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HomeMy WebLinkAboutNC0024911_Compliance Evaluation Inspection_20240308 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. March 8, 2024 Thomas E Hartye Metropolitan Sewerage District of Buncombe County North Carolina Email: thartye@msdbc.org SUBJECT: Compliance Inspection Report French Broad River WRF NPDES WW Permit No. NC0024911 Buncombe County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the French Broad River WRF 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. NC0024911. 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 me at 828-296-4667 or via email at lauren.armeni@deq.nc.gov. Sincerely, Lauren Armeni, Environmental Specialist II Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Bart Farmer (ORC) Schuyler Taylor (BORC) DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 EPA United States Environmental Protection Agency Washington, D.C. 20460 Water Compliance Inspection Report Form Approved. OMB No. 2040-0057 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 N 52 NC0024911 24/02/22 C S31112171819 20 21 66 Inspection Work Days Facility Self-Monitoring Evaluation Rating B1 QA ----------------------Reserved------------------- N67707172 73 74 75 80 Section B: Facility Data Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include POTW name and NPDES permit Number) French Broad River WRF NC Hwy 251 Asheville NC 28814 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:00AM 24/02/22 18/10/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Bart T Farmer/ORC/828-225-8224/ Other Facility Data 04:00PM 24/02/22 22/12/31 Name, Address of Responsible Official/Title/Phone and Fax Number Thomas E Hartye,2028 Riverside Dr Asheville NC 288043054/General Manager/828-225-8399/ Contacted Yes Section C: Areas Evaluated During Inspection (Check only those areas evaluated) Permit Flow Measurement Operations & Maintenance Records/Reports Self-Monitoring Program Sludge Handling Disposal Facility Site Review Effluent/Receiving Waters 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 Melanie Kemp DWR/ARO WQ/ - - / Lauren E Armeni DWR/ARO WQ/828-296-4500/ Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page#1 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 3/8/2024 3/11/2024 3/11/2024 NPDES yr/mo/day 24/02/22 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, Melanie Kemp, and Daniel Boss, with the Asheville Regional Office (ARO), conducted a Compliance Evaluation Inspection of the French Broad River WRF on February 22, 2024. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0024911. Bart Farmer (ORC), Schuyler Taylor (BORC), Ken Stines (Director of Maintenance), Chad Ledford (Pretreatment Supervisor), and Patrick Smith (Pretreatment Laboratory Specialist) were present and assisted in the inspection. Additionally, the EPA was conducting an inspection audit of the ARO during this inspection. Chris McHugh (Environmental Engineer) and Asher Sampong (Physical Scientist) were present from the EPA. Overall, the facility is very well-maintained and paperwork is incredibly organized and thorough. The following is additional information obtained prior to and during the inspection: Permit: The permit is currently under renewal. The draft permit lists the schedule of compliance for the new ammonia limits - interim limits will be effective December 31, 2035, and final limits will be effective December 31, 2037. In order to achieve these ammonia limits, the plant will undergo a complete upgrade. Mr. Farmer indicated that they are in the process of working with engineers to figure out a new treatment process to replace the RBCs, considering they will keep their current plant online and use the same footprint when building the new plant. Per the current permit effective October 1, 2018, Special Condition A.(8) discusses the Ammonia Schedule of Compliance. The last progress report was submitted to the DEQ on December 18, 2023. The High Rate Primary Treatment (HRPT) system was originally set to be completed on October 28, 2020; however, due to delays and supply chain shortages,the introduction of wastewater to the system began on December 9, 2021. Mr. Taylor indicated that the system has not met their expectations, since they were told each train could handle 42 MGD, however 15 MGD is the maximum flow they can sustain with minimal ballast loss. They are still in the process of testing it for at least two more years. Fine Screens/Grit Removal/High Rate Primary Treatment: The fine screens are prior to grit removal. The fine screen trains are rotated weekly. During high flow events, two trains are used. Each train is rated for 40 MGD. Debris from the fine screens goes to a dumpster. After the fine screens, flow goes to grit removal and then to the High Rate Primary Treatment (HRPT) system, where it's introduced to each of the two trains. Ultimately, the primary biosolids created from the HRPT system and the intermediate clarifier biosolids are combined using a mixer before both are sent to the gravity thickeners. Mr. Taylor provided Ms. Armeni a detailed description of the HRPT system process via email. It was noted that after grit removal, flow can go to the HRPT system, can be diverted to the EQ basins if needed, or can go straight to the first set of RBCs if the HRPT system is not being used. Solids Handling Equipment: The sludge from the gravity thickeners mixes with a polymer and then goes to the belt press. The belt press constantly runs, and since there are two belt press units they are alternated once per shift. After the sludge is belt pressed it's incinerated on-site. Incinerator ash is thickened on-site via a gravity ash thickener and pumped to an on-site lagoon where groundwater is monitored. The preheat burner and heat exchanger will be replaced for the incinerator this year. Flow Measurement - Effluent: It is recommended to wash off the staff gauge so that flow can be verified. NC0024911 17 (Cont.) Page#2 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 Permit:NC0024911 Inspection Date:02/22/2024 Owner - Facility: Inspection Type: French Broad River WRF 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? The permit is currently under renewal. See summary for details.Comment: Operations & Maintenance Yes No NA NE Is the plant generally clean with acceptable housekeeping? Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge Judge, and other that are applicable? Some process controls analyzed include checking microbes, pH, DO, and using the sludge judge to check the sludge blanket. The entire plant has SCADA, which gives staff full automated control of the WRF. Comment: 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? Page#3 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 Permit:NC0024911 Inspection Date:02/22/2024 Owner - Facility: Inspection Type: French Broad River WRF Compliance Evaluation Record Keeping Yes No NA NE 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? All files were well organized, and the facility had both hardcopy and digital files.Comment: Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical Are the bars adequately screening debris? Is the screen free of excessive debris? Is disposal of screening in compliance? Is the unit in good condition? There are two bar screens with 1/2" spacing that automatically alternate. Mr. Farmer indicated that they are planning maintenance on the bar screens in 2028. Debris from the bar screens dewaters and then goes to a dumpster, which is emptied daily. Comment: Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? Is the wet well free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Is SCADA telemetry available and operational? Is audible and visual alarm available and operational? The audible alarm was operational, but there was no visual alarm. The audible alarm is sufficient since the pump station is connected to SCADA. The wet well is under the bar screen. There are portable pumps available if the influent pumps were to fail. Comment: Influent Sampling Yes No NA NE # Is composite sampling flow proportional? Is sample collected above side streams? Is proper volume collected? Is the tubing clean? Page#4 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 Permit:NC0024911 Inspection Date:02/22/2024 Owner - Facility: Inspection Type: French Broad River WRF Compliance Evaluation Influent Sampling Yes No NA NE # Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? Is sampling performed according to the permit? Influent composite sampling is time-based. A certified, NIST thermometer is used in the sampling fridge. Mr. Ledford indicated that it was time to recertify the thermometer. At the time of the inspection, the thermometer read one degree Celcius. On March 5, 2024, Mr. Taylor sent Ms. Armeni a text indicating that they received new NIST-certified thermometers and they are now in the influent and effluent sampling fridges. He also said they started a 6-month protocol for calibration of the thermometers. Comment: Grit Removal Yes No NA NE 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? There are perforated-plate fine screens after the pump station, which consist of three units with 1/4" openings. After the fine screens is the Pista vortex grit removal system, which consists of two units. One unit is online at a time, and the units act as a centrifuge to take out the grit. The grit is automatically disposed of in dumpsters. The High Rate Primary Treatment is after the grit removal. See summary for details. Comment: Equalization Basins Yes No NA NE Is the basin aerated? Is the basin free of bypass lines or structures to the natural environment? Is the basin free of excessive grease? Are all pumps present? Are all pumps operable? Are float controls operable? Are audible and visual alarms operable? # Is basin size/volume adequate? Each EQ basin has a capacity of 2.1 million-gallons. When the EQ basins are used, the flow is slowly put back into the plant using the splitter box. When the flow of the plant gets to 60 MGD, flow automatically gets diverted to the EQ basins. There are floats on the EQ basins, but they are connected to SCADA and not audible/visual alarms. Comment: Rotating Biological Contactor Yes No NA NE Page#5 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 Permit:NC0024911 Inspection Date:02/22/2024 Owner - Facility: Inspection Type: French Broad River WRF Compliance Evaluation Rotating Biological Contactor Yes No NA NE Is the unit free of excessive sloughing of growth? Is the unit operational? Are media panels in good condition? There are 152 RBCs total (1st stage has 44 units, 2nd stage has 72 units, and 3rd stage has 36 units). Mr. Farmer indicated that eighteen of them were broken, so they got rid of those two weeks ago. He also said that sometimes the growth on the RBCs is uneven, so when one gets lopsided they can use water to help it rotate. Flow from the 3rd RBC stage is pumped to the intermediate clarifiers. The RBC trains are cleaned by shutting them down and filling them up with chlorinated water. Three trains are cleaned each quarter. Comment: Secondary Clarifier Yes No NA NE 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 ¼ of the sidewall depth) At the time of the inspection, the sludge blanket was 6" out of 12' of water. There was evidence of short circuiting throughout the troughs. Mr. Taylor indicated that the SW trough will be replaced first this year, and the rest will eventually be replaced. Comment: Solids Handling Equipment Yes No NA NE Is the equipment operational? Is the chemical feed equipment operational? Is storage adequate? Is the site free of high level of solids in filtrate from filter presses or vacuum filters? Is the site free of sludge buildup on belts and/or rollers of filter press? Is the site free of excessive moisture in belt filter press sludge cake? The facility has an approved sludge management plan? Page#6 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 Permit:NC0024911 Inspection Date:02/22/2024 Owner - Facility: Inspection Type: French Broad River WRF Compliance Evaluation Solids Handling Equipment Yes No NA NE The sludge from the intermediate clarifiers goes straight to the gravity thickeners when the HRPT system is offline. When it is online, primary biosolids created from the system and the intermediate clarifier biosolids are combined using a mixer before both are sent to the gravity thickeners. A sludge judge is used in the gravity thickeners daily. Sludge from the gravity thickeners goes to the belt press, where it presses the sludge to a moisture of around 22-24%. See summary for details. Comment: Filtration (High Rate Tertiary)Yes No NA NE Type of operation:Cross flow 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? The tertiary filters consist of sixteen AASI AquaDisk units that are cloth-media filter disks. This type of system uses a vacuum that sucks solids off of the filters during the backwash cycle. The backwash goes to the gravity thickeners. This type of system does not have clear wells; instead, the effluent from the filters travels directly to the start of the chlorine contact chamber. Comment: Disinfection-Liquid Yes No NA NE Is there adequate reserve supply of disinfectant? (Sodium Hypochlorite) Is pump feed system operational? Is bulk storage tank containment area adequate? (free of leaks/open drains) 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? The disinfection building consists of four, 15,000-gallon sodium hypochlorite tanks. Mr. Taylor indicated that they go through a tank every 10-15 days. Chlorine residual is checked every three hours. 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? Comment: Page#7 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 Permit:NC0024911 Inspection Date:02/22/2024 Owner - Facility: Inspection Type: French Broad River WRF Compliance Evaluation De-chlorination Yes No NA NE Are the tablets the proper size and type? Are tablet de-chlorinators operational? Number of tubes in use? Comment: Flow Measurement - Effluent Yes No NA NE # 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? The effluent flow meter was last calibrated on December 11, 2023 by Instrumentation Services, Inc. The flow meter is calibrated every six months. See summary for details. 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? The effluent leaves the plant and goes into the hydro flume and mixes with river water, which then travels downstream through the turbines to help in power generation. At the time of the inspection, the effluent pipe exiting the plant could not be seen because it is under water. Comment: Effluent Sampling Yes No NA NE 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)? At the time of the inspection, the thermometer in the sampling fridge read 2 degrees Celcius. The aliquot volume was checked during the inspection and it was 100 mL for every 250,000 gallons of flow. Comment: Standby Power Yes No NA NE Page#8 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505 Permit:NC0024911 Inspection Date:02/22/2024 Owner - Facility: Inspection Type: French Broad River WRF Compliance Evaluation 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? 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? There are two, 1 MW back-up generators and one, 2 MW back-up generator. The two, 1 MW generators can power the entire plant as well as the 2 MW generator. The generators run under load once a month. A full load test is conducted annually. The generators automatically exercise weekly. Grace Fuel fills up the diesel fuel tanks as needed. Comment: Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, and sampling location)? Comment: Page#9 DocuSign Envelope ID: 54AE7255-90B6-4B0C-8327-92C5BF2EB505