NC0068888_Compliance Evaluation Inspection_20240319

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
Bill Trudnak, Public Works Director
Town of Dallas
210 N Holland Street
Dallas, NC 28034
SUBJECT: Notice of Deficiency
Compliance Evaluation Inspection
Town of Dallas WWTP
NPDES Permit No. NCO06888
Gaston County
Tracking No. NOD-2024-PC-0049
Dear Mr. Trudnak:
NORTH CAROLINA
Environmental Quality
March 19, 2024
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject
facility on March 14, 2024, by Mr. Wes Bell of this Office. This Office would like to thank the Operator -in -Responsible
Charge (ORC) for his cooperation and assistance that was provided throughout this inspection. In addition, please advise the
facility's Operator -in -Responsible Charge (ORC) of our findings by forwarding a copy of the enclosed report.
This report is being issued as a Notice of Deficiency (NOD) due to the Town's failure to complete and submit the 2023
Performance Annual Report which is a violation of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-
215.1. Please note that G.S. 143-215.6A provides for a civil penalty of not more than twenty-five thousand dollars
($25,000.00), or twenty-five thousand dollars ($25,000.00) per day when the violation is of a continuing nature, against any
person either 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.
It is requested that a written response be submitted to this Office by April 9, 2024, detailing the actions taken to complete
and submit the 2023 Annual Performance Report. In addition, the Town has submitted four late eDMRs during the previous
twelve-month period. The response should also include the actions taken by the Town to ensure all future eDMRs are
submitted on time. In responding, please address your comments to the attention of Mr. Wes Bell.
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.663,1699

Should you have any questions concerning this report, please do not hesitate to contact Mr. Bell at [phone] or at
[e-mail].
Enclosure: Inspection Report
Cc: NPDES Program Files - Laserfiche
Sincerely,
DocuSigned by:
A wNN,uft
F161 F669A2D84A3...
Andrew H. Pitner, P.G., Regional Supervisor
Water Quality Regional Operations Section
Mooresville Regional Office
Division of Water Resources, NCDEQ
North Carolina Department of Environmental Quality I Division of Water Resources
Mooresville Regional Office 1 610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115
704.6631699

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 NCO068888 111 121 24/03/14 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 I r6
Inspection
Work Days Facility Self -Monitoring Evaluation Rating B1 QA ---------------------- Reserved -------------------
67
2.0 701d I 71 I„ I 72 I r., I 71 I 74 79 I I I I I I I80
L—I ty L-1 I I
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)
09:40AM 24/03/14
20/07/01
Dallas WWTP
704 E Holly St
Exit Time/Date
Permit Expiration Date
Dallas NC 28034
12:40PM 24/03/14
25/01/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
Michael Eugene Stafford/ORC//
Name, Address of Responsible Official/Title/Phone and Fax Number
Contacted
Ben Blackburn,210 N Holland St Dallas NC 28034/Interim Town
Manager/704-922-3176/ 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
Wes Bell DocuSigned by: DWR/MRO WQ/704-235-2192/ 3/18/2024
A61696D90=437...
&r&Qr&RVtviewer Agency/Office/Phone and Fax Numbers Date
Signature of MaFrX,4"
Andrew Pitn H P44-iPWR/MRO WQ/704-663-1699 Ext.2180/
3.19.24
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page#

NPDES yr/mo/day Inspection Type
NCO068888 I11 12I 24/03/14 117 18 i c i
(Cont.)
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Record Keeping Section cont'd:
Discharge Monitoring Reports (eDMRs) were reviewed for the period January 2023 through
December 2023. Weekly and monthly average effluent TSS violations were reported in April 2023.
The March, October and December 2023 and January 2024 eDMRs were submitted late. Please be
advised that eDMRs must be submitted to the Division no later than the last calendar day of the
month following the completed reporting period as required by the NPDES Permit. All above -noted
violations will be separately addressed by the Division through the issuances of a Notice of
Deficiency, Notice of Violation and/or civil penalty assessment.
Page#

Permit: NCO068888 Owner -Facility: Dallas WWTP
Inspection Date: 03/14/2024 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
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■
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application?
Is the facility as described in the permit?
■
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# Are there any special conditions for the permit?
■
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Is access to the plant site restricted to the general public?
■
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Is the inspector granted access to all areas for inspection?
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Comment: The Town continues to divert approximately 0.150 MGD of influent wastewater
(via
interconnect) to the Two Rivers Utilities/Long Creek WWTP (NPDES Permit No.
NC0020184).
The last compliance evaluation inspection at this facility was performed by
DWR staff
on 12/14/21.
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
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Is all required information readily available, complete and current?
■
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Are all records maintained for 3 years (lab. reg. required 5 years)?
■
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Are analytical results consistent with data reported on DMRs?
■
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Is the chain -of -custody complete?
■
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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?
■
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Has the facility submitted its annual compliance report to users and DWQ?
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(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified
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operator on each shift?
Is the ORC visitation log available and current?
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Is the ORC certified at grade equal to or higher than the facility classification?
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Is the backup operator certified at one grade less or greater than the facility
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classification?
Is a copy of the current NPDES permit available on site?
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Facility has copy of previous year's Annual Report on file for review?
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Page# 3

Permit: NCO068888
Inspection Date: 03/14/2024
Owner -Facility: Dallas WWTP
Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Comment: The records reviewed durinq the inspection were well maintained. This Office
recommends the ORC to organize the operation & maintenance records pertaining to
chlorine/sulfur dioxide cylinders (shipment receipts, etc.), lime, generator services, and
screenings disposal in their own respective files/folders. The Town's Annual
Performance Report is based on the calendar year. The Town has not submitted the
2023 report by March 1, 2024 as required by the subject NPDES Permit [Part II,
Section E. (12.) Annual Performance Reportsl. Please be advised that these reports
are due within 60 days of the selected reporting period (fiscal or calendar year). In
addition, the 2022 Annual Performance Report had not been placed on the Town's
website (only 2021's report was available) for public review. Note: The 2023 Annual
Performance Report should also be placed on the website once completed. See
"Summarv" Section for additional comments.
Laboratory
Yes
No
NA
NE
Are field parameters performed by certified personnel or laboratory?
0
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Are all other parameters(excluding field parameters) performed by a certified lab?
0
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# Is the facility using a contract lab?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0
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■
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degrees Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
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■
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Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
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■
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Comment: Influent and effluent samplinq and samplinq (includinq field parameters) are performed
by Two Rivers Utilities certified laboratory (#210). Environmental Testing Solutions, Inc.
has also been contracted to perform effluent chronic toxicity testing.
The ORC and staff must ensure future effluent total residual chlorine values are not
reported on the eDMR below the lowest standard (20 ug/L) verified on the meter.
Influent Sampling
Yes
No
NA
NE
# Is composite sampling flow proportional?
0
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Is sample collected above side streams?
0
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Is proper volume collected?
■
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Is the tubing clean?
■
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0
0
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degrees Celsius)?
Is sampling performed according to the permit?
0
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Comment: The subject permit requires influent composite BOD and TSS samples.
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
0
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Is sample collected below all treatment units?
0
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Page# 4

Permit: NCO068888 Owner -Facility: Dallas WWTP
Inspection Date: 03/14/2024 Inspection Type: Compliance Evaluation
Effluent Sampling
Yes
No
NA
NE
Is proper volume collected?
0
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Is the tubing clean?
0
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# Is proper temperature set for sample storage (kept at less than or equal to 6.0
■
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degrees Celsius)?
Is the facility sampling performed as required by the permit (frequency, sampling type
0
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representative)?
Comment: The subject permit requires composite and grab effluent samples.
Upstream / Downstream Sampling Yes No NA NE
Is the facility sampling performed as required by the permit (frequency, sampling type, ■ ❑ ❑ ❑
and sampling location)?
Comment:
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 wastewater treatment facilitv appeared to be properly operated and well
maintained at the time of the inspection. Process control measurements were being
performed/documented and the records were maintained on -site. The facility is
equipped with a SCADA system to assist the wastewater staff in treatment operations.
The wastewater staff are also notified of selected alarm conditions via telemetry type
alarm system.
Bar Screens
Yes
No
NA
NE
Type of bar screen
a.Manual
b.Mechanical
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Are the bars adequately screening debris?
0
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Is the screen free of excessive debris?
0
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Is disposal of screening in compliance?
0
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Is the unit in good condition?
0
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Comment: Screenings are disposed at the County Landfill.
Pump Station - Influent
Yes
No
NA NE
Is the pump wet well free of bypass lines or structures?
0
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Is the wet well free of excessive grease?
0
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Page# 5

Permit: NCO068888
Inspection Date: 03/14/2024
Pump Station - Influent
Owner -Facility: Dallas WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Are all pumps present?
0
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Are all pumps operable?
■
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Are float controls operable?
0
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Is SCADA telemetry available and operational?
0
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Is audible and visual alarm available and operational?
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Comment: The Town also uses a portable diesel pump
at the influent pump station as a backup.
Aeration Basins
Yes No
NA
NE
Mode of operation
Ext. Air
Type of aeration system
Diffused
Is the basin free of dead spots?
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Are surface aerators and mixers operational?
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0
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Are the diffusers operational?
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Is the foam the proper color for the treatment process?
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Does the foam cover less than 25% of the basin's surface?
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Is the DO level acceptable?
0 ❑
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Is the DO level acceptable?(1.0 to 3.0 mg/1)
0 ❑
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Comment: Aqueous lime is added at the influent pump station to maintain appropriate
alkalinity/pH
levels. The 30-minute settleability tests for both trains were 240 ml/L and 250 ml/L with
clear supernate.
Secondary Clarifier
Yes
No
NA
NE
Is the clarifier free of black and odorous wastewater?
0
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Is the site free of excessive buildup of solids in center well of circular clarifier?
■
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Are weirs level?
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0
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Is the site free of weir blockage?
0
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Is the site free of evidence of short-circuiting?
■
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Is scum removal adequate?
■
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Is the site free of excessive floating sludge?
0
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Is the drive unit operational?
0
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Is the return rate acceptable (low turbulence)?
0
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Is the overflow clear of excessive solids/pin floc?
■
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Is the sludge blanket level acceptable? (Approximately'/4 of the sidewall depth)
0
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Page# 6

Permit: NCO068888
Inspection Date: 03/14/2024
Secondary Clarifier
Owner -Facility: Dallas WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: All weirs were not level; however, no short-circuiting was observed. Wastewater staff
should repair the leakages between the weir plate and clarifier structure (several
areas) within the near future.
Disinfection -Gas
Are cylinders secured adequately?
Are cylinders protected from direct sunlight?
Is there adequate reserve supply of disinfectant?
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?
Does the Stationary Source have more than 2500 Ibs of Chlorine (CAS No.
7782-50-5)?
If yes, then is there a Risk Management Plan on site?
If yes, then what is the EPA twelve digit ID Number? (1000- - )
If yes, then when was the RMP last updated?
Comment: The chlorination and dechlorination systems are service annual
company (Piedmont Chlorinator).
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?
Yes
No
NA
NE
•
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•
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•
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•
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•
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•
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a contracted
Yes No NA NE
Gas
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Comment: The chlorine and sulfur dioxide cylinders are stored in the same building.
Are tablet de -chlorinators operational? ❑ ❑ ❑
Number of tubes in use?
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
0
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Is the flow meter operational?
0
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(If units are separated) Does the chart recorder match the flow meter?
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0
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Page# 7

Permit: NCO068888
Inspection Date: 03/14/2024
Flow Measurement - Effluent
Owner -Facility: Dallas WWTP
Inspection Type: Compliance Evaluation
Yes No NA NE
Comment: Each circular treatment train is equipped with flow measurement systems that are
calibrated annually and was last calibrated on 11/28/23 by Clearwater, Inc. The ORC
manually adds the flow totals from each train.
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?
Yes No NA NE
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■ ❑ ❑ ❑
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Comment: The effluent appeared clear with trace suspended solids and no foam. The receiving
stream did not appear to be negatively impacted.
Aerobic Digester
Yes
No
NA
NE
Is the capacity adequate?
0
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Is the mixing adequate?
0
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Is the site free of excessive foaming in the tank?
■
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# Is the odor acceptable?
M
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# Is tankage available for properly waste sludge?
0
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Comment: Aerobically digested bio-solids are land applied by a contracted company (U.S.
Bio-Solids) under the authority of Permit No. WQ0020912.
Drying Beds
Yes
No
NA
NE
Is there adequate drying bed space?
0
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Is the sludge distribution on drying beds appropriate?
0
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Are the drying beds free of vegetation?
■
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# Is the site free of dry sludge remaining in beds?
0
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Is the site free of stockpiled sludge?
0
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Is the filtrate from sludge drying beds returned to the front of the plant?
0
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# Is the sludge disposed of through county landfill?
■
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# Is the sludge land applied?
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0
❑
(Vacuum filters) Is polymer mixing adequate?
❑
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0
❑
Comment: The facility is equipped with four drying beds (all operational).
Standby Power Yes No NA NE
Is automatically activated standby power available? 0 ❑ ❑ ❑
Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑
Page# 8

Permit: NC0068888
Inspection Date: 03/14/2024
Standby Power
Is the generator tested under load?
Owner -Facility: Dallas WWTP
Inspection Type: Compliance Evaluation
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
■ ❑ ❑ ❑
■ ❑ ❑ ❑
■ ❑ ❑ ❑
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■ ❑ ❑ ❑
Comment: The generator is automated to test weekly (not under load) and is serviced twice per
year by a contracted company (Carolina CAT).
Page# 9