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Home My WebLink AboutNC0025135_Compliance Evaluation Inspection_20240717 SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED July 17, 2024 Lee T Huffman Huffman Finishing Company Inc Email: huffhoslth@aol.com SUBJECT: Compliance Inspection Report Huffman Finishing NPDES WW Permit No. NC0025135 Caldwell County Dear Permittee: The North Carolina Division of Water Resources conducted an inspection of the Huffman Finishing on 6/19/2024. This inspection was conducted to verify that the facility is operating in compliance with the conditions and limitations specified in NPDES WW Permit No. NC0025135. 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 Mikal Willmer with the Water Quality Regional Operations Section in the Asheville Regional Office at 828-296-4686 or via email at mikal.willmer@deq.nc.gov. Sincerely, Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ ATTACHMENTS: Inspection Report Ec: LF Jon Gragg, ORC Water Tech Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 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 NC0025135 24/06/19 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) Huffman Finishing 4919 Hickory Blvd Granite Falls NC 28630 Entry Time/Date Permit Effective Date Exit Time/Date Permit Expiration Date 11:30AM 24/06/19 23/01/01 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) /// Jonathan David Gragg/ORC/828-396-4444/ Other Facility Data 12:30PM 24/06/19 27/12/31 Name, Address of Responsible Official/Title/Phone and Fax Number Lee T Huffman,PO Box 170 Granite Falls NC 286300170/Manager/Owner/828-396-1741/ 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 Compliance Schedules 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 Rachel Rose DWR/ARO WQ/828-296-4500/ Mikal Willmer DWR/ARO WQ/828-296-4686/ 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: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 7/17/2024 7/17/2024 7/17/2024 NPDES yr/mo/day 24/06/19 Inspection Type C3111218 1 Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Mikal Willmer and Rachel Rose, with the Asheville Regional Office, conducted a Compliance Evaluation Inspection of Huffman Finishing’s WWTP on June 19, 2024. This inspection was conducted to determine whether the facility is being operated and maintained in compliance with NPDES Permit #NC0025135. Jon Gragg, ORC-Water Tech, was present and assisted in the inspection. The following items were noted during the inspection: All treatment units were designed for higher daily flows. Current flows are approximately 0.015 MGD and peak at 0.04 MGD, depending on the time of the year. The facility is permitted for 0.25 MGD. Huffman Finishing’s influent is dark in color due to dye. The effluent discharge maintains a dark tint. There are currently no color limits or requirement for further color removal in the permit. EQ Basin: The basin utilizes surface aerators and two submersible pumps. A highwater audible and visual alarm are installed but were not working at the time of the inspection. The alarm is not connected to telemetry or SCADA and the plant is not visible to Huffman Finishing staff. The ORC reports that in the event of pump failure, there is at least seven days’ worth of storage within the basin. The ORC reported and verified the high water alarms were repaired the week of June 24,2024. Oxidation Ditch: The aerator is set to turn on for an hour and off for three hours. ORC reports he attempts to maintain the MLSS in the ditch at approximately 2500 mg/L. Since the waste stream is hard on meters, the ORC reports he bases treatment changes to the oxidation ditch on the DO at the top of the cascade aeration and only periodically checks in the oxidation ditch. DO is typically 3 mg/L in the oxidation ditch. Division staff were unable to measure DO at the time of the inspection due to a meter malfunction. pH read 7.5 and Settleability was 725 mL/L. Inspectors also noted significant spray from the influent line that enters over the sidewall of the oxidation ditch. Mr. Gragg indicated this is due to the air-gap in the influent line. The oxidation influent did not appear to be reaching the ground surface outside of the side wall; however, it is recommended staff continue to monitor this location to ensure a bypass does not occur. Clarifier: Solids depth was approximately 2.5 feet out of 13 feet. Chlorine tablets are maintained in the effluent launder to reduce algal growth. ORC reports a scum rake is not necessarily due to influent composition. Influent flows are predominately industrial in nature. The drive appeared to be operational, and weirs appeared level. No major issues were noted. Some components above the surface of the clarifier are showing age related wear but the ORC reports the tank was drawn down approximately 6 months ago and all components appeared ok. Chlorine Feed: Facility still utilizes chlorine gas cylinders. The plant feeds approximately 2-3 lbs. of chlorine a day. Cylinders in use are in a closed building; however, spare tanks are stored in a cage open to direct sunlight. Division staff recommend a sunshade or cover to reduce the sun exposure on the chlorine tanks. Chlorine Contact chamber: The Chlorine contact chamber was cleaned of solids six months ago when the clarifier was drawn down. Composite Sampler: Composite sampler fridge was reading 0 °C at the time of the inspection. The ORC reports that he checks the fridge thermometer reading against the temperature of his samples to verify it is reading accurately. Sampler is set to pull every one pulse which is equal to every 1,000 gallons of flow. Sample volume is 100 mL and checked periodically. Recommend the ORC check this more frequently and record the results to ensure the minimum volume (100 mL) is consistently being pulled. Aerated Sludge Holding Tanks & Solids Handling: Facility has two aerated sludge holding tanks NC0025135 17 (Cont.) Page#2 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 Permit:NC0025135 Inspection Date:06/19/2024 Owner - Facility: Inspection Type: Huffman Finishing Compliance Evaluation onsite. ORC stated they have not had to land apply or haul off solids since 2014 due to reduced flows. There is currently adequate capacity within the tanks to continue to decant and hold the solids. The facility has a Class B residuals land application permit, WQ0002431, with permitted fields onsite, should they need to land apply in the future Drying Beds: The drying beds have not been in use for years and would need substantial repairs before being placed back into service. The ORC does not see these being actively used any time soon. Effluent Pipe: The permit required the effluent pipe to be repaired within one year of the permit effective date (repair by January 1, 2024). The right-of-way to the effluent pipe is now being actively maintained and is accessible by vehicle. Cracks in the top of the effluent pipe have been patched and repaired. No other issues were noted with the pipe at the time of the inspection and no additional action is being requested by the Division at this time. A photo of the pipe repair will be filed with the inspection report as documentation of compliance. Page#3 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 Permit:NC0025135 Inspection Date:06/19/2024 Owner - Facility: Inspection Type: Huffman Finishing Compliance Evaluation Compliance Schedules Yes No NA NE Is there a compliance schedule for this facility? Is the facility compliant with the permit and conditions for the review period? Facility was required to repair the effluent pipe within one year of permit issuance (by January 2024). 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? ORC analyzes MLSS, DO and Settleability. See summary for details.Comment: 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? 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? Page#4 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 Permit:NC0025135 Inspection Date:06/19/2024 Owner - Facility: Inspection Type: Huffman Finishing 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 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? Records are maintained digitally.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? Basin size is adequate due to reduced flows. See summary for details.Comment: Oxidation Ditches Yes No NA NE Are the aerators operational? Are the aerators free of excessive solids build up? # 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? Are settleometer results acceptable (> 30 minutes)? Is the DO level acceptable?(1.0 to 3.0 mg/l) Are settelometer results acceptable?(400 to 800 ml/l in 30 minutes) See summary for details.Comment: Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? Page#5 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 Permit:NC0025135 Inspection Date:06/19/2024 Owner - Facility: Inspection Type: Huffman Finishing Compliance Evaluation Secondary Clarifier Yes No NA NE 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) See summary for details.Comment: Pumps-RAS-WAS Yes No NA NE Are pumps in place? Are pumps operational? Are there adequate spare parts and supplies on site? Spare parts are kept onsite.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? Two aerated sludge holding ponds.Comment: Drying Beds Yes No NA NE Is there adequate drying bed space? Is the sludge distribution on drying beds appropriate? Are the drying beds free of vegetation? # Is the site free of dry sludge remaining in beds? Is the site free of stockpiled sludge? Is the filtrate from sludge drying beds returned to the front of the plant? Page#6 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 Permit:NC0025135 Inspection Date:06/19/2024 Owner - Facility: Inspection Type: Huffman Finishing Compliance Evaluation Drying Beds Yes No NA NE # Is the sludge disposed of through county landfill? # Is the sludge land applied? (Vacuum filters) Is polymer mixing adequate? Drying beds are still onsite, but have not been used in years. ORC does not see these being used in the forseeable future. See summary details. 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? Facility has a Class B Residual Land Application Permit. See summary for details.Comment: Disinfection-Gas Yes No NA NE 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 lbs 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? Cylinders are secured in a cage. Recommend sun cover to keep direct sunlight off of tanks. Comment: De-chlorination Yes No NA NE Type of system ?Liquid Is the feed ratio proportional to chlorine amount (1 to 1)? Page#7 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 Permit:NC0025135 Inspection Date:06/19/2024 Owner - Facility: Inspection Type: Huffman Finishing Compliance Evaluation De-chlorination Yes No NA NE 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? chlorine and dechlor are time based since flows are consistent throughout the day.Comment: Chemical Feed Yes No NA NE Is containment adequate? Is storage adequate? Are backup pumps available? Is the site free of excessive leaking? 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? 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? Facility has step-aeration prior to discharge.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? Page#8 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0 Permit:NC0025135 Inspection Date:06/19/2024 Owner - Facility: Inspection Type: Huffman Finishing Compliance Evaluation Effluent Sampling Yes No NA NE # 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)? Sampler was reading 0 degrees at the time of the inspection. See summary for details.Comment: Page#9 Docusign Envelope ID: 17DA1FD5-725A-4C06-B235-B9DDDEEC0FE0