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Home My WebLink AboutNC0021628_Compliance Evaluation Inspection_20241004ROY COOPER Governor MARY PENNY KELLEY Secretary RICHARD E. ROGERS, JR. Director Ray Allen, Town Administrator Town of Norwood Post Office Box 697 Norwood, NC 28128 SUBJECT: Notice of Violation Compliance Evaluation Inspection Town of Norwood WWTP NPDES Permit No. NCO021628 Stanly County Tracking #: NOV-2024-PC-0566 Dear Mr. Allen: NORTH CAROLINA Environmental Quality October 4, 2024 Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on September 25, 2024, by Mr. Wes Bell of this Office. This Office would like to thank the Operator -in -Responsible Charge (ORC) for his cooperation and assistance that was provided throughout this inspection. This report is being issued as a Notice of Violation (NOV) due to the following: - Flow proportional influent and effluent composite samples were not being collected; - All permit -required documents were not being maintained for a period of three and/or five years; - Excessive vegetation was observed on the sludge drying beds; - One of the surface aerators was not operational; - No System Annual Performance Reports (past three years) were available and/or performed. The Town's failures to properly collect composite (influent and effluent) samples, retain permit -required documentation and provide proper operation and maintenance are violations of the subject NPDES Permit and North Carolina General Statute (G.S.) 143-215.1. 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. It is requested that a written response be submitted to this Office by October 25, 2024, detailing the actions taken to address all violations as discussed in more detail in the Record Keeping, Influent Sampling, Effluent Sampling, Laboratory, Aeration Basin and Drying Beds Sections of the attached report. North Carolina Department of Environmental Quality I Division of Water Resources Mooresville Regional Office 1610 East Center Avenue, Suite 301 1 Mooresville, North Carolina 28115 NORTH CAROLINp DkW edoiEeWranment=ud\ /"� 704.663.1699 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.bellkdeq.nc.gov. Sincerely, DocuSigned by: A wNP,uft F161 F669A2D84A3... Andrew H. Pitner, P.G. Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Enclosure: Inspection Report Cc: Ray Allen, Town of Norwood (via eCopy) Todd Robinson, Envirolink (via eCopy) Charles McCoy, Envirolink (via eCopy) NPDES Program Files - Laserfiche 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 28115 NORTH CARIXINA �aWrlman[of EnNnmmanbl Qual� /"� 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 NCO021628 I11 121 24/09/25 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 70LJ 71 I„ I 72 L.71 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 permit Number) 09:25AM 24/09/25 24/08/01 Norwood WWTP 6896 US Hwy 52 Exit Time/Date Permit Expiration Date Norwood NC 28128 12:40PM 24/09/25 29/01/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Charles H McKoy/ORC/704-408-3030/ Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Ray AIIen,PO Box 679 Norwood NC 281280679/Town Administrator/704-474-3416/ 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 Wes Bell Docusigned by: DWR/MRO WQ/704-235-2192/ 10/2/2024 A61696D90=437... Signature of M I�R�,�l�'WA Reviewer Agency/Office/Phone and Fax Numbers Date Andrew Pit jl`u`' H P44"ebWR/MRO WQ/704-663-1699 Ext.2180/ 10/4/2024 F161FB69A2D84A3... EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO021628 I11 12I 24/09/25 117 18 i c i (Cont.) Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Record Keeping Section cont'd: Records (including flow meter calibrations, sludge disposal, monitoring records, etc.) were not accessible and/or not being retained for a period of three/five years as required by the permit [Permit Condition Reference: Part II, Section D(6) Record Retention]. Please be advised that the permittee must maintain all required records (including monitoring records, operation & maintenance, flow meter calibrations, etc.) for a period of three (3) years with the exception of sludge records, which are required to be maintained for five (5) years. No System Annual Performance Reports were found for the past three years. Please be advised that the permittee is required to submit an annual System Annual Performance Report to the Division within sixty (60) days of the reporting period (calendar or fiscal year) as required by the subject permit [Part ll, Section E(12) Annual Performance Reports]. Influent Sampling: The ORC and staff must ensure the following: composite samples are collected over an entire 24-hr. period, sample container does not overfill, aliquot volumes are checked (and documented) twice per month and the preset gallon interval between sample collection is fixed at no greater than 1/24 of the total daily flow. Effluent Sampling: The ORC and staff must ensure the following: composite samples are collected over an entire 24-hr. period, sample container does not overfill, aliquot volumes are checked (and documented) twice per month and the preset gallon interval between sample collection is fixed at no greater than 1/24 of the total daily flow. The ORC has been collecting effluent fecal coliform samples from an intermediate container that had not been properly sterilized (according to Standard Methods). Effluent fecal coliform samples should be collected either directly into the laboratory's sample container or with a sterilized intermediate container. Page# Permit: NCO021628 Owner -Facility: Norwood WWTP Inspection Date: 09/25/2024 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 Town was issued SOC No. WQ S18-011 on 5/3/2019. The Town complied with all required timelines (begin construction, complete construction, compliance with NPDES Permit limits, etc.). The Division issued an Authorization to Construct (AtC) on 6/16/2020 for WWTP upgrades that included the installation of the following: new headworks (rotary bar screen and aerated grit removal system), influent parshall flume, aeration basin weirs, two secondary clarifiers, RAS/WAS pump station, RAS flow meter station, plant drain pump station and dual chlorine contact chambers. Construction activities were completed in October/November 2022. The last compliance evaluation inspection at this facility was performed by DWR staff on 3/6/2019. 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? Yes No NA NE ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ❑ ❑ Page# 3 Permit: NCO021628 Owner -Facility: Norwood WWTP Inspection Date: 09/25/2024 Inspection Type: Compliance Evaluation Record Keeping Yes No NA NE Is the backup operator certified at one grade less or greater than the facility 0 ❑ ❑ ❑ classification? Is a copy of the current NPDES permit available on site? ❑ 0 ❑ ❑ Facility has copy of previous year's Annual Report on file for review? ❑ 0 ❑ ❑ Comment: Discharge Monitoring Reports (eDMRs) were reviewed for the period August 2023 through July 2024. Weekly average effluent fecal coliform violations were reported in August 2023 and January 2024. Weekly average effluent BOD violations were reported in April and May 2024. A monthly average flow violation was reported in January 2024 and a monthly average effluent BOD violation was reported in April 2024. The Division has previously addressed these limit violations through the issuances of either a Notice of Violation (NOV) or NOV/civil penalty assessment. See "Summary" Section for additional comments. 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? ❑ ❑ 0 ❑ Comment: On -site field analyses (pH, temperature, total residual chlorine) are performed under Environlink, Inc.'s field laboratory certification #5212. Statesville Analytical and ETS (toxicity) have also been contracted to provide analytical support. If effluent samples are temporarily stored in the on -site refrigerator, then the internal temperature must be monitored every day of use to verify samples are being properly preserved at less than or equal to six degrees Celsius (Regulatory Reference: 40 CFR 136.3, Table II). The annual verification documents did not have the correct serial number for the total residual chlorine meter being currently used. The ORC must contact the contracted laboratory and revise the documents if applicable. The TRC meter must be verified every twelve months. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? ❑ ■ ❑ ❑ 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 0 ❑ ❑ ❑ degrees Celsius)? Is sampling performed according to the permit? ❑ 0 ❑ ❑ Page# 4 Permit: NCO021628 Inspection Date: 09/25/2024 Influent Sampling Owner -Facility: Norwood WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The subject permit requires influent BOD and TSS composite samples. Time based composite samples were being collected; however, the subject permit requires flow proportional. Please be advised that flow proportional influent composite must be collected as required b the subject permit (Permit Condition Reference: Part II, Section A. Composite Sample). The composite sampler was only collecting 80 mL aliquots. Please be advised that the subject permit requires a minimum of 100 mL per aliquot (Permit Condition Reference: Part II, Section A. Composite Sample). See "Summary" Section for additional comments. 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? ❑ 0 ❑ ❑ # Is proper temperature set for sample storage (kept at less than or equal to 6.0 M ❑ ❑ ❑ 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. Time based composite samples were being collected; however, the subject permit requires flow proportional. Please be advised that flow proportional influent composite must be collected as required b the subject permit (Permit Condition Reference: Part II, Section A. Composite Sample). The composite sampler was only collecting 90 mL aliquots. Please be advised that the subject permit requires a minimum of 100 mL per aliquot (Permit Condition Reference: Part II, Section A. Composite Sample). Note: The facility can collect flow proportional effluent composite samples based on the influent flow measurements. See "Summary" Section for additional comments. 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 wastewater treatment facilitv appeared to be adequately treatinq wastewater at the time of the inspection; however, operation and maintenance issues were noted and are discussed in more detail in the Aeration Basin and Drying Beds Sections. Please be advised that the subject permit requires the permittee to ensure proper operation and maintenance on the treatment facility at all times [Part II, Section C(2) Proper Operation and Maintenancel. Bar Screens Type of bar screen Yes No NA NE Page# Permit: NCO021628 Inspection Date: 09/25/2024 Owner -Facility: Norwood WWTP Inspection Type: Compliance Evaluation Bar Screens Yes No NA NE 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 ❑ ❑ ❑ Comment: Grit Removal Yes No NA NE Type of grit removal a.Manual ❑ b.Mechanical Is the grit free of excessive organic matter? 0 ❑ ❑ ❑ Is the grit free of excessive odor? 0 ❑ ❑ ❑ # Is disposal of grit in compliance? ❑ ❑ ❑ Comment: Screenings and grit are disposed at a permitted landfill. 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? 0 ❑ ❑ ❑ Comment: The flow meter is calibrated annually and was last calibrated on 6/6/2024 by Instrumentation Services. Aeration Basins Yes No NA NE Mode of operation Ext. Air Type of aeration system Surface Is the basin free of dead spots? ❑ 0 ❑ ❑ Are surface aerators and mixers operational? ❑ 0 ❑ ❑ 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? 0 ❑ ❑ ❑ Is the DO level acceptable? E ❑ ❑ ❑ Page# 6 Permit: NCO021628 Inspection Date: 09/25/2024 Aeration Basins Is the DO level acceptable?(1.0 to 3.0 mg/1) Owner -Facility: Norwood WWTP Inspection Type: Compliance Evaluation Yes No NA NE ■ ❑ ❑ ❑ Comment: Both aeration basin trains are equipped with surface aerators (two per train). One of the surface aerators was not operational. The surface aerator must be either repaired or replaced as soon as possible. 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: Both secondaries were operational and in service. The weirs on one of the clarifiers will need to be cleaned of the algal/vegetative growth within the near future. 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? ❑ ❑ ❑ ■ Comment: Disinfection -Gas 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? Yes No NA NE ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Page# 7 Permit: NCO021628 Inspection Date: 09/25/2024 Disinfection -Gas Owner -Facility: Norwood WWTP Inspection Type: Compliance Evaluation 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? If yes, then what is the EPA twelve digit ID Number? (1000- - ) If yes, then when was the RMP last updated? Comment: De -chlorination Type of system ? 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: Effluent Pipe 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? Comment: The effluent appeared slightly turbid with no foam. Drying Beds 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? # Is the sludge disposed of through county landfill? # Is the sludge land applied? Yes No NA NE ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE Liquid ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ Yes No NA NE ❑ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ Yes No NA NE ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ■ ❑ ❑ Page# 8 Permit: NCO021628 Inspection Date: 09/25/2024 Drying Beds (Vacuum filters) Is polymer mixing adequate? Owner -Facility: Norwood WWTP Inspection Type: Compliance Evaluation Yes No NA NE ❑ ❑ ■ ❑ Comment: The facilitv is equipped with two sludge drvinq beds. One of the drvinq beds contained an excessive amount of vegetation throughout the entire bed. The second drying bed contained dewatered sludge along with a section of excessive vegetation. The vegetation must be removed and properly disposed. In addition, the permittee and ORC must ensure both drying beds are properly maintained at all times. Dewatered sludge is transported by a contracted company to a permitted landfill. The permittee and ORC must ensure the dumpster is covered to prevent rainwater from accumulating inside the dumpster and contacting the sludge. 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? 0 ❑ ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up ■ ❑ ❑ ❑ power? Is the generator fuel level monitored? 0 ❑ ❑ ❑ Comment: The ORC indicated that the backup generator is tested weekly (automatically) and Town staff oversee the maintenance/operation of the generator. Page# 9