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HomeMy WebLinkAboutNC0020664_Compliance Evaluation Inspection_20240802Docusign Envelope ID: F1FFC3B0-E286-4D1B-9369-2D481258682E ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS. JR. Dfredur NORTH CAR-OLINA ETWir-VAmerttd! Qeeorrrp August 2, 2024 Scott Webber, Town Manager Town of Spindale PO Box 186 Spindale, NC 28160 Subject: Notice of Violation NOV-2024-PC-0468 Compliance Inspection Town of Spindale NPDES Permit No. NCO020664 Rutherford County Dear Mr. Webber: The North Carolina Division of Water Resources conducted an inspection of the Town of Spindale facility on July 23, 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. NC0020664. The findings and comments noted during this inspection are provided in the enclosed copy of the inspection report entitled " Compliance Inspection Report". The main area of concern observed during the inspection is that Clarifier number #3 has been continually out of service for over 5 years, which does not allow the facility to operate at it's permitted flow of 3 MGD. Please note that Part II, Section C, Condition 2 of your permit requires that, "the Permittee shall at all times properly operate and maintain all facilities and systems of treatment and control (and related appurtenances) which are installed or used by the Permittee to achieve compliance with the conditions of this permit.". Please be advised that this letter is a Notice of Violation. You are requested to respond to this Notice in writing within thirty (30) days of receipt indicating your Plan of Action to ensure future compliance. This Plan of Action should include a timeline within which the items will be adequately addressed. Failure to respond and/or failure to resolve the violations could subject you for further action by the Division of Water Resources. ,�EQi�l NW Carvl3na f]rpaRmrnt of Env] ronmcwsl QuaYty i] vision of Water Resources & 9WA1c Rrgicoal Qflict' 12090 t15. Ftghwav 70 1 Swenrtanpa. North Garoins 28776 o�a..r, !l"2iS.l96.+ISUU Docusign Envelope ID: F1FFC3B0-E286-4D1B-9369-2D481258682E The report should be self-explanatory; however, should you have any questions concerning this report, please do not hesitate to contact Ori Tuvia at (704) 235-2190, or at ori.tuvia(cdeq.nc.gov. Sincerely, Docu Signed by: Va�,it,�, �°jbSS E397192DABFB4FF... by Daniel Boss, Assistant Regional Supervisor Water Quality Regional Operations Section Asheville Regional Office Division of Water Resources, NCDEQ Attachments: Compliance Inspection Report Cc: Central Files w/ attachment (Laserfiche) Guy O'Connor, ORC (E-copy) Docusign Envelope ID: F1 FFC3BO-E286-4D1 B-9369-2D481258682E 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 NCO020664 I11 121 24/07/23 I17 18I � I 19 I s I 201 I 211IIIII 111111III II III III1 I I IIIII IIIIIIIII II 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 Dermit Number) 10:OOAM 24/07/23 20/07/01 Spindale WWTP Ecology St Exit Time/Date Permit Expiration Date Spindale NC 28160 11:45AM 24/07/23 24/07/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Guy Peter O'Connor/ORC/704-434-2261/ Sibyl Canipe Brotherton/ORC// Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Guy O'Connor,327 Ecology St Spindale NC 28160//828-286-3407/ 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 DocuSigned by: OriATuvia DWR/NPDES WW Permitting Unit/704-663-1699/ 8/1/2024 CC i 66057A2DE017498... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date DocuSigned by: Daniel J Boss DWR/ARO WQ/828-296-4658/ 8/1/2024 Fyauut,�, �°jbSS `trait a�uH�tr�snrr.. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E NPDES yr/mo/day Inspection Type (Cont.) NCO020664 I11 12I 24/07/23 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Ori Tuvia, Alex Brown and Eric Anne visited the site on July 23, 2024 and met with ORC Guy O'Conner and BORC Sybil Brotherton. Overall, the facility is well -maintained and operated. All paperwork was organized and easily accessible. The main area of concern is that Clarifier number #3 has been continually out of service due to maintenance issue for over 5 years, which does not allow the facility to operate at it's permitted flow of 3 MGD. Bar Screen: The facility is still experiencing pass through into the plant from the manual bar screen of the septage dump station and the mechanical bar screen due to the bars being spaced too far apart this project will be applied for once financing is secured. Page# Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E Permit: NCO020664 Owner -Facility: Spindale WWTP Inspection Date: 07/23/2024 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 ■ ❑ ❑ ❑ 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: The facility's permit has expired, however, the facility has appliied for permit renwall within the time alloted. Currently the permit under a compliance schedule per Part I, Section A. (4.) of their NPDES permit for Silver and Copper effluent limits. 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? Is a copy of the current NPDES permit available on site? ■ ❑ ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ❑ ■ Page# 3 Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E Permit: NCO020664 Owner -Facility: Spindale WWTP Inspection Date: 07/23/2024 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Comment: The records reviewed durinq the inspection were organized and well maintained. In-depth operation and maintenance records including process control measurements were being documented and maintained on -site. Discharge monitoring reports (eDMRs) ORC log and calibration logs were reviewed for the period April 2024 through June 2024. Flow Measurement - Influent Yes No NA NE # Is flow meter used for reporting? ❑ 0 ❑ ❑ Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? ❑ ❑ ❑ Comment: The influent flow meter is not used for reporting. The influent flow meter was last calibrated on March 6, 2024 by Laboratory Instrument Service. Laboratory Yes No NA NE Are field parameters performed by certified personnel or laboratory? ■ ❑ ❑ ❑ Are all other parameters(excluding field parameters) performed by a certified lab? 0 ❑ ❑ ❑ # Is the facility using a contract lab? 0 ❑ ❑ ❑ # 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? ❑ ❑ ■ ❑ Comment: Influent Sampling Yes No NA NE # Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected above side streams? 0 ❑ ❑ ❑ Is proper volume collected? ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # 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? 0 ❑ ❑ ❑ Comment: The subject permit requires influent BOD and TSS composite samples. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Page# 4 Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E Permit: NCO020664 Owner -Facility: Spindale WWTP Inspection Date: 07/23/2024 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? 0 ❑ ❑ ❑ Is the tubing clean? 0 ❑ ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 0 ❑ ❑ ❑ degrees Celsius)? Is the facility sampling performed as required by the permit (frequency, sampling type ❑ ❑ ❑ representative)? Comment: The subject permit requires composite and grab effluent samples. Aliquat sample was taken duing the inspection and was withinn acceptable range. Upstream / Downstream Sampling Yes No NA NE Is the facility sampling performed as required by the permit (frequency, sampling type, 0 ❑ ❑ ❑ and sampling location)? Comment: Operations & Maintenance 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? Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ❑ Comment: Process controls analyzed include DO, PH, MLSS, SVI, settleable solids, and a sludge fudge. Clarifier number #3 has been continually out of service due to maintenance issue for over 5 years 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? ■ ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Comment: Grit Removal Yes No NA NE Type of grit removal a.Manual ❑ Page# 5 Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E Permit: NCO020664 Inspection Date: 07/23/2024 Owner -Facility: Spindale WWTP Inspection Type: Compliance Evaluation Grit Removal b.Mechanical Is the grit free of excessive organic matter? Is the grit free of excessive odor? # Is disposal of grit in compliance? Comment: Lime is added as needed during grit removal to increase pH. Grit wheelbarrows and is then disposed of in dumpsters. Equalization Basins 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? into Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ Comment: The EQ basin is only utilized during wet weather and is fully operational. Flow is diverted to the EQ basin as needed and the EQ basin is pumped out to the aeration basin once influent flow lowers. At the time of the inspection the EQ basin was empty and not in use due to dry weather. 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? E ❑ ❑ ❑ Is the foam the proper color for the treatment process? 0 ❑ ❑ ❑ Does the foam cover less than 25% of the basin's surface? 0 ❑ ❑ ❑ Is the DO level acceptable? 0 ❑ ❑ ❑ Is the DO level acceptable?(1.0 to 3.0 mg/1) 0 ❑ ❑ ❑ Comment: At the time of the inspection, the south basin was the only aeration basin in operation. The south aeration basin has four zones with diffusers - each zone has a permanent DO meter. Page# 6 Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E Permit: NCO020664 Owner -Facility: Spindale WWTP Inspection Date: 07/23/2024 Inspection Type: Compliance Evaluation Secondary Clarifier 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'/4 of the sidewall depth) Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Flow is split between clarifiers #1 and #2, the clarifiers are in need of maintenance however, they cannot be taken off-line for repair due to the 3rd clarifier being continuously out of service. Clarifier #3 has still not been refurbished there during the inspection it appeared to have excessive vegetation growing in it, inoperable pumps, rusting drive units and require extensive repairs. With the clarifier being out of service, the ORC, indicated that the facility can not treat it's permitted flow of 3 MGD, and has difficulty maintaining maintenance schedule for clarifiers 1 and 2. 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: RAS pumps are requarly cleaned out. There is a spare impellar and motor on -site as a backup. Disinfection -Gas Yes No NA NE Are cylinders secured adequately? 0 ❑ ❑ ❑ Are cylinders protected from direct sunlight? ■ ❑ ❑ ❑ Is there adequate reserve supply of disinfectant? 0 ❑ ❑ ❑ 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? ❑ ❑ ❑ Page# 7 Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E Permit: NCO020664 Owner -Facility: Spindale WWTP Inspection Date: 07/23/2024 Inspection Type: Compliance Evaluation Disinfection -Gas Yes No NA NE If yes, then what is the EPA twelve digit ID Number? (1000- - ) If yes, then when was the RMP last updated? Comment: There are two chlorine contact basins, but De -chlorination Type of system ? Is the feed ratio proportional to chlorine amount (1 to 1)? one is currently in use due to low flow. Is storage appropriate for cylinders? # Is de -chlorination substance stored away from chlorine containers? Are the tablets the proper size and type? Comment: Cylinders sit outside of the chemical feed rooms under a roof. Are tablet de -chlorinators operational? Number of tubes in use? Comment: 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? Yes No NA NE Gas ❑ ❑ ❑ ■ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ■ Comment: The effluent flow meter was last calibrated on March 6, 2024 by Laboratory Instrument Service. 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? ❑ ❑ 0 ❑ Comment: The effluent pipe is approximately two miles away from the facility. Staff have a sampling manhole down by the river. Mr. O'Connor indicated that the effluent pipe is checked weekly and the right of way is properly maintained. The discharge from the facility can be re -aerated if needed. Aerobic Digester Is the capacity adequate? Is the mixing adequate? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 8 Docusign Envelope ID: F1 FFC3B0-E286-4D1 B-9369-2D481258682E Permit: NCO020664 Owner -Facility: Spindale WWTP Inspection Date: 07/23/2024 Inspection Type: Compliance Evaluation Aerobic Digester Yes No NA NE Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? ■ ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: There are two aerobic digesters available on -site. Decant from the digesters goes to the aeration basin. One digester is wasted at a time. Spindale holds a Class B land application permit (WQ0001953) and contracts US Biosolids for land application events. Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ 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: The generator automatically exercises once per week and runs under load every couple months. The manufacturer maintains the generator semi-annually, the fuel is checked once a month. Page# 9