NC0025879_NOD2024PC0106 & CEI Report_20240619

SENT VIA ELECTRONIC MAIL ONLY: NO HARD COPY WILL BE MAILED.

June 19, 2024

Shaun Adams, Mayor
Town of Robbinsville
Email: [e-mail]

SUBJECT: NOTICE OF DEFICIENCY
Tracking Number: NOD-2024-PC-0106
Permit No. NC0025879
Robbinsville WWTP
Graham County

Dear Permittee:

The North Carolina Division of Water Resources conducted an inspection of the Robbinsville WWTP on June 4,
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. NC0025879. 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 deficiencies were noted during the inspection:
Inspection Area Description of Deficiency _________________________________________________________________________________________________________________________________________________________________________
Influent Sampling There was no thermometer in the composite sampling fridge.
_________________________________________________________________________________________________________________________________________________________________________
Effluent Sampling The thermometer was broken in the composite sampling fridge.
_________________________________________________________________________________________________________________________________________________________________________

DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2

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
Lamar Williams (ORC)
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
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 NC0025879 24/06/04 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)
Robbinsville WWTP
US Hwy 129
Robbinsville NC 28771
Entry Time/Date Permit Effective Date
Exit Time/Date Permit Expiration Date
10:00AM 24/06/04 23/08/01
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
///
Everette Lamar Williams/ORC/828-479-3250/
Other Facility Data
12:15PM 24/06/04 27/11/30
Name, Address of Responsible Official/Title/Phone and Fax Number
Everette Lamar Williams,1032 Cockran's Creek Robbinsville NC
287711032/ORC/828-479-3250/
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
Lauren E Armeni 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: EB676DA2-E189-4A60-96A5-F512066FFFB2
6/19/2024
6/19/2024
6/19/2024
NPDES yr/mo/day
24/06/04
Inspection Type
C3111218
1
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
Lauren Armeni and Mikal Willmer, with the Asheville Regional Office, conducted a Compliance
Evaluation Inspection of the Robbinsville WWTP on June 4, 2024. This inspection was conducted to
determine whether the facility is being operated and maintained in compliance with NPDES Permit No.
NC0025879. Mr. Lamar Williams (ORC) was present and assisted in the inspection.
Overall, the facility was well-maintained and operated. All paperwork was organized and easily
accessible. Flow at the plant initially enters the anoxic basin, aeration basin, and then post-anoxic
basin, which then goes to the secondary clarifier. There are two treatment units in parallel. The entire
WWTP is on a SCADA system, except the sludge handling lift station.
The following items were noted during the inspection:
1. Permit: The permit components list should be updated to say "aerobic basins" instead of
"anaerobic basins", and “post-clarifier liquid filters” could be changed to say “tertiary filters".
2. Pump Station - Influent: The wet well had some excess grease which should be removed.
3. Influent sampling: There was no thermometer in the composite sampling fridge. A thermometer
should be kept in the fridge at all times. Sampling tubing was dirty and should be changed.
The following deficiencies were noted during the inspection:
1. Influent sampling: There was no thermometer in the composite sampling fridge.
2. Effluent sampling: The thermometer was broken in the composite sampling fridge.
NC0025879 17 (Cont.)
Page#2
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
Permit:NC0025879
Inspection Date:06/04/2024
Owner - Facility:
Inspection Type:
Robbinsville 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?
Special condition A. (4.) in the permit is for effluent mercury analysis and reporting.
The Permittee is required to provide one effluent mercury sample and analysis using
clean EPA Method 1631E no sooner than two months prior to applying for renewal, and
the analytical results should be attached to the next permit renewal application. The
permit components list needs updated. 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?
Process controls analyzed include pH, DO, and measuring the sludge blanket with a
sludge judge. Each aeration basin has an in-line DO meter.
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?
Page#3
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
Permit:NC0025879
Inspection Date:06/04/2024
Owner - Facility:
Inspection Type:
Robbinsville WWTP
Compliance Evaluation
Record Keeping Yes No NA NE
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?
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?
Collection system (CS) staff maintain the influent lift station. At the time of the
inspection, there was some excess grease in the wet well that should be removed. The
high level float is not used in the wet well - flow is determined by a level sensor. SCADA
could not be evaluated because the floats are not used. The permanent generator fuel
level was full. 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?
At the time of the inspection, the sampling tubing was dirty and should be changed,
and there was no thermometer in the sampling fridge. See summary for details.
Comment:
Bar Screens Yes No NA NE
Type of bar screen
a.Manual
b.Mechanical
Page#4
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
Permit:NC0025879
Inspection Date:06/04/2024
Owner - Facility:
Inspection Type:
Robbinsville WWTP
Compliance Evaluation
Bar Screens Yes No NA NE
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 mechanical bar screen is located at the influent lift station and is maintained by CS
staff. At the time of the inspection, the bar screen was down, therefore the bypass
manual bar screen was being used. The manual bar screen is raked at least daily. Mr.
Chadd Carpenter (CS ORC) indicated that the bar screen would be fixed in July
because they are waiting on parts.
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?
The EQ basin contains mixers but is not aerated. The basin can overflow into the
anoxic zone if it gets too high.
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?
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)
Page#5
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
Permit:NC0025879
Inspection Date:06/04/2024
Owner - Facility:
Inspection Type:
Robbinsville WWTP
Compliance Evaluation
Aeration Basins Yes No NA NE
At the time of the inspection, DEQ's DO/pH meter read the following: AB #1 - DO: 5.6
mg/L; pH: 7.0 and AB #2 - DO: 5.5 mg/L; pH: 6.95. The DO was not in the specified
range, but was acceptable. Settleability was 82.5% in AB #1 and 85% in AB #2. The
aeration basins have in-line DO meters that control the blowers. At 2.0 mg/L, the
blowers turn on, and at 4.5 mg/L the blowers turn off. The in-line DO meters are
calibrated annually.
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 blankets in clarifier #1 and #2 were both 0.5'
out of 12' of water.
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 March 12, 2024 by KDT Service
Technologies.
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?
Page#6
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
Permit:NC0025879
Inspection Date:06/04/2024
Owner - Facility:
Inspection Type:
Robbinsville WWTP
Compliance Evaluation
Filtration (High Rate Tertiary)Yes No NA NE
Is the scouring acceptable?
Is the clear well free of excessive solids and filter media?
There are two sets of filters and they are backwashed daily. Backwash pumps to the
sludge handling lift station. Filters are completely drained down and sprayed off
annually.
Comment:
Disinfection - UV Yes No NA NE
Are extra UV bulbs available on site?
Are UV bulbs clean?
Is UV intensity adequate?
Is transmittance at or above designed level?
Is there a backup system on site?
Is effluent clear and free of solids?
The UV intensity readout has not been repaired. Both UV banks are run in series, but
one UV bank can be used at a time. UV bulbs are changed annually and cleaned every
six months.
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?
Sludge from the clarifiers is wasted to the digesters monthly. If the digesters need
decanted, the decant goes to the EQ basin.
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#7
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
Permit:NC0025879
Inspection Date:06/04/2024
Owner - Facility:
Inspection Type:
Robbinsville WWTP
Compliance Evaluation
Solids Handling Equipment Yes No NA NE
At the time of the inspection, the belt press was not in operation, but was operable. Mr.
Williams indicated that the belt press is ran every three to four months. Sludge comes
in and mixes with polymer, and is then pressed. Once the solids are pressed they are
mixed with lime and sit under cover until they meet the requirements of an Alkaline
Treated Class A product, at which point they can be distributed. The belt was replaced
this year. The facility has a Class A residuals permit - WQ0039348. Runoff from the
belt press and stormwater from the residuals storage area also goes into the sludge
handling lift station.
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?
There are currently no plans to expand the plant, therefore the pipe has not been
relocated.
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 composite sampling fridge was
broken and needs to be replaced.
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?
Page#8
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2
Permit:NC0025879
Inspection Date:06/04/2024
Owner - Facility:
Inspection Type:
Robbinsville WWTP
Compliance Evaluation
Standby Power Yes No NA NE
The Town still has a contract with Carolina Energy Systems to maintain the generator.
The generator is tested under load manually. At the time of the inspection, the fuel
level was 3/4 full. When the level gets to 1/2 full the tank is filled by Mountain Energy.
During extended outages, Mountain Energy refuels the tank as needed.
Comment:
Page#9
DocuSign Envelope ID: EB676DA2-E189-4A60-96A5-F512066FFFB2