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HomeMy WebLinkAboutNC0039420_Virginia_DOT_I-77_Rest_Area_CEI_NOV_Letter_20240404ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Virginia DOT Attn: Allen Campbell 1401 East Broad Street Richmond, VA 23219 NORTH CAROLINA Environmental Quality April 4, 2024 SUBJECT: Compliance Evaluation Inspection & Notice of Violation NOV Tracking Number: NOV-2024-LC-0001 Virginia DOT/1-77 Rest Area Wastewater Treatment Plant NPDES Permit Number: NCO039402 Surry County Dear Mr. Campbell: On March 28, 2024, Division of Water Resources staff Ron Boone, conducted a routine compliance evaluation inspection at the Virginia DOT/1-77 Rest Area Wastewater Treatment Plant, NPDES permit NC0039420. Operator in Responsible Charge (ORC) Chris Marion was present for the inspection. A review of records, data, treatment components, structures, and the outfall was completed. This inspection reflected non-compliance with the subject permit. Mr. Boone noted the following violations: 1. The permittee does NOT possess a current field laboratory certification as required by Part II, Section D, Paragraph 4, of the permit. 2. Effluent composite sampling is NOT collected flow proportionally as required by Part 11, Section A, of the permit. You can find the inspection details in the attached Water Compliance Inspection report. Other than these two violations the plant appears to be run very well by the operators. The effluent quality appears to be excellent. Please take immediate action to correct the two violations listed above. Mr. Boone has already initiated the process of correcting the missing laboratory certification by contacting our laboratory certification branch and including Mr. Marion in the email conversation. As far as flow proportional sampling is concerned, Virginia DOT should take the necessary steps to make the Moan D_'E' North Carolina Department of Environmental Quality I Division of Water Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 I Winston-Salem, North Carolina 27105 336.776.9800 effluent composite sampling flow proportional or request an official waiver from this requirement. We expect that you should be able to have both violations corrected, or at a minimum, corrective actions identified and initiated, no later than 90 days after receiving this notice. Please feel free to contact Mr. Boone by phone at 336.776.9690, or by email at ron.boone@deg.nc.gov, with any questions or concerns you may have. Sincerely, DocuSigned by: OD2D3CE3F167456_. Jennifer F. Graznak, Assistant Regional Supervisor Water Quality Regional Operations Section Winston-Salem Regional Office Division of Water Resources, NCDEQ Attachments: Water Compliance Inspection Report cc: Chris Marion, Operator in Responsible Charge, via email REQ� North Carolina Department ofEnvironmental Quality I Division ofWater Resources Winston-Salem Regional Office 1 450 W. Hanes Mill Rd, Suite 300 1 Winston-Salem, North Carolina 27105 NORTH CAROLINA 336.776.9800 naparMeM of EmironmanW 9uallly 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 NC0039420 111 121 24/03/28 I17 18 LC] I 19 I s I 20L] 21111I I I I I I I II I I I I I I I I I I I I I I I I I I I I I I I II I I I I 1166 Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved ------------------- 67 I 72 I ni I 71 I 74 79 I I I I I I I80 701 I 71 I LL -1 I I 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 Dermit Number) 10:OOAM 24/03/28 19/03/01 Virginia DOT/1-77 Rest Area 1-77 NC-Va State Line Car Exit Time/Date Permit Expiration Date Pine Hall NC 27042 12:OOPM 24/03/28 24/02/28 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Christopher S Marion/ORC/336-786-3597/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Allen Campbell,1401 E Broad St Richmond VA 23219//804-786-0668/8047860652 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 Ron Boone Docusigned by: DWR/WSRO WQ/336-776-9690/ Ostia& Boone, 4/4/2024 B20FSDD5F2A3460... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Docusigned by: _D- "-4. DWR/WSRo 336-776-9695 4/4/2024 Fj '--OD2D3CE3F1B7456.- EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO039420 I11 12I 24/03/28 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) On March 28, 2024, Division of Water Resources staff, Ron Boone, conducted a routine compliance evaluation inspection at the Wastewater Treatment Plant for the Virginia DOT/1-77 Rest Area, NPDES permit NC0039420. Operator in Responsible Charge (ORC), Chris Marion, was present during the inspection. A review of records, data, treatment components, structures, and the outfall was completed. This inspection reflected non-compliance with the subject permit. The permit was issued in December 2018 and expired in February 2024. The permit renewal application was received by the Division in November 2023 and is currently under review for reissuance. Outfall 001 for this plant discharges to Naked Run, a Class WS-IV, trout stream in the Yadkin -Pee Dee River Basin. Flow enters the plant passing first through the solids screening basket, which is emptied by hand. The basket appears to be in good condition. Flow then goes to the aeration basins. Only one of three treatment trains is currently in operation. The others are used for storage as needed. The operators are currently using heat blankets to cover all treatment processes, which entraps heat to improve treatment and also protects the units from exterior falling matter, such as leaves. It was difficult to see the mixed liquor but what was observed looked good and had a healthy activated sludge odor. From the aeration basins, the wastewater flows to the secondary clarifiers. The overflow of the clarifier was very clear, with no solids and very little foam. The weirs appeared level and scum removal appeared adequate. No apparent mechanical issues were noted with any of the aeration basins and clarifiers. Wastewater then flows from the clarifier(s) to the UV system and backup chlorination and dechlorination units. All units are currently in use because the UV system's intensity sensor is down, and operators are unable to determine whether UV disinfection is sufficient without it. The intensity sensor has been ordered, according to operators. The chlorine/dechlori nation systems are tablet type. The proper tablets are being used, and two chlorine tubes and three dechlorination tubes are currently in use. Effluent flow is measured with a Siemens Milltronics OCM III meter/recorder, which was last calibrated 3/27/2024. Effluent composite sampling is NOT currently flow proportional. This must be corrected immediately or you must request a waiver from the Division from using flow proportional composite sampling. The right of way to the outfall is completely clear and fully accessible. The discharge of treated wastewater to Naked Run is very clear with no solids or foam formation. All required records were evaluated during the inspection including laboratory results and chains of custody along with matching discharge monitoring reports, visitation logs, operation and maintenance logs, sludge records, etc. No discrepancies were noted, however the facility is not currently certified as a field laboratory. Therefore, all field measurements are technically invalid at this point. Please work with the NC Laboratory Certification Branch to obtain the required certification. Wet sludge is pumped and hauled to Mount Airy for disposal. The plant can be operated entirely using the on -site permanent diesel driven generator. The generator is inspected regularly by the operators and receives annual maintenance via contractor. The fuel level is monitored. The generator automatically runs every Tuesday for exercise and to ensure operability. Page# Permit: NCO039420 Inspection Date: 03/28/2024 Owner -Facility: Virginia DOT/1-77 Rest Area Inspection Type: Compliance Evaluation This plant seems very well operated and maintained. The operators appear to be doing an excellent job. The issues for flow proportional sampling and the field lab certification must be immediately addressed. If you have any questions or concerns, please contact Ron Boone by phone at 336.776.9690, or by email at ron.boone@deq.nc.gov. Page# Permit: NCO039420 Inspection Date: 03/28/2024 Owner -Facility: Virginia DOT/1-77 Rest Area Inspection Type: Compliance Evaluation Permit (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: Plant actually has a screening basket, rather than a bar screen. 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? (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? Facility has copy of previous year's Annual Report on file for review? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The operators have several loqs they use to annotate O&M and visitation. Mr. Marion asked Mr. Boone during the inspection whether the logbook was necessary and whether it could be eliminated considering the other logs that they use. Mr. Boone told him he thought the logbook could be eliminated and that they would still be meeting the requirements of the permit using the remaining means of documentation. Page# 4 Permit: NCO039420 Inspection Date: 03/28/2024 Owner -Facility: Virginia DOT/1-77 Rest Area Inspection Type: Compliance Evaluation Laboratory Are field parameters performed by certified personnel or laboratory? Are all other parameters(excluding field parameters) performed by a certified lab? # Is the facility using a contract lab? # 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? Yes No NA NE ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ Comment: None. The facility does not currently have a field laboratory certification. The operator informed Mr. Boone that they are working with Michael Cumbus, with DWR, to obtain the required certification. Mr. Boone emailed Mr. Cumbus on 4/4/24 to get an update on that effort. Effluent Sampling 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)? Comment: Composite sampling is not flow proportional. ❑ ■ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑ and sampling location)? Comment: None Bar Screens Yes No NA NE Type of bar screen a.Manual b.Mechanical ❑ Are the bars adequately screening debris? 0 ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? ■ ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Page# 5 Permit: NCO039420 Owner -Facility: Virginia DOT/1-77 Rest Area Inspection Date: 03/28/2024 Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE Comment: This is a screeninq basket, not a bar screen. 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? ■ ❑ ❑ ❑ Are all pumps present? ■ ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? ■ ❑ ❑ ❑ # Is basin size/volume adequate? ■ ❑ ❑ ❑ Comment: None Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? 0 ❑ ❑ ❑ Are surface aerators and mixers operational? ❑ ❑ 0 ❑ Are the diffusers operational? 0 ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? ■ ❑ ❑ ❑ Is the DO level acceptable? ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) ❑ ❑ ❑ ■ Comment: Operators were using heat blankets over all the units during the inspection to entrap heat inside the treatment process, so, the mixed liquor couldn't be evaluated very well. The small area that could be seen looked good though and no noxious odors were present. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? ❑ ❑ 0 ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? E ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Page# 6 Permit: NCO039420 Inspection Date: 03/28/2024 Owner -Facility: Virginia DOT/1-77 Rest Area Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE Is scum removal adequate? 0 ❑ ❑ ❑ Is the site free of excessive floating sludge? 0 ❑ ❑ ❑ Is the drive unit operational? ❑ ❑ 0 ❑ Is the return rate acceptable (low turbulence)? 0 ❑ ❑ ❑ Is the overflow clear of excessive solids/pin floc? E ❑ ❑ ❑ Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth) ❑ ❑ ❑ Comment: Aqain, heat blankets were beinq used here too but Mr. Boone could see the weirs and the overflow. The weirs appear level and the overflow was very clear and free of solids. Pumps-RAS-WAS Yes No NA NE Are pumps in place? 0 ❑ ❑ ❑ Are pumps operational? 0 ❑ ❑ ❑ Are there adequate spare parts and supplies on site? 0 ❑ ❑ ❑ Comment: None Aerobic Digester Yes No NA NE Is the capacity adequate? 0 ❑ ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming in the tank? ■ ❑ ❑ ❑ # Is the odor acceptable? 0 ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: Records of sludge removal appeared to be complete. Sludqe is hauled to Mount Airy's wastewater treatment plant for disposal. 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? Comment: Meter was last calibrateed 3/27/2024. Disinfection -Tablet Are tablet chlorinators operational? Are the tablets the proper size and type? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 7 Permit: NC0039420 Owner -Facility: Inspection Date: 03/28/2024 Inspection Type: Virginia DOT/1-77 Rest Area Compliance Evaluation Disinfection -Tablet Yes No NA NE Number of tubes in use? 2 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? ❑ ❑ ❑ Comment: None Disinfection - UV Yes No NA NE Are extra UV bulbs available on site? 0 ❑ ❑ ❑ Are UV bulbs clean? 0 ❑ ❑ ❑ 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: UV was in operation during inspection but the intensity sensor is broken and on order so the operators are currently using chlorination and dechlorination simultaneously with the UV to ensure complete disinfection occurs. De -chlorination Type of system ? 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? Are the tablets the proper size and type? Comment: None Are tablet de -chlorinators operational? Number of tubes in use? Comment: None Effluent Pipe 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? Comment: None Yes No NA NE Tablet ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ 3 Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 8 Permit: NCO039420 Inspection Date: 03/28/2024 Owner -Facility: Virginia DOT/1-77 Rest Area Inspection Type: Compliance Evaluation 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: None 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? Comment: Generator runs automatically every Tuesday for a short period of exercise. Yes No NA NE ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 9