the ORC maintains a spare set on -site. The system is equipped with warning lights for bulb outages and sleeves for the bulbs are also replaced with the bulbs. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Number of tubes in use? Is the level of chlorine residual acceptable? Is the contact chamber free of growth, or sludge buildup? Is there chlorine residual prior to de -chlorination? Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Comment: The Domestic system no longer utilizes tablet chlorination. When previously utilized, tablets were inserted into the submerged collection tank prior to the recirculation tank. 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? MOM ill r•7ill rim ill I:I • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ Comment: Flow measurement for the Domestic System is estimated usinq pump hour meter readings in comparison to pump curves. Outfall 001 is equipped with a level sensor in a partial flume and the unit was calibrated 1/12/2024 by Chadwick Instruments. Outfall 003 has a magnehelic flow sensor and this unit is reportedly calibrated annually by system staff. Effluent Sam plinq Yes No NA NE Is composite sampling flow proportional? ■ ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Page# 7 DocuSign Envelope ID: C931830E-21 E6-477F-8FD3-5ED5B53F66B9 Permit: NC0003875 Owner - Facility: Castle Hayne Plant Inspection Date: 02/22/2024 Inspection Type: Compliance Evaluation Effluent Sam plinq Yes No NA NE Is the tubing clean? ❑ 0 ❑ ❑ # 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 0 ❑ ❑ ❑ representative)? Comment: The composite sampler for Outfall 001 is located within a ("Blockhouse") building located west of and between the facility operations and the Northeast Caper Fear River. The composite sampler was inspected and the exterior of the sample tubing was dirty and in need of replacement, but had no kinks and the storage chamber had a dedicated thermometer which indicated a temperature of approximately 3°C. Samples for Outfall 002 are obtained from a sample tap on the pipe after final treatment and by the Domestic System plant before flowing into the Process System waste tank. Samples from Outfall 003 are obtained from a sample tap and second composite sampler located within a building located with the process area. This second composite sampler was off during the inspection as no discharge was occurring. 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: Flow from Outfalls 001 and 003 are combined after the effluent flow meter and sampling station for the Process System. The effluent pipe ends underwater, approximately 60 feet from the southern edge of bank of the Northeast Cape Fear River. The pipe reportedly has no diffuser. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑ and sampling location)? Comment: The current permit requires upstream and downstream sampling of Outfall 001 for weekly grab samples of DO, temperature, conductivity and salinity. The Lower Cape Fear River Monitoring Coalition also monitors 36 locations along the river, including a downstream ebb tide monitoring site at the Castle Hayne Boat Ramp on the east side of NC Hwy 117 at Station B9580000. Page#