Loading...
HomeMy WebLinkAboutNC0081370_Compliance Evaluation Inspection_20240924ROY COOPER Governor MARY PENNY KELLEY Secretary RICHARD E. ROGERS, JR. Director Jason Brown, City Manager City of Claremont Post Office Box 446 Claremont, NC 28610 SUBJECT: Notice of Violation NORTH CAROLINA Environmental Quality September 24, 2024 Compliance Evaluation Inspection City of Claremont/McLin Creek WWTP NPDES Permit No. NCO081370 Catawba County Tracking #: NOV-2024-PC-0545 Dear Mr. Brown: Enclosed is a copy of the Compliance Evaluation Inspection (CEI) Report for the inspection conducted at the subject facility on September 18, 2024, by Mr. Wes Bell of this Office. This Office would like to thank all WWTP staff for their cooperation and assistance that was provided throughout this inspection. This report is being issued as a Notice of Violation (NOV) due to the following: - Effluent composite samples were not collected over a 24-hr. period; - Alarm system for high water and loss of power were not operational. The City's failures to properly collect effluent composite samples 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 14, 2024, detailing the actions taken to address the violations as discussed in more detail in the attached report. The response should also include the City's actions that will be taken to address the slug loads of flow from a local industry that has caused disruptions to plant operations. 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.bell =,deq.nc.gov. 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 Sincerely, Docuftned by: A*4tuw N Nu." F161 FB69AMUA3... Andrew H. Pitner, P.G. Regional Supervisor Water Quality Regional Operations Section Mooresville Regional Office Division of Water Resources, NCDEQ Enclosure: Inspection Report Cc: Jason Brown, City of Claremont (via eCopy) David Cox, City of Hickory (via eCopy) Richard Icard, City of Hickory (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 NCO081370 I11 121 24/09/18 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 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) 10:36AM 24/09/18 21/06/01 McLin Creek WWTP NCSR 1728 Exit Time/Date Permit Expiration Date Claremont NC 28610 02:OOPM 24/09/18 26/03/31 Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s) Other Facility Data Richard Shawn (Card/ORC/828-228-9638/ Todd Atwell Bumgarner//828-228-3021 / Name, Address of Responsible Official/Title/Phone and Fax Number Contacted Jason A Brown,PO Box 446 Claremont NC 286100446/City Manager/828-466-7255/8284667185 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: 9/2 3/2024 Wes Bell �� � DWR/MRO WQ/704-235-2192/ A:c,96D9OCC3437... Signature of Man Aflo a4S viewer Agency/Office/Phone and Fax Numbers Date Andrew Pitn r AP'�'' ' H P41WR/MRO WQ/704-663-1699 Ext.2180/ 9/24/2024 F161 FB69A2D84A3.,. EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete. Page# NPDES yr/mo/day Inspection Type NCO081370 I11 12I 24/09/18 117 18 i c i Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary) Page# Permit: NCO081370 Owner -Facility: McLin Creek WWTP Inspection Date: 09/18/2024 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 sewer line construction for the connection of the McLin Creek WWTP to the City of Hickory's sewer system and WWTP (Hickory -Catawba) is ongoing and is currently projected to be completed in 2025. The last compliance evaluation inspection at this facility was performed by DWR staff on 7/29/2021. 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 Permit: NCO081370 Inspection Date: 09/18/2024 Record Keeping Owner -Facility: McLin Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The records reviewed durinq the inspection were orqanized and well maintained. In-depth operation and maintenance records including process control measurements were being documented and maintained on -site. Discharge monitoring reports (eDMRs) were reviewed for the period August 2023 through July 2024. An effluent fecal coliform weekly average limit violation was reported in June 2024. The Division has previously addressed this limit violation through the issuance of a Notice of Violation (NOV)/civil penalty assessment. The ORC and staff must ensure that all flow meter calibrations, generator maintenance activities, system performance annual reports, etc. are maintained for a mininum of three years as required by the subject permit [Permit Condition Reference: Part II, Section D(6) Records Retentionl. 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 and effluent analyses (includinq field) are performed under the City of Hickory's municipal laboratory certification #203. ETT Environmental (toxicity) has also been contracted to provide analytical support. Influent Sampling Yes No NA NE # Is composite sampling flow proportional? 0 ❑ ❑ ❑ Is sample collected above side streams? EIN ❑ ❑ 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 sampling performed according to the permit? 0 ❑ ❑ ❑ Comment: The subiect permit requires influent BOD and TSS composite samples. The sampler's aliquot volume is checked twice per month. A review of the previous sampling event revealed the sampler missed twelve samples. The ORC and staff should investigate and correct the issue causing missed samples. In addition, the ORC and staff must ensure the following: composite samples (influent and effluent) are collected over an entire 24-hr. period, sample container does not overfill and the preset gallon interval between sample collection is fixed at no greater than 1/24 of the total daily flow. Effluent Sampling Yes No NA NE Page# 4 Permit: NCO081370 Inspection Date: 09/18/2024 Effluent Sampling Is composite sampling flow proportional? Is sample collected below all treatment units? Owner -Facility: McLin Creek WWTP Inspection Type: Compliance Evaluation 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)? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ■ ❑ ❑ Comment: The subject permit requires composite and qrab effluent samples. The sampler's aliquot volume is checked twice per month. A review of the composite sampler's previous sampling event revealed the sampler only collected samples for approximately 16 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). 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 0 ❑ ❑ ❑ Solids, pH, DO, Sludge Judge, and other that are applicable? Comment: The wastewater treatment facility appeared to be properly operated and well The WWTP experiences larae suraes of influent flows from a local industry that interferes with the facility's operations (flooding of tertiary filters). City personnel must identify the industry and incorporate the appropriate corrective actions (local limits, education, etc.) to prevent these future slug flows and associated disruptions of plant operations as required by the subject permit. Bar Screens Yes No NA NE Type of bar screen a.Manual ❑ b.Mechanical Are the bars adequately screening debris? ■ ❑ ❑ ❑ Is the screen free of excessive debris? 0 ❑ ❑ ❑ Is disposal of screening in compliance? 0 ❑ ❑ ❑ Page# 5 Permit: NCO081370 Inspection Date: 09/18/2024 Bar Screens Is the unit in good condition? Owner -Facility: McLin Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE ❑ ■ ❑ ❑ Comment: Two metal bracket/support guides for the chain assembly were severely rusted and deteriorated. Screenings 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 twice per year and was last calibrated on 7/16/2024 by Diversified Integration. Pump Station - Influent 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? Yes No NA NE • ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ■ ❑ ❑ ■ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ❑ ❑ ■ Comment: Two of three influent pumps were operational. The inoperable pump is in the process of being removed for repairs. The telemetry type alarm system for high water and loss of power were not operational. The alarm system must be repaired as soon as possible. Please be advised that the permittee must ensure that the treatment facility is properly operated and maintained at all times [Part II, Section C(2) Operation and Maintenance]. Sequencing Batch Reactors Type of operation: Is the reactor effluent free of solids? Does minimum fill time correspond to the peak hour flow rate of the facility? Is aeration and mixing cycled on and off during fill? The operator understands and can explain the process? Comment: Both SBR trains were operational and in service. Aeration Basins Yes No NA NE Duplex ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ Yes No NA NE Page# 6 Permit: NCO081370 Inspection Date: 09/18/2024 Aeration Basins Owner -Facility: McLin Creek WWTP Inspection Type: Compliance Evaluation Mode of operation Type of aeration system 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/1) Yes No NA NE Ext. Air Diffused ■ ❑ ❑ ❑ ❑ ❑ ■ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ ■ ❑ ❑ ❑ Comment: Soda ash is added on an as -needed basis to maintain appropriate alkalinity/pH levels. Filtration (High Rate Tertiary) Yes No NA NE Type of operation: Down 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: All three tertiary filters were operational and in service. 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 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? Page# 7 Permit: NC0081370 Inspection Date: 09/18/2024 Disinfection -Gas Owner -Facility: McLin Creek WWTP Inspection Type: Compliance Evaluation Yes No NA NE Comment: The facility is equipped with two chlorine contact chamber trains: however, only one train was in service due to low influent flows. 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? Are the tablets the proper size and type? Yes No NA NE Gas ■ ❑ ❑ ❑ • ❑ ❑ ❑ • ❑ ❑ ❑ ❑ ❑ ■ ❑ Comment: The chlorination and dechlorination systems are serviced annually (at a minimum) by a contracted company. Are tablet de -chlorinators operational? ❑ ❑ ❑ Number of tubes in use? Comment: 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? ❑ ❑ ■ ❑ Comment: The effluent appeared clear with no floatable solids or foam. The receiving stream did not appear to be negatively impacted. Aerobic Digester Yes No NA NE Is the capacity adequate? 0 ❑ ❑ ❑ Is the mixing adequate? 0 ❑ ❑ ❑ Is the site free of excessive foaming in the tank? 0 ❑ ❑ ❑ # Is the odor acceptable? ■ ❑ ❑ ❑ # Is tankage available for properly waste sludge? 0 ❑ ❑ ❑ Comment: Each SBR train is equipped with an aerobic digester (both operation and in service). City of Hickory staff transport digested solids to the Hickory Regional Compost Facility for continued treatment/disposal (Class A product). Standby Power Yes No NA NE Is automatically activated standby power available? 0 ❑ ❑ ❑ Is the generator tested by interrupting primary power source? 0 ❑ ❑ ❑ Page# 8 Permit: NC0081370 Owner -Facility: McLin Creek WWTP Inspection Date: 09/18/2024 Inspection Type: Compliance Evaluation Standby Power Yes No NA NE Is the generator tested under load? 0 ❑ ❑ ❑ Was generator tested & operational during the inspection? 0 ❑ ❑ ❑ Do the generator(s) have adequate capacity to operate the entire wastewater site? ❑ N ❑ ❑ Is there an emergency agreement with a fuel vendor for extended run on back-up M ❑ ❑ ❑ power? Is the generator fuel level monitored? 0 ❑ ❑ ❑ Comment: The facility is equipped with a backup generator that only provides power to the influent pump station. The backup generator is tested (not under load) monthly and serviced annually by a contracted company. Page# 9