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Home My WebLink AboutNC0026697_NOD2024PC0077 & CEI Report_20240430 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED. April 30, 2024 Debbie Mauney, County Manager Clay County Water & Sewer District Email: dmauney@claync.us SUBJECT: NOTICE OF DEFICIENCY Tracking Number: NOD-2024-PC-0077 Permit No. NC0026697 Clay County WWTP Clay County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Clay County WWTP on April 16, 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. NC0026697. A summary of the findings and comments noted during the inspection are provided in the enclosed copy of the inspection report. The Compliance Evaluation inspection was conducted by Division of Water Resources staff from the Asheville Regional Office. The following deficiency was noted during the inspection: Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________ Record Keeping The Annual Wastewater Performance Report has not been done. _________________________________________________________________________________________________________________________________________________________________________ DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 Remedial actions 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. To prevent further action, carefully review these deficiencies and address the causes of non-compliance to prevent the recurrence of similar situations. If you should have any questions, please do not hesitate to contact Lauren Armeni with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4667. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: Laserfiche Dusty Beal (Director, Clay County Water & Sewer) Zach Storie (ORC, Environmental Inc.) DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 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 NC0026697 24/04/16 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) Clay County WWTP 238 Jarrett Rd Hayesville NC 28904 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 10:30AM 24/04/16 22/10/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Zachary Kyle Storie/ORC/828-586-5588/ Other Facility Data 01:30PM 24/04/16 27/08/31 Name, Address of Responsible Official/Title/Phone and Fax Number Debbie Mauney,75 Riverside Cir Ste 2 Hayesville NC 28904/County Manager/828-389-0089/ Contacted No 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 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: 33D94E22-9686-4197-97E0-5C264FFB0DF7 4/30/2024 4/30/2024 NPDES yr/mo/day 24/04/16 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Lauren Armeni, with the Asheville Regional Office (ARO), conducted a Compliance Evaluation Inspection of the Clay County WWTP on April 16, 2024. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit No. NC0026697. Zach Storie (ORC, Enironmental Inc.) and David Houston (Clay County Staff) were present and assisted in the inspection. Ms. Armeni spoke with Mr. Dusty Beal (Director of Clay County Water & Sewer) on April 23, 2024 to ask questions that came up during the inspection. Mr. Beal indicated that there are no current plans for expansion, but they are in the process of applying for a grant, that if awarded could cover the cost to upgrade the headworks (mechanical bar screen and possible grit removal), replace the belt press, and install a permanent generator at the WWTP. The following items were noted during the inspection: 1. Operations & Maintenance: Based on the settleability tests in the aeration basins and sludge blanket levels in the clarifiers, the solids are high throughout the plant. 2. Recordkeeping: The Annual Wastewater Performance Report has not been done. Ms. Armeni sent an example report to Mr. Beal. This report should be submitted to the ARO annually. 3. Aeration Basins: Flow is split between the two aeration basins. Pass-through debris was minimal. There are catch baskets at the end of the basins which trap any excess debris, and these baskets are checked daily and emptied as needed. At the time of the inspection, in AB #1, DO was 1.1 mg/L and settleability was 48%; in AB #2, DO was 2.6 mg/L and settleability was 45%. 4. Secondary Clarifiers: The weirs were below the water level, so they could not be evaluated. Mr. Beal indicated that the weirs have always been under water. Ideally, the weirs should be above the water in order to function as intended. 5. Effluent Pipe: The effluent was a blue/green tint during the inspection. Mr. Storie indicated that they were not sure where this color came from, but it was not affecting sampling results. Mr. Beal indicated that as of April 23, 2024, the effluent color was back to normal and they checked every pump station and were not about to find the cause. Mr. Storie used his meter during the inspection on the effluent and the pH was 7.2 and the DO was 6.9 mg/L. 6. Effluent Sampling: At the time of the inspection, the effluent sampling tubling was placed prior to dechlorination. On April 17, 2024, Mr. Storie sent Ms. Armeni a picture confirming that the tubing was moved to post-dechlorination. Grab samples are collected at the effluent pipe. The composite sampler fridge read 5 degrees Celcius during the inspection. 7. Solids Handling Equipment: The belt press is older and undersized for the amount of solids throughout the facility. Mr. Storie indicated that the efficiency of the belt press has gone down. Mr. Beal indicated that the District's engineer is currently working on assessing the belt press, and then a company will come in and repair the current belt press. If awarded, part of the grant will go to purchasing a new belt press. Mr. Beal is also discussing with the engineer about putting in a drying bed and hauling the solids to the landfill themselves. Additionally, the current shed could be expanded to use a larger dumpster so more solids can be pressed; however, the current hauling company can only haul off a certain amount at a time and on certain days of the month which is also a limiting factor. The following defieciency was noted during the inspection: 1. Recordkeeping: The Annual Wastewater Performance Report has not been done. NC0026697 17 (Cont.) Page#2 DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 Permit:NC0026697 Inspection Date:04/16/2024 Owner - Facility: Inspection Type: Clay County WWTP 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? 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? Process controls analyzed include MLSS, DO, and temperature. See summary for details. 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? Is the backup operator certified at one grade less or greater than the facility classification? Page#3 DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 Permit:NC0026697 Inspection Date:04/16/2024 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Record Keeping Yes No NA NE Is a copy of the current NPDES permit available on site? Facility has copy of previous year's Annual Report on file for review? The Annual Wastewater Performance Report has not been done. See summary for details. 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? # 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. At the time of the inspection, the composite sampler fridge temperature was 8 degrees Celcius. On April 17, 2024, Mr. Storie indicated that he had turned down the fridge temperature and it was reading 4.5 degrees Celcius. 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? The 2019 report indicated that debris was able to pass through the bar screen since the spacing was too large. This appears to still be an issue to a lesser extent. Debris is first dried and then placed into a trash can. Mr. Beal indicated that an ARPA grant was applied for, and if awarded some of this money would go to installing a new mechanical bar screen. Comment: Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Diffused Is the basin free of dead spots? Are surface aerators and mixers operational? Page#4 DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 Permit:NC0026697 Inspection Date:04/16/2024 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Aeration Basins Yes No NA NE Are the diffusers operational? Is the foam the proper color for the treatment process? 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/l) The 2019 report indicated that two of the diffusers were clogged during the inspection. Since then, those diffusers have been unclogged. Blowers run continuously during the summer and some valves are closed in the winter. See summary for details. 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, there was some excess floating sludge in the two clarifiers. Mr. Storie indicated that this sludge is occasionally sprayed and will then settle to the bottom. In clarifier #1 the sludge blanket level was 5' out of 11' of water and in clarifier #2 the level was 3.5' out of 10' of water. See summary for details. Comment: Aerobic Digester Yes No NA NE Is the capacity adequate? Is the mixing adequate? Is the site free of excessive foaming in the tank? # Is the odor acceptable? # Is tankage available for properly waste sludge? Solids are pumped to the belt press weekly if there's capacity in the dumpster.Comment: Page#5 DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 Permit:NC0026697 Inspection Date:04/16/2024 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation 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? 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: 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 flow meter was last calibrated on April 9, 2024 by Laboratory Instrument Service.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? At the time of the inspection, the effluent color was blue/green. See summary for details. Comment: Page#6 DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 Permit:NC0026697 Inspection Date:04/16/2024 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation 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)? It was noted during the inspection that the effluent sampling tubing was placed prior to dechlorination. See summary for details. 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: 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 is one portable generator that is kept at the lift station that is checked once a week. This portable generator can run the entire facility. The generator is tested at the WWTP annually. This generator is also used for five of the lift stations. Fuel is maintained on-site and the District has a contract with Parker Oil in Hayesville for refueling and maintenance as needed. Mr. Dusty indicated that if awarded, part of the money from the grant would go to installing a permanent generator at the WWTP, as well as permanenet generators at five of the lift stations. 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? Page#7 DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7 Permit:NC0026697 Inspection Date:04/16/2024 Owner - Facility: Inspection Type: Clay County WWTP Compliance Evaluation Solids Handling Equipment Yes No NA NE 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? The belt press is old and does not appear to keep up with the amount of solids throughout the facility. See summary for details. Comment: Page#8 DocuSign Envelope ID: 33D94E22-9686-4197-97E0-5C264FFB0DF7