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Home My WebLink AboutNC0064734_Compliance Evaluation Inspection_20240813ROY COOPER Governor ELIZABETH S. BISER Secretary RICHARD E. ROGERS, JR. Director Gary Peacock, Director of Operations Carolina Water Service, Inc. of NC Post Office Box 240908 Charlotte, NC 28224 SUBJECT: Notice of Violation Compliance Evaluation Inspection Bradfield Farms WWTP NPDES Permit No. NCO064734 Cabarrus County Tracking #: NOV-2024-PC-0477 Dear Mr. Peacock: NORTH CAROLINA Environmental Quality August 13, 2024 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on July 31, 2024, by Mr. Wes Bell of this Office. This Office would like to thank all wastewater staff for their assistance and cooperation provided during the inspection. This report is being issued as a Notice of Violation (NOV) due to the following: - The effluent composite sampler was not collecting samples over a 24-hr. time period; - The 2023 Annual Performance Report had not been submitted to the Division within sixty (60) days of the reporting period (calendar year). Please be advised that the failures to collect composite samples over a 24-hr. period and submit the 2023 Annual Performance Report within sixty (60) days of the reporting period which are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1. as discussed further in the Record Keeping and Effluent Sampling Sections of the attached report 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 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. Penalties may also be assessed for any damage to surface waters of the State that may result from the violation. 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 26115 704.663.1699 It is requested that a written response be submitted to this Office by September 3, 2024, detailing the actions taken to address the above -noted violations and the additional issues discussed in the Secondary Clarifier Section in the attached report. In responding, please address your comments to the attention of Mr. Wes Bell. Should you have any questions concerning this Notice, please do not hesitate to contact Mr. Bell at (704) 235-2192 or at wes.belI&deq.nc. gov. Enclosure: Inspection Report Cc: Garry Peacock, CWS (via eCopy) Larry Henry, CWS (via eCopy) NPDES Program Files - Laserfiche Sincerely, DocuSigned by: 27DF9ACF858043F... Brandy Costner Assistant 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 26115 704.663.1699 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 NCO064734 111 121 24/07/31 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 70LJ 71 I„ I 72 L71 74 79 I I I I 80 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) 09:15AM 24/07/31 24/01/01 Bradfield Farms WWTP 3822 Tearoyal Ct Exit Time/Date Permit Expiration Date Charlotte NC 28215 12:12PM 24/07/31 28/11/30 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Larry Darnell Henry/ORC/704-361-0641/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Gary Mack Peacock,PO Box 240908 Charlotte NC 282240908//828-242-7588/ 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: Wes Bell �� Be& DWR/MRO WQ/704-235-2192/ 8/13/2024 A:c.D90CC3437... Signature of Management Q A Reviewer Agency/Office/Phone and Fax Numbers Date Brandy Costner DWR/MRO WQ/704-235-2185/ DocuSigned by: 8/13/2024 F L&,*. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. �-27DFMCF858043F.. Page# NPDES yr/mo/day Inspection Type NCO064734 I11 12I 24/07/31 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCO064734 Owner -Facility: Bradfield Farms WWTP Inspection Date: 07/31/2024 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? 0 ❑ ❑ ❑ # Are there any special conditions for the permit? ❑ ❑ 0 ❑ Is access to the plant site restricted to the general public? 0 ❑ ❑ ❑ Is the inspector granted access to all areas for inspection? 0 ❑ ❑ ❑ Comment: The last compliance evaluation inspection at this facility was performed by DWR staff on 11 /3/2020. Record Keeping 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ Page# 3 Permit: NCO064734 Inspection Date: 07/31/2024 Record Keeping Owner -Facility: Bradfield Farms WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The records reviewed durinq the inspection were orqanized and well maintained. Discharge monitoring reports (eDMRs) were reviewed for the period July 2023 through June 2024. No monitoring violations were reported. A daily maximum effluent fecal coliform violation was reported in September 2023. The Division has previously addressed this limit violation through the issuance of a Notice of Violation (NOW The 2023 System Annual Performance Report was not submitted to the Division within sixty (60) days of the reporting period (calendar year in this case) as required by the subject permit (Part II, Section E (#12)1. The ORC must ensure the sample collection and analysis times are documented for PH and total residual chlorine to verify compliance with the 15-minute holding time requirement (reference: 40 CFR 136.3, Table II). 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: Effluent field analyses (dissolved oxygen, temperature and pH) are performed under Carolina Water Service, Inc. of NC's field laboratory certification #5228. K&W Labs has also been contracted to provide analytical support for all remaining permit -required analyses. Effluent Sampling Yes No NA NE Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected below all treatment units? 0 ❑ ❑ ❑ Is proper volume collected? ■ ❑ ❑ ❑ Is the tubing clean? ■ ❑ ❑ ❑ # 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 ❑ 0 ❑ ❑ representative)? Comment: The subject permit requires composite and qrab effluent samples. This Office recommends the sampler's aliquot volume be checked and calibrated (if needed) weekly to ensure compliance with the subject permit. These sampler checks and/or calibrations should also be documented in the operation & maintenance log maintained on -site. A review of the composite sampler's previous sampling event revealed the sampler only collected samples for approximately thirteen (13) hours. Please be advised that composite sampling must be performed over a 24-hr. period as required by the subject permit (Part II, Section A. Composite Sample). Page# 4 Permit: NCO064734 Owner - Facility: Bradfield Farms WWTP Inspection Date: 07/31/2024 Inspection Type: Compliance Evaluation Effluent Sampling Yes No NA NE 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 facility appeared to be adequately treatinq the wastewater that was bein discharged. Process control measurements were being performed and documented on -site. Operational issues were noted with the secondary clarifiers as discussed in more detail in the Secondary Clarifier Section. The permittee and ORC must ensure that the wastewater facility is being properly operated and maintained at all times as required by the subject permit [Part II, Section C (#2)1. The facility is equipped with a SCADA system to assist wastewater staff with plant operations and alarm notifications. Pump Station - Influent Yes No NA NE Is the pump wet well free of bypass lines or structures? 0 ❑ ❑ ❑ Is the wet well free of excessive grease? 0 ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Is SCADA telemetry available and operational? 0 ❑ ❑ ❑ Is audible and visual alarm available and operational? 0 ❑ ❑ ❑ Comment: The high water alarm system operated properly during the on -site activation. 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? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Is the unit in good condition? 0 ❑ ❑ ❑ Page# 5 Permit: NCO064734 Inspection Date: 07/31/2024 Bar Screens Owner -Facility: Bradfield Farms WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The facility is equipped with manual and static screens that were all operational and in service. Screenings are disposed at a permitted landfill. Equalization Basins Yes No NA NE Is the basin aerated? 0 ❑ ❑ ❑ Is the basin free of bypass lines or structures to the natural environment? ■ ❑ ❑ ❑ Is the basin free of excessive grease? ■ ❑ ❑ ❑ Are all pumps present? 0 ❑ ❑ ❑ Are all pumps operable? 0 ❑ ❑ ❑ Are float controls operable? 0 ❑ ❑ ❑ Are audible and visual alarms operable? ❑ ❑ ■ ❑ # Is basin size/volume adequate? 0 ❑ ❑ ❑ 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? 0 ❑ ❑ ❑ 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: Lime is added to maintain appropriate alkalinity/pH levels. Secondary Clarifier Yes No NA NE Is the clarifier free of black and odorous wastewater? 0 ❑ ❑ ❑ Is the site free of excessive buildup of solids in center well of circular clarifier? 0 ❑ ❑ ❑ Are weirs level? 0 ❑ ❑ ❑ Is the site free of weir blockage? ■ ❑ ❑ ❑ Is the site free of evidence of short-circuiting? 0 ❑ ❑ ❑ Is scum removal adequate? 0 ❑ ❑ ❑ Page# 6 Permit: NCO064734 Owner -Facility: Bradfield Farms WWTP Inspection Date: 07/31/2024 Inspection Type: Compliance Evaluation Secondary Clarifier Yes No NA NE 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) ❑ ■ ❑ ❑ Comment: The secondary clarifier in train #2 had excessive floatinq solids that were enterinq the clarifier effluent due to a high sludge blanket and denitrification. The clarifier effluent was ultimately being recirculated back into aeration basin. The sludge blanket for the secondary clarifier in train #1 was measured at approximately nine and a half feet with only one and a half feet of supernate. The ORC and staff must ensure that the return activated sludge rates are appropriately adjusted and the mixed liquor suspended solids levels are properly maintained to prevent denitrification and high sludge blankets. 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? ❑ ❑ ■ ❑ Is the scouring acceptable? ■ ❑ ❑ ❑ Is the clear well free of excessive solids and filter media? ■ ❑ ❑ ❑ Comment: Both disc cloth -type tertiary filters were operational and in service. 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? ■ ❑ ❑ ❑ Comment: Both UV disinfection trains were operation and in service. Flow Measurement - Effluent Yes No NA NE # Is flow meter used for reporting? ■ ❑ ❑ ❑ Page# 7 Permit: NCO064734 Owner -Facility: Inspection Date: 07/31/2024 Inspection Type: Bradfield Farms WWTP Compliance Evaluation Flow Measurement - Effluent Yes No NA NE Is flow meter calibrated annually? 0 ❑ ❑ ❑ Is the flow meter operational? 0 ❑ ❑ ❑ (If units are separated) Does the chart recorder match the flow meter? 0 ❑ ❑ ❑ Comment: The flow meter is calibrated annually (at a minimum) and was last calibrated on 6/11/2024 by B.W. Allen. The permittee and on -site staff must ensure that future calibrations include the results of the instantaneous check versus the flow meter reading (must be less than 10% deviation). The chart recorder for the flow meter was approximately three hours off. The ORC must ensure the chart recording system is properly operated and maintained at all times. Effluent Pipe Yes No NA NE Is right of way to the outfall properly maintained? 0 ❑ ❑ ❑ Are the receiving water free of foam other than trace amounts and other debris? 0 ❑ ❑ ❑ If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ 0 ❑ Comment: The effluent appeared clear with no floatable solids or foam. The receiving stream did not appear to be negatively impacted. Aerobic Digester 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? Comment: Both aerated sludge digestion tanks were operational and in service. Solids Handling Equipment 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Both sludge dewatering boxes were operational; however, not in service. Liquid sludge is currently being removed by a contracted company (Liquid Waste). Page# 8 Permit: NC0064734 Inspection Date: 07/31/2024 Owner - Facility: Bradfield Farms WWTP Inspection Type: Compliance Evaluation Standby Power 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? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: The generator is serviced twice per year by a contracted company (Kraft) and is weekly tested (automatically) under load. Page# 9